Text

IR 05000336-05-002, 05000423-05-002; on 01/01/2005 - 03/31/2005; for Millstone Power Station, Unit 2 and Unit 3; Adverse Weather Protection, Heat Sink Performance, Post-Maintenance Testing, Temporary Plant Modifications, Other Activities
	ML051310282
Person / Time
Site:	Millstone
Issue date:	05/11/2005
From:	Paul Krohn; NRC/RGN-I/DRP/PB6
To:	Christian D; Dominion Resources Services
	Krohn P, RI/DRP/PB6/610-337-5120
References
	IR-05-002
	Download: ML051310282 (60)
	v • d • e

May 11, 2005

Mr. David A. Christian

Sr. Vice President and Chief Nuclear Officer

Dominion Resources

5000 Dominion Boulevard

Glenn Allen, VA 23060-6711

SUBJECT: MILLSTONE POWER STATION UNIT 2 AND UNIT 3 - NRC INTEGRATED

INSPECTION REPORT 05000336/2005002 AND 05000423/2005002

Dear Mr. Christian:

On March 31, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed inspections at

your Millstone Power Station Unit 2 & Unit 3. The enclosed integrated inspection report

documents the inspection findings, which were discussed on April 21, 2005, with

Mr. J. Alan Price and other members of your staff.

The inspections 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 four NRC-identified and two self-revealing findings of very low safety

significance (Green). Five of these findings were determined to involve violations of NRC

requirements. However, because of their very low safety significance and because they have

been entered into your corrective action program, the NRC is treating these issues as Non-cited

Violations (NCVs), in accordance with Section VI.A.1 of the NRCs Enforcement Policy.

If you contest any NCV in this report, you should provide a response within 30 days of the date

of these inspection reports, 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 the

Millstone Power Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosures, 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 NRCs

document 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/

Paul G. Krohn, Chief

Projects Branch 6

Division of Reactor Projects

Mr. D. A. Christian 2

Docket Nos.: 50-336, 50-423

License Nos.: DPR-65, NPF-49

Enclosure: Inspection Report 05000336/2005002 and 05000423/2005002

w/Attachment: Supplemental Information

cc w/encl:

J. A. Price, Site Vice President, Millstone Station

C. L. Funderburk, Director, Nuclear Licensing and Operations Support

D. W. Dodson, Supervisor, Station Licensing

L. M. Cuoco, Senior Counsel

C. Brinkman, Manager, Washington Nuclear Operations

J. Roy, Director of Operations, Massachusetts Municipal Wholesale Electric Company

First Selectmen, Town of Waterford

R. Rubinstein, Waterford Library

J. Markowicz, Co-Chair, NEAC

E. Woollacott, Co-Chair, NEAC

E. Wilds, Director, State of Connecticut SLO Designee

J. Buckingham, Department of Public Utility Control

G. Proios, Suffolk County Planning Department

R. Shadis, New England Coalition Staff

G. Winslow, Citizens Regulatory Commission (CRC)

S. Comley, We The People

D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN

J. M. Block, Attorney, CAN

Mr. D. A. Christian 3

Distribution w/encl (VIA E-MAIL):

S. Collins, RA

J. Wiggins, DRA

S. Lee, RI OEDO

D. Roberts, NRR

V. Nerses, NRR

G. Wunder, NRR

S. Schneider, Senior Resident Inspector

E. Bartels, Resident OA

P. Krohn, RI

S. Barber, RI

T. Madden, OCA

ROPreports@nrc.gov

Region I Docket Room (with concurrences)

SISP Review Complete: ___PGK______ (Reviewers Initials)

DOCUMENT NAME: E:\Filenet\ML051310282.wpd

After declaring this document An Official Agency Record it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure

"E" = Copy with attachment/enclosure "N" = No copy

OFFIC RI/DRP RI/DRP RI/DRP

E

NAME SSchneider/PGK SBarber/PGK PKrohn/PGK

for for

DATE 05/06/05 05/11/05 05/11/05 05/ /05

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 05000336, 05000423

License No.: DPR-65, NPF-49

Report No.: 05000336/2005002 and 05000423/2005002

Licensee: Dominion Nuclear Connecticut, Inc.

Facility: Millstone Power Station, Unit 2 and Unit 3

Location: P. O. Box 128

Waterford, CT 06385

Dates: January 1, 2005 - March 31, 2005

Inspectors: S. M. Schneider, Senior Resident Inspector, Division of Reactor Projects

(DRP)

S. R. Kennedy, Resident Inspector, DRP

K. A. Mangan, Resident Inspector, DRP

K. M. Jenison, Senior Reactor Inspector, DRP

M. X. Davis, Reactor Inspector, Division of Reactor Safety (DRS)

K. S. Kolaczyk, Senior Resident Inspector, Ginna, DRP

J. A. Krafty, Reactor Inspector, DRS

T. A. Moslak, Health Physicist, DRS

J. G. Schoppy, Senior Reactor Inspector, DRS

Accompanied by: M. L. Heath, Nuclear Safety Professional

Approved by: Paul G. Krohn, Chief

Projects Branch 6

Division of Reactor Projects

Enclosure

CONTENTS

SUMMARY OF FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

REACTOR SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1R01 Adverse Weather Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1R04 Equipment Alignment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

1R05 Fire Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

1R06 Flood Protection Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

1R07 Heat Sink Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1R11 Licensed Operator Requalification Program . . . . . . . . . . . . . . . . . . . . . . . . . . 10

1R12 Maintenance Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

1R13 Maintenance Risk Assessments and Emergent Work Evaluation . . . . . . . . . . 11

1R14 Personnel Performance During Non-Routine Plant Evolutions and Events . . . 12

1R15 Operability Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

1R16 Operator Work-Arounds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

1R19 Post-Maintenance Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

1R22 Surveillance Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

1R23 Temporary Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

1EP4 Emergency Action Level and Emergency Plan (E-PLAN) Changes . . . . . . . . 23

1EP6 Drill Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

RADIATION SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2OS1 Access Controls to Radiologically Significant Areas . . . . . . . . . . . . . . . . . . . . 24

2OS2 ALARA Planning and Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

OTHER ACTIVITIES [OA] . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4OA2 Identification and Resolution of Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4OA3 Event Followup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

4OA4 Cross Cutting Aspects of Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

4OA5 Other Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

4OA6 Meetings, Including Exit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

SUPPLEMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

KEY POINTS OF CONTACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . A-2

LIST OF DOCUMENTS REVIEWED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-3

LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-16

ii Enclosure

SUMMARY OF FINDINGS

IR 05000336/2005002, 05000423/2005002; 01/01/2005 - 03/31/2005; Millstone Power Station,

Unit 2 and Unit 3; Adverse Weather Protection, Heat Sink Performance, Post-Maintenance

Testing, Temporary Plant Modifications, Other Activities.

The report covered a 3-month period of inspection by resident inspectors and announced

inspections by regional inspectors. Five (Green) NCVs and one (Green) finding were identified.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using

Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings

for which the 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 3,

dated July 2000.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Initiating Events

Unit 2

! Green. The inspectors identified a self-revealing finding for the failure to

adequately address issues related to the operation of an outdoor temporary air

compressor and associated air dryer skid during cold weather conditions. On

November 11, 2004, Dominion had identified that additional freeze protection

actions were required to ensure the availability of the compressor during cold

weather. Subsequently, the inspectors identified two occasions where actions

taken to ensure availability of the compressor were not adequate. On December

17, 2004, the inspectors identified that a heat trace for the system dryer was

deenergized. On February 1, 2005, the temporary air compressor failed causing

the B instrument air compressor to start. Following the air transient, Dominion

conducted an investigation and concluded that the cause of the temporary air

compressor failure was freezing of the pre-filter on the air dryer skid. Dominion

replaced the compressor, installed a tent around the air-dryer towers, and placed

a heating unit inside the tent.

The finding was more than minor because it affected the equipment performance

attribute of the Initiating Events cornerstone objective of limiting the likelihood of

events that upset plant stability at power. The performance issue associated

with this finding was the failure to take adequate actions to ensure that adverse

weather conditions did not affect the availability of the temporary instrument air

system. The risk of this finding was determined to be of very low safety

significance (Green), because, although the temporary air compressor system

became unavailable, the standby instrument air compressor restored instrument

air system pressure. The instrument air system pressure stabilized and

recovered such that the instrument air header pressure did not cause a reactor

trip. This finding was related to the cross-cutting area of Problem Identification

iii Enclosure

and Resolution in that Dominion failed to take adequate corrective actions to

prevent the air dryer skid from freezing.. (Section 1R01.2)

Cornerstone: Mitigating Systems

Unit 2

! Green. The inspectors identified a self-revealing non-cited violation of Technical

Specification 6.8.1a, Procedures and Programs, for the failure to adequately

implement the procedure for installing temporary ventilation through the East 480

volt vital switchgear room when normal cooling was disabled for maintenance.

The procedure establishes the required flow path in the switchgear room when

compensatory cooling measures were required. On January 12, 2005, operators

failed to perform the procedure step that opens doors to provide for an exhaust

path to allow warm air to leave the switchgear room.

The finding was greater than minor because the failure to install the

compensatory cooling system, per the procedure, caused the air flow through

the East 480 volt switchgear room to be below the minimum required to support

cooling of the 480 volt system for initiating events (transients), mitigating

systems, and barrier integrity systems. The finding was associated with the

equipment performance attribute of the initiating events and mitigating systems

cornerstones, and the containment structures, systems, and components and

barrier performance attribute of the barrier integrity cornerstone. Since more

than one cornerstone was affected, a Reactor Safety Significance Determination

Process Phase 2 analysis was performed. The analysis resulted in a finding of

very low safety significance (Green) because the improper installation of the

compensatory measures did not result in an actual loss of the supported 480 volt

AC system or electro hydraulic control functions. This finding was related to the

cross-cutting area of Human Performance in that both Engineering and

Operations personnel failed to correctly implement the procedure for

compensatory cooling. (Section 1R23)

Unit 3

! Green. The inspector identified a non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, for Dominions failure to take

prompt and appropriate corrective actions to address a condition adverse to

quality. Specifically, Dominion did not promptly evaluate and correct a degraded

condition associated with the divider plate for all three reactor plant component

cooling water (RPCCW) heat exchangers (HXs).

The inspector determined that this issue was more than minor because it was

associated with the equipment performance attribute of the mitigating systems

cornerstone, and it potentially affected the objective to ensure the availability and

reliability of the RPCCW HXs. The finding was of very low safety significance

(Green), because the finding was a qualification deficiency confirmed not to

result in loss of a function. The issue was similarly of very low risk in the

Initiating Events cornerstone because the finding did not increase the likelihood

iv Enclosure

of a reactor trip or a loss of service water (SW) event. The finding was

associated with the cross-cutting area of problem identification and resolution

(PI&R) in that Dominions inadequate evaluation and untimely corrective actions

for a degraded condition potentially affected the RPCCW HXs. (Section 1R07.2)

! Green. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B,

Criterion XI, Test Control, for the failure to adequately implement

post-maintenance test (PMT) procedures for restoring the A emergency diesel

generator (EDG) to service following maintenance of the neutral breaker. On

March 1, 2005, Dominion conducted maintenance and doble testing of the A

EDG neutral breaker. The Maintenance Department turned the breaker over to

Operations for final post-maintenance testing and restoration. After racking in

the breaker, Operations noted that the red light on the front of the EDG neutral

breaker panel did not light as expected. Contrary to the PMT acceptance

criteria, Operations assessed that the PMT was satisfactorily completed and

exited the EDG technical specification. The oncoming shift investigated and

determined the red light was not lit because there was a problem with the neutral

breaker trip circuit. Operations declared the EDG inoperable and re-entered the

EDG technical specification.

This issue was more than minor because it was associated with the reliability of

the A EDG. The inspectors determined that the finding was of very low safety

significance (Green) because it did not involve a design or qualification

deficiency, represent an actual loss of safety function of the A EDG, or involve

seismic, flooding, or severe weather initiating events. This finding was related to

the cross-cutting area of Human Performance in that Dominion personnel signed

the PMT as satisfactory and restored the EDG neutral breaker to an operable

status although the acceptance criteria was not met. (Section 1R19.1)

! Green. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B,

Criterion XVI, Corrective Action, which requires, in part, that measures be

established to assure that conditions adverse to quality are promptly identified

and corrected. From May to October 2004, Dominion failed to properly assess

and correct a degraded A Residual Heat Removal (RHR) system during an

extent of condition examination for air found in the RHR discharge piping.

Specifically, after discovering a significant amount of air in the A RHR piping

system in May 2004, Dominion vented the system but did not adequately

evaluate whether the corrective actions were effective in removing air from the

RHR heat-exchanger tubing. As a result, Dominion did not evaluate the effect of

the remaining air on the RHR and high pressure injection systems. Dominion

subsequently instituted compensatory measures to vent the suction piping after

every RHR pump run and performed a special procedure to flush the air out of

the heat exchanger.

This finding was more than minor because it affected the equipment

performance attribute and the availability, reliability, and capability objective of

the Mitigating system cornerstone. Specifically, Dominions extent of condition

evaluation did not determine that a significant volume of air remained in the A

RHR heat exchanger tubing even though air was found in several other sections

v Enclosure

of piping subsequent to their initial corrective actions. This air could have

caused the A RHR pump to become inoperable if enough air had migrated to

the suction of the RHR pump and could have adversely affected high pressure

injection pumps if air had migrated to crossover piping. This finding was

determined to be of very low safety significance (Green) since an actual loss of

RHR would not have occurred with the amount of air identified and no air

pockets were subsequently identified in crossover piping to the charging and

high pressure injection systems; the finding did not involve a design or

qualification deficiency; or involve seismic, flooding, or severe weather initiating

events. This finding was related to the cross-cutting area of Problem

Identification and Resolution in that Dominion failed to perform an adequate

extent-of-condition review to fully evaluate the effect of air that had been

introduced into the A RHR system. (Section 4OA5.2)

Cornerstone: Barrier Integrity

Unit 3

! Green. The inspectors identified a non-cited violation of Technical Specification

(TS) 3.6.4.2, Electric Hydrogen Recombiners, which requires that two

independent hydrogen recombiner systems remain Operable. On February 22,

2005, Dominion performed maintenance on the A train hydrogen monitor. On

February 23, 2005, Dominion identified that pipe fittings for the A train

hydrogen monitor had been disassembled, however, a post-maintenance test

had not been conducted to prove operability of the system. Dominion performed

a leak test on February 24, 2005, however, the test failed. Dominions

investigation determined that the leakage was from a mechanical joint that had

been worked on December 2, 2004, but that this joint had not been disturbed

during the February 22, 2005, maintenance. Additionally, Dominion determined

that following the work in December 2004 no post-maintenance leak test had

been performed to verify system operability. The inspectors identified that the

leakage would have resulted in the shutdown of the A hydrogen recombiner,

under post-accident conditions. Therefore, the train would not have been

considered operable from December 2, 2004 to March 1, 2005. Following the

identification of the failed joint, Dominion repaired the joint, leak tested the

system, and restored the A train hydrogen monitor to service.

This issue was more than minor because it was associated with the Barrier

Integrity cornerstone attribute of configuration control in that it affected

containment boundary preservation and maintaining containment design

parameters. The failure to specify adequate PMT resulted in loose mechanical

joints in the system not being detected which would have allowed an open

pathway to the atmosphere from containment during post accident conditions.

Additionally, Dominion postulated that the post accident leakage from these

joints would have caused a radiation monitor alarm which would have isolated

the A hydrogen recombiner. This violation was evaluated using an IMC 0609,

Appendix H, Containment Integrity Significance Determination Process, Phase

2 analysis, and was determined to be of very low safety significance (Green).

Specifically, the leak was not of the magnitude to recycle the containment

vi Enclosure

atmosphere in a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, post event. This finding was related to the

cross-cutting issue of Human Performance in that Dominion failed to adequately

perform post-maintenance testing to ensure incorrect maintenance activities

were identified prior to returning the hydrogen monitor to service.

(Section 1R19.2)

B. Licensee-Identified Violations

None.

vii Enclosure

REPORT DETAILS

Summary of Plant Status

Unit 2 operated at or near 100 percent power for the duration of the inspection period.

Unit 3 operated at or near 100 percent power for the duration of the inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01 - Two Unit 2 Samples and One Unit 3 Sample)

1. Onset of Adverse Weather Site Inspection (One Unit 2 Sample and One Unit 3 Sample)

a. Inspection Scope

The inspectors performed a review of adverse weather preparations during the onset of

a winter snowstorm on January 22, 2005, to evaluate the sites readiness for the

expected weather conditions. The inspectors reviewed Dominions

preparations/protection for the adverse weather and its impact on the protection of

safety-related systems, structures and components. The inspectors verified that

operator actions, taken in response to the adverse weather, maintained readiness of

essential systems and that adequate operator and Site Emergency Response

Organization staffing was specified. Documents reviewed during the inspection are

listed in the Attachment.

b. Findings

No findings of significance were identified.

2. System Inspection (One Unit 2 Sample)

a. Inspection Scope

The inspectors reviewed the Unit 2 temporary instrument air system for extreme

weather condition preparation. The inspection was intended to ensure that the indicated

equipment, its instrumentation, and its supporting structures were configured in

accordance with Dominion procedures and that adequate controls were in place to

ensure functionality of the system. The inspectors reviewed licensee procedures and

condition reports and walked down the system. Documents reviewed during the

inspection are listed in the Attachment.

Enclosure

2

b. Findings

Introduction. A Green self-revealing finding was identified for the failure to implement

adequate actions to ensure the availability of a temporary instrument air compressor

during cold weather conditions. This resulted in the failure of the compressor while it

was required for operation.

Description. The inspectors reviewed Dominions installation of a diesel-driven outdoor

instrument air compressor (IAC) and associated air dryer skid used to provide air to the

Unit 2 instrument air system. Unit 2 was designed with three IACs, however, a fourth

temporary IAC was installed due to reliability issues associated with these compressors

and the retirement of the C IAC. On January 30, 2005, the A instrument air

compressor failed to load and was declared inoperable. The temporary instrument air

compressor was placed in service as the lead compressor and the B instrument air

compressor was placed in standby. On February 1, 2005, the temporary air compressor

failed. The B instrument air compressor started on a low instrument air header

pressure and restored the instrument air system pressure. Dominion determined that

the prefilter for the outdoor air drying unit had frozen which had prevented the air

compressor from providing air to the instrument air system.

The inspectors review of licensee actions related to the temporary IAC found that

Dominion had several opportunities to take measures to prevent cold weather from

affecting the temporary air compressor. On November 11, 2004, an operator

questioned what actions were required for freeze protection of the temporary air

compressor and documented his concerns in CR-04-10102. Dominion addressed the

concern by applying heat wrap to the air dryer and energizing the engine heater block.

On December 17, 2004, the inspectors walked down the system and questioned the

adequacy of the installation and the freeze protection methods since, for example, the

dryer heat trace did not appear to be operating. Subsequently, Dominions investigation

identified the heat trace power supply breaker had tripped. Dominion addressed the

specific concerns but did not perform an evaluation as to the adequacy of the entire

system to operate during cold weather conditions. As a result, on February 1, 2005, the

temporary air compressor failed when the prefilter for the outdoor air drying unit froze.

The inspectors discussed the adequacy of the November 11, 2004, corrective actions

with Operations. Following the second failure of the system, Dominion replaced the

IAC, enclosed the dryer skid in a tent, and installed a heater inside the tent.

Analysis. The performance deficiency associated with this issue was that Dominion

failed to adequately address issues related to freeze protection of the outdoor temporary

air compressor, which subsequently resulted in a failure of the system when the prefilter

on the air dryer skid froze. Traditional enforcement does not apply to this issue because

there were no violations of NRC requirements, no actual safety consequences, and no

impacts on the NRCs ability to perform its regulatory function. The finding was more

than minor because it affected the equipment performance attribute of the Initiating

Events cornerstone objective of limiting the likelihood of events that upset plant stability

at power. Specifically, the failure to take measures to prevent the air compressor from

freezing increased the likelihood of a loss of instrument air event and manual scram. If

Enclosure

3

the B instrument air compressor had failed, the instrument air system pressure would

have fallen below the 80 psig limit, requiring operators to manually scram the reactor.

The inspectors determined that the finding was of very low safety significance (Green)

through performance of a Phase 1 SDP in accordance with IMC 0609, Appendix A,

"Significance Determination of Reactor Inspection Findings for At-Power Situations,"

dated December 1, 2004. Specifically, the finding did not contribute to the likelihood of

a primary or secondary system loss of coolant accident initiator, contribute to both the

likelihood of a reactor trip and the likelihood that mitigating equipment would not be

available, or increase the likelihood of a fire or internal/external flood. The instrument air

system remained operable during the duration of the transient. Therefore, the risk of

this finding was determined to be of very low safety significance (Green).

This finding was related to the cross-cutting issue of problem identification and

resolution because Dominion failed to take adequate corrective actions to prevent the

air dryer skid from freezing.

Enforcement. There were no violations of NRC regulatory requirements since the

instrument air system is not safety-related. However, the instrument air system

functions have an impact on the overall plant risk, and the inspectors determined that

Dominion was ineffective in taking corrective actions to prevent failure of the temporary

air compressor. The issues relating to this inspection were documented by the

Dominion corrective action program under CR-05-00922. (FIN 05000336/2005002-01)

1R04 Equipment Alignment (71111.04)

1. Partial System Walkdowns (71111.04Q - Three Unit 2 Samples and Three Unit 3

Samples)

a. Inspection Scope

The inspectors performed six partial system walkdowns during this inspection period.

The inspectors reviewed the documents listed in the Attachment to determine the

correct system alignment. The inspectors conducted a walkdown of each system to

verify that the critical portions of selected systems were correctly aligned in accordance

with these procedures and to identify any discrepancies that may have had an effect on

operability. The inspectors verified that equipment alignment problems that could cause

initiating events, impact mitigating system availability or function, or affect barrier

functions, were identified and resolved. The following systems were reviewed based on

their risk significance for the given plant configuration:

Unit 2

Partial equipment alignment of the "B" train of the auxiliary feedwater (AFW)

system during maintenance on the "A" train of the AFW system,

January 25, 2005;

Enclosure

4

Partial equipment alignment of the A motor-driven auxiliary feedwater pump

(MDAFW) during maintenance and testing on the turbine-driven auxiliary

feedwater (TDAFW) pump, February 4, 2005; and

Partial equipment alignment of the TDAFW system during maintenance on the

"B" train of the AFW system, March 7, 2005.

Unit 3

Partial equipment alignment of the A and B motor driven auxiliary feedwater

trains while turbine driven AFW train was out for maintenance, March 9, 2005;

Partial equipment alignment of offsite electrical distribution system due to

Montville-Haddam Neck line out of service, March 10, 2005; and

Partial equipment alignment of auxiliary steam system during power supply

replacement, March 21, 2005.

b. Findings

No findings of significance were identified.

2. Complete System Walkdown. (71111.04S - One Unit 2 Sample and One Unit 3

Sample)

a. Inspection Scope

Unit 2

The inspectors completed a detailed review of the alignment and condition of the Unit 2

control room air conditioning (CRAC) system. The inspectors conducted a walkdown of

the system to verify that the critical portions, such as valve positions, switches, control

room heat loads and breakers, were in accordance with procedures and any

discrepancies that may have had an effect on operability were resolved.

The inspectors also conducted a review of outstanding maintenance work orders to

verify that the deficiencies did not significantly affect the CRAC system function. The

inspectors discussed system health with the system engineer and reviewed the

condition report database to verify that equipment alignment problems were being

identified and appropriately resolved. Documents reviewed during the inspection are

listed in the Attachment.

Unit 3

The inspectors completed a detailed review of the alignment and condition of the Unit 3

post accident control room ventilation envelope. The inspectors conducted a complete

control room verification and/or walkdown of critical system functions, alignments, valve

positions, switches, and breakers, to ensure correct alignment in accordance with

procedures and to determine if any identified conditions affected operability. The

inspectors also conducted a review of outstanding maintenance work orders to verify

Enclosure

5

that existing deficiencies did not significantly affect the system operability. The

inspectors reviewed control room ventilation system health documents and related

condition reports to verify that equipment alignment, temporary modifications, operator

workarounds and other problems were being identified and appropriately resolved.

Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

1. Quarterly Sample Review (71111.05Q - Six Unit 2 Samples and Six Unit 3 Samples)

a. Inspection Scope

The inspectors performed twelve walkdowns of fire protection areas during the

inspection period. 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

those 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 then compared the existing conditions of the

inspected fire protection areas to the fire protection program requirements to ensure all

program requirements were being met. Documents reviewed during the inspection are

listed in the Attachment. The fire protection areas reviewed included:

Unit 2

West Pipe Penetration, -5' Elevation (Fire Area A-8C);

West Electric Penetration, 14'6" Elevation (Fire Area A-8D);

Upper 4160 Volt Switchgear Room - Turbine Building, 31'-6" Elevation (Fire Area

T-7);

Lower 4160 Volt Switchgear Room - Turbine Building, 56'-6" Elevation (Fire Area

T-10);

A and B Motor Driven Auxiliary Feedwater Pump Cubicle - Turbine Building,

1'-6" Elevation (Fire Area T-3); and

Turbine Driven Auxiliary Feedwater Pump Cubicle - Turbine Building, 1'-6"

Elevation (Fire Area T-4).

Unit 3

Instrument Rack Room - Control Building, 47'-6" Elevation - (Fire Area CB-11,

Zones A and B);

North Floor Area - Auxiliary Building, 4'-6" Elevation - (Fire Area AB-1, Zone A);

South Floor Area - Auxiliary Building, 4'-6" Elevation - (Fire Area AB-1, Zone B);

Enclosure

6

East Floor Area, 4'-6" Elevation - (Fire Area ESF-4, Zone N/A);

Southeast Floor Area - Auxiliary Feed Pump Cubicle, 4'-6" & 24'-6" Elevation -

(Fire Area ESF-5, Zone N/A); and

South Air Conditioning Unit Cubicle- Engineered Safety Features Building, 36'-6"

Elevation - (Fire Area ESF-11, Zone N/A).

b. Findings

No findings of significance were identified.

2. Annual Fire Drill Observation (71111.05A - One Unit 3 Sample)

a. Inspection Scope

Unit 3

The inspectors observed personnel performance during a fire brigade drill on March 16,

2005, to evaluate the readiness of station personnel to prevent and fight fires. The drill

simulated a fire on the Turbine Deck in the Unit 3 Turbine Building. The inspectors

observed the fire brigade members using protective clothing, turnout gear, and

self-contained breathing apparatus and entering the fire area in a controlled manner.

The inspectors also observed the fire fighting equipment brought to the fire scene to

evaluate whether sufficient equipment was available to effectively control and extinguish

the simulated fire. The inspectors evaluated whether the permanent 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 communications

between fire brigade members. The inspectors verified that the pre-planned drill

scenario was followed and reviewed the post drill critique to ensure that the drill

objectives were satisfied and that any drill weaknesses were discussed.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures (71111.06)

Internal Flooding Inspection (One Unit 3 Sample)

a. Inspection Scope

The inspectors reviewed one sample of flood protection measures for equipment in the

safety related room listed below. This review was conducted to evaluate Dominions

protection of the enclosed safety-related systems from internal flooding conditions. The

inspectors performed a walkdown of the area and reviewed the Final Safety Analysis

Report, the internal flooding evaluation and related documents. The inspectors

compared the as-found equipment and conditions to ensure they remained consistent

with those indicated in the design basis documentation, flooding mitigation documents,

Enclosure

7

and risk analysis assumptions. Documents reviewed during the inspection are listed in

the Attachment.

Unit 3

B Residual Heat Removal (RHR) Cubicle.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance (71111.07 - One Unit 2 Sample and Five Unit 3 Samples)

1. Annual Heat Sink Performance (71111.07A - One Unit 2 Sample and One Unit 3

Sample)

a. Inspection Scope

The inspectors reviewed two samples of safety related heat exchanger testing to identify

any degraded performance or potential for common cause problems that could increase

plant risk. The inspectors reviewed the results of inspections performed in accordance

with Dominion procedures. The inspectors reviewed the inspection results against the

acceptance criteria contained within the procedure, and verified that all acceptance

criteria had been satisfied. The inspectors also reviewed the Final Safety Analysis

Report to ensure that heat exchanger inspection results were consistent with the design

basis. The inspectors verified that adverse conditions identified by Dominion were

appropriately entered into Dominion's corrective action program. Documents reviewed

during the inspection are listed in the Attachment.

Unit 2

A Reactor Building Closed Cooling Water System Heat Exchanger.

Unit 3

Engineered Safety Features Building Ventilation Heat Exchanger.

b. Findings

No findings of significance were identified.

2. Biennial Heat Sink Performance (71111.07B - Four Unit 3 Samples)

a. Inspection Scope

Based on a plant specific risk assessment, resident inspector input, and the last biennial

inspection, the inspector selected the B RPCCW, B containment recirculation spray

Enclosure

8

system (RSS), B emergency diesel generator jacket water (JW), and B EDG

intercooler HXs for this biennial review. Each of these HXs transfers its heat load

directly to the SW system. The SW system was designed to supply cooling water from

Long Island Sound (the ultimate heat sink) to various heat loads to ensure a continuous

flow of cooling water to systems and components necessary for plant safety both during

normal operation and under abnormal or accident conditions.

The inspector reviewed Dominions inspection, cleaning, chemical control, and

performance monitoring methods and frequency for the selected components to ensure

alignment with Dominions response to Generic Letter 89-13, Service Water System

Problems Affecting Safety-Related Equipment. The inspector compared surveillance

test and inspection data to the established acceptance criteria to verify that the results

were acceptable and that operation was consistent with design. The inspector walked

down the selected HXs, the sodium hypochlorite system, and the SW system to assess

the material condition of these systems and components. In addition, the inspector

walked down control room instrumentation panels, viewed several SW intake inspection

videos, reviewed work order history for the selected HXs, and discussed system health

with the respective system engineers.

The inspector also reviewed a sample of condition reports (CRs) related to the selected

HXs and the SW system to ensure that Dominion was appropriately identifying,

characterizing, and correcting problems related to these essential systems and

components. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

Introduction. The inspector identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, for Dominions failure to take prompt and

appropriate corrective actions to evaluate and correct a degraded condition associated

with the divider plate for all three RPCCW HXs.

Description. On May 20, 2003, engineering identified a bent divider plate in the B

RPCCW HX. The divider plate was deflected approximately 1/2 inch from centerline to

the outlet SW side. The divider plate separates the inlet SW flow from the outlet SW

flow and ensures that the incoming SW flow is routed to the tube side of the two-pass

RPCCW HXs. Engineering initiated CR-03-04924 that included actions to straighten the

divider plate, inspect the A and C RPCCW HXs, modify their HX inspection form to

include a divider plate inspection step, and to develop and implement a modification to

strengthen the divider plate.

On June 9, 2003, engineering found a deflected divider plate in the C RPCCW HX and

a deflected divider plate in the A RPCCW HX on June 25, 2003. Engineering

determined that high differential pressure (d/p) across the divider plates due to tube

plugging caused the plates to bend. In addition, Engineering reviewed the May 2003

operating experience (OE) information from D.C. Cook that discussed catastrophic

failure of a component cooling water HX divider plate due to repeated divider plate

deflections (OE16319). Based on the above information, engineering proposed a

Enclosure

9

modification to stiffen the RPCCW HX divider plates through their Engineering Level of

Effort (LOE) process. Maintenance used mechanical means to straightened the divider

plate in each HX; however, engineering found the divider plate deflected again on

subsequent HX inspections (A HX on May 23, 2004; B HX on September 9, 2004

and December 1, 2004).

The inspector noted that engineering had treated each of the six instances of deflected

divider plates discovered since May 2003 in a broke-fixed manner without evaluating

the degraded condition for continued operability of the RPCCW HXs. Given the

degraded condition of the divider plates deflecting over time and potentially causing

fatigue failure of the divider plate welds, and the industry OE documenting the failure of

a similar HX under operating conditions, the inspector determined that engineering

should have promptly evaluated and documented their basis for a reasonable

expectation of operability.

Engineering designated the divider plate stiffening modification as a low priority item.

The inspector noted that Engineering extended the due date for the associated LOE

review seven times since August 2003, and in March 2004 deferred the activity out to

2005. Presently, the Engineering portion of the modification package is scheduled to be

completed by September 2005. The inspector determined that the timeliness of

Dominions corrective actions were not commensurate with the potential safety

significance of the issue. The inspector found no evidence that Dominion evaluated the

effects on operability or the significance of the degraded condition when extending the

corrective actions well beyond their first opportunity to correct.

The inspector also identified that Dominion failed to implement their corrective action

assignment (CR-03-04924/03003369-05) to revise the SW cooled HX inspection form,

although they closed out this action as complete in September 2003 (CR-05-01233).

On February 10, 2005, Engineering initiated CR-05-01281 to evaluate additional

information concerning the RPCCW HX divider plates. Subsequently, on February 25,

Engineering initiated CR-05-01767 to evaluate an elevated RPCCW HX DP (23 psid as

compared to a 20 psid design) observed by the RPCCW system engineer during two

SW pump operation during SW surveillance testing. Engineering performed an

operability determination (MP3-004-05) and concluded that the RPCCW HXs were

operable but not fully qualified. Engineerings determination was based on recent HX

inspections, a structural evaluation of the divider plate (conservatively assuming 35

psid), and a flow and heat transfer analysis (including surveillance testing trends).

Engineering also documented their evaluation of OE16319 in CR-05-01767.

Engineering determined that the RPCCW HXs would be able to remove the required

heat loads during accident events.

Analysis. The inspector considered Dominions failure to take timely and adequate

corrective actions for the degraded RPCCW HX divider plates a performance deficiency

since Dominions corrective action program should correct conditions adverse to quality

in a timely manner. Given the repeated nature of the adverse condition (deflected

divider plates) and industry OE relative to an in-service failure, the deficiency was

Enclosure

10

reasonably within Dominions ability to appropriately evaluate and correct prior to

February 2005.

The inspector determined that the issue was more than minor because it was

associated with the Mitigating Systems cornerstone attribute for equipment performance

and potentially affected the objective to ensure the availability and reliability of the

RPCCW HXs. The RPCCW system mitigates initiating events as it supplies cooling to

the residual heat removal pumps and HXs in the shutdown cooling mode. The

degraded RPCCW HX divider plates, if left uncorrected, would result in a more

significant safety concern should a divider plate fail catastrophically while in service.

The inspector determined the issue to be very low safety significance (Green) using the

Phase 1 SDP worksheet for at power situations for the Mitigating Systems cornerstone.

This was because the finding was a qualification deficiency confirmed not to result in

loss of function. The issue was similarly of very low risk in the Initiating Events

cornerstone because the finding did not increase the likelihood of a reactor trip or a loss

of SW event.

The finding was associated with the cross-cutting area of PI&R based on Dominions

inadequate evaluation and untimely corrective actions for this identified deficiency

potentially affecting the RPCCW HXs.

Enforcement. Code of Federal Regulations 10 CFR Part 50, Appendix B, Criterion

XVI, Corrective Action, requires, in part, that conditions adverse to quality are promptly

identified and corrected. Contrary to this requirement, Dominion failed to take prompt

and appropriate corrective actions to address a condition adverse to quality.

Specifically, since May 2003, Dominion failed to promptly evaluate and correct a

degraded condition associated with the divider plate for all three RPCCW HXs.

However, because of the very low safety significance and because the issue was

entered into Dominions corrective action program (CR-05-01281 & CR-05-01767), this

finding is being treated as a non-cited violation, consistent with Section VI.A of the

Enforcement Policy, issued May 1, 2000 (65FR25368). (NCV 05000423/2005002-02)

1R11 Licensed Operator Requalification Program (71111.11Q - Two Unit 2 Samples and One

Unit 3 Sample)

a. Inspection Scope

The inspectors observed two samples of Unit 2 licensed operator requalification training

on March 30, 2005, and March 31, 2005. The inspectors observed one sample of Unit 3

licensed operator requalification training on February 1, 2005. The inspectors verified

that the training evaluators adequately addressed that the applicable training objectives

had been achieved. Documents reviewed during the inspection are listed in the

Attachment.

b. Findings

No findings of significance were identified.

Enclosure

11

1R12 Maintenance Effectiveness (71111.12)

Routine Maintenance Effectiveness Inspection (71111.12Q - Two Unit 2 Samples and

Two Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed four samples of Dominion's evaluation of degraded conditions,

involving safety related structures, systems and/or components (SSC) for maintenance

effectiveness during this inspection period. The inspectors reviewed licensee

implementation of the Maintenance Rule (MR), 10 CFR 50.65, and verified that the

conditions associated with the referenced CRs were appropriately evaluated against

applicable MR functional failure criteria as found in licensee scoping documents and

procedures. The inspectors also discussed these issues with the system engineers and

maintenance rule coordinators to verify that they were appropriately tracked against

each system's performance criteria and that the systems were appropriately classified in

accordance with MR implementation guidance. Documents reviewed during the

inspection are listed in the Attachment. The following conditions were reviewed:

Unit 2

Failure of B51 Motor Control Center Air Conditioning System (CR-04-11119);

and

Facility 2 Control Room Air Conditioning failure (CR-05-00638).

Unit 3

Station Blackout Diesel Uninterruptible Power Supply Battery Failed Voltage

Testing (CR-05-00127); and

Engineered Safety Features Building Ventilation Filter Clogged Due to Snow

(CR-05-00617).

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13 - Four Unit 2

Samples and Six Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed ten samples of the adequacy of maintenance risk assessments

of emergent and planned activities on Unit 2 and Unit 3 during the inspection period.

The inspectors utilized the Equipment Out of Service quantitative risk assessment tool

to evaluate the risk of the plant configurations and compared the results to Dominion's

stated risk. The inspectors verified that Dominion entered appropriate risk categories

and implemented risk management actions as necessary. Documents reviewed during

Enclosure

12

the inspection are listed in the Attachment. The inspectors verified the conduct and

adequacy of scheduled maintenance risk assessments for plant conditions affected by

the following maintenance and testing activities:

Unit 2

Work schedule for the week of January 17, 2005, including maintenance and

testing on the containment sump/shutdown cooling heat exchanger valve;

Work schedule for the week of February 28, 2005, including maintenance on the

A circulating water bay;

Work schedule for the week of March 7, 2005, including maintenance and

testing on emergency safeguards actuation system, reserve station service

transfer, and sequencer; and

Work schedule for the week of March 14, 2005, including maintenance and

testing on the B high pressure safety injection pump.

Unit 3

Work schedule for the week of January 3, 2005, including maintenance and

testing on the A circulating water pump;

Emergent risk assessment of "A" EDG sequencer inoperability on January 21,

2005;

Work schedule for the week of January 31, 2005, including maintenance and

testing on the A circulating water bay outage, switchyard breaker, and C

service water strainer;

Work schedule for the week of February 28, 2005, including maintenance and

testing on the B EDG;

Work schedule for the week of March 21, 2005, including maintenance and

testing on the supplementary leak collection and release system, quench spray

system pump, and power operated relief valves relays; and

Work schedule of the week of March 28, 2005, including maintenance and

testing on A safety injection pump, A train ESF air conditioning, and A train

emergency diesel fuel oil pump

b. Findings

No findings of significance were identified.

1R14 Personnel Performance During Non-Routine Plant Evolutions and Events (71111.14 -

Three Unit 2 Samples and Two Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed five samples of events that demonstrated personnel

performance in coping with non-routine evolutions and transients on Unit 2 and Unit 3.

The inspectors observed operations in the control room and reviewed applicable

operating and alarm response procedures, technical specifications, plant process

Enclosure

13

computer indications, and control room shift logs to evaluate the adequacy of

Dominion's response to these events. The inspectors also verified the events were

entered into the corrective action program to resolve identified adverse conditions.

Documents reviewed during the inspection are listed in the Attachment.

Unit 2

On January 12, 2005, the inspectors observed Dominions actions following the

identification of a defective cable insulation on one of the two offsite power

supplies to Unit 2. During unrelated maintenance, Dominion observed a partial

phase to phase ground between the A and C phases of the backup offsite

power supply to Unit 2. This fault also prevented the station blackout diesel from

supplying Unit 2 loads. Dominion entered the appropriate Technical

Specification, de-energized the cable, and completed repairs. Additionally,

Dominion took appropriate actions to minimize risk to the plant while the power

supply was unavailable.

On January 14, 2005, Operations personnel responded to a fire in an electrical

panel in the Unit 2 turbine building. Dominion declared an Unusual Event since

the fire lasted greater than 15 minutes and was located in an area of concern for

safe shutdown (the Unit 2 turbine building). The resident inspectors responded

and Region I staffed the Incident Response Center. A special inspection team

was chartered to conduct an investigation and evaluation of this event which will

be documented in Inspection Report 05000336/2005009.

On January 22, 2005, Operations personnel notified the inspectors regarding

their actions taken in response to an impending snowstorm. See Unit 3

discussion for details.

Unit 3

On January 20, 2005, Operations personnel responded to the unexpected start

of the A auxiliary building filter fan and an A EDG sequencer alarm.

Operations bypassed the A EDG sequencer and entered Technical

Specification 3.3.2, Engineered Safety Features Actuation System

Instrumentation, which specifies a six hour shutdown action statement.

Instrumentation and Controls personnel commenced troubleshooting and

determined that the A EDG sequencer circuitry was not resetting an automatic

test signal. An operability determination was generated that determined the

function of the sequencer was not impacted. The EDG sequencer automatic

testing function was removed from service by placing the EDG sequencer

automatic tester switch in RESET and TS 3.3.2 was exited.

On January 22, 2005, Operations personnel notified the inspectors of an

impending snowstorm and of the actions they had taken in preparation for the

snowstorm. These actions included notifying Site Emergency Response

Organization members to ensure each position had staffing available (two people

Enclosure

14

deep) who lived between the I-95 bridges. This ensured their ability to respond

to the plant even if the bridges were closed. On January 23, 2005, Operations

personnel notified the inspectors that they had entered Technical Specification

3.0.3, Limiting Condition For Operation, due to snow loading which affected the

inlets of both trains of emergency safeguards features (ESF) building ventilation.

Maintenance personnel were called in, the filter elements were changed out, and

the ESF ventilation was restored in approximately one hour.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - Four Unit 2 Samples and Six Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed ten operability determinations associated with degraded or

non-conforming conditions to ensure that operability was justified and that mitigating

systems or those affecting barrier integrity remained available and no unrecognized

increase in risk had occurred. The inspectors also reviewed compensatory measures to

ensure that the compensatory measures were in place and were appropriately

controlled. The inspectors reviewed licensee performance to ensure all related TS and

Final Safety Analysis Report (FSAR) requirements were met. The inspectors reviewed

the following degraded or non-conforming conditions:

Unit 2

Failure of the Facility 2 Control Room Air Conditioning system (CR-05-00638);

Loss of Remote Shutdown Panel Steam Generator Pressure Indication

(CR-05-01336);

Failure of the Pressurizer Power Operated Relief Valve acoustic monitor and tail

pipe temperature indication (CR-05-00748); and

"B" Charging Pump/Train metallic noise (CR-05-02350).

Unit 3

A Service Water Header Brazed Joint Leak (MP3-002-05);

Non-Safety Related Valve Seat Material Used in a Safety Related Application

(CR-05-01213);

A Hydrogen Recombiner Leakage (CR-05-01689);

A Emergency Generator Loading Sequence Autotest Circuit Failed, Resulting

in Auto Start of 3HVR*FN6A (CR-05-00550)

Station Blackout Failed Battery Surveillance (CR-05-00127); and

Leakage Detection Systems Unidentified Leakage Sump Pump (CR-05-02751).

Enclosure

15

b. Findings

No findings of significance were identified.

1R16 Operator Work-Arounds (71111.16)

1. Selected Operator Work-arounds (One Unit 2 Sample)

a. Inspection Scope

The inspectors reviewed one risk significant operator work-around (OWA) for Unit 2

during the inspection period. The inspectors evaluated the condition to determine if

there was any effect on human reliability in responding to an initiating event or any

adverse effects on the function of mitigating systems. The work-around was also

reviewed to ensure compliance with licensee documents which administratively control

OWAs. Documents reviewed during the inspection are listed in the Attachment.

Inoperable Automatic Steam Dump Valve Pressure Control Function

b. Findings

No findings of significance were identified.

2. Cumulative Effects of Operator Work-Arounds (One Unit 2 Sample and One Unit 3

Sample)

a. Inspection Scope

The inspectors reviewed the current listing of active OWAs for Millstone Unit 2 and Unit

3. The review was conducted to verify that Dominion procedures and practices provided

the necessary guidance to plant personnel, that the cumulative effects of the known

OWAs were addressed, and that the overall impact on the affected systems was

assessed by Dominion. The inspectors independently assessed the cumulative impact

of known OWAs to determine if they adversely affected the ability of plant operators to

implement emergency procedures, respond to plant transients, or perform normal

functions within the expectations of the established Dominion risk models. In support of

this assessment, the inspectors reviewed various condition reports regarding OWAs and

verified that OWAs were being identified, tracked, and resolved in Dominion's corrective

action program.

b. Findings

No findings of significance were identified.

Enclosure

16

1R19 Post-Maintenance Testing (71111.19 - Five Unit 2 Samples and Six Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed eleven samples of PMTs during this inspection period. The

inspectors reviewed these activities to determine whether the PMT adequately

demonstrated that the safety-related function of the equipment was satisfied given the

scope of the work specified and that operability of the system was restored. In addition,

the inspectors evaluated the applicable test acceptance criteria to verify consistency

with the associated design and licensing bases, as well as Technical Specification

requirements. The inspectors also verified that 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

their post maintenance tests were evaluated:

Unit 2

"A" Train of the Auxiliary Feedwater system (M2-00-19686);

D Instrument Air compressor (DM2-00-0363-04);

Containment Radiation Monitor (RM-8123) (M2-04-06866);

UAC4 Transformer Replacement (M2-03-00711); and

"B" Charging Pump/Train Metallic Noise (M2-05-02151).

Unit 3

Auxiliary feed pump cubicle ventilation intake filter replacement (M3-05-010226);

A EDG Sequencer (M3-05-04081);

BYS*CHGR7 Battery Charger Leakage Test (M3-01-09552);

ACUS2A ESF Air Conditioning Maintenance (M3-04-15984);

A EDG Neutral Breaker Preventive Maintenance (M3-02-16737); and

Hydrogen Recombiner (M3-05-04144)

b. Findings

Unit 2

No findings of significance were identified.

Unit 3

1. A Emergency Diesel Generator Neutral Breaker

Introduction. The inspectors identified a green NCV of Appendix B, Criterion XI, Test

Control, for the failure to adequately implement PMT procedures for restoring the A

EDG to service following maintenance of the neutral breaker.

Enclosure

17

Description. On March 1, 2005, Dominion conducted maintenance and doble testing of

the A EDG neutral breaker. After Operations racked down the breaker, the

electricians removed the breaker from its cubicle. The Maintenance Department

conducted planned maintenance on the breaker and then performed doble testing.

After completing doble testing, the Maintenance Department returned the breaker to its

cubicle in the seismic position (racked out), and turned the breaker over to Operations

for final post-maintenance testing and restoration.

Operations racked in the breaker in accordance with OP 3370A, Electrical Breaker

Procedure. After the breaker was racked in, Operations noted that the red light on front

of the EDG neutral breaker panel did not light as expected. Operations confirmed that

the breaker closed electrically and assessed that the close and trip fuses were not

blown. Additionally, the plant equipment operator stated that the red flag properly

indicated the breaker was closed. Satisfied the breaker was closed, Operations

returned the EDG to operable status and exited the EDG technical specification. The

oncoming shift investigated and determined the red light was not lit because there was a

problem with the neutral breaker trip circuit. An auxiliary circuit contact did not make up

properly when the breaker was racked in. Operations declared the EDG inoperable and

re-entered the EDG technical specification.

The inspectors reviewed the work order and determined Operations did not adequately

implement the post-maintenance test procedure. The post-maintenance test directed by

the work order was to cycle the breaker in accordance with MP-20-WP-GDL40,

Attachment 4. Specifically, MP-20-WP-GDL40, paragraph 2.3.6, stated in part, Direct

performance of PMT as described in Work Order/PMT Plan, to include the following, as

appropriate: PMT results reviewed against the acceptance criteria. Attachment 4

stated that acceptance criteria for electrical breakers included verifying local/remote

indications function properly, and correctly indicate component position/status. Despite

this acceptance criteria, Dominion signed the PMT as satisfactory and restored the EDG

neutral breaker to an operable status although the acceptance criteria was not met.

Specifically, the neutral breaker trip circuitry indication did not indicate as expected.

This resulted in restoration of the A EDG with the neutral breaker trip circuitry

inoperable.

Additionally, the inspectors noted a deficiency in OP 3370A, Electrical Breaker

Procedure, which was used for racking and testing electrical breakers. Although

Operations used this procedure to implement the PMT requirements, the procedure

lacked steps to ensure that all indications were properly checked for the racking of

breakers.

Analysis. The performance deficiency was Dominions failure to adequately implement

testing procedures for restoring the A EDG to service following maintenance and doble

testing of the neutral breaker. Dominion returned the EDG to an operable status

although the position indication for the neutral breaker did not indicate in accordance

with the acceptance criteria. This resulted in restoration of the EDG with the neutral

breaker inoperable. This issue was more than minor because it was associated with the

reliability of the A EDG. On phase-to-ground faults initiating in the emergency system,

Enclosure

18

the generator neutral breaker trips first to attempt to isolate the fault while continuing to

supply vital loads powered from the emergency bus. Thus, during an event requiring

emergency diesel generator operation with the neutral breaker inoperable, a ground on

the emergency bus or diesel could cause the diesel to trip prematurely. The inspectors

determined that the finding was of very low safety significance (Green) through

performance of a Phase 1 SDP in accordance with IMC 0609, Appendix A, "Significance

Determination of Reactor Inspection Findings for At-Power Situations." Specifically, this

finding did not involve a design or qualification deficiency, represent an actual loss of

safety function of the A EDG, or involve seismic, flooding, or severe weather initiating

events.

Enforcement. Code of Federal Regulations 10 CFR Part 50, Appendix B, Criterion XI,

Test Control, states in part, A test program shall be established to assure that all

testing required to demonstrate that structures, systems, and components will perform

satisfactorily in service is identified and performed in accordance with written test

procedures which incorporate the requirements and acceptance limits contained in

applicable design documents. Contrary to this requirement, on March 1, 2005,

Dominion failed to implement testing procedures for returning the A EDG neutral

breaker to an operable status following completion of electrical breaker maintenance.

This violation has been determined to have a very low safety significance and is in

Dominion's corrective action program as CR-05-03569. Therefore, this violation is being

treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy

(NCV 05000423/2005002-03).

2. Hydrogen Recombiner

Introduction. A non-cited violation of TS 3.4.6.2, Electric Hydrogen Recombiners, was

identified for the failure to perform post maintenance tests of the hydrogen recombiner

following intrusive testing on the piping system which disturbed piping joints.

Subsequent testing found leakage from the system which would have affected

operability of the A hydrogen recombiner during a design basis event.

Description. On December 2, 2004, Dominion performed maintenance on the A

hydrogen recombiner which included disassembly and reassembly of mechanical joints.

Following the maintenance, the associated TSs were exited and the system was

returned to service without performing a post maintenance leak test. Subsequently, on

February 22, 2005, Dominion performed maintenance on the A hydrogen monitor.

Following the maintenance, the system was returned to service and the TS action

statement was exited without performing the required post-maintenance test. Dominion

then determined that pipe fittings for the A hydrogen monitor had been disassembled

and, therefore, a PMT was required to show the joints were reassembled correctly.

Since this test was required to assure operability of the system, Dominion declared the

hydrogen monitor inoperable and re-entered the associated TS. The A hydrogen

recombiner was also declared inoperable in order to support the test boundaries for the

hydrogen monitor PMT.

Enclosure

19

The inspectors observed that a leak tightness surveillance test was conducted to verify

the integrity of the disturbed joints for the hydrogen monitor. The test results found that

there was an approximately 11,000 standard cubic centimeter per minute (SCCM) leak

on the system. This exceeded the 2000 sccm limit established in the surveillance.

Dominion investigation found that the leak was not on a mechanical joint disturbed

during the February 22, 2005, maintenance. A review of previous maintenance activities

determined that work performed on December 2, 2004, disturbed the joint that had

failed and the leaking joints remained unidentified until a post-maintenance test was

conducted on February 23, 2005.

The inspectors determined that the leak would impact both the integrity of containment

and operability of the A hydrogen recombiner. When the hydrogen recombiner would

be placed in service following a design basis event, the air inside containment would

have had an open path to atmosphere through the hydrogen recombiner room and

ventilation train via the loose mechanical joints. As a result, radiation levels inside the

A hydrogen recombiner room would increase and cause the ventilation radiation

monitor to alarm which would shut down the hydrogen recombiner. Operators following

their alarm response procedure would then isolate the recombiner which would stop the

leak.

Analysis. The performance deficiency associated with this issue was that Dominion

failed to adequately perform post-maintenance testing to ensure incorrect maintenance

activities were identified prior to declaring the A hydrogen recombiner system

Operable, exiting TS, and returning the system to service. Traditional enforcement does

not apply to this issue because there were no actual safety consequences, impacts on

the NRCs ability to perform its regulatory function, or willful aspects to the violation.

This issue was more than minor because it is associated with the Barrier Integrity

cornerstone of configuration control for containment boundary preservation and

ensuring containment design parameters are maintained. The failure to specify

adequate PMT resulted in loose mechanical joints in the system not being detected

which would have allowed an open pathway to atmosphere from containment.

Additionally, Dominion postulated that the post accident leakage from these joints would

have caused a radiation monitor alarm which would have isolated the A hydrogen

recombiner during an event. This condition existed from December 2, 2004, through

March 1, 2005.

The inspectors performed a Phase 1 SDP in accordance with Inspection Manual

Chapter (IMC) 0609, Appendix A, "Significance Determination of Reactor Inspection

Findings for At-Power Situations" which required that an Appendix H, Containment

Integrity Significance Determination Process of IMC 0609 be used because there was a

direct path from containment to atmosphere. The Appendix H analysis for large dry and

sub-atmospheric containment types determined that, since the leak was of a small

enough magnitude (11,000 SCCM), the entire containment atmosphere would not leak

to the environment over a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. Therefore, the risk of this finding was

determined to be of very low safety significance (Green).

Enclosure

20

Enforcement. Technical Specification 3.6.4.2, Electric Hydrogen Recombiners,

requires that two independent hydrogen recombiner systems remain Operable.

Contrary to this, on December 2, 2004, Dominion exited the associated TS action

statement with an inoperable system. As a result, Dominion did not comply with the

required TS action statement which states restore the inoperable system to Operable

status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , an action

required on January 1, 2005. Dominion continued in this condition until March 1, 2005,

when the system was repaired, tested, and restored to an Operable status. This

violation has been determined to be of very low safety significance and was entered into

Dominion's corrective action program (CR-05-01713 and CR-05-03896). Therefore, this

violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC

Enforcement Policy. (NCV 05000423/2005002-04).

1R22 Surveillance Testing (71111.22 - Five Unit 2 Samples and Five Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed ten samples of surveillance activities to determine whether the

testing adequately demonstrated the equipments' operational readiness and its ability to

perform its intended safety-related function. The inspectors attended pre-job briefs,

verified that selected prerequisites and precautions were met and that the tests were

performed in accordance with the procedural steps. Additionally, the inspectors

evaluated the applicable test acceptance criteria to verify consistency with associated

design basis, licensing bases and Technical Specification requirements, and to ensure

that the applicable acceptance criteria were satisfied. The inspectors also verified that

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

B Low Pressure Safety Injection (LPSI) In-Service Test (IST) (SP-2604D);

B Containment Spray (CS) Pumps IST (SP-2606B);

Facility 2 Control Room Ventilation Filter Testing IST (SP-2609F);

"B" AFW Pump Testing IST (SP-2605F); and

AFW/Fire System Cross Connects 2-Fire-94A/B/C Testing (SP-2605R).

Unit 3

Steam Generator Water Level Channel Calibration Channel 3 (SP-3444A01);

Sweep of Train A RHR to Refueling Water Storage Tank (SP-3610A.3);

A Quench Spray Pump Operational Readiness Test (SP-3609.1);

B RPCCW Operational Test IST (SP-3630A.5); and

RHR A Pump Operational Readiness Test IST (SP-3610A.1).

b. Findings

Enclosure

21

No findings of significance were identified.

1R23 Temporary Plant Modifications (71111.23 - One Unit 2 Sample and One Unit 3 Sample)

a. Inspection Scope

The inspectors reviewed two samples of temporary modifications to verify that the

temporary modifications did not affect the safety function of important safety systems.

The inspectors reviewed the temporary modifications and their associated 10 CFR 50.59

screening against the FSAR and Technical Specifications to ensure the modifications

did not affect system operability or availability. Documents reviewed during the

inspection are listed in the Attachment.

Unit 2

Installation and operation of compensatory cooling to East 480 Volt Switchgear

(OP-2315D)

Unit 3

B Circulating Water Pump Proceduralized Temporary Modification (OP-3225A).

b. Findings

Unit 2

Introduction. A green self-revealing NCV of TS 6.8.1, Procedures and Programs, was

identified for the failure to correctly install temporary cooling to the East 480 volt

switchgear room. Dominion failed to perform all required steps in the procedure

resulting in insufficient cooling to the room.

Description. On January 12, 2005, Dominion installed temporary cooling to the East 480

volt switchgear room. The safety-related cooler in the East 480 volt switchgear room

was removed from service to perform preventive maintenance. Compensatory cooling

measures to the switchgear room were installed per Operating Procedure (OP) 2315D -

"Vital Electric Switchgear Room Cooling". The temporary cooling system consisted of

two Appendix R air blowers and a ventilation lineup which including positioning room

doors and securing fans external to the room. The procedure was completed and the

vital switchgear cooling system was removed from service. Subsequent to the

installation of the equipment, the system engineer walked down the compensatory

measures installation and found that door 203-31-008 was closed. This door was

required to be open per the procedure to provide a discharge path for the compensatory

fans. The engineer reported the discrepancy to the control room. The switchgear was

declared inoperable until the door was opened and the complete lineup verified.

Enclosure

22

The inspectors noted that prior to this failure Dominion had taken numerous corrective

actions to ensure proper implementation of the compensatory cooling. Non-cited

Violation 05000336/2003010-03 discussed a similar violation related to the installation of

this equipment and subsequent corrective actions. More recently, Dominion required

that the system engineer review the procedure with the Operating crew to ensure the

system was properly installed to address confusion with the use of the procedure. In

this case, the engineer discussed the procedure with the implementing operations crew

over the phone. Procedure step 4.9.9.c states: "Open the following doors: Door

203-31-007, 203-31-008, 105-36-112. As required, station security guards and fire

watches". The discussion between the Operations crew and the engineer determined

that operation of these doors was "as required" and, therefore, only door 203-45-003

was opened. The inspectors determined that all the doors were required to be opened

and the statement "as required" only applied to the stationing of security guards and fire

watches. Dominion's corrective actions include a revision to the procedure to remove all

"as required statements.

Analysis. The performance deficiency associated with this issue was that Dominion

failed to implement procedures to correctly install temporary cooling to the East 480 volt

switchgear. The finding was more than minor because, if left uncorrected, one division

of the 480 volt vital AC system (480VACS) may not be available to respond to design

basis events due to increasing room temperatures exceeding the switchgear design

temperature limits and subsequent failure of the switchgear In addition, the equipment

performance attribute of the mitigating systems cornerstone and the objective of

ensuring the availability of systems that respond to initiating events to prevent

undesirable circumstances was affected, since the 480VACS provided vital power to a

number of safety-related systems designed to mitigate design basis events. The finding

also affected the containment structures, systems, and components and barrier

performance attribute of the barrier integrity cornerstone and the objective of providing

reasonable assurance that physical design barriers protect the public from radionuclide

releases caused by accidents or events, because hydrogen recombiners and

containment air recirculation fans are also powered from the 480VACS. Finally, the

finding impacted the equipment performance attribute of the initiating events

cornerstone objective of limiting the likelihood of those events that upset plant stability

since temperature sensitive electro hydraulic control (EHC) equipment was located in

this room. The failure of this equipment would result in a turbine trip. Traditional

enforcement did not apply to this issue because there were no actual safety

consequences, impacts on the NRC's ability to perform its regulatory function, or willful

aspects to the violation.

Manual Chapter 0609, Appendix A , was used to determine the risk associated with this

finding. Phase 1 of the Appendix requires that a Phase 2 analysis be performed

because three cornerstones were affected. The entry into the tables associated with the

Phase 2 analysis assumed that the 480VACS is inoperable. However, this finding

concerned the support room cooling system for the 480VACS, therefore, an evaluation

of the impact on this system due to the degraded cooling system was performed. Since

the actual room temperature did not exceed 104 degrees Fahrenheit, it was reasonable

Enclosure

23

to conclude that although the compensatory measures for the 480VACS room cooling

system were not properly implemented, the 480VACS remained operable. This

evaluation also applied to the EHC equipment located in this room. Since both trains of

the 480VACS and the EHC equipment remained operable, there was no entry condition

for evaluating this in the Phase 2 Tables. Therefore, the safety significance of this issue

is very low (Green).

This finding was related to the Human Performance cross cutting area because of the

failure of Engineering and Operations to correctly implement the procedure for

compensatory cooling.

Enforcement. Technical Specification 6.8.1 requires, in part, that written procedures

shall be established and implemented as recommended in Appendix "A" of Regulatory

Guide 1.33. Contrary to this requirement, on January 12, 2005, Dominion failed to

correctly establish temporary cooling with the correct flow path in accordance with

procedure OP-2315D which affected safety-related equipment in the East 480 volt

switchgear room. However, the failure to establish the correct ventilation path was

determined to be of very low safety significance and has been addressed in Dominion's

Corrective Action Program (CR-05-00370). Therefore, this violation is being treated as

an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy.

(NCV 05000336/2005002-05).

Unit 3

No findings of significance were identified.

Cornerstone: Emergency Preparedness [EP]

1EP4 Emergency Action Level and Emergency Plan (E-PLAN) Changes (IP 71114.04 -

1 Sample)

a. Inspection Scope

During the period of January 11, 2005, through March 31, 2005, the NRC has received

and acknowledged the changes made to Millstones E-Plan in accordance with 10 CFR

50.54(q), which Dominion Nuclear had determined resulted in no decrease in

effectiveness to the Plan and which have concluded to continue to meet the

requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. The inspector

conducted a sampling review of the Plan changes which could potentially result in a

decrease in effectiveness. This review does not constitute an approval of the changes

and, as such, the changes are subject to future NRC inspection. The inspection was

conducted in accordance with NRC Inspection Procedure 71114, Attachment 4, and the

applicable requirements in 10 CFR 50.54(q) were used as reference criteria.

b. Findings

Enclosure

24

No findings of significance were identified.

1EP6 Drill Evaluation (71114.06 - One Unit 2 Sample and One Unit 3 Sample)

a. Inspection Scope

The inspectors observed one sample of the conduct of Unit 2 licensed operator

simulator training on January 24, 2005. The inspectors evaluated the Operations crew

activities related to evaluating the scenario related to a loss of off site power, during a

reduced inventory plant configuration, and making proper classification determinations.

Additionally, the inspectors assessed the ability of Dominions evaluators to adequately

address operator performance deficiencies identified during the exercise. Documents

reviewed during the inspection are listed in the Attachment.

The inspectors observed one sample of the conduct of a Unit 3 licensed operator

simulator training on February 1, 2005, including assessment of Emergency Planning for

performance indicator submittals. The inspectors observed the Operations crew

performance at the simulator and emergency response organization performance at the

site emergency operations center and technical support center. The inspectors verified

that the classification, notification, and protective action recommendations were

accurate and timely. Additionally, the inspectors assessed the ability of Dominions

evaluators to adequately address operator performance deficiencies identified during

the exercise. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

2. RADIATION SAFETY

Cornerstone: Occupational Radiation Safety [OS]

2OS1 Access Controls to Radiologically Significant Areas (71121.01)

a. Inspection Scope (Eleven Samples)

During the period February 28, 2005, through March 3, 2005, the inspector conducted

the following activities to verify that Dominion was properly implementing physical,

administrative, and engineering controls for access to locked high radiation areas, and

other radiologically controlled areas, and that workers were adhering to these controls

when working in these areas. Implementation of these controls was reviewed against

the criteria contained in 10 CFR 20, Technical Specifications, and Dominions

procedures. This inspection activity represents completion of eleven (11) samples

relative to this inspection area.

Enclosure

25

Plant Walkdown and Radiation Work Permits (RWP) Reviews

The inspector identified areas in Units 2 and 3 where radiologically significant

work was being performed. These areas included the Unit 2 spent fuel pool,

where diving operations were being conducted to repair fuel transfer system

components, and the Unit 3 containment building, where entries were being

made for steam generator blow-down system valve realignments and component

inspections. The Unit 3 containment entry involved personnel entering a

potentially very high radiation area (VHRA), the moveable in-core detector

(MIDS) area. The inspector reviewed RWPs associated with these activities,

RWP Nos. 74 and 90/91, respectively, and the radiation survey maps of the work

areas to determine if the radiological controls were acceptable. Additionally, the

inspector reviewed the procedural controls implemented for personnel entry into

a potential VHRA in the Unit 3 containment.

The inspector toured accessible radiologically controlled areas in Units 2 and 3,

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.

In reviewing various RWPs, the inspector reviewed electronic dosimeter

dose/dose rate alarm setpoints to determine if the setpoints were consistent with

the survey indications and plant policy. The inspector verified that the workers

were knowledgeable of the actions to be taken when the electronic dosimeter

alarms or malfunctions for tasks being conducted under selected RWPs. Work

activities reviewed included Unit 2 spent fuel pool diving operations (RWP 74),

Unit 3 steam generator blowdown system valve realignment (RWP 90), and

Unit 3 in-containment inspections of the MIDS (RWP 91).

The inspector reviewed the RWPs and associated instrumentation and

engineering controls for potential airborne radioactivity areas. Through review of

relevant condition reports and supporting documentation, the inspector reviewed

the dose assessment methodology and corrective actions for airborne incidents

that occurred during 2004, resulting in an internal dose in excess of 50 mrem.

The inspector reviewed the physical and procedural controls for highly

activated/contaminated materials stored in the Unit 2 and 3 spent fuel pools.

Problem Identification and Resolution

The inspector reviewed elements of Dominions Corrective Action Program

related to controlling access to radiologically significant areas, completed since

the last inspection of this area, to determine if problems were being entered into

the program for resolution. Details of this review are contained in Section 4OA2

of this report.

Enclosure

26

Jobs-In-Progress Review

The inspector observed aspects of various maintenance activities being

performed during the inspection period to verify that radiological controls, such

as required pre-job surveys, area postings, job coverage, and pre-job RWP

briefings were conducted; personnel dosimetry was properly worn; and that

workers were knowledgeable of work area radiological conditions. The inspector

attended the pre-job RWP briefings and observed selected aspects of Unit 2

spent fuel pool diving operations and a Unit 3 containment entry.

High Risk Significant, High Dose Rate High Radiation Area and VHRA Controls

The inspector discussed with Radiation Protection Supervision the adequacy of

physical and procedural controls for performing work in potential VHRAs.

Specific VHRA controls were reviewed for ongoing work performed in the MIDS

area in the Unit 3 containment building (during power operations) and diving

operations performed in the Unit 2 spent fuel pool. Safety measures reviewed

included use of remote dosimetry, multi-badging, pre-job removal of radioactive

sources, confirmatory surveys, video cameras, management authorizations, and

key controls.

Keys to Unit 2 and 3 locked high radiation areas (LHRA) and VHRAs were

inventoried and accessible LHRAs were verified to be properly secured and

posted during plant tours.

The inspector discussed with the project lead and cognizant radiation protection

staff the radiological controls to be implemented for replacement and storage of

the Unit 2 reactor head during the upcoming spring 2005 refueling outage.

Radworker and Radiation Protection Technician Performance

The inspector evaluated radiation worker and radiation protection technician

performance by observing various jobs-in-progress, reviewing daily log entries,

attending pre-job RWP briefings, and attending outage challenge board and

daily departmental meetings.

The inspector reviewed condition reports related to radiation protection

technician and radiation worker errors to determine if an observable pattern

traceable to a similar cause was evident.

b. Findings

No findings of significance were identified.

Enclosure

27

2OS2 ALARA Planning and Controls (71121.02)

a. Inspection Scope (Four Samples)

During the period February 28, 2005, through March 3, 2005, the inspector conducted

the following activities to verify that Dominion was properly implementing operational,

engineering, and administrative controls to maintain personnel exposure

as-low-as-is-reasonably-achievable (ALARA) for activities performed in 2004 and in

preparing for the upcoming Unit 2 refueling outage. Implementation of these controls

was reviewed against the criteria contained in 10 CFR 20, applicable industry standards,

and Dominions procedures. The inspection represents completion of four samples

relative to this inspection area.

Radiological Work Planning

The inspector reviewed pertinent information regarding cumulative exposure

history, current exposure trends, and ongoing activities to assess current

performance and the challenges for the upcoming Unit 2 refueling outage.

The inspector reviewed the projected Unit 2 (spring 2005) refueling outage work

schedule and the associated work activity exposure estimates. Scheduled work

reviewed included reactor head replacement, permanent cavity pit seal

installation, Alloy 600 mitigation activities, and primary systems equipment

changeouts.

The inspector 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 the ALARA Coordinator and Radiation Protection

Manager, reviewing station ALARA Council meeting minutes, attending the

Unit 2 Outage Schedule Review meeting, and attending Unit 2 Outage Project

Challenge Board meetings. Challenge Board meetings attended included

primary systems equipment changeout and Alloy 600 mitigation activities.

The inspector reviewed the assumptions and basis for the annual site collective

exposure projections for site power operations and for the Unit 2 and Unit 3

refueling outages, scheduled later this year. Additionally, the inspector reviewed

the 2005-2006 Station Exposure Reduction Plan.

b. Findings

No findings of significance were identified.

Enclosure

28

4. OTHER ACTIVITIES [OA]

4OA2 Identification and Resolution of Problems (71152)

1. Daily Review of Problem Identification and Resolution

a. Inspection Scope

As required by Inspection Procedure 71152, "Identification and Resolution of Problems",

and in order to help identify repetitive equipment failures or specific human performance

issues for followup, the inspectors performed a daily screening of items entered into

Dominion's corrective action program. This review was accomplished by reviewing

summary lists of each condition report, attending screening meetings, and accessing

Dominion's computerized condition report database.

b. Findings

No findings of significance were identified.

2. Annual Sample Review (One Unit 3 Sample)

Unit 3

a. Inspection Scope

The inspectors completed one Unit 3 sample by selecting condition report CR-04-01569,

EDG exhaust temperature spread, for a detailed review. The deficiency report was

associated with exhaust temperatures on the B EDG and a technical evaluation

M3-EV-04-002, EDG Exhaust Temperature Spread performed by Dominion. The

specific CR and CR history were reviewed to ensure that the full extent of the issue was

identified, appropriate evaluations were performed, and appropriate corrective actions

were specified and prioritized. The inspectors also evaluated the reports against the

requirements of Dominions corrective action program.

b. Findings

No findings of significance were identified.

3. Access Control to Radiologically Significant Areas (71121.01)

a. Inspection Scope

The inspector reviewed ten (10) Condition Reports, recent ALARA Council Meeting

minutes, and Nuclear Quality Assessment field observation reports to evaluate the

threshold for identifying, evaluating, and resolving occupational radiation safety

Enclosure

29

problems. This review included a check of possible repetitive issues such as radiation

worker and radiation protection technician errors.

The review was conducted against the criteria contained in 10 CFR 20, Technical

Specifications, and Dominions procedures.

b. Findings

No findings of significance were identified.

4. Cross-References to PI&R Findings Documented Elsewhere

Section 1R01 describes a failure to take adequate actions to prevent the air dryer skid

from freezing following identification of an inadequate freeze protection system. The

inspectors determined that the Dominion extent of condition review was not adequate to

ensure Dominion assessed and corrected the degraded condition in a timely manner.

Section 1R07.2 describes a failure to promptly identify and take actions to address a

condition adverse to quality concerning a degraded condition associated with all three

RPCCW HXs.

Section 4OA5.2 describes a failure to take effective corrective actions to identify air

entrapped in the residual heat removal heat exchanger. The inspectors determined that

the extent-of-condition review was not adequate to ensure Dominion assessed and

corrected the degraded condition in a timely manner.

4OA3 Event Followup (71153)

1. Unit 2 Unusual Event Declared Due To Fire

a. Inspection Scope

On January 14, 2005, Operations personnel responded to a fire in an electrical panel in

the Unit 2 turbine building. Dominion declared an Unusual Event since the fire lasted

greater than 15 minutes and was located in an area of concern for safe shutdown (the

Unit 2 turbine building). The resident inspectors responded and Region 1 staffed the

Incident Response Center. A special inspection team was chartered to conduct an

investigation and evaluation of this event which will be documented in NRC Inspection

Report 05000336/2005009.

b. Findings

Refer to Special Inspection Report Number 05000336/2005009.

Enclosure

30

2. (Closed) Licensee Event Report (LER) 0500423/2004-002-00, Inoperable Motor Driven

Auxiliary Feedwater (MDAFW) Pump Resulting From A Degraded Service Water

System Brazed Joint

The inspectors interviewed Dominion personnel and reviewed this LER with its

associated condition reports to verify that the root cause and corrective actions related

to the event described in the LER was adequate. No findings were identified during the

inspectors review. This LER is closed.

4OA4 Cross Cutting Aspects of Findings

Cross-Reference to Human Performance and PI&R Findings Documented Elsewhere

Section 1R19.1 describes a failure to implement testing procedures for returning the A

EDG to an operable status following completion of electrical breaker maintenance. The

finding was related to the cross cutting area of human performance in that Dominion

signed a PMT as satisfactory and restored the EDG neutral breaker to an operable

status although the acceptance criteria was not met. .

Section 1R19.2 describes a failure to implement testing procedures for maintenance

performed on the A hydrogen recombiner and which would have made the hydrogen

recombiner inoperable during an actual event. This finding was related to the cross-

cutting issue of Human Performance in that Dominion failed to adequately perform

post-maintenance testing to ensure incorrect maintenance activities were identified prior

to returning the hydrogen monitor to service.

Section 1R23 describes a failure to implement compensatory cooling measures as

required by procedure when normal cooling to the East 480VACS was not available.

This finding was related to the cross-cutting area of Human Performance in that both

Engineering and Operations personnel failed to correctly implement the procedure for

East 480 volt swithcgear room compensatory cooling.

Section 4OA5.2 describes a failure to properly assess and correct degraded conditions

in the A RHR discharge piping. This finding was related to the cross cutting area of

Problem Identification and Resolution in that Dominion failed to perform an adequate

extent-of-condition review to fully evaluate the effect of air that had been introduced into

the A RHR system.

4OA5 Other Activities

1. (Closed) URI 05000336/2004007-01, Adequacy of the Enclosure Building Filtration

System (EBFS) Operability Determination And The Potential Risk Significance Of Any

Degradation in EBFS Function

This URI was opened to assess the impact of a steam and debris laden atmosphere on

the post accident operation of the EBFS. Based on Dominion Engineering Technical

Enclosure

31

Evaluation M2-EV-04-0024, Evaluation of Pressure Entering the EBFS Region, the

inspectors determined that there was no operability impact on the EBFS. This URI is

closed.

2. (Closed) URI 05000423/2004008-01, Air Entrainment of Residual Heat Removal System

This URI was opened to assess the impact of additional air found in the A residual

heat removal system heat exchanger. The inspectors reviewed the operability

determinations and Technical Evaluations associated with the degraded condition of the

RHR system to ensure that operability was justified and that mitigating systems or those

affecting barrier integrity remained available and no unrecognized increase in risk had

occurred. The inspectors also reviewed compensatory measures to ensure that the

compensatory measures were in place and were appropriately controlled. The

inspectors reviewed licensee performance to ensure all related TS and FSAR

requirements were met. Documents reviewed are listed in the Attachment.

Introduction. A green non-cited violation of 10 CFR 50, Appendix B, Criterion XVI,

Corrective Action, was identified for failure to determine the extent of condition of air

found in the RHR discharge piping. Specifically, after discovering and subsequently

venting a significant amount of air in the A RHR system in May 2004, Dominion did not

adequately investigate to determine if air remained in the RHR heat exchanger tubing.

Description. Following the Spring 2004 refueling outage, NRC inspectors questioned

why Dominion had found air in the RHR discharge piping. The inspectors determined

that the build-up of air in the "A" RHR train occurred when Dominion secured the "A"

RHR pump during the reactor coolant system sweep and vent evolution during the

Spring outage. Additionally, contrary to procedure requirements, Dominion had decided

not to vent the A RHR train while coming out of the outage. This issue was dis-

positioned as an NCV in Inspection Report 05000423/2004007.

Dominion performed a root cause evaluation to determine the cause of the air intrusion

and to recommend actions to prevent recurrence. One of the corrective actions that

was recommended by the root cause team was to add an RHR suction piping vent valve

to the monthly venting surveillance of the system. The root cause evaluation was

completed in August 2004 and concluded that there was no air remaining in the RHR

system. Subsequently, additional air was found in July 2004 and again in October 2004

during RHR system venting (CR-04-09306) following quarterly RHR pump runs.

The inspectors questioned Dominion as to the source of this additional air discovered in

July and again in October 2004. Dominion suspected that the source of air was the A

RHR heat exchanger and determined that this amount of additional air did not impact

A RHR pump operability. However, during the subsequent November vent and valve

lineup of the "A" train of the RHR system, air was again vented from the suction piping

of the "A" RHR pump. Operations determined that this amount of air was excessive,

declared the "A" RHR train inoperable, and entered the appropriate limiting condition of

operation. Dominion instituted a troubleshooting plan consisting of running the A RHR

Enclosure

32

pump several times to strip the air out of the system, performing ultrasonic tests to

identify voids, and running full recirculation flow through the "A" RHR heat exchanger.

Based on this troubleshooting effort, Dominion confirmed that the source of air was the

"A" RHR heat exchanger and was part of the original volume of air first identified in the

A RHR system following the Spring outage. When the "A" RHR pump was run on

recirculation, air was swept out of the "A" RHR heat exchanger and relocated to a

horizontal run of pipe at the "A" RHR pump suction. Dominion determined that it would

take running the A RHR pump approximately 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months to build up enough air to make

the RHR pump inoperable. According to Dominion, the mission time of the RHR pump

for a design basis loss of coolant accident (LOCA) is 30 minutes. Dominion evaluated

whether the air in the A RHR heat exchanger would adversely affect any emergency

core cooling system (ECCS) pumps and wrote an operability determination (OD) to

support continued operability of the A RHR system. Operations then declared the A

RHR train operable and exited the associated technical specification.

Analysis. The performance deficiency was the failure to take prompt corrective actions

to determine the extent of condition of air that was introduced into the A RHR system

during the Spring 2004 outage. Dominions extent-of-condition review did not determine

that a significant volume of air remained in the RHR heat exchanger after finding and

venting air in the A RHR system during subsequent venting evolutions conducted in

July and October of 2004. Specifically, Dominion did not recognize the need to expand

and accelerate their extent of condition corrective actions following the identification that

air remained in the A RHR system in July and subsequently again in October of 2004.

This finding was more than minor because it affected the equipment performance

attribute and the availability, reliability, and capability objective of this mitigating system.

However, subsequent analysis determined that for a large break LOCA, the air would be

swept into the core without affecting the RHR pump, and for small break LOCAs, the air

would not have affected the operability of the RHR pump within its required mission

time, and for all accidents the air would not have migrated to a section of crossover

piping that could affect other ECCS equipment. Therefore, this finding, assessed in

accordance with NRC Manual Chapter 0609, Appendix A, Attachment 1, Significance

Determination Process for Reactor Inspection Findings for At-Power Situations, was

determined to be of very low safety significance (Green) because it did not involve a

design or qualification deficiency, represent an actual loss of safety function, or involve

seismic, flooding, or severe weather initiating events.

This finding was related to the cross-cutting issue of problem identification and

resolution because Dominion failed to perform an adequate extent of condition review to

fully evaluate the effect of air that was introduced into the A RHR system.

Enforcement. Code of Federal Regulations 10 CFR Part 50 Appendix B, Criterion XVI,

Corrective Action, requires, in part, that measures shall be established to assure that

conditions adverse to quality are promptly identified and corrected. Contrary to this

requirement, from May to October 2004, Dominion failed to properly assess and correct

degradation of the A RHR system caused by air introduction during the Spring 2004

Enclosure

33

refueling outage. Because subsequent evaluation of the air void determined that the

system retained operability, the issue was determined to be of very low safety

significance and has been addressed by Dominions CAP (CR 04-10129), this violation

is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement

Policy. (NCV 05000423/2005002-06)

4OA6 Meetings, Including Exit

Heat Sink Performance Exit Meeting Summary

On February 11, the inspector presented the inspection results to members of Dominion

management led by Mr. Alan Price. Dominion management stated that none of the

information reviewed by the inspector was considered proprietary. The inspector also

discussed Dominions associated operability determination and OE evaluation during a

conference call on March 21, 2005.

Occupational Radiation Safety Exit Meeting Summary

On March 3, 2005, the inspector presented the inspection results to Mr. Skip Jordan,

and other members of the Dominion staff, who acknowledged the findings.

Integrated Report Exit Meeting Summary

On April 21, 2005, the resident inspectors presented the overall inspection results to

Mr. J. Alan Price and other members of his staff who acknowledged the findings. The

inspectors confirmed that proprietary information was not provided or examined during

the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

A. Airas, System Engineer

S. Alligood, Radiation Protection Technician

T. Armagno, Supervisor, Health Physics

B. Bartron, Licensing

B. Bowen, Radiation Protection Technician

P. Calandra, ALARA Coordinator

W. Collins, Radiation Protection Technician

D. DelCore, Shift Supervisor, Health Physics, Unit 2

E. Dundon, System Engineer

I. Haas, Acting Supervisor Exposure Control

A. Johnson, Supervisor, Radiation Protection Support, (Technical)

A. Jordan, Director, Nuclear Engineering

J. Joszick, Radiation Protection Technician

B. Kaufman, (Acting) Manager, Nuclear Quality Assurance

R. King, ALARA Coordinator

E. Laine, Manager, Radiological Protection & Chemistry

J. Langan, Site Engineering Manager

L. Loomis, System Engineer

F. Mueller, System Engineer

F. Perkins, System Engineer

A. Price, Site Vice President - Millstone

D. Regan, Supervisor, Radiation Protection Support (ALARA)

S. Sarver, Director, Nuclear Station Operations & Maintenance

S. Scace, Director, Nuclear Station Safety and Licensing

W. Spahn, Site Engineering Supervisor

M. Wood, Health Physicist

M. Wynn, Health Physicist

NRC personnel

M. X. Davis, Reactor Inspector, Division of Reactor Safety (DRS)

M. L. Heath, Nuclear Safety Professional

K. M. Jenison, Senior Reactor Inspector, Division of Reactor Projects (DRP)

S. R. Kennedy, Resident Inspector, DRP

K. S. Kolaczyk, Senior Resident Inspector, Ginna, DRP

J. A. Krafty, Reactor Inspector, DRS

K. A. Mangan, Resident Inspector, DRP

T. A. Moslak, Health Physicist, DRS

S. M. Schneider, Senior Resident Inspector, DRP

J. G. Schoppy, Senior Reactor Inspector, DRS

Attachment

A-2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000336/2005002-01 FIN Failure to adequately address

concerns related to freeze protection

of an outdoor temporary instrument

air compressor (1R01.2)05000423/2005002-02 NCV Failure to promptly evaluate and

correct a degraded condition

associated with the divider plate for

all three RPCCW HXs

(Section 1R07.2)05000423/2005002-03 NCV Failure to adequately implement

testing procedures for restoring the

A EDG to service (1R19.1)05000423/2005002-04 NCV Failure to adequately perform

post-maintenance testing on

hydrogen recombiner (1R19.2)05000336/2005002-05 NCV Failure to implement procedures to

correctly install temporary cooling to

the East 480 volt switchgear (1R23)05000423/2005002-06 NCV Failure to take prompt corrective

actions to determine the extent of

condition of air trapped in the RHR

suction and discharge piping

(4OA5.2)

Closed

05000423/2004-002-00 LER Inoperable Motor-Driven Auxiliary

Feedwater Pump Resulting From A

Degraded Service Water System

Brazed Joint (4OA3.2)05000336/2004007-01 URI Adequacy of the Enclosure Building

Filtration System Operability

Determination And The Potential

Risk Significance Of Any

Degradation in EBFS Function

(4OA5.1)05000423/2004008-01 URI Air Entrainment of Residual Heat

Removal System (4OA5.2)

Attachment

A-3

Discussed

None

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

CR-05-00633, Organization Response to Weekend Snowstorm

CR-05-00922, Temporary Air Compressor Dryer Prefilters High DP and Lowering Air Pressure

TS 3.0.3, Limiting Condition For Operation

C OP 2006, Revision 001-02, Storm and Other Hazardous Phenomena (Preparation and

Recovery)

Section 1R04: Equipment Alignment

Major Equipment Schedule

Electrical On-Line Diagrams

OPS Form 2610C-002, Revision 019-05, Auxiliary Feedwater System Lineup Verification

OP-3314F, Unit 2 Control Building HVC HVK Valve Lineup

OP-2322, Revision 025-02, Auxiliary Feedwater System

OP-2315A, Revision 014-03, Control Room Air Conditioning System

SP-2610C, Revision 012-08, AFW System Lineup Valve Operability and Operational Readiness

Tests

SP-3670.1, Revision 010-10, Control Room Surveillances

SP-3670.2, Revision 010-06, Technical Specification Related PEO Rounds (Mode 1 to 4)

SP-3670.1-002, Revision 010-03, SP-3670.1 Surveillance Form

SP-3670.2-002, Revision 013-05, SP-3670.2 Surveillance Form

SP-2669A-002, Revision 034, Unit 2 Aux Building Rounds

SP-2610CO, Revision 000-00, Auxiliary Feedwater Flow-Path Lineup Verification

SP-2609B, Revision 016-01, EBFS and Control Room Ventilation Operability Test, Facility 2

SP-3622.4-002, Revision 005-02, Auxiliary Feedwater System Lineup (MDAFW Train B)

SP-3622.4-001, Revision 005-02, Auxiliary Feedwater System Lineup (MDAFW Train A)

SP-3622.4, Revision 005-02, Auxiliary Feedwater System Lineup Verification

PI&D 25203-26005, Sheet 3 of 4, Revision 46, Condensate Storage and Auxiliary Feedwater

P&ID 25203-26027, Sheet 3 of 4, Revision 28, Control Room Air Conditioning System

DCM 05-5A, Revision 010, MP2 Control Room, Heating, Cooling & Ventilation Requirements

Calculations

DCM Form 5-1A, Revision 05, Control Room HVAC Regain, Pressure Drop and Flowrate

FSAR, Table 9.9-11, Revision 21, Control Room Air Conditioning System

EOP 2541, Appendix 43, Revision 000, Operating Control Room Emergency Air Intakes

Millstone Nuclear Power Station Unit 2 Technical Specifications 4.7.1.2.a

Millstone Nuclear Power Station Unit 2 Technical Specifications 3/4 3-33, Table 3.3-11

Millstone Nuclear Power Station Unit 2 (MNPS-2) Final Safety Analysis Report (FSAR)

CR-05-00638, The Facility 2 Control Room Air Conditioning System is not Maintaining Control

Room Temp. And it Appears that the Compressor is Tripped

Attachment

A-4

CR-04-01743, The A Vital Chiller (X169A) Tripped During its Surveillance Run Via SP-2604T

CR-04-11217, The Facility 1 Control Room Air Conditioning System is not Maintaining Control

Room Temp. And it Appears that the Compressor is Tripped

CR-05-00769, The Vital Chillers (X169A/B) Require a Maintenance Rule (a)(1) Evaluation due

to Repetitive Failures

CR-05-02072, Discovered Montville-Haddam Neck 364 Line Out of Service Which is the Same

as Millstone-Montville 371 Line Out

CR-05-02873, MP2 Control Room HVAC System Calculation Changes

Drawing 25203-32023, Sheet 55, Revision 6, Control Room A/C Air Cool Condenser MF36A

Drawing 25203-32023, Sheet 53, Revision 8, Control Room A/C System Refrig. Compressor

MF22A

Maintenance Rule (a)(1) Evaluation, Revision 0, Control Room Air Conditioning System (2315A)

COP 200.8, Revision 002-01, Response to ISO New England/Convex Emergencies & Alerts

Unit 3 Final Safety Analysis Report

EM-135B&C, Auxiliary Steam System

Section 1R05: Fire Protection

SP-3641B.2, Revision 013-00, Functional Check of the Fire Protection Halon System

SP-3641D.5-001, Revision 008-4, Fire Damper Operability Verification

CR-04-02019, Incorrect reference in MP3 Fire Protection Evaluation Report

CR-04-02202, Audit 04-04 Hourly Fire Watch for MP3 impairment #23534-01-H exceeded 25%

grace period

CR-04-02762, Fire Protection: Tank inspections not performed as required by procedure

CR-04-07072, During fire protection inspection, identified slight difference in component name

between label and procedure

CR-04-07377, Fire protection cleaned up small oil spill

CR-04-07430, During NRC fire protection inspection, apparent inconsistency between fire

shutdown action matrix and EOP direction

CR-04-08275, Excessive leakage from fire protection water system

CR-04-08399, Review of OE-18887 unanalyzed condition related to fire protection cable

separation

S&W Drawing No. 12179 Piping and Instrument Diagram Fire Protection

Millstone Unit 3 Fire Protection Evaluation Report, Revision 17

Millstone Unit 3 Updated Final Safety Analysis Report

Millstone Unit 3 Licensed Operator Training Manual

Millstone Unit 3 Technical Requirements Manual

FPI 50-001, Revision 010-00, Fire Brigade Drill Assessment Data Sheet

Millstone Unit 2 Individual Plant Examination for External Events

Millstone Unit 2 Fire Hazards Analysis

Millstone Unit 2 Fire Hazard Analysis Boundary Drawing Area Figures

Unit 3 Fire Hazards Analysis

Attachment

A-5

Section 1R06: Flood Protection Measures

Millstone Unit 3 PSD Civil/Mechanical Design Calculation No. P) 1194, ESF Bldg Flood

Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break

Calculation No. 12179-P)-1194, Revision 2, Change No. 1, ESF Building Flood Study:

Maximum Flood Height in the ESF Building due to a Pipe Break

Calculation No. 12179-P)-1194, Revision 2, Change No. 2, ESF Building Flood Study:

Maximum Flood Height in the ESF Building due to a Pipe Break

Calculation No. 12179-P)-1194, Revision 2, Change No. 3, ESF Building Flood Study:

Maximum Flood Height in the ESF Building due to a Pipe Break

Calculation No. P)-1038, Revision 0, Change No. 1, Fuel Bldg. Flood Study: Determination of

Maximum Height of Water in Fuel Bldg. Due to Pipe Crack

Section 1R07: Heat Sink Performance

MP-2701J-096, Revision 007, Service Water Cooled Heat Exchangers Subject to GL-89-13

M2-EV-99-0103, Revision 03, MP2 Service Water System Operability for Increase in Ultimate

Heat Sink Temperature to 77 Degrees F.

NRC Generic Letter 89-13 dated July 18, 1989, Service Water System Problems Affecting

Safety-Related Equipment

M2-04-10878, A RBCCW Heat Exchanger Inspection

89-13 Program and Design Basis Documents

Millstone Unit 3 Generic Letter 89-13 Responses and Updates, January 1990 - February 2001

EN 31084, Revision 006-02, Operating Strategy For Service Water System At Millstone Unit 3

M3-EV-02-0031, Technical Evaluation for Service Water Heat Exchanger Monitoring Millstone

Unit 3, dated 3/4/04

EPRI NP-7552, Heat Exchanger Performance Monitoring Guidelines, December 1991

EPRI TR-107397, Service Water Heat Exchanger Testing Guidelines, March 1998

Corrective Action Documents

PIR 3-93-056 03-05653 04-03673 04-09608

AR 97000674 03-05942 04-04036 04-10667

01-10079 03-06070 04-06364 04-10672

02-03287 03-06080 04-06977 05-01227*

03-04802 03-08587 04-05227 05-01233*

03-04924 03-08729 04-06364 05-01278*

03-05524 03-08819 04-08539 05-01281*

03-05528 03-09039 04-08578 05-01767*

03-05615 03-09241 04-09331

Initiated in response to inspector concerns.

Attachment

A-6

Engineering Evaluations and Calculations

DCR M3-97045, Revision 1, RSS Pump Restriction Orifices to Prevent Suction Line Flashing

DCR M3-00029, Revision 0, Operation with the MP3 Ultimate Heat Sink Temperature below the

Design Basis Low Temperature of 330F

CALC No.03-059, Revision 0, Analysis of the Emergency Diesel Generator Jacket Water

Cooler Thermal Performance Test Results

CALC No.03-060, Revision 0, Emergency Diesel Generator Intercooler Water Cooler Proto-HX

Benchmark and Analysis of the Thermal Performance Test Results

Calculation No. 90-069-1130 M3, Revision 0, Millstone Unit 3 - Service Water System -

Summary of Westinghouse Heat Exchanger Calculations

Calculation No. 90-069-01065M3, Revision 1, MP3 SW System - Service Water System - NRC

Generic Letter 89-13, Item No. IV, Design Basis Summary Report

Operability Determination MP3-004-05, Revision 0

EDG Testing and Inspections

SP 3646A.2, Emergency Diesel Generator B Operability Tests, dated 12/21/04

PD04266.02, Record of Eddy Current Inspection of Emergency Diesel Generator - B Air Cooler

3EDS-1B and Water jacket Cooler 3EDS-2B, May 1999

Service Water Cooled Heat Exchangers Inspection Form (EN31084 Attachment 2) for 3GS-

E1B & E2B; dated 10/26/04

SP 3626.13, CCI and EGS Train B Heat Exchanger Fouling Determination, dated 1/31/05

SP 3626.13, CCI and EGS Train B Heat Exchanger Fouling Determination, dated 2/7/05

Miscellaneous

Risk-Informed Inspection Notebook for Millstone Nuclear Power Plant, Unit 3, Revision 1

Millstone Unit 3 Individual Plant Examination for Severe Accident Vulnerabilities (NUSCO 171)

S & W DWG. No. 12179-EM-133D, Piping & Instrumentation Diagram Service Water

Intake Structure Information Book

System Operability Determination Notebook (MP3-065-01, MP3-072-04, MP3-079-04)

Request for Engineering LOE Support, dated 12/8/04

Millstone Power Station Unit 3 2003 Annual Environmental Protection Plan Operating Report

Intercooler Water Cooler Heat Exchanger Specification Sheet, dated 7/28/75

Jacket Water Cooler Heat Exchanger Specification Sheet, dated 7/28/75

Containment Recirculation Coolers Tubular Heat Exchanger Data, dated 2/10/74

D.C. Cook Nuclear Power Plant, Units 1 and 2 NRC Special Inspection Report 50-315/03-08;

50-316/03-08, dated 7/3/03

Operating Experience

NRC Information Notice 94-59: Accelerated Dealloying of Cast Aluminum-Bronze Valves

Caused by Microbiologically Induced Corrosion, dated 8/17/94

NRC Information Notice 96-36: Degradation of Cooling Water Systems Due to Icing, dated

6/12/96

Attachment

A-7

NRC Information Notice 98-02: Nuclear Power Plant Cold Weather Problems and Protective

Measures, dated 1/21/98

Millstone Unit 3 Response to NRC IN 94-59, NRC IN 96-36, and NRC IN 98-02

NUREG-1275, Vol. 3 - Operating Experience Feedback Report - Service Water System

Failures and Degradations

Ice Blockage of Water Intakes, NUREG/CR-0548

Generic Service Water System Risk-Based Inspection Guide, NUREG/CR-5865 EGG-2674

NRC Generic Letter 96-06, Supplement 1: Assurance of Equipment Operability and

Containment Integrity During Design-Basis Accident Conditions, dated 11/13/97

Millstone Unit 3 Generic Letter 96-06 Responses and Updates, May 1998 - December 2000

Procedures

AOP 3560, Revision 007, Loss of Service Water

AOP 3569, Revision 015-02, Severe Weather Conditions

OP 3326, Revision 021-15, Service Water System

OP 3306, Revision 008-03, Containment Recirculation Spray System

OP 3330A, Revision 015-08, Reactor Plant Component Cooling Water

OP 3353.WTC, Revision 1, Chlorine Panel Annunciator Response

OP 3353.MBIB, Revision 002-06, Chlorination System Trouble

OP 3353.MBIC, Revision 005-04, RPCCW HX SW FLOW HI/LO

OP 3353.MBIC, Revision 005-04, CTMT RECIRC CLR SW FLOW HI/LO

OP 3353.MBIC, Revision 005-04, DG B COOLER SW FLOW HI

OP 3353.MBIC, Revision 005-04, DG B COOLER SW FLOW LO

OP 3353.MBIC, Revision 005-04, Service WTR PP Strainer DIFF Pres HI

OP 3353.MBIC, Revision 005-04, Service WTR Pump DIS Pres LO

OP 3353.MBIC, Revision 005-04, RPCCW HX OUT TEMP HI/LO

OP 3353.MBID, Revision 002-04, CTMT RECIRC Spray System

OP 3353.MBID, Revision 002-04, Service Water System

Op 3346A, Revision 021-02, Emergency Diesel Generator

SP 3626.13, Revision 019-04, Service Water Heat Exchangers Fouling Determination

SP 3626.14, Revision 001-01, RSS Heat Exchanger SW Supply Piping Flush

RPCCW Testing and Inspections

Service Water Cooled Heat Exchangers Inspection Form (EN31084 Attachment 2) for

3CCP*E1A; dated 2/6/02, 4/29/02, 6/25/03, 5/24/04

Service Water Cooled Heat Exchangers Inspection Form (EN31084 Attachment 2) for

3CCP*E1B; dated 9/3/02, 11/25/02, 5/14/03, 9/8/03, 9/20/04

Service Water Cooled Heat Exchangers Inspection Form (EN31084 Attachment 2) for

3CCP*E1C; dated 7/27/01, 7/2/02, 6/9/03

Longview Inspection damaged Tube/Condition Report for RPCCW E1-B, dated 9/28/01

PD04573, Record of Eddy Current Inspection of RPCCW Heat Exchanger 3CCP-E1B,

September 2003

Attachment

A-8

RSS Testing and Inspections

Service Water Cooled Heat Exchangers Inspection Form (EN31084 Attachment 2) for

3RSS*E1B; dated 12/15/04

Service Water Cooled Heat Exchangers Inspection Form (EN31084 Attachment 2) for

3RSS*E1D; dated 12/16/04

SP 3626.14, RSS Train B Heat Exchangers SW Supply Piping Flush, dated 12/15/04 &

12/17/04

SW Testing and Inspections

SP-3626.3, 3SWP*MOV71B, TPCCW HX SW Supply, Stroke Test; dated 12/20/04

SP-3626.3, 3SWP*MOV50A and MOV50B, CCP HXs Train A and Train B SW Supply, Stroke

Test; dated 4/24/04

SP-3626.3, 3SWP*MOV54B and MOV54D, RSS Coolers B and D SW Supply, Stroke Test;

dated 12/15/04

SP-3626.3, 3SWP*AOV39B, EDG B Service Water HX Outlet, Stroke Test; dated 10/26/04

SP-3626.4, Service Water Pump 3SWP*P1A Operational Readiness Test, dated 11/09/04

SP-3626.5, Service Water Pump 3SWP*P1B Operational Readiness Test, dated 12/23/04

SP-3626.6, Service Water Pump 3SWP*P1C Operational Readiness Test, dated 11/10/04

SP-3626.7, Service Water Pump 3SWP*P1D Operational Readiness Test, dated 12/20/04

SP-3626.6, Service Water Pump 3SWP*P1C Operational Readiness Test, dated 11/10/04

SP 3626.13, Service Water Heat Exchangers Fouling Determination, dated 1/29/05, 2/6/05

System Health Reports and Trending Data

B EDG Service Water Flow and Differential Temperature, 09/28/04 - 01/18/05

B EDG Lube Oil & Jacket Water Temperatures, 09/28/04 - 01/18/05

B EDG JW and Intercooler, B RSS, and B RPCCW HX Flow & D/P Trending, 1/7/02 - 1/10/05

Emergency Diesel Generator and EDG Fuel Oil System Health Report (Third Quarter 2004)

Service Water System Health Report (Third Quarter 2004)

Containment Recirculation Spray System Health Report (Third Quarter 2004)

Reactor Plant Component Cooling Water System Health Report (Third Quarter 2004)

Work Orders

M30106969 M30206235 M30307754 M30416542

M30202096 M30206237 M30308193 M39803648

M30202098 M30206239 M30310919 M39804420

M30206009 M30206241 M30407936 M39804423

M30206010 M30206243 M30413782

M30206233 M30307593 M30414020

Attachment

A-9

Section 1R11: Licensed Operator Requalification Program

2R16 Outage Modification Lesson Plan

2R16 Shutdown Cooling on Containment Spray SPROC Lesson Plan

LORTSE11, Revision 5, Change 3, Unit 3 Simulator Exam Overview

Emergency Action Level Tables

Section 1R12: Maintenance Effectiveness

CR-05-00638, The Facility 2 Control Room Air Conditioning System is not Maintaining Control

Room Temp. And it Appears that the Compressor is Tripped

CR-04-01743, The A Vital Chiller (X169A) Tripped During its Surveillance Run Via SP-2604T

CR-04-11217, The Facility 1 Control Room Air Conditioning System is not Maintaining Control

Room Temp. And it Appears that the Compressor is Tripped

CR-05-00769, The Vital Chillers (X169A/B) Require a Maintenance Rule (a)(1) Evaluation due

to Repetitive Failures

CR-04-10911, MCC B51 Air Conditioning Unit A/C-3 Making High Pitched Whistle

CR-04-1119, MCC B51 Enclosure Air Conditioner Not Working

CR-03-06001, A/C-3 (MCC B51 AC Unit) TRS not Resolved in a Timely Manner

CR-04-08032, AC-4 not Operating Properly

CR-04-02083, Air bubbles Noted in B51 Enclosure Cooler Sight Glass

CR-04-00969, B61 Enclosure Cooling Unit A/C-4, Operating with Bubbles in the Liquid Line

Sightglass

CR-03-00634, The Air Conditioner for MCC B61 was not Maintaining Temperature

CR-05-00127, SBO Diesel UPS Battery #1 Failed Voltage Testing

CR-05-00617, Received HI DP on HVQ*PDIS47, HVQ*FLT3 Closed due to Snow; Required

Entry into TS 3.0.3 to Restore

SP-M2-ME-018, Vital MCC Coolers

MP-24-MR-FAP710, Revision 000, Maintenance Rule Functional Failure Evaluation

MP-24-MR-FAP710, Revision 000-02, Maintenance Rule Functional Failures and Evaluations

IM-034060-1, Revision 0, March 1998, Installation, Operation & Maintenance Manual for Air-

conditioning Unit EEI P/N: 394

DCM Form 5-1A, Revision 05, Auxiliary Building - MCC B51, B61 Enclosures - Vital Cooling

System

Maintenance Rule Functional Failure Evaluation dated January 27, 2005

Drawing 25203-32023, Sheet 55, Revision 6, Control Room A/C Air Cool Condenser MF36A

Drawing 25203-32023, Sheet 53, Revision 8, Control Room A/C System Refrig. Compressor

MF22A

Maintenance Rule (a)(1) Evaluation, Revision 0, Control Room Air Conditioning System (2315A)

Maintenance Rule Scoping Table, Vital SWGR Emergency Cooling

Unit 3 Control Room Logs

Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation

MP-13-PRA-FAP01.1, Revision 000, Performing Risk Reviews

MP-20-OM-FAP02.1, Revision 001-02, Shutdown Risk Management

Attachment

A-10

MP-20-WM-FAP02.1, Revision 009-00, Conduct of On-Line Maintenance

NUMARC 93-01, Revision 2, NEI Industry Guideline for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants

Millstone Nuclear Power Station Unit 3 Technical Specifications L.C.O 3.3.2 (Table 3.3-3)

Millstone Nuclear Power Station Unit 3 (MNPS-3) Final Safety Analysis Report (FSAR)

CR-05-00550, Unplanned LCO Entry (3.3.2) due to 3HVR*FN6A starting Unexpectedly,

followed by MB2B 2-4A Sequencer A Trouble

CR-04-09890, 3SIH*PIA oil leakage will exceed the oil reservoir capacity within the SIH pump

design mission run time

Major Equipment Schedule

Equipment Out of Service Quantitative Risk Assessment Tool

Unit 2 Control Room Logs

Unit 3 Control Room Logs

Section 1R14: Personnel Performance During Non-Routine Plant Evolutions and Events

Technical Specification 3.0.3, Limiting Condition for Operation

C OP 200.6, Revision 001-02, Storms and Other Hazardous Phenomena (Preparation and

Recovery)

CR-05-00633, Organization Response to Weekend Snowstorm

CR-05-00399, Unusual Event Declared Due to Fire

Incident Report Forms

Unit 2 Control Room Logs

Unit 3 Control Room Logs

DNAP-2000, Troubleshooting Sheet

Equipment Out of Service Risk Tool

RP-5, Revision 004-00, Operability Determinations

RECO MP3-001-05, A EDG Autotest Circuit Failed, Resulting in Auto Start of 3HVR*FN6A

ISO-New England, Master/Local Control Center Procedure No. 2, Abnormal Conditions Alert

TS 3.3.2, Engineered Safety Features Actuation System Instrumentation

Trouble Shooting Plan, A Diesel Sequencer is Displaying a Failure Code and Needs to be

Troubleshot to Determine Operability

OP-3250.46A, Revision 006-01, Diesel Sequencer Bypass Procedure

SP-3448E31, Revision 006-02, Train A - diesel Sequencer Actuation Logic Test

Section 1R15: Operability Evaluations

MP2-003-05, On second sound cut of pulsation dampener surveillance SP2664, a rattling noise

was detected by accelerometers from the B charging pump pulsation dampener

MP3-002-05, Service water brazed joint leak in drain line for A train

CR-05-01960, TE-107 Spiking at C03F

CR-05-01959, TE-106 Operation is Erratic

CR-05-01336, Alternate Plant Configuration was Established by Isolating Steam to #2 Steam

Generator Pressure Instrument Loop

CR-05-02655, Backup Measurement Method Required for TI-106

CR-05-00748, TI-106 PORV Discharge Temp Appears to be Drifting High

Attachment

A-11

CR-05-02359, Acoustic Valve Monitor for RC-404 Reading 15%

CR-05-00127, SBO Diesel UPS Battery #1 Failed Voltage Testing

CR-05-02751, Unplanned LCO entry TS Section 3.4.6.1, Leakage Detection Systems, Action

Statement B

CR-05-02350, Impact of LER 2004-002-00, Inoperable EDG

CR-05-01213, 3CDS*CTV38A T-Ring (Seat) Requires Upgrade to Safety Related Per DCM03

(MEPL) Procedure

CR-05-01689, Retest for Hydrogen Monitor Maintenance Needs Resolution

CR-05-00550, Unplanned LCO Entry (3.3.2) due to 3HVR*FN6A Starting Unexpectedly,

Followed by MB2B 2-4A Sequencer A Trouble

RECO MP3-001-05, A EGLS Autotest Circuit Failed, resulting in Auto Start of 3HVR*FN6A

RECO/OD MP3-003-05, During a Review of the bill of materials for 3CDS*CTV38A-B,

3CDS*CTV39A-B, 3CDS*CTV91A-B, and 3SWP*ADV39A-B, it was discovered that the

T-ring (valve seat) had been improperly evaluated by previous MEPL determinations as

being non-safety related (NSR)

RP-5, Revision 004-00, Operability Determinations

OD MP3-001-05, Revision 1, Autotest Circuit Failed, Resulting in Auto Start of 3HVR*FN6A

Millstone Unit 3 Risk Informed Inspection Notebook - Brookhaven

IC-3471A01, Revision 002, Station Blackout Diesel Uninterruptable Power Supply Testing

AMP-24-MR-GDL700, Revision 003, Attachment 3, Availability Assessment for Emergent

Conditions

Unit 3 Technical Specifications Section 3.4.6.1, Leakage Detection Systems

TS 3.3.2, Engineered Safety Features Actuation System

Unit 3 Control Room Logs

Section 1R16: Operator Work-Arounds

Unit 2 and 3 Operator Workaround Management Summaries dated 3/11/05

MP-14-OPS-GDL600, Revision 001, Plant Status and Configuration Control

MP-14-OPS-GDL400, Revision 002, Operations Administrative Procedures

Section 1R19: Post-Maintenance Testing

AWO M2-00-19686, "A" Auxiliary Feedwater (AFW) Pump

AWO M2-05-00565, NT

AWO M2-00-12762, Removal/Re-Install Elbow in TDAFW PMP Suction Line

M2-02009, Replacement of Non Vital Transformer

M3-02-06072, 18 Month Battery Charger Load Test

M3-03-13876, A EDG Sequence Troubleshooting Plan

AWO M3-05-010226, Auxiliary Feed Pump Cubicle Vents

M3-03-05461, Train A Hydrogen Recombiner Instrumentation

M3-05-04144, Replace Leaking Tubing and Fittings per C MP 721A

OP-3314D, Revision 010-12, ESF Building Ventilation and Air Conditioning

CR-05-00617, Received Hi Dip on HVQ*PDIS47, HUQ*FLT3 Clogged due to Snow, Required

Entry into TS 3.0.3 to Restore

CR-03-00712, M&TE QA-3000-17G (AEMC Corp Clamp-on Model MN-115) Was Lost

Attachment

A-12

CR-05-03569, PMT Requirements of OP3370A not Consistent with Those in MP-20-GDL40

CR-05-01713, A Hydrogen Recombiner Failed the Leak Tightness Verification

(SP-3613A.2-01)

CR-05-01689, Retest for Hydrogen Monitor Maintenance Needs Resolution

CR-05-03896, A Hydrogen Recombiner may have been Inoperable for Greater than the Tech

Spec Allowed Outage Time

SP-2610AO-001, Revision 000-00, "A" AFW Pump and Recirc Check Valve IST, Facility 1

MP-20-WP-GDL40, Revision 03, "Pre and Post Maintenance Testing"

MP-20-WP-GDL40, Revision 002-01, Pre and Post Maintenance Testing C PT 1405,

Revision 000, 4.16KV and 6.9KV Motor and Surge Capacitor

DM2-02-0237-03, Replacement Containment Air Radiation Monitor, RM-8123

DM2-00-0363-04, Instrument Air Compressor F3C Replacement, Electrical and I&C Changes

Unit 3 Control Room Logs

DWG EM115A, rev 33, Quench Spray and Hydrogen Recombiner

SP-2664, Charging Pump Pulsation Dampner

SP-3448E31, EDG Sequencer Actuation Logic Test

SP-3646A.1, EDG Operability Test

SP-2402M, Function Test of AFW Ignition

SP-3448

SPROC 6T503-2-01, Mag-Amp Regulating Transformers

NRC IEN 85-91, Load Sequencers for EDG

M3-02-16737, A EDG Neutral Grounding Breaker Preventive Maintenance and Doble Testing

CR-05-01888, 15G-14U-2N, A EDG Ground Neutral Breaker, Red Closed Light on Breaker

Cabinet Not Lit.

OP 3370A, Revision 013-07, Electrical Breaker Maintenance

Section 1R22: Surveillance Testing

SP-2606B, Revision 013-01 Containment Spray Pump Operability and Inservice Testing

SP-2604D, Revision 011-00, LPSI Pump Tests

SP-3444A01, Revision 006-02, Steam Generator Water Level Channel Calibration

SP-3444A01-003R, Revision 000-01, Steam Generator Water Level Channel 3 Calibration -

Rack Instrumentation Data Sheet

SP-3609.1, Revision 009-03, Quench Spray Pump 3QSS*P3A Operational Readiness Test

SP-3610A.3-001, Revision 005, RHR System Venting & Valve Lineup-Train A

SP-3610A.3-002, Revision 006, RHR System Valve Lineup Verification Train A and Common

Header

SP-2609F-004, Revision 001-01, Control Room Ventilation System Filter Testing Efficiency,

Facility 2

SP-2609F-002, Revision 011-01, Control Room Ventilation System Filter Testing, Flow and

D/P, Facility 2

SP-3630A.5, Revision 008-005, Reactor Plant Component Cooling Water Pump 3CCP*P1B

Operational Readiness Test

SP-3630A.5-002, Revision 006-04, Reactor Plant Component Cooling Water Pump 3CCP*P1B

Operational Test

Attachment

A-13

SP-3626.7-001, Revision 013-04, Service Water Pump 35SWP*PID Operational Readiness

Test

SP-3646A.1, Revision 015-07, Emergency Diesel Generator A Operability Test

SP-2619A-001, Channel Check of Radiation Monitoring Systems

SP-2730B, Main Steam Safety Valve Testing (IPTE)

SP-2605R, 2-Fire-34/94A/94B/94C Stroke Time Test IST

SP-3610A.1, Residual Heat Removal Pump 3RHS*P1A Operational Readiness Test

SPROC OPS04-2-04, Revision 000-01, Sweep of A Train RHR to RWST

Surveillance Form SP-3609.1-001, Revision 011-01, Quench Spray Pump 3QSS*P3A

Operational Readiness Test

Surveillance Form SP-3610A.1-001, Revision 010-02, 3RHS*P1A Operational Readiness Test

in Mode 1, 2, 3, or 4 (when aligned for injection)

MP-UT-5, Revision 000-03, UT Examination Straight Bean Measurements

CR-04-03611, TDAFW Pump Control Valve Failed Stroke Time Test

CR-04-03491, Failed Operations Surveillance on 3CCP*V060

CR-04-03348, Diesel Surveillance Step Could Not Be Performed

CR-04-09799, Failed Surveillance SP-31029 Channel 4T

CR-04-10217, Incorrect Revision of Procedure Form Used to Complete Surveillance

CR-04-10814, Surveillance SP-3604C.7 Requires Addition of 2 Valves for Non Operating Boric

Acid Pump

CR-05-00281, CCP OP Test Surveillance Requires Additional Steps to Establish Minimum Flow

While Shifting Pumps

CR-05-02888, QSS Pump Surveillance Procedures Need to be Revised to be Consistent with

RHR and SIH Surveillance Procedures regarding the Auto-Start of 3HVQ*ACUS1A/B

PI&D 25203-26015, Revision 28, Low Pressure Safety Injection System

TS 3/4.6.2, Containment Quench Spray System

TS 4.0.5, IST Test Program

TS 3.5.2, ECCS SubsystemsTarg greater than or equal to 350EF.

FSAR Chapter 6.2, Containment Systems

FSAR Chapter 9.2, Service Water System

OPS Form 3609.1-1, IST Pump Test Plan

Millstone Nuclear Power Station Unit 2 Technical Specifications 3.5.2.a, 4.0.5, and 4.5.2.d

Millstone Nuclear Power Station Unit 2 Technical Specifications 3.3.2.1 and 4.6.2.1.1.b

Millstone Nuclear Power Station Unit 2 (MNPS-2) Final Safety Analysis Report (FSAR),

Sections 6.3 and 6.4.

SV-138, (Excerpted) Hydroset Analysis - Dresser Safety Valve Report

MP-05-DC-REF02, Verification Determination and Standards

M3-EV-98-0183, MSSV Set Pressure Test Validation

Dresser Letter dated 2/14/2005, Certificate of Compliance

MTDI 4.02, MTE Calibration

Calibration Verification of Hydroset 1566-2, dated 2/9/2000

MTE-HEI-004, Heise Pressure Gauge

10CFR Part 21, Notification 1566 Hydroset Constant dated August 3, 1990

WC-10, Revision 005-01, Temporary Modifications

WC-10-006, Revision 000, Equipment Used For Testing and Maintenance Design Configuration

Review

Attachment

A-14

Section 1R23: Temporary Plant Modifications

CR-05-01595, Negative Trend Identified Regarding Compensatory Cooling of Vital Electrical

Equipment Rooms

CR-05-00360, During the Implementation of Comp Cooling for the East 480V Switchgear Room

(OP-2315D), Door 203-31-008 (#229) was Improperly Left Closed

CR-05-00370, Follow Up Details for CR-05-00360 Related to Performance of OP-2315D

Compensatory Cooling Section for East 480 Volt Switchgear Room

CR-05-00922, Temporary Air Compressor Dryer Prefilters High DP and Lowering Air Pressure

CR-04-10102, Freeze Protection not Apparent on Temporary Air Compressor Dryer Assy.

OP-2332B, Revision 019-08, Instrument Air System

OP-2315D, Revision 012-03, Vital Electrical Switchgear Room Cooling Systems

OP-3225A, Revision 022-01, Circulating Water

Unit 2 Shift Orders

MP3 Shift Turnover Report

WC-10, Revision 005-02, Temporary Modification

MP-14-OPS-GDL200, Revision 009, Attachment 2, MP2 Shift Turnover Report (Sheet 6 of 10)

Section 1EP4: Emergency Action Level (EAL) and Emergency Plan (E-Plan) Changes

Millstone Emergency Plan and Implementing Procedures

Section 1EP6: Drill Evaluation

NEI 99-01, Revision 4, Permanently Defueled Station IC/EALs

Simulator Exercise Guide Approval Sheet, Operational Exercise #3, Loss of All AC Power

During Shutdown Conditions, Abnormal Events During RIO, Fuel Handling Accident

MP-26-EPA-REF02, Revision 005, Millstone Unit 2 Emergency Action Level (EAL) Technical

Basis Document

Emergency Action Level Tables

LORTSE11, Revision 5, Change 3, Unit 3 Simulator Exam Overview

DNAP-2605, Revision 0, Emergency Preparedness Performance Indicators

MP-26-EPA-GDL01, Revision 002, Attachment 1, Drill and Exercise Performance Indicator

Evaluation Form

Millstone Emergency Plan, Revision 30, December 2003, Page I-2 of 8

Section 2OS1: Access Control to Radiologically Significant Areas

Procedures

RPM 1.3.8, Revision 8, Criteria for Dosimetry Issue

RPM 1.4.1, Revision 7, ALARA Reviews and Reports

RPM 1.4.2, Revision 2, ALARA Engineering Controls

RPM 1.4.4, Revision 2, Temporary Shielding

RPM 1.5.2, Revision 4, High Radiation Area Key Control

RPM 1.5.5, Revision 4, Guidelines for Performance of Radiological Surveys

Attachment

A-15

RPM 1.5.6, Revision 3, Survey Documentation and Disposition

RPM 2.1.1, Revision 5, Issuance and Control of RWPs

RPM 2.1.2, Revision 2, ALARA Interface with the RWP Process

RPM 2.2.8, Revision 2, Underwater Radiological Surveys

RPM 2.4.1, Revision 3, Posting of Radiological Control Areas

RPM 2.5.1, Revision 1, Health Physics Requirements for Diving Operations

RPM 2.5.2, Revision 2, Guidelines for Spent Fuel Pool & Flooded Reactor Cavity Work

RPM 2.5.7, Revision 0, SAIC Underwater Personnel Dosimetry Operation

RPM 2.5.8, Revision 2, Staytime Tracking & Multi-badging for Special Work

RPM 5.2.2, Revision 10, Basic Radiation Worker Responsibilities

RPM 5.2.3, Revision 3, ALARA Program and Policy

RPM-GDL-008, Revision 0, Electronic Dosimeter Alarm Setpoints

MP-02-NO-GDL110, Revision 0, oversight by Nuclear Specialists

EN 31013, Revision 2, Spent Fuel Pool Operations

Nuclear Oversight Field Observations (QCFOB):

05-006, 04-04204-036,04-034, 04-031

Condition Reports:

05-01236, 05-01614, 05-01631, 04-11038, 04-11230, 04-11288, 04-09849, 04-10328,

04-09176, 04-07577

ALARA Council Meeting Notes:

Meetings conducted on: 02/08/2005, 02/16/2005

Section 4OA3: Event Followup

CR-05-00399, Unusual Event Declared Due to Fire

Incident Report Forms

Section 4OA5: Other Activities

NUREG/CR-2792, An Assessment of Residual Heat Removal and Containment Spray Pump

Performance Under Air and Debris Ingesting Conditions

PI&D 12179-EM-112A, Revision 42, Low Pressure Safety Injection

SP-3610A.3, Revision 005-03, RHR System Vent and Valve Lineup Verification

MP3-EV-04-0021, Revision 1, Assessment for as Accumulations in the RHR A Train Piping as

Documented in CR-04-05384, CR-04-05822, and CR-04-06615

M3-EV-04-0021, Revision 2, Assessment for Gas Accumulations in the RHR A Train Piping as

Documented in CR-04-05384, CR-04-05822, CR-04-0-06615, CR-04-6697 and

CR-04-10129

CR-05-00835, Small Amount of Air Found at 3SIL*V875 Following Run on Miniflow

Recirculation

Attachment

A-16

MP3-080-04, Revision 0, Operability Determination for CR-04-10129

MP3-080-04, Revision 1, Operability Determination for CR-04-10129

LIST OF ACRONYMS

AC alternating current

AFW auxiliary feedwater

ALARA as low as reasonably achievable

CFR Code of Federal Regulations

CR condition report

CRAC control room air condition

CS containment spray

DRP Division of Reactor Projects

DRS Division of Reactor Safety

E-PLAN emergency plan

EBFS enclosure building filtration system

EAL emergency action level

ECCS emergency core cooling system

EDG emergency diesel generator

EHC electro hydraulic control

EP emergency preparedness

ESF emergency safeguards features

FSAR Final Safety Analysis Report

HX heat exchanger

IAC instrument air compressor

IMC Inspection Manual Chapter

IST in-service testing

JW jacket water

LCO limiting condition of operations

LER Licensee Event Report

LHRA locked high radiation area

LOCA loss of coolant accident

LOE level of effort

LPSI low pressure safety injection

MCC motor control center

MDAFWP motor-driven auxiliary feedwater pump

MIDS moveable-in core detector

MR Maintenance Rule

NCV non-cited violation

NRC Nuclear Regulatory Commission

OD operability determination

OE operating experience

OP operating procedure

OWA operator workaround

PI&R problem identification and resolution

PM planned maintenance

Attachment

A-17

PMT post maintenance testing

RHR residual heat removal

RPCCW reactor plant component cooling water

RSS recirculation spray system

RWP radiation work permits

SCCM standard cubic centimeter per minute

SSC structures, systems and components

SDP significance determination process

SW service water

TDAFW turbine-driven auxiliary feedwater

TS technical specification

480VACS 480 volt vital AC system

VHRA very high radiation area

Attachment

ML051310282

Text

Navigation menu

Search