IR 05000336/2007004

IR 05000336-07-004 and 05000423-07-004, on 07/01/2007 - 09/30/2007, Millstone Power Station, Unit 2 and Unit 3;, Post-Maintenance Testing Inspection

ML073050271
Person / Time
Site:	Millstone
Issue date:	10/31/2007
From:	Racquel Powell NRC/RGN-I/DRP/PB5
To:	Christian D Dominion Resources Services
Powell R, RI/DRP/610-337-6967
References
IR-07-004
Download: ML073050271 (40)

Text

ctober 31, 2007

SUBJECT:

MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2007004 AND 05000423/2007004

Dear Mr. Christian:

On September 30, 2007, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station Unit 2 and Unit 3. The enclosed inspection report documents the inspection results, which were discussed on October 10, 2007, with Mr. J. Alan Price and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This report documents one self-revealing finding of very low safety significance (Green).

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Raymond J. Powell, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-336, 50-423 License Nos.: DPR-65, NPF-49 Enclosure: Inspection Report 05000336/2007004 and 05000423/2007004 w/Attachment: Supplemental Information cc w/encl:

see next page

M

SUMMARY OF FINDINGS

IR 05000336/2007-004, 05000423/2007-004; 07/01/2007 - 09/30/2007; Millstone Power

Station, Unit 2 and Unit 3; Post-Maintenance Testing.

The report covered a 3-month period of inspection by resident inspectors and announced inspections by regional inspectors. One Green finding was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

A self-revealing finding was identified for Dominions failure to implement procedure OP 3330B, Turbine Plant Component Cooling Water during restoration of the B turbine plant component cooling water (TPCCW) heat exchanger on August 28, 2007. Specifically, following maintenance that left the heat exchanger shell in a partially drained condition, Dominion did not fill and vent the heat exchanger in accordance with OP 3330B. This resulted in two of the three TPCCW pumps receiving an automatic trip signal on low suction pressure. Loss of the remaining TPCCW pump would have required the operators to manually trip the reactor within three minutes per plant procedures. Dominion entered this issue into their corrective action program as CR-07-09057. Corrective actions included revising OP 3330B to require the fill and vent section be used following maintenance to ensure the TPCCW side of the heat exchanger is completely full of water, and revising the work planning procedure to request operations work planning provide restoration packages for all applicable work orders.

This finding is more than minor because it was associated with the human performance attribute of the Initiating Events Cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Dominions failure to implement the fill and vent procedure, when required by heat exchanger conditions, could potentially have led to the loss of all TPCCW pumps and required operators to manually trip the reactor. This finding was determined to be of very low safety significance (Green) by performing a Phase 1 evaluation in accordance with NRC IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The finding has a cross-cutting aspect in the area of Human Performance, work practices component, because Dominion did not implement proper procedures for the restoration of the B TPCCW heat exchanger. H.4(b) (Section 1R19)

Licensee-Identified Violations

None.

iii

REPORT DETAILS

Summary of Plant Status

Units 2 & 3 operated at or near 100 percent through out the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Seasonal Site Inspection

a. Inspection Scope

(One Sample)

The inspectors performed a review of severe weather preparations during the onset of the hurricane season to evaluate the sites readiness for seasonal susceptibilities. The inspectors reviewed selected equipment, instrumentation, and supporting structures to determine if they were configured in accordance with Dominions procedures and that adequate controls were in place to ensure functionality of the systems. The inspectors reviewed the Unit 2 and 3 Updated Final Safety Analysis Report (UFSAR) and Technical Specifications (TS) and compared the analysis with procedure requirements to ascertain that procedures were consistent with the UFSAR. The inspectors performed partial walkdowns of the Unit 2 and Unit 3 intake structures, service water systems, intake structure traveling screens and emergency diesel generators (EDGs) to determine the adequacy of equipment protection from the effects of hurricanes. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 System Inspection

a. Inspection Scope

(One Sample)

The inspectors reviewed the readiness of the Unit 2 service water system for extreme weather conditions, specifically, hurricanes, high winds, high tides, and other severe weather events. The inspectors reviewed licensee procedures and walked down the system to determine if the service water systems, including instrumentation and supporting structures, were configured in accordance with Dominion procedures and that adequate controls were in place to ensure functionality of the system. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns (Four Samples)

a. Inspection Scope

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

The inspectors reviewed the documents listed in the Attachment to determine the correct system alignment. The inspectors conducted a walkdown of each system to determine if the critical portions of selected systems were correctly aligned, in accordance with these procedures, and to identify any discrepancies that may have had an effect on operability. The walkdowns included selected switch and valve position checks, and verification of electrical power to critical components. Finally, the inspectors evaluated other elements, such as material condition, housekeeping, and component labeling. The following systems were reviewed based on their risk significance for the given plant configuration:

Unit 2

• C High Pressure Safety Injection (HPSI) system while B HPSI out for planned maintenance on August 7, 2007; and

• B Enclosure Building Filtration System (EBFS) while the A train was out for planned maintenance on August 14, 2007.

Unit 3

• B EDG while A EDG out for planned maintenance on July 18, 2007; and

• A High Pressure Safety Injection (SIH) system while B SIH out for planned maintenance on August 28, 2007.

b. Findings

No findings of significance were identified.

.2 Complete System Walkdown

a. Inspection Scope

(Two Samples)

The inspectors completed a detailed review of the alignment and condition of the Unit 2 Safety Injection System (SIS) and Unit 3 Containment Recirculation Spray System (RSS). The inspectors conducted walkdowns of the systems to determine if critical portions, such as valve positions, switches, and breakers, were correctly aligned, in accordance with procedures, to identify any discrepancies that may have had an effect on operability.

The inspectors also conducted a review of outstanding maintenance work orders to determine if the deficiencies significantly affected the SIS and RSS system functions. In addition, the inspectors discussed system health with the system engineering staff and reviewed the condition report (CR) database to determine if equipment alignment problems were being identified and appropriately resolved. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Quarterly Sample Review

a. Inspection Scope

(Twelve Samples)

The inspectors performed walkdowns of fire protection areas during the inspection period. The inspectors reviewed Dominion's fire protection program to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. The inspectors walked down these areas to assess Dominion's control of transient combustible material and ignition sources. In addition, the inspectors evaluated the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors then compared the existing conditions of the areas to the fire protection program requirements to determine if all program requirements were being met. Documents reviewed during the inspection are listed in the Attachment. The fire protection areas reviewed included:

Unit 2

• Auxiliary Building 480 Volt MCC B51 and B41A (Fire Area A-13);

• Auxiliary Building Railroad Bay Area (Fire Area A-14B);

• Enclosure Building Filtration System EBFAS Equipment Area (Fire Area A-14D);

• Diesel Generator Room A (Fire Area A-15);

• Diesel Generator Room B (Fire Area A-16); and

• Auxiliary Building Hallway/Storage Area/Hot Tool Crib (Fire Area A-19).

Unit 3

• Auxiliary Building, West Motor Control Center and Rod Control Area, 24'-6" Elevation (Fire Area AB-6, Zone A);

• Auxiliary Building, West Motor Control Center and Rod Control Area, 43'-6" Elevation (Fire Area AB-6, Zone A);

• West Service Water Cubicle, 14'-6" Elevation (Fire Area CSW-4);

• Control Building, Cable Spreading Area, 24'-6" (Fire Area CB-8);

• Control Building, East Switchgear Area, 4'-6" (Fire Area CB-2); and

• Control Building, West Switchgear Area, 4'-6" (Fire Area CB-1).

b. Findings

No findings of significance were identified.

.2 Annual Fire Drill Observation

a. Inspection Scope

(One Sample)

Unit 2 The inspectors observed personnel performance during a fire brigade drill on September 14, 2007, to evaluate the readiness of station personnel to fight fires. The drill simulated a fire in the Unit 2 A DC Switchgear Room. The inspectors observed the fire brigade members using protective clothing, turnout gear, and self-contained breathing apparatus and entering the fire area. The inspectors also observed the fire fighting equipment brought to the fire scene to evaluate whether sufficient equipment was available to effectively control and extinguish the simulated fire. The inspectors evaluated whether the permanent plant fire hose lines were capable of reaching the fire area and whether hose usage was adequately simulated. The inspectors observed the fire fighting directions and communications between fire brigade members. The inspectors also evaluated whether the pre-planned drill scenario was followed and observed the post drill critique to evaluate if the drill objectives were satisfied and that any drill weaknesses were discussed.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

.1 Internal Flooding Inspection

a. Inspection Scope

(One Sample)

The inspectors reviewed the flood protection measures for Unit 3 equipment in the safety-related A and B service water pump cubicles. This review was conducted to evaluate Dominions protection of the enclosed safety-related systems from internal flooding conditions. The inspectors performed a walkdown of the area, reviewed the UFSAR, the internal flooding evaluation and related documents. The inspectors examined the as-found equipment and conditions to ensure that they remained consistent with those indicated in the design basis documentation, flooding mitigation documents, and risk analysis assumptions. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 External Flooding Inspection

a. Inspection Scope

(One Sample)

The inspectors evaluated Dominion's preparation for, and protection from, the effects of external flooding conditions for Unit 2. The inspectors reviewed the UFSAR and applicable procedures to determine the readiness of protection for applicable safety-related structures, systems, and components. The inspectors performed walkdowns of the Unit 2 turbine, auxiliary, and EDG rooms to determine the adequacy of the floodgates, flood doors, temporary equipment, and removable flood planks to perform their design function. Additionally, the inspectors reviewed recent Dominion inspection results, including floodgate inspections, to determine whether previously identified deficiencies had been entered into Dominion's corrective action program for resolution.

Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance (71111.7A)

Inspection Scope (One Sample)

The inspectors reviewed the Unit 2 B EDG service water heat exchanger. The inspectors observed the as-found condition of the heat exchanger once it was opened to determine whether any adverse fouling concerns were appropriately addressed. The inspectors reviewed the results of the inspections performed in accordance with Dominion procedures. The inspectors reviewed the inspection results against the acceptance criteria contained within the procedure to determine whether all acceptance criteria had been satisfied. The inspectors also reviewed the UFSAR to evaluate whether heat exchanger inspection results were consistent with the design basis. The inspectors determined whether adverse conditions identified by Dominion were appropriately entered into Dominions corrective action program. The inspectors also reviewed Work Order (WO) M2 06 07171, B EDG Clean service water heat exchanger and inspect expansion joints, and WO M2 0510019 B EDG 18 Month 100 percent eddy current testing tubing examination.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

Resident Inspector Quarterly Review

a. Inspection Scope

(Two Samples)

The inspectors observed simulator-based licensed operator requalification training provided to operators for Unit 2 on August 28, 2007, and Unit 3 on August 28, 2007.

The inspectors evaluated crew performance in the areas of clarity and formality of communications; ability to take timely actions; prioritization, interpretation, and verification of alarms; procedure use; control board manipulations; oversight and direction from supervisors; and command and control. Crew performance in these areas was compared to Dominion management expectations and guidelines as presented in OP-MP-100-1000, Millstone Operations Guidance and Reference Document. The inspectors also compared simulator configurations with actual control board configurations. The inspectors also observed Millstone evaluators discuss identified weaknesses with the crew and/or individual crew members, as appropriate.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (71111.12Q)

a. Inspection Scope

(Three Samples)

The inspectors reviewed three samples of Dominion's evaluation of degraded conditions, involving safety-related structures, systems and/or components for maintenance effectiveness during this inspection period. The inspectors reviewed licensee implementation of the Maintenance Rule. The inspectors reviewed work practices that may have contributed to degraded system performance, Millstones ability to identify and address common cause failures, the applicable maintenance rule scoping document for each system, the current classification of these systems in accordance with 10 CFR 50.65 (a)(1) or (a)(2), the applicable system (a)(1) performance evaluation, and the adequacy of the performance criteria and goals established for each system, as appropriate. The inspectors also reviewed recent system health reports and/or discussed system performance with the responsible system engineer. The specific samples are listed below:

Unit 2

• CRAC (a)1 Action Plan; and

• DC Breakers Testing and Maintenance.

Unit 3

• Emergency Safeguards Facility (ESF) Building Ventilation (HVQ) System (a)1 Action Plan.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

(Nine Samples)

The inspectors evaluated online risk management for emergent and planned activities.

The inspectors reviewed maintenance risk evaluations, work schedules, and control room logs to determine if concurrent planned and emergent maintenance or surveillance activities adversely affected the plant risk already incurred with out-of-service components. The inspectors evaluated whether Dominion took the necessary steps to control work activities, minimize the probability of initiating events, and maintain the functional capability of mitigating systems. The inspectors assessed Dominions risk management actions during plant walkdowns. Documents reviewed during the inspection are listed in the Attachment. The inspectors reviewed the conduct and adequacy of scheduled and emergent maintenance risk assessments for the following maintenance and testing activities:

Unit 2

• A instrument air compressor unavailable due to planned maintenance on July 19, 2007;

• B EDG starting air tank unavailable due to planned maintenance for the double check valve replacement on July 23, 2007;

• Containment and enclosure building heating and ventilation maintenance during A EDG maintenance on August 8, 2007;

• Dominions response to rising power operated relief valve (PORV) temperatures during the time period of August 15 -20, 2007;

• Dominions response to an unexpected indication during surveillance testing of Reactor Protection System (RPS) matrix logic circuitry on September 7, 2007; and

• Dominions response to pressurizer back-up heater failures during the time period of September 1-21, 2007.

Unit 3

• A EDG jacket water cooling heat exchanger unavailable due to planned maintenance on July 20, 2007;

• TDAFW system unavailable due to emergent maintenance on August 19, 2007; and

• TDAFW and B quench spray system (QSS) unavailable due to planned maintenance on August 23, 2007.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

(Six Samples)

The inspectors reviewed six operability determinations. The inspectors evaluated the operability determinations against the guidance contained in NRC Regulatory Issue Summary 2005-20, Revision to Guidance Formerly Contained in NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability. The inspectors also discussed the conditions with operators and system and design engineers, as necessary. The inspectors reviewed the adequacy of the following evaluations of degraded or non-conforming conditions:

Unit 2

• CR-07-07926, Six tubes recommended for plugging in X53B, EDG lube oil heat exchanger on July 26, 2007;

• CR-07-02246 B CRAC exhaust fan damper leaks by air causing fan to rotate backwards on August 30, 2007; and

• CR-07-09015, Potential failure scenario for the pressurizer PORVs on September 11, 2007.

Unit 3

• CR-07-08539, Pressure test not performed after Class I valve replacement;

• CR-07-08565, C component cooling water (CCP) heat exchanger cover suspended over A CCP pump; and

• CR-07-08599, Feedwater isolation trip valves closing capability degraded.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

a. Inspection Scope

(One Sample)

The inspectors reviewed a permanent plant modification on Unit 2 B EDG output breaker 15G-13U-2 closing coil. The inspectors performed a walkdown of the area and reviewed the UFSAR, licensing and design basis documents, and the engineering disposition. These reviews were conducted to determine whether

(1) the modified components remained consistent with the assumptions indicated in the design basis documents,

(2) system availability, reliability, and functional capability were maintained, and

(3) any unrecognized conditions that significantly affected risk or could place the plant in an unsafe condition were introduced as a result of the modifications.

Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were determined.

1R19 Post-Maintenance Testing

a. Inspection Scope

(Eight Samples)

The inspectors reviewed post-maintenance test (PMT) activities to determine whether the PMT adequately demonstrated that the safety-related function of the equipment was satisfied, given the scope of the work specified, and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to evaluate consistency with the associated design and licensing bases, as well as TS requirements. The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following maintenance activities and their post-maintenance tests were evaluated:

Unit 2

• B EDG operability test following various preventive maintenance tasks and lube oil heat exchanger tube plugging on July 24, 2007 (WO M2-06-07171);

• Doble Testing on the 4.16KV breaker for C service water (SW) Pump following a design change to wiring involving the power switch on August 21, 2007 (WOs M2 04-12276, 03-08727, 04-07956); and

• Repair of B TPCCW heat exchanger tube leak.

Unit 3

• B service water strainer inspection and repairs on July 16, 2007 (WO M3-07-10233);

• A EDG jacket water cooling heat exchanger tube plugging on July 18, 2007 (WO M3-07-09476);

• Motor driven auxiliary feedwater pump oil leak repairs on July 23, 2007 (WO M3-07-08384);

• High pressure safety injection (SIH) to cold leg check valve (WO M3-06-00145);and

• A EDG testing following completion of an engine overhaul on September 11, 2007 (SP 3646A.1, Emergency Diesel Generator A Operability Test, Revision 17).

b. Findings

Introduction:

A self-revealing finding was identified for Dominion's failure to implement procedure OP 3330B, "Turbine Plant Component Cooling Water," during restoration of the "B" TPCCW heat exchanger on August 28, 2007. Specifically, Dominion did not fill and vent the heat exchanger in accordance with OP 3330B following maintenance that left the heat exchanger shell in a partially drained condition. This resulted in two of the three TPCCW pumps receiving an automatic trip signal on low suction pressure. Plant procedures would have required the operators to manually trip the reactor within three minutes had the third TPCCW pump tripped.

Description:

On August 8, 2007, Dominion identified a tube leak originating from the "B" TPCCW heat exchanger. Dominion prepared a work package to identify and repair the source of the leak. On August 27, Dominion personnel began work on repairing the TPCCW heat exchanger. A leaking tube was identified near the bottom of the heat exchanger, and the leak rate was estimated to be approximately one half gallon per minute at that time. Dominion successfully completed the repairs to the heat exchanger on August 28.

During restoration of the heat exchanger, when operators opened the "B" TPCCW heat exchanger discharge isolation valve, the "C" TPCCW pump immediately tripped on low suction pressure. The "B" TPCCW pump, which was in standby, also received an automatic trip signal on low suction pressure, preventing the pump from starting. The "A" pump, which was running, did not receive a trip signal and remained in operation.

Heat loads on the TPCCW system at full power require at least two pumps to be in service. The plant operated with only one TPCCW pump running for approximately five minutes, during which time lube oil temperatures increased and a generator bus duct cooling system high temperature alarm was received. Operators were able to restart the "B" TPCCW pump within five minutes, which provided sufficient cooling to the TPCCW system.

Dominions investigation determined that the TPCCW side of the heat exchanger had been slowly draining through the failed tube since August 8, when the heat exchanger was first isolated. Restoring the B TPCCW heat exchanger while in a substantially drained condition resulted in two of the three TPCCW pumps receiving automatic trip signals on low suction pressure, and could have potentially also led to a trip signal being sent to the only remaining TPCCW pump. The performance deficiency is that Dominion failed to implement procedure OP 3330B, Section 4.8, Filling TPCCW Heat Exchanger(s), when required by heat exchanger conditions following maintenance to repair a tube leak.

Analysis:

As a result of not implementing OP 3330B, Section 4.8, Filling TPCCW Heat Exchanger(s), Dominion restored the B TPCCW heat exchanger while in a substantially drained condition, which resulted in the B and C TPCCW pumps receiving automatic trip signals on low suction pressure. This finding is more than minor because it was associated with the human performance attribute of the Initiating Events Cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Dominions failure to implement the fill and vent procedure, when required by heat exchanger conditions, could potentially have led to the loss of all TPCCW pumps and required operators to manually trip the reactor.

The inspectors conducted a Phase 1 screening of the finding in accordance with IMC 0609, Appendix A, "Determining the Significance of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available.

The performance deficiency has a cross-cutting aspect in the area of Human Performance, Work Practices, in that Dominion did not implement proper procedures for the restoration of the B TPCCW heat exchanger. H.4(b)

Enforcement:

Enforcement action does not apply because the performance deficiency did not involve a violation of regulatory requirements because the TPCCW system is not safety-related equipment. Dominion entered this issue into their corrective action program (CR-07-09057). Corrective actions include revising the work planning procedure to request Operations Work Planning provide restoration packages for all applicable work orders, and revising OP 3330B to require the fill and vent section be used following maintenance to ensure the TPCCW side of the heat exchanger is completely full of water. Because this finding does not include a violation of regulatory requirements and is of very low safety significance (Green), it is identified as FIN 05000336/2007004-01, Failure to Perform Fill and Vent of TPCCW Heat Exchanger Resulted in Loss of Two TPCCW Pumps.

1R22 Surveillance Testing

a. Inspection Scope

(Seven Samples)

The inspectors reviewed surveillance activities to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety-related function. The inspectors attended pre-job briefs, reviewed selected prerequisites and precautions to determine if they were met, and observed the tests to determine whether they were performed in accordance with the procedural steps. Additionally, the inspectors reviewed the applicable test acceptance criteria to evaluate consistency with associated design bases, licensing bases, and TS requirements and that the applicable acceptance criteria were satisfied. The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following surveillance activities were evaluated:

Unit 2

• On July 19, 2007, A containment spray pump and check valve IST;

• On July 27, 2007, C high pressure core spray check valve IST;

• On September 25, 2007, Diesel Fire Pump M7-7 monthly operability demonstration; and

• On September 28, 2007, C service water pump IST test.

Unit 3

• Reactor protection set cabinet II operational surveillance test (SP 3443B21);

• On August 8, 2007, Service water relief valve 3SWP*RV94A; and

• On August 24, 2007, Auxiliary Feedwater Pump 3FWA*P2 operational readiness test.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

(Two Samples)

The inspectors reviewed two temporary modifications to evaluate if the temporary modifications adversely affected the function of the associated safety systems. The inspectors reviewed the temporary modifications and their associated 10 CFR 50.59 screening against the UFSAR and TS determine whether the modifications affected system operability or availability. Documents reviewed during the inspection are listed in the Attachment.

Unit 2

• Disconnect of faulted pressurizer back-up heaters in order to restore remaining heater on the breakers to operation on September 20, 2007 (DCN DM2-00-0185-07).

Unit 3

• Temporary removal of the A control building air conditioning booster pump check valve 3SWP*V010 (DM3-00-0238-07).

b. Findings

No findings of significance were identified.

Emergency Preparedness

1EP2 Alert and Notification System (ANS) Evaluation

a. Inspection Scope

(One Sample)

An onsite review was conducted to assess the maintenance and testing of the licensees ANS. During this inspection, the inspector interviewed site Emergency Preparedness (EP) staff responsible for implementation of the ANS testing and maintenance. CRs pertaining to the ANS were reviewed for causes, trends, and corrective actions. The inspector reviewed the licensees original ANS design report to ensure compliance with those commitments for system maintenance and testing. The inspector also interviewed EP staff to gain an understanding of the new ANS plans for Millstone. Planning standard, 10 CFR 50.47(b)(5) and the related requirements of 10 CFR 50, Appendix E were used as reference criteria.

b. Findings

No findings of significance were identified.

1EP3 Emergency Response Organization (ERO) Staffing and Augmentation System

a. Inspection Scope

(One Sample)

A review of Millstones ERO augmentation staffing requirements and the process for notifying the ERO was conducted. This was performed to ensure the readiness of key staff for responding to an event and to ensure timely facility activation. The inspector reviewed procedures, CRs, and call-in drills associated with the ERO notification system and drills. The inspector interviewed personnel responsible for testing the ERO augmentation process. The inspector compared qualification requirements to the training records for a sample of ERO members. The inspector also verified that the EP department staff were receiving required training as specified in the emergency plan.

Planning standard, 10 CFR 50.47(b)(2) and related requirements of 10 CFR 50, Appendix E were used as reference criteria.

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level (EAL) and Emergency Plan Changes

a. Inspection Scope

(One Sample)

Since the last NRC inspection of this program area, the latest Emergency Plan Revision was implemented based on Dominions determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. The inspector conducted a sampling review of the Emergency Plan changes, and all changes to EALs, to evaluate for potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes.

Therefore, these changes remain subject to future NRC inspection in their entirety.

b. Findings

No findings of significance were identified.

1EP5 Correction of Emergency Preparedness Weaknesses

a. Inspection Scope

(One Sample)

The inspector reviewed self-assessments and audit reports to assess the licensees ability to evaluate their performance and programs. The inspector reviewed CRs initiated from January 2006 to September 2007 from drills, self-assessments, and audits for 2006 and 2007 required by 50.54(t). Planning standard, 10 CFR 50.47(b)(14) and the related requirements of 10 CFR 50, Appendix E were used as reference criteria.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

Combined Functional Drill

a. Inspection Scope

(One Sample)

The inspectors observed the conduct of a Unit 2 licensed operator training emergency planning drill on August 29, 2007. The inspectors observed the operating crew performance at the simulator and the emergency response organization performance at the site emergency operations center. The inspectors evaluated the classification, notification and protective action recommendations for accuracy and timeliness.

Additionally, the inspectors assessed the ability of Dominions evaluators to adequately address operator performance deficiencies identified during the exercise. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety (OS)

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

(Nine samples)

During the period September 24-28, 2007, the inspectors conducted the following activities to evaluate the operability and accuracy of radiation monitoring instrumentation, and the adequacy of the respiratory protection program, relative to maintaining and issuing self-contained breathing apparatus (SCBA). Implementation of these programs was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Dominions procedures.

The inspectors reviewed the UFSAR to identify area radiation monitors that are installed in Millstone Units 2 and 3 for the protection of workers, and reviewed the calibration procedure and current calibration records for selected instrumentation, including the Unit 2 spent fuel area monitors (RM-8139/8142/8156/8157), the Unit 3 spent fuel pool area monitors (3RMS-RIY08/36) and the Unit 3 containment area monitors (RE-01/02/03). The inspector discussed with the Instrument and Control (I&C)supervisor the monitoring system health report and instrument reliability trends.

The inspector reviewed the operating procedure and current source activities/dose rate characterizations for the Shepherd Model 89 instrument calibrators (Serial Nos. 9155 &

9068). The inspector observed a technician perform safety interlock testing on the calibrator prior to using it.

The inspector reviewed the calibration records for selected survey instruments and contamination monitors including the small article contamination monitors (SAM 9 & 11),personnel contamination monitors (ARGOS-4A/B), electronic dosimeters (Seimens Mk2), and various portable survey instruments (FH40TC, RO-2A, RO-20).

The inspector reviewed the relevant procedures and observed a technician performing a calibration validation on electronic dosimeters and calibrate portable radiation survey instruments (RO-2A & RO-20).

The inspector observed a technician performing daily functional checks on a variety of contamination monitors and survey instruments located in Units 2 and 3 including SAC-4, SAM-11, ARGOS 4A/B, CM-11, RM-14, Ludlum 177, BC-4, and Teleprobes.

The inspector reviewed the procedure and quality control records associated with performing the instrument daily functional checks, including air sample counting equipment and gamma spectrometers.

The inspector reviewed recent contamination sampling (10 CFR 61 data) results for Units 2 and 3 to determine if the instrument calibration sources used were representative of the radioisotopes found in the plant source term.

The inspector evaluated the adequacy of the respiratory protection program regarding the maintenance and issuance of SCBA to emergency response personnel. Training and qualification records were reviewed for licensed operators from each of the five operating shifts at each unit and for selected response personnel who would wear SCBAs in the event of an emergency.

The inspector, with the assistance of Fire Protection technicians, physically inspected three SCBAs staged for use in each control room, two SCBAs staged for use in the Unit 3 turbine building, and two SCBAs staged in the Unit 2 Technical Services Area.

Maintenance and regulator test records were reviewed for selected SCBAs. The inspector also evaluated whether the air used to fill the SCBAs met the Grade D quality criteria of the Compressed Gas Association.

The inspectors evaluated the licensees program for assuring quality in the radiation monitoring instrumentation and respiratory protection programs by reviewing self-assessments (MP-SA-06-56/69/74/79), Nuclear Oversight audits (Nos.05-06, 06-04/08, 07-06), and 21 CRs related to these program areas. The inspector determined if problems were identified in a timely manner, that an extent of condition and cause evaluation were performed, previous radiation surveys remained valid, and corrective actions were appropriate to preclude repetitive problems.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

[OA]

4OA1 Performance Indicator (PI) Verification

.1 Cornerstone: Initiating Events

a. Inspection Scope

(Two Samples)

The inspectors reviewed Dominion submittals for the PIs listed below to verify the accuracy of the data reported during that period. The PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Revision 5, were used to verify the basis for reporting each data element.

The inspectors reviewed portions of the operations logs and monthly operating reports, and discussed the methods for compiling and reporting the PIs with cognizant licensing and engineering personnel. Documents reviewed during this inspection are listed in the

.

Unit 2 C Unplanned Power Changes per 7000 critical hours.

Unit 3

• Unplanned Power Changes per 7000 critical hours.

b. Findings

No findings of significance were identified.

.2 Emergency Planning Cornerstone (3 samples)

a. Inspection Scope

(Three Samples)

The inspector reviewed data for the EP PIs: Drill and Exercise Performance, ERO Drill Participation; and ANS Reliability. The inspector reviewed supporting documentation from drills and tests from April 2006 to June 2007 to evaluate the accuracy of the reported data. The acceptance criteria used for the review were NEI 99-02.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"

and in order to help identify repetitive equipment failures or specific human performance issues for followup, the inspectors performed a daily screening of items entered into Dominion's corrective action program. This was accomplished by reviewing the description of each new CR and attending daily management review committee meetings. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 Annual Sample: Safety Injection Tank (SIT) Leakage (One Sample)

a. Inspection Scope

The inspectors reviewed the actions taken by Dominion to evaluate and correct several instances of valve leakage that impacted SIT accumulator water levels and/or boron concentration over the past several years of operation. The inspectors reviewed CRs related to SIT accumulator leakage, the completed evaluations, and associated corrective actions to assess the performance history and effectiveness of Dominions actions. The inspectors conducted interviews with plant personnel. The inspectors also reviewed procedures, data and drawings.

b. Assessments and Observations No findings of significance were identified. The inspectors concluded that Dominion had adequately evaluated and corrected the various individual valve leakage issues.

However, the inspectors noted that engineers and operators were challenged by the multiple system/valve leaks over the last several years. In particular, operator actions were necessary to frequently fill the affected SIT accumulators or to depressurize an associated accumulator fill header (via a temporary modification). Engineers and operators also developed and executed troubleshooting plans to identify leaking components. Although the past problems have not resulted in rendering the SIT accumulator or related emergency cooling systems inoperable, continued leaks represent challenges to plant equipment and staff. Dominion management acknowledged the concerns related to the continuing challenges, and discussed some of their ongoing and planned efforts to broadly address and evaluate additional proactive measures to prevent further leakage problems, including an inter-discipline review of the potential leakage paths and scenarios.

4OA6 Meetings, Including Exit

On September 14, 2007, the EP inspector presented the inspection results to Mr. J. Alan Price, Site Vice President, and other members of his staff. The inspector confirmed that proprietary information was not provided or examined during the inspection.

On September 28, 2007, the radiation protection inspector presented the inspection results to Mr. J. Alan Price, Site Vice President, and other members of his staff. The inspector confirmed that no proprietary information was provided or examined during the inspection.

On October 10, 2007, the resident inspectors presented the overall inspection results to Mr. J. Alan Price, Site Vice President, and other members of his staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

A. Price Site Vice President

A. Jordan Director, Nuclear Station Operations and Maintenance

R. Griffin Director, Nuclear Station Safety & Licensing

D. Atwood Fire Protection Instructor

M. Brooks Senior Radiation Protection Technician

T. Cleary Licensing Engineer

K. Collins Fire Protection Technician

C. Dibiasi Chemist

S. Dubicki Fire Protection Technician

J. Firmam Radiation Protection Technician, Instrument Calibration Facility

T. Gilbert Emergency Preparedness

T. Gleason Radiation Protection Technician, Instrument Calibration Facility

W. Gorman Supervisor Instrumentation & Control

J. Hochdorfer Supervisor, Water Treatment

N. Hunter Senior Radiation Protection Technician

J. Kunze Supervisor Nuclear Operations Support

J. Laine Manager Radiation Protection/Chemistry

P. Luckey Manager, Emergency Preparedness

S. Mazzola Supervisor, Emergency Preparedness

E. Reiman Fire Protection Technician

S. Turowski Supervisor HP Technical Services

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000423/2007004-01 FIN Failure to Perform Fill and Vent of TPCCW Heat Exchanger (Section 1R19)