IR 05000336/2015001
| ML15132A300 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/08/2015 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Heacock D Dominion Resources |
| McKinley R | |
| References | |
| IR 2015001 | |
| Download: ML15132A300 (34) | |
Text
May 8, 2015
SUBJECT:
MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2015001 AND 05000423/2015001
Dear Mr. Heacock:
On March 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station (Millstone), Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on April 29, 2015, with Mr. John Daugherty, 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.
This report documents two violations of NRC requirements, both of which were of very low safety significance (Green). One of the violations was NRC-identified and the other was self-revealing. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violations in this report, 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. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement 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 Title 10 of the Code of Federal Regulations (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 component of the NRCs Agencywide Documents Access and 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/
Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49
Enclosure:
Inspection Report 05000336/2015001 and 05000423/2015001 w/Attachment: Supplementary Information
REGION I==
Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49 Report Nos. 05000336/2015001 and 05000423/2015001 Licensee: Dominion Nuclear Connecticut, Inc. (Dominion)
Facility: Millstone Power Station, Units 2 and 3 Location: P.O. Box 128 Waterford, CT 06385 Dates: January 1, 2015 through March 31, 2015 Inspectors: J. Ambrosini, Sr. Resident Inspector, Division of Reactor Projects (DRP)
B. Haagensen, Resident Inspector, DRP L. McKown, Resident Inspector, DRP J. Furia, Sr. Health Physics Inspector, Division of Reactor Safety K. Reid, Reactor Engineer, DRP Approved By: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
IR 05000336/2015001, 05000423/2015001; 01/01/2015 - 03/31/2015; Millstone Power Station (Millstone), Units 2 and 3; Operability Determinations and Functionality Assessments, Post-Maintenance Testing.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified two findings of very low safety significance (Green), both of which were non-cited violations (NCVs). The significance of most findings is 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 19, 2012. Cross-cutting aspects are determined using IMC 0310,
Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, associated with Dominions failure to promptly identify conditions adverse to quality associated with the Millstone Unit 3 Charging System (CHS) and Component Cooling Primary (CCP) area heaters which are required to support operability of the charging system when outside temperature is less than 17°F, from September 17, 2014, to February 11, 2015. Dominion completed restoration of the B train CHS and CCP area heaters on February 14, 2015, and has scheduled completion of the A train heater restoration for April 16, 2015.
This finding was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, as it represented a challenge to the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding screened to be of very low safety significance (Green)as safety function of the charging system was not lost based upon the capability of the nonconforming heaters to maintain charging area temperatures greater than 65°F. Inspectors identified a cross-cutting aspect in Human Performance, Procedure Adherence, for Dominions failure to adequately screen the condition adverse to quality upon discovery of heater failure and failure to evaluate heater maintenance history when making changes to heater preventive maintenance frequency. [H.8] (Section 1R15)
- Green.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, associated with Dominions failure to prevent recurrence of a significant condition adverse to quality, installation of defective fuses in the Unit 2 emergency diesel generators (EDGs) from September 26, 2015, until October 23, 2015. Dominions immediate corrective actions included replacing the defective fuses in both EDGs and assessing the extent of condition in other safety systems.
This finding was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, as it represented a challenge to the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding screened to be of very low safety significance (Green)because the finding did not represent an actual loss of function of a single train for greater than its allowable outage time. The inspectors assigned a cross-cutting aspect in the Problem Identification and Resolution, Operating Experience, in that Dominion failed to effectively implement relevant internal and external operating experience. [P.5] (Section 1R19)
REPORT DETAILS
Summary of Plant Status
Millstone Unit 2 and 3 remained 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
.1 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Dominions preparations for the onset of a blizzard on January 26 and 27, 2015, at Units 2 and 3. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the EDGs and Service Water (SW) to ensure system availability. The inspectors verified that operator actions defined in Dominions adverse weather procedure 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 Attachment.
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 A Containment Spray while the B Containment Spray Pump was out of service for planned maintenance on February 23 Unit 3 A Motor Driven Auxiliary Feedwater during B Train surveillance test on January 26 A EDG Fuel Oil System following operability testing on February 18 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), Technical Specifications (TSs), work orders, condition reports (CRs),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 corrective action program (CAP) for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
The inspectors performed a complete system walkdown of accessible portions of the following systems to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, 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, component lubrication, and hangar and support functionality. 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.
Unit 2 CHS on March 4 through March 23 Unit 3 SW System while the E Circulating Water Pump was being replaced on February 26 through March 3
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 out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 2 Auxiliary Building East 480V Load Center, Fire Area A-28/R-11 on March 2 Turbine Building West 480 V Load Center, Fire Area T-6/R-13 on March 2 West Electrical Penetration Room, Fire Area A-8 Zone D on March 13 Unit 3 Cable Spreading Room, Fire Area CB-8, on January 22 Auxiliary Building 24 level on February 25 Station blackout diesel on March 3 Turbine Driven Auxiliary Feedwater Pump Valve Room, ESF-5, on March 5
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Annual Review of Cables Located in Underground Bunkers/Manholes
a. Inspection Scope
The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including the Unit 3 North and South Cable Tunnels, on March 6 and 9, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged. The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed. For those cables found submerged in water, the inspectors verified that Dominion had conducted an operability evaluation for the cables and were implementing appropriate corrective actions.
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 2 licensed operator simulator training on March 3, which included a review and exercise of immediate operator actions for a number of different initial conditions, such as stuck open spray valves, inadvertent safety injection signal, and Reactor Building Closed-Cooling Water (RBCCW) pump trip. 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.
The inspectors observed just in time training for planned restoration of the Unit 3 A turbine driven main feedwater pump on March 9. The inspectors observed the control room operators reducing reactor power to 85 percent, starting the A turbine driven main feedwater pump and securing the motor driven main feedwater pump as well as feedwater and steam flow balancing evolutions. The inspectors observed focus briefings and other control room communications to verify that activities were performed in accordance with procedures and that the evolutions were controlled and coordinated in accordance with operations department standards and expectations.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed a planned swap of the Unit 3 motor driven main feedwater pump for the A turbine driven main feedwater pump on February 7. The inspectors observed the control room operators reducing reactor power to 85 percent and the pump swap and flow balancing evolution. The inspectors observed focus briefings and other control room communications to verify that activities were performed in accordance with procedures and that the evolutions were controlled and coordinated in accordance with operations department standards and expectations.
The inspectors observed a quarterly turbine control and stop valve testing conducted on Unit 2 on February 21. The inspectors observed the pre-job briefings, the reduction in power, control valve surveillance testing, and restoration of power. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
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 system, structure, 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 3 Emergency Generator Loading Sequencer Maintenance Effectiveness on January 12
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 Emergent Yellow Risk when the Unit 3 diesel generator (DG) sequencer failed while conducting Unit 2 Reactor Protection System (RPS) matrix testing on January 12 Emergent risk for degraded ventilation systems supplying cooling to three vital switchgear rooms on January 15 Planned high Risk for Electrohydraulic Control (EHC) software update ETE-MP-2014-1183 on February 19 Emergent Yellow Risk/High Risk for 383 line outage and RBCCW work on March 16 Unit 3 Emergent Risk for extent of condition evaluation of 'A' Emergency Generator Loading Sequencer on January 21 Emergent Risk following sprinkler head failure during B EDG deluge testing with Station Blackout out of service on February 25
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 RPS operability determination for replacing digital voltmeters on the RPS Calibration and Indication Panel on February 27 Unit 3
'A Emergency Generator Loading Sequencer following 'B' failure on January 12 A-24-8 Dual High-Energy Line Break & Fire Door failure to latch on January 15 Turbine Driven Auxiliary Feedwater Pump Heat loading upon failure of room cooling on January 20 B Control Building Ventilation Chiller trip due to Low Chilled Water Cut-Out on February 1 OD 000607, Revision 1, SW leak in supply piping on February 5 Shutdown Margin Monitors following Environmental Qualification Part 21 Report on February 9 Charging and Primary Closed Cooling Water Area Heater Transformers equipment environmental qualification non-conformance on February 12 Reactor Plant Ventilation Fan, 3HVR*FN14A, Elevated Motor Currents following Filter Change-out on March 12 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
Introduction.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, associated with Dominions failure to promptly identify conditions adverse to quality associated with the Millstone Unit 3 CHS and CCP area heaters which are required to support operability of the charging system when outside temperature is less than 17°F, from September 17, 2014, to February 11, 2015.
Description.
On September 17, 2014, during performance of B train Auxiliary Building CHS and CCP Area Ventilation Heater (non-TS) surveillance testing (MP 3789AA),
Dominion discovered that CHS and CCP area heater 3HVR*UHE1 failed to start (CR558986). The eight safety-related CHS and CCP area heaters are divided into two trains, A and B, of four heaters which support operability of the respective A and B trains of charging. In accordance with TS 3.5.2 and Technical Requirements Manual 3.1.2.4, all four heaters in a train, A or B, must be functional to maintain the associated charging train, A or B, operable when outside temperatures are less than 17°F.
Inspectors identified three conditions adverse to quality related to the safety-related area heaters which challenged the reliability of the charging system as described in the design and licensing basis.
Inappropriate classification of a significance level 2 equipment issue as a significance level 3:
CR558986 was screened to significance level 3 with actions to perform troubleshooting under work order 53102769964. In accordance with PI-AA-200, Corrective Action, Revision 23, Attachment 4, CR Significance Determination, a significance level 3 equipment issue is consistent with non-safety-related equipment problems and power block equipment issues closed to troubleshooting (i.e., not a condition adverse to quality). A significance level 2 equipment issue is consistent with abnormal failure of equipment important to safety or reliability (i.e., a condition adverse to quality). A level 2 equipment failure CR requires an equipment reliability and preventive maintenance evaluation while a level 3 does not. As of February 12, 2014, the work history of 3HVR*UHE1 contained a total of 20 work orders. Five work orders were associated with the transformer by their title. Page two of work order 53M30412132 under which the transformer was scheduled to have been replaced in 2004 to meet environmental qualification states that the transformer was not replaced.
2. Preventive maintenance interval extension without consideration of recent failure:
On December 9, 2014, a recurring task evaluation request (P-MILL-341504) was approved in accordance with ER-AA-102, Preventive Maintenance Program, Revision 8, to extend the frequency of the B train performance of MP 3789AA from once per year to once per two years, despite the failure in September 2014.
Inspectors identified that P-MILL-341504 documents the ER-AA-102 required cross-disciplinary review of the maintenance history of the B train CHS and CCP heaters was performed by Operations, Maintenance, Outage & Planning, and Engineering organizations. However, there were no specific results of the review captured, technical justification for the frequency change provided, or mention of the recent identified failure of 3HVR*UHE1 in September 2014 within the approved frequency change request.
3. Failed heater transformer not tracked in accordance with seasonal weather
operations procedure despite winter weather conditions:
On January 8, 2015, Dominion discovered that the work activity to restore 3HVR*UHE1 had not been performed (CR569092). On January 9, 2015, it was identified by inspectors that the degraded condition was not tracked in accordance with the Seasonal Weather Operations procedure. Inspectors further inquired as to the extent of condition of the failed heater transformer upon the other seven CHS and CCP heaters and the charging system due to their impact upon charging system operability. Dominion concluded that the extent of condition was limited to the individual failed heater. On January 12, 2015, Dominion completed repairs to 3HVR*UHE1.
The inspectors determined that these three issues were missed opportunities for Dominion to identify potential weaknesses in the equipment reliability of the area heaters which could lead to charging system inoperability.
On February 11, 2015, Dominion performed an equipment reliability review of the maintenance history of the CHS and CCP heaters outside of the corrective action and preventive maintenance programs due to the lack of causal analysis for the failure of safety-related heater 3HVR*UHE1. During this review, Dominion discovered that all eight CHS and CCP heater transformers had exceeded their environmental qualification program life of 20.4 years in early 2014 (CR571519). Given the winter weather, the extent of the nonconforming condition of the CHS and CCP heaters presented an immediate operability challenge to the charging system. There was no actual loss of charging system safety function from September 2014 through February 2015 as the CHS and CCP area temperature remained greater than 65°F. Inspectors reviewed Dominions prompt operability determination which determined under all analyzed conditions that there would be no loss of the charging system safety function through completion of scheduled corrective actions. Dominion completed restoration of the B train CHS and CCP area heaters on February 14, 2015. Completion of corrective actions for the A train heaters is scheduled for April 16, 2015.
The inspectors determined that it was reasonable for Dominion to perform this equipment reliability review upon the initial failure of the heater in September. The inspectors determined there were multiple opportunities for Dominion to identify challenges to maintaining the design and licensing basis of the Unit 3 charging system posed by the expired environmental qualification life.
Analysis.
The inspectors determined that failure to promptly identify conditions adverse to quality associated with the Millstone Unit 3 CHS and CCP area heaters was a performance deficiency that was reasonably within Dominions ability to foresee and correct. Specifically, Dominion failed to identify the failure of heater, 3HVR*UHE1, as a condition adverse to quality during CR screening on September 17, 2014 (CR558986).
Dominion failed to identify the conditions adverse to quality during heater maintenance history review when extending the frequency of the activity which identified the heater failure on December 9, 2014 (P-MILL-341504). Having failed to take timely corrective action in accordance with their winter readiness program, Dominion failed to identify the conditions adverse to quality following direct questioning by the inspectors as to the extent of condition on the other heaters on January 9, 2014 (CR569092). This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, as it represented a challenge to the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Reliability of the charging system was challenged based upon Dominions failure to ensure that the CHS and CCP area heater transformers were maintained within their environmental qualification life during conditions in which their function was required to support charging system operability.
In accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating Systems, Structures or Components and Functionality, the finding screened to be of very low safety significance (Green), when all screening questions were answered no. The safety function of the charging system was not lost based upon the capability of the nonconforming heaters to maintain charging area temperatures greater than 65°F.
The inspectors determined that this issue had a cross-cutting aspect in the Human Performance, Procedure Adherence, in that individuals failed to follow processes, procedures, and work instructions. Specifically, on September 17, 2014, Dominion failed to adequately screen CR558986 in accordance with PI-AA-200. Further, on December 2, 2014, Dominion failed to adequately evaluate the preventive maintenance history of the B train CHS and CCP area heaters in accordance with ER-AA-102 [H.8].
Enforcement.
10 CFR 50, Appendix B, Criterion XVI, states, in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from September 17, 2014, to February 11, 2015, Dominion failed to promptly identify conditions adverse to quality, abnormal failure of equipment important to safety or reliability and nonconformance of environmental qualifications, of the CHS and CCP area heater transformers which are required to support operability of both trains of the charging system when outside temperature is less than 17°F. Because this issue is of very low safety significance (Green) and Dominion has taken corrective action and entered this issue into their CAP (CR571519), this finding is being treated as an NCV consistent with the NRC Enforcement Policy Section 2.3.2. (NCV 05000423/2015001-01, Failure to Identify Charging and Primary Closed Cooling Water Area Heater Transformers Equipment Environmental Qualification Non-Conformance)
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests (PMTs) 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 PMT following A EDG Overhaul on January 14 PMT for replacement of RPS Calibration and Instrument Panel digital voltmeters on March 2 PMT for B EDG repairs on the Jacket Water Heat Exchanger on March 27 Unit 3 Retest following corrective maintenance on the Reactor Plant Closed Cooling Water containment isolation valve 3CCP*MOV45A on March 11 B EDG Loading Sequencer failure on January 12 Reactor Plant Ventilation Fan, 3HVR*FN14A, Elevated Motor Currents following filter change-out on March 13
b. Findings
Introduction.
The inspectors identified a self-revealing Green NCV of 10 CFR 50, Appendix B, Criteria XVI, associated with Dominions failure to prevent the recurrence of a significant condition adverse to quality associated with the installation of defective Bussmann fuses in the A EDG that prevented the EDG from reliably providing emergency power to Emergency Safeguards Features components between September 26, 2014, and October 23, 2014.
Description.
On October 21, 2015, Dominion control room operators identified the auto voltage control light on the main control board for the A EDG was not lit indicating that the automatic voltage regulator was not operable. The control room operators declared the A EDG to be inoperable and entered the action statement for TS 3.8.1.1
- (b) which allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to identify and correct the problem. Initial troubleshooting determined that the power supply was intermittently making continuity with the automatic voltage regulator control circuit. The technicians initially attributed the cause to a loose terminal block for fuse FU5. The terminal block was tightened restoring power to the circuit. The A EDG subsequently failed the PMT on October 22, 2015, when the field failed to flash and the generator did not achieve output voltage.
Further troubleshooting efforts concluded that fuses FU5 and FU7 were failing intermittently when mechanically agitated. These fuses were identified as Bussmann type KWN-R-10 fuses that had been the subjects of extensive NRC generic operating experience communications (Part 21 notifications) and industry operating experience reports from 2004 to 2008. These communications had informed Millstone that all Bussmann fuses manufactured between certain dates were susceptible to an internal manufacturing defect that could cause intermittent connectivity and should be either replaced or individually tested to verify that the fuse did not have the defect. Fuses FU5 and FU7 were subsequently determined by forensic analysis to have contained this manufacturing defect; inadequate solder adherence between the fusible element and the fuse end cap.
In January 2015, Dominion received a report from an independent testing laboratory confirming that both FU5 and FU7 contained the manufacturing defect (cold solder connections between the fusible link and the fuse end cap), known to be problematic in Bussmann fuses, which caused an intermittent loss of connectivity. Dominions earlier assessment and response to the Part 21 notifications and industry operating experience investigations was narrowly focused in scope and should have been expanded to consider the entire at-risk population of Bussmann KWN-R fuses.
On two prior occasions in 2010, a similar intermittent connectivity problem had occurred on the Unit 2 A EDG automatic voltage regulator control circuit that, at the time, was attributed to loose wiring connections in terminal block for fuse FU7. Initially, Dominion had corrected the problem by tightening the terminal block connections restoring power continuity (CR397817). However; one month later, the same problem recurred and Dominion identified (CR402056/CA183787) that fuse FU7 was losing internal connectivity when tapped. FU7 was subsequently replaced with another defective Bussmann KWN-R-10 fuse. At the time, Dominion did not recognize that this failure was caused by the Bussmann fuse manufacturing defect that had been the subject of the operating experience reports. Subsequently, in March 2015, the inspectors identified that Dominion failed to recognize the cause of the fuse failure and therefore had not prevented the recurrence of a significant condition adverse to quality.
The 2010 CR (CR402056) was screened to significance level 3 under PI-AA-200, Corrective Actions, and closed to work order 53102391907 which tightened the fuse holder terminal blocks and replaced fuse FU7. By failing to properly evaluate the prior operating experience on Bussmann KWN-R fuses, Dominion failed to identify a significant condition adverse to quality. PI-AA-200, Attachment 4, states that a significance level 2 is appropriate for unplanned reductions in nuclear safety margin such as an inoperable train of a safety system. Attachment 5 states that root cause evaluation should be considered for equipment defects that are significance level 2 that are subject to the maintenance rule. DOM-QA-1, Nuclear Facility Quality Assurance Program Description, states that significant conditions adverse to quality shall be prevented. Per Dominion procedures, a root cause evaluation is the appropriate process to be used to ensure that corrective actions to prevent recurrence are properly identified.
Dominion concluded that the A EDG contained Bussmann fuses that evidenced a known manufacturing defect. The B EDG also had similar Bussmann fuses installed in the same circuitry and was susceptible to common mode failure. Dominion also recognized that these potentially defective Bussmann fuses were also installed in other safety-related equipment. As of the end of this reporting period, Dominion is assessing the extent of condition and has assigned immediate corrective actions in CR562861 and CR562887.
Analysis.
The inspectors determined that the failure to prevent the recurrence of a significant condition adverse to quality associated with the installation of defective fuses in the A EDG was a performance deficiency that was reasonably within Dominions ability to foresee and prevent. Specifically, Dominion failed to prevent the recurrence of the failure of the A EDG caused by the installation of defective Bussmann type KWN-R fuses in the A EDG field flash and voltage regulator control circuits from October 2010 (CR402056 and CA183787) until October 2014 (CR562861 and CR562887). This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, as it represented a challenge to the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
In accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating Systems, Structures or Components and Functionality, the finding screened to be of very low safety significance (Green) because the finding did not represent an actual loss of function of a single train for greater than its allowable outage time. This finding has a cross-cutting aspect in the Problem Identification and Resolution, Operating Experience, in that Dominion failed to effectively implement relevant internal and external operating experience. Specifically, Dominion failed to adequately screen NRC Part 21 reports (Event Reports 42021 in 2005, and 44634 in 2008) and NRC Information Notice 2006-05, as well as external industry operating experience reports OE199034 (Pilgrim 2002),
OE208987 (Pilgrim 2004), OE21214 (Pilgrim 2005), OE217203 (Pilgrim 2005), and OE230674 (Watts Bar 2008). Subsequently, Dominion failed to recognize a significant condition adverse to quality in October 2010 (CR402056); that defective Bussmann fuses had been installed in the A EDG. [P.5]
Enforcement.
10 CFR 50, Appendix B, Criterion XVI, states, in part, Measures shall be established to prevent recurrence of significant conditions adverse to quality. Contrary to the above, from October 2010 to October 23, 2015, Dominion failed to prevent a significant condition adverse to quality, the loss of reliability of the Unit 2 EDGs, because of the installation of Bussmann type KWN-R fuses that contained a known internal defect. Because this issue is of very low safety significance (Green) and Dominion has taken immediate corrective action and entered this issue into their CAP (CR562861 and CR562887) for further assessment, this finding is being treated as an NCV consistent with the NRC Enforcement Policy Section 2.3.2. (NCV 05000336/2015001-02, Failure to Replace Defective Fuses in the A EDG Resulting in Generator Failure)
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 SP 2613K A EDG Surveillance Test on March 11 SP 2613M DG operability test, Safety Injection Actuation Signal start of B EDG on January 16 CP 2802N Reactor Coolant System (RCS) coolant sample surveillance for Performance Indicator (PI) BI01 and SP 2602A Reactor Coolant Leakage for PI BI02 and on March 27 Unit 3 B EDG operability test on January 6 Turbine Driven Auxiliary Feedwater enhanced monitoring frequency surveillance test on January 13 B Motor Driven Auxiliary Feedwater surveillance test on January 26 B SW Pump Quarterly operability test on February 6 A Residual Heat Removal Pump Train In-service testing program test on February 11 Turbine Driven Auxiliary Feedwater enhanced monitoring frequency surveillance test on February 19 RCS activity sample on March 31
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine Dominion emergency drill on March 17 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and operations support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.
The inspectors also attended the station drill critique to compare inspector observations with those identified by Dominion staff in order to evaluate Dominions critique and to verify whether the Dominion staff was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public and Occupational Safety
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation (71124.08 - 1 sample)
a. Inspection Scope
During January 12-16, 2015, the inspectors reviewed the effectiveness of Dominions programs for processing, handling, storage, and transportation of radioactive material.
The inspectors used the requirements of 49 CFR Parts 170-177; 10 CFR Parts 20, 61, and 71; applicable industry standards; and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors conducted an in-office review of the solid radioactive waste system description in the final safety analysis report, the Process Control Program, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed. The inspectors reviewed the scope of quality assurance audits performed for this area since the last inspection.
Radioactive Material Storage The inspectors inspected areas where containers of radioactive waste were stored, including the Millstone Radwaste Reduction Facility and Warehouse 9 (Building 409).
The inspectors reviewed Dominions established process for monitoring the impact of long-term storage.
Radioactive Waste System Walk-down The inspectors walked down areas of the plant, and reviewed:
accessible portions of liquid and solid radioactive waste processing systems to verify current system alignment and material condition radioactive waste processing equipment that was abandoned in place, and reviewed the controls in place to ensure protection of personnel changes made to the radioactive waste processing systems since the last inspection processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers current methods and procedures for dewatering radioactive waste Waste Characterization and Classification The inspectors identified radioactive waste streams and reviewed radiochemical sample analysis results to support radioactive waste characterization. The inspectors reviewed the use of scaling factors and calculations to account for difficult-to-measure radionuclides in radioactive wastes.
Shipment Preparation The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness.
Shipping Records The inspectors reviewed selected non-excepted package shipment records.
Identification and Resolution of Problems The inspectors reviewed problems associated with radioactive waste processing, handling, storage, and transportation, and were addressed for resolution in Dominions CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 RCS Specific Activity and RCS Leak Rate (2 samples)
a. Inspection Scope
The inspectors reviewed Dominions submittal for the RCS specific activity and RCS leak rate PIs for both Unit 2 and Unit 3 for the period of April 1, 2014 through March 31, 2015.
To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. 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 PI.
Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample.
b. 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.
4OA6 Meetings, Including Exit
On April 29, 2015, the inspectors presented the inspection results to Mr. John Daugherty, 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.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Adams Plant Manager
P. Anastas Equipment Environmental Qualification Program Engineer
J. Ashburn Unit 2 Shift Manager
G. Auria Nuclear Chemistry Supervisor
- B. Bartron Supervisor, Licensing
- P. Baumann Manager, Nuclear Protection Services
- D. Blakeney Director, Nuclear Station Safety & Licensing
T. Berger Unit 3 Shift Manager
- S. Brabec Nuclear Specialist, Maintenance
J. Brown Unit 2 Shift Manager
R. Castillo Nuclear Access Specialist
A. Chapman Unit 2 Reactor Operator (OTAC)
- W. Chestnut Supervisor, Nuclear Shift Operations Unit 2
T. Cleary Licensing Engineer
G. Closius Licensing Engineer
- L. Crone Supervisor, Nuclear Chemistry
- J. Curling Manager, Protection Services
J. Daugherty Site Vice President
J. Dorosky Health Physicist III
- M. Finnegan Supervisor, Health Physics, ISFSI
P. Freeman Electrical Maintenance Technician
M. Furiosi Senior Training Instructor
M. Garza Unit 2 Shift Manager
J. Gardner System Engineer
B. Gaynier Unit 2 Shift Manager
A. Gharakhanian Nuclear Engineer III
M. Goolsbey Unit 2 Operations Manager
- W. Gorman Supervisor, Instrumentation & Control
- M. Greaney Supervisor, Nuclear Maintenance
A. Harris Unit 2 Control Operator (test operator)
C. Houska I&C Technician
J. Huff Unit 2 Senior Reactor Operator
N. Kostopulous Unit 2 Unit Supervisor
J. Kruse Shipper
- J. Laine Manager, Radiation Protection/Chemistry
A. Leone Unit 2 unit Supervisor
- G. Marshall Manager, Outage and Planning
W. McCollum Unit 2 Shift Technical Advisor
M. Morrisette Unit 2 Control Operator
M. Paine Unit 2 Chemistry Technician
- J. Palmer Manager, Training
J. Rein Emergency Preparedness Specialist IV
- J. Rigatti Manager, Nuclear Site Engineering
M. Roche Senior Nuclear Chemistry Technician
T. Ryan Mechanical Maintenance Technician
- L. Salyards Licensing, Nuclear Technology Specialist
C. Sanders Unit 2 Control Operator
M. Sanders Emergency Preparedness Specialist IV
J. Shaffer Unit 2 Chemistry Technician
- S. Smith Manager, Nuclear Operations
J. Stilphen Unit 2 Control Operator
- J. Stoddard Supervisor, Nuclear Shift Operations Unit 3
- S. Turowski Supervisor, Health Physics Technical Services
- C. Vournazos IT Specialist, Meteorological Data
J. Wasilyk Unit 2 Shift Manager and SNSO
M. Watson Unit 2 Unit Supervisor
V. Wessling Unit 2 Unit Supervisor (Reactivity SRO)
B. Wilkens Millstone Power Station Fire Marshal
M. Wood Radiation Protection Supervisor
N. Vuono Unit 2 Chemistry Technician
A. Zumo Work Week Coordinator
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000423/2015001-01 NCV Failure to Identify Charging and Primary Closed Cooling Water Area Heater Transformers Equipment Environmental Qualification Non-Conformance (Section 1R15)
- 05000336/2015001-02 NCV Failure to Replace Defective Fuses in the A EDG Resulting in Generator Failure (Section 1R19)