IR 05000336/2006004

IR 05000336-06-004 and 05000423-06-004; 07/01/2006 - 09/30/2006; Millstone, Units 2 and Unit 3; Equipment Alignment, Operability Evaluations, Radioactive Material Processing and Transportation, Identification and Resolution of Problems

ML063110292
Person / Time
Site:	Millstone
Issue date:	11/07/2006
From:	Paul Krohn NRC/RGN-I/DRP/PB6
To:	Christian D Dominion Resources
Krohn P, RI/DRP/PB6/610-337-5120
References
IR-06-004
Download: ML063110292 (56)

Text

November 7, 2006Mr. David A. ChristianSr. Vice President and Chief Nuclear Officer Dominion Resources 5000 Dominion Boulevard Glenn Allen, VA 23060-6711SUBJECT:MILLSTONE POWER STATION - NRC INTEGRATED INSPECTIONREPORT 05000336/2006004 AND 05000423/2006004

Dear Mr. Christian:

On September 30, 2006, the US Nuclear Regulatory Commission (NRC) completed aninspection at your Millstone Power Station Unit 2 and Unit 3. The enclosed inspection report documents the inspection results, which were discussed on October 12, 2006, with Mr. A. Skip Jordan and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.This report documents two NRC-identified finding and two self-revealing findings of very lowsafety significance (Green). All of these findings were determined to involve violations of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. However, because of their very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), in accordance with Section VI.A.1 of the NRC's 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 Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Millstone Power Station.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, 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 NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/Paul G. Krohn, ChiefReactor Projects Branch 6 Division of Reactor Projects Mr. D. A. Christian2Docket Nos.:50-336, 50-423License Nos.:DPR-65, NPF-49Enclosure:Inspection Report 05000336/2006004 and 05000423/2006004w/Attachment: Supplemental Informationcc w/encl:J. A. Price, Site Vice President, Millstone StationC. L. Funderburk, Director, Nuclear Licensing and Operations Support D. W. Dodson, Supervisor, Station Licensing L. M. Cuoco, Senior Counsel C. Brinkman, Manager, Washington Nuclear Operations J. Roy, Director of Operations, Massachusetts Municipal Wholesale Electric Company First Selectmen, Town of Waterford B. Sheehan, Co-Chair, NEAC E. Woollacott, Co-Chair, NEAC E. Wilds, Director, State of Connecticut SLO Designee J. Buckingham, Department of Public Utility Control G. Proios, Suffolk County Planning Dept.

R. Shadis, New England Coalition Staff G. Winslow, Citizens Regulatory Commission (CRC)

S. Comley, We The People D. Katz, Citizens Awareness Network (CAN)

R. Bassilakis, CAN J. M. Block, Attorney, CAN P. Eddy, Electric Division, Department of Public Service, State of New York P. Smith, President, New York State Energy Research and Development Authority J. Spath, SLO Designee, New York State Energy Research and Development Authority Mr.

SUMMARY OF FINDINGS

IR 05000336/2006004, 05000423/2006004; 07/01/2006 - 09/30/2006; Millstone Power Station,Unit 2 and Unit 3; Equipment Alignment, Operability Evaluations, Radioactive Material

Processing and Transportation, Identification and Resolution of Problems. The report covered a 3-month period of inspection by resident inspectors and announcedinspections by regional inspectors. Four green findings, all of which were non-cited violations (NCVs) 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" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.

NRC-Identified and Self-Revealing Findings

Unit 2

Cornerstone: Mitigating Systems

!Green. A Green self-revealing non-cited violation (NCV) of 10 CFR 50,Appendix B, Criterion XVI, "Corrective Action," was identified because Dominion did not take effective corrective action to prevent the east 480 volt vital alternating current (AC) switchgear cooling damper (2-HV-274D) from failing on July 2, 2006. This damper had previously failed on August 26, 2003, after which Dominion specified corrective actions to replace the damper and revise the damper preventive maintenance (PM) schedule and activities. The damper was not replaced and the PM activities were not conducted as planned. As a result, on July 2, 2006, 2-HV-274D failed again. This finding was entered into Dominion's corrective action program (CR-06-06396). Corrective actions for the 2006 failure were similar to those in 2003. The finding is more than minor because it is associated with the equipmentperformance attributes under the Initiating Events, Mitigating Systems, and Barrier Integrity Cornerstone objectives. Inspection Manual Chapter 0609,

Appendix A, was used to determine the risk associated with this finding.

Phase 1 of Appendix A requires that a Phase 2 analysis be performed when multiple cornerstones are affected. The Phase 2 analysis assumes that the 480 volt system is inoperable. Since Dominion implemented compensatory cooling measures prior to actual room temperatures exceeding design limits and the equipment remained operable, there was no entry condition for evaluating this finding in the Phase 2 tables. Therefore, this issue is considered to be of very low safety significance (Green). This finding is related to the cross-cutting aspect of Problem Identification and Resolution in that Dominion did not take effective actions to correct a condition adverse to quality after damper 2-HV-274D failed on August 28, 2003. As a result of the ineffective corrective actions, damper 2-HV-274D failed again on July 2, 2006. (Section 1R04)

iv

Cornerstone: Barrier IntegrityUnit 2!

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B,Criterion XVI, "Corrective Action," for failure to promptly identify and correct a condition adverse to quality affecting the "B" control room emergency ventilation (CREV) train's ability to operate as designed. On August 1, 2006, the "B" CREV train was declared inoperable after Operations detected an improper system flow balance. On August 3, 2006, the system was restored to service after troubleshooting activities were complete. However, the condition which resulted in the flow imbalance had not been identified or corrected. On August 6, 2006, the system was declared inoperable a second time after Operations detected a similar system flow imbalance. A second troubleshooting plan was developed which directed an inspection of the "B" exhaust fan belts. During the inspection, two "B" CREV exhaust fan belts were found stretched and scored. On August 10, 2006, the belts were replaced and operability was restored. This finding was entered into Dominion's corrective action program (CR-06-07115).

Corrective actions for this issue included replacing the associated belts, an extent of condition review, the creation of a specific PM to periodically inspect the associated belts, and an evaluation to modify the operating procedure to extend the fan belt life.This finding is more than minor because it is associated with the Barrier IntegrityCornerstone attribute of maintaining the radiological barrier functionality of the control room. This issue is of very low safety significance (Green) since this finding only represented a degradation of the control room's radiological barrier function. This finding is related to the cross-cutting aspect of Problem Identification and Resolution because Dominion did not promptly identify or completely evaluate a condition adverse to quality prior to restoring the "B" control room emergency ventilation train system back to service on August 3, 2006, despite indications of 1) burning rubber smells when placing the "B" train in service (July 27, 2006 and August 2, 2006); and 2) system flow imbalances that only occurred with the "B" train in service (August 1, 2006, two occasions).

(Section 1R15.2)

Cornerstone: Public Radiation SafetyUnit 3!

Green.

A self-revealing NCV of 10 CFR 20, Appendix G, "Requirements forTransfers of Low-Level Radioactive Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifest," was identified for failure to list on a shipping manifest all radioactive materials that were shipped to a waste processor. On February 24, 2006, Dominion shipped a spent filter liner (Shipment No.06-019) to a waste processor. On March 2, 2006, the waste processor notified Dominion that upon opening the liner, two bags, containing vcontaminated rags and mop heads, were not accounted for on the manifest. This issue was entered into Dominion's corrective action program (CR 06-02234). Corrective action for this issue included informing the waste processor by phone of the correct activity, weight, and volume of this material and providing an amended uniform manifest.The finding is more than minor because it is associated with Public RadiationSafety Cornerstone and involves a failure to comply with NRC regulations. This finding is of very low safety significance because the quantity of radioactive material did not involve under-classifying the shipment's waste (Class C) or the Department of Transportation shipping category (LSA II). This finding is related to the cross-cutting aspect of human performance because Dominion did not adequately implement procedures for preparation of the manifest.

(Section 2PS2)

Cornerstone: Emergency Preparedness Unit 3!

Green.

A Green NCV was identified regarding the site engineeringorganization's failure to evaluate, in a timely manner, the effects that thermally induced currents (TIC) have on the operability of the Unit 3 containment high range radiation monitors (HRRM) (RMS*RE-04A and RMS*RE-05A) during a design basis accident, as required by Technical Specification 3.3.3.6. On September 6, 2006, site engineering issued condition report (CR-06-08181),

documenting that engineering calculations demonstrated that the Unit 3 containment HRRMs (RMS*RE-04A and RMS*RE-05A) would provide false indications due to TICs that would occur following a loss of coolant accident (LOCA). Upon review of the matter, Dominion declared both channels of the Unit-3 containment HRRM monitoring system inoperable on September 6, 2006, in accordance with Technical Specification Action Statement 3.3.3.6. Immediate corrective actions included submitting a Special Report as required by TS 3.3.3.6 and revision of operating procedures to identify alternative methods for monitoring Unit 3 containment radiological conditions, when required.

Additionally, Dominion generated CR-06-08340 to identify its untimely response to this condition and affect corrective measures to prevent recurrence.This finding is more than minor because it is associated with the facilities andequipment attribute of the Emergency Preparedness Cornerstone and adversely affects the cornerstone objective to ensure that Dominion is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. This finding was evaluated using Sheet 1, Failure to Comply, of Inspection Manual Chapter 0609, Appendix B,

Emergency Preparedness Significance Determination Process (SDP). The finding is of low safety significance because the performance deficiency was a failure to comply with a non-risk significant planning standard and no planning standard function failure occurred since other parameters could be used to validate the indications from the Unit 3 containment HRRMs. The cause of the vifinding is related to the cross-cutting element of problem identification andresolution, in that, Dominion failed to adequately evaluate and correct the condition for impact on operability. (Section 4OA2.2)

B.Licensee-Identified Violations

A violation of very low safety significance, which was identified by Dominion pertaining toinaccuracies within the emergency action levels, was reviewed by the inspectors. This issue has been entered into Dominion's corrective action program. The violation and corrective actions are listed in Section 4OA7 of this report.

Enclosure

REPORT DETAILS

Summary of Plant StatusUnit 2 operated at essentially 100 percent power for the duration of the inspection period.

Unit 3 operated at essentially 100 percent power for the duration of the inspection period.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01)System Inspection (One Unit 2 Sample and One Unit 3 Sample)

a. Inspection Scope

The inspectors reviewed one sample of the readiness of the Unit 2 service water systemand one sample of the Unit 3 service water system for extreme weather conditions; specifically, hurricanes, high winds, high tides, and other severe weather events. The inspection was intended to ensure that the indicated equipment, its instrumentation, and its supporting structures were configured in accordance with Dominion procedures and that adequate controls were in place to ensure functionality of the system. The inspectors reviewed licensee procedures and walked down the system. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04).1Partial System Walkdowns (71111.04 - Two Unit 2 Samples and Two Unit 3 Samples)

a. Inspection Scope

The inspectors performed four partial system walkdowns during this inspection period. The inspectors reviewed the documents listed in the Attachment to determine the correct system alignment. The inspectors conducted a walkdown of each system to verify that the critical portions of the selected systems were correctly aligned in accordance with these procedures and to identify any discrepancies that may have had an effect on operability. The inspectors verified that equipment alignment problems that could cause initiating events, impact mitigating system availability or function, or affect barrier functions, were identified and resolved. The following systems were reviewed based on their risk significance for the given plant configuration:

2EnclosureUnit 2*Partial equipment alignment of backup auxiliary feedwater supply onJuly 18, 2006; and*Partial equipment alignment of the east 480 volt switchgear room during theweek of August 14, 2006. Unit 3*Partial equipment alignment of backup auxiliary feedwater system supply onJuly 31, 2006; and*Partial equipment alignment of the "A" safety injection train on September 29, 2006.

b. Findings

Unit

Introduction.

A Green self-revealing non-cited violation (NCV) of 10 CFR 50, AppendixB, Criterion XVI, "Corrective Action," was identified because Dominion did not take effective corrective action to prevent the east 480 volt vital AC switchgear cooling damper (2-HV-274D) from failing on July 2, 2006. This damper had previously failed on August 26, 2003, after which Dominion specified corrective actions to replace the damper and revise the damper preventive maintenance (PM) schedule and activities.

The damper was not replaced and the PM activities were not conducted as planned. As a result, 2-HV-274D failed again.

Description.

On July 2, 2006, a Unit 2 plant equipment operator (PEO) observed thatthe door between the east 480 volt switchgear room and the control room was not latching properly. Upon further investigation, the PEO determined that the vital AC air supply fan discharge damper (2-HV-274D) had failed in the closed direction. Upondiscovery of the failed discharge damper, Operations entered Technical Specification (TS) 3.8.2.1, "A.C. Distribution," at 5:25 p.m., July 2, 2006, for an inoperable 480 volt emergency load center since the vital AC cooling switchgear support system was lost.

Later that day, 2006, at 10:05 p.m., Operations implemented compensatory measures to provide alternate cooling to the room and exited the TS.Dominion conducted an apparent cause evaluation (ACE), to determine the reasondamper 2-HV-274D failed on July 2, 2006 (CR-06-08199). The licensee determined that this damper had previously failed in a similar fashion on August 26, 2003. The previous damper failure was caused by rusted damper ball joints that were seized and broken.

The ball joints interconnect the damper's louver sections such that failure of these ball joints would prevent the damper's external motor from operating the louvers and cause the damper to fail in the closed position. The investigation for the August 26, 2003, 2-HV-274D failure determined that:

3Enclosure*The biennial inspection and lubrication PM did not specify a lubricant to be usedon the damper's ball joint and a lubricant that was not long-lasting had been used in the past (i.e. WD-40);*The two year frequency to perform the PM was not adequate; and

• The damper was not in good material condition and should be replaced.As a result of this investigation, Dominion specified the following corrective actions:

• Specify a longer lasting neolube graphite lubricant;*Change the damper's inspection and lubrication PM from biennial to annual (the vendor's recommended PM frequency); and*The damper should be replaced by November 15, 2004.Dominion conducted an ACE to determine the reason damper 2-HV-274D failed onJuly 2, 2006, and determined that:*The last correct performance of the PM was performed on August 29, 2003,(after the August 28, 2003 damper failure); and*The damper had not been replaced following the August 26, 2003, failure. The inspectors reviewed Dominion's investigation and determined that Dominion did nottake effective corrective action for a condition adverse to quality. This issue is a condition adverse to quality because the failure of ventilation to the 480 volt switchgear room would lead to the loss of mitigating equipment and increase the likelilhood of initiating events. The performance deficiency is that Dominion did not perform effective corrective actions following a previous damper 2-HV-274D failure on August 26, 2003.

Specifically, following the August 26, 2003, damper failure, Dominion specified corrective action to increase the damper's inspection and lubrication PM from biennial to annual and to replace the damper by November 15, 2004. These corrective actions were not performed and the damper subsequently failed again on July 2, 2006.Analysis. The finding was more than minor because it was associated with theequipment performance attribute of the Initiating Events, Mitigating Systems, and Barrier Integrity Cornerstones. Traditional enforcement does not apply for this finding because it did not have any actual safety consequences, or the potential for impacting the NRC's regulatory function, and was not the result of any willful violations of NRC requirements.

Inspection Manual Chapter 0609, Appendix A, was used to determine the risk associated with this finding. Phase 1 of the Appendix requires that a Phase 2 analysis be performed because more than one cornerstone was affected. The entry into the tables of Phase 2 analysis assumes that the 480 volt system is inoperable. Since Dominion implemented compensatory cooling measures prior to actual room temperatures exceeding design limits, no entry condition existed for evaluating this finding in the Phase 2 tables. Therefore, the safety significance of this issue is very low (Green). This finding is related to the cross-cutting aspect of Problem Identification and Resolution in that Dominion did not take effective actions to correct a condition adverse to quality after damper 2-HV-274D failed on August 28, 2003. As a result of the ineffective corrective actions, damper 2-HV-274D failed again on July 2, 2006.

4EnclosureEnforcement. Code of Federal Regulations 10 CFR Part 50, Appendix B, Criterion XVI,"Corrective Action," requires, in part, for significant conditions adverse to quality, that measures be taken to promptly identify and correct the cause of the condition. Contrary to this requirement, Dominion did not take adequate corrective actions after 2-HV-274D failed on August 26, 2003, to prevent a similar failure from occurring on July 2, 2006.

This issue was determined to be of very low safety significance (Green) and has been addressed in Dominion's corrective action program (CR-06-06396). This violation is being treated as a non-cited violation, consistent with Section VI.A of the NRCEnforcement Policy (NCV 05000336/2006004-01, Failure to Implement CorrectiveActions to Prevent Repeat Vital AC 480V Switchgear Cooling Damper Failures)

.Unit 3No findings of significance were identified..2Complete System Walkdown (71111.04S - One Unit 2 Sample and One Unit 3 Sample)

a. Inspection Scope

Unit 2 and Unit 3The inspectors completed a detailed review of the alignment and condition of the Unit 2"A" control room air conditioning system and the Unit 3 service water system. The inspectors conducted a walkdown of the system to verify that the critical portions, such as valve positions, switches, and breakers, were correctly aligned in accordance with procedures to identify any discrepancies that may have had an effect on operability.The inspectors also conducted a review of outstanding maintenance work orders toverify that the deficiencies did not significantly affect the system function. In addition, the inspectors discussed system health with the system engineer and reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

5Enclosure1R05Fire Protection (71111.05).1Quarterly Sample Review (71111.05Q - Nine Unit 2 Samples and Eight Unit 3 Samples)

a. Inspection Scope

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

. The fire protection areas reviewed included:Unit 2*Auxiliary Building, 480 Volt Motor Control Center B61 and B41A, 14'-6" Elevation(Fire Area A-13);*Reserve Station Service Transformer, 14'-6" Elevation (Fire Area XR-3);

• East 480 Volt Load Center Room (Fire Area A-28);

• West 480 Volt Load Center Room (Fire Area T-6);

• Auxiliary Building, "A" Emergency Diesel Generator Room, 14'6" Elevation (FireAreas A-15);*Auxiliary Building, "B" Emergency Diesel Generator Room, 14'6" Elevation (FireAreas A-16);*Auxiliary Building, "C" High Pressure Safety Injection Pump Room, -45'6"Elevation (Fire Zone A-4);*Turbine Building, Motor-Driven Auxiliary Feedwater Pump Room, 1'6" Elevation(Fire Zones T-3); and*Turbine Building, Turbine-Driven Auxiliary Feedwater Pump Room, 1'6" Elevation(Fire Zones T-4).Unit 3*Auxiliary Building, West Motor Control Center and Rod Control Area,24'6" Elevation (Fire Area AB-6, Zone A);*Auxiliary Building, West Motor Control Center and Rod Control Area,43'6" Elevation (Fire Area AB-6, Zone A);*Engineered Safety Features Building, North Motor-Driven Auxiliary FeedwaterPump Cubicle, 21'6" Elevation (Fire Area ESF-8);*Engineered Safety Features Building, South Motor-Driven Auxiliary FeedwaterPump Cubicle, 21'6" and 36'6" Elevations (Fire Area ESF-9);

6Enclosure*North Emergency Diesel Generator Enclosure, 24'6" and 37'0" Elevations(Fire Area EG-3);*South Emergency Diesel Generator Enclosure, 24'6" and 37'0" Elevations(Fire Area EG-4); *Auxiliary Building, West Motor Control Center and Rod Control Air ConditioningUnit Room, 66'6" Elevation (Fire Area AB-6); and*Service Building, East Switchgear Room 4'6" Elevation (Fire Area CB-2).

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures (71111.06).1Internal Flooding (One Unit 3 Sample)

a. Inspection Scope

The inspectors reviewed one sample of flood protection measures for equipment in thesafety-related room listed below. This review was conducted to evaluate Dominion's protection of the enclosed safety-related systems from internal flooding conditions. The inspectors performed a walkdown of the area and reviewed the Final Safety Analysis Report (FSAR), the internal flooding evaluation, and related documents. The inspectors examined the as-found equipment and conditions to ensure that they remained consistent with those indicated in the design basis documentation, flooding mitigation documents, and risk analysis assumptions. The inspectors also interviewed Dominion engineers and other staff. Documents reviewed during the inspection are listed in the

.Unit 3*Control Building 4'6" Elevation - Flood Compartment CB-2(East Switchgear Room).

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance (71111.07).1Annual Heat Sink Performance (71111.07A - One Unit 2 Sample and One Unit 3Sample)

a. Inspection Scope

The inspectors reviewed two samples of safety-related heat exchanger testing to identifyany degraded performance or potential for common cause problems that could increase 7Enclosureplant risk. The inspectors reviewed the results of inspections performed in accordancewith Dominion procedures. The inspectors reviewed the inspection results against the acceptance criteria contained within the procedure, and verified that all acceptance criteria had been satisfied. The inspectors also reviewed the FSAR to ensure that heat exchanger inspection results were consistent with the design basis. The inspectors verified that adverse conditions identified by Dominion were appropriately entered into Dominion's corrective action program. Documents reviewed during the inspection are listed in the Attachment.Unit 2*"C" Reactor Building Closed Cooling Water Heat Exchanger.

Unit 3*"A" Safety Injection Heat Exchanger.

b. Findings

No findings of significance were identified..2Biennial Heat Sink Performance (71111.07B - Three Unit 2 Samples)

a. Inspection Scope

Based on a plant specific risk assessment, resident inspector input, and the last biennialinspection, the inspector selected the following Unit 2 heat exchangers (HXs) for review:*"B" Shutdown Cooling (containment spray) HX, X-23B;*"D" Containment Air Recirculation (CAR) Cooling Unit, X-35D; and

• "B" Reactor Building Closed Cooling Water (RBCCW) System HX, X-18B.The RBCCW HX transfers its heat load directly to the service water (SW) system, whilethe CAR and shutdown cooling HXs transfer their heat load indirectly to SW, through the RBCCW system. The SW system is designed to supply cooling water from Long Island Sound (the ultimate heat sink) to various heat loads, to ensure a continuous flow of cooling water to systems and components necessary for plant safety both during normal operation and abnormal or accident conditions.The inspector reviewed Dominion's inspection, maintenance, chemical control, andperformance monitoring methods and frequency for the selected components to determine whether potential deficiencies could mask degraded performance and to assess the capability of the HXs to perform their design functions. The inspector evaluated the associated Millstone Unit 2 programs to assess whether they conformed to Dominion's commitments to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." In addition, the inspector evaluated 8Enclosurewhether any potential common cause heat sink performance problems could affectmultiple HXs in mitigating systems or result in an initiating event.The inspector reviewed system health reports, HX inspection records, eddy current testresults, performance and surveillance test results, as-left HX tube plugging, and design specifications and calculations. The inspector compared as-found HX inspection resultsand performance and surveillance test results to established acceptance criteria to determine whether the as-found conditions were acceptable and conformed to design basis assumptions for heat transfer capability. The inspector evaluated performance trends to assess whether the inspection and test frequencies were adequate to identify degradation prior to loss of heat removal capabilities below their design requirements.

In addition, the inspector assessed Dominion's methods to monitor and control bio-fouling, corrosion, erosion, and silting to verify whether Dominion's methodology and acceptance criteria, as-implemented, were adequate.The inspector performed field walkdowns of the accessible portions of the selected HXs,the sodium hypochlorite system, and the SW system to independently assess the material condition of these systems and components. In addition, the inspector performed control board walkdowns in the main control room, viewed several SW intake structure and piping inspection videos from the 2R16 refueling outage, reviewed work order history, and discussed system health with the respective system engineers.

Documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11Q - One Unit 2 Sample and OneUnit 3 Sample).1Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors observed one sample of Unit 2 licensed operator simulator training onAugust 29, 2006, and one sample of Unit 3 licensed operator simulator training on August 30, 2006. The inspectors verified that the training evaluators ensured that the applicable training objectives were achieved, operator performance was adequate, and that the evaluators were identifying and documenting crew performance problems.

Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

9Enclosure.2Licensed Operator Requalification Program (71111.11B)

a. Inspection Scope

The effectiveness of the Millstone Unit 2 licensed operator requalification trainingprogram was evaluated through reviews of the following documents related to the facility operating history for the previous two years:*NRC inspection reports and plant issue matrix;*Licensee event reports (LERs); and

• Operator and training related condition reports (CRs).During the week of this inspection, the quality and content of the requalificationexaminations were evaluated and a survey of the facility's requalification scenarios and job performance measures (JPM) banks was completed. This review assessed the coverage of the exams as specified in 10 CFR 55.41, 43, and 59 and the inclusion of probabilistic risk assessment insights. The discrimination level and construction of the exams was also evaluated against the criteria set forth in NUREG -1021, "Operator Licensing Examination Standards for Power Reactors."Licensed operator training on important tasks identified in the Individual PlantExamination was verified by reviewing a sample of risk significant systems and operator actions and verifying that training items existed for these tasks.Observations of licensee exam administration and grading practices for two crews wereconducted, including evaluator review of final grading reports. Repeat test items from one exam week to the next were controlled and below the established criteria for consideration of potential compromise of examination security. Licensee updating of the requalification program was assessed by review of plant andindustry events, and verification of appropriate updating of both specific system lesson plans and generic "plant and industry events" lessons.Remediation practices were assessed by review of instances where operators or crewshad failed either a written examination or simulator evaluation during the current requalification program. No instances of failed annual exams occurred; two examples of a failed "cold evaluation" at the start of a training week and subsequent remediation were reviewed. One example of a failed biennial written exam and the reexamination was reviewed.Utilization of feedback to update and modify the requalification program was evaluatedby verification of training on plant modifications and plant and industry events.

Operators were interviewed to discuss the effectiveness of the feedback process.Compliance with license conditions was verified through review of attendance records,and reviews of medical records for the operators observed during this inspection.

10EnclosureWatchstanding proficiency and reactivation documentation was reviewed for a samplingof licensed operators.For the site specific simulator, the inspectors observed simulator performance during theconduct of the examinations, reviewed simulator performance tests and simulator deficiency reports to verify compliance with the requirements of 10 CFR 55.46.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12)Routine Maintenance Effectiveness Inspection (71111.12Q - Two Unit 2 Samples andTwo Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed four samples of Dominion's evaluation of degraded conditions,involving safety-related structures, systems and/or components for maintenance effectiveness during this inspection period. The inspectors reviewed licensee implementation of the Maintenance Rule (MR), 10 CFR 50.65, and verified that the conditions associated with the referenced CRs were appropriately evaluated against applicable MR functional failure criteria as found in licensee scoping documents and procedures. The inspectors also discussed these issues with the system engineers and maintenance rule coordinators to verify that they were appropriately tracked against each system's performance criteria and that the systems were appropriately classified in accordance with MR implementation guidance. Documents reviewed during the inspection are listed in the Attachment. The following conditions were reviewed:Unit 2*Enclosure Building Filtration System Backdraft Damper Testing (CR-06-05318);

and*"B" Control Room Air Conditioning Unit Belt Slippage (CR-06-06945).Unit 3*Failure of Stroke Time Test of Turbine-Driven Auxiliary Feedwater Pump FlowControl Valve (CR-06-07665); and*Found "B" Gravity Boration Line Essentially Empty (CR-06-03730).

b. Findings

No findings of significance were identified.

11Enclosure1R13Maintenance Risk Assessments and Emergent Work Control (71111.13 - Four Unit 2Samples and Four Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed eight samples of the adequacy of maintenance riskassessments for emergent and planned activities during the inspection period. The inspectors utilized Dominion's equipment-out-of-service quantitative risk assessment tool for assessing the risk of various plant configurations and compared the results to those previously obtained by Dominion. The inspectors verified that Dominion entered appropriate risk categories and implemented risk management actions as necessary.

Documents reviewed during the inspection are listed in the Attachment. The inspectors verified the conduct and adequacy of scheduled maintenance risk assessments for plant conditions affected by performance of the following maintenance and testing activities:Unit 2*Risk assessment of emergent work following unexpected reactor protectionsystem trip circuit breaker response, July 24, 2006;*Risk assessment of routine work activities, July 31, 2006 to August 4, 2006;

• Emergent risk assessment of Unit 2 due to Unit 3 "B" emergency dieselgenerator (EDG) inoperable, August 8-10, 2006; and*Risk assessment associated with the "B" control room emergency ventilation andthe "A" reserve service station transformer (RSST) out of service due to testing, August 24, 2006.Unit 3*Risk assessment due to grid capacity deficiency alert, July 18, 2006;*Emergent risk assessment due to "B" EDG inoperable, August 8-10, 2006;

• Emergent evaluation of unavailability of the "A" EDG, August 29, 2006; and

• Emergent risk assessment due to "B" EDG declared inoperable, September 8, 2006.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - Four Unit 2 Samples and Three Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed seven operability determinations associated with degraded ornon-conforming conditions to ensure that operability was justified, that mitigating systems or those affecting barrier integrity remained available, and that no unrecognized increase in risk had occurred. The inspectors also reviewed compensatory measures to ensure that they were in place and were appropriately controlled. The inspectors 12Enclosurereviewed licensee performance to ensure all related TS and FSAR requirements weremet. The inspectors reviewed the following degraded or non-conforming conditions:Unit 2*Application of TS 3.0.5 during RSST Surveillance Testing;*"B" Control Room Air Conditioning Exhaust Fan Belt Assessment(CR-06-06945);*High Particulate Level in Emergency Diesel Generator Storage Tank(CR-06-07708 and see

4OA2 of this report); and*Failure Mode to Charging System Pulsation Bladders (CR-06-00243).Unit 3*Containment Unidentified Sump Level Indication (CR-06-07068);*"B" Emergency Diesel Generator Fuel Oil Particulate Level Above TechnicalSpecification Limit (CR-06-07073 and see 4OA2 of this report); and*A Reasonable Assurance of Safety (RAS) is Needed to Support Leak RepairActivities on Service Water Line 3SWP (CR-06-06509).

b. Findings

Unit 2.1Application of TS 3.0.5 During RSST Surveillance TestingOn August 6, 2006, the inspectors questioned Operators whether removing the RSSTfrom service with the "B" control room emergency ventilation (CREV) unavailable was a violation of TS 3.0.5, a Limiting Condition of Operation that precludes removing the emergency or normal power supply from a train of equipment when its redundant train is unavailable. Operators determined that TS 3.0.5 did not apply since the normal power supply could consist of either the RSST or the backup power cross-connect from Unit 3.

The inspectors reviewed TS Bases and the FSAR which described the normal power supply as both the RSST and the backup power cross-connect from Unit 3. In addition, the inspectors noted that the TS Bases assumed three hours to lineup the backup power cross-connect from Unit 3 which did not appear consistent with the timing expectation of the availability of safety-related equipment. This question was raised to Dominion who agreed to review their application of TS 3.0.5, "Normal Power Source Applicablilty" for these circumstances. Thus, this issue remains unresolved pending NRC review of Dominion's determination of the definition of what constitutes a "normal" power supply and their evaluation of the acceptability of a three hour delay time forproviding a backup power supply. (URI 05000336/2006004-02, Application of TS 3.0.5for Emergency or Normal Power Source Inoperable

).

13Enclosure.2Control Room Air Conditioning Exhaust Fan BeltIntroduction. The inspectors identified a Green NCV of 10 CFR 50, Appendix B,Criterion XVI, "Corrective Action," for failure to promptly identify and correct a condition adverse to quality affecting the "B" control room emergency ventilation (CREV) train's ability to operate as designed.Description. On July 27, 2006, Operations identified a burning rubber smell aftershifting from the "A" CREV train to the "B" CREV train. A condition report was initiated (CR-06-06945), identifying that the burning rubber smell was possibly being caused during the CREV train swap by leaking discharge fan dampers. This condition report was assigned a low significance level with a corresponding low priority work order.

Dominion assessed system operability and determined the following:*The condition was previously evaluated under CR-05-07785 as not affectingoperability;*The system's ability to cool or filter the control room during an accident wasnot affected;*The condition did not affect the ability to start the fan during an accident; and

• The assessment recommended that Operations should consider a differentmethodology for shifting the CREV system to preclude shortening the life span of the fan belts.On August 1, 2006, Operations noticed an abnormal positive control room pressure withthe "B" CREV train in service. The "A" CREV train was placed in service and control room pressure dropped to the expected value. Later that day, the "B" CREV was returned to service, and Operations again identified the same abnormal conditions.

Operations entered TS 3.7.6.1a, "Control Room Emergency Ventilation," based on uncertainties that the positive control room pressure would have on the "B" CREV train's ability to provide the designed recirculation flow during an accident.On August 2, 2006, Operations authorized a troubleshooting plan to investigate the "B"CREV train degraded condition. The troubleshooting plan consisted of ensuring damper positions were correct for both trains in the normal and accident operating modes. In addition, fan vibrations and motor amps measurements were taken and found to be acceptable. Operations noted that no degraded conditions were identified and all control room pressures were found to be normal throughout the troubleshooting plan.

However, a technician did note during troubleshooting a burning rubber smell when the "A" CREV train was swapped to the "B" CREV train. On August 3, 2006, Operations restored the "B" CREV train and exited TS 3.7.6.1awithout determining the cause or taking corrective action to resolve the degraded condition. On August, 6, 2006, Operations again entered TSAS 3.7.6.1a observing a similar abnormal control room positive pressure. Maintenance prepared a second troubleshooting plan that focused on inspecting the "B" CREV train exhaust fan belts, replacing the belts, and retesting the "B" CREV train. Upon inspection, maintenance identified that two exhaust fan belts were degraded (i.e., stretched and scored).

14EnclosureOn August 10, the fan belts were replaced, retested, and TS 3.7.6.1.a was exited. Theperformance deficiency associated with this issue is that Dominion did not promptly identify an adverse condition and then take appropriate corrective action. Specifically, Dominion identified a burning rubber smell when shifting from the "A" CREV to the "B" CREV train on July 27, 2006, (CR-06-06945) and again during troubleshooting activities August 2, 2006. Dominion did not identify that the burning rubber smell was related to stretched and scored fan belts until the second unplanned TS 3.7.6.1 entry on August 6, 2006.Analysis. This finding is more than minor because it is associated with the BarrierIntegrity Cornerstone attribute of maintaining the radiological barrier functionality of the control room. Traditional enforcement does not apply to this issue because there were no actual safety consequences, impacts on the NRC's ability to perform its regulatory function, or willful aspects to the violation. The inspectors performed a Phase 1 analysis in accordance with Inspection Manual Chapter (IMC) 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." This issue is of very low safety significance (Green) since this finding only represented a degradation of the control room's radiological barrier function. This finding is related to the cross-cutting aspect of Problem Identification and Resolution because Dominion did not promptly identify or completely evaluate a condition adverse to quality prior to restoring the "B" control room emergency ventilation train system back to service on August 3, 2006, despite indications of 1) burning rubber smells when placing the "B" train in service (July 27, 2006 and August 2, 2006); and 2) system flow imbalances that only occurred with the "B" train in service (August 1, 2006, two occasions).Enforcement. 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, inpart, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to this requirement, on July 27, 2006, Dominion did not identify that the smell of burning rubber and abnormal positive control room pressure when shifting the "A" CREV train to the "B" CREV train was indicative of significantly degraded "B" CREV exhaust fan belts.

Additionally, Dominion did not identify the recurrence of the burning rubber smell during troubleshooting activities on August 2, 2006, as indicative of the need to investigate the condition of the rubber fan belts. As a result, the CREV system was returned to service on August 3, 2006, with no definitive corrective action identified. Subsequently, the system exhibited the same condition and was again declared inoperable. Corrective actions included replacing and retesting the degraded fan belts. This violation is determined to be of very low safety significance (Green) and has been entered into Dominion's corrective action program (CR-06-06945). Therefore, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy(NCV 05000336/2006004-03, Failure to Identify an Adverse Condition AffectingControl Room Emergency Ventilation Performance).

15EnclosureUnit 3No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19 - Three Unit 2 Samples and Four Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed seven samples of post-maintenance tests (PMT) during thisinspection period. The inspectors reviewed these activities to determine whether the PMT adequately demonstrated that the safety-related function of the equipment was satisfied given the scope of the work specified and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to verify consistency with the associated design and licensing bases, as well as TSrequirements. The inspectors also verified that conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following maintenance activities and their post-maintenance tests were evaluated:Unit 2*"B" Control Room Emergency Ventilation Retest on August 2, 2006 andAugust 7, 2006 (M2-03-12937);*Channel "D" Reactor Protection System Trip Bistable Replacement(M2-06-03525); and*"C" Reactor Building Closed Cooling Water Heat Exchanger Clean and InspectRetest (M2-06-00544).Unit 3*Replace Hydramotor Actuator for Auxiliary Feedwater Pump Area Ventilation(M3-02-18011);*"D" Service Water Pump Strainer Overhaul (M3-02-04935);

• Charging Pump Cubicle Inlet Ventilation Damper (M3-05-05844); and

• "B" Reactor Plant Component Cooling Water Heat Exchanger Pass PlateStiffener.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - Two Unit 2 Samples and Four Unit 3 Samples)

a. Inspection Scope

The inspectors reviewed six samples of surveillance activities to determine whether thetesting adequately demonstrated equipment operational readiness and the ability to 16Enclosureperform the intended safety-related function. The inspectors attended pre-job briefs,verified that selected prerequisites and precautions were met, and that the tests were performed in accordance with the procedural steps. Additionally, the inspectors evaluated the applicable test acceptance criteria to verify consistency with associated design bases, licensing bases, and TS requirements and that the applicable acceptance criteria were satisfied. The inspectors also verified that conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following surveillance activities were evaluated:Unit 2*Auxiliary Feedwater Train "A" and "B" Failure Mode and Stroke Timing In-ServiceTest (IST) (SP-2610CO); and*Reactor Coolant System Leak Rate Determination (SP-2602A).Unit 3*Auxiliary Feedwater Train "A" Valve Stroke Time IST (SP-3622.8-001);*Reactor Coolant System Leak Rate Determination (SP-3680.1-003);

• "B" Quench Spray Header Isolation Valve Stroke Time IST (ContainmentIsolation Valve) (SP-3609.9); and*"B" Quench Spray Pump Operational Readiness IST (SP-3609.2).

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications (71111.23 - One Unit 2 Sample and One Unit 3 Sample)

a. Inspection Scope

The inspectors reviewed two samples of temporary modifications to verify that thetemporary modifications did not affect the function of important safety systems. The inspectors reviewed the temporary modifications and their associated 10 CFR 50.59 screening against the FSAR and TSs to ensure the modifications did not affect system operability or availability. Documents reviewed during the inspection are listed in the

. Unit 2*Alternate Plant Configuration for 2-RC-100E Out-of-Service (50.59/72.48 ScreenForm).Unit 3*Quench Spray System Pump Discharge Header Fill.

b. Findings

No findings of significance were identified.Cornerstone: Emergency Preparedness [EP]1EP6Drill Evaluation (71114.06 - One Unit 2 Sample and One Unit 3 Sample)

a. Inspection Scope

The inspectors observed one sample of the conduct of a Unit 2 licensed operator simulator training on August 29, 2006, and one sample of the conduct of Unit 3 licensed operator simulator training on August 30, 2006. The inspectors evaluated the Operations crew activities related to evaluating the scenario and making proper emergency action level classification determinations. Additionally, the inspectors assessed the ability of Dominion's evaluators to adequately address operator performance deficiencies identified during the exercise. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.2.RADIATION SAFETYCornerstone: Public Radiation Safety2PS2Radioactive Material Processing and Transportation (71122.02)

a. Inspection Scope

(6 Samples)During the period September 18 - 21, 2006, the inspector conducted the followingactivities to verify that Dominion's radioactive processing and transportation programs complied with the requirements of 10 CFR 20, 61, and 71; and Department of Transportation (DOT) regulations contained in 49 CFR 170-189.Radioactive Waste System WalkdownThe inspector walked down accessible portions of the Unit 2 and Unit 3 radioactive liquidand solid waste collection/processing systems with the cognizant system engineer. The inspector evaluated if the systems and facilities were consistent with the descriptions contained in the FSAR and the Process Control Program (PCP), evaluated the general material conditions of the systems and facilities, and identified any changes made to the systems. Also, the inspector and the Supervisor of Radioactive Material Controls visually inspected the radwaste storage areas located within the site protected area, 18Enclosureincluding Warehouse No. 9, the Millstone Radwaste Reduction Facility, and outdoorstaging areas. Stored material inventories were reviewed for these areas.The inspector discussed, with the radioactive waste systems engineer, the status ofnon-operational, abandon/retired-in-place, radioactive waste processing equipment, and the administrative and physical controls for various components in these systems. The inspector evaluated recent changes made to radwaste processing systems and their potential impact on routine plant operations. The inspector also reviewed the current processes for transferring radioactive resin and sludge to shipping containers and subsequent resin sampling and de-watering. The inspector reviewed the radioactivity characterization data and plans for shipping theold reactor head and pressurizer during the upcoming Unit 2 refueling outage. Waste Characterization and ClassificationThe inspection included selective review of the waste characterization and classification program for regulatory compliance, including:*the radio-chemical analytical results for samples taken from various radioactivewaste streams, including spent resins, dry active waste, and mechanical filters;*the development of scaling factors for hard-to-detect radio-nuclides from theradio-chemical data;*methods and practices to detect changes in waste streams;

• characterization and classification of waste relative to 10 CFR 61.56 and todetermine DOT shipment subtype per 49 CFR 173; and*review of data for characterizing the Unit 2 pressurizer and old reactor head thatwill be shipped in November 2006.Shipment PreparationThe inspection included a review of radioactive waste program documents and shipmentpreparation procedures, and in-progress activities for regulatory compliance, including:*review of certificates of compliance for in-use shipping casks;*verification of appropriate NRC (or agreement state) license authorization forshipment recipients for six recent shipments listed in the shipping records

section;*verification that training was provided, in accordance with NRC Bulletin 79-19,and 49 CFR 172, Subpart H, to appropriate personnel directly responsible for classifying, handling, and shipping radioactive materials;*review of the 2005 Radioactive Effluent Release Report;

• review of radiological survey data for receipt of a reactor coolant pump;

• review of radioactive material inventories for material staged on site; and

• review of shipping logs for 2004, 2005, and 2006 (to September 20, 2006).

19EnclosureShipping RecordsThe inspector selected and reviewed records associated with six non-exceptedshipments of radioactive materials made since the last inspection of this area. The shipments were numbers06-032, 06-029,06-019, 06-018,05-082, and 04-070. The following aspects of the radioactive waste packaging and shipping activities were reviewed for these shipments:*implementation of applicable shipping requirements including proper completionof the uniform manifests;*implementation of specifications in applicable certificates of compliance, for theapproved shipping casks including limits on package contents;*classification of radioactive materials relative to 10 CFR 61.55 and 49 CFR 173;

• labeling of containers;

• placarding of transport vehicles;

• radiation and contamination surveys of packages;

• conduct of vehicle checks;

• providing of driver emergency instructions;

• completion of shipping papers; and

• notification of shipment arrival at the receiving site.

b. Findings

Introduction.

A self-revealing NCV of 10 CFR 20, Appendix G, "Requirements forTransfers of Low-Level Radioactive Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifest," was identified for failure to list on a shipping manifest all radioactive material that was shipped to a waste processor.Description. On February 24, 2006, Dominion shipped a spent filter liner (ShipmentNo.06-019) to a waste processor. On March 2, 2006, the waste processor notified Dominion that upon opening the liner, two bags, containing contaminated rags and mop heads, were not accounted for on the manifest. This material contained approximately 2.06 Curies of activity and weighed about 40 pounds (1.8 cubic feet). Dominion initiated an investigation (CR 06-02234) to determine the cause for the failure to document the material on the uniform manifest and to implement corrective actions. The inspector determined that Dominion's failure to account on the manifest for all radioactive material shipped was a performance deficiency, since a fundamental attribute of the radioactive waste transportation program is accountability for all shipped radioactive material on the uniform manifest.Analysis. The finding is more than minor because it is associated with Public RadiationSafety cornerstone and involves a failure to comply with NRC regulations. This finding is of very low safety significance (Green) because the quantity of radioactive material involved did not involve under classifying the shipment's waste (Class C) or the Department of Transportation shipping category (LSA II). Dominion promptly determined that inadequate oversight resulted in the misfiling of records for the two bags of material. Subsequently, on March 3, 2006, the waste processor was informed 20Enclosureby phone of the correct activity, weight, and volume of this material, and an amendeduniform manifest was provided.Enforcement. 10 CFR 20, Appendix G, Section I.B., requires that the shipper provide,on the uniform manifest, the total radio-nuclide activity, volume, and disposal weight for each shipment. Contrary to this requirement, for shipment No.06-019, made on February 24, 2006, the radionuclide activity, volume, and disposal weight were not accounted for on a shipping manifest for two bags of radioactive waste. Because this violation was determined to be of very low safety significance and it has been promptly entered into Dominion's corrective action program as CR 06-02234, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy(NCV 05000423/2006004-04, Failure to account for all shipped radioactive materialon the uniform manifest).

OTHER ACTIVITIES

[OA]4OA2Identification and Resolution of Problems (71152).1Review of Items Entered into the Corrective Action ProgramAs required by Inspection Procedure 71152, "Identification and Resolution of Problems,"and in order to help identify repetitive equipment failures or specific human performance issues for followup, the inspectors performed a daily screening of items entered into Dominion's corrective action program. This was accomplished by reviewing the description of each new CR and attending daily management review committee meetings. Documents reviewed are listed in the Attachment..2Annual Sample Review (Two Site Samples and One Unit 2 Sample and Two Unit 3Samples)Unit 3Containment High Range Radiation Monitors

a. Inspection Scope

The inspector evaluated site engineering response to a recent Condition Reportregarding the operability of Unit 3 post accident instrumentation. On September 6, 2006, site engineering issued condition report (CR-06-08181), documenting that engineering calculations demonstrated that the Unit 3 containment high range radiation monitors (RMS*RE-04A and RMS*RE-05A) would provide false indications due to thermally induced currents (TIC) that would occur following a loss of coolant accident (LOCA). The calculations were prompted by control room operators challenging engineering guidance regarding the high range radiation monitors' (HRRM)post-accident operability, given during a refresher training session on the Unit 3 radiation monitoring system. At that time, engineering guidance directed the operators 21Enclosureto observe the Unit 3 containment HRRMs for at least fifteen

(15) minutes to determineif the readings were credible, prior to determining the Emergency Action Level (EAL).

Subsequently, site engineering determined that TIC in the containment HRRM cabling would cause significant false radiation indications in the instrumentation. Both monitorswere declared inoperable on September 6, 2006, as required by Technical Specification Action Statement 3.3.3.6.

b. Findings

Introduction.

A Green Non-Cited Violation (NCV) was identified regarding the siteengineering organization's failure to evaluate, in a timely manner, the effects that TICs have on the operability of the Unit 3 containment high range radiation monitors (RMS*RE-04A and RMS*RE-05A) during a design basis accident, as required by Technical Specification 3.3.3.6.

Description.

On September 6, 2006, site engineering issued condition report(CR-06-08181), documenting that engineering calculations demonstrated that the Unit 3 containment high range radiation monitors (RMS*RE-04A and RMS*RE-05A) wouldprovide false indications due to TICs that would occur following a LOCA. The condition report was developed in a response to a situation in which reactor operating personnel challenged the system engineering organization to document a long-standing degraded condition that affected the operability of the containment HRRM system.Specifically, during a operator refresher training session in August 2006, systemengineering personnel informed the operators of the TIC phenomenon, i.e., that certain cable types and lengths could be affected by TICs when exposed to high temperatures, such as in a LOCA condition. System engineering informed the operators that the cable type and length used for the Unit-3 containment HRRM had the potential to be affected by TIC and the condition may result in a false indication of high radiation in the containment, which may affect the interpretation of plant conditions, certain Emergency Action Levels, and alarm responses.In response, the operators challenged the engineering organization to effectively handleand resolve this condition. Upon review of the matter, Dominion declared both channels of the Unit-3 containment HRRM monitoring system inoperable on September 6, 2006, in accordance with Technical Specification Action Statement 3.3.3.6. Subsequently, Dominion submitted a Special Report, as required by TS 3.3.3.6, on September 20, 2006, identifying the condition, immediate corrective measures, and actions initiated to effect resolution. Immediate corrective actions included the revision of operating procedures to identify alternative methods for monitoring Unit 3 containment radiological conditions, when required. Additionally, Dominion generated CR-06-08340 to identify its untimely response to this condition and affect corrective measures to prevent recurrence.The inspector noted that Dominion was initially informed of the effect that TICs have onradiation monitoring instrumentation through NRC Information Notice (IN) 97-45, "Environmental Qualification Deficiency for Cables and Containment Penetration 22EnclosurePigtails." Additionally, Dominion was cognizant of an industry study entitled, "HighRange Radiation Monitor Cable Study: Phase II," issued in May 2000, which confirmed the effect and identified measures for resolution. In response to this information, Dominion's system engineering organization regularly documented the condition in its quarterly systems health reports but failed to initiate any actions to resolve the condition, or effectively communicate the implications of the matter to the operating organization.

The inspector determined that Dominion's failure to initiate actions to resolve this condition was a performance deficiency.

Analysis.

The finding is more than minor because it is associated with the facilities andequipment attribute of the Emergency Preparedness Cornerstone and adversely affects the cornerstone objective to ensure that Dominion is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. This finding was evaluated using Sheet 1, Failure to Comply, of Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process (SDP). The finding is of low safety significance (Green) because the performance deficiency was a failure to comply with a non-risk significant planning standard and no planning standard function failure occurred since other parameters could be used to validate the indications from the Unit 3 containment HRRMs. The cause of the finding is related to the cross-cutting aspect of problem identification and resolution, in that, Dominion failed to adequately evaluate and correct the condition for impact on operability. Specifically, the issue was not resolved in a timely manner and the interim measures were not effectively communicated to the operations staff nor included in relevant procedures.Enforcement. TS 3.3.3.6 requires accident monitoring instrumentation channels beoperable, and that with the required containment HRRM channels being inoperable for greater than 7 days, Dominion shall submit a Special Report to the NRC within 14 days detailing the actions taken, the cause of the inoperability, and the plans and schedule for restoring the channels to operable status. Contrary to this, from 2000 until September 2006, Dominion failed to restore RMS*RE-04A and RMS*RE-05A to operable status or submit the required Special Report to the NRC. Because this violation was determined to be of very low safety significance and has been entered into Dominion's corrective action program as CR-06-08181 and CR-06-08340, this violation is being treated as anNCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV05000423/2006004-05, Failure to Comply with Technical Specification Required Actions for Inoperable Containment High Range Radiation Monitors).Digital Rod Position Indication Malfunction

a. Inspection Scope

The inspector reviewed licensee corrective actions for a digital rod position indicationmalfunction on Unit 3 which occurred on May 1, 2005, in which the operators misdiagnosed the event as an actual mispositioned rod.

b. Findings and Observations

No findings of significance were identified.Dominion generated CR-05-06050, "Lessons Learned From Investigation of the DRPIFailure That Occurred on 5/1/2005," to address this event. Corrective actions included:*shift briefs on the event;*changes to AOP 3552 "Malfunction of the Rod Drive System" to better improve diagnosis of an apparent mispositioned rod resulting from an indication failure;*development of a simulator malfunction for training on this type of failure; and

• incorporation of this malfunction into planned training.The inspector reviewed the brief and abnormal operating procedure (AOP) changes andconsidered these corrective actions to be appropriate.Unit 2Radiation Monitoring System

a. Inspection Scope

The inspector reviewed the actions taken by Dominion to restore the Unit 2 radiationmonitoring system (RMS) to Maintenance Rule (a)(2) status. In 2001, Dominion developed a Maintenance Rule (a)(1) action plan for Unit 2 process and area radiation monitors as a result of exceeding the maintenance rule performance criteria. To implement this plan an Engineering Work Request (EWR M2-98106), was developed that detailed the replacement, removal, and upgrading of various radiation monitors to preclude repetitive maintenance. In 2005, all action plan requirements were completed and the Unit 2 RMS was monitored to assess reliability. During the second quarter of 2006, Dominion determined that the system met the maintenance rule criteria (a)(2) with no functional failures during the monitoring period. The inspector reviewed the Unit 2 RMS Maintenance Rule (a)(1) Action Plan,EWR M2-98106, relevant condition reports, RMS equipment health reports, and Millstone Station Radiation Monitor Program Self-Assessment (MP-SA-03-63). The inspector also discussed the status of the corrective actions, the Unit 2 RMS maintenance backlog, and the current reliability of this system with the cognizant Unit 2 system engineer and the Instrumentation & Control (I&C) supervisor.

b. Findings and Observations

No findings of significance were identified. The inspector determined that the Unit 2RMS has been returned to a Maintenance Rule (a)(2) status in a controlled, systematic manner.

24EnclosureUnit 2 and Unit 3Departure from Nucleate Boiling

a. Inspection Scope

The inspectors selected CRs associated with Unit 2 and Unit 3's unplanned entranceinto their respective Technical Specifications dealing with departure from nucleate boiling (DNB). The reports were reviewed to ensure that the full extent of the issues were identified, an appropriate evaluation was performed, and appropriate corrective actions were specified, prioritized, and implemented. The inspectors evaluated the reports as well as the requirements of Dominion's corrective action program as delineated in MP-16-CAP-FAP01.1, "CR Screening and Review," and 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action." Documents reviewed during this inspection are listed in the Attachment.

b. Findings and Observations

No findings of significance were identified.

The inspectors reviewed work order M2-05-09889, which had been generated torepair/replace the pressurizer pressure indicating controller in response to CR-05-09846, which was written to address the apparent failure of the P100X controller associated with pressurizer pressure indication. During their review, the inspectors noted that the job description steps in this work order did not provide clear and concise direction as to what parameters were to be recorded by the technicians as data points, and that the documentation of work actually performed on the controller prior to reinstallation did not contain sufficient detail to allow for a determination that the controller was restored to a fully functional condition prior to performance of the post maintenance testing. Dominion entered this observation into their corrective action program as CR-06-07951. This issue was determined to be minor because inspectors did not identify any conditions that resulted in the pressurizer pressure indicating controller being degraded or non-operable while in service.Emergency Diesel Generator Fuel Oil Storage Tanks Particulate Level Trend

a. Inspection Scope

The inspectors reviewed Dominion's actions to resolve problems with increasingparticulate levels in EDG fuel oil (FO) storage tanks. This review was initiated following the discovery of fuel oil particulates in excess of the TS limit on the Unit 3 "B" EDG fuel oil storage tank. On August 8, 2006, Dominion identified that the Unit 3 "B" EDG fuel oil storage tank contained particulates in excess of the TS limit of 10.0 mg/l. Dominion declared the "B" EDG inoperable and contracted a fuel oil vendor to come to the site to filter the "B" EDG fuel oil storage tank. The "B" EDG fuel oil tank was filtered to less than one mg/l and the TS action statement was exited. Subsequently, fuel oil particulates were also discovered in Unit 2 EDG fuel oil tanks and Dominion initiated a 25Enclosureroot cause investigation. This problem identification and resolution sample evaluatedthese events and the results of the root cause evaluation.

b. Findings and Observations

No findings of significance were identified.

On August 21, 2006, Dominion identified an increasing trend in Unit 2 EDG fuel oilstorage tank particulate levels. Dominion generated a CR and operability determination basis. Based on this increasing trend in Unit 2 and the high particulate level seen previously in the Unit 3 fuel oil storage tanks, Dominion initiated a root cause investigation.Dominion determined that the root cause of increasing particulate levels at both units tobe fuel degradation resulting from fuel oxidation. In addition, Dominion concluded that the susceptibility of ultra low sulfur fuel to oxidation occurs from one or both of the following:*The use of a catalytic cracking process in the refining of distillate fuels resultingin a more chemically dynamic fuel; and*The chemical interaction between different additives used by different refineriesand suppliers.The inspectors reviewed Dominion's identification evaluation, root cause investigation,and corrective actions. The inspectors considered that Dominion was effective in identifying this trend, evaluating the trend and taking immediate corrective actions. In addition, the inspectors noted that Dominion identified the potential generic implications and initiated operating experience documentation to inform the industry and the NRC of this potential generic vulnerability associated with ultra low sulfur fuel oil.

.3 Cross-References to PI&R Findings Documented Elsewhere in this ReportSection 1R04 describes a finding for the failure to take effective corrective action toprevent a repeat failure of damper 2-HV-274D in the 480 volt ventilation system.

This finding is related to the cross-cutting aspect of Problem Identification and Resolution in that Dominion did not take effective actions to correct a condition adverse to quality after damper 2-HV-274D failed on August 28, 2003. As a result of the ineffective corrective actions, damper 2-HV-274D failed again on July 2, 2006.Section 1R15.2 describes a finding associated with the "B" train Control RoomEmergency Ventilation. This finding is related to the cross-cutting aspect of Problem Identification and Resolution because Dominion did not promptly identify or completely evaluate a condition adverse to quality prior to restoring the "B" control room emergency ventilation train system back to service on August 3, 2006, despite indications of 1)burning rubber smells when placing the "B" train in service (July 27, 2006 and August 2, 2006); and 2) system flow imbalances that only occurred with the "B" train in service (August 1, 2006, two occasions).

26EnclosureSection 4OA2.2 describes a finding associated with the Unit 3 containment high rangeradiation monitors (HRRMs). The cause of the finding is related to the cross-cutting aspect of Problem Identification and Resolution, in that, Dominion failed to adequately evaluate and correct the condition for impact on operability. Specifically, the issue was not resolved in a timely manner and the interim measures were not effectively communicated to the operations staff nor included in relevant procedures..4Heat Sink Performance

a. Inspection Scope

The inspector reviewed a sample of CRs related to the selected HXs and the servicewater system, to determine whether Dominion was appropriately identifying, characterizing, and correcting problems associated with these areas and whether the planned or completed corrective actions were appropriate. Documents reviewed during this inspection are listed in the Attachment under Section

==1R07 .

b. Findings

No findings of significance were identified..5Radioactive Material Processing and Transportation==

a. Inspection Scope

The inspector reviewed ten Condition Reports and two Nuclear Oversight Audit Reports(05-06, and 06-08) related to radioactive material processing and shipment. Through this review, the inspector assessed Dominion's threshold for identifying problems, and the promptness and effectiveness of the resulting corrective actions. This review was conducted against the criteria contained in 10 CFR 20.1101, Technical Specifications, and Dominion's procedures.

b. Findings

No findings of significance were identified.4OA3Followup of Events and Notices of Enforcement Discretion (71153).1Unit 2 Leak to Primary Drain Tank

a. Inspection Scope

On July 17, 2006, the inspectors were informed of a 1 to 2.5 gallons per minute (gpm)reactor coolant system (RCS) identified leak to the Unit 2 primary drain tank (PDT). The RCS leak was steady and appeared following the completion of a forcing pressurizer spray evolution. Dominion entered containment and isolated the source of the leakage to a pressurizer spray valve packing leakoff line which drains to the PDT. Dominion 27Enclosurerepaired the pressurizer spray valve packing leak and the identified RCS leakage valuereturned to normal. The inspectors reviewed Dominion's Abnormal Operating Procedure for RCS leaks, control room logs, technical specifications, and evaluated the adequacy of operator actions.

b. Findings

No findings of significance were identified..2Tropical Storm

a. Inspection Scope

On July 20, 2006, the inspectors discussed site preparations for tropical storm Beryl withDominion. Dominion reviewed applicable storm preparation procedures, evaluated in-progress work on the Unit 3 intake structure and the Unit 3 "A" emergency diesel generator, and conducted a storm preparations meeting with Operations, Work Control, Engineering, Security, and Site Services personnel. Dominion also conducted site walkdowns to ensure any loose equipment or material was secure in the event of high winds. The inspectors tracked the tropical storm path, reviewed Dominion's preparations and procedures, and conducted a walkdown of the site.

b. Findings

No findings of significance were identified..3Unit 2 Leak from Pressurizer Spray Flow Control Valve Packing

a. Inspection Scope

On July 31, 2006, at 11:12 p.m., Operations personnel responded to a 4 gpm RCS leakbased on a lowering level in the volume control tank and rising level in the PDT shortly following a biweekly forced pressurizer spray evolution. Operators entered AOP-2568, "Reactor Coolant System Leakage," and promptly determined the source of the leak to be coming from the 2-RC-100E pressurizer spray flow control valve packing. Leakage from the packing was being directed to the PDT through a leakage detection line coming off the spray control valve's bonnet. On August 1, 2006, at 5:23 a.m., Dominion made a containment entry at 100 percent power and stopped the leakage by isolating the associated leakage detection line. Dominion processed this configuration change as an alternate plant configuration consistent with site procedures, and entered the condition into their corrective action program (CR-06-07086).

b. Findings

No findings of significance were identified.

28Enclosure.4Loss of Control Board Annunciators

a. Inspection Scope

On August 11, 2006, the inspectors observed operator response to a loss of Unit 3 MainControl Board #4 annunciators due to a failed power supply. Operators followed alarm response procedures for a failure of the Main Board # 4 annunciator alarms and entered AOP-3574, "Loss of Main Board Annunciation." Emergency action level applicability was reviewed (no EAL applied), an additional operator was staged at the panel to monitor Main Control Board #4 indications, the computer alarm printer was monitored for off-normal conditions, and instrumentation and control technicians commenced troubleshooting the power supply for corrective action. The inspectors evaluated the adequacy of operator actions and reviewed AOP-3574, Operating Procedure 3353.MB4A, EALs, and TSs.

b. Findings

No findings of significance were identified..5Unit 3 "A" Rod Control/Motor Control Center (MCC) Air Conditioning Maintenance

a. Inspection Scope

On August 31, 2006, Operations personnel removed the Unit 3 "B" EDG from service formaintenance at 3:09 a.m. At 9:17 a.m., operators authorized work on both the "A" and "B" rod control/MCC room air conditioning units. At 10:33 a.m., during the conduct of AC sources checks for the inoperable "B" EDG, operators realized that the "A" rod control/MCC air conditioning unit should not have been removed from service.

Operators entered TS 3.8.1.1, action b.3, for both the "B" EDG inoperable and "A" train equipment inoperable, which results in a Shutdown to Hot Standby within six hours. The work package for the "A" rod control/MCC air conditioning maintenance was pulled back, both air conditioning units were started, and TS 3.8.1.1, action b.3 was exited at 11:00 a.m. Maintenance had not commenced on the "A" rod control/MCC air conditioning unit when the work-control error was discovered.

b. Findings

No findings of significance were identified..6(Closed) Licensee Event Report 05000423/2004-003-00, Oil Leak May Have CausedUnrecognized Inoperability of Safety Injection PumpOn November 4, 2004, it was determined that an existing oil leak, previously assessedas not affecting the operability of Unit 3 safety injection pump, 3SIH*P1A, may have rendered the pump inoperable. Dominion determined the root cause to be a latent organizational weakness in understanding the risks and consequences of oil leaks on safety-related equipment. Dominion took corrective actions to address the root cause 29Enclosureas well as other contributing causes to prevent recurrence of this condition. The LERwas reviewed by the NRC and no additional findings of significance or violations of NRC requirements were identified. On July 7, 2006, Dominion submitted a withdrawal of LER MP3-2004-003, after completing a technical evaluation that concluded that the emergency core cooling subsystem remained operable in the as-found condition. The NRC reviewed the technical evaluation and concluded that the technical evaluation was adequate to support the retraction of LER MP3-2004-003. The LER was reviewed by the NRC and no additional findings of significance or violations of NRC requirements were identified. This LER is closed..7(Closed) LER 05000336/2006-001-00 and LER 05000336/2006-001-01, Loss ofCharging FunctionOn January 9, 2006, operators declared both Unit 2 charging pumps inoperable due to acharging pump discharge pulsation bladder failure alarm and a drop in charging header flow indication. The failure of the discharge pulsation bladder was determined to be the result of operating the bladder at a high pre-charge pressure combined with changes made to the bladder shell during fabrication. The pulsation bladder failure coupled with an over reliance on industry operating experience and faulty design assumptions were determined to be Dominion's root cause. Dominion took corrective actions to address the root cause as well as other contributing causes to prevent recurrence of this condition. This issue was previously reviewed by the inspectors in NRC Inspection Report 05000336/2006002, Section 1R14, and dispositioned in Inspection Report 05000336/2006006, Section 4OA2.1.c.3, as a Green NCV of 10 CFR 50, Appendix B, Criterion III, "Design Control." The LER was reviewed by the NRC and no additionalfindings of significance or violations of NRC requirements were identified. This LER is

closed..8(Closed) LER 05000336/2006-004-00, Failure to Enter the Technical SpecificationAction Statement for Inoperable Reactor Protection System TripsOn April 13, 2006, the NRC identified an historical issue related to Dominion's failure tocomply with Unit 2 Technical Specification requirements when one wide range nuclear instrumentation channel was taken out of service for testing. This issue was reviewed by the inspectors and dispositioned as a Green NCV in Inspection Report 05000336/2006002. This LER and the associated condition reports were reviewed by the inspectors and no additional findings of significance or violations of NRC requirements were identified. This LER is closed..9(Closed) LER 05000336/2006-005-00, Inadvertent Actuation of "A" Motor-DrivenAuxiliary Feedwater PumpOn May 2, 2006, with Unit 2 at 100 percent power, the "A" motor-driven auxiliaryfeedwater pump automatically started due to a personnel error during restoration following surveillance testing. Dominion operators recognized that the start signal was invalid, secured the pump, and entered the issue into the corrective action program (CR-06-04271). The inspectors reviewed this LER and the associated condition report 30Enclosureto verify that Dominion's causal analysis and corrective actions were adequate. Nofindings of significance or violations of NRC requirements were identified. This LER is

closed.4OA5Other Activities.1(Closed) Unresolved Item (URI) 05000336&423/2005008-1, Acceptability or Suitability ofMillstone Unit 2 and Unit 3 Scenario Based Testing for Meeting ANSI/ANS-3.5-1198 Performance Testing CriteriaThis URI was opened because the American National Standards Institute (ANSI) standard provides little guidance concerning what constitutes acceptable plant data comparison for scenario based testing, and the inspectors did not consider the facility tests to be adequate. For this inspection, the inspectors reviewed NSEM-6.06 Revision 4, "Simulator Scenario Based Testing", and the tests listed under documents reviewed in the Attachment 1R11. This latest revision of the scenario based testing procedure provides for a more detailed evaluation than previously. Absent more specific requirements in the ANSI Standard or Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities For Use in Operator Training and License Examination," this item is

closed.4OA6Meetings, Including ExitBiennial Heat Sink Performance Exit Meeting SummaryOn July 14, 2006, the inspector presented the overall inspection results to Mr. R. Griffinand other members of the staff, who acknowledged the findings. The inspector asked Dominion whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.Two Annual PI&R Samples Exit Meeting SummaryOn September 7, 2006, the inspector presented the overall inspection results relative totwo PI&R annual samples to Mr. R. Griffin and other members of the staff, who acknowledged the findings. The annual samples related to the Unit 3 Containment High Range Radiation Monitors and the Unit 2 Radiation Monitoring System. The inspectorasked Dominion whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified. A telephone re-exit was conducted with Mr. R. Griffin on October 23, 2006, related to the Unit 3 Containment High Range Radiation Monitors.Integrated Report Exit Meeting SummaryOn October 12, 2006, the resident inspectors presented the overall inspection results toMr. A. Skip Jordan and other members of his staff. Dominion acknowledged the conclusions presented. The inspectors asked Dominion whether any of the material 31Enclosureexamined during the inspection should be considered proprietary. No proprietaryinformation was identified.40A7Licensee-Identified ViolationThe following finding of very low safety significance (Green) was identified by Dominionand is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a non-cited violation.*10 CFR 50.54(q) requires that licensees maintain their emergency plans. TheMillstone Nuclear Power Station Emergency Plan, Section 4, Classification System, states that incident classifications are driven by unit specific emergency action level (EAL) tables. The Millstone EALs described in Emergency Plan Implementing Procedure MP-26-EPI-FAP06, Classification and protective action recommendations (PARs), are based upon criteria established under Revision 2 to NUMARC/NESP-007, Methodology for Development of Emergency Action Levels. Contrary to the above, in August 2006, Millstone 3 personnel identified that the containment vent and supplemental collection and release system (SLCRS) radiation monitor channels (RE-10A and RE-19A, respectively), called out in the Unit 3 EALs, had setpoints which were not set for the Alert C-1 level for the offsite dose

OA1 EAL.

Dominion's investigation determined that the plant process computer did provide an alarm at the proper setpoints. Corrective actions planned by Dominion included changing the radiation monitor designation in the EAL so that channels with the proper indicating range and alarm setpoint would meet the Alert thresholds in the EALs. The inspector reviewed Dominion's 10 CFR 50.54(q) review for the EAL changes and determined that the error associated with this EAL parameter to be of very low safety significance. The inspector determined the error would not have delayed the declaration of any emergency, because redundant EALs and instrumentation were available that would have indicated an offsite release at the Alert threshold.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

B. Bartron, Licensing

K. Beagle, Systems Engineer - Radwaste Systems

J. Bergin, Supervisor - Nuclear Operations Support

G. Closius, Licensing Engineer

M. Cote, Supervisor, Nuclear Training Unit 2

D. Delcore, Supervisor - Health Physics

T. Gilbert, Millstone Emergency Preparedness Coordinator

R. Griffin, Director, Nuclear Station Safety & Licensing

B. Hoffner, Manager Nuclear Operations

G. Holtz, Radwaste Health Physicist

T. Horner, Supervisor, Nuclear Training Unit 2

A. Jordan, Director, Nuclear Station Operations and Maintenance

T. Kulterman, Supervisor, Nuclear Training Unit 3

J. Kunze, Supervisor, Nuclear Shift Operations Unit 2

P. Luckey, Millstone Emergency Preparedness Manager

R. MacManus, Director, Nuclear Engineering

D. MacNeill, Supervisor - Nuclear System Engineering

J. Mangeno - Unit 3 Fire Protection Engineer

M. Marino, Supervisor - Mechanical Design Engineering

G. McGovern, Supervisor - Nuclear Engineering

T. Moore, System Engineer - Service Water

A. Price, Site Vice President - Millstone

J. Riley, Senior Instructor (Nuclear Operations)

B. Souder, Simulator Analyst Specialist

J. Spence, Manager of Nuclear Training

R. Sturgis, Supervisor - Auxiliary Systems Engineering

H. Tompson, System Engineer - RBCCW

P. Tulba, Supervisor - Radioactive Material Control

S. Turowski, Supervisor - Health Physics Technical Services

NRC personnel

G. S. Barber, Senior Project Engineer, Division of Reactor Projects (DRP)

S. T. Barr, Senior EP Inspector, Division of Reactor Safety (DRS)

J. C. Benjamin, Resident Inspector, DRP

G. T. Bowman, Resident Inspector, Indian Point 2, DRP

J. M. D'Antonio, Senior Operations Engineer, DRS

E. E. Huang, Reactor Engineer, DRP

J. E. Josey, Reactor Inspector, DRS

S. R. Kennedy, Resident Inspector, DRP

W. J. Raymond, Senior Resident Inspector, Pilgrim, DRP

A-2Attachment

T. A. Moslak, Health Physicist, DRS

J. E. Richmond, Reactor Inspector, DRS

S. M. Schneider, Senior Resident Inspector, DRP

C. R. Welch, Resident Inspector, Pilgrim, DRP

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened05000336/2006004-02URIApplication of TS 3.0.5 forEmergency or Normal Power Source

Inoperable (1R15.1)

Opened and Closed

05000336/2006004-01NCVFailure to Implement CorrectiveActions to Prevent Repeat Vital AC

480V Switchgear Cooling Damper

Failures (1R04.1)05000336/2006004-03NCVFailure to Identify an AdverseCondition Affecting Control Room

Emergency Ventilation Performance

(1R15.2)

05000423/2006004-04NCVFailure to Account for All ShippedRadioactive Material on the Uniform

Manifest (2PS2)

05000423/2006004-05NCVFailure to Comply with TechnicalSpecification Required Actions for

Inoperable Containment High Range

Radiation Monitors (4OA2.2)

Closed

05000423/2004-003-00LEROil Leak May Have CausedUnrecognized Inoperability of Safety

Injection Pump (4OA3.6)05000336/2006-001-00,LERLoss of Charging Function (4OA3.7)05000336/2006-001-01

A-3Attachment05000336/2006-004-00LERFailure to Enter the TechnicalSpecification Action Statement for

Inoperable Reactor Protection

System Trips (4OA3.8)05000336/2006-005-00LERInadvertent Actuation of "A" MotorDriven Auxiliary Feedwater Pump

(4OA3.9)05000336&423/2005008-1URIAcceptability or Suitability ofMillstone Unit 2 and Unit 3 Scenario

Based Testing for Meeting

ANSI/ANS-3.5-1198 Performance

Testing Criteria (4OA5.1)

Discussed

05000336/2006006-03NCVInadequate Suitability of ApplicationEvaluation for Dampener

Modification

(4OA3.6)

Section 1R01: Adverse Weather ProtectionUnit 2 Technical SpecificationUnit 2

UFSAR