ML17230A273

Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information; Inspection Report 05000237/2017004; 05000249/2017004 (Gfo)

ML17230A273
Person / Time
Site:	Dresden
Issue date:	08/18/2017
From:	O'Dwyer G Division of Reactor Safety III
To:	Bryan Hanson Exelon Generation Co
References
IR 2017004
Download: ML17230A273 (9)

See also: IR 05000237/2017004

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

August 18, 2017

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Co., LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3NOTIFICATION

OF AN NRC TRIENNIAL HEAT SINK PERFORMANCE INSPECTION AND

REQUEST FOR INFORMATION; INSPECTION REPORT 05000237/2017004;

05000249/2017004

Dear Mr. Hanson:

On October 16, 2017, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite

portion of the Triennial Heat Sink Performance Inspection at your Dresden Nuclear Power

Station, Units 2 and 3. This inspection will be performed in accordance with NRC baseline

Inspection Procedure 71111.07.

In order to minimize the impact that the inspection has on the site and to ensure a productive

inspection, we have enclosed a request for documents needed for the inspection. The

documents have been divided into three groups.

The first group lists information necessary for our initial inspection scoping

activities. This information should be available to the lead inspector no later than

September 5, 2017. By September 12, 2017, the inspector will communicate the initial

selected set of approximately 2-3 risk-significant heat exchangers.

The second group is needed to support our in-office preparation activities. This set of

documents, including the calculations associated with the selected heat exchangers,

should be available at the Regional Office no later than October 3, 2017. This

information should be separated for each selected component, especially if provided

electronically (e.g., folder with component name that includes calculations, condition

reports, maintenance history, etc.). During the in-office preparation activities, the

inspector may identify additional information needed to support the inspection.

The last group includes the additional information above as well as plant specific

reference material. This information should be available onsite to the inspector on

October 16, 2017. It is also requested that corrective action documents and/or

questions developed during the inspection be provided to the inspector as the

documents are generated.

B. Hanson

-2-

All requested documents are to be for the time period from the onsite inspection period back

to the documents that were provided in response to the previous Heat Sink Performance

Inspection. If no activities were accomplished in that time period, then the request applies to

the last applicable document in the previous time period. It is important that these documents

be as complete as possible, in order to minimize the number of documents requested during

the preparation week or during the onsite inspection.

The lead inspector for this inspection is Mr. Gerard ODwyer. We understand that our licensing

contact for this inspection is Mr. Dean J. Walker of your organization. If there are any questions

about the inspection or the material requested in the enclosure, please contact the lead

inspector at 630-829-9624 or via e-mail at Gerard.ODwyer@nrc.gov.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget Control

Number.

This letter and its enclosure 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Gerard ODwyer, Reactor Inspector

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-237; 50-249

License Nos. DPR-19; DPR-25

Enclosure:

Triennial Heat Sink Performance Inspection

Document Request

cc: Distribution via LISTSERV

B. Hanson

-3-

Letter to Bryan C. Hanson from Gerard ODwyer dated August 18, 2017

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3NOTIFICATION

OF AN NRC TRIENNIAL HEAT SINK PERFORMANCE INSPECTION AND

REQUEST FOR INFORMATION; INSPECTION REPORT 05000237/2017004;

05000249/2017004

DISTRIBUTION:

Jeremy Bowen

RidsNrrDorlLpl3

RidsNrrPMDresden Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

James Trapp

Richard Skokowski

Allan Barker

Carole Ariano

Linda Linn

DRPIII

DRSIII

ROPreports.Resource@nrc.gov

ADAMS Accession Number ML17230A273

OFFICE

RIII

RIII

RIII

RIII

NAME

GODwyer:cl

DATE

08/18/17

OFFICIAL RECORD COPY

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

Enclosure

Inspection Report: 05000237/2017004; 05000249/2017004

Inspection Dates:

October 16 - 20, 2017

Inspection Procedure:

IP 71111.07, Heat Sink Performance

Lead Inspector:

Gerard ODwyer

630-829-9624

Gerard.ODwyer@nrc.gov

Please provide the information electronically in pdf files, Excel, or other searchable formats,

preferably on some portable electronic media (e.g., CD-ROM, DVD). The portable electronic

media should contain descriptive names, and be indexed and hyperlinked to facilitate ease of

use. Information in lists should contain enough information to be easily understood by

someone who has knowledge of light water reactor technology.

I.

Information Requested By September 5, 2017:

1. List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting

Safety-Related Equipment, heat exchangers in order of risk significance.

2. Copy of heat exchanger performance trending data tracked for each GL 89-13

heat exchanger.

3. List of Corrective Action Program (CAP) documents (with a short description)

associated with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling,

aging, or heat exchanger testing, ultimate heat sink (UHS), and safety-related

service and closed cooling water systems for the previous 3 years or since the last

CAP document list was sent to the U.S. Nuclear Regulatory Commission for the

previous heat sink performance inspection. The list should include all CAP

documents not on the last CAP document list.

4. Copy of any self-assessment done on any of GL 89-13 heat exchangers, UHS, and

safety-related service water systems since the last heat sink performance inspection.

5. Last two System Health Report(s) and maintenance rule system notebooks for all the

GL 89-13 heat exchangers, UHS, and safety-related service water systems.

6. List of engineering-related operator workarounds (with a short description)

associated with GL 89-13 heat exchangers. The requested documents are to be for

the time period from the onsite inspection period back to the documents that were

provided in response to the previous heat sink performance inspection.

7. List of permanent and temporary modifications (with a short description) associated

with GL 89-13 heat exchangers, UHS, and safety-related service and closed cooling

water systems. The requested documents are to be for the time period from the

onsite inspection period back to the documents that were provided in response to the

previous heat sink performance inspection.

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

2

8. Electronic copies of the current Final Safety Analysis Report (FSAR), Technical

Specifications, Technical Specifications Basis, and Technical Report Manual.

9. List of enhancements and/or commitments made during license renewal for

GL 89-13 heat exchangers, UHS, and safety-related service water systems

(as applicable).

II.

Information Requested By October 3, 2017:

1. Copies of the GL 89-13 responses.

2. Copies of procedures developed to implement the recommendations of GL 89-13

(e.g., the GL 89-13 Heat Exchanger Program description).

3. Copies of the selected CAP documents.

4. For the specific heat exchangers selected:

a. Copy of system descriptions and applicable Updated FSAR sections for the heat

exchangers (as applicable).

b. Provide a list of calculations (with a short description) which currently apply to

each heat exchanger.

c. Provide the calculations or evaluations that:

i. establish the limiting design basis heat load required to be removed by

each of these heat exchangers;

ii. demonstrate the heat exchangers capacity to remove the limiting heat

load;

iii. correlate surveillance testing and/or inspection results from these heat

exchangers with design basis heat removal capability (e.g., basis for

surveillance test and/or inspection acceptance criteria);

iv. evaluate the potential for water hammer in each heat exchanger or

associated piping; and

v. evaluate excessive tube vibration in each heat exchanger.

d. Copy of any operability determinations or other documentation of degradation

associated with the heat exchangers or the systems that support the operation

for the selected heat exchangers.

e. Copy of the design specification, heat exchanger data sheets, and vendor

documents including component drawings applicable for the selected heat

exchangers.

f. Copies of normal, abnormal, and emergency operating procedures associated

with the selected heat exchangers.

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

3

g. Copies of the Aging Management Programs (AMP) and the implementing

procedures that manage aging of the selected heat exchangers (as applicable).

5. For the UHS and the safety-related service water systems (or equivalent):

a. Copy of system description and applicable Updated FSAR sections

(as applicable).

b. Copy of any operability determinations or other documentation of degradation

associated with the UHS and the safety-related service water systems.

c. Copy of the document (e.g., Updated FSAR or Technical Requirements Manual)

that states the maximum cooling water system inlet temperature limit that still

allows full licensed power operation of the nuclear reactor.

d. Copy of system description and design basis document (as applicable).

e. Copy of the construction code and Design Specification.

f. Copies of normal, abnormal, and emergency operating procedures associated

with the UHS and safety-related service systems including procedures for loss of

these systems.

g. Copies of CAP documents associated with waterhammer or hydraulic transients

in the safety-related service water systems since the last Heat Sink Inspection.

h. If available, provide an electronic copy of piping and instrumentation diagrams for

the service water systems, including the intake structure.

i.

Provide a list of calculations (with a short description), which currently apply to

the UHS and safety-related service water systems.

j.

Provide a list of instruments (with a short description) associated with automatic

or alarm functions for the UHS and safety-related service water systems.

k. Provide a list of any design change (with a short description) performed on

the UHS and safety-related service water systems since the last heat sink

performance inspection.

l.

Copies of the AMPs and the implementing procedures that manage aging of

the UHS (including the intake structure) and the safety-related service (as

applicable).

6. A schedule of all inspections, cleanings, maintenance, or testing of any

safety-related plant heat exchanger to be performed during the onsite portion

of the inspection.

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

4

III.

Information Requested to be Available on First Day of Inspection,

October 16, 2017:

1. For the specific heat exchangers selected.

a. Copy of the calculation which correlates surveillance testing results from these

heat exchangers with design basis heat removal capability (e.g., basis for

surveillance test acceptance criteria).

b. Copies of the two most recent completed tests and evaluation data confirming

thermal performance for those heat exchangers which are performance tested.

c. Documentation and procedures that identify the types, accuracy, and location of

any special instrumentation used for the two most recently completed thermal

performance tests for the heat exchangers (e.g., high accuracy ultrasonic flow

instruments or temperature instruments). Include calibration records for the

instruments used during these tests.

d. Information regarding any alarms which monitor on-line performance.

e. Copy of the document describing the inspection results of each heat exchanger.

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

f. The cleaning and inspection maintenance schedule for each heat exchanger for

the next 5 years.

g. Copy of the calculation which establishes the limiting (maximum) design basis

heat load which is required to be removed by each of these heat exchangers.

h. Copy of the operating procedure that ensures that the maximum cooling water

system inlet temperature limit is not exceeded.

i.

Copy of the calculations or documents which evaluate the potential for water

hammer in each heat exchanger or associated piping.

j.

Copy of the calculations that evaluate excessive tube vibration in each heat

exchanger and the documents that describe the controls that prevent heat

exchanger degradation due to excessive flow induced vibration during operation.

k. Copy of the periodic flow testing at or near maximum design flow. The requested

documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous heat sink

performance inspection.

l.

Copy of the document which identifies the current number of tubes in service for

each heat exchanger and the supporting calculation which establishes the

maximum number of tubes which can be plugged in each heat exchanger.

m. Copy of the document establishing the repair criteria (plugging limit) for degraded

tubes which are identified in each heat exchanger.

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

5

n. Copies of the documents that verify the structural integrity of the heat exchanger

(e.g., eddy current summary sheets, ultrasonic testing results, and visual

inspection results).

o. Copies of those documents that describe the methods taken to control water

chemistry in the heat exchangers, including those credited by any AMPs (as

applicable).

p. Copies of any credited AMP monitoring/inspection results for the selected heat

exchangers (as applicable). The requested documents are to be for any

completed monitoring/inspection in the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

2. For the review of the operation of the safety-related service water systems and the

UHS:

a. Copies of any design changes performed on the UHS. The requested

documents are to be for the time period from the onsite inspection period back

to the documents that were provided in response to the previous heat sink

performance inspection.

b. Copies of any design change performed on the safety-related service water

systems. The requested documents are to be for the time period from the onsite

inspection period back to the documents that were provided in response to the

previous heat sink performance inspection.

c. Copies of procedures for a loss of UHS.

d. Copies of procedures for a loss of service water systems.

e. Inspections and/or maintenance related to preventing macrofouling (e.g., silt,

dead mussel shells, or debris) and biotic fouling (e.g., fish, algae, grass, or kelp).

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

f. Copies of documents associated with the monitoring of pump performance for

potential strong-pump vs. weak-pump interaction.

3. For the review associated with the system walkdown of the service water intake

structure:

a. Copies of documentation that demonstrates proper functioning of the traveling

screens and strainers including backwash strainer function, (e.g., copies of the

last two inspections and surveillances associated with service water strainers,

traveling screens and trash racks).

b. List of preventive maintenance, including frequency, associated with service

water strainers, traveling screens and trash racks

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

6

c. Copies of abnormal procedures for the traveling screens and service water

strainers.

d. Copies of the last two inspections and/or surveillances documenting that

component mounts have not excessively degraded (i.e., due to corrosion). For

example, inspections for the mounts for the service water pumps, service water

strainers, traveling screens and trash racks.

e. Copies of the documents associated with the monitoring, trending, and

remediation of silt accumulation at the service water pump bay.

f. Copies of surveillance procedures and testing results performed on the service

water pump bay water level instruments. The requested documents are to be for

the time period from the onsite inspection period back to the documents that

were provided in response to the previous heat sink performance inspection.

g. Copies of procedures associated with operating during adverse weather

conditions (e.g., icing especially frazil icing, high temperatures, or low level).

h. Copy of the evaluation for the potential effects of low flow/level on underwater

weir walls intended to limit silt or sand intake, if applicable.

i.

Copies of any credited AMP monitoring/inspection results for the safety-related

service and closed cooling water systems, and the UHS (as applicable). The

requested documents are to be for any completed monitoring/inspection in the

time period from the onsite inspection period back to the documents that were

provided in response to the previous heat sink performance inspection.

If the information requested above will not be available, please contact Gerard ODwyer as soon

as possible at 630-829-9624 or e-mail Gerard.ODwyer@nrc.gov.