IR 05000336/2014003
| ML14224A098 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/12/2014 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Heacock D Dominion Resources |
| McKinley R | |
| References | |
| IR 14-003 | |
| Download: ML14224A098 (54) | |
Text
August 12, 2014
SUBJECT:
MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2014003 AND 05000423/2014003
Dear Mr. Heacock:
On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station, Units 2 and 3 (Millstone). The enclosed inspection report documents the inspection results, which were discussed on July 30, 2014, with Mr. Stephen E. Scace, Site Vice President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents three violations of NRC requirements, all of which were of very low safety significance (Green). However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Millstone. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Millstone. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects
Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49
Enclosure:
Inspection Report 05000336/2014003 and 05000423/2014003
w/Attachment: Supplementary Information
REGION I==
Docket Nos.
50-336 and 50-423
License Nos.
Report Nos.
05000336/2014003 and 05000423/2014003
Licensee:
Dominion Nuclear Connecticut, Inc. (Dominion)
Facility:
Millstone Power Station, Units 2 and 3
Location:
P.O. Box 128
Waterford, CT 06385
Dates:
April 1, 2014 through June 30, 2014
Inspectors:
J. Ambrosini, Sr. Resident Inspector, Division of Reactor Projects (DRP)
J. Krafty, Resident Inspector, DRP
B. Haagensen, Resident Inspector, DRP
L. McKown, Project Engineer, DRP
N. Day, Acting Resident Inspector, DRP
E. DiPaolo, Sr. Resident Inspector, Limerick Generating Station, DRP
H. Anagnostopoulous, Health Physicist, Division of Reactor Safety (DRS)
G. Meyer, Sr. Reactor Inspector, DRS
M. Modes, Sr. Reactor Inspector, DRS
E. Burket, Emergency Preparedness Inspector, DRS
D. Kern, Sr. Reactor Inspector, DRS
J. Patel, Reactor Inspector, DRS
B. Fuller, Sr. Operations Engineer, DRS
D. Silk, Sr. Operations Engineer, DRS J. Nicholson, Health Physicist, Division of Nuclear Materials Safety (DNMS)
D. Lawyer, Health Physicist, DNMS
Approved By:
Raymond R. McKinley, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
SUMMARY
IR 05000336/2014003, 05000423/2014003; 04/01/2014 - 06/30/2014; Millstone Power Station
Units 2 and 3 (Millstone); Refueling and Other Outage Activities, In-Plant Airborne Radioactivity Control and Mitigation, and Other Activities.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three non-cited violations (NCVs) of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, revised July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Occupational/Public Radiation Safety
- Green.
A self-revealing Green NCV of Technical Specification (TS) 6.8.1; Regulatory Guide 1.33, Appendix A; Radiation Work Permits (RWP); and as low as reasonably achievable (ALARA) procedures was identified for Dominions failure to utilize respiratory protection, as required by the applicable RWP and associated ALARA evaluation for work on replacement of valve 2-SI-227 on April 20, 2014. This failure resulted in an unplanned intake of radioactive material for one worker. Dominion subsequently enforced the respiratory protection requirements to complete the work and entered this issue into their corrective action program (CAP) as condition report (CR) 546439.
Failure to use respiratory protection during machining work as required by Dominion procedure was a performance deficiency that was reasonably within Dominions ability to foresee and correct. The inspectors determined that the performance deficiency was more than minor because it affected the Radiation Safety - Occupational Radiation Safety Cornerstone attribute of Program and Process associated with exposure/contamination controls, because it resulted in the unintended internal exposure of a worker. A cross-cutting aspect of Human Performance, Conservative Bias, was associated with the finding.
Specifically, radiation protection staff did not adhere to the RWP requirements [H.14].
(Section 2RS3)
Cornerstone: Emergency Preparedness
- Green.
The inspectors identified a Green NCV associated with emergency preparedness planning standard Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(4) and the requirements of Sections IV.B and IV.C of Appendix E to 10 CFR 50. Specifically, Dominion did not maintain the Millstone Units 2 and 3 emergency action level (EAL) schemes for assessing a loss of forced flow cooling during refueling operations. Dominion entered this issue into the CAP and implemented temporary corrective actions which included procedure changes to direct operators to the shutdown safety assessment checklists to determine representative reactor coolant system (RCS) temperature increases in order to assess the initiating conditions (ICs) for this situation.
The inspectors determined that the failure by Dominion to provide site specific criteria for operators to adequately implement the EALs for a loss of forced flow cooling during refueling was a performance deficiency that was reasonably within their ability to foresee and prevent. The finding is more than minor because it is associated with the Procedure Quality attribute of the Emergency Planning Cornerstone and affected the cornerstone objective to ensure that Dominion is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was an issue where two EAL ICs had been rendered ineffective such that an Unusual Event and an Alert would not be declared, or declared in a degraded manner for a loss of forced flow cooling during refueling. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, in that Dominion did not implement a CAP with a low threshold for identifying issues. Dominions self-assessment for two previous NCVs regarding EAL deficiencies failed to identify the lack of specific criteria to assess the ICs for EALs EU1.2 and EA2.1 for a loss of forced cooling flow during refueling
[P.1]. (Section 4OA5)
Cornerstone: Initiating Events
- Green.
The inspectors identified a Green NCV of TS 6.8.1, Procedures, for Dominions failure to maintain an adequate procedure for reactor filling and draining that incorporates guidance contained in NRC Generic Letter 88-17. Specifically, OP2301E, Draining the RCS, permitted operation in a reduced RCS inventory condition without ensuring redundant means of level indication contrary to the inventory control requirements of OU-M2-201,
Shutdown Safety Assessment Checklist.
The failure to maintain an adequate procedure for operating in reduced inventory conditions is a performance deficiency. The inspectors determined this performance deficiency is more than minor because it is associated with the Initiating Events cornerstone attribute of equipment performance and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, inadequate procedural guidance increased the likelihood that operators could experience a loss of level indication during the reduced inventory condition.
The inspectors evaluated the significance of the finding using IMC 0609 Appendix G,
Shutdown Operations Significance Determination Process, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, and the issue screened to a Phase 2 analysis. Using the guidance contained in IMC 0609, Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, the inspectors worked with regional and headquarters senior reactor analysts to determine the issue screened to
- Green.
The inspectors determined this issue had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, where individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the latent error of considering L-112 and LI-112 as independent level instruments even though a single failure impacted both instruments contributed to the issue [H.12]. (Section 1R20)
REPORT DETAILS
Summary of Plant Status
Millstone Unit 2 and 3 began the inspection period operating at 100 percent power. On April 5, Unit 2 shut down for refueling outage 2R22. Unit 2 returned to 100 percent power on May 19.
On May 25, both units experienced a loss of offsite power and automatically shut down. Unit 2 returned to 100 percent power on May 28. Unit 3 returned to 100 percent power on June
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems
a. Inspection Scope
The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system on May 9 to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Dominions procedures affecting these areas and the communications protocols between the transmission system operator and Dominion. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Dominion established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system engineers, reviewing CRs and open work orders, and walking down portions of the offsite and AC power systems including the 345
[kilovolt] kV switchyard.
b. Findings
No findings were identified.
==1R04 Equipment Alignment
==
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Unit 2
B Service Water (SW) following restoration from maintenance on May 2
Facility 2 Containment Spray following pump overhaul on May 6 Unit 3
Letdown System and Volume Control Tank following restoration from head vent letdown configuration following loss of offsite power and unit trip on May 29 and 30
Motor Driven Auxiliary Feedwater Pump Train B while the Engineered Safety Features B Train was protected on June 3
The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TS, work orders, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Dominion staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On April 19, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 spent fuel pool cooling system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, and equipment line-up check-off lists to verify that the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and work orders to ensure Dominion appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
==1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
==
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Dominion controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 2
Containment, Fire Area C-1 on April 8
Auxiliary Building -45 level on May 23
Main Control Room Area A-25 on June 30
Unit 3
Control Building, Cable Spreading Room 24-6, CB-8 on June 2
Engineered Safety Features Building, North Motor Driven Auxiliary Pump Cubicle 21-6, ESF-8 on June 3
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Annual Review of Cables Located in Underground Bunkers/Manholes
a. Inspection Scope
The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including cable vault 3EMH*1A which contains power cables for the SW system, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged.
The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed. For those cables found submerged in water, the inspectors verified that Dominion had conducted an operability evaluation for the cables and were implementing appropriate corrective actions.
b. Findings
No findings were identified.
==1R08 In-service Inspection (7111108P - 1 sample)
a. Inspection Scope
Unit 2
==
In-service inspection activities detect precursors to pressure boundary failures in the RCS, emergency core cooling systems, risk-significant piping and components, and containment systems. Degradation of pressure retaining components in these systems would result in a significant increase in risk. This inspection is intended to assess the effectiveness of Dominions program for monitoring degradation of vital system boundaries.
Non-destructive Examination Activities and Welding Activities
The inspectors observed the phased array ultrasonic inspection of the Loop 1, Hot Leg drain nozzle safe-end weld. The inspectors observed the scanning of a portion of the nozzle and subsequently reviewed the encoded data, the final report, including disposition of any indications discovered during the examination of the nozzle. The inspectors reviewed the qualification of the personnel performing the examination and compared them against the requirements of American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section XI, Appendix VIII. The inspectors observed the magnetic particle inspection of a weld utilizing a magnetic yoke noting if magnetic field overlap was maintained. The inspectors reviewed the preliminary results of encoded phased array inspection of various cold leg Alloy 600 welds for which the NRC had granted relief from ASME, Boiler and Pressure Vessel Code,Section XI ultrasonic coverage requirements of 100 percent coverage.
Pressurized-Water Reactor (PWR) Vessel Upper Head Penetration Inspection Activities
No inspections were performed by Dominion.
Boric Acid Corrosion Control Inspection Activities
The inspectors observed the condition of pressurized components during a walk-down of containment. The inspectors reviewed the records of boric acid leaks and discussed the programs effectiveness with the program manager. The inspectors verified that degraded or non-conforming conditions are identified properly in Dominions CAP.
Steam Generator (SG) Tube Inspection Activities
The inspectors reviewed Dominion's SG Degradation Assessment required by Dominion Administrative Procedure ER-AP-SGP-101, SG Program. The site specific assessment was compared with the guidance contained in Electric Power and Research Institute "PWR SG Guideline", Revision 7, and Electric Power and Research Institute "SG Integrity Assessment Guidelines", Revision 3. The inspectors compared the site specific assessment with the eddy current inspection plan to determine if the results of the assessment were adequately reflected in the scope of inspection. The inspectors reviewed the plugging history of the SGs. The inspectors reviewed the history of secondary side sludge taken from the generators. These results were compared with the results of plugging and sludge removal at other sites with similar SGs. The inspectors reviewed the results of the eddy current inspection for the current outage.
The inspectors discussed the results of the inspection with Dominion staff and vendor eddy current inspection personnel.
The inspectors reviewed a sample of Dominions vendor Examination Technique Specification Sheets to determine if the eddy current probes and equipment were qualified for detection or sizing of the expected types of tube degradation. In particular, the inspectors focused the review on the site specific factors potentially effecting the qualification of one or more techniques.
There was no in-situ pressure testing. There was no tube leakage prior to the beginning of the outage and no repairs undertaken during this inspection.
The inspectors observed the acquisition and evaluation of eddy current data. During SG eddy current inspection, debris was discovered adhering to the inside surface of tube 49-108 of M2X26, SG #2. The material intruded into the tube internal cavity sufficiently to block the passage of eddy current probes. The inspectors observed the implementation of a retrieval plan, including video probing.
Repair and Replacement
The inspectors reviewed Design Change MP2-11-01093, 2R22 FAC Piping Replacements for Line 18-EBB-6 and 6-EBB-1, Containment Penetration #15 (A-Train) to SG #1, and compared them against the requirements of the ASME Code.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed selected portions of the licensed operator requalification testing and training program.
Unit 2
The inspectors reviewed senior reactor operator (SRO) qualifications for SROs limited to fuel handling operations limited senior reactor operator (LSROs) at Unit 2. The inspectors verified that SROs with inactive licenses had properly reactivated their SRO licenses for fuel handling operations during the last two refueling outages, 2RFO21 (in 2012) and 2RFO22 (during this quarter). The inspectors reviewed the training program requirements, verified that LSROs stood watch under instruction for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and verified that administrative controls were established to prevent LSROs from standing watch as unrestricted SROs in the control room. This inspection effort was coordinated with the Region 1 Branch Chief for Operations.
Unit 3
The inspectors observed licensed operator simulator training on May 22, which included just-in-time training to conduct a downpower from 90 percent power to offline using the hydraulic jack to manually position the B feedwater regulating valve (FRV) and control feedwater flow. The crew attempted to secure a feedwater pump without losing control of SG levels while operating on the jack for the bypass FRV. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal operating procedures (AOPs)and emergency operating procedures (EOPs). The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the TS action statements entered by the shift manager. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed control room activities for a four hour period of time that included infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in Dominions Operations Section Expectations Handbook and Dominions Administrative Procedure OP-AA-106, Infrequently Conducted or Complex Evolutions, Revision 9.
Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
Unit 2
Startup activities and low power physics testing in the Unit 2 main control room at the completion of refueling outage 2R22 on May 16 through 17
Unit 3
Control room activities during the replacement of the B FRV positioner on May 23
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that Dominion was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)
- (2) performance criteria established by Dominion staff was reasonable. Additionally, the inspectors ensured that Dominion staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Unit 3
A Low Pressure Turbine Atmospheric Relief Diaphragm actuation on May 26
Instrument air system on June 30
Station Blackout Diesel Reliability on June 30
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Dominion performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Dominion personnel performed risk assessments as required by 10 CFR 50.65(a)
- (4) and that the assessments were accurate and complete. When Dominion performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Unit 2
2R22 Pre-Outage Shutdown Safety Assessment on April 3
Yellow Risk Assessment for RCS Drain Down to Decreased Inventory on April 8
Orange Risk Associated with Maintenance on Shutdown Cooling Valves on April 18 Yellow Risk Associated with the North Bus Outage on June 19
Unit 3
Emergent work risk assessment for B FRV Failing to Modulate on May 21
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Unit 2
OD 000587, Unit 2 supply piping to the Emergency Diesel Generator (EDG) on April 28
Unit 3
CR547492, B FRV will not close in manual on May 3
OD000590, Basis for operability of the MP3 Turbine Driven Auxiliary Feedwater (TDAFW) pump following the loss of offsite power reactor trip on May 25
The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Dominions evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Dominion. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Specific concerns associated with discharge pressure oscillations were referred to the Special Inspection Team for review.
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Modifications
a. Inspection Scope
The inspectors evaluated the below modifications and verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modifications.
Unit 2 design modification to replace the low pressure safety injection (LPSI) line check valve, 2-SI-227 in design change MP2-13-01062, Replacement of 2-SI-227 B Safety Injection Non-Return Check Valve, on May 10. In addition, the inspectors reviewed modification documents associated with the design change including the Final Safety Analysis Report (FSAR) design basis, restoration of compliance with Generic Letter 87-06 commitments for leak tight integrity, welding process documents, alarm response procedure changes, operational decision making documents, and post-modification testing documents. The inspectors observed the post-maintenance testing and interviewed design engineering personnel involved in the installation and testing of 2-SI-227.
Unit 2 modification to the Control Element Assembly Position Display System (CEAPDS) in design change MP2-12-01148, CEAPDS Replacement, on May 15.
The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including the 50.59 Evaluation, cyber security plan, procedures for the control of portable media devices, and post-modification testing documents. The inspectors also interviewed design engineering personnel to ensure that the pulse counting position indication system remained independent from CEAPDS.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
Unit 2
SW Temperature Control Valve, 2-SW-8.1C, following deflector plate modification on April 30
201B Battery following replacement of cells 6 and 27 on April 29
B EDG following overhaul on May 2
Motor driven auxiliary feedwater pump P9B following overhaul on May 11
B Containment Spray Pump following overhaul on May 11
2-SI-227 check valve following valve replacement on May 21
RCS Beyond Design Basis connections following modifications on May 8
Normal Service Station Transformer following modification on May 3
Unit 3
A SW pump after impeller was trimmed on April 8
Failed Pressurizer Pressure Card RCS*PB457B on April 29
Repairs to the B FRV positioner on May 23
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage activities for one refueling outage on Unit 2 and one forced outage on Unit 3.
Unit 2
The inspectors reviewed the stations work schedule and outage risk plan for the Unit 2 maintenance and refueling outage 2R22, which was conducted April 5 through May 19.
The inspectors reviewed Dominions development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:
Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment out of service
Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing
Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting
Status and configuration of electrical systems and switchyard activities to ensure that TSs were met Monitoring of decay heat removal operations
Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system
Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss
Activities that could affect reactivity
Maintenance of secondary containment as required by TS
Refueling activities, including fuel handling and fuel receipt inspections
Fatigue management
Tracking of startup prerequisites, walkdown of the primary containment to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation
Identification and resolution of problems related to refueling outage activities
Unit 3
From May 25 until June 2, Unit 3 experienced a forced outage that was caused by a loss of offsite power. Complications during the event required Unit 3 to cooldown to Mode 4 in order to conduct repairs on several components that had been damaged during the event. These included;
Replacement of the Pressurizer Relief Tank Rupture Disk
Containment inspection
Troubleshooting and repairs for excessive pressurizer power operated relief valve leakage
Troubleshooting and repairs for a loss of instrument air
Replacement of the low pressure turbine rupture disk
Repairs to the reactor head vent pipe hangar that had been disrupted during the event
During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:
Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TS when taking equipment out of service
Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing
Status and configuration of electrical systems and switchyard activities to ensure that TS were met
Monitoring of decay heat removal operations
Activities that could affect reactivity
Maintenance of secondary containment as required by TS
Tracking of startup prerequisites and startup and ascension to full power operation
Identification resolution of problems related to outage activities
All repairs were completed and Unit 3 was synchronized to the grid on June 2 at 9:43 PM and returned to 100 percent power on June 4 at 2:00 PM.
b. Findings
Introduction.
The inspectors identified a Green NCV of TS 6.8.1, Procedures, for Dominions failure to maintain an adequate procedure for reactor filling and draining that incorporates guidance contained in NRC Generic Letter 88-17. Specifically, OP2301E, Draining the RCS, permitted operation in a reduced RCS inventory condition without ensuring redundant means of level indication contrary to the inventory control requirements of OU-M2-201, Shutdown Safety Assessment Checklist.
Description.
On May 10, Dominion terminated the vacuum fill of the RCS during the refueling outage at Unit 2 based on unexpected indications of RCS level. During the investigation which followed, operators determined that 2-RC-419, pressurizer and head vent, was open when it should have been closed. In addition, 2-EB-81, the reactor head/pressurizer vent to enclosure building filtration system drain, was tagged open and uncapped when it should have been closed and capped in support of the vacuum fill activity. This left an open pathway which caused an unexpected d/p across the level instrumentation, which indicated a drop in level in the control room instrumentation display (no actual water level drop occurred). The troubleshooting and recovery activities also created a delay which extended the orange shutdown risk window for RCS decay heat removal.
In 1988, the NRC issued Generic Letter 88-17 to communicate recommendations to remediate concerns about loss of decay heat removal capability during shutdown operations and to request information from licensees on how the agencys recommendations would be implemented at each site. OU-M2-201, Shutdown Safety Assessment Checklist, Attachment 5, Revision 12, lists inventory control requirements during an outage as: At least one (two if in Reduced Inventory Operations) RCS level monitor systems should remain available at all times. To satisfy the requirements of Generic Letter 88-17 and OU-M2-201 for level indication and during times of reduced inventory, Dominion committed to three potential level indications: LI-112 (number 1 hot leg RCS mid-loop level indicator), L-112 (RCS mid-loop wide range RCS level transmitter), and L-122 (number 2 hot leg narrow range level instrument). LI-112 and L-112 share a common sensing line and therefore both were susceptible to the unexpected d/p caused by the 2-RC-419 valve being out of position. The L-122 instrument had experienced prior failures earlier in the outage and exhibited erratic indications throughout the evolution, so it could not be considered a reliable alternative level indication during this event.
Procedure OP 2301E, Draining the RCS, Revision 025-02, step 4.1.12 states that operators must verify at least two of the following independent RCS monitoring systems are in service (LI-112, L-112, L-122). As demonstrated in the events of May 10, this does not ensure the requirements of the Generic Letter are met because these are not independent indications as two of the instruments share a common sensing line.
Analysis.
The failure to maintain an adequate procedure for operating in reduced inventory conditions is a performance deficiency which was within Dominions ability to foresee and correct. The inspectors determined this performance deficiency is more than minor because it is associated with the Initiating Events cornerstone attribute of equipment performance and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, inadequate procedural guidance increased the likelihood that operators could experience a loss of level indication during the reduced inventory condition. The inspectors evaluated the significance of the finding using IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, and the issue screened to a Phase 2 analysis. Using the guidance contained in IMC 0609, Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, the inspectors worked with regional and headquarters senior reactor analysts to determine the issue screened to Green.
The inspectors determined this issue had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, where individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the latent error of considering L-112 and LI-112 as independent level instruments even though a single failure impacted both instruments contributed to the issue [H.12].
Enforcement.
TS 6.8.1, Procedures, requires that written procedures be established, implemented, and maintained for activities described in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements. Specifically, Section 3 of Regulatory Guide 1.33, Appendix A includes draining and filling the RCS. Contrary to the above, on May 10, the inspectors identified that OP 2301E was not appropriately maintained and permitted reactor operation in reduced level inventory condition without redundant means of level indication contrary to the requirements of OU-M2-201, Shutdown Safety Assessment Checklist. Because this violation was of very low safety significance (Green) and was entered into the CAP as CR 548409 and CR 553383, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000336/2014003-01, Failure to Maintain Adequate Procedure for RCS Drain/Fill)
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Dominion procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Unit 2
SP 2402I, Low Temperature/Over Pressure Circuitry Functional Test, Revision 010-02 on April 3
SP 2730B-001, Main steam Safety Valve Testing, Revision 011-01 on April 3
SP 2613H, Integrated Test of Facility Components, Revision 013-01 on April 29 OP 2307X00-001, LPSI Flow Verification, Defueled, Revision 000-01 on May 1
SP 2613K, Diesel Generator Slow Start Operability Test, Facility 1, Revision 005-04 on June 4
Unit 3
SP 3646A.2, B EDG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run on April 10
SP 3622.3, 3FWA*P2 Operational Readiness Test on June 1
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Dominion implemented various changes to the Millstone EALs, Emergency Plan, and Implementing Procedures. Dominion had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.
The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Dominion as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report (SER) and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public and Occupational Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
During April 21 - 25, 2014, the inspectors reviewed and assessed Dominions performance in assessing the radiological hazards and exposure control in the workplace.
The inspectors used the requirements in 10 CFR 20 and guidance in Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas (VHRA) for Nuclear Plants, TS, and Dominions procedures required by TS as criteria for determining compliance.
Inspection Planning
The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection.
Radiological Hazard Assessment
The inspectors selected the following risk-significant work activities that involved exposure to radiation.
Replacement of the 2-SI-227 valve
Entry into the reactor cavity and saddle areas
SG primary side inspection
Radiography in support of feed-water piping replacement
For these work activities, the inspectors assessed whether the pre-work surveys performed were appropriate to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the radiological survey program to determine if radiological hazards were properly identified (e.g., discrete radioactive hot particles, transuranics and hard to detect nuclides in air samples, transient dose rates, and large gradients in radiation dose rates).
The inspectors observed work in potential airborne radioactivity areas and evaluated whether the air samples from the 2-SI-227 valve, the south saddle area entry, and an event documented in CR544789 were properly evaluated. The inspectors evaluated whether continuous air monitors were representative of actual work areas and had adequate radiation detection sensitivity. The inspectors evaluated the Dominion program for monitoring levels of loose surface contamination in areas of the plant.
Instructions to Workers
The inspectors reviewed the RWP used to access high radiation areas (HRAs) and evaluated if the specified work control instructions and control barriers were consistent with TS requirements for HRA.
For these RWPs, the inspectors assessed whether allowable stay times or permissible doses for radiologically work under each RWP were clearly identified. The inspectors evaluated whether electronic personal dosimeter (EPD) alarm set-points were in conformance with survey indications and plant procedural requirements.
For work activities that could suddenly increase radiological conditions, the inspectors assessed Dominions means to inform workers of these changes.
Radiological Hazards Control and Work Coverage
The inspectors evaluated the adequacy of radiological controls, required surveys, radiation protection job coverage, and contamination controls. The inspectors evaluated Dominions use of EPDs in high noise areas that were also HRAs.
The inspectors assessed whether radiation monitoring devices were placed on the individuals body consistent with procedures. The inspectors assessed whether the dosimeter was placed in the location of highest expected dose or that Dominion implemented an NRC-approved method of determining effective dose equivalent.
The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in high-radiation work areas with dose rate gradients.
The inspectors reviewed RWPs for work within a potential airborne radioactivity area, with the potential for individual worker internal exposures.
For these RWPs, the inspectors evaluated airborne radioactive controls and monitoring, including potential for significant airborne levels. The inspectors assessed applicable containment barrier integrity and the operation of temporary high-efficiency particulate air ventilation systems.
VHRA Controls
The inspectors evaluated Dominions controls for VHRAs and areas with the potential to become a VHRA to ensure that an individual was not able to gain unauthorized access to these VHRAs.
Radiation Worker Performance
The inspectors observed the performance of radiation workers with respect to radiation protection work requirements. The inspectors assessed whether workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place, and whether their behavior reflected the level of radiological hazards present.
Radiation Protection Technician Proficiency
The inspectors observed the performance of the radiation protection technicians with respect to controlling radiation work. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the RWP controls/limits, and whether their behavior was consistent with their training and qualifications with respect to the radiological hazards and work activities.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
During April 21 - 25, 2014, the inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures ALARA. The inspectors used the requirements in 10 CFR 20, Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be ALARA, Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure ALARA, TS, and Dominion procedures required by TS as criteria for determining compliance.
Inspection Planning
The inspectors reviewed information regarding Millstones collective dose history, current exposure trends, and planned radiological work activities in order to assess current performance and exposure challenges. The inspectors reviewed the plants three year rolling average collective exposure.
The inspectors reviewed any changes in the radioactive source term by reviewing the trend in average contact dose rate with reactor coolant piping.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA, and for processes used to estimate and track exposures from specific work activities.
Radiological Work Planning
The inspectors assessed whether Dominions planning identified appropriate dose reduction techniques; considered alternate dose reduction features; and estimated reasonable dose goals. The inspectors evaluated whether Dominions ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices and/or heat stress mitigation equipment. The inspectors determined whether work planning considered the use of remote technologies as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors assessed the integration of ALARA requirements into work procedure and RWP documents.
Radiation Worker Performance
The inspectors observed radiation worker and radiation protection technician performance during work activities being performed in radiation areas, airborne radioactivity areas, and HRAs. The inspectors evaluated whether workers demonstrated the ALARA philosophy in practice and whether there were any procedure or RWP compliance issues.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
During April 21 - 25, 2014, the inspectors verified in-plant airborne concentrations are being controlled consistent with ALARA principles and the use of respiratory protection devices on-site does not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR 20, the guidance in Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection, Regulatory Guide 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, TS, and Dominion procedures required by TS as criteria for determining compliance.
Inspection Planning
The inspectors reviewed reported performance indicators to identify any related to unintended dose resulting from intakes of radioactive material.
Use of Respiratory Protection Devices
The inspectors selected two work activities where respiratory protection devices were used to limit the intake of radioactive materials and assessed whether Dominion performed an evaluation concluding that further engineering controls were not practical and that the use of respirators is ALARA. The inspectors also evaluated whether Dominion had established means (such as routine bioassay) to determine if the level of protection (protection factor) provided by the respiratory protection devices during use was at least as good as that assumed in Dominions work controls and dose assessment.
The inspectors assessed whether respiratory protection devices were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration, or have been approved by the NRC. The inspectors evaluated whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification or NRC approval.
b. Findings
Introduction.
A self-revealing Green NCV of TS 6.8.1, Procedures, was identified for Dominions failure to utilize respiratory protection, as required in the applicable RWP and as required in the associated ALARA evaluation, for work on the replacement of the 2-SI-227 valve.
Description.
A Total Effective Dose Equivalent (TEDE) ALARA review was previously performed by radiation protection staff to evaluate the use of respiratory protection for the 2R22 refueling outage. This evaluation, dated March 21, 2014, concludes that work on replacement of the 2-SI-227 valve is to be performed with respiratory protection.
RWP 2140402, Revision 1, task 2, Respiratory Requirements states: Respiratory protection - PAPH or equivalent - required for entry into the valves contamination control enclosure (tent), just prior to valve or loop piping is breached, and worn inside the tent until conditions no longer warrant.
Dominion initiated work to replace the Unit 2 1B Safety Injection Non-Return Check Valve (2-SI-227) during the 2R22 refueling outage. On April 20, 2014, two contractors entered the tent and began machining the open ends of the contaminated piping as part of preparations for welding-in a new valve. Radiation protection personnel overseeing the work specified that respiratory protection was not required for this evolution, although powered air purifying hoods had been previously worn during valve removal and piping decontamination. This determination (to not wear respirators) was not documented.
The levels of loose surface contamination on the interior surfaces of the piping ranged from 40,000 dpm/100cm2 beta/gamma to 120,000 dpm/100cm2 beta/gamma, with low levels of alpha contamination. The machining operation included beveling of the pipe ends, and a slight counter-bore of the piping interior. An interview with one machinist indicated that this counter-bore operation was a skim cut; producing a fine, dust-like material. These levels of loose surface contamination were considered high given the type of work being performed.
Upon completion of the planned work, one machinist alarmed the personnel contamination monitor while exiting the radiologically controlled area. Follow-up investigation revealed that the technician had a positive whole-body count and that an intake of radioactive material had occurred as a result of the subject work. Subsequent whole-body counts confirmed that an internal exposure to the individual had occurred.
Subsequent work following the unplanned internal exposure was performed in respiratory protection, as required.
Analysis.
Failure to use respiratory protection during machining work on valve 2-SI-227 contaminated piping on April 20, 2014, as required by RWP 2140402, Revision 1, task 2, was a performance deficiency that was reasonably within Dominions ability to foresee and correct.
The inspectors determined that the performance deficiency was more than minor because it affected the Radiation Safety - Occupational Radiation Safety Cornerstone.
Specifically, the Program and Process attribute of exposure/contamination controls, because the performance deficiency resulted in the unintended internal exposure of a worker.
Failure to implement the requirements of the RWP and the TEDE ALARA review is a violation of NRC requirements. Traditional enforcement does not apply because the issue did not have any actual safety consequences or the potential for impacting the NRCs regulatory function, and was not the result of any willful violation of NRC requirements.
The finding was assessed using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated June 2, 2011, and was determined to be of very low safety significance (Green) because: it was not related to ALARA; did not result in an overexposure or a substantial potential for overexposure; and did not compromise the licensee's ability to assess dose. A single worker was affected by the event, and the estimated internal dose to the worker is a small fraction of the annual occupational exposure limit.
A cross-cutting aspect of Human Performance, Conservative Bias, was associated with the finding. Specifically, radiation protection staff did not adhere to the RWP requirements, followed by: conservative decision making that emphasized prudent choices in the evaluation of radiological conditions, the assessment of the hazards from planned work, and the decision to forego respiratory protection during work (which included counter-boring the interior surface of primary system piping) [H.14].
Enforcement.
TS 6.8.1 requires that written procedures shall be established, implemented and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 1. RWPs and ALARA procedures are specified in Appendix A. RWP 2140402, Revision 1, task 2, and the TEDE ALARA review specified the use of respiratory protection for work on valve 2-SI-227 replacement work.
Contrary to this requirement, respirators were not worn for work on the 2-SI-227 valve on April 20, 2014; resulting in an unplanned internal exposure as required by the RWP and the TEDE ALARA review. Because this violation was of very low safety significance (Green) and was entered into the CAP as CR 546439, this violation is being treated as a NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV
===05000336/2014003-02, Failure to Utilize Respiratory Protection as Specified in Work Control Documents)
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with
Complications===
a. Inspection Scope
The inspectors reviewed Dominions submittals for the following Initiating Events Cornerstone performance indicators for the period April 1, 2013 through March 30, 2014.
Unit 2
Unplanned Scrams per 7000 Critical Hours
Unplanned Scrams with Complications
Unplanned Transients per 7000 Critical Hours
Unit 3
Unplanned Scrams per 7000 Critical Hours
Unplanned Scrams with Complications
Unplanned Transients per 7000 Critical Hours
To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed Dominions operator narrative logs, maintenance planning schedules, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Dominion entered issues into their CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Dominion outside of the CAP, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Dominions CAP database for the first and second quarters of 2014 to assess CR written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed the effective implementation of corrective actions for several significant conditions adverse to quality, including the recent TDAFW pump overspeed and related performance events.
b. Findings and Observations
No findings were identified.
Corrective actions assigned to the TDAFW pump discharge flow control valves, 3FWA*HCV36A, B, C, and D, following a series of overspeed trips have not yet been adequately implemented. Recent operational events have demonstrated that the operators are required to limit the rate at which they close these valves when the TDAFW pump is operating at low flow conditions to avoid challenging or exceeding the 3FWA*RV45 relief valve setpoint. Operations standing order (SO)14-004 was promulgated in January to direct operators to limit the rate at which these valves were closed to no faster than 15 seconds. This SO, while still in effect, was implemented under a 50.59 screen which concluded that an evaluation was not required. Dominion is committed to NEI 96-07, as endorsed by Regulatory Guide 1.187. Example 4.2.1.2 from this document states that any changes to emergency operating procedures (EOPs) that affect how SSC design functions are controlled in an adverse manner should be screened in.
The inspectors have not determined that, if a 50.59 evaluation had been completed, it would reasonably meet the standard that NRC approval would be required for implementation and hence the observation does not rise above the threshold of a finding. Dominion CR 555213 was initiated to address this issue.
In addition, these actions have not yet been incorporated into the required EOPs and remain as a knowledge-based action that is not procedurally directed. OP-AA-100, Conduct of Operations, states that Periodic reviews of Standing Orders ensure that they are removed in a timely manner (typically within six months). Current plans are to implement a design change to reduce the speed of the TDAFW pump to improve margin which would make this EOP change unnecessary. Dominion is assessing this condition and is considering a design change that, if implemented during the next outage, would make the EOP change unnecessary. The inspectors will continue to follow up on this issue.
.3 Annual Sample: Review of the Operator Workaround Program
a. Inspection Scope
The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on EOP operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in Dominion procedure OP-AA-1700.
The inspectors reviewed Dominions process to identify, prioritize, and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent Dominion self-assessments of the program. The inspectors also toured the control rooms and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance. The inspectors fulfilled two inspection samples for the Review of the Operator Workaround Program during this quarter.
b. Findings and Observations
No findings were identified.
The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement AOPs or EOPs. The inspectors also verified that Dominion entered operator workarounds and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.
.4 Annual Sample: Review of the Request for Engineering Assistance Program
a. Inspection Scope
The inspectors reviewed the Request for Engineering Assistance (REA) process to determine if Dominion appropriately identified, classified, and prioritized issues for implementation of future modifications or plant design changes. The inspectors reviewed process documents and compared the project lists with information in the CAP database to ensure that Dominion was appropriately entering and tracking conditions adverse to quality in the CAP. The inspectors reviewed REA procedures to ensure appropriate guidance existed in the documentation to ensure consistent application of the process. The inspectors interviewed cognizant personnel to understand their perceptions of the process and its use.
b. Findings and Observations
No findings were identified.
The inspectors determined that the process to characterize issues as REA appeared to be appropriate and was generally effective. The inspectors noted there had been several problems prior to 2013 where the REA process was inappropriately used to track corrective action assignments. This situation was problematic because REA actions could be cancelled without the level of management involvement that would be appropriate if Dominion were to cancel a corrective action for a condition adverse to quality. This issue appears to be corrected as a result of Dominions actions taken in response to [self-assessment report] SAR002556, Request for Engineering Assistance (REA) Process Self-Assessment. The inspectors did not identify any existing REAs without corresponding corrective action assignments at the time of the inspection.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Dominion made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Dominions follow-up actions related to the events to assure that Dominion implemented appropriate corrective actions commensurate with their safety significance.
Dual Unit Loss of Offsite Power on May 25
On May 25, both Millstone 2 and 3 shut down due to a loss of off-site power. Both units experienced a reactor trip and a loss of condenser vacuum. Unit 2 recovered the plant in mode 3 (hot shutdown) with few complications. Additional complications at Unit 3 included a main steam isolation signal due to a steam leak in the turbine building and an unexpected loss of instrument air pressure. The loss of instrument air pressure led to the inability to maintain a normal RCS letdown flow path, which resulted in the necessary diversion of letdown through the reactor head vent into the pressurizer relief tank (PRT). After the PRT exceeded rated pressure, the PRT rupture disk opened as designed and reactor coolant drained into the containment building basement and collected in the structures sump system. During the restoration of instrument air pressure, a relief valve on the units volume control tank lifted as the normal drainage flow path was being restored causing the primary drains transfer tank to overflow inside the auxiliary building. The NRC decided to conduct a Special Inspection to review the event and dispatched an inspection team to the site on June 2. The results of this inspection will be communicated in an inspection report to be issued within 45 days following the final exit meeting for the inspection.
b. Findings
No findings were identified.
The Special Inspection Team will review Dominions performance and develop any necessary findings for this event.
.2 (Closed) Licensee Event Report (LER) 05000423/2013-009-00: Secondary Containment
Boundary Breach Could Have Prevented Safety Function
On November 19, 2013, Dominion personnel found a security door in the Unit 3 auxiliary building unlatched during a routine check of door seals. This door is a supplemental leak collection release system boundary door and is part of the secondary containment boundary. The door was successfully latched immediately upon discovery. On November 20, 2013, operators determined that the unlatched door resulted in a condition that could have prevented the fulfillment of the safety function of a structure needed to control the release of radioactive material. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
4OA5 Other Activities
.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI) at Operating Plants
(60855 and 60855.1)
a. Inspection Scope
The inspectors evaluated Millstones activities related to long-term operation and monitoring of their ISFSI, and verified that activities were being performed in accordance with the Certificate of Compliance (CoC), TS, regulations, and site procedures.
The inspectors performed tours of the ISFSI pad to assess the material condition of the pad and the loaded horizontal storage modules (HSMs). The inspectors also verified that transient combustibles were not being stored on the ISFSI pad or in the vicinity of the HSMs. The inspectors verified that Millstone was performing daily HSM surveillances in accordance with TS requirements, in addition to the periodic monitoring of the condition of the pad and HSM exterior surfaces.
The inspectors interviewed corporate spent fuel group personnel and reviewed Millstones program associated with fuel characterization and selection for storage from the last ISFSI loading campaign in 2012. The inspectors verified that the criteria meets the conditions for cask and canister use as specified in the CoC. The inspectors also confirmed that physical inventories were conducted annually and were maintained as required by the regulations.
The inspectors reviewed radiological records from the last ISFSI loading campaign to confirm that radiation and contamination levels measured on the casks were within limits specified by the TS and consistent with values specified in the FSAR. The inspectors reviewed radiation protection procedures associated with ISFSI operations. The inspectors also reviewed annual environmental reports to verify that areas around the ISFSI pad and the ISFSI site boundary were within limits specified in 10 CFR 20 and 10 CFR 72.104.
The inspectors reviewed CRs and the associated follow-up actions associated with ISFSI operations to ensure that issues were entered into their CAP, prioritized, and evaluated commensurate with their safety significance.
b. Findings
No findings were identified
.2 License Renewal Inspection
a. Inspection Scope
During the 2R22 refueling outage the inspectors sampled from ongoing activities related to license renewal. The inspectors observed activities in the field related to the internal inspection of 2A feedwater heater under work order 53102297084 and tan-delta testing of electrical cables under work order 53102593047.
b. Findings
No findings were identified.
In addition, the inspectors reviewed three commitments related to the Tank Inspection Program, as follows:
Commitment 22: Appropriate inspections of sealants and caulking used for moisture intrusion prevention in and around aboveground tanks will be performed.
a. Inspection Scope
The inspectors reviewed the License Renewal Application (LRA) and associated SER for the Tank Inspection Program and the program procedures for both units. The inspectors walked down the accessible parts of the Unit 2 condensate storage tank (CST), refueling water storage tank (RWST), and primary water storage tank (PWST), and reviewed the results of the external tank inspections and CRs for these tanks.
The inspectors noted that inspection guidance related to sealants and caulking in the inspection plans was not specific as to what aspects to inspect or acceptance criteria.
Further, the RWST and PWST appeared to be of a similar design and had similar sealants and caulking; nonetheless, the inspection plans for the tanks were inconsistent.
Dominion initiated CRs 544498 and 545500 to address these deficiencies.
b. Findings
No findings were identified.
The inspectors determined that implementation of Commitment 22 should be reviewed during a future NRC license renewal inspection regarding sealant and caulk acceptance criteria.
Commitment 23: Non-destructive volumetric examination of the in-scope inaccessible locations, such as the external surfaces of tank bottoms, will be performed prior to the period of extended operation. Subsequent inspections will be performed on a frequency consistent with scheduled tank internals inspection activities.
a. Inspection Scope
The inspectors reviewed the LRA and SER for the Tank Inspection Program and the program procedures for both units. The inspectors walked down the accessible parts of the Unit 2 CST, RWST, and diesel fire pump fuel oil tank, and reviewed the results of the tank bottom inspections and CRs for these tanks.
On the Ultrasonic Examination Data Sheet for the diesel fire pump tank inspection completed on April 12, 2012, the inspectors noted that there was no acceptance criterion. Further, EN 31154, Tank Inspection Plan, stated that thickness results should be within 10 percent of nominal thickness. The inspectors determined that the diesel fire pump tank minimum thickness of 0.111 inches was greater than 10 percent below the measured average thickness of 0.125 to 0.128 inches, and no action had been taken to address this result. Dominion initiated CR 544492 to address this issue.
b. Findings
No findings were identified.
The inspectors determined that implementation of Commitment 23 should be reviewed during a future license renewal inspection to determine actions taken by Dominion regarding tank thickness acceptance criteria and evaluation of results.
Commitment 24: The security diesel fuel oil tank and diesel fire pump fuel oil tank are in-scope for license renewal and will be included on the respective Tank Inspection Program inspection plan.
a. Inspection Scope
The inspectors reviewed the LRA and SER for the Tank Inspection Program and the tank inspection plan procedures for both units. The inspectors walked down the accessible parts of the security diesel fuel oil tank and diesel fire pump fuel oil tank, and reviewed the results of the tank inspections and CRs for these tanks. The inspectors noted that EN 21154A, Tank Inspection Plan, Attachment 5 listed two security diesel fuel oil tanks, though only one tank existed. (The prior security diesel had been replaced by a newer security diesel.) Dominion initiated CR 544488 to address this discrepancy.
b. Findings
No findings were identified.
The inspectors determined that implementation of Commitment 24 should be reviewed during a future license renewal inspection to determine Dominion actions taken for the identified discrepancy.
.3 (Closed) Unresolved Item (URI) 05000336&423/2013005-01, Implementation of NEI 99-
01 Guidance
a. Inspection Scope
During a previous inspection of Dominions corrective actions for two NCVs related to their EALs, the inspectors identified what had appeared to be inadequacies with two EALs (EU1.2 and EA2.1) that would be implemented during refueling operations. These issues were initially assessed by the inspectors as possible industry-wide generic issues. Given the possibility of a generic issue, the inspectors concluded that inspection with an URI pending further detailed review by the NRC staff. Since that inspection, the NRC has determined that no generic issues exist. Thus, this inspection closed the URI and assessed the enforcement aspect of the finding.
b. Findings
Introduction.
The inspectors identified a Green NCV associated with emergency planning standard 10 CFR 50.47(b)(4) and the requirements of Sections IV.B and IV.C of Appendix E to 10 CFR Part 50. Specifically, Dominion did not maintain in effect the Millstone Units 2 and 3 EAL schemes for assessing a loss of core cooling during refueling operations.
Description.
During a problem identification and resolution sample inspection in December 2013 that reviewed Dominions corrective actions for two NCVs related to their EALs, the inspectors identified inadequacies with two EALs that would be implemented during refueling operations. Specifically, for both Units 2 and 3, with a loss of forced flow or shutdown cooling during refueling, there would be no temperature indication readily available in the control room because no RCS water would be forced past the instrumentation which was located in the shutdown cooling or residual heat removal systems. Furthermore, during refueling, the core exit thermocouples are not available. Therefore, with no temperature indication available, operators would not be able to directly determine if the criteria for an Unusual Event (loss of cold shutdown function) as indicated by EU1.2 (Uncontrolled RCS temperature increase > 10°F) or an Alert (inability to maintain cold shutdown) as indicated by EA2.1 (Uncontrolled RCS temperature increase > 10°F that results in RCS temperature > 200°F) had been met.
The preliminary NRC staff assessment at that time was that this issue appeared to be an industry-wide generic issue pertaining to these two EALS and therefore this issue at Millstone was considered to be an URI.
Following the December 2013 inspection, regional NRC staff requested that NRC staff from the Office of Nuclear Security and Incident Response (NSIR) assess the generic nature of this issue. NSIRs review determined that this was not a generic issue.
Licensees are required, by 10 CFR 50.54(q)(2), to maintain the effectiveness of the emergency plans. EALs use site specific instrumentation, or other indications, that are representative of a particular IC. When plant conditions change, or instruments fail, licensees are required to implement compensatory measures until the specific instrument, or indication, is returned to service. In Mode 5 or 6, accurate RHR temperature indication would not be available if shutdown cooling was lost and the plant could not maintain cold shutdown.
Upon further review by the regional NRC staff, it was determined that Dominion did not adequately implement the EAL scheme to which they are committed. Specifically, Dominion is committed to NUMARC/NESP-007 EAL methodology. Revision 3 of Regulatory Guide 1.01, Emergency Planning and Preparedness for Nuclear Power Reactors, endorsed the NUMARC/NESP-007, Methodology for Development of Emergency Action Levels. For System Malfunctions (Equipment Failure) pertaining to the Inability to Maintain Cold Shutdown, NUMARC/NESP-007, specifically stated that Site specific indicators for these EALs are those methods used by the plant in response to Generic Letter 88-17 which include core exit temperature monitoring and RCS water level monitoring. Dominion did not use the core exit thermocouples indications (which are not in service in Mode 6). They did include RCS water level in EAL RA1 but they established EALs that were unrepresentative of refueling operations. The Alert EAL would only be met if spent fuel is exposed from an open vessel and the spent fuel has decayed for greater than 30 days. These conditions do not exist in Mode 6 when they are refueling the core.
In response to two previous NCVs for ineffective EALs, Dominion conducted a self-assessment in 2013 of the extent of condition for potential additional EALs that could not be declared from the indications available to the operators. This self-assessment did not identify these EALs as being ineffective.
Dominion initiated CR 534421 in response to this finding and implemented interim corrective actions which included making immediate changes to AOP 3561, Loss of Reactor Plant Component Cooling Water, AOP 2572, Loss of Shutdown Cooling, and EOP 3505, Loss of Shutdown Cooling and/or RCS Inventory, that direct operators for both units to their respective shutdown safety assessment checklists to determine representative RCS temperature increases based on time without shutdown cooling in service in order to assess the ICs for EALs EU1.2 and EA2.1.
Analysis.
The inspectors determined that the failure by Dominion to provide site specific criteria for operators to adequately implement the EALs for a loss of shutdown cooling during refueling was a performance deficiency that was reasonably within their ability to foresee and prevent. The finding is more than minor because it is associated with the Procedure Quality attribute of the Emergency Preparedness Cornerstone and affected the cornerstone objective to ensure that Dominion is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, Dominions ability to classify an Unusual Event or an Alert for an uncontrolled RCS heat up event was adversely affected because of the lack of site specific criteria to assess RCS temperature.
In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination, issued February 24, 2012, and Table 5.4-1, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was an issue where two EAL ICs had been rendered ineffective such that an Unusual Event and an Alert would not be declared, or declared in a degraded manner for a loss of shutdown cooling during refueling. During such an event, AOPs would have directed operators to implement the EALs but without specific direct temperature indication or procedural guidance, operators would have had to recognize that RHR loop temperature was not increasing as expected and manually calculate the RCS temperature to determine of the EAL thresholds had been exceeded. The inspectors determined that operators would have been able to make an appropriate declaration, but in a degraded manner because it would not be timely. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Identification, in that Dominion did not implement a CAP with a low threshold for identifying issues.
Specifically, Dominions self-assessment for two previous NCVs regarding EAL deficiencies failed to identify the lack of specific criteria to assess the ICs for EALs EU1.2 and EA2.1 for a loss of shutdown cooling during refueling [P.1].
Enforcement.
10 CFR 50.54(q)(2) requires, in part, that a licensee shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this Part and, for nuclear power reactor licensees, the planning standards of § 50.47(b). 10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification and action level scheme is in use by the licensee, the bases of which include facility system and effluent parameters. Contrary to the above, Dominion did not follow and maintain an emergency plan using a standard emergency classification and action level scheme. Specifically, Dominion did not implement EALs that contained adequate parameter indication to assess Equipment Failure Initiating Conditions for EU1.2 and EA2.1 in the Unit 2 and Unit 3 EAL tables. As a result, this deficiency adversely affected Dominions ability to classify an emergency event involving an uncontrolled RCS temperature rise caused by a loss of forced flow cooling during refueling. Because this issue was of very low safety significance (Green) and has been entered into the CAP (CR534421), this issue is being treated as an NCV, consistent with Section 2.3.2 of the NRCs Enforcement policy. (NCV 05000336/2014003-03 and 05000423/2014003-03, Failure to Adequately Maintain EALs).
4OA6 Meetings, Including Exit
On July 30, 2014, the inspectors presented the inspection results to Mr. Stephen E. Scace, Site Vice President, and other members of the Millstone staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
R. Acquaro
Unit 3 Shift Manager
M. Adams
Plant Manager
L. Armstrong
Director, Nuclear Station Safety & Licensing
G. Auria
Nuclear Chemistry Supervisor
R. Baker
Senior Quality Control Inspector
B. Bartron
Supervisor, Licensing
A. Bassham
Manager, Corrective Actions Process
P. Baumann
Manager, Nuclear Protection Services
J. Beaudoin
Unit 3 Control Operator
T. Berger
Unit 3 Shift Manager
G. Blackburn
Assistant Maintenance Manager
R. Borchart
Consulting Engineer
B. Bowen
Health Physics Shift Supervisor
M. Brehler
Senior NDE Inspector
D. Brown
Nuclear Excellence Team, Manager of Operations
C. Chatman
Unit 3 Shift Manager
W. Chestnut
Supervisor, Nuclear Shift Operations Unit 2
M. Ciccone
Unit 2 Shift Technical Advisor/Unit Supervisor
F. Cietek
Nuclear Engineer, Probabilistic Risk Assessment
T. Cleary
Licensing Engineer
G. Cloutier
Unit One Supervisor
G. Closius
Licensing Engineer
L. Crone
Supervisor, Nuclear Chemistry
J. Curling
Manager, Protection Services
T. Davis
Engineering Supervisor
S. Deboe
Unit 2 Shift Manager
D. DelCore
Supervisor, Health Physics
W. Denny
Nuclear Technical Specialist III
M. Dolishny
Nuclear Operations Support Coordinator
J. Dorosky
Health Physicist III
E. Dundon
System Engineer
M. Finnegan
Supervisor, Health Physics, ISFSI
J. Garner
system Engineer
A. Gharakhanian
Nuclear Engineer III
M. Gobely
D. Gonsalves
Nuclear Instrument Technician
M. Goolsbey
Unit 3 Operations Manager
W. Gorman
Supervisor, Instrumentation & Control
J. Grogan
Supervisor, Nuclear Training
K. Hajnal
Unit 3 Shift Technical Advisor
W. Hoffner
Nuclear Corporate Functional Area Manager (Operations)\\
K. Holt
Manager, Millstone Communications
C. Houska
I&C Technician
T. Ickes
IST Engineer
C. Janus
Maintenance Rule Coordinator
R. Kastner
Unit 2 Unit Supervisor
J. Keith
Unit 3 Unit Supervisor
J. Kelly
Unit 3 Control Operator
J. Laine
Manager, Radiation Protection/Chemistry
J. Langan
Manager, Nuclear Oversight
J. Langworthy
Radiation Protection Technician
J. Magyrick
Unit 2 Shift Technical Advisor
D. MacDonald
Manager of Nuclear Design Engineering
G. Marshall
Manager, Outage and Planning
J. Menje
System Engineer, Instrument Air
R. Mello
Unit 3 Control Operator
M. Nappi
Health Physics Shift Supervisor
B. Nichols
Unit 3 Shift Technical Advisor
T. Nguyen
Design Engineer
J. Palmer
Manager, Training
R. Peters
Nuclear Instrument Technician
J. Powers
BDB Engineer
T. Quinley
Nuclear Technical Specialist III
D. Reed
Unit 3 Shift Manager
D. Regan
Health Physics Supervisor, Operations
J. Rigatti
Manager, Nuclear Site Engineering
M. Roche
Senior Nuclear Chemistry Technician
P. Russell
Unit 3 Shift Manager
R. Saddler
Unit 3 Unit Supervisor
J. Salvatore
Unit 3 Unit Supervisor
L. Salyards
Licensing, Nuclear Technology Specialist
S. Scace
Site Vice President
I. Scaggs
Motor Component Engineer
P. Scott
unit 3 Shift Manager
J. Semancik
Director, Nuclear Engineering
M. Shultz
WSI Machinist
D. Smith
Manager, Emergency Preparedness
S. Smith
Manager, Nuclear Operations
T. Snow
Corporate License Renewal Contractor
M. Stark
Steam Generator Program Manager
J. Stoddard
Supervisor, Nuclear Shift Operations Unit 3
P. Thomas
Site License Renewal Staff
T. Thull
Boric Acid Program Manager
D. Todaro
Project Engineer
S. Turowski
Supervisor, Health Physics Technical Services
A. Vomastila
Corporate Employee Concerns Manager
C. Vournazos
IT Specialist, Meteorological Data
K. Wallace
System Engineer
K. Wietham
Nuclear Engineer III, Nuclear Spent Fuel Group
K. Woods
Unit 3 Control Operator
W. Woolery
Unit 2 Shift Manager
M. Wynn
Supervisor, Radiological Analysis
D. Yapchanyk
Senior Mechanical Project Engineer
R. Zieber
ISI Program Engineer
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000336/2014-003-01
Failure to Maintain Adequate Procedure
For RCS Drain/Fill (Section 1R20)
Failure to Utilize Respiratory Protection as
Specified in Work Control Documents
(Section 2RS3)
Failure to Adequately Maintain EALs
(Section 4OA5)
Failure to Adequately Maintain EALs
(Section 4OA5)
Closed
- 05000423/2013-009-00
LER
Secondary Containment Boundary Breach
Could Have Prevented Safety Function
(Section 4OA3)
- 05000336/2013-005-01
Implementation of NEI 99-01 Guidance
(Section 4OA5)
- 05000423/2013-005-01
Implementation of NEI 99-01 Guidance
(Section 4OA5)