IR 05000245/2011002

From kanterella
Jump to navigation Jump to search

Download: ML111290320

Text

May 9, 2OILMr. David HeacockPresident and Chief Nuclear OfficerDominion Resources5000 Dominion BoulevardGlen Allen. VA 23060-6711

SUBJECT: MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT05000336/201 1 002 AN D 050004231201 1 002

Dear Mr. Heacock:

On March 31,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspectionat your Millstone Power Station Unit 2 and Unit 3. The enclosed inspection report documentsthe inspection results, which were discussed on April 20, 2011, with Mr. A. J. Jordan and othermembers of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations, and with the conditions of yourlicense. The inspectors reviewed selected procedures and records, observed activities, andinterviewed personnel.This report documents two self-revealing findings of very low safety significance (Green). Bothof these findings were determined to involve violations of NRC requirements. However,because of the very low safety significance and because they have been entered into yourcorrective action program, the NRC is treating these findings as non-cited violations (NCVs)consistent with Section 2.3.2.a of the NRC Enforcement Policy. lf you contest any NCV, youshould provide a response within 30 days of the date of this inspection report, with the basis foryour denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk,Washington DC 20555-0001; with copies to the Regional Administrator, Region l; the Director,Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident lnspector at Millstone. lf you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30days of the date of this inspection report, with the basis for your disagreement, to the RegionalAdministrator, Region l, and the NRC Senior Resident lnspector at Millstone. The informationyou provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 2.390 of the NRC's"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Web Site at http://www.nrc.qov/readinq-rm/adams.html (thePublic Electronic Reading Room).Sincerelv.AItl lnl e I I t t/\. r -t- ^- r t rt / -l+. vnv\I X-X)V.AUA L . t \7v'r,v'" o'o.uro El .,r.*$'d chierProjects Branch 5Division of Reactor ProjectsDocket Nos. 50-336, 50-423License Nos. DPR-65, NPF-49

Enclosure:

Inspection Report No. 0500033612011002 and 05000423/2011002M

Attachment:

Supplemental Informationcc wiencl: Distribution via Listserv

SUMMARY

OF FlNDINGS........... .........3

REPORT DETAILS

1.

REACTOR SAFETY

... .................51R01 Adverse Weather Protection. ...........51R04 Equipment Alignment ...................... 51R05 Fire Protection........... ......................71R06 Flood Protection Measures.. ............81R07 Heat Sink Performance.............. .................... 101R11 Licensed Operator Requalification Program.............. ...... 101R12 Maintenance Effectiveness.......... ................... 111R13 Maintenance Risk Assessments and Emergent Work Control ..........121R15 Operability Evaluations ..................121R18 Plant Modifications ....... 131R19 Post-Maintenance Testing .............141R22 Surveillance Testing ..... 162. RADIATlON SAFETY ................172RS01 RadiologicalHazard Assessment and Exposure Controls ................172RS02 OccupationalALARA Planning and Controls ............. ... .'182RS03 In-PlantAirborne Radioactivity Control and Mitigation ........... ..........194. OTHER ACTlVlTIES ............. ....................214OA1 Performance Indicator (Pl) Verification........... .................214OA2 ldentification and Resolution of Problems............... .........214OA3 Event Follow-up ...........234OA5 Other Activities .............244OAO Meetings, including Exit........... ......25ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

........ ......4-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

....4-2

LIST OF DOCUMENTS REVIEWED

.... ...... .......4-2

LIST OF ACRONYMS

.A-9Enclosure

3SUMMAR Y
OF [[]]
FINDIN [[]]
GS [[lR 0500033612011002, 0500042312011002;0110112011 - 0313112011; Millstone Power StationUnit 2 and Unit 3; Flood Protection Measures, Post-Maintenance Testing.This report covered a three-month period of inspection by resident and region-based inspectors.Two Green self-revealing findings, both of which were non-cited violations (NCVs), wereidentified. The significance of most findings is indicated by their color (Green, White, Yellow,Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process." Thecross-cutting aspects were determined using]]
IMC 0310, "Components Within the Cross CuttingAreas." Findings for which the significance determination process (
SDP ) does not apply may beGreen or be assigned a severity level after
NRC management review. The
NRC 's program foroverseeing the safe operation of commercial nuclear power reactors is described in
NUREG -1649, "Reactor Oversight Process," Revision 4, dated December 2006.Cornerstone: Mitigating Systems. Green. A self-revealing Green non-cited violation (
NCV ) of
10 CFR [[Part 50, Appendix B,Criterion lll, "Design Control," was identified for Dominion's failure to maintain safetyrelated cables in an environment for which they were designed. Specifically, 480Vsafety related cables, which are not qualified for continuous submergence, were foundsubmerged in a cable vault since approximately October 20,2010, to March 14,2011.Dominion took immediate corrective action to remove the water from the cable vault andentered the issue into their corrective action program (]]
CAP [[).The inspectors determined that the finding was more than minor because if leftuncorrected, the performance deficiency would have the potential to lead to a moresignificant safety concern. Specifically, the inspectors noted that the insulation ofcontinuously submerged cables would degrade more than dry or periodically wettedcables, which would lead to failures. The finding was of very low safety significance(Green) because the finding was not a design or qualification deficiency which resultedin a loss of operability or functionality, did not represent a loss of system safety function,did not represent an actual loss of safety function of a single train for greater than itsTechnical Specification allowed outage time, did not represent an actual loss of safetyfunction of one or more non-Technical Specification trains of equipment designated asrisk-significant for greater than 24 hours, and was not potentially risk significant due to aseismic, flooding or severe weather initiating event. The inspectors determined that thefinding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Operating Experience component, because Dominion did not effectivelyimplement Operating Experience to prevent submergence of safety related cables.lP.2(b)l (Section 1R06). Green. A self-revealing Green]]
NCV of 10
CFR Part 50, Appendix B, Criterion V,"lnstructions, Procedures, and Drawings," was identified for Dominion's failure toproperly restore
3HVQ.A [[]]

CU52B, "Containment Recirculation Pumps and Coolers Area'B'Air Conditioning Unit," following maintenance. This resulted in approximately anEnclosure

4additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of inoperability of the 'B' train of the recirculation spray system(RSS). Dominion entered the issue into their corrective action program. 'The inspectors determined that the finding was more than minor because it wasassociated with the Human Performance attribute of the Mitigating Systems cornerstone,and affected the cornerstone objective of ensuring the availa-bilitylreliability, andcapability of systems that respond to initiating events to prevent undesirableconsequences. Specifically, Dominion's failure to follow the written instructions in thetagging cover sheet caused the 'B'train of

RSS [[to be inoperable for approximately anadditional 24 hours. Using lMc 0609.04, "phase 1 - Initial Screening'andCharacterization of F^indings," the inspectors determined that the find'ing was of very lowsafety significance (Green) because the finding did not represent a losJ of system iafetyfunction, did not represent an actual loss of saiety function of a single train for greaterthan its Technical Specification allowed outage time, did not represlent an actuil loss ofsafety function of one or more non-Technicaispecification trains of equipmentdesignated as risk-significant for greater than 2,4 hours, and was not potentially risksignificant due to a s-eismic, flooding, or severe weather initiating event. The inspectorsdetermined that the finding had a cross-cutting aspect in the Human performance cross-cutting area, Work Practices component, beciuse operations personnel did not foltowthe instructions on the tagging cover sheet when returning the air conditioning unit toservice. tH.4(b)l (Section 1R19)Enclosure]]
5REPORT [[]]
DETAIL [[SSummarv of Plant StatusMillstone Unit 2 and Unit 3 began the inspection period operating at 100 percent power. Withthe exception of minor downpowers for turbine valve testing, both Unit 2 and Unit 3 operated ator near 100 percent power for the inspection period.1.]]
REACTO [[]]

RSAFETYGornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01 Adverse Weather Protection (71111.01 - 1 sample)lmpendinq Adverse Weathera. Inspection ScopeThe inspectors evaluated Dominion's preparations for heavy snowfall on January 12,2011. The inspectors reviewed Dominion's procedures to determine the plant areasmost likely to be affected by the heavy snoMall and verified that actions recommendedby the procedures were in progress or complete. The inspectors spoke with supervisionin several departments and determined that snow removal equipment was available,additional personnel were being scheduled into the site, and that fatigue restrictionswere considered in their planning. The inspectors also walked down the site in order toverify that the heavy snowfall would not impact any essential plant equipment.Documents reviewed during the inspection are listed in the Attachment.b. FindinqsNo findings were identified.1R04 Equipment Aliqnment (71111.04 - 5 samples).1 Partial Svstem Walkdownsa. Inspection ScopeThe inspectors performed five partial system walkdowns during this inspection period.The inspectors reviewed the documents listed in the Attachment to determine the correctsystem alignment. The inspectors performed a walkdown of each system to determine ifthe critical portions of the selected systems were correctly aligned in accordance withthe procedures, and to identify any discrepancies that may have had an effect onoperability. The walkdowns included selected switch and valve position checks, andverification of electrical power to critical components. Finally, the inspectors evaluatedEnclosure

6other elements, such as material condition,following systems were reviewed based onconfiguration:Unit 2housekeeping, and component labeling. Thetheir risk significance for the given plantb..2a.o 'B' High Pressure Safety Injection (HPSI) while the 'A'

HPSI was out-of-service(
OOS ) for surveillance testing on January 25,2Q11;. 'A' Emergency Diesel Generator (EDG) while the 'B'
EDG was
OOS for surveillancetesting on February 2,2011:Unit 3. Charging system following in-service testing (lST) of the 'C' charging pump onJanuary 10,2011;. 'B'
EDG during monthly maintenance on the 'A'
EDG on January 25, 2011; and. 'B' Service Water (SW) train while the 'A'
SW pump was

OOS for repairs onFebruary 24,2Q11.FindinqsNo findings were identified.Complete Svstem Walkdown (71111.04S -1 sample)Inspection ScopeThe inspectors completed a detailed review of the alignment and condition of the Unit 2Containment Spray System. The inspectors performed a walkdown of the system todetermine whether the valves were aligned in accordance with procedures and toidentify any discrepancies that may have had an adverse effect on operability. Theinspectors also reviewed the system health reports, condition reports (CR), andmaintenance rule evaluations to determine whether equipment problems were beingidentified and appropriately resolved. Documents reviewed during the inspection arelisted in the Attachment.FindinqsNo findings were identified.b.Enclosure

71R05 Fire Protection (71111.05Q -7 samples).1 Fire Protection-Toursa. Inspection ScopeThe inspectors performed walkdowns of seven fire protection areas. The inspectorsreviewed Dominion's fire protection program to determine the required fire protectiondesign features, fire area boundaries, and combustible loading requirements for theselected areas. The inspectors walked down these areas to assess Dominion's controlof transient combustible material and ignition sources. In addition, the inspectorsevaluated the material condition and operational status of fire detection and suppressioncapabilities, fire barriers, and any related compensatory measures. The inspectorscompared the existing conditions of the areas to the fire protection programrequirements to determine if all program requirements were being met. Documentsreviewed during the inspection are listed in the Attachment. The fire protection areasreviewed included:Unit 2aaaaAuxiliary Building GeneralArea, Sample Sink and Boronometer Room, Fire Area A-12i480 Volt

MCC 861, Fire Area A-13;Auxiliary Building, Spent Fuel Pool and Fuel Handling Area, Fire Area A-14;Auxiliary Building,
HPSI Pump room, Fire Area A-4;Auxiliary building, Coolant Tank Area, Fire Area A-5;Unit 3. East Service Water Cubicle, Fire Area
CSW -3; ando West Service Water Cubicle, Fire Area

CSW-4.FindinosNo findings were identified.Annual Fire Drill Observation (71111.05A - 1 sample)lnsoection ScopeThe inspectors observed Dominion personnel performance during a fire brigade drill onMarch 11, 2011, to evaluate the readiness of station personnel to fight fires. The drillsimulated a fire in a motor control center (MCC) in the Unit 3 turbine building. Theinspectors observed the fire brigade members using protective clothing, turnout gear,self-contained breathing apparatus and entering the fire area. The inspectors alsoobserved the fire fighting equipment brought to the fire scene to evaluate whethersufficient equipment was available to effectively control and extinguish the simulated fire.b..2Enclosure

8The inspectors evaluated whether the permanent plant fire hose lines were capable ofreaching the fire area and whether hose usage was adequately simulated. Theinspectors observed the fire fighting directions and communications between fire brigademembers. The inspectors also evaluated whether the pre-planned drill scenario wasfollowed and observed the post drill critique to evaluate if the drill objectives weresatisfied and that any drill weaknesses were discussed.b. FindinqsNo findings were identified.1R06 Flood Protection Measures (71111.06 - 2 samples).1 lnternal Floodinqa. lnspection ScopeThe inspectors reviewed the flood protection measures for equipment in the Unit 2 MotorDriven Auxiliary Feedwater Pump Room. The inspectors evaluated Dominion'sprotection of safety-related systems from internal flooding conditions. The inspectorsperformed a walkdown of the area, interviewed the system engineer, reviewed theinternalflooding evaluation, and verified that preventive maintenance was beingperformed on critical flood protection detection equipment to ensure that equipment andconditions remained consistent with those indicated in the design basis and floodingevaluation documents. Documents reviewed during the inspection are listed in theAttachment.b. FindinqsNo findings were identified..2 Inspection of Cable Vaultsa. Inspection ScopeThe inspectors inspected

3EMH *3A and 3
EMH. [[3B underground cable vaults in order todetermine if the safety related cables contained in the vaults were submerged in water.The inspectors also observed the condition of the cables, cable splices, cable supportstructures, and general condition of the vault to verify that there had not been significantdegradation. The inspectors discussed the results with the system engineer.b. FindinqsIntroduction: A self-revealing Green]]
NCV of 10

CFR Part 50, Appendix B, Criterion lll,Design Control," was identified for Dominion's failure to maintain safety related cables inan environment for which they were designed. Specifically, 480V safety related cables,Enclosure

9which are not qualified for continuous submergence, were submerged in a cable vault foran undetermined length of time.Description: On March 14,2011, Dominion opened up manhole

3EMH. 3B forinspection. 3
EMH. [[3B contains safety related and non-safety related cables for the Unit3'A'Engineered Safety Feature (ESF) building components. Upon opening themanhole, Dominion discovered that there was approximately four feet of water in thevault. After inspecting the vault and reviewing drawings, Dominion determined that the480V safety related cables for fan]]
3HVQ.FN 5A and
MCC 32-4T had been submergedfor an undetermined length of time.
MCC 32-4T loads include several safety relatedmotor operated valves (
MOV ) for Emergency Core Cooling Systems (ECCS). Accordingto
SP -M3-
EE -353, "Millstone Unit 3 Equipment Qualification Record," the cables are notqualified for submergence. A review of maintenance history revealed that
3EMH. [[3Bwas last inspected on October 20,2Q10. Dominion performed an operability review anddetermined that the equipment supplied from these cables was operable, based onvisual inspection of the cables, and recent operation of equipment serviced by thecables.Analvsis: The inspectors determined that Dominion's failure to maintain safety relatedcaUtes in an environment for which they were designed was a performance deficiency.The cause was reasonably within Dominion's ability to foresee and correct, and shouldhave been prevented. Traditional enforcement does not apply since there were noactual safety consequences, no impacts on the]]
NRC 's ability to perform its regulatoryfunction, and no willful aspects to the finding. A review of
IMC [[0612, Appendix E,"Examples of Minor lssues," revealed that the performance deficiency was not similar toany of the examples. The inspectors determined that the finding was more than minorbecause if left uncorrected, the performance deficiency would have the potential to leadto a more significant safety concern. Specifically, the inspectors noted that the insulationof continuously submerged cables would degrade more than dry or periodically wettedcables, which would lead to failures.Using]]

IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," theinspectors determined that the finding was of very low safety significance (Green)because the finding was not a design or qualification deficiency which resulted in a lossof operability or functionality, did not represent a loss of system safety function, did notrepresent an actual loss of safety function of a single train for greater than its- TechnicalSpecification allowed outage time, did not represent an actual loss of safety function ofone or more non-Technical Specification trains of equipment designated as risk-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and was not potentially risk significant due to aseismic, flooding, or severe weather initiating event'The inspectors determined that the finding had a cross-cutting aspect in the Problemldentification and Resolution cross-cutting area, Operating Experience component,because Dominion did not effectively implement Operating Experience to preventsubmergence of safety related cables. P.2(b)]Enclosure

10Enforcement:

10 CFR [[Part 50, Appendix B, Criterion lll, "Design Control," requires, inpart, that measures shall be established to ensure that applicable regulatoryrequirements and design bases are correctly translated into specifications, drawings,procedures, and instructions. Contrary to the above, from approximately October 20,2010, to March 14, 2011, Dominion failed to maintain the safety-related cables in cablevault 3]]
EMH [[*38 in an environment for which they were designed. Dominion tookimmediate corrective actions to remove the water from the cable vault. Because thisviolation was of very low safety significance (Green), and has been entered intoDominion's corrective action program (CR417729), this violation is being treated as anNCV, consistent with the]]
NRC Enforcement Policy. (
NCV 05000423/2011002-01,Failure to Prevent Safety Related Cables from Being Submerged)1R07 Heat Sink Performance (71111.7A- 1 sample)a. Inspection ScopeThe inspectors observed the as-found condition of the 'A'
EDG [[heat exchangers afterthey were opened to verify that any adverse fouling concerns were appropriatelyaddressed. The inspectors reviewed the results of the inspections against theacceptance criteria contained within the procedure to determine whether all acceptancecriteria had been satisfied. The inspectors also reviewed the Generic Letter 89-13responses to ensure that heat exchanger inspection results were consistent with theresponses. Documents reviewed during the inspection are listed in the Attachment.b. FindinqsNo findings were identified.1R1 1 Licensed Operator Requalification Proqram (71111.11 - 2 samples)Resident Inspector Quarterlv Review (71111.1 1O)a. Inspection ScopeThe inspectors observed simulator-based licensed operator requalification training forUnit 2 and Unit 3 on January 19, 2011. The inspectors evaluated crew performance inthe areas of clarity and formality of communications; ability to take timely actions;prioritization, interpretation, and verification of alarms; procedure use; control boardmanipulations; oversight and direction from supervisors; and command and control.Crew performance in these areas was compared to Dominion management expectationsand guidelines as presented in Dominion procedure]]

OP-MP-100-1000, "MillstoneOperations Guidance and Reference Document." The inspectors compared simulatorconfigurations with actual control board configurations. The inspectors also observedDominion evaluators discuss identified weaknesses with the crew and/or individual crewmembers, as appropriate. Documents reviewed during the inspection are listed in theAttachment.Enclosure

11b. FindinqsNo findings were identified.1R12 Maintenance Effectiveness (71111.12Q - 5 samples)a. Inspection ScopeThe inspectors reviewed five samples of Dominion's evaluation of degraded conditions,involving safety-related structures, systems and/or components for maintenanceeffectiveness during this inspection period. The inspectors reviewed Dominion'simplementation of the "Maintenance Rule,"

10 CFR 50.65. The inspectors reviewedDominion's ability to identify and address common cause failures, the applicableMaintenance Rule scoping document for each system, the current classification of thesesystems in accordance with 10
CFR 50.65 (aX1 ) or (a)(2), and the adequacy of theperformance criteria and goals established for each system, as appropriate. Theinspectors also reviewed recent system health reports,
CR [[s, apparent causedeterminations, functionalfailure determinations, operating logs, and discussed systemperformance with the responsible system engineer. Documents reviewed during theinspection are listed in the Attachment.The specific systems/components reviewed were:Unit 2r Pressurizer;. 120 Volt Non Vital Regulated Alternating Current (]]

AC) Power;o 480 Volt AC Motor Control Center;Unit 3o Main Steam; and. Service Water.FindinqsNo findings were identified.b.Enclosure

21 R13 Maintenance Risk Assessments and Emerqent Work Control (71111 . 13 - 6 samples)a. Inspection ScopeThe inspectors evaluated online risk management for emergent and planned activities.The inspectors reviewed maintenance risk evaluations, work schedules, and controlroom logs to determine if concurrent planned and emergent maintenance or surveillanceactivities adversely affected the plant risk already incurred with

OOS [[components. Theinspectors evaluated whether Dominion took the necessary steps to control workactivities, minimize the probability of initiating events, and maintain the functionalcapability of mitigating systems. The inspectors assessed Dominion's risk managementactions during plant walkdowns. Documents reviewed during the inspection are listed inthe Attachment. The inspectors reviewed the conduct and adequacy of riskassessments for the following maintenance and testing activities:Unit 2Yellow Risk for'B']]
HPSI Pump
IST Surveillance on January 25,2011;Yellow Risk for Facility 1 Emergency Core Cooling System (
ECCS ) Suction LineLeak Test on January 26,2011;Yellow Risk for inoperable 'B'
EDG with 'A'
EDG running to verify no common causefailure on March 31,2011;Unit 3Emergent risk assessment for'A' condenser backflush during the 'C' circulatingwater bay outage with the 'C'
SW pump
OOS on January 19,2011;Emergent work to repair Supplementary Leak Collection and Release System(SLCRS) boundary on February 11,201 1; andEmergent risk assessment (Yellow) due to failure of
3HVQ.AC [[]]
US 2B while restoringrelief valve
CCP "
RVS 9B with 'B' Engineered Safety Feature (ESF)
OOS on March 3,2011.Findin
SN o findings were identified.1R15 Operabilitv Evaluations (71111.15 - 5 samples)a. Inspection ScopeThe inspectors reviewed five operability determinations (OD). The inspectors evaluatedthe
OD s against the guidance contained in
NRC Regulatory lssue Summary
2QO 5-2Q,Revision to Guidance Formerly Contained in

NRC Generic Letter 91-18, "lnformation toLicensees Regarding Two NRC lnspection Manual Sections on Resolution of Degradedand Nonconforming Conditions and on Operability." The inspectors also discussed theconditions with operators and system and design engineers, as necessary. DocumentsEnclosureaa

b.13reviewed during the inspection are listed in the Attachment. The inspectors reviewed theadequacy of the following evaluations of degraded or non-conforming conditions:Unit 2.

CR 411667, Water Drained from Facility 1
ECCS Encapsulation Drain More thanNormal;.
CR 41 1479, Feedwater Temperature Indication
TE -5318 Erratic which challenged theoperability of the calorimetric calculation;.
CR 413310, Engineered Safety-Feature Actuation System (
ESAS ) Channel 'D'Bistable 8A409 potentiometer locking mechanism not functioning;.
CR 416871, Operability and Maintenance Rule questions on Unit 2
ECCS gassurveillance; andUnit 3.
IOD 000170 written to address the concern in
CR 415000 which covered theinstallation of incorrect parts in the'B', 'C', and 'D'
SW strainers.FindinqsNo findings were identified.Plant Modifications (71111.18 - 1 sample)1R18a. Inspection ScopeThe inspectors assessed the adequacy of
DM [[2-00-0001-1 1, "Design Change Requiredto Remove Failed Facility 2 Proportional Heater," Revision 11, which is a temporarymodification. The inspectors walked down the system and components, interviewedplant staff, and reviewed applicable documents, including procedures, calculations,modification packages, engineering evaluations, drawings, corrective action programdocuments, the Updated Final Safety Analysis Report (UFSAR), and TechnicalSpecifications (TS).For the modification reviewed, the inspectors determined whether selected attributes(component safety classification, energy requirements supplied by supporting systems,seismic qualification, instrument setpoints, uncertainty calculations, electricalcoordination, electrical loads analysis, and equipment environmental qualification) wereconsistent with the design and licensing bases, Design assumptions were reviewed toverify that they were technically appropriate and consistent with the]]
UFSAR. For eachmodification, the 10
CFR 50.59 screenings or safety evaluations were reviewed. Theinspectors also verified that procedures, calculations, and the
UFS [[]]

AR were properlyupdated with revised design information. In addition, the inspectors verified that the as-built configuration was accurately reflected in the design documentation and that post-modification testing was adequate to ensure the structures, systems, and componentsEnclosure

14would function properly. Documents reviewed during the inspection are listed in theAttachment.b. FindinqsNo findings were identified.1R19 PostMaintenance Testinq (71111.19 - 8 samples)a. Inspection ScopeThe inspectors reviewed eight post-maintenance test (PMT) activities to determinewhether the

PMT [[adequately demonstrated that the safety-related function of theequipment was satisfied, given the scope of the work specified, and that operability ofthe system was restored. ln addition, the inspectors evaluated the applicable testacceptance criteria to evaluate consistency with the associated design and licensingbases, as well as]]
TS requirements. The inspectors also evaluated whether conditionsadverse to quality were entered into the corrective action program for resolution.Documents reviewed during the inspection are listed in the Attachment. The followingmaintenance activities and
PMT s were evaluated:Unit 2
OP 23458, "120 Volt Vital Instrument
AC System," Revision 017-02 followingReplacement of the Capacitors on Inverter 6 on January 5,2Q11;
SP 26128-003, "'C'SW Pump and Facility 2 Discharge Check Valve lST," Revision002-08 and
SP 26128-005, "'C'SlV Pump Comprehensive Pump Test," Revision000 following 'C'
SW strainer overhaul on February 12,2011;SP 2613L, "Periodic
EDG Slow Start Operability Test, Facility 2 (Loaded Run),"Revision 004-08 and
SP 26248, "'B'
EDG Starting Air Vent Valve l
ST ," Revision 002-05 following replacement of starting air valves and differential relay calibrations onthe 'B'
EDG on March 2,2Q11:Unit 3
SP 3626.3, "SW Valve Operability Tests," Revision 010-08, following maintenanceon
3SWP *
MOV 57A and
3SWP.MO V57C on January 19,2011;
SP 3626.6, "SW Pump
3SWP.P 1C Comprehensive TeSt," Revision 0-01, followingrefurbishment of the 'C'
SW pump on January 29,2011;SP 3608.2, "safety Injection Pump'B'Quarterly
IST Pump Test," Revision 010,foflowing maintenance on the 'B'
SIH pump on February 25,2011;EN
31096 PMT following restoration of 3
HVQ.AC US2B following plannedmaintenance on March 2, 2011; andWO53O1 12601973/CR415773 following maintenance on
3HVC "

ACUlB on March 3,2011.Enclosure

b.15FindinqsIntroduction: A self-revealing Green

NCV of 10
CFR Part 50, Appendix B, Criterion V,"lnstructions, Procedures, and Drawings," was identified for Dominion's failure toproperly restore
3HVQ.AC [[]]
US 2B, "Containment Recirculation Pumps and Coolers Area'B' Air Conditioning Unit," following maintenance. This resulted in an additional24 hoursof inoperability of the 'B' train of the
RSS.D escription: On March 2,2011, at 3:46 a.m., Unit 3 removed 3
HVQ.AC US2B fromservice for planned maintenance. Technical Specifications limiting condition foroperations (LCO) 3.5.2 and 3.6.2.2 were entered. The equipment was returned toservice and the
TS s were exited that afternoon at 1:50 p.m. On March 3,2011, at 10:Q7a.m., 3
HVQ.AC US2B failed to start. Dominion entered unplanned
LCO actions
TS [[3.5.2and 3.6.2.2. An initial investigation determined that the compressor low oil pressureswitch (3HVQ.PDS10228)was tripped and had not been reset following the calibrationof the switch the previous day. The switch was reset, the air conditioning run wassuccessful, and the]]
TS [[]]
LCO [[s were exited at 1:35 p.m.Further investigation determined that operations personnel did not properly align the airconditioning unit for automatic operation as specified in the tagging cover sheet for theswitch calibration. An interview with the l&C technician revealed that he did not realizethat the switch was tripped following the calibration.Analvsis: The inspectors determined that Dominion's failure to follow the instructions onthe tagging cover sheet for restoration of]]
3HVQ.AC [[]]
US 2B was a performance deficiency.The cause was reasonably within Dominion's ability to foresee and correct, and shouldhave been prevented. Traditional enforcement does not apply since there were noactual safety consequences, no impacts on the
NRC [['s ability to perform its regulatoryfunction, and no willful aspects to the finding. The inspectors determined that the findingwas more than minor because it was associated with the Human Performance attributeof the Mitigating Systems cornerstone, and affected the cornerstone objective ofensuring the availability, reliability, and capability of systems that respond to initiatingevents to prevent undesirable consequences. Specifically, Dominion's failure to followthe written instructions in the tagging cover sheet caused the'B'train of]]

RSS to beinoperable for approximately an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.Using IMC 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings," theinspectors determined that the finding was of very low safety significance (Green)because the finding did not represent a loss of system safety function, did not representan actual loss of safety function of a single train for greater than its TechnicalSpecification allowed outage time, did not represent an actual loss of safety function ofone or more non-Technical Specification trains of equipment designated as risk-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and was not potentially risk significant due to aseismic, flooding, or severe weather initiating event. The inspectors determined that thefinding had a cross-cutting aspect in the Human Performance cross-cutting area, WorkPractices component, because operations personnel did not follow the instructions onthe tagging cover sheet when returning the air conditioning unit to service. H.4(b)]Enclosure

16Enforcement:

10 CFR [[Part 50, Appendix B, Criterion V, "lnstructions, Procedures, andDrawings," requires, in part, that activities affecting quality shall be prescribed bydocumented instructions, procedures, or drawings of a type appropriate to thecircumstances, and shall be accomplished in accordance with these instructions,procedures, or drawings. Contrary to the above, Dominion did not accomplish the taskin accordance with instructions on the tagging cover sheet when returning the airconditioning unit to service from March 2, 2011, at 1:50 p.m. until March 3, 2011, at 1:35p.m., which resulted in the 'B' train of]]
RSS being inoperable for approximately anadditional 24 hours. Because this violation was of very low safety significance (Green),and has been entered into Dominion's corrective action program (CR415899,CR415954,
CR 417419), this violation is being treated as an
NCV [[, consistent with theNRC Enforcement Policy. (NCV 05000423/2011002-02, lmproper Restoration of AirConditioning Equipment Following Maintenance Results in Inoperability of 'B'Train of Recirculation Spray System1R22 Surveillance Testinq (71111.22 - 7 samples)a. lnspection ScopeThe inspectors reviewed seven surveillance activities to determine whether the testingadequately demonstrated equipment operational readiness and the ability to perform theintended safety-related function. The inspectors attended pre-job briefings, reviewedselected prerequisites and precautions to determine if they were met, and observed thetests to determine whether they were performed in accordance with the proceduralsteps. Additionally, the inspectors reviewed the applicable test acceptance criteria toevaluate consistency with associated design bases, licensing bases, and]]
TS [[requirements and that the applicable acceptance criteria were satisfied. The inspectorsalso evaluated whether conditions adverse to quality were entered into the correctiveaction program for resolution. Documents reviewed during the inspection are listed inthe Attachment. The following surveillance activities were evaluated:Unit 2.]]
CP 2802N, "Primary Coolant Sampling and Analysis," Revision 000-03;.
OP 2602A, "Reactor Coolant Leakage," Revision 006-01;.
SP 2611B, "'C'
RBCCW Pump Tests," Revision 009;.
SP 2605W, "Leak Testing of Containment Sump Header Piping, Facility 1 andFacility 2," Revision 000-02;Unit 3.
3CHS *P3C, Charging Pump quarterly
IST on January 11, 2011;.
SP 36464.13,

EDG 'B' Lockout Test," Revision 01 on February 8,2011; and. SP 3601F.6, "Reactor Coolant System Water Inventory Measurement," Revision006-03.Enclosure

17b.FindinqsNo findings were identified.RADIATION

SAFETY Occupational Radiation Safety2
RS [[01 Radioloqical Hazard Assessment and Exposure Controls (71 124.01)a. lnspection ScopeDuring the period February 28, 2011, through March 3,2011, the inspectors conductedthe following activities to verify that Dominion was evaluating, monitoring, and controllingradiological hazards for work performed in locked high radiation areas (LHRA) and otherradiological controlled areas. The inspectors also confirmed that workers were adheringto these controls when working in these areas. lmplementation of these controls wasreviewed against the criteria contained in]]
10 CFR 20,
TS [[, and with Dominion'sprocedures.Radioloqical Hazards Control and Work CoveraqeThe inspectors identified recent work performed in radiological controlled areas in Unit 2and Unit 3 and evaluated Dominion's assessment of the radiological hazards. Theinspectors reviewed exposure control evaluations and radiation work permits (RWP)associated with these areas to determine if the associated controls were acceptable.Specific work activities evaluated included the troubleshooting, planning, and repair ofvatve 2-FW-2618 (AEs 2-10-03/04/05 respectively), and replacement of the Unit 3 'C'charging pump rotating assembly (AE3-10-16).Additionally the inspectors reviewed the Radiation Work Permits (RWP) developed forwork to be performed during 2011, including the Spring Unit 2 (2R20) refueling outage.The inspectors reviewed the electronic dosimeter dose/dose rate alarm set points statedon the]]
RWP [[to determine if the set points were consistent with the survey indicationsand plant policy.Problem ldentification and ResolutionA review of Nuclear Oversight field observation reports, dose/dose rate alarm reports,personnel contamination event reports and associated]]

CRs, was performed to determineif identified problems and negative performance trends were entered into the correctiveaction program and evaluated for resolution and to determine if an observable patterntraceable to a similar cause was evident.Relevant CR's, associated with radiation protection control access initiated November2010 through January 2011, were reviewed and discussed with Dominion stafftodetermine if the follow up activities were being performed in an effective and timelymanner, commensurate with their safety significance.Enclosure

18b. FindinqsNo findings were identified.2RS02 Occupational

ALARA [[Planninq and Controls (71124.02)a. Inspection ScopeDuring the period February 28,2011, through March 3,2011, the inspectors conductedthe following activities to verify that Dominion was properly implementing operational,engineering, and administrative controls to maintain personnel exposure as low asreasonably achievable (]]
ALARA ) in making preparations for the spring refueling outage(2R20).lmplementation of this program was reviewed against the criteria contained in
10 CFR [[20, applicable industry standards and with Dominion's procedures.Radioloqical Work PlanninqThe inspectors reviewed the preparations being made for performing radiologicalsignificant tasks during the spring 2011 Unit 2 refueling outage (2R20). Included in thisreview was the]]
ALARA [[Plans (AP)for all of the jobs whose dose was estimated toexceed 5 person rem. These jobs included reactor vessel disassembly/re-assembly (AP2-11-01), steam generator (SG) corrective & preventative maintenance activities (AP 2-11-09), scaffolding installation/removal (AP 2-11-13), 'C' reactor coolant pumpmotor/seal replacement (AP 2-1 1-16), and radiation protection support activities (AP 2-11-26).In performing this review, the inspectors evaluated contamination control measures, useof portable ventilation systems, use of temporary shielding, and the control of systemdrain-downs. Additionally, the inspectors evaluated the departmental interfaces betweenradiation protection, operations, maintenance crafts, and engineering to identify missingALARA program elements and potential interface problems. The evaluation wasaccomplished by reviewing recent]]
ALARA Committee meeting minutes, NuclearOversight Reports, and interviewing the site Radiation Protection Manager and the
ALARA Supervisor regarding the spring 2R2O preparations'Problem ldentification and ResolutionThe inspectors reviewed
CR , Nuclear Oversight field observations, and
ALARAC ommittee meeting minutes to evaluate the threshold for which
AL [[]]

AM related issuesare entered into the corrective action program, the comprehensiveness of the causeevaluation, and the effectiveness of the corrective actions'Enclosure

19b. FindinqsNo findings were identified.2RS03 ln-Plant Airborne Radioactivitv Control and Mitiqation (71124.03)a. Insoection ScopeDuring the period February 28,2011, through March 3,2011, the inspectors conductedthe following activities to verify that in-plant airborne concentrations of radioactivematerials are being controlled and monitored, and to verify that respiratory protectiondevices are properly maintained and used by qualified personnel.lmplementation of these programs was evaluated against the criteria contained in

10CFR [[20, applicable industry standards, and with Dominion's procedures.Enqineerinq ControlsThe inspectors verified that Dominion uses installed ventilation systems as part of itsengineering controls (in lieu of respiratory protection devices) to control airborneradioactivity. The inspectors reviewed procedural guidance for use of an installedsystem, the Unit 2 Control Room emergency ventilation system, also known as theControl Room Air Conditioning System (]]
CRACS ), and determined that the system wasoperable. The inspectors reviewed surveillance testing procedures and related data toconfirm that the airflow capacity, flow path, and charcoal/HEPA filter efficiencies met
TS [[operating criteria and are consistent with maintaining concentrations of airborneradioactivity as low as practicable. Also reviewed were the radiation detector calibrationrecords for installed monitors (9799 A/B) and testing records that the system realigned atthe appropriate radiation level. The inspectors reviewed the]]
CRACS system healthreport and
CR to evaluate current operating status. With the assistance of the plantsystem engineer, the inspectors verified the system configuration by walking downcomponents.The inspectors evaluated the use of portable continuous air monitors (
AMS -4) andportable
HEPA ventilation systems that are used during refueling outages, at worklocations where airborne contamination may occur. The inspectors reviewed thecalibration records for
AMS -4 monitors to determine if the instruments were operableand that their alarm set points were appropriately established. The inspectors reviewedtesting records for portable
HE [[]]

PA ventilation systems to determine that proceduralrequirements were met.Through review of relevant procedures and analytical data, the inspectors determinedthat Dominion has established an alpha and transuranic monitoring program. Includedin this program were trigger levels for conducting additional measurements to assurethat the airborne concentrations were properly characterized and that bioassaymeasurements would be taken should the monitoring threshold be reached.Enclosure

b.20Use of Respiratorv Protection DevicesThe inspectors observed the respirator fit testing on one individual to determine if thetesting was appropriately conducted per the procedural guidance. Additionally, theinspectors confirmed that the individual tested had completed the requisite training andwas medically qualified to wear a respirator.The inspectors examined various negative pressure and self-contained respiratoryprotection devices and determined that these devices were certified for use by theNational Institute for Occupational Safety and Health/Mine Safety and HealthAdministration (NIOSH/MSHA).Self-Contained Breathinq Apparatus for Emerqencv UseThe inspectors evaluated the adequacy of the respiratory protection program regardingthe maintenance and issuance of self-contained breathing apparatus (SCBA) toemergency response personnel. Training and qualification records were reviewed for atleast ihree licensed operators from each of the operating shifts, and for selectedradiation protection personnel who would wear

SCBA s in the event of an emergency.The inspectors observed a technician perform functional inspections on five randomlyselected
SCBA staged in the Unit 2 and Unit 3 control rooms. Maintenance, flow alarmtests, and regulatoiflow test records for these
SCBA were reviewed. Air sample resultswere reviewed to confirm that the tank air quality met
CGA G-7 '1, Grade D (2004)standards. Through review of training lesson plans and interviews, the inspectorsconfirmed that individuals qualified to wear
SCBA were trained in replacing spent aircylinders.Problem ldentification and ResolutionThrough review of
CR , Nuclear Oversight field observations and the
CRA [[]]

CS systemhealth report, the inspectors verified that problems associated with the control andmitigation of in-plant airborne radioactivity are being identified at an appropriatetnreihold and are properly addressed for resolution in the corrective action program'FindinqsNo findings were identified.Enclosure

214.

OTHER [[]]
ACTIVI TIES
IOAI 4

OA1 Performance lndicator (Pl) Verification (71151)Cornerstone: lnitiatinq Eventsa. Inspection Scope (4 Samples)4c42.1a.b.The inspectors reviewed Dominion submittals for the Pls listed below to verify theaccuracy of the data reported during that period. The Pl definitions and guidancecontained in Nuclear Energy Institute (NEl) 99-02, "Regulatory Assessment IndicatorGuideline," Revision 5, were used to verify the basis for reporting each data element.The inspectors reviewed portions of the operations logs, monthly operating reports, andLicensee Event Reports (LER) and discussed the methods for compiling and reportingthe Pls with cognizant licensing and engineering personnel. Documents reviewed duringthe inspection are listed in the Attachment.Unit 2r Reactor Coolant System ActivitY;r Reactor Coolant System Leakage;Unit 3r Reactor Coolant System Activity; andr Reactor Coolant System Leakage.FindinqsNo findings were identified.ldentification and Resolution of Problems (71152)Review of ltems Entered into the Corrective Action ProqramInspection ScopeAs required by Inspection Procedure71152, "ldentification and Resolution of Problems,"and in order to help identify repetitive equipment failures or specific human performanceissues for follow-up, the inspectors performed a daily screening of items entered intoDominion's corrective action program. This was accomplished by reviewing thedescription of each new CR and attending daily management review committeemeetings. Documents reviewed during the inspection are listed in the Attachment.Enclosure

b.22FindinqsNo findings were identified.Annual Sample: Unit

3 EOP 3506. Loss of All Charqinq Pumpslnspection Scope (1 sample)The inspectors reviewed Dominion's implementation of changes to Unit 3 EmergencyOperating Procedure (
EOP ) 3506 and corrective actions associated with issuesidentified with this procedure's deviation from Westinghouse Owners Group (WOG)Emergency Response Guidelines (ERG). Related
CR [[s and associated actions werereviewed against the requirements of Dominion's corrective action program to ensure thefull extent of the issues were identified, appropriate evaluations were performed, andappropriate corrective actions were specified and prioritized. The inspectors interviewedrelevant station personnel and reviewed]]
WOG [[]]
ERG background documents, procedurechange documentation, and
EOP [[deviation documents. Documents reviewed during theinspection are listed in the Attachment.Findinqs and ObservationsNo findings were identified. The inspectors determined that initial proposed correctiveactions were closed without appropriately addressing the issue of concern. After theNRC inspectors raised the issue a second time, Dominion initiated a second]]
CR anddeveloped and prioritized corrective actions to address the problem.Dominion had developed
EOP 3506 to implement an event mitigation strategy thatdeviated from the industry standard
EOP mitigation strategy provided by the
WOGERG s. This new strategy had the operators exiting the
WOG [[]]
ERG network andconducting a plant cooldown and depressurization in the operating procedures, if acharging pump could not be promptly restored. This revised strategy had previouslybeen considered by the
WOG in 1984 and determined not to be necessary orappropriate. Dominion elected to implement the revised strategy without revisiting theoriginal
WOG decision based on new insights since 1984. While licensees may deviatefrom the
WOG [[]]
ERG [[network, these deviations should only be justified based on sitespecific equipment variations. Deviating from the fundamental event mitigation strategy,based entirely on non-site specific event strategy approaches, is not appropriate withoutfirst approaching the Owners Group for additional consideration and guidance by theindustry experts.CRs 395584 and 395591 were initiated in September 2010 to address identifiedproblems with the]]
EOP status of
EOP 3506 and the guidance in
OP 3272, "
EOP UsersGuide," relating to parallel use of
ERG derived procedures with non-
ERG [[]]
EOP s. These
CR s were subsequently closed to an action tracking system outside of the correctiveaction process. In February 2011, the inspectors identified that no changes had beenimplemented to
ES -O.1,
EOP 3506 or
OP 3272. Subsequently,

CR 416445 was initiatedto re-address the problem. lt was determined that EOP 3506 cannot be properly.2a.b.Enclosure

40A323implemented as written in light of conflicts with

ES 0.1 goals and
EOP Users Guideparallel performance requirements. Corrective actions were defined to return MillstoneUnit
3 EOP s into alignment with the
WOG [[]]
ERG s by:. Changing
EOP 3506 to an
AOP ;. Deleting guidance in 3506 for the cooldown / depressurization strategy; ando Modifying rules of usage for non-
ERG derived
EOP s to clarify they are notincluded in the exemption from the 'parallel use' requirement (an exemption isallowed for other procedures such as
GA s,
AOP s and
EOP -related sections ofOPs).The inspectors screened the procedure compliance issues in accordance with
NRC lnspection Manual Chapter (l
MC ) 0612 Appendix B, "lssue Screening," and determinedthat they constitute issues of minor significance that are not subject to enforcementaction in accordance with the
NRC [['s Enforcement Policy.Event Follow-up (71153 - 2 samples)Unit 2 Unplanned Power Transient durinq Control Valve TestinqInspection ScopeOn February 12,2011, Millstone Unit 2 experienced an unplanned power transient whileconducting turbine control valve testing. Several human errors by the control room teamcaused reactor power to increase from 88 percent to 96 percent over approximatelythree minutes. The event was categorized as a level 2 reactivity management event inaccordance with]]
OP -AA-300, "Reactivity Management".The inspectors evaluated the adequacy of operator actions in accordance with approvedprocedures and
TS [[requirements. The inspectors performed walkdowns of the controlroom and interviewed personnel. The inspectors also reviewed the sequence of eventsinformation in order to determine if there were any other plant or equipment anomalies.ln response to this event, a determination was made using the decision process inInspection Manual Chapter 0309 to send a Special inspection Team (SlT) from Region 1to conduct the follow up investigation.FindinqsAny findings as a result of the inspection effort by this]]

SIT will be documented in theSpecial Inspection report 05000336/201 1008, due to be published soon..1a.b.Enclosure

,124(Closed)

LER [[05000336/2010-003. Reactor Trip on Low Condenser Vacuuma. lnspection ScopeOn November 28, 2010, Millstone Unit 2's reactor automatically tripped from 100 percentpower. Prior to the event, Millstone was establishing conditions to perform a backwashof the 'B' condenser water box. Operators pressed the stop pushbutton for the 'B'circulating water (]]
CW ) pump and were closing the 'A' and 'B'water box outlet valveswhen the 'A'
CW [[pump automatically ramped off. Upon loss of the second pump in thecondenser, the condenser vacuum degraded to the low condenser vacuum trip set point,causing an automatic turbine generator trip which then caused an automatic reactor trip.b. FindinqsThis issue was previously documented in]]
NRC Inspection Report 05000336/2010005 asa Green finding. The
LER was reviewed and no additionalfindings were identified. This
LER is closed.4OA5 Other ActivitiesInstitute of Nuclear Operators (INPO) Evaluation ReportInspection Scope (1 Sample)The inspectors reviewed the report for the
INPO plant assessment of Millstone NuclearGenerating Station conducted August 2010. The inspectors reviewed the report toensure that issues identified were consistent with the
NRC perspectives of Millstoneperformance and to verify that the
INPO team did not identify any safety significantissues requiring further
NRC follow-up.FindinqsNo findings were identified.(Closed) Notice of Violation (NOV) 05000423/2010011-01 - Failure to Develop aMitiqation Strateqv Required bv
10 CFR 50.54(hh)lnspection Scope (1 Sample)The inspector reviewed the actions taken by Dominion to address the issues identified inan
NOV documented in
NRC inspection report 05000423/201001 1 , concerning a singlestrategy put in place as required by 10

CFR 50.54 (hhx2xii) and License Condition2.C.(10). These actions included additional staged equipment, engineering justifications,and implementing procedure changes. The inspector concluded that the actions takenaddressed the technical issues and provided an adequate level of confidence that theassociated strategy could be accomplished successfully.a.b..2a.Enclosure

b.25FindinqsNo findings were identified.Meetinqs. includino ExitExit Meetino SummarvOn April 20,2011, the resident inspectors presented the overall inspection results to Mr.A.

J. Jordan and members of his staff. The inspectors confirmed that no proprietaryinformation was provided or examined during the inspection.
ATTACH MENT:
SU [[]]
PPLEME NTAL
INFORM [[]]

ATIONEnclosure

Dominion personnelL. ArmstrongR. ArquaroG. AuriaB. BarronB. BartronE. BrodeurW. ChestnutF. CietekT. ClearyG. ClosiusL. CroneJ. CurlingJ. DoroskyB. FergusonM. FinneganA. GharakhanianW. GormanJ. GroganK. GroverC. HouskaA. JordanB. KellyK. KeithJ. KunzeJ. LaineR. MacManusG. MarshallM. MartellM. NoniewiczM. O'ConnorR. ParretteD. ReedR. RileyM. RocheD. RoweL. SalyardsM. SartainJ. SemancikM. SibiliaA. SmithD. SmithS. SmithA-1SUPPLEMENTAL

INFORM [[]]
ATIONK EY
POINTS [[]]
OF [[]]
CONTAC [[]]
TM anager, TrainingUnit 3 Shift ManagerNuclear Chemistry SupervisorManager, Nuclear OversightSupervisor, LicensingShift ManagerSupervisor, Nuclear Shift Operations Unit 2Nuclear Engineer,
PRAL icensing EngineerLicensing EngineerSupervisor, Nuclear ChemistryManager, Protection ServicesHealth Physicist lllNuclear Quality Assurance SpecialistSupervisor, Health Physics,
ISFSIN uclear Engineer lllSupervisor, Instrumentation & ControlAssistant Operations ManagerManager, Nuclear Operationsl&C TechnicianSite Vice PresidentUnit 3 Work Control
SR [[]]
OU [[nit 3 Unit SupervisorSupervisor, Nuclear Operations SupportManager, Radiation Protection/ChemistryDirector, Nuclear Station Safety & LicensingManager, Outage and PlanningUnit 3 Shift ManagerUnit 3 Reactor OperatorNuclear Specialist, Outage and PlanningOperations Manager on-CallUnit 3 Shift ManagerSupervisor, Nuclear Shift Operations Unit 3Senior Nuclear Chemistry TechnicianShift ManagerLicensing, Nuclear Technology SpecialistDirector, Nuclear EngineeringPlant ManagerUnit 3 Balance of Plant OperatorAsset ManagementManager, Emergency PreParednessManager, EngineeringAttachment]]
J. StoddardS. TurowskiC. Vournazos
LIST [[]]
OFO pened and Closed0500042312011002-0105000423i2011002-02Closed05000336/201 000305000423/2010011-01A-2Unit 3 Shift ManagerSupervisor, Health Physics Technical ServiceslT Specialist, Meteorological Data
ITEMS [[]]
OPENED ,
CLOSED ,
AND [[]]
DISCUS [[SEDNCV Failure to Prevent Safety Related Cables from BeingSubmerged (Section 1R06)NCV lmproper Restoration of Air Conditioning EquipmentFollowing Maintenance Results in Inoperability of 'B'Trainof Recirculation Spray System (Section 1R19)LER Reactor Trip on Low Condenser Vacuum (Section]]
4OA 3)
NOV Failure to develop a mitigation strategy required by
10 CFR 50.54(hh) (Section 4
OA 5)LIST
OF [[]]
DOCUME NTS
REVIEW [[]]
EDS ection 1R01: Adverse Weather ProtectionAOP 2560, "Storms, High Winds and High Tides," Revision 010-04AOP 3569, "severe Weather Conditions," Revision 016-00C
OP 200.6, "storms and Other Hazardous Phenomena (Preparation and Recovery)," Revision002-01Section 1R04: Equipment Aliqnmentrt 4th Quarter 2009 and 2010Containment Spray System Unavailability 2009 and 2010
OP [[2308-002, "HPSI System Valve Alignment, Facility 2," Revision 000-03OP 2309-001, "CS System Valve Alignment Verification, Facility 1," Revision 000-04OP 23Og-002, "CS System Valve Alignment Verification, Facility 2," Revision 000-05OP 2346A-011, "'A']]
DG Service Water Valve Alignment," Revision 000-03
OP 2346A-012, "'A'
DG Starting Air Valve Alignment," Revision 000-00
OP 23464-013, "'A'
DG Jacket Water Valve Alignment," Revision 000-02

OP 23464-014,"'A'DG Lube OilValve Alignment," Revision 000-02OP 23468-002, "'A'DG Fuel OilValve Alignment," Revision 000-00OP 33044-001, 'MB3 Charging and Letdown Lineup," Revision 005-03OP3304A-003, "Charging and Letdown Lineup," Revision 013-04OP 3326-002, "Train 'B' Service Water System," Revision 010-03OP 3326-008, 'EDG 'B' Service Water System Supply," Revision 004-01OP 3326-010, "service Water System - Control Building Air Cond 'B' Supply," Revision 007-02OP 3926-014, "ESF Bldg Emergency Ventilation 'B' Service Water System Supply," Revision008-01OP 3326-017, 'RSS Train 'B' Service Water System Supply," Revision 004-01Attachment

A-3OP3346B Attachment 4, "Valve lineup for'B' Diesel Fuel Oil," Revision

4OP 3346B AttachmentT, "'B' Diesel Fuel Oil Electrical Alignment," Revision 1
OP 3346B Attachment 2, 'EDG 'B'- Cooling Water Valve Lineup," Revision
7MRE 010544
MREO [[10606MRE011182MRE011252MRE011367MREo11631MRE01163253102314764cR-05-07023cR363499cR393939cR412290Section 1R05: Fire ProtectionMillstone Unit 2 Fire Hazards Analysis, Revision 1 1Millstone Unit 2 Fire Fighting Strategies April 2005Fire Brigade Drill and Assessment for Unit 3 Turbine Building 38'6"]]
MCC 32-2A Cabinet 14DcR417179Section 1R06: Flood Protection MeasuresW2-517-1070-
RE , "Unit 2 Internal Flooding Evaluation," Revision 0System Health Report, Station Sumps and Drains 4th Quarter
2010MRE 01161053M208002035310226629053102266292Section 1R07: Heat Sink Performance
ER -AA-HTX-1002, "Heat Exchanger Inspection Form", Revision
1MP 2701J-096, "Heat Exchanger'As Found' Inspection Checklist," Revision 007-01Section 1Rl1: Licensed Operator Requalification ProqramMillstone Unit 2
ES 11101A, "Unit
2 LORT Evaluated Simulator Exam," Revision 0Millstone Unit 3
LORT Exam
SE 50, Revision 2Section 1 Rl2: Maintenance Effectiveness96-001, "Ernpirical Adjustment of the
MP #
SW Model to 1995 Flow Test Data and Incorporationof the Latest
SW System Design Change Notices," Revision
01EN 31 121, "l
ST Pump Operational Readiness Evaluation," Revision 7System Health Report, Main Steam Vents and Drains and
SG Blowdown, 4tn Quarter 2010System Health Report, Reactor Coolant,.4th Quarter 2009 and 4th Quarter 2010System Health Report, Service Water, 4tn Quarter 2010System Health Report, 120Volt
AC Distribution, 4'n Quarter 2009System Health Report, 120 Volt
AC Distribution and Vital Regulated Instrument

AC, 4th Quarter2010Attachment

A-4System Health Report, 480 Volt

AC [[]]
MCC , 4th Quarter 2009 and 4th Quarter 2010Maintenance Rule Scoping TablesMillstone Unit 2, Maintenance Rule Scoping TablesMillstone Unit 2, Pressurizer Unavailability, January 2009 - December 2010Millstone Unit 2, 480 Volt
MCC Unavailability February 2009 - January 2011Millstone Unit 3, Service Water Unavailability, February 2009 - January 2Q11Millstone Unit 3, 3
MSS.MO [[V74A-D Unavailability February 2009 - January 2011cR111344cR347716cR357873cR409403MREo10244MREO10266MREo10288MREO10518MREo10524MREo10528MREo10804MREo10805MREo10809MREo10814MREo10845MRE011016MREO11262MRE011266MREo11308MRE011410MRE011426MRE011434MRE011453MREo11602MREO11608MREo11621MREo1]]
1805MRE o11902

MREo11907MREo11909MREo11925MREo12002MREO12070MREo12080MREo12087MRE012121MREo12123MRE012127MREo12128MREo12134MREo12160Attachment

A-5MREo12299MREo12332MREo12430MREo12431MREO12470MREo12510MREO12573MREo12574MREo12713MREO12730MREo12731MREo12762MREo12846MREo12904MREo12941MREo13045Section 1R13: Maintenance Risk Assessments and Emerqent Work GontrolOP

3325A. 1, "Condenser Backflush of Circulating Water Bays," Revision 000-03
OP [[3327, "Travelling Screen Wash," Revision 019-08SP 2605W, "Leak Testing of Containment Sump Header Piping, Facility 1 and Facility 2,"Revision 000-02NERF 2011015, "Condition Discovered on February 13,2011 could have prevented fulfillmentof Safety Function to control release of radioactive material"CR 413480,"ESF Building]]
SLCR s Boot Tears in 2 Locations, 'A' Sl Pump Cubicle," datedFebruary 11,2011
CR [[415899, "3HVQ*ACUS2B did not start when manual start was attempted," dated March 3,2011wo530112601973Section 1Rl5: Operabilitv Evaluations0zooSafetyParametersFunctionalTeSt,Revision003-02Section 1Rl8: Plant ModificationsSP 2602E, "Pressurizer Heater Capacity Test," Revision 000-0053102405192cR409465Section 1Rl9: Post Maintenance TestinqOP 3314D,]]
ES f euitOing Ventilation and Air Conditioning," Revision 011-04Tag Out Coversheet for Calibration of 3
HVQ.AC US2B Low Oil Pressure Shutdown & AlarmDifferential Pressure SwitchMillstone Unit 3 Control Room Logs, March 2,2011 and March 3,2Q11AWO 53102378189, "Oil Change due to Pump oil Sample in'Monitor'Status"SP 3608.2, "safety lnjection Pump'B'Quarterly
IST Pump Test", Revision 010
SP 3626.3, "service Water Operability Tests," Revision 010-08Sp 3626.3-012, '3SWP.MOVs7A and
MOVS 7C,

RSS Cooler outlets, Stroke Time," Revision002-05Attachment

A-6MP-2O-WP-GLD 40, Attachment 453M2040161953M2040451353M2060437153M2070047353M2070576953M2070705853M2080496453M2080642653M306016645310231723953102358457531023589315310236174453102368939531 02379895531 02601 973cR409570cR410793cR410870cR410892cR410893cR410900cR410929cR411121cR41 1 136cR411154cR411159cR41 1 159cR411217cR411172cR41 1239cR411262cR41 1256cR411257cR413162cR413350cR413583cR413473cR415773cR415954cR415899cR417419Section 1R22: Surveillance TestinsCp ZgOZNf,;?rimary Systems Sampling and Analysis," Revision 000-03SP 2602A, "Manual

RCS Leak Rate Determination," Revision 006-02

SP 26118-002, "'C'RBCCW Pump lST," Revision 002-01Attachment

A-7SP 36044.3, "Charging Pump'C'Operational Readiness Test," Revision 011-Q4SP

3604A. 3-001, "3
CHS *P3C Quarterly
IST Pump Test (Two Charging Pumps Aligned forService)," Revision 01 3
SP 21157, "HPSI System and
ECCS Suction Leak Test," Revision 008-02
SP [[]]
3601F. 6, "Reactor Coolant System Water Inventory Measurement," Revision 006-03
SP [[]]
3601F. 6-001, "
RCS Inventory Balance"C
OP 200.15, "
RCS Leakage Trending and lnvestigation," Revision 001-01cR41
1667CR 415760, "Procedure change requested for
SP [[]]
3601F. 6,
RCS [[Water Inventory Measurement"MitisationProceduresSP %042112, Revision 2,]]
CRACS Facility Z1t2 Area Radiation Monitor
RIT -9799 A/B FunctionalTestSP 24O4BA112, Revision 1, Control Room Ventilation Radiation Monitor
RM -9799 A/
BC alibrationRPM 2.2.6, Revision 12, Continuous Air MonitorsRPM 4.1.11, Revision 3,
AMS -4 Air Monitoring System Calibration
SFP 24, Revision 3, Inspection and Inventory of Self Contained Breathing ApparatusRPM 2.3.1, Revision 7, Quantitative Respirator Fit Testing Using the
TSI Porta Count
RP -M-300, Revision 4,
ALARA Reviews and Reports
RP -M-26, Revision 0, Alpha MonitoringRpM 2.4.3, Revision 5,
DOP Testing of Portable
HEPA 9-RSP-PRG, Revision 4, Respiratory ProtectionRPM 5.4.1, Revision 7, lssue and Control of Respiratory Protection EquipmentEN 21235, Revision 3, Millstone Unit 2 Radiation Monitor High Radiation Set-pointsCondition Reports406896l;0r?99307917,410723,411502,414163,406814,411502,406838,404796,405914,406274,406831 ,408106,407364, 399682, 401788,405951, 406361 ,415528,382239Nuclear Oversioht Field Observation Report SummarvOecemOer 21, 2010, Decemb er 07, 201 0, October 26, 2010, Septemb er 28, 201 0,August 3, 2010, July 20,2010ALARA Committee Meetinq MinutesThird Quarter 2010, Fourth Quarter 2010, First Quarter 2011Calibration Records ReviewedA]MS4, Serrdl Nos,.1270,657, 1698,662, 1695,783, 1697,781, 1696, 1675,783FunctionalT89601073, 99700206, 89300056, 3880163,]]
89300070SCBA Personnel Qualification Reportsonal

ALARAAttachment

A-8Operations DepartmentRadiation Protection DepartmentSurveillance Tests - Unit 2 Control Room Emerqencv Ventilation Svstem5P2404A21, Train A Rad Monitor (R9797A) Functional Test - MonthlySP2404AZ2,Train B Rad Monitor (R97998) Functional Test - MonthlySP2609F, Filter Testing, Flow and D/P, Facility 1 and 2Miscellaneous DocumentsAlpha Characterization Report for Unit 2 and Unit 3 for 2008, 2009, and 2010System Health Report for Unit 2 Control Room Air Conditioning System2R20

ALAM Plans (
AP )AP-2-11 -01, Reactor vessel disassembly/re-assemblyAP-2-11-07,
SG corrective & preventative maintenance activities
AP [[-2-1 1 - 1 3, Scaffold ing installationiremovalAP-2-11-16, 'C' reactor coolant pump motor and seal replacementAP-2-11 -26, Radiation Protection Outage Support ActivitiesALAM Evaluations (AE)AE 2-10-06, Unit 2'C' charging pump motor replacementAE 3-10-16, Unit 3'C'charging pump rotating assembly replacementAE 2-10-03, Unit 2 in containment inspection of 2-FW'2618AE 2-10-04, Unit 2 in containment prepare repair plan for 2-FW-2618AE 2-10-05, Unit 2 in containment lubricate bonnet bolting for 2-FW-2618Section]]
4OA 1: Performance Indicator (Pl) Verificationep Z8
OZN , "Primary System Sampling and Analysis," Revision 000-03Millstone Nuclear Power Station Gamma Spectrum Analysis, January 20,2011Reactor Coolant System Activity Performance lndicator 2010Reactor Coolant System Leakage Performance Indicator
2010SP 26194-001, "Control Room Daily Surveillance," Revision 046-12
SP [[]]
3601F. 6, "Reactor Coolant System Water Inventory Measurement," Revision 006-03
SP [[]]
3601F. 6-001, '
RCS Inventory Balance"Section
4OM ldentification and Resolution of ProblemsCondition ReportscR 323486cR 395584cR 395591cR 413185cR 416445Procedures
EOP 3506, Loss of All Charging Pumps, Revision 009-02EOP 35 E-0, Reactor Trip or Safety Injection, Revision
26EOP 35

ES-0.1, ReactorTrip Response, Revision24OP 3272, EOP Users Guide, Revision 008-1 1Attachment

A-9OP 3265,

EOP Network Procedure Revision Process, Revision 009-01
OP 3266,
EOP Writers Guide, Revision 006-03
OP -AP-104, Emergency and Abnormal Operating Procedures, Revision 2Miscellaneous DocumentsDW-84-006,
WOG [[]]
ERG Direct Work Request on Loss of All Charging PumpsMillstone Step Deviation Document for
EOP 35
ES -0.1, Revision 24Section
4OA 5: Other Activities
SAG -9 Revision 10cR390275Drawing 25212-28912Calculationffech memo
NUCENG -1 0-1 7Calculation W3-51 7-981
REACAD AMSALARAAOPAPASMECAPCFRCRACSCRCWDGDNBDNCDRPDRSDWECCSEDGEOPEPERGESASESFFINFSARGAHPSIt&cLIST
OF [[]]

ACRONYMSAlternating CurrentAgencywide Documents Access and Management SystemAs Low As Reasonably AchievableAbnormal Operating ProcedureALAM PlansAmerican Society of Mechanical EngineersCorrective Action ProgramCode of Federal RegulationsControl Room Air Conditioning SystemCondition ReportCirculating WaterDiesel GeneratorDeparture from Nucleate BoilingDominion Nuclear ConnecticutDivision of Reactor ProjectsDivision of Reactor SafetyDirect Work RequestEmergency Core Cooling SystemEmergency Diesel GeneratorEmergency Operating ProcedureEmergency PreparednessEmergency Response GuidelineEngineered Safety-Feature Actuation SystemEngineered Safety FeatureFindingFinal Safety Analysis ReportGeneric AttachmentHigh Pressure Safety Injectionlnstrumentation and ControlAttachment

tMcINPOtoDISTLCOLERLHRAMCCMOVmremNCVNEINOVNRCODOEoosOPPARSPIPI&RPMTRBCCWRCARCSRSSRWPSCBASDPSIHSITSGSLCRSSWTSUFSARWOGA-10Inspection Manual ChapterInstitute of Nuclear Operationslmmediate Operability Determinationln-Service TestingLimiting Condition for OperationsLicensee Event ReportsLocked High Radiation AreaMotor Control CenterMotor Operated ValvesmilliremNon-Cited ViolationNuclear Energy InstituteNotice of ViolationNuclear Regulatory CommissionOperability DeterminationsOperating ExperienceOut Of ServiceOperating ProcedurePublicly Available Records SystemPerformance IndicatorProblem ldentification and ResolutionPost Maintenance TestingReactor Building Closed Cooling WaterRadiologically Controlled AreaReactor Coolant SystemRecirculation Spray SystemRadiological Work PermitSelf Contained Breathing ApparatusSignificance Determination ProcessSafety lnjection HighSpecial lnspection TeamSteam GeneratorSupplementary Leak Collection and Release SystemService WaterTechnical SpecificationUpdated Final Safety Analysis ReportWestinghouse Owners GroupAttachment