IR 05000237/2021002

Integrated Inspection Report 05000237/2021002 and 05000249/2021002

ML21216A199
Person / Time
Site:	Dresden
Issue date:	08/09/2021
From:	Kenneth Riemer NRC/RGN-III/DRP/B1
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
References
IR 2021002
Download: ML21216A199 (27)

Text

August 9, 2021

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000237/2021002 AND 05000249/2021002

Dear Mr. Rhoades:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Nuclear Power Station, Units 2 and 3. On July 7, 2021, 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. 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 violation or the significance or severity of the violation 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, Signed by Riemer, Kenneth on 08/09/21 Kenneth R. Riemer, 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: 05000237/2021002 and 05000249/2021002 Enterprise Identifier: I-2021-002-0087 Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Units 2 and 3 Location: Morris, IL Inspection Dates: April 01, 2021 to June 30, 2021 Inspectors: M. Domke, Resident Inspector G. Edwards, Health Physicist A. Nguyen, Senior Resident Inspector M. Porfirio, Illinois Emergency Management Agency G. Roach, Senior Operations Engineer L. Rodriguez, Project Engineer Approved By: Kenneth R. Riemer, 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 Prevent Water from Entering the Safety-Related Differential Pressure Switch, dPIS 2-0261-35E Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71152 Systems NCV 05000237,05000249/2021002-01 Resolution Open/Closed A self-revealed Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, was identified for the failure to prevent water from entering the safety-related differential pressure switch, dPIS 2-0261-35E, that resulted in it failing to function during surveillance testing on April 14, 2021. Specifically, the licensee failed to correct known water intrusion onto the Unit 2 A reactor recirculation pump differential pressure switch, 2-0261-35E, from the Unit 2 East ECCS corner room cooler, which wetted the switch and caused internal corrosion and material deposits that prevented it from operating as designed (inoperable).

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On May 11, 2021, the unit was taken off-line for forced outage, D2F60, to affect repairs to damaged cables related to the 2A and 2B reactor recirculation system. The unit commenced startup on May 16, 2021 and synched to the grid on May 17, 2021, exiting the forced outage, and reaching full thermal power later that day. Unit 2 remained at or near rated thermal power for the remainder of the inspection period.

Unit 3 began the inspection period at rated thermal power. On May 26, 2021, the unit commenced an emergency downpower to approximately 37 percent power to repair a leaking air line in the drywell related to the 'A' inboard Main Steam Isolation Valve. The unit returned to full rated thermal power on May 28, 2021 and remained at or near rated thermal 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated summer readiness for seasonal extreme weather conditions prior to the onset of hot temperatures for the following systems:

Auxiliary electrical equipment and battery rooms HVAC, ultimate heat sink, and the emergency diesel generators on May 25, 2021

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 3 emergency diesel generator (EDG) post-maintenance alignment on April 22, 2021

(2) Unit 2 shutdown cooling system during forced outage (D2F60) on May 12, 2021

(3) 2/3 EDG alignment during automatic voltage regulator (AVR) troubleshooting on May 19, 2021

(4) Reactor building closed cooling water (RBCCW) alignment during AVR troubleshooting on May 19, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) FZ 8.2.6.C, Unit 2/3 lube oil reservoir area, elevation 534' and compensatory measures for fire hose stations out of service for fire piping replacement on April 26, 2021

(2) Unit 2/3 crib house deluge out of service compensatory measures including fire watch observation on May 4, 2021

(3) Compensatory measures for out of service fire protection equipment on Unit 2 during repairs in D2F60 on May 13, 2021

(4) FZ 1.1.2.1, Unit 2 torus basement and torus catwalk, elevation 476' on June 7, 2021

(5) FZ 8.2.5.A, Unit 2 switchgear and motor control center (MCC) elevation 517', Unit 2 trackway 517', Unit 2 condensate transfer pumps/hallway elevation 517', Unit 2 reactor feed pumps elevation 517' on June 8, 2021

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam and comprehensive written exam administered to all licensed operators in May and June 2021

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on May 27, 2021 Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46 Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room for Unit 2 shutdown and startup activities during D2F60 on May 11, 2021 and May 16, 2021

(2) The inspectors observed and evaluated licensed operator performance in the control room during the Unit 3 emergency downpower and subsequent power ascension due to a partially closed main steam isolation valve (MSIV) on May 27, 2021

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operators during a crew performance evaluation scenario in the main control room simulator on April 13, 2021

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Auxiliary electrical equipment room (AEER) HVAC system

(2) 2B reactor recirculation pump trip on June 14, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 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) Elevated plant risk for various work windows for work week April 26, 2021 through April 30, 2021

(2) Dry fuel storage campaign activities that involved elevated risk, multiple weeks in April through May 2021

(3) Emergent troubleshooting and elevated risk due to 2A recirculation pump automatic speed drive (ASD) ground fault throughout the second quarter 2021

(4) Emergent troubleshooting and elevated risk due to AVR not responding to voltage adjustments on May 19, 2021

(5) Unit 2 shutdown safety during D2F60 from May 11, 2021 through May 15, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Historic operability review of the Unit 2 low pressure coolant injection (LPCI) loop select differential pressure switch (dPIS 2-0261-35E) that failed during surveillance testing

(2) Unit 2 rod block monitor (RBM) quad trip card failure

(3) Degraded ventilation seal identified on the Unit 2/3 EDG

(4) Trip of the Unit 2 high pressure coolant injection (HPCI) pump during quarterly surveillance

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Temporary modification for new 2B recirculation pump motor ASD input cables on May 18, 2021

(2) Permanent modification to replace the 2A recirculation pump motor ASD input cable on May 18, 2021

(3) Unit 3 'A' MSIV air line permanent repair on June 10, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) DOS 6600-01, Unit 3 emergency diesel generator post-maintenance test on April 22, 2021

(2) Unit 2 reactor recirculation pump cable replacements per work orders (WO)

(3) Unit 2 intermediate range monitor (IRM) 13 repair on May 14, 2021

(4) Unit 2/3 'A' standby gas treatment (SBGT) cable replacement

(5) Unit 3 component cooling service water (CCSW) vault check valve, 3-4999-75, replacement per WO 1617519

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the Unit 2 forced outage, D2F60, from May 11, 2021 through May 16, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) DIS 1500-32, Unit 2 Division I LPCI ECCS Loop Selection Circuitry Logic System Function Test on April 14, 2021

(2) DOS 660-08, emergency diesel generator cooling water (EDGCW) pump quarterly and comprehensive in-service test on June 9, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) DOS 1400-05, Unit 2 core spray (CS) system comprehensive pump test with torus available (IST) on April 27, 2021

FLEX Testing (IP Section 03.02) (1 Sample)

(1) DOS 0010-50, diesel driven FLEX equipment surveillances on May 25, 2021

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(2 Samples)

(1) Second quarter 2021 Dresden focus area emergency preparedness drill on May 6, 2021

(2) Dresden off-year emergency preparedness exercise on June 15,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (3 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) Unit 2/3, advanced liquid processing system (ALPS)

(2) Unit 2/3, turbine building ventilation system discharge to main plant vent chimney

(3) Unit 2/3, service water monitor

Sampling and Analysis (IP Section 03.02) (3 Samples)

(1) Inspectors evaluated effluent samples from the Unit 2/3 chimney exhaust

(2) Inspectors evaluated effluent samples from Unit 2/3 reactor building vent

(3) Inspectors evaluated effluent samples from the low-pressure coolant injection heat exchangers

Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1) Gaseous release discharge permit from Unit 2/3 chimney in January 2021

(2) Gaseous release discharge permit from Unit 2/3 reactor building in February 2021

Abnormal Discharges (IP Section 03.04) (1 Sample)

The inspectors evaluated the following abnormal discharges:

(1) Groundwater from the west tritium remediation well which is monitored via the Unit 2/3 discharge tunnel

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,

& Transportation

Radioactive Material Storage (IP Section 03.01)

(1) Inspectors evaluated the licensees performance in controlling, labelling, and securing radioactive materials. This included the radioactive waste storage portion of the facility.

Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

(1) Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

(1) The inspectors evaluated the licensees characterization and classification of radioactive waste. This included the condensate resin waste stream at the facility.

(2) The inspectors evaluated the licensees characterization and classification of radioactive waste. This included the dry activated waste (DAW) stream at the facility.

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed that a shipment containing radioactive material was prepared according to requirements. The shipment identification number was DW-21-011 for an LSA-II shipment of bead resin from the spent fuel pool.

Shipping Records (IP Section 03.05) (3 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Shipment DW-21-011 for an LSA-II shipment of bead resin from the spent fuel pool

(2) Shipment DW-20-001 for an LSA-II shipment of condensate resin pre-filters

(3) Shipment DW-20-026 for an LSA-II shipment of Unit 2/3 dry activated waste (DAW)

OTHER ACTIVITIES - BASELINE

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

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) Unit 2 (April 1, 2020 through March 31, 2021)

(2) Unit 3 (April 1, 2020 through March 31, 2021)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 2 (April 1, 2020 through March 31, 2021)

(2) Unit 3 (April 1, 2020 through March 31, 2021)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in water leakage and safety related SSCs that might be indicative of a more significant safety issue.

Annual Follow-Up of Selected Issues (IP Section 02.03) (3 Samples)

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

(1) Multiple failures and out of tolerance surveillance tests due to water intrusion for the Unit 2 and 3 LPCI loop selection logic differential pressure switches

(2) Leak-by on the Unit 3 'D' CCSW discharge check valve

(3) Deficiencies identified in implementation of the scaffold control program

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

(1) The inspectors evaluated a trip of the Unit 2 'B' reactor recirculation pump and the licensees response to operating in Single Loop Operations from May 8, 2021 through May 10, 2021

(2) The inspectors evaluated the Unit 3 AVR going into discharge mode (locking out) and the licensee's response to this issue from May 18, 2021 through May 20,

INSPECTION RESULTS

Failure to Prevent Water from Entering the Safety-Related Differential Pressure Switch, dPIS 2-0261-35E Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71152 Systems NCV 05000237,05000249/2021002-01 Resolution Open/Closed A self-revealed Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, was identified for the failure to prevent water from entering the safety-related differential pressure switch, dPIS 2-0261-35E, that resulted in it failing to function during surveillance testing on April 14, 2021. Specifically, the licensee failed to correct known water intrusion onto the Unit 2 A reactor recirculation pump differential pressure switch, 2-0261-35E, from the Unit 2 East ECCS corner room cooler, which wetted the switch and caused internal corrosion and material deposits that prevented it from operating as designed (inoperable).

Description:

On April 14, 2021, during performance of DIS 1500-32, Division I Low Pressure Coolant Injection ECCS Loop Selection Circuitry Logic System Functional Test, LPCI loop select logic relay, 2-1530-271, failed to drop out when required. Investigation into this condition revealed that dPIS 2-0261-35E, the Unit 2 A reactor recirculating pump differential pressure switch, failed to drop out (return to its original state) during the surveillance test. The licensee was already in the applicable technical specification (TS) limiting condition for operation (LCO), 3.3.5.1, due to the surveillance test. This is a 24-hour action statement. The licensee replaced the switch and exited the LCO the next day. It was determined that the switch failed due to moisture intrusion causing corrosion deposits to form and affect the switch operation.

The moisture came from leakage from the Unit 2 room cooler which is directly above the instrument rack where this switch (and three others for this division of logic) are mounted. A historical operability evaluation was completed under AR 4423697 which determined that even though the dPIS was not functional, there was no loss of safety function for the LPCI system Division I loop select logic since there were three other switches that provided redundant design functions to this switch. These switches successfully passed the surveillance test. The last successful completion of the quarterly functional surveillance test for dPIS 2-0261-35E was on March 15, 2021.

The inspectors reviewed the corrective action program (CAP) history of dPIS 2-0261-35E and noted multiple action requests, beginning in October 2015, that documented moisture intrusion related to this safety-related switch. In October 2015 and May 2017, during quarterly functional testing, moisture and mineral deposits were found inside this switch. In both cases, the switch met the Technical Specification requirements of the test and the internals were cleaned to remove the moisture/deposits. Also, in both instances, water was noted to be dripping from the room cooler above the instrument rack and varying catch container configurations were arranged to divert the leakage away from the rack. Leakage from this room cooler had been documented in CAP since at least 2008. The work order to replace the internal cooling coil (the ultimate fix) is still open (currently scheduled for the 2021 refueling outage if it occurs).

The inspectors also reviewed the CAP for instances of moisture intrusion into the other switches (dPISs 2-0261-35A/C/G) on this rack on Unit 2 and the same instrumentation rack on Unit 3. The configuration for the Unit 3 East ECCS corner room is the same as Unit 2, which is the room cooler directly above the instrument rack where dPISs 3-0261-35A/C/E/G are located. For Unit 2, the A switch had two instances (2015 and 2018) where it was identified as being out of tolerance for the testing criteria. This switch has not been replaced and no work has been done on it. The C switch had one instance of being found out of tolerance (2020) and it was replaced with a new model of Barton switch. This switch was found to have moisture intrusion that caused internal corrosion (ARs 4367045 and 4400499).

On Unit 3, dPIS 3-0261-35C was determined to be non-functional when it failed to change state during the logic system functional test in September 2019. A corrective action program evaluation (CAPE) was completed for this failure and determined that the Unit 3 East corner room cooler leaked onto this switch, causing internal moisture buildup and degradation of the switch, eventually leading to its failure. Corrective actions from this event included replacing the switch with a newer model Barton switch which was determined to be less susceptible to water intrusion (better seal) and correcting the leakage from the Unit 3 room cooler, which was accomplished in April 2021 by replacing the cooler coil. Engineering Changes (ECs)were initiated for all older Barton switches (the four per unit listed above as well as four more per unit that are on racks not located under the room coolers) to change them out to the newer models. These ECs were never scheduled for work but rather were coded as contingencies if a switch were to fail (see example above on 2-0261-35C). No actions were taken as extent-of-condition to address the leakage on the Unit 2 room cooler.

As part of their in-depth review, the inspectors reviewed the design documentation related to the dPISs to determine the appropriate operating environment. The licensees Environmental Qualification document showed that these switches were not designed to be used in wet environments. This was supported by the licensees proposed corrective actions from the 2019 event to replace the old-style switch with a newer model that was less susceptible to water intrusion. Based on this information, it was reasonable to conclude that these switches were not anticipated to be subjected to wet conditions, and that the licensee failed to correct this condition in a prompt manner when it occurred.

Corrective Actions: The licensee replaced dPIS 2-0261-35E on April 15, 2021, with the newer style Barton switch. The licensee also generated ARs 4418395 and 4418398 for the extent of condition replacement of dPISs 2-0261-35A and 2-0261-35G with the newer style Barton switch. Repairs to the Unit 2 East ECCS corner room cooler are scheduled for D2R27 in November 2021 Corrective Action References: AR 4416605, DIS 1500-32: Relay 2-1530-271 Not Dropped Out

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee failed to prevent water from entering the safety-related differential pressure switch, dPIS 2-0261-35E, as required by 10 CFR 50 Appendix B, Criterion III, that resulted in it failing to function during surveillance testing on April 14, 2021.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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. Specifically, failure to prevent moisture intrusion into this switch resulted in its inoperability and failure to perform its design function.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the issue using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, and determined that this finding was of very low safety significance, or Green, since it did not represent the loss of the PRA function of any TS train of equipment or system. The Unit 2 Division I LPCI Loop Selection function was still maintained by the three other differential pressure switches that passed the surveillance test.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensee had multiple opportunities to take appropriate actions to correct identified moisture intrusion into the differential pressure switches from the unit corner room coolers to ensure continued operability of these safety-related components. The licensee did not properly resolve moisture intrusion and degradation of the 2-0261-35E switch when identified during TS surveillance testing in 2015 and 2017. Also, the 2019 CAPE for failure of the 3-0261-35C switch did not perform a thorough extent of condition evaluation to address leakage from the Unit 2 East ECCS corner room cooler or appropriately prioritize actions to address the moisture intrusion into the other dPISs.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, requires, in part, that 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 October 30, 2015 to April 14, 2021, corrective action program documentation has shown that water intrusion has occurred into the Unit 2 A reactor recirculation pump differential pressure switch (dPIS), 2-0261-35E, from the Unit 2 East ECCS corner room cooler. This eventually resulted in the inoperability of the dPIS when it failed to function due to internal corrosion and material deposits buildup during surveillance testing on April 14, 2021.

Design documentation review identified that these switches were not designed to be in wetted environments. Corrective action program documentation review found that this issue was previously identified by the licensee and corrective actions were not promptly taken to appropriately resolve the issue as an extent of condition action from prior failures.

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

Observation: NRC-Identified Trend for Water Leaks Causing Failure, 71152 Degradation, or Abnormal Manipulation of Components The inspectors performed a semiannual review of issues entered into the corrective action program (CAP) and a cognitive review of plant walkdown observations over the period of January 1, 2021 to June 30, 2021, to identify any potential trends that might indicate the existence of a more significant safety issue. Based on these reviews, the inspectors concluded that there was a negative trend in the licensee addressing water leakage onto components that resulted in their failure, degradation, or abnormal manipulation. Specifically, there were a number of issues where safety-related and important to safety equipment needed to be emergently removed from service or manipulated in a manner outside its normal operational state to prevent adverse consequences from water intrusion. Also, some examples were identified where plant personnel needed to take prompt actions to prevent unanticipated water intrusion onto equipment. Finally, some of these examples required prompt determinations that the components could still perform their design and/or safety functions. Examples of these issues, and their associated CAP documents, are listed below:

IR 4244414, Unexpected Alarm in Main Control Room due to Unit 3 HPCI Minimum Flow Valve Opening, IR 4412599, Degraded Piping off of the Unit 2 ECCS Jockey Pump, IR 4395944, Leak onto 2A CRD Pump from Fire Header Leak, IR 4393484, Excessive In-Leakage onto 3C Circulating Water Pump MOV, IR 4352983, Corrosion on TBCCW Supply to Unit 2 Circulating Water Pumps, IR 4335087, Conduit Rusted for Cabling into the 2202-19A Rack, IR 4324368, Operations to Evaluate Disabling HPCI Fire Protection Pre-Action System, and Issues with Leakage from the ECCS Corner Room Coolers onto the LPCI dPIS Racks (NCV 05000237,05000249/2021002-01)

Through their review of the associated CAP documentation and by performing independent walkdowns, the residents determined that the impact of water leakage was not always thoroughly and rigorously evaluated. Sometimes the scope of evaluation of the issue was narrowly focused on the immediate impact to the system that had the leak and not necessarily on equipment/components in the surrounding area that were impacted (or potentially impacted) by water from the leak. Also, it was noted that some leaks have existed for a prolonged period of time. The cumulative impact of water intrusion onto components from these leaks has not been fully evaluated. The residents also questioned the promptness of resolution of some of these issues. This is especially evident lately as some of the items have led to more safety significant issues. The residents discussed these observations with the licensee, and they are revising their action plan to address water leakage.

Observation: Scaffolding Program Procedure Use 71152 The inspectors performed a semiannual review of issues entered into the corrective action program (CAP) and a cognitive review of plant walkdown observations over the period of January 1, 2021 to June 30, 2021, to identify any potential trends that might indicate the existence of a more significant safety issue. Based on these reviews, the inspectors concluded that there was a negative trend in the licensee addressing scaffolding installation, inspection, modification, and removal processes. Specifically, scaffolding status logs maintained by coordination personnel did not accurately reflect scaffolding erected within the plant. Contractor-erected scaffold logs were not shared with permanent scaffold coordinators because, according to interviews, the contractor logs were considered proprietary as they contained sensitive billing rate information. Interviews also indicated the contractor-to-station turnover of scaffolding status was controlled by action request generation, but documentation reviews for the retrieved instances of this turnover stemmed from refueling outage periods and not, for example, forced outage periods where contractors also constructed scaffolding.

Inspector field assessments and document reviews revealed instances of scaffolding unaccounted for by logs or instances of misclassified permanent scaffolds as temporary.

Inspectors identified various instances of non-permanent scaffolds left in-plant after scheduled work was completed which conflicts with procedure guidance.

Scaffolding program adherence observations indicate issues are administrative. Field assessments did not reveal any instances of improper bracing to SSC or seismic-related concerns, fire protection or safe-shutdown impairments, or impedance for SSC to perform their design functions. The station is tracking completion of scaffolding observations by AR

EXIT MEETINGS AND DEBRIEFS

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

On July 7, 2021, the inspectors presented the integrated inspection results to Mr. P. Karaba, Site Vice President, and other members of the licensee staff.

On June 2, 2021, the inspectors presented the Biennial Licensed Operator requalification inspection exit meeting inspection results to Mr. P. Karaba, Site Vice President, and other members of the licensee staff.

On June 11, 2021, the inspectors presented the Radiation Protection inspection results to Mr. P. Boyle, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 4425411 Transformer 27 Temporary Oil Repair on Southeast Cooling 05/24/2021

Documents Banks Degraded

26433 Cottonwood Buildup on Transformer 3 05/29/2021

27803 Elevated Transformer 3 Oil Temps due to Buildup on Oil 06/06/2021

Coolers

27804 Transformer 81 Minor Trouble Alarm and Cooler Fail Alarm 06/06/2021

29043 Unit 3 Battery Room High Temperature 06/12/2021

29545 Cottonwood and Dust Accumulation for AEER HVAC System 06/15/2021

4430433 DOA 0010-02 Entry 06/20/2021

Procedures DOA 0010-02 Tornado Warning/Severe Winds 25

DOP 4450-08 Dresden Cooling Lake Operation 35

OP-AA-108-107- Station Response to Grid Capacity Conditions 08

1001

OP-DR-108-111- Hot Weather Strategy 07

1001

71111.04 Procedures DOP 1000-E1 Unit 2 Shutdown Cooling Electrical 03

DOP 6600-E1 Unit 3 Standby Diesel Generator 07

71111.05 Corrective Action 4428453 IEMA Identified Issue with High Rise Pack Implementation 06/09/2021

Documents

Fire Plans 138 U2TB-41 FZ 8.2.5A Unit 2 High Pressure Heaters/Steam Lines 03

Elevation 517'

139 U2TB-42 FZ 8.2.5A Unit 2 Reactor Feed Pumps Elevation 517' 02

141 U2T-44 FZ 8.2.5A Unit 2 Condensate Transfer Pumps/Hallway 02

Elevation 517'

2 U2TB-45 FZ 8.2.5A Unit 2 Trackway Area Elevation 517' 04

144 U2TB-47 FZ 8.2.5A Unit 2 Switchgear & MCC Elevation 517' 04

FZ 1.1.2.1 Unit 2 Torus Basement and Torus Catwalk, Elev. 476' 04

FZ 8.2.6.C Unit 2/3 Lube Oil Reservoir Area, Elev. 534 03

Miscellaneous Fire Impairment Fire Protection Out of Service, Turbine Building 05/11/2021

21-056

71111.11B Corrective Action IR 04268169 NRC Questions in MCR Simulator During NRC EP Exercise 07/30/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents IR 04286723 NOS ID: Active License Holder Did Not Sign Reactivation 10/10/2019

Log

IR 04297448 NRC Question on Continuing to Run Recirc During Mode 2 11/14/2019

IR 04339885 4.0 Critique - U2 Restoration from Single Loop Operation 04/30/2020

IR 04394393 Ops Crew 3 Clock Reset 01/07/2021

IR 04412353 TRNG: NRC Pre-71111.11 Inspection Report Findings 03/29/2021

IR 04421965 LORT DEP Failure on Declaration 05/06/2021

Engineering EC 627506 Hydrogen Cooler Temperature Controller Replacement in 09/10/2020

Changes Simulator

EC 631456 Time Delays on 902-4 G3 and G7 Annunciators in Simulator 05/18/2020

Miscellaneous 2019 NRC Comprehensive Biennial Written Examination - 05/01/2019

RO Week 1

2018-2021 Watch Standing Records for Crew 3 05/24/2021

D2C27 Core Load Test 12/13/2019

2019 LORT Training Attendance Records 12/31/2019

20 LORT Training Attendance Records 12/31/2020

21 LORT Training Attendance Records 03/31/2021

Individual SRO Accelerated Requalification Plan 01/01/2021

21 Comprehensive NRC Written Exam - RO Week 5 05/27/2021

21 Comprehensive NRC Biennial Written Examination - 05/27/2021

SRO Week 5

2019 Comprehensive NRC Biennial Written Examination - 05/01/2019

SRO Week 1

2019 LORT NRC Exam Week 6 - RO - Completed RO 05/09/2019

Written Exam for Individual

2019 LORT NRC Exam Week 6 - RO - Completed Written 05/23/2019

Exam Retake for Individual

00701597 Dresden Training Simulator Cycle 27 Core Update 08/29/2019

Biennial Physical Medical Records Review for 6 Licensed Operators 05/25/2021

Examination and

SRO/RO Medical

Records

OPEX-AW Simulator Exercise Guide 5

Inspection Type Designation Description or Title Revision or

Procedure Date

OPEX-I Simulator Exercise Guide 13

OPEX-O Simulator Exercise Guide 13

OPEX-P Simulator Exercise Guide 14

P2-1100-03 In Plant JPM 15

P2-6400-01 In Plant JPM 3

P2-6600-02 In Plant JPM 15

P3-0202-1 In Plant JPM 16

S-0700-13 Simulator JPM 4

S-1300-04 Simulator JPM 2

S-2300-07 Simulator JPM 4

S-5370-01 Simulator JPM 0

S-AR-03 Admin JPM 3

S-EP-22 Admin JPM 6

S-RD-01 Admin JPM 3

Scenario Based 2019 NRC Graded Emergency Preparedness Exercise 05/08/2019

Testing

Scenario Based Simulator Dynamic Scenario LORT NRC Annual Operating 03/30/2020

Testing Test - OPEX AS

TA-AA-155-F05 Simulator Evaluation Form for Crew - Crew 3 AM - LORT 05/26/2021

CYCLE 2019-2021 Cycle 11

TQ-AA-150-F03A RE-EVALUATION: JPM Evaluation Results 05/24/2019

TQ-AA-150-F03A JPM Evaluation Results 05/10/2019

TQ-AA-155-F04 Simulator Evaluation Form for Individuals - Crew 3 AM - 05/26/2021

LORT Cycle 2019-2021 Cycle 11

TQ-AA-155-F04 Simulator Evaluation Forms for Individuals - Crew 3 PM - 05/26/2021

LORT Cycle 2019-2021 Cycle 11

TQ-AA-155-F05 Simulator Evaluation Form for Crew - Crew 3 PM - LORT 05/26/2021

Cycle 2019-2021 Cycle 11

TQ-AA-224-F090 Failure of NRC Biennial Written Examination 05/12/2021

TQ-AA-224-F090 Performance Review Committee Data Sheet - LORT 05/16/2019

Biennial Written and Annual JPM Exam Failure - 2019

LORT NRC Exam/JPMs Week 4 - RO

Inspection Type Designation Description or Title Revision or

Procedure Date

TQ-AA-224-F100 Remedial Training Notification and Action on Failure for an 05/09/2019

Individual - 2019 LORT NRC Exam/JPMs Week 4 - RO

TQ-AA-224-F100 Remedial Training Notification and Action on Failure 05/09/2019

TQ-AA-306-F-02 Simulator Review Board Minutes 12/31/2019

TQ-AA-306-F-02 Simulator Review Board Minutes 03/27/2020

TQ-AA-306-F-02 Simulator Review Board Minutes 07/10/2020

TQ-AA-306-F-02 Simulator Review Board Minutes 03/12/2021

TQ-AA-306-F-02 Simulator Review Board Minutes 09/05/2020

TQ-AA-306-F-03 Steady State Testing for D2C27 04/29/2020

TQ-AA-306-F-03 Transient Testing for D2C27 04/29/2020

Self-Assessments IR 4301168 Pre-NRC 71111.11 Licensed Operator Requalification 02/27/2020

Program and Licensed Operator Performance

IR 4403204-02 Pre-NRC 71111.11 Licensed Operator Requalification 04/08/2021

Program and Licensed Operator Performance

NOSA-DRE-19- Operations Functional Area Audit Report 10/16/2019

NOSA-DRE-20- Training and Staffing Audit Report 06/10/2020

Work Orders SWR 0135166 2A Reg. Valve Reset Pushbutton Does Not Consistently 04/15/2019

Work

SWR 0135178 Recorder Clear 04/18/2019

SWR 0135422 Drywell Pressure Response During High Torus/Drywell 07/30/2019

Temperatures

SWR 0135455 ASD Fault Reset is Not Modeled Correctly 08/14/2019

SWR 0136184 SRM Indication Discrepancy 06/19/2020

SWR 0136211 SBLC Computer Switch Command Does Not Work Properly 06/29/2020

SWR 136372 Fuel Pool Cooling Pump Trip Intermittent 08/28/2020

SWR 136769 Electrical Overcurrent Malfunctions 02/13/2021

71111.11Q Corrective Action 4423096 LPRM 16-41 'C' Downscale Light 05/11/2021

Documents 4427175 D2F60 Operations Startup Critique 05/16/2021

71111.12 Corrective Action 4351928 2/3 'B' AEER A/C Compressor Trip 06/22/2020

Documents 4357050 AEER Air Conditioner Compressor Trip 07/16/2020

4392247 AEER Air Conditioner Compressor Trip 12/27/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

4394945 2/3-57214B-B, AEER A/C RCU Compressor 'B' Tripped 01/09/2021

4399725 2/3-57214B-B, AEER A/C RCU Compressor 'B' Tripped 02/02/2021

4400863 AEER HVAC Compressor Trip 02/07/2021

4410467 AEER HVAC Compressor Trip 03/21/2021

4411622 Trend IR: 'B' AEER HVAC Compressor Trips 03/25/2021

4411622 Trend IR: 'B' AEER HVAC Compressor Trips 03/25/2021

22420 2B Reactor Recirc Pump Trip 05/08/2021

Engineering (a)(1) Determination Evaluation for Maintenance Rule 00

Evaluations Function 5714

71111.13 Corrective Action 4413041 2A Recirculation Drive Minor Trouble 03/31/2021

Documents 4414920 2A Recirculation Drive Minor Trouble Alarm 04/08/2021

4416293 2A Recirc Drive Minor Trouble 04/14/2021

4417425 2A Recirc Drive Minor Trouble 04/18/2021

21564 Unexpected Alarm 902-4 B-1, 2A Recirculation Drive Minor 05/04/2021

Trouble

Operability DRE-2-2021- Operational Decision Matrix for 2A ASD Output Ground 01

Evaluations 0108 Voltage

Procedures DFP 0800-69 Hi-TRAC Movement Within the Unit 2/3 Reactor Building 42

DFP 0800-74 Helium Cooldown System Operation and MPC Reflood 06

DMP 5800-18 Load Handling of Heavy Loads and Lifting Devices 31

OP-AA-108-117 Protected Equipment Lists for Various On-Line Plant 04/01/2021 -

Configurations 06/31/2021

OP-AA-108-117 Protected Equipment Lists for Shutdown Safety, D2F60 05/11/2021 -

05/15/2021

OU-DR-104 Shutdown Safety Management Program 23

WC-DR-104-1001 Dresden 345kV Switchyard Configuration Risk Assessment 08

71111.15 Corrective Action 4415618 No Light Indication for LPRM 2-0756-501L Detector 'C' when 04/10/2021

Documents Bypassed

4418952 Unit 2 RBM 7 Power Pot would not go to 0V DC 04/26/2021

23697 Historical Operability Evaluation for DPIS 2-0261-35E 05/14/2021

25527 Sealant Around 2/3 EDG Vent Requires Replacement 05/25/2021

4430004 HPCI Trip during Quarterly Surveillance 06/17/2021

4430857 DW Temps TE 3-5741-12A and TE 3-1053-B above EQ 06/22/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Limits

Drawings M-26, Sheet 2 Diagram of Nuclear Boiler and Reactor Recirculating Piping KV

Procedures DIS 0700-08 Rod Block Monitor Calibration Test 45

DTS 1600-38 Drywell EQ Temperature Monitoring 06

71111.18 Engineering 634272 2A Reactor Recirc Motor ASD Output Cables 00

Changes TCCP 634252 TCCP for 2B Reactor Recirc Motor ASD Input Cables 00

71111.19 Corrective Action 4423001 IRM 13 Failed 05/11/2021

Documents 4423863 Unexpected Alarm: 902-4 E-5, 2A Recirculation Pump 05/16/2021

Temperature High

23961 IRM 13 Off-Scale High 05/16/2021

Work Orders 05141167-28 EM & Vendor Cable Testing 22269, 22272, 22277, 22253 05/16/2021

05141167-50 CE Install Replacement Cable 20502 per EC 634272 05/15/2021

05141167-68 CE Repairs of Damaged Cable Jackets in Trays 05/15/2021

05141167-72 EM Tan Delta Testing Replacement Cable 2A ASD CA20502 05/15/2021

05150956-01 EWP EMD Perform Megger Test of 2B Reactor Recirculation 05/16/2021

Pump 4kV Feed Cables

05150956-05 EWP EM Vendor Cable Diagnostics 05/10/2021

5115618 IRM 13 Failed Upscale 05/14/2021

71111.20 Corrective Action 4423129 Unexpected Alarms due to IRM 15 Spiking 05/12/2021

Documents 4423174 Extraction MOV 2-3101-A will not go Closed 05/12/2021

23219 Control Valve #1 Servo Cable Replacement Needed 05/12/2021

23221 Control Valve #3 LVDT #1 Cable Replacement Needed 05/12/2021

23222 Control Valve #3 LVDT #2 Cable Replacement Needed 05/12/2021

23223 Control Valve #3 LVDT #3 Cable Replacement Needed 05/12/2021

23240 Unexpected Alarm: 902-8 C-9, Unit 2 125V DC Battery 05/12/2021

Ground

23256 M-13 Unable to Withdraw 05/12/2021

23470 Normal Level Control Valve for 3B2 Heater 05/13/2021

23690 Recommend 345kV Line 1221 Disconnect Repair in D2F60 05/14/2021

23808 Unit 2 Control Valve #2 Servo Output Current Discrepancy 05/15/2021

23815 NRC Question Unit 2 Reactor Recirculation Pump Discharge 05/15/2021

Valve Packing Leaks

23874 Entered DOA 0010-21, High Condensate Pump Discharge 05/16/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Conductivity

71111.22 Corrective Action 4349768 FLEX Diesel Samples Out of Specification 06/11/2020

Documents 4416605 DIS 1500-32: Relay 2-1503-271 Not Dropped Out 04/14/2021

4419492 2B Core Spray Flow Differences Between Edgewise and 04/27/2021

Computer

27252 FLEX Flood Pumps A and B Diesel Fuel Failed Sample 06/02/2021

Testing

Procedures CC-AA-118 Diverse and Flexible Coping Strategies (FLEX), Spent Fuel 06

Pool Instrumentation (SFPI), and Hardened Containment

Vent System (HCVS) Program Document

DIS 1500-32 Division I Low Pressure Coolant Injection ECCS Loop 15

Selection Circuitry Logic System Functional Test

DOS 0010-50 Diesel Driven FLEX Equipment Surveillances 01

DOS 6600-08 Diesel Generator Cooling Water Pump Quarterly and 66

Comprehensive/Preservice Test for Operational Readiness

and In-Service Test Program

Work Orders 457636 Contingency Work Order for Failed dPIS 2-0261-35E 04/15/2021

4917683 Unit 2 Technical Specification Core Spray Comprehensive 04/27/2021

Pump Test with Torus Available

5055953 FLEX Diesel Flood Pump 'A' 05/25/2021

5059261 FLEX Diesel Flood Pump 'B' 05/25/2021

71114.06 Corrective Action 4430890 MCR / Simulator Emergency Preparedness Pre-Exercise 06/22/2021

Documents Lessons Learned

4430897 TSC Lessons Learned from EP Pre-Exercise 06/22/2021

4430899 OSC Lessons Learned from 2021 EP Pre-Exercise 06/22/2021

Miscellaneous Dresden Off-Year Emergency Preparedness Exercise 06/15/2021

71124.06 Corrective Action AR 04356445 Error in 2019 ARERR 07/13/2020

Documents AR 04412896 Unit 3 Area Radiation Monitor Power Supply Issue 03/31/2021

Corrective Action AR 04344598 Typographical Errors Identified in the 2019 ARERR 05/20/2020

Documents

Resulting from

Inspection

Miscellaneous 2020 Annual Radioactive Effluent Release Report (ARERR) 04/2021

2019 Annual Radioactive Effluent Release Report (ARERR) 04/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Dresden 2019 Offsite Dose Calculation Manual (ODCM) 16

Dresden 2019 Offsite Dose Calculation Manual (ODCM) 15

G-20210101-817- Gas Permit Post Release Data 02/01/2021

C

G-20210201-824- Gas Permit Post-Release Data 03/01/2021

C

Procedures CY-AA-130-201 Radiochemistry Quality Control 8

CY-AA-170-210 Potentially Contaminated System Controls Program 2

Self-Assessments AR 04384090 Radioactive Gaseous & Liquid Effluent Treatment IP 03/11/2021

71124.06 Self-Assessment

71124.08 Corrective Action AR 04339867 NOS ID: Two Radwaste Shipments had Identical Shipping 04/30/2020

Documents Numbers

AR 04340168 NOS ID: ARMA 55 Shipping Records Not Sent to Records 05/01/2020

Management for 7 Months

Operability FO-OP-023 Bead Resin/Activated Carbon Dewatering Procedure for 22

Evaluations Duratek 14-215 or Smaller Liners

Procedures RW-AA-100 Process Control Program for Radioactive Wastes 12

Radiation 2020 10 CFR 61 Analysis for Dry Activated Waste 04/29/2021

Surveys 2019 10 CFR 61 Analysis for Condensate Resin 01/12/2021

Self-Assessments AR 04378875-06- Radioactive Solid Waste Processing and Radioactive 05/2021

Material Handling, Storage, and Transportation

Self-Assessment

Shipping Records DW-20-001 Shipment DW-20-001 for an LSA-II Shipment of Condensate 06/08/2020

Resin Pre-Filters

DW-20-026 Shipment DW-20-026 for an LSA-II Shipment of Unit 2/3 Dry 07/15/2020

Activated Waste (DAW)

DW-21-011 Shipment DW-21-011 for an LSA-II Shipment of Bead Resin 06/07/2021

from the Spent Fuel Pool

71151 Corrective Action 4393484 Excessive In-Leakage onto 3C Circulating Water Pump MOV 01/02/2021

Documents

Procedures DR-MSPI-01 Reactor Oversight Process MSPI Basis Document 14

71152 Corrective Action 04404340 3B LPCI HX Tube Side Inlet Pressure Reading 0# 02/24/2021

Documents 2579419 Found Moisture Inside Switch Body 10/30/2015

4007152 Found Mineral Deposits Inside Barton Switch 05/05/2017

Inspection Type Designation Description or Title Revision or

Procedure Date

4133781 DPIS 2-0261-35A Found Out of Tolerance 05/02/2018

4193454 3B RR Pump DP Switch is Grounded 11/09/2018

244414 Unexpected Alarm 903-4 C-22 due to 3-2301-14 Opening 04/29/2019

280928 DPIS will not Trip 09/20/2019

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

24368 Operations Evaluate Disabling HPCI Pre-Action as OWA/OC 03/06/2020

4335087 Conduit Rusted for Cabling into 2202-19A Rack 04/13/2020

4352983 IEMA Walkdown TBCCW 06/26/2020

4367045 Found DPIS 2-0261-35C Out of Tolerance 09/02/2020

4388991 3B LPCI Heat Exchanger Tube Side Pressure Reading 0# 12/09/2020

4389830 U3 LPCI Loop II CCSW Pump D Discharge Test Connection 12/13/2020

Valve Plugged

4395944 Leak on 2A CRD Pump from Fire Header Leak 01/14/2021

4400499 Documenting Failure Analysis of 2A Recirculation Pump 02/05/2021

DPIS

4406791 3D CCSW Discharge Check Valve Inspection 02/26/2021

4412599 Degraded Piping off the 2-1401-4 Jockey Pump 03/30/2021

4418395 EOC Replace 2-0261-35A DPIS 04/22/2021

4418398 EOC Replace 2-0261-35G 04/22/2021

29936 NRC Concerns: Scaffold Program 06/17/2021

Miscellaneous MMD2021 Dresden Scaffold Control Log 06/14/2021

Procedures MA-AA-716-025 Scaffold Installation, Modification, and Removal Request 18

Process

MA-AA-796-024 Scaffold Installation, Inspection, and Removal 12

PI-AA-125 Corrective Action Program (CAP) Procedure 6 and 7

Work Orders 4634412 Unit 3 Open, Clean, and Inspect 3A LPCI Room Cooler Coils 04/16/2021

71153 Corrective Action 4422420 2B Reactor Recirculation Pump Trip 05/08/2021

Documents 4422466 Unit 2 125V DC Ground 05/09/2021

22801 Report of Wisping Smoke from Cable Tray in Unit 2 LPHB 05/11/2021

24306 Unit 3 Generator Voltage Regulator Unresponsive 05/18/2021

Procedures DAN 903-8, C-4 4 kV Bus 33-1 Voltage Degraded 15

DGA-07 Unexpected Reactivity Change 26

DGP 03-01 Power Changes 140

Inspection Type Designation Description or Title Revision or

Procedure Date

DGP 03-03 Single Recirculation Loop Operation 50

DIP 0700-25 APRM Setpoint Adjustments to Enter into Single Loop 17

Operation

DIP 0700-26 Single Recirculation Loop Operation Rod Block Monitor 11

Calibration Test

DOA 0010-10 Fire-Explosion 26

DOA 0202-01 Recirculation Pump Trip 47

DOA 6500-08 Unit 3 4 kV Emergency Bus Degraded Voltage 12

DOS 0202-04 Operators Single Loop Operation Surveillance 17

24