IR 05000336/2023010

Commercial Grade Dedication Report 05000336/2023010 and 05000423/2023010

ML23251A053
Person / Time
Site:	Millstone
Issue date:	09/08/2023
From:	Glenn Dentel NRC/RGN-I/DORS
To:	Carr E Dominion Energy
References
IR 2023010
Download: ML23251A053 (1)

Text

September 8, 2023

SUBJECT:

MILLSTONE POWER STATION, UNITS 2 AND 3 - COMMERCIAL GRADE DEDICATION REPORT 05000336/2023010 AND 05000423/2023010

Dear Eric Carr:

On August 3, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station, Units 2 and 3 and discussed the results of this inspection with Lori Armstrong, Director Nuclear Station Safety and Licensing, a nd other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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, DC 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, DC 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, Glenn T. Dentel, Chief Engineering 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: 05000336/2023010 and 05000423/2023010

Enterprise Identifier: I-2023-010- 0034

Licensee: Dominion Energy Nuclear Connecticut, Inc.

Facility: Millstone Power Station, Units 2 and 3

Location: Waterford, CT

Inspection Dates: July 17, 2023 to August 3, 2023

Inspectors: J. Brand, Reactor Inspector E. Miller, Reactor Inspector M. Patel, Senior Reactor Inspector

Approved By: Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Commercial Grade Dedication 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

Failure to Identify and Evaluate Critical Characteristics in the Procurement Process for Safety Injection Tank Vent Valve Diaphragm.

Cornerstone Significance Cross-Cutting Report Section Aspect Mitigating Green [H.8] - 71111.21N.03 Systems NCV 05000336/2023010-01 Procedure Open/Closed Adherence An NRC identified green finding and non-cited violation (NCV) for 10 CFR Appendix B, Criterion IV, "Procurement Document Control," when Dominion failed to identify and evaluate adequate critical characteristics for a procurement technical evaluation. Specifically, Dominion failed to identify and evaluate that the diaphragms installed in the Unit 2 Safety Injection Tank (SIT) vent to containment valves, M22-SI-613, 623, 633, 643, needed to withstand accident temperatures of 279 degrees Fahrenheit and failed to establish critical characteristics to ensure that the diaphragm would meet design specifications.

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.

REACTOR SAFETY

71111.21N.03 - Commercial Grade Dedication Commercial Grade Dedication (Section 03.01)

The inspectors reviewed the implementation of the licensees processes for dedicating commercial grade items/services as basic components and/or for procuring safety-related structures, systems, and components for the following samples:

(1) Breaker - 200 amp, thermal magnetic breaker (PO# MP-PO-MAT-4500691669-00002-000000306987, MM# 42202531, DP# MP-PTE- 000- 10000015656, Revision 12)

(2) Diaphragm - 13" diameter, 1/2" BUNA-N diaphragm (PO# MP-PO-MAT-4500669375-00001-000000303297_M3668251, MM# M3668251, DP# MP-PTE- 000-9004677, Revision 5)

(3) Capacitor - E2 Capacitor; axial, radial, can and snap-in style (PO# MP-PO-MAT-4500483913-00002- 000000281211_42036832, MM# 42036832, Dedication Plan No.

DP# MP-PTE-000-10000033884, Revision 34)

(4) Lubricant - SRI-2 bearing grease ((MP-PO-MAT-4500398858-00001-000000262003_M3525291, MM# M3525291, MP-PTE- 000- 10000016316, Revision 2)

(5) Shroud coupling repair kit 2-1/2, for the Unit 3 Turbine Driven Auxiliary Feedwater Pump M33FWA*P1A (P.O #4500486551-00001- 0274272, MM# M4196401, PTE 1000022684, Revision 2)

(6) Valve replacement for Unit 2 SW-183B (P.O# 4500427069-00001-0265853, MM#

M3699141, PTE-10000053564, Revision 1)

(7) Belt replacement for Unit 2, Direct Current Switchgear Fan M2F54B (P.O#

4500580286-00001-0290106, MM# M3705591, PTE-10000052755, Revision 3)

(8) Pipe sleeve for Unit 2, Service Water M224-KE-1 (P.O# 4500849344-00001-0331256, MM# M42498517, PTE-10000073249, Revision 1)

(9) Controller amplifier for Unit 3, Turbine Driven Auxiliary Feedwater valve M33FWA-032D (P.O# 4500410747-00001- 0263559, MM# 42299355, PTE -10000052604, Revision 0)

(10) Lubricant for Unit 2 Turbine Driven Auxiliary Feedwater Governor replacement M2P4G (P.O# 4500549117-00001- 0283929, MM# M2912521, PTE-10000038503, Revision 3)

(11) Coupling - Coupling for the Unit 3 1B Charging Pump Cooling Pump Motor (PO#4500616377-00001-000000295897, MM# 42300299, DP# 10000052759, Revision 1)

(12) Power Supply - Unit 2 Reactor Pressure System Trip Unit Power Supply (PO#4500701147-00003-000000308011, MM# M2959421, DP# 10000015359, Revision 4)

(13) Contact Block - Contact Block for the Unit 3 A Diesel Generator Control Relays (PO#4500602027-00002-000000293575, MM# 42115851, DP# 10000059697, Revision 2)

(14) Circuit Board - Circuit Board Battery replacement for Unit 3 Radiation Monitor (PO#4500436816-00001-000000269369, MM# M3118051, DP# 10000022065, Revision 4)

(15) Auxiliary Contact - Auxiliary Contact for Unit 2 B Diesel Generator Pre-Lube Oil Pump (PO#4500604184-00001-000000293686, MM# 42336174, DP# 10000058567, Revision 0)

INSPECTION RESULTS

Failure to Identify and Evaluate Critical Characteristics in the Procurement Process for Safety Injection Tank Vent Valve Diaphragm Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71111.21N.03 Systems NCV 05000336/2023010 - 01 Procedure Open/Closed Adherence An NRC identified green finding and non-cited v iolation (NCV) for 10 CFR Appendix B, Criterion IV, "Procurement Document Control," when Dominion failed to identify and evaluate adequate critical characteristics for a procurement technical evaluation. Specifically, Dominion failed to identify and evaluate that the diaphragms installed in the Unit 2 Safety Injection Tank (SIT) vent to containment valves, M22-SI-613, 623, 633, 643, needed to withstand accident temperatures of 279 degrees Fahrenheit and failed to establish critical characteristics to ensu re that the diaphragm would meet design specifications.

Description:

The SIT vent to containment valves, M22 -SI-613, 623, 633, 643 are air operated valves that maintain the high end of the nitrogen pressure band for the 4 SITs. Originally, these valves had a safety function to close, but a modification performed in 1999, DC - M2 - 99004, reassigned these components to have dual safety functions to both close and open.

These components will fail close on loss of air or failure of the diaphragm. The new open safety function is to prevent the nitrogen intrusion into the reactor coolant system during a small break loss of coolant accident. During this accident condition, the atmospheric temperature inside of containment is expected to reach temperatures up to 279 degrees Fahrenheit.

When reviewing the procurement technical evaluation (PTE) for the diaphragms installed in these valves, inspectors questioned the temperature capabilities of the BUNA - N diaphragms that were installed in the SIT system.

Discussions with the vendor revealed that these diaphragms had a thermal limit of only 220 degrees Fahrenheit.

In March 2021, Revision 4 of Procurement Technical Evaluation, MP - PTE- 000- 9004677, was utilized for the procurement of the diaphr agms installed in the system, and it did not include the design accident temperature nor the diaphragms design temperature in the evaluation.

Furthermore, it did not evaluate the temperature limitations of the diaphragm as part of the critical characteristics. MS-AA-PTE-401 -1004, Commercial Grade Dedication, provides guidance for Dominion in the development of procurement technical evaluations, and it has guidance to select critical characteristics based on safety function and accident conditions.

Corrective Actions: Dominion wrote a corrective action and set the status of Procurement Technical Evaluation, MP-PTE- 000- 9004677 to review required to prevent it from being used until the condition report (CR) could be resolved.

Corrective Action References: CR1234417

Performance Assessment:

Performance Deficiency: Dominion procedure MS-AA-PTE-401-1004, Commercial Grade Dedication, Step 3.4.1 states that engineering must select critical characteristics for acceptance based on complexity, safety function, and performance of a commercial grade item and to utilize tools which include the Design basis requirements for normal or accident conditions of service. During the dedication process, the procurement process failed to identify the requirement for the diaphragm to be able to withstand accident conditions that included temperatures exceeding the BUNA-N thermal limits and evaluate whether the component was adequate for the environment.

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. This finding closely parallels IMC 0612 Appendix E example 3.M. for more than minor, which states in part that the performance defi ciency was associated with the E quipment Performance attribute of the Mitigating Systems cornerstone, adversely affected the cornerstone objective, and through the process of performing the functionality determination, there was reasonable doubt regarding the availability, reliability, or capability of the valves.

Specifically, the design temperature was below the containment accident temperature, and a new approach to support the use of these BUNA-N diaphragms had to be utilized. The inspectors reviewed the prompt operability evaluation and determined that based on the refined engineering analysis related to the temperature profile within containment during accident conditions, the utilization time of the valves during accident conditions based on procedure review, and the industry testing data related to similar elastomer family, provided reasonable assurance to the inspectors that the diaphragm will maintain its operability and functionality.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Si gnificance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power dated January 1 st, 2021. The inspectors determined that this finding was of very low safety significance (Green) because the deficiency affecting the qualification of the associated structure, system, or component maintains its operability and PRA functionality.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Individuals follow processes, procedures, and work instructions.

Dominion personnel failed to adequately create a PTE based off the instructions in MS-AA-PTE-401-1004, Commercial Grade Dedication, and ensure that the PTE analyzed the procured diaphragm for maximum design basis temperature.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion IV, Procurement Document Control, states, in part, measures shall be established to assure that applicable design bases and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services. Contrary to the above, since February 23, 2021, the licensee did not assure that the design basis requirements for the SIT vent to Containment valve diaphragm were suitably included in the documents for procurement of a replacement diaphragm. Specifically, Procurement Technical Evaluation, MP-PTE- 000-9004677, did not adequately identify the critical characteristics to verify design function nor evaluate the temperature requirements for the BUNA-N diaphragm during an accident condition.

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

EXIT MEETINGS AND DEBRIEFS

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

• On August 3, 2023, the inspectors presented the Commercial Grade Dedication results to Lori Armstrong, Director Nuclear Station Safety and Licensing, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.03 Corrective Action 1036100

Documents 1081789

1182100

29098

1178810

1140182

71111.21N.03 Corrective Action 1229098

Documents 1233700

Resulting from 1234413

Inspection 1234417

235116

71111.21N.03 Drawings 25212-30268 SH20A, MS U-3, AFW System Control Valve Revision 5

3FW*HV32D, Test Loop Diaphragm

71111.21N.03 Engineering DNC-DC M2-Safety Injection Tank Nitrogen System Modification Revision 0

Changes 99004

71111.21N.03 Engineering MP2-23-01060 U-2 A Train 24KE-1-Service Water Pipe Degradation Revision 1

Changes Restoration

71111.21N.03 Engineering MP3-17-00111 Replacement of 3CCE*P1B Charging Pump Cooling Revision 0

Changes Pump Motor

71111.21N.03 Miscellaneous Survey 24130 NUPIC Commercial Grade Item Survey, Engineering 10/17/2016

Solutions Good Year, AZ

71111.21N.03 Miscellaneous Survey 24630 NUPIC Commercial Grade Item Survey, Exxon Mobil Fuel 10/10/2018

& Lubricants Company Beaumont, TX

71111.21N.03 Procedures MS-AA-MVL-101 Quality Receipt Inspection Revision 9

71111.21N.03 Procedures MS-AA-PRO-401 Procurement Control Revision 12

71111.21N.03 Procedures MS-AA-PTE-401 Procurement Technical Evaluation Determination Revision 19

71111.21N.03 Procedures MS-AA-PTE-401-Commercial Grade Dedication Revision 11

1004

71111.21N.03 Work Orders 53102574458

53102866598

53102904845

53103131320

Inspection Type Designation Description or Title Revision or

Procedure Date

203357736

203381122

53102766108

203268963

53102717485

53102571707

53102512739

53102570013

53102570551

203321776

203295851

8