ML030300803: Difference between revisions

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Exelon Generation Company, LLC
Exelon Generation Company, LLC
4300 Winfield Road
4300 Winfield Road
Warrenville, IL 60555
Warrenville, IL 60555
SUBJECT:       DRESDEN NUCLEAR POWER STATION
SUBJECT:
                NRC INSPECTION REPORT 50-237/01-21(DRS); 50-249/01-21(DRS);
DRESDEN NUCLEAR POWER STATION
                PRELIMINARY WHITE FINDING
NRC INSPECTION REPORT 50-237/01-21(DRS); 50-249/01-21(DRS);
PRELIMINARY WHITE FINDING
Dear Mr. Skolds:
Dear Mr. Skolds:
On October 16, 2001, the NRC completed an inspection at your Dresden Nuclear Power
On October 16, 2001, the NRC completed an inspection at your Dresden Nuclear Power
Station. While the inspection findings were discussed on October 16, 2001, with Mr. P.
Station. While the inspection findings were discussed on October 16, 2001, with Mr. P.
Swafford of your Dresden staff and documented in Inspection Report 50-237/01-21(DRS);
Swafford of your Dresden staff and documented in Inspection Report 50-237/01-21(DRS);
50-249/01-21(DRS), dated November 16, 2001, it was not until December 3, 2002, when
50-249/01-21(DRS), dated November 16, 2001, it was not until December 3, 2002, when
Licensee Event Report (LER) No. 2002-005-00, Unit 3 High Pressure Coolant Injection System
Licensee Event Report (LER) No. 2002-005-00, Unit 3 High Pressure Coolant Injection System
Inoperable Due to Water Hammer Event, was issued, that the significance of the issue could
Inoperable Due to Water Hammer Event, was issued, that the significance of the issue could
be fully evaluated. Further discussion occurred on January 27, 2003, following our review of
be fully evaluated. Further discussion occurred on January 27, 2003, following our review of
your operability determination.
your operability determination.
The report discusses a finding that appears to have a low to moderate safety significance.
The report discusses a finding that appears to have a low to moderate safety significance.  
As described in Section 1R15 of the report, the issue pertains to operability of the Unit 3
As described in Section 1R15 of the report, the issue pertains to operability of the Unit 3
High Pressure Coolant Injection (HPCI) system with a degraded pipe support between July 5,
High Pressure Coolant Injection (HPCI) system with a degraded pipe support between July 5,
2001, and September 30, 2001. The HPCI pipe support was likely damaged when HPCI
2001, and September 30, 2001. The HPCI pipe support was likely damaged when HPCI
automatically activated during a July 5, 2001 scram. A hydrodynamic transient/water hammer
automatically activated during a July 5, 2001 scram. A hydrodynamic transient/water hammer
event occurred as a result of a combination of air pockets and steam voids in the piping due to
event occurred as a result of a combination of air pockets and steam voids in the piping due to
inadequate venting of the system. The ability of the HPCI system to perform its designed
inadequate venting of the system. The ability of the HPCI system to perform its designed
safety functions was an unresolved item pending further review and determination of operability
safety functions was an unresolved item pending further review and determination of operability
while in the damaged state. After your staff determined in the above LER that the Unit 3 HPCI
while in the damaged state. After your staff determined in the above LER that the Unit 3 HPCI
system was inoperable during the July 5 to September 30, 2001 time period, the finding was
system was inoperable during the July 5 to September 30, 2001 time period, the finding was
assessed using the applicable significance determination process and was preliminarily
assessed using the applicable significance determination process and was preliminarily
determined to be White, i.e., a finding with some increased importance to safety, which may
determined to be White, i.e., a finding with some increased importance to safety, which may
require additional NRC inspection. The finding has a low-to-moderate safety significance based
require additional NRC inspection. The finding has a low-to-moderate safety significance based
on the Significance Determination Process (SDP) Phase 2 analysis results using the
on the Significance Determination Process (SDP) Phase 2 analysis results using the
benchmarked SDP notebook and the Standardized Plant Analysis Risk (SPAR) model.
benchmarked SDP notebook and the Standardized Plant Analysis Risk (SPAR) model.


J. Skolds                                       -2-
J. Skolds
-2-
On September 30, 2001, the damaged Unit 3 HPCI pipe support was repaired, and an adjacent
On September 30, 2001, the damaged Unit 3 HPCI pipe support was repaired, and an adjacent
hanger was adjusted to support pipe dead weight loads. By October 3, 2001, venting of the
hanger was adjusted to support pipe dead weight loads. By October 3, 2001, venting of the
Unit 2 and Unit 3 HPCI pump discharge piping was completed. Dresden procedures were
Unit 2 and Unit 3 HPCI pump discharge piping was completed. Dresden procedures were
revised to vent HPCI intermediate high points and to require the venting of HPCI pump
revised to vent HPCI intermediate high points and to require the venting of HPCI pump
discharge piping while aligned to the contaminated condensate storage tank.
discharge piping while aligned to the contaminated condensate storage tank.
As discussed with Dresden staff on January 27, 2003, the NRC has concluded that the finding
As discussed with Dresden staff on January 27, 2003, the NRC has concluded that the finding
is an apparent violation of Criterion XVI, Corrective Action, of 10 CFR Part 50, Appendix B, for
is an apparent violation of Criterion XVI, Corrective Action, of 10 CFR Part 50, Appendix B, for
failure to promptly correct conditions adverse to quality and for failure to take corrective action
failure to promptly correct conditions adverse to quality and for failure to take corrective action
to preclude repetition in the case of a significant condition adverse to quality. Your staff did not
to preclude repetition in the case of a significant condition adverse to quality. Your staff did not
promptly correct damaged pipe support M-1187D-80 on the Unit 3 HPCI system after it was
promptly correct damaged pipe support M-1187D-80 on the Unit 3 HPCI system after it was
identified on July 19, 2001, a significant condition adverse to quality, and your staff did not take
identified on July 19, 2001, a significant condition adverse to quality, and your staff did not take
corrective action to preclude repetition until prompted by NRC staff on September 30, 2001.
corrective action to preclude repetition until prompted by NRC staff on September 30, 2001.  
The finding is also an apparent violation of NRC requirements and is being considered for
The finding is also an apparent violation of NRC requirements and is being considered for
escalated enforcement action in accordance with the General Statement of Policy and
escalated enforcement action in accordance with the General Statement of Policy and
Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current
Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current
Enforcement Policy is included on the NRCs website at www.nrc.gov/OE.
Enforcement Policy is included on the NRCs website at www.nrc.gov/OE.  
We believe that sufficient information was considered to make a preliminary significance
We believe that sufficient information was considered to make a preliminary significance
determination. However, before we make a final decision on this matter, we are providing you
determination. However, before we make a final decision on this matter, we are providing you
an opportunity to present to the NRC your perspectives on the facts and assumptions, used by
an opportunity to present to the NRC your perspectives on the facts and assumptions, used by
the NRC to arrive at the finding and its significance, at a Regulatory Conference or through the
the NRC to arrive at the finding and its significance, at a Regulatory Conference or through the
submittal to the NRC of your position on the finding in writing. If you choose to request a
submittal to the NRC of your position on the finding in writing. If you choose to request a
Regulatory Conference, it should be held within 30 days of the receipt of this letter and we
Regulatory Conference, it should be held within 30 days of the receipt of this letter and we
encourage you to submit supporting documentation at least one week prior to the conference in
encourage you to submit supporting documentation at least one week prior to the conference in
an effort to make the conference more efficient and effective. If a Regulatory Conference is
an effort to make the conference more efficient and effective. If a Regulatory Conference is
held, it will be open for public observation. If you decide to submit only a written response, such
held, it will be open for public observation. If you decide to submit only a written response, such
submittal should be sent to the NRC within 30 days of the receipt of this letter.
submittal should be sent to the NRC within 30 days of the receipt of this letter.
Please contact Mr. David Hills at (630) 829-9733 within 10 business days of the receipt of this
Please contact Mr. David Hills at (630) 829-9733 within 10 business days of the receipt of this
letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will
letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will
continue with our significance determination and enforcement decision and you will be advised
continue with our significance determination and enforcement decision and you will be advised
by separate correspondence of the results of our deliberations on this matter.
by separate correspondence of the results of our deliberations on this matter.
Since the NRC has not made a final determination in this matter, no Notice of Violation is being
Since the NRC has not made a final determination in this matter, no Notice of Violation is being
issued for this inspection finding at this time. In addition, please be advised that the number
issued for this inspection finding at this time. In addition, please be advised that the number
and characterization of apparent violations described above may change as a result of further
and characterization of apparent violations described above may change as a result of further
NRC review.
NRC review.  
Today, we are also issuing correspondence concerning a Predecisional Enforcement
Today, we are also issuing correspondence concerning a Predecisional Enforcement
Conference concerning possible incomplete or inaccurate information provided to the NRC staff
Conference concerning possible incomplete or inaccurate information provided to the NRC staff
Line 93: Line 95:
Investigations Case No. 3-2001-054).
Investigations Case No. 3-2001-054).


J. Skolds                                       -3-
J. Skolds
-3-
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be
available electronically for public inspection in the NRC Public Document Room or from the
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS
Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Electronic Reading Room).
                                                Sincerely,
Sincerely,
                                /RA by Roy Caniano Acting For/
/RA by Roy Caniano Acting For/  
                                                Cynthia D. Pederson, Director
Cynthia D. Pederson, Director
                                                Division of Reactor Safety
Division of Reactor Safety
Docket No. 50-249
Docket No. 50-249
License No. DPR-25
License No. DPR-25
cc:     Site Vice President - Dresden Nuclear Power Station
cc:
        Dresden Nuclear Power Station Plant Manager
Site Vice President - Dresden Nuclear Power Station
        Regulatory Assurance Manager - Dresden
Dresden Nuclear Power Station Plant Manager
        Chief Operating Officer
Regulatory Assurance Manager - Dresden
        Senior Vice President - Nuclear Services
Chief Operating Officer
        Senior Vice President - Mid-West Regional
Senior Vice President - Nuclear Services
          Operating Group
Senior Vice President - Mid-West Regional
        Vice President - Mid-West Operations Support
  Operating Group
        Vice President - Licensing and Regulatory Affairs
Vice President - Mid-West Operations Support
        Director Licensing - Mid-West Regional
Vice President - Licensing and Regulatory Affairs
          Operating Group
Director Licensing - Mid-West Regional
        Manager Licensing - Dresden and Quad Cities
  Operating Group
        Senior Counsel, Nuclear, Mid-West Regional
Manager Licensing - Dresden and Quad Cities
          Operating Group
Senior Counsel, Nuclear, Mid-West Regional
        Document Control Desk - Licensing
  Operating Group
        M. Aguilar, Assistant Attorney General
Document Control Desk - Licensing
        Illinois Department of Nuclear Safety
M. Aguilar, Assistant Attorney General
        State Liaison Officer
Illinois Department of Nuclear Safety
        Chairman, Illinois Commerce Commission
State Liaison Officer
Chairman, Illinois Commerce Commission


J. Skolds                                               -3-
J. Skolds
-3-
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be
available electronically for public inspection in the NRC Public Document Room or from the
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS
Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Electronic Reading Room).
                                                        Sincerely,
Sincerely,
                                                /RA by Roy Caniano Acting For/
/RA by Roy Caniano Acting For/  
                                                        Cynthia D. Pederson, Director
Cynthia D. Pederson, Director
                                                        Division of Reactor Safety
Division of Reactor Safety
Docket No. 50-249
Docket No. 50-249
License No. DPR-25
License No. DPR-25
cc:     Site Vice President - Dresden Nuclear Power Station
cc:
        Dresden Nuclear Power Station Plant Manager
Site Vice President - Dresden Nuclear Power Station
        Regulatory Assurance Manager - Dresden
Dresden Nuclear Power Station Plant Manager
        Chief Operating Officer
Regulatory Assurance Manager - Dresden
        Senior Vice President - Nuclear Services
Chief Operating Officer
        Senior Vice President - Mid-West Regional
Senior Vice President - Nuclear Services
          Operating Group
Senior Vice President - Mid-West Regional
        Vice President - Mid-West Operations Support
  Operating Group
        Vice President - Licensing and Regulatory Affairs
Vice President - Mid-West Operations Support
        Director Licensing - Mid-West Regional
Vice President - Licensing and Regulatory Affairs
          Operating Group
Director Licensing - Mid-West Regional
        Manager Licensing - Dresden and Quad Cities
  Operating Group
        Senior Counsel, Nuclear, Mid-West Regional
Manager Licensing - Dresden and Quad Cities
          Operating Group
Senior Counsel, Nuclear, Mid-West Regional
        Document Control Desk - Licensing
  Operating Group
        M. Aguilar, Assistant Attorney General
Document Control Desk - Licensing
        Illinois Department of Nuclear Safety
M. Aguilar, Assistant Attorney General
        State Liaison Officer
Illinois Department of Nuclear Safety
        Chairman, Illinois Commerce Commission
State Liaison Officer
DOCUMENT NAME: G:\DRS\ML030300803.wpd
Chairman, Illinois Commerce Commission
DOCUMENT NAME: G:\\DRS\\ML030300803.wpd
To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy
To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy
OFFICE           RIII               RIII                 RIII                 RIII               RIII
OFFICE
NAME             ADunlop for         DHills               MRing                 CWeil for         RCaniano for
RIII
                  JNeurauter:sd                                                  BClayton          CPederson
RIII
DATE             01/28/03           01/28/03             01/28/03             01/29/03           01/30/03
RIII
                                          OFFICIAL RECORD COPY
RIII
RIII
NAME
ADunlop for
JNeurauter:sd
DHills
MRing
CWeil for
BClayton
RCaniano for
CPederson
DATE
01/28/03
01/28/03
01/28/03
01/29/03
01/30/03
OFFICIAL RECORD COPY


J. Skolds                               -4-
J. Skolds
-4-
ADAMS Distribution:
ADAMS Distribution:
ADAMS (PARS)
ADAMS (PARS)
Line 177: Line 201:
SJC1
SJC1
RWB1
RWB1
WDR
WDR  
TJK3
TJK3
Enforcement Coordinators
Enforcement Coordinators
RI, RII, RIII, RIV (DJH, CFE, HBC, GFS)
  RI, RII, RIII, RIV (DJH, CFE, HBC, GFS)
TJF
TJF
SFG
SFG

Latest revision as of 12:46, 16 January 2025

Preliminary White Finding, NRC IR 05000237-01-021(DRS); IR 05000249-01-021(DRS), Dresden Units 2 & 3
ML030300803
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 01/30/2003
From: Pederson C
Division of Reactor Safety III
To: Skolds J
Exelon Generation Co, Exelon Nuclear
References
EA-02-264 IR-01-021
Download: ML030300803 (5)
v • d • e


See also: IR 05000237/2001021

Text

January 30, 2003

EA-02-264

Mr. John L. Skolds, President

Exelon Nuclear

Exelon Generation Company, LLC

4300 Winfield Road

Warrenville, IL 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION

NRC INSPECTION REPORT 50-237/01-21(DRS); 50-249/01-21(DRS);

PRELIMINARY WHITE FINDING

Dear Mr. Skolds:

On October 16, 2001, the NRC completed an inspection at your Dresden Nuclear Power

Station. While the inspection findings were discussed on October 16, 2001, with Mr. P.

Swafford of your Dresden staff and documented in Inspection Report 50-237/01-21(DRS);

50-249/01-21(DRS), dated November 16, 2001, it was not until December 3, 2002, when

Licensee Event Report (LER) No. 2002-005-00, Unit 3 High Pressure Coolant Injection System

Inoperable Due to Water Hammer Event, was issued, that the significance of the issue could

be fully evaluated. Further discussion occurred on January 27, 2003, following our review of

your operability determination.

The report discusses a finding that appears to have a low to moderate safety significance.

As described in Section 1R15 of the report, the issue pertains to operability of the Unit 3

High Pressure Coolant Injection (HPCI) system with a degraded pipe support between July 5,

2001, and September 30, 2001. The HPCI pipe support was likely damaged when HPCI

automatically activated during a July 5, 2001 scram. A hydrodynamic transient/water hammer

event occurred as a result of a combination of air pockets and steam voids in the piping due to

inadequate venting of the system. The ability of the HPCI system to perform its designed

safety functions was an unresolved item pending further review and determination of operability

while in the damaged state. After your staff determined in the above LER that the Unit 3 HPCI

system was inoperable during the July 5 to September 30, 2001 time period, the finding was

assessed using the applicable significance determination process and was preliminarily

determined to be White, i.e., a finding with some increased importance to safety, which may

require additional NRC inspection. The finding has a low-to-moderate safety significance based

on the Significance Determination Process (SDP) Phase 2 analysis results using the

benchmarked SDP notebook and the Standardized Plant Analysis Risk (SPAR) model.

J. Skolds

-2-

On September 30, 2001, the damaged Unit 3 HPCI pipe support was repaired, and an adjacent

hanger was adjusted to support pipe dead weight loads. By October 3, 2001, venting of the

Unit 2 and Unit 3 HPCI pump discharge piping was completed. Dresden procedures were

revised to vent HPCI intermediate high points and to require the venting of HPCI pump

discharge piping while aligned to the contaminated condensate storage tank.

As discussed with Dresden staff on January 27, 2003, the NRC has concluded that the finding

is an apparent violation of Criterion XVI, Corrective Action, of 10 CFR Part 50, Appendix B, for

failure to promptly correct conditions adverse to quality and for failure to take corrective action

to preclude repetition in the case of a significant condition adverse to quality. Your staff did not

promptly correct damaged pipe support M-1187D-80 on the Unit 3 HPCI system after it was

identified on July 19, 2001, a significant condition adverse to quality, and your staff did not take

corrective action to preclude repetition until prompted by NRC staff on September 30, 2001.

The finding is also an apparent violation of NRC requirements and is being considered for

escalated enforcement action in accordance with the General Statement of Policy and

Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current

Enforcement Policy is included on the NRCs website at www.nrc.gov/OE.

We believe that sufficient information was considered to make a preliminary significance

determination. However, before we make a final decision on this matter, we are providing you

an opportunity to present to the NRC your perspectives on the facts and assumptions, used by

the NRC to arrive at the finding and its significance, at a Regulatory Conference or through the

submittal to the NRC of your position on the finding in writing. If you choose to request a

Regulatory Conference, it should be held within 30 days of the receipt of this letter and we

encourage you to submit supporting documentation at least one week prior to the conference in

an effort to make the conference more efficient and effective. If a Regulatory Conference is

held, it will be open for public observation. If you decide to submit only a written response, such

submittal should be sent to the NRC within 30 days of the receipt of this letter.

Please contact Mr. David Hills at (630) 829-9733 within 10 business days of the receipt of this

letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will

continue with our significance determination and enforcement decision and you will be advised

by separate correspondence of the results of our deliberations on this matter.

Since the NRC has not made a final determination in this matter, no Notice of Violation is being

issued for this inspection finding at this time. In addition, please be advised that the number

and characterization of apparent violations described above may change as a result of further

NRC review.

Today, we are also issuing correspondence concerning a Predecisional Enforcement

Conference concerning possible incomplete or inaccurate information provided to the NRC staff

on September 27, 2001 about the water hammer event on July 5, 2001 (NRC Office of

Investigations Case No. 3-2001-054).

J. Skolds

-3-

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be

available electronically for public inspection in the NRC Public Document Room or from the

Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS

is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA by Roy Caniano Acting For/

Cynthia D. Pederson, Director

Division of Reactor Safety

Docket No. 50-249

License No. DPR-25

cc:

Site Vice President - Dresden Nuclear Power Station

Dresden Nuclear Power Station Plant Manager

Regulatory Assurance Manager - Dresden

Chief Operating Officer

Senior Vice President - Nuclear Services

Senior Vice President - Mid-West Regional

Operating Group

Vice President - Mid-West Operations Support

Vice President - Licensing and Regulatory Affairs

Director Licensing - Mid-West Regional

Operating Group

Manager Licensing - Dresden and Quad Cities

Senior Counsel, Nuclear, Mid-West Regional

Operating Group

Document Control Desk - Licensing

M. Aguilar, Assistant Attorney General

Illinois Department of Nuclear Safety

State Liaison Officer

Chairman, Illinois Commerce Commission

J. Skolds

-3-

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be

available electronically for public inspection in the NRC Public Document Room or from the

Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS

is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA by Roy Caniano Acting For/

Cynthia D. Pederson, Director

Division of Reactor Safety

Docket No. 50-249

License No. DPR-25

cc:

Site Vice President - Dresden Nuclear Power Station

Dresden Nuclear Power Station Plant Manager

Regulatory Assurance Manager - Dresden

Chief Operating Officer

Senior Vice President - Nuclear Services

Senior Vice President - Mid-West Regional

Operating Group

Vice President - Mid-West Operations Support

Vice President - Licensing and Regulatory Affairs

Director Licensing - Mid-West Regional

Operating Group

Manager Licensing - Dresden and Quad Cities

Senior Counsel, Nuclear, Mid-West Regional

Operating Group

Document Control Desk - Licensing

M. Aguilar, Assistant Attorney General

Illinois Department of Nuclear Safety

State Liaison Officer

Chairman, Illinois Commerce Commission

DOCUMENT NAME: G:\\DRS\\ML030300803.wpd

To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy

OFFICE

RIII

RIII

RIII

RIII

RIII

NAME

ADunlop for

JNeurauter:sd

DHills

MRing

CWeil for

BClayton

RCaniano for

CPederson

DATE

01/28/03

01/28/03

01/28/03

01/29/03

01/30/03

OFFICIAL RECORD COPY

J. Skolds

-4-

ADAMS Distribution:

ADAMS (PARS)

SECY

OCA

WDT

WFK

FJC

JLD, OE

JED2

DCD

SJC1

RWB1

WDR

TJK3

Enforcement Coordinators

RI, RII, RIII, RIV (DJH, CFE, HBC, GFS)

TJF

SFG

HTB

GPC

RCP2

RJS2

AJM

DFT

LWR

RidsNrrDipmIipb

GEG

HBC

DRC1

DRPIII

DRSIII

PLB1

JRK1

OEMAIL

CHW1

LAD

JGL

MAR

CAC

MJR1

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