Text

Integrated Inspection Report 05000336/2019003 and 05000423/2019003
	ML19312A324
Person / Time
Site:	Millstone
Issue date:	11/06/2019
From:	Daniel Schroeder; Reactor Projects Branch 2
To:	Stoddard D; Dominion Energy
	Schroeder D
References
	IR 2019003
	Download: ML19312A324 (20)
	v • d • e

November 6, 2019

SUBJECT:

MILLSTONE POWER STATION, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000336/2019003 AND 05000423/2019003

Dear Mr. Stoddard:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station, Units 2 and 3. On October 8, 2019, the NRC inspectors discussed the results of this inspection with John Daugherty, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

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

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

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Millstone. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects

Docket Nos. 05000336 and 05000423 License Nos. DPR-65 and NPF-49

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000336 and 05000423

License Numbers:

DPR-65 and NPF-49

Report Numbers:

05000336/2019003 and 05000423/2019003

Enterprise Identifier: I-2019-003-0048

Licensee:

Dominion Energy Nuclear Connecticut, Inc.

Facility:

Millstone Power Station, Units 2 and 3

Location:

P. O. Box 128

Waterford, CT 06385

Inspection Dates:

July 1, 2019 to September 30, 2019

Inspectors:

E. Allen, Resident Inspector

J. Ambrosini, Sr. Emergency Preparedness Inspector

J. Brand, Reactor Inspector

J. DeBoer, Reactor Inspector

J. Fuller, Senior Resident Inspector

B. Haagensen, Senior Resident Inspector

C. Highley, Resident Inspector

L. McKown, Senior Resident Inspector

J. Rady, Emergency Preparedness Inspector

A. Siwy, Resident Inspector

S. Wilson, Senior Health Physicist

Approved By:

Daniel L. Schroeder, Chief

Reactor Projects Branch 2

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Millstone Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to establish a preventive maintenance schedule for the Unit 3 emergency diesel generator governor drive components Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000423/2019003-01 Open/Closed None (NPP)71111.15 A finding of very low safety significance (Green) and associated non-cited violation (NCV) of Millstone Power Station Unit 3 Technical Specification 6.8.1.a, Procedures and Programs, was self-revealed on July 9, 2019, when the 'A' emergency diesel generator (EDG)automatically stopped during a scheduled operability run. The EDG automatically shut down when the governor drive components seized due to a lack of lubrication. The licensee failed to establish procedures covering the activities referenced in Regulatory Guide 1.33, Revision 2, Appendix A, Section 9 for the preventive maintenance inspection of the governor drive components.

Additional Tracking Items

None.

PLANT STATUS

Both Units 2 and 3 began the inspection period at rated thermal power (RTP). On July 25, 2019, Unit 2 commenced a planned power reduction to 68 percent RTP to repair a minor steam leak on the feedwater heater system. Unit 2 returned to full RTP on July 26, 2019, and operated at or near full power for the remainder of the cycle.

Unit 3 operated at or near RTP for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04Q - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 2 'B' emergency diesel generator air start system on September 30, 2019

(2) Unit 3 train 'B' auxiliary feed water equipment alignment on August 14, 2019

(3) Unit 3 train 'B' service water equipment alignment on August 20, 2019

71111.04S - Equipment Alignment

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 vital 125 volt direct current (DC) electrical bus 201A on August 28, 2019.

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (6 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 2 480 volt B61 motor control center (fire area A-13) on July 9, 2019

(2) Unit 2 cable vault (fire area A-24) on July 29, 2019

(3) Unit 2 charging pump room (fire zone A-6A) on August 1, 2019

(4) Unit 3 fuel pool cooling pumps and coolers (fire area FB-2) with focus on fire penetration seals on July 2, 2019

(5) Unit 3 north cable tunnel (fire area SB-2) with penetration seal inoperable and continuous fire watch on July 9, 2019

(6) Unit 3 north emergency generator enclosure (fire area EG-3, zone A) on July 16, 2019

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 2 flood zone A-24, cable vault (elevation 25'6") on August 21, 2019

===71111.07T - Heat Sink Performance

Triennial Review (IP Section 02.02)===

Main article: IP 71111.07

The inspectors evaluated heat exchanger/sink performance on the following:

(1) Unit 2 DC switchgear cooling, section 02.02.b, heat exchanger, cooled by service water

(2) Unit 2 'A' EDG cooling, section 02.02.b, heat exchanger, cooled by service water

(3) Unit 3 'A', safety injection pump cooler, section 02.02.b, heat exchanger, cooled by service water

(4) Units 2 and 3 ultimate heat sink, section 02.02d, specifically sections 02.02d 5(a), (b),

(c),

(d) and 02.02d 6(a), (b), (c), (d), (f), and

(g) were completed.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors observed and evaluated licensed operator performance in the Unit 2 control room during OP-2204 Load Changes, Revision 043, which required a reduction of reactor power to 68 percent RTP in support of the repair of a cracked feedwater heater pipe. The inspectors observed the conduct of operations which included three-way communications, senior leadership interaction with the crew, shift manager and unit supervisor management of the crew's conduct, and observation of several alarm response procedures on July 25, 2019.

(2) The inspectors observed and evaluated licensed operator performance in the Unit 3 control room during SP 3643.2 Turbine Overspeed Protection System Test, Revision 013. The test involved a reduction of reactor power to approximately 95 percent RTP and cycling the high pressure turbine control valves, stop valves, and low pressure turbine combined intermediate stop and intercept valves. The inspectors observed the conduct of operations which included three-way communications, senior leadership interaction with the crew, shift manager and unit supervisor management of the crew's conduct, observation of response to several unexpected annunciators, and prioritization of personnel resources on August 9, 2019.

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

(1) The inspectors observed and evaluated licensed operator performance on the Unit 2 simulator during a loss of reactor building component cooling water, complete loss of feed water flow, reactor scram, and feeding of steam generators from the condensate pumps. Additionally, the inspectors observed classification of events for unusual event and alert. Instructor interaction with the crew and three-way communication was also observed on September 3, 2019.

(2) The inspectors observed and evaluated licensed operator performance in the Unit 3 simulator during Licensed Operator Requalification Program Cycle 19-5. The licensed operator requalification training included four evaluated scenarios in the Unit 3 simulator. The inspectors observed license operator performance, the ability of the licensee to administer the evaluation, the post-scenario critique, and follow up of the critical task to isolate reactor coolant pump seals within established time limits on September 17, 2019.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 2 maintenance rule functional failure evaluation for a fuel oil leak on the 'A' EDG that occurred on March 1, 2019 and was documented in CA7531599

(2) Unit 2 fire protection and deluge system (system 2341) on July 31, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 2 elevated risk due to emergent tube leak in the 'C' reactor building component cooling water heat exchanger on August 20, 2019

(2) Unit 2 elevated risk during planned work activities (engineered safeguards actuation signal testing, automatic auxiliary feedwater initiation logic testing, and a 'B' EDG operability test) on September 9, 2019

(3) Unit 3 elevated risk due to emergent failure of Unit 3 'A' EDG on July 9 and 10, 2019

(4) Units 2 and 3 elevated risk due to planned high risk switch-yard work on the 15G-2T-8 breaker from August 13 to August 16, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 'B' atmospheric dump valve intermittently opening approximately 5 percent and closing on September 20, 2019 (CR 1131471)

(2) Unit 3 leakage from 3RSS*MOV23D ('D' containment recirculation pump suction isolation valve) documented in CR 1118124

(3) Unit 3 'A' EDG failure to run (CR1126559 and CR1126657) on July 9, 2019

(4) Unit 3 digital rod position indication operability review (CR 1127184 and CR

===1123841) on July 31, 2019

(5) Unit 3 nonconservative technical specification value for station battery connection resistance value (CR 1129409) on August 22, 2019

71111.18 - Plant Modifications

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

=

Main article: IP 11238

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 3 digital rod position indication for rod H-12 temporary modification to card to jumper out coil #20 on July 25, 2019

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance tests:

(1) Unit 2 'C' charging pump replacement of oil lip seals on plungers and repack of charging pump outlet isolation valve (M22-CH-336) on August 3, 2019 (WO

===53203221297 and 53203164218)

(2) Unit 2 'C' reactor building component cooling water tube leak repair on August 21, 2019

(3) Unit 2 replacement of PY-4224-1, the current to pneumatic converter for 'B' atmospheric dump valve (2-MS-190B), on September 22, 2019

(4) Unit 3 'A' EDG after repair to mechanical governor and governor drive box on July 14 and 17, 2019

(5) Unit 3 clean lubricate and adjust reactor plant ventilation (HVR) air operated damper 33 'B' on August 15, 2019

(6) Unit 3 engineered safety features building ventilation (HVQ) air conditioning unit 2 'B',

following the heat exchanger inspection on August 19, 2019

(7) Unit 3 degraded filter capacitor replacement associated with the auxiliary feedwater control valve 3FWA*HV36C controller/positioner on September 26, 2019 (WO 53203255131)

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22

(1) Unit 3 'B' EDG fast start and run on July 23, 2019

(2) Unit 3 SP 3646A.8 "Containment Spray Actuation S931 Relay K645, Slave Relay" on August 6, 2019

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04)===

Main article: IP 53203

(1) The inspectors evaluated Dominion's maintenance and testing of the Millstone alert and notification system on August 5-8, 2019, for the period of August 2017 through July 2019.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of Dominion's Emergency Preparedness Organization on August 5-8, 2019.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes onsite on August 5-8, 2019.

EP-AA-101, 10CFR50.54(q) Change Evaluation, Revision 8

MP-19-04S, C OP 200.5, Oil, Hazardous Material, Hazardous Waste, and Mixed Contingency Plan, Revision 8

MP-19-05S, Millstone Power Station Emergency Preparedness Plan, Revision 60

MP-19-06S, Millstone Procedure Updates from Changes to EPA-400 Guidance

MP-19-07S, Unit 2 EAL Technical Basis

MP-19-08S, Unit 3 EAL Technical Basis

This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program on August 5-9, 2019, for the period of August 2017 through July 2019.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Unit 2 emergency planning drill on July 9,

RADIATION SAFETY

71124.05 - Radiation Monitoring Instrumentation

Walk Downs and Observations (IP Section 02.01) (1 Sample)

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) The inspectors reviewed the following:

Portable Survey Instruments

Eberline RO-20

MGP AMP-100

MGP Telepole

RADEYE GX

Far West Technology REM 500

Source Check Demonstration

Thermo ED

Canberra HPGe

Eberline RO-20

MGP Telepole

Area Radiation Monitors and Continuous Air Monitors

U2 Radwaste Exhaust Monitor 8999

U2 Aerated Liquid Radwaste Monitor RM-9116

U2 Refuel Area Radiation Monitor RM-7891

U2 Stack Monitor RM-8132A and 8132B

U3 Waste Neutralizer Sump Discharge Rad Monitor 3CNDRE07

U3 Containment Radiation Monitor RMS*RE0-5A

Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

U2 RCA Exit TEM

U2 RCA Exit PCM

U3 RCA Exit TEM

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

Whole Body Counters - Fastscan and Accuscan onsite

PM-12 at Dosimetry office

Failure to Meet Calibration or Source Check Acceptance Criteria

RO-20,

MGP Telepole

RADEYE GX

71124.07 - Radiological Environmental Monitoring Program

Site Inspection (IP Section 02.01) (1 Sample)

The inspectors evaluated the radiological environmental monitoring program implementation.

(1) The inspectors reviewed the following:

Walkdowns, Calibrations, and Maintenance Record Review

NAP Parking Lot North air monitoring station and TLD location

Weather Shack air monitoring station and TLD location

Bird Sanctuary air monitoring station,TLD and Soil sample location

Environmental Sample Collections and Preparation Observation

REMP DIscharge location continuous liquid sampler

NAP Parking Lot North vegetation sample location. Vegetation sample demonstrated/observed

Niantic Shoals bottom sediment sample observed

Niantic Bay lobster and fish samples observed

Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement

Increased tritium activity in discharge sample location 32 (CR1124525)

Goshen Fire Department air sampling station vegetation encroachment (CR1085353)

Sampling Program for the Potential of Licensed Material Entering Groundwater

Underground piping testing and maintenance program

Storage tank monitoring

Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (2 Samples)

(1) The inspectors verified that the licensee is continuing to implement the voluntary Nuclear Energy Institute/ Industry Ground Water Protection Initiative.

(2) The inspectors observed groundwater sampling from monitoring well S1-MW-1.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (IP Section 02.12)===

Main article: IP 71151

(1) January 1, 2018 - June 30, 2019

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) January 1, 2018 - June 30, 2019

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) Unit 2 (April 1, 2019 - June 30, 2019)