IR 05000336/2011003
| ML112160449 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/03/2011 |
| From: | Diane Jackson NRC/RGN-I/DRP/PB5 |
| To: | Heacock D Dominion Resources |
| Jackson D E, RGN-I/DRP/PB5/610-337-5306 | |
| References | |
| IR-11-003 | |
| Download: ML112160449 (57) | |
Text
August 3, 2011
SUBJECT:
MILLSTONE POWER STATION. NRC INTEGRATED INSPECTION REPORT 05000336/20 1 1 003 AND 050004231201 1003
Dear Mr. Heacock:
On June 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone power Station Unit 2 and Unit 3. The enclosed inspection report documents the inspection results, which were discussed on August 1,2011, with Mr. A. J. Jordan and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents two NRC-identified findings and two self-revealing findings of very low safety significance (Green). Three of these findings were determined to involve violations of NRC-req-uirements. However, because of the very low safety significance and because they have been entered into your corrective action program (CAP), the NRC is treating these{in_dings as non-cited violations (i.fCVs) consistent with Seition 2.3.2.a of the NRC Enforcement Policy'
lf you contest any NCV in this report, you should provide a response within 30 days of the date of this inspectionreport, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document iontrol Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region l; the Director, Offile of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at Millstone. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should piovide a response within 30 days of the date of this inspection report, with the baiis for your disagreement, to the RegionalAdministrator, Region l, and the NRC Senior Resident Inspector at Millstone. In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS).
ADAMS is accessible from the NRC Web Site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
Donald E. Jacks Projects Branch 5 Division of Reactor Projects Docket Nos. 50-336. 50-423 License Nos. DPR-65, NPF-49
Enclosure:
Inspection Report No. 0500033612011003 and O5OOO42312O1 1003 W Attachment: Supplemental Information
REGION I==
50-336, 50-423 DPR-65, NPF-49 05000336/201 1 003 and 05000 4231201 1003 Dominion Nuclear Connecticut, Inc.
Millstone Power Station, Units 2 and 3 P. O. Box 128 Waterford, CT 06385 April 1,2011through June 30, 2011 S. Shaffer, Senior Resident Inspector, Division of Reactor Projects (DRP)
J. Krafty, Resident Inspector, DRP B. Haagensen, Resident Inspector, DRP M. Modes, Senior Reactor Inspector, Division of Reactor Safety (DRS)
T. Moslak, Health Physicist, DRS Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Enclosure
Table of Contents suMMARy OF FlNDlNGS...........
.........3 1. REACTOR SAFETY
......................6 1R01 Adverse Weather Protection
.............6 1R04 Equipment Alignment.
.......................7 1R05 Fire Protection............
......................9 1R08 In-Service Inspection
..... 10 1R11 Licensed Operator Requalification Program.........,....
........11 1R12 Maintenance Effectiveness
.............12 1R13 MaintenanceRiskAssessmentsandEmergentWorkControl............12 1R15 Operability Evaluations
...................13 1R18 Plant Modifications....
..... 16 1R19 Post-Maintenance Testing
.............. 16 1R20 Refueling and Other Outage Activities
............. 1g 1R22 Surveillance Testing
...... 19 IEPO Drill Evaluation...........
.....................21 2. RADIATION SAFETY
..................21 2RS01 RadiologicalHazard Assessment and Exposure controls....
..............21 2RS02 OccupationalALAM Planning and Controts..............
......24 2RS03 In-Plant Airborne Radioactivity Control and Mitigation............
...........26 2RS04 Occupational Dose Assessment..............
........27 2RS05 Radiation Monitoring Instrumentation..........
.....28 2RS06 Radioactive Gaseous and Liquid Effluent Treatment
........30 4. OTHER ACTIVITlES [OA].......
.....32 4OA1 Performance Indicator (Pl) Verification.........
....................32 4OA2 ldentification and Resolution of Problems...............
..........32 4OA3 Event Follow-up
.............37 4OAO Meetings, including Exit...........
.......42 ATTACHMENT: SUPPLEMENTAL I NFORMATION SUPPLEMENTAL INFORMATION...........
...........A-1 KEY POINTS OF CONTACT
.A-1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
....A-2 LIST OF DOCUMENTS REVIEWED LIST OF ACRONYMS
.A-11 Enclosure
A-3
SUMMARY OF FINDINGS
lR 0500033612011003, 0500042312011003; 0410112011 - 0613012011; Millstone Power Station
Unit 2 and Unit 3; Operability Evaluations, Surveillance Testing, Event Follow-up.
The report covered a three-month period of inspection by resident and region-based inspectors.
Four Green findings, three of which were non-cited violations (NCV), were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process." The cross-cutting aspects were determined using IMC 0310, "Components Within the Cross Cutting Areas." Findings for which the significance determination process (SDP) does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Cornerstone: Initiating Events
- Green.
A self-revealing finding (FlN) of very low safety significance (Green) was identified for Dominion's failure to follow procedure OP 2204, "Load Changes," when starting the 'A' steam generator feedpump (SGFP). Specifically, the operating crew failed to maintain adequate SGFP suction pressure (greater than 325 psig) while starting the 'A' SGFP, which led to a trip of the 'B' SGFP and subsequent reactor trip on low steam generator level. Dominion entered this issue into their corrective action program (CR431574); conducted training exercises emphasizing safe operating envelopes, critical parameters to monitor, and actions to take to restore margin if plant conditions degrade; and has revised procedure OP 2204.
The finding is more than minor because it is similar to NRC Inspection Manual Chapter 0612, Appendix E, "Examples of Minor lssues," Example 4b; in that, a failure to follow procedure led to a reactor trip. This issue is associated with the Human Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure of the operators to properly monitor SGFP suction pressure led to a loss of adequate feedwater flow and a reactor trip. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment 0609.04, "Phase 1
- Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available.
The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel did not properly follow the load changes procedure. tH.4(b)l (Section 4OA3)
Cornerstone: Mitigating SYstems
- Green.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, rcorrective Action," for Dominion's failure to take timely corrective actions for a condition adverse to quality involving the degradation and subsequent through-wall leakage of Unit 3 service water valves 3SWP.V699 (3HVQ.ACUS1B Bypass Valve), 3SWP.VO18 (3HVQ.ACUS2B Unit Cooler Inlet Valve), and 3SWP*V696 (3HVQ.ACUS2B Unit Cooler Outlet Valve). Specifically, Dominion did not adequately implement a schedule for prioritizing and completing corrective actions on affected aluminum bronze components, which were known to be susceptible to de-alloying, commensurate with the safety significance of the degraded condition. As a result, through-wall leaks developed on these valves and resulted in unplanned loss of operability and additional unavailability of the safety-related support systems for the 'B' train of containment recirculation spray pumps. bominion took immediate corrective action to replace the three leaking service water (SW) valves (CR428785).
The inspectors determined that this issue was more than minor because it is similar to the more than minor example, 4.f, of IMC 0612, Appendix E, "Examples of Minor lssues." Specifically, the degraded condition caused a loss of operability of the 'B' train of the containment iecirculation spray system. Additionally, the finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring-the availability of systems that respond to initiating events to prevent undesirable consequences. ln accordance with NRC lnspection Manual Chapter 0609,
Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1 SDp screening was performed and determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent an actual loss of system safety function of a single train for greater than its Technical Specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
The finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not ensure thatissues potentially impacting nuclear safety were corrected in a timely manner commensurate with their safety significance. Specifically, Dominion failed to adequately implement corrective actions to address a known de-alloying issue with SW valves before ihe condition led to the unplanned loss of operability and additional unavailability of the safety-related support systems for the 'B' train of containment recirculation spray pumps P'1(d)' (Section 1R15)
.
- Green.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, rcorrective Action," for Dominion's failure to take timely corrective action to address repetitive out of calibration conditions associated with safety-related 120 VAC Unit 2 inverters. To date, Dominion has taken corrective action to adjust the over-frequency and under-freq uency transfer limits (CR426589).
The inspectors determined the finding was more than minor because it is similar to the more than minor Example '4f' of NRC lnspection Manual Chapter (lMC) 0612, Appendix E, "Examples of Minor issues." Additionally, the issue is more than minor because the performance deficiency can be reasonably viewed as a precursor to a significant event; in that, the history of over-and under-frequency limits drifting out of tolerance could lead to the unavailability of safety-related equipment powered from the inverters. The inspectors conducted a Phase 1 screening in accordance with NRC IMC Attachment 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action in a timely manner to address the repetitive out of calibration conditions with the 120 VAC safety related inverters. tP.1(d)l (Section 1R22)
Cornerstone: Barrier IntegritY
.
- Green.
A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl,
"Corrective Action," was identified for Dominion's failure to take prompt corrective action to address the cause of main steam safety valve (MSSV) exhaust pipe bushings not seating, which resulted in a loss of the Building's safety function to control the release of radioactive material. Dominion took corrective action to clean and lubricate the MSSV exhaust pipe and also implemented a modification to upgrade the MSSV outlet boot and qualify it as part of the Building filtration boundary (cR420485).
The finding was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure of the MSSV sliding bushings to seat properly caused the Building Filtration System (EBFS) to fail its surveillance test, and its safety function to control the release of radioactive material could not be assured. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because it only represents a degradation of the radiological barrier function provided for the auxiliary building.
The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action to address the
Building surveillance test failure in 2009. P.1(d) (Section 4OA3)
REPORT DETAILS
Summarv of Plant Status Millstone Units 2 and 3 began the inspection period operating at 100 percent power. On April 2, 2011, Unit 2 was shutdown to begin refueling outage 2R20. Unit 2 returned to 100 percent power on May 4,2011. On June 20, 2011, Unit 2 reduced power to 30 percent to repair an oil leak on the'C' reactor coolant pump (RCP) motor. Following repairs, Unit 2 increased power to approximately 59 percent power when the plant tripped on low steam generator water level.
Unit 2 returned to 100 percent power on June 23, 2011. Unit 3 remained at or near 100 percent power for the entire inspection period.
1. REACTORSAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 External Floodinq Inspection
a. Inspection Scope
The inspectors evaluated Dominion's readiness to cope with external flooding at Unit 2 and Unit 3. The inspectors reviewed the Unit 2 and Unit 3 Updated Final Safety Analysis Report (UFSAR) and identified areas that could be affected by external flooding due to a design basis flood. The inspectors reviewed applicable procedures to verify that the actions required in the event of flooding could reasonably be completed, and that the appropriate equipment was pre-staged. The inspectors performed walkdowns of the Unit 2 and Unit 3 intake structures, fire pump houses, and inspected the material condition of flood doors in order to determine if the structures and components were being adequately maintained. Documents reviewed during the inspection are listed in the Attachment.
b.
Findinqs No findings were identified.
.2 Grid Stabilitv - Readiness of Offsite and Alternate AC Power Svstems
a. Inspection Scope
The inspectors reviewed Dominion's Independent System Operator (lSO) New England and Connecticut Valley Electric Exchange (CONVEX) procedures for notifications of abnormal grid conditions to determine if they were adequate to ensure the reliability of alternating cunent (AC) power systems. The inspectors reviewed Dominion's procedures to determine if they addressed inadequate post-trip voltages of the offsite power supply, unknown post trip voltages, reassessment of risk when maintenance activities could affect grid reliability, and required communication between Dominion and ISO New England/CONVEX when changes at the site could impact the transmission system. The inspectors interviewed selected shift managers to determine if they were dmiliar with the procedures for abnormal grid conditions. The inspectors performed a walkdown of the switchyard, main transformers, normal station service transformers, and reserve station service transformers; and performed a review of the system health reports for the switchyard and transformers in order to determine the material condition of the offsite power sources.
b.
Findinqs No findings were identified.
.3 Seasonal Site lnsPection
a.
lnspection Scope The inspectors performed a review of Dominion's readiness for hurricane season. The inspectors reviewed selected equipment, instrumentation, and supporting structures to determine if they were configured in accordance with Dominion's procedures, and that adequate controls were in place to ensure functionality of the systems. The inspectors reviewed the Unit 2 and Unit 3 UFSAR and Technical Specifications (TS) and compared the analysis with procedure requirements to ascertain that procedures were consistent with the UFSAR. The inspectors performed partial walkdowns of the Unit 2 and Unit 3 intake structures, fire pump houses, flood doors, and flood protection equipment to determine the material condition of installed flood protection equipment, and verify that the portable flood protection equipment was properly staged. The inspectors also reviewed previous CRs and work orders to verify that the deficiencies identified have been corrected. Documents reviewed during the inspection are listed in the Attachment.
b. Findinqs No findings were identified.
1 R04 Equipment Aliqnment (71111
.04 - 3 samples)
.1 Partial Svstem Walkdowns
a. Inspection Scope
The inspectors performed three partial system walkdowns during this inspection period.
The inspectors reviewed the documents listed in the Attachment to determine the correct system alignment. The inspectors performed a walkdown of each system to determine if the critical portions of the selected systems were correctly aligned, in accordance with the procedures, and to identify any discrepancies that may have had an effect on operability. The walkdowns included selected switch and valve position checks, and verification of electrical power to critical components. Finally, the inspectors evaluated other elements, such as material condition, housekeeping, and component labeling' The I
following systems were reviewed based on their risk significance for the given plant configuration:
Unit 2
. Spent Fuel Cooling with the 'A' Low Pressure Safety Injection (LPSI) pump and 'A' Shutdown cooling (SDC) heat exchanger with the core off-loaded in the spent fuel pool on April 13,2011; o 'B' High Pressure Safety Injection (HPSI) train while the 'A' train was out of service (OOS) for testing on May 12,2011; and Unit 3
. 'A' system HPSI with the 'B' train out for testing on May 5, 2011.
b.
Findinqs No findings were identified.
.2 Complete Svstem Walkdown
a. Inspection Scope
The inspectors completed a detailed review of the alignment and condition of Unit 2 EBFS. The inspectors performed a walkdown of the system to determine whether critical portions, such as circuit breakers and switches, were aligned in accordance with procedures and to identify any discrepancies that may have had an adverse effect on operability. The inspectors also reviewed the system health reports, condition reports, and Maintenance Rule evaluations to determine whether equipment problems were being identified and appropriately resolved. Documents reviewed during the inspection are listed in the Attachment.
b.
Findinqs No findings were identified.
1R05 Fire Protection
.1 Fire Protection Tours
a. Inspection Scope
The inspectors performed walkdowns of five fire protection areas. The inspectors reviewed Dominion's fire protection program to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. The inspectors walked down these areas to assess Dominion's control of transient combustible material and ignition sources. In addition, the inspectors evaluated the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors compared the existing conditions of the areas to the fire protection program requirements to determine if all program requirements were being met. Documents reviewed during the inspection are listed in the Attachment. The fire protection areas reviewed included:
Unit 2 o Containment Building, Fire Area C-1; o West DC Switchgear Room, Fire Area A-21;
. West Battery Room, Fire Area A-23;
. Auxiliary Building, -5' General Area, Fire Area A-1; and Unit 3 o East Motor Control Center (MCC) and Rod Control Area, Fire Area AB-5' Findinqs No findings were identified.
Annual Fire Drill Observation (71111'05A - 1 sample)lnspection Scope To evaluate the readiness of station personnel to fight fires, the inspectors observed Dominion personnel performance during a fire brigade drill on May 13,2011' The drill simulated a fire in the Unit 2 East Cable Vault in the turbine building. The inspectors observed the fire brigade members using protective clothing, turnout gear, self-contained breathing apparatuslnd entering the fire area. The inspectors also observed the fire fighting Jquipment brought to the fire scene to evaluate whether sufficient equipment wis aiailable to effectively control and extinguish the simulated fire' The inspectors evaluated whether the peimanent plant fire hose lines were capable of reaching the fire area and whether hose usage was adequately simulated. The inspectors observed the fire fighting directions and c6mmunications between fire brigade members. The inspeitorJalso evaluated whether the pre-planned drill scenario was followed and b.
.2 "4.
observed the post drill critique to evaluate if the drill objectives we-re satisfied and that any drillweaknesses were discussed. The inspectors evaluated fire brigade performance, including the readiness of the fire brigade to fight fires and the utilization of preplanned strategies.
b.
Findinqs No findings were identified.
1R08 ln-Service Inspection
a.
Inspection ScoPe ln-Service Insoection Proqram The inspectors reviewed a sample of nondestructive examination activities and discussed the results of the examination with the Dominion corporate Level lll ln-Service Inspection Inspector. There were no volumetric or surface examinations from the previous outage with relevant indications that were analytically evaluated and accepted by Dominion for continued service.
Vessel Head Inspection No vessel head activities were performed during this outage' Weldino and Repair Proqram The inspectors reviewed a complete welding and fabrication package consisting of a revised piping anchor to determine if the welding activities were performed in accordance with American Society of Mechanical Engineers (ASME) Code requirements, or an NRC approved alternative' Boric Acid Control Proqram The inspectors reviewed the boric acid control program with the Dominion engineering lead. The inspectors reviewed the photographic evidence of boric acid leaks with the Dominion engineering lead and discussed various engineering evaluations performed for boric acid found on Riactor Coolant System (RCS) piping and components. Also, the inspectors verified that degraded or non-conforming conditions are identified properly in Dominion's corrective action program.
Steam Generator (SG) Proqram No in-situ pressure testing'was performed during this inspection. The inspectors compared the estimated Jize and number of tube flaws detected during the current outage against the previous outage operational assessment predictions to assess Domlnion:s prediction capability. The inspectors confirme_d that the SG tube eddy current examination scope and e*pansion criteria meet TS requirements, Electric Power Research Institute Guidelines, and commitments made to the NRC. The inspectors confirmed all areas of potential degradation (based on site-specific experience and industry experience) are being inspected, especially areas which are known to represent potentiil eddy current challenges. The inspectors confirmed that the eddy current probes and equipment are qualified for the expected types of tube degradation and assessed the site specific qualification of one or more techniques.
Because Dominion identified loose parts or foreign material on the secondary side of the SG, the inspectors evaluated Dominion's corrective actions. The inspectors confirmed that Domin'ron has taken/planned appropriate repairs of affected SG tubes, and inspected the secondary side of the SG to remove foreign objects. lf the foreign objects are inaccessible, the inspectors determined whether Dominion has performed an evaluation of the potential effects of object migration and/or tube fretting damage' The inspectors reviewed a random sample of eddy current data in this regard.
b. Findinqs No findings were identified 1R1 1 Licensed Operator Requalification Proqram (71111.11 - 3 samples)
Resident Inspector Quarterlv Review (7 1111.1 1O)a.
lnspection ScoPe The inspectors observed simulator-based licensed operator requalification training for Unit 2 on May 24,2011, and June 7, 2A11, and for Unit 3 on June 7, 2011. The inspectors evaluated crew performance in the areas of clarity and formality of communications; ability to take timely actions; prioritization, interpretation, and verification of alarms; procedure use; control board manipulations; oversight and direction from supervisors, and command and control. Crew performance in these areas was compared to Dominion management expectations and guidelines as presented in Op-Mp-100-1000, "Millstone Operations Guidance and Reference Document." The inspectors compared simulator configurations with actual control board configurations' The inspectors also observed Dominlon evaluators discuss identified weaknesses with the crew and/or individual crew members, as appropriate. Documents reviewed during the inspection are listed in the Attachment.
b.
Findinqs No findings were identified.
1R12 Maintenance Effectiveness
a.
Inspection ScoPe The inspectors performed one maintenance effectiveness inspection sample of Dominion's evaiuation of degraded conditions for the Unit 2 Charging and Letdown system. The inspectors reviewed Dominion's implementation of the "Maintenance Rule,"
10 CFR 50.65. ihe inspectors reviewed Dominion's ability to identify and address common cause failures; the applicable maintenance rule scoping document for each system; the current classification of these systems in accordance with 10 CFR 50.65 piragraph (aX1) or (a)(2); and the adequacy oj the performance criteria and goals established foi each sysiem, as appropriate. The inspectors also reviewed recent system health reports, Condition Reports (CR), apparent cause determinations' functionalfailure determinations, and discussed system performance with the responsible iystem engineer. Documents reviewed during the inspection are listed in the Attachment.
b.
Findinqs No findings were identified.
==1R13 a.
(71111.13 - 9 samPles) Inspection ScoPe==
The inspectors evaluated online risk managementfor emergent and planned activities' The inspectors reviewed maintenance risk-evaluations, work schedules, and control room logs to determine if concurrent planned and emergent maintenance or surveillance activitiel adversely affected the plant risk already incurred with out-of service (oos)
-omponents. Thg,inspectors evaluated whether Dominion took the necessary steps to control work activities, minimize the probability of initiating events, and maintain the functional capability of mitigating systems. The inspectors assessed Dominion's risk r"n"g"t"ni actiohs during plant walkdowns' Documents reviewed during the inspeJtion are listed in the Aitachment. The inspectors reviewed the conduct and adequacy of risk assessments for the following maintenance and testing activities:
Unit 2 2R2O Shutdown Risk Assessment on March 31,2011; Orange Risk for RCS Drain down to Mid-Loop on April 5,2011; Orange Risk for North Bus Outage on April 5,2Q11; Orante Risk for Replaceme nt of 2 SW-978 (only one train of SW available) on April 7,2011; Risk Mitigation Plan for lsophase Bus Duct Seal Bushing Installation on April 19' 2011; Alternate Plant Configuration for lsolating the 'A' Pressurizer Spray Line; Yellow Risk for'A' S\\i/ pump OOS and ECCS suction valve testing on May 24' 2011; a
a a
a o
a Unit 3 o Emergent risk assessment for a failure of the Sl logic module in the SSPS train 'B' while iwitchyard work was in progress on April 18, 2011; and o Emergent work to replace SW valves 3SWP"V699, 3SWP"V018 and 3SWP*V696 due to de-alloYing.
b.
Findinqs No findings were identified.
==1R15 Operabilitv Evaluations (71111-15 - 7 samples) a.
lnspection ScoPe==
The inspectors reviewed seven operability determinations (OD). The inspectors evaluated the ODs against the guidance contained in NRC Regulatory lssue Summary 2OOS-20, Revision tobuidance Formerly Contained in NRC Generic Letter 91-18, "lnformation to Licensees Regarding Two NRC lnspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability'" The inspectors atso discussed the conditions with operators, and system and design engineers, as necessary. Documents reviewed during the inspection are listed in the
. The inspectors reviewed the adequacy of the following evaluations of degraded or non-conforming conditions:
Unit 2 Engineering Technical Evaluation, ETE-MP-2011-0030, addressing a small breach in the control room envelope via a halon piping penetration; Engineering Technical Evaluation, ETE-MP-201 1 -0045, providing use-as-is conclusion on terry turbine shaft pitting; ODM 000202, Operation with 2-RS-252, Loop 1A Pressurizer Spray Header lsolation Valve closed; Unit 3 RAS 000176 l CR41g723, "Fire Shutdown Analysis Time Critical Operator Action (TCOA) to secure RCPs," dated March 28,2Q11; CR427354, Degraded Condition for MOV 87018 and MOV 8702A RHR lsolations; ODM000192, "Addressing Increased Hydrogen Pressure in the VCT Creating an lncrease in UnidentitieO RCS leakage and Increased Leakage From the 'D' RCP #1 Seal Leak-off," dated March 17,2011; and a
a
.
1OD000173, "lnitial Operability for Aluminum-Bronze Service Water Valves De-alloying," dated May 25,2011.
Findinqs lntroduction: The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," for Dominion's failure to take timely corrective actions for a condition adverse to quality involving the degradation and subsequent through-wall leakage of Unit 3 service water valves 3SWP.V699 (3HVQ.ACUS1B Bypass Valve),3SWP.VO18 (3HVQ.ACUS2B Unit Cooler Inlet Valve), and 3SWP*V696 (3HVQ.ACUS2B Unit Cooler Outlet Valve). Specifically, Dominion did not adequately implement a schedule for prioritizing and completing corrective actions on affected aluminum bronze components, which were known to be susceptible to de-alloying, commensurate with the safety significance of the degraded condition. As a result, through-wall leaks developed on these valves and resulted in unplanned loss of operability and additional unavailability of the safety-related support systems for the 'B' train of containment recirculation spray pumps.
Description:
On May 25,2011, through-wall leaks were identified on SW valves 3SWP.V699, 3SWP*V018, and 3SWP.V696. These valves provide cooling water flow to the room air conditioning units that support the 'B' train of containment recirculation spray pumps. The leaks were caused by de-alloying of the aluminum bronze (Al-Br)valve bodies that had not been properly heat-treated to prevent the galvanic leaching of aluminum from the Al-Br metal matrix. Dominion had previously identified the susceptibility of these service water (SW) valves to de-alloying in apparent cause evaluation (ACE) 017509 dated March 30, 2009. Dominion had identified the de-alloying issue, characterized the de-alloying process, and determined that the cause was due to an old design issue where Al-Br valves had been procured without a specified heat-treatment that would have minimized the susceptibility of the valves to the de-alloying process. Dominion concluded in ACE 017509 that, "Based on past experience, this new valve (3SWP.V699) will leak 12to 18 months from installation." Dominion then prioritized all installed SW valves that were susceptible to de-alloying into four tiers based on their susceptibility and risk significance in the extent of condition assessment.
Valves 3SWP.V699, 3SWP*V018, and 3SWP.V696 were prioritized as "tier one" and should have been replaced promptly.
Dominion subsequently initiated CR428785 on May 25, 2011, to address through-wall leakage from these SW valves and completed OD0004211o assess operability and extent of condition. The leaking valves were replaced and the air conditioners (3HVQ.ACUS1B and 3HVQ.ACUS2B) were returned to service on May 26,2011. The repeated failure of 3SWP.V699 and the additionalfailures of 3SWP.VO18 and 3SWP.V696 resulted in the loss of operability and additional unavailability of the 'B' train of containment recirculation spray pumps during valve replacement.
Analysis:
The inspectors determined that the failure to take timely corrective action following identification of a degraded condition was a performance deficiency that was reasonably within Dominion's ability to foresee and prevent, Traditional Enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function, and was not the result of any willful violation of NRC requirements.
The inspectors determined that this issue was more than minor because it is similar to the more than minor example, 4.f, of IMC 0612, Appendix E, "Examples of Minor lssues." Specifically, the degraded condition caused a loss of operability of the 'B' train of the containment recirculation spray system. Additionally, the finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. In accordance with NRC Inspection Manual Chapter 0609, 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent an actual loss of system safety function of a single train for greater than its Technical Specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
The finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not ensure that issues potentially impacting nuclear safety were corrected in a timely manner commensurate with their safety significance. Specifically, Dominion failed to adequately implement corrective actions in a timely fashion to address a known de-alloying issue with SW valves before the condition led to the inoperability and unavailability of the safety-related support systems for the 'B' train of containment recirculation spray pumps [P. 1 (d)].
Enforcement:
10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, from March 30, 2009, to May 25, 2011, Dominion did not take timely corrective actions to correct the de-alloying of Al-Br SW valves prior to the condition adversely impacting 'B' containment recirculation spray system operability. Dominion took immediate corrective action to replace the three leaking SW valves. Because the issue is of very low safety significance (Green) and has been entered into Dominion's CAP (CR428785), the NRC is treating this finding as an NCV, consistent with the NRC's Enforcement Policy. (NCV 05000423/2011003-01, Failure to Take Timely Corrective Actions for De-alloying of Aluminum Bronze Service Water Valves).
1R18 Plant Modifications
a.
lnspection ScoPe To assess the adequacy of the modifications, the inspectors performed walkdowns of selected plant systems and components, interviewed plant staff, and reviewed applicable documents, including procedures, calculations, modification packages, engineering evaluations, drawings, corrective action program documents, the UFSAR, and TS.
For the modifications reviewed, the inspectors determined whether selected attributes (component safety classification, energy requirements supplied by supporting systems, seismic qualificatibn, instrument setpoints, uncertainty calculations, electrical coordination, electrical loads analysis, and equipment environmental qualification) were consistent *itn tn" design and licensing bases. Design assumptions \\ryere reviewed to verify that they were technically appropriate and consistent with the UFSAR. For each modification, ihe 10 CFR 50.59 screenings or safety evaluations were reviewed' The inspectors also verified that procedures, calculations, and the UFSAR were properly updated with revised design information. In addition, the inspectors verified that the as-built configuration was acCurately reflected in the design documentation and that post-modification testing was adequate to ensure the structures, systems, and components would function property. Documents reviewed during the inspection are listed in the
. The following plant modifications were inspected:
Unit2
. MP2-10-01037-000, "MP2 Motor (permanent);
Driven AFW Pump Bearing Replacement" o DM2-00-01 10-01, "lnstallation of High Point Vents on Containment Spray Suction Piping" (permanent);
H.P & L.P. Safety lnjection &
. DM2-03-0183-09, "Temporary DCN Restoration Additional Replacement Anomalies" (permanent); and RTB Meter RelaY
.
MP2-11-01057, "MP2 MSSV Outlet Boot Design" (permanent).
b.
Findinqs No findings were identified'
1R19 Post-Maintenance Testino
a.
Inspection ScoPe The inspectors reviewed post-maintenance test (PMT) activities to determine whether the pMT adequately demonstrated that the safety-related function of the equipment was satisfied, given the icope of the work specified, and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to evaluate consistency with the associated design and licensing bases, as well as TS requirements. The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following maintenance activities and PMTs were evaluated:
Unit2
. Sp 26131,"Facility 2 ESF Integrated Test Data Sheet," Revision 010-02, following replacement of the 'B' Emergency Diesel Generator (EDG) channel heads on April 17,2011;
. Hypot Testing on the lsophase following the lsophase Duct Seal Plate Installation on April 19,2011;
. SP 2660-001, "AFP Turbine Overspeed Trip TeSt," Revision 005-06, on April 21, 2011 and Sp2619BS-003,'TDAFP Comprehensive Pump Test (MODE 3)," Revision 001-03, on May 2,2011 following the overhaul of the Terry Turbine;
. Sp 2601C-009, "Chemical and Volume Control System (CVCS) Valve Remote Position Indication lST, Facility 2," Revision 000-00, and SP 260'1C-008, "CVCS Valve Stroke and Timing lST, Facility 2," Revision 000-00, following overhaul of 2-cH-S14;
. C Sp 760-003, "Battery DB3-201D Discharge Inspection," Revision 002-01, following battery replacement on April 10,2O11;
. Sp ZilOe, 'MSIV Closure and Main Steam Valve Operational Readiness Testing,"
Revision 011-03, following leak injection repair of 2-MS-1908;
. SP 2613-8-001, "Periodic DG Operability Test, Facility 2 (Fast Start, Revision 021-05, following 'B' EDG governor replacement; Loaded Run),"
. Sp 2411, "CEA Motion Inhibit Verification," Revision 002-08, following CEAPIDS monitor failure; and Unit 3
. Sp 36464.1-003, "EDG 'A'Air Start Valves Independence Test," Revision 010, and Sp 3646A.1-001, "EDG 'A' Operability Tests," Revision 018-01, following repair of a jacketwaterleakandreplacementoftheairstartfilter.
b.
Findinqs No findings were identified.
1R20 Refuelinq and other outaqe Activities
Millstone Unit 2 Refuelino Outaqe (2R20)a.
Inspection ScoPe Dominion began refueling outage 2R20 on April 2,2011, and completed the outage on May 4, 2011. The inspectors evaluated the outage plan and outage activities to detbrmine if Dominion had considered risk, developed risk reduction and plant configuration control methods, considered mitigation strategies in the event of loss of safety functions, and adhered to licensee and TS requirements. The inspectors observed portions of the shutdown, cooldown, heat up, and start up processes.
Additionaliy, the inspectors performed an initial containment Mode 3 walk down to evaluate the as-found condition of containment. The inspectors also performed a final Mode 3 walk down to ensure that no loose material or debris, which could be transported to the containment sump, were present. The inspectors reviewed CRs to determine if conditions adverse to quality were entered for resolution. Documents reviewed for the inspection are listed in the Attachment. Some of the specific activities the inspectors observed and Performed included:
o scaffolding walkdown for potential interference with sscs; o Reactor shutdown and cool down; o Reactor water level drain down to the reactor flange; o Midloop and reduced inventory operations;
. Fuel handling, core loading, and fuel element assembly tracking;
. Containment as-found walk down; e Review of outage risk Plan; e orange Risk - Replacement of service water valve 2swP-978; o Risk Mitigation Plan for the North Bus Outage;
. Generic Letter 88-17 verification; o Refueling Seal InsPection;
. Containment as-left walk down; o Reactor Heat-up;
.
Reactor Start-up;
. Low Power PhYsics Testing; o Reactor power ascension;
. Unit 2 Generator synchronization to the grid;
.
Review of Work Schedules for Operations, Maintenance, and Security; and o Fatigue Management.
b.
Findinqs No findings were identified.
1R22 Surveillance Testinq
a. Inspection Scope
The inspectors reviewed surveillance activities to determine whether the testing adequaiely demonstrated equipment operational readiness and the ability to perform the intended safety-related function. The inspectors attended pre-job briefings, reviewed selected prerequisites and precautions to determine if they were met, and observed the tests to determine whether they were performed in accordance with the procedural steps. Additionally, the inspectors reviewed the applicable test acceptance criteria to evaluate consistency with associated design bases, licensing bases, and TS requirements, and that the applicable acceptance criteria were satisfied. The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following surveillance activities were evaluated:
Unit 2 a
a a
a a
Sp 2610E, "MSIV Closure and Main Steam Valve Operational Readiness Testing,"
Revision 11-02 (lST);
SP 27308-001, "Main Steam Safety Valve Testing," Revision 011; SP 2613H, "lntegrated Test of Facility 2 Components (ICCE)," Revision 012-Q2; sP 2602E-001, "Pressurizer Heater Capacity Test," Revision 000-00; sP 2651N-001, "Main control valves operability Test," Revision 002-09; Pf 21415A,"MPzInverters 1-4 Tests," Revision 004-02; Unit 3
. Sp g622.3, "TDAFW Pump Operational Readiness and Quarterly IST Group'B' Pump Tests," Revision 017-03;
. sP 3556812, "SSPS Train 'B' Operational Test," Revision 012-04; and
. CP 3802E, "Reactor Coolant gas Sampling and Analysis," Revision 002-01' Findinqs lntroduction: The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Cntenon XVl, "Corrective Action," for Dominion's failure to take timely corrective action to address repetitive out of calibration conditions associated with safety-related 120 VAC Unit 2 inverters.
Description:
Millstone Unit 2 safety-related inverters 1 through 4 supply po{el to safety-related 121VAC instrument panels. ln April 2011, during refueling outage 2R20, inverters 1 through 4 were found outside the acceptance criteria for the under-frequency and over-frequency transfer limiter test. The over-frequency and under-frequency limits were adjusted bac[< into the acceptance criteria; however, these inverters have had a history of Oritting outside their acceptance criteria. In March 2009, the NRC documented an NCV for the inverters being found frequently out of calibration for over-frequency and b.
under-frequency between 2005 and 2008 (NRC inspection report 05000336&42312009006). Dominion wrote CR333435 which requested a setpoint change to address the issue identified in the NCV. This request was approved in a Request for Engineering Assistance (REA), but has not been funded to date.
Additionally, during the Problem ldentification and Resolution team inspection in February 2010, NRC inspectors noted that three of the inverters had over-frequency and under-frequency transfer limits outside acceptance criteria during testing in October 2009, and that corrective action had not been implemented.
Dominion performed an assessment of the system impact of the over-and under-frequency transfer limits and determined that the equipment supplied by the inverters are designed for a wide range of frequencies, and are insensitive to the small frequency band set by the over-and under-frequency transfer limit setpoints. Dominion concluded that the out-of{olerance over-and under-frequency transfer limits do not present a safety concern and that the inverters remained operable. The inspectors reviewed Dominion's assessment and reached the same conclusion. Dominion's corrective actions will be to perform the detailed analysis necessary to increase the allowable tolerances of the over-and under-frequency setpoints from the current +l- 0.1 Hz.
Analvsis: The inspectors determined that the failure to take timely corrective action to address the repetitive out of calibration over-frequency and under-frequency transfer limits was a performance deficiency that was reasonably within Dominion's ability to foresee and correct, and should have been prevented. Traditional enforcement does not apply since there were no actual safety consequences, impacts on the NRC's ability to perform its regulatory function, or willful aspects of the finding.
The inspectors determined the finding was rnore than minor because it is similar to the more than minor Example '4f' oI NRC lnspection Manual Chapter (lMC) 0612, Appendix E, "Examples of Minor lssues." Additionally, the issue is more than minor because the performance deficiency can be reasonably viewed as a precursor to a significant event; in that, the history of over-and under-frequency limits drifting out of tolerance could lead to the unavailability of safety-related equipment powered from the inverters. The inspectors conducted a Phase 1 screening in accordance with NRC IMC Attachment 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action in a timely manner to address the repetitive out of calibration conditions with the 120 VAC safety related inverters. tP.1(d)l
Enforcement:
10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, and defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from March 2009, until June 2011, Dominion failed to take timely corrective action to address the repetitive out of calibration conditions associated with the 120 VAC safety related inverters. To date, Dominion has taken corrective action to adjust the over-frequency and under-frequency transfer limits. Because this violation was of very low safety significance and was entered into Dominion's corrective action program (CR426589), this violation is being treated as an NCV, consistent with the NRC's Enforcement Policy. (NCV 0500336/2011003-02 Untimely Corrective Action for Safety Related tnverters Leads to Repetitive Out of Calibration Results)
Emergency Preparedness (EP)lEPO Drill Evaluation Q1114.06 - l sample)
Classification and Notification durinq Requalification Traininq a. Inspection ScoPe The inspectors reviewed the operator's emergency classification and notification completed during Unit 2's requalification training on June 7, 2011. The inspectors verified the classification and notification were accurate and timely.
b.
Findinqs No findings were identified.
RADIATION SAFETY
Gornerstone: Public and Occupational Radiation Safety 2RS01 Radiolooical Hazard Assessment and Exposure Controls (71124'01)
a. Inspection Scope
(1 samPle)
During the period April 1 8,2011 through April 21,2011, the inspectors performed the following activities to verify that Dominion was evaluating, monitoring, and controlling radiological hazards for work performed during the 2R20 refueling outage in locked high radiation areas (LHRA) and other radiological controlled areas. lmplementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, Technical Specifications, and with Dominion's procedures' Radioloqical Ha4ards Control and Work Qoveraqe The inspectors identified work performed in radiological controlled areas in Unit 2 and evaluated Dominion's assessment of the radiological hazards. The inspectors evaluated the survey maps, exposure control evaluations, electronic dosimeter dose/dose rate alarm set points, and radiation work permits (RWP) associated with these areas to determine if the exposure controls were acceptable. Specific work activities evaluated included inspection/removal of a damaged incore instrument (lOl) thimble tube (RWP 391) from the lCl plate and reinstalling the lCl plate and Upper Guide Structure (UGS) in the reactor vessel (RWP 302). For these tasks, the inspectors attended the pre-job briefings and discussed the job assignments with the workers. The inspectors also observed (from the centralized monitoring system and during containment tours), the implementation of exposure controls for disassembling/removing scaffolding from containment (RWP 331), re-installing insulation (RWP 326), and demobilization of SG tasks (RWP 307).
The inspectors reviewed the air sample records for samples taken prior to installing SG nozzle dams to determine if the samples collected were representative of the breathing air zone and analyzed/recorded in accordance with established procedures. During tours of the Unit 2 containment building, the inspectors verified that continuous air monitors were strategically located to assure that potential airborne contamination could be timely identified and that the monitors were located in low background areas.
The inspectors toured accessible radiologically controlled areas (RCA) in the Unit 2 containment and with the assistance of a radiation protection technician, performed independent radiation surveys of selected areas to confirm the accuracy of survey data, and the adequacy of postings. Radiation protection technicians were questioned regarding their knowledge of plant radiological conditions for selected jobs, and the associated controls, Additionally, the inspectors reviewed the RWPs developed for other work performed during 2R20 including installation of permanent shielding and diving operations. ln particular, the inspectors reviewed the electronic dosimeter dose/dose rate alarm set points, stated on the RWP, to determine if the setpoints were consistent with the survey indications and plant policy.
lnstructions to Workers By attending pre-job briefings, the inspectors determined that workers performing radiological significant tasks were properly informed of electronic dosimeter alarm setpoints, low dose waiting areas, stay times, and work site radiological conditions. By observing work-in-progress, the inspectors determined that stay times were appropriately monitored by supervision to assure no procedural limit was exceeded.
Jobs observed included inspection of a damaged lCl thimble tube and preparations for moving the UGS.
During tours of containment, the inspectors determined that LHRA and a very high radiation area (VHRA) had the appropriate warning signs and were secured.
Additionally, the inspectors identified that low dose waiting areas were appropriately surveyed, identified, and used by personnel.
The inspectors inventoried the keys to LHRAs to determine if the keys were "ppropii"t"ly controlled, as required by procedure' The-inspectors discussed with 1."Oiution protection supervision the procedural controls for accessing LHRAs and VHRAs and determined that no changes have been made to reduce the effectiveness and level of worker Protection.
During tours of containment, the inspectors confirmed that contaminated materials were prop"ity bagged, surveyed/labeled and segregated from work areas. The inspectors observed workers using contamination monitors to determine if various tools/equipment were potentially contariinated and met criteria for releasing the materials from the RCA' Radioloqical Hazards Control and Work Coveraqe By observing preparations for inspecting/removing a damaged lCl thimble tube' the inspectors d-eiermined that workers wore the appropriate. protective equipment, had dosimetry properly located on their bodies, and were under the positive control of radiation protection personnel. Clear radio communication was established between the workers and the centralized monitoring system. stay times were properly measured and supervisory personnel controlled the movements of the workers to assure that exposure was minimized.
Rad iation Worker Performance During job performance observations, the inspectors determined that workers complied witfr n:Wp iequirements and were aware of radiological conditions at the work site' Additionally, the inspectors determined that radiation protection technicians were aware of RWp controls/limits applied to various tasks and provided positive control of workers to reduce the potential oi'unplanned exposure and personnel contaminations' Problem ldentification and Resolution A review of Nuclear Oversight field observation (2R20 outage snapshots) reports, dose/dose rate alarm reports, personnel contamination event reports and associated cRs, were conducted to determine if identified problems and negative performance trends were enter"d into Dominion's CAP and evaluated for resolution and to determine if an observable pattern traceable to a similar cause was evident' Relevant cRs, associated with radiation protection control access and radiological hazardassessment, initiated between January 2011 and March 2011, were reviewed and discussed with bominion staff to determine if the follow up activities were being conducted in an effective and timely manner, commensurate with their safety significance.
b.
Findinos No findings were identified.
2RS0 2 Occupational ALARA Planninq and Controls
a. Inspection Scope
(1 samPle)
During the period April 1 8,2011 through April 21,2011, the inspectors performed the following activities to verify that Dominion was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as reasonably achievable (ALARA) for tasks performed during the Unit 2 refueling outage
2R20. lmplementation of this program was reviewed against the criteria contained in 10
CFR Part 20, applicable industry standards, and with Dominion's procedures' Radioloqical Work Planninq The inspectors reviewed pertinent information regarding site cumulative exposure history, current exposure trends, and exposure challenges for the Unit 2 outage. The inspectors reviewed various 2R20 Outage ALARA Plans.
The inspectors reviewed the exposure status for tasks performed during the Unit 2 outage and compared actual exposure with forecasted estimates contained in various proje-ct ALARA Plans (AP). ln particular, the inspectors evaluated the effectiveness of ALARA controls for alljobs that were estimated to exceed the 5 person rem limit' These jobs included reactor vessel disassembly/reassembly (AP 2-1 1-01), SG lnspections/maintenance (AP 2-11-Og), scaffolding installation/removal (AP 2-11-13)'insulation removal/installation (AP 2-11-14), and radiation protection support activities (AP 2-11-26).
The inspectors reviewed the Work-ln-Progress ALARA reviews for those jobs whose actual dose approached the forecasted estimate. The inspectors evaluated the departmental'interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems' The evaluation-was accomplished by interviewing site staff, reviewing outage Work-in-progress reviews, and reviewing recent Station ALARA Council (SAC) meeting minutes.
tnctuded was a review of the exposure controls for the 'C' reactor coolant pump (RCP)motor and seal replacement, and scaffolding installation.
Verification of Dose Estimates The inspectors reviewed the assumptions and basis for the 2R20 outage ALARA forecasted exposure. The inspectors also reviewed the revisions made to various outage proleci dose estimates due to a reduced source term (i.e., lower dose rates);e.g.,leactor disassembly/reassembly activities, reactor coolant pump maintenance, and SG maintenance.
The inspectors evaluated the implementation of Dominion procedures associated with monitoring and re-evaluating dose estimates and allocations when the forecasted cumulative exposure for tasks exceeded the actual exposure. lncluded in the review were Work-ln-progress reports, that evaluated the effectiveness of ALARA measures, including source term conirols, and actions by the SAC to subsequently lower dose goals from the original estimates.
Additionally, the inspectors reviewed the exposures for the.ten workers receiving the nigilst Ooses tor ZOll to confirm that no individual exceeded the regulatory limits or performance indicator thresholds.
Source Term Reduction and Control The inspectors reviewed the status and historical trends for the Unit 2 source term' fniough review of survey maps and interviews with the Radiation Protection Manager, tne inJpectors evaluated recent source term measurements and control strategies' Specifib strategies being employed included use of macro-porous clean up resin' enhanced opeiational chemistry controls, and installation of permanent/temporary shielding.
The inspectors reviewed the effectiveness of temporary shielding by reviewing pre/post-installation radiation surveys for selected components having elevated dose rates' Shielding packages reviewed included those placg{ on the reactor head stand, pressuriier spray piping, SG penetrations, and RCP piping' Job Site lnsPections During plant tours, the inspectors assessed the implementation of ALAM controls rG.iri,tO in ALARA Plans and RWPs, for lCl thimble tube cutting/removal, RCP maintenance, and sG tube inspections, performed during 2R20.
The inspectors also observed workers performing SG demobilization from eddy current testing,'lcl inspections, and scaffolding removal. workers were questioned regarding in"ii rino*redge of ;oO lite radiologicaiconditions and ALARA measures applied to their tasks.
Problem ldentification and Resolution The inspectors reviewed elements of Dominion's cAP related to implementing the ALARA program to determine if problems were being entered into the program for timely resolution, the comprehensiveness of the cause evaiuation, and the effectiveness of the corrective actions. Specifically, CRs related to programmatic dose challenges' plrsonnel contaminaiions, doie/dose rate alarms, and the effectiveness in predicting and controlling worker exposure were reviewed' No findings were identified.
2RS03 In-Plant Airborne Radioactivitv Control and Mitiqation (71124'03)b.
Inspection ScoPe (1 samPle)
During the period April 1 8, 2011 through April21,2011, the inspectors performed the followlng activities to verify that in-planl airborne concentrations of radioactive materials are bein'g controlled and monitored, and to verify that respiratory protection devices are properly-selected and used by qualified personnel._lmplementation of these programs
- "s "uilruted against the criieria contained in 10 CFR Part2Q, applicable industry standards, and with Dominion's procedures.
Enqineerinq Controls The inspectors evaluated the use of portable continuous air monitors (AMS-4) and portable HEpA ventilation systems installed in containment during the 2R20 outage' The inspectors determined ihat the monitors were located at work locations; e.9., SG primary side openings, in containment where airborne contamination could potentially occur.
-The inspecto'rs reviewed testing records for portable HEPA ventilation systems to determine that procedural performance criteria were met' Respiratorv Protection The inspectors reviewed the use of respiratory protection devices worn by workers. The inspectors reviewed air sampling records, SG channel head removable contamination data, RWPS, and Total Effective Dose Equivalent (TEDE) ALARA DAC evaluations to determine if the use of respiratory protection devices was commensurate with the fotential external dose that may be received when wearing these devices.
Problem ldentification and Resolution The inspectors reviewed elements of Dominion's CAP related to implementing the airborne monitoring program to determine if problems w9r9 being entered into the program for timely-resolution, the comprehensiveness of the cause evaluation, and the effeitiveness of the corrective actions-Specifically, CRs related to monitoring challenges, personnel contaminations, dose aSSeSSments, and the reliability of monitoring equipment were reviewed.
Findinqs No findings were identified' 2RS04 Occupational Dose Assessment (7 1 124'04)a.
lnsPection ScoPe (1 samPle)
During the period April 1 8,2011 through April 21,2011, the inspectors performed the followlng activities to verify the accuracy and operability of personal monitoring equlpmlnt and the effectiveness in determining a worker's TEDE. lmplementation of these programs was evaluated against the criteria contained in 10 CFR Part20' applicablJindustry standards, and with Dominion's procedures.
External Dosimetrv The inspectors verified that Dominion's dosimetry processor was accredited by the NationalVoluntary Laboratory Accreditation Program (NVLAP). The inspectors verified tnat tne approveddosimeter irradiation categories were consistent with the types and "nergi"r bi g'" site's source term. The inspectors reviewed Dominion's audit of the dosimetry processor and the areas identified for improvement contained in the report' The inspectors confirmed that Dominion has developed "correction factors" to address th","rponse differences of electronic dosimeters as compared to thermoluminescent dosimeters (TLD).
lnternal Dosimetrv The inspectors evaluated the equipment and methods used to assess worker dose resulting from the uptake of radioactive materials. lncluded in this review were bioassay pio""O,it"t, whole SoOy "ounting equipment (FastScan, AccuScan, portal contamination lionitors) calibration checks and operating procedures, and the analytical results for 10 CFR Part 61 samPles' The inspectors determined that the procedural methods include techniques to distinguish internatiy depositeJ radioisotopes from external contamination, methods to assess dose from hard-to-measure radioisotopes, and methods to distinguish ingestion pathways from inhalation PathwaYs.
The inspectors reviewed the results from three whole body counts to assess the adequacy of the "ounting time, background radiation contribution, and the nuclide library used for assessing O"po'rition.' No inioividual exposure exceeded a committed effective dose equivalent (CEDE) of 10 mrem.
Declared Preqnant Workers The inspectors reviewed the procedural controls, and associated records, for managing declared pregnant;oftrt (DPW) and determined that three DPW5 were employed during the Unit 2 outage. The inspectors reviewed the individual exposure results and moniioring controls to assure compliance with 10 CFR Part20.
Multi-Dosimetrv Methods The inspectors reviewed Dominion's procedures for monitoring external dose where significant dose gradients exist at thework site. For 2R20, multi-dosimetry methods were used, insteid of external effective dose equivalent (EDEX) methods. The inspectors reviewed the dosimetric results for jobs where workers wore multiple dosimeters. in"t" jobs included SG nozzle installations, fuel transfer equipment repair, and diving operations. The inspectors confirmed that in addition to the TLDs worn, workers also wore electronic dosimeters, equipped with telemetry, to assure that dose fields were promply monitored by radiation'protection technicians in the centralized monitoring station.
Problem ldentification and Resolution The inspectors reviewed elements of Dominion's CAP related to implementing the dosimetry prolr"r to determine if problems-were being entered into the program for timely reioluti6n, the comprehensiveness of the cause evaluation, and the effectiveness of the corrective actions.
'specifically, CR related to dose assessments, personnel contaminations, and dose/dose rate alarms were reviewed.
b.
Findinqs No findings were identified.
2RS05 Q1124'05-1samPle)a.
lnsPection ScoPe (1 samPle)
During the period May 23, 2011 through May 26,.2011, the inspectors performed the following activities to
-evaluate the opelability and accuracy of radiation monitoring instrumentation used to detect and quantify effluent releases. lmplementation of these programs was reviewed against the criterii contained in 10 CFR Parl'20, applicable industry standards, and with Dominion's procedures' The inspectors walked down selected portions of the liquid and gaseous monitoring systemi installed in Unit 2 and Unit 3 to assess material condition, observe maintenance/calibration activities, and determine the status of system upgrades' In Unit 2, the walkdown included portions of the following monitors:
Gaseous Effluent Monitors
. Enclosure Building Roof Vent Monitor, RM-8132 NB
. Fuel Handling Building Exhaust, RM-8145 o Radwaste Building Exhaust, RM-8997 o Auxiliary Building Exhaust, RM-8434
. Stack Monitor - Wide Range, RM-8169 r Waste Gas Tank Monitor, RM-9095
. Steam Jet Air Ejector Monitor, RM-5099 Liquid Effluent Monitors
. Clean Liquid Waste Effluent Monitor, RM-9049 o Aerated Liquid Waste Effluent Monitor, RM-9116
. Steam Generator Blow-down Monitor, RM'4262 o Condensate Receiving Tank Monitor, RM-9327
. Reactor Building component cooling water Monitor, RM-6038 In Unit 3, the walkdown included portions of the following monitors:
Gaseous Effluent Monitors o Ventilation Vent Monitor, RE-10A/B
. Supplemental Leak Collection and Release System (SLCRS) Monitor, RE 19A/B o Engineered Safeguards Building Monitor, RE-49 Liquid Effluent Monitors r Turbine Building Sump Monitor, RE-50
. Liquid Waste Effluent Monitor, RE-70 o Waste Neutralization Sump Monitor, RE-07 Calibration and Testinq Proqram Through record reviews, the inspectors confirmed that the effluent monitoring instruments were prop"ity calibiated, and that the required source checks and functional tests had been routinely fierformed. The inspectors verified that the effluent monitor alarm set points are esiablished in accordance with the Off Site Dose Calculation Manual (ODCM).
The inspectors reviewed contamination sampling results (per 10 CFR Part 61) used to characterize difficult-to-measure radioisotopes, to determine if the calibration sources were representative of the radioisotopes found in the plant's source term' Problem ldentification and Resolution The inspectors reviewed selected cRs, system health reports, and various Nuclear euality Assurance reports to evaluate Dominion's threshold for identifying, evaluating, and resolving problems for the radiation monitoring instrumentation' lncluded in this review were cRs related to radiation worker and ridiation protection technician errors to determine if an observable pattern traceable in the maintenance or use of radiation instruments was evident.
b.
Findinos No findings were identified.
2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124'06 - 1 sample)a. Inspection ScoPe (1 samPle)
During the period May 23,201 1 through May 26,2011, the inspectors performed the followi"ng activities to verify that Dominion was properly maintaining the gaseous and liquid effluent processing iystems to ensure that radiological releases.were properly mitigated, monitored, an-d evaluated with respect to public exposure' lmplementation of these controls was reviewed against the criteria contained in the 10 CFR Parts 20 and 50, of Dominionls Radiological-Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM), and with Dominion's procedures' Effluent RePort Reviews The inspectors reviewed the 2009 and 2010 Annual Radiological Effluent Release Reports to verify that the effluents program was implemented as required by the REMODCM. tnbuoeo in this review w:ere the results of the ground water protection program, the inclusion of Carbon-14 dose contributions, the current land use census, and verification that no significant changes were made to the Unit 2 and unit 3 gaseous and liquid release systern-configurationi, as specified in the Final Safety Analysis Report (FSAR) and ODCM descriPtions.
Walkdowns and Observations The inspectors walked down the major componentsof the unit 2 and Unit 3 gaseous and liquid r"f""r" ryriems, to verify the system. configurations complied with the FSAR description, and to evaluate equipment material condition.
The inspectors reviewed the most current Unit 2 and Unit 3 liquid and gaseous effluent monitor monthly source checks, quarterly functional test results and 18-month calibration records to verify ihat instrumentaiion and associated pumps/isolation valves or fans/isolation dampers, respectively, were operable' The inspectors reviewed the air cleaning systems surveillance test results for the HEPA and charcoalfiltration systems installed in Unit 2 and Unit 3' The inspectors confirmed that the air flow rates were consistent with the FSAR values and the filtration system met the accePtance criteria.
Samplinq and Analvsis The inspectors reviewed the relevant surveillance procedures (SP) and observed technicians cottecting weekly air particulate and iodine samples. Airborne-particulate and iodine t"*pf"r i,ere taften fiom the Main Station Stack monitor (RM-8169), using Sp-2g15. Samples were taken from the Unit2 Enclosure Building roof vent monitor (RM-81 32), using SP-281 44.
During the walkdowns of effluent monitoring systems, the inspectors determined that appro-priate compensatory sampling measurei were implemented for monitors that were removed from service for maintenance or calibration. compensatory measures were in ptace for the U-2 Ventilation Vent monitor (RM-8132), Unit 3 SCLRS monitor (HVR-19)'and Unit 3 Liquid Waste monitor (LWS-RE-70)'
The inspectors reviewed the results of Dominion's inter-laboratory comparison (blind sample) program to verify the accuracy of effluent sample analysis performed by Dominion.
Dose Calculations The inspectors reviewed monthly, quarterly, and annual dose projections for liquid and gaseous effluents performed duiing the past 12 m-o1tlr9-to verify that the effluent was firocesseO and released in accordance with REMODCM requirements and to ensure that the licensee properly calculated the offsite dose from effluent releases. The inspectors confirmed that no p"rforr"n"e indicator (criteria contained in Appendix I to 10 CFR 50)was exceeded for these releases.
The inspectors reviewed liquid discharge permits for Unit.2 and Unit 3 to evaluate the adequacy of dilution flow, radioactive c-onient, and overall accuracy of the documented data.
Ground Water Protection Proqram The inspectors verified that Dominion is continuing to implement the voluntary Nuclear Energy Institute/lndustry Ground water Protection Initiative. The inspectors reviewed monitoring wett sampie?esutts, trending data, and decommissioning regor!9 (maintained per 10 CfYn SO.ZS tdll to evaluate procLdural compliance and to identify off normal results.
Problem ldentification and Resolution The inspectors reviewed selected CRs, system heal-th reports, and Nuclear Quality Assurance audits to evaluate Dominion'sihreshold for identifying, evaluating, and resolving problems regarding effluent treatment and monitoring.
b. Findinos No findings were identified.
OTHER ACTIVITIES
[oAl
4OA1 Performance Indicator (Pl) \\lbrification
Cornerstone: lnitiatinq Events
a.
InsPection ScoPe The inspectors reviewed Dominion submittals for the Pls listed below to verify the accuracy of ine data reported during that period T.h" Pl definitions and guidance contained in Nuclear Energy Instituie (NEi) 99-02, "Regulatory Assessment Indicator Guideline,', Revision 5, were used to v'erify the basis for reporting each data element' The inspectors reviewed portions of the operations logs, monthly ope.rating reports,.and Licensee Euent Reports (Lfn) and discussed the methods for compiling and reporting the Pls with cognizant licensing and engineering personnel.
Unit2
. Unplanned Scrams per 7000 Critical Hours; o Unplanned Scrams with Complications;
. Unplanned Transients per 7000 Critical Hours; Unit 3 o Unplanned Scrams per 7000 Critical Hours; o Unplanned Scrams with Complications; and
. Unplanned Transients per 7000 Critical Hours' b.
Findinqs No findings were identified.
.1 4OA2 tdentification and Resolution of Problems
lnspection ScoPe As required by lnspection procedu re 71152, "ldentification and Resolution of Problems,"
and in order to hetp identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into Dominion's corrective action program. This was accomplished by reviewing the a.
b.
description of each new CR and attending daily management review committee meetings.
Findinqs No findings were identified.
.2 a.
Inspection ScoPe (1 samPle)
The inspectors reviewed Dominion's current performance relevant to the cross-cutting aspect,'1H.1 (b)l Human Performance, Decision Making. Licensee Decisions demonstrate that nuclear safety is an overriding priority, and Dominion uses conservative assumptions in decision making and adopts a requirement to demonstrate Gt tn" proposed action is safe in order to pioceed, rather.than a requirement to demonstrate that it is unsafe in order to disapprove the action' Dominion conducts effectiveness reviews of safety-significant decisions to verify the validity.of the underlying asiumptions, identifies possible ulintended consequences, and determines how to improve future decisions. Millstone was noted to have three ROP findings with this associated.ror.-"uttinj aspect in the last assessment period. The inspectors reviewed related cRs, interviewed staff personnel, conducted behavioral observations of staff interactions during several meetings and training sessions^, and developed a case study of Dominion's response to the Uni[ Z reactor trip on June 20, 2011' Findinqs and Observations No findings were identified' The inspectors determined that Dominion had identified the trend in the cross-cutting aspect iH. r tOlt in their CAP (CR4031 1 1 ) DoTilg! l3!.gonducted a common cause evatuation of the crois-cutting area tH.1ib)l (ccE000164) and concluded that "no common cause, most prevalent cause tdfateb to Conservative Assumptions and Safe Actions was derived frbm the review of these three events." The inspectors noted that' at the end of tne cuirent quarter, Dominion will have only one finding with a cross-cutting aspect tH.1(b)l in tnis rep6rting period because two of the findings are no longer current and no additionaltinOinSjs hav6 assigned H'1(b)]as a cross-cutting aspect' The inspectors reviewed cc"eooot64 and noteo tnaiinis evaruation was somewhat narrowly focused on the tnree inoividual findings. while Dominion concluded that there was no common cause, tney Oroadened the icope of this evaluation and determined there was a common theme,"ro$ the three events that included some aspect of inadequate worker knowledge "no uppropriate risk recognition. -Th.ey subsequently addressed this common theme by implementing corrective ictions for the three findings (CA170523' cA183044 and CAtoisezl by c-onducting training on the specific issues' The inspectors followed Dominion's response to the unit 2 reactor trip that occurred on June 20, 2011, as a real time case study in the effectiveness of the Millstone conservative decision making process. Dominion immediately prepared CRs that b.
addressed the human performance errors (CR431574 RCE), procedural issues tCi+af 722) andsimulator fidelity issues (CR432012) and is presently conducting a root
."ur" evaluation (RCE) of the event. Prior to restarting the reactor, the inspectors observed a management meeting to implement procedural changes prior to restart, just-r+i*" training llifl for the crew supporting the restart, and the lessons learned iraining on criilcat paiameter monitoring (CR431936) conducted after the event for the remediation of all shifts. These activities observed in this case study demonstrated an appropriate emphasis on conservative decision making, critical parameter monitoring by ob"ruiorr and a tocus on operator fundamentals. In addition, the inspectors observed Supervisor Leadership Training conducted by the Plant Manager that reemphasized the safety culture aspects, expectitions and responsibilities of front line supervisors' This included lessons learned irom the response to this event. Based on this sample, it "pp"rrr that Dominion has recognized the implications of the trend in the cross-cutting
- i tH.itOlt. Current efforts to address this aspect are in progress within the Dominion cAP and will be assessed in the future after the RCE has been completed, and when lessons learned and corrective actions to prevent recurrence have been formulated and imPlemented'
.3 b.
lnspection ScoPe (1 samPle)
The inspectors reviewed Dominion's current performance relevant to the cross-cutting asject ip.t(r)l' Problem ldentification and Resolution, Corrective Action Program' Dominion ensures that issues potentially impacting nuclear safety are promptly iO"ntiti"O, fully evaluated, and tfrat actiohs are takbn to address safety issues in a timely manner, "orr"n"u13t" *it their significance. Dominion implements their cAP with a low threshold for identifying issues. bominion identifies such issues completely, accurately, and in a timely manner commensurate with their safety significance' At the end of the last ROp issessment period, Dominion was noted to have three ROP findings with this associated cross-cutting aspect and at the end of the current quarter' Dominion will continue to have the samelhree findings with a cross-cutting aspect tp.1(a)l in this assessment period because no additionalfindings have been added and in" thi"" original findings occurred within the past four quarters' The inspectors reviewed related cni, interviewed staff personnel, conducted behavioral observations of staff interactions ouring several meetings and training sessions, and developed a case
- i;ey of Dominion', 1."iponte to the unit z reactor trip on June 20, 2011' Findinqs and Observations No findings were identified.
The inspectors assessed Dominion's response to the area of identifying, fully evaluating
,no "oor"rsing sateiy Lir"t in a timely manner. The inspectors determined that Dominion had identified a trend in the safety culture cross-cutting aspect P'1(a) and had concluded that the three ROP findings had been properly evaluated and closed inJiviOuatty. Dominion did not perform a common cause assessment for the cross-
"rtti^g u;pect [p.1(a)]. During this ROP inspection period, no additionalfindings were identified that involved [P'1 (a)].
lnterviews with Dominion managers indicated that Millstone was planning to further address the broader issue of coirective action program effectiveness by making irprou"r"nts to their cAP including improving th_e_-quality of their apparent cause evaluations (ACE) and root cause e-valuations (ncr); sJrengthening the effectiveness of the corrective Action Review Board (CARB); initiating cRs for all rejected AcEs and nCfr; and enhancing the minimum iequired qualifications and training for CARB members. They alsJwere planning to conduct a sampling of lower level CR evaluations to determine if they were missing key trends and reducing the extension of corrective action due dates. other corrective actions will be considered based on the results of the common cause assessment for this trend that is presently_in progress' The inspectors noted that Millstone staff initiates a substantial volume of CRs every year and the threshold for preparing a CR appeared to be appropriately low' There appeared to be litile reluctance to oraiting a cR'by the vast majority of the staff at Millstone.
The inspectors followed Dominion's response to the Unit 2 reactor trip that occurred on June 20, 2011,as a real time case study in the eff_ectiveness of the Millstone corrective action pio""r". Dominion immediately prepared CRs thataddressed the human performance errors lCAnySl+ RCE); proceduralissues (CR431722) and simulator ilO"tity issues CR)01 2, and is presently conducting a RCE of the event' Prior to restarting tne reactoi, the inspectors observed a management meeting to implement procedural cnanges prior to restart, just-in-time training (JITT) for the crew supporting the restart, and the lessons learned training on critical parameter monitoring conducted after the event for all shifts. These activitiei demonstrated an appropriate threshold of proor"rn identification, an ability to promptly resolve adverse conditions and effective corrective action lmplementation in'responle to this e.vell In addition, the inspectors observed Supervisor Leadership Training conducted by the Plant Manager that reemphasized the safety culture aspectsl expectations and responsibilities of front line supervisors that included lessons learned from the response to this event' Based on this sample, it appears that Dominion has recognized the implications of the cross-cutting tfr"ry1" ip f tilt Current efforts to address [his theme are in progress and will be assessed in the future after the RCE has been completed and corrective actions to prevent recurrence have been implemented'
.4 a.
Inspection ScoPe (1 samPle)
The semi-annual trend review's focus was to determine Dominion's progress in correcting negative trends. The inspectors reviewed Dominion's corrective action trend
- f;tn"i" quarter 2010 and selected the work management trend-s for review' Work management was selected because it has been a site focus area for over a year' rne inspect6rs reviewed corrective action assignments CA173666, CA177780' b.
cA177781, and all corrective action assignments from apparent cause ACE 018411' ih" in.p""tors reviewed the trends and interviewed several maintenance and planning personnel in order to determine if the corrective action assignment matched the issue and if the corrective actions completely addressed the issue.
Assessments and Observations No findings were identified.
The overall goal of the corrective actions was to address negative trends in meeting work management milestones, work order readiness, and backlog management' The inspectors ietermined that since February 2011, overall work management has been improving. Total backlog per unit has been reduced from 3946 to 3771 between i"'Orru.iund May 2Ol1: britical and non critical PMs deferred per rolllnO quarter have oroppeo tro m 24 and 23 respectively in July 2010, to 6 and 0 in May 2011' T4 scope staOiiity has been consistenily at approximately 90 percent for several months' Dominion has started looking out to T16 to determine if overtime or contractor use will be iefuireO to complete the necessary work. Not all trends have been positive, as annualized critical and non critical PMs performed late in the grace n-er!o{!1ve steadily increased from 24 percent and 26.5 percent respectively in July 2010, to 31'6 percent and 34.3 Percent in MaY 2011.
The inspectors identified that one corrective action was closed out before the work was "orpf"i"O.
CA173OOO was to evaluate the gap to excellence in schedule adherence' The work completed was a draft plan to efficiently use resources to plan and complete work. The drait plan has several tasks to implement other plans. The assignment was closed out without any documentation that the plan had been implemented. lt appears g'ui i6" plan is Oeing'impremented, but the details are not captured under that corrective action. There was one corrective action that the inspectors could not completely verify iti compretion. CA18b7g0's assignment was to address work orders removed from the schedule because tf'"V OiO not miet the milestones. This assignment was closed primarily because of T4 scope stability and implementation week adherence greater than 90 percent.
4OA3 Event Follow-up
.1 a.
Inspection ScoPe on April 3,2011, Millstone lJnit2 Enclosure Building Filtration system (EPF? negative pr"$rr" test results failed to meet acceptance criteria while the unit was in Mode 4' making the Enclosuie Building inoperabie. Since the Enclosure Building failed its surveillance test, its safety fuiction to control the release of radioactive material could not be assured. Dominion determined that the cause for the failure was that the sliding bushings on the main steam safety valve (MSSV) exhaust piping had become stuck and were not seated ProPerlY.
Findinqs lntroduction: A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl,
,,Corrective Action," was ideritified for Dominion's failure to take prompt corrective action to address the cause of MSSV exhaust pipe bushings not seating, which resulted in a loss of the Enclosure Building's safety function to control the release of radioactive material. Dominion has since cleaned and lubricated the MSSV exhaust pipe, and also implemented a modification to upgrade the MSSV outlet boot and qualify it as part of the Building filtration boundary' Djscription: on April 3,2011, Millstone Unit 2 was performing a plant cool-down in Mode b when the data iat<en on the EBFS test while in Mode 4 indicated that it had not met its acceptance criteria. The Enclosure Building's safety function to control the release of radioactive material could therefore not be assured. Dominion determined that the cause of the failure was eight MSSV exhaust pipe bushings not being-seated properly because they had becomi $uck on the exhaust pipe' Dominion performed cleaning and lubrication of the MSSV exhaust pipe and.performed a successful retest on April 26, 2011. The Enclosure Building had also t?19d. its surveillance test in July 2009 when two MSSV bushings had not seaied. The 2009 investigation delermined that the lifting of the relief valveJassociated with these bushings as a result of the July 3' 2009 iiip n'"0 caused the bushings to slide up the exhaust pipe and become stuck' The bushings were reseated and a successful retest was performed' one of the corrective actions from the 2009 root cause was to develop a new procedure for the inspection and cleaning of the sliding bushings. Details were to include lifting of the bushing, and to provide necessary tooling and criteria for clearances and cfeanliness. proced'ur)e MP27O2F1 0A, "Cleaning and lnspection of MSSVs Sliding Bushings," *". uppioulJ in Nou"tber 2009. However, the work performed on the bushings *",.orii"t"O in October 2009, which occurred prior to the approval of p.."0-ur" MZ27O)F10A. As a result, the work orders for the sixteen sliding bushings did not contain Oetaifslor properly cleaning the bushings'. The work orders only stated'
,,verify that the sliding bushing is free to slile on vent siack without excessive binding in b.
Dislodqed Bushinos accordance with MF 2701J-114." Far the eight bushings that were not seated, only three of the work orders' comments stated that cleaning of the sliding bushing was performed. Dominion's apparent cause evaluation from the April 2011 failure stated that a contributing cause was,"iineffective implementation of corrective actions from root cause RCE000984; inadequate/inconsisient maintenance cleaning approach may have resulted in MSSV sliding bushings hanging up'"
Analvsis: The inspectors determined the failure to take prompt corrective action to clean the sliding bushings in October 2009 was a performance deficiency that was reasonably within Diminion's aOitity to foresee and correct, and should have been prevented' Traditional enforcement doet not apply since there were no actual safety consequences' impacts on the NRC',s ability to perform its regulatory function, or willful aspects of the finding.
The finding was more than minor because it was associated with the Procedure Quality attribute of the garrier Integrity cornerstone and affected the cornerstone objective to prouio" reasonable assura-nce that physical design barriers protect the public from radionuclide releases caused by accidents or events. specifically, the failure of the MSSV sliding busninls to seat property caused the EBFS to fail its surveillance test, and its safety function to iontrol the release of radioactive material could not be assured' The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual'chapter (lMC) Attachment 0609.04, "Phase 1 - Initial screening and Characterization of FinOingt," and determined that the finding was of very.low safety significance (Green) O"""ir" it only represents a degradation of the radiological barrier function provided for the auxiliary building' The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, corrective Action Program component, because Dominion did not take appropriale or timely corrective action to address the Building surveillance test failure in 2009. tP.1(d)l
Enforcement:
10 cFR 50, Appendix B, Criterion XVl, "corrective Action," states, in part' that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, and defective materialand equipment' and non-contormances are prompily identified and corrected' Contrary to the above' from October 2009 until April 2011, Dominion failed to take prompt corrective action to address the cause of the trrtssv exhaust pipe bushings not seating properly, which caused the inoperability of the Enclosure'Building and a loss of its safety function on April 3, 2011. Dominion took corrective action to clean and lubricate the MSSV exhaust pipe and also implemented a modification to upgrade the MSSV outlet boot and qualify it ld-part of the Enclosure Building filtration boundary. Because this violation was of very low safety significance and was entered into Domihion's CAP (CR420485), this violation is being treated as an NCV, consistent with the NRC's Enforcement Policy' (NCV 0500336/2011003-03 lnadequate Gorrective Action Results in Loss of Enclosure Building's SafetY Function.)
.2 a.
lnspection ScoPe On June 20,2Q11, at 1 1:52 a.m., Unit 2 experienced an automatic trip on low steam geneiator level. The low steam generator level was caused by a loss of feedwater flow when the 'B, steam generator feedwater pump (SGFP) tripped on low suction pressure while the operators irere in the process of bringing the 'A' SGFP on-line' The inspectors responded to the control room and evaluated the adequacy of operator actions in accordance with approved procedures and TS requirements. The-inspectors p"trom"o a walkdown of the control room and interviewed personnel to verify that the ffi;i;"r stable. The inspectors also reviewed the sequence of events and post trip review report in order to d'etermine if there were any other plant or equipment anomalies' The inspectors observed the reactor startup and portions of the power ascension inciuOin'g the starting of the second SGFP. The inspectors reviewed CRs to ensure conditions adverse io quality associated with this event were entered into Dominion's corrective action program for resolution' Findinqs lntroduction: A self-revealing finding (FlN) of very low_safetY significance (Green) was identified for Dominion's failure to follow proceduie OP 2204, "Load Changes," when starting the 'A' SGFF. Specifically, the operating crew failed to maintain adequate SGFP suction pressure (greatei than 32-5 psig) while starting the 'A' SGFP, which led to a trip of the 'B' SGFP and subsequent reactoi trip on low steam generator level'
Description:
On June 20,2A11, Millstone Unit 2 reduced power to 30 percent to repair an oil leak on the'c' reactor coolant pump (RCP) moto-r, following the repairs, Millstone Unit 2 began increising power to 59'percent with the 'B' SGFP feeding the steam generators. operatorjwere in the process of bringing the 'A' SGFP pump on-line when feed regutating varve irnVloitr"t"ntial pressure t+] oecreased outside of the operating band. The operator tnen incorrectly lowered 'g' SGpP speed to increase FRV dp' The operator did not get the desired response, and increased 'B' SGFP speed back to its original value. The operator then increased the speed of the 'A' SGFP in order to bring the pump on-line to feed the steam generators. This action decreased feed pump suction pressure and caused the'B;SGFP to trip on low suction pressure' The resulting loss of feedwater flow caused a reactor trip on low steam generator level at 11:52 a'm' Dominion's post trip review identified some instances where operator actions.were not as expected. OP iZOq,"Load Changes", step 4'121-tj3l9t' "When placing the second SGFp in service, fHnOfff-E open dtttM-2,';CONO DEMIN BYP," as needed to maintain both SGFp suction pressures greater than 325 psig (C-05)'" CNM-? was not throttled open by the operating crew unJ SCrp suction pressure was not maintained above 325 psig, noi*ut it ad6quately monitored. SGFP suction pressure dropped below 325 psig at 11:44a.m., and at 11:50 a.m. the 'B' SGFP suction pressure low b.
alarm came in at 260 psig on the plant process computer (PPC). The operating crew took no corrective action in response to the alarm' ln addition, the post trip review also identified that recent revisions to procedure OP 22e4, which delayed the start of the heater drain pumps until 70 percent reactor power and increased the reactor power band for starting a second SGFP from 45 percent - 50 percent to 45 percent - 65 percent, may not have been appropriate.
The inspectors noted that oP 2321, "Main Feedwater system," which contains the procedure for starting a second SGFP, does not mention monitoring SGFP suction pressure. lt only staies in the initial steps, "Verify the following: Condensatg header fr"rrur" greater than 425 psig (C-05).'; The inspectors also noted that JITT for the power asJension did not include starting the second q9FP, because other power ascension evolutions, such as synchronizing to the grid, were deemed to be more difficult.
Analysis:
The inspectors determined the failure to adequately monitor and take correctVe action when SGFP suction pressure dropped below 325 psig was a performance deficiency that was reasonably within Dominion's ability to foresee and correct, and should have been prevented. Traditional enforcement does not apply since there were no actual safety consequences, impacts on the NRC's ability to perform its regulatory function, or willful aspects of the finding' The finding is more than minor because it is similar to NRC Inspection Manual Chapter O612,App-endix E, "Examples of Minor lssues," Example 4b; in that, a failure to follow procedure led to a reactor trip. This issue is associated with the Human Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of thlse events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure of the operators to properly monitor SGFP suction pressure led to a loss of adequate feedwater flow and a reactor trip. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment 0609'04, "Phase 1
- lnitial Screening and Chara cterization of Findings," and determined that the finding was of very low *ut"ty significance (Green) because it did not contribute to both the likelihood of a react,oitrid and the likelihood that mitigation equipment or functions would not be available.
The inspectors determined that this finding had a cross-cutting aspect 'l thg Human Performance cross-cutting area, Work Practices component, because Dominion personnel did not properly follow the load changes procedure' tH.4(b)l
Enforcement:
This finding does not involve enforcement action because no regulatory requ-rcment "iolation waiidentified. Dominion entered this issue into their corrective action program (CR431 574); conducted training exercises emphasizing safe operating envelopesl critical parameters to monitor, and actions to take to restore margin if plant conditions degrade; and has revised procedure oP 2204. Because this finding does not involve a violation of regulatory requiiements and has very low safety significance, it is 4045 identified as a finding. (FlN 05000336/2011003'04 Failure to Follow Procedure for Starting a Second SCfp Results in Reactor Trip)
Other Activities The inspectors assessed the activities and actions taken by the licensee to assess its readiness to respond to an event simirar to the Fukushima Daiichi nuclear plant fuel orrug" event. This included
- (1) an assessment of the licensee's capability to mitigate conditions that may result from beyond design basis events, with a particular emphasis on strategies retated to the spent flel pool, Js required by NRC Security Order Section 8.5.b issued February 25,2dQ2, as committed to in severe accident management guidetines, and as re6uir"O by 19 CFR-50.54(hh);
- (2) an assessment of the licensee's capability to mitigate,t"ttn blackout (SBO) conbitions, as required by 10 CFR 50'63 and station design bases;
- (3) an assessment of the licensee's capability to mitigate internal and externalflooding events, as required by station design bases; and
- (4) an assessment of the tfrorougniess of the walkdowns and inspections of important "qripr"nt needed io titli"t" fire and flood events, which were performed by the licensee to identify any piential loss of function of this equipment during seismic events possible for the site.
Inspection Report 05000245,3 36,42312011009 (ML111320660) documented detailed results of this inspection activity'
.1.2
on May 13, 2011, the inspeCtOrS completed a review of the licensee's severe accident management guioetinerlbnMc.l, implemented as a voluntary industry initiative in the 1990,s, to determine tij ivr,etn"r ii'" SAMGs were available and updated,
- (2) whether the licensee had pro"Ldrr", and processes in place to control and update its
-SAMGS'
- (3) the nature and extent of the licensee's training of personnel on the use of SAMGs' and(4)licenseepersonnel'sfamiIiaritywithSAMGimplementation.
The results of this review were provided to the NRC task force chartered by the Executive Director for operations to conduct a near-term evaluation of the need for agency actions rorrowing thefukushima Daiichi fuel damage event in Japan' Plant-
- "iii6 resutts for Millsione Power Station were providc'c1 in an Attachment to a memorandum to the Chief, Reactor Inspection Bianch,.Division of Inspection and negionat Support, dated May 27,2011 (ML111470361)'4046 Meetinqs. includinq Exit Exit Meetinq Summarv On August 1, 2011, the resident inspectors presented the overall inspection results to Mr. A. J. Jordan and members of his staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.
ATTACH MENT: SU PPLEMENTAL INFORMATION SUPPLEMENTAL IN FORMATION KEY POINTS OF CONTACT Dominion personnel R. Arquaro L. Armstrong G. Auria B. Barron B. Bartron C. Chapin W. Chestnut F. Cietek T. Cleary G. Closius L. Crone J. Curling J. Dorosky M. Finnegan J. Gauvin A. Gharakhanian M. Gobeli W. Gorman J. Grogan K. Grover C. Houska A. Jordan J. Kunze J. Laine R. MacManus G. Marshall M. Martel C. Rheims R. Riley M. Roche L. Salyards M. Sartain J. Semancik A. Smith D. Smith S. Smith J. Stoddard R. Sturgis M. Socha S. Turowski C. Vournazos P. Zahn U3 Shift Manager Manager, Training Nuclear Chemistry SuPervisor Manager, Nuclear Oversight Supervisor, Licensing Assistant OPerations Manager Supervisor, Nuclear Shift Operations Unit 2 Nuclear Engineer, PRA Licensing Engineer Licensing Engineer Supervisor, Nuclear Chemistry Manager, Protection Services Health PhYsicist lll Supervisor, Health PhYsics, ISFSI Unit 3 ChemistrY Technician Nuclear Engineer lll Shift Technical Advisor Supervisor, lnstrumentation & Control Assistant OPerations Manager Manager, Nuclear OPerations l&C Technician Site Vice President Supervisor, Nuclear Operations -Suppgrt Manager, Radiation Protection/Chemistry Direct6r, Nuclear Station Safety & Licensing Manager, Outage and Planning U3 Shift Manager l&C Engineer Supervlsor, Nuclear Shift Operations Unit 3 Senior Nuclear Chemistry Technician Licensing, Nuclear Technology Specialist Director, Nuclear Engineering Plant Manager Asset Management Manager, EmergencY PreParedness Manager, Engineering Unit 3 Shift Manager Secondary Systems Engineering Supervisor Unit 3 Work Control SRO Supervisor, Health Physics Technical Services lT Specialist, Meteorological Data Operations SuPPort SPecialist LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED 05000336/201 1 003-03 05000336/201 1 003-04 Opened and Closed 0500042312011003-01 NCV 05000336/2011003-02 NCV Failure to Take Timely Corrective Actions for De-alloying of Aluminum Bronze Service Water Valves (Section 1R15)
Untimely Corrective Action for Safety Related lnverters Leads to Repetitive Out of Calibration Results (Section
1R22 ) Inadequate Corrective Action Results in Loss of Enclosure
Building's Safety Function (Section 4OA3)
Failure to Follow Procedure for Starting a Second SGFP Results in Reactor Trip (Section 4OA3)
Building Rendered Inoperable Due to Dislodged Bushings Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5.1)
Availability and Readiness Inspection of Severe Accident Management Guidelines (Section 40 A5.2)
NCV FIN Closed 05000336/2011-001 LER 05000245, 336,4231 251 5/1 83 Tl 05000336,423125151184 Tl LIST OF
DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
@inds
and High Tides," Revision 010-05
AOP 3569, "severe Weather Conditions," Revision 016-00
C Op 200.g,,,Response to ISO New England/CONVEX Notifications and Alerts," Revision 004-
ISO New England OP 4, "Action during a Capacity Deficiency," Revision 10.
ISO New England M/LCC 5, "proceduie for Millstone Point Station Generation Reduction,"
Revision 10
SP 2665, "Building Flood Gate Inspections," Revision 005-02
System Health RJport, NSST, RSST and Main Transformer, 1"'Quarter 2011
System Health Report, 345KV Switchyard, 1"'Quarter 2011
System Health Report, Unit 2 and Unit 3 Doors and Barriers, 1"'Quarter 2011
M2 99 13754
53102268158
53102355714
53102410971
53102410973
cR381899
cR381901
cR412022
cR412023
cR412024
cR412026
cR412028
Revision 37
203-26023 Sheet 2,
System," Revision 30
MREo10817
MREo10866
MREo10875
MREo10883
MREO10886
53102410975
53102410976
53102410977
cR412032
cR412033
cR412035
cR412036
cR420060
cR420238
cR420239
cR420495
Section 1R04: EquiPment Aliqnment
9E for FacilitY 1 on APril 3,2O11"
Maintenance Rule Scoping Tables for Enclosure Building Filtration
OP 2301B, "SDC/SFPC Core Off-Loaded," Revision 000-05
oP 2308-002, "HPSI System Valve Alignment, Facility 2," Revision 000-04
Op 2314G-001, "Enclosure Building Filtration System Alignment," Revision 012-01
oP 3308, "Train'A' High Pressure safety Injection," Revision 004-06
system Health Report Enclosure Building Filtration,J " quarter 201 1
203-2602g Sheet 5,,',piping and Instrr.rmentation Diagram containment and Enclosure
Building Ventilation," Revision 36
203-26015 Sheet 1, "piping & Instrumentation Diagram
"Piping & Instrumentation Diagram Spent Fuel Pool Cooling & Cleanup
MREO10952
MRE01 1396
MRE011510
MREO13253
MREO13468
MRE013497
MRE013572
MRE013505
MRE013653
MREO1 3571
Section 1R05: Fire Protection
mstoneUnit2,FireHazardsAnalysis,Revision11
Millstone Unit 2 Firefighting Strategies, April2002
Brigade Drill and Assessment for Unit 2 East Cable Vault
Section 1R08: ln'Service Inspection
Miscellaneous
n""-r, r.rp, rnc. Engineering Information Record, No. 51-91521 16-000, "Millstone Unit 2 - 2R2o
ECT Inspection Plan
M2-EV-11-001, Revision 0, "Millstone Unit 2 Steam
Assessment (2R20)"
Generator I ntegritY Degradation
Weldinq Packaqe
SA4A-123, Reftion 0, "safety Requirements for Welding, Cutting and Brazin-g"
Wo s31 o23g2sss, "SWLB - Modification of Service Water Spt 60469 - DM2-00, 01-0132110
CMP 701.01, Revision 002-04, "Pre-Job Checklist"
SA-AA-1 1 0, Attachm ent 2, "Job Hazard Assessment"
WM-AA-3O1, Attachment '14, "High Contingency Plan Actions"
Procedures
ER4A-N DE-UT-7O 1, Revision 4, "U ltrasonic Thickness Measurement Proced u re"
CM-AA-FPA-101, Revision 3, "Control of Combustible and Flammable Materials"
ER-AA-RRM-100, Revision 2, "ASME Section Xl Repair/Replacement Program Fleet
lmplementation Req uirements"
gi-nn-XOE-\\rr-G03, Revision 3, "VT-3 Visual Examination Procedure"
MA-AA-101, Revision 5, "Fleet Lifting and Material Handling"
MA-AA-1001, Revision 4, "supplemental Personnel"
Mp-VE-g, Revision 001, iVisual Weld Acceptance Criteria for Weldments and Brazed
Joints"
SA-AA-107, Revision 0, "Fall Protection"
SA-AA-108, Revision 0, "Hand and Portable Power Tool safety"
SA-AA-111, Revision 0, "Ladder Safety"
SA-AA-1 18, Revision 2, "Personal Protective Equipment"
SA-AA-119, Revision 2, "safety Signs and Barriers"
SA-AA-123, Revision 0, "Welding, Cutting, and Brazing Safety"
Drawinqs
2003-22200, sH 60469G
tvtpZ eSt 1301A, "Evaluated Simulator Exam"
Section 1Rl2: Maintenance Effectiveness
gPumpMotor,ElectricMotor&ContractingCo.,
lnc.
Maintenance Rule Scoping Tables, Charging, Letdown and Boric Acid
System Health Report,'Chirging, Letdown and Boric Acid, 1"t Quarter 2010 and 1" quarter 2011
MREO10523
MREO1 081 7
MREo10827
MREO10852
MREO1091 1
MREO109',l2
MREo10933
MREo10954
MRE011216
MRE01 1 21 7
MREO11377
MRE012159
MREo12314
MREo12382
MREo12902
MREO13587
MREO13664
MREo13670
Alternateetantcon@ting2-RC-252,pressurizerspraylineisolation
ETE-Mp-2011-0090, "Structural Integrity Evaluation for MPS3 Dealloyed Aluminum Bronze
Valves," Revision 0, dated May 26,2Q11
Millstone Unit 2 & Millstone Unit 3, 2R2O Switchyard Work Risk Management Plan, Revision 1,
March 31, 2011
Millstone Unit 2 Shutdown Safety Assessment (SSA) Checklist April 5, 2011, April7,2011
Millstone Unit 2 High Risk Evolution Plan for the 1't Reduction in RCS Inventory
Millstone Unit 3 EOOS Operator's Risk Report, April 14,2011
OP-AA-1 500, "Operational Configuration Control," Revision 5
OP 2301E, "Draining the RCS (ICCE)," Revision O24-O7
OU-M-200, "shutdown Risk Management," Revision 2
ou-M2-201, "shutdown safety Assessment checklist," Revision 1
Pre-2R2Q Shutdown Risk Schedule Review
shutdown Risk contingency Plan Replacement of 2-SW-97B - Orange
Sp 344681 2,"Train 'B;Soli-d State Protection System Operational Test," Revision 012-04
ESI-TP-3 96000049, "345 KV System," Revision 1
cR421347
cR422907
cR422915
cR428600
cR428654
cR428658
wo 53102273422
Section 1R15: Operabilitv Evaluations
AOP{551 "Reactor Coolant System Leak," Revision A17-O2
EOP-3505, "Loss of Shutdown booling and/or RCS lnventory," Revision 10-03
EOP-ECA-1.2, "LOCA Outside of Containment," Revision 008
RAS 000176, "Justification for TCOA to Secure RCPs," Revision 0 dated April4,2011
NRC Memo from John Hannon to Sunil Weerakkody, "subject: Resolution of Questions
concerning Compliance with Section lll.L.2 of Appendix'R"'dated February 10' 2005
ETE-Mp-tg11-0090, "structural Integrity Evaluation for Millstone Unit 3 Dealloyed Aluminum
Bronze Valves," Revision 0 dated May 26,2011
1OD000173, "Millstone Unit 3 Service Water Valves Dealloying Conditior," dated May 28,2011
CR41}T23,,,Fire Shutdown Analysis Time Critical Operator Action (TCOA) to secure RCPs"
dated March 28,2011
cR428600
cR428654
cR428658
Section 1Rl8: Plant Modifications
@m
SafetyValve Vent Piping," Revision 4
203-20150, "Main Steam Relief Valve Discharge to Atmosphere," Revision 9
53102364164
531 023641 65
531 023641 66
531 023641 69
531 02379998
Section 1R19: Post Maintenance Te,stinq
@ry
Quarterly Inspection," Revision 001-04
OP 2346C-002, "'B' DG Data Sheet," Revision 001-06
SP 2411A, "CEA Motion Inhibit Verification (deviation)," Revision 002-04
SP 2411B, "PDIL Alarm Verification," Revision 000-04
sP 2613J-001, "'B'Emergency DG LoSS of Load Test," Revision 003
Sp 2613L-001,,,periodicbG Slow start Operability Test, Facility 2 (Loaded Run)," Revision 003-
53M20300833
53M20807099
53102283860
531 02301 088
53102322778
cR420696
cR422697
cR422840
cR432098
53102389917
53102394659
53102435234
53102447327
cR432184
cR432201
cR432228
cR432400
cR432419
Section 1R20: Refuelinq and Oth.er gutaqq Aqtjvities
, "lTC Measurements," Revision 006-06
EN 21004K, "Low Power Physics Test," Revision 003-00
MP 271281, "Control of Heavy Loads," Revision 010-06
MP 27O4A
- A. "Unit 2 Reactor Disassembly and Reassembly," Revision 002-03
OP 22O2A, "Reactor Startup by Dilution lCCE," Revision 000-04
OPS-FH 215, "Refueling Machine Operation," Revision 001-03
SP 21018-001, "Core R6activity Balance Surveillance Form," Revision 010-02
cR420439
cR421265
cR423437
cR424910
cR424939
cR425314
cR42551 3
Section 1R22: Surveillance Testlnq
lReadinessandQuarterlylSTGroup.B,PumpTeStS,,'
Revision 017-03
SP 3622.3-001, Surveillance Form Revision 014-03
sP 3556812, "SSPS Train'.B' Operational Test," Revision 012-04
CR41 2930, "Chemistry procedut'e needs enhancement"
Millstone Nuclear power Station Gamma Spectrum Analysis dated May 27,2011
CP 3802E, "Reactor Coolant gas Sampling and Analysis," Revision 002-01
53102294614
53102299983
53102296198
53102300352
cR422915
cR420164
cR425958
cR422421
cR426589
cR422847
cR426592
cR422907
Procedures
sP 2815, Main station stack WRGM Sampling for lodine and Particulates
SP 28144, Gaseous Effluents for lodines and Particulates from Unit 2 Vent
SP 3878, Unit 3 Monthly Liquid and Gaseous Effluent Dose Projection
SP 2858, Offsite Dose Noble Gases from Unit 2
SP 2859, Off-Site Dose-lodine and Particulate Releases
RP-AA-502, Groundwater Protection Program
Rp-AA-bO4, Remediation Process for the Groundwater Protection Program
Rp-AA-524, performinj Sour"" Term Estimates and Dose Calculations for Carbon-14 Effluents
RpM 2.8.S, Sampling alnd Oisposal of Unit 3 Waste Test Tank Berm Water
EN 21235, Millstone-Unit 2 Radiation Monitor High Radiation Setpoints
EN31 153, Millstone Unit 3 Radiation Monitor High Radiation Setpoints
EP-AA-303, Equipment lmportant to Emergency Response
CY-AA-LQC-400- 1 O0O, Confi rmatory Measurements using Bl ind sam ples
SP 3880, Unit 3 SCLRS Vent Radiation Monitor lnoperable
Radioloqical Hazard Assessment (21 124.01 )
@
High Radiation Area Key Control
RPM 1.5.5, Revision 4, Guidelines for Performance of Radiological Surveys
RPM 1.5.6, Revision 3, Survey Documentation and Disposition
RPM 2.1.1, Revision 5, lssuance and Control of RWPs
RPM 2.4'1, Revision 6, Posting of Radiological Control Areas
RpM 2.S.2, Revision 2, Guidelines for Spent Fuel Pool or Flooded Reactor Cavity Work
RPM 5.2.2, Revision 10, Basic Radiation worker Responsibilities
RPM-GDL-008, Revision 0, EleCtronic Dosimeter Alarm set Points
Rp-M-201, Revision 4, Access Controls for High and Very High Radiation Areas
RP-AA-106, Revision 1, Radiological Work Control Program
RP-AA-124, Revision 2, Dosimetry Discrepancy and ED Alarm
Rp-M-201, Revision 5, Access Controls for High and Very High Radiation Areas
RP-M-203, Revision 0, Radiological Labeling and Marking
RP-AA-222, Revision 0, Radiation Surveys
RP-M-223, Revision 1, Contamination Surveys
ALARA Planninq & Controls (71124'02)
RP-M-103, Revision 0, ALARA Program
RP-M-103-1000, Revision 1, Station ALARA Committee
RP-M-300, Revision 4, ALARA Reviews and Reports
RPM 1.4.2, Revision 2, ALARA Engineering Controls
RPM 1.4.4, Revision 2, Temporary Shielding
RPM 2.1.2, Revision 2, ALARA lnterface with the RWP Process
RPM 5.2.3, Revision 3, ALARA Program and Policy
24.03
fportaoteHEPAFilteredVentilationandVacuumUnits
RPM 2.10.2, Revision 11, Air Sample Counting and Analysis
Catibration/Source/Functional Testinq Records Reviewed:
ln-Plant Effluent Monitors
Unit2
ffiinment Gaseous and Particulate Process Radiation Monitor (RM-8123)
Aerated Liquid Rad waste Process Radiation Monitor (RM-g116)
Waste Gas Process Radiation Monitor (RM-9095)
Reactor Building Closed Cooling Water Radiation Monitor (RM-6038)
clean Liquid Rad waste Process Radiation Monitor (RM-9049)
Unit 3
Contlinment Area High Range Radiation Monitor (3RMS.R1Y05A)
Waste Neutralization Sump Radiation Monitor (3CND-RlYO7)
Ventilation Vent Stack High Range Radiation Monitor (3HVR.RlY10A
Ventilation Vent Stack Normal Range Radiation Monitor (3HVR-RlY10B)
Supplemental Leak Collection and Release System High Range Radiation Monitor
(3HVR.RIY19A)
Liquid Waste Radiation Monitor (3LWS-RlY70)
Turbine Building Floor Drains Radiation Monitor (3DAS-RlY5o)
Air Cleaninq Svstem Testino
@ryBuildingVentilationSystemSurveillanceTests
Sp 36141, Unit 3 Supplemental Leak Collection and Release System Surv_eillance Tests
Sp 2654e, Unit 2 Containment and Enclosure Building Exhaust Filter L-25 HEPA
Filtration Testing
SP 2609D, Unit! Enclosure Building Charcoal/HEPA Filtration Testing
Sp 34498; SLCRS Gaseous Radiation Monitor and Ventilation Vent Stack Calibration
VPROC-OPSo3-Oo1, In-Place Testing of HEPA Filters & Charcoal Absorbers
Other Documents
Monthly, Ouartedy, and Annual Liquid and Gaseous Effluent Dose Assessments for
Unit 2 and Unit 3 from April 2010 through April 2011
2010 Radioactive Effluent Release Report
Mp-22-REC-BAp01, Revision 26, Radiological Effluent Monitoring and Off-Site Dose
Calculation Manual
Audit 0g-15, Off-site Dose calculation Manual/Radiological Environmental Monitoring
Program (REMODCM)
Occupational Dose Assessment (71 124'04)
npV t.3.8, Revision 8, Criteria for Dosimetry lssue
RPM 1.3.12, Revision 8, Internal Monitoring Program
RPM 1.3.13, Revision 8, Bioassay Sampling and Analysis
RPM 1.3.14, Revision 7, Personnel Dose Calculations and Assessments
RPM 1.6.4, Revision 3, Siemens Electronic Dosimetry System
RPM 2.5.8, Revision 3, Stay Time Tracking and Multi-Badging for Special Work
RP-AA-123, Revision 1, Effective Dose Equivalent
RP-AA-150, Revision 1, TLD Performance Testing
Condition Reports
iffi,q6953,418801,41g2go,41g87g,42o476,42o959,421ooo,421o56,421115,
21661, 421769, 421906:, 421g15i,, +Z2Zg3, 422281, 422384, 422712, 428440, 417715' 420139',
}B21OT, 42Sg4B:, 421522, 422894, 422553i, 418694, 409791, 387731, 380555, 370396, 368894
Site ALARA Council Meetinq Minutes
rations&LocalLeakRateTesting,Decon,Shielding
lnstallation & Removal, In-service lnspection, Steam Generator Corrective Maintenance (CM)
and preventative Mainienance (PM), iReactor Disassembly/Reassembly, Mechanical CMs &
PMs, Instrumentation & Controls Tasks
Miscellaneous Documents
NVLAP Certfication Records, Personnel Dosimetry Performance Testing
Annual Review Report of the 2010 1o cFR Part 61 Radionuclide Analysis
Electronic Dosimeter Dose/Dose Rate Alarm Reports, January 2011 - April 2011
Top Ten Individual Exposure Records for 2011
Portable HEPA Inventory & Test Records
EPRI Standard Radiatioh Monitoring Program Data Summary for Unit 2 piping
Unit 2 Reactor Coolant System 2R20 Clean Up Data
Nuclear oversight Field observation 2R20 Snapshot Reports
2R20 ALARA Plans (AP)/ Work-ln-Proqress (WlP) Reviews
AP 2-11 -01, Reactor Disassembly/Reassembly
AP 2-11-09, Steam Generator PMs & CMs
Ap 2-11-13, Scaffolding lnstallation/Removal, lnstallation of Permanent Scaffolding
AP 2-11-14, Insulation Removal/lnstallation
AP 2-11-26, Radiation Protection Support Activities for 2R20
Section 4OA3: Event Follow'uP
@re
of SP 2609E for Facility 1 on April 3,2011
MP 2701J-114, "Main Steam Safety Valve Discharge Piping," Revision 0
Mp27O2Fj0A, "Cleaning and Inspection of MSSVs Sliding Bushings," Revision 000
RCE000984, "EnclosurJ Auitding'Filtration System (EBFS) Negative Pressure Test Failed
Acceptance Criteria
SP 2609E, "EBFS Negative Pressure Test," Revision 009-04
SP 2609EE-001, "EBFS Negative Pressure Test, Facility 1,"
SP 2609EE-002, "EBFS Negative Pressure Test, Facility 2,"
cR420485
53M20807056
53M29208468
008-03
001-04
CFR
CR
EDEX
EBFS
rcl
r&c
IMC
LER
mrem
MWTH
LIST OF ACRONYMS
Alternating Current
Agencywide Documents Access and Management System
As Low As ReasonablY Achievable
Abnormal Operating Procedure
ALARA Plans
American Society of Mechanical Engineers
Corrective Action Program
Committed Effective Dose Equivalent
Code of Federal Regulations
Current Licensing Basis
Condition Report
Chemicaland Volume Control System
Circulating Water
Derived Air Concentration
Diesel Generator
Departure from Nucleate Boiling
Dominion Nuclear Connecticut
Declared Pregnant Workers
Division of Reactor Projects
Division of Reactor SafetY
External Effective Dose Equivalent
Building Filtration System
Emergency PrePared ness
Engineered Safety-Feature Actuation System
Engineered SafetY Feature
Final Safety AnalYsis RePort
High Efficiency Particulate Air
High Pressure SafetY Injection
lncore lnstrument
lnstrumentation and Control
lnspection Manual ChaPter
In-Service Testing
Just-intime-training
Licensee Event RePorts
Low Pressure SafetY Injection
Loss of Coolant Accident
Motor Control Center
millirem
Megawatts Thermal
Non-Cited Violation
NEI
NRC
oos
REMODCM
SAC
TS
UGS
Nuclear Energy lnstitute
Nuclear Regulatory Commission
National Voluntary Laboratory Accreditation Program
Operability Determ inations
Off-Site Dose Calculation Manual
Out Of Service
Publicly Available Records System
Performance Indicator
Problem ldentification and Resolution
Preventive Maintenance
Post Maintenance Testing
Reactor Building Closed Cooling Water
Radiologically Controlled Area
Root Cause Evaluation
Reactor Coolant PumP
Radiological Effluent Monitoring and Offsite Dose Calculation Manual
Radiological Work Permit
Site ALARA Council
Significance Determination Process
Steam Generator Feedwater PumP
Supplemental Leak Collection and Release System
Surveillance Procedures
Total Effective Dose Equivalent
Thermoluminescent Dosimeter
Technical Specification
Updated Final Safety Analysis Report
Upper Guide Structure
Very High Radiation Areas
Work Order
Wide Range Gas Monitor
Attachment