IR 05000336/2003002
| ML031320609 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/12/2003 |
| From: | Blough A Division Reactor Projects I |
| To: | Price J Dominion Nuclear Connecticut |
| References | |
| EA-03-080, FOIA/PA-2005-0208 IR-03-002 | |
| Download: ML031320609 (56) | |
Text
SUBJECT:
MILLSTONE POWER STATION UNIT 2 AND UNIT 3 - NRC INTEGRATED INSPECTION REPORTS 50-336/03-02 AND 50-423/03-02 EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Price:
On March 29, 2003, the Nuclear Regulatory Commission (NRC) completed inspections at your Millstone Power Station Unit 2 and Unit 3. The enclosed integrated inspection reports document the inspection findings, which were discussed on April 16, 2003 with you and members of your staff.
The inspections examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
These reports document one NRC-identified finding at Unit 3 and one self-revealing finding at Unit 2, both of which were of very low safety significance (Green) and were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these two findings as non-cited violations (NCVs) consistent with Section VI.A of the NRC Enforcement Policy. Additionally, two licensee-identified violations which were determined to be of very low safety significance are listed in Section 4OA7 of the enclosed reports. If you contest any NCV in this report, you should provide a response within 30 days of the date of these inspection reports, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Millstone Power Station.
In addition, the inspectors reviewed two licensee-identified events at Unit 2 concerning reactor coolant system (RCS) pressure boundary leakage in a reactor coolant pump seal cooler and in a pressurizer heater penetration. Each event was a violation of a Millstone Unit 2 technical specification, which prohibits operation in Modes 1 through 4 with RCS pressure boundary leakage. The inspectors have reviewed your root cause analyses of the events and concluded that the equipment failures were not avoidable by the implementation of reasonable quality assurance measures or other management controls. Therefore, after consultation with the
Mr. J. Alan Price 2 Director, Office of Enforcement, the NRC has chosen to exercise enforcement discretion and not issue a violation for these issues.
Since the terrorist attacks on September 11, 2001, the NRC has issued five Orders (dated February 25, 2002, January 7, 2003, and April 30, 2003) and several threat advisories to licensees of commercial power reactors to strengthen licensee capabilities, improve security force readiness, and enhance controls over personnel access authorization. The NRC also issued Temporary Instruction 2515/148 on August 28, 2002, that provided guidance to inspectors to audit and inspect licensee implementation of the interim compensatory measures (ICMs) required by the February 25 Order. Phase 1 of TI 2515/148 was completed at all commercial nuclear power plants during calendar year (CY) 02, and the remaining inspections are scheduled for completion in CY 03. Additionally, table-top security drills were conducted at several licensees to evaluate the impact of expanded adversary characteristics and the ICMs on licensee protection and mitigative strategies. Information gained and discrepancies identified during the audits and drills were reviewed and dispositioned by the Office of Nuclear Security and Incident Response. For CY 03, the NRC will continue to monitor overall safeguards and security controls, conduct inspections, and resume force-on-force exercises at selected power plants to pilot a long-term program that will test the adequacy of licensee security and safeguards strategies. Should threat conditions change, the NRC may issue additional Orders, advisories, and temporary instructions to ensure adequate safety is being maintained at all commercial power reactors.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) 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/
A. Randolph Blough, Director Division of Reactor Projects Docket Nos.: 50-336, 50-423 License Nos.: DPR-65, NPF-49
Enclosures:
NRC Inspection Report 50-336/03-02 w/Attachment: Supplemental Information NRC Inspection Report 50-423/03-02 w/Attachment: Supplemental Information
Mr. J. Alan Price 3
REGION I==
Docket No.: 50-336 License No.: DPR-65 Report No.: 50-336/03-02 Licensee: Dominion Nuclear Connecticut, Inc.
Facility: Millstone Power Station, Unit 2 Location: P. O. Box 128 Waterford, CT 06385 Dates: December 29, 2002 - March 29, 2003 Inspectors: S. M. Schneider, Senior Resident Inspector S. R. Kennedy, Resident Inspector P. C. Cataldo, Resident Inspector K. A. Mangan, Resident Inspector K. M. Jenison, Senior Project Engineer, DRP N. T. McNamara, Emergency Preparedness Specialist, DRS T. A. Moslak, Health Physicist, DRS D. M. Silk, Senior Emergency Preparedness Inspector, DRS Approved by: Robert J. Summers, Chief Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000336/03-02; Dominion Nuclear Connecticut, Inc.; on 12/29/02 - 03/29/03; Millstone
Power Station, Unit 2; Other Activities.
The report covered a 13-week period of inspection by resident and regional inspectors. The inspection identified one green issue, which was a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after Nuclear Regulatory Commission (NRC) management review. The NRC program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
A. Inspector Identified and Self-Revealing Findings
Cornerstone: Public Radiation Safety
- Green.
The licensee did not label a package containing radioactive waste prior to shipping the package to a low-level burial facility.
This self-revealing NCV of 49 CFR 172.400 is greater than minor because if left uncorrected, an incorrectly labeled radioactive waste package could lead to a more significant safety concern if the integrity of the shipping package was compromised and the radiological risk, associated with the package contents, could not be promptly determined. Further, program procedures did not provide adequate guidance to ensure packages were properly labeled in accordance with Department of Transportation requirements. This finding was of very low safety significance since the motor vehicle was properly placarded as a radioactive shipment, shipping documentation contained the information to identify the radioactive material, and emergency information was included with the shipping papers. (4OA5.1)
Licensee-Identified Violations
A violation of very low safety significance, which was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number is listed in Section 4OA7.
iii
REPORT DETAILS
Summary of Unit 2 Plant Status The Unit operated at essentially 100% power for the duration of the inspection period with two exceptions. On March 3, 2003, the Unit downpowered to 88% power to support cleaning of the "A" condenser waterbox tubes and planned maintenance on the "A" circulating water bay. The Unit was restored to 100% power on March 6, 2003. On March 7, 2003, the plant tripped from 100% power due to an equipment (switch) failure during reactor protection system (RPS)testing. The reactor plant trip was complicated by subsequent equipment problems in the charging system and atmospheric and condenser steam dumps. Following significant investigation and system repairs, the Unit was restored to 100% power on March 28,
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment
a. Inspection Scope
The inspectors performed three partial system walkdowns during this inspection period.
The following systems were reviewed:
- "B" emergency diesel generator (EDG) during preventive maintenance activities on the "A" EDG on January 29
- "B" reactor building closed cooling water (RBCCW) during heat exchanger (HX) clean and inspect on "A" RBCCW HX on February 27
- "A" Diesel Generator while "B" Diesel Generator was inoperable due to maintenance on January 15 The inspectors evaluated system and component alignment to identify any discrepancies that would impact system operability. The inspectors reviewed selected valve positions, electrical power availability and the general condition of major system components. The inspectors reviewed the following related licensee documents:
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
The inspectors performed six walkdowns of fire protection areas during the inspection period. The inspectors reviewed the licensees fire protection program to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for selected areas. The inspectors walked down those areas to assess the licensees control of transient combustible material and ignition sources. In addition, the inspectors evaluated the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures.
The inspectors also reviewed completed surveillances for selected areas. The fire areas reviewed included:
- "B" EDG Room - Auxiliary Building, 14'-6" Elevation (Fire Area A-16) on January 28
- Degasifier Area - Auxiliary Building, -25'-6" Elevation (Fire Area A-6, Zone B) on February 14
- East Piping Penetration Area - Auxiliary Building, -25'-6" and -5'-0"Elevations (Fire Area A-10, Zone A) on February 14
- Charging Pump Room - Auxiliary Building, -25'-6" Elevation (Fire Area A-6, Zone A)on February 14
- East Electrical Penetration Area - Auxiliary Building, 14'-6" (Fire Area A-10, Zone B)on February 14
- East Blowdown Tank Room, - Auxiliary Building, 38' 6" Elevation (Fire Area T-10C)on March 13 The inspectors reviewed the following related licensee documents:
- Unit 2 Fire Hazards Analysis
- Unit 2 Fire Hazards Analysis Boundary Drawings
- East Piping Penetration Area Combustible Loading Analysis
- East Electrical Penetration Area Combustible Loading Analysis
- Refer to Attachment for list of reviewed fire protection evaluations
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification
a. Inspection Scope
The inspectors observed the conduct of licensed operator simulator training on March 21, 2003. The inspectors observed licensed operator performance relative to the following activities: effective communications, implementation of normal, abnormal and emergency operating procedures, command and control, and technical specification (TS) compliance. In addition, the inspectors reviewed simulator physical fidelity to verify similarity between the simulator and the unit control room. The inspectors verified that the training evaluators adequately addressed operator performance issues that were identified during the exercise, and that applicable training objectives had been achieved.
b. Findings
No findings of significance were identified.
1R12 Maintenance Rule Implementation
a. Inspection Scope
The inspectors reviewed the handling of two degraded safety systems and components (SSC) conditions for maintenance effectiveness during this inspection period. The inspectors reviewed licensee implementation of the maintenance rule, 10 CFR 50.65, in response to identified performance issues associated with the following condition reports (CRs):
- CR-03-02551, "B" Service Water Pump Failed Its Acceptance Criteria for D/P in SP 2612B-003. D/P Was Too High
- CR-03-02381, #3 Safety Injection Tank Level Going Down with Outlet Valve Closed The inspectors verified that the issues were appropriately evaluated against applicable maintenance rule functional failure criteria, as set forth in Functional Administration Procedure MP-24-MR-FAP710, "Maintenance Rule Functional Failures & Evaluations."
The inspectors also discussed the issues with the system engineer and verified that the issues were appropriately tracked against the systems performance criteria and that the systems were appropriately classified under 10 CFR 50.65.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a. Inspection Scope
The inspectors reviewed five maintenance risk assessments during the inspection period. The inspectors verified the conduct and adequacy of scheduled maintenance risk assessments for plant conditions affected by the conduct of the following scheduled maintenance and testing activities:
- Unit 2 Work Schedule for the week of 1/27/03 - maintenance and testing on the charging pump "A" outage, "A" emergency diesel generator (EDG) slow start test, 2-CN-29A suction valve manual stroke test.
- Unit 2 Work Schedule for the week of 2/10/03 - maintenance and testing on the "B" engineering safeguards actuation system (ESAS) undervoltage.
- Unit 2 Work Schedule for the week of 2/24/03 - maintenance and testing on the high pressure safety injection (HPSI) train "A" & "B" testing, "B" charging pump work
- Unit 2 Work Schedule for the week of 3/17/03 - troubleshooting and repair of the charging system.
- Unit 2 Work Schedule for the week of 3/24/03 - maintenance and testing on the "A" EDG slow start and charging pump in-service surveillance.
The inspectors utilized the Equipment Out of Service quantitative risk assessment tool to evaluate the risk of the above plant configurations and compared the result to the licensee's stated risk. The inspectors also verified that the licensee entered appropriate risk categories and implemented risk management actions as necessary. In addition, the inspectors reviewed the following related licensee documents:
- Major Equipment Schedule
- MP-14-OPS-GDL02, Revision 007, "Operations Standards"
- MP-20-MMM, Revision 001, "Work Management"
- MP-20-WM-FAP02.1, Revision 005-02, "Conduct of On-Line Maintenance"
- MP-20-WM-SAP02, Revision 1, "On-Line Maintenance"
- Control Room Logs
- CR-03-00941, P3 Plan for 1/29/03 Would Have Resulted in TSAS 3.0.3 Entry
b. Findings
No findings of significance were identified.
1R14 Personnel Performance During Non-Routine Plant Evolutions
a. Inspection Scope
The inspectors reviewed personnel performance in coping with non-routine evolutions and transients described below:
- On February 24, 2003, operations personnel responded to the start of both backup charging pumps while at 100% power and in the pressurizer level program band.
Instrumentation and Control (I&C) personnel were conducting a pressurizer level control circuit calibration when they entered the wrong panel and pulled the wrong card. This started both backup charging pumps when the controlling circuitry sensed program band deviation from the removed card. Operations personnel secured the backup charging pumps and I&C personnel replaced the card. I&C conducted a maintenance stand down and briefed the occurrence stressing 3-way communications.
- On February 27, 2003, operations personnel entered TS 3.0.5, Operability When Emergency Power Supply Is Unavailable, for both containment radiation monitors being inoperable. On this day, the "A" EDG emergency power supply for the "A" containment radiation monitor was inoperable for surveillance activities. The "B" containment radiation monitor was then taken out of service (inappropriately) for filter replacement. With the emergency power supply for the "A" containment radiation monitor inoperable and its redundant system ("B" containment radiation monitor)inoperable, TS 3.0.5 applied. When this was recognized, operations personnel entered TS 3.0.5 and restored the "B" containment radiation monitor to service within the two-hour shutdown action statement time limit.
- On March 7, 2003, during RPS testing, operations personnel responded to an automatic reactor trip from 100% power. The apparent cause was a switch failure during RPS testing. Complications following the trip involved secondary system performance and the normal charging system. Two standby charging pumps automatically started to restore pressurizer level. A pressure spike in the charging system caused three charging pump discharge relief valves to lift. The pressure spike damaged the relief valves and resulted in leakage from the charging system into the auxiliary building and the loss of charging to the primary. Operators responded by establishing charging to the primary via the alternate injection path.
Operations personnel entered TS 3.0.3 and commenced a normal reactor plant cooldown to mode 5.
The inspectors observed control room operator response and reviewed operator logs, plant computer data, and response procedures. The inspectors also reviewed the following related licensee documents:
- Refer to Attachment for list of reviewed personnel performance during non-routine plant evolutions documents
b. Findings
No findings of significance were identified for the February 24 and 27 events. A Special Inspection Team was chartered to review the licensee response to the March 7 event.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed five operability determinations associated with degraded or non-conforming conditions to ensure that operability was justified and that mitigating systems or those affecting barrier integrity remained available and no unrecognized increase in risk had occurred. The inspectors also reviewed compensatory measures to ensure that the compensatory measures were in place and were appropriately controlled. The inspectors reviewed the following degraded or non-conforming conditions:
- Enclosure Building Filtration System Boundary Doors Degraded
- "A" and "B" Charging Pump Soft Foot Condition
- "B" RBCCW HX Service Water Relief Valve Failure
- Minor Through-Wall Service Water Piping Leak Upstream of 2-SW-87A
- EDG Service Water Bypass Valve Operability The inspectors reviewed the following related licensee documents:
- Refer to Attachment for a list of documents reviewed under operability evaluations
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed five post-maintenance test activities during the inspection period. The inspectors reviewed post-maintenance test (PMT) activities to determine whether the tests were performed in accordance with the approved procedures. The inspectors assessed the tests adequacy by comparing the test methodology to the scope of maintenance work performed. In addition, the inspectors evaluated the test acceptance criteria to verify whether the test criteria demonstrated that the tested components satisfied the applicable design and licensing bases and the TS requirements. The inspectors reviewed the recorded test data to determine whether the acceptance criteria were satisfied. In addition, the inspectors verified that any identified deficiencies were entered into the licensee's corrective action program. The following maintenance activities and specified post-maintenance tests were evaluated:
- "A" Charging Pump Low Speed Coupling
- "B" EDG Service Water Supply Valve
- "A" Charging Pump Repack
- "A" MDAFW Pump
- "B" Charging Pump Discharge Relief Valve The inspectors reviewed the following related licensee documents:
- Refer to Attachment for list of reviewed post-maintenance testing documents.
b. Findings
No findings of significance were identified.
1R20 Refueling and Outage Activities
a. Inspection Scope
The inspector reviewed areas related to a forced outage following a complicated reactor trip on March 7, 2003 for conformance to TS requirements and approved procedures.
The inspectors also reviewed risk reduction methodologies for configuration control and scheduling and mitigation strategies for affected key safety functions. Selected activities were verified for the following evolutions:
- Shutdown risk evaluations
- Startup Scheduling
- Plant heatup
- Criticality
- Power ascension The inspectors also reviewed the following related licensee documents:
- Refer to Attachment for list of reviewed refueling and outage activities documents
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed six surveillance activities, including one Inservice Testing (IST)activity, during this inspection period. The inspectors reviewed licensee performance of surveillance testing of structures, systems, and components to ensure these systems are capable of performing their intended safety functions and to ensure related TS requirements are met. The inspectors reviewed surveillance testing activities associated with the following:
- "A" Service Water Pump Operability
- "B" Service Water Pump Operability
- "B" Service Water Pump Facility 1, IST
- "C" Service Water Pump
- "A" Charging Pump
- Containment Spray System The inspectors attended test briefs, verified selected prerequisites and precautions, and verified the tests were performed in accordance with the procedural steps. The inspectors also reviewed completed data sheets and verified that TS requirements were met. The inspectors also reviewed the following related licensee documents:
- Refer to Attachment for list of reviewed surveillance testing documents
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed a temporary modification for an emergency safety features test pump assembly to verify that the temporary modification did not affect the safety function of important safety systems. The inspectors reviewed the temporary modification and its associated 10 CFR 50.59 screening against the Final Safety Analysis Report (FSAR) and Technical Specifications to ensure the modification did not affect system operability or availability. The inspectors also reviewed the following related licensee documents:
- Work Control -10, Revision 004-01, Temporary Modifications
- FSAR, Chapter 6, Engineered Safety Features System
- Low Pressure Safety Injection System Drawing No. 25203-26015, Sheet 1
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness [EP]
1EP3 Site Emergency Response Organization (SERO) Augmentation Testing
a. Inspection Scope
An EP program inspection was conducted in August 2001 and documented in NRC Inspection Reports 50-336,423/01-07. The subject inspection resulted in the issuance of Unresolved Item (URI) 50-336,423/01-07-02, related to Dominions utilization of pager notification test data to assess the capability of SERO to respond to an event and the implementation of corrective actions to resolve test data deficiencies.
The inspectors assessed Dominions corrective actions for historical SERO notification test deficiencies, which included:
- (1) a review of the pager test data for accuracy;
- (2) an evaluation of SERO participants;
- (3) an implementation of a new call-out pager system that was intended to improve the activation of SERO pagers; and
- (4) performance of an unannounced come-in drill on January 23, 2003, that was conducted off-hours to ensure the current SERO would meet the staffing requirements. In addition, the inspectors reviewed come-in test results that were documented in a Dominion Report dated January 23, 2003, as well as corrective actions associated with CR-03-00822, CR-03-00899, and CR-03-00900. The review was performed to ensure that the Millstone emergency facilities were staffed within the allotted time, all drill objectives were met and Dominions corrective actions were adequate. Based on these inspection activities, URI 50-336,423/01-07-02 is closed.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety [OS]
2OS1 Access Control to Radiologically Significant Areas
a. Inspection Scope
During the period February 10-13, 2003, the inspector conducted the following activities to verify that Dominion Nuclear was properly implementing physical, engineering, and administrative controls for access to radiologically controlled areas, and that workers were adhering to these controls when working in these areas.
C Keys to TS Locked High Radiation Areas and other High Radiation Areas located in Units 2 and 3 were inventoried. These areas were verified to be properly secured and posted during plant tours.
C The inspector verified that highly activated materials stored in the Unit 2 and Unit 3 spent fuel pools were properly secured.
C Independent radiation surveys were performed in radiologically controlled areas in Units 2 and 3 to confirm the accuracy of posted survey results and assess the adequacy of radiation work permits (RWP) and associated controls. Areas surveyed included the Unit 2 Auxiliary and Fuel Handling Buildings and the Unit 3 Auxiliary Building, Waste Building, Fuel Handling Building, and Engineered Safeguards Building.
C The inspector attended pre-job RWP briefings, reviewed the exposure controls specified in the RWPs, and observed workers perform the following associated jobs:
- The transfer of spent resin from the Unit 2 Spent Resin Tank to a waste container, and subsequent resin liner de-watering performed on February 12, 2003. (RWP 17, Job Step 2)
- The taking of a Unit 3 reactor coolant system sample from the Post-Accident Sampling System (PASS) on February 13, 2003. (RWP 4, Job Step 1)
C The inspector interviewed technicians regarding their knowledge of applicable RWPs, electronic dosimetry set points, and work area radiological conditions for the following jobs:
- Thermography performed on sections of the Unit 2 Charging System (RWP 30, Job Step 1)
- Snubber repair in the Unit 3, B-Residual Heat Removal System Cubicle (RWP12)
C The inspector reviewed pertinent information regarding Radiation Protection/Chemistry Department cumulative exposure history, exposure trends, and plant survey records to assess the licensees effectiveness in establishing exposure goals, and in limiting and equalizing worker dose.
The evaluation of Dominion Nuclear Connecticuts performance and implementation of the access control program in the above areas was reviewed against criteria contained in 10 CFR 20, the respective units technical specifications, and the licensees procedures.
b. Findings
No findings of significance were identified.
SAFEGUARDS
Cornerstone: Physical Protection [PP]
3PP4 Security Plan Changes
a. Inspection Scope
An in-office review was conducted of changes to the Physical Security Plan identified as Revision 41, 42, 43, and 44, changes to the Training & Qualification Plan identified as Revision 16 and 17, and the licensees Contingency Plan identified as Revision 4 and 5, in accordance with the provisions of 10 CFR 50.54(p). The review was conducted to confirm that the changes were made in accordance with 10 CFR 50.54(p), and did not decrease the effectiveness of the above listed plans. The NRC recognizes that some requirements contained in these program plans may have been superceded by the February 2001 Interim Compensatory Measures Order.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
[OA]
4OA1 Performance Indicator Verification
.1 Emergency Preparedness (EP)
a. Inspection Scope
The inspector reviewed the licensees process for identifying the data that is utilized to determine the values for the three EP performance indicators (PIs), which are: 1) Drill and Exercise Performance, 2) Emergency Response Organization (ERO) Participation, and 3) Alert Notification System Reliability. The review assessed data from the second, third and fourth quarters of 2002 (since the last EP PI verification inspection).
Classification, notification and protective action opportunities were reviewed from licensed operator requalification simulator sessions and site ERO drills and exercises.
Attendance records for drill and exercise participation was reviewed for completeness and accuracy. Test records were reviewed and details of the siren testing and data collection were discussed with individuals responsible for that program. The inspector reviewed this data using the criteria of Nuclear Energy Institute (NEI) 99-02, Revision 2, "Regulatory Assessment PI Guideline."
b. Findings
No findings of significance were identified.
.2 Physical Protection
a. Inspection Scope
The inspectors reviewed the licensees programs for gathering, processing, evaluating, and submitting data for the Fitness-for-Duty, Personnel Screening, and Protected Area Security Equipment Performance Indicators (PIs) to verify these PIs had been properly reported as specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 1 and Rev. 2. The review included the licensees tracking and trending reports, personnel interviews, and security event reports for the PI data collected from the 2nd quarter of 2002 through February 2003.
b. Findings
No findings of significance were identified.
.3 Reactor Safety
a. Inspection Scope
The inspectors sampled PI information provided to the NRC to ensure the PIs were complete and accurate and in accordance with the guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 2. The following licensee PIs were reviewed:
- RCS Activity
- Reactor Coolant System Leakage The RCS activity PI was verified by the inspectors by reviewing the results of daily reactor coolant system dose equivalent Iodine-131 measurements, as logged in the licensees chemistry data management system. Additionally, the inspectors verified the equipment used to measure the activity was properly calibrated. The inspectors verified the RCS leakage PI by reviewing the results of daily reactor coolant system identified leakage measurements. The inspectors sampled the January through December 2002 data by reviewing three months of data for each PI.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The inspector reviewed seven CRs, three Radiological Protection Department Self-Assessments, and three Nuclear Oversight Department Surveillance Reports relating to the implementation of radiological controls for performing work in radiologically significant areas. This review assessed the licensees threshold for identifying problems, the comprehensiveness of the cause evaluation, and the promptness/effectiveness of the resulting corrective actions.
The evaluation of Dominion Nuclear Connecticuts performance was against the criteria contained in 10 CFR 20, Technical Specifications, and the station procedures.
b. Findings
In reviewing CR-02-13322, a self-revealing finding, related to the proper labeling of a shipping package containing radioactive waste, was identified. Refer to Section 4OA5.1 for details.
4OA3 Event Followup
a. Inspection Scope
On March 7, 2003, the inspectors observed the licensee's response to an unplanned reactor trip, which was complicated by charging system and secondary plant problems.
The inspectors observed the implementation of emergency operating procedures, as well as emergency plan implementation following the declaration of an Unusual Event, due to indications and subsequent diagnosis of an RCS leak, and exceeding the shutdown time requirement of TS 3.0.3. The inspectors reviewed licensee event notification information, observed several shift briefs during the event, observed the transition to an alternate charging flowpath for RCS makeup, and reviewed the licensees response to the radiological conditions resulting from the event. The inspectors also evaluated the licensees transition to plant cooldown and compliance with applicable cooldown rates. Information from this event response was utilized to determine the level of investigatory response by the NRC. A Special Inspection Team was chartered on March 12, 2003 to review the licensee response to this event.
b. Findings
A more detailed assessment of licensee activities during and following the event will be captured under separate title by a forthcoming Special Inspection Team Inspection Report, NRC Inspection Report 50-336/03-06.
4OA4 Cross-Cutting Findings
A finding discussed in Section 4OA5.1 of this report had as its primary cause a human performance deficiency, in that, Dominion Nuclear-Connecticut attributed the cause of an incorrectly labeled radiological shipping package to human error and inadequate instructions contained in shipping procedures.
4OA5 Other Activities
.1 Transportation Violation Issued by a Third Party
a. Inspection Scope
The inspector reviewed a Notice of Infraction dated February 3, 2003 issued by the State of South Carolina to Dominion Nuclear Connecticut, involving one package of unlabeled radioactive waste (de-watered filters) transported in a shipment (No. 1202-11638) from the Millstone Station to the Barnwell Low-Level Waste Burial Ground. Also, reviewed was Chem-Nuclear Systems Condition Report (CR) No. B-02-069 and Dominion Nuclears CR No. 02-13322, which documented that incident.
b. Findings
Introduction.
A Green, self-revealing finding was identified involving the requirement to properly label, in accordance with 49 CFR 172.400, a shipping package containing Low Specific Activity radioactive waste, greater than a Type A quantity, prior to shipping the material to the disposal facility.
Description.
On December 13, 2002, a Chem-Nuclear site inspector, performing a receipt inspection of a shipment (No. 1202-11638) of radioactive waste from the Millstone Station, at the Barnwell Low-Level Waste Burial Facility, identified that the shipping package was not labeled as required by 49 CFR 172.400. The package containing de-watered filters did not have "Radioactive Yellow -III" labels affixed to opposite sides of the shipping package. Additionally, the shipping manifest incorrectly stated that shipping labels were not required for the package. Subsequently, Chem-Nuclear Systems, LLC, issued a CR No. B-02-069 to the Millstone Power Station on December 15, 2002 requesting that the licensee identify the cause for the non-compliance and the actions that would be taken to prevent a recurrence. On February 3, 2003, the Department of Health and Environmental Control issued Dominion Nuclear Connecticut a notice of infraction for this incident.
Analysis.
The transportation of non-labeled radioactive material is a performance deficiency because it was a violation of a regulatory requirement contained in 49 CFR 172.400, and was reasonably within the licensees ability to foresee and correct (e.g.,
via quality assurance processes). Traditional enforcement does not apply because the issue did not have any actual safety consequence or potential for impacting the NRCs regulatory function, and was not the result of any willful violation of NRC requirements or licensees procedures. The finding was more than minor because if left uncorrected, an incorrectly labeled radioactive waste package could lead to a more significant safety concern if the integrity of the shipping package was compromised and the radiological risk, associated with the package contents, could not be promptly determined. Further, program procedures did not provide adequate guidance to ensure packages were properly labeled in accordance with Department of Transportation requirements.
Dominion Nuclear-Connecticut attributed the cause to human error and inadequate instructions contained in shipping procedures. This finding is related to the cross-cutting issue of Human Performance.
Dominion Nuclear Connecticuts failure to label a radioactive material package prior to shipping the package to a low-level burial facility was determined to have very low safety significance (Green) using the Public Radiation Safety Significance Determination Process. Specifically, the issue involved Dominion not meeting a regulatory requirement; however, this issue did not involve the package exceeding a radiation limit; did not involve a package breach; did not involve the Certificate of Compliance; did not involve non-conformance with low level burial ground access requirements; and did not involve emergency notification information. The inspector determined that there was no actual safety consequence associated with this condition in that the vehicle was appropriately placarded, the documentation accompanying the shipment contained information to identify the radioactive material contained in the shipping package, and the emergency instructions were present.
Enforcement.
49 CFR 172.400 requires that each licensee who transports a hazardous material shall label the package with labels specified in the regulations. The licensee entered the issue into the corrective action program as CR No. 02-13322 and initiated an investigation into the causes. The requirement for placing radioactive labels, per 49 CFR 172.400, was specified in various procedures, but the format of the procedures did not organize the information by package type, causing two authorized shippers to miss the need for attaching the required label as discovered by Chem-Nuclear on December 13, 2002. Because this failure to comply with 49 CFR 172.400 is of very low safety significance and has been entered into the corrective action program, this violation is being treated as an NCV 50-336/03-02-01, consistent with Section VI.A of the NRC Enforcement Policy.
.2 (Closed) URI 50-336/02-06-02 RCS Pressure Coolant System (RCS) Pressure
Boundary Leakage, EA 03-080
Description.
This unresolved item was opened to complete an evaluation of two licensee-identified reactor coolant system (RCS) pressure boundary leakage conditions.
These leaks were located in a reactor coolant pump (RCP) seal cooler and in a pressurizer heater penetration. The conditions represented a violation of Technical Specification (TS) 3.4.6.2, which prohibited operation in Modes 1-4 with RCS pressure boundary leakage. Both leaks were minor in nature and well below the TS limit of one gpm for unidentified RCS leakage.
Analysis.
The inspectors reviewed the licensees evaluation and circumstances associated with the leakage conditions to determine whether a performance deficiency existed and to determine the safety significance of the leakage. Based on this review, the inspectors determined that each occurrence of leakage resulted from an equipment failure that was not avoidable using reasonable quality measures or management controls established by the licensee. Although the leakage was very low, the inspectors determined that the leakage was of greater than minor significance because the RCS pressure boundary, which is designed to be leak-free, was affected.
During the safety significance assessment, which was qualitative in nature, the inspectors focused on two primary criteria which were
- (1) whether the leakage conditions could have reasonably resulted in an increase in the loss of coolant accident (LOCA) frequency (small, medium, or large as appropriate based on the characteristics of the mechanism that caused the leakage) and
- (2) whether the leakage could have resulted in the failure of other mitigating systems to perform their intended safety function. The safety assessment of the pressurizer heater penetration leakage was in part based on the resident inspectors review of industry operating experience. This review indicated that there have been similar small leaks in the industry caused by primary water stress corrosion cracking (PWSCC) of pressurizer heater sleeve penetrations manufactured with alloy 600 stainless steel. All previous leaks had been identified and corrected before a failure of the heater penetration occurred. Based on this operating experience and the nature of the leakage mechanism (i.e., maximum leak size potential and likelihood of complete failure of the penetration sleeve) the inspectors concluded that the leakage would not likely result in increasing the frequency of a small LOCA. For the RCP seal cooler leakage, the licensee determined that the maximum leak rate that could be achieved was less than one gpm, and the likelihood of a complete failure of the RCP seal cooler cover, which was the most likely affected component, had not measurably increased. Based on this information and the nature of the leakage condition, the inspectors concluded that the leakage was insufficient to increase the small LOCA frequency or have an appreciable impact on the interfacing system LOCA event. In both cases, the inspectors determined that the leakage would not impact other mitigating systems resulting in a loss of function. Additionally, for each case the inspectors determined that the licensee had mitigating procedures, routine inspection activities, operable leakage detection equipment and TS requirements designed to detect low levels of leakage from the RCS and minimize the potential that a flaw could remain undetected and result in failure of the associated RCS boundary.
Based on the above, the inspectors determined, qualitatively, that both RCS pressure boundary leakage conditions were of very low safety significance.
Enforcement.
The staff concluded that each occurrence of RCS pressure boundary leakage resulted from an equipment failure that was not avoidable by the implementation of reasonable quality measures or management controls. The staff further concluded that Dominion appropriately identified and corrected the conditions, implemented measures to preventive recurrence and adequately characterized the extent of condition and safety significance associated with each RCS pressure boundary leak. Accordingly, although RCS pressure boundary leakage is a violation of NRC requirements, the NRC has decided to exercise enforcement discretion in accordance with VII.B.6 of the NRC Enforcement Policy and refrain from issuing enforcement action for these violations. URI 50-336/02-06-02 is closed.
4OA6 Meetings, including Exit
.1 Occupational Radiation Safety
The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on February 13, 2003.
.2 Resident Exit Meeting Summary
The inspectors presented the inspection results to Mr. Alan Price and other members of licensee management on April 16, 2003. The inspectors asked the licensee whether any material examined during this inspection should be considered proprietary. No proprietary information was identified.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.
- On February 6, 2003, a worker entered into the Unit 2 Auxiliary Building, a radiological controlled area (RCA), and did not properly log onto the applicable RWP and did not wear an electronic dosimeter. Failure to log onto the RWP and wear an electronic dosimeter when entering the RCA is contrary to procedure RPM 5.2.2, Basic Radiation Worker Responsibilities. This finding is of very low safety significance and is being treated as an NCV since the individual was wearing a thermoluminescent dosimeter and did not receive any unplanned exposure. This deficiency was entered into the corrective action program as CR-03-01260. Note that the licensee is reviewing this matter in conjunction with a similar occurrence which occurred at Unit 1 on January 28, 2003. (See NRC Inspection Report No. 50-245/2002-013.)
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- A. Price, Site Vice President - Millstone
- D. Hicks, Director, Nuclear Safety and Licensing
- A. Jordan, Director, Engineering
- S. Sarver, Director, Nuclear Station Operations & Maintenance
- S. Scace, Assistant to the Site Vice President
- A. Armagno, Unit 2 Health Physics Shift Supervisor
- M. Birch, Emergency Planning Staff
- R. Bracal, Manager, Maintenance
- P. Calandra, On-Line ALARA Coordinator
- T. Delgoto, Radiation Protection Technician
- D. Dodson, Acting Manager, Licensing
- M. Finnegan, Unit 3 Health Physics Shift Supervisor
- D. Glover, Manager, Nuclear Outage & Planning
- R. Griffin, Manager, Radiological Protection & Chemistry
- W. Hoffne, Operations Manager
- A. Johnson, Supervisor, Radiation Protection Support (Technical)
- M. Jaworsky, Licensing Engineer
- J. Joswick, Radiation Protection Technician
- E. Laine, Supervisor, Health Physics
- R. Leach, Staff Health Physicist
- P. Luckey, Manager, Emergency Preparedness
- F. Matovic, Radiation Protection Technician
- S. Matthess, Supervisor, Chemistry
- S. Mazolla, Emergency Planning Staff
- F. Neff, Nuclear Oversight Assessor
- F. Perry, Unit 1 Health Physics Supervisor
- G. Stearns, Radiation Protection Technician
- P. Tulba, Supervisor, Waste Services
- P. Willoughby, Supervisor, Licensing
- M. Wynn, Health Physicist
NRC personnel
- S. M. Schneider, Senior Resident Inspector
- S. R. Kennedy, Resident Inspector
- P. C. Cataldo, Resident Inspector
- K. A. Mangan, Resident Inspector
- A. J. Blamey, Senior Operations Engineer, Division of Reactor Safety (DRS)
- D. C. Caron, Physical Security Inspector, DRS
- P. R. Frechette, Physical Security Inspector, DRS
- N. T. McNamara, Emergency Preparedness Specialist, DRS
- T. A. Moslak, Health Physicist, DRS
- D. M. Silk, Senior Emergency Preparedness Inspector, DRS
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed During this Inspection 50-336/03-02-01 NCV Failure to label a radioactive material package prior to shipping the package to a low-level burial facility (4OA5.1)
Closed
50-336,423/01-07-02 URI Augmenting SERO in a Timely Manner (1EP3)
50-336/02-06-02 URI RCS Pressure Boundary Leakage, EA 03-080 (4OA5.2)