IR 05000336/2013002
| ML13102A146 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/11/2013 |
| From: | Ronald Bellamy NRC/RGN-I/DRP/PB5 |
| To: | Heacock D Dominion Nuclear Connecticut |
| Bellamy R | |
| References | |
| IR-13-002 | |
| Download: ML13102A146 (29) | |
Text
April 11, 2013
SUBJECT:
MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2013002 AND 05000423/2013002
Dear Mr. Heacock:
On March 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station, Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on April 9, 2013 with Stephen E. Scace, Site Vice President, and other members of your staff.
The inspection 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.
One NRC-identified finding of very low safety significance (Green) was indentified during this inspection.
This finding was determined to involve violations of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance of this NCV, you should provide a 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 Resident Inspector at Millstone.
If you disagree with a cross-cutting aspect assignment 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 Resident Inspector at Millstone. 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 Agencywide Documents Access Management 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, PhD, Chief Reactor Projects Branch 5 Division of Reactor Projects
Docket Nos.: 50-336, 50-423 License Nos.: DRP-65, NPF-49
Enclosure:
Inspection Report 05000336/2013002 and 05000423/2013002
w/Attachment: Supplementary Information
REGION I==
Docket Nos.:
50-336, 50-423
License Nos.:
Report No.:
05000336/2013002 and 05000423/2013002
Licensee:
Dominion Nuclear Connecticut, Inc.
Facility:
Millstone Power Station, Units 2 and 3
Location:
P.O. Box 128
Waterford, CT 06385
Dates:
January 1, 2013 through March 31, 2013
Inspectors:
J. Ambrosini, Sr. Resident Inspector, Division of Reactor Projects (DRP)
J. Krafty, Resident Inspector, DRP
B. Haagensen, Resident Inspector, DRP J. Laughlin, Emergency Preparedness Inspector, Office of Nuclear Security and Incident Response (NSIR)
Approved By:
Ronald R. Bellamy, PhD, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
SUMMARY
IR 05000336/2013002, 05000423/2013002; 01/01/2013-03/31/2013: Millstone Power Station
Units 2 and 3; Problem Identification and Resolution.
This report covered a three-month period of inspection by resident inspectors and an in-office review by a specialist from the Office of Nuclear Security and Incident Response (NSIR). The inspectors indentified one finding of very low safety significance (Green) which was a non-cited violation (NCV). The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated June 7, 2012. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of 10 CFR 50 Appendix B, Criterion XI, Test Control, for Dominions failure to perform an adequate post maintenance test (PMT) on 2-RC-404, the Unit 2 B power operated relief valve (PORV). Specifically, a stroke test of the valve under hot conditions was not performed prior to entering Mode 3. Since the valve was observed to be leaking, Dominion cooled down the plant to repair the PORV and performed the specified PMTs including the valve stroke under hot conditions. Dominion entered the issue into their corrective action program (CAP), CR506539.
The finding is more than minor because it is associated with the Human Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Dominions PMT of the PORV did not adequately demonstrate the valves capability to stroke under all operating conditions. The finding was of very low safety significance (Green) because the finding did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its technical specification (TS) allowed outage time, did 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 Dominions maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event. The finding had a cross-cutting aspect in Human Performance, Work Control, because Dominion did not adequately incorporate actions to address the impact of work activities on plant operation. Specifically, Dominion incorrectly concluded that the PORV functional test was not required prior to entering Mode 3 H.3(b).
(Section 4OA2)
REPORT DETAILS
Summary of Plant Status
Millstone Unit 2 and Unit 3 operated at or near 100 percent power for the entire inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Dominions preparations for the winter storm on February 8.
The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors verified that operator actions defined in Dominions adverse weather procedures maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.
Documents reviewed for each section of this inspection report are listed in the
.
b. Findings
No findings were identified.
==1R04 Equipment Alignment
==
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Unit 2
C charging pump while A was out of service (OOS) for planned maintenance on January 24
B Emergency Diesel Generator (EDG) on February 13 while the A EDG was OOS for cylinder liner replacement
Facility 2 reactor building closed cooling water (RBCCW) while the Facility 1 RBCCW was OOS for testing on March 13 Unit 3
A motor driven auxiliary feedwater (AFW) pump and train while B MDAFW pump was OOS for testing on March 25.
The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TS, work orders, condition reports (CR), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Dominion staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On February 1 through 5, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 boric acid system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CR and work orders to ensure Dominion appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
==1R05 Fire Protection
==
.1 Resident Inspector Quarterly Walkdowns
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Dominion controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for OOS, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 2
Auxiliary Building 480 Volt MCC B61 and B41A, Fire Area A-13 on February 11
Turbine Building Motor Driven Auxiliary Feed Pump Pit, Fire Area T-3 on February 11
6.9 and 4.16KV Switchgear Room, Fire Area T-7 on February 22
West Cable Vault, Fire Area T-8 on February 22
Low Pressure Safety Injection (LPSI) Pump Room, Fire Area A-3 on March 26
Unit 3
Turbine Building Battery Room 6, Fire Area TB-3 on March 22
Engineered Safeguards Features Building Refueling Water Storage Pumps Cubicle, Fire Area ESF-7 on March 21
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Dominion personnel identified deficiencies, openly discussed them in a self-critical manner and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:
Proper wearing of turnout gear and self-contained breathing apparatus
Proper use and layout of fire hoses
Employment of appropriate fire-fighting techniques
Sufficient fire-fighting equipment brought to the scene
Effectiveness of command and control
Search for victims and propagation of the fire into other plant areas
Smoke removal operations
Utilization of pre-planned strategies
Adherence to the pre-planned drill scenario
Drill objectives met
The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with Dominions fire-fighting strategies.
Unit 2
Drill Scenario conducted on March 22 that involved a fire in the motor driven AFW pump cubicle
Unit 3
Drill Scenario conducted on March 12 that involved a fire in the A service water (SW) cubicle of the Unit 3 intake structure.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if Dominion identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on the Unit 2 DC switchgear rooms (flooding zones A-20 and A-21) to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed Unit 3 licensed operator simulator training on January 22, which included an instrument failure (RCS*LT459E), loss of condenser vacuum, and four faulted steam generators (SG). On January 29, the inspectors observed Unit 2 licensed operator simulator training scenario MP2 ES13101A, which included a recirculation pump seal failure and loss of coolant accident.
The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed the Unit 2 B EDG slow start surveillance and attempted restoration from the cross tying of 480V Bus 22A and 22B following troubleshooting on February 28. The inspectors also observed Unit 2 turbine control valve testing on March 10. The inspectors observed infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in Dominions Operations Section Expectations Handbook and Dominions Administrative Procedure OP-AA-329, Conduct of Infrequently Performed Tests and Evolutions, Revision 1. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities among work groups similarly met established expectations and standards.
The inspectors observed routine Unit 3 control room activities on March 27 including radiation monitor and reactor protection system testing, operator response to unplanned control room alarms, and response to a medical emergency onsite. The inspectors observed the operators to verify that the crew appropriately coordinated and prioritized activities, that they used procedures as expected, and ensured the operators performed required turnover briefings.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that Dominion was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)
- (2) performance criteria established by Dominion staff was reasonable. As applicable, for SSCs classified as (a) (1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a) (2). Additionally, the inspectors ensured that Dominion staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Unit 2
B PORV on January 22
`A` and `B` EDG on February 6
Containment Isolation on February 27
Unit 3
Control Room HVK Chillers on January 30
Maintenance Rule (a)(3) Periodic Self Assessment on March 29
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Dominion performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Dominion personnel performed risk assessments as required by 10 CFR 50.65(a)
- (4) and that the assessments were accurate and complete. When Dominion performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Unit 2
C RBCCW pump during planned surveillance testing on January 10
Yellow risk due to RPS matrix testing with the lower 4160V switchgear room in compensatory cooling on February 14
Emergent work to replace the AC-4 matrix relay in the reactor protection system on March 14
Yellow risk due to the reserve station service transformer and C SW pump OOS for scheduled maintenance on March 21
Unit 3
Emergent Work on 3FWS*CTV41A-D feedwater isolation valve replacement project bypasses SLCRs envelope on February 5
Yellow Risk assessment due to Station Blackout (SBO) and EDG B being unavailable on February 6
Yellow Risk Assessment due to all station Fire Pumps being unavailable on February 22 Emergent Repairs on the main generator output breaker air supply on March 22
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Unit 2
Leak on SW Supply to Vital Switchgear Coolers, X181A/B and X182 on January 2
CR502542 Acoustic Valve Monitoring System failed surveillance on January 15
Unit 3
CR500743/5/7 SW Valves 3SWP*870/873/868 dealloying on January 14
OD000524/525 Main Steam Line Pressure Transmitters Environmental Qualification Covers on February 19
RAS000220 3SWP*TV35B not maintaining SW temperature on 3HVK*CHL1B on January 14
CR503305 Unplanned Entry into TS 3.0.3 for ESF Building Supply and Exhaust fans 3HVQ*FN5A/6A starter replacement with safety injection pump 3SIH*P1A tagged out for maintenance on January 23
OD000529 Leakage and Corrosion identified on SW valves 3SWP*V661, 664, 665, 668 due to dealloying on February 26.
The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Dominions evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Dominion. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
Unit 3
TCC-MP-2013-009, Encapsulation of Dealloying SW Valves 3SWP*V661, 3SWP*V664, 3SWP*V665, and 3SWP*V668, Revision 000 on March 7
TCC-MP-2013-011, Temporary Installation of Main Generator Output Breaker 15G-3U-2 Air Supply on March 23.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
Unit 2
Turbine Driven AFW Weld Repair on Steam Leak on Trip Throttle Valve 2MS-464 on January 18
A EDG cylinder liner replacement and two year preventive maintenance on February 25
AC-4 matrix relay replacement in the reactor protection system on March 14
Unit 3
Chiller 3HVK*CHL1B overhaul and PMT on March 1
Starter replacement on 3SIH*MV8821B, safety injection pump to cold leg injection isolation valve on March 6
Post Maintenance Testing for repairs on main generator output breaker 15G-3U-2 Air Supply on March 22
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Dominion procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Unit 2
SP2602A, Reactor Coolant System (RCS) Leakage on January 2
C RBCCW pump in-service test (IST) on January 10
SP 2604D, LPSI Pump and Min-Recirc Check Valve (IST), Facility 2 on February 4
SP 2612A-005, A SW Pump Comprehensive Pump Test, Revision 001-00 on February 25 (IST)
Unit 3
SP 3626.7, D SW pump (IST) on January 15
SP 31005A, MTC and Power Coefficient Measurements on February 15
SP 3622.3, TDAFW Pump Quarterly Operational Test (IST) on February 25
SP3604A.2, Charging Pump B Operational Readiness Test, Revision 014-02 on March 1
CP 3807F, Operation of the Reactor Plant Sample Sink, Revision 006-03 on March 26
SP3680.1, General RCS Leakage Trending, Revision 005-04 on March 27
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
NRC staff from the Office of Nuclear Security and Incident Response (NSIR) performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession number ML12363A067.
Dominion determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for Unit 2 licensed operators on January 29 which required emergency plan implementation by an operations crew.
Dominion planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Dominion evaluators noted the same issues and entered them into the corrective action program.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate (4 samples)
a. Inspection Scope
The inspectors reviewed Dominions submittal for the RCS specific activity and RCS leak rate performance indicators for both Unit 2 and Unit 3 for the period of January 1, 2012 through December 31, 2012. To determine the accuracy of the performance indicator data reported, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing a RCS sample.
b. Inspection Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Dominion entered issues into their CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Power Operated Relief Valve (PORV) Post Maintenance Testing
a. Inspection Scope
The inspectors performed an in-depth review of Dominions corrective actions associated with CR497201, Need to Review Mode 3 Entry on November 15 to Ensure Compliance with TSSR 4.4.3.1.C. Following a rebuild of valve 2-RC-404, B PORV, Dominion entered Mode 3, a mode which required the PORV to be operable, without performing all the required PMTs specified in work order 53102395511.
The inspectors reviewed Dominions assessment of the issue and corrective actions and interviewed licensing and operations personnel in order to determine whether Dominion was appropriately identifying and characterizing the issue and whether the planned or completed corrective actions were appropriate.
b. Findings and Observations
Introduction.
The inspectors identified a Green NCV of 10 CFR 50 Appendix B, Criterion XI, Test Control, for Dominions failure to perform an adequate PMT on 2-RC-404, the B PORV. Specifically, a stroke test of the valve under hot conditions was not performed prior to entering Mode 3.
Description.
In October 2012, during the Unit 2 refueling outage, Dominion overhauled the B PORV because of seat leakage during the operating cycle. Work order 53102395511 specified the following PMTs: PORV stroke time IST, normal pressurizer vent path verification and PORV position IST, and PORV functional test. The stroke time test was performed on October 21 in Mode 6 and the vent path verification and PORV position test was performed on November 11 in Mode 5, but the functional test was not performed prior to entering Mode 3 on November 15. TS 3.4.3 requires both PORVs to be operable in Mode 3. Dominion entered Mode 4 on November 16 at 08:10 to rework the PORV due to seat leakage.
The inspectors questioned why the PORV function test had not been performed prior to entering Mode 3. The primary plant senior reactor operator who determined the post maintenance testing requirements for the PORV repair, put a restraint on the work order indicating that hot functional test had to be performed prior to Mode 2 since the surveillance requirement stated that the PORV had to be stroked at conditions representative of Mode 3 or 4. The shift manager was unaware of the PMT requirement.
His concern at the time was low temperature overpressure protection and determined that the stroke time test and vent path verification tests, which were performed under cold plant conditions, were sufficient to demonstrate operability. The inspectors disagreed with the shift managers determination based on Generic Letter 90-06 which stated that testing of the PORVs in HOT STANDBY (Mode 3) or HOT SHUTDOWN (Mode 4) was required in order to simulate the temperature and pressure environmental effects on the PORV. The inspectors concluded that Dominions PMT was inadequate because it did not demonstrate the valves capability to stroke under all operating conditions prior to entering Mode 3.
Analysis.
The inspectors determined that the failure to perform adequate PMT on the PORV in accordance with 10 CFR 50, Appendix B, Criterion XI, was a performance deficiency that was reasonably within Dominions ability to foresee and correct, and should have been prevented. The finding is more than minor because it is associated with the Human Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, the inspectors concluded that stroking the PORV only under cold conditions following the valve overhaul was insufficient to demonstrate that the valve would be operable under normal operating temperatures and pressures. As a result, the inspectors concluded that there was insufficient basis to justify valve operability when Dominion entered Mode 3.
In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that the finding was of very low safety significance (Green)because the finding did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its TS allowed outage time, did 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 Dominions maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event.
The inspectors determined that this finding had a cross-cutting aspect in Human Performance, Work Control, because Dominion did not adequately incorporate actions to address the impact of work activities on plant operation. Specifically, Dominion incorrectly concluded that the PORV functional test was not required prior to entering Mode 3 H.3(b).
Enforcement.
10 CFR 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures. Test results shall be documented and evaluated to assure that test requirements have been satisfied.
Contrary to the above, from November 15 until November 16, Dominion failed to perform an adequate PMT on the B PORV. Dominion cooled down the plant on November 16 to repair the leaking valve a second time and performed the PORV functional test prior to entering Mode 3. Because this finding was of very low safety significance (Green)and has been entered into Dominions CAP (CR506539), this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
(NCV 5000336/2013002-01: Inadequate Post Maintenance Testing Following PORV Maintenance)
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
(Closed) Licensee Event Report (LER) 05000336/2013-001-00: Historical Acoustic Monitor Channel Check Discovered to Have Not Met Acceptance Criteria
On January 15, the required monthly channel check of the B channel pressurizer safety valve acoustic valve monitor system (AVMS) position indication did not meet the acceptance criteria. The B channel of AVMS was declared inoperable and TS 3.3.3.8, Accident Monitoring Instrumentation, Action 3 was entered. Upon review of previous data, Dominion determined that the December 2012 channel check had also failed to meet its acceptance criteria. This had not been recognized on the initial review in December. TS 3.3.3.8 Action 3 requires obtaining quench tank temperature, level, and pressure information and monitoring discharge pipe temperature once per shift when a channel of AVMS position indication is inoperable.
Dominion had not performed the monitoring requirements of TS 3.3.3.8 Action 3 from December 18, 2012 until January 15, 2013. Dominions failure to perform Action 3 is a minor performance deficiency because the failure to implement the TS requirement had no safety impact and the required indications were always available. Upon discovery in January, Dominion immediately implemented monitoring of the parameters required by TS 3.3.3.8 Action 3. The failure to comply with TS 3.3.3.8 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. This LER is closed.
4OA6 Meetings, Including Exit
On April 9, 2013, the inspectors presented the inspection results to Stephen E. Scace, Site Vice President, and other members of the Millstone staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report. At this meeting, NRC Branch Chief Dr. Ronald Bellamy presented the results of the NRCs 2012 annual assessment of Millstone Power Station as detailed in their annual assessment letter (ML13060A342).
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Adams
Plant Manager
L. Armstrong
Manager, Training
R. Acquaro
Unit 3 Shift Manager
D. Atwood
Senior Instructor
G. Auria
Nuclear Chemistry Supervisor
K. Bailey
Fire Brigade Leader, Unit 3 Plant Equipment Operator
B. Bartron
Supervisor, Licensing
R. Beal
Unit 2 Shift Manager
J. Beaudoin
Unit 3 Reactor Operator
H. Beeman
Supervisor, Nuclear Engineering
T. Berger
Unit 3 Shift Manager
E. Brodeur
Unit 3 Shift Manager
W. Chestnut
Supervisor, Nuclear Shift Operations Unit 2
F. Cietek
Nuclear Engineer, PRA
T. Cleary
Licensing Engineer
G. Closius
Licensing Engineer
C. Corey
Nuclear Instrument Technician
H. Covin
Senior Instructor, Nuclear Operations
L. Crone
Supervisor, Nuclear Chemistry
J. Curling
Manager, Protection Services
S. Doboe
Unit 2 Shift Manager
J. Dorosky
Health Physicist III
J. Figueria
Fire Brigade Member, Unit 2 Plant Equipment Operator
M. Finnegan
Supervisor, Health Physics, ISFSI
J. Foster
Fire Brigade Member, Unit 2 Plant Equipment Operator
J. Gauvin
Unit 3 Chemistry Technician
A. Gharakhanian
Nuclear Engineer III
W. Gorman
Supervisor, Instrumentation & Control
J. Grogan
Supervisor Nuclear Training
K. Grover
Manager, Nuclear Operations
C. Janus
Maintenance Rule Coordinator
C. Karpinski
Senior Instructor
D. Koropatkin
Fire Brigade Member, Unit 2 Plant Equipment Operator
J. Laine
Manager, Radiation Protection/Chemistry
Y. Landry
Fire Brigade Member, Unit 2 Plant Equipment Operator
S. Loeser
Senior Nuclear Instrument Technician
R. MacManus
Director, Nuclear Station Safety & Licensing
P. Malzahn
Operations Manager On-Call
G. Marshall
Manager, Outage and Planning
S. Matthesse
Nuclear Chemistry Supervisor, Unit 3
C. Maxson
Manager, Nuclear Oversight
S. McArthur
Fire Brigade Member, Unit 3 Plant Equipment Operator
R. McDonald
Senior Instructor, Nuclear Operations
F. Perkins
Unit 3 STA
D. Reed
Unit 3 Shift Manager
R. Riley
Supervisor, Nuclear Shift Operations Unit 3
M. Roche
Senior Nuclear Chemistry Technician
L. Salyards
Licensing, Nuclear Technology Specialist
S. Scace
Site Vice President
J. Semancik
Director of Engineering
A. Smith
Asset Management
D. Smith
Manager, Emergency Preparedness
S. Smith
Manager, Engineering
J. Stoddard
Unit 3 Supervisor Nuclear Shift Operations (Acting)
T. Stringfellow
Unit 3 Unit Supervisor
D. Tilton
Engineering Supervisor
S. Turowski
Supervisor, Health Physics Technical Services
K. Underwood
Senior Instructor, Nuclear Operations
C. Vournazos
IT Specialist, Meteorological Data
R. Walsh
Unit 3 Control Operator
B. Wilkens
Senior Safety Specialist, Site Fire Marshall
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
Inadequate Post Maintenance Testing
Following PORV Maintenance (Section
4OA2)
Closed
- 05000336/2013-001-00
LER
Historical Acoustic Monitor Channel Check
Discovered to Have Not Met Acceptance
Criteria (Section 4OA3)