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05000219/FIN-2017003-012017Q3Oyster CreekInadequate Augmented Offgas System Procedure Resulted in a Manual ScramA self -revealing NCV of Technical Specification 6.8.1, Procedures and Programs, was identified because Exelon did not adequately establish and maintain the augmented offgas (AOG) system operation procedure as required by NRC Regulatory Guide 1.33, Quality Assurance Requirements (Operation), Appendix A, Section 7, Procedures for Control of Radioactivity. Specifically, Exelon procedure 350.1, Augmented Offgas System Operation, did not include adequate guidance for placing the AOG system into a recycle or shutdown configuration following a system trip. Without this guidance, Operations personnel failed to ensure the correct configuration of the AOG system following a partial trip of the system which resulted in degraded main condenser vacuum and a subsequent manual reactor scram on July 3, 2017. This issue was entered into the corrective action program as issue report 4028402. The corrective actions included placing the AOG system in the correct configuration and revising the AOG system operation procedure to provide guidance for verifying proper alignment of the AOG system when the system is in recycle or shutdown. The inspectors determined the performance deficiency was more than minor because it was associated with the Initiating Events cornerstone attribute of Procedure Quality and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to establish an adequate procedure for verifying proper alignment of the AOG system following a full or partial trip of the system resulted in the AOG inlet valve being left in the open position, which allowed demineralized water to be siphoned from the flame arrestor tank and slowly fill the offgas hold- up pipe. This caused a degradation of main condenser vacuum and resulted in operators inserting a manual reactor scram on July 3, 2017. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Screening and Characterization of Findings, and IMC 0609, Appendix A, Exhibit 1, Initiating Event Screening Questions. The inspectors determined the finding was a transient initiator that did not contribute to both the likelihood of a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition, and therefore was of very low safety significance (Green). The finding had a cross- cutting aspect in the area of Human Performance, Avoid Complacency , because Exelon failed to recognize and plan for the possibility of mistakes or latent errors and implement appropriate error reduction tools by verifying the AOG system was properly aligned following a system trip ; instead , Operations personnel relied upon using a procedure that did not contain adequate guidance to place the AOG system in the correct configuration following a system trip (H. 12)
05000219/FIN-2016001-032016Q1Oyster CreekInadequate Instructions for the Flexible Coupling Hose Preventative Maintenance Resulting in an Inoperable Emergency Diesel GeneratorThe inspectors identified a preliminary White finding and associated apparent violation of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Exelon did not appropriately prescribe instructions or procedures for maintenance on the emergency diesel generator (EDG) No. 1 cooling water system to ensure the EDG cooling flexible coupling hose was maintained to support the EDG safety function. Specifically, Exelon did not have appropriate work instructions to replace the EDG cooling flexible coupling hoses every 12 years as specified by Exelons procedure and vendor information. As a result, the flexible coupling hose was in service for approximately 22 years and subjected to thermal degradation and aging that eventually led to the failure of EDG No. 1 during operation on January 4, 2016. As a consequence of this inappropriate work instruction issue, Exelon violated Technical Specification 3.7.C because EDG No. 1 was determined to be inoperable for greater than the technical specification allowed outage time of seven days. Exelons immediate corrective actions included entering the issue into their corrective action program (issue reports 2607247 and 2610027), replacing of the EDG No. 1 and No. 2 flexible coupling hoses, and initiating a failure analysis to determine the causes of the failed flexible coupling hose. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the ruptured flexible coupling hose caused the failure of EDG No. 1 to perform its safety function. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, this finding required a detailed risk evaluation (DRE) because EDG No. 1 was inoperable for greater than the technical specification allowed outage time. The DRE estimated the increase in core damage frequency was 7E-6, or White (low to moderate safety significance) for this finding. This finding does not have an associated cross-cutting aspect because the performance deficiency occurred in 2005 and is not reflective of present performance.
05000334/FIN-2015008-012015Q2Beaver ValleyFailure to Initiate a Condition Report for an Adverse ConditionA Green self-revealing finding of NOP-LP-2001, Corrective Action Program, was identified after FENOC failed to generate a condition report for a condition adverse to quality. Specifically, FENOC did not initiate a condition report when a lifted lead was identified during preventative maintenance and installation of the Unit 1 main transformer. As a result, corrective actions were not taken and this led to an unplanned downpower from 100 percent to 15 percent reactor power on January 31, 2014. The performance deficiency was more-than-minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was determined to be of very low safety significance (Green), because it did not cause a reactor trip and the loss of mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Field Presence, because FENOC failed to ensure supervisory and management oversight of work activities, including contractors and supplemental personnel (H.2).
05000336/FIN-2014004-022014Q3MillstoneLicensee-Identified Violation10 CFR 50, Appendix B, Criterion XVI, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, for the January 30 Unit 2 pressurizer heater failure, Dominion determined the root cause of the event was the continued failure of pressurizer heaters due to manufacturing defects associated with replacement heaters and determined this was a repeat failure because CAPRs from a previous event in 2009 were not complete. Dominion entered the issue into the CAP as CR 538495. The inspectors determined that this finding was of very low safety significance using IMC 0609, Appendix A, because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
05000336/FIN-2014004-012014Q3MillstoneLicensee-Identified ViolationTS 3.6.2.1, Containment Spray and Cooling Systems, requires two containment spray trains and two containment cooling trains to be operable in Modes 1, 2, and 3. If one containment spray train is inoperable, the TS required action is to restore the inoperable train within 72 hours or be in Hot Standby within 6 hours. Contrary to the above, at 7:33 PM on May 16, Dominion exceeded the 72 hour allowed outage time for the A containment spray train, due to the delayed completion of the gas void detection surveillance test. In addition, TS 3.0.4 prohibits entry into an Operational Mode without all requisite limiting conditions of operation met. Contrary to the above, at 7:33 PM on May 13, Unit 2 entered Mode 3 with pressure greater than 1750 psia and an inoperable A containment spray train. Dominion entered the issue into the CAP as CR 549280. The inspectors determined that this finding was of very low safety significance using IMC 0609, Appendix A, because the period of unavailability was of short duration (approximately 88 hours) and occurred during Mode 3. The B train of containment spray remained unaffected by the voids found in the A train.
05000244/FIN-2014008-012014Q1GinnaFailure to Effectively Implement Corrective Actions Associated with Heater Drain Tank Pump Tripping IssuesThe inspectors identified a Green finding (FIN) for CENGs failure to effectively implement a CA associated with an apparent cause evaluation (ACE) that addressed both heater drain tank (HDT) pumps tripping on October 21, 2012. Specifically, CENG failed to effectively implement a CA to modify all procedures in which the feedwater system would be impacted by stopping HDT or condensate booster pumps, which resulted in both HDT pumps tripping and an unplanned power reduction from approximately 79 percent power to approximately 48 percent power on January 14, 2014. These issues were entered into CENGs corrective action program as condition report (CR)-2014-000197 and CR-2014- 001208. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to effectively implement CA-2012-003493 and modify all procedures impacted by stopping HDT or condensate booster pumps, including procedure AP-FW.1, resulted in both HDT pumps tripping and an unplanned power reduction of approximately 31 percent power. Additionally, this issue is similar to Example 4b described in IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, which states that issues are not minor if procedural issues cause a reactor trip or other transient. Using Exhibit 1, Initiating Events Screening Questions, of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined this finding did not involve the complete or partial loss of a support system that contributes to the likelihood of, or causes, an initiating event and affects mitigation equipment and is therefore of very low safety significance (Green). This finding has a crosscutting aspect in the area of Human Performance, Procedure Adherence, because individuals did not follow processes, procedures, and work instructions. Specifically, CENG staff did not follow procedure CNG-CA-1.01-1005 and ensure that CAs (CA-2012-003494) were effectively implemented and addressed identified causes associated with the ACE for CR-2012-007133.
05000317/FIN-2013002-012013Q1Calvert CliffsFailure to Establish Adequate Design Control Measures for Diesel Fuel Oil Cloud PointThe inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, because Constellation failed to provide design control measures to assure appropriate specifications were translated into procedures for diesel fuel oil (DFO) in the No.11 fuel oil storage tank (FOST). Specifically, Constellations cloud point maximum specification for DFO is above historical minimum temperatures recorded in the vicinity of CCNPP. The inspectors determined that Constellation did not have adequate measures in place such as a calculation, temperature monitoring, and/or procedures to assess the operability of the DFO transfer system from the No. 11 FOST for sustained outdoor temperatures below the cloud point specification temperature but above the minimum expected temperature the site may experience. Constellation entered this issue in their corrective action program (CAP). Immediate corrective actions included adding a note in Operations turnover sheet to determine No.11 FOST DFO operability if ambient temperatures dropped below 10F at the site. Planned corrective actions include performing a calculation to determine cold weather effects on the No.11 FOST. This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, a reasonable doubt of operability existed because the minimum temperature limits and duration of low temperature had not been established for diesel generator operability and historical low temperatures have been below the cloud point of the DFO. If left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern because an inadequate cloud point specification could impact emergency diesel generator (EDG) and/or station blackout (SBO) diesel operation during an actual event during extreme low temperature conditions. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the finding is a deficiency affecting the design or qualification of a mitigating structure, system, and component (SSC); however, the SSC maintained its operability or functionality. This finding did not have a cross-cutting aspect because the most significant contributor of the performance deficiency was not reflective of current licensee performance. Specifically, the most reasonable opportunity to identify this issue was in 1994 when Constellation reviewed this issue in response to Information Notice (IN) 94-19, Emergency Diesel Generator Vulnerability to Failure from Cold Fuel Oil.
05000317/FIN-2013002-022013Q1Calvert CliffsInadequate Technical Specification Surveillance Testing of the Diesel Fuel Oil Transfer SystemThe inspectors identified an NCV of Technical Specification (TS) surveillance requirement (SR) 3.8.1.7 because Constellation failed to adequately perform SR associated with the DFO transfer system. Specifically, since approximately 1996, Constellation did not test the 2A EDG fuel oil transfer system aligned to the No. 21 FOST. The No. 21 FOST is the credited tank in the plants licensing bases. Immediate corrective actions included entering this issue into the CAP and entering TS SR 3.0.3 for a missed surveillance which required performing a probabilistic risk assessment and performing the missed surveillance within 31 days. Corrective actions planned includes revising the quarterly EDG surveillance procedure to test the 2A EDG while aligned to the No. 21 FOST and develop and implement a testing program to periodically test each EDG aligned to the normal and alternate FOSTs. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, Constellations testing program did not provide assurance that no obstruction exists in the DFO transfer system. If left uncorrected, this issue potentially would result in a greater safety concern in that an obstruction could exist would not be identified until an actual event requiring the 2A EDG to be aligned to the No. 21 FOST as described in the safety analysis. In accordance with IMC 0609.04, Initial Characterization of Findings and Exhibit 2 of IMC 0609, Appendix A, Significance Determination Process For Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time; and did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety significance. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, CAP, because Constellation did not ensure that issues potentially impacting nuclear safety are promptly identified, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their significance. Specifically, Constellation did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner associated with previously identified inadequate testing programs of risk significant equipment.
05000317/FIN-2012004-042012Q3Calvert CliffsInattentive Non-Licensed OperatorIn accordance with Inspection Procedure 92702, Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders, the inspectors conducted a follow-up inspection of a Severity Level IV NCV which was identified due to the deliberate failure of a non-licensed operator to remain attentive to their duties while performing a maintenance evolution on the 2B EDG on June 15, 2011, contrary to Technical Specification 5.4.1.a, Procedures. This issue was communicated to Constellation in a letter dated April 9, 2012, following the completion of an NRC investigation into this matter. The inspectors reviewed the scope and depth of analysis performed in addressing the identified deficiency. The inspectors also reviewed Constellations assessment of generic implications of the identified violation and evaluated the corrective actions implemented by Constellation personnel to determine whether they were adequate to address the identified deficiency and prevent recurrence. The inspectors reviewed Constellations identified causes and the actions taken to prevent recurrence of those causes.
05000317/FIN-2012004-012012Q3Calvert Cliffs2A Diesel Generator Ventilation Train 10 CFR 50.65 (a)(2) Performance Demonstration Not MetAn NRC-identified NCV of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, paragraph (a)(2), was identified because Constellation personnel did not adequately demonstrate that the 2A diesel generator ventilation train (a)(2) performance was effectively controlled through performance of appropriate preventive maintenance. Specifically, Constellation personnel did not identify and properly account for a functional failure of the 2A emergency diesel generator (EDG) ventilation train in June 2012, and thereby did not recognize that the train exceeded its performance criteria and required a Maintenance Rule (a)(1) evaluation. The subsequent evaluation concluded that the 2A EDG ventilation train (a)(2) performance demonstration was no longer justified and therefore the train should be classified as (a)(1), corrective actions specified, and train monitoring completed. Constellation personnel entered the issue into their CAP as CR-2012- 006132. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, following a functional failure of the 2A EDG ventilation train in June 2012, Constellation did not identify that the train should be monitored in accordance with 10 CFR 50.65(a)(1) for establishing goals and monitoring against the goals. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power. The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent a loss of safety system function; and did not screen as potentially risk significant due to external initiating events. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution because Constellation personnel did not thoroughly evaluate the problem such that the resolution fully addressed causes and extent of conditions, as necessary. This includes properly classifying, prioritizing, and evaluating for operability and reportabililty a condition adverse to quality. Specifically, Constellation personnel did not properly evaluate the impact of the condition of the dampers on the ability of the ventilation train to perform its safety function.
05000317/FIN-2012004-022012Q3Calvert CliffsCorrective Actions Not Completed for Drains in the Intake StructureAn NRC-identified finding of very low safety significance was identified because Constellation staff did not follow Procedure CNG-CA-1.01-1000, Corrective Action Program. Specifically, Constellation staff did not complete corrective actions previously prescribed within their Corrective Action Program as a result of root and apparent cause evaluations for drain failures which impacted safety-related equipment. This resulted in a drain line within the intake structure becoming clogged and the 21 saltwater (SW) pump becoming submerged in water. Constellation personnel entered the issue into their CAP as CR-2012-008363, cleaned out the drain line, and implemented a new preventive maintenance (PM) schedule to keep the drain line clear. Planned corrective actions include overhauling the 21 SW pump bearings. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, because the intake structure drain piping was clogged, the 21 saltwater pump pit filled with water and caused the pump bearing housings to be contaminated with water, which adversely impacts the long-term reliability of the pump bearings and will cause the pump to be unavailable while the issue is corrected. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power. The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent a loss of safety system function; and did not screen as potentially risk significant due to external initiating events. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution because Constellation personnel did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, Constellation personnel did not perform corrective actions previously prescribed to address and correct drain failures that impacted safety-related equipment.
05000317/FIN-2012004-032012Q3Calvert CliffsInadequate Assessment of Unit 1 RCS Pressure Boundary LeakageA self-revealing NCV of Technical Specification (TS) 3.4.13, Reactor Coolant System (RCS) operational LEAKAGE, was identified because Constellation failed to completely isolate a fault in the RCS pressure boundary, which resulted in Constellation operating with RCS pressure boundary leakage for a period of time prohibited by Technical Specifications. Constellations corrective actions included entering the issue in their Corrective Action Program (CAP) (CR-2012-007012 and CR-2012-007276), performing repairs, and conducting root and apparent cause analyses for the issue. The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, after the Constellation personnel identified reactor coolant pressure boundary (RCPB) leakage at 5:15 p.m. on July 17, 2012, they did not reach Mode 3 within six hours because they did not verify complete isolation of the leak. Constellations actions did not limit the likelihood of a small loss of coolant accident (LOCA) event when they operated with RCS pressure boundary leakage from July 17 until July 21, 2012. The inspectors evaluated the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power, and determined the finding is of very low safety significance (Green) because the performance deficiency, after a reasonable assessment of degradation, could not result in exceeding the RCS leak rate for a small LOCA and could not likely affect other systems used to mitigate a LOCA, resulting in a total loss of their function. The finding has a cross-cutting aspect in the area of Human Performance, Decision Making, because Constellation personnel did not use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action was safe in order to proceed, rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. Specifically, after attempting to isolate the RCS pressure boundary leakage, Constellation personnel non-conservatively assumed that the leak was isolated based on an inadequate post-isolation verification and monitoring plan.
05000317/FIN-2012004-052012Q3Calvert CliffsLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation. TS LCO 3.4.10.4, Pressurizer Safety Valves, requires that two pressurizer safety valves shall be operable, which is specifically met, in part, if the as-found setpoints are within applicable acceptance criteria during in-service testing. Contrary to this requirement, on July 7, 2011, Constellation personnel determined that the as-found lift setpoint for PSV, serial number BS03213, exceeded the TS required value by 1 psi. Therefore, Unit 2 PSV BS03213 was determined to be inoperable for an indeterminate period while it had been installed in the plant between March 2007 and March 2009. Calvert Cliffs personnel documented this issue into their corrective action program as CR-2011- 001263. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power. The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent a loss of safety system function; and did not screen as potentially risk significant due to external initiating events.
05000336/FIN-2012003-022012Q2MillstoneLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by Dominion and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. Technical Specification 3.3.2 states, in part, that The Engineered Safety Features Actuation System instrumentation channels and interlocks shown in Table 3.3-3 shall be operable with their Trip Setpoints set consistent with the values shown in the Nominal Trip Setpoint column of Table 3.3-4. TS 3.3.3.4 states in part that these accident monitoring channels shall be operable. Contrary to these requirements, all main steam line steam generator pressure transmitters were reinstalled after maintenance using gaskets that were not environmentally qualified for use in an accident environment, thereby rendering these transmitters inoperable from January 17 through February 9, a condition prohibited by TS. Dominion identified the condition and immediately entered TS 3.0.3. Dominion replaced the gaskets and restored full EQ qualification to all main steam line pressure transmitters while complying with the action statements of TS 3.0.3, and entered the issue into the corrective action program as condition report CR462222.
05000336/FIN-2012003-012012Q2MillstoneInadequate Operability Determination for 3FWS*CTV41 Feedwater Isolation Valve Hydraulic ActuatorsAn NRC identified finding of very low safety significance (Green) was identified for Dominions failure to adequately assess the operability of the Unit 3 Feedwater isolation valves, 3FWS*CTV41A, B, C and D in accordance with OP-AA-102-1001, Development of Technical Guidance Basis to Support Operability Determinations, and C OP 200.18, Time Critical Operator Action Validation and Verification. Specifically, Dominion did not properly validate or credit manual operator actions to isolate the main feedwater lines during a feedline break inside containment as a compensatory measure for degraded hydraulic valve actuators. Dominion entered this issue into their corrective action program (CAP) as condition report number 478020, and conducted a reanalysis of the operability determination. The finding is more than minor because it is similar to NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, Example 3.k; in that the inadequate assessment of operability resulted in a condition where there was a reasonable doubt on the operability of the feedwater isolation function and the feedwater isolation valves. This issue is associated with the Equipment Control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Dominion did not explicitly take credit for manual operator actions to trip the main feedwater pumps as a compensatory measure for the degraded capability of the 3FWS*CTV41 feedwater isolation valves to perform their safety function during a feedline break event inside containment. The inspectors determined this finding was not a design qualification deficiency resulting in a loss of functionality or operability, did not represent an actual loss of safety function of a system or train of equipment, and was not potentially risksignificant due to a seismic, fire, flooding, or severe weather initiating event. Therefore, the finding is considered to be of very low safety significance. The inspectors did not assign a cross cutting aspect to this finding because the finding was not reflective of current performance. Operability determination OD000237 was completed in 2009 and OP-AA-102-1001 does not require periodic reassessment of active operability determinations.
05000336/FIN-2011005-012011Q4MillstoneLicensee-Identified ViolationTechnical Specification 4.0.4 states, in part, that entry into an operational Mode shall not be made unless the surveillance requirement(s) .associated with the limiting condition for operation has been performed within the stated surveillance interval. Contrary to the above, while performing RPS matrix and trip path testing during the Unit 2 start-up on July 24, 2009, Dominion closed the TCSs and rendered the CEA drive system capable of CEA withdrawal without first demonstrating that the TCSs were operable. Dominion entered this issue into their corrective action program (CR442964) and is revising the surveillance procedure. This violation is of very low safety significance because the performance of the surveillance verified the operability of the TCSs.
05000220/FIN-2011004-012011Q3Nine Mile PointInadequate Actions to Prevent Vibration Induced Failure on a Socket Weld for a Vent Line on the lA\' FWP Minimum Flow LineA Green self revealing finding was identified for inadequate implementation of corrective actions regarding vibration induced failures of socket welds. This finding resulted in an August 11, 2011, Nine Mile Unit 2 scram due to a failed socket weld on the vent line for the \'A\' feedwater pump (FWP) minimum flow line. NMPNS did not properly consider the impact of high vibration levels on a vent line attached to the \'A\' FWP mini-flow recirculation line. NMPNS corrective actions included upgrading the socket weld to the requirements outlined in industry operating experience (OE). The inspectors determined that the finding was of very low safety significance (Green) through performance of a Phase 1 SOP in accordance with IMC 0609.04, Table 4a, Characterization Worksheet for Initiating Events, Mitigating Systems (MS) and Barrier Integrity Cornerstones. Specifically, the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. This finding has a cross-cutting aspect in the area of problem identification and resolution in that NMPNS did not implement and institutionalize OE through changes to station processes, procedures, equipment and training programs. Specifically in 1998 and again in 2010, NMPNS did not institutionalize external and internal OE to reduce the probability of a socket weld failure.
05000336/FIN-2011004-012011Q3MillstoneFailure to Electrically Isolate Dissimilar Metal Flanged Joint Leads to Forced Shutdown Due to Service Water LeakA self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for Dominion\\\'s failure to properly electrically isolate service water (SW) flanged joints of dissimilar metals. This caused a more rapid corrosion rate when a defect occurred in the lining of the carbon steel pipe and eventually led to a SW leak. On September 3, 2011, Dominion was forced to shut down Unit 2 when the spool leaked in excess of the limit allowed in authorized relief from American Society of Mechanical Engineers (ASME) code requirements. Dominion repaired the spool and electrically isolated the flanged joint. Dominion entered this issue into their corrective action program (CAP) CR441302. The finding is more than minor because it is associated with the Human Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency that did not result in loss of operability, did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its technical specification (TS) allowed outage time, did not represent an actual loss of safety function of one or more non-technical specification trains of equipment designated as risk significant per 10 CFR 50.65, and did not screen as risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel proceeded in the face of uncertainty andlor unexpected circumstances when they had difficulty installing the isolating sleeves in the flanged joint.
05000220/FIN-2011003-012011Q2Nine Mile PointInadequate Procedural Guidance for Main Turbine and Generator Maintenance ActivitiesA Green self revealing finding for inadequate procedural guidance was identified. The inadequate procedural guidance resulted in a May 2,2011 Nine Mile Unit 1 scram due to a turbine trip. NMPNS determined that the turbine tripped when the main turbine master trip solenoid (MTS) actuated due to pressure fluctuations caused by a combination of leaking oil supply fittings to the MTS; binding of the secondary speed relay linkages, and main shaft tuOe oil disCharge pressure fluctuations. These degraded conditions occurred because the governing work control documents and procedures that were implemented during the spiing 2O1i refuel outage contained inadequate detail and guidance. NMPNS correltive actions included repairing the degraded components and initiating actions to revise the procedures. This 1nding is more than minor because it affected the procedure quality attribute of the Initiating Events Cornerstone objective of limiting the likelihood of those events that upset plant stibility and challenge critical safety functions during shutdown as well as power operations. The finding was of very low safety significance because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. This finding has a cross-cutting aspect in the area of human performance in that NMPNS did not ensure that complete and accurate and upto-date design documentation and procedures were available to implement turbine maintenance during the spring 2Q11 refuel outage.
05000336/FIN-2011003-042011Q2MillstoneFailure to Follow Procedure for Starting a Second SGFP Results in Reactor TripA self-revealing finding (FlN) of very low safety significance (Green) was identified for Dominion\'s failure to follow procedure OP 2204, Load Changes, when starting the \'A\' steam generator feedpump (SGFP). Specifically, the operating crew failed to maintain adequate SGFP suction pressure (greater than 325 psig) while starting the \'A\' SGFP, which led to a trip of the \'B\' SGFP and subsequent reactor trip on low steam generator level. Dominion entered this issue into their corrective action program (CR431574); conducted training exercises emphasizing safe operating envelopes, critical parameters to monitor, and actions to take to restore margin if plant conditions degrade; and has revised procedure OP 2204. The finding is more than minor because it is similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor lssues, Example 4b; in that, a failure to follow procedure led to a reactor trip. This issue is associated with the Human Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure of the operators to properly monitor SGFP suction pressure led to a loss of adequate feedwater flow and a reactor trip. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel did not properly follow the load changes procedure.
05000336/FIN-2011003-032011Q2MillstoneInadequate Corrective Action Results in Loss of Enclosure Building\'s Safety FunctionA self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl, Corrective Action, was identified for Dominion\'s failure to take prompt corrective action to address the cause of main steam safety valve (MSSV) exhaust pipe bushings not seating, which resulted in a loss of the Enclosure Building\'s safety function to control the release of radioactive material. Dominion took corrective action to clean and lubricate the MSSV exhaust pipe and also implemented a modification to upgrade the MSSV outlet boot and qualify it as part of the Enclosure Building filtration boundary (cR420485). The finding was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure of the MSSV sliding bushings to seat properly caused the Enclosure Building Filtration System (EBFS) to fail its surveillance test, and its safety function to control the release of radioactive material could not be assured. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it only represents a degradation of the radiological barrier function provided for the auxiliary building. The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action to address the Enclosure Building surveillance test failure in 2009.
05000336/FIN-2011003-022011Q2MillstoneUntimely Corrective Action for Safety Related lnverters Leads to Repetitive Out of Calibration ResultsThe inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, corrective Action, for Dominion\'s failure to take timely corrective action to address repetitive out of calibration conditions associated with safety-related 120 VAC Unit 2 inverters. To date, Dominion has taken corrective action to adjust the over-frequency and under-frequency transfer limits (CR426589). The inspectors determined the finding was more than minor because it is similar to the more than minor Example \'4f\' of NRC lnspection Manual Chapter (lMC) 0612, Appendix E, Examples of Minor issues. Additionally, the issue is more than minor because the performance deficiency can be reasonably viewed as a precursor to a significant event; in that, the history of over- and under-frequency limits drifting out of tolerance could lead to the unavailability of safety-related equipment powered from the inverters. The inspectors conducted a Phase 1 screening in accordance with NRC IMC Attachment 0609.04, Phase 1 - lnitial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action in a timely manner to address the repetitive out of calibration conditions with the 120 VAC safety related inverters.
05000336/FIN-2011003-012011Q2MillstoneFailure to Take Timely Corrective Actions for De-alloying of Aluminum Bronze Service Water ValvesThe inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, corrective Action, for Dominion\'s failure to take timely corrective actions for a condition adverse to quality involving the degradation and subsequent through-wall leakage of Unit 3 service water valves 3SWP.V699 (3HVQ.ACUS1B Bypass Valve), 3SWP.VO18 (3HVQ.ACUS2B Unit Cooler Inlet Valve), and 3SWP*V696 (3HVQ.ACUS2B Unit Cooler Outlet Valve). Specifically, Dominion did not adequately implement a schedule for prioritizing and completing corrective actions on affected aluminum bronze components, which were known to be susceptible to de-alloying, commensurate with the safety significance of the degraded condition. As a result, through-wall leaks developed on these valves and resulted in unplanned loss of operability and additional unavailability of the safety-related support systems for the \'B\' train of containment recirculation spray pumps. Dominion took immediate corrective action to replace the three leaking service water (SW) valves (CR428785). The inspectors determined that this issue was more than minor because it is similar to the more than minor example, 4.F, of IMC 0612, Appendix E, Examples of Minor lssues. Specifically, the degraded condition caused a loss of operability of the \'B\' train of the containment iecirculation spray system. Additionally, the finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring-the availability of systems that respond to initiating events to prevent undesirable consequences. ln accordance with NRC lnspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent an actual loss of system safety function of a single train for greater than its Technical Specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not ensure that issues potentially impacting nuclear safety were corrected in a timely manner commensurate with their safety significance. Specifically, Dominion failed to adequately implement corrective actions to address a known de-alloying issue with SW valves before ihe condition led to the unplanned loss of operability and additional unavailability of the safety-related support systems for the \'B\' train of containment recirculation spray pumps.
05000336/FIN-2010005-012010Q4MillstoneFailure to Provide an Adequate Procedure for Backwashing Condenser Water BoxesA self-revealing finding (FIN) of very low significance was identified for Dominion\'s failure to provide an adequate procedure for backwashing the Unit 2 condenser water boxes in accordance with procedure MP-05-MMM, Manuals, Procedures, Guidelines, Handbooks and Forms. Specifically, in implementing the procedure, the A circulating water (CW) pump automatically ramped down to zero speed shortly after securing the B CW pump. This resulted in a loss of condenser vacuum, which caused an automatic turbine trip. The turbine trip caused an automatic reactor trip. Dominion entered the issue into their corrective action program (CAP) and revised the operating procedure (OP) 2325D. The finding is more than minor because it was similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Example 4b, in that an inadequate procedure led to a reactor trip. The finding was associated with the Procedure Quality attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Dominion\'s failure to provide an adequate procedure for backwashing Unit 2 condenser water boxes resulted in the variable frequency drive (VFD) logic securing the only CW pump running in that condenser, and subsequently caused a reactor trip. The finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because Dominion did not provide an accurate and up-tO-date procedure for the backwashing of the Unit 2 water boxes.
05000336/FIN-2010005-022010Q4MillstoneFailure to Take Adequate Corrective Actions For a Broken Jacket Water Banjo Bolt on the 3 B EDGThe inspectors identified a Green, NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that, Dominion did not take adequate corrective action following the identification of a degraded condition. Specifically, maintenance personnel identified a broken jacket water fitting (banjo bolt) on the Unit 3, B emergency diesel generator (EDG), but a condition report (CR) was not initiated. Subsequently, an additional similarly degraded fitting resulted in extended unavailability on the Unit 3, B EDG. In response, Dominion entered the issue into the CAP and replaced the broken jacket water fitting. The finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent an actual loss of system safety function of a single train for greater than its Technical Specification (TS) allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not ensure that issues potentially impacting nuclear safety were promptly identified, fully evaluated, and that actions were taken to address safety issues in a timely manner, commensurate with their safety significance. Specifically, Dominion did not initiate a CR in September 2009 for a degraded condition on the safety-related Unit 3, B EDG.
05000336/FIN-2010005-032010Q4MillstoneLicensee-Identified ViolationTS 3.7.2.1 states that the TDAFW pump has an allowable outage time of 72 hours. TS 4.0.1 requires that the licensee shall declare the TDAFW pump to be inoperable if the pump fails a surveillance test required by TSs. Contrary to this requirement, the TDAFW pump failed a surveillance test on June 30, 2010, and was inoperable for a period of approximately 54 days, which exceeded the TS allowable outage time. Dominion was not aware of the surveillance test failure until an extent of condition review triggered by another failed surveillance test on August 19, 2010, revealed that the TDAFW pump had failed the earlier test. Upon discovery, Dominion restored operability by repairing 3FWA RV45 and placed the condition in the CAP (CR392003 and CR392155). This finding is of very low safety significance because the TDAFW pump was available to fulfill its safety function during the period of time that it was inoperable.
05000220/FIN-2011009-012010Q4Nine Mile PointIntentional Failure to Follow ProcedureOn Friday, March 5,2010, the SE received information indicating that a charcoal sample taken from an NMP #11 R8EVS charcoal filter had failed its two-year required surveillance test (ST). The sample did not meet the minimum value for radioactive methyl iodide removal specified in NMP Technical Specifications (TS). As a result, in accordance with the TS, the NMP1 R8EVS train should have been declared inoperable and the plant should have promptly entered the seven day TS limiting condition of operation (LCO) action statement. In addition, in accordance with 10 CFR 50, App. 8. Criterion XVI and site procedures, the SE should have immediately notified his supervision of the failed ST, since it constituted a condition adverse to quality. However, the SE deliberately decided to not inform his supervision of the failed ST until Monday, March 8, 2010. The SE later admitted his failures to Constellation during the internal Constellation investigation into this matter, and the SE also cooperated with NRC investigators during the NRC 01 investigation. Because licensees are responsible for the actions of their employees and because the violation involved deliberate misconduct, the violation was evaluated under the NRC\\\'s traditional enforcement process as set forth in Section 2.2.4 of the NRC Enforcement Policy. The violation is considered to be of very low safety significance because NMP returned the #11 RBEVS train to service on March 9, 2010, which would have been within the required seven day timeframe even if the LCO had been appropriately entered on March 5, 2010, Therefore, the NRC has characterized the violation at Severity Level (SL) IV, in accordance with the NRC Enforcement Policy. The violation is being cited in the Notice in accordance with the Enforcement Policy, because the violation involved the acts of an SE who with the operability information he possessed, was in a position with responsibilities that were directly related to the oversight of licensed activities, Constellation\\\'s corrective actions included: 1) replacing the subject NMP #11 RBEVS charcoal, ensuring the #11 RBEVS train successfully passed the ST, and then returning the system to service on March 9, 2010; 2) taking appropriate disciplinary action against the involved SE and, 3) conducting training for all SEs regarding following requirements and not engaging in deliberate misconduct.
05000220/FIN-2010008-012010Q4Nine Mile PointDeliberately Failing to Use a Whole Body Contamination monitor When Exiting the Radiologically Controlled AreaThe actions of the non-licensed operator violated Nine Mile Point Unit 2 Technical Specifications Section 5.4.1, which caused Constellation to be in violation of its license conditions and NRC requirements. This section states, in part, that written procedures shall be established, implemented, and maintained covering the following activities: the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 7.e of Appendix A of Regulatory Guide 1.33, Revision 2, lists procedures for radiation protection contamination control and radiation protection - personnel monitoring. Licensee procedure GAP-RPP-O1, Radiation Protection Program, Revision 01900, Section 3.5.2.d states, in part: To control personnel contamination, Radiation Protection should establish and maintain personnel monitoring areas at various locations throughout the RCA, and at exits from the RCA, as determined by RP Supervision. Personnel shall monitor themselves for contamination upon exiting the RCA and other RCAs as specified by RP Supervision, in a WBCM. Contrary to the above, on April 15,2010, Constellation identified that a non-licensed operator exited the RCA without first monitoring himself for contamination in a WBCM. Specifically, the non-licensed operator admitted he exited the RCA without using the WBCM in order to avoid a long line waiting to use the monitor. Later, when attempting to leave the site, the operator alarmed a portal monitor, due to contamination on his clothing. Although Constellation was initially unaware that the non-licensed operator exited the RCA without using the WBCM, Constellation is responsible for the actions of its employees. Because you are responsible for the actions of your employees, and because the violation involved deliberate misconduct, the violation was evaluated under the NRC\\\'s traditional enforcement process as set forth in Section 2.2.4 of the NRC Enforcement Policy. After considering the low level of contamination found, that no contamination left the site, and the violation was not repetitive, the NRC has categorized it at Severity Level lV in accordance with the NRC Enforcement Policy. Because this violation was of very low safety significance and was entered into Nine Mile Point\\\'s corrective action program, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000410/2010008-01, Deliberately Failing to Use a Whole Body Contamination Monitor When Exiting the Radiologically Controlled Area). The current NRC Enforcement Policy is included on the NRC\\\'s website at http.//www.nrc.qov; select About NRC, Regulation, Enforcement, then, Enforcement Policy
05000336/FIN-2010004-042010Q3MillstoneLicensee-Identified Violation10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to this, Dominion had no documented procedure for bypassing undervoltage protection for the vital buses. As a result, on October 7, 2009, Dominion bypassed the undervoltage protection for the vital buses and rendered both EDGs inoperable for approximately seven hours. Upon discovery, Dominion restored the undervoltage protection and entered the issue into their corrective action program (CR351389). The finding is of very low safety significance because of the short duration of the inoperability, and because both EDGs could be manually started from the Control Room.
05000336/FIN-2010004-062010Q3MillstoneLicensee-Identified Violation10 CFR 50 Appendix B, Criterion III, Design Control requires, in part, that measures shall be established to assure that the applicable design basis for structures, systems, and components, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this, from approximately 1995 until August 13, 2010, Dominion failed to ensure that the design basis for the reactor coolant system was maintained when it specified and installed flex hoses with an insufficient pressure rating. Upon discovery, Dominion entered the issue into their corrective action program (CR 390963), shutdown the plant, and replaced the hoses with flex hoses of the proper pressure rating. The finding is of very low safety significance because a failure of the hose would have resulted in a leak that was within the capability of the charging pumps.
05000336/FIN-2010004-032010Q3MillstoneFailure to Implement Timely Corrective Actions for a Degraded Unit 2 FRV Results in Manual Reactor TripA self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to implement timely corrective actions for a degraded Unit 2 feedwater regulating valve (FRV) in accordance with procedure PI-AA-200, Corrective Action. Specifically, two weeks after the issue was first identified, the #2 FRV further degraded causing Dominion to trip the reactor when the #2 steam generator (SG) level could not be adequately controlled. Dominion subsequently repaired the FRV and returned the plant to 100 percent power. The inspectors determined that Dominion\'s failure to implement timely corrective actions for a degraded #2 FRV in accordance with procedure PI-AA-200, Corrective Action, was a performance deficiency. This finding is more than minor because it was similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Example 4f, in that the failure to correct a condition adverse to quality led to a reactor trip. The finding was associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Dominion\'s failure to implement timely corrective actions for the #2 FRV caused the operators to manually trip the reactor when the #2 SG level could not be controlled. The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action to address the degraded #2 FRV in a timely manner, commensurate with its safety significance. (P.1(d)).
05000336/FIN-2010004-012010Q3MillstoneFailure to Promptly Identify and Correct the Source of a Unit 2 RCS Pressure Boundary LeakThe inspectors identified a Green, NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for Dominion\'s failure to promptly identify and correct the source of a reactor coolant system (RCS) pressure boundary leak from July 3, 2009, through July 13, 2009. Dominion subsequently repaired the leak and returned to 100 percent power. The inspectors determined that Dominion\'s failure to promptly identify and correct the cause of pressure boundary leakage is a performance deficiency that was reasonably within Dominion\'s ability to foresee and correct and should have been prevented. This issue is more than minor because the issue is similar to NRC Inspection Manual Chapter (IMC) 0612, Appendix E, and minor example 2.g. The inspectors determined that the issue affected the Initiating Events Cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors concluded that this condition, assuming the worst case degradation, would not have affected other mitigating systems resulting in a total loss of their safety function. Accordingly, the finding was determined to be of very low safety significance (Green) using IMC 609, Attachment 0609.004, Phase 1 Screening Worksheet. The inspectors determined that this issue had a crosscutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not identify the pressure boundary leakage completely, accurately, and in a timely manner commensurate with its safety significance. (P.1 (a))
05000336/FIN-2010004-072010Q3MillstoneLicensee-Identified ViolationTS 3.7.1.2 LCO (c) requires the TDAFW pump to be operable in Mode 1. If the pump is not operable, Action Statement (c) directs restoration within 72 hours after which a plant shutdown to Mode 3 in six hours is required. Contrary to this requirement, on August 23, 2010, the TDAFW pump failed its quarterly surveillance test and a review of prior surveillance tests indicated that the pump had been inoperable since June 30, 2010 (a period of 54 days). Dominion had not properly evaluated the results of the previous surveillance test. During both of these tests, the TDAFW pump failed to produce an acceptable discharge flow rate because the charging pump discharge relief valve, 3FWA*RV45, leaked by its seat. Upon discovery, Dominion declared the TDAFW pump inoperable and promptly repaired the relief valve. Dominion entered the issue into their corrective action program (CR392003), and restored the TDAFW pump to an operable condition. The finding is of very low safety significance because the TDAFW pump was later determined to be available to support core heat removal during the period when the relief valve was degraded.
05000336/FIN-2010004-052010Q3MillstoneLicensee-Identified ViolationTS 3.6.6.2 requires that if secondary containment is inoperable, it must be restored to operable status within 24 hours or the plant must be shutdown. Contrary to this, from May 13, 2010, until May 27, 2010, two sets of auxiliary building tunnel exhaust dampers were open, which rendered secondary containment inoperable. Upon discovery, Dominion immediately restored operability by closing one set of dampers and placed the issue into their corrective action program (CR382686). The finding is of very low safety significance because it only represented a degradation of the radiological barrier function for the auxiliary building.
05000336/FIN-2010004-022010Q3MillstoneFailure to Perform an ASME Code-compliant Radiographic Examination on a Class 1 Weld on the Unit 2 \'A\' RCP Seal Cooler PipingThe inspectors identified a Severity Level IV, NCV of 10 CFR 50.55a(2)( c)( 1) and 10 CFR 50.55a(3), when Dominion did not perform an ASME Code compliant radiographic examination for a leak in a Class 1 weld on the Unit 2 \'A\' RCP seal cooler piping before returning the system to service. Dominion was out of compliance with 10 CFR 50.55a(2)(c)(1), 10 CFR 50.55a(3), and Section III of the American Society of Mechanical Engineers (ASME) Code between July 24, 2009, and November 10,2009. The NRC granted verbal relief from the 10 CFR 50.55a(2)(c)(1), 10 CFR 50.55a(3), and the ASME Code requirements on November 10, 2009. Subsequently, the relief request was approved, in writing, by the NRC on April 26, 2010. In accordance with IMC 0612, Appendix B, Section 1-2, this finding had the potential to impact the NRC\'s ability to perform its regulatory function because Dominion verbally informed the NRC on July 17, 2009, that they would repair the affected component in accordance with ASME Code requirements. However, due to Dominion\'s misinterpretation of the ASME Code, Dominion did not subsequently inform the NRC of its inability to meet Code requirements (i.e. perform a Code compliant radiographic examination of the affected weld) before returning the plant to service. As a result, Dominion\'s actions had impeded the NRC\'s ability to evaluate and determine the efficacy of the licensee\'s actions. The issue was characterized as Severity Level IV because it is similar to the example provided in the NRC Enforcement Policy Section 6.1.d.2, in that, it involved a violation of NRC requirements that resulted in a condition evaluated as having very low safety significance (i.e., Green) by the Significance Determination Process (SDP). The inspector determined that this issue had a crosscutting aspect in the Human Performance cross-cutting area, Decision Making component, because Dominion did not use conservative assumptions in their decision making when they concluded that Code relief from the NRC would not be necessary to accomplish the repair. (H.1 (b))
05000336/FIN-2010003-032010Q2MillstoneFailure to Make a 10 CFR 50.72 (b )(3)(v) Report for an Inoperable Unit 3 Secondary ContainmentThe inspectors identified a Severity Level IV NCV of 10 CFR 50.72(b)(3)(v); in that, Dominion failed to make a timely 10 CFR 50.72 eighthour report to the NRC for a condition that, at the time of discovery, could have prevented secondary containment from fulfilling its safety function. On May 27, 2010, operations personnel found both sets of the auxiliary and service building tunnel exhaust dampers open which could have prevented secondary containment from fulfilling its safety function. Operations declared secondary containment inoperable, closed the auxiliary building tunnel exhaust dampers to restore operability, and initiated a 10 CFR 50.72 report. The inspectors determined that Dominion\\\'s failure to make a 10 CFR 50.72 eight-hour report to the NRC regarding the inoperable secondary containment as a condition that could have prevented it from fulfilling its safety function was a performance deficiency. The inspectors determined that traditional enforcement applied, since the failure to make a required report could adversely impact the NRC\\\'s ability to perform its regulatory function. In accordance with the NRC Enforcement Policy, Supplement I - Reactor Operations, Example D.4, a failure to make a required Licensee Event Report (LER) is categorized as a Severity Level IV violation. The inspectors determined that this finding had a cross-culling aspect in the Human Performance cross-culling area, Decision Making component, because Dominion did not use conservative assumptions in their decision-making when they could not demonstrate that secondary containment would have fulfilled its safety function (H.1(b)).
05000336/FIN-2010003-012010Q2MillstoneFailure to Properly Identify and Correct a Degraded Governor Condition in the Unit 2 \'A\' EDGA self-revealing, NCV of 1 0 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for Dominion\'s failure to properly evaluate a condition adverse to quality involving the Unit 2 \'A\' emergency diesel generator (EDG). Dominion did not properly evaluate a degraded condition of the \'A\' EDG, which led to its inoperability from May 12,2010, to May 17, 2010. Dominion took immediate corrective action to replace the EDG govemor. The inspectors determined this finding was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Dominion\'s inadequate evaluation of the degraded condition of the \'A\' EDG governor after the March 17, 2010, surveillance test did not result in effective corrective action to address the cause of the rapid load increase. As a result, the \'A\' EDG was declared inoperable when it again experienced a rapid load increase during its surveillance on May 12, 2010. The inspectors determined the significance of the finding using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Decision Making component, because Dominion did not use conservative assumptions in its decision making when they could not conclude that the EDG load fluctuations would not recur (H.1 (b )).
05000336/FIN-2010003-022010Q2MillstoneFailure to Properly Plan Work Activities for the Unit 2 \'D\' Circulating Water Bay Outage Results in Manual Reactor Trip.A self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to properly plan work activities associated with the Unit 2 \'D\' circulating water (CW) bay outage in accordance with Dominion procedure WM-M- 3000, Managing Complex Work. The work plan failed to properly sequence work activities to prevent fouling of the \'C\' CW screens. The subsequent fouling of the \'C\' CW travelling screen resulted in an automatic trip of the \'C\' CW pump. Loss of the \'C\' CW pump, coupled with the unavailability of the \'D\' CW pump, required the operators to manually trip the reactor. Dominion entered this issue into their corrective action program (CR370363). This finding is more than minor because it was similar to NRC IMC 0612, Appendix E, Examples of Minor Issues, Example 4b, in that the implementation of the inadequate work plan caused the loss of the \'C\' CW pump, and required the operators to manually trip the reactor. The inspectors determined this finding was associated with the Human Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, the work plan for the \'D\' CW bay outage did not properly sequence the work, which led to the loss of the \'C\' CW pump and required the operators to manually trip the reactor. The inspectors determined the significance of the finding using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Dominion did not appropriately plan the bay cleaning and demucking (removal of scraped material) work activity to address the risk of the activity to impact the other CW bays (H.3(a)).
05000336/FIN-2010003-042010Q2MillstoneCharging Pump Overheating and Cavitation during RCS Loop Vacuum FillA self-revealing, NCVof 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for Dominion\'s failure to have an adequate procedure for operating the Unit 3 charging pumps. Specifically, Dominion operating procedure (OP) 3304A, Charging and Letdown, did not require verification of Reactor Plant Closed Cooling Water (RPCCW) flow to the seal water heat exchanger, which resulted in overheating of the \'B\' charging pump during a reactor coolant system (RCS) vacuum fill on May 1, 2010. Dominion has created corrective actions to make procedural enhancements to OP-3304A, Charging and Letdown, and OP-3353.MB1C, Main Board Annunciator Response. The inspectors determined this finding was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors performed an initial screening of the finding in accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations - Significance Determination Process, Checklist 3, PWR Cold Shutdown and Refueling Operation; RCS Open and Refueling Cavity Level < 23\' Or RCS Closed and No Inventory in Pressurizer; Time to Boiling < 2 hours, and determined that the finding was of very low safety significance (Green) because all of the shutdown safety function guidelines were met. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Dominion relied on the work control process to assure that the RPCCW cooling water was in service to the seal water heat exchanger at the time that the RCS vacuum fill was scheduled. Specifically, the work control process was insufficiently robust to ensure that cooling water was supplied to the seal water heat exchanger during charging pump operations (H.3(b)).
05000336/FIN-2010003-052010Q2MillstoneReactor Trip Caused by Loss of Positive Control of Steam Generator LevelA self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to correct a long-standing stability problem with control of the Unit 3 feedwater regulating bypass valves (FRBVs). Operation at low power conditions has resulted in excessive steam generator (SG) level oscillations while in automatic control and unintended equipment response when attempting to control SG level in manual control. The inadequate design of the SG level control system for low power operations was identified by numerous condition reports dating back to 2002, but had not been corrected. Dominion entered this issue into their corrective action program (CR381435, CR384014). The finding is more than minor because it was similar to NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, Example 4b, in that the failure to correct a condition adverse to quality resulted in a reactor trip. The inspectors determined that the finding was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, the long standing condition of the FRBVs\' inability to control SG level at low power operations led to an automatic reactor trip. The inspectors performed an initial screening of the finding in accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined the finding was of very low safety significance (Green) because it did not affect both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that the finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action to address the longstanding adverse conditions associated with control of the FRBVs (P.1 (d)).
05000336/FIN-2010006-012010Q1MillstoneBroken Jacket Water Banjo Bolt Adversely Impacted EDG 3B OperabilityAn unresolved item (URI) was identified because additional information from Dominion and additional NRC review and evaluation is needed to assess the existence of a performance deficiency and its associated characterization (i.e., more than minor, and whether the issue constitutes a violation).During the conduct of 3B EDG routine testing on February 11, 2010, a significant JW system leak occurred at a JW fitting to one of the 14 EDG cylinders. These fittings are referred to as banjo bolts due to their physical configuration resembling a bolt through the body of a banjo. On July 22, 2009, Dominion initiated CR 343051 to address minor JW leakage from the No. 13 cylinder on EDG 38. Dominion estimated the leak rate at approximately 60 drops per minute and determined that it did not have the potential to impact EDG operability. Dominion closed the CR to WO 53102270827. On September22, 2009, operators tagged out EDG 38 for preventive maintenance on the service waterside of the heat exchangers (WO 53102241548). Maintenance completed the planned work on the EDG and operators completed their pre-job briefing for EDG postmaintenance testing. As operators were clearing tags and aligning the EDG for testing, maintenance called to report that during the performance of EDG minor maintenance under WO 53102283391 (to check the leak tightness of No. 13 cylinder banjo bolt), they had discovered that the gasket appeared crushed or the JW fitting could be possibly cracked. They recommended that an immediate repair be pursued. Since the JW banjo bolt tightness check was performed as minor maintenance and not planned into the work window, there were no contingency parts on hand and a corrective maintenance work order was not ready in case of scope expansion. The emergent failure required draining the JW system and resulted in extending the EDG 38unavailability beyond the original planned unavailability (although still within the technical specification allowed outage time). On September 22, 2009, maintenance repaired the JW leak by replacing a degraded banjo bolt on No. 13 cylinder using the original banjo bolt WO 53102270827. Maintenance documented an unanticipated failure of the broken banjo bolt in the WO package. Operations and maintenance supervision reviewed and closed WO 53102270827 with no additional actions taken. On February 11, 2010, operations noted excessive JW leakage from No.3 cylinder during the EDG 3B monthly test, immediately declared the EDG inoperable, performed a controlled shutdown of the EDG, and initiated CR 368610. The team walked down EDG38 shortly after it was shut down and noted that operations had made an appropriate operability decision based on amount of JW that spilled on the floor and the magnitude of the JW leak rate with the EDG shutdown. Dominion determined that the JW leak was from a cracked banjo bolt. The cracked banjo bolt resulted in approximately 20 hours of unplanned unavailability on EDG 38. Maintenance replaced the banjo bolt on NO.3cylinder and operations declared the EDG operable on February 12 following postmaintenance testing. On February 22, 2010, maintenance replaced the banjo bolts on all 14 cylinders on EDG 38, resulting in approximately ten more hours of EDG unavailability. On February 23, 2010, preliminary results from a magnetic particle inspection of the removed EDG 38 banjo bolts revealed seven additional cracked bolts (CR 369856). On February 23, 2010, maintenance replaced all the banjo bolts on the redundant EDG 3A to address the extent-of-condition. Dominion\\\'s initial review of the banjo bolts removed from EDG 3A did not identify any degraded bolts similar to those removed from EDG 38.The team noted that Dominion took prompt and appropriate corrective actions following the emergent banjo bolt failure on February 11; however, the team identified that Dominion had not initiated a corrective action CR in September 2009 when they had identified the first failed banjo bolt. The team noted that this represented a missed opportunity to evaluate the deficiency within Dominion\\\'s CAP, and may have precluded the emergent EDG unavailability in February 2010. Specifically, Dominion procedure PIAA-200, Corrective Action, Attachment 1, listed examples of conditions that require a CR, several of which were applicable to the unanticipated failure of the banjo bolt ,including 1) deficiencies or adverse conditions identified during performance of work, 2)a component failure that is outside of what would normally be expected, and 3)documentation of equipment failures. The team identified that Dominion did not initiate anew CR for the increased JW leakage that potentially impacted EDG operability or for the failed bolt in September 2009, did not re-open and re-screen the July 2009 CR (CR343051), and did not initiate a CR to perform a Maintenance Rule (MR) functional failure evaluation for the banjo bolt failure. The team noted that the failure to initiate a CR for the failed banjo bolt was a missed opportunity because Dominion proactively addressed other JW leaks on EDG 3B during an additional planned unavailability in December 2009 that required draining the JW system. If Dominion had evaluated the banjo bolt failure within their CAP, they may have inspected a sample of banjo bolts and/or proactively replaced all the banjo bolts on the 3B EDG during the December work window. On February 24, Dominion initiated CR 369962 to perform a MR evaluation for the banjo bolt failure discovered in September 2009. Based on the team\\\'s concerns, Dominion initiated CR 370566 for not identifying the degraded JW banjo bolt condition in the CAP in September 2009 and to evaluate their work order documentation review process to address potential generic concerns in this area. The team determined that the degraded condition identified in September 2009 (the broken banjo bolt) was unanticipated and represented an operability concern in contrast to the relatively minor JW leak identified in July 2009. Also the team was concerned that the failure to document the September 2009 failure and take actions to prevent recurrence could have allowed the February 2010 failure during surveillance testing. However, the team concluded that additional information is needed to fully evaluate and characterize the potential performance deficiency. An unresolved item is an issue of concern about which more information is required to determine if a performance deficiency exists, if the performance deficiency is more than minor, or if the issue of concern constitutes a violation. Therefore, this issue will be treated as an URI. Information necessary to complete the NRC\\\'s review is as follows: The failure mechanism of the banjo bolts, including common cause(s); Dominion\\\'s assessment of EDG 3B prior operability (Le., prior to the February 11monthly test), including the associated reportability determination; Confirmation of maintenance history for banjo bolts on both EDG 3A and 3B(Le., preventive maintenance such as torquing, repairs for leaks, replacement, etc.); Assessment regarding the extensive degradation of banjo bolts on EDG 3B (9 out of14) vs. none on EDG 3A; and Dominion\\\'s assessment/communication regarding 10 CFR Part 21 applicability. Upon availability of the above information, additional NRC review will be required to independently assess Dominion\\\'s associated causal analyses for the issue, and determine the appropriate characterization. Specifically, the NRC will assess 1) whether the issue was reasonably within Dominion\\\'s ability to foresee and correct prior to February 2010,2) the banjo bolt failure mechanism, 3) EDG fault exposure, and 4) any associated violations. (URI 05000423/2010006-01, Broken Jacket Water Banjo Bolt Adversely Impacted EDG 3B Operability)
05000336/FIN-2010002-012010Q1MillstoneLicensee-Identified ViolationTechnical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide1.33. Contrary to this, Dominion\'s procedure MP2704U, Containment Personnel Airlock, was inadequate because it was not established with sufficient detail to complete interlock restoration. As a result, the containment airlock interlock was not properly reset at the end of the refueling outage on November 13, 2009. On December 2, 2009, containment integrity was not maintained when the improperly reset interlock allowed both airlock doors to be briefly open during a containment entry while Unit 2 was at 100 percent power. Dominion immediately closed the door and entered the issue into their corrective action process, CR 360277. The finding is of very low safety significance because both airlock doors were only open briefly 1 minute) and there were no other degraded plant conditions that would have created a safety concern during the time the airlock doors were open
05000336/FIN-2009005-022009Q4MillstoneImplementation of Design Change Results in an Unplanned Shutdown of ReactorA self-revealing, Green finding (FIN) was identified for Dominion\'s failure to take Adequate precautions and adequately schedule maintenance on a Unit 2 motor-operated disconnect (MOD) associated with the main transformer. The maintenance on the MOD disrupted a switch connection and caused increasing conductor temperatures, which forced Dominion to perform an unplanned shutdown of the Unit 2 reactor. Dominion has taken corrective action to modify the appropriate procedures and has entered this issue into their corrective action program (CR 351109).This finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors performed a Phase 1screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined the finding was of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available. Enforcement action did not apply because the performance deficiency did not involve a violation of a regulatory requirement. Because this finding did not involve a violation of regulatory requirements, and has very Ipw safety significance (Green), it has been identified as a finding (FIN). This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Dominion did not appropriately incorporate risk insights and work scheduling of activities consistent with nuclear safety. H.3(a
05000336/FIN-2009005-042009Q4MillstoneInadequate and Untimely Corrective Actions Causes Loss of Annunciators and Declaration of a NOUEA Green, self-revealing finding (FIN) was identified for Dominion\'s failure to complete effective corrective actions for known degraded conditions associated with theVR-11 and VR-21 120-volt AC non-vital instrument power supplies. This condition led to a loss of annunciators and declaration of a Notification of Unusual Event (NOUE) on November 15, 2009. Dominion took immediate action to expedite the installation of an uninterruptible power supply (UPS) for VR-11 and VR-21.This finding was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance(Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. No violation of regulatory requirements occurred, because the annunciator system is non-safety related. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. P.1(d
05000336/FIN-2009005-032009Q4MillstoneRCS Drain Down Loss of Configuration ControlA Green, self-revealing non-cited violation (NCV) of Millstone Technical Specification (TS) 6.8.1 (a), Procedures, was identified for Dominion\'s failure to adequately implement procedures during partial draining of the reactor coolant system(RCS) in preparation for defueling the reactor. Dominion did not properly align the reactor vessel vent path prior to partially draining the RCS as required by Dominion procedure OP-2301E, Draining the RCS (ICCE). Immediate corrective actions included stopping the drain down and verifying the valve alignment. Dominion entered this issue into the corrective action program (CR 351853).This finding was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective to limit the likelihood of those events that challenge critical safety functions during shutdown operations. Specifically, the operators failed to properly position 2-RC447to vent to the reactor vessel during partial drain down of the reactor vessel. The inspectors determined the significance of this finding using NRC Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significant Determination Process. This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion failed to define and effectively communicate expectations regarding procedural compliance, and personnel follow procedures. H.4(b
05000336/FIN-2009005-012009Q4MillstoneTS Surveillance Channel Calibration of ICCMS Not PerformedThe inspectors identified a Green, non-cited violation (NCV) of Millstone PowerStation Technical Specification (TS) surveillance requirement 4.3.3.8 for Dominion\'s failure to perform a channel calibration of the Unit 2 Inadequate Core Cooling Monitoring System (ICCMS) every 18 months. Dominion entered the issue into their corrective action program and concluded that the ICCMS was operable. Dominion performed a risk assessment of the missed surveillance in accordance with TS 4.0.3, and determined that the completion of the surveillance could be delayed up to the 18 month surveillance interval without a significant increase in risk. This finding was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone, and affected the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding) protect the public from radionuclide releases caused by accidents or events. Specifically, in 1997, Dominion incorrectly revised surveillance procedure SP 2407A so that it no longer met the requirements of TS surveillance requirement 4.3.3.8. The inspectors determined the finding was of very low safety significance (Green) because it was associated with a fuel barrier of the Barrier Integrity cornerstone. This finding did not have a cross-cutting aspect because the performance deficiency occurred in 1997, and was not indicative of current performance
05000336/FIN-2009004-012009Q3MillstoneInadequate and Untimely Corrective Actions Causes Reactor TripA self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to provide timely and effective corrective actions for known degraded conditions on the Unit 2 VR-11 and VR-21 120-volt AC non-vital instrument power supplies. Specifically, VR-11 and VR-21 were known to cycle on and off repeatedly whenever an electrical disturbance on the grid affected the input supply voltages from their respective regulating transformers. The degraded condition on the instrument buses had not been corrected despite numerous prior opportunities and Ultimately led to a reactor trip on July 3, 2009. Dominion entered this issue into their corrective action program (CR340569 and CR340579). Interim corrective actions included the installation of dedicated uninterruptable power supplies (UPS) for the Electro-Hydraulic Control (EHC) system and feedwater level control system loads prior to reactor startup. Final corrective actions to install a larger UPS to power the VR-11 and VR-21 DC buses are under engineering evaluation. This finding is more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Dominion did not implement effective interim corrective actions, nor did they take timely final corrective actions to prevent recurrence of the power cycling of the VR-11 and VR-21 instrument buses in time to prevent a reactor trip on July 3, 2009. The inspectors performed a Phase 1 screening, in accordance with fMC 0609, Significance Determination Process, and determined that the finding is of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity P.1.d
05000220/FIN-2009004-012009Q3Nine Mile PointUnqualified HPCS Pump Power Cables Used in Submerged ConditionsAn NRC-identified non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified, in that Nine Mile Point Nuclear Station (NMPNS) failed to maintain the Unit 2 high pressure core spray (HPCS) pump power cables in an environment for which they were designed. Although NMPNS had indications that these cables were periodically submerged in water, they could not demonstrate that the cables were designed for submerged conditions. As immediate corrective action, NMPNS dewatered and inspected the HPCS cable run, and changed the frequency of dewatering to monthly. Based on the inspection results, along with the cable design specifications and most recent test results, NMPNS concluded that the HPCS pump power cables would remain operable while they conduct a design change evaluation to examine methods to reduce cable exposure to submerged conditions. The issue was entered into the corrective action program (CAP) as condition report (CR) 2009-2901.The finding was more than minor because, if left uncorrected, it had the potential to lead to a more significant safety concern. The finding affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was of very low safety significance because it was a qualification deficiency that did not result in loss of operability. The finding had a cross-cutting aspect in the area of problem identification and resolution, operating experience, because NMPNS did not use operating experience, such as Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients, to evaluate possible adverse effects of periodic submergence of the HPCS pump power cables (P.2.a per IMC 0305).
05000336/FIN-2009004-022009Q3MillstoneInadequate Procedures Caused a Leak from the Charging Header into the Auxiliary Building Drain SystemA violation of 10 CFR 50, Appendix 8, Criteria V dispositioned as an NCV was identified for Dominion\'s failure to provide adequate operating procedures that were appropriate for the circumstances to operate the Unit 2 charging pumps during reactor shutdown. Specifically, on July 9, 2009, the operators were required to raise pressurizer level while drawing a bubble in the pressurizer in preparation for transitioning from mode5 to mode 4. Dominion started the 8 positive displacement charging pump without first opening the charging header isolation valves and damaged two relief valves in the charging line. Neither of the operating procedures in use for this evolution required the charging header isolation valves to be opened. This event was more than minor because if left uncorrected, the performance deficiency had a potential to lead to a more significant safety concern. This finding is associated with the equipment performance attribute of the mitigating systems cornerstone. The finding has a cross-cutting aspect in the area of human performance, maintaining complete accurate and up-to-date procedures, because Dominion did not provide an operating procedure that was appropriate for accomplishing the task under the circumstances (H.2.c).
05000336/FIN-2009004-042009Q3MillstoneLicensee-Identified Violation10 CFR Part 50.54(q), Conditions of licenses, states in part, A holder of a nuclear power reactor operating license under this part, or a combined license under part 52of this chapter after the Commission makes the finding under 52.1 03(g) of this chapter, shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of this part. Contrary to this requirement, on several occasions in December 2008 and January 2009, the Emergency Medical Technician (EMT) position was not staffed as required by the Emergency Plan. Prior to 2007, the Millstone Power Station fire brigade was an independent organization responsible for meeting the qualified EMT Emergency Plan requirement. In 2007, the site fire brigade became part of the Operations Department and Plant Equipment Operators (PEO) became responsible for meeting the EMT requirement. This change to the organizational structure impacted the Emergency Plan in that some of the PEOs did not maintain their EMT qualifications. This resulted in the EMT position not being staffed on multiple occasions in December 2008 and January 2009. The Dominion Emergency Plan requires the EMT position to be staffed on a continuous basis. This finding is of very low safety significance based on a SDP Phase 1 screen utilizing IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process. Upon identifying the issue, Dominion entered the issue into their corrective action program as CR 0712258to capture the non-compliance with the Emergency Plan. The finding is licensee-identified because it was discovered by Dominion during a self evaluation in2007 (CR-07-12258).