IR 05000336/2012010

IR 05000336-12-010 and 05000423-12-010, 07/16/2012 - 08/02/2012, Millstone Power Station; Biennial Baseline Inspection of Problem Identification and Resolution

ML12244A160
Person / Time
Site:	Millstone
Issue date:	08/31/2012
From:	Bellamy R NRC/RGN-I/DRP/PB5
To:	Heacock D Dominion Resources
Bellamy R
References
IR-12-010
Download: ML12244A160 (27)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ust 31, 2012

SUBJECT:

MILLSTONE POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000336/2012010 AND 05000423/2012010

Dear Mr. Heacock:

On August 2, 2012, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station, Units 2 and 3. The enclosed report documents the inspection results, which were discussed on August 2, 2012, with Mr. Stephen Scace, Site Vice President, and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspectors concluded that Dominion was generally effective in identifying, evaluating, and resolving problems. In most cases, Dominion personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. Dominion appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences.

The inspectors also determined that Dominion typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that Dominion adequately identified, reviewed, and applied relevant industry operating experience to Millstone Power Station operations. In addition, based on those items selected for review, the inspectors determined that in general, Dominions self-assessments and audits were thorough.

This report documents three NRC-identified findings of very low safety significance (Green).

Two of the findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they have been entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs),

consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a written response within 30 days of the date of this inspection report, 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 Senior Resident Inspector at Millstone Power Station. In addition, if you disagree with the cross-cutting aspects assigned to the findings in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at Millstone Power Station.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, 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 the NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-336, 50-423 License Nos.: DRP-65, NPF-49

Enclosure:

Inspection Report 05000336/2012010 and 05000423/2012010 w/Attachment: Supplemental Information

REGION I==

Docket Nos.: 50-336, 50-423 License Nos.: DRP-65, NPF-49 Report Nos.: 05000336/2012010 and 05000423/2012010 Licensee: Dominion Nuclear Connecticut, Inc.

Facility: Millstone Power Station, Units 2 and 3 Location: P.O. Box 128 Waterford, CT 06385 Dates: July 16, 2012 through August 2, 2012 Team Leader: Thomas C. Setzer, Senior Project Engineer Division of Reactor Projects (DRP)

Inspectors: Brian C. Haagensen, Millstone Resident Inspector, DRP Sherlyn D. Ibarrola, Project Engineer, DRP Eric D. Miller, Project Engineer, DRP Approved by: Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000336/2012010 and 05000423/2012010; 07/16/2012 - 08/02/2012; Millstone Power

Station; Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified three findings in the areas of Prioritization and Evaluation of Issues; Effectiveness of Corrective Actions; and Self-Assessments and Audits.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified three findings of very low safety significance (Green) during this inspection. Two findings were determined to involve violations of NRC requirements. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0310, Components Within the Cross-Cutting Areas. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Problem Identification and Resolution The inspectors concluded that Dominion was generally effective in identifying, evaluating, and resolving problems. In most cases, Dominion personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. Dominion appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Dominion typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified two violations of NRC requirements in the areas of Prioritization and Evaluation of Issues, and Effectiveness of Corrective Actions.

The inspectors concluded that Dominion adequately identified, reviewed, and applied relevant industry operating experience to Millstone Power Station operations. In addition, based on those items selected for review, the inspectors determined that in general, Dominions self-assessments and audits were thorough. However, the inspectors identified one finding in the area of Self-Assessments and Audits that was determined not to be a violation of NRC requirements.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues, nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criteria XVI,

Corrective Action, for Dominions failure to take prompt and effective corrective actions for conditions adverse to quality involving degradation of the Unit 3 turbine driven auxiliary feedwater (TDAFW) pump trip latch mechanism. Dominion did not identify the cause of the trip latch mechanism degradation until after multiple surveillance test failures had occurred.

In response to questions from NRC inspectors, Dominion performed additional troubleshooting and determined that the linkage was not properly lubricated, and the linkage impact gap was out of adjustment. Dominion lubricated and adjusted the linkage, and declared the TDAFW pump operable after a successful retest.

The inspectors determined that this issue was more than minor because it is similar to the more than minor example 4.f of Inspection Manual Chapter (IMC) 0612, Appendix E,

Examples of Minor Issues. Additionally, the finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was determined to be of very low safety significance (Green) because the finding does not represent a loss of system and/or function, does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time, and does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program for greater than 24 hrs. The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not thoroughly evaluate the problem such that the resolution addressed the causes P.1(c). (Section 4OA2.1.c)

Cornerstone: Barrier Integrity

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criteria XVI,

Corrective Action, for Dominions failure to take timely corrective actions for conditions adverse to quality involving the degradation of the closing capability of four Unit 3 main feedwater isolation valves. Dominion has deferred correcting this condition adverse to quality for over a period of six years (three refueling outages), and correction of the degraded condition is currently scheduled for the next refueling outage (April 2013).

The inspectors determined this issue was more than minor because it is similar to the more than minor examples, 4.f and 4.g of NRC IMC 0612, Appendix E, Examples of Minor Issues. Additionally, the finding is more than minor because it is associated with the Design Control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstones objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. The inspectors determined the finding was of very low safety significance (Green) because the issue did not represent an actual open pathway in the physical integrity of the reactor containment. The inspectors determined this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Decision Making component, because Dominion did not use conservative assumptions in decision making when delaying the repairs H.1(b). (Section 4OA2.1.c)

Other Findings

Green.

The inspectors identified a finding (FIN) of very low safety significance (Green) for Dominions failure to perform procedurally required effectiveness reviews for numerous formal self-assessments. Consequently, Dominion missed opportunities to identify potential corrective actions for resolution in the corrective action program. Dominion has entered the issue into the corrective action program (CR482135).

The inspectors determined that this finding was more than minor because it is similar to IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, example 3.j; in that, it represents a programmatic deficiency that could lead to worse errors if uncorrected. This finding was of very low safety significance (Green) because the finding does not represent a loss of system and/or function, does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time, and does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program for greater than 24 hrs. This finding is not associated with an NRC Reactor Oversight Process cornerstone. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel failed to follow procedures. H.4(b). (Section 4OA2.3.c)

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Dominions corrective action program at Millstone Power Station. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and Dominion procedure PI-AA-200, Corrective Action. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Condition Report Review Team (CRT) meetings and Corrective Action Assignment Review Team (CAART) meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and the Maintenance Rule program.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems for both Unit 2 and Unit 3, such as the emergency core cooling pump rooms, auxiliary feedwater pump room, intake structure, turbine building, central alarm station, secondary alarm station, armory, and cable spreading rooms. Additionally, the inspectors reviewed a sample of condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Dominion entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of condition reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in February 2010. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Dominions completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Dominions timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected NCVs and findings to verify that Dominion personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Dominions actions related to Unit 2 safety-related inverter issues.

b.

Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Dominion identified problems and entered them into the corrective action program at a low threshold. Dominion staff at Millstone Power Station initiated approximately 38,000 condition reports between January 2010 and July 2012. The inspectors observed supervisors at the CRT and CAART meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Dominion trended equipment and programmatic issues, and appropriately identified problems in condition reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels.

During a plant walkdown, the inspectors identified two degraded conditions that had not been previously entered into the Dominion corrective action program:

A radiological floor drain label was found to be covering a portion of a floor drain in the Unit 3 safeguards building, elevation 37. The label was moved during painting of the floor and was blocking a portion of the drain. This was a performance deficiency because Dominions work control program failed to identify the improperly placed label following work activities in the area.

Dominion immediately entered the issue into the corrective action program as CR481939, and properly installed the label. Dominion evaluated the issue and determined the function of the drain was not adversely impacted by the label.

The inspectors determined that because the label did not impact the function of the floor drain, and that the issue was isolated and not programmatic in nature, this performance deficiency was minor and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

An extension ladder was found to be tied off to electrical conduit located in the Unit 2 B safeguards room. The ladder was being stored in the area to allow personnel access to an upper mezzanine area of the room. The inspectors questioned whether the ladder was adequately restrained to withstand a seismic event, and how long the ladder had been in the area. Dominion performed an evaluation and concluded that the ladder was properly restrained; however, it was not being stored in accordance with site housekeeping procedures. This was a performance deficiency because Dominions housekeeping program failed to identify the improperly stored ladder. Dominion immediately entered the issue into the corrective action program as CR481975, removed the ladder, and determined that the ladder would not adversely impact the operability of safety-related equipment during a seismic event. The inspectors determined that because the issue did not affect equipment operability and was isolated and not programmatic in nature, this performance deficiency was minor and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Dominion appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.

Dominion screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by Dominion corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors identified one example of more than minor significance where Dominion personnel did not take timely corrective actions to correct a known degraded condition for Unit 3 main feedwater isolation valves. This finding is documented in Section 4OA2.1.c.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were, in general, timely and adequately implemented. For significant conditions adverse to quality, Dominion, in general, identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were, in general, timely and effective. However, the inspectors found the following examples where corrective actions were not completed or fully effective to address an issue:

Millstone Corrective Action Program Workflow Extension Policy In April 2012, Dominion implemented a new policy governing extensions of condition report due dates. The new policy was put in effect based on an assessment Dominion had completed which concluded the station had been inappropriately or excessively extending the due dates of corrective actions. If a due date is to be extended, the new policy requires specific levels of approval (Manager, Director, Site Vice President) based on the significance of the issue or number of previous extensions. The inspectors reviewed a list of 95 condition reports that had been extended since this policy was placed in effect, and randomly sampled 15 condition reports for a detailed review. The inspectors found that 11 of the 15 condition reports reviewed did not receive the proper approval per the new policy. The inspectors determined that the policy has not been effective since numerous condition report due dates were extended without following policy guidance. This was a performance deficiency because it is a failure to follow a self-imposed standard; however, it is not a violation of NRC requirements since the policy is not required by Dominions operating license. The inspectors determined the issue was minor because even though the proper approvals were not received for the condition report due date extensions, Dominion had addressed each of the issues in a timely manner commensurate with the safety significance. Therefore, the inspectors determined the issue is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Abnormal Operating Procedure (AOP) 2579B The inspectors reviewed corrective actions in apparent cause evaluation (ACE) 014108, which were written to address an NCV from a 2008 NRC triennial fire protection inspection. The NRC issued this NCV for Dominions failure to demonstrate they could restore auxiliary feedwater to a steam generator within 30 minutes following a fire consistent with the Unit 2 fire safe shutdown analysis. A corrective action from the ACE was assigned to revise AOP 2579B to support operator success in meeting the time critical operator action of 30 minutes. The inspectors found that this enhancement was closed inappropriately with no work performed. However, subsequent to the NCV having been issued, Dominion performed an evaluation of operator actions that showed the station could meet the 30 minute requirement to restore auxiliary feedwater.

Therefore, the inspectors determined that this issue did not represent a more than minor performance deficiency because Dominion had performed an evaluation that proved the operators could meet the 30 minute requirement despite the AOP having not been revised.

Unit 1 Emergency Preparedness Drill The inspectors reviewed CR460177, which was written to document potential enhancements for emergency response following a December 2011 Unit 1 emergency preparedness training drill. The condition report was closed with no action taken on the enhancements. The condition report should have opened corrective actions to address each enhancement item. The inspectors determined this issue was minor because the items were enhancements and not required for adequate emergency response.

Unit 3 Tritium Found in Electrical Manhole The inspectors reviewed corrective actions CA208029 and CA208030, which were associated with tritium found in electrical manhole 3EMH-3A. The corrective actions required engineering to evaluate capturing condensation before tritiated water vapor is introduced into the environment, and present the results of the evaluation to the stations plant health committee. Both corrective actions had requested due date extensions but were then improperly closed before the work was done. The inspectors determined that this issue did not represent a more than minor performance deficiency because the corrective actions were enhancement items and previous corrective actions completed by Dominion had effectively addressed the tritium issue. Therefore, this issue is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Finally, the inspectors identified one example of more than minor significance where Dominion personnel failed to take prompt and effective corrective actions for a degraded trip latch mechanism on the Unit 3 turbine driven auxiliary feedwater pump turbine. This finding is documented in Section 4OA2.1.c.

c. Findings

(1) Failure to Take Timely Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation Valves

Introduction.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, for Dominions failure to take timely corrective actions for conditions adverse to quality involving the degradation of the closing capability of four Unit 3 main feedwater isolation valves. Dominion has deferred correcting this condition adverse to quality for over a period of six years (three refueling outages), and correction of the degraded condition is currently scheduled for the next refueling outage (April 2013).

Discussion. On June 27, 2007, Dominion identified that four Unit 3 main feedwater isolation valves, 3FWS*CTV41A, B C, and D, would not positively close against main feedwater pump discharge pressure to isolate feedwater flow into containment in the event of a main feedwater line rupture. Further analysis concluded that the feedwater isolation would likely occur when the feedwater pumps were subsequently stopped by either a non-safety grade trip signal or manual operator action. The feedwater isolation valves are safety-related valves that comprise train B of the main feedwater isolation function as described in the Millstone Updated Final Safety Analysis Report (UFSAR).

Dominion determined that the hydraulic actuators for these valves were inadequately sized based on operating experience as described in Electric Power Research Institute (EPRI) Technical Report TR-103232. The valves were initially scheduled to be restored to full qualification during refueling outage (RFO), 3RFO11, in October 2008, but the repairs were deferred to 3RFO12 due to maintenance schedule conflicts. Subsequently, repairs were not completed in either 3RFO12 or 3RFO13, and have been rescheduled to the upcoming refueling outage 3RFO14 in April of 2013, six years after the problem was first identified.

The main feedwater isolation valves are safety-related containment isolation valves that rapidly close in response to a phase B feedwater isolation emergency safeguards feature (ESF) signal. These valves are relied upon to ensure that the flow of hot feedwater is rapidly isolated for a variety of analyzed events including the rupture of a feedwater header inside containment. If feedwater flow is not isolated to the break, the additional energy transported into containment may challenge containment pressure and temperature limits, as well as the equipment qualification of various instruments and equipment inside containment.

Dominion issued condition report CR483637 on August 1, 2012, and placed the motor-driven feedwater pump in pull-to-lock to prevent it from automatically starting if a drop in feed header pressure occurred from a feed header rupture. Dominion subsequently completed an immediate operability determination (IOD), which concluded that the feedwater isolation function was degraded but operable based upon the conclusion that the main feedwater pumps would likely trip within a short period of time. The non-safety grade main feedwater pump trip signal that would likely stop the pumps and operator actions would also manually stop the main feedwater pump while implementing emergency operating procedure E-0, Reactor Trip or Safety Injection.

Analysis.

The inspectors determined that the failure to take timely corrective action following identification of a degraded condition of the Unit 3 main feedwater isolation valves was a performance deficiency that was reasonably within Dominions ability to foresee and prevent.

The inspectors determined this issue was more than minor because it is similar to the more than minor examples, 4.f and 4.g of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues. Specifically, a condition adverse to quality was not corrected in a timely manner and resulted in a situation that impacted the operability of the feedwater isolation valves. Additionally, the finding is more than minor because it is associated with the Design Control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstones objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.

In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, a Phase 1 significance determination process (SDP)screening was performed and determined the finding was of very low safety significance (Green) because the issue did not represent an actual open pathway in the physical integrity of the reactor containment. In the event of a ruptured feedwater line, the train A main feedwater regulating valves and bypass valves would remain capable of closing to isolate feedwater flow.

The inspectors determined this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Decision Making component, because Dominion did not use conservative assumptions in decision making when delaying the repairs H.1(b).

Specifically, Dominions decision to defer repair of the main feedwater isolation valves was primarily based on the conclusions in OD00027, which determined the valves would be operable based on several non-conservative assumptions including an incorrect valve factor and not establishing compensatory actions to credit the main feedwater pump trip signal and manual time critical operator actions.

Enforcement.

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, on June 27, 2007, Dominion did not take timely corrective actions to correct the degraded condition of the Unit 3 main feedwater isolation valves. Dominion has taken action to schedule the replacement of the main feedwater isolation valves in the next refueling outage (April 2013). Because this finding is of very low safety significance (Green) and has been entered into Dominions corrective action program (CR483477),the NRC is treating this finding as an NCV, consistent with the NRCs Enforcement Policy. (NCV 05000423/2012010-01, Failure to Take Timely Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation Valves)

(2) Failure to Take Prompt and Effective Corrective Actions to Address TDAFW Pump Trip Latch Mechanism Degradation

Introduction.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, for Dominions failure to take prompt and effective corrective actions for conditions adverse to quality involving degradation of the TDAFW pump trip latch mechanism. Dominion did not identify the cause of the trip latch mechanism degradation until after multiple surveillance test failures had occurred. In response to questions from NRC inspectors, Dominion performed additional troubleshooting and determined that the linkage was not properly lubricated, and the linkage impact gap was out of adjustment.

Discussion. On November 17, 2011, the TDAFW pump turbine steam supply valve 3MSS*MSV5 failed to trip when the mechanical trip lever was depressed during a quarterly operational surveillance test. Initial troubleshooting efforts indicated that the trip latch mechanism had paint residue on the latch surface, and that the paint had interfered with the operation of the trip mechanism. The trip latch surfaces were cleaned and the trip latch was retested satisfactorily. On March 26, 2012, 3MSS*MSV5 again failed to trip when the mechanical trip lever was depressed during a quarterly operational surveillance test. Initial troubleshooting efforts indicated that rust particles had interfered with the operation of the trip mechanism. The trip latch surfaces were cleaned and the trip latch was retested satisfactorily. Finally on March 27, 2012, another surveillance test revealed that the mechanical latch again failed to trip. Additional troubleshooting did not reveal any additional causes of the failure, and the trip latch subsequently passed a surveillance test after it had been cleaned and exercised by maintenance. No condition report was written by Dominion for the failure on March 27. The TDAFW pump was subsequently declared operable on March 28, 2012.

On May 5, 2012, in response to questions from NRC inspectors, troubleshooting and testing conducted by Dominion revealed that the latching mechanism was excessively stiff. A pull test was conducted and the latching mechanism required 30 to 35 lbs to trip the latch. The vendor specification for the force required to trip the latch is less than 25 lbs force. Additional troubleshooting revealed that the linkage impact gap was out of proper adjustment. On May 8, 2012, Dominion lubricated and exercised the trip throttle linkage, reduced the force required to trip the latch to within specifications, and adjusted the impact gap to the proper dimensions. The trip latch was then retested satisfactorily.

The inspectors determined that Dominion did not perform adequate troubleshooting on the trip latch mechanism, such as verifying the linkage was within vendor specifications for trip force until May 8, 2012, a period of 42 days after the March 27, 2012 failure. Due to the inadequate troubleshooting, the underlying problems with the trip latch mechanism were not identified and corrected.

Analysis.

The inspectors determined that the failure to take prompt and effective corrective action following identification of a condition adverse to quality with the trip latch mechanism was a performance deficiency that was reasonably within Dominions ability to foresee and prevent.

The inspectors determined that this issue was more than minor because it is similar to the more than minor example 4.f of IMC 0612, Appendix E, Examples of Minor Issues.

Specifically, Dominion failed to correct a condition adverse to quality that affected the operability of the TDAFW pump. Additionally, the finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, a condition adverse to quality with the trip latch mechanism was not properly evaluated, not effectively corrected, and resulted in a situation that impacted the reliability of the component.

In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Phase 1 -

Initial Screening and Characterization of Findings, a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green)because the finding does not represent a loss of system and/or function, does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time, and does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program for greater than 24 hrs.

The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not thoroughly evaluate the problem such that the resolution addressed the causes P.1(c). Specifically, Dominions causal evaluation did not provide for prompt and effective resolution of the degraded trip latch.

Enforcement.

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, from November 17, 2011, to May 8, 2012, Dominion did not take prompt and effective corrective actions to identify and resolve the degraded condition of the TDAFW pump trip latch mechanism prior to the condition adversely impacting reliability of the component. Dominion prepared CR483676 to assess the cause and corrective actions for ACE 019090. Because of the very low safety significance (Green) and because it has been entered into Dominions CAP (CR483676), the NRC is treating this finding as an NCV, consistent with the NRCs Enforcement Policy. (NCV 05000423/2012010-02, Failure to Take Prompt and Effective Corrective Actions to Address TDAFW Pump Trip Latch Mechanism Degradation)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of condition reports associated with the review of industry operating experience to determine whether Dominion appropriately evaluated the operating experience information for applicability to Millstone Power Station and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Dominion adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Dominion appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of CRT meetings.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Dominion entered problems identified through these assessments into the corrective action program, when appropriate, and whether Dominion initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal Dominion assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Dominion personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Dominion completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance. However, the inspectors identified one example of more than minor significance where Dominion personnel failed to perform procedurally required effectiveness reviews for numerous formal self assessments. This finding is documented in Section 4OA2.3.c.

c. Findings

Introduction.

The inspectors identified a finding (FIN) of very low safety significance (Green) for Dominions failure to perform procedurally required effectiveness reviews for numerous formal self-assessments. Consequently, Dominion missed opportunities to identify potential corrective actions for resolution in the corrective action program.

Description:

The inspectors performed a review of Dominion self-assessments completed since the last PI&R inspection in February 2010. Dominion self-assessments include both formal and informal self-assessments. Formal self-assessments are performed to ensure the level of performance is equal to industry experience and best practices, and typically are conducted by a diverse, multimember team of site employees and industry peers. Informal self-assessments are short duration, rapid turnaround activities designed to review a program or process.

The inspectors performed a review of procedures that detail the requirements for formal self-assessments. Specifically, the inspectors reviewed Dominion procedure PI-AA-100-1004, Self-Assessments, Revision 8. Step 3.5.2 of the procedure states that if a formal self-assessment is being performed, then an effectiveness review of the results of the assessment shall be created. The inspectors reviewed a list of approximately 230 formal and informal self-assessments, and sampled 14 formal self-assessments for a detailed inspection. The inspectors found that six formal self-assessments did not include the procedurally required effectiveness review. These formal self-assessments reports (SAR) were:

SAR001048, Procedure Use and Adherence SAR001067, VPP to Include Employee Involvement and Slips/Trips/Falls SAR001473, Processing of Protective Services SAR001542, Fleet Job-Hazard Control Assessment in Support of 2015 Business Plan SAR001723, Maintenance Outage Preparations SAR001782, 2012 Millstone PI&R Inspection Readiness.

Team leaders from the departments of operations, safety, security, maintenance, and organizational effectiveness had failed to ensure that an effectiveness review was completed for the self-assessment they had led. Further inspection of the issue revealed that multiple programmatic barriers had failed to ensure that the effectiveness reviews would be completed. This included insufficient training of team leaders, a failure to perform planning checklists which assign the effectiveness review to the team leader, and a failure of the self-assessment program oversight to discover the missing effectiveness review during a final review of the self assessment. Due to the failure of numerous barriers in the program, the inspectors determined that this represented a programmatic weakness in the stations ability to ensure that formal self-assessments and their effectiveness reviews are completed in accordance with procedural requirements.

Analysis.

The inspectors determined that Dominions failure to consistently implement procedural requirements with respect to performing effectiveness reviews for formal self-assessments was a performance deficiency that was within Dominions ability to foresee and correct and should have been prevented.

This finding is more than minor because it is similar to IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, example 3.j; in that, it represents a programmatic deficiency that could lead to worse errors if uncorrected.

The inspectors determined it was a programmatic deficiency because multiple programmatic barriers had failed to ensure the effectiveness reviews would be completed. The inspectors determined that the issue could have the potential to lead to worse errors if left uncorrected because not following an established process for performing effectiveness reviews could lead to ineffective corrective actions that go undetected. This finding was evaluated in accordance with NRC IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green) because the finding does not represent a loss of system and/or function, does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time, and does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program for greater than 24 hrs. The inspectors determined that this finding is not associated with an NRC Reactor Oversight Process cornerstone.

The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel failed to follow procedures. H.4(b).

Enforcement.

This finding does not involve enforcement action since no regulatory requirement violation was identified because Dominion procedure PI-AA-100-1004 is not required to be implemented as part of the Dominions 10 CFR 50 Appendix B Quality Assurance Program. Dominion has entered the issue into the corrective action program (CR482135). Because this finding does not involve a violation, it is identified as a finding (FIN). FIN 05000336&423/2012010-03, Failure to Perform Effectiveness Reviews for Formal Self-Assessments.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at Millstone Power Station. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Dominion entered issues into the corrective action program, when appropriate.

b. Assessment During interviews, Dominion staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On Thursday, August 2, 2012, the inspectors presented the inspection results to Mr. Stephen Scace, Site Vice President, and other members of the Millstone Power Station staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

P. Anastas - Nuclear Engineer III ENGR - Nuclear Engineering Programs

D. Bajumpaa - Consulting Engineer - Nuclear Safety Analysis

D. Cleary - System Engineering Supervisor

J. (W.) Cote - Senior Instructor, Unit 3

G. D'auria - Nuclear Chemistry Supervisor

P. Dellarco - Coordinator Nuclear Procedures

T. Fecteau - Design Engineer

B. Ferguson - Shift Manger (Unit 2)

C. Flory - Nuclear Technical Specialist III

K. Grover - Manager Nuclear Operations

S. Hanerfeld - Corrective Action Program Manager

M. Hess - Nuclear Engineer III

S. Matthess - Nuclear Chemistry Supervisor

J. Paris - System Engineer

D. Regan - Radiation Protection Supervisor

L. Salyards - Licensing Specialist

J. Shaffer - Sr. Nuclear Chemistry Technician

D. Smith - Emergency Preparedness Manager

E. Smith - System Engineer

R. Smith - Procedures Group Manager

S. Smith - Manager, Nuclear Engineering

R. Steenbergen - Nuclear Engineer III

H. Williamson - Shift Manager (Unit 2)

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000423/2012010-01 NCV Failure to Take Timely Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation Valves

05000423/2012010-02 NCV Failure to Take Prompt and Effective Corrective Actions to Address TDAFW Pump Trip Latch Mechanism Degradation

05000336&423/2012010-03 FIN Failure to Perform Effectiveness Reviews for Formal Self-Assessments