IR 05000336/2023001

Integrated Inspection Report 05000336/2023001 and 05000423/2023001

ML23125A125
Person / Time
Site:	Millstone
Issue date:	05/08/2023
From:	Matt Young Division of Operating Reactors
To:	Stoddard D Dominion Energy Nuclear Connecticut, Dominion Energy
References
IR 2023001
Download: ML23125A125 (1)

Text

May 8, 2023

SUBJECT:

MILLSTONE POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000336/2023001 AND 05000423/2023001

Dear Daniel Stoddard:

On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station, Units 2 and 3. On April 5, 2023, the NRC inspectors discussed the results of this inspection with Michael OConnor, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Both findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Millstone Power Station, Units 2 and 3.

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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Millstone Power Station, Units 2 and 3. 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 (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety

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:

05000336/2023001 and 05000423/2023001

Licensee:

Dominion Energy Nuclear Connecticut, Inc.

Facility:

Millstone Power Station, Units 2 and 3

Location:

Waterford, CT

Inspection Dates:

January 1, 2023 to March 31, 2023

Inspectors:

J. Fuller, Senior Resident Inspector

E. Allen, Resident Inspector

E. Bousquet, Resident Inspector

L. Dumont, Senior Reactor Inspector

N. Eckhoff, Health Physicist

Approved By:

Matt R. Young, Chief

Projects Branch 2

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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

Through-Wall Leak on Unit 3 Service Water Piping Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000423/2023001-01 Open/Closed

[H.8] -

Procedure Adherence 71111.04 The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to promptly identify a condition adverse to quality related to the safety-related service water system at Unit 3. Specifically, a through-wall leak went undetected by the licensee for some time between November 2022 and January 11, 2023, when the NRC inspectors identified the leak. This pipe supplied service water to the 'A' train of the engineered safety features (ESF) building ventilation and the 'A' safety injection pump cooler.

Expired Appendix R Batteries Discovered in the Fire Shutdown Storage Box Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000336/2023001-02 Open/Closed

[H.4] -

Teamwork 71111.24 The inspectors identified a finding of very low safety significance (Green) and an associated NCV of Millstone Unit 2 Operating License Condition 2.C.(3), Fire Protection, for failure to implement and maintain in effect all provisions of the approved fire protection program.

Specifically, the licensee failed to adequately implement Surveillance Procedure (SP) 2657,

Inventory Remote Shutdown Stations Storage Boxes, to ensure the expiration date of the battery packs for the #1 steam generator level and pressure instrumentation were beyond the next performance of the surveillance.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On February 14, 2023, Unit 2 reduced power to 34 percent due to an emergent feedwater heater tube leak. The unit returned to rated thermal power on February 19, 2023, and operated at or near full power for the remainder of the cycle.

Unit 3 began the inspection period at rated thermal power. On January 6, 2023, Unit 3 reduced power to 16 percent for planned maintenance on a disconnect switch located in the Millstone switchyard. The unit returned to rated thermal power on January 9, 2023. On March 4, 2023, Unit 3 reduced power to 83 percent due to degraded condenser backpressure during a winter storm while the 'B' circulating water pump was out of service for planned maintenance. The unit returned to rated thermal power on the same day, March 4, 2023, and operated at or near full power for the remainder of the cycle.

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 performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Impending Severe Weather (IP Section 03.02) (2 Samples)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather (high winds and possible coastal flooding) on January 25, 2023.

(2) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather (sub-zero temperatures and high winds) on February 3, 2023.

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (5 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 3 service water supply to the 'A' and 'B' ESF air conditioning units and safety injection pump coolers on January 11 and 12, 2023

(2) Portions of the Unit 2 'B' and 'C' charging pump suction and discharge lines in the charging pump cubicle on January 26 and February 15, 2023

(3) Unit 2 'A' high-pressure safety injection system outside of containment on February 3, 2023

(4) Unit 3 'A' auxiliary feedwater system from demineralized water storage tank to containment wall on February 16, 2023

(5) Unit 3 'A' residual heat removal cubicle piping components and associated valves during 'A' residual heat removal pump run on March 2 and 3, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (IP Section 03.01) (7 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 2 auxiliary building general area on the 5'-6" elevation (fire area A-1G) on January 4, 2023

(2) Unit 3 refueling water recirculation pumps cubicle (fire area ESF-7) on January 9 and 12, 2023

(3) Unit 3 south motor driven auxiliary feedwater pump cubicle (fire area ESF-9) on January 12, 2023

(4) Unit 2 charging pump room on the 25'-6" elevation (fire area A-6A) on January 25 and 26, 2023

(5) Unit 3 verification of compensatory measures and fire watches for a sample of fire areas impaired by WO53203359225, U3 Fire Detection Upgrade 3FPA-PNLZP4 Cable Pull and Connection, (fire areas CB-2, CB-3, and CB-7) on February 2, 2023

(6) Unit 2 turbine building 6.9 and 4.16 kV switchgear room (fire area T-10) on February 10, 2023

(7) Unit 2 auxiliary building spent fuel pool and cask laydown area on the 14'-6" elevation (fire area A-14E) on February 16, 2023

Fire Brigade Drill Performance (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on January 11, 2023.

71111.06 - Flood Protection Measures

Flooding (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated internal and external flooding mitigation protections in the Unit 3 east switchgear room (flood compartment CB-2) on February 6 and 8, 2023.

(2) The inspectors evaluated internal flooding mitigation protections in the Unit 2 auxiliary building general area, 45'-6" elevation, on March 15, 2023.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the Unit 3 control room during a planned downpower using OP3206, Plant Shutdown, which had been modified with a one-time-only procedure change to support switchyard and turbine control system repairs on January 7, 2023.

(2) The inspectors observed and evaluated licensed operator performance in the Unit 2 control room during the following: an emergency diesel generator surveillance testing on January 3, 2023, restoration of power following control valve testing on January 27, 2023, and an unplanned downpower on February 14, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated Unit 3 licensed operator performance and the ability of the licensee to administer a requalification examination in the simulator on February 7, 2023.

(2) The inspectors observed and evaluated Unit 2 licensed operator performance during a practice crew performance evaluation scenario in the simulator on March 22, 2023.

71111.12 - Maintenance Effectiveness

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Review of commercial grade dedication activities, receipt inspection records, and Part 21 evaluation for a Unit 3 service water strainer failed distribution arm due to use of incorrect materials (CR1210262)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (9 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 3 high risk plan and associated risk mitigation actions for troubleshooting the turbine speed sensor while online on January 7, 2023 (WO53102315146)

(2) Unit 3 elevated risk due to planned offsite line 383 outage on January 12, 2023

(3) Unit 2 elevated risk due to planned motor control center cleaning and inspection of B6202 feeder breaker for steam supply to turbine driven auxiliary feedwater pump valve on January 26, 2023 (WO53102997342)

(4) Unit 3 elevated risk during planned 'C' circulating water bay outage and emergent challenges with 'A' service water strainer on January 30, 2023

(5) Unit 3 elevated risk due to planned motor control center cleaning and inspection of feeder breaker M332-2R(F5M) for main steam pressure relieving isolation valve (3MSS-18C) on February 3, 2023 (WO53103105996)

(6) Unit 2 elevated risk due to emergent feed and bleed of the '2A' emergency diesel generator jacket water to dilute high chloride levels on February 27, 2023

(7) Unit 2 elevated risk due to emergent work of the 'A' service water strainer failure on March 5, 2023 (CR1220965) (WO53203375768)

(8) Unit 2 high risk plan and associated mitigating actions for the planned steam generator main feedwater regulating valve packing adjustment on March 8, 2023

(9) Unit 2 elevated risk and associated mitigating actions associated with the planned

'2B' emergency diesel generator outage and an unplanned alarm on the 201A vital direct current bus from March 27 to 31, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (11 Samples)

The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 3 operability determination for 'A' train of service water after a through-wall flaw was identified on January 11, 2023 (CR1217060 and CA11418803)

(2) Unit 3 structural integrity evaluation for valve 3SWP*V874, which had indications of dealloying on January 16, 2023 (CR1217347)

(3) Unit 2 structural integrity evaluation for 'B' reactor building closed-cooling water header piping due to external corrosion of pipe caused by hydrazine leaking onto pipe from above on January 18, 2023 (CR1217477)

(4) Unit 3 'A' train residual heat removal, quench spray, and safety injection pumps due to refrigerant leak on the ESF building ventilation system self-contained air conditioning unit (3HVQ*ACUS1A) on January 20, 2023 (CR1217696)

(5) Unit 3 'B' power operated relief valve loss of position indication on February 4, 2023 (CR1218768)

(6) Unit 3 operability evaluation for containment due to increased frequency that containment vacuum pumps must run to maintain containment pressure below technical specification limits on February 9, 2023 (CR1215786)

(7) Units 2 and 3 station blackout diesel functionality assessment with starting air bank out of service, governor oil leakage, and computer system trouble on March 6, 2023 (CR1220973, CR1220981, and CR1220972)

(8) Unit 2 functionality assessment for the 'A' and 'B' reactor coolant pump oil collection tanks on March 17, 2023 (CR1221955)

(9) Unit 3 service water through-wall flaw located on the 'A' train of control building chilled water on March 21, 2023 (CR1222222)

(10) Unit 2 functionality assessment and associated compensatory actions for planned, temporary use of beyond design basis front end loader for refueling outage activities on March 29, 2023 (CR1222292)

(11) Unit 2 reactor coolant system increased unidentified leakage combined with lowering volume control tank level and increased containment sump level rise on March 31, 2023 (CR1220131, CR1220979, and CR1220450)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 3 permanent modification to the fire pump house entrance (door number 123-14-001) by installing removable flood barriers on January 31, 2023

(2) Unit 2 temporary modification to boric acid addition to the chemical and volume control system from a temporary borated water source on March 10 and 14, 2023

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage (IP Section 03.01) (1 Partial)

(1)

(Partial)

The inspectors reviewed licensee activities associated with the planning and preparation for the upcoming Unit 2 refueling outage (2R28).

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (IP Section 03.01) (7 Samples)

(1) Unit 3 service water pipe spool replacement on January 11, 2023 (WO53203360750)

(2) Unit 2 'B' reactor building closed-cooling water pump surveillance after greasing of the motor pump coupling on January 17, 2023 (WO53203257219)

(3) Unit 3 HVQ*ACUS1A ('A' ESF air conditioning unit) after replacement of a leaking parker fitting on January 22, 2023 (CR1217696, WO53203371707)

(4) Unit 2 'B' charging pump after replacement of the suction pressure switch on January 27, 2023 (CR1217826, WO53203371890)

(5) Unit 2 valve stroke and position verification of charging valve 192 refueling water storage tank to charging pumps following valve maintenance performed in 2R27 resetting baseline position data on February 7, 2023 (WO53203310164)

(6) Unit 2 steam generator main feedwater regulating valve (2-FW-51A) after packing adjustment on March 8, 2023 (WO53203373514)

(7) Unit 3 'B' emergency diesel generator service water supply valve M33SWP*AOV39B overhaul on March 17, 2023 (WO53203358060)

Surveillance Testing (IP Section 03.01) (4 Samples)

(1) Unit 2 'A' emergency diesel generator 18-month hot restart surveillance on January 4, 2023

(2) Review of completed surveillance SP 2657, Fire Shutdown Storage Box Inventory, which was performed at Unit 2 on January 1, 2022 (WO53203291940), but failed to identify that the surveillance acceptance criteria was not met (CR1217569) on February 10, 2023

(3) Unit 2 service water flow path verification and valve test on March 9, 2023 (SP 2612C)

(4) Unit 3 turbine driven auxiliary feedwater pump operational readiness and quarterly inservice test on March 27, 2023 (SP 3622.3)

Inservice Testing (IST) (IP Section 03.01) (2 Samples)

(1) Unit 2 'C' charging pump discharge check valve IST on January 27, 2023 (SP 2601H-006)

(2) Unit 3 'B' auxiliary feedwater pump (3FWA*P1B) operational readiness test on February 13, 2023

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Unit 3 reactor coolant system leakage detection surveillance on February 11, 2023

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Unit 2 emergency preparedness drill with an event classification, notification, and protective action recommendations from the Emergency Operations Facility on February 22, 2023

Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)

The inspectors evaluated:

(1) Unit 3 licensed operator requalification training and event classification in the simulator on February 7, 2023

(2) Unit 2 licensed operator requalification training and event classification in the simulator on March 22,

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Unit 3 control room ventilation system and surveillance testing report

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Temporary installed high-efficiency particulate air vacuums in Unit 3

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments:

(1) Whole body counting program and positive uptake evaluation

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker program

(2) Neutron dosimetry program

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity (IP Section 02.10)===

(1) Unit 2, January 1, 2022, through December 31, 2022

(2) Unit 3, January 1, 2022, through December 31, 2022

BI02: RCS Leak Rate (IP Section 02.11) (2 Samples)

(1) Unit 2, January 1, 2022, through December 31, 2022

(2) Unit 3, January 1, 2022, through December 31, 2022

===71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03)===

(1) Corrective actions associated with the failure of internal limit switch for 'B' residual heat removal discharge valve to the safety injection suction line (MV 8920B)

(CR1199404)

71153 - Follow-up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated Unit 2 licensed reactor operator and non-licensed plant equipment operators performance during a loss of all letdown flow after the 2B charging pump tripped on January 23, 2023.

Reporting (IP Section 03.05) (3 Samples)

The inspectors evaluated the following reporting events:

(1) Unit 3 pressurizer safety valve failed as-found set pressure test (CR1215854)

(2) Unit 3 ESF building ventilation system self-contained air conditioning unit (3HVQ*ACUS1A) refrigerant leak on January 20, 2023 (CR1217696)

(3) Unit 3 control room emergency air supply fan (3HVC*FN1B) did not start when automatic start signal was received on January 31, 2023 (CR1218472)

INSPECTION RESULTS

Through-Wall Leak on Unit 3 Service Water Piping Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000423/2023001-01 Open/Closed

[H.8] -

Procedure Adherence 71111.04 The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to promptly identify a condition adverse to quality related to the safety-related service water system at Unit 3. Specifically, a through-wall leak went undetected by the licensee for some time between November 2022 and January 11, 2023, when the NRC inspectors identified the leak. This pipe supplied service water to the 'A' train of the ESF building ventilation and the 'A' safety injection pump cooler.

Description:

On January 11, 2023, the NRC inspectors identified a through-wall leak from service water piping supplying cooling water to the 'A' train of the ESF building ventilation system and 'A' safety injection pump cooler. The area of the leak was showing green deposits coming from a weld above, check valve 3SWP*V705. There were also salt deposits visible from the pipe elbow just below the leak and salt deposits hanging off the pipe support structure.

The safety-related service water system provides cooling water for heat removal from the reactor plant auxiliary systems during all modes of operation. The ESF building ventilation system provides a suitable environment for personnel and equipment operation and to prevent or minimize the spread or release of airborne radioactive material to the atmosphere. The safety injection pump cooling system transfers heat load from the safety injection pumps bearing oil to the service water system.

The licensee entered the issue in its corrective action program as CR1217060. The licensee performed a visual and ultrasonic examination to characterize the flaw. Unit 3 entered Technical Requirements Manual (TRM) 3.4.10, Structural Integrity - American Society of Mechanical Engineers (ASME) Code Class 1, 2, 3 Components, and performed a structural integrity evaluation (ETE-MP-2023-1003, Revision 1) in accordance with NRC-approved Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1. Based on the structural integrity evaluation and associated operability determination (CA11418803), the licensee concluded the safety function of the 'A' train service water header was maintained and the service water system was operable and capable of performing its design function. The analysis determined that the piping was structurally acceptable under all design-basis accident conditions. The licensee also implemented compensatory actions to perform daily leak rate monitoring and periodic ultrasonic inspections until a full code repair or replacement could be completed. Based on the engineering technical evaluation and operability determination, Unit 3 exited the TRM 3.4.10, Structural Integrity - ASME Code Class 1, 2, 3 Components on January 14, 2023.

The inspectors noted that there was a known, active leak from check valve SWP*V705, which was on the same line, a few feet below this through-wall leak. The inspectors noted that Section 5.2.5 of procedure MA-AA-1002, Leak Management, Revision 7, states, in part, that operations personnel are responsible for... identifying and monitoring leaks as part of their routine walkdowns and issuing condition reports to document new leaks. In review of catch container reports from the fluid leak management program owner, there was no evidence that the active leak from 3SWP*V705 was being tracked as required by Section 5.2.10 of MA-AA-1002. Moreover, Section 12, Equipment Monitoring and Routine Inspections, of 2, Shift Operations, of procedure OP-AA-100, Conduct of Operations, states under General Inspection Items that Each shift Operator performs a thorough, general inspection of assigned areas. Abnormal conditions are corrected on the spot or the proper corrective action initiated and reported to the Shift Manager. This includes for General Area:

oil and water leakage are minimal and external surfaces of components do not exhibit signs of degradation.

The inspectors identified that the licensee did not effectively implement its leak management program with respect to the active leakage from check valve 3SWP*V705, and shift operators did not perform a thorough general inspection of this area. Based on this, and the observable discoloration of the salt deposits emanating from the weld, the inspectors determined that it was reasonable that the licensee could have identified the through-wall leak. Moreover, other licensee personnel such as health physics, security, and system engineering routinely toured this area of the plant and failed to identify the active leak.

Corrective Actions: The licensee entered the issue into its corrective action program as CR1217060, performed a structural integrity evaluation (ETE-MP-2023-1003), extent of condition inspection, and operability determination (CA11418803). The licensee also installed a housekeeping patch to stop any leakage from the system and initiated a work order (WO53203371268) to perform a full code repair or replacement during the next refueling outage.

Corrective Action References: CR1217060

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to monitor known leaks and perform thorough inspections of plant areas, as required by procedures MA-AA-1002 and OP-AA-100, resulted in its failure to identify and correct a through-wall leak, a condition adverse to quality, in a timely manner.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the as-found condition of the weld did not meet the current licensing basis (ASME Code), which resulted in reasonable doubt about the equipments seismic qualifications, which reduced assurance in the equipments availability and reliability. As described by Example 3.e in IMC 0612, Appendix E, regardless of the conclusion of the operability determination, there was reasonable doubt about the seismic qualification because the ASME Class 3 weld was noncompliant due to the through-wall leak.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This finding is a deficiency affecting the qualification of a mitigating SSC, but the SSC maintained its operability and probabilistic risk assessment functionality; therefore, it screens to Green.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the licensee did not effectively implement plant procedures for monitoring existing leaks which, if implemented, would have directed plant personnel to the area where the through-wall leak was located.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective equipment, and non-conformances are promptly identified and corrected.

Contrary to the above, from approximately November 30, 2022 to January 11, 2023, the licensee did not promptly identify and correct a condition adverse to quality. Specifically, it failed to promptly identify a through-wall leak from safety-related, ASME Class III service water piping, which resulted in reasonable doubt about the structural integrity of the piping.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Expired Appendix R Batteries Discovered in the Fire Shutdown Storage Box Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000336/2023001-02 Open/Closed

[H.4] -

Teamwork 71111.24 The inspectors identified a finding of very low safety significance (Green) and an associated NCV of Millstone Unit 2 Operating License Condition 2.C.(3), Fire Protection, for failure to implement and maintain in effect all provisions of the approved fire protection program.

Specifically, the licensee failed to adequately implement SP 2657, Inventory Remote Shutdown Stations Storage Boxes, to ensure the expiration date of the battery packs for the

1. 1 steam generator level and pressure instrumentation were beyond the next performance of the surveillance.

Description:

On January 19, 2023, while electrical maintenance personnel attempted to replace eight 6-volt batteries in the fire shutdown storage box, they communicated that the replacement batteries had quality control issues and the original batteries had an expiration date of December 2022 (CR1217569). Expired batteries required Unit 2 to enter TRM 7.1.26, Support Equipment, Appendix R Components, action statements because they are part of a TRM surveillance to inventory the fire storage box. The batteries were in the expired configuration from January 1, 2023, until they were replaced on February 2, 2023. The fire shutdown box is required to have eight 6-volt batteries available. Four 6-volt batteries are connected in a series to form two sets of 24-volt battery packs. On February 20, 2023, the licensee performed a capacity test of the expired batteries and noted that one of the two battery packs failed to provide the necessary amperage to power the transmitter. The other battery pack did successfully power one transmitter for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

During a postulated fire at Unit 2 in fire area R-1, operations personnel will implement AOP 2579A, Fire Procedure for Hot Standby, Appendix R, Fire Area R-1, to achieve and maintain hot standby outside of the control room at remote shutdown panel C-10 utilizing the turbine driven auxiliary feedwater pump in conjunction with the #2 steam generator. To ensure cold shutdown is achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the #1 steam generator is used for decay heat removal. AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown, Appendix R, Fire Area R-1, directs station personnel to restore the #1 steam generator by selecting the instrumentation wiring and connecting test leads, a digital multimeter, and 24-volt battery pack in series. This provides instrument loop power to the #1 steam generator pressure and level instrument.

The fire shutdown storage box is inventoried once a refueling cycle and was last inventoried on January 3, 2022, the next scheduled surveillance is July 7, 2023, and the batteries were marked with an expiration date of December 2022. The licensee failed to take an appropriate action that would cause the expiration to extend beyond July 7, 2023. The inventory is done to ensure reliability and availability of dedicated repair procedures, equipment, and materials to support a post-fire safe shutdown of Unit 2. During the January 3, 2022, inventory of the surveillance form did not contain documentation, comments, or corrective action addressing the eight 6-volt batteries expiration date. A reoccurring work order scheduled for June 2022 to replace the batteries was never completed and the batteries expired January 1, 2023, which reduced the reliability of these battery packs when needed to provide instrument loop power during implementation of AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown, Appendix R, Fire Area R-1. While the licensee took prompt action to procure new batteries once the condition was identified, the inspectors identified that the licensee had not recognized that the inventory was not adequately performed in accordance with the surveillance procedure on January 3, 2022. In response to the NRCs questions, the licensee initiated CR1219117 to document the inadequate surveillance. Additionally, the inspectors performed an independent inspection of the fire shutdown box on February 10, 2023, and identified other deficiencies with the contents of the fire shutdown box. Specifically, the inspectors identified a pyrometer out of calibration, missing lanterns, and a missing radio charger. The licensee created CR1219297 to address these issues.

Corrective Actions: The licensee entered the TRM action statements and replaced the eight 6-volt batteries on February 2, 2023. The licensee made a corrective action to update the surveillance procedure to document the expiration and calibration dates to help reduce the possibility of this issue.

Corrective Action References: CR1217569, CR1219297, CR1219117

Performance Assessment:

Performance Deficiency: The licensee failed to successfully perform a surveillance to ensure that eight 6-volt batteries in the fire storage box would not expire prior to the next scheduled surveillance. The inspectors determined that the failure to ensure those batteries were not expired was contrary to License Condition 2.C.(3), Fire Protection, as implemented by SP 2657, Inventory Remote Shutdown Stations Storage Boxes, and was a performance deficiency. Specifically, SP 2657, step 4.2.3, IF an item is equipped with a disposable battery, ENSURE the battery Expiration Date is beyond the next performance date of SP 2657, contrary to that, the licensee did not ensure that the batteries would not expire prior to the next performance of the surveillance.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The performance deficiency was more than minor because it was similar to Example 2.a of IMC 0612, Appendix E, and was associated with the Protection Against External Factors (e.g., Fire) attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The performance deficiency was associated with a mitigating system and the as-left inventory was such that the licensee had to enter TRM action statements due to exceeding the expiration date of the eight 6-volt batteries. The expired batteries were on the safe shutdown equipment list and proper maintenance was required to ensure that the batteries could provide loop power to the

1. 1 steam generator pressure and level instrumentation when needed to achieve cold shutdown conditions for a postulated fire in fire area R-1. The inspectors performed a Phase 1 SDP screening in accordance with IMC 0609, Appendix F, and Fire Protection SDP. This finding affected the post-fire safe shutdown category and per step 1.4.7, the performance deficiency did not adversely affect the ability to reach and maintain hot standby using the credited safe shutdown path. Therefore, the finding screened to very low safety significance (Green).

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Operations, maintenance, and work control organizations did not communicate licensing requirements, delays in replacement parts, or important completion dates to one another. This prevented appropriate coordination among the groups to prevent the batteries from expiring.

Enforcement:

Violation: 10 CFR Part 50, Appendix R, Sections III.L, requires there to be an alternative and dedicated shutdown capability to achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. Unit 2 safe shutdown analysis 25203-SP-M2-SU-1046 Section 1.2 states that Unit 2 complies with 10 CFR 50, Appendix R, Sections III.G, J, L, and O. Section 3 of the safe shutdown analysis requires repair to facility 1 instrumentation including the #1 steam generator pressure and wide range level to restore the #1 steam generator and reach cold shutdown in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. SP 2657, Inventory Remote Shutdown Stations Storage Boxes, provides an inventory to ensure safe shutdown equipment needed to reach cold shutdown is available.

Contrary to the above, from January 1, 2023, to February 2, 2023, the licensee failed to ensure eight 6-volt batteries were not expired and that they were available to provide electrical power to the #1 steam generator pressure and level instruments.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: High-Pressure Safety Injection Isolation Limit Switch 71152A The issue of concern was associated with the safety injection isolation miniflow valves (MV8920) internal limit switch broken arm contact.

During a surveillance test, MV 8820B, 'B' residual heat removal discharge valve to the safety injection suction line did not stroke open when required. The failure to open was caused by an interlock limit switch of another valve, MV8920, safety injection miniflow isolation valve that failed to provide the required permissive signal. The valve interlock contact did not make up because the internal limit switch contact arm was broken and was unable to complete the contact and provide the interlock permissive signal to the 'B' residual heat removal discharge valve.

The inspector performed an assessment of the license corrective actions to ensure that actions taken by the licensee were appropriate with NRC regulations and in accordance with their corrective action process. No performance deficiency was identified during the inspection.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On February 28, 2023, the inspectors presented the high-pressure safety injection miniflow isolation limit switch inspection results to Daniel Beachy, Licensing and NRC Coordinator Supervisor, and other members of the licensee staff.

• On March 15, 2023, the inspectors presented the in-plant airborne and occupational dose assessment inspection results to Michael OConnor, Site Vice President, and other members of the licensee staff.

• On April 5, 2023, the inspectors presented the integrated inspection results to Michael OConnor, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Procedures

OP 2271B

Response to Intake Structure Degraded Conditions

Revision 005

OP 3215

Response to Intake Structure Degraded Conditions

Revision 016

SP 2654R

Weather and Seas Condition Determination

Revision 005

SP 3665.2

Intake Structure Condition Determination

Revision 012

71111.04

Corrective Action

Documents

CR1217826

CR1217060

CR1217238

CR1217584

CR1217921

CR1217973

CR1221595

Drawings

203-26015

Piping and Instrumentation Diagram High-Pressure Safety

Injection Pumps, Sheet 2

Revision 51

203-26017

Piping and Instrumentation Diagram Charging System

Revision 67

212-26930

Piping and Instrumentation Diagram Feedwater System,

Sheet 2

Revision 49

212-26933

Piping and Instrumentation Diagram Service Water, Sheet 2

Revision 95

Procedures

OP 3208

High-Pressure Safety Injection System

Revision 14

OP 3322-002

Auxiliary Feedwater Train A

Revision 8

SP 2601H

'C' Charging Pump and Discharge Check IST

Revision 12

71111.05

Calculations

MP-CALC-ENG-

EPM

186 Calculation No. EPM-186, Millstone Nuclear Power

Plant Unit 2

Corrective Action

Documents

CR1215631

Corrective Action

Documents

Resulting from

Inspection

CR1219002

CR1219117

CR1219297

Engineering

Evaluations

MP-SPEC-ENG-

SP-M2-SU-1046

MP2 Appendix R Compliance Report

Revision 01

Procedures

EOP 3509

Fire Emergency

Revision 39

MP-PROC-ENG-

U2-24-FFS-

BAP01

Fire Fighting Strategies

Revision 003

SA-AA-115

Fire Protection Maintenance

Revision 7

71111.06

Drawings

203-24101

Containment & Aux. Bldg. el. 45'-6" Barrier Boundaries

04/27/1994

Miscellaneous

Probabilistic Risk Assessment Internal Flooding NOTEBK-

PRA-MPS2-IF.2

Revision 6

Millstone Power Station Unit 2 Probabilistic Risk

Assessment Model Notebook Category IF - Internal Flood

71111.11Q Procedures

AD-AA-102

Procedure Use and Adherence

Revision 16

OP-2204

Load Changes

Revision 48

OP-2208

Reactivity Calculations

Revision 17

OP-3206

Plant Shutdown

Revision 27-

OTO1

OP-AA-100

Conduct of Operations

Revision 46

OP-AA-300

Reactivity Management

Revision 28

71111.13

Calculations

Unit 2 Current Risk Summary Report

01/26/2023

Unit 3 Current Risk Summary Report

2/01/2023

Corrective Action

Documents

CR1222606

CR1222735

Procedures

AOP 2557

Emergency Generation Reduction

Revision 012

ARP 2591A-006

Jacket Coolant Level Low

Revision 003

C OP 200.6

Storms and Other Hazardous Phenomena (Preparation

and Recovery)

Revision 011

C OP 200.8

Response to ISO New England/CONVEX Notifications and

Alerts

Revision 007

OP-2346A14

A EDG Jacket Water Feed and Bleed

Revision 3

OP-AA-100

Conduct of Operations Standing Order 23-01

Revision 45

SP 2619G-005

AC Sources Daily Surveillance

Revision 1

SP 2619G-006

EDG Inoperable for Extend Maintenance Outage

Revision 4

SP 3646A.7

AC Electrical Sources Inoperability

Revision 015

WM-AA-20

Risk Assessment of Maintenance Activities

Revision 2

WM-AA-301

Medium Risk Plan Actions

03/22/2023

WM-AA-301

Medium Risk Plan for Switchyard Work and Post

Contingent Backdown

01/11/2023

WM-AA-301

Operational Risk Assessment

Revision 23

Work Orders

53103058973

203268986

203377101

71111.15

Corrective Action

Documents

CA11748001

CA11756030

CA11761167

CR1222619

CR1220984

Corrective Action

Documents

Resulting from

Inspection

CR1220883

Drawings

203-26017

PI&D Deborating & Purification System, Sheet 2

Revision 38

Engineering

Evaluations

ETE-MP-2023-

22

Code Case N-513-4 Evaluation of Unit 3 Service Water

Flaw Located in Line 3-SWP-006-261-03, DS of Lap Joint

Flange

Revision 0

Miscellaneous

ETE-CPR-2012-

0009

FLEX Strategy Overall Integrated Plan

Revision 9

NEI 16-08

Guidance for Optimizing the Use of Portable Equipment

Revision 0

Procedures

C OP 200.15

RCS Leakage Trending and Investigation

Revision 004

CM-AA-BDB-101

Beyond Design Basis FLEX Program Maintenance

Revision 7

CM-AA-BDB-102

Beyond Design Basis FLEX Equipment Unavailability

Tracking

Revision 12

MP 2712B1

Control of Heavy Loads

Revision 016

SP 2614C

MP2 Cask Crane Restricted Load Path Checks

Revision 009

71111.18

Drawings

DWG-MP-3-V-

59000

SH-00021001 Stackable Flood Barrier for #123-14-001A

Engineering

Changes

EC MPG-21-

01026

Work Orders

203360197

71111.20

Miscellaneous

2R28 Shutdown Risk Schedule Review Memorandum

03/13/2022

71111.24

Corrective Action

Documents

CR1212489

CR1219117

Corrective Action

Documents

Resulting from

Inspection

CR1219297

Fire Plans

M2-EV-0 1-

0006

Emergency Diesel Generator Availability During Testing

Revision 02

Miscellaneous

203-ER-98-

0056

EDO Parallel Operation to NSST or RSST - CR M2-97-1065

Revision 0

203-SP-M2-

SU-1046

MP 2 Appendix R Compliance Report

Revision 1

Operability

Evaluations

SO-22-015

RWST to Charging Header Isolation Valve Operation in

AOPs

11/10/2022

Procedures

OP 2346A-004

'A' Diesel Generator Data Sheet

Revision 26

SP 2601C

CVCS Valve Tests, IST

Revision 013

SP 2601O

Manual Cycling of CVCS AOV

Revision 01

SP 2611G

'B' RBCCW Pump Tests

Revision 009

SP 2613K

Diesel Generator Slow Start Operability Test Facility 1

Revision 7

SP 2613O

'A' Emergency Diesel Generator Hot Restart

Revision 006

SP 2657

Inventory Remote Shutdown Stations Storage Boxes

Revision 10

Work Orders

203257219

203305676

71152A

Corrective Action

Documents

CR1199404

CR1198921

Corrective Action

Documents

Resulting from

Inspection

CR1120599

Procedures

ER-AA-PRS-

1003

Equipment Reliability Component Classifications

Revision 10

Work Orders

203350844

203350316

203350843