IR 05000336/2014002
| ML14129A244 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/07/2014 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Heacock D Dominion Resources |
| McKinley R | |
| References | |
| IR 14-002 | |
| Download: ML14129A244 (37) | |
Text
May 7, 2014
SUBJECT:
MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2014002 AND 05000423/2014002
Dear Mr. Heacock:
On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station, Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on April 22, 2014, with Mr. Stephen E. Scace, Site Vice President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions 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 one violation of NRC requirements, which was of very low safety significance (Green). However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Millstone. In addition, if you disagree with the cross-cutting aspect assigned to the finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Millstone.
Additionally, as we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter (IMC) 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross-cutting aspect assigned, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Millstone.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs 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 component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects
Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49
Enclosure:
Inspection Report 05000336/2014002 and 05000423/2014002
w/Attachment: Supplementary Information
REGION I==
Docket Nos.
50-336 and 50-423
License Nos.
Report No.
05000336/2014002 and 05000423/2014002
Licensee:
Dominion Nuclear Connecticut, Inc.
Facility:
Millstone Power Station, Units 2 and 3
Location:
P.O. Box 128
Waterford, CT 06385
Dates:
January 1, 2014 through March 31, 2014
Inspectors:
J. Ambrosini, Sr. Resident Inspector, Division of Reactor Projects (DRP)
J. Krafty, Resident Inspector, DRP
B. Haagensen, Resident Inspector, DRP
E. Andrews, Reactor Engineer, DRP
J. Richmond, Senior Reactor Engineer, Division of Reactor Safety (DRS)
H. Anagnostopoulos, Health Physicist, DRS
Approved By:
Raymond R. McKinley, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
SUMMARY
IR 05000336/2014002, 05000423/2014002; 01/01/2014 - 03/31/2014; Millstone Power Station (Millstone) Units 2 and 3; Operability Determinations and Functionality Assessments.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One NRC-identified non-cited violation (NCV) of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XI, Test Control, because Dominion did not properly evaluate test results outside of the acceptance criteria for the Unit 3 A service water (SW) pump. Specifically, on February 23, when the A SW pump did not meet its acceptance criteria for running amps, Dominion did not fully evaluate pump operability under all conditions. Dominions immediate corrective actions included entering the issue into their corrective action program (CAP) and placing the pump in pull to lock status until the issue could be resolved.
The inspectors determined that Dominions failure to properly evaluate test results outside of the acceptance criteria for the A SW pump in accordance with the requirements of 10 CFR 50, Appendix B, Criterion XI, to assure that test requirements have been satisfied was a performance deficiency that was within Dominions ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, without proper evaluation of the test results, Dominion kept a component in service that was later determined to be non-functional. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification (TS) allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event, and did not represent an actual loss of function of a non-TS train of equipment designated as high safety significant. This finding has a cross-cutting aspect in the area of Human Performance, Design Margins, in that Dominion did not operate and maintain the pump within design margins, where margins are carefully guarded and changed only through a systematic and rigorous process. [H.6]
(Section 1R15)
REPORT DETAILS
Summary of Plant Status
Millstone Unit 2 began the inspection period operating at 100 percent power. On January 31, Unit 2 shut down the plant in order to comply with TSs due to inoperable group 1 proportional heaters while the B emergency diesel generator (EDG) was out of service (OOS) for maintenance. Unit 2 returned to 100 percent power on February 3. On February 27, Unit 2 reduced power to 17 percent to address a failed cell in the 201B battery. Unit 2 returned to 100 percent power on February 28.
Millstone Unit 3 operated at or near 100 percent power for the entire inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Dominions preparations for the onset of a winter storm on February 12. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition.
The inspectors walked down the intake structure to ensure system availability. The inspectors verified that operator actions defined in Dominions adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
==1R04 Equipment Alignment
==
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Unit 2
SW System while the A SW pump was OOS for maintenance on February 25 Unit 3
Turbine Driven Auxiliary Feedwater (TDAFW) pump while Station Blackout (SBO)diesel was OOS on January 8
Train B SW system while the A SW pump was OOS for maintenance on March 25
The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TS, work orders, condition reports (CR), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Dominion staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On January 28 and 29, the inspectors performed a complete system walkdown of accessible portions of the Unit 3 A charging system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CR and work orders to ensure Dominion appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
==1R05 Fire Protection
==
.1 Resident Inspector Quarterly Walkdowns
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Dominion controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for OOS, degraded or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 2
Diesel Generator Room A, Fire Area A-15 on March 14
Unit 3
Fire Area AB-1, Auxiliary Building on January 7
Fire Area ESF-8, North Motor Driven Auxiliary Feed Pump Cubicle on March 6
Fire Area ESF-9, South Motor Driven Auxiliary Feed Pump Cubicle on March 6
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed an announced fire drill conducted on January 16, on the Unit 3 East Switchgear room. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Dominion personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:
Proper wearing of turnout gear and self-contained breathing apparatus (SCBA)
Proper use and layout of fire hoses
Employment of appropriate fire-fighting techniques
Sufficient fire-fighting equipment brought to the scene
Effectiveness of command and control
Search for victims and propagation of the fire into other plant areas
Smoke removal operations
Utilization of pre-planned strategies
Adherence to the pre-planned drill scenario
Drill objectives met The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with Dominions fire-fighting strategies.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed a Unit 2 licensed operator simulator emergency drill on February 18, which included a failure of a reactor coolant pump that lead to a reactor trip followed by a loss of offsite power for a sustained period of time. The inspectors also observed Unit 3 licensed operator training on March 6, which included immediate action response to a series of individual events including the failure of pressure transmitter PT-505, an uncontrolled rod withdrawal, a turbine runback, an abnormal steam generator (SG) water level transient, the inadvertent opening of a pressurizer power operated relief valve, a SG atmospheric relief valve, and a pressurizer spray valve, a main steam line break, the loss of vital instrument AC [alternating current] buses 1, 2 and 3, and the loss of safety bus 34C. The inspectors evaluated operator performance during the simulated events and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisors. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift managers and the TS action statements entered by the shift technical advisors. Additionally, the inspectors assessed the ability of the crews and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed full flow testing of the Unit 3 TDAFW pump on January 26.
This test is typically performed in Mode 3 and was designated as an Infrequently Conducted or Complex Evolution (ICCE), subject to the provisions described in OP-AA-106, Infrequently Conducted or Complex Evolutions, when performed in Mode 1. On February 1, the inspectors observed the Unit 2 reactor startup which is also an ICCE.
The inspectors observed pre-job briefs and focus briefs to verify control requirements of the ICCE were met. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or components (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that Dominion was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Dominion staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Dominion staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Unit 2
Vital Switchgear Emergency Cooling on March 14
Unit 3
TDAFW Pump on February 17
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Dominion performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Dominion personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Dominion performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Unit 2
Orange risk for emergent work to jumper out a cell of 201B battery on February 26
High risk for Control Element Assembly Position Display System replacement project on March 11
Yellow risk for RSST Load Tap Changer Position Indicator Replacement project testing on March 19
Unit 3
Emergent risk for testing TDAFW pump while SBO OOS on January 10
High risk for total spent fuel pool cooling outage relief valve testing on January 13
Yellow Risk for failure of the SBO diesel when the B EDG was OOS for repairs on March 5
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Unit 2
OD000558, Lower 4160V switchgear room cooler incorrect tube material on February 14
OD000580, Deformation of the A EDG Heat Exchanger Expansion Joints on March 31
Unit 3
OD000571, TDAFW Pump Tripped During Performance of SP 3622.3 on January 23 OD000577, TDAFW Pump Operability Following Full Flow Surveillance on February 5 ETE-MP-2014-1002, Revision 0, TDAFW Pump Steam Supply Lines, Condensate Accumulation Between 3MSS*AOV31A/B/D and 3MSS*MOV17A/B/D, on March 5 OD000571, Revision 1, TDAFW Pump Tripped During Performance of SP 3622.3 on March 17 CR 542534, A SW Pump Motor Operating Outside of Manufacturer Design on March 31
The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Dominions evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Dominion. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
Introduction.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for the failure to properly evaluate test results outside of the acceptance criteria for the A SW pump. When the A SW pump did not meet its acceptance criteria, Dominion did not remove the pump from service or perform an adequate evaluation until questioned by the inspectors.
Description.
On February 23, Dominion performed post-maintenance testing on the A SW pump and the pump did not meet its acceptance criteria. The acceptance criteria included the requirement for running amps to be less than or equal to 84.1 amps and the results at the three testing positions were 85, 82, and 85 amps. The 84.1 amp value is the nameplate current value listed on the motor. Operations consulted the engineering department for assistance in disposition of the results and engineering concurred that the acceptance criteria could be changed to 85 amps and the A SW pump returned to an operable state. Engineering concluded that exceeding the motor nameplate current by 0.9 amps would not result in any significant short term motor degradation. Based on engineerings assessment, operations changed the acceptance criteria to 85 amps and declared the A SW pump functional.
The inspectors questioned the basis of this assertion, because the service factor of the A SW pump is 1.0, which would imply that even a small increase in amperage could have adverse consequences to the motor. Dominion generated a CR with the inspectors concerns (CR541081) and upon further investigation found that they had not considered whether the motor will start/accelerate as designed during a degraded bus voltage consideration or what impact there would be on the bus if the motor is running and the station encounters a degraded bus voltage condition. Dominion operators placed the pump in a pull to lock condition and entered Technical Requirements Manual 3.7.4 for having one SW pump non-functional.
Analysis.
The inspectors determined that Dominions failure to properly evaluate test results outside of the acceptance criteria for the A SW pump in accordance with the requirements of 10 CFR 50, Appendix B, Criterion XI, to assure that test requirements have been satisfied was a performance deficiency that was within Dominions ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, without proper evaluation of the test results, Dominion returned a component to service that was later determined to be non-functional. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event, and did not represent an actual loss of function of a non-TS train of equipment designated as high safety significant.
This finding has a cross-cutting aspect in the area of Human Performance, Design Margins, in that Dominion did not operate and maintain the pump within design margins, where margins are carefully guarded and changed only through a systematic and rigorous process. Specifically, Dominion did not perform a thorough evaluation as required to maintain the functionality of safety-related equipment under all conditions.
[H.6]
Enforcement.
10 CFR 50, Appendix B, Criterion XI, Test Control, states, in part, that test results shall be documented and evaluated to assure that test requirements have been satisfied. Contrary to the above, from February 23 to March 19, Dominion did not properly evaluate test results outside of the acceptance criteria for the A SW pump.
Dominions immediate corrective actions included entering the issue into their CAP as CR542534 and placing the A SW pump in pull to lock until the condition could be evaluated and full functionality restored. Because this violation was of very low safety significance (Green), and Dominion entered this issue into their CAP, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy.
(NCV 05000423/2014002-01, Failure to Evaluate Test Results Outside of Acceptance Criteria for A Service Water Pump)
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
Unit 2
TCC-MP-2013-040, Remove Failed RPS Tcold Input M2TE-112CB from Service, Revision 1, on January 6
TCC-MP-2014-008, Jumper out cell 27 of battery DB2-201B and De-energize DC
[Direct Current] Emergency Lights at Panel D021 on February 27
Unit 3
CR539463 and associated 10 CFR 50.59 applicability review for OD000577 compensatory actions on February 20
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
Unit 2
B EDG governor replacement on January 29
A low pressure safety injection pump breaker preventative maintenance and drain valve replacement on February 18
A SW pump strainer maintenance on March 10
Removal of flow limiter plate on 2-SW-8.1A, SW flow control valve to A Reactor Building Closed Loop Cooling Water Heat Exchanger on March 31
Unit 3
Repairs to the SBO diesel power supply on January 13
Repairs to a failed weld the TDAFW Pump steam supply bypass line by 3MSS*V877 on January 23
Repairs to the TDAFW pump on January 25
Repairs to the control room chillers (3HVK*CHL1A/B) on February 12
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Dominion procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Unit 2
SP 2610BO-002, TDAFW and Recirculation Check Valve In-service test (IST),
Revision 000-06, on February 5
SP 2602A, Reactor Coolant Leakage, Revision 006-03, (RCS Leakage) on February 21
Unit 3
SP 3622.3, TDAFW Pump Operational Test (IST) on January 16
SP 3646A, A EDG Operability Test on January 21
SP 3622.9, Auxiliary Feedwater Pump 3FWA*P2 Full Flow test in MODE 1 (ICCE) on January 26
SP 3680.1, General Trending Procedure (for RCS Leakage), Revision 005-04, on March 18
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine Unit 2 Dominion emergency drill on February 18 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Dominion staff in order to evaluate Dominions critique and to verify whether the Dominion staff was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public and Occupational Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
During March 10 - 13, 2014, the inspectors reviewed Dominions performance in assessing the radiological hazards and exposure control in the workplace.
The inspectors used the requirements in 10 CFR 20 and guidance in Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas for Nuclear Plants, TS, and the Dominion procedures that are required by TS as criteria for determining compliance.
a. Inspection Scope
Radiological Hazard Assessment
The inspectors determined if there have been changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether Dominion assessed the potential impact of these changes.
The inspectors reviewed the last two radiological surveys from the Unit 3 Auxiliary Building 4 elevation, the Unit 3 Auxiliary Building 43 elevation, and the Unit 2 Solid Radioactive Waste area. The inspectors evaluated whether the thoroughness and frequency of the surveys were appropriate.
The inspectors conducted walkdowns and independent radiation measurements in the facility, including radioactive waste processing, storage, and handling areas to evaluate material and radiological conditions.
Instructions to Workers
The inspectors selected five containers of non-exempt licensed radioactive materials.
The inspectors assessed whether the containers were labeled and controlled in accordance with 10 CFR 20 requirements.
The inspectors reviewed two occurrences where a workers electronic personal dosimeter malfunctioned or alarmed. The inspectors evaluated whether workers responded appropriately. The inspectors assessed whether the issue was included in their CAP and whether compensatory dose evaluations were conducted as appropriate.
Contamination and Radioactive Material Control The inspectors observed one location where Dominion monitors potentially contaminated material leaving the radiological control area and inspected the methods used for control, survey, and release of these materials from this area. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors assessed whether the radiation monitoring instrumentation used for equipment release and personnel contamination surveys had appropriate sensitivity for the type(s) of radiation present.
The inspectors reviewed Dominions criteria for the survey and release of potentially contaminated material. The inspectors evaluated whether there was sufficient alarm response procedural guidance.
The inspectors reviewed Dominions procedures and records to verify that the radiation detection instrumentation was used at appropriate detection sensitivity. The inspectors selected three sealed sources from the Dominion inventory records and verified whether the sources were accounted for and were tested for loose surface contamination.
The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with 10 CFR 20 requirements.
Radiological Hazards Control and Work Coverage The inspectors evaluated ambient radiological conditions and performed independent radiation measurements during walkdowns of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, radiation work permits, and associated worker briefings.
The inspectors examined Dominions physical and programmatic controls for highly activated or contaminated materials stored within spent fuel and other storage pools.
The inspectors assessed whether appropriate controls were in place to preclude inadvertent removal of these materials from the pool.
The inspectors examined the posting and physical controls for selected high radiation areas (HRA), locked HRAs, and very high radiation areas (VHRAs) to verify conformance with the occupational performance indicator.
Risk-Significant HRA and VHRA Controls The inspectors discussed with the Radiation Protection Manager the controls and procedures for high-risk HRAs and VHRAs. The inspectors assessed any changes to relevant procedures.
The inspectors discussed with first-line health physics supervisors the controls in place for special areas that have the potential to become VHRAs during certain plant operations.
Radiation Worker Performance The inspectors reviewed 17 radiological problem reports since the last inspection that attributed the cause of the event to human performance errors. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by Dominion to resolve the reported problems.
Radiation Protection Technician Proficiency The inspectors reviewed six radiological problem reports since the last inspection that attributed the cause of the event to radiation protection technician error. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by Dominion to resolve the reported problems.
Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by Dominion at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by Dominion that involves radiation monitoring and exposure controls. The inspectors assessed Dominions process for applying operating experience to their plant.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
During March 10 - 13, 2014, the inspectors verified in-plant airborne concentrations are being controlled consistent with as low as reasonably achievable (ALARA) principles, and that the use of respiratory protection devices on-site does not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, RG 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, TS, and the Dominions procedures that are required by TS as criteria for determining compliance.
a. Inspection Scope
Inspection Planning
The inspectors reviewed the UFSAR for Millstone Units 2 and 3 to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. This review included instruments used to identify changing airborne radiological conditions. The review included an overview of the respiratory protection program and a description of the types of devices used. The inspectors reviewed the UFSARs, TS, and emergency planning documents to identify the location and quantity of respiratory protection devices stored for emergency use.
The inspectors reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including SCBA, as well as procedures for air quality maintenance.
Engineering Controls The inspectors reviewed Dominions use of permanent and temporary ventilation to determine whether Dominion uses ventilation systems as part of its engineering controls to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems to reduce dose and assessed whether the systems are used, to the extent practicable, during high-risk activities The inspectors selected two installed ventilation systems used to mitigate the potential for airborne radioactivity. The inspectors evaluated whether the ventilation system operating parameters were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne radioactivity area.
The inspectors selected two temporary ventilation system setups used to support work in contaminated areas. The inspectors assessed whether the use of these systems was consistent with Dominions procedural guidance and the principles of ALARA.
The inspectors reviewed airborne monitoring protocols by selecting two installed systems used to monitor and warn of changing airborne concentrations in the plant. The inspectors evaluated whether the alarms and set-points were adequate.
The inspectors assessed whether Dominion had established threshold criteria for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.
Use of Respiratory Protection Devices The inspectors reviewed records of air testing for supplied-air devices and SCBA bottles to assess whether the air used in these devices meets or exceeds Grade D quality. The inspectors reviewed plant breathing air supply systems to determine whether they meet the minimum pressure and airflow requirements for the devices in use.
The inspectors selected five individuals qualified to use respiratory protection devices, and verified whether they were deemed qualified to use the devices by successfully passing an annual medical examination, respirator fit-test, and relevant respiratory protection training.
The inspectors selected three individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device.
Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence.
The inspectors chose ten respiratory protection devices staged and ready for use in the plant. The inspectors assessed the physical condition of the device components and reviewed records of equipment inspection for each type of equipment. The inspectors selected several of the devices and reviewed records of maintenance on the vital components. The inspectors verified that onsite personnel assigned to repair respiratory protection equipment have received vendor-provided training.
SCBA for Emergency Use The inspectors reviewed the status and surveillance records of selected SCBAs staged in-plant for use during emergencies. The inspectors reviewed Dominions capability for refilling and transporting SCBA air bottles to and from the control rooms and the operations support center during emergency conditions.
The inspectors selected four individuals on control room shift crews and from designated departments currently assigned emergency duties to assess whether control room operators and other emergency response and RP personnel were trained and qualified in the use of SCBA. The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task.
The inspectors determined whether appropriate mask sizes and types are available for use. The inspectors determined whether on-shift operators had any facial hair that would interfere with the sealing of the mask to the face and whether vision correction mask inserts were available, as appropriate.
The inspectors reviewed the past two years of maintenance records for three SCBA units to assess whether any maintenance and repairs on any self-contained breathing apparatuses were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. For those self-contained breathing apparatuses that were ready for use, the inspectors verified that the required, periodic air cylinder hydrostatic testing was documented and up to date.
Problem Identification and Resolution The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by Dominion at an appropriate threshold and were properly addressed for resolution in Dominions CAP. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by Dominion.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate
a. Inspection Scope
The inspectors reviewed Dominions submittal for the RCS specific activity and RCS leak rate performance indicators for both Unit 2 and Unit 3 for the period of January 1, 2013 through December 31, 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the performance indicator.
Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Dominion entered issues into their CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP.
b. Findings
No findings were identified.
.2 Annual Sample:
Safety-Related Circuit Cards Repaired with Non-Safety Related Parts
a. Inspection Scope
The inspectors performed an in-depth review of Dominion's evaluations and corrective actions associated with CR520432 and Apparent Cause Evaluation 019518, for non-safety related (NSR) parts installed in safety-related Westinghouse 7300 series circuit cards. The affected circuit cards performed analog signal processing for inputs into the Solid State Protection System for reactor protection system trip functions and engineered safety feature actuation functions. Specifically, Dominion's technical staff identified that NSR parts had been installed in Millstone Unit 3 cards during card repair and refurbishment performed at Dominion's North Anna Power Station (NAPS) Module Repair Facility.
The inspectors assessed Dominion's problem identification threshold, problem analysis, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Dominion's corrective actions to determine whether Dominion was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Dominion's CAP and 10 CFR 50, Appendix B. The inspectors interviewed engineering and maintenance personnel to assess the effectiveness of the implemented corrective actions, the reasonableness of the planned corrective actions, and to evaluate the extent of any on-going problems.
In addition, the inspectors reviewed ETE-MP-2013-1198, Dominion's Use-As-Is Disposition, the Millstone module repair process, commercial grade dedication process, NAPS Module Repair Facility test procedures, and selected circuit card test results.
b. Findings and Observations
No findings were identified.
The Dominion technical staff identified weaknesses in Dominion's NAPS Module Repair Facility, regarding administrative controls and oversight of safety-related circuit card repairs and the use of NSR parts without the use of a commercial grade dedication process. Dominion had a corrective action in place to suspend using the NAPS Module Repair Facility for repair of Millstone 7300 series circuit cards until adequate administrative controls and procurement requirements could be established. In addition, Dominion supply chain management placed all of the affected spare 7300 cards in restricted stock (e.g., quality assurance hold), pending final resolution. Dominion evaluated the affected installed cards and determined they were acceptable for safety-related use without any additional rework or testing, and without performing any commercial grade dedication evaluations of the NSR parts.
Dominion's Use-As-Is evaluation identified 75 cards which had been repaired and/or refurbished at the NAPS Module Repair Facility over a 9-year period (2005 to 2013).
Dominion stated that the 7300 system had about 600 cards installed. Based on a review of warehouse inventory records, the inspectors determined that about 50 of the 75 repaired cards were currently installed in Millstone Unit 3. The inspectors independently reviewed 7300 system maintenance rule functional failure evaluations from 2003 to present, and identified 2 to 6 card failures per year. Based on the total population of 7300 cards and the number of recorded failures, the inspectors determined that the overall failure rate was low (i.e., 0.6 percent average failure rate per year).
The inspectors concluded that Dominion's Apparent Cause Evaluation and Use-As-Is Disposition were, in part, narrowly focused because they did not identify or evaluate:
number of installed cards which had been repaired with NSR parts
length of time that the affected cards had been in-service
performance history of the installed affected cards
process instrument channels potentially affected
commercial grade dedication requirements for the NSR parts
Specifically, Dominion had not tracked, trended, or reviewed the performance of the installed cards that had been repaired with NSR parts. Based on interviews, the inspectors determined that Dominion assumed none of the repaired cards had failed, because the overall failure rate of all 7300 cards was believed to be very, very low.
Contrary to Dominion's assumed failure rate for cards with NSR parts, the inspectors identified two instances of repaired cards which had been returned to NAPS for additional repairs after an in-service period of a few years. Therefore, the inspectors concluded that Dominion's assessments were based, in part, on an unverified assumption regarding the failure rate of cards repaired at NAPS because the performance history (e.g., failure rate) of the installed affected cards was not fully understood.
In addition, Dominion had assumed that commercial grade dedication evaluations were not necessary because the repaired cards had satisfactory test results (i.e., NAPS post-repair card testing and subsequent Millstone surveillance testing) and had been installed at Dominion with no known/recognized in-service failures. Therefore, the Dominion technical staff had concluded it was not necessary to
- (1) identify or evaluate the critical characteristics of the installed NSR parts, or
- (2) to determine whether there were any applicable component-level conditioning requirements, such as component-specific burn-in or selection testing, to eliminate unsuitable commercial parts (e.g., components with higher drift, lower tolerance, or higher infant mortality rates).
Therefore, the inspectors concluded that Dominion's determination to not assess commercial grade dedication requirements was also based, in part, on an unverified assumption regarding the failure rate of cards repaired at NAPS because the performance history (e.g., failure rate) of the installed affected cards was not fully understood.
The inspectors determined these weaknesses were minor issues because the number of installed affected cards was less than 10 percent of the total card population and the total card population had an acceptably low failure rate. Therefore, the inspectors concluded that the Dominion technical staff's overall response to this issue was commensurate with the safety significance and the actions taken or planned appeared reasonable to resolve the identified issue.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Dominion made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Dominions follow-up actions related to the events to assure that Dominion implemented appropriate corrective actions commensurate with their safety significance.
Unit 2
TS required plant shutdown on January 31 due to inoperable group 1 proportional heaters with B EDG OOS for maintenance on January 31
Unit 3
Notification of Enforcement Discretion (NOED) for repairs to the TDAFW Pump on January 26
b. Findings
No findings were identified.
Introduction.
The NRC identified an unresolved item (URI) for Dominions request for enforcement discretion from TS 3.7.1.2(a) limiting condition of operation (LCO) action statement (C) on January 26, 2014, in accordance with IMC 0410, Notices of Enforcement Discretion. Following an overspeed trip of the Unit 3 TDAFW pump during a scheduled surveillance test, Dominions efforts to complete troubleshooting, repairs and retesting could not be completed in time to comply with TS 3.7.1.2(a) action (C),which allowed up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to complete repairs before a plant shutdown was required.
Dominion requested additional time to complete the repairs without having to shutdown Unit 3, and the NRC granted a NOED that extended the allowable outage time for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Discussion. On January 23, 2014, the Unit 3 TDAFW pump failed a required surveillance test. During the starting sequence, the pump tripped on overspeed due to mechanical binding in the turbine governor linkage. Dominion entered TS LCO 3.7.1.2(a) action (C) which provided up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to repair the failed pump before requiring Unit 3 to be shutdown to Mode 3. Troubleshooting efforts revealed that the mechanical linkage between the governor and the turbine control valve (3MSS*MCV5)was binding due to a degraded cam follower bearing and a mechanical link that had been installed incorrectly. Although repairs had been completed, it became apparent that the required post-maintenance tests, including a full flow test at full power, could not be completed prior to the expiration of the LCO on January 26, 2014. Dominion requested enforcement discretion from compliance with TS 3.7.1.2 for a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The NRC reviewed the request in accordance with IMC 0410, NOED, and granted a one-time 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> extension to required action (C) of TS LCO 3.7.1.2(a).
Dominion completed the post-maintenance testing and restored the TDAFW pump to an operable status within the additional time granted.
The NOED specified a list of prerequisites and compensatory actions to mitigate risk that were required to be verified and completed prior to the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> extension becoming effective. Closure of this URI will require review and verification of Dominions satisfactory completion of the specified requirements in the NOED in coordination with the Special Inspection Team that is inspecting Dominions performance during this event. (URI 05000423/2014002-02, NOED Granted by NRC for TDAFW Pump Repairs on January 26, 2014)
4OA5 Other Activities
The table below provides a cross-reference from the 2013 and earlier findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014 will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.
Finding Old Cross-Cutting Aspect
New Cross-Cutting Aspect
H.14 05000423/2013004 H.2(a)
H.14
4OA6 Meetings, Including Exit
On April 22, 2014, the inspectors presented the inspection results to Mr. Stephen E. Scace, Site Vice President, and other members of the Millstone staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
S. Scace
Site Vice President
M. Adams
Plant Manager
L. Armstrong
Director, Nuclear Station Safety & Licensing
G. Auria
Nuclear Chemistry Supervisor
D. Bajumpaa
Consulting Engineer
J. Barile
Nuclear Engineer III
B. Bartron
Supervisor, Licensing
P. Baumann
Manager, Nuclear Protection Services
J. Bergin
Supervisor Nuclear Operations Support
T. Brigham
Nuclear Maintenance Supervisor
R. Castillo
Emergency Preparedness Specialist I, Communications Evaluator
W. Chestnut
Supervisor, Nuclear Shift Operations Unit 2
F. Cietek
Nuclear Engineer, PRA
T. Cleary
Licensing Engineer
G. Closius
Licensing Engineer
J. Cote
Senior Instructor
L. Crone
Supervisor, Nuclear Chemistry
J. Curling
Manager, Protection Services
M. Finnegan
Supervisor, Health Physics, ISFSI
W. Forrest
Senior Instructor
W. Gorman
Supervisor, Instrumentation & Control
J. Grogan
Assistant Operations Manager
C. Janus
Maintenance Rule Coordinator
L. Kelly
Supervisor Procurement Engineering Group
J. Laine
Manager, Radiation Protection/Chemistry
J. Langan
Manager, Nuclear Oversight
G. Marshall
Manager, Outage and Planning
M. Nappi
Shift Supervisor, Health Physics
M. OConner
Nuclear Specialist
S. OHearn
Nuclear Engineer III
J. Palmer
Manager, Training
F. Perry
Supervisor, Exposure Control and Instruments
J. Rein
Emergency Preparedness Specialist IV, Lead Controller
J. Rigatti
Manager, Nuclear Site Engineering
M. Sanders
Emergency Preparedness Specialist IV, Evaluator
J. Semancik
Director, Nuclear Engineering
D. Smith
Manager, Emergency Preparedness
S. Smith
Manager, Nuclear Operations
J. Stoddard
Supervisor, Nuclear Shift Operations Unit 3
S. Turowski
Supervisor, Health Physics Technical Services
C. Vournazos
IT Specialist, Meteorological Data
M. Wynn
Supervisor, Radiological Analysis
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
Failure to Evaluate Test Results
Outside of Acceptance Criteria
For A Service Water Pump
(Section IR15)
Opened
Pump Repairs on January 26, 2014
(Section 4OA3)