IR 05000336/2024003
| ML24311A220 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Calvert Cliffs (DPR-065, NPF-049) |
| Issue date: | 11/07/2024 |
| From: | Matt Young Division of Operating Reactors |
| To: | Carr E Dominion Energy |
| References | |
| IR 2024001, IR 2024003 | |
| Download: ML24311A220 (1) | |
Text
November 7, 2024
SUBJECT:
MILLSTONE POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000336/2024003 AND 05000423/2024003 AND APPARENT VIOLATION AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200008/2024001
Dear Eric Carr:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station, Units 2 and 3. On October 2, 2024, the NRC inspectors discussed the results of this inspection with Michael O'Connor, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. We determined that additional follow-up using Inspection Procedure 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution, was not warranted because the violation can be appropriately sampled using baseline inspection resources.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as an NCV 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, 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. 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 (10 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, 05000423, and 07200008 License Nos. DPR-65 and NPF-49
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000336, 05000423, and 07200008
License Numbers:
Report Numbers:
05000336/2024003, 05000423/2024003, and 07200008/2024001
Enterprise Identifier: I-2024-003-0037 and I-2024-001-0061
Licensee:
Dominion Energy Nuclear Connecticut, Inc.
Facility:
Millstone Power Station, Units 2 and 3
Location:
Waterford, CT
Inspection Dates:
July 1, 2024 to September 30, 2024
Inspectors:
J. Fuller, Senior Resident Inspector
D. Antonangeli, Resident Inspector
E. Bousquet, Resident Inspector
N. Eckhoff, Health Physicist
C. Hargest, Health Physicist
M. Henrion, Senior Health Physicist
A. Kostick, Health Physicist
K. Mangan, Senior Reactor Inspector
N. Mentzer, Reactor Inspector
T. Winkel, 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. A licensee -identified non-cited violation (NCV) is documented in report Section 71111.0
List of Findings and Violations
Oil Leakage from Containment Recirculation Pump Motor Challenged Meeting Its Mission Time Resulting in a Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000423/2024003-01 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV NCV of Technical Specification (TS) 3.6.2.2, Recirculation Spray System, was identified when the licensee observed that the motor upper bearing oil level for the Unit 3 'C' containment recirculation spray system (RSS) pump (3RSS*P1C) was below the acceptance criteria.
Additional Tracking Items
Type Issue Number Title Report Section Status AV 05000336/2024001-01 Failure to Implement Structures Monitoring Program and Infrequently Accessed Areas Inspection Program for the Condensate Storage Tank Pipe Trench 71111.12 Discussed LER 05000423/2023-002-00 LER 2023-002-00 for Millstone Power Station,
Unit 3, Auxiliary Feedwater Control Valve Failure Resulting in a Condition Prohibited by Technical Specifications 71153 Closed LER 05000423/2023-005-00 LER 2023-005-00 for Millstone Power Station,
Unit 3, Oil Leakage from 'C'
RSS Pump Motor Challenged Meeting Its Mission Time Resulting in a Condition Prohibited by Technical Specifications 71153 Closed
PLANT STATUS
Unit 2 operated at or near rated thermal power for the entire inspection period.
Unit 3 began the inspection period at rated thermal power. On September 3, 2024, the unit was shut down for a planned maintenance outage to replace a pressurizer safety relief valve and reactor coolant pump seal. The unit was returned to rated thermal power on September 18, 2024, and remained at or near rated thermal power for the remainder of the inspection period.
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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures during the week of July 6, 2024, for the following systems:
- Units 2 and 3 intake building ventilation systems
- Unit 3 engineered safety feature ventilation systems
- Unit 3 emergency diesel generator enclosure
- Station blackout diesel enclosure
71111.04 - Equipment Alignment
Partial Walkdown (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 'A' train of the main feedwater system in the turbine building on July 8, 2024
- (2) Unit 3 'B' high-pressure safety injection from the refueling water storage tank to containment penetrations on July 16, 2024
- (3) Unit 3 supplementary leak collection and release system in the auxiliary building near the waste disposal building exhaust fans on August 21, 2024
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 turbine lubricating oil system on the 14'-6" elevation (fire area T-2) on July 8, 2024
- (2) Unit 2 sample sink area and A-12C boronmeter room in the auxiliary building on the 14'-6" elevation (fire area A-12B) on July 19, 2024
- (3) Unit 2 waste gas decay tank area in the auxiliary building on the 14'-6" elevation (fire area A-1E) on July 26, 2024
- (4) Unit 3 engineered safety features building, south containment recirculation cooler cubicle (fire area ESF-1), on August 29, 2024
- (5) Unit 2 top of fuel pool and fuel handling area (fire area A-14C) on September 18, 2024
- (6) Unit 3 turbine building operating floor, turbine shaft area, and general support lay down (fire areas TB-2D, TB-2E, and TB-2F) on September 25, 2024
- (7) Unit 3 machine shop (fire areas MS-1A, MS-1B, MS-1C, MS-1D, MS-1E, MS-1F, MS-1G, MS-1H, and MS-1I) on September 25, 2024
Fire Brigade Drill Performance (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the on-site fire brigade training and performance during response to a valid fire alarm for the Unit 2 service building on September 4, 2024
71111.06 - Flood Protection Measures
Flooding (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the Unit 3 emergency diesel generators enclosure building on September 5, 2024
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 2 control room during operation of the 'A' emergency diesel generator and increased risk due to SPEC 200 card replacement on July 3, 2024, and during operators response to an unplanned reactor coolant system pressure transient on August 1, 2024.
- (2) The inspectors observed and evaluated licensed operator performance in the Unit 3 control room during entry into a fire emergency operating procedure on July 10, 2024, and while operators performed a planned shutdown on September 3, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated Unit 3 operator requalification training on August 8, 2024.
- (2) The inspectors observed and evaluated Unit 2 licensed operator performance during simulator training on shutdown plant conditions on August 28, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2 'A' control room air condition system maintenance rule a(1) evaluation
- (2) Unit 3 emergency diesel generators maintenance rule monitoring and scoping
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Unit 3 control of quality parts for 'B' pressurizer safety valve 3RCS*SV8010B (work order (WO) 53203408458)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management (IP Section 03.01) (5 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 2 elevated risk during 'A' emergency diesel generator operation and online SPEC 200 card replacement when the 'A' reactor building closed-cooling water heat exchanger was out of service for inspection and cleaning on July 3, 2024
- (2) Units 2 and 3 risk mitigating actions associated with the station blackout diesel out of service for planned maintenance on July 15, 2024 (WO53102548942)
- (3) Unit 3 high-risk plan and associated mitigating actions associated with installation of a temporary modification (MP3-24-01062) for battery 6 on August 21, 2024 (WO53203423397)
- (4) Unit 3 elevated risk during solid-state protection system testing while the reactor coolant system was operating under solid plant pressure control, which is an infrequently conducted and complex evolution, on September 6, 2024 (Surveillance Procedure (SP) 3446B11)
- (5) Units 2 and 3 elevated risk and associated mitigating actions with Bus 24E out of service on September 23 and 24, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 2 reserve station service transformer after receiving out of sync alarm on July 7, 2024 (CR1263558, CR1263797)
- (2) Unit 2 operational decision-making checklist for the failure of both main pressurizer spray flow control valves on August 1, 2024 (CR1265532, CR1265633, CR1266044)
- (3) Unit 3 operational decision-making checklist and associated trigger points for increased reactor coolant system leakage through the 'B' pressurizer safety relief valve on August 22, 2024 (CR1267068, CR1266657, CR1264896)
- (4) Unit 3 reactor vessel head vent isolation valve did not show open indication when expected during surveillance testing on September 7, 2024 (CR1268273)
- (5) Unit 2 structural integrity and operability evaluations for the water supply to all three auxiliary feedwater pumps due to a latent calculation error for a pipe support in the condensate storage tank (CST) pipe trench on September 16, 2024 (CR1258936)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 2 temporary engineering change number MP2-24-01017, Temporary Change to M2TI-106 Pressurizer Relief Temp Set-Point, Revision 0, on July 2, 2024
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 3 forced outage activities from September 3 to 16, 2024
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 (PMT) (IP Section 03.01) (8 Samples)
- (1) Unit 2 steam generator level transmitter (L52773A) after replacement of a failed circuit card on July 3, 2024 (WO53203423375, CR1263144)
- (2) Units 2 and 3 station blackout diesel after planned maintenance on July 16, 2024 (WO53203409674)
- (3) Unit 2 engineered safeguards actuation system channel for #1 steam generator pressure indication on July 19, 2024 (WO53203424473 and CR1264672)
- (4) Unit 3 3HVK*CHL1B following maintenance outage during the week of July 22, 2024 (WO53203364234)
- (5) Unit 3 mechanical cleaning of the heat exchanger for the west motor control center rod control and cable vault air conditioning unit on July 23, 2024 (WO53203383602)
- (6) Unit 3 reinstallation of waste disposal exhaust fan, 3HVR*FN8A, as part of the boundary for the supplementary leak collection and release system on August 21, 2024 (CR1266993)
- (7) Unit 3 replacement of the 'B' pressurizer safety relief valve on September 5, 2024 (WO53203408458)
- (8) Unit 2 following repair of vital motor control center B51 air cooling unit, AC3, on September 19, 2024 (WO53203423527, WO53203438705)
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) Unit 3 emergency diesel generator 'B' monthly operability test on July 23, 2024
- (2) Unit 2 turbine-drive auxiliary feedwater surveillance testing on July 24, 2024
Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) Unit 3 elevated unidentified leakage that met action level 3 limits on August 9, 2024 (CR1266108, CR1267066, CR1267610)
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
- (1) The inspectors evaluated Unit 3 emergency planning drill and event classification in the simulator and emergency operations facility on August 20,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Unit 2 plant gaseous ventilation system and radiation monitor RM8132A/B
- (2) Unit 2 liquid effluent radiation monitor system RM4262
- (3) Unit 3 plant gaseous ventilation system and the charcoal banks 3HVR*FLT3A/B
- (4) Unit 3 liquid effluent radiation monitor system 3SSR-RE08
Sampling and Analysis (IP Section 03.02) (4 Samples)
Inspectors evaluated the following effluent samples, sampling processes, and compensatory samples:
- (1) Unit 3 charcoal and particulate filter air sample from 3HVQ-RE49
- (2) Unit 3 analysis of charcoal and particulate sample from HVR-10B
- (3) Unit 3 analysis of charcoal and particulate sample from HVR-19B
- (4) Unit 2 analysis of charcoal and particulate sample from RM8169A
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) Analysis of annual gaseous effluent release projected dose estimates for 2023
- (2) Unit 3 gaseous effluents through supplementary leakage collection and release system, effluent permit number G-EFF3-20240903-418-C
Abnormal Discharges (IP Section 03.04) (1 Sample)
The inspectors evaluated the following abnormal discharges:
- (1) Unit 3 analysis of auxiliary building effluent discharge to DSN-006 for Co-60 and H-3 on April 16,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) (IP Section 02.04)===
- (1) Unit 2 July 1, 2023 through June 30, 2024
- (2) Unit 3 July 1, 2023 through June 30, 2024
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 2 July 1, 2023 through June 30, 2024
- (2) Unit 3 July 1, 2023 through June 30, 2024
MS07: High-Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 2 July 1, 2023 through June 30, 2024
- (2) Unit 3 July 1, 2023 through June 30, 2024
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 2 July 1, 2023 through June 30, 2024
- (2) Unit 3 July 1, 2023 through June 30, 2024
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 2 July 1, 2023 through June 30, 2024
- (2) Unit 3 July 1, 2023 through June 30, 2024
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 2 July 1, 2023 through June 30, 2024
- (2) Unit 3 July 1, 2023 through June 30, 2024
===71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03)===
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Unit 3 spurious control building isolation due to 3HVC*RE16 radiation monitors (Evaluation CA12797781)
- (2) Evaluation of the cause and corrective actions taken by the licensee associated with several Unit 2 reactor coolant pump seal failures following the 2023 refueling outage (CR1250497)
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential adverse trends related to missed fire roves that might be indicative of a more significant safety issue (CR1249971).
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.
- (1) Licensee Event Report (LER) 05000423/2023-005-00, Oil Leakage from 'C' RSS Pump Motor Challenged Meeting Its Mission Time Resulting in a Condition Prohibited by Technical Specifications, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24039A186): The inspection conclusions associated with this LER are documented in this report under the Inspection Results Section, Severity Level IV NCV. This LER is closed.
- (2) LER 05000423/2023-002-00, Auxiliary Feedwater Control Valve Failure Resulting in a Condition Prohibited by Technical Specifications (ADAMS Accession No.
ML23334A152): The circumstances surrounding this LER and a Green NCV
===05000423/2023004-02 are documented in Millstone Power Station, Units 2 and 3 - Integrated Inspection Report 05000336/2023004 and 05000423/2023004 (ADAMS Accession No. ML24045A114) under the Inspection Results Section 71152A. The inspectors determined the deficiency documented in the NCV directly led to the failure to meet TS 3.7.1.2 and TS 3.6.3; therefore, a separate TS violation is not warranted. This LER is closed.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855 - Operation of an Independent Spent Fuel Storage Installation (ISFSI)
The inspectors evaluated the licensee's ISFSI Unit 2 dry storage cask (DSC) loadings from July 22 to 25, 2024. Specifically, the inspectors observed the following activities:
Operation of an ISFSI===
(1)
- Fuel verification for DSC #1
- Fuel loading for DSC #2
- Welding and nondestructive examination on DSC #2
- Radiation protection and as low as reasonably achievable practices throughout the loading campaign
- ISFSI heavy haul path material conditions
- ISFSI pad material conditions
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.04 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Unit 3 TS 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operation), Revision 2, February 1978. Specifically, RG 1.33, Appendix A, Section 9, Procedures for Performing Maintenance, Part A, states, in part, Maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
TS 3.6.6.2 requires that while the plant is in Modes 1, 2, 3, or 4, secondary containment shall be operable. The TS ACTION statement requires that with secondary containment inoperable, restore secondary containment to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, from August 2 to 21, 2024, with Unit 3 in Mode 1, maintenance that affected the safety-related secondary containment boundary was not properly pre-planned and work instructions were not appropriate to the circumstances. Specifically, the licensee failed to enter TS 3.6.6.2 when the waste building exhaust fan, 3HVR-FN8A, was physically removed from the ventilation system, which rendered the secondary containment not operable. As a result, the secondary containment was inoperable for approximately 19 days, and the licensee had not entered the appropriate TS action statement.
Significance/Severity: Green. The inspectors evaluated this finding using IMC 0609, 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined the finding to be of very low safety significance because the finding only represented a degradation of the radiological barrier function provided for the auxiliary building. Therefore, the finding was of very low safety significance (Green).
Corrective Action References: CR1266993 AV (Discussed)
Failure to Implement Structures Monitoring Program and Infrequently Accessed Areas Inspection Program for the Condensate Storage Tank Pipe Trench AV 05000336/2024001-01 71111.12
Description:
During this inspection period, the inspectors identified a third aging management program commitment (Buried Pipe Inspection Program) that had not been implemented prior to entering the period of extended operation as required by Millstone Unit 2, License Condition 2.C.(11).
Section 15.2.1.4, Buried Pipe Inspection Program, states, in part, The following program enhancements will be implemented prior to the period of extended operation: A baseline inspection of the in-scope buried piping located in a damp soil environment has been performed for a representative sample of each combination of material and protective measures. Inspection for the loss of material due to selective leaching has been performed by visual, mechanical, or other appropriate methods. These inspections complete the actions required for Commitment Item 3 in Table 15.6-1.
ETE-MP-2012-1248, Underground Pipe and Tank Program Life Cycle Management Plan Technical Basis, identifies that the condensate storage and auxiliary feedwater lines 10-HBD-45 and 10-HBD-46, which supply auxiliary feedwater from the CST to all three auxiliary feedwater pumps, are contained in the CST pipe trench and are required to be visually inspected per WO53102501784 and procedure MP-VE-5,Visual Examination Procedure for the Examination of Interior/Exterior Surfaces of Piping and Components, prior to the period of extended operation. The inspectors identified that WO53102501784 was cancelled on June 14, 2014, prior to the period of extended operation, with a note that stated the inspections for the subject piping will be performed under the inservice inspection program and not the underground piping program.
Procedure MP-VE-5, Revision 1, required a direct visual examination of the piping to detect and record surface conditions such as cracks, wear, erosion, general corrosion, flow accelerated corrosion, leakage, physical damage, or other surface conditions. As noted above, this inspection was not performed. The American Society of Mechanical Engineers,Section XI, inspection (i.e., the inservice inspection) that was performed did not require a direct visual examination of the piping. Therefore, the inspectors determined that the license renewal commitment to perform the buried pipe direct visual examination prior to the period of extended operation was not implemented for these two auxiliary feedwater supply lines contained in the CST pipe trench. As of the end of the inspection period, the licensee has not yet performed the inspections of the CST pipe trench or the auxiliary feedwater supply lines in accordance with the structures monitoring, the infrequently accessed areas, and buried pipe inspection programs.
The inspectors determined that the failure to implement the Buried Pipe Inspection Program for these two lines is a third example of the same performance deficiency previously described in Apparent Violation 05000336/2024001-01, Failure to Implement Structures Monitoring Program and Infrequently Accessed Areas Inspection Program for the Condensate Storage Tank Pipe Trench.
The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Because the licensee has not performed an inspection of the CST pipe trench, and the inspectors do not have access to directly observe current CST pipe trench conditions, the inspectors could not answer the screening questions provided by Exhibit 2 - Mitigating Systems Screening Questions. As a result, the inspectors could not screen the issue to Green and do not have enough information to complete a detailed risk evaluation. The finding is pending a significance determination, which cannot be performed until sufficient information on the condition of the CST pipe trench SSCs is available after required inspections.
Observation: Semiannual Trend Review for Missed Fire Roves 71152S The inspectors reviewed the licensees corrective action program for potential adverse trends related to missed fire roves that might be indicative of a more significant safety issue. The inspectors reviewed licensee CR1249971, which documented an adverse trend with missed fire roves at both Units 2 and 3 on February 1, 2024. The inspectors reviewed the licensee's corrective actions and conducted a review of 2024 corrective action records to determine if the specified corrective actions were effective at correcting the issue with missed fire roves.
The inspectors did not identify any other instances of missed fire roves since the trend CR was written in February 2024. Moreover, the inspectors reviewed records for a sample of areas that required a fire rove and did not identify any missed fire roves. Based on this review, the inspectors determined that the licensee's corrective action has been effective, and that the instances of missed fire roves did not lead to a safety issue and did not represent an adverse trend.
Oil Leakage from Containment Recirculation Pump Motor Challenged Meeting Its Mission Time Resulting in a Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000423/2024003-01 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV NCV of TS 3.6.2.2, Recirculation Spray System, was identified when the licensee observed that the motor upper bearing oil level for the Unit 3 'C' containment RSS pump (3RSS*P1C) was below the acceptance criteria.
Description:
On December 10, 2023, with Unit 3 at 47 percent power, while performing routine monthly SP 3670.4, Monthly PMs, the licensee observed that the motor upper bearing oil level for Unit 3 'C' containment RSS pump (3RSS*P1C) was below the acceptance criteria. The motor upper bearing oil level was approximately 0.5 inches below the standstill mark on the sight glass. The acceptance criteria for the RSS pump motor oil level was at standstill mark on sight glass to 0.25 inches above the standstill mark. Oil was added to the upper motor bearing on the same day, which returned the level to above its acceptance criteria.
SP 3670.4 was previously performed on November 19, 2023, at which time the oil level in the 3RSS*P1C upper motor bearing was documented as being within acceptance criteria. Past operability was reviewed, and it was concluded that with the reduced oil level and leak to the upper motor bearing, the 'C' RSS pump may not have been capable of performing its safety function to meet its mission time requirements. It was also determined that this condition existed for longer than allowed by the plant's TSs.
The licensee submitted LER 05000423/2023-005-00, Oil Leakage from 'C' RSS Pump Motor Challenged Meeting Its Mission Time Resulting in a Condition Prohibited by Technical Specifications, on February 8, 2024, for this condition as an operation or condition prohibited by TSs in accordance with Title 10 of the Code of Federal Regulations 50.73(a)(2)(i)(B).
Corrective Actions: The licensee added oil to the upper motor bearing and repaired the leak on January 13, 2024, when it replaced the upper sight glass assembly and installed new O-rings.
Corrective Action References: CR1249141, CR1245872
Performance Assessment:
The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.
Enforcement:
Severity: The NRC determined this violation was Severity Level IV in accordance with example 6.1.d.1 of the NRC Enforcement Policy.
Violation: TS 3.6.2.2 requires two independent RSSs to be operable in Modes 1, 2, 3, and 4.
With one RSS inoperable, the action is to restore the inoperable system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The action also requires restoring the inoperable RSS to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, from approximately November 25 to December 10, 2024, the plant operated in a condition prohibited by TS 3.6.2.2 because the 'C' RSS pump did not contain enough oil to meet its mission time and was not operable.
The disposition of this finding closes LER 05000423/2023-005-00, Oil Leakage from 'C' RSS Pump Motor Challenged Meeting Its Mission Time Resulting in a Condition Prohibited by Technical Specifications.
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 July 25, 2024, the inspectors presented the ISFSI inspection results to Michael O'Connor, Site Vice President, and other members of the licensee staff.
- On September 13, 2024, the inspectors presented the radioactive gaseous and liquid effluent treatment inspection results to Michael O'Connor, Site Vice President, and other members of the licensee staff.
- On October 2, 2024, the inspectors presented the integrated inspection results to Michael O'Connor, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OP 3211
Solid Plant Pressure Control (ICCE)
Revision 1
SP 3446B11
Train A Solid-State Protection System Operational Test
Revision 21
Procedures
ARP 2590F-20
NSST/RSST 4160 Out of Sync
Revision 0
SP 2619G
AC Electrical Sources Inoperability
Revision 12
Miscellaneous
Memorandum to
2R29 Shutdown Risk Schedule Review
09/26/2024
Procedures
RCS Leakage Trending and Investigation
Revision 7
Corrective Action
Documents
CR1250497
CR1224449
CR1230610
CR1231835
CR1236627
CR1229741
CR1230610
Engineering
Evaluations
ETE-MP-2023-
1036
2R28 Core Plate Foreign Material Evaluation for the RCS
and ECCS Systems
Revision 0
ETE-MP-2024-
1007
MP2 RCP Seal Collective Significance Review
Revision 0
Corrective Action
Documents
CR1224123
CR1238903
CR1246448
CR1248051
CR1249971
Corrective Action
Documents
CA12328601
CR1245872
CR1249141