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#REDIRECT [[IR 05000245/2009005]]
{{Adams
| number = ML100341288
| issue date = 02/03/2010
| title = IR 05000336/2009005, 05000423/2009005; October 1, 2009 - December 31, 2009; Millstone Power Station Unit 2 and Unit 3; Operability Evaluations; Refueling and Other Outage Activities; Event Follow-up
| author name = Jackson D E
| author affiliation = NRC/RGN-I/DRP/PB5
| addressee name = Heacock D
| addressee affiliation = Dominion Resources, Inc
| docket = 05000336, 05000423
| license number = DPR-065, NPF-049
| contact person =
| case reference number = FOIA/PA-2011-0115
| document report number = IR-09-005
| document type = Inspection Report, Letter
| page count = 52
}}
 
{{IR-Nav| site = 05000336 | year = 2009 | report number = 005 }}
 
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY REGION 475 ALLENDALE KING OF PRUSSIA, PENNSYLVANIA February 3, 2010 Mr. David Heacock President and Chief Nuclear Officer Dominion Resources 5000 Dominion Boulevard Glen Allen, VA 23060-6711 MILLSTONE POWER STATION -NRC INTEGRATED INSPECTION REPORT 05000336/2009005 AND 05000423/2009005
 
==Dear Mr. Heacock:==
On December 31, 2009, the U.s. 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 January 13. 2010, with Mr. A. J. Jordan, and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's 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 NRC-identified finding and three self-revealing findings of very low safety significance (Green). Two of these findings were determined to involve violations of NRC requirements.
 
However, because of the very low safety significance and because they have been entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission.
 
ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrat'or, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at Millstone.
 
In addition.
 
if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report. with the basis for your disagreement, 10 the Regional Administrator.
 
Region I, and the NRC Senior Resident Inspector at Millstone.
 
The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
 
D. 2 In 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 be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,Mf. Donald E. Jacks ,Chief Projects Branch 5 Division of Reactor Projects Docket Nos. 50-336, 50-423 License Nos. DPR-65, NPF-49 Inspection Report 05000336/2009005 and 05000423/2009005
 
===w/Attachment:===
Supplemental Information cc Distribution via Listserv In 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 be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,IRA! Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Distribution w/encl: S. Collins, PA (R10RAMAll RESOURCE)
S. Shaffer. DRP, SRI M. Dapas, DRA (R10RAMAll RESOURCE)
B. Haagensen, RI D. Lew, DRP (R1DRPMAll RESOURCE)
J. Krafty. DRP. RI J. Clifford.
 
DRP (R1DRPMAll RESOURCE)
B. Haagensen, DRP. RI C. Kowalyshyn, OA D. Roberts, DRS (R1DRSMaii Resource)
L. Troclne, RI OEDO P. Wilson. DRS (R1DRSMaii RidsNRRPM Millstone D. Jackson, RidsNRRDor1Lp11-2 T. Setzer, DRP J. Heinly, DRP ROPreportsResource@nrc.gov B. Sienel, DRP SUNSI Review Complete:
__--=-TC;:..S=--
___ {Reviewer's Initials)
ML 100341288 DOCUMENT NAME: G:\DRP\BRANCH5\Reports\FinaI\Milistone IR2009005 Final .doc After declaring this document Official Agency Record" it will be released to the Public. To receive! a copy of this document, indicate in the box: "c" =Copy without a tt ac h men t}enc I osure "E" = C *th a tt ae h men V! "Nil =N o copy OPYWI ene osure OFFICE RI/DRP I RIIDRP I RIIDRP I I I NAME SShafferlTCS for TSetzerfTCSr DJackson/DEJ DATE 0202/10 02/02/10 02/03/10 OFFICIAL RECORD COPY
.,:1.", , ,.:. i' , Docket No.: License No.: Report No.: Licensee:
Facility:
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",', Dates: Inspectors:
Approved by: U.S. NUCLEAR REGULATORY COMMISSION REGION I 50-336,50-423 DPR-65, NPF-49 05000336/2009005 and 05000423/2009005 Dominion Nuclear Connecticut, Inc. Millstone Power Station, Units 2 and 3 P. O. Box 128 Waterford, CT 06385 October 1,2009 through December 31,2009 S. Shaffer, Senior Resident Inspector, Division of Reactor ProJects (ORP) J. Krafty, Resident Inspector, DRP B. Haagensen, Resident Inspector, DRP D. Silk, Senior Operations Engineer, Division of Reactor Safety (DRS) G. Johnson, Operations Engineer, DRS T. Moslak. Health Physicist, DRS M. Modes, Senior In-Service Inspection Inspector, DRS Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Enclosure 2
 
=SUMMARY OF FINDINGS=
IR 05000336/2009005, 05000423/2009005;
 
October 1,2009 -December 31,2009; Millstone Power Station Unit 2 and Unit 3; Operability Evaluations;
Refueling and Other Outage Activities;
Event Follow-up.
 
The report covered a period of inspection by resident and region-based inspectors.
 
Four Green findings, two of which were non-cited violations (NCV), were identified.
 
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process (SOP}." The cross-cutting aspect was determined using IMC 0305, "Operating Reactor Assessment Program." Findings for which the SOP 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, Green finding (FIN) was identified for Dominion's failure to take adequate precautions and adequately schedule maintenance on a Unit 2 operated disconnect (MOD) associated with the main transformer.
 
The maintenance on the MOD disrupted a switch connection and caused increaSing conductor temperatures, which forced Dominion to perform an unplanned shutdown of the Unit 2 reactor. Dominion has taken corrective action to modify the appropriate procedures and has entered this issue into their corrective action program (CR 351109). This finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations.
 
The inspectors performed a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined the finding was of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available.
 
Enforcement action did not apply because the performance deficiency did not involve a violation of a regulatory requirement.
 
Because this finding did not involve a violation of regulatory requirements, and has very low safety significance (Green), it has been identified as a finding (FIN). This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component.
 
because Dominion did not appropriately incorporate risk inSights and work scheduling of activities consistent with nuclear safety. [H.3(a)] (Section 1 R20) GreEm. A
: '''Green.'''
self-revealing non-cited violation (NCV) of Millstone Technical Specification (TS) 6.8.1(a}. "Procedures." was identified for Dominion's failure to adequately implement procedures during partial draining of the reactor coolant system (RCS) in preparation for defueling the reactor. Dominion did not properly align the reactor vessel vent path prior to partially draining the RCS as required by Dominion procedure OP w 2301E, "Draining the RCS (ICCE)." Immediate corrective actions included stopping the drain down and verifying the valve alignment.
 
Dominion entered this issue into the corrective action program (CR 351853). This finding was more than minor because it was associated with the Human Peliormance attribute of the Initiating Events cornerstone, and affected the cornerstone objective to limit the likelihood of those events that challenge critical safety functions during shutdown operations.
 
Specifically, the operators failed to properly position 447 to vent to the reactor vessel during partial drain down of the reactor vessel. The inspectors determined the significance of this finding using NRC Inspection Manual Chapter 0609, Appendix "G," *Shutdown Operations Significant Determination Process." This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion failed to define and effectively communicate expectations regarding procedural compliance, and personnel follow procedures.
 
[H.4(b)] (Section 1R20)
 
===Cornerstone: Mitigating===
 
Systems
: '''Green.'''
A Green, self-revealing finding (FIN) was identified for Dominion's failure to complete effective corrective actions for known degraded conditions associated with the VR-11 and VR-21 120-volt AC instrument power supplies.
 
This condition led to a loss of annunciators and declaration of a Notification of Unusual Event (NOUE) on November 15, 2009. Dominion took immediate action to expedite the installation of an uninterruptible power supply (UPS) for VR-11 and VR-21. This finding was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring capability of systems that respond to initiating events to prevent undesirable consequences.
 
The finding was determined to be of very low safety significance (Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. No violation of regulatory requirements occurred, because the annunciator system is safety related. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety Significance and complexity.
 
[P.1(d)] (Section 40A3)
 
===Cornerstone: Barrier Integrity ===
: '''Green.'''
The inspectors identified a Green, nonwcited violation (NCV) of Millstone Power Station Technical Specification (TS) surveillance requirement 4.3.3.8 for Dominion's failure to perform a channel calibration of the Unit 2 Inadequate Core Cooling Monitoring System (ICCMS) every 18 months. Dominion entered the issue into their corrective action program and concluded that the ICCMS was operable.
 
Dominion performed a risk assessment of the missed surveillance in accordance with TS 4.0.3, and determined that the completion of the surveillance could be delayed up to the 18 month surveillance interval without a significant increase in risk. This finding was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone.
 
and affected the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding)protect the public from radionuclide releases caused by accidents or events. Specifically, in 1997, Dominion incorrectly revised surveillance procedure SP 2407 A so that It no longer met the requirements of TS surveillance requirement 4.3.3.8. The inspectors determined the finding was of very low safety significance (Green) because it was associated with a fuel barrier of the Barrier Integrity cornerstone.
 
This finding did not have a cross-cutting aspect because the performance deficiency occurred in 1997, and was not indicative of current performance. (Section 1 R15)
 
=REPORT DETAILS=
Summary of Plant Status Millstone Power Station Units 2 and 3 began the inspection period operating at 100 percent power. On October 6,2009, Unit 2 was shutdown to begin refueling outage 2R19. Unit 2 -returned to 100 percent power on November 18,2009, and remained at or near 100 percent power for the remainder of the inspection period. On December 19, 2009, the Unit 3 reactor tripped due to a damaged main generator output breaker, and remained shutdown to repair the breaker thrQugh the remainder of the inspection period,
 
==REACTOR SAFETY==
Cornerstones:
Initiating Events, Mitigating Systems, and Barrier Integrity 1 R01 Adverse Weather Protection (71111.01 -1 sample) Seasonal Site Inspection
 
====a. Inspection Scope====
The inspectors reviewed the readiness of Unit 2 and Unit 3 for seasonal cold weather. The inspectors reviewed selected equipment, instrumentation, and supporting structures to determine if they were configured in accordance with Dominion's 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 Condensate Storage and Surge Tanks, and Refueling and Primary Water Storage Tanks. The inspectors also performed partial walkdowns of the Unit 3 Condensate Storage and Surge Tanks, Intake Structure ventilation, Main Steam Isolation Valve Building.
 
and heat tracing for safety related systems. The walkdowns were performed to verify completion of cold weather preparations.
 
Documents reviewed during the inspection are listed in the Attachment.
 
No findings of significance were identified.
 
1 R04 Eguipment Alignment (71111.04 5 samples) Partial System Walkdowns
 
====a. Inspection Scope====
The inspectors performed five partial system walkdowns during this inspection period. The inspectors reviewed the documents listed in the Attachment to determine the correct system alignment.
 
The inspectors performed a walkdown of each system to determine if the critical portions of the selected systems were correctly aligned in accordance with the 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 fonowing systems were reviewed based on their risk significance for the given plant configuration: Spent fuel pool cooling system on October 15, 2009; Unit 3 "An Service Water (SW) System while the "B" train was out of service (OOS) for planned maintenance on October 14, 2009; "B" Motor Driven Auxiliary Feedwater (MDAFW) Pump and the Turbine Driven Auxiliary Feedwater (TDAFW) Pump while the "A" MDAFW Pump was OOS for surveillance testing on November 9, 2009; "An Charging while the "6" train was OOS for surveillance testing on November 18, 2009; and "A" Emergency Diesel Generator (EDG) while the "6" EDG was OOS for planned maintenance on December 16,2009.
 
====b. Findings====
No findings of significance were identified.
 
1 ROS Fire Protection (71111.050 8 samples) a. l.n.§Qection Scope The inspectors performed walkdowns of eight fire protection areas. 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
 
===.1 evaluated===
 
the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures.
 
The inspectors 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:
* Containment Building Elevation
-3', Zone C-1;
* Containment Building Elevation
-22'-6", Zone C-1;
* Containment Building Elevation 14'-6", ZOl1e C-1;
* Containment Building Elevation 38'-6", Zone C-1;
* North Containment Recirculation Cooler Cubicle, Fire Area ESF-2;
* North Residual Heat Removal Heat Exchanger Cubicle, Fire Area ESF-3;
* East Floor Area, Fire Area ESF-4; and * "An EDG Enclosure, Fire Area EG-3, Zone A.
 
====b. Findings====
No findings of significance were identified.
 
1 R06 Flood Protection Measures (71111.06 -2 sa mples) Underground Power gable
 
====a. Inspection Scope====
The inspectors inspected underground cable vault 3EMH*1, which contained, in part, the 4160 volt (V) cables for the "An & "c" SW pumps. The inspectors evaluated Dominion's protection of safety-related systems from subsurface vault conditions.
 
The inspectors performed a walkdown of the area, Interviewed the system engineer, and reviewed the insulation ratings of the 4160V cables. Documents reviewed during the inspection are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified.
 
===.2 Internal Flooding===
 
====a. Inspection Scope====
The inspectors reviewed the flood protection measures for the equipment in the Unit 2 direct current Switchgear and Battery Rooms. The inspectors evaluated Dominion's protection of safety-related systems from internal flooding conditions.
 
The inspectors performed a walkdown of the area, interviewed the system engineers, reviewed the internal flooding evaluation, and verified that the floor drain configuration remained consistent with those Indicated in the design basis and flooding documents.
 
Oocuments reviewed during the Inspection are listed in the Attachment.
 
====b. Findings====
No findings of significance were Identirred.
 
1 R08 Inservice Inspection (lSI) (71111.08 -1 sample)
 
====a. Inspection Scope====
The purpose of this inspection was to assess the effectiveness of the licensee's inservice inspection program for monitoring degradation of the reactor coolant system boundary and risk significant piping system boundaries.
 
The inspector assessed the inservice inspection activities using the criteria specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI. One repair activity was reviewed.
 
consisting of the reactor coolant pump seal weld. to ensure that the welding activities and applicable non-destructive examination (NDE) was performed in accordance with ASME Code requirements.
 
the inspector reviewed for adequacy the root cause analysis for the pressure boundary leak related to the repair. The inspector reviewed the results of the automated visual test (VT) examinations of a sample of reactor vessel head penetrations.
 
The inspector reviewed licensee criteria for confirming visual examination quality and Instructions for resolving interference or masking issues to confirm they are consistent with 10 CFR 50.55a(g)(6)(ii)(0).
 
The inspector reviewed the records recording the extent of inspection for each penetration nozzle including documents which resolved interference or masking issues to confirm that the extent of examination meets 10 CFR 50.55a(g)(6}(ii)(0).
 
The inspector reviewed coverage achieved with no limitations in coverage recorded.
 
The inspector verified that the activities were performed In accordance with the requirements of 10 CFR 50.55a(g}(6)(ii)(D), and indications and defects, if detected, were dlspositioned in accordance with 10 CFR 50.55a(g)(6)(ii)(0).
 
The results of a number of ultrasonic examinations were reviewed.
 
The phased array examination of a diSSimilar metal weld was reviewed.
 
Although the steam generators were not examined by eddy current during this outage, the inspector reviewed the engineering justification for deferring the inspection, and compared the justification with Enclosure
 
===.1 the results of the last eddy current inspection===
 
of the steam generators.
 
The inspector verified that the basis for deferral met the NRC accepted Electric Power Research Institute (EPRI) Steam Generator management guideline recommendations.
 
inspector reviewed the dissimilar weld metal program using the guidance in NRC inspection procedure 71111.08P, and Temporary Instruction
("1"1) 172. The inspector determined what deviations from EPRI's Materials Reliability Program (MRP) 139 guidelines were planned, and the basis for the deviation.
 
The inspector reviewed the results of volumetric examinations utilizing the guidance in MRP-139 for volumetric examinations being performed during the outage. The inspector reviewed the phased array results of a number of welds to verify conformance with MRP-139, Sec. 5.1. The inspector verified conformance with the relief request for a weld overlay. The inspector verified that personnel performing the examination were qualified, and deficiencies were being appropriately dispositioned.
 
====b. Findings====
No findings of significance were identified.
 
1 R11 LicEmsed Operator Regualification Program (71111.11 -3 samples) Resident Inspector Quarterly Review (71111.11 Q -2 samples)
 
====a. Inspection Scope====
The inspectors observed simulator-based licensed operator requalification training for Unit 2 on December 4,2009, and for Unit 3 on November 19, 2009. 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 procedure OP-MP* 100-1000, "Millstone Operations Guidance and Reference Document." The inspectors compared simulator configurations with actual control board configurations.
 
The inspectors also observed Dominion evaluators discuss identified weaknesses with the crew and individual crew members, as appropriate.
 
Documents reviewed during the inspection are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified.
 
===.2 Biennial Licensed Operator Regualification===
 
(71111.11 B-1 sample)
 
====a. Inspection Scope====
The following inspection activities were performed using NRC NUREG 1021, Revision 9, "Operator Licensing Examination Standards for Power Reactors," NRC inspection procedure 71111.11, "Licensed Operator Requalification Program," and 10 CFR 55. A review was performed of recent operating history documentation found in the inspection reports, Dominion's corrective action program, and the most recent NRC plant issues matrix (PIM) .. The inspectors also reviewed specific events from Dominion's corrective action program which indicated possible training deficiencies to verify that they had been appropriately addressed.
 
The three written examinations from 2008 and selected operating tests from the 2009 annual examination were reviewed for content, quality, and excessive overlap to ensure that these exams met the criteria established in the Examination Standards and 10 CFR 55.59. On October 9,2009, the results of the annual operating tests for 2009 were reviewed to determine if pass/fail rates were consistent with the guidance of NUREG-1 021, Revision 9, *Operator Licensing Examination Standards for Power Reactors," and NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process (SDP)." The review verified the following: Crew pass rates were greater than 80%. (Pass rate was 100%); Individual pass rates on the dynamic simulator test were greater than 80%, (Pass rate was 1 00%); Individual pass rates on the job performance measures of the operating examination were greater than 80%, (Pass rate was 96.5%); Individual pass rates on the written examination (2008) were greater than 80%, (Pass rate was 95.9%); More than 75% of the individuals passed all portions of the 2009 operating examination, (Pass rate was 96.5%); Crew pass rates were greater than 80%, (Pass rate was 100%); Individual pass rates on the dynamic simulator test were greater than 80%, (Pass rate was 1 00%); Individual pass rates on the job performance measures of the operating examination were greater than 80%, (Pass rate was 95.0%); Enclosure Individual pass rates on the written examination (2008) were greater than 80°10, (Pass rate was 95.4%); and More than 75% of the individuals passed all portions of the 2009 operating examination, (Pass rate was 95.0%). Observations were made of the Unit 3 dynamic simulator examinations and job performance measures (JPM) administered during the week of August 31,2009 for Operations Crew E and Administrative Crew E. These observations included facility evaluations of crew and individual performance during the dynamic simulator examinations and individual performance of JPMs. The: remediation plans for several Unit 2 and Unit 3 failures were reviewed to assess the effectiveness of the remedial training.
 
Eight Unit 3 Dominion reactivations were reviewed to ensure that Dominion conditions and applicable program requirements were mel. Five reactor operator records were checked to verify the maintenance of an active license. Simulator performance and fidelity were reviewed for conformance to the reference plant control room. Selected simulator deficiency reports were reviewed to assess Dominion prioritization and timeliness of resolution.
 
Simulator testing records were reviewed to verify that scheduled tests were performed.
 
A sample of records for requ8lification training attendance, program feedback, reporting, and six operator medical reports were reviewed for compliance with Dominion conditions, including NRC regulations.
 
Two reactor operators were interviewed to assess the operator's perspectives regarding training quality, incorporation of feedback, simulator performance, and examination difficulty.
 
====b. Findings====
No findings of significance were identified.
{{a|1R12}}
==1R12 Maintenance==
 
Effectiveness (71111.12Q.1 sample)
 
====a. Inspection Scope====
The inspectors reviewed Dominion's evaluation of degraded conditions, involving related structures, systems and components for maintenance effectiveness during this inspection period for the Unit 2 Enclosure Building Filtration System (EBFS). The inspectors reviewed Dominion's implementation of the "Maintenance Rule," 10 CFR 50.65. The inspectors reviewed Dominion's 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 paragraph (a)(1) or (a}{2), and the adequacy of the performance criteria and goals established for each system, as appropriate.
 
The inspectors also reviewed recent Enclosure system health reports, condition reports (CR), apparent cause determinations, functional failure determinations, operating logs, and discussed system performance with the responsible system engineer.
 
Documents reviewed during the inspection are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified.
 
'I R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 -4 samples)
 
====a. Inspection Scope====
inspectors evaluated online risk management for emergent and planned activities.
 
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 OOS 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 Dominion's risk management actions during plant walkdowns.
 
Documents reviewed during the inspection are listed in the Attachment.
 
The inspectors reviewed the conduct and adequacy of risk assessments for the following maintenance and testing activities: Shutdown risk assessment (Orange) during RCS drain down into reduced inventory operations for defueling on October 10, 2009; Shutdown risk assessment (Orange) during north bus outage on October 16, 2009; Shutdown risk assessment (Orange) during RCS drain down into reduced inventory operations and SI-306 valve repairs on October 26, 2009; and On-line risk assessment (Green) during maintenance on the "B" EDG and "B" Safety Injection pump on December 17,2009.
 
====b. Findings====
No findings significance were identified.
 
1 R15 Operability Evaluations (71111.15
-7 samples)
 
====a. Inspection Scope====
The inspectors reviewed seven operability determinations
{OD. The inspectors evaluated the ODs 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, system engineers, and design engineers.
 
Documents reviewed during the inspection are listed in the Attachment.
 
The inspectors reviewed seven operability determinations (00). The inspectors evaluated the ODs 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, system engineers, and design engineers.
 
Documents reviewed during the inspection are listed in the Attachment.
 
The inspectors reviewed the adequacy of the following evaluations of degraded or non-conforming conditions: Operational decision making (ODM) for CR 350860, "Generator Hydrogen Seal Failed Megger Test;" CR354434 dispositioning of a 5/8 inch bolt found in the reactor vessel; Condition Report Engineering Disposition (CRED) for CRs 355509 and 355455 for unrecoverable debris in fuel assemblies Y12. Y15, and Y35; ODM for CR352045. "B" Reactor Coolant Pump (RCP) electrical penetration M2SWX-A2-T1 failed locallaak rate test (LLRT) administrative limit; Engineering information record Document No. 51-9126147-00 which evaluates the effects of the thimble tubes being cut 1 inches shorter than designed; Channel "S" Wide Range Logarithmic Nuclear Instrument OOS for reactor startup; and CR359570 seven core exit thermocouples reading outside tolerance.
 
====b. Findings====
 
=====Introduction:=====
The inspectors identified a Green, non-cited violation (NCV) of Millstone Power Station Technical Specification (TS) surveillance requirement 4.3.3.8 for Dorninion's failure to perform a channel calibration of the Unit 2 Inadequate Core Cooling Monitoring System (ICCMS) every 18 months.
 
=====Description:=====
On November 15, 2009. condition report (CR) 358117 was submitted as a result of one of the retests for the incore thimble replacement modification.
 
The CR Enclosure identified that seven of the core exit thermocouples (CET) indicated 12 degrees higher than cold leg temperature (Tcold) while at hot zero power. These seven CETs also indicated 12 degrees higher than Tcold prior to the modification.
 
The inspectors reviewed the most recent surveillance performed and TS; interviewed the system engineer; and questioned whether the channel calibration required by the TS had been performed.
 
After review, Dominion concluded that the required channel calibration for the ICCMS, which includes the CETs, reactor vessel coolant level indication, and reactor coolant system subcooled/superheat monitor, had not been adequately performed since 1997. The apparent cause evaluation determined that surveillance procedure SP 2407 A was revised in 1997 to support new equipment that was installed under modification DCR M2**96-077, "Replacement Inadequate Core Cooling Monitoring System (ICCMS)." The surveillance was approved in accordance with existing Millstone procedures.
 
The new ICeMS system has input cards and an analog to digital (AID) card that must be adjusted separately.
 
The personnel involved with the procedure revision incorrectly assumed that adjusting the Digital and Analog Loopback and Calibration card, which adjusts the AID card, was all that was required for the calibration.
 
Dominion concluded that the seven individual CETs were inoperable, but the overall CET system remained operable since the number of remaining operable CETs per quadrant was greater than the TS required minimum. Dominion also concluded that the realr;tor vessel coolant level indication and reactor coolant system subcooled/superheat monitor were operable.
 
Dominion entered the issue into their corrective action program (CR 359247), and performed a risk assessment of the missed surveillance in accordance with TS 4.0.3, which determined that completion of the surveillance could be delayed up to the 18 month surveillance interval without a significant increase in risk. The! inspectors reviewed the risk assessment and verified that there was no unacceptable increase in risk.
 
=====Analysis:=====
The inspectors determined that Dominion's failure to provide an adequate calibration procedure for the ICCMS was a performance deficiency.
 
The cause was reasonably within Dominion's ability to foresee and correct, and should have been prevented.
 
Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.
 
A review of NRC Inspection Manual Chapter 0612, Appendix E, "Minor Examples," revealed that no minor examples applied to this finding. This finding was more than minor because it was associated wi,th the Procedure Quality attribute of the Barrier Integrity cornerstone, and affected the cornerstone's objective of providing reasonable assurance that physical design barriers (fuel cladding)protect the public from radionuclide releases caused by accidents or events. Specifically, in 1997, Dominion incorrectly revised surveillance procedure SP 2407 A, which caused them to no longer meHt the requirements of TS surveillance requirement 4.3.3.8 to perform a channel calibration of the Unit 2 ICCMS every 18 months. Enclosure 16 Thl3 inspectors performed a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined the finding was of very low safety significance (Green) because it was associated with a fuel barrier of the Barrier Integrity cornerstone.
 
This finding did not have a cross*cutting aspect because the performance deficiency occurred in 1997, and was not indicative of current performance.
 
=====Enforcement:=====
Millstone Power Station TS surveillance requirement 4.3.3.8 requires that a channel calibration of the ICCMS be performed every 18 months. Contrary to the above, from 1997 until December 2009, Dominion did not perform an adequate channel calibration of the ICCMS. Following discovery of the inadequate channel calibration, Dominion performed an overall assessment, including a risk assessment that concluded there was not a significant increase in risk by delaying completion of the surveillance until the procedure could be performed during the next refueling outage. Because this violation is of very low safety significance (Green). and has been entered into Dominion's corrective action program (CR 359247), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 0500033612009005-01, TS Surveillance Channel Calibration of ICCMS Not Performed)1 R18 Plant Modifications (71111.18 -2 samples)
 
====a. Inspection Scope====
To assess the adequacy of the modifications, the inspectors performed walkdowns of selected plant systems and components, Interviewed plant staff, and reviewed applicable documents, including procedures, calculations, modification packages, engineering evaluations, drawings, corrective action program documents, the UFSAR, and TS. Design assumptions were reviewed to verify that they were technically appropriate and consistent with the UFSAR. For each modification, the 10 CFR 50.59 sCrE3enings or safety evaluations were reviewed.
 
The inspectors also verified that procedures, calculations, and the UFSAR were properly updated 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 components would function properly.
 
Documents reviewed during the inspection are listed in the Attachment. Temporary modification to open 2-RW-27 in Mode 1 allowing for purification of the Refueling Water Storage Tank (RWST) via the spent fuel pool purification system; ;and Permanent modification to install variable frequency drive units on the circulating water pumps.
 
====b. Findings====
No findings of significance were identified.
 
R19 Post-Maintenance Testing (71111.19 -8 samples)
 
====a. Inspection Scope====
The inspectors reviewed post-maintenance test (PMT) activities to determine whether the PMT adequately demonstrated that the safetYwrelated 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 PMTs were evaluated: Automated Work Order (AWO) 53102300705 following Letdown Regenerative Heat Exchanger Outlet Temperature Loop (TI-221) testing and repair on November 11, 2009; AWO 53102302188 following Pressurizer Proportional Heater Controller testing and* repair on November 12, 2009; AWO 53102221324 following RCP vibration monitoring system testing and repair on November 16, 2009; AWO 53102258097 following 2-SW-97A "B" circulating water pump cross-tie valve testing and repair on November 22, 2009; AWO 53M20808798 following the "B" heater drain pump testing and repair on iDecember 2, 2009; SP 3646A.1, "EDG "A" Operability Test," Revision 18 following maintenance on the jacket water and electrical systems on December 1,2009; SPROC lave ReductionNalve Wide Open Test (ICCE)," Revision 000-01 as a result of the stretch power uprate on December 2, 2009; and SP 3630A.6-002. "Reactor Plant Component Cooling Water Pump 3CCP*P1 C Group "An Test," Revision 012 following pump bearing replacement on December 16,2009.
 
====b. Findings====
No findings of significance were identified.
 
1 R20 Refueling and Other Outage Activitie§ (71111.20 -1 sample) Millstone Unit 2 Refueling Outage (2R19)
 
====a. Inspection Scope====
Dominion began refueling outage 2R19 on October 6, 2009, and completed the outage on November 18, 2009. The inspectors evaluated the outage plan and outage activities to determine if Dominion had considered risk, developed risk reduction and plant configuration control methods, considered mitigation strategies in the event of loss of safety functions, and adhered to licensee and TS requirements.
 
The inspectors observed portions of the shutdown.
 
cooldown.
 
heat up and start up processes.
 
Additionally.
 
the inspectors performed an initial containment Mode 3 walk down to eVl:lluate the as-found condition of containment.
 
The inspectors also performed a final Mode 3 walk down to ensure that no loose material or debris, which could be transported to the containment sump, were present. The inspectors reviewed eRs to determine if conditions adverse to quality were entered for resolution.
 
Documents reviewed for the inspection are listed in the Attachment.
 
Some of the specific activities the inspectors observed and performed included:
* Reactor shutdown and cool down;
* Reactor water level drain down to the reactor flange;
* Midloop and reduced inventory operations;
* Reactor head lift;
* Fuel handling, core loading, and fuel element assembly tracking;
* Containment as-found walk down:
* Review of outage risk plan;
* Orange Risk -Replacement of main transformer insulators;
* Alloy 600 weld overlay project;
* Service Water piping inspections;
* Circulating Water pump "A" replacement;
* In-core instrument thimble replacement;
* RCS vacuum fill;
* Containment Integrated Leak Rate Test;
* Containment as-left walk down;
* Reactor Heat up;
* Reactor Start up;
* low Power Physics Testing;
* Reactor power ascension; and
* Unit 2 Generator synchronization to the grid. Enclosure
 
===.1
 
====b. Findings====
Implementation===
 
of Design Change Results in an Unplanned Shutdown of Reactor
 
=====Introduction:=====
A self-revealing.
 
Green finding (FIN) was identified for Dominion's failure to take adequate precautions and adequately schedule maintenance on a Unit 2 operated disconnect (MOD) associated with the main transformer.
 
The maintenance on the MOD disrupted a switch connection and caused increasing conductor temperatures.
 
which forced Dominion to perform an unplanned shutdown of the Unit 2 reactor.
 
=====Description:=====
On October 6,2009, with Unit 2.at 100 percent power, Dominion maintenance personnel began implementing design change notice (DCN)09 to install a rain guard intended to prevent water intrusion into the motor of the MOD for 15G-2X 1-4. While decoupling the vertical drive shaft of the MOD, a shift in the disconnect switch occurred.
 
This resulted In arcing on the disconnect switch and increasing surface temperatures.
 
Continued operation in this condition could have resulted in failure of the switch which in turn would have caused a reactor trip. Due to this condition, an unplanned shutdown of Unit 2 was performed.
 
MOlDs constructed of this design are known to occasionally have tension remaining post closure of the switch. and decoupling of the shaft can result in shifting of the switch. This is what occurred on October 6, 2009 when Dominion attempted to perform maintenance on the MOD. The Dominion root cause evaluation (RCE) determined the root cause to be a programmatic failure to identify and manage risk related to 345 kilovolt (kV) work. A significant contributing factor was an inadequate process for identification and management of risk during the design change process (implementation of the DCN). The RCE states in part. "CM-AA-RSK-1 001, Engineering Risk Assessment, has inconsistent guidance for evaluating potential for engineering error. In addition.
 
guidance is entirely subjective for evaluation of potential consequence of engineering failure." The weakness of procedure CM-AA-RSK-1001 resulted in the DCN not receiving the additional reviews that elevated risk switchyard work would normally get. The additional reviews would have added additional precautions, potential scope of work changes, and postponement of the work for a few days at which point Unit 2 would have been offline for a planned refueling outage.
 
=====Analysis:=====
The inspectors determined that Dominion's failure to adequately manage the risk to plant stability associated with the installation of the DCN was a performance deficiency.
 
The cause was reasonably within Dominion's ability to foresee and correct. and should have been prevented.
 
Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence.
 
had no willful aspects, nor did it impclct the NRC's ability to perform its regulatory function.
 
===.2 A review of NRC Inspection===
 
Manual Chapter 0612, Appendix E, "Minor Examples," revealed that no minor examples applied to this finding. This finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations.
 
Specifically, Dominion did not adequately assess and manage the risk involved in implementing DCN DM2-00-093-09, which resulted in the need to perform an unplanned shutdown of the Unit 2 reactor on October 6,2009. The inspectors performed a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined the finding was of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available.
 
This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Dominion did not appropriately incorporate risk insights and work scheduling of activities consistent with nuclear safety. [H.3(a)J
 
=====Enforcement:=====
No violation of regulatory requirements occurred, because the MOD switch and the main transformer are non-safety related. Dominion has taken corrective action to modify the appropriate procedures, and has entered this issue into their corrective action program(CR 351109). Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory Because this finding does not involve a violation of regulatory requirements, and has very low safety significance (Green), it is identified as a finding (FIN). (FIN 05000336/2009005-02 Implementation of Design Change Results in an Unplanned Shutdown of Reactor) RCS Drain Down Loss of Configuration Control
 
=====Introduction:=====
A Green, self-revealing NCVof Millstone Technical Specification (TS) . 6.8.1 (a),
was identified for Dominion's failure to adequately implement procedures during partial draining of the reactor coolant system (RCS) in preparation for defueling the reactor. Dominion did not properly align the reactor vessel vent path prior to partially draining the RCS as required by Dominion procedure OP-2301 E, "Draining the RCS (ICCE)."
 
=====Description:=====
On October 1 0, 2009, Dominion performed a partial drain*down of the fueh3d reactor vessel to the radioactive waste processing system in preparation for removing the reactor vessel head and defueling the reactor. The reactor vessel vent path was not properly established because manual valve 2-RC-447 had been mispositioned (locked shut instead of locked open) during the valve line-up for the evolution.
 
Without an open vent path in the reactor vessel, the vessel inventory was not reduced when the ReS was being drained. When the RCS mid-loop wide range level instruments (LT-112 and lI-112) came on scale at +99 inches, the reactor vessel level monitoring system (RVLM) still indicated that the reactor vessel level was greater than +135 inches. The operators stopped the RCS drain down evolution and determined that Enclosure 
 
vent path had not been properly aligned to the reactor vessel in accordance with Dominion procedure OP-2301E-005, "Preferred RCS Vent Path Alignment." Upon investigation, Dominion discovered that they did not align valve 2-RC-447 to vent the reactor vessel head during the RCS drain down in preparation for defueling the reactor. This resulted in the reactor vessel remaining full of water while the pressurizer and steam generator tubes were being drained. Operators failed to immediately realize that RCS level indication did not accurately reflect the level in the reactor vessel. This condition constituted a loss of positive control during the RCS drain down.
 
=====Analysis:=====
The inspectors determined that Dominion's failure to properly align a vent path to the reactor vessel in accordance with Dominion procedure OP-2301 E-005, "Preferred RCS Vent Path Alignment," was a performance deficiency.
 
The cause was reasonably within Dominion's ability to foresee and correct, and should have been prevented.
 
Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.
 
A review of NRC Inspection Manual Chapter 0612, Appendix E, "Minor Examples,*
revealed that no minor examples applied to this finding. The finding was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective to limit the likelihood of those events that challenge critical safety functions during shutdown operations.
 
Specifically, the operators failed to properly position 2-RC-447 to vent to the reactor vessel during partial drain down of the reactor. The inspectors determined the significance of this finding using NRC Inspection Manual Chapter 0609, Appendix "G," "Shutdown Operations Significant Determination Process." The issue was determined to be of very low safety significance (Green) because the OpE:lrators performed continuous RCS inventory balances during the drain down, and toolk prompt appropriate corrective action as soon as a level deviation became apparent between the RCS level instruments (LT-112 and U-112) and the in-core RVLMs heated core thermocouples.
 
Immediate corrective actions included stopping the drain down and verifying the valve alignment.
 
This finding had a crossoocutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion failed to define and effectively communicate expectations regarding procedural compliance, and personnel follow procedures.
 
[H.4(b)] ,
 
=====Enforcement:=====
Millstone TS 6.8.1 (a) "Procedures,*
requires, in part, that written procedures be established, implemented and maintained covering the activities described in Appendix "A" of NRC Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)." Section 2.k requires general plant operating procedures for, "Preparation for Refueling and Refueling Equipment Operation." Draining the RCS in preparation for defueling the reactor was required to be accomplished using Section 4.2 of Dominion procedure OP-2301 E, "Draining the RCS (ICCE)." Contrary to the above, Dominion did not correctly implement procedure OP-230'1 E-005 to establish the Enclosure 22 correct valve line-up for draining the ReS. This resulted in a loss of positive control over ReS level during a risk significant evolution.
 
Because this violation is of very low safety significance (Green), and has been entered into Dominion's corrective action program (CR 351853), it is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000336/2009005-03 ReS Drain Down Loss of Configuration Control) 1 R22 Surveillance Testing (71111.22 -2 samples)
 
====a. Inspection Scope====
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 briefings, 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 als() 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: SP-2613G Routine Surveillance Integrated Test of Facility 1 Components (ICCE) Loss of Normal Power; and VPROC ENG09-2-011 Integrated Leak Rate Test of Containment.
 
====b. Findings====
No findings of significance were identified.
 
===2. RADIATION ===
 
SAFETY Cornerstone:
Occupational Radiation Safety 20S1 Access Control to Radiologically Significant Areas (71121.01
-11 samples)
 
====a. Inspection Scope====
During the period November 2, 2009 and November 5, 2009, the inspectors performed the Following activities to verify that Dominion was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas (LHRA) and other radiological controlled areas (RCA), and that workers were adhering to these controls when working in these areas during the Unit 2 refueling outage (2R19). Enclosure Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, Unit 2 TS, and Dominion's procedures.
 
This inspection activity represents completion of eleven samples relative to this inspection area. Plant Walkdown and Radiation Work Permit (RWP) Reviews During the Unit 2 refueling outage, the inspectors identified exposure significant work areas in the Unit 2 reactor building containment, fuel handling building, and auxiliary building.
 
The inspectors reviewed radiation survey maps and RWPs associated with these areas to determine if the radiological controls were acceptable; The inspectors performed independent surveys of selected areas in the Unit 2 containment building and auxiliary building to confirm the accuracy of survey maps, the adequacy of postlngs, and that technical specification locked high radiation areas (TSLHRA) were properly secured and posted. Areas in containment surveyed included:
the SG cubicles, radwaste storage areas, pressurizer relief tank, access port to under vessel area, and RCP areas; In evaluating RWPs, the inspectors reviewed electronic dose/dose rate alarm set points to determine if the set points were consistent with survey indications and plant policy. The inspectors verified that workers were knowledgeable of the actions to be taken when a dosimeter alarms or malfunctions for tasks being performed under selected RWPs. Work activities reviewed included scaffolding removal. insulation installation, and upper guide structure transfer; and The inspectors reviewed Personnel Contamination Reports (PCR), airbome sampling results, personnel dosimetry data, and whole body counting results to assess the effectiveness of airborne monitoring and contamination controls.
 
The inspectors also reviewed the associated dose assessment for a worker who fell into the spent fuel pool during pre-outage preparations.
 
The inspectors determined that no intake of radioactive material resulted in an internal dose exceeding 10 mrem. Jobs-in-Progress Review The inspectors observed the preparations and various work stages for several tasks including containment demobilization and transfer of the reactor upper guide structure into the reactor vessel, fuel assembly transfers, and in service inspections.
 
The inspectors observed various aspects of these activities from the centralized monitoring system (CMS) to determine if remotely monitored work area dose rates and worker dose, and the coordination of activities by the CMS staff, were adequately communicated to the workers. High Risk Significant.
 
High Dose Rate Controls The inspectors reviewed the preparations made for various potentiaJly high dose rate jobs and the resulting dose assessments to determine if exposure monitoring was effective in controlling personnel exposure.
 
Tasks reviewed included the transfer of the upper guide structure back into the reactor vessel, alloy 600 inspections/
mitigation, and the thimble tube replacement; 24 The inspectors inventoried keys to TSLHRA stored at the Unit 2 Control Point to verify that Dominion accounted for all keys. During tours of Unit 2, the inspectors verified that locked high radiation areas (LHRA) were properly secured and posted; and The inspectors verified that Unit 2 LHRAs in containment, such as the regenerative heat exchanger and under vessel area, were properly secured and posted and that surrounding area dose rates and postings met regulatory criteria.
 
Radiation Worker and Radiation Protection Technician Performance Several radiologically related CRs and PCRs were reviewed to evaluate if the incidents resulted from repetitive worker errors and to determine if an observable pattern traced to a similar cause was evident; During site tours, radiation protection technicians and radworkers were questioned regarding their knowledge of plant radiological conditions and controls associated with their jobs. Additionally.
 
the inspectors observed radiation protection technicians effectively control and coordinate in-containment tasks by using the centralized remote monitoring system; and The inspectors reviewed field observation reports made by the Nuclear Oversight staff to determine the degree in which the independent department was actively engaged in critically monitoring worker performance during 2R19.
 
====b. Findings====
No findings of significance were Identified.
 
20S2 ALARA Planning and Controls (71121.02
-7 samples) a. Inspection SCQDe During the period November 2,2009 through November 5,2009, the inspectors performed the following activities to verify that Dominion was properly implementing opElrational, engineering, and administrative controls to maintain personnel exposure as low as reasonably achievable (ALARA) for tasks performed during the Unit 2 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Dominion's procedures.
 
This inspection activity represents completion of seven samples relative to this inspection area. Radiological Work Planning The inspectors reviewed pertinent information regarding Unit 2 outage exposure history. current exposure trends, and ongoing activities to assess current performance and outage exposure challenges.
 
The inspectors determined the site's three-year rolling collective average exposure and compared it to current trends; The inspectors reviewed the refueling outage work scheduled during the outage period and the associated work activity exposure estimates.
 
Scheduled work Enclosure included thimble tube cutting, alloy 600 inspections, valve maintenance, fuel assembly transfers, fuel transfer system up-ender upgrades, and various support activities.
 
The inspectors compared the current actual dose accrued for these tasks with the initial exposure estimates; Additionally, the inspectors reviewed the ALARA Reviews (AR), Work-In-Progress (WIP) ARs, ALARA challenge board presentations, and ALARA pre-job briefing materials that addressed estimating and controlling dose for other outage activities.
 
Jobs reviewed included:
insulation removal and installation, scaffolding removal and installation, reactor disassembly, pressurizer heater replacement, and boric acid inspections.
 
WIP ALARA reviews were evaluated for boric acid corrosion control inspections, alloy 600 inspection and mitigation, health physics outage support, pressurizer heater replacement, and temporary shielding installation; The inspectors evaluated the effectiveness of exposure mitigation requirements specified in RWPs and associated ALARA reviews. Jobs reviewed include reactor vessel disassembly (RWP 302, AR 2-09-01), thimble tube replacement (RWP 406, AR 2-09-35), pressurizer heater replacement (RWP 401, AR 2-09-29), insulation removal and installation (RWP326, AR 2-09-14), and scaffolding removal and installation (RWP 331, AR 2-09-13); The inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems.
 
The evaluation was accomplished by reviewing recent ALARA Council meeting minutes and ALARA challenge board presentations.
 
The inspectors also attended daily outage status meetings to assess interdepartmental coordination and communications; and Through job site observations and radiation survey measurements, the inspectors determined if work activity planning included the use of temporary shielding.
 
system flushes, and operational considerations (Le. scheduling work when SGs were fIlled to further minimize worker exposure).
 
The inspectors reviewed temporary shielding effectiveness measurements and performed independent measurements on various system components in the reactor building and auxiliary building work areas to determine if temporary shielding was appropriately used. Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for the annual site collective 19xposure and the Unit 2 refueling outage dose projection; and The inspectors reviewed Dominion's exposure tracking system to determine whether the level of dose tracking detail, exposure report timeliness, and distribution was sufficient to support the control of outage project exposures.
 
Included in this review were departmental dose assessments and individual dose records. Job Site Inspection and ALARA Controls The inspectors observed activities performed in containment including valve inspections/repairs, upper guide structure transfer, and scaffolding
& shielding demobilization.
 
The inspectors verified that the appropriate radiological controls Enclosure 26 were implemented including briefings, radiation protection technician coverage, contamination mitigation, proper dosimetry, and that workers were knowledgeable of radiological conditions.
 
Source Term Reduction and Control The inspectors reviewed the current status and historical trends of the Unit 2 source term. Through interviews with the Radiation Protection, Chemistry Manager, and the ALARA Supervisor, the inspectors evaluated Dominion's source term measurements (Le. reactor coolant system piping dose rates and control strategies).
 
The inspectors reviewed reactor coolant chemistry data to evaluate the effectiveness of post shutdown source term reduction efforts. Specific strategies being employed included:
use of macro-porous cleanup resins, system flushes, installation of temporary shielding, use of temporary filtration system, and chemistry controls.
 
Radiation Worker Performance The inspectors observed radiation worker and radiation protection technician performance for selected tasks. Tasks observed included containment demobilization activities, and reactor re-assembly.
 
The inspectors determined that the individuals were aware of radiological conditions and access controls that applied to their tasks; and The inspectors reviewed eRs, related to radiation worker and radiation protection technician errors, and PCRs to determine if an observable pattern traceable to a common cause was evident. Declared Pregnant Workers The inspectors determined that one declared pregnant worker was employed to perform outage related activities in the radiological controlled areas. The inspectors verified that the individual's exposure was appropriately monitored, per procedural requirements, and controlled to meet regulatory criteria.
 
Problem Identification and Resolution The inspectors reviewed elements of Dominion's corrective action program related to implementing the radiological controls program to determine if problems were being entered into the program for resolution.
 
Included in this review were relevant eRs, Nuclear Oversight field observation reports, and a program audit.
 
====b. Findings====
No findings of Significance were identified.
 
==OTHER ACTIVITIES==
lOA] Performance Indicator (PI) Verification (71151 -4 samples) Cornerstone:
Mitigating Systems Inspection Scope 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 Performance Indicator Guideline," Revision 5, were used to verify the basis for reporting each data element. The inspectors reviewed portions of the operations logs, monthly operating reports, and LERs, and discussed the methods for compiling and reporting the Pis with cognizant licensing and engineering personnel.
 
Documents reviewed during the inspection are listed in the Attachment.
* Safety System Functional Failures (SSFF) [MS06]; Unit
* SSFF [MS05J. Findings No findings of significance were identified . . Occupational Exposure Control Effectiveness
[OR01] Inspection Scope The inspectors reviewed implementation of Dominion's Occupational Exposure Control Effectiveness Performance Indicator Program. Specifically, the inspectors reviewed CRs, and associated documents for occurrences involving locked high radiation areas, very high radiation areas, and unplanned exposures.
 
The PI definitions and guidance contained in Nuclear Energy Institute
{NEI} 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used to verify the basis for reporting each data element. This inspection activity represents the completion of one sample relative to this inspection area. completing the annual inspection requirement.
 
No findings of significance were
 
===.3 RETS/ODCM===
 
Radiological Effluent Occurrences
[PR01]
 
====a. Inspection Scope====
The inspectors reviewed relevant effluent release reports for the period October 1, 2008 through October 30, 2009, for issues related to the public radiation safety performance indicator, which measures radiological effluent release occurrences that exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ dose for liquid effluents; 5 mrads/qtr gamma air dose; 10 mrads/qtr beta air dose; and 7.5 mrads/qtr organ dose for gaseous effluents.
 
The PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used to verify the basis for reporting each data element. This inspection activity represents the completion of one sample relative to this inspection area, completing the annual inspection requirement.
 
No findings of significance were identified.
 
40A2 Identification and Resolution of Problems (71152 -5 sam pies)
 
===.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 follow-up, the inspectors performed a daily screening of items entered into Dominion's corrective action program. This was accomplished by reviewing the of each new CR and attending daily management review committee meEltings.
 
The Inservice Inspection program inspector reviewed a sample of corrective action reports related to problems in Inservice Inspection in order to determine if problems wen3 identified and corrected in a timely fashion. The inspector determined the nonconforming conditions identified were reported, characterized, evaluated and appropriately disposed of commensurate with their importance to safety. Documents reviewed during the inspection are listed in the Attachment.
 
No findings of significance were identified.
 
===.2 Ogerator WorkwAround===
 
(2 samples)
 
====a. Inspection Scope====
The inspectors reviewed the current listing of operator work-arounds for Units 2 and 3. The review was performed to verify that Dominion procedures and practices provided necessary guidance to plant personnel, that the cumulative effects of the known operator work-arounds were addressed, and that the overall impact on the affected systems were assessed.
 
The inspectors independently assessed the cumulative impact of known operator work-arounds to determine if they adversely affected the ability of operators to implement operating procedures (both normal and off-normal)and respond to plant transients.
 
In support of this assessment, the inspectors reviewed various eRs regarding operatorwork-arounds and verified that work-a rounds were being identified.
 
tracked, and resolved in accordance with Dominion's corrective action program. This inspection effort represented one sample for Unit 1 and one sample for Unit 2. Documents reviewed during the inspection are listed in the Attachment.
 
====b. Findings====
and Opservations No findings of significance were identified.
 
The inspectors determined that operator work-arounds were adequately classified, tracked, and assessed in accordance with Dominion procedures, and that the cumulative impact of the work,.arounds did not adversely impact the ability of the operators to implement the operating procedures . . 3 Semi-Annual Problem Identification
& Resolution (PI&R) Trend Review (1 sample)
 
====a. Inspection Scope====
As required by Inspection Procedure 71152, the inspectors performed a review of the Dominion corrective action program and associated documents to identify trends that may indicate existence of safety significant issues. The inspectors review was focused on repetitive equipment and corrective maintenance issues, but also considered the results of daily inspector corrective action program item screening.
 
====b. Findings and Observations====
No findings of significance were identified.
 
The inspectors review determined that the trend reports reviewed adequately captured the site's negative trends. The inspectors noted that the trend reports were revised, based on the inspectors comments from the previous semi-annual trend review, to include a listing of open adverse trends. The inspectors also noted that two long term trends and a few recurring issues that were listed in the second quarter report were not listed in the third quarter report and there was no discussion of the resolution of these items. Enclosure
 
===.4 Annual Sample -Omission of a Nondestructive===
 
Evaluation Examination on Replacement Valve 3SIH*V028 in the Safety Injection System (1 sample)
 
====a. Inspection Scope====
The inspector reviewed the corrective action related to ACE 017370. The licensee Identified the omission of a nondestructive evaluation examination on the installation of replacement valve 3SIH*V028 in the safety injection system.
 
====b. Findings and Observations====
A field change, implementing an ASME Code Case, did not take into account the jurisdictional change in the edition of the ASME Code referred to in the Code Case. Earlier editions of the Code, including the edition in force during the outage, did not require an examination of piping below a nominal size of four inches. However, ASME Code Case N-416-3 was invoked which requires examinations in conformance with the 1992 Edition of the Code. This edition changes the examination lower limit to two inches nominal pipe size. The nondestructive examinations were undertaken in a timely fashion after the omission was identified.
 
No indications were found as a result of the examinations. Event Follow-up (71153 -2 samples) . . Unit 2 Notification Of Unusual Event Classification (NOUE) -Loss of Control Room Annunciators
 
====a. Inspection Scope====
On November 15,2009, at 8:11 a.m .. Unit 2 experienced a loss of all control room annunciators lasting greater than 15 minutes while operating in Mode 5 (cold shutdown).
 
The shift manager classified the event at the level of a Notification of Unusual Event (NOUE). An electrical transient caused non-vital 120 volt AC Instrument busses, VR-11 and VR-21 , to cycle repeatedly on and off. which caused the power supply to the main control board annunciators to lose power and lock out. The operators took immediate action in accordance with AOP-2504A, "Loss of VR-11, nand AOP-2504B, of VR-21." The electrical transient was initiated when the "S" heater drain pump was started for post maintenance testing following an overhaul of the motor. In addition to the loss of annunciators, a letdown isolation occurred, and the operators secured the charging and letdown systems. A NOUE was declared at 8:26 a.m. after 15 minutes had elapsed without power to the annunciators.
 
At 8:33 a.m., I&C technicians reset the annunciator power supply, and all main control board annunciators were restored to service. The crew determined that all safety functions were met. The NOUE declaration was subsequently terminated at 8:58 a.m. The inspectors responded to the control room and evaluated the adequacy of operator actions in accordance with approved procedures and TS irnplications.
 
The inspectors 31 penformed walk downs and interviewed personnel to verify that the plant was stable, and that the annunciators had been restored to service. Documents reviewed during the inspection are listed in the Attachment.
 
====b. Findings====
 
=====Introduction:=====
A Green, self-revealing finding (FIN) was identified for Dominion's failure to complete effective corrective actions for known degraded conditions associated with the VR-11 and VR-21 120-volt AC non-vital instrument power supplies.
 
Specifically, 11 and VR-21 were known to cycle on and off repeatedly whenever an electrical disturbance on the grid affected the input supply voltages from their respective regulating transformers.
 
The degraded condition on the instrument buses had not been corrected despite prior opportunities.
 
This condition led to a loss of annunciators and declaration of a Notification of Unusual Event (NOUE) on November 15, 2009.
 
=====Description:=====
On November 15, 2009, Millstone Unit 2 was operating at 60 percent power when VR-11 and VR-21 began to rapidly turn on and off (power cycling) for approximately one minute. This rapid power cycling started when a fuse was being replaced in the "S" heater drain pump, which created an electrical ground condition.
 
The rapid fluctuation of power to the non-safety instrument buses resulted in a Chemical and Volume Control System (CVCS) letdown isolation, and the rapid flashing of all main board annunciators.
 
The regulated power supply for the main board annunciators subsequently deenergized and caused a loss of annunciation in the control room for 21 minutes. The operators responded by entering Abnormal Operating Procedure (AOP) 2504A (and AOP-2504S), "Loss of VR-11 (VR-21 )," which directed isolating the charging system and stabilizing the plant. The Shift Manager entered the station emergency plan and declared a NOUE when the annunciators had remained in a non-functional state for 15 minutes in accordance with Emergency Action Level (EAL) EU-3, "Loss of Annunciators." The probable cause of the event was the degraded power cycling response of VR-11 and VR-21 to an electrical disturbance.
 
This vulnerability of VR-11 and VR-21 to electrical disturbances had most recently been identified on July 3, 2009, when an offsite grid disturbance caused VR-11 and VR-21 to exhibit a similar degraded system response.
 
The original problem with VR-11 and VR-21 had been first identified and entered into the corrective action process as early as 2001. The long-term corrective action for this adverse condition was to power VR-11 and VR-21 from a large uninterruptible power supply (UPS) to prevent the rapid power cycling between the normal and alternate power supplies.
 
To date, this has not been implemented.
 
This corrective action has been scheduled for implementation in February 2010. Previous interim corrective actions had included disabling the normal supply regulated transformer supplies UAC1 and UAC2, temporarily removing some loads from VR-11 and VR-21 , and installing small UPS power supplies on isolated circuits, all of which did not prevent the November 15, 2009 event. Previously, grid disturbances on June 28, 2008, February 2, 2009, April 30, 2009, and July 3, 2009 continued to challenge the Unit 2 operator's ability to operate the plant Enclosure because of degraded system responses from the cycling of and VR w 21 during these events. These actions included main feedwater regulating valve lockup, isolation of tl1e letdown system, unexpected steam dump response, and automatic startup of all three charging pumps. In each case, the previous interim corrective actions were ineffective in preventing VR w 11 and VR-21 from rapidly cycling and disrupting plant system equipment alignments.
 
Despite the ineffectiveness of the short term corrective actions, Dominion did not complete the long-term corrective action to install a UPS as the normal power source for VR-11 and VR-21 by the end of the refueling outage 2R19.
 
=====Analysis:=====
The inspectors determined that Dominion's failure to effectively implement interim corrective actions to prevent recurrence of the power cycling of VR-11 and 21 was a performance deficiency.
 
The cause was reasonably within Dominion's ability to foresee and correct, and should have been prevented.
 
Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.
 
A review of NRC Inspection Manual Chapter 0612, Appendix E, Examples," revealed that no minor examples applied to this finding. The finding was more than minor be.cause it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring capability of systems that respond to initiating events to prevent undesirable consequences.
 
The main board annunciators provide operators with critical notification and assessment capability during plant upset or transient conditions.
 
Annunciators are used to direct operators to appropriate alarm response procedures, which further direct operators to AOPs and direct entry conditions into EOPs. Annunciators also provide early warning to operators of adverse trends in key plant parameters before the degradation becomes sig nificant.
 
The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1 Initial Screening and Characterization of Findings." The finding was determined to be of very low safety Significance (Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety Significance and complexity.
 
[P.1 (d)]
 
=====Enforcement:=====
No violation of regulatory requirements occurred, because the annunciator system is non-safety related. Dominion took immediate action to expedite the installation of the UPS for VR-11 and VR-21. Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement.
 
Because this finding does not involve a violation of regulatory requirements, and has very low safety significance (Green), it is identified as a finding (FIN). (FIN 05000336/2009005-04 Inadequate and Untimely Corrective Actions Causes Loss of Annunciators and Declaration of a NOUE) Enclosure
 
===.2 Unit 3 Main Generator===
 
Ground Fault
 
====a. Inspection Scope====
On December 19, 2009 at 22:53, Millstone Unit 3 tripped from 100 percent power during a significant snow storm. A generator protection and main generator leads ground fault resulted in a turbine/generator trip with subsequent reactor trip and fast transfer to the Reserve Station Service Transformer (RSST). All safety systems responded as expected.
 
Relays 59NL-3SPUB1 0 anq 59NH-3SPUB17 actuated on detecting a severe ground fault condition as measured through the main generator neutral. The relays opened the main generator output breakers and isolated the fault from the main generator to the generator output breaker. This resulted in a main turbine and reactor trip. After a time delay, the 59NB-3SPLIB 17 relay actuated, indicating a fault on the transformer side of the breaker, opening Unit 3 normal offsite power supply breakers, 13T and 14T, and causing a fast transfer to the reserve offsite power supply. Walkdowns determined that the "e" phase of the main generator output breaker was damaged. Unit 3 later entered Technical Specification Action Statement 3.0.3 for 73 minutes when snow plugged the filter for the Engineered Safety Feature (ESF) building emergency ventilation, making all safety-related pumps in the ESF building inoperable.
 
The inspectors responded to the control room and evaluated the adequacy of operator actions in accordance with approved procedures and TS implications.
 
The inspectors performed walk downs and interviewed personnel to verify that the plant was stable, Documents reviewed during the inspection are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified.
 
40A5 Other Activities Quarterly Resident Inspector Observations of Security Personnel and Activities
 
====a. Inspection Scope====
During the inspection period, the inspectors performed observations of security force personnel and activities to ensure that the activities were consistent with site security procedures and regulatory requirements relating to nuclear plant security.
 
These observations took place during both normal and off-normal plant working hours. These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.
 
Findings No findings of significance were identified.
 
40A6 Meetings, including Exit Exit Meeting Summary On January 13, 2010, the resident inspectors presented the overall inspection results to Mr. A. J. Jordan and members of his staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.
 
ATTACHMENT:
 
=SUPPLEMENTAL
INFORMATION=
 
===Licensee personnel===
: [[contact::E. Annino G. Auria B]], Barron B. Bartron P. Baumann H. Beemon R. Borchardt
R. Carey C. Chapin A. Chyra T. Cleary G. Closius L. Crone J. Dorosky A. Elms M. Finnegan G. Gardner A. Gharakhanian
M. Gobeli W. Gorman J. Grogan C. Houska A. Jordan C. Janus J. Kunze B. Krauth J. Laine M. Lalikos P. Luckey R. MacManus M. Marino C. Maxson M. O'Connor L. Perry R. Riley M. Roche J. Semancik A. Smith S. Smith J. Spence P. Strickland
S. Turowskj A-1 SUPPLEMENTAL
KEY POINTS OF Dominion Licensing
Nuclear Chemistry
Supervisor
Manager, Nuclear Oversight
Supervisor.
licensing
Manager, Security Supervisor.
Nuclear Engineering
Consulting
Engineer, Reactor Engineering
Consulting
Engineer, ILRT, Inc. Supervisor, Nuclear Shift Operations
Unit 2 Nuclear Engineer.
PRA Licensing
Engineer Licensing
Engineer Supervisor, Nuclear Chemistry
Health Physicist
III Manager, Nuclear Engineering
Supervisor, Health Physics, ISFSI Dominion Engineering
Nuclear Engineer III Nuclear Engineer III Supervisor.
Instrumentation
& Control Assistant
Operations
Manager I&C Technician
Site Vice President
Nuclear Engineer III Supervisor, Nuclear Operations
Support Licensing, Nuclear Technology
Specialist
Manager. Radiation
Protection/Chemistry
ISIINDE Engineering
Manager, Emergency
Preparedness
Director, Nuclear Station Safety & Licensing
VFD Modification
Project Manager Director, Engineering
Manager, Operations
Dominion lSI Supervisor, Nuclear Shift Operations
Unit 3 Senior Nuclear Chemistry
Technician
Plant Manager Asset Management
Manager, Engineering
Manager, Training VFD Modification
Test Director Supervisor, Health Physics Technical
Services Attachment
M. VanHalter
Dominion Engineering
: [[contact::M. Vezzina Dominion lSI C. Voumazos IT Specialist]], Meteorological
Data R. West Dominion Engineering
: [[contact::J. Williams Dominion lSI LIST OF ITEMS OPENED]], CLOSED, AND DISCUSSED
Opened and Closed 05000336/2009005-01
NCV -TS Surveillance
Channel Calibration
of ICCMS Not Performed. (Section 1 R15)
FIN -Implementation
of Design Change Results in an Unplanned
Shutdown of Reactor. (SecUon 1 R20)
NCV -RCS Drain Down loss of Configuration
Control. (Section 1R20)
FIN -Inadequate
and Untimely Corrective
Actions Causes loss of Annunciators
and Declaration
of a NOUE. (Section 40A3) LIST OF DOCUMENTS
REVIEWED Section 1 R01: Adverse Weather Protection
COP 200.13, "Cold Weather Preparations," Revision 003-00 OP 2331, "Plant Heating and Condensate
Recovery System, n Revision 006-09 OP 3314G, "Intake structure
Ventilation," Revision 009-06 OP 3352, "Heat Tracing," Revision 013-05 Section 1 R04: Equipment
Alignment
OP 3304A-001, "MB3 Charging and Letdown lineup," Revision 005-03 OP 3304A-003, *Charging
and letdown lineup," Revision 013 OP 3322-001, "TDAFW Pump and Components
Common to Both Trains," Revision 007 OP 3322-003, "Auxiliary
Feedwater
Train "B,"" Revision 006-05 OP 3322-005, "Electrical
Checklist
for Auxiliary
Feedwater
System," Revision 006-01 OP 3326-001, "Train "A" Service Water System," Revision 009-03 OP 3326-003, "RPCCW "An Service Water System Supply," Revision 004-01 OP 3326-009, "Service Water System -Control Building Air Conditioner "AU Supply," Revision 007-01 OP 3326-013, "ESF Building Emergency
Ventilation "An SW System Supply," Revision 008-01 OU-AA-200, "Shutdown
Risk Management," Revision 0 OP 2264, Attachment
2, Shutdown Safety Assessment
Checklist
for October 14 and 15, 2009 Attachment
Section 1 R05: Fire Protection
Millstone
Unit 2 Fire Hazards Analysis, Revision 9 Millstone
Unit 2 Fire Fighting Strategies, April 2002 Millstone
Unit 3 Fire Protection
Evc;tluation
Report, Revision 16 Millstone
Unit 3 Fire Fighting Strategies, April 2002 Section 1 R06: Flood Protection
Measures W2-517-1070RE, PMiIIstone
Unit 21ntemal Flooding Evaluation," Revision 0 Qualification
Documentation
for Kerite 5KY and 8KV HTK, Shielded FR Jacketed Power Cables dated August 13, 1980 Engineering
Memorandum
No. 223 dated May 4, 1977 25203-ER-99-0170, "Millstone
Unit 2 Plant Drains and Flood Protection," Revision 0 25203-11003, "Paving, Drainage and Fencing Plan Details," Revision 11 25203-20152
Sheet 372, "Area Drains -Aux Bldg, Drains to Collection
TK-T-43," Revision 0 25203-24018
Sheet 1, "Area Floor Drains Aux. Bldg E
: [[contact::I. 14'-6"]], Revision 2 25203-24028, "Area Drains -Auxiliary
Building Plan E
: [[contact::I. 14'-6" and EI. 25'-6"]], Revision 11 98-ENG-02411-C2, "Millstone
Unit 2 Evaluation
of Flooding Outside Containment," Revision 001-01 Section 1 R08: .nservice
Inspection
Condition
Report Engineering
Di§position
Form Form DE2-DT-0473-09
dated 7/16/09 Root Cause Evaluation
Reports RCE000983, 'A' RCP RBCCW Cooling Leak, Millstone
Unit 2,7/28/09
RCE000981, 'N Reactor Coolant Pump Seal Leakage, Millstone
Unit 2, Procedures "Radiographic
Examination
Procedure
for ASME Boiler and Pressure Vessel Code RT010,>> Revision 001-01,9/8/09
Procedure
PI-AA-200, Revision 8, "Corrective
Action Process" NDE Examination
Reports (Data Liquid Penetrant
Data Sheet. ECW 1, 2, 3, 4 Seal Cooler, dated 7/15/09
Liquid Penetrant
Data Sheet, ECW 2 Seal Cooler, dated 7/15/09
Liquid Penetrant
Data Sheet, ECW 2 Seal Cooler partial exam, dated 7/15/09
Liquid Penetrant
Data Sheet, ECW 1, 3, 4 Seal Cooler, dated 7/15/09
Liquid Penetrant
Data Sheet, ECW 3 Seal Cooler, dated 7/15/09
Liquid Penetrant
Data Sheet, ECW 3 re-exam Seal Cooler, dated 7/15/09
Liquid Penetrant
Data Sheet, ECW 1,2,4 Seal Cooler, dated 7/15/09
Radiographic
Report M2-2453, A RCP seal cooler leak repair, 7/17/09 (info report Radiographic
Report M2-2452, A RCP seal cooler leak repair, 7/16/09 (info report Ultrasonic
Data Package 218-01-035
RCS Zone Ultrasonic
Data Package
Ultrasonic
Data Package 218 w 01-045 RCS Zone Ultrasonic
Data Package 218-01-048
RCS Safety Injection
Sht 44Weld Ultrasonic
Data Package 218-01-086
RCS Surge Nozzle Weld Attachment
Ultrasonic
Data Package 218-01-087
RCS Shutdown Cooling Weld Overlay Ultrasonic
Data Package 218-01-090
AWO M2-06-10388
Field Weld 3 Repair-Replacement
Work Order Weld Data and Inspection
Map -WO 53102266944, 9116/09 Miscellaneous
Documents
Dominion Letter 07-0555, "Millstone
Unit 2, Alternate
Request RR-89-01, Use of Weld Overlays as an Alternative
Repair and Mitigation
Technique." NRC Letter," MILLSTONE
POWER STATION, UNIT NO.2-RELIEF
REQUEST RR-89-61, REVISION 2, REGARDING
THE USE OF WELD OVERLAYS AS AN ALTERNATIVE
REPAIR (TAC N
: [[contact::O. ME1765)" Dominion Letter (no number) to ASME]], Section XI, dated 7/30/09; "Examination
Requirements
Following
Defect Removal and Weld Repair, IWA-4422.2.2 (e) and IWA-4520 (1998 Edition with the 2000 Addenda)" Dominion Letter 09-ZZZ to ASME, Section XI, dated 8/11/09; "Examination
Requirements
Following
Defect Removal and Weld Repair, IWA-4422.2.2 (e) and IWA-4520 (1998 Edition)" ASME, Section XI Letter 09-1315 dated 8/17/09; "ASME BPVC Section XI, IWA-4422.2.2(e)
and IWA-4520, 1998 Edition with the 2009 Addenda" Dominion Letter 09-474, dated 9/22109; DOMINION NUCLEAR CONNECTICUT, INC. MILLSTONE
POWER STATION UNIT 2 ALTERNATE
REQUEST RR-89-67 FOR THE P40A RCP SEAL COOLER RETURN TUBING Section 1R11: Licensed Operator Regualification
Program Requalification
Program Procedures/Documents
ANSI/ANS-3.4-1983, Medical Certification
and Monitoring
of Personnel
Requiring
Operator Licenses for Nuclear Power Plants
ANSIIANS-3.5-1998, Nuclear Power Plant Simulators
for Use in Operator Training and Examination
Training Program Procedures
Licensed Operator Requalification
Training (LORT), TPD-7.080, Revision 12, Change 2 Millstone
Unit 3 LORT, S09702L, Revision 0 Developing, Administering, and Evaluating
Operator Training Written Examination
Materials, NTP 122.1, Revision 5 Developing
and Conducting
Job Performance
Measures, NTP 146, Revision 001-01 Operator Training Examination
Security, NTP 122.4, Revision 002-01 Conducting
simulator
Training and Examinations, NTP 144, Revision 005 Licensed Operator Biennial and Annual Operator Requalification
Exam Process, TR-M-730, Revision 0 Development, TR-M-300, Revision 1 Millstone
Unit 3 Written Exam Sample Plan 2007/2008
Licensed Operator Requalification
{LORT)/STA
Program 2009 LORT Annual Operating
Test Sample Plan Attachment
Simulator-Related
Documentation
Nuclear Simulator
Engineering
Manual, NSEM-6.06
Simulator
Scenario Based Testing Transient
Test 8, Maximum size LOCA with a Loss of Normal Off site Power Transient
Test 10, Slow RCS Depressurization
to Saturated
Conditions
Using PORV Stuck Open Steady State Tests <<50%, <100%, & 100%) DR-200B-30073
DR-2009-3-0027
DR-2009-3-0031
DR-2009-3-0037
Job Aid Millstone
Unit 2 LORT Operational
Exercise #1 (809501) Job Aid Millstone
Unit 3*LORT*S09404L
Root CausE1 Evaluation (RCE) 000235, Automatic
Reactor Trip Millstone
Unit 3 CACC000275, Training to Review Simulator
Model CACC00286, RCE Contributing
Cause Action Follow-up
Assignment
CAPR 000350, Millstone
Unit 3 Automatic
Reactor Trip Simulator
Exercise Guide Plant Startup Training JIT03-08-007
Condition
Reports CR-08-07476
CR-08-08278
CR113512 CR325620 CR327201 CR329044 CR330334 NRC Inspection
Report 05000423/2009002
NRC Inspection
Report 05000423/2008004
NRC Inspection
Report 05000423/2008005
Operational
Exercise #2 (S09702) Section 1R12: Maintenance
Effectiveness
EOP2532, Loss of Coolant Accident, Revision 29 SP2609E, "EBFS Negative Pressure Test," Revision 009-01 EBFS Hearth Reports, 1st quarter 2008 and 3rd quarter 2009 PRA memo NE-97-SAB-199
Memo NSE-02-073
ACE17402, "The nAil EBFS filter bed L29A test results are UNSAT" RCE000984, "EBFS Negative Pressure Test Failed Acceptance
Criteria" MRE010273
MRE0108H MRE010866
MRE010875
MRE010883
MRE010886
MRE010952
MRE011396
MRE011510
CR321622, "EBFS filter bed L29A test results are UNSAT" dated January 28,2009 CR340306, "2-MS-247
Lower Discharge
Pipe Seal Torn" dated July 4,2009 CR341915, "SP2609E EBFS Negative Pressure Test, failed acceptance
criteria for Z1 and Z2" dated July 19, 2009 Section 1R13: Maintenance
Risk Assessments
and Emergent Work Control OP2264 Attachment
2, "Shutdown
Safety Assessment
Checklist" dated October 14, 2009 OP2264 Attachment
3, High Risk Evolution
Contingency
Plan -A305 Racking Mechanism
Replacement" dated October 12, 2009 .OP-2264 Attachment
2, "Shutdown
Safety Assessment
Checklist
dated October 26,2009 Orange Risk for SI-306 valve repairs" SPROC OPS09-2-02
CR356180, "Implementation
of Orange Risk Color in EOOS for the RSST OOS at Millstone
Unit 2" dated November 3, 2009 Section 1 R15: Operability
Evaluations
Engineering
Information
Record Document No. 51-9126147-00
EVAL-ENG-RSE-M2C20, Revision 1 NIS-01-C, "Nuclear Instrumentation
System," Revision 3 Control Room Log dated November 16, 2009 Night Shift CR358159, ""8" WR NIS Source Range Counts is reading 5.2E04, other channels reading 2 CPS" dated November 15, 2009 CR358117 CR358896 CR359247 CR359570
CR 352045 ACE017934, "Apparent
missed surveillance
Unit 2 TS Table 4.307 items 3, 10, 12 Channel Cal" Section 1R18: Plant Modifications
DCN DM2-00-0200-09
OCR M2-08003 Circulating
Water Pumps Variable Frequency
Drives -Phase II OP 23058 "RWST Purification," Revision 000-01 OP 2305 "Spent Fuel Pool COOling and Purification
System," Revision 021*01 SPROC ENG09-2-001, "Unit 2 Variable Frequency
Drive," Revision 002 dated October 26, 2009 Drawing 25203-26008
SH1, "Circulating
Water," Revision 80 CR354682, "VFD Enclosure
#2 is leaking rain water" dated October 24, 2009 CR354727, "VFD terminal boards not labeled" dated October 25,2009 CR354953, "Potential
for unexpected
Unit 2 Cire pump trip during light bulb replacement" dated October 26, 2009 CR355372, "Rain Water Leaking into Unit 2 VFD PDC Enclosure
#1 & #2 & Unit 3 Enclosure
#1 &#3" dated October 28,2009 CR355466, "Unit 2 VFD failed cell" dated October 29, 2009 CR355519, "Procedure
change needed to OP2315N" dated October 29,2009 Attachment
CR357133, "Deficiencies
identified
while performing
VFD SPROC on "A" Cire Water uncoupled
pump" dated November 8, 2009 CR357264, "Failures
of one portion of testing for "A"&"D" VFDs" dated November 9, 2009 Section 1 R.19: Post Maintenance
Testing AW0531 02296942, 'Inspect and Repair Letdown Outlet Temperature
Loop." Revision 0 dated November 2, 2009 AWO 53102258097, "Determ/Reterm
2-SW-97A to support valve replacement" dated November 4, 2009 AWO 53102301247, "1'1-109, Pressurizer
Vapor Space reading incorrectly" dated November 9,2009 AW0531 02300705, "Perform Post Maintenance
Test on T221 Regen Hx Out," Revision 0, dated November 11, 2009 AWO 53102302188, "Pressurizer
Proportional
Heater Controller
Failed to Furl Power Output" dated November 12, 2009 AWO 53102306805,
Replace Pump Bearings and Mechanical
Seals" AWO 53M20803550, "PMT for Pzr Proportional
Heater Controller
Failure," dated November 13, 2009 AW053M20808798, ""B" Heater Drain Pump Oil Leak" OP2264 Attachment
3, "High Risk Evolution
Contingency
Plan, Replacement
of 2-SW-97 A" dated October 7, 2009 CR356091, "Section of OP2326A to return 2-SW-97 A to automatic
operation
does not work" dated November 2, 2009 CR356126. "Service Water valve
does not operate properly from the control room" dated November 2, 2009 CR357016, "Perform Post Maintenance
Test on TI-221, Regen Hx Outlet Loop" dated November 7, 2009 CR357154, "TI-109, Pressurizer
Vapor Space Temperature
reading incorrectly" dated November 9, 2009 CR357623, "Pressurizer
Proportional
Heater Controller
Failed to Full Power Output" dated November 11, 2009 CR358310, "Hex head bolts were installed
for cap screws during installation
of 2SW-97A" dated November 16, 2009 CR358905, "liB" Heater Drains Pump Motor, P3BM has two vibration
measurement
points in ALERT" dated November 19, 2009 CR358939, "Oil leak on "B" heater drain pump upper motor RTD tap" dated November 20, 2009 CR359987, "JITT associated
with Downpower
for "B" Heater Drain Pump Cancelled" dated November 30,2009 CR360018. "Overhaul
of Unit 2 P3BM heater drain pump motor results as they pertain to the "An motor" dated December 1. 2009 CR360274, "No process to create EPIX assignment
for a certain ER clock reset type" dated December 2, 2009 Section IR20: Refueling
Outage OP 2203. "Plant Startup," Revision 018-08 OP 2323
: [[contact::A. "Turbine]]," Revision 023-01 OP 2324A, "Turbine Generator
and Exciter," Revision 016-04 ARP 2590E-241, Revision 000-01. "Generator
Ground Fault" dated June 22,2004 Attachment
Control Room Log dated November 4, 2009 Day Shift Control Room Log dated November 8, 2009 Night Shift CVC-OO-C, "Chemical
and Volume Control System," Revision 8.3 Drawing M2 86001650, Revision 1, "In-Core Instrument
Installation
Arrangement" dated August 28, 1998 Drawing M2 86001648, "In-Core Instrument
Arrangement" dated November 14, 1986 OP-2264, "Conduct of Outages," Revision 012-02 dated September
23, 2009 OP-2301 E, "Draining
the RCS (ICC E), " Revision 024-03 dated October 8, 2009 OP-2301E-005, "Preferred
RCS Vent Path," Revision 003-03 dated October 8,2009 OP-2301 G "Vacuum Fill of the Reactor Coolant System (lCCE)," Revision 001-00 dated October 7,2009 SP2613G, "Integrated
Test of Facility 1 Components (ICCE)," Revision 012-00 dated October 9,2009 RR-89-67, "Dominion
Alternative
Request for the P40A Seal Cooler Return Tubing" dated September
2,2009 RAC 05 Attachment
Reportabllity
Determination
CR34582, "EDG Timer Failure" dated October 30,2009 CR345382, "Timer TC065 failed and need to be replaced" dated August 19, 2009 CR351372, "Millstone
Unit 2 Containment
Ambient Temperatures
Appear Significantly
Hotter during Entry dated October 6, 2009 CR351389, "Under voltage protection
bypassed in Modes 4 and 5 per AWO" dated October 7, 2009 CR351395, "Calculated
RCS cooldown rate exceeded
: [[contact::T.S. limit of 50 degrees/hour" dated October 7]], 2009 CR351429, "Breaker B0111 opened after closing the cross tie buses 22A and 22B" dated October 8, 2009 CR351435, "Unable to obtain closed indication
for 2-FW-51A during MSI push button test" dated October 8,2009 CR352180, "DCN DM2-S-1622-92
does not meet B31.1 Design Code requirements
for min wall" dated October 12,2009 CR353193, "Workers started to open inspection
flange -service water inspection
on the operable header" dated October 17, 2009 CR353396, "Refuel Machine stopped operating
while performing
load tests" dated October 19, 2009 CR353540, "Unexpected
responses
from refuel machine during fuel movement" dated October 19, 2009 CR353569, "Adverse Trend in GSI-191 Debris Identified
in Millstone
Unit 2 Containment" dated October 19, 2009 CR353571, "Refuel Machine Hoist Issues during 2R19 Core Offload" dated October 19, 2009 CR353580, "Containment
Upender Discrepant
Conditions" dated October 20,2009 CR353588, "Containment
Upender Improvement
Recommendations" dated October 20, 2009 CR353590, "Spent Fuel Pool Upender Improvement
Recommendations" dated October 20, 2009 CR353725, "Loose debris detected on Rx Head" dated October 20, 2009 CR353732, "Unacceptable
Final Weld Inspection" dated October 20,2009 CR353775, "DV-10 Supply Breaker 00105 reclosed automatically
after opening" dated October 20,2009 Attachment
CR353779, "Bus 24C under voltage cleared on ESAS "A" Sensor Cabinet while restoring power" dated
October 20,2009 CR353812, "Breaker 00108 will not stay
when tripped" dated October 21, 2009 CR353990, "Limited GSI-191 Margin for Bare Concrete in Unit 2 Containment" dated October 21, 2009 CR354040, "EDG Timer Failure has the Potential
for Affecting
EDG Operability" dated October 21, 2009 CR354059, "Loss of 120 VAC Vital Bus VA-30" dated October 21,2009 CR394693, "Outage Planning Lessons Learned" dated October 25, 2009 CR354694, "Orange Substance
dripping down condenser
hotwell southeast
corner dated October 25, 2009 CR354719, "A" SGFP Vapor Extractor
Flange Over tightened
Causing Irreparable
Damage" dated October 25,2009 CR354784, "Relay RA107 as-found calibration
results were outside acceptance
range for RPS" dated October 25,2009 CR35478S*, "Relay RA 108 as-found calibration
results were outside acceptance
range for RPS" dated October 25,2009 CR354833, "Relay RA027 as-found failure"'dated
October 25,2009 CR354839, "Non tech spec limit not satisfied
for DB1-201A during quarterly
surveillance" dated October 26,2009 ' CR354841, "Discrepancy
on data sheet for Battery Quarterly
Surveillance" dated October 26, 2009 CR354962, "Clarification
requested
for RCE000983
-"N' RCP RBCCW Cooling Leak" dated October 26. 2009 CR355006" "Thimble Tube Project stub ends cut shorter than design documents" dated October 27. 2009 CR355043, "Valve installed
backwards
during reassembly
of EDG UN' SW piping" dated October 26,2009 CR355097, "Flexitallic
gasket material in, RCS could impact SG tube integrity" dated October 26. 2009 CR355127, "Missing bolts on Millstone
Unit 2 refueling
machine" dated October 27,2009 CR355133, "NOD audit 09-15; Possibility
of explosive
mixture in WGDT during Millstone
Unit 2 start-up" dated October 27, 2009 CR355182, "Empcenter
Potential
Deviations
require Prompt Dept. Review" dated October 26,2009 CR355350" ''''A'' AFW pump failed to develop required discharge
pressure during surveillance" dated October 28, 2009 CR355352" Potential
OCFR26 work hour rule infraction
-requires prompt review and records" datE3d October 27. 2009 CR355379, "Lessons Learned enhancement
to Rx Head Shroud Lift/Lower
per MP2704N' dated October 29,2009 CR355387,. "MS-190A.
#1 ADV will not open from C05 or the Foxboro screen" dated October 29,2009 CR355387. "MS-190A would not open during repeat surveillance" dated October 31, 2009 CR355388, "#1 AFW Flow indicator
FI-5277 A 1 is reading approximately
gpm with NO FLOW" dated October
29, 2009 CR355455, "One piece of Flexitallic
material found in top nozzle of fuel assembly Y-35" dated October 29,2009 Attachment
CR355726, "2-SI-306
SDC Total flow control not configured
correctly
for remote operation" dated October 31, 2009 CR355770, SW valves 2-SW-9A and 2-SW-10B would only open 20 percent" dated November 1, 2009 CR355792, "Unit 2 RSST trip test had UNSAT results for SLOD trouble alarm at 909 panel" dated October 31, 2009 CR355797, "Failed "A" EDG Starting Air Valves 1ST (SP2624A-001)" dated November 1, 2009 CR355825, "Old computer room air conditioning
work not proceeding" dated November 1, 2009 CR355843, "Computer point values
are out of tolerance" dated November 1, 2009 CR355849, "Procedure
Change Required for SP-2624A and SP-2624B" dated November 1, 2009 CR355915, "Relay Located inside "A" Diesel Generator
Control Panel is cycling" dated November 1, 2009 CR355946, "As found condition "A" circulating
water pump P6A Plug support column" dated November 2, 2009 CR355948, "FOSAR inspection
of Millstone
Unit 2 Reactor Lower Core Support Plate reveals debris" dated November '1, 2009 CR355990, "DB1-201A
battery has 5 cells with low specific gravity" dated November 2, 2009 CR356039, "3 Turbine Battery Cells have low specific gravity" dated November 2, 2009 CR356077, "Poor workmanship
on valve assembly" dated November 2, 2009 CR356091, "Section of OP2326A to return 2-SW-97 A to automatic
operation
does not work" dated November 3,2009 CR356101, "Unexpected
Results when starting "A" Train RBCCW" dated November 3,2009 CR3561 07, "OP-2264, Conduct of Outages needs a complete re-write" dated November 2, 2009 CR356310, "Non-QA Tendon Access Drain Piping Support Welded to ASME XI AFW Piping Support" dated November 3, 2009 CR356314, "Disposition
of CR119843 closed out without addressing
original issue" dated November 3, 2009 CR356385, "Main Board Annunciator
C08 A22 came in during EHC calibrations" dated November 4, 2009 CR357078, "Temporary
PPC Alarms Set for Unheated Thermocouples
Nulled out Database Alarms" dated November 8, 2009 CR357123, 'liB" Charging Pump tripped following
start during performance
of OP-2301 G" dated November 8, 2009 CR357137, "RWST to CVCS Stop Valve, 2-CS-028 is missing from SP-2601 B-001 " dated Nov'ember
9, 2009 CR357300, "Procedure
changes needed for consistency
and human factors" dated Nov'ember
8, 2009 CR357459, "Current Measurements
needed as a design input to VR-11 and VR-21 Upgrade Project" dated November 10, 2009 CR357766, Millstone
Unit 2 Circ Water Pump Shaft Vibration" dated November 12, 2009 CR358723, 'liB" AFW Pump Discharge
Check Valve leak by" dated November 19, 2009 CR358872, "ODM Required for VR11/21" dated November 19,2009 CR359527, "Trend of wiring discrepancies
during "Redlining" checks for design Changes OP-230'1 E, "Preferred
RCS Vent Path Alignment," Revision 003-03 dated October 8, 2009 OP-2301, "Draining
the RCS (ICGE)" Revision 024-03, dated October 8, 2009 Attachment
ACE 017848, "Valve 2-RC-447 not aligned for RCS drain down," Revision 1 dated October 14, 2009 Control Room Log dated October 10, 2009 -day shift Drawing M2107-08-99, Revision 0 9900025 Figure 12 "Shutdown
Cooling Operations" CR359925, "Millstone
Unit 2 Reactor Trip breakers #4 and #5 needed to be manually reset" dated November 25, 2009 Section 1R22: Surveillance
Testing SP-2613G, "Integrated
Test offacility
Components (ICCE)," Revision 012-00 dated October 19, 2009 SP-2613G-001, Facility 1 ESF Integrated
Test Data Sheet" dated October 15, 2009 MP-24-APPJ-FAP01, "Integrated
Leak Rate Test (ILRT) Process" dated January 1, 2008 VPROC ENG09-2-011, "Containment
Integrated
Leak rate test Type "A" (ICCE)
MP2)," Revision 000-01 dated November 4,2009 CR352069, "Transitions
between ESF and LNP Test needs to be managed better" dated October 14, 2009 CR357519, "Temporary
Valve at Penetration
#75 Bound Up" dated November 11,2009 CR357521, "Penetration
discharge
valve handwheel
shear pin broke during depressurization" dated November 11, 2009 CR357575, "Near miss safety concern on ILRT job" dated November 11. 2009 CR357586, "Lessons Learned -ILRT Delayed by Temporary
Butterfly
Valve Did Not Fully Open n dated November 11, 2009 Section 2081/2082:
Access to Radiologically
Significant
Areas/ALARA
Planning and Controls Occupational
Radiation
Safety RPM 1.3.8, Revision 8, Criteria for DOSimetry
Issue RPM 1.3.12, Revision 8, Internal Monitoring
Program RPM 1.3.13, Revision 8, Bioassay Sampling and Analysis RPM 1.3.14, Revision 7, Personnel
Dose Calculations
and Assessments
RPM 1.4.1, Revision 7, ALARA Reviews and Reports RPM 1.4.2, Revision 2, ALARA Engineering
Controls RPM 1.4.4, Revision 2, Temporary
Shielding
RPM 1.5.2, Revision 4, High Radiation
Area Key Control RPM 1.5.5, Revision 4, Guidelines
for Performance
of Radiological
Surveys RPM 1.5.6, Revision 3, Survey Documentation
and Disposition
RPM 1.6.4, Revision 3, Siemens Electronic
DOSimetry
System RPM 2.1.1, Revision 5, Issuance and Control of RWPs . RPM 2.1.2, Revision 2, ALARA Interface
with the RWP Process RPM 2.4.1, Revision 6, Posting of Radiological
Control Areas RPM 2.1
Revision 11, Air Sample Counting and Analysis RPM 5.2.2, Revision 10, Basic Radiation
Worker Responsibilities
RPM 5.2.3, Revision 3, ALARA Program and Policy RPM-GDL-008, Revision 0, Electronic
Dosimeter
Alarm Set Points RP-AA-123, Revision 0, Effective
Dose Equivalent
RPM 2.5.8, Revision 3, Stay Time Tracking and Multi-Badging
for Special Work Attachment
Condition
Reports 350246,355487,353560, 353464,353129,352736, 350044,346984, 322470, 334712, 331243,336978,340510,349141,356318,356317
2R19 ALARA Challenge
Board/Council
Meeting Presentations
Alloy 600 Inspections/Mitigation
Boric Acid Response Team Activities
Refueling
Team Activities
Source Term Reduction
Thimble Tube Replacement
Valve Maintenance
Team Activities
2R19 ALARA Dose Goal Approval Nuclear Oversight
Department
Reports/Audit
Audit 09-08, Radiation
Protection/Process
Control Program/Chemistry
Field Observation
Reports for 2R19 Nuclear Oversight Monthly
Reports to Site Vice President
ALARA Reviews 2-09-01, Reactor Disassembly/Reassembly
2-09-04, Fuel Movement 2-09-05, lSI Weld Inspections
& Boric Acid Corrosion
Control Program w 09-07, Boric Acid Corrosion
Control Inspections
2-09-09, Mechanical
PM/CMs & Minor Maintenance
2-09-11, Valve Maintenance
2-09-13, Scaffold Installation
& Removal 2-09-14, Insulation
Removalllnstallation
2-09-15, Shielding
Installation
2-09-35, Thimble Tube Cutting Miscellanec'us
Reports Millstone
Unit 2 Source Term Data Dose & Dose Rate Alarm Reports for the period May 1, 2009 through November 5, 2009 Monthly Gaseous and liquid Effluent Release Reports October 2008 through September
2009 Personnel
Contamination
Reports 2R19 Thimble Tube Replacement
Dive Plan (WCP-09-001)
Personnel
Dosimetry
Data . Section 40A1: Performance
Indicator (PI) Verification
The PI definitions
and guidance contained
in Nuclear Energy Institute (NEI) 99-02, "Regulatory
Assessment
Performance
Indicator
Guideline," Revision 5, were used to verify the basis for reporting
each data element. LER 05000336/2009-001-00
LER 05000336/2009-002-00
LER 05000423/2008-001-00
LER 05000423/2008-002-00
LER 05000423/2008-003-00
LER 05000423/2008-004-00
LER 05000423/2008*005*00
LER 05000423/2008-006-00
LER 05000423/2009-001-00
Section 40A2: Identification
and Resolution
of Problems Dominion Nuclear Trend Report Millstone
Station tid Quarter 2009 Dominion Nuclear Trend Report Millstone
Station 3rd Quarter 2009 Millstone
Operator Work Around, Burdens and Distractions, November 10.2009 Millstone
Operator Work Around, Burdens and Distractions, November 10, 2009 OP-AA-1700, "Operations
Aggregate
Impact," Revision 2 CR117074 CR337891 Section 40A3: Event Follow-up
EN 45498 "Millstone
Unit 2 Declared an Unusual Event due to a Loss of Annunciators" dated November 15, 2009 Event Review Team Report "Millstone
Unit 2 Unexpected
Loss of Annunciators
November 15. 2009 CR358168" dated October 17, 2009 Incident Report Form 2009062 dated November 15. 2009 Incident Report Form 2009063 dated November 15. 2009 OP-AA-100
Control Room Log, Day Shift dated November 15, 2009 Post Trip Review Report, Millstone
2/19/09, Main Generator
Ground Fault CR 362549 CR358168, "Unexpected
Loss of Annunciator
System" dated November 15,2009 CR358185, Foxboro DCS System Trouble Alarm Received during Plant Transient" dated November 15, 2009 CR358297, VR11/21 Power Cycling on November 15,2009 caused various Foxboro valve control Issues" dated November 16. 2009 CR362549 Event Review Team Report "Millstone
Unexpected
loss of Annunciators," dated November 15, 2009 CR358168, "Unexpected
loss of annunciator
system," dated November 15, 2009 LIST OF ACRONYMS AC Alternating
Current AD Analog to Digital ADAMS Agencywide
Documents
Access and Management
System AOP Abnormal Operating
Procedures
ALARA As Low As Reasonably
Achievable
AR ALARA Review ASME American So'ciety of Mechanical
Engineers
BPVC American Society of Mechanical
Engineers
Boiler and Pressure Vessel Code AWO CET CFR
CMS CR Automated
Work Order Core Exit Thermocouples
Code of Federal Regulations
Central Monitoring
System Condition
Report Attachment
CRED CVCS DCN DG DNB DNC DRP DRS EAL EBFS EDG EOP EP ESF FSAR ICCMS 1&0 IMC 1ST JPM LER LHRA LLRT LORT
MDAFW MOD mrem NCV NEI NOUE NRC OD
ODM OOS PARS
PCR PI PIM PI&R PM PMT RCA RCE RCP RCS RSST RVLM RWP Condition
Report Engineering
Disposition
Chemical and Volume Control System Design Change Notice Diesel Generator
Departure
from Nucleate BOiling Dominion Nuclear Connecticut
Division of Reactor Projects Division of Reactor Safety Emergency
Action Level Enclosure
Building Filtration
System Emergency .Diesel Generator
Emergency
Operating
Procedures
Emergency
Preparedness
Engineered
Safety Feature Final Safety Analysis Report Inadequate
Core Cooling Monitoring
System Instrumentation
and Control Inspection
Manual Chapter In-Service
Testing Job Performance
Measures Licensee Event Reports Locked High Radiation
Area Local Leak Rate Test Licensed Operator Requalification
Training Motor Driven Auxiliary
Feedwater
Motor Operated Disconnect
Switch millirem
Violation
Nuclear Energy Institute
Notice Of Unusual Event Nuclear Regulatory
Commission
Operability
Determinations
Operation
Decision Making Out Of Service Publicly Available
Records System Personnel
Contamination
Report Performance
Indicator
Plant Issues Matrix Problem Identification
and Resolution
Preventive
Maintenance
Post Maintenance
Testing Radiologically
Controlled
Area Root Cause Evaluation
Reactor Coolant Pump Reactor Coolant System Reserve Station Service Transformer
Reactor Vessel Level Monitoring
Radiation
Work Permit Attachment
RWST SOP SG SSFF SW TDAFW TS TSLHRA UFSAR WIP A-15 Refueling
Water Storage Tank Signi'ficance
Determination
Process Steam Generator
Safety System Functional
Failures Service Water Turbine Driven Auxiliary
Feedwater
Technical
Specification
Technical
SpeCification
Locked High Radiation
Area Updated Final Safety Analysis Report Work:-!n-Progress
Attachment
}}

Revision as of 17:58, 30 January 2019

IR 05000336/2009005, 05000423/2009005; October 1, 2009 - December 31, 2009; Millstone Power Station Unit 2 and Unit 3; Operability Evaluations; Refueling and Other Outage Activities; Event Follow-up
ML100341288
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 02/03/2010
From: Jackson D E
NRC/RGN-I/DRP/PB5
To: Heacock D
Dominion Resources
References
FOIA/PA-2011-0115 IR-09-005
Download: ML100341288 (52)


Text

UNITED NUCLEAR REGULATORY REGION 475 ALLENDALE KING OF PRUSSIA, PENNSYLVANIA February 3, 2010 Mr. David Heacock President and Chief Nuclear Officer Dominion Resources 5000 Dominion Boulevard Glen Allen, VA 23060-6711 MILLSTONE POWER STATION -NRC INTEGRATED INSPECTION REPORT 05000336/2009005 AND 05000423/2009005

Dear Mr. Heacock:

On December 31, 2009, the U.s. 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 January 13. 2010, with Mr. A. J. Jordan, and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's 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 NRC-identified finding and three self-revealing findings of very low safety significance (Green). Two of these findings were determined to involve violations of NRC requirements.

However, because of the very low safety significance and because they have been entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission.

ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrat'or, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at Millstone.

In addition.

if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report. with the basis for your disagreement, 10 the Regional Administrator.

Region I, and the NRC Senior Resident Inspector at Millstone.

The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

D. 2 In 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 be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,Mf. Donald E. Jacks ,Chief Projects Branch 5 Division of Reactor Projects Docket Nos. 50-336, 50-423 License Nos. DPR-65, NPF-49 Inspection Report 05000336/2009005 and 05000423/2009005

w/Attachment:

Supplemental Information cc Distribution via Listserv In 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 be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,IRA! Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Distribution w/encl: S. Collins, PA (R10RAMAll RESOURCE)

S. Shaffer. DRP, SRI M. Dapas, DRA (R10RAMAll RESOURCE)

B. Haagensen, RI D. Lew, DRP (R1DRPMAll RESOURCE)

J. Krafty. DRP. RI J. Clifford.

DRP (R1DRPMAll RESOURCE)

B. Haagensen, DRP. RI C. Kowalyshyn, OA D. Roberts, DRS (R1DRSMaii Resource)

L. Troclne, RI OEDO P. Wilson. DRS (R1DRSMaii RidsNRRPM Millstone D. Jackson, RidsNRRDor1Lp11-2 T. Setzer, DRP J. Heinly, DRP ROPreportsResource@nrc.gov B. Sienel, DRP SUNSI Review Complete:

__--=-TC;:..S=--

___ {Reviewer's Initials)

ML 100341288 DOCUMENT NAME: G:\DRP\BRANCH5\Reports\FinaI\Milistone IR2009005 Final .doc After declaring this document Official Agency Record" it will be released to the Public. To receive! a copy of this document, indicate in the box: "c" =Copy without a tt ac h men t}enc I osure "E" = C *th a tt ae h men V! "Nil =N o copy OPYWI ene osure OFFICE RI/DRP I RIIDRP I RIIDRP I I I NAME SShafferlTCS for TSetzerfTCSr DJackson/DEJ DATE 0202/10 02/02/10 02/03/10 OFFICIAL RECORD COPY

.,:1.", , ,.:. i' , Docket No.: License No.: Report No.: Licensee:

Facility:

Location:

",', Dates: Inspectors:

Approved by: U.S. NUCLEAR REGULATORY COMMISSION REGION I 50-336,50-423 DPR-65, NPF-49 05000336/2009005 and 05000423/2009005 Dominion Nuclear Connecticut, Inc. Millstone Power Station, Units 2 and 3 P. O. Box 128 Waterford, CT 06385 October 1,2009 through December 31,2009 S. Shaffer, Senior Resident Inspector, Division of Reactor ProJects (ORP) J. Krafty, Resident Inspector, DRP B. Haagensen, Resident Inspector, DRP D. Silk, Senior Operations Engineer, Division of Reactor Safety (DRS) G. Johnson, Operations Engineer, DRS T. Moslak. Health Physicist, DRS M. Modes, Senior In-Service Inspection Inspector, DRS Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Enclosure 2

SUMMARY OF FINDINGS

IR 05000336/2009005, 05000423/2009005;

October 1,2009 -December 31,2009; Millstone Power Station Unit 2 and Unit 3; Operability Evaluations;

Refueling and Other Outage Activities;

Event Follow-up.

The report covered a period of inspection by resident and region-based inspectors.

Four Green findings, two of which were non-cited violations (NCV), were identified.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process (SOP}." The cross-cutting aspect was determined using IMC 0305, "Operating Reactor Assessment Program." Findings for which the SOP 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, Green finding (FIN) was identified for Dominion's failure to take adequate precautions and adequately schedule maintenance on a Unit 2 operated disconnect (MOD) associated with the main transformer.

The maintenance on the MOD disrupted a switch connection and caused increaSing conductor temperatures, which forced Dominion to perform an unplanned shutdown of the Unit 2 reactor. Dominion has taken corrective action to modify the appropriate procedures and has entered this issue into their corrective action program (CR 351109). This finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations.

The inspectors performed a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined the finding was of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available.

Enforcement action did not apply because the performance deficiency did not involve a violation of a regulatory requirement.

Because this finding did not involve a violation of regulatory requirements, and has very low safety significance (Green), it has been identified as a finding (FIN). This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component.

because Dominion did not appropriately incorporate risk inSights and work scheduling of activities consistent with nuclear safety. H.3(a) (Section 1 R20) GreEm. A

Green.

self-revealing non-cited violation (NCV) of Millstone Technical Specification (TS) 6.8.1(a}. "Procedures." was identified for Dominion's failure to adequately implement procedures during partial draining of the reactor coolant system (RCS) in preparation for defueling the reactor. Dominion did not properly align the reactor vessel vent path prior to partially draining the RCS as required by Dominion procedure OP w 2301E, "Draining the RCS (ICCE)." Immediate corrective actions included stopping the drain down and verifying the valve alignment.

Dominion entered this issue into the corrective action program (CR 351853). This finding was more than minor because it was associated with the Human Peliormance attribute of the Initiating Events cornerstone, and affected the cornerstone objective to limit the likelihood of those events that challenge critical safety functions during shutdown operations.

Specifically, the operators failed to properly position 447 to vent to the reactor vessel during partial drain down of the reactor vessel. The inspectors determined the significance of this finding using NRC Inspection Manual Chapter 0609, Appendix "G," *Shutdown Operations Significant Determination Process." This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion failed to define and effectively communicate expectations regarding procedural compliance, and personnel follow procedures.

H.4(b) (Section 1R20)

Cornerstone: Mitigating

Systems

Green.

A Green, self-revealing finding (FIN) was identified for Dominion's failure to complete effective corrective actions for known degraded conditions associated with the VR-11 and VR-21 120-volt AC instrument power supplies.

This condition led to a loss of annunciators and declaration of a Notification of Unusual Event (NOUE) on November 15, 2009. Dominion took immediate action to expedite the installation of an uninterruptible power supply (UPS) for VR-11 and VR-21. This finding was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring capability of systems that respond to initiating events to prevent undesirable consequences.

The finding was determined to be of very low safety significance (Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. No violation of regulatory requirements occurred, because the annunciator system is safety related. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety Significance and complexity.

P.1(d) (Section 40A3)

Cornerstone: Barrier Integrity

Green.

The inspectors identified a Green, nonwcited violation (NCV) of Millstone Power Station Technical Specification (TS) surveillance requirement 4.3.3.8 for Dominion's failure to perform a channel calibration of the Unit 2 Inadequate Core Cooling Monitoring System (ICCMS) every 18 months. Dominion entered the issue into their corrective action program and concluded that the ICCMS was operable.

Dominion performed a risk assessment of the missed surveillance in accordance with TS 4.0.3, and determined that the completion of the surveillance could be delayed up to the 18 month surveillance interval without a significant increase in risk. This finding was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone.

and affected the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding)protect the public from radionuclide releases caused by accidents or events. Specifically, in 1997, Dominion incorrectly revised surveillance procedure SP 2407 A so that It no longer met the requirements of TS surveillance requirement 4.3.3.8. The inspectors determined the finding was of very low safety significance (Green) because it was associated with a fuel barrier of the Barrier Integrity cornerstone.

This finding did not have a cross-cutting aspect because the performance deficiency occurred in 1997, and was not indicative of current performance. (Section 1 R15)

REPORT DETAILS

Summary of Plant Status Millstone Power Station Units 2 and 3 began the inspection period operating at 100 percent power. On October 6,2009, Unit 2 was shutdown to begin refueling outage 2R19. Unit 2 -returned to 100 percent power on November 18,2009, and remained at or near 100 percent power for the remainder of the inspection period. On December 19, 2009, the Unit 3 reactor tripped due to a damaged main generator output breaker, and remained shutdown to repair the breaker thrQugh the remainder of the inspection period,

REACTOR SAFETY

Cornerstones:

Initiating Events, Mitigating Systems, and Barrier Integrity 1 R01 Adverse Weather Protection (71111.01 -1 sample) Seasonal Site Inspection

a. Inspection Scope

The inspectors reviewed the readiness of Unit 2 and Unit 3 for seasonal cold weather. The inspectors reviewed selected equipment, instrumentation, and supporting structures to determine if they were configured in accordance with Dominion's 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 Condensate Storage and Surge Tanks, and Refueling and Primary Water Storage Tanks. The inspectors also performed partial walkdowns of the Unit 3 Condensate Storage and Surge Tanks, Intake Structure ventilation, Main Steam Isolation Valve Building.

and heat tracing for safety related systems. The walkdowns were performed to verify completion of cold weather preparations.

Documents reviewed during the inspection are listed in the Attachment.

No findings of significance were identified.

1 R04 Eguipment Alignment (71111.04 5 samples) Partial System Walkdowns

a. Inspection Scope

The inspectors performed five partial system walkdowns during this inspection period. The inspectors reviewed the documents listed in the Attachment to determine the correct system alignment.

The inspectors performed a walkdown of each system to determine if the critical portions of the selected systems were correctly aligned in accordance with the 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 fonowing systems were reviewed based on their risk significance for the given plant configuration: Spent fuel pool cooling system on October 15, 2009; Unit 3 "An Service Water (SW) System while the "B" train was out of service (OOS) for planned maintenance on October 14, 2009; "B" Motor Driven Auxiliary Feedwater (MDAFW) Pump and the Turbine Driven Auxiliary Feedwater (TDAFW) Pump while the "A" MDAFW Pump was OOS for surveillance testing on November 9, 2009; "An Charging while the "6" train was OOS for surveillance testing on November 18, 2009; and "A" Emergency Diesel Generator (EDG) while the "6" EDG was OOS for planned maintenance on December 16,2009.

b. Findings

No findings of significance were identified.

1 ROS Fire Protection (71111.050 8 samples) a. l.n.§Qection Scope The inspectors performed walkdowns of eight fire protection areas. 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

.1 evaluated

the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures.

The inspectors 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:

  • Containment Building Elevation

-3', Zone C-1;

  • Containment Building Elevation

-22'-6", Zone C-1;

  • Containment Building Elevation 14'-6", ZOl1e C-1;
  • Containment Building Elevation 38'-6", Zone C-1;
  • North Containment Recirculation Cooler Cubicle, Fire Area ESF-2;
  • East Floor Area, Fire Area ESF-4; and * "An EDG Enclosure, Fire Area EG-3, Zone A.

b. Findings

No findings of significance were identified.

1 R06 Flood Protection Measures (71111.06 -2 sa mples) Underground Power gable

a. Inspection Scope

The inspectors inspected underground cable vault 3EMH*1, which contained, in part, the 4160 volt (V) cables for the "An & "c" SW pumps. The inspectors evaluated Dominion's protection of safety-related systems from subsurface vault conditions.

The inspectors performed a walkdown of the area, Interviewed the system engineer, and reviewed the insulation ratings of the 4160V cables. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 Internal Flooding

a. Inspection Scope

The inspectors reviewed the flood protection measures for the equipment in the Unit 2 direct current Switchgear and Battery Rooms. The inspectors evaluated Dominion's protection of safety-related systems from internal flooding conditions.

The inspectors performed a walkdown of the area, interviewed the system engineers, reviewed the internal flooding evaluation, and verified that the floor drain configuration remained consistent with those Indicated in the design basis and flooding documents.

Oocuments reviewed during the Inspection are listed in the Attachment.

b. Findings

No findings of significance were Identirred.

1 R08 Inservice Inspection (lSI) (71111.08 -1 sample)

a. Inspection Scope

The purpose of this inspection was to assess the effectiveness of the licensee's inservice inspection program for monitoring degradation of the reactor coolant system boundary and risk significant piping system boundaries.

The inspector assessed the inservice inspection activities using the criteria specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. One repair activity was reviewed.

consisting of the reactor coolant pump seal weld. to ensure that the welding activities and applicable non-destructive examination (NDE) was performed in accordance with ASME Code requirements.

the inspector reviewed for adequacy the root cause analysis for the pressure boundary leak related to the repair. The inspector reviewed the results of the automated visual test (VT) examinations of a sample of reactor vessel head penetrations.

The inspector reviewed licensee criteria for confirming visual examination quality and Instructions for resolving interference or masking issues to confirm they are consistent with 10 CFR 50.55a(g)(6)(ii)(0).

The inspector reviewed the records recording the extent of inspection for each penetration nozzle including documents which resolved interference or masking issues to confirm that the extent of examination meets 10 CFR 50.55a(g)(6}(ii)(0).

The inspector reviewed coverage achieved with no limitations in coverage recorded.

The inspector verified that the activities were performed In accordance with the requirements of 10 CFR 50.55a(g}(6)(ii)(D), and indications and defects, if detected, were dlspositioned in accordance with 10 CFR 50.55a(g)(6)(ii)(0).

The results of a number of ultrasonic examinations were reviewed.

The phased array examination of a diSSimilar metal weld was reviewed.

Although the steam generators were not examined by eddy current during this outage, the inspector reviewed the engineering justification for deferring the inspection, and compared the justification with Enclosure

.1 the results of the last eddy current inspection

of the steam generators.

The inspector verified that the basis for deferral met the NRC accepted Electric Power Research Institute (EPRI) Steam Generator management guideline recommendations.

inspector reviewed the dissimilar weld metal program using the guidance in NRC inspection procedure 71111.08P, and Temporary Instruction

("1"1) 172. The inspector determined what deviations from EPRI's Materials Reliability Program (MRP) 139 guidelines were planned, and the basis for the deviation.

The inspector reviewed the results of volumetric examinations utilizing the guidance in MRP-139 for volumetric examinations being performed during the outage. The inspector reviewed the phased array results of a number of welds to verify conformance with MRP-139, Sec. 5.1. The inspector verified conformance with the relief request for a weld overlay. The inspector verified that personnel performing the examination were qualified, and deficiencies were being appropriately dispositioned.

b. Findings

No findings of significance were identified.

1 R11 LicEmsed Operator Regualification Program (71111.11 -3 samples) Resident Inspector Quarterly Review (71111.11 Q -2 samples)

a. Inspection Scope

The inspectors observed simulator-based licensed operator requalification training for Unit 2 on December 4,2009, and for Unit 3 on November 19, 2009. 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 procedure OP-MP* 100-1000, "Millstone Operations Guidance and Reference Document." The inspectors compared simulator configurations with actual control board configurations.

The inspectors also observed Dominion evaluators discuss identified weaknesses with the crew and individual crew members, as appropriate.

Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 Biennial Licensed Operator Regualification

(71111.11 B-1 sample)

a. Inspection Scope

The following inspection activities were performed using NRC NUREG 1021, Revision 9, "Operator Licensing Examination Standards for Power Reactors," NRC inspection procedure 71111.11, "Licensed Operator Requalification Program," and 10 CFR 55. A review was performed of recent operating history documentation found in the inspection reports, Dominion's corrective action program, and the most recent NRC plant issues matrix (PIM) .. The inspectors also reviewed specific events from Dominion's corrective action program which indicated possible training deficiencies to verify that they had been appropriately addressed.

The three written examinations from 2008 and selected operating tests from the 2009 annual examination were reviewed for content, quality, and excessive overlap to ensure that these exams met the criteria established in the Examination Standards and 10 CFR 55.59. On October 9,2009, the results of the annual operating tests for 2009 were reviewed to determine if pass/fail rates were consistent with the guidance of NUREG-1 021, Revision 9, *Operator Licensing Examination Standards for Power Reactors," and NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process (SDP)." The review verified the following: Crew pass rates were greater than 80%. (Pass rate was 100%); Individual pass rates on the dynamic simulator test were greater than 80%, (Pass rate was 1 00%); Individual pass rates on the job performance measures of the operating examination were greater than 80%, (Pass rate was 96.5%); Individual pass rates on the written examination (2008) were greater than 80%, (Pass rate was 95.9%); More than 75% of the individuals passed all portions of the 2009 operating examination, (Pass rate was 96.5%); Crew pass rates were greater than 80%, (Pass rate was 100%); Individual pass rates on the dynamic simulator test were greater than 80%, (Pass rate was 1 00%); Individual pass rates on the job performance measures of the operating examination were greater than 80%, (Pass rate was 95.0%); Enclosure Individual pass rates on the written examination (2008) were greater than 80°10, (Pass rate was 95.4%); and More than 75% of the individuals passed all portions of the 2009 operating examination, (Pass rate was 95.0%). Observations were made of the Unit 3 dynamic simulator examinations and job performance measures (JPM) administered during the week of August 31,2009 for Operations Crew E and Administrative Crew E. These observations included facility evaluations of crew and individual performance during the dynamic simulator examinations and individual performance of JPMs. The: remediation plans for several Unit 2 and Unit 3 failures were reviewed to assess the effectiveness of the remedial training.

Eight Unit 3 Dominion reactivations were reviewed to ensure that Dominion conditions and applicable program requirements were mel. Five reactor operator records were checked to verify the maintenance of an active license. Simulator performance and fidelity were reviewed for conformance to the reference plant control room. Selected simulator deficiency reports were reviewed to assess Dominion prioritization and timeliness of resolution.

Simulator testing records were reviewed to verify that scheduled tests were performed.

A sample of records for requ8lification training attendance, program feedback, reporting, and six operator medical reports were reviewed for compliance with Dominion conditions, including NRC regulations.

Two reactor operators were interviewed to assess the operator's perspectives regarding training quality, incorporation of feedback, simulator performance, and examination difficulty.

b. Findings

No findings of significance were identified.

1R12 Maintenance

Effectiveness (71111.12Q.1 sample)

a. Inspection Scope

The inspectors reviewed Dominion's evaluation of degraded conditions, involving related structures, systems and components for maintenance effectiveness during this inspection period for the Unit 2 Enclosure Building Filtration System (EBFS). The inspectors reviewed Dominion's implementation of the "Maintenance Rule," 10 CFR 50.65. The inspectors reviewed Dominion's 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 paragraph (a)(1) or (a}{2), and the adequacy of the performance criteria and goals established for each system, as appropriate.

The inspectors also reviewed recent Enclosure system health reports, condition reports (CR), apparent cause determinations, functional failure determinations, operating logs, and discussed system performance with the responsible system engineer.

Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

'I R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 -4 samples)

a. Inspection Scope

inspectors evaluated online risk management for emergent and planned activities.

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 OOS 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 Dominion's risk management actions during plant walkdowns.

Documents reviewed during the inspection are listed in the Attachment.

The inspectors reviewed the conduct and adequacy of risk assessments for the following maintenance and testing activities: Shutdown risk assessment (Orange) during RCS drain down into reduced inventory operations for defueling on October 10, 2009; Shutdown risk assessment (Orange) during north bus outage on October 16, 2009; Shutdown risk assessment (Orange) during RCS drain down into reduced inventory operations and SI-306 valve repairs on October 26, 2009; and On-line risk assessment (Green) during maintenance on the "B" EDG and "B" Safety Injection pump on December 17,2009.

b. Findings

No findings significance were identified.

1 R15 Operability Evaluations (71111.15

-7 samples)

a. Inspection Scope

The inspectors reviewed seven operability determinations

{OD. The inspectors evaluated the ODs 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, system engineers, and design engineers.

Documents reviewed during the inspection are listed in the Attachment.

The inspectors reviewed seven operability determinations (00). The inspectors evaluated the ODs 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, system engineers, and design engineers.

Documents reviewed during the inspection are listed in the Attachment.

The inspectors reviewed the adequacy of the following evaluations of degraded or non-conforming conditions: Operational decision making (ODM) for CR 350860, "Generator Hydrogen Seal Failed Megger Test;" CR354434 dispositioning of a 5/8 inch bolt found in the reactor vessel; Condition Report Engineering Disposition (CRED) for CRs 355509 and 355455 for unrecoverable debris in fuel assemblies Y12. Y15, and Y35; ODM for CR352045. "B" Reactor Coolant Pump (RCP) electrical penetration M2SWX-A2-T1 failed locallaak rate test (LLRT) administrative limit; Engineering information record Document No. 51-9126147-00 which evaluates the effects of the thimble tubes being cut 1 inches shorter than designed; Channel "S" Wide Range Logarithmic Nuclear Instrument OOS for reactor startup; and CR359570 seven core exit thermocouples reading outside tolerance.

b. Findings

Introduction:

The inspectors identified a Green, non-cited violation (NCV) of Millstone Power Station Technical Specification (TS) surveillance requirement 4.3.3.8 for Dorninion's failure to perform a channel calibration of the Unit 2 Inadequate Core Cooling Monitoring System (ICCMS) every 18 months.

Description:

On November 15, 2009. condition report (CR) 358117 was submitted as a result of one of the retests for the incore thimble replacement modification.

The CR Enclosure identified that seven of the core exit thermocouples (CET) indicated 12 degrees higher than cold leg temperature (Tcold) while at hot zero power. These seven CETs also indicated 12 degrees higher than Tcold prior to the modification.

The inspectors reviewed the most recent surveillance performed and TS; interviewed the system engineer; and questioned whether the channel calibration required by the TS had been performed.

After review, Dominion concluded that the required channel calibration for the ICCMS, which includes the CETs, reactor vessel coolant level indication, and reactor coolant system subcooled/superheat monitor, had not been adequately performed since 1997. The apparent cause evaluation determined that surveillance procedure SP 2407 A was revised in 1997 to support new equipment that was installed under modification DCR M2**96-077, "Replacement Inadequate Core Cooling Monitoring System (ICCMS)." The surveillance was approved in accordance with existing Millstone procedures.

The new ICeMS system has input cards and an analog to digital (AID) card that must be adjusted separately.

The personnel involved with the procedure revision incorrectly assumed that adjusting the Digital and Analog Loopback and Calibration card, which adjusts the AID card, was all that was required for the calibration.

Dominion concluded that the seven individual CETs were inoperable, but the overall CET system remained operable since the number of remaining operable CETs per quadrant was greater than the TS required minimum. Dominion also concluded that the realr;tor vessel coolant level indication and reactor coolant system subcooled/superheat monitor were operable.

Dominion entered the issue into their corrective action program (CR 359247), and performed a risk assessment of the missed surveillance in accordance with TS 4.0.3, which determined that completion of the surveillance could be delayed up to the 18 month surveillance interval without a significant increase in risk. The! inspectors reviewed the risk assessment and verified that there was no unacceptable increase in risk.

Analysis:

The inspectors determined that Dominion's failure to provide an adequate calibration procedure for the ICCMS was a performance deficiency.

The cause was reasonably within Dominion's ability to foresee and correct, and should have been prevented.

Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of NRC Inspection Manual Chapter 0612, Appendix E, "Minor Examples," revealed that no minor examples applied to this finding. This finding was more than minor because it was associated wi,th the Procedure Quality attribute of the Barrier Integrity cornerstone, and affected the cornerstone's objective of providing reasonable assurance that physical design barriers (fuel cladding)protect the public from radionuclide releases caused by accidents or events. Specifically, in 1997, Dominion incorrectly revised surveillance procedure SP 2407 A, which caused them to no longer meHt the requirements of TS surveillance requirement 4.3.3.8 to perform a channel calibration of the Unit 2 ICCMS every 18 months. Enclosure 16 Thl3 inspectors performed a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined the finding was of very low safety significance (Green) because it was associated with a fuel barrier of the Barrier Integrity cornerstone.

This finding did not have a cross*cutting aspect because the performance deficiency occurred in 1997, and was not indicative of current performance.

Enforcement:

Millstone Power Station TS surveillance requirement 4.3.3.8 requires that a channel calibration of the ICCMS be performed every 18 months. Contrary to the above, from 1997 until December 2009, Dominion did not perform an adequate channel calibration of the ICCMS. Following discovery of the inadequate channel calibration, Dominion performed an overall assessment, including a risk assessment that concluded there was not a significant increase in risk by delaying completion of the surveillance until the procedure could be performed during the next refueling outage. Because this violation is of very low safety significance (Green). and has been entered into Dominion's corrective action program (CR 359247), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 0500033612009005-01, TS Surveillance Channel Calibration of ICCMS Not Performed)1 R18 Plant Modifications (71111.18 -2 samples)

a. Inspection Scope

To assess the adequacy of the modifications, the inspectors performed walkdowns of selected plant systems and components, Interviewed plant staff, and reviewed applicable documents, including procedures, calculations, modification packages, engineering evaluations, drawings, corrective action program documents, the UFSAR, and TS. Design assumptions were reviewed to verify that they were technically appropriate and consistent with the UFSAR. For each modification, the 10 CFR 50.59 sCrE3enings or safety evaluations were reviewed.

The inspectors also verified that procedures, calculations, and the UFSAR were properly updated 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 components would function properly.

Documents reviewed during the inspection are listed in the Attachment. Temporary modification to open 2-RW-27 in Mode 1 allowing for purification of the Refueling Water Storage Tank (RWST) via the spent fuel pool purification system; ;and Permanent modification to install variable frequency drive units on the circulating water pumps.

b. Findings

No findings of significance were identified.

R19 Post-Maintenance Testing (71111.19 -8 samples)

a. Inspection Scope

The inspectors reviewed post-maintenance test (PMT) activities to determine whether the PMT adequately demonstrated that the safetYwrelated 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 PMTs were evaluated: Automated Work Order (AWO) 53102300705 following Letdown Regenerative Heat Exchanger Outlet Temperature Loop (TI-221) testing and repair on November 11, 2009; AWO 53102302188 following Pressurizer Proportional Heater Controller testing and* repair on November 12, 2009; AWO 53102221324 following RCP vibration monitoring system testing and repair on November 16, 2009; AWO 53102258097 following 2-SW-97A "B" circulating water pump cross-tie valve testing and repair on November 22, 2009; AWO 53M20808798 following the "B" heater drain pump testing and repair on iDecember 2, 2009; SP 3646A.1, "EDG "A" Operability Test," Revision 18 following maintenance on the jacket water and electrical systems on December 1,2009; SPROC lave ReductionNalve Wide Open Test (ICCE)," Revision 000-01 as a result of the stretch power uprate on December 2, 2009; and SP 3630A.6-002. "Reactor Plant Component Cooling Water Pump 3CCP*P1 C Group "An Test," Revision 012 following pump bearing replacement on December 16,2009.

b. Findings

No findings of significance were identified.

1 R20 Refueling and Other Outage Activitie§ (71111.20 -1 sample) Millstone Unit 2 Refueling Outage (2R19)

a. Inspection Scope

Dominion began refueling outage 2R19 on October 6, 2009, and completed the outage on November 18, 2009. The inspectors evaluated the outage plan and outage activities to determine if Dominion had considered risk, developed risk reduction and plant configuration control methods, considered mitigation strategies in the event of loss of safety functions, and adhered to licensee and TS requirements.

The inspectors observed portions of the shutdown.

cooldown.

heat up and start up processes.

Additionally.

the inspectors performed an initial containment Mode 3 walk down to eVl:lluate the as-found condition of containment.

The inspectors also performed a final Mode 3 walk down to ensure that no loose material or debris, which could be transported to the containment sump, were present. The inspectors reviewed eRs to determine if conditions adverse to quality were entered for resolution.

Documents reviewed for the inspection are listed in the Attachment.

Some of the specific activities the inspectors observed and performed included:

  • Reactor shutdown and cool down;
  • Reactor water level drain down to the reactor flange;
  • Midloop and reduced inventory operations;
  • Reactor head lift;
  • Fuel handling, core loading, and fuel element assembly tracking;
  • Containment as-found walk down:
  • Review of outage risk plan;
  • Circulating Water pump "A" replacement;
  • In-core instrument thimble replacement;
  • RCS vacuum fill;
  • Containment as-left walk down;
  • Reactor Heat up;
  • Reactor Start up;
  • low Power Physics Testing;
  • Reactor power ascension; and
  • Unit 2 Generator synchronization to the grid. Enclosure

===.1

b. Findings

Implementation===

of Design Change Results in an Unplanned Shutdown of Reactor

Introduction:

A self-revealing.

Green finding (FIN) was identified for Dominion's failure to take adequate precautions and adequately schedule maintenance on a Unit 2 operated disconnect (MOD) associated with the main transformer.

The maintenance on the MOD disrupted a switch connection and caused increasing conductor temperatures.

which forced Dominion to perform an unplanned shutdown of the Unit 2 reactor.

Description:

On October 6,2009, with Unit 2.at 100 percent power, Dominion maintenance personnel began implementing design change notice (DCN)09 to install a rain guard intended to prevent water intrusion into the motor of the MOD for 15G-2X 1-4. While decoupling the vertical drive shaft of the MOD, a shift in the disconnect switch occurred.

This resulted In arcing on the disconnect switch and increasing surface temperatures.

Continued operation in this condition could have resulted in failure of the switch which in turn would have caused a reactor trip. Due to this condition, an unplanned shutdown of Unit 2 was performed.

MOlDs constructed of this design are known to occasionally have tension remaining post closure of the switch. and decoupling of the shaft can result in shifting of the switch. This is what occurred on October 6, 2009 when Dominion attempted to perform maintenance on the MOD. The Dominion root cause evaluation (RCE) determined the root cause to be a programmatic failure to identify and manage risk related to 345 kilovolt (kV) work. A significant contributing factor was an inadequate process for identification and management of risk during the design change process (implementation of the DCN). The RCE states in part. "CM-AA-RSK-1 001, Engineering Risk Assessment, has inconsistent guidance for evaluating potential for engineering error. In addition.

guidance is entirely subjective for evaluation of potential consequence of engineering failure." The weakness of procedure CM-AA-RSK-1001 resulted in the DCN not receiving the additional reviews that elevated risk switchyard work would normally get. The additional reviews would have added additional precautions, potential scope of work changes, and postponement of the work for a few days at which point Unit 2 would have been offline for a planned refueling outage.

Analysis:

The inspectors determined that Dominion's failure to adequately manage the risk to plant stability associated with the installation of the DCN was a performance deficiency.

The cause was reasonably within Dominion's ability to foresee and correct. and should have been prevented.

Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence.

had no willful aspects, nor did it impclct the NRC's ability to perform its regulatory function.

.2 A review of NRC Inspection

Manual Chapter 0612, Appendix E, "Minor Examples," revealed that no minor examples applied to this finding. This finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations.

Specifically, Dominion did not adequately assess and manage the risk involved in implementing DCN DM2-00-093-09, which resulted in the need to perform an unplanned shutdown of the Unit 2 reactor on October 6,2009. The inspectors performed a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined the finding was of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available.

This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Dominion did not appropriately incorporate risk insights and work scheduling of activities consistent with nuclear safety. H.3(a)J

Enforcement:

No violation of regulatory requirements occurred, because the MOD switch and the main transformer are non-safety related. Dominion has taken corrective action to modify the appropriate procedures, and has entered this issue into their corrective action program(CR 351109). Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory Because this finding does not involve a violation of regulatory requirements, and has very low safety significance (Green), it is identified as a finding (FIN). (FIN 05000336/2009005-02 Implementation of Design Change Results in an Unplanned Shutdown of Reactor) RCS Drain Down Loss of Configuration Control

Introduction:

A Green, self-revealing NCVof Millstone Technical Specification (TS) . 6.8.1 (a),

was identified for Dominion's failure to adequately implement procedures during partial draining of the reactor coolant system (RCS) in preparation for defueling the reactor. Dominion did not properly align the reactor vessel vent path prior to partially draining the RCS as required by Dominion procedure OP-2301 E, "Draining the RCS (ICCE)."

Description:

On October 1 0, 2009, Dominion performed a partial drain*down of the fueh3d reactor vessel to the radioactive waste processing system in preparation for removing the reactor vessel head and defueling the reactor. The reactor vessel vent path was not properly established because manual valve 2-RC-447 had been mispositioned (locked shut instead of locked open) during the valve line-up for the evolution.

Without an open vent path in the reactor vessel, the vessel inventory was not reduced when the ReS was being drained. When the RCS mid-loop wide range level instruments (LT-112 and lI-112) came on scale at +99 inches, the reactor vessel level monitoring system (RVLM) still indicated that the reactor vessel level was greater than +135 inches. The operators stopped the RCS drain down evolution and determined that Enclosure

vent path had not been properly aligned to the reactor vessel in accordance with Dominion procedure OP-2301E-005, "Preferred RCS Vent Path Alignment." Upon investigation, Dominion discovered that they did not align valve 2-RC-447 to vent the reactor vessel head during the RCS drain down in preparation for defueling the reactor. This resulted in the reactor vessel remaining full of water while the pressurizer and steam generator tubes were being drained. Operators failed to immediately realize that RCS level indication did not accurately reflect the level in the reactor vessel. This condition constituted a loss of positive control during the RCS drain down.

Analysis:

The inspectors determined that Dominion's failure to properly align a vent path to the reactor vessel in accordance with Dominion procedure OP-2301 E-005, "Preferred RCS Vent Path Alignment," was a performance deficiency.

The cause was reasonably within Dominion's ability to foresee and correct, and should have been prevented.

Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of NRC Inspection Manual Chapter 0612, Appendix E, "Minor Examples,*

revealed that no minor examples applied to this finding. The finding was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective to limit the likelihood of those events that challenge critical safety functions during shutdown operations.

Specifically, the operators failed to properly position 2-RC-447 to vent to the reactor vessel during partial drain down of the reactor. The inspectors determined the significance of this finding using NRC Inspection Manual Chapter 0609, Appendix "G," "Shutdown Operations Significant Determination Process." The issue was determined to be of very low safety significance (Green) because the OpE:lrators performed continuous RCS inventory balances during the drain down, and toolk prompt appropriate corrective action as soon as a level deviation became apparent between the RCS level instruments (LT-112 and U-112) and the in-core RVLMs heated core thermocouples.

Immediate corrective actions included stopping the drain down and verifying the valve alignment.

This finding had a crossoocutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion failed to define and effectively communicate expectations regarding procedural compliance, and personnel follow procedures.

H.4(b) ,

Enforcement:

Millstone TS 6.8.1 (a) "Procedures,*

requires, in part, that written procedures be established, implemented and maintained covering the activities described in Appendix "A" of NRC Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)." Section 2.k requires general plant operating procedures for, "Preparation for Refueling and Refueling Equipment Operation." Draining the RCS in preparation for defueling the reactor was required to be accomplished using Section 4.2 of Dominion procedure OP-2301 E, "Draining the RCS (ICCE)." Contrary to the above, Dominion did not correctly implement procedure OP-230'1 E-005 to establish the Enclosure 22 correct valve line-up for draining the ReS. This resulted in a loss of positive control over ReS level during a risk significant evolution.

Because this violation is of very low safety significance (Green), and has been entered into Dominion's corrective action program (CR 351853), it is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000336/2009005-03 ReS Drain Down Loss of Configuration Control) 1 R22 Surveillance Testing (71111.22 -2 samples)

a. Inspection Scope

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 briefings, 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 als() 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: SP-2613G Routine Surveillance Integrated Test of Facility 1 Components (ICCE) Loss of Normal Power; and VPROC ENG09-2-011 Integrated Leak Rate Test of Containment.

b. Findings

No findings of significance were identified.

2. RADIATION

SAFETY Cornerstone:

Occupational Radiation Safety 20S1 Access Control to Radiologically Significant Areas (71121.01

-11 samples)

a. Inspection Scope

During the period November 2, 2009 and November 5, 2009, the inspectors performed the Following activities to verify that Dominion was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas (LHRA) and other radiological controlled areas (RCA), and that workers were adhering to these controls when working in these areas during the Unit 2 refueling outage (2R19). Enclosure Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, Unit 2 TS, and Dominion's procedures.

This inspection activity represents completion of eleven samples relative to this inspection area. Plant Walkdown and Radiation Work Permit (RWP) Reviews During the Unit 2 refueling outage, the inspectors identified exposure significant work areas in the Unit 2 reactor building containment, fuel handling building, and auxiliary building.

The inspectors reviewed radiation survey maps and RWPs associated with these areas to determine if the radiological controls were acceptable; The inspectors performed independent surveys of selected areas in the Unit 2 containment building and auxiliary building to confirm the accuracy of survey maps, the adequacy of postlngs, and that technical specification locked high radiation areas (TSLHRA) were properly secured and posted. Areas in containment surveyed included:

the SG cubicles, radwaste storage areas, pressurizer relief tank, access port to under vessel area, and RCP areas; In evaluating RWPs, the inspectors reviewed electronic dose/dose rate alarm set points to determine if the set points were consistent with survey indications and plant policy. The inspectors verified that workers were knowledgeable of the actions to be taken when a dosimeter alarms or malfunctions for tasks being performed under selected RWPs. Work activities reviewed included scaffolding removal. insulation installation, and upper guide structure transfer; and The inspectors reviewed Personnel Contamination Reports (PCR), airbome sampling results, personnel dosimetry data, and whole body counting results to assess the effectiveness of airborne monitoring and contamination controls.

The inspectors also reviewed the associated dose assessment for a worker who fell into the spent fuel pool during pre-outage preparations.

The inspectors determined that no intake of radioactive material resulted in an internal dose exceeding 10 mrem. Jobs-in-Progress Review The inspectors observed the preparations and various work stages for several tasks including containment demobilization and transfer of the reactor upper guide structure into the reactor vessel, fuel assembly transfers, and in service inspections.

The inspectors observed various aspects of these activities from the centralized monitoring system (CMS) to determine if remotely monitored work area dose rates and worker dose, and the coordination of activities by the CMS staff, were adequately communicated to the workers. High Risk Significant.

High Dose Rate Controls The inspectors reviewed the preparations made for various potentiaJly high dose rate jobs and the resulting dose assessments to determine if exposure monitoring was effective in controlling personnel exposure.

Tasks reviewed included the transfer of the upper guide structure back into the reactor vessel, alloy 600 inspections/

mitigation, and the thimble tube replacement; 24 The inspectors inventoried keys to TSLHRA stored at the Unit 2 Control Point to verify that Dominion accounted for all keys. During tours of Unit 2, the inspectors verified that locked high radiation areas (LHRA) were properly secured and posted; and The inspectors verified that Unit 2 LHRAs in containment, such as the regenerative heat exchanger and under vessel area, were properly secured and posted and that surrounding area dose rates and postings met regulatory criteria.

Radiation Worker and Radiation Protection Technician Performance Several radiologically related CRs and PCRs were reviewed to evaluate if the incidents resulted from repetitive worker errors and to determine if an observable pattern traced to a similar cause was evident; During site tours, radiation protection technicians and radworkers were questioned regarding their knowledge of plant radiological conditions and controls associated with their jobs. Additionally.

the inspectors observed radiation protection technicians effectively control and coordinate in-containment tasks by using the centralized remote monitoring system; and The inspectors reviewed field observation reports made by the Nuclear Oversight staff to determine the degree in which the independent department was actively engaged in critically monitoring worker performance during 2R19.

b. Findings

No findings of significance were Identified.

20S2 ALARA Planning and Controls (71121.02

-7 samples) a. Inspection SCQDe During the period November 2,2009 through November 5,2009, the inspectors performed the following activities to verify that Dominion was properly implementing opElrational, engineering, and administrative controls to maintain personnel exposure as low as reasonably achievable (ALARA) for tasks performed during the Unit 2 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Dominion's procedures.

This inspection activity represents completion of seven samples relative to this inspection area. Radiological Work Planning The inspectors reviewed pertinent information regarding Unit 2 outage exposure history. current exposure trends, and ongoing activities to assess current performance and outage exposure challenges.

The inspectors determined the site's three-year rolling collective average exposure and compared it to current trends; The inspectors reviewed the refueling outage work scheduled during the outage period and the associated work activity exposure estimates.

Scheduled work Enclosure included thimble tube cutting, alloy 600 inspections, valve maintenance, fuel assembly transfers, fuel transfer system up-ender upgrades, and various support activities.

The inspectors compared the current actual dose accrued for these tasks with the initial exposure estimates; Additionally, the inspectors reviewed the ALARA Reviews (AR), Work-In-Progress (WIP) ARs, ALARA challenge board presentations, and ALARA pre-job briefing materials that addressed estimating and controlling dose for other outage activities.

Jobs reviewed included:

insulation removal and installation, scaffolding removal and installation, reactor disassembly, pressurizer heater replacement, and boric acid inspections.

WIP ALARA reviews were evaluated for boric acid corrosion control inspections, alloy 600 inspection and mitigation, health physics outage support, pressurizer heater replacement, and temporary shielding installation; The inspectors evaluated the effectiveness of exposure mitigation requirements specified in RWPs and associated ALARA reviews. Jobs reviewed include reactor vessel disassembly (RWP 302, AR 2-09-01), thimble tube replacement (RWP 406, AR 2-09-35), pressurizer heater replacement (RWP 401, AR 2-09-29), insulation removal and installation (RWP326, AR 2-09-14), and scaffolding removal and installation (RWP 331, AR 2-09-13); The inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems.

The evaluation was accomplished by reviewing recent ALARA Council meeting minutes and ALARA challenge board presentations.

The inspectors also attended daily outage status meetings to assess interdepartmental coordination and communications; and Through job site observations and radiation survey measurements, the inspectors determined if work activity planning included the use of temporary shielding.

system flushes, and operational considerations (Le. scheduling work when SGs were fIlled to further minimize worker exposure).

The inspectors reviewed temporary shielding effectiveness measurements and performed independent measurements on various system components in the reactor building and auxiliary building work areas to determine if temporary shielding was appropriately used. Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for the annual site collective 19xposure and the Unit 2 refueling outage dose projection; and The inspectors reviewed Dominion's exposure tracking system to determine whether the level of dose tracking detail, exposure report timeliness, and distribution was sufficient to support the control of outage project exposures.

Included in this review were departmental dose assessments and individual dose records. Job Site Inspection and ALARA Controls The inspectors observed activities performed in containment including valve inspections/repairs, upper guide structure transfer, and scaffolding

& shielding demobilization.

The inspectors verified that the appropriate radiological controls Enclosure 26 were implemented including briefings, radiation protection technician coverage, contamination mitigation, proper dosimetry, and that workers were knowledgeable of radiological conditions.

Source Term Reduction and Control The inspectors reviewed the current status and historical trends of the Unit 2 source term. Through interviews with the Radiation Protection, Chemistry Manager, and the ALARA Supervisor, the inspectors evaluated Dominion's source term measurements (Le. reactor coolant system piping dose rates and control strategies).

The inspectors reviewed reactor coolant chemistry data to evaluate the effectiveness of post shutdown source term reduction efforts. Specific strategies being employed included:

use of macro-porous cleanup resins, system flushes, installation of temporary shielding, use of temporary filtration system, and chemistry controls.

Radiation Worker Performance The inspectors observed radiation worker and radiation protection technician performance for selected tasks. Tasks observed included containment demobilization activities, and reactor re-assembly.

The inspectors determined that the individuals were aware of radiological conditions and access controls that applied to their tasks; and The inspectors reviewed eRs, related to radiation worker and radiation protection technician errors, and PCRs to determine if an observable pattern traceable to a common cause was evident. Declared Pregnant Workers The inspectors determined that one declared pregnant worker was employed to perform outage related activities in the radiological controlled areas. The inspectors verified that the individual's exposure was appropriately monitored, per procedural requirements, and controlled to meet regulatory criteria.

Problem Identification and Resolution The inspectors reviewed elements of Dominion's corrective action program related to implementing the radiological controls program to determine if problems were being entered into the program for resolution.

Included in this review were relevant eRs, Nuclear Oversight field observation reports, and a program audit.

b. Findings

No findings of Significance were identified.

OTHER ACTIVITIES

lOA] Performance Indicator (PI) Verification (71151 -4 samples) Cornerstone:

Mitigating Systems Inspection Scope 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 Performance Indicator Guideline," Revision 5, were used to verify the basis for reporting each data element. The inspectors reviewed portions of the operations logs, monthly operating reports, and LERs, and discussed the methods for compiling and reporting the Pis with cognizant licensing and engineering personnel.

Documents reviewed during the inspection are listed in the Attachment.

  • Safety System Functional Failures (SSFF) [MS06]; Unit
  • SSFF [MS05J. Findings No findings of significance were identified . . Occupational Exposure Control Effectiveness

[OR01] Inspection Scope The inspectors reviewed implementation of Dominion's Occupational Exposure Control Effectiveness Performance Indicator Program. Specifically, the inspectors reviewed CRs, and associated documents for occurrences involving locked high radiation areas, very high radiation areas, and unplanned exposures.

The PI definitions and guidance contained in Nuclear Energy Institute

{NEI} 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used to verify the basis for reporting each data element. This inspection activity represents the completion of one sample relative to this inspection area. completing the annual inspection requirement.

No findings of significance were

.3 RETS/ODCM

Radiological Effluent Occurrences

[PR01]

a. Inspection Scope

The inspectors reviewed relevant effluent release reports for the period October 1, 2008 through October 30, 2009, for issues related to the public radiation safety performance indicator, which measures radiological effluent release occurrences that exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ dose for liquid effluents; 5 mrads/qtr gamma air dose; 10 mrads/qtr beta air dose; and 7.5 mrads/qtr organ dose for gaseous effluents.

The PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used to verify the basis for reporting each data element. This inspection activity represents the completion of one sample relative to this inspection area, completing the annual inspection requirement.

No findings of significance were identified.

40A2 Identification and Resolution of Problems (71152 -5 sam pies)

.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 follow-up, the inspectors performed a daily screening of items entered into Dominion's corrective action program. This was accomplished by reviewing the of each new CR and attending daily management review committee meEltings.

The Inservice Inspection program inspector reviewed a sample of corrective action reports related to problems in Inservice Inspection in order to determine if problems wen3 identified and corrected in a timely fashion. The inspector determined the nonconforming conditions identified were reported, characterized, evaluated and appropriately disposed of commensurate with their importance to safety. Documents reviewed during the inspection are listed in the Attachment.

No findings of significance were identified.

.2 Ogerator WorkwAround

(2 samples)

a. Inspection Scope

The inspectors reviewed the current listing of operator work-arounds for Units 2 and 3. The review was performed to verify that Dominion procedures and practices provided necessary guidance to plant personnel, that the cumulative effects of the known operator work-arounds were addressed, and that the overall impact on the affected systems were assessed.

The inspectors independently assessed the cumulative impact of known operator work-arounds to determine if they adversely affected the ability of operators to implement operating procedures (both normal and off-normal)and respond to plant transients.

In support of this assessment, the inspectors reviewed various eRs regarding operatorwork-arounds and verified that work-a rounds were being identified.

tracked, and resolved in accordance with Dominion's corrective action program. This inspection effort represented one sample for Unit 1 and one sample for Unit 2. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

and Opservations No findings of significance were identified.

The inspectors determined that operator work-arounds were adequately classified, tracked, and assessed in accordance with Dominion procedures, and that the cumulative impact of the work,.arounds did not adversely impact the ability of the operators to implement the operating procedures . . 3 Semi-Annual Problem Identification

& Resolution (PI&R) Trend Review (1 sample)

a. Inspection Scope

As required by Inspection Procedure 71152, the inspectors performed a review of the Dominion corrective action program and associated documents to identify trends that may indicate existence of safety significant issues. The inspectors review was focused on repetitive equipment and corrective maintenance issues, but also considered the results of daily inspector corrective action program item screening.

b. Findings and Observations

No findings of significance were identified.

The inspectors review determined that the trend reports reviewed adequately captured the site's negative trends. The inspectors noted that the trend reports were revised, based on the inspectors comments from the previous semi-annual trend review, to include a listing of open adverse trends. The inspectors also noted that two long term trends and a few recurring issues that were listed in the second quarter report were not listed in the third quarter report and there was no discussion of the resolution of these items. Enclosure

.4 Annual Sample -Omission of a Nondestructive

Evaluation Examination on Replacement Valve 3SIH*V028 in the Safety Injection System (1 sample)

a. Inspection Scope

The inspector reviewed the corrective action related to ACE 017370. The licensee Identified the omission of a nondestructive evaluation examination on the installation of replacement valve 3SIH*V028 in the safety injection system.

b. Findings and Observations

A field change, implementing an ASME Code Case, did not take into account the jurisdictional change in the edition of the ASME Code referred to in the Code Case. Earlier editions of the Code, including the edition in force during the outage, did not require an examination of piping below a nominal size of four inches. However, ASME Code Case N-416-3 was invoked which requires examinations in conformance with the 1992 Edition of the Code. This edition changes the examination lower limit to two inches nominal pipe size. The nondestructive examinations were undertaken in a timely fashion after the omission was identified.

No indications were found as a result of the examinations. Event Follow-up (71153 -2 samples) . . Unit 2 Notification Of Unusual Event Classification (NOUE) -Loss of Control Room Annunciators

a. Inspection Scope

On November 15,2009, at 8:11 a.m .. Unit 2 experienced a loss of all control room annunciators lasting greater than 15 minutes while operating in Mode 5 (cold shutdown).

The shift manager classified the event at the level of a Notification of Unusual Event (NOUE). An electrical transient caused non-vital 120 volt AC Instrument busses, VR-11 and VR-21 , to cycle repeatedly on and off. which caused the power supply to the main control board annunciators to lose power and lock out. The operators took immediate action in accordance with AOP-2504A, "Loss of VR-11, nand AOP-2504B, of VR-21." The electrical transient was initiated when the "S" heater drain pump was started for post maintenance testing following an overhaul of the motor. In addition to the loss of annunciators, a letdown isolation occurred, and the operators secured the charging and letdown systems. A NOUE was declared at 8:26 a.m. after 15 minutes had elapsed without power to the annunciators.

At 8:33 a.m., I&C technicians reset the annunciator power supply, and all main control board annunciators were restored to service. The crew determined that all safety functions were met. The NOUE declaration was subsequently terminated at 8:58 a.m. The inspectors responded to the control room and evaluated the adequacy of operator actions in accordance with approved procedures and TS irnplications.

The inspectors 31 penformed walk downs and interviewed personnel to verify that the plant was stable, and that the annunciators had been restored to service. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

Introduction:

A Green, self-revealing finding (FIN) was identified for Dominion's failure to complete effective corrective actions for known degraded conditions associated with the VR-11 and VR-21 120-volt AC non-vital instrument power supplies.

Specifically, 11 and VR-21 were known to cycle on and off repeatedly whenever an electrical disturbance on the grid affected the input supply voltages from their respective regulating transformers.

The degraded condition on the instrument buses had not been corrected despite prior opportunities.

This condition led to a loss of annunciators and declaration of a Notification of Unusual Event (NOUE) on November 15, 2009.

Description:

On November 15, 2009, Millstone Unit 2 was operating at 60 percent power when VR-11 and VR-21 began to rapidly turn on and off (power cycling) for approximately one minute. This rapid power cycling started when a fuse was being replaced in the "S" heater drain pump, which created an electrical ground condition.

The rapid fluctuation of power to the non-safety instrument buses resulted in a Chemical and Volume Control System (CVCS) letdown isolation, and the rapid flashing of all main board annunciators.

The regulated power supply for the main board annunciators subsequently deenergized and caused a loss of annunciation in the control room for 21 minutes. The operators responded by entering Abnormal Operating Procedure (AOP) 2504A (and AOP-2504S), "Loss of VR-11 (VR-21 )," which directed isolating the charging system and stabilizing the plant. The Shift Manager entered the station emergency plan and declared a NOUE when the annunciators had remained in a non-functional state for 15 minutes in accordance with Emergency Action Level (EAL) EU-3, "Loss of Annunciators." The probable cause of the event was the degraded power cycling response of VR-11 and VR-21 to an electrical disturbance.

This vulnerability of VR-11 and VR-21 to electrical disturbances had most recently been identified on July 3, 2009, when an offsite grid disturbance caused VR-11 and VR-21 to exhibit a similar degraded system response.

The original problem with VR-11 and VR-21 had been first identified and entered into the corrective action process as early as 2001. The long-term corrective action for this adverse condition was to power VR-11 and VR-21 from a large uninterruptible power supply (UPS) to prevent the rapid power cycling between the normal and alternate power supplies.

To date, this has not been implemented.

This corrective action has been scheduled for implementation in February 2010. Previous interim corrective actions had included disabling the normal supply regulated transformer supplies UAC1 and UAC2, temporarily removing some loads from VR-11 and VR-21 , and installing small UPS power supplies on isolated circuits, all of which did not prevent the November 15, 2009 event. Previously, grid disturbances on June 28, 2008, February 2, 2009, April 30, 2009, and July 3, 2009 continued to challenge the Unit 2 operator's ability to operate the plant Enclosure because of degraded system responses from the cycling of and VR w 21 during these events. These actions included main feedwater regulating valve lockup, isolation of tl1e letdown system, unexpected steam dump response, and automatic startup of all three charging pumps. In each case, the previous interim corrective actions were ineffective in preventing VR w 11 and VR-21 from rapidly cycling and disrupting plant system equipment alignments.

Despite the ineffectiveness of the short term corrective actions, Dominion did not complete the long-term corrective action to install a UPS as the normal power source for VR-11 and VR-21 by the end of the refueling outage 2R19.

Analysis:

The inspectors determined that Dominion's failure to effectively implement interim corrective actions to prevent recurrence of the power cycling of VR-11 and 21 was a performance deficiency.

The cause was reasonably within Dominion's ability to foresee and correct, and should have been prevented.

Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of NRC Inspection Manual Chapter 0612, Appendix E, Examples," revealed that no minor examples applied to this finding. The finding was more than minor be.cause it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring capability of systems that respond to initiating events to prevent undesirable consequences.

The main board annunciators provide operators with critical notification and assessment capability during plant upset or transient conditions.

Annunciators are used to direct operators to appropriate alarm response procedures, which further direct operators to AOPs and direct entry conditions into EOPs. Annunciators also provide early warning to operators of adverse trends in key plant parameters before the degradation becomes sig nificant.

The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1 Initial Screening and Characterization of Findings." The finding was determined to be of very low safety Significance (Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety Significance and complexity.

[P.1 (d)]

Enforcement:

No violation of regulatory requirements occurred, because the annunciator system is non-safety related. Dominion took immediate action to expedite the installation of the UPS for VR-11 and VR-21. Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement.

Because this finding does not involve a violation of regulatory requirements, and has very low safety significance (Green), it is identified as a finding (FIN). (FIN 05000336/2009005-04 Inadequate and Untimely Corrective Actions Causes Loss of Annunciators and Declaration of a NOUE) Enclosure

.2 Unit 3 Main Generator

Ground Fault

a. Inspection Scope

On December 19, 2009 at 22:53, Millstone Unit 3 tripped from 100 percent power during a significant snow storm. A generator protection and main generator leads ground fault resulted in a turbine/generator trip with subsequent reactor trip and fast transfer to the Reserve Station Service Transformer (RSST). All safety systems responded as expected.

Relays 59NL-3SPUB1 0 anq 59NH-3SPUB17 actuated on detecting a severe ground fault condition as measured through the main generator neutral. The relays opened the main generator output breakers and isolated the fault from the main generator to the generator output breaker. This resulted in a main turbine and reactor trip. After a time delay, the 59NB-3SPLIB 17 relay actuated, indicating a fault on the transformer side of the breaker, opening Unit 3 normal offsite power supply breakers, 13T and 14T, and causing a fast transfer to the reserve offsite power supply. Walkdowns determined that the "e" phase of the main generator output breaker was damaged. Unit 3 later entered Technical Specification Action Statement 3.0.3 for 73 minutes when snow plugged the filter for the Engineered Safety Feature (ESF) building emergency ventilation, making all safety-related pumps in the ESF building inoperable.

The inspectors responded to the control room and evaluated the adequacy of operator actions in accordance with approved procedures and TS implications.

The inspectors performed walk downs and interviewed personnel to verify that the plant was stable, Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

40A5 Other Activities Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors performed observations of security force personnel and activities to ensure that the activities were consistent with site security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours. These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

Findings No findings of significance were identified.

40A6 Meetings, including Exit Exit Meeting Summary On January 13, 2010, the resident inspectors presented the overall inspection results to Mr. A. J. Jordan and members of his staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.

ATTACHMENT:

=SUPPLEMENTAL

INFORMATION=

Licensee personnel

E. Annino G. Auria B, Barron B. Bartron P. Baumann H. Beemon R. Borchardt

R. Carey C. Chapin A. Chyra T. Cleary G. Closius L. Crone J. Dorosky A. Elms M. Finnegan G. Gardner A. Gharakhanian

M. Gobeli W. Gorman J. Grogan C. Houska A. Jordan C. Janus J. Kunze B. Krauth J. Laine M. Lalikos P. Luckey R. MacManus M. Marino C. Maxson M. O'Connor L. Perry R. Riley M. Roche J. Semancik A. Smith S. Smith J. Spence P. Strickland

S. Turowskj A-1 SUPPLEMENTAL

KEY POINTS OF Dominion Licensing

Nuclear Chemistry

Supervisor

Manager, Nuclear Oversight

Supervisor.

licensing

Manager, Security Supervisor.

Nuclear Engineering

Consulting

Engineer, Reactor Engineering

Consulting

Engineer, ILRT, Inc. Supervisor, Nuclear Shift Operations

Unit 2 Nuclear Engineer.

PRA Licensing

Engineer Licensing

Engineer Supervisor, Nuclear Chemistry

Health Physicist

III Manager, Nuclear Engineering

Supervisor, Health Physics, ISFSI Dominion Engineering

Nuclear Engineer III Nuclear Engineer III Supervisor.

Instrumentation

& Control Assistant

Operations

Manager I&C Technician

Site Vice President

Nuclear Engineer III Supervisor, Nuclear Operations

Support Licensing, Nuclear Technology

Specialist

Manager. Radiation

Protection/Chemistry

ISIINDE Engineering

Manager, Emergency

Preparedness

Director, Nuclear Station Safety & Licensing

VFD Modification

Project Manager Director, Engineering

Manager, Operations

Dominion lSI Supervisor, Nuclear Shift Operations

Unit 3 Senior Nuclear Chemistry

Technician

Plant Manager Asset Management

Manager, Engineering

Manager, Training VFD Modification

Test Director Supervisor, Health Physics Technical

Services Attachment

M. VanHalter

Dominion Engineering

M. Vezzina Dominion lSI C. Voumazos IT Specialist, Meteorological

Data R. West Dominion Engineering

J. Williams Dominion lSI LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed 05000336/2009005-01

NCV -TS Surveillance

Channel Calibration

of ICCMS Not Performed. (Section 1 R15)

FIN -Implementation

of Design Change Results in an Unplanned

Shutdown of Reactor. (SecUon 1 R20)

NCV -RCS Drain Down loss of Configuration

Control. (Section 1R20)

FIN -Inadequate

and Untimely Corrective

Actions Causes loss of Annunciators

and Declaration

of a NOUE. (Section 40A3) LIST OF DOCUMENTS

REVIEWED Section 1 R01: Adverse Weather Protection

COP 200.13, "Cold Weather Preparations," Revision 003-00 OP 2331, "Plant Heating and Condensate

Recovery System, n Revision 006-09 OP 3314G, "Intake structure

Ventilation," Revision 009-06 OP 3352, "Heat Tracing," Revision 013-05 Section 1 R04: Equipment

Alignment

OP 3304A-001, "MB3 Charging and Letdown lineup," Revision 005-03 OP 3304A-003, *Charging

and letdown lineup," Revision 013 OP 3322-001, "TDAFW Pump and Components

Common to Both Trains," Revision 007 OP 3322-003, "Auxiliary

Feedwater

Train "B,"" Revision 006-05 OP 3322-005, "Electrical

Checklist

for Auxiliary

Feedwater

System," Revision 006-01 OP 3326-001, "Train "A" Service Water System," Revision 009-03 OP 3326-003, "RPCCW "An Service Water System Supply," Revision 004-01 OP 3326-009, "Service Water System -Control Building Air Conditioner "AU Supply," Revision 007-01 OP 3326-013, "ESF Building Emergency

Ventilation "An SW System Supply," Revision 008-01 OU-AA-200, "Shutdown

Risk Management," Revision 0 OP 2264, Attachment

2, Shutdown Safety Assessment

Checklist

for October 14 and 15, 2009 Attachment

Section 1 R05: Fire Protection

Millstone

Unit 2 Fire Hazards Analysis, Revision 9 Millstone

Unit 2 Fire Fighting Strategies, April 2002 Millstone

Unit 3 Fire Protection

Evc;tluation

Report, Revision 16 Millstone

Unit 3 Fire Fighting Strategies, April 2002 Section 1 R06: Flood Protection

Measures W2-517-1070RE, PMiIIstone

Unit 21ntemal Flooding Evaluation," Revision 0 Qualification

Documentation

for Kerite 5KY and 8KV HTK, Shielded FR Jacketed Power Cables dated August 13, 1980 Engineering

Memorandum

No. 223 dated May 4, 1977 25203-ER-99-0170, "Millstone

Unit 2 Plant Drains and Flood Protection," Revision 0 25203-11003, "Paving, Drainage and Fencing Plan Details," Revision 11 25203-20152

Sheet 372, "Area Drains -Aux Bldg, Drains to Collection

TK-T-43," Revision 0 25203-24018

Sheet 1, "Area Floor Drains Aux. Bldg E

I. 14'-6", Revision 2 25203-24028, "Area Drains -Auxiliary

Building Plan E

I. 14'-6" and EI. 25'-6", Revision 11 98-ENG-02411-C2, "Millstone

Unit 2 Evaluation

of Flooding Outside Containment," Revision 001-01 Section 1 R08: .nservice

Inspection

Condition

Report Engineering

Di§position

Form Form DE2-DT-0473-09

dated 7/16/09 Root Cause Evaluation

Reports RCE000983, 'A' RCP RBCCW Cooling Leak, Millstone

Unit 2,7/28/09

RCE000981, 'N Reactor Coolant Pump Seal Leakage, Millstone

Unit 2, Procedures "Radiographic

Examination

Procedure

for ASME Boiler and Pressure Vessel Code RT010,>> Revision 001-01,9/8/09

Procedure

PI-AA-200, Revision 8, "Corrective

Action Process" NDE Examination

Reports (Data Liquid Penetrant

Data Sheet. ECW 1, 2, 3, 4 Seal Cooler, dated 7/15/09

Liquid Penetrant

Data Sheet, ECW 2 Seal Cooler, dated 7/15/09

Liquid Penetrant

Data Sheet, ECW 2 Seal Cooler partial exam, dated 7/15/09

Liquid Penetrant

Data Sheet, ECW 1, 3, 4 Seal Cooler, dated 7/15/09

Liquid Penetrant

Data Sheet, ECW 3 Seal Cooler, dated 7/15/09

Liquid Penetrant

Data Sheet, ECW 3 re-exam Seal Cooler, dated 7/15/09

Liquid Penetrant

Data Sheet, ECW 1,2,4 Seal Cooler, dated 7/15/09

Radiographic

Report M2-2453, A RCP seal cooler leak repair, 7/17/09 (info report Radiographic

Report M2-2452, A RCP seal cooler leak repair, 7/16/09 (info report Ultrasonic

Data Package 218-01-035

RCS Zone Ultrasonic

Data Package

Ultrasonic

Data Package 218 w 01-045 RCS Zone Ultrasonic

Data Package 218-01-048

RCS Safety Injection

Sht 44Weld Ultrasonic

Data Package 218-01-086

RCS Surge Nozzle Weld Attachment

Ultrasonic

Data Package 218-01-087

RCS Shutdown Cooling Weld Overlay Ultrasonic

Data Package 218-01-090

AWO M2-06-10388

Field Weld 3 Repair-Replacement

Work Order Weld Data and Inspection

Map -WO 53102266944, 9116/09 Miscellaneous

Documents

Dominion Letter 07-0555, "Millstone

Unit 2, Alternate

Request RR-89-01, Use of Weld Overlays as an Alternative

Repair and Mitigation

Technique." NRC Letter," MILLSTONE

POWER STATION, UNIT NO.2-RELIEF

REQUEST RR-89-61, REVISION 2, REGARDING

THE USE OF WELD OVERLAYS AS AN ALTERNATIVE

REPAIR (TAC N

O. ME1765)" Dominion Letter (no number) to ASME,Section XI, dated 7/30/09; "Examination

Requirements

Following

Defect Removal and Weld Repair, IWA-4422.2.2 (e) and IWA-4520 (1998 Edition with the 2000 Addenda)" Dominion Letter 09-ZZZ to ASME,Section XI, dated 8/11/09; "Examination

Requirements

Following

Defect Removal and Weld Repair, IWA-4422.2.2 (e) and IWA-4520 (1998 Edition)" ASME,Section XI Letter 09-1315 dated 8/17/09; "ASME BPVC Section XI, IWA-4422.2.2(e)

and IWA-4520, 1998 Edition with the 2009 Addenda" Dominion Letter 09-474, dated 9/22109; DOMINION NUCLEAR CONNECTICUT, INC. MILLSTONE

POWER STATION UNIT 2 ALTERNATE

REQUEST RR-89-67 FOR THE P40A RCP SEAL COOLER RETURN TUBING Section 1R11: Licensed Operator Regualification

Program Requalification

Program Procedures/Documents

ANSI/ANS-3.4-1983, Medical Certification

and Monitoring

of Personnel

Requiring

Operator Licenses for Nuclear Power Plants

ANSIIANS-3.5-1998, Nuclear Power Plant Simulators

for Use in Operator Training and Examination

Training Program Procedures

Licensed Operator Requalification

Training (LORT), TPD-7.080, Revision 12, Change 2 Millstone

Unit 3 LORT, S09702L, Revision 0 Developing, Administering, and Evaluating

Operator Training Written Examination

Materials, NTP 122.1, Revision 5 Developing

and Conducting

Job Performance

Measures, NTP 146, Revision 001-01 Operator Training Examination

Security, NTP 122.4, Revision 002-01 Conducting

simulator

Training and Examinations, NTP 144, Revision 005 Licensed Operator Biennial and Annual Operator Requalification

Exam Process, TR-M-730, Revision 0 Development, TR-M-300, Revision 1 Millstone

Unit 3 Written Exam Sample Plan 2007/2008

Licensed Operator Requalification

{LORT)/STA

Program 2009 LORT Annual Operating

Test Sample Plan Attachment

Simulator-Related

Documentation

Nuclear Simulator

Engineering

Manual, NSEM-6.06

Simulator

Scenario Based Testing Transient

Test 8, Maximum size LOCA with a Loss of Normal Off site Power Transient

Test 10, Slow RCS Depressurization

to Saturated

Conditions

Using PORV Stuck Open Steady State Tests <<50%, <100%, & 100%) DR-200B-30073

DR-2009-3-0027

DR-2009-3-0031

DR-2009-3-0037

Job Aid Millstone

Unit 2 LORT Operational

Exercise #1 (809501) Job Aid Millstone

Unit 3*LORT*S09404L

Root CausE1 Evaluation (RCE) 000235, Automatic Reactor Trip Millstone

Unit 3 CACC000275, Training to Review Simulator

Model CACC00286, RCE Contributing

Cause Action Follow-up

Assignment

CAPR 000350, Millstone

Unit 3 Automatic Reactor Trip Simulator

Exercise Guide Plant Startup Training JIT03-08-007

Condition

Reports CR-08-07476

CR-08-08278

CR113512 CR325620 CR327201 CR329044 CR330334 NRC Inspection

Report 05000423/2009002

NRC Inspection

Report 05000423/2008004

NRC Inspection

Report 05000423/2008005

Operational

Exercise #2 (S09702) Section 1R12: Maintenance

Effectiveness

EOP2532, Loss of Coolant Accident, Revision 29 SP2609E, "EBFS Negative Pressure Test," Revision 009-01 EBFS Hearth Reports, 1st quarter 2008 and 3rd quarter 2009 PRA memo NE-97-SAB-199

Memo NSE-02-073

ACE17402, "The nAil EBFS filter bed L29A test results are UNSAT" RCE000984, "EBFS Negative Pressure Test Failed Acceptance

Criteria" MRE010273

MRE0108H MRE010866

MRE010875

MRE010883

MRE010886

MRE010952

MRE011396

MRE011510

CR321622, "EBFS filter bed L29A test results are UNSAT" dated January 28,2009 CR340306, "2-MS-247

Lower Discharge

Pipe Seal Torn" dated July 4,2009 CR341915, "SP2609E EBFS Negative Pressure Test, failed acceptance

criteria for Z1 and Z2" dated July 19, 2009 Section 1R13: Maintenance

Risk Assessments

and Emergent Work Control OP2264 Attachment

2, "Shutdown

Safety Assessment

Checklist" dated October 14, 2009 OP2264 Attachment

3, High Risk Evolution

Contingency

Plan -A305 Racking Mechanism

Replacement" dated October 12, 2009 .OP-2264 Attachment

2, "Shutdown

Safety Assessment

Checklist

dated October 26,2009 Orange Risk for SI-306 valve repairs" SPROC OPS09-2-02

CR356180, "Implementation

of Orange Risk Color in EOOS for the RSST OOS at Millstone

Unit 2" dated November 3, 2009 Section 1 R15: Operability

Evaluations

Engineering

Information

Record Document No. 51-9126147-00

EVAL-ENG-RSE-M2C20, Revision 1 NIS-01-C, "Nuclear Instrumentation

System," Revision 3 Control Room Log dated November 16, 2009 Night Shift CR358159, ""8" WR NIS Source Range Counts is reading 5.2E04, other channels reading 2 CPS" dated November 15, 2009 CR358117 CR358896 CR359247 CR359570

CR 352045 ACE017934, "Apparent

missed surveillance

Unit 2 TS Table 4.307 items 3, 10, 12 Channel Cal" Section 1R18: Plant Modifications

DCN DM2-00-0200-09

OCR M2-08003 Circulating

Water Pumps Variable Frequency

Drives -Phase II OP 23058 "RWST Purification," Revision 000-01 OP 2305 "Spent Fuel Pool COOling and Purification

System," Revision 021*01 SPROC ENG09-2-001, "Unit 2 Variable Frequency

Drive," Revision 002 dated October 26, 2009 Drawing 25203-26008

SH1, "Circulating

Water," Revision 80 CR354682, "VFD Enclosure

  1. 2 is leaking rain water" dated October 24, 2009 CR354727, "VFD terminal boards not labeled" dated October 25,2009 CR354953, "Potential

for unexpected

Unit 2 Cire pump trip during light bulb replacement" dated October 26, 2009 CR355372, "Rain Water Leaking into Unit 2 VFD PDC Enclosure

  1. 1 & #2 & Unit 3 Enclosure
  1. 1 &#3" dated October 28,2009 CR355466, "Unit 2 VFD failed cell" dated October 29, 2009 CR355519, "Procedure

change needed to OP2315N" dated October 29,2009 Attachment

CR357133, "Deficiencies

identified

while performing

VFD SPROC on "A" Cire Water uncoupled

pump" dated November 8, 2009 CR357264, "Failures

of one portion of testing for "A"&"D" VFDs" dated November 9, 2009 Section 1 R.19: Post Maintenance

Testing AW0531 02296942, 'Inspect and Repair Letdown Outlet Temperature

Loop." Revision 0 dated November 2, 2009 AWO 53102258097, "Determ/Reterm

2-SW-97A to support valve replacement" dated November 4, 2009 AWO 53102301247, "1'1-109, Pressurizer

Vapor Space reading incorrectly" dated November 9,2009 AW0531 02300705, "Perform Post Maintenance

Test on T221 Regen Hx Out," Revision 0, dated November 11, 2009 AWO 53102302188, "Pressurizer

Proportional

Heater Controller

Failed to Furl Power Output" dated November 12, 2009 AWO 53102306805,

Replace Pump Bearings and Mechanical

Seals" AWO 53M20803550, "PMT for Pzr Proportional

Heater Controller

Failure," dated November 13, 2009 AW053M20808798, ""B" Heater Drain Pump Oil Leak" OP2264 Attachment

3, "High Risk Evolution

Contingency

Plan, Replacement

of 2-SW-97 A" dated October 7, 2009 CR356091, "Section of OP2326A to return 2-SW-97 A to automatic

operation

does not work" dated November 2, 2009 CR356126. "Service Water valve

does not operate properly from the control room" dated November 2, 2009 CR357016, "Perform Post Maintenance

Test on TI-221, Regen Hx Outlet Loop" dated November 7, 2009 CR357154, "TI-109, Pressurizer

Vapor Space Temperature

reading incorrectly" dated November 9, 2009 CR357623, "Pressurizer

Proportional

Heater Controller

Failed to Full Power Output" dated November 11, 2009 CR358310, "Hex head bolts were installed

for cap screws during installation

of 2SW-97A" dated November 16, 2009 CR358905, "liB" Heater Drains Pump Motor, P3BM has two vibration

measurement

points in ALERT" dated November 19, 2009 CR358939, "Oil leak on "B" heater drain pump upper motor RTD tap" dated November 20, 2009 CR359987, "JITT associated

with Downpower

for "B" Heater Drain Pump Cancelled" dated November 30,2009 CR360018. "Overhaul

of Unit 2 P3BM heater drain pump motor results as they pertain to the "An motor" dated December 1. 2009 CR360274, "No process to create EPIX assignment

for a certain ER clock reset type" dated December 2, 2009 Section IR20: Refueling

Outage OP 2203. "Plant Startup," Revision 018-08 OP 2323

A. "Turbine," Revision 023-01 OP 2324A, "Turbine Generator

and Exciter," Revision 016-04 ARP 2590E-241, Revision 000-01. "Generator

Ground Fault" dated June 22,2004 Attachment

Control Room Log dated November 4, 2009 Day Shift Control Room Log dated November 8, 2009 Night Shift CVC-OO-C, "Chemical

and Volume Control System," Revision 8.3 Drawing M2 86001650, Revision 1, "In-Core Instrument

Installation

Arrangement" dated August 28, 1998 Drawing M2 86001648, "In-Core Instrument

Arrangement" dated November 14, 1986 OP-2264, "Conduct of Outages," Revision 012-02 dated September

23, 2009 OP-2301 E, "Draining

the RCS (ICC E), " Revision 024-03 dated October 8, 2009 OP-2301E-005, "Preferred

RCS Vent Path," Revision 003-03 dated October 8,2009 OP-2301 G "Vacuum Fill of the Reactor Coolant System (lCCE)," Revision 001-00 dated October 7,2009 SP2613G, "Integrated

Test of Facility 1 Components (ICCE)," Revision 012-00 dated October 9,2009 RR-89-67, "Dominion

Alternative

Request for the P40A Seal Cooler Return Tubing" dated September

2,2009 RAC 05 Attachment

Reportabllity

Determination

CR34582, "EDG Timer Failure" dated October 30,2009 CR345382, "Timer TC065 failed and need to be replaced" dated August 19, 2009 CR351372, "Millstone

Unit 2 Containment

Ambient Temperatures

Appear Significantly

Hotter during Entry dated October 6, 2009 CR351389, "Under voltage protection

bypassed in Modes 4 and 5 per AWO" dated October 7, 2009 CR351395, "Calculated

RCS cooldown rate exceeded

T.S. limit of 50 degrees/hour" dated October 7, 2009 CR351429, "Breaker B0111 opened after closing the cross tie buses 22A and 22B" dated October 8, 2009 CR351435, "Unable to obtain closed indication

for 2-FW-51A during MSI push button test" dated October 8,2009 CR352180, "DCN DM2-S-1622-92

does not meet B31.1 Design Code requirements

for min wall" dated October 12,2009 CR353193, "Workers started to open inspection

flange -service water inspection

on the operable header" dated October 17, 2009 CR353396, "Refuel Machine stopped operating

while performing

load tests" dated October 19, 2009 CR353540, "Unexpected

responses

from refuel machine during fuel movement" dated October 19, 2009 CR353569, "Adverse Trend in GSI-191 Debris Identified

in Millstone

Unit 2 Containment" dated October 19, 2009 CR353571, "Refuel Machine Hoist Issues during 2R19 Core Offload" dated October 19, 2009 CR353580, "Containment

Upender Discrepant

Conditions" dated October 20,2009 CR353588, "Containment

Upender Improvement

Recommendations" dated October 20, 2009 CR353590, "Spent Fuel Pool Upender Improvement

Recommendations" dated October 20, 2009 CR353725, "Loose debris detected on Rx Head" dated October 20, 2009 CR353732, "Unacceptable

Final Weld Inspection" dated October 20,2009 CR353775, "DV-10 Supply Breaker 00105 reclosed automatically

after opening" dated October 20,2009 Attachment

CR353779, "Bus 24C under voltage cleared on ESAS "A" Sensor Cabinet while restoring power" dated

October 20,2009 CR353812, "Breaker 00108 will not stay

when tripped" dated October 21, 2009 CR353990, "Limited GSI-191 Margin for Bare Concrete in Unit 2 Containment" dated October 21, 2009 CR354040, "EDG Timer Failure has the Potential

for Affecting

EDG Operability" dated October 21, 2009 CR354059, "Loss of 120 VAC Vital Bus VA-30" dated October 21,2009 CR394693, "Outage Planning Lessons Learned" dated October 25, 2009 CR354694, "Orange Substance

dripping down condenser

hotwell southeast

corner dated October 25, 2009 CR354719, "A" SGFP Vapor Extractor

Flange Over tightened

Causing Irreparable

Damage" dated October 25,2009 CR354784, "Relay RA107 as-found calibration

results were outside acceptance

range for RPS" dated October 25,2009 CR35478S*, "Relay RA 108 as-found calibration

results were outside acceptance

range for RPS" dated October 25,2009 CR354833, "Relay RA027 as-found failure"'dated

October 25,2009 CR354839, "Non tech spec limit not satisfied

for DB1-201A during quarterly

surveillance" dated October 26,2009 ' CR354841, "Discrepancy

on data sheet for Battery Quarterly

Surveillance" dated October 26, 2009 CR354962, "Clarification

requested

for RCE000983

-"N' RCP RBCCW Cooling Leak" dated October 26. 2009 CR355006" "Thimble Tube Project stub ends cut shorter than design documents" dated October 27. 2009 CR355043, "Valve installed

backwards

during reassembly

of EDG UN' SW piping" dated October 26,2009 CR355097, "Flexitallic

gasket material in, RCS could impact SG tube integrity" dated October 26. 2009 CR355127, "Missing bolts on Millstone

Unit 2 refueling

machine" dated October 27,2009 CR355133, "NOD audit 09-15; Possibility

of explosive

mixture in WGDT during Millstone

Unit 2 start-up" dated October 27, 2009 CR355182, "Empcenter

Potential

Deviations

require Prompt Dept. Review" dated October 26,2009 CR355350" ''A AFW pump failed to develop required discharge

pressure during surveillance" dated October 28, 2009 CR355352" Potential

OCFR26 work hour rule infraction

-requires prompt review and records" datE3d October 27. 2009 CR355379, "Lessons Learned enhancement

to Rx Head Shroud Lift/Lower

per MP2704N' dated October 29,2009 CR355387,. "MS-190A.

  1. 1 ADV will not open from C05 or the Foxboro screen" dated October 29,2009 CR355387. "MS-190A would not open during repeat surveillance" dated October 31, 2009 CR355388, "#1 AFW Flow indicator

FI-5277 A 1 is reading approximately

gpm with NO FLOW" dated October

29, 2009 CR355455, "One piece of Flexitallic

material found in top nozzle of fuel assembly Y-35" dated October 29,2009 Attachment

CR355726, "2-SI-306

SDC Total flow control not configured

correctly

for remote operation" dated October 31, 2009 CR355770, SW valves 2-SW-9A and 2-SW-10B would only open 20 percent" dated November 1, 2009 CR355792, "Unit 2 RSST trip test had UNSAT results for SLOD trouble alarm at 909 panel" dated October 31, 2009 CR355797, "Failed "A" EDG Starting Air Valves 1ST (SP2624A-001)" dated November 1, 2009 CR355825, "Old computer room air conditioning

work not proceeding" dated November 1, 2009 CR355843, "Computer point values

are out of tolerance" dated November 1, 2009 CR355849, "Procedure

Change Required for SP-2624A and SP-2624B" dated November 1, 2009 CR355915, "Relay Located inside "A" Diesel Generator

Control Panel is cycling" dated November 1, 2009 CR355946, "As found condition "A" circulating

water pump P6A Plug support column" dated November 2, 2009 CR355948, "FOSAR inspection

of Millstone

Unit 2 Reactor Lower Core Support Plate reveals debris" dated November '1, 2009 CR355990, "DB1-201A

battery has 5 cells with low specific gravity" dated November 2, 2009 CR356039, "3 Turbine Battery Cells have low specific gravity" dated November 2, 2009 CR356077, "Poor workmanship

on valve assembly" dated November 2, 2009 CR356091, "Section of OP2326A to return 2-SW-97 A to automatic

operation

does not work" dated November 3,2009 CR356101, "Unexpected

Results when starting "A" Train RBCCW" dated November 3,2009 CR3561 07, "OP-2264, Conduct of Outages needs a complete re-write" dated November 2, 2009 CR356310, "Non-QA Tendon Access Drain Piping Support Welded to ASME XI AFW Piping Support" dated November 3, 2009 CR356314, "Disposition

of CR119843 closed out without addressing

original issue" dated November 3, 2009 CR356385, "Main Board Annunciator

C08 A22 came in during EHC calibrations" dated November 4, 2009 CR357078, "Temporary

PPC Alarms Set for Unheated Thermocouples

Nulled out Database Alarms" dated November 8, 2009 CR357123, 'liB" Charging Pump tripped following

start during performance

of OP-2301 G" dated November 8, 2009 CR357137, "RWST to CVCS Stop Valve, 2-CS-028 is missing from SP-2601 B-001 " dated Nov'ember

9, 2009 CR357300, "Procedure

changes needed for consistency

and human factors" dated Nov'ember

8, 2009 CR357459, "Current Measurements

needed as a design input to VR-11 and VR-21 Upgrade Project" dated November 10, 2009 CR357766, Millstone

Unit 2 Circ Water Pump Shaft Vibration" dated November 12, 2009 CR358723, 'liB" AFW Pump Discharge

Check Valve leak by" dated November 19, 2009 CR358872, "ODM Required for VR11/21" dated November 19,2009 CR359527, "Trend of wiring discrepancies

during "Redlining" checks for design Changes OP-230'1 E, "Preferred

RCS Vent Path Alignment," Revision 003-03 dated October 8, 2009 OP-2301, "Draining

the RCS (ICGE)" Revision 024-03, dated October 8, 2009 Attachment

ACE 017848, "Valve 2-RC-447 not aligned for RCS drain down," Revision 1 dated October 14, 2009 Control Room Log dated October 10, 2009 -day shift Drawing M2107-08-99, Revision 0 9900025 Figure 12 "Shutdown

Cooling Operations" CR359925, "Millstone

Unit 2 Reactor Trip breakers #4 and #5 needed to be manually reset" dated November 25, 2009 Section 1R22: Surveillance

Testing SP-2613G, "Integrated

Test offacility

Components (ICCE)," Revision 012-00 dated October 19, 2009 SP-2613G-001, Facility 1 ESF Integrated

Test Data Sheet" dated October 15, 2009 MP-24-APPJ-FAP01, "Integrated

Leak Rate Test (ILRT) Process" dated January 1, 2008 VPROC ENG09-2-011, "Containment

Integrated

Leak rate test Type "A" (ICCE)

MP2)," Revision 000-01 dated November 4,2009 CR352069, "Transitions

between ESF and LNP Test needs to be managed better" dated October 14, 2009 CR357519, "Temporary

Valve at Penetration

  1. 75 Bound Up" dated November 11,2009 CR357521, "Penetration

discharge

valve handwheel

shear pin broke during depressurization" dated November 11, 2009 CR357575, "Near miss safety concern on ILRT job" dated November 11. 2009 CR357586, "Lessons Learned -ILRT Delayed by Temporary

Butterfly

Valve Did Not Fully Open n dated November 11, 2009 Section 2081/2082:

Access to Radiologically

Significant

Areas/ALARA

Planning and Controls Occupational

Radiation

Safety RPM 1.3.8, Revision 8, Criteria for DOSimetry

Issue RPM 1.3.12, Revision 8, Internal Monitoring

Program RPM 1.3.13, Revision 8, Bioassay Sampling and Analysis RPM 1.3.14, Revision 7, Personnel

Dose Calculations

and Assessments

RPM 1.4.1, Revision 7, ALARA Reviews and Reports RPM 1.4.2, Revision 2, ALARA Engineering

Controls RPM 1.4.4, Revision 2, Temporary

Shielding

RPM 1.5.2, Revision 4, High Radiation

Area Key Control RPM 1.5.5, Revision 4, Guidelines

for Performance

of Radiological

Surveys RPM 1.5.6, Revision 3, Survey Documentation

and Disposition

RPM 1.6.4, Revision 3, Siemens Electronic

DOSimetry

System RPM 2.1.1, Revision 5, Issuance and Control of RWPs . RPM 2.1.2, Revision 2, ALARA Interface

with the RWP Process RPM 2.4.1, Revision 6, Posting of Radiological

Control Areas RPM 2.1

Revision 11, Air Sample Counting and Analysis RPM 5.2.2, Revision 10, Basic Radiation

Worker Responsibilities

RPM 5.2.3, Revision 3, ALARA Program and Policy RPM-GDL-008, Revision 0, Electronic

Dosimeter

Alarm Set Points RP-AA-123, Revision 0, Effective

Dose Equivalent

RPM 2.5.8, Revision 3, Stay Time Tracking and Multi-Badging

for Special Work Attachment

Condition

Reports 350246,355487,353560, 353464,353129,352736, 350044,346984, 322470, 334712, 331243,336978,340510,349141,356318,356317

2R19 ALARA Challenge

Board/Council

Meeting Presentations

Alloy 600 Inspections/Mitigation

Boric Acid Response Team Activities

Refueling

Team Activities

Source Term Reduction

Thimble Tube Replacement

Valve Maintenance

Team Activities

2R19 ALARA Dose Goal Approval Nuclear Oversight

Department

Reports/Audit

Audit 09-08, Radiation

Protection/Process

Control Program/Chemistry

Field Observation

Reports for 2R19 Nuclear Oversight Monthly

Reports to Site Vice President

ALARA Reviews 2-09-01, Reactor Disassembly/Reassembly

2-09-04, Fuel Movement 2-09-05, lSI Weld Inspections

& Boric Acid Corrosion

Control Program w 09-07, Boric Acid Corrosion

Control Inspections

2-09-09, Mechanical

PM/CMs & Minor Maintenance

2-09-11, Valve Maintenance

2-09-13, Scaffold Installation

& Removal 2-09-14, Insulation

Removalllnstallation

2-09-15, Shielding

Installation

2-09-35, Thimble Tube Cutting Miscellanec'us

Reports Millstone

Unit 2 Source Term Data Dose & Dose Rate Alarm Reports for the period May 1, 2009 through November 5, 2009 Monthly Gaseous and liquid Effluent Release Reports October 2008 through September

2009 Personnel

Contamination

Reports 2R19 Thimble Tube Replacement

Dive Plan (WCP-09-001)

Personnel

Dosimetry

Data . Section 40A1: Performance

Indicator (PI) Verification

The PI definitions

and guidance contained

in Nuclear Energy Institute (NEI) 99-02, "Regulatory

Assessment

Performance

Indicator

Guideline," Revision 5, were used to verify the basis for reporting

each data element. LER 05000336/2009-001-00

LER 05000336/2009-002-00

LER 05000423/2008-001-00

LER 05000423/2008-002-00

LER 05000423/2008-003-00

LER 05000423/2008-004-00

LER 05000423/2008*005*00

LER 05000423/2008-006-00

LER 05000423/2009-001-00

Section 40A2: Identification

and Resolution

of Problems Dominion Nuclear Trend Report Millstone

Station tid Quarter 2009 Dominion Nuclear Trend Report Millstone

Station 3rd Quarter 2009 Millstone

Operator Work Around, Burdens and Distractions, November 10.2009 Millstone

Operator Work Around, Burdens and Distractions, November 10, 2009 OP-AA-1700, "Operations

Aggregate

Impact," Revision 2 CR117074 CR337891 Section 40A3: Event Follow-up

EN 45498 "Millstone

Unit 2 Declared an Unusual Event due to a Loss of Annunciators" dated November 15, 2009 Event Review Team Report "Millstone

Unit 2 Unexpected

Loss of Annunciators

November 15. 2009 CR358168" dated October 17, 2009 Incident Report Form 2009062 dated November 15. 2009 Incident Report Form 2009063 dated November 15. 2009 OP-AA-100

Control Room Log, Day Shift dated November 15, 2009 Post Trip Review Report, Millstone

2/19/09, Main Generator

Ground Fault CR 362549 CR358168, "Unexpected

Loss of Annunciator

System" dated November 15,2009 CR358185, Foxboro DCS System Trouble Alarm Received during Plant Transient" dated November 15, 2009 CR358297, VR11/21 Power Cycling on November 15,2009 caused various Foxboro valve control Issues" dated November 16. 2009 CR362549 Event Review Team Report "Millstone

Unexpected

loss of Annunciators," dated November 15, 2009 CR358168, "Unexpected

loss of annunciator

system," dated November 15, 2009 LIST OF ACRONYMS AC Alternating

Current AD Analog to Digital ADAMS Agencywide

Documents

Access and Management

System AOP Abnormal Operating

Procedures

ALARA As Low As Reasonably

Achievable

AR ALARA Review ASME American So'ciety of Mechanical

Engineers

BPVC American Society of Mechanical

Engineers

Boiler and Pressure Vessel Code AWO CET CFR

CMS CR Automated

Work Order Core Exit Thermocouples

Code of Federal Regulations

Central Monitoring

System Condition

Report Attachment

CRED CVCS DCN DG DNB DNC DRP DRS EAL EBFS EDG EOP EP ESF FSAR ICCMS 1&0 IMC 1ST JPM LER LHRA LLRT LORT

MDAFW MOD mrem NCV NEI NOUE NRC OD

ODM OOS PARS

PCR PI PIM PI&R PM PMT RCA RCE RCP RCS RSST RVLM RWP Condition

Report Engineering

Disposition

Chemical and Volume Control System Design Change Notice Diesel Generator

Departure

from Nucleate BOiling Dominion Nuclear Connecticut

Division of Reactor Projects Division of Reactor Safety Emergency

Action Level Enclosure

Building Filtration

System Emergency .Diesel Generator

Emergency

Operating

Procedures

Emergency

Preparedness

Engineered

Safety Feature Final Safety Analysis Report Inadequate

Core Cooling Monitoring

System Instrumentation

and Control Inspection

Manual Chapter In-Service

Testing Job Performance

Measures Licensee Event Reports Locked High Radiation

Area Local Leak Rate Test Licensed Operator Requalification

Training Motor Driven Auxiliary

Feedwater

Motor Operated Disconnect

Switch millirem

Violation

Nuclear Energy Institute

Notice Of Unusual Event Nuclear Regulatory

Commission

Operability

Determinations

Operation

Decision Making Out Of Service Publicly Available

Records System Personnel

Contamination

Report Performance

Indicator

Plant Issues Matrix Problem Identification

and Resolution

Preventive

Maintenance

Post Maintenance

Testing Radiologically

Controlled

Area Root Cause Evaluation

Reactor Coolant Pump Reactor Coolant System Reserve Station Service Transformer

Reactor Vessel Level Monitoring

Radiation

Work Permit Attachment

RWST SOP SG SSFF SW TDAFW TS TSLHRA UFSAR WIP A-15 Refueling

Water Storage Tank Signi'ficance

Determination

Process Steam Generator

Safety System Functional

Failures Service Water Turbine Driven Auxiliary

Feedwater

Technical

Specification

Technical

SpeCification

Locked High Radiation

Area Updated Final Safety Analysis Report Work:-!n-Progress

Attachment