IR 05000336/2020012
| ML21014A456 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/14/2021 |
| From: | Daniel Schroeder Reactor Projects Branch 2 |
| To: | Stoddard D Dominion Energy Nuclear Connecticut, Dominion Energy |
| Schroeder D | |
| References | |
| IR 2020012 | |
| Download: ML21014A456 (16) | |
Text
January 14, 2021
SUBJECT:
MILLSTONE POWER STATION, UNITS 2 AND 3 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000336/2020012 AND 05000423/2020012
Dear Mr. Stoddard:
On December 17, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Millstone Power Station, Units 2 and 3 and discussed the results of this inspection with Mr. John Daugherty, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, X /RA/
Signed by: Daniel L. Schroeder Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000336 and 05000423 License Nos. DPR-65 and NPF-49
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000336 and 05000423 License Numbers: DPR-65 and NPF-49 Report Numbers: 05000336/2020012 and 05000423/2020012 Enterprise Identifier: I-2020-012-0002 Licensee: Dominion Energy Nuclear Connecticut, Inc.
Facility: Millstone Power Station, Units 2 and 3 Location: Waterford, CT Inspection Dates: November 30, 2020 to December 17, 2020 Inspectors: E. Allen, Resident Inspector C. Bickett, Senior Reactor Inspector S. Elkhiamy, Operations Engineer C. Hobbs, Reactor Inspector Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Millstone Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the yard fire water system.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program -
Identification: The inspectors determined that Dominion identified issues and entered them into the corrective action program at a low threshold. During plant walk downs, the inspectors identified a few deficiencies not previously identified and captured in Dominion's corrective action program. The station promptly entered each issue into their corrective action program and took actions to evaluate and address. All issues were determined to be of minor significance.
Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that Dominion appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Dominion appropriately screened condition reports (CRs) for operability and reportability, categorized CRs by significance, and assigned actions to the appropriate departments for evaluation and resolution. However, the inspectors noted some challenges with the evaluation of a condition adverse to quality (CAQ) and performance of extent of condition reviews. See below for details concerning this observation and minor performance deficiency.
Correcting Problems: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. Dominion implemented corrective actions to resolve problems in a timely manner.
Assessment 71152B Operating Experience, Self-Assessments and Audits -
Use of Operating Experience: The team determined that Dominion appropriately evaluated industry operating experience for its relevance to the facility. Dominion appropriately incorporated both internal and external operating experience into plant procedures and processes.
Self-Assessments and Audits: The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team concluded that Dominion had an effective self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment -
The team performed interviews related to safety conscious work environment. The purpose of these interviews was
- (1) to evaluate the willingness of the staff to raise nuclear safety issues,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the safety-conscious work environment. The personnel interviewed were randomly selected by the inspectors from the Operations, Engineering, Maintenance, Emergency Preparedness, and Radiation Protection work groups. The inspectors also interviewed the station Employee Concerns (ECP) Manager to determine what actions are implemented to ensure employees were aware of the program and its availability with regard to raising safety concerns. The team also reviewed select ECP files and 2019 Nuclear Safety Culture Survey.
There were no indications of a declining safety conscious work environment. During interviews, plant staff expressed a willingness to identify plant issues and deficiencies and stated that they were willing to raise safety issues. interviewees indicated they were adequately trained and proficient on initiating CRs. Individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. For the most part, ECP was familiar to all those interviewed, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP.
When asked, individuals stated that they had not experienced retaliation or other negative actions for raising safety concerns. Additionally, they were aware that they are protected from such acts.
Observation: Corrective Action Product Evaluation 71152B On March 1, 2019, the Unit 2 'A' emergency diesel generator was declared inoperable because of a leak from a carbon steel fuel oil line causing Unit 2 to enter a 72-hour technical specification shutdown action statement. Level of Effort Evaluation (LEE) 7531597 was completed for the fuel oil line leak to ensure that CAQ were promptly identified and corrected. PI-AA-300-3007, Level of Effort Evaluation, requires performance of an extent of condition review IAW Attachment 5 of PI-AA-300, Cause Evaluation Program, for level 3 significant events. PI-AA-300 further describes evaluating extent of condition for similar components in the same applications, the impact on an opposite unit, and for related or similar equipment. Contrary to this, the inspectors determined that the casual evaluation performed for this level 3 significant event did not include the impact of the opposite unit, Unit 3 emergency diesel generators, and support tubing as part of the extent of condition.
The inspectors determined the performance deficiency was minor. Using NRC Inspection Manual Chapter 0612, Appendices B and E, the inspectors determined the performance deficiency was minor because, although the extent of condition was not performed on the U3 EDG, the inspectors independently performed a walkdown of the emergency diesel generators at both units as part of this inspection did not identify any concerns. Additionally, the team reviewed the preventative maintenance procedures and concluded that scheduled preventive maintenance will inspect all tubing susceptible to vibration induced failures as described in Information Notice 89-07 "Failures of Small-Diameter Tubing in Control Air, Fuel Oil, And Lube Oil Systems Which Render Emergency Diesel Generators Inoperable. The station documented this minor performance deficiency in CR 1162619.
The inspectors also noted that the station missed an opportunity to incorporate Information Notice 89-07, susceptibility to vibration induced failures that could render emergency diesel generators inoperable in the evaluation. PI-AA-300-3007, Level of Effort Evaluation, Step 3.5.12 requires a review of internal and external operating experience for equipment analysis checklists and that applicable operating experience documents (including NRC and licensee event reports) are referenced in the report. The procedure places particular emphasis on causes of and lessons learned from these reports representing missed opportunities to prevent the current event or condition, requiring initiation of actions to address causes of missed opportunities. Although mentioned in the evaluation, the evaluation incorrectly states that the NRC concern was specifically for copper or vendor supplied materials and therefore the carbon steel tubing which failed was not identified or explicitly called out as a potential cause.
The station corrected the condition since the evaluation independently concluded that the tubing inspections that were being performed lacked adequate scope. Dominion created an enhancement to update the preventative maintenance work via a recurring task (RE603967/RE603968) to include tubing inspections regardless of material.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On December 17, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. John Daugherty, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action 1055547
Document 1081896
1105981 Emergency Preparedness Corrective Action Reports
1110198
1112643
1114244
1116868
1118175
1119087
24052
24057
25478
26361
26610
26683
28129
1130757
1140458
1140661
1144574
1149131
1149256
1149579
1149579
1106233
1106523
1108081
1108945
1109000
1109492
1112855
1114738
Inspection Type Designation Description or Title Revision or
Procedure Date
1114745
1116470
1117563
1117864
23802
26416
1130791
1132335
1137806
1138573
1138906
1138909
1140169
1152542 Reactor Protection System Channel 'B' Power Range
1153180 Monitor
1153712
1154294
1156679
516470
20747
20751
23530
1037258
1074931
1082135
1083525
1086233
1089343
1095430,
1107999
1108263
1111842
20296
20300
Inspection Type Designation Description or Title Revision or
Procedure Date
21572
21588
22576
23841
23848
23970
24010
24217
25027
26112
27184
27233
27645
27774
28152
28417
1130761
1132845
1135818
1137952
1138130
1138137
1138325
1138383
1141646
1144276
1144771
1145882
1149842
1151361
1152492
1152938
1152947
1153364
Inspection Type Designation Description or Title Revision or
Procedure Date
1156872
1160648
1162209
1162210
2908
563148
CA209193 Install replacement mechanical actuator 08/11/2011
CA3084785 Inspect both failed 'A' HJTC probe transition cables in 3R19 12/21/2017
CA7272707 Track issue to full qualification of the identified electrical 05/21/2018
busses and emergency diesel
CA7293320 Replace the B Train DT1748-EX circuit board 06/12/2018
LEE 7412441 Evaluation for inadvertent withdrawal of an adjacent CEA 11/07/2018
when moving fuel assemblies into the core
LEE 7415773 Evaluation for Inadequate maintenance procedures led to 11/01/2018
both control room emergency ventilation trains declared
inoperable and unable to perform their safety function
LEE 7421331 Following closure of the Containment Personnel Airlock 12/18/2019
Outer Door to support the Enclosure Building Negative
Pressure Test, plant personnel were unable to re-open the
door.
LEE 7449000 Containment Recirculation Cooler Service Water Outlet 12/17/18
Radiation Monitor 3SWP*RE60B is intermittently spiking into
alert.
LEE 7454162 Unit 2 Control Room Boundary Door 204-36-008 was 5/4/19
discovered to not be able to be closed due to the latch being
stuck in the extended position which prohibited the door from
closing.
LEE 7531597 Emergency Diesel Generator (EDG) leaked fuel oil from a 5/2/19
crack in its fuel oil line. This resulted in the Diesel being
declared inoperable and unavailable to provide one train of
emergency power in the event of the loss of offsite power.
LEE 7531597 Unit 2 'A' Emergency Diesel Generator leaked fuel oil from a
crack in its fuel oil line. This resulted in the Diesel being
declared inoperable and unavailable to provide one train of
Inspection Type Designation Description or Title Revision or
Procedure Date
emergency power in the event of the loss of offsite power.
LEE 7626110 Evaluation for Inadequate post maintenance testing resulted 08/07/2019
in engineered safety features building emergency ventilation
failure to start
LEE 7658938 Evaluation for Inadequate Unit 2 Alternative Shutdown 09/18/2019
Procedure for Fire in East 480 Volt Load Center Room
LEE 7936714 Evaluation for Unit 2 discharge pH exceeding the four-hour 06/19/2020
designated sampling interval in accordance with the Millstone
NPDES Permit
LEE 8099784 Evaluation for degrading environmental conditions at the Unit 09/11/2020
and Unit 3 intakes during Tropical storm Isaias caused
severe biological fouling
LEE CA7795011 A Service Water leak occurred on UNIT 2 A Emergency 12/10/2019
Diesel Generator, requiring service water to be isolated to
the A Emergency Diesel Generator.
LEE CA7807222 The Unit 3 A EDG was unable to maintain 110% Load 12/18/2019
(Defect) resulting in the U3 A EDG remaining inoperable for
greater than the 14-day Allowed Outage Time
OPEX Unusual Event Emergency Classification for Oconee 05/10/2018
PIR1104262
OPEX Startup Transformer Lockout Results in Loss of Power 05/18/2018
PIR1105065 During Outage
OPEX Westinghouse 7300 Circuit Card Increased Failure Rate 09/20/2018
PIR1106850
OPEX Part 21 - Target Rock - Curtiss Wright Flow Control Co. 03/06/2019
PIR1117782
OPEX Target Rock Curtis-Wright Flow Control Co. 03/06/2019
PIR1118892
OPEX Automatic Reactor And Turbine Trip Due to Generator 04/25/2019
PIR1131841 Ground Resulting in 56.6 Day Forced Outage
OPEX Troubleshooting DC Ground Results In Automatic Reactor 03/18/2018
PIR1131994 Scram
OPEX General Atomics (Part 21) - Vendor Notification #54435 12/10/2019
PIR1137844
Inspection Type Designation Description or Title Revision or
Procedure Date
OPEX Reactor Protection System Half Scram 08/20/2019
PIR1141727
Corrective Action 1161610
Documents
Resulting from
Inspection
Drawings 12179-EM-104A Millstone Unit 3 P&ID for Chemical and Volume Control Revision 54
System
Engineering MP3-19-01096 Temporary Bypass DRPI Coil # 20 (Correspond Step 228) 11/17/2020
Changes for rod H12 of Bravo Data Cabinet
Engineering MPS3-SCRN- 50.59 Screen for Update to the Millstone Unit 3 Cycle 20 08/16/2019
Evaluations 2019-0146 Core Operating Limits Report (COLR) to support Digital Rod
Position Indication (DRPI) System operation with a failure of
one of its two data channels (half accuracy mode)
Miscellaneous CARB Package 03/11/2020
2018003-01 Failure to Assure that Safety-Related Service Water Piping
Conformed to the Procurement Documents
2019002-02 Degraded jacket water piping for emergency diesel generator
not promptly corrected
2019003-01 Failure to establish a preventive maintenance schedule for
the Unit 3 emergency diesel generator governor drive
components
20001-01 Millstone Unit 2 'A' Emergency Diesel Generator Service
Water Gasket Leak
NCV-2019-001-
NCV-2019-002-
NCV-2019-004-
NCV-2019-410-
NCV-2020-001-
Inspection Type Designation Description or Title Revision or
Procedure Date
SP 3670.1 Modes 1 - 4, Weekly Control Room Rounds 11/28/2020
Procedures AOP 3551 DC Bus Ground Revision 5
AOP 3552 Malfunction of the Rod Drive System Revision 17
C SP 750 Unit 3 - Battery Quarterly Inspection Revision 4
CM-AA-DDC-201 Design Changes Revision 22
CM-AA-TCC-204 Temporary Configuration Changes Revision 7
ER-AA-102 Preventive Maintenance Program Revision 13
ER-AA-MRL-10 Maintenance Rule Program Revision 7
ER-AA-MRL-100 Implementing Maintenance Rule Revision 12
ER-AA-PRA-1010 Preventive Maintenance Task Basis and Maintenance Revision 13
Strategy
MOV-1201 Limitorque Operator Preventive Maintenance (EQ) Revision 5
MP 3782CA 480V ABB K-Line Load Center Breaker PM and Testing Revision 15
OP 3353.MB8A Main Board 8A Annunciator Response Revision 11
OP-AA-1700 Operations Aggregate Impact Revision 8
OPS-FH-215 Refueling Machine Operation Revision 7
PI-AA-100-1004 Self-Assessments Revision 14
PI-AA-100-1007 Operating Experience Program Revision 18
PI-AA-200 Corrective Action Revision 36
PI-AA-300 Cause Evaluation Revision 17
PI-AA-300-3004 Cause Evaluation Methods Revision 7
SP 3602A.1 Rod Cluster Control Exercise Revision 14
SP 3670.1 Control Room and PEO Surveillances Revision 20
WM-AA-100 Work Management Revision 35
Self-Assessments Audit 18-10 Maintenance, NAPS/SPS Inspection & SPS Refueling 02/18/2019
Activities
Audit 18-10 Nuclear Oversight Audit of Maintenance, NAPS/SPS 01/30/2019
Inspection Program, SPS Refueling Activities
Audit 19-01: 02/25/2019
Security
Audit 19-02 Emergency Preparedness 04/17/2019
Audit 20-02 Emergency Preparedness 04/27/2020
PIR 1105912 OPEX: Inoperable Control Rod Absolute Position Indication 12/11/2018
Inspection Type Designation Description or Title Revision or
Procedure Date
Results in Plant Transient
PIR 1116733 Chemistry Program Self Assessment 12/19/2019
PIR 1116766 Radioactive Material Control Program Review 01/30/2020
PIR 1119865 Operations Comprehensive Self Assessment 08/29/2019
PIR 1130259 OPEX: Patient Skin Contamination Events Associated with I- 09/10/2019
131
PIR 1140927 OPEX: Failure to Enter Correct Technical Specification 05/19/2020
Following Failure of Containment Personnel Air Lock
PIR1119757 The B.5.b. Self Assessment - EP-2019-B.5.b-SA Emergency 11/28/19
Preparedness (INPO 12-013)
PIR1119834 Maintenance & Technical Comprehensive Self Assessment 9/9/19
PIR1150201 Maintenance & Technical Comprehensive Self-Assessment 9/23/21
Work Orders 53102471707
53102637144
202247304
202251466
202251598
202257996
203150144
203250689
203257432
53102782940
203259570
203263228
203263487
203287947
203294582
13