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SUBJECT: MILLSTONE POWER STATION . NRC INTEGRATED INSPECTION REPORT05000336/20 1 1 003 AND 050004231201 1003

==Dear Mr. Heacock:==
On June 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection atyour Millstone power Station Unit 2 and Unit 3. The enclosed inspection report documents theinspection results, which were discussed on August 1,2011, with Mr. A. J. Jordan and othermembers of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations, and with the conditions of yourlicense. The inspectors reviewed selected procedures and records, observed activities, andinterviewed personnel.This report documents two NRC-identified findings and two self-revealing findings of very lowsafety significance (Green). Three of these findings were determined to involve violations ofNRC-req-uirements. However, because of the very low safety significance and because theyhave been entered into your corrective action program (CAP), the NRC is treating these{in_dingsas non-cited violations (i.fCVs) consistent with Seition 2.3.2.a of the NRC Enforcement Policy'lf you contest any NCV in this report, you should provide a response within 30 days of the dateof this inspectionreport, with the basis for your denial, to the Nuclear Regulatory Commission,ATTN.: Document iontrol Desk, Washington DC 20555-0001; with copies to the RegionalAdministrator, Region l; the Director, Offile of Enforcement, United States Nuclear RegulatoryCommission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector atMillstone. In addition, if you disagree with the cross-cutting aspect assigned to any finding inthis report, you should piovide a response within 30 days of the date of this inspection report,with the baiis for your disagreement, to the RegionalAdministrator, Region l, and the NRCSenior Resident Inspector at Millstone.

D. HeacockIn accordance with Title 10 of the Code of Federal Regulations (CFR) Part 2.390 of the NRC's"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Web Site at http://www.nrc.qov/readinq-rm/adams.html (thePublic Electronic Reading Room).Donald E. JacksProjects Branch 5Division of Reactor ProjectsDocket Nos. 50-336. 50-423License Nos. DPR-65, NPF-49

===Enclosure:===
Inspection Report No. 0500033612011003 and O5OOO42312O1 1003W 

===Attachment:===
Supplemental Informationcc Mencl: Distribution via Listserv D. Heacockln accordance with Tiile 10 of the Code of Federal Regulations (cFR) Part 2.390 of the NRC's,,Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will beavailable electronicallv fii public inspection in the NRC Public Document Room or from theFrnti.ty Avairabre Recoros'(pARS) component of the NRC's document system (ADAMS)'ADAMS is accessible from ir'" Nnb we'n site at http://www.nrc.qov/readinq-rm/adams.html (thePublic Electronic Reading Room).SincerelY,/RA/Donald E. Jackson, ChiefProjects Branch 5Division of Reactor ProjectsDocket Nos. 50-336, 50-423License Nos. DPR-65, NPF-49

===Enclosure:===
lnspection Report No. 0500033612011003 and 050004231201 1003M 

===Attachment:===
Supplemental lnformationDistribution w/encl:W. Dean, RAD. Lew. DRAD. Roberts, DRPJ. Clifford, DRPD. Jackson, DRPP. Wilson, DRSC. Miller, DRSJ. McHale, RIOEDOT. Setzer, DRPD. Dodson, DRPS. Shaffer, DRP, SRIJ. Krafty, DRP, RlB. Haagensen, DRP, RlC. KowalyshYn, DRP, OARidsNRRPM Millstone ResourceRidsN RRDo rlLPll -2 Resou rceROPreports@NRC.govSUNSI Review Gomplete: S (Reviewer's Initials)DOCU MENT NAME:G IDRP\BRANCHs\Reports\Final\MillstonelRl 1 03'docxAfter declaring this document "An Official Agency Record" it will.be released to the Public'To receive a copy of this document, indiiate in the box: "G" = copy without attachmenuenclosure "E" = copywith attachmenUenclosure "N" = No copyML11216Q449orrrctt RECORD COPY Docket No.:License No.:Report No.:Licensee:Facility:Location:Dates:Inspectors:Approved by:1U.S. NUCLEAR REGULATORY COMMISSIONREGION I50-336, 50-423DPR-65, NPF-4905000336/201 1 003 and 05000 4231201 1003Dominion Nuclear Connecticut, Inc.Millstone Power Station, Units 2 and 3P. O. Box 128Waterford, CT 06385April 1 ,2011through June 30, 2011S. Shaffer, Senior Resident Inspector, Division of Reactor Projects (DRP)J. Krafty, Resident Inspector, DRPB. Haagensen, Resident Inspector, DRPM. Modes, Senior Reactor Inspector, Division of Reactor Safety (DRS)T. Moslak, Health Physicist, DRSDonald E. Jackson, ChiefProjects Branch 5Division of Reactor ProjectsEnclosure 2Table of ContentssuMMARy OF FlNDlNGS........... .........31. REACTOR SAFETY ......................61R01 Adverse Weather Protection .............61R04 Equipment Alignment. .......................71R05 Fire Protection............ ......................91R08 In-Service Inspection ..... 101R11 Licensed Operator Requalification Program.........,.... ........111R12 Maintenance Effectiveness .............121R13 MaintenanceRiskAssessmentsandEmergentWorkControl...... ......121R15 Operability Evaluations ...................131R18 Plant Modifications.... ..... 161R19 Post-Maintenance Testing .............. 161R20 Refueling and Other Outage Activities ............. 1g1R22 Surveillance Testing ...... 19IEPO Drill Evaluation........... .....................212. RADIATION SAFETY ..................212RS01 RadiologicalHazard Assessment and Exposure controls.... ..............212RS02 OccupationalALAM Planning and Controts.............. ......242RS03 In-Plant Airborne Radioactivity Control and Mitigation ............ ...........262RS04 Occupational Dose Assessment.............. ........272RS05 Radiation Monitoring Instrumentation.......... .....282RS06 Radioactive Gaseous and Liquid Effluent Treatment ........304. OTHER ACTIVITlES [OA]....... .....324OA1 Performance Indicator (Pl) Verification ......... ....................324OA2 ldentification and Resolution of Problems............... ..........324OA3 Event Follow-up .............374OAO Meetings, including Exit........... .......42ATTACHMENT: SUPPLEMENTAL I NFORMATIONSUPPLEMENTAL INFORMATION........... ...........A-1KEY POINTS OF CONTACT.A-1LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED ....A-2LIST OF DOCUMENTS REVIEWEDLIST OF ACRONYMS.A-11Enclosure42A-3 3SUMMARY OF FINDINGSlR 0500033612011003, 0500042312011003; 0410112011 - 0613012011; Millstone Power StationUnit 2 and Unit 3; Operability Evaluations, Surveillance Testing, Event Follow-up.The report covered a three-month period of inspection by resident and region-based inspectors.Four Green findings, three of which were non-cited violations (NCV), were identified. Thesignificance of most findings is indicated by their color (Green, White, Yellow, Red) usingInspection Manual Chapter (lMC) 0609, "Significance Determination Process." The cross-cutting aspects were determined using IMC 0310, "Components Within the Cross CuttingAreas." Findings for which the significance determination process (SDP) does not apply may beGreen or be assigned a severity level after NRC management review. The NRC's program foroverseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.Cornerstone: Initiating EventsGreen. A self-revealing finding (FlN) of very low safety significance (Green) wasidentified for Dominion's failure to follow procedure OP 2204, "Load Changes," whenstarting the 'A' steam generator feedpump (SGFP). Specifically, the operating crewfailed to maintain adequate SGFP suction pressure (greater than 325 psig) while startingthe 'A' SGFP, which led to a trip of the 'B' SGFP and subsequent reactor trip on lowsteam 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 conditionsdegrade; and has revised procedure OP 2204.The finding is more than minor because it is similar to NRC Inspection Manual Chapter0612, Appendix E, "Examples of Minor lssues," Example 4b; in that, a failure to followprocedure led to a reactor trip. This issue is associated with the Human Performanceattribute of the Initiating Events cornerstone and affected the cornerstone objective tolimit the likelihood of those events that upset plant stability and challenge critical safetyfunctions during shutdown as well as power operations. Specifically, the failure of theoperators to properly monitor SGFP suction pressure led to a loss of adequatefeedwater flow and a reactor trip. The inspectors conducted a Phase 1 screening inaccordance with NRC Inspection Manual Chapter (lMC) Attachment 0609.04, "Phase 1- Initial Screening and Characterization of Findings," and determined that the findingwas of very low safety significance (Green) because it did not contribute to both thelikelihood of a reactor trip and the likelihood that mitigation equipment or functions wouldnot be available.The inspectors determined that this finding had a cross-cutting aspect in the HumanPerformance cross-cutting area, Work Practices component, because Dominionpersonnel did not properly follow the load changes procedure. tH.4(b)l (Section 4OA3)Enclosure 4Cornerstone: Mitigating SYstemsGreen. The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl,rcorrective Action," for Dominion's failure to take timely corrective actions for a conditionadverse to quality involving the degradation and subsequent through-wall leakage ofUnit 3 service water valves 3SWP.V699 (3HVQ.ACUS1B Bypass Valve), 3SWP.VO18(3HVQ.ACUS2B Unit Cooler Inlet Valve), and 3SWP*V696 (3HVQ.ACUS2B Unit CoolerOutlet Valve). Specifically, Dominion did not adequately implement a schedule forprioritizing and completing corrective actions on affected aluminum bronze components,which were known to be susceptible to de-alloying, commensurate with the safetysignificance of the degraded condition. As a result, through-wall leaks developed onthese valves and resulted in unplanned loss of operability and additional unavailability ofthe safety-related support systems for the 'B' train of containment recirculation spraypumps. bominion took immediate corrective action to replace the three leaking servicewater (SW) valves (CR428785).The inspectors determined that this issue was more than minor because it is similar tothe more than minor example, 4.f , of IMC 0612, Appendix E, "Examples of Minorlssues." Specifically, the degraded condition caused a loss of operability of the 'B' trainof the containment iecirculation spray system. Additionally, the finding was more thanminor because it is associated with the Equipment Performance attribute of theMitigating Systems cornerstone, and adversely affected the cornerstone objective ofensuring-the availability of systems that respond to initiating events to preventundesirable consequences. ln accordance with NRC lnspection Manual Chapter 0609,Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1SDp screening was performed and determined the finding was of very low safetysignificance (Green) because it was not a design or qualification deficiency, did notrepresent an actual loss of system safety function of a single train for greater than itsTechnical Specification allowed outage time, and did not screen as potentially risksignificant due to a seismic, flooding, or severe weather initiating event.The finding had a cross-cutting aspect in the Problem ldentification and Resolutioncross-cutting area, Corrective Action Program component, because Dominion did notensure thatissues potentially impacting nuclear safety were corrected in a timelymanner commensurate with their safety significance. Specifically, Dominion failed toadequately implement corrective actions to address a known de-alloying issue with SWvalves before ihe condition led to the unplanned loss of operability and additionalunavailability of the safety-related support systems for the 'B' train of containmentrecirculation spray pumps [P'1(d)]' (Section 1R15). Green. The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl,rcorrective Action," for Dominion's failure to take timely corrective action to addressrepetitive out of calibration conditions associated with safety-related 120 VAC Unit 2inverters. To date, Dominion has taken corrective action to adjust the over-frequencyand under-freq uency transfer limits (CR426589).The inspectors determined the finding was more than minor because it is similar to themore than minor Example '4f' of NRC lnspection Manual Chapter (lMC) 0612, AppendixE, "Examples of Minor issues." Additionally, the issue is more than minor because theEnclosure 5performance 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 leadto the unavailability of safety-related equipment powered from the inverters. Theinspectors conducted a Phase 1 screening in accordance with NRC IMC Attachment0609.04, "Phase 1 - lnitial Screening and Characterization of Findings," and determinedthat the finding was of very low safety significance (Green) because it was not a designor qualification deficiency, did not represent a loss of system safety function, did notrepresent an actual loss of safety function of a single train, and did not screen aspotentially 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 Problemldentification and Resolution cross-cutting area, Corrective Action Program component,because Dominion did not take appropriate corrective action in a timely manner toaddress the repetitive out of calibration conditions with the 120 VAC safety relatedinverters. tP.1(d)l (Section 1R22)Cornerstone: Barrier IntegritY. Green. A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl,"Corrective Action," was identified for Dominion's failure to take prompt corrective actionto address the cause of main steam safety valve (MSSV) exhaust pipe bushings notseating, which resulted in a loss of the Enclosure Building's safety function to control therelease of radioactive material. Dominion took corrective action to clean and lubricatethe MSSV exhaust pipe and also implemented a modification to upgrade the MSSVoutlet 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 Qualityattribute of the Barrier Integrity cornerstone and affected the cornerstone objective toprovide reasonable assurance that physical design barriers protect the public fromradionuclide releases caused by accidents or events. Specifically, the failure of theMSSV 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 ofradioactive material could not be assured. The inspectors conducted a Phase 1screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment0609.04, "Phase 1 - Initial Screening and Characterization of Findings," and determinedthat the finding was of very low safety significance (Green) because it only represents adegradation of the radiological barrier function provided for the auxiliary building.The inspectors determined that this finding had a cross-cutting aspect in the Problemldentification and Resolution cross-cutting area, Corrective Action Program component,because Dominion did not take appropriate corrective action to address the EnclosureBuilding surveillance test failure in 2009. [P.1(d)] (Section 4OA3)Enclosure 6REPORT DETAILSSummarv of Plant StatusMillstone Units 2 and 3 began the inspection period operating at 100 percent power. On April 2,2011, Unit 2 was shutdown to begin refueling outage 2R20. Unit 2 returned to 100 percentpower on May 4,2011. On June 20, 2011, Unit 2 reduced power to 30 percent to repair an oilleak on the'C' reactor coolant pump (RCP) motor. Following repairs, Unit 2 increased power toapproximately 59 percent power when the plant tripped on low steam generator water level.Unit 2 returned to 100 percent power on June 23, 2011 . Unit 3 remained at or near 100 percentpower for the entire inspection period.1. REACTORSAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01 Adverse Weather Protection (71111.01 - 3 samples).1 External Floodinq Inspectiona. Inspection ScopeThe inspectors evaluated Dominion's readiness to cope with external flooding at Unit 2and Unit 3. The inspectors reviewed the Unit 2 and Unit 3 Updated Final Safety AnalysisReport (UFSAR) and identified areas that could be affected by external flooding due to adesign basis flood. The inspectors reviewed applicable procedures to verify that theactions required in the event of flooding could reasonably be completed, and that theappropriate equipment was pre-staged. The inspectors performed walkdowns of theUnit 2 and Unit 3 intake structures, fire pump houses, and inspected the materialcondition of flood doors in order to determine if the structures and components werebeing adequately maintained. Documents reviewed during the inspection are listed inthe Attachment.b. FindinqsNo findings were identified..2 Grid Stabilitv - Readiness of Offsite and Alternate AC Power Svstemsa. Inspection ScopeThe inspectors reviewed Dominion's Independent System Operator (lSO) New Englandand Connecticut Valley Electric Exchange (CONVEX) procedures for notifications ofabnormal grid conditions to determine if they were adequate to ensure the reliability ofalternating cunent (AC) power systems. The inspectors reviewed Dominion'sprocedures to determine if they addressed inadequate post-trip voltages of the offsitepower supply, unknown post trip voltages, reassessment of risk when maintenanceactivities could affect grid reliability, and required communication between Dominion andEnclosure 7ISO New England/CONVEX when changes at the site could impact the transmissionsystem. The inspectors interviewed selected shift managers to determine if they weredmiliar with the procedures for abnormal grid conditions. The inspectors performed awalkdown of the switchyard, main transformers, normal station service transformers, andreserve station service transformers; and performed a review of the system healthreports for the switchyard and transformers in order to determine the material conditionof the offsite power sources.b. FindinqsNo findings were identified..3 Seasonal Site lnsPectiona. lnspection ScopeThe inspectors performed a review of Dominion's readiness for hurricane season. Theinspectors reviewed selected equipment, instrumentation, and supporting structures todetermine if they were configured in accordance with Dominion's procedures, and thatadequate controls were in place to ensure functionality of the systems. The inspectorsreviewed the Unit 2 and Unit 3 UFSAR and Technical Specifications (TS) and comparedthe analysis with procedure requirements to ascertain that procedures were consistentwith the UFSAR. The inspectors performed partial walkdowns of the Unit 2 and Unit 3intake structures, fire pump houses, flood doors, and flood protection equipment todetermine the material condition of installed flood protection equipment, and verify thatthe portable flood protection equipment was properly staged. The inspectors alsoreviewed previous CRs and work orders to verify that the deficiencies identified havebeen corrected. Documents reviewed during the inspection are listed in the Attachment.b. FindinqsNo findings were identified.1 R04 Equipment Aliqnment (71111 .04 - 3 samples).1 Partial Svstem Walkdownsa. Inspection ScopeThe inspectors performed three partial system walkdowns during this inspection period.The inspectors reviewed the documents listed in the Attachment to determine the correctsystem alignment. The inspectors performed a walkdown of each system to determine ifthe critical portions of the selected systems were correctly aligned, in accordance withthe procedures, and to identify any discrepancies that may have had an effect onoperability. The walkdowns included selected switch and valve position checks, andverification of electrical power to critical components. Finally, the inspectors evaluatedother elements, such as material condition, housekeeping, and component labeling' TheEnclosure Ifollowing systems were reviewed based on their risk significance for the given plantconfiguration:Unit 2. Spent Fuel Cooling with the 'A' Low Pressure Safety Injection (LPSI) pump and 'A'Shutdown cooling (SDC) heat exchanger with the core off-loaded in the spent fuelpool on April 13,2011;o 'B' High Pressure Safety Injection (HPSI) train while the 'A' train was out of service(OOS) for testing on May 12,2011; andUnit 3. 'A' system HPSI with the 'B' train out for testing on May 5, 2011.b. FindinqsNo findings were identified..2 Complete Svstem Walkdown (71111.04S - 1 sample)a. Inspection ScopeThe inspectors completed a detailed review of the alignment and condition of Unit 2EBFS. The inspectors performed a walkdown of the system to determine whethercritical portions, such as circuit breakers and switches, were aligned in accordance withprocedures and to identify any discrepancies that may have had an adverse effect onoperability. The inspectors also reviewed the system health reports, condition reports,and Maintenance Rule evaluations to determine whether equipment problems werebeing identified and appropriately resolved. Documents reviewed during the inspectionare listed in the Attachment.b. FindinqsNo findings were identified.Enclosure 91R05 Fire Protection (71111.05Q - 5 samples).1 Fire Protection Toursa. Inspection ScopeThe inspectors performed walkdowns of five fire protection areas. The inspectorsreviewed Dominion's fire protection program to determine the required fire protectiondesign features, fire area boundaries, and combustible loading requirements for theselected areas. The inspectors walked down these areas to assess Dominion's controlof transient combustible material and ignition sources. In addition, the inspectorsevaluated the material condition and operational status of fire detection and suppressioncapabilities, fire barriers, and any related compensatory measures. The inspectorscompared the existing conditions of the areas to the fire protection programrequirements to determine if all program requirements were being met. Documentsreviewed during the inspection are listed in the Attachment. The fire protection areasreviewed included:Unit 2o Containment Building, Fire Area C-1;o West DC Switchgear Room, Fire Area A-21;. West Battery Room, Fire Area A-23;. Auxiliary Building, -5' General Area, Fire Area A-1; andUnit 3o East Motor Control Center (MCC) and Rod Control Area, Fire Area AB-5'FindinqsNo findings were identified.Annual Fire Drill Observation (71111'05A - 1 sample)lnspection ScopeTo evaluate the readiness of station personnel to fight fires, the inspectors observedDominion personnel performance during a fire brigade drill on May 13,2011' The drillsimulated a fire in the Unit 2 East Cable Vault in the turbine building. The inspectorsobserved the fire brigade members using protective clothing, turnout gear, self-containedbreathing apparatuslnd entering the fire area. The inspectors also observed the firefighting Jquipment brought to the fire scene to evaluate whether sufficient equipmentwis aiailable to effectively control and extinguish the simulated fire' The inspectorsevaluated whether the peimanent plant fire hose lines were capable of reaching the firearea and whether hose usage was adequately simulated. The inspectors observed thefire fighting directions and c6mmunications between fire brigade members. TheinspeitorJalso evaluated whether the pre-planned drill scenario was followed andEnclosureb..2"4.

10observed the post drill critique to evaluate if the drill objectives we-re satisfied and thatany drillweaknesses were discussed. The inspectors evaluated fire brigadeperformance, including the readiness of the fire brigade to fight fires and the utilization ofpreplanned strategies.b. FindinqsNo findings were identified.1R08 ln-Service Inspection (71111.08 - 1 sample)a. Inspection ScoPeln-Service Insoection ProqramThe inspectors reviewed a sample of nondestructive examination activities anddiscussed the results of the examination with the Dominion corporate Level lll ln-ServiceInspection Inspector. There were no volumetric or surface examinations from theprevious outage with relevant indications that were analytically evaluated and acceptedby Dominion for continued service.Vessel Head InspectionNo vessel head activities were performed during this outage'Weldino and Repair ProqramThe inspectors reviewed a complete welding and fabrication package consisting of arevised piping anchor to determine if the welding activities were performed inaccordance with American Society of Mechanical Engineers (ASME) Coderequirements, or an NRC approved alternative'Boric Acid Control ProqramThe inspectors reviewed the boric acid control program with the Dominion engineeringlead. The inspectors reviewed the photographic evidence of boric acid leaks with theDominion engineering lead and discussed various engineering evaluations performed forboric acid found on Riactor Coolant System (RCS) piping and components. Also, theinspectors verified that degraded or non-conforming conditions are identified properly inDominion's corrective action program.Steam Generator (SG) ProqramNo in-situ pressure testing'was performed during this inspection. The inspectorscompared the estimated Jize and number of tube flaws detected during the currentoutage against the previous outage operational assessment predictions to assessDomlnion:s prediction capability. The inspectors confirme_d that the SG tube eddycurrent examination scope and e*pansion criteria meet TS requirements, Electric PowerEnclosure 11Research Institute Guidelines, and commitments made to the NRC. The inspectorsconfirmed all areas of potential degradation (based on site-specific experience andindustry experience) are being inspected, especially areas which are known to representpotentiil eddy current challenges. The inspectors confirmed that the eddy currentprobes and equipment are qualified for the expected types of tube degradation andassessed the site specific qualification of one or more techniques.Because Dominion identified loose parts or foreign material on the secondary side of theSG, the inspectors evaluated Dominion's corrective actions. The inspectors confirmedthat Domin'ron has taken/planned appropriate repairs of affected SG tubes, andinspected the secondary side of the SG to remove foreign objects. lf the foreign objectsare inaccessible, the inspectors determined whether Dominion has performed anevaluation of the potential effects of object migration and/or tube fretting damage' Theinspectors reviewed a random sample of eddy current data in this regard.b. FindinqsNo findings were identified1R1 1 Licensed Operator Requalification Proqram (71111.11 - 3 samples)Resident Inspector Quarterlv Review (7 1111.1 1O)a. lnspection ScoPeThe inspectors observed simulator-based licensed operator requalification training forUnit 2 on May 24,2011, and June 7, 2A11, and for Unit 3 on June 7, 2011. Theinspectors evaluated crew performance in the areas of clarity and formality ofcommunications; ability to take timely actions; prioritization, interpretation, andverification of alarms; procedure use; control board manipulations; oversight anddirection from supervisors, and command and control. Crew performance in these areaswas compared to Dominion management expectations and guidelines as presented inOp-Mp-100-1000, "Millstone Operations Guidance and Reference Document." Theinspectors compared simulator configurations with actual control board configurations'The inspectors also observed Dominlon evaluators discuss identified weaknesses withthe crew and/or individual crew members, as appropriate. Documents reviewed duringthe inspection are listed in the Attachment.b. FindinqsNo findings were identified.Enclosure 121R12 Maintenance Effectiveness (71111.12Q- 1 sample)a. Inspection ScoPeThe inspectors performed one maintenance effectiveness inspection sample ofDominion's evaiuation of degraded conditions for the Unit 2 Charging and Letdownsystem. The inspectors reviewed Dominion's implementation of the "Maintenance Rule,"10 CFR 50.65. ihe inspectors reviewed Dominion's ability to identify and addresscommon cause failures; the applicable maintenance rule scoping document for eachsystem; the current classification of these systems in accordance with 10 CFR 50.65piragraph (aX1) or (a)(2); and the adequacy oj the performance criteria and goalsestablished foi each sysiem, as appropriate. The inspectors also reviewed recentsystem health reports, Condition Reports (CR), apparent cause determinations'functionalfailure determinations, and discussed system performance with theresponsible iystem engineer. Documents reviewed during the inspection are listed inthe Attachment.b. FindinqsNo findings were identified.1R13a.(71111.13 - 9 samPles)Inspection ScoPeThe inspectors evaluated online risk managementfor emergent and planned activities'The inspectors reviewed maintenance risk-evaluations, work schedules, and controlroom logs to determine if concurrent planned and emergent maintenance or surveillanceactivitiel adversely affected the plant risk already incurred with out-of service (oos)-omponents. Thg,inspectors evaluated whether Dominion took the necessary steps tocontrol work activities, minimize the probability of initiating events, and maintain thefunctional capability of mitigating systems. The inspectors assessed Dominion's riskr"n"g"t"ni actiohs during plant walkdowns' Documents reviewed during theinspeJtion are listed in the Aitachment. The inspectors reviewed the conduct andadequacy of risk assessments for the following maintenance and testing activities:Unit 22R2O Shutdown Risk Assessment on March 31,2011;Orange Risk for RCS Drain down to Mid-Loop on April 5,2011;Orange Risk for North Bus Outage on April 5,2Q11;Orante Risk for Replaceme nt of 2 SW-978 (only one train of SW available) on April7,2011;Risk Mitigation Plan for lsophase Bus Duct Seal Bushing Installation on April 19'2011;Alternate Plant Configuration for lsolating the 'A' Pressurizer Spray Line;Yellow Risk for'A' S\i/ pump OOS and ECCS suction valve testing on May 24' 2011;aaaaoaEnclosure 13Unit 3o Emergent risk assessment for a failure of the Sl logic module in the SSPS train 'B'while iwitchyard work was in progress on April 18, 2011; ando Emergent work to replace SW valves 3SWP"V699, 3SWP"V018 and 3SWP*V696due to de-alloYing.b. FindinqsNo findings were identified.1R15 Operabilitv Evaluations (71111-15 - 7 samples)a. lnspection ScoPeThe inspectors reviewed seven operability determinations (OD). The inspectorsevaluated the ODs against the guidance contained in NRC Regulatory lssue Summary2OOS-20, Revision tobuidance Formerly Contained in NRC Generic Letter 91-18,"lnformation to Licensees Regarding Two NRC lnspection Manual Sections onResolution of Degraded and Nonconforming Conditions and on Operability'" Theinspectors atso discussed the conditions with operators, and system and designengineers, as necessary. Documents reviewed during the inspection are listed in theAttachment. The inspectors reviewed the adequacy of the following evaluations ofdegraded or non-conforming conditions:Unit 2Engineering Technical Evaluation, ETE-MP-2011-0030, addressing a small breach inthe control room envelope via a halon piping penetration;Engineering Technical Evaluation, ETE-MP-201 1 -0045, providing use-as-isconclusion on terry turbine shaft pitting;ODM 000202, Operation with 2-RS-252, Loop 1A Pressurizer Spray Header lsolationValve closed;Unit 3RAS 000176 l CR41g723, "Fire Shutdown Analysis Time Critical Operator Action(TCOA) to secure RCPs," dated March 28,2Q11;CR427354, Degraded Condition for MOV 87018 and MOV 8702A RHR lsolations;ODM000192, "Addressing Increased Hydrogen Pressure in the VCT Creating anlncrease in UnidentitieO RCS leakage and Increased Leakage From the 'D' RCP #1Seal Leak-off," dated March 17,2011; andaaEnclosure 14. 1OD000173, "lnitial Operability for Aluminum-Bronze Service Water Valves De-alloying," dated May 25,2011.Findinqslntroduction: The inspectors identified a Green NCV of 10 CFR 50, Appendix B,Criterion XVl, "Corrective Action," for Dominion's failure to take timely corrective actionsfor a condition adverse to quality involving the degradation and subsequent through-wallleakage 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 adequatelyimplement a schedule for prioritizing and completing corrective actions on affectedaluminum 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 ofoperability and additional unavailability of the safety-related support systems for the 'B'train of containment recirculation spray pumps.Description: On May 25,2011, through-wall leaks were identified on SW valves3SWP.V699, 3SWP*V018, and 3SWP.V696. These valves provide cooling water flowto the room air conditioning units that support the 'B' train of containment recirculationspray pumps. The leaks were caused by de-alloying of the aluminum bronze (Al-Br)valve bodies that had not been properly heat-treated to prevent the galvanic leaching ofaluminum from the Al-Br metal matrix. Dominion had previously identified thesusceptibility of these service water (SW) valves to de-alloying in apparent causeevaluation (ACE) 017509 dated March 30, 2009. Dominion had identified the de-alloyingissue, characterized the de-alloying process, and determined that the cause was due toan old design issue where Al-Br valves had been procured without a specified heat-treatment that would have minimized the susceptibility of the valves to the de-alloyingprocess. Dominion concluded in ACE 017509 that, "Based on past experience, this newvalve (3SWP.V699) will leak 12to 18 months from installation." Dominion thenprioritized all installed SW valves that were susceptible to de-alloying into four tiersbased on their susceptibility and risk significance in the extent of condition assessment.Valves 3SWP.V699, 3SWP*V018, and 3SWP.V696 were prioritized as "tier one" andshould have been replaced promptly.Dominion subsequently initiated CR428785 on May 25, 2011, to address through-wallleakage from these SW valves and completed OD0004211o assess operability andextent of condition. The leaking valves were replaced and the air conditioners(3HVQ.ACUS1B and 3HVQ.ACUS2B) were returned to service on May 26,2011. Therepeated failure of 3SWP.V699 and the additionalfailures of 3SWP.VO18 and3SWP.V696 resulted in the loss of operability and additional unavailability of the 'B' trainof containment recirculation spray pumps during valve replacement.Analysis: The inspectors determined that the failure to take timely corrective actionfollowing identification of a degraded condition was a performance deficiency that wasreasonably within Dominion's ability to foresee and prevent, Traditional Enforcementdoes not apply because the issue did not have any actual safety consequences orEnclosure 15potential for impacting the NRC's regulatory function, and was not the result of any willfulviolation of NRC requirements.The inspectors determined that this issue was more than minor because it is similar tothe more than minor example, 4.f , of IMC 0612, Appendix E, "Examples of Minorlssues." Specifically, the degraded condition caused a loss of operability of the 'B' trainof the containment recirculation spray system. Additionally, the finding was more thanminor because it is associated with the Equipment Performance attribute of theMitigating Systems cornerstone, and adversely affected the cornerstone objective ofensuring the availability of systems that respond to initiating events to preventundesirable consequences. In accordance with NRC Inspection Manual Chapter 0609,Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1SDP screening was performed and determined the finding was of very low safetysignificance (Green) because it was not a design or qualification deficiency, did notrepresent an actual loss of system safety function of a single train for greater than itsTechnical Specification allowed outage time, and did not screen as potentially risksignificant due to a seismic, flooding, or severe weather initiating event.The finding had a cross-cutting aspect in the Problem ldentification and Resolutioncross-cutting area, Corrective Action Program component, because Dominion did notensure that issues potentially impacting nuclear safety were corrected in a timelymanner commensurate with their safety significance. Specifically, Dominion failed toadequately implement corrective actions in a timely fashion to address a known de-alloying issue with SW valves before the condition led to the inoperability andunavailability of the safety-related support systems for the 'B' train of containmentrecirculation spray pumps [P. 1 (d)].Enforcement: 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, inpart, that measures shall be established to assure that conditions adverse to quality,such as failures, malfunctions, deficiencies, deviations, defective material andequipment, and non-conformances are promptly identified and corrected. Contrary tothe above, from March 30, 2009, to May 25, 2011, Dominion did not take timelycorrective actions to correct the de-alloying of Al-Br SW valves prior to the conditionadversely impacting 'B' containment recirculation spray system operability. Dominiontook immediate corrective action to replace the three leaking SW valves. Because theissue is of very low safety significance (Green) and has been entered into Dominion'sCAP (CR428785), the NRC is treating this finding as an NCV, consistent with the NRC'sEnforcement Policy. (NCV 05000423/2011003-01, Failure to Take Timely CorrectiveActions for De-alloying of Aluminum Bronze Service Water Valves).Enclosure 161R18 Plant Modifications (71111.18 - 4 samples)a. lnspection ScoPeTo assess the adequacy of the modifications, the inspectors performed walkdowns ofselected plant systems and components, interviewed plant staff, and reviewedapplicable documents, including procedures, calculations, modification packages,engineering evaluations, drawings, corrective action program documents, the UFSAR,and TS.For the modifications reviewed, the inspectors determined whether selected attributes(component safety classification, energy requirements supplied by supporting systems,seismic qualificatibn, instrument setpoints, uncertainty calculations, electricalcoordination, electrical loads analysis, and equipment environmental qualification) wereconsistent *itn tn" design and licensing bases. Design assumptions \ryere reviewed toverify that they were technically appropriate and consistent with the UFSAR. For eachmodification, ihe 10 CFR 50.59 screenings or safety evaluations were reviewed' Theinspectors also verified that procedures, calculations, and the UFSAR were properlyupdated with revised design information. In addition, the inspectors verified that the as-built configuration was acCurately reflected in the design documentation and that post-modification testing was adequate to ensure the structures, systems, and componentswould function property. Documents reviewed during the inspection are listed in theAttachment. The following plant modifications were inspected:Unit2. MP2-10-01037-000, "MP2 Motor(permanent);Driven AFW Pump Bearing Replacement"o DM2-00-01 10-01, "lnstallation of High Point Vents onContainment Spray Suction Piping" (permanent);H.P & L.P. Safety lnjection &. DM2-03-0183-09, "Temporary DCN Restoration AdditionalReplacement Anomalies" (permanent); andRTB Meter RelaY. MP2-11-01057, "MP2 MSSV Outlet Boot Design" (permanent).b. FindinqsNo findings were identified'1R19 Post-Maintenance Testino (71111.19 - 9 samples)a. Inspection ScoPeThe inspectors reviewed post-maintenance test (PMT) activities to determine whetherthe pMT adequately demonstrated that the safety-related function of the equipment wassatisfied, given the icope of the work specified, and that operability of the system wasrestored. In addition, the inspectors evaluated the applicable test acceptance criteria toevaluate consistency with the associated design and licensing bases, as well as TSEnclosure 17requirements. The inspectors also evaluated whether conditions adverse to quality wereentered into the corrective action program for resolution. Documents reviewed duringthe inspection are listed in the Attachment. The following maintenance activities andPMTs were evaluated:Unit2. Sp 26131,"Facility 2 ESF Integrated Test Data Sheet," Revision 010-02, followingreplacement of the 'B' Emergency Diesel Generator (EDG) channel heads on April17,2011;. Hypot Testing on the lsophase following the lsophase Duct Seal Plate Installation onApril 19,2011;. SP 2660-001, "AFP Turbine Overspeed Trip TeSt," Revision 005-06, on April 21,2011 and Sp2619BS-003,'TDAFP Comprehensive Pump Test (MODE 3)," Revision001-03, on May 2,2011 following the overhaul of the Terry Turbine;. Sp 2601C-009, "Chemical and Volume Control System (CVCS) Valve RemotePosition Indication lST, Facility 2," Revision 000-00, and SP 260'1C-008, "CVCSValve Stroke and Timing lST, Facility 2," Revision 000-00, following overhaul of 2-cH-S14;. C Sp 760-003, "Battery DB3-201D Discharge Inspection," Revision 002-01, followingbattery replacement on April 10,2O11;. Sp ZilOe, 'MSIV Closure and Main Steam Valve Operational Readiness Testing,"Revision 011-03, following leak injection repair of 2-MS-1908;. SP 2613-8-001 , "Periodic DG Operability Test, Facility 2 (Fast Start,Revision 021-05, following 'B' EDG governor replacement;Loaded Run),". Sp 2411, "CEA Motion Inhibit Verification," Revision 002-08, following CEAPIDSmonitor failure; andUnit 3. Sp 36464.1-003, "EDG 'A'Air Start Valves Independence Test," Revision 010, andSp 3646A.1-001, "EDG 'A' Operability Tests," Revision 018-01, following repair of ajacketwaterleakandreplacementoftheairstartfilter.b. FindinqsNo findings were identified.Enclosure 181R20 Refuelinq and other outaqe Activities (71111.20 - 1 sample)Millstone Unit 2 Refuelino Outaqe (2R20)a. Inspection ScoPeDominion began refueling outage 2R20 on April 2,2011, and completed the outage onMay 4, 2011. The inspectors evaluated the outage plan and outage activities todetbrmine if Dominion had considered risk, developed risk reduction and plantconfiguration control methods, considered mitigation strategies in the event of loss ofsafety functions, and adhered to licensee and TS requirements. The inspectorsobserved portions of the shutdown, cooldown, heat up, and start up processes.Additionaliy, the inspectors performed an initial containment Mode 3 walk down toevaluate the as-found condition of containment. The inspectors also performed a finalMode 3 walk down to ensure that no loose material or debris, which could be transportedto the containment sump, were present. The inspectors reviewed CRs to determine ifconditions adverse to quality were entered for resolution. Documents reviewed for theinspection are listed in the Attachment. Some of the specific activities the inspectorsobserved and Performed included:o scaffolding walkdown for potential interference with sscs;o Reactor shutdown and cool down;o Reactor water level drain down to the reactor flange;o Midloop and reduced inventory operations;. Fuel handling, core loading, and fuel element assembly tracking;. Containment as-found walk down;e Review of outage risk Plan;e orange Risk - Replacement of service water valve 2swP-978;o Risk Mitigation Plan for the North Bus Outage;. Generic Letter 88-17 verification;o Refueling Seal InsPection;. Containment as-left walk down;o Reactor Heat-up;. Reactor Start-up;. Low Power PhYsics Testing;o Reactor power ascension;. Unit 2 Generator synchronization to the grid;. Review of Work Schedules for Operations, Maintenance, and Security; ando Fatigue Management.b. FindinqsNo findings were identified.Enclosure 191R22 Surveillance Testinq (71111.22 - 9 samples)a. Inspection ScopeThe inspectors reviewed surveillance activities to determine whether the testingadequaiely demonstrated equipment operational readiness and the ability to perform theintended safety-related function. The inspectors attended pre-job briefings, reviewedselected prerequisites and precautions to determine if they were met, and observed thetests to determine whether they were performed in accordance with the proceduralsteps. Additionally, the inspectors reviewed the applicable test acceptance criteria toevaluate consistency with associated design bases, licensing bases, and TSrequirements, and that the applicable acceptance criteria were satisfied. The inspectorsalso evaluated whether conditions adverse to quality were entered into the correctiveaction program for resolution. Documents reviewed during the inspection are listed inthe Attachment. The following surveillance activities were evaluated:Unit 2aaaaaSp 2610E, "MSIV Closure and Main Steam Valve Operational Readiness Testing,"Revision 11-02 (lST);SP 27308-001, "Main Steam Safety Valve Testing," Revision 011;SP 2613H, "lntegrated Test of Facility 2 Components (ICCE)," Revision 012-Q2;sP 2602E-001, "Pressurizer Heater Capacity Test," Revision 000-00;sP 2651N-001, "Main control valves operability Test," Revision 002-09;Pf 21415A,"MPzInverters 1-4 Tests," Revision 004-02;Unit 3. Sp g622.3, "TDAFW Pump Operational Readiness and Quarterly IST Group'B'Pump Tests," Revision 017-03;. sP 3556812, "SSPS Train 'B' Operational Test," Revision 012-04; and. CP 3802E, "Reactor Coolant gas Sampling and Analysis," Revision 002-01'Findinqslntroduction: The inspectors identified a Green NCV of 10 CFR 50, Appendix B,Cntenon XVl, "Corrective Action," for Dominion's failure to take timely corrective actionto address repetitive out of calibration conditions associated with safety-related 120 VACUnit 2 inverters.Description: Millstone Unit 2 safety-related inverters 1 through 4 supply po{el to safety-related 121VAC instrument panels. ln April 2011, during refueling outage 2R20,inverters 1 through 4 were found outside the acceptance criteria for the under-frequencyand over-frequency transfer limiter test. The over-frequency and under-frequency limitswere adjusted bac[< into the acceptance criteria; however, these inverters have had ahistory of Oritting outside their acceptance criteria. In March 2009, the NRC documentedan NCV for the inverters being found frequently out of calibration for over-frequency andEnclosureb.

20under-frequency between 2005 and 2008 (NRC inspection report05000336&42312009006). Dominion wrote CR333435 which requested a setpointchange to address the issue identified in the NCV. This request was approved in aRequest for Engineering Assistance (REA), but has not been funded to date.Additionally, during the Problem ldentification and Resolution team inspection inFebruary 2010, NRC inspectors noted that three of the inverters had over-frequency andunder-frequency transfer limits outside acceptance criteria during testing in October2009, and that corrective action had not been implemented.Dominion performed an assessment of the system impact of the over- and under-frequency transfer limits and determined that the equipment supplied by the inverters aredesigned for a wide range of frequencies, and are insensitive to the small frequencyband set by the over- and under-frequency transfer limit setpoints. Dominion concludedthat the out-of{olerance over- and under-frequency transfer limits do not present asafety concern and that the inverters remained operable. The inspectors reviewedDominion's assessment and reached the same conclusion. Dominion's correctiveactions will be to perform the detailed analysis necessary to increase the allowabletolerances of the over- and under-frequency setpoints from the current +l- 0.1 Hz .Analvsis: The inspectors determined that the failure to take timely corrective action toaddress the repetitive out of calibration over-frequency and under-frequency transferlimits was a performance deficiency that was reasonably within Dominion's ability toforesee and correct, and should have been prevented. Traditional enforcement does notapply since there were no actual safety consequences, impacts on the NRC's ability toperform its regulatory function, or willful aspects of the finding.The inspectors determined the finding was rnore than minor because it is similar to themore than minor Example '4f' oI NRC lnspection Manual Chapter (lMC) 0612, AppendixE, "Examples of Minor lssues." Additionally, the issue is more than minor because theperformance 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 leadto the unavailability of safety-related equipment powered from the inverters. Theinspectors conducted a Phase 1 screening in accordance with NRC IMC Attachment0609.04, "Phase 1 - lnitial Screening and Characterization of Findings," and determinedthat the finding was of very low safety significance (Green) because it was not a designor qualification deficiency, did not represent a loss of system safety function, did notrepresent an actual loss of safety function of a single train, and did not screen aspotentially 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 Problemldentification and Resolution cross-cutting area, Corrective Action Program component,because Dominion did not take appropriate corrective action in a timely manner toaddress the repetitive out of calibration conditions with the 120 VAC safety relatedinverters. tP.1(d)lEnforcement: 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," states, in part,that measures shall be established to assure that conditions adverse to quality, such asfailures, malfunctions, deficiencies, deviations, and defective material and equipment,Enclosure 21and nonconformances are promptly identified and corrected. Contrary to the above,from March 2009, until June 2011 , Dominion failed to take timely corrective action toaddress the repetitive out of calibration conditions associated with the 120 VAC safetyrelated inverters. To date, Dominion has taken corrective action to adjust the over-frequency and under-frequency transfer limits. Because this violation was of very lowsafety significance and was entered into Dominion's corrective action program(CR426589), this violation is being treated as an NCV, consistent with the NRC'sEnforcement Policy. (NCV 0500336/2011003-02 Untimely Corrective Action forSafety Related tnverters Leads to Repetitive Out of Calibration Results)Emergency Preparedness (EP)lEPO Drill Evaluation Q1114.06 - l sample)Classification and Notification durinq Requalification Traininqa. Inspection ScoPeThe inspectors reviewed the operator's emergency classification and notificationcompleted during Unit 2's requalification training on June 7, 2011. The inspectorsverified the classification and notification were accurate and timely.b. FindinqsNo findings were identified.2. RADIATION SAFETYGornerstone: Public and Occupational Radiation Safety2RS01 Radiolooical Hazard Assessment and Exposure Controls (71124'01)a. Inspection Scope (1 samPle)During the period April 1 8,2011 through April 21 ,2011, the inspectors performed thefollowing activities to verify that Dominion was evaluating, monitoring, and controllingradiological hazards for work performed during the 2R20 refueling outage in locked highradiation areas (LHRA) and other radiological controlled areas. lmplementation of thesecontrols was reviewed against the criteria contained in 10 CFR Part 20, TechnicalSpecifications, and with Dominion's procedures'Radioloqical Ha4ards Control and Work QoveraqeThe inspectors identified work performed in radiological controlled areas in Unit 2 andevaluated Dominion's assessment of the radiological hazards. The inspectors evaluatedthe survey maps, exposure control evaluations, electronic dosimeter dose/dose ratealarm set points, and radiation work permits (RWP) associated with these areas todetermine if the exposure controls were acceptable. Specific work activities evaluatedEnclosure 22included inspection/removal of a damaged incore instrument (lOl) thimble tube (RWP391) from the lCl plate and reinstalling the lCl plate and Upper Guide Structure (UGS) inthe reactor vessel (RWP 302). For these tasks, the inspectors attended the pre-jobbriefings and discussed the job assignments with the workers. The inspectors alsoobserved (from the centralized monitoring system and during containment tours), theimplementation of exposure controls for disassembling/removing scaffolding fromcontainment (RWP 331), re-installing insulation (RWP 326), and demobilization of SGtasks (RWP 307).The inspectors reviewed the air sample records for samples taken prior to installing SGnozzle dams to determine if the samples collected were representative of the breathingair zone and analyzed/recorded in accordance with established procedures. Duringtours of the Unit 2 containment building, the inspectors verified that continuous airmonitors were strategically located to assure that potential airborne contamination couldbe timely identified and that the monitors were located in low background areas.The inspectors toured accessible radiologically controlled areas (RCA) in the Unit 2containment and with the assistance of a radiation protection technician, performedindependent radiation surveys of selected areas to confirm the accuracy of survey data,and the adequacy of postings. Radiation protection technicians were questionedregarding their knowledge of plant radiological conditions for selected jobs, and theassociated controls,Additionally, the inspectors reviewed the RWPs developed for other work performedduring 2R20 including installation of permanent shielding and diving operations. lnparticular, the inspectors reviewed the electronic dosimeter dose/dose rate alarm setpoints, stated on the RWP, to determine if the setpoints were consistent with the surveyindications and plant policy.lnstructions to WorkersBy attending pre-job briefings, the inspectors determined that workers performingradiological significant tasks were properly informed of electronic dosimeter alarmsetpoints, low dose waiting areas, stay times, and work site radiological conditions. Byobserving work-in-progress, the inspectors determined that stay times wereappropriately monitored by supervision to assure no procedural limit was exceeded.Jobs observed included inspection of a damaged lCl thimble tube and preparations formoving the UGS.During tours of containment, the inspectors determined that LHRA and a very highradiation area (VHRA) had the appropriate warning signs and were secured.Additionally, the inspectors identified that low dose waiting areas were appropriatelysurveyed, identified, and used by personnel.Enclosure 23The inspectors inventoried the keys to LHRAs to determine if the keys were"ppropii"t"ly controlled, as required by procedure' The-inspectors discussed with1."Oiution protection supervision the procedural controls for accessing LHRAs andVHRAs and determined that no changes have been made to reduce the effectivenessand level of worker Protection.EnclosureDuring tours of containment, the inspectors confirmed that contaminated materials wereprop"ity bagged, surveyed/labeled and segregated from work areas. The inspectorsobserved workers using contamination monitors to determine if various tools/equipmentwere potentially contariinated and met criteria for releasing the materials from the RCA'Radioloqical Hazards Control and Work CoveraqeBy observing preparations for inspecting/removing a damaged lCl thimble tube' theinspectors d-eiermined that workers wore the appropriate. protective equipment, haddosimetry properly located on their bodies, and were under the positive control ofradiation protection personnel. Clear radio communication was established between theworkers and the centralized monitoring system. stay times were properly measured andsupervisory personnel controlled the movements of the workers to assure that exposurewas minimized.Rad iation Worker PerformanceDuring job performance observations, the inspectors determined that workers compliedwitfr n:Wp iequirements and were aware of radiological conditions at the work site'Additionally, the inspectors determined that radiation protection technicians were awareof RWp controls/limits applied to various tasks and provided positive control of workersto reduce the potential oi'unplanned exposure and personnel contaminations'Problem ldentification and ResolutionA review of Nuclear Oversight field observation (2R20 outage snapshots) reports,dose/dose rate alarm reports, personnel contamination event reports and associatedcRs, were conducted to determine if identified problems and negative performancetrends were enter"d into Dominion's CAP and evaluated for resolution and to determineif an observable pattern traceable to a similar cause was evident'Relevant cRs, associated with radiation protection control access and radiologicalhazardassessment, initiated between January 2011 and March 2011, were reviewedand discussed with bominion staff to determine if the follow up activities were beingconducted in an effective and timely manner, commensurate with their safetysignificance.

24b.FindinosNo findings were identified.2RS02 Occupational ALARA Planninq and Controls (71124.02)a. Inspection Scope (1 samPle)During the period April 1 8,2011 through April 21 ,2011, the inspectors performed thefollowing activities to verify that Dominion was properly implementing operational,engineering, and administrative controls to maintain personnel exposure as low asreasonably achievable (ALARA) for tasks performed during the Unit 2 refueling outage2R20. lmplementation of this program was reviewed against the criteria contained in 10CFR Part 20, applicable industry standards, and with Dominion's procedures'Radioloqical Work PlanninqThe inspectors reviewed pertinent information regarding site cumulative exposurehistory, current exposure trends, and exposure challenges for the Unit 2 outage. Theinspectors reviewed various 2R20 Outage ALARA Plans.The inspectors reviewed the exposure status for tasks performed during the Unit 2outage and compared actual exposure with forecasted estimates contained in variousproje-ct ALARA Plans (AP). ln particular, the inspectors evaluated the effectiveness ofALARA controls for alljobs that were estimated to exceed the 5 person rem limit' Thesejobs included reactor vessel disassembly/reassembly (AP 2-1 1-01), SGlnspections/maintenance (AP 2-11-Og), scaffolding installation/removal (AP 2-11-13)'insulation removal/installation (AP 2-11-14), and radiation protection support activities(AP 2-11-26).The inspectors reviewed the Work-ln-Progress ALARA reviews for those jobs whoseactual dose approached the forecasted estimate. The inspectors evaluated thedepartmental'interfaces between radiation protection, operations, maintenance crafts,and engineering to identify missing ALARA program elements and interface problems'The evaluation-was accomplished by interviewing site staff, reviewing outage Work-in-progress reviews, and reviewing recent Station ALARA Council (SAC) meeting minutes.tnctuded was a review of the exposure controls for the 'C' reactor coolant pump (RCP)motor and seal replacement, and scaffolding installation.Verification of Dose EstimatesThe inspectors reviewed the assumptions and basis for the 2R20 outage ALARAforecasted exposure. The inspectors also reviewed the revisions made to variousoutage proleci dose estimates due to a reduced source term (i.e., lower dose rates);e.g.,leactor disassembly/reassembly activities, reactor coolant pump maintenance, andSG maintenance.Enclosure 25The inspectors evaluated the implementation of Dominion procedures associated withmonitoring and re-evaluating dose estimates and allocations when the forecastedcumulative exposure for tasks exceeded the actual exposure. lncluded in the reviewwere Work-ln-progress reports, that evaluated the effectiveness of ALARA measures,including source term conirols, and actions by the SAC to subsequently lower dosegoals from the original estimates.Additionally, the inspectors reviewed the exposures for the.ten workers receiving thenigilst Ooses tor ZOll to confirm that no individual exceeded the regulatory limits orperformance indicator thresholds.Source Term Reduction and ControlThe inspectors reviewed the status and historical trends for the Unit 2 source term'fniough review of survey maps and interviews with the Radiation Protection Manager,tne inJpectors evaluated recent source term measurements and control strategies'Specifib strategies being employed included use of macro-porous clean up resin'enhanced opeiational chemistry controls, and installation of permanent/temporaryshielding.The inspectors reviewed the effectiveness of temporary shielding by reviewing pre/post-installation radiation surveys for selected components having elevated dose rates'Shielding packages reviewed included those placg{ on the reactor head stand,pressuriier spray piping, SG penetrations, and RCP piping'Job Site lnsPectionsDuring plant tours, the inspectors assessed the implementation of ALAM controlsrG.iri,tO in ALARA Plans and RWPs, for lCl thimble tube cutting/removal, RCPmaintenance, and sG tube inspections, performed during 2R20.The inspectors also observed workers performing SG demobilization from eddy currenttesting,'lcl inspections, and scaffolding removal. workers were questioned regardingin"ii rino*redge of ;oO lite radiologicaiconditions and ALARA measures applied to theirtasks.Problem ldentification and ResolutionThe inspectors reviewed elements of Dominion's cAP related to implementing theALARA program to determine if problems were being entered into the program for timelyresolution, the comprehensiveness of the cause evaiuation, and the effectiveness of thecorrective actions. Specifically, CRs related to programmatic dose challenges'plrsonnel contaminaiions, doie/dose rate alarms, and the effectiveness in predictingand controlling worker exposure were reviewed'Enclosure 26No findings were identified.2RS03 In-Plant Airborne Radioactivitv Control and Mitiqation (71124'03)b.Inspection ScoPe (1 samPle)During the period April 1 8, 2011 through April21,2011, the inspectors performed thefollowlng activities to verify that in-planl airborne concentrations of radioactive materialsare bein'g controlled and monitored, and to verify that respiratory protection devices areproperly-selected and used by qualified personnel._lmplementation of these programs*"s "uilruted against the criieria contained in 10 CFR Part2Q, applicable industrystandards, and with Dominion's procedures.Enqineerinq ControlsThe inspectors evaluated the use of portable continuous air monitors (AMS-4) andportable HEpA ventilation systems installed in containment during the 2R20 outage'The inspectors determined ihat the monitors were located at work locations; e.9., SGprimary side openings, in containment where airborne contamination could potentiallyoccur. -The inspecto'rs reviewed testing records for portable HEPA ventilation systems todetermine that procedural performance criteria were met'Respiratorv ProtectionThe inspectors reviewed the use of respiratory protection devices worn by workers. Theinspectors reviewed air sampling records, SG channel head removable contaminationdata, RWPS, and Total Effective Dose Equivalent (TEDE) ALARA DAC evaluations todetermine if the use of respiratory protection devices was commensurate with thefotential external dose that may be received when wearing these devices.Problem ldentification and ResolutionThe inspectors reviewed elements of Dominion's CAP related to implementing theairborne monitoring program to determine if problems w9r9 being entered into theprogram for timely-resolution, the comprehensiveness of the cause evaluation, and theeffeitiveness of the corrective actions- Specifically, CRs related to monitoringchallenges, personnel contaminations, dose aSSeSSments, and the reliability ofmonitoring equipment were reviewed.FindinqsNo findings were identified'Enclosure 272RS04 Occupational Dose Assessment (7 1 124'04)a. lnsPection ScoPe (1 samPle)During the period April 1 8,2011 through April 21 ,2011, the inspectors performed thefollowlng activities to verify the accuracy and operability of personal monitoringequlpmlnt and the effectiveness in determining a worker's TEDE. lmplementation ofthese programs was evaluated against the criteria contained in 10 CFR Part20'applicablJindustry standards, and with Dominion's procedures.External DosimetrvThe inspectors verified that Dominion's dosimetry processor was accredited by theNationalVoluntary Laboratory Accreditation Program (NVLAP). The inspectors verifiedtnat tne approveddosimeter irradiation categories were consistent with the types and"nergi"r bi g'" site's source term. The inspectors reviewed Dominion's audit of thedosimetry processor and the areas identified for improvement contained in the report'The inspectors confirmed that Dominion has developed "correction factors" to addressth" ,"rponse differences of electronic dosimeters as compared to thermoluminescentdosimeters (TLD).lnternal DosimetrvThe inspectors evaluated the equipment and methods used to assess worker doseresulting from the uptake of radioactive materials. lncluded in this review were bioassaypio""O,it"t, whole SoOy "ounting equipment (FastScan, AccuScan, portal contaminationlionitors) calibration checks and operating procedures, and the analytical results for10 CFR Part 61 samPles'The inspectors determined that the procedural methods include techniques to distinguishinternatiy depositeJ radioisotopes from external contamination, methods to assess dosefrom hard-to-measure radioisotopes, and methods to distinguish ingestion pathwaysfrom inhalation PathwaYs.The inspectors reviewed the results from three whole body counts to assess theadequacy of the "ounting time, background radiation contribution, and the nuclide libraryused for assessing O"po'rition.' No inioividual exposure exceeded a committed effectivedose equivalent (CEDE) of 10 mrem.Declared Preqnant WorkersThe inspectors reviewed the procedural controls, and associated records, for managingdeclared pregnant;oftrt (DPW) and determined that three DPW5 were employedduring the Unit 2 outage. The inspectors reviewed the individual exposure results andmoniioring controls to assure compliance with 10 CFR Part20.Enclosure 28Multi-Dosimetrv MethodsThe inspectors reviewed Dominion's procedures for monitoring external dose wheresignificant dose gradients exist at thework site. For 2R20, multi-dosimetry methodswere used, insteid of external effective dose equivalent (EDEX) methods. Theinspectors reviewed the dosimetric results for jobs where workers wore multipledosimeters. in"t" jobs included SG nozzle installations, fuel transfer equipment repair,and diving operations. The inspectors confirmed that in addition to the TLDs worn,workers also wore electronic dosimeters, equipped with telemetry, to assure that dosefields were promply monitored by radiation'protection technicians in the centralizedmonitoring station.Problem ldentification and ResolutionThe inspectors reviewed elements of Dominion's CAP related to implementing thedosimetry prolr"r to determine if problems-were being entered into the program fortimely reioluti6n, the comprehensiveness of the cause evaluation, and the effectivenessof the corrective actions. 'specifically, CR related to dose assessments, personnelcontaminations, and dose/dose rate alarms were reviewed.b. FindinqsNo findings were identified.2RS05 Q1124'05-1samPle)a. lnsPection ScoPe (1 samPle)During the period May 23, 2011 through May 26,.2011, the inspectors performed thefollowing activities to -evaluate the opelability and accuracy of radiation monitoringinstrumentation used to detect and quantify effluent releases. lmplementation of theseprograms was reviewed against the criterii contained in 10 CFR Parl'20, applicableindustry standards, and with Dominion's procedures'The inspectors walked down selected portions of the liquid and gaseous monitoringsystemi installed in Unit 2 and Unit 3 to assess material condition, observemaintenance/calibration activities, and determine the status of system upgrades'In Unit 2, the walkdown included portions of the following monitors:Gaseous Effluent Monitors. Enclosure Building Roof Vent Monitor, RM-8132 NB. Fuel Handling Building Exhaust, RM-8145o Radwaste Building Exhaust, RM-8997o Auxiliary Building Exhaust, RM-8434Enclosure 29. Stack Monitor - Wide Range, RM-8169r Waste Gas Tank Monitor, RM-9095. Steam Jet Air Ejector Monitor, RM-5099Liquid Effluent Monitors. Clean Liquid Waste Effluent Monitor, RM-9049o Aerated Liquid Waste Effluent Monitor, RM-9116. Steam Generator Blow-down Monitor, RM'4262o Condensate Receiving Tank Monitor, RM-9327. Reactor Building component cooling water Monitor, RM-6038In Unit 3, the walkdown included portions of the following monitors:Gaseous Effluent Monitorso Ventilation Vent Monitor, RE-10A/B. Supplemental Leak Collection and Release System (SLCRS) Monitor, RE19A/Bo Engineered Safeguards Building Monitor, RE-49Liquid Effluent Monitorsr Turbine Building Sump Monitor, RE-50. Liquid Waste Effluent Monitor, RE-70o Waste Neutralization Sump Monitor, RE-07Calibration and Testinq ProqramThrough record reviews, the inspectors confirmed that the effluent monitoringinstruments were prop"ity calibiated, and that the required source checks and functionaltests had been routinely fierformed. The inspectors verified that the effluent monitoralarm set points are esiablished in accordance with the Off Site Dose CalculationManual (ODCM).The inspectors reviewed contamination sampling results (per 10 CFR Part 61) used tocharacterize difficult-to-measure radioisotopes, to determine if the calibration sourceswere representative of the radioisotopes found in the plant's source term'Problem ldentification and ResolutionThe inspectors reviewed selected cRs, system health reports, and various Nucleareuality Assurance reports to evaluate Dominion's threshold for identifying, evaluating,and resolving problems for the radiation monitoring instrumentation' lncluded in thisreview were cRs related to radiation worker and ridiation protection technician errors todetermine if an observable pattern traceable in the maintenance or use of radiationinstruments was evident.Enclosure 30b. FindinosNo findings were identified.2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124'06 - 1 sample)a. Inspection ScoPe (1 samPle)During the period May 23,201 1 through May 26,2011, the inspectors performed thefollowi"ng activities to verify that Dominion was properly maintaining the gaseous andliquid effluent processing iystems to ensure that radiological releases.were properlymitigated, monitored, an-d evaluated with respect to public exposure' lmplementation ofthese controls was reviewed against the criteria contained in the 10 CFR Parts 20 and50, of Dominionls Radiological-Effluent Monitoring and Offsite Dose Calculation Manual(REMODCM), and with Dominion's procedures'Effluent RePort ReviewsThe inspectors reviewed the 2009 and 2010 Annual Radiological Effluent ReleaseReports to verify that the effluents program was implemented as required by theREMODCM. tnbuoeo in this review w:ere the results of the ground water protectionprogram, the inclusion of Carbon-14 dose contributions, the current land use census,and verification that no significant changes were made to the Unit 2 and unit 3 gaseousand liquid release systern-configurationi, as specified in the Final Safety Analysis Report(FSAR) and ODCM descriPtions.Walkdowns and ObservationsThe inspectors walked down the major componentsof the unit 2 and Unit 3 gaseousand liquid r"f""r" ryriems, to verify the system. configurations complied with the FSARdescription, and to evaluate equipment material condition.The inspectors reviewed the most current Unit 2 and Unit 3 liquid and gaseous effluentmonitor monthly source checks, quarterly functional test results and 18-month calibrationrecords to verify ihat instrumentaiion and associated pumps/isolation valves orfans/isolation dampers, respectively, were operable'The inspectors reviewed the air cleaning systems surveillance test results for the HEPAand charcoalfiltration systems installed in Unit 2 and Unit 3' The inspectors confirmedthat the air flow rates were consistent with the FSAR values and the filtration system metthe accePtance criteria.Samplinq and AnalvsisThe inspectors reviewed the relevant surveillance procedures (SP) and observedtechnicians cottecting weekly air particulate and iodine samples. Airborne-particulateand iodine t"*pf"r i,ere taften fiom the Main Station Stack monitor (RM-8169), usingEnclosure 31Sp-2g15. Samples were taken from the Unit2 Enclosure Building roof vent monitor(RM-81 32), using SP-281 44.During the walkdowns of effluent monitoring systems, the inspectors determined thatappro-priate compensatory sampling measurei were implemented for monitors that wereremoved from service for maintenance or calibration. compensatory measures were inptace for the U-2 Ventilation Vent monitor (RM-8132), Unit 3 SCLRS monitor (HVR-19)'and Unit 3 Liquid Waste monitor (LWS-RE-70)'The inspectors reviewed the results of Dominion's inter-laboratory comparison (blindsample) program to verify the accuracy of effluent sample analysis performed byDominion.Dose CalculationsThe inspectors reviewed monthly, quarterly, and annual dose projections for liquid andgaseous effluents performed duiing the past 12 m-o1tlr9-to verify that the effluent wasfirocesseO and released in accordance with REMODCM requirements and to ensure thatthe licensee properly calculated the offsite dose from effluent releases. The inspectorsconfirmed that no p"rforr"n"e indicator (criteria contained in Appendix I to 10 CFR 50)was exceeded for these releases.The inspectors reviewed liquid discharge permits for Unit.2 and Unit 3 to evaluate theadequacy of dilution flow, radioactive c-onient, and overall accuracy of the documenteddata.Ground Water Protection ProqramThe inspectors verified that Dominion is continuing to implement the voluntary NuclearEnergy Institute/lndustry Ground water Protection Initiative. The inspectors reviewedmonitoring wett sampie?esutts, trending data, and decommissioning regor!9 (maintainedper 10 CfYn SO.ZS tdll to evaluate procLdural compliance and to identify off normalresults.Problem ldentification and ResolutionThe inspectors reviewed selected CRs, system heal-th reports, and Nuclear QualityAssurance audits to evaluate Dominion'sihreshold for identifying, evaluating, andresolving problems regarding effluent treatment and monitoring.Enclosure 32b. FindinosNo findings were identified.4. OTHER ACTIVITIES [oAl4OA1 Performance Indicator (Pl) \lbrification (71151- 6 samples)Cornerstone: lnitiatinq Eventsa. InsPection ScoPeThe inspectors reviewed Dominion submittals for the Pls listed below to verify theaccuracy of ine data reported during that period T.h" Pl definitions and guidancecontained in Nuclear Energy Instituie (NEi) 99-02, "Regulatory Assessment IndicatorGuideline,', Revision 5, were used to v'erify the basis for reporting each data element'The inspectors reviewed portions of the operations logs, monthly ope.rating reports,.andLicensee Euent Reports (Lfn) and discussed the methods for compiling and reportingthe Pls with cognizant licensing and engineering personnel.Unit2. Unplanned Scrams per 7000 Critical Hours;o Unplanned Scrams with Complications;. Unplanned Transients per 7000 Critical Hours;Unit 3o Unplanned Scrams per 7000 Critical Hours;o Unplanned Scrams with Complications; and. Unplanned Transients per 7000 Critical Hours'b. FindinqsNo findings were identified..14OA2 tdentification and Resolution of Problems (71152)lnspection ScoPeAs required by lnspection procedu re 71152, "ldentification and Resolution of Problems,"and in order to hetp identify repetitive equipment failures or specific human performanceissues for follow-up, the inspectors performed a daily screening of items entered intoDominion's corrective action program. This was accomplished by reviewing thea.Enclosure b.33description of each new CR and attending daily management review committeemeetings.FindinqsNo findings were identified..2a.Inspection ScoPe (1 samPle)The inspectors reviewed Dominion's current performance relevant to the cross-cuttingaspect,'1H.1 (b)l Human Performance, Decision Making. Licensee Decisionsdemonstrate that nuclear safety is an overriding priority, and Dominion usesconservative assumptions in decision making and adopts a requirement to demonstrateGt tn" proposed action is safe in order to pioceed, rather.than a requirement todemonstrate that it is unsafe in order to disapprove the action' Dominion conductseffectiveness reviews of safety-significant decisions to verify the validity.of the underlyingasiumptions, identifies possible ulintended consequences, and determines how toimprove future decisions. Millstone was noted to have three ROP findings with thisassociated .ror.-"uttinj aspect in the last assessment period. The inspectors reviewedrelated cRs, interviewed staff personnel, conducted behavioral observations of staffinteractions during several meetings and training sessions^, and developed a case studyof Dominion's response to the Uni[ Z reactor trip on June 20, 2011'Findinqs and ObservationsNo findings were identified'The inspectors determined that Dominion had identified the trend in the cross-cuttingaspect iH. r tOlt in their CAP (CR4031 1 1 ) DoTilg! l3!.gonducted a common causeevatuation of the crois-cutting area tH.1ib)l (ccE000164) and concluded that "nocommon cause, most prevalent cause tdfateb to Conservative Assumptions and SafeActions was derived frbm the review of these three events." The inspectors noted that'at the end of tne cuirent quarter, Dominion will have only one finding with a cross-cuttingaspect tH.1(b)l in tnis rep6rting period because two of the findings are no longer currentand no additionaltinOinSjs hav6 assigned [H'1(b)]as a cross-cutting aspect' Theinspectors reviewed cc"eooot64 and noteo tnaiinis evaruation was somewhat narrowlyfocused on the tnree inoividual findings. while Dominion concluded that there was nocommon cause, tney Oroadened the icope of this evaluation and determined there wasa common theme ,"ro$ the three events that included some aspect of inadequateworker knowledge "no uppropriate risk recognition. -Th.ey subsequently addressed thiscommon theme by implementing corrective ictions for the three findings (CA170523'cA183044 and CAtoisezl by c-onducting training on the specific issues'The inspectors followed Dominion's response to the unit 2 reactor trip that occurred onJune 20, 2011, as a real time case study in the effectiveness of the Millstoneconservative decision making process. Dominion immediately prepared CRs thatEnclosureb.

34addressed the human performance errors (CR431574 RCE), procedural issuestCi+af 722) andsimulator fidelity issues (CR432012) and is presently conducting a root."ur" evaluation (RCE) of the event. Prior to restarting the reactor, the inspectorsobserved a management meeting to implement procedural changes prior to restart, just-r+i*" training llifl for the crew supporting the restart, and the lessons learnediraining on criilcat paiameter monitoring (CR431936) conducted after the event for theremediation of all shifts. These activities observed in this case study demonstrated anappropriate emphasis on conservative decision making, critical parameter monitoring byob"ruiorr and a tocus on operator fundamentals. In addition, the inspectors observedSupervisor Leadership Training conducted by the Plant Manager that reemphasized thesafety culture aspects, expectitions and responsibilities of front line supervisors' Thisincluded lessons learned irom the response to this event. Based on this sample, it"pp"rrr that Dominion has recognized the implications of the trend in the cross-cutting#;;i tH.itOlt. Current efforts to address this aspect are in progress within theDominion cAP and will be assessed in the future after the RCE has been completed,and when lessons learned and corrective actions to prevent recurrence have beenformulated and imPlemented'.3b.lnspection ScoPe (1 samPle)The inspectors reviewed Dominion's current performance relevant to the cross-cuttingasject ip.t(r)l' Problem ldentification and Resolution, Corrective Action Program'Dominion ensures that issues potentially impacting nuclear safety are promptlyiO"ntiti"O, fully evaluated, and tfrat actiohs are takbn to address safety issues in a timelymanner, "orr"n"u13t" *it their significance. Dominion implements their cAP with alow threshold for identifying issues. bominion identifies such issues completely,accurately, and in a timely manner commensurate with their safety significance' At theend of the last ROp issessment period, Dominion was noted to have three ROPfindings with this associated cross-cutting aspect and at the end of the current quarter'Dominion will continue to have the samelhree findings with a cross-cutting aspecttp.1(a)l in this assessment period because no additionalfindings have been added andin" thi"" original findings occurred within the past four quarters' The inspectorsreviewed related cni, interviewed staff personnel, conducted behavioral observations ofstaff interactions ouring several meetings and training sessions, and developed a case;i;ey of Dominion', 1."iponte to the unit z reactor trip on June 20, 2011'Findinqs and ObservationsNo findings were identified.The inspectors assessed Dominion's response to the area of identifying, fully evaluating,no "oor"rsing sateiy Lir"t in a timely manner. The inspectors determined thatEnclosure 35Dominion had identified a trend in the safety culture cross-cutting aspect [P'1(a)] andhad concluded that the three ROP findings had been properly evaluated and closedinJiviOuatty. Dominion did not perform a common cause assessment for the cross-"rtti^g u;pect [p.1(a)]. During this ROP inspection period, no additionalfindings wereidentified that involved [P'1 (a)].lnterviews with Dominion managers indicated that Millstone was planning to furtheraddress the broader issue of coirective action program effectiveness by makingirprou"r"nts to their cAP including improving th_e_-quality of their apparent causeevaluations (ACE) and root cause e-valuations (ncr); sJrengthening the effectiveness ofthe corrective Action Review Board (CARB); initiating cRs for all rejected AcEs andnCfr; and enhancing the minimum iequired qualifications and training for CARBmembers. They alsJwere planning to conduct a sampling of lower level CR evaluationsto determine if they were missing key trends and reducing the extension of correctiveaction due dates. other corrective actions will be considered based on the results of thecommon cause assessment for this trend that is presently_in progress' The inspectorsnoted that Millstone staff initiates a substantial volume of CRs every year and thethreshold for preparing a CR appeared to be appropriately low' There appeared to belitile reluctance to oraiting a cR'by the vast majority of the staff at Millstone.The inspectors followed Dominion's response to the Unit 2 reactor trip that occurred onJune 20, 2011,as a real time case study in the eff_ectiveness of the Millstone correctiveaction pio""r". Dominion immediately prepared CRs thataddressed the humanperformance errors lCAnySl+ RCE); proceduralissues (CR431722) and simulatorilO"tity issues CR*)01 2, and is presently conducting a RCE of the event' Prior torestarting tne reactoi, the inspectors observed a management meeting to implementprocedural cnanges prior to restart, just-in-time training (JITT) for the crew supportingthe restart, and the lessons learned training on critical parameter monitoring conductedafter the event for all shifts. These activitiei demonstrated an appropriate threshold ofproor"rn identification, an ability to promptly resolve adverse conditions and effectivecorrective action lmplementation in'responle to this e.vell In addition, the inspectorsobserved Supervisor Leadership Training conducted by the Plant Manager thatreemphasized the safety culture aspectsl expectations and responsibilities of front linesupervisors that included lessons learned from the response to this event' Based on thissample, it appears that Dominion has recognized the implications of the cross-cuttingtfr"ry1" ip f tilt Current efforts to address [his theme are in progress and will beassessed in the future after the RCE has been completed and corrective actions toprevent recurrence have been implemented'.4a.Inspection ScoPe (1 samPle)The semi-annual trend review's focus was to determine Dominion's progress incorrecting negative trends. The inspectors reviewed Dominion's corrective action trend;;;;f;tn"i" quarter 2010 and selected the work management trend-s for review'Work management was selected because it has been a site focus area for over a year'rne inspect6rs reviewed corrective action assignments CA173666, CA177780'Enclosure b.36cA177781, and all corrective action assignments from apparent cause ACE 018411'ih" in.p""tors reviewed the trends and interviewed several maintenance and planningpersonnel in order to determine if the corrective action assignment matched the issueand if the corrective actions completely addressed the issue.Assessments and ObservationsNo findings were identified.The overall goal of the corrective actions was to address negative trends in meetingwork management milestones, work order readiness, and backlog management' Theinspectors ietermined that since February 2011, overall work management has beenimproving. Total backlog per unit has been reduced from 3946 to 3771 betweeni"'Orru.iund May 2Ol1: britical and non critical PMs deferred per rolllnO quarter haveoroppeo tro m 24 and 23 respectively in July 2010, to 6 and 0 in May 2011' T4 scopestaOiiity has been consistenily at approximately 90 percent for several months'Dominion has started looking out to T16 to determine if overtime or contractor use will beiefuireO to complete the necessary work. Not all trends have been positive, asannualized critical and non critical PMs performed late in the grace n-er!o{!1ve steadilyincreased from 24 percent and 26.5 percent respectively in July 2010, to 31'6 percentand 34.3 Percent in MaY 2011.The inspectors identified that one corrective action was closed out before the work was"orpf"i"O. CA173OOO was to evaluate the gap to excellence in schedule adherence'The work completed was a draft plan to efficiently use resources to plan and completework. The drait plan has several tasks to implement other plans. The assignment wasclosed out without any documentation that the plan had been implemented. lt appearsg'ui i6" plan is Oeing'impremented, but the details are not captured under that correctiveaction. There was one corrective action that the inspectors could not completely verifyiti compretion. CA18b7g0's assignment was to address work orders removed from theschedule because tf'"V OiO not miet the milestones. This assignment was closedprimarily because of T4 scope stability and implementation week adherence greater than90 percent.Enclosure 374OA3 Event Follow-up (71153 - 2 samples).1a.Inspection ScoPeon April 3,2011, Millstone lJnit2 Enclosure Building Filtration system (EPF? negativepr"$rr" test results failed to meet acceptance criteria while the unit was in Mode 4'making the Enclosuie Building inoperabie. Since the Enclosure Building failed itssurveillance test, its safety fuiction to control the release of radioactive material couldnot be assured. Dominion determined that the cause for the failure was that the slidingbushings on the main steam safety valve (MSSV) exhaust piping had become stuck andwere not seated ProPerlY.Findinqslntroduction: A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl,,,Corrective Action," was ideritified for Dominion's failure to take prompt corrective actionto address the cause of MSSV exhaust pipe bushings not seating, which resulted in aloss of the Enclosure Building's safety function to control the release of radioactivematerial. Dominion has since cleaned and lubricated the MSSV exhaust pipe, and alsoimplemented a modification to upgrade the MSSV outlet boot and qualify it as part of theEnclosure Building filtration boundary'Djscription: on April 3,2011, Millstone Unit 2 was performing a plant cool-down inMode b when the data iat<en on the EBFS test while in Mode 4 indicated that it had notmet its acceptance criteria. The Enclosure Building's safety function to control therelease of radioactive material could therefore not be assured. Dominion determinedthat the cause of the failure was eight MSSV exhaust pipe bushings not being- seatedproperly because they had becomi $uck on the exhaust pipe' Dominion performedcleaning and lubrication of the MSSV exhaust pipe and.performed a successful retest onApril 26, 2011. The Enclosure Building had also t?19d. its surveillance test in July 2009when two MSSV bushings had not seaied. The 2009 investigation delermined that thelifting of the relief valveJassociated with these bushings as a result of the July 3' 2009iiip n'"0 caused the bushings to slide up the exhaust pipe and become stuck' Thebushings were reseated and a successful retest was performed'one of the corrective actions from the 2009 root cause was to develop a new procedurefor the inspection and cleaning of the sliding bushings. Details were to include lifting ofthe bushing, and to provide necessary tooling and criteria for clearances andcfeanliness. proced'ur)e MP27O2F1 0A, "Cleaning and lnspection of MSSVs SlidingBushings," *". uppioulJ in Nou"tber 2009. However, the work performed on thebushings *", .orii"t"O in October 2009, which occurred prior to the approval ofp.."0-ur" MZ27O)F10A. As a result, the work orders for the sixteen sliding bushingsdid not contain Oetaifslor properly cleaning the bushings'. The work orders only stated',,verify that the sliding bushing is free to slile on vent siack without excessive binding inEnclosureb.Dislodqed Bushinos 38accordance with MF 2701J-114." Far the eight bushings that were not seated, onlythree of the work orders' comments stated that cleaning of the sliding bushing wasperformed. Dominion's apparent cause evaluation from the April 2011 failure stated thata contributing cause was,"iineffective implementation of corrective actions from rootcause RCE000984; inadequate/inconsisient maintenance cleaning approach may haveresulted in MSSV sliding bushings hanging up'"Analvsis: The inspectors determined the failure to take prompt corrective action to cleanthe sliding bushings in October 2009 was a performance deficiency that was reasonablywithin Diminion's aOitity to foresee and correct, and should have been prevented'Traditional enforcement doet not apply since there were no actual safety consequences'impacts on the NRC',s ability to perform its regulatory function, or willful aspects of thefinding.The finding was more than minor because it was associated with the Procedure Qualityattribute of the garrier Integrity cornerstone and affected the cornerstone objective toprouio" reasonable assura-nce that physical design barriers protect the public fromradionuclide releases caused by accidents or events. specifically, the failure of theMSSV sliding busninls to seat property caused the EBFS to fail its surveillance test, andits safety function to iontrol the release of radioactive material could not be assured'The inspectors conducted a Phase 1 screening in accordance with NRC InspectionManual'chapter (lMC) Attachment 0609.04, "Phase 1 - Initial screening andCharacterization of FinOingt," and determined that the finding was of very.low safetysignificance (Green) O"""ir" it only represents a degradation of the radiological barrierfunction provided for the auxiliary building'The inspectors determined that this finding had a cross-cutting aspect in the Problemldentification and Resolution cross-cutting area, corrective Action Program component,because Dominion did not take appropriale or timely corrective action to address theEnclosure Building surveillance test failure in 2009. tP.1(d)lEnforcement: 10 cFR 50, Appendix B, Criterion XVl, "corrective Action," states, in part'that measures shall be established to assure that conditions adverse to quality, such asfailures, malfunctions, deficiencies, deviations, and defective materialand equipment'and non-contormances are prompily identified and corrected' Contrary to the above'from October 2009 until April 2011, Dominion failed to take prompt corrective action toaddress the cause of the trrtssv exhaust pipe bushings not seating properly, whichcaused the inoperability of the Enclosure'Building and a loss of its safety function onApril 3, 2011. Dominion took corrective action to clean and lubricate the MSSV exhaustpipe and also implemented a modification to upgrade the MSSV outlet boot and qualify itld- part of the Enclosure Building filtration boundary. Because this violation was of verylow safety significance and was entered into Domihion's CAP (CR420485), this violationis being treated as an NCV, consistent with the NRC's Enforcement Policy' (NCV0500336/2011003-03 lnadequate Gorrective Action Results in Loss of EnclosureBuilding's SafetY Function.)Enclosure 39.2a.lnspection ScoPeOn June 20,2Q11, at 1 1:52 a.m., Unit 2 experienced an automatic trip on low steamgeneiator level. The low steam generator level was caused by a loss of feedwater flowwhen the 'B, steam generator feedwater pump (SGFP) tripped on low suction pressurewhile the operators irere in the process of bringing the 'A' SGFP on-line'The inspectors responded to the control room and evaluated the adequacy of operatoractions in accordance with approved procedures and TS requirements. The-inspectorsp"trom"o a walkdown of the control room and interviewed personnel to verify that theffi;i;"r stable. The inspectors also reviewed the sequence of events and post tripreview report in order to d'etermine if there were any other plant or equipment anomalies'The inspectors observed the reactor startup and portions of the power ascensioninciuOin'g the starting of the second SGFP. The inspectors reviewed CRs to ensureconditions adverse io quality associated with this event were entered into Dominion'scorrective action program for resolution'Findinqslntroduction: A self-revealing finding (FlN) of very low_safetY significance (Green) wasidentified for Dominion's failure to follow proceduie OP 2204, "Load Changes," whenstarting the 'A' SGFF. Specifically, the operating crew failed to maintain adequate SGFPsuction pressure (greatei than 32-5 psig) while starting the 'A' SGFP, which led to a tripof the 'B' SGFP and subsequent reactoi trip on low steam generator level'Description: On June 20,2A11, Millstone Unit 2 reduced power to 30 percent to repairan oil leak on the'c' reactor coolant pump (RCP) moto-r, following the repairs, MillstoneUnit 2 began increising power to 59'percent with the 'B' SGFP feeding the steamgenerators. operatorjwere in the process of bringing the 'A' SGFP pump on-line whenfeed regutating varve irnVloitr"t"ntial pressure t+] oecreased outside of the operatingband. The operator tnen incorrectly lowered 'g' SGpP speed to increase FRV dp' Theoperator did not get the desired response, and increased 'B' SGFP speed back to itsoriginal value. The operator then increased the speed of the 'A' SGFP in order to bringthe pump on-line to feed the steam generators. This action decreased feed pumpsuction pressure and caused the'B;SGFP to trip on low suction pressure' The resultingloss of feedwater flow caused a reactor trip on low steam generator level at 11:52 a'm'Dominion's post trip review identified some instances where operator actions.were notas expected. OP iZOq,"Load Changes", step 4'121-tj3l9t' "When placing the secondSGFp in service, fHnOfff-E open dtttM-2,';CONO DEMIN BYP," as needed tomaintain both SGFp suction pressures greater than 325 psig (C-05)'" CNM-? was notthrottled open by the operating crew unJ SCrp suction pressure was not maintainedabove 325 psig, noi*ut it ad6quately monitored. SGFP suction pressure droppedbelow 325 psig at 11:44a.m., and at 11:50 a.m. the 'B' SGFP suction pressure lowb.Enclosure 40alarm came in at 260 psig on the plant process computer (PPC). The operating crewtook no corrective action in response to the alarm'ln addition, the post trip review also identified that recent revisions to procedure OP22e4, which delayed the start of the heater drain pumps until 70 percent reactor powerand increased the reactor power band for starting a second SGFP from 45 percent - 50percent to 45 percent - 65 percent, may not have been appropriate.The inspectors noted that oP 2321, "Main Feedwater system," which contains theprocedure for starting a second SGFP, does not mention monitoring SGFP suctionpressure. lt only staies in the initial steps, "Verify the following: Condensatg headerfr"rrur" greater than 425 psig (C-05).'; The inspectors also noted that JITT for thepower asJension did not include starting the second q9FP, because other powerascension evolutions, such as synchronizing to the grid, were deemed to be moredifficult.Analysis: The inspectors determined the failure to adequately monitor and takecorrectVe action when SGFP suction pressure dropped below 325 psig was aperformance deficiency that was reasonably within Dominion's ability to foresee andcorrect, and should have been prevented. Traditional enforcement does not apply sincethere were no actual safety consequences, impacts on the NRC's ability to perform itsregulatory function, or willful aspects of the finding'The finding is more than minor because it is similar to NRC Inspection Manual ChapterO612,App-endix E, "Examples of Minor lssues," Example 4b; in that, a failure to followprocedure led to a reactor trip. This issue is associated with the Human Performanceattribute of the Initiating Events cornerstone and affected the cornerstone objective tolimit the likelihood of thlse events that upset plant stability and challenge critical safetyfunctions during shutdown as well as power operations. Specifically, the failure of theoperators to properly monitor SGFP suction pressure led to a loss of adequatefeedwater flow and a reactor trip. The inspectors conducted a Phase 1 screening inaccordance with NRC Inspection Manual Chapter (lMC) Attachment 0609'04, "Phase 1- lnitial Screening and Chara cterization of Findings ," and determined that the findingwas of very low *ut"ty significance (Green) because it did not contribute to both thelikelihood of a react,oitrid and the likelihood that mitigation equipment or functions wouldnot be available.The inspectors determined that this finding had a cross-cutting aspect 'l thg HumanPerformance cross-cutting area, Work Practices component, because Dominionpersonnel did not properly follow the load changes procedure' tH.4(b)lEnforcement: This finding does not involve enforcement action because no regulatoryrequ-rcment "iolation waiidentified. Dominion entered this issue into their correctiveaction program (CR431 574); conducted training exercises emphasizing safe operatingenvelopesl critical parameters to monitor, and actions to take to restore margin if plantconditions degrade; and has revised procedure oP 2204. Because this finding does notinvolve a violation of regulatory requiiements and has very low safety significance, it isEnclosure 404541identified as a finding. (FlN 05000336/2011003'04 Failure to Follow Procedure forStarting a Second SCfp Results in Reactor Trip)Other ActivitiesThe inspectors assessed the activities and actions taken by the licensee to assess itsreadiness to respond to an event simirar to the Fukushima Daiichi nuclear plant fuelorrug" event. This included (1) an assessment of the licensee's capability to mitigateconditions that may result from beyond design basis events, with a particular emphasison strategies retated to the spent flel pool, Js required by NRC Security Order Section8.5.b issued February 25,2dQ2, as committed to in severe accident managementguidetines, and as re6uir"O by 19 CFR-50.54(hh); (2) an assessment of the licensee'scapability to mitigate ,t"ttn blackout (SBO) conbitions, as required by 10 CFR 50'63and station design bases; (3) an assessment of the licensee's capability to mitigateinternal and externalflooding events, as required by station design bases; and (4) anassessment of the tfrorougniess of the walkdowns and inspections of important"qripr"nt needed io titli"t" fire and flood events, which were performed by thelicensee to identify any piential loss of function of this equipment during seismic eventspossible for the site.Inspection Report 05000245,3 36,42312011009 (ML1 1 1320660) documented detailedresults of this inspection activity'.1.2on May 13, 2011, the inspeCtOrS completed a review of the licensee's severe accidentmanagement guioetinerlbnMc.l, implemented as a voluntary industry initiative in the1990,s, to determine tij ivr,etn"r ii'" SAMGs were available and updated, (2) whetherthe licensee had pro"Ldrr", and processes in place to control and update its -SAMGS'(3) the nature and extent of the licensee's training of personnel on the use of SAMGs'and(4)licenseepersonnel'sfamiIiaritywithSAMGimplementation.The results of this review were provided to the NRC task force chartered by theExecutive Director for operations to conduct a near-term evaluation of the need foragency actions rorrowing thefukushima Daiichi fuel damage event in Japan' Plant-;;;"iii6 resutts for Millsione Power Station were providc'c1 in an Attachment to amemorandum to the Chief, Reactor Inspection Bianch,.Division of Inspection andnegionat Support, dated May 27,2011 (ML111470361)'Enclosure 424046 Meetinqs. includinq ExitExit Meetinq SummarvOn August 1, 2011 , the resident inspectors presented the overall inspection results toMr. A. J. Jordan and members of his staff. The inspectors confirmed that no proprietaryinformation was provided or examined during the inspection.ATTACH MENT: SU PPLEMENTAL INFORMATIONEnclosure A-1SUPPLEMENTAL IN FORMATIONKEY POINTS OF CONTACTDominion personnelR. ArquaroL. ArmstrongG. AuriaB. BarronB. BartronC. ChapinW. ChestnutF. CietekT. ClearyG. ClosiusL. CroneJ. CurlingJ. DoroskyM. FinneganJ. GauvinA. GharakhanianM. GobeliW. GormanJ. GroganK. GroverC. HouskaA. JordanJ. KunzeJ. LaineR. MacManusG. MarshallM. MartelC. RheimsR. RileyM. RocheL. SalyardsM. SartainJ. SemancikA. SmithD. SmithS. SmithJ. StoddardR. SturgisM. SochaS. TurowskiC. VournazosP. ZahnU3 Shift ManagerManager, TrainingNuclear Chemistry SuPervisorManager, Nuclear OversightSupervisor, LicensingAssistant OPerations ManagerSupervisor, Nuclear Shift Operations Unit 2Nuclear Engineer, PRALicensing EngineerLicensing EngineerSupervisor, Nuclear ChemistryManager, Protection ServicesHealth PhYsicist lllSupervisor, Health PhYsics, ISFSIUnit 3 ChemistrY TechnicianNuclear Engineer lllShift Technical AdvisorSupervisor, lnstrumentation & ControlAssistant OPerations ManagerManager, Nuclear OPerationsl&C TechnicianSite Vice PresidentSupervisor, Nuclear Operations -SuppgrtManager, Radiation Protection/ChemistryDirect6r, Nuclear Station Safety & LicensingManager, Outage and PlanningU3 Shift Managerl&C EngineerSupervlsor, Nuclear Shift Operations Unit 3Senior Nuclear Chemistry TechnicianLicensing, Nuclear Technology SpecialistDirector, Nuclear EngineeringPlant ManagerAsset ManagementManager, EmergencY PreParednessManager, EngineeringUnit 3 Shift ManagerSecondary Systems Engineering SupervisorUnit 3 Work Control SROSupervisor, Health Physics Technical ServiceslT Specialist, Meteorological DataOperations SuPPort SPecialistAttachment A-2LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED05000336/201 1 003-0305000336/201 1 003-04Opened and Closed0500042312011003-01 NCV05000336/2011003-02 NCVFailure to Take Timely Corrective Actions for De-alloying ofAluminum Bronze Service Water Valves (Section 1R15)Untimely Corrective Action for Safety Related lnvertersLeads to Repetitive Out of Calibration Results (Section1R22)Inadequate Corrective Action Results in Loss of EnclosureBuilding's Safety Function (Section 4OA3)Failure to Follow Procedure for Starting a Second SGFPResults in Reactor Trip (Section 4OA3)Enclosure Building Rendered Inoperable Due to DislodgedBushingsFollow-up to the Fukushima Daiichi Nuclear Station FuelDamage Event (Section 4OA5.1)Availability and Readiness Inspection of Severe AccidentManagement Guidelines (Section 40 A5.2)NCVFINClosed05000336/2011-001 LER05000245, 336,4231 251 5/1 83 Tl05000336,423125151184 TlAttachment A-3LIST OF DOCUMENTS REVIEWEDSection 1R01: Adverse Weather Protection@inds and High Tides," Revision 010-05AOP 3569, "severe Weather Conditions," Revision 016-00C Op 200.g, ,,Response to ISO New England/CONVEX Notifications and Alerts," Revision 004-05ISO New England OP 4, "Action during a Capacity Deficiency," Revision 10.ISO New England M/LCC 5, "proceduie for Millstone Point Station Generation Reduction,"Revision 10SP 2665, "Building Flood Gate Inspections," Revision 005-02System Health RJport, NSST, RSST and Main Transformer, 1"'Quarter 2011System Health Report, 345KV Switchyard, 1"'Quarter 2011System Health Report, Unit 2 and Unit 3 Doors and Barriers, 1"'Quarter 2011M2 99 1375453102268158531023557145310241097153102410973cR381899cR381901cR412022cR412023cR412024cR412026cR412028Revision 3726203-26023 Sheet 2,System," Revision 30MREo10817MREo10866MREo10875MREo10883MREO10886531024109755310241097653102410977cR412032cR412033cR412035cR412036cR420060cR420238cR420239cR420495Section 1R04: EquiPment Aliqnment9E for FacilitY 1 on APril 3,2O11"Maintenance Rule Scoping Tables for Enclosure Building FiltrationOP 2301B, "SDC/SFPC Core Off-Loaded," Revision 000-05oP 2308-002, "HPSI System Valve Alignment, Facility 2," Revision 000-04Op 2314G-001, "Enclosure Building Filtration System Alignment," Revision 012-01oP 3308, "Train'A' High Pressure safety Injection," Revision 004-06system Health Report Enclosure Building Filtration,J " quarter 201 125203-2602g Sheet 5, ,',piping and Instrr.rmentation Diagram containment and EnclosureBuilding Ventilation," Revision 3626203-26015 Sheet 1, "piping & Instrumentation Diagram L.P. Safety Injection system,""Piping & Instrumentation Diagram Spent Fuel Pool Cooling & CleanupMREO10952MRE01 1396MRE011510MREO13253MREO13468Attachment A-4MRE013497 MRE013572MRE013505 MRE013653MREO1 3571Section 1R05: Fire ProtectionmstoneUnit2,FireHazardsAnalysis,''Revision11Millstone Unit 2 Firefighting Strategies, April2002Brigade Drill and Assessment for Unit 2 East Cable VaultSection 1R08: ln'Service InspectionMiscellaneousn""-r, r.rp, rnc. Engineering Information Record, No. 51-91521 16-000, "Millstone Unit 2 - 2R2oECT Inspection PlanM2-EV-11-001, Revision 0, "Millstone Unit 2 SteamAssessment (2R20)"Generator I ntegritY DegradationWeldinq PackaqeSA4A-123, Reftion 0, "safety Requirements for Welding, Cutting and Brazin-g"Wo s31 o23g2sss, "SWLB - Modification of Service Water Spt 60469 - DM2-00, 01-0132110CMP 701.01, Revision 002-04, "Pre-Job Checklist"SA-AA-1 1 0, Attachm ent 2, "Job Hazard Assessment"WM-AA-3O1, Attachment '14, "High Contingency Plan Actions"ProceduresER4A-N DE-UT-7O 1, Revision 4, "U ltrasonic Thickness Measurement Proced u re"CM-AA-FPA-101, Revision 3, "Control of Combustible and Flammable Materials"ER-AA-RRM-100, Revision 2, "ASME Section Xl Repair/Replacement Program Fleetlmplementation Req uirements"gi-nn-XOE-\rr-G03, Revision 3, "VT-3 Visual Examination Procedure"MA-AA-101, Revision 5, "Fleet Lifting and Material Handling"MA-AA-1001, Revision 4, "supplemental Personnel"Mp-VE-g, Revision 001, iVisual Weld Acceptance Criteria for Weldments and BrazedJoints"SA-AA-107, Revision 0, "Fall Protection"SA-AA-108, Revision 0, "Hand and Portable Power Tool safety"SA-AA-111, Revision 0, "Ladder Safety"SA-AA-1 18, Revision 2, "Personal Protective Equipment"SA-AA-119, Revision 2, "safety Signs and Barriers"SA-AA-123, Revision 0, "Welding, Cutting , and Brazing Safety"Drawinqs252003-22200, sH 60469GtvtpZ eSt 1301A, "Evaluated Simulator Exam"LORT SE 16, Revision 4Attachment A-5Section 1Rl2: Maintenance EffectivenessgPumpMotor,ElectricMotor&ContractingCo.,lnc.Maintenance Rule Scoping Tables, Charging, Letdown and Boric AcidSystem Health Report,'Chirging, Letdown and Boric Acid, 1"t Quarter 2010 and 1" quarter 2011MREO10523MREO1 081 7MREo10827MREO10852MREO1091 1MREO109',l2MREo10933MREo10954MRE011216MRE01 1 21 7MREO11377MRE012159MREo12314MREo12382MREo12902MREO13587MREO13664MREo13670Alternateetantcon@ting2-RC-252,pressurizerspraylineisolationETE-Mp-2011-0090, "Structural Integrity Evaluation for MPS3 Dealloyed Aluminum BronzeValves," Revision 0, dated May 26,2Q11Millstone Unit 2 & Millstone Unit 3, 2R2O Switchyard Work Risk Management Plan, Revision 1,March 31, 2011Millstone Unit 2 Shutdown Safety Assessment (SSA) Checklist April 5, 2011, April7 ,2011Millstone Unit 2 High Risk Evolution Plan for the 1't Reduction in RCS InventoryMillstone Unit 3 EOOS Operator's Risk Report, April 14,2011OP-AA-1 500, "Operational Configuration Control," Revision 5OP 2301E, "Draining the RCS (ICCE)," Revision O24-O7OU-M-200, "shutdown Risk Management," Revision 2ou-M2-201, "shutdown safety Assessment checklist," Revision 1Pre-2R2Q Shutdown Risk Schedule Reviewshutdown Risk contingency Plan Replacement of 2-SW-97B - OrangeSp 344681 2,"Train 'B;Soli-d State Protection System Operational Test," Revision 012-04ESI-TP-3 96000049, "345 KV System," Revision 1cR421347cR422907cR422915cR428600cR428654cR428658wo 53102440496wo 53102273422Section 1R15: Operabilitv EvaluationsAOP{551 "Reactor Coolant System Leak," Revision A17-O2EOP-3505, "Loss of Shutdown booling and/or RCS lnventory," Revision 10-03EOP-ECA- 1.2, "LOCA Outside of Containment," Revision 008RAS 000176, "Justification for TCOA to Secure RCPs," Revision 0 dated April4,2011NRC Memo from John Hannon to Sunil Weerakkody, "subject: Resolution of QuestionsAttachment A-6concerning Compliance with Section lll.L.2 of Appendix'R"'dated February 10' 2005ETE-Mp-tg11-0090, "structural Integrity Evaluation for Millstone Unit 3 Dealloyed AluminumBronze Valves," Revision 0 dated May 26,20111OD000173, "Millstone Unit 3 Service Water Valves Dealloying Conditior," dated May 28,2011CR41}T23, ,,Fire Shutdown Analysis Time Critical Operator Action (TCOA) to secure RCPs"dated March 28,2011cR428600cR428654cR428658Section 1Rl8: Plant Modifications@m SafetyValve Vent Piping," Revision 425203-20150, "Main Steam Relief Valve Discharge to Atmosphere," Revision 953102364164531 023641 65531 023641 66531 023641 69531 02379998Section 1R19: Post Maintenance Te,stinq@ry Quarterly Inspection," Revision 001-04OP 2346C-002, "'B' DG Data Sheet," Revision 001-06SP 2411A, "CEA Motion Inhibit Verification (deviation)," Revision 002-04SP 2411B, "PDIL Alarm Verification," Revision 000-04sP 2613J-001, "'B'Emergency DG LoSS of Load Test," Revision 003Sp 2613L-001, ,,periodicbG Slow start Operability Test, Facility 2 (Loaded Run)," Revision 003-0753M2030083353M2080709953102283860531 02301 08853102322778cR420696cR422697cR422840cR43209853102389917531023946595310243523453102447327cR432184cR432201cR432228cR432400cR432419Section 1R20: Refuelinq and Oth.er gutaqq Aqtjvities, "lTC Measurements," Revision 006-06EN 21004K, "Low Power Physics Test," Revision 003-00MP 271281, "Control of Heavy Loads," Revision 010-06MP 27O4AA. "Unit 2 Reactor Disassembly and Reassembly," Revision 002-03OP 22O2A, "Reactor Startup by Dilution lCCE," Revision 000-04OPS-FH 215, "Refueling Machine Operation," Revision 001-03SP 21018-001, "Core R6activity Balance Surveillance Form," Revision 010-02Attachment A-6cR420439cR421265cR423437cR424910cR424939cR425314cR42551 3Section 1R22: Surveillance TestlnqlReadinessandQuarterlylSTGroup.B,PumpTeStS,,'Revision 017-03SP 3622.3-001, Surveillance Form Revision 014-03sP 3556812, "SSPS Train'.B' Operational Test," Revision 012-04CR41 2930, "Chemistry procedut'e needs enhancement"Millstone Nuclear power Station Gamma Spectrum Analysis dated May 27,2011CP 3802E, "Reactor Coolant gas Sampling and Analysis," Revision 002-0153102294614 5310229998353102296198 53102300352cR422915cR420164 cR425958cR422421 cR426589cR422847 cR426592cR422907ProceduressP 2815, Main station stack WRGM Sampling for lodine and ParticulatesSP 28144, Gaseous Effluents for lodines and Particulates from Unit 2 VentSP 3878, Unit 3 Monthly Liquid and Gaseous Effluent Dose ProjectionSP 2858, Offsite Dose Noble Gases from Unit 2SP 2859, Off-Site Dose-lodine and Particulate ReleasesRP-AA-502, Groundwater Protection ProgramRp-AA-bO4, Remediation Process for the Groundwater Protection ProgramRp-AA-524, performinj Sour"" Term Estimates and Dose Calculations for Carbon-14 EffluentsRpM 2.8.S, Sampling alnd Oisposal of Unit 3 Waste Test Tank Berm WaterEN 21235, Millstone-Unit 2 Radiation Monitor High Radiation SetpointsEN31 153, Millstone Unit 3 Radiation Monitor High Radiation SetpointsEP-AA-303, Equipment lmportant to Emergency ResponseCY-AA-LQC-400- 1 O0O, Confi rmatory Measurements using Bl ind sam plesSP 3880, Unit 3 SCLRS Vent Radiation Monitor lnoperableRadioloqical Hazard Assessment (21 124.01 )@ High Radiation Area Key ControlRPM 1.5.5, Revision 4, Guidelines for Performance of Radiological SurveysRPM 1.5.6, Revision 3, Survey Documentation and DispositionRPM 2.1.1, Revision 5, lssuance and Control of RWPsRPM 2.4'1, Revision 6, Posting of Radiological Control AreasAttachment A-8RpM 2.S.2, Revision 2, Guidelines for Spent Fuel Pool or Flooded Reactor Cavity WorkRPM 5.2.2, Revision 10, Basic Radiation worker ResponsibilitiesRPM-GDL-008, Revision 0, EleCtronic Dosimeter Alarm set PointsRp-M-201, Revision 4, Access Controls for High and Very High Radiation AreasRP-AA-106, Revision 1, Radiological Work Control ProgramRP-AA-124, Revision 2, Dosimetry Discrepancy and ED AlarmRp-M-201, Revision 5, Access Controls for High and Very High Radiation AreasRP-M-203, Revision 0, Radiological Labeling and MarkingRP-AA-222, Revision 0, Radiation SurveysRP-M-223, Revision 1, Contamination SurveysALARA Planninq & Controls (71124'02)RP-M-103, Revision 0, ALARA ProgramRP-M-103-1000, Revision 1, Station ALARA CommitteeRP-M-300, Revision 4, ALARA Reviews and ReportsRPM 1.4.2, Revision 2, ALARA Engineering ControlsRPM 1.4.4, Revision 2, Temporary ShieldingRPM 2.1.2, Revision 2, ALARA lnterface with the RWP ProcessRPM 5.2.3, Revision 3, ALARA Program and Policy24.03fportaoteHEPAFilteredVentilationandVacuumUnitsRPM 2.10.2, Revision 11, Air Sample Counting and AnalysisCatibration/Source/Functional Testinq Records Reviewed:ln-Plant Effluent MonitorsUnit2ffiinment Gaseous and Particulate Process Radiation Monitor (RM-8123)Aerated Liquid Rad waste Process Radiation Monitor (RM-g116)Waste Gas Process Radiation Monitor (RM-9095)Reactor Building Closed Cooling Water Radiation Monitor (RM-6038)clean Liquid Rad waste Process Radiation Monitor (RM-9049)Unit 3Contlinment Area High Range Radiation Monitor (3RMS.R1Y05A)Waste Neutralization Sump Radiation Monitor (3CND-RlYO7)Ventilation Vent Stack High Range Radiation Monitor (3HVR.RlY10AVentilation Vent Stack Normal Range Radiation Monitor (3HVR-RlY10B)Supplemental Leak Collection and Release System High Range Radiation Monitor(3HVR.RIY19A)Liquid Waste Radiation Monitor (3LWS-RlY70)Turbine Building Floor Drains Radiation Monitor (3DAS-RlY5o)Attachment A-9Air Cleaninq Svstem Testino@ryBuildingVentilationSystemSurveillanceTestsSp 36141, Unit 3 Supplemental Leak Collection and Release System Surv_eillance TestsSp 2654e, Unit 2 Containment and Enclosure Building Exhaust Filter L-25 HEPAFiltration TestingSP 2609D, Unit! Enclosure Building Charcoal/HEPA Filtration TestingSp 34498; SLCRS Gaseous Radiation Monitor and Ventilation Vent Stack CalibrationVPROC-OPSo3-Oo1, In-Place Testing of HEPA Filters & Charcoal AbsorbersOther DocumentsMonthly, Ouartedy, and Annual Liquid and Gaseous Effluent Dose Assessments forUnit 2 and Unit 3 from April 2010 through April 20112010 Radioactive Effluent Release ReportMp-22-REC-BAp01, Revision 26, Radiological Effluent Monitoring and Off-Site DoseCalculation ManualAudit 0g-15, Off-site Dose calculation Manual/Radiological Environmental MonitoringProgram (REMODCM)Occupational Dose Assessment (71 124'04)npV t.3.8, Revision 8, Criteria for Dosimetry lssueRPM 1 .3.12, Revision 8, Internal Monitoring ProgramRPM 1.3.13, Revision 8, Bioassay Sampling and AnalysisRPM 1 .3.14, Revision 7, Personnel Dose Calculations and AssessmentsRPM 1.6.4, Revision 3, Siemens Electronic Dosimetry SystemRPM 2.5.8, Revision 3, Stay Time Tracking and Multi-Badging for Special WorkRP-AA-123, Revision 1, Effective Dose EquivalentRP-AA-150, Revision 1, TLD Performance TestingCondition Reportsiffi,q6953,418801,41g2go,41g87g,42o476,42o959,421ooo,421o56,421115,421661, 421769, 421906:, 421g15i,, +Z2Zg3, 422281, 422384, 422712, 428440, 417715' 420139',}B21OT , 42Sg4B:, 421522, 422894, 422553i, 418694, 409791, 387731, 380555, 370396, 368894Site ALARA Council Meetinq Minutesrations&LocalLeakRateTesting,Decon,Shieldinglnstallation & Removal, In-service lnspection, Steam Generator Corrective Maintenance (CM)and preventative Mainienance (PM), iReactor Disassembly/Reassembly, Mechanical CMs &PMs, Instrumentation & Controls TasksMiscellaneous DocumentsNVLAP Certfication Records, Personnel Dosimetry Performance TestingAnnual Review Report of the 2010 1o cFR Part 61 Radionuclide AnalysisElectronic Dosimeter Dose/Dose Rate Alarm Reports, January 2011 - April 2011Top Ten Individual Exposure Records for 2011Portable HEPA Inventory & Test RecordsEPRI Standard Radiatioh Monitoring Program Data Summary for Unit 2 pipingUnit 2 Reactor Coolant System 2R20 Clean Up DataNuclear oversight Field observation 2R20 Snapshot ReportsAttachment A-102R20 ALARA Plans (AP)/ Work-ln-Proqress (WlP) ReviewsAP 2-11 -01, Reactor Disassembly/ReassemblyAP 2-11-09, Steam Generator PMs & CMsAp 2-11-13, Scaffolding lnstallation/Removal, lnstallation of Permanent ScaffoldingAP 2-11-14, Insulation Removal/lnstallationAP 2-11-26, Radiation Protection Support Activities for 2R20Section 4OA3: Event Follow'uP@re of SP 2609E for Facility 1 on April 3,2011MP 2701J-114, "Main Steam Safety Valve Discharge Piping," Revision 0Mp27O2Fj0A, "Cleaning and Inspection of MSSVs Sliding Bushings," Revision 000RCE000984, "EnclosurJ Auitding'Filtration System (EBFS) Negative Pressure Test FailedAcceptance CriteriaSP 2609E, "EBFS Negative Pressure Test," Revision 009-04SP 2609EE-001, "EBFS Negative Pressure Test, Facility 1,"SP 2609EE-002, "EBFS Negative Pressure Test, Facility 2,"cR42048553M2080705653M29208468008-03001-04Attachment ACADAMSALARAAOPAPASMECAPCEDECFRCLBCRCVCSCWDACDGDNBDNCDPWDRPDRSECCSEDEXEDGEBFSEPESASESFFSARHEPAHPSIHRArclr&cIMCISTJITTLERLHRALPSILOCAMCCmremMSSVMWTHNCVA-11LIST OF ACRONYMSAlternating CurrentAgencywide Documents Access and Management SystemAs Low As ReasonablY AchievableAbnormal Operating ProcedureALARA PlansAmerican Society of Mechanical EngineersCorrective Action ProgramCommitted Effective Dose EquivalentCode of Federal RegulationsCurrent Licensing BasisCondition ReportChemicaland Volume Control SystemCirculating WaterDerived Air ConcentrationDiesel GeneratorDeparture from Nucleate BoilingDominion Nuclear ConnecticutDeclared Pregnant WorkersDivision of Reactor ProjectsDivision of Reactor SafetYEmergency Core Cooling SYstemExternal Effective Dose EquivalentEmergency Diesel GeneratorEnclosure Building Filtration SystemEmergency PrePared nessEngineered Safety-Feature Actuation SystemEngineered SafetY FeatureFinal Safety AnalYsis RePortHigh Efficiency Particulate AirHigh Pressure SafetY InjectionHigh Radiation Areaslncore lnstrumentlnstrumentation and Controllnspection Manual ChaPterIn-Service TestingJust-intime-trainingLicensee Event RePortsLocked High Radiation AreaLow Pressure SafetY InjectionLoss of Coolant AccidentMotor Control CentermilliremMain Steam SafetY ValveMegawatts ThermalNon-Cited ViolationAttachment NEINRCNVLAPODODCMoosPARSPIPI&RPMPMTRBCCWRCARCERCPRCSREMODCMRWPSACSDCSDPSGSGFPSLCRSSPSWTEDETLDTSUFSARUGSVHRAWOWRGMA-12Nuclear Energy lnstituteNuclear Regulatory CommissionNational Voluntary Laboratory Accreditation ProgramOperability Determ inationsOff-Site Dose Calculation ManualOut Of ServicePublicly Available Records SystemPerformance IndicatorProblem ldentification and ResolutionPreventive MaintenancePost Maintenance TestingReactor Building Closed Cooling WaterRadiologically Controlled AreaRoot Cause EvaluationReactor Coolant PumPReactor Coolant SystemRadiological Effluent Monitoring and Offsite Dose Calculation ManualRadiological Work PermitSite ALARA CouncilShutdown CoolingSignificance Determination ProcessSteam GeneratorSteam Generator Feedwater PumPSupplemental Leak Collection and Release SystemSurveillance ProceduresService WaterTotal Effective Dose EquivalentThermoluminescent DosimeterTechnical SpecificationUpdated Final Safety Analysis ReportUpper Guide StructureVery High Radiation AreasWork OrderWide Range Gas MonitorAttachment
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