IR 05000245/2008002
Download: ML081300080
Text
May 8, 2008
Mr. David Christian Sr. Vice President and Chief Nuclear Officer Dominion Resources 5000 Dominion Boulevard Glenn Allen, VA 23060-6711
SUBJECT: MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2008002 AND 05000423/2008002
Dear Mr. Christian:
On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station Unit 2 and Unit 3. The enclosed inspection report documents the inspection results, which were discussed on April 8, 2008, with Mr. Alan Price and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the 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 three NRC-identified findings of very low safety significance (Green).
Two of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Millstone.
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Raymond J. Powell, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-336, 50-423 License Nos. DPR-65, NPF-49
Enclosure:
Inspection Report No. 05000336/2008002 and 05000423/2008002 w/
Attachment:
Supplemental Information
cc w/encl: J. A. Price, Site Vice President, Millstone Station C. L. Funderburk, Director, Nuclear Licensing and Operations Support W. Bartron, Supervisor, Station Licensing J. Spence, Manager Nuclear Training 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, Jr., Ph.D, Director, State of Connecticut SLO Designee J. Buckingham, Department of Public Utility Control C. Meek-Gallagher, Commissioner, Suffolk County, Department of Environment and Energy V. Minei, P.E., Director, Suffolk County Health Department, Division of Environmental Quality R. Shadis, New England Coalition Staff S. Comley, We The People D. Katz, Citizens Awareness Network (CAN)
R. Bassilakis, CAN
SUMMARY OF FINDINGS
.........................................................................................................3
REPORT DETAILS
.....................................................................................................................6
REACTOR SAFETY
...................................................................................................................6 1R01 Adverse Weather Protection..........................................................................................6 1R04 Equipment Alignment.....................................................................................................7 1R05 Fire Protection...............................................................................................................8 1R06 Flood Protection Measures............................................................................................9 1R07 Heat Sink Performance................................................................................................10 1R11 Licensed Operator Requalification Program................................................................10 1R12Maintenance Effectiveness .........................................................................................11 1R13 Maintenance Risk Assessments and Emergent Work Control.....................................11 1R15 Operability Evaluations................................................................................................12 1R18 Plant Modifications.......................................................................................................15 1R19 Post-Maintenance Testing...........................................................................................16 1R22 Surveillance Testing.....................................................................................................17 1EP6 Drill Evaluation.............................................................................................................21 1EP7 Force-On-Force Exercise Evaluation...........................................................................22
RADIATION SAFETY
...............................................................................................................22 2OS1 Access to Radiological Significant Areas.....................................................................22 2OS2 ALARA Planning and Controls....................................................................................24
OTHER ACTIVITIES
[OA]........................................................................................................26
4OA1 Performance Indicator (PI) Verification........................................................................26 4OA2 Identification and Resolution of Problems...................................................................27 4OA6 Meetings, including Exit...............................................................................................29
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
..................................................................................................A-1
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
......................................................A-2
LIST OF DOCUMENTS REVIEWED
......................................................................................A-2
LIST OF ACRONYMS
............................................................................................................A-9
- OF [[]]
- FINDIN [[]]
GS IR 05000336/2008-002, 05000423/2008-002; 01/01/2008 - 03/31/2008; Millstone Power Station
Unit 2 and Unit 3; Operability Determinations and Surveillance Testing.
The report covered a three-month period of inspection by resident and region-based inspectors.
Three green findings were identified, two of which were non-cited violations (NCVs). The
significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the
significance determination process (SDP) does not apply may be Green or be assigned a
severity level after
NRC's program for overseeing the safe
operation of commercial nuclear power reactors is described in
- NUR [[]]
EG-1649, "Reactor
Oversight Process," Revision 4, dated December 2006.
- A. [[]]
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. The inspectors identified a finding for Dominion's failure to evaluate a non-conforming plant condition against the current licensing basis (CLB) as required by
Dominion procedure
AA-102-1101, Revision 0, "Development of Technical Basis to
Support Operability Determinations." Specifically, Dominion, in multiple instances, failed to evaluate the impact that a potential common mode charging system failure would
have on the Updated Final Safety Analysis Report Chapter 14.6.1, "Inadvertent Opening
of Power Operated Relief Valves (PORVs)," event, the analysis of record for which
credited both charging and safety injection availability. Corrective actions for this issue
included the initiation of an operations standing order and crew briefings to ensure all
crews understood the CLB related to Unit 2 charging and the need to implement the
compensatory action for this chapter 14.6.1 event, and a subsequent operability
determination (OD) revision to ensure charging was properly evaluated and documented
within the OD. This finding is more than minor because, if left uncorrected, the issue would become a
more significant safety concern. Specifically, degraded and non-conforming plant
conditions must be evaluated against their credited functions in the CLB to ensure the
adverse condition is properly evaluated for operability. This finding was determined to
be of very low safety significance (Green) because it did not result in a loss of charging
system operability or functionality. This finding has a cross-cutting aspect in the area of
Problem Identification and Resolution, Corrective Action Program component, because
Dominion did not thoroughly evaluate a Unit 2 charging system non-conforming
condition against the
- CLB [[[P.1(c)]. (Section 1R15) Green. The inspectors identified a non-cited violation (]]
XI, "Test Control," for Dominion's failure to adequately evaluate surveillance
test results to ensure test acceptance criteria had been met on June 20, 2007.
Specifically, the inspectors identified that the "A" charging pump pulsation dampener
4surveillance test had incorrect data (i.e., testing duration time) and had been accepted as satisfactorily complete, although the test data was outside the surveillance
acceptance criteria. The test, in part, demonstrated that nitrogen gas from a failed
charging pump discharge dampener would not migrate into the common suction line
prior to the credited operator action to shut the pump's suction valve. A subsequent
review determined the surveillance test data was incorrect and the "A" charging pump
was operable. Dominion's corrective actions for this issue included briefings to provide
additional coaching and heighten awareness to the Unit 2 operations shift crews, a
review of actual surveillance computer data and review of subsequent surveillances to
ensure system operability, and the creation of a trend condition report including other
related human performance errors (CR-08-03220). This finding was more than minor because it was associated with the human
performance attribute of the Mitigating Systems cornerstone and affected the
cornerstone objective of ensuring the availability of systems that respond to initiating
events to prevent undesirable consequences (i.e., core damage). Specifically, the
failure to identify out of specification data could result in the failure to identify inoperable
equipment. The inspectors also concluded that if the failure to properly evaluate
charging pump discharge dampener test data was not corrected, a more significant
concern could exist (i.e. common mode failure of charging). The finding was
determined to be of very low significance (Green), because it was a deficiency
confirmed not to result in loss of safety function. The performance deficiency had a
cross-cutting aspect in the area of Problem Identification and Resolution, Corrective
Action Program component, because Dominion did not identify out of specification test
data P.1(a). (Section 1R22). Green. The inspectors identified a non-cited violation (NCV) of
XVI, "Corrective Action," for Dominion's failure to identify a condition adverse to
quality after the "B" service water (SW) pump failed a Technical Specification in-service
test (IST). Specifically, on March 9, 2008, Dominion declared the "B" Service Water
(SW) pump operable, despite a failed IST flow surveillance. Dominion based this
declaration on the incorrect assumption that the failed pump differential pressure (dp)
was indicative of faulty test equipment vice an actual equipment issue. On March 10, 2008, Dominion determined that the unacceptable "B" SW dp was caused by
back pressure from the running "C" SW pump through the shut "B" swing pump cross
connect valve (2-SW-79B). The inspectors identified that Dominion did not have a
reasonable basis to consider the IST invalid based on the information available at the
time. Corrective actions for this issue included implementing an alternate plant
configuration to ensure train separation, performing an assessment to evaluate past
operability and to establish a bounding service water temperature at which the "B"
service water pump would be considered inoperable, and incorporating the 2-SW-97B
leakage repair in the 2R18 refueling outage. This finding was more than minor because it was associated with the equipment
performance attribute of the Mitigating System cornerstone, and affected the
cornerstone's objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Specifically, Dominion concluded that the "B"
IST containing
5unacceptable dp data was invalid based, in part, on an inability to justify the results (i.e. high dp and nominal flow). Consequently, the "B" SW pump was inappropriately
declared operable and the actual degraded condition was not promptly identified and
corrected. This finding is of very low safety significance (Green) because it did not
result in a confirmed loss of service water train operability. This finding has a
cross-cutting aspect in the area Human Performance, Decision Making Component,
because Dominion did not use conservative assumptions in restoring "B" SW pump
operability following a failed IST surveillance H.1(b). (Section 1R22)
- 6REPORT [[]]
DETAILS Summary of Plant Status
Millstone Units 2 & 3 operated at or near 100 percent through out the inspection period with the
following exceptions. Unit 3 reduced power to 88 percent on January 18, 2008, and to 90 percent
on February 6, 2008, to perform turbine control valve testing. 1.
SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01) .1 Seasonal Site Inspection a. Inspection Scope (1 Sample) The inspectors reviewed Unit 3 readiness for seasonal site conditions, specifically extreme cold weather. The inspectors reviewed procedures and operator logs, interviewed
the work control supervisor, and walked down the heat tracing for the high head safety
injection pumps recirculation line and the component cooling water make-up pumps, to
determine if the actions required by Dominion's procedures were completed. Documents
reviewed during the inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
.2 Impending Adverse Weather Conditions Inspection a. Inspection Scope (1 Sample) The inspectors reviewed Unit 2 readiness for impending adverse weather conditions,
specifically high winds and rain, potentially accompanied by external flooding. The
inspector walked down flood protection barriers in the intake structure (circulating water
pumps and
EDGs) rooms, and the related
sumps and drains for the ground water system. The inspectors also reviewed Dominion
procedures for coping with external flooding, and interviewed the shift manager to
determine if the flooding mitigation plans and equipment were consistent with the
licensee's design requirements and the risk analysis assumptions. Documents reviewed
during the inspection are listed in the Attachment.
b. Findings No findings of significance were identified. 1R04 Equipment Alignment (71111.04)
.1 Partial System Walkdowns (4 Samples) a. Inspection Scope The inspectors performed four partial system walkdowns during this inspection period.
The inspectors reviewed the documents listed in the Attachment to determine the correct
system alignment. The inspectors conducted a walkdown of each system to determine if
the critical portions of selected systems were correctly aligned, in accordance with
applicable procedures, and to identify any discrepancies that may have had an effect on
operability. The walkdowns included selected switch and valve position checks, and
verification of electrical power to critical components. Finally, the inspectors evaluated
other elements, such as material condition, housekeeping, and component labeling.
Documents reviewed during the inspection are listed in the Attachment. The following
systems were reviewed based on their risk significance for the given plant configuration:
Unit 2 * "A" & "B" trains of high pressure safety injection (HPSI) while the "C"
- HPSI [[pump was inoperable for maintenance; and * "A" & "B" trains of charging with the "B" charging pump out of service. Unit 3 * "C" charging while aligned to the "A" train due to "A" charging pump rotating element replacement; and * "B" residual heat removal (]]
RHR) system while the "A" RHR system was out of service for testing. b. Findings
No findings of significance were identified, .2 Complete System Walkdown (71111.04S)
a. Inspection Scope (1 Sample) The inspectors completed a detailed review of the alignment and condition of the Unit 3
"B" EDG. The inspectors conducted a walkdown of the system to determine whether
critical portions, such as valve positions, switches, and breakers, were correctly aligned in
8accordance with procedures to identify any discrepancies that may have had an effect on operability. The inspectors also conducted a review of outstanding maintenance work orders to
determine if the deficiencies significantly affected the "B" EDG system functions. In
addition, the inspectors discussed system health with the system engineer and reviewed
the condition report (CR) database to determine whether equipment alignment problems
were being identified and appropriately resolved. Documents reviewed during the
inspection are listed in the Attachment.
b. Findings
No findings of significance were identified. 1R05 Fire Protection (71111.05Q) a. Inspection Scope (14 Samples) The inspectors performed walkdowns of fourteen fire protection areas during the
inspection period. The inspectors reviewed Dominion's fire protection program to
determine the required fire protection design features, fire area boundaries, and
combustible loading requirements for the selected areas. The inspectors walked down
these areas to assess Dominion's control of transient combustible material and ignition
sources. In addition, the inspectors evaluated the material condition and operational
status of fire detection and suppression capabilities, fire barriers, and any related
compensatory measures. The inspectors compared the existing conditions of the areas to
the fire protection program requirements to determine if all program requirements were
being met. Documents reviewed during the inspection are listed in the Attachment. The
fire protection areas reviewed included: Unit 2 * Auxiliary Building Boric Acid Batch Tank / Chemical Addition Tank (Fire Area A-12); * Auxiliary Building 480 Volt
- MCC B61 and B41A (Fire Area A-13); * Auxiliary Building Spent Fuel Pool and Cask Laydown Area (Fire Area A-14); *
- EDG "B" Cubicle (Fire Area A-16); and * Intake Structure Pump Room (Fire Area I-1 Zone A). Unit 3 * Main Steam Valve Enclosure, Elevation 24' 6" (Fire Area
- MSV -1); * Main Steam Valve Enclosure, Elevation 71' (Fire Area MSV-1); * Circulating & Service Water Pumphouse, North Floor Area, Elevation 14' 6" (Fire Area
CB-8). b. Findings No findings of significance were identified.
.2 Annual Fire Drill Observation (71111.05A)
a. Inspection Scope (1 Sample) Unit 2 The inspectors observed a fire brigade drill on January 22, 2008, to evaluate the
readiness of station personnel to fight fires. The drill simulated a fire in the Unit 2
Drumming/Maintenance Room. The inspectors observed the fire brigade members using
protective clothing, turnout gear, and self-contained breathing apparatus and entering the
fire area. The inspectors also observed the fire fighting equipment brought to the fire
scene to evaluate whether sufficient equipment was available to effectively control and
extinguish the simulated fire. The inspectors evaluated whether the permanent plant fire
hose lines were capable of reaching the fire area and whether hose usage was
adequately simulated. The inspectors observed the fire fighting directions and
communications between fire brigade members. The inspectors also evaluated whether
the pre-planned drill scenario was followed, and observed the post drill critique to evaluate
if the drill objectives were satisfied and that any drill weaknesses were discussed.
b. Findings No findings of significance were identified.
1R06 Flood Protection Measures (71111.06)
.1 Internal Flooding Inspection a. Inspection Scope (1 Sample) The inspectors reviewed the internal flood protection measures for the Unit 3 auxiliary
feedwater pump cubicles. 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 Updated Final Safety Analysis Report
(UFSAR), the internal flooding evaluation, and related documents. The inspectors
examined the as-found equipment and conditions to determine if they remained consistent
with those indicated in the design basis documentation, flooding mitigation documents,
10and risk analysis assumptions. Documents reviewed during the inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
1R07 Heat Sink Performance (71111.7A) Inspection Scope (1 Sample) The inspectors reviewed one sample associated with the Unit
- 3 HVQ [[]]
ACUS1B heat
exchanger. The inspectors observed the as-found condition of the heat exchanger once it
was opened to verify that any adverse fouling concerns were appropriately addressed.
The inspectors reviewed the results of the inspections performed in accordance with
Dominion procedures including Proto-Power Calculation 03-100, Revision A. The
inspectors reviewed the inspection results against the acceptance criteria contained within
the procedure to determine whether all acceptance criteria had been satisfied. The
inspectors also reviewed the
- UFS [[]]
AR to determine if heat exchanger inspection results
were consistent with the design basis. Documents reviewed during the inspection are
listed in the Attachment.
b. Findings No findings of significance were identified. 1R11 Licensed Operator Requalification Program (71111.11) Resident Inspector Quarterly Review (71111.11Q)
a. Inspection Scope (2 Samples) The inspectors observed simulator-based licensed operator requalification training for Unit
on January 29, 2008, and the Unit 3 Operational Exam 22, Revision 1, on
January 29, 2008. The inspectors evaluated crew performance in the areas of clarity and
formality of communications; ability to take timely actions; prioritization, interpretation, and
verification of alarms; procedure use; control board manipulations; oversight and direction
from supervisors; and command and control. Crew performance in these areas was
compared to Dominion management expectations and guidelines as presented in
MP-100-1000, AMillstone Operations Guidance and Reference Document.@ The inspectors compared simulator configurations with actual control board configurations. The inspectors also observed Millstone evaluators discuss identified weaknesses with the
crew and/or individual crew members, as appropriate. Documents reviewed during the
inspection are listed in the Attachment.
11 b. Findings
No findings of significance were identified. 1R12 Maintenance Effectiveness (71111.12Q) a. Inspection Scope (4 Samples) 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. The inspectors reviewed Millstone=s ability to identify and address common cause failures, the applicable maintenance rule scoping document for each system, the current classification of the systems in accordance with
CFR 50.65 (a)(1) or (a)(2), and the adequacy of the performance criteria and goals
established for each system, as appropriate. The inspectors also reviewed recent system
health reports, CRs, apparent cause determinations, function failure determinations,
operating logs and discussed system performance with the responsible system engineer.
Documents reviewed are listed in the Attachment. The specific systems/components
reviewed were: Unit 2 * charging pumps and associated instrumentation; and * EDG room sumps, drains, and backflow preventers.
Unit 3 * SW strainers; and * auxiliary feedwater system.
b. Findings No findings of significance were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) a. Inspection Scope (6 Samples) The inspectors evaluated online risk management for emergent and planned activities.
The inspectors reviewed maintenance risk evaluations, work schedules, and control room
logs to determine if concurrent planned and emergent maintenance or surveillance
activities adversely affected the plant risk already incurred with out-of-service
components. The inspectors evaluated whether Dominion took the necessary steps to
control work activities, minimize the probability of initiating events, and maintain the
functional capability of mitigating systems. The inspectors assessed Dominion=s risk
2management actions during plant walkdowns. Documents reviewed during the inspection are listed in the Attachment. The inspectors reviewed the conduct and adequacy of
scheduled and emergent maintenance risk assessments for the following maintenance
and testing activities: Unit 2 * Planned work activities associated with "B"
EDG unavailability following a fast start run on January 11, 2008; * Planned work activities associated with "D" circulating water pump (reactor trip risk) and Facility 1 reserve station service transformer (RSST) testing on January 22, 2008;
and * Planned work activities associated with "B" charging pump check valve leakage repairs on February 22, 2008. Unit 3 * Dominion's operational decision making implementation action plan for resolving "C" accumulator leakage on January 18, 2008; * Dominion's troubleshooting efforts for the electrohydraulic control system's over response to grid frequency changes in Load Set on January 18, 2008; and * Planned work activities associated with "A" charging pump replacement, "B" Safety Injection High (SIH) pump operational test, and "A" SIH pump run on
February 13, 2008. b. Findings No findings of significance were identified. 1R15 Operability Evaluations (71111.15) a. Inspection Scope (7 Samples) The inspectors evaluated seven
NRC Regulatory
Issue Summary 2005-20, Revision to Guidance Formerly Contained in NRC Generic
NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability.@ The inspectors also discussed the conditions with operators and system and design engineers, as necessary. Documents reviewed during the inspection are listed in the Attachment.
13The inspectors reviewed the adequacy of the following evaluations of degraded or non-conforming conditions:
Unit 2 *
- OD [[]]
- TMLP [[[Thermal Margin Low Pressure] is Fluctuating between 2010 and 2060]]
- OD [[]]
- OD [[]]
CR-08-01810, "Impact from PZR Blockhouse Modification Needs to be Quantified and Addressed for Future Unit 2 Pressurizer Safety Valve Setpoint
Testing;" *
- OD [[]]
OD MP2-008-06, "Unit 2 Charging System Common Mode Failure."
Unit 3 *
- OD [[]]
ESF Outdoor Sump Indicated Tritium Levels." b. Findings Introduction. The inspectors identified a finding for Dominion's failure to evaluate a non-conforming plant condition against the current licensing basis (CLB) as required by
Dominion procedure
AA-102-1101, Revision 0, "Development of Technical Basis to
Support Operability Determinations." Specifically, Dominion, in multiple instances, failed to evaluate the impact that a potential common mode charging system failure would have
on the
- UFS [[]]
AR Chapter 14.6.1, "Inadvertent Opening of Power Operated Relief Valves
(PORVs)," event, the accident analysis of record for which credited both charging and
safety injection availability. Description. On January 9, 2006, a charging system common mode failure occurred at Unit 2. After a charging pump was secured, nitrogen from a failed discharge dampener
bladder migrated backwards through the charging pump's internal check valves and into
the common suction line. This resulted in the remaining standby charging pumps
becoming gas bound shortly after they were started. Dominion initiated
- OD [[]]
MP2-008-06
to ensure that the common mode failure would not reoccur before a final corrective action
plan could be implemented to ensure long term success. The OD assumed that upon a
bladder failure and its associated charging pump being secured, it would take at least two
hours for nitrogen gas migration to bind the common suction header. The OD determined
that the charging system remained operable since it instituted a compensatory measure
that required a charging pump's suction valve to be shut within the two hour period thus
preventing the nitrogen gas from reaching the common suction line. The OD, and
subsequent charging related ODs, concluded that the charging pumps were not credited
14in any
- UFS [[]]
AR Chapter
14.6.1, "Inadvertent Opening of the Pressurizer Power Operated Relief Valves (PORVs),"
stated that "The charging and SISs' [safety injection systems] have been shown to have
sufficient capacity to easily compensate for the loss of primary coolant mass through the
inadvertent opening of the pressurizer relief valves. Therefore, the core is not expected to
uncover during this event." Dominion identified that Areva had performed the analysis in
the first cycle for which they provided fuel (cycle 10) and had remarked in the
- UFS [[]]
- PO [[]]
RVs was
compensated by the actions of the safety injection and charging pumps. Furthermore, the
modeling of the Emergency Core Cooling System (ECCS) that accompanied cycle 10
included the automatic actuation of the charging pumps. This CR was assigned a level N
significance (lowest significance and identified as a condition not adverse to quality) and
did not contain an operation's assessment to determine if the CR adversely impacted
plant operations (i.e., impact of operability not evaluated). The CR created a corrective
action to perform an engineering technical evaluation to evaluate the effects that removing
charging system flow would have on the
EV-08-004).
This evaluation was completed on February 15, 2008, and concluded that
- HP [[]]
SI, by itself,
was adequate to prevent uncovering the core following inadvertent opening of the
- OD [[]]
UFSAR Chapter 14.6.1
event. Dominion determined that the charging system remained operable since the Unit 2
charging system was not credited in the chapter 14.6.1 event. Dominion engineering
concluded that the
- UFS [[]]
AR Chapter 14.6.1 statements were administrative and not
reflective of the
- CLB. From March 14, 2006 through March 25, 2008, the inspectors engaged Dominion's operations, engineering staff, and management on the inadequate
OD; and, therefore the
inadequate basis to support charging system operability. Dominion initiated
CR 08-02880, and concluded that the charging pumps remained operable based on the
outcome of the previously performed technical evaluation (M2-EV-08-004). On
March 25, 2008, the inspectors reviewed the CR and determined that operations did not
adequately evaluate the non-conforming condition against the CLB since technical
evaluation (M2-EV-08-004) had not been processed through the 10 CFR 50.59 process.
The inspectors concluded and communicated to Dominion that technical evaluation
M2-EV-08-004 did not change the
CR-08-02919, and concluded that CR-08-02880
did not have an adequate basis to support charging system operability based on its
reference to technical evaluation M2-EV-08-004. The CR concluded that the previously
established
- OD compensatory actions must apply to the Chapter 14.6.1 event. Analysis. The performance deficiency associated with this finding was that Dominion failed to evaluate a Unit 2 non-conforming charging system condition against its
CLB, as
15required by Dominion procedure
AA-102-1101. This finding is more than minor because, if left uncorrected, the issue would become a more significant safety concern.
Specifically, degraded and non-conforming plant conditions must be evaluated against
their credited functions in the CLB to ensure the adverse condition is properly evaluated
for operability. This finding was evaluated in accordance with IMC 0609, Attachment 4,
"Phase 1 - Initial Screening and Characterization of Findings" and determined to be of
very low safety significance (Green) since it did not result in a loss of charging system
operability or functionality. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution (PI&R), Corrective Action Program component, because Dominion did not
thoroughly evaluate a Unit 2 charging system non-conforming condition against the CLB.
Enforcement. Enforcement does not apply because the performance deficiency, not evaluating a non-conforming condition against the CLB as required by Dominion
procedure
AA-102-1101, Revision 0, "Development of Technical Basis to Support
Operability Determinations," did not involve a Technical Specifications (TS) required
procedure. Dominion entered this issue into their corrective action program
(CR-08-02919). Corrective actions for this issue included the initiation of an operations
standing order and crew briefings to ensure all crews understood the CLB related to Unit
charging and need to implement the compensatory action for this chapter 14.6.1 event,
and a subsequent OD revision to ensure charging was properly evaluated and
documented within the OD. Because this finding does not involve a violation of regulatory
requirements and is of very low safety significance (Green), it is identified as
- FIN 05000336/2008002-01, Failure to Evaluate a Unit 2 Charging System Non-conforming Condition against the Current Licensing Bases. 1R18 Plant Modifications (
.1 Permanent Modification
a. Inspection Scope (1 Sample)
The inspectors reviewed a Unit 3 modification that installed a hydrostatic pump to refill the
safety injection accumulators due to system leakage. The modification was reviewed to
verify that the design bases, licensing bases, and performance capability of risk significant structures, systems, and components had not been degraded through the plant
modification and that the configuration change did not place the plant in an unsafe
condition. To assess the adequacy of the modifications, the inspectors performed a
system walkdown, interviewed plant staff, and reviewed applicable documents, including
procedures, modification packages, drawings, corrective action program documents, the
UFSAR and TS. Documents
reviewed during the inspection are listed in the Attachment.
16b. Findings No findings of significance were identified.
a. Inspection Scope (1 Sample) The inspectors reviewed a Unit 3 temporary modification which installed a manual
isolation valve in the "C" safety injection accumulator test header (DCN DM3-00-0013-08).
The modification was reviewed to evaluate if the temporary modification adversely
affected the function of the associated safety systems. The inspectors reviewed the
temporary modification and the associated
and TS to determine whether the modification affected system operability or availability.
Documents reviewed during the inspection are listed in the Attachment.
b. Findings No findings of significance were identified. 1R19 Post-Maintenance Testing (71111.19) a. Inspection Scope (5 Samples) The inspectors reviewed five post-maintenance test (PMT) activities to determine whether
the PMT adequately demonstrated that the safety-related function of the equipment was
satisfied, given the scope of the work specified, and that operability of the system was
restored. In addition, the inspectors evaluated the applicable test acceptance criteria to
evaluate consistency with the associated design and licensing bases, as well as TS requirements. The inspectors also evaluated whether conditions adverse to quality were
entered into the corrective action program for resolution. Documents reviewed during the
inspection are listed in the Attachment. The following maintenance activities and their
PMTs were evaluated:
Unit 2 * "B" EDG testing following troubleshooting activities on January 10, 2008.
Unit 3 *
- 3SIH -V822 testing following installation of the valve in the "C" safety injection accumulator test header on February 1, 2008; *
- OP 3304C, "Primary Makeup and Chemical Addition," Revision 21, after replacement of a relay in the reactor coolant makeup controller on February 28, 2008; *
ACU 2A following replacement of two freon pressure control valves and the hot gas bypass valve on March 19, 2008; and
17*
- SPROC [[]]
ENG08-3-001, "'A' Charging Pump Post Shaft Replacement Functional Test," Revision 1, following pump overhaul on March 15, 2008.
b. Findings
No findings of significance were identified. 1R22 Surveillance Testing (71111.22) a. Inspection Scope (9 Samples) The inspectors reviewed nine surveillance activities to determine whether the testing
adequately demonstrated equipment operational readiness and the ability to perform the
intended safety-related function. The inspectors attended pre-job briefs, reviewed
selected prerequisites and precautions to determine if they were met, and observed the
tests to determine whether they were performed in accordance with the procedural steps.
Additionally, the inspectors reviewed the applicable test acceptance criteria to evaluate
consistency with associated design bases, licensing bases, and TS requirements and that
the applicable acceptance criteria were satisfied. The inspectors also evaluated whether
conditions adverse to quality were entered into the corrective action program for
resolution. Documents reviewed during the inspection are listed in the Attachment. The
following surveillance activities were evaluated:
Unit 2 *
SP 2664A, "'A' Charging Pump Pulsation Dampener Test," Rev. 000, on March 25, 2008.
Unit 3 *
- SP 3601F.6, "Reactor Coolant System Water Inventory Measurement," Revision 005-05, on January 15, 2008; *
RHS*P1A Operation Readiness Test," Revision 011-05, on March 19, 2008.
18b. Findings
.1 Failure to Identify Unacceptable Unit 2 Charging Pump Surveillance Test Data Introduction. The inspectors identified a non-cited violation (NCV) of
XI, "Test Control," for Dominion's failure to adequately evaluate
surveillance test results to ensure test acceptance criteria had been met on
June 20, 2007. Specifically, the inspectors identified that the "A" charging pump pulsation
dampener surveillance test had incorrect data (i.e., testing duration time) and had been
accepted as satisfactorily complete, although the test data was outside the surveillance
acceptance criteria. The test, in part, demonstrated that nitrogen gas from a failed
charging pump discharge dampener would not migrate into the common suction line prior
to the credited operator action to shut the pump's suction valve.
Description. On February 24, 2008, the inspectors reviewed surveillance form SP 2264, "Charging Pump 'A' Pulsation Dampener Test," performed on June 19, 2007, as part of a
review to evaluate the effectiveness of the corrective actions from a previous NRC
identified finding, (NCV 05000336/2007003-03, "Failure to Adequately Evaluate
Surveillance Test Data"). The inspectors identified that the acceptance criteria for the
time duration of the test had not been met. Specifically, the test data indicated the test
had not been performed for a minimally acceptable period of one hour since the
surveillance record listed 9:52 p.m. and 10:04 p.m. as the times that the initial pump
pressure and final pump pressure were measured (12 minutes).
During the review of the surveillance results, and final approval of the surveillance, several
personnel had accepted this data as being satisfactory. Following the observation, the
inspectors notified system engineering and operations personnel of this discrepancy, and
they agreed that the acceptance criteria had not been met. Based on a review of
computer data related to the June 19, 2007, surveillance and subsequent surveillance test, Dominion concluded the "A" charging pump remained operable.
Analysis. The performance deficiency associated with this NRC identified finding involved an inadequate review of surveillance test results to ensure the Unit 2 charging system was
not susceptible to a previously identified common mode failure. This finding was more
than minor because it was associated with the human performance attribute of the
Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the
availability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage). Specifically, the failure to identify out of specification data could result in the failure to identify inoperable equipment. The inspectors also
concluded that if the failure to properly evaluate charging pump discharge dampener test
data was not corrected, a more significant concern could exist (i.e., common mode failure
of charging).
The inspectors conducted a Phase 1 SDP Table 4a worksheet for Mitigating Systems and
determined that the finding was of very low significance (Green), because it was a
deficiency confirmed not to result in loss of safety function.
19The performance deficiency had a cross-cutting aspect in the area of PI&R, Corrective Action Program component, because Dominion did not identify out of specification test
data. P.1(a).
Enforcement.
XI, "Test Control," states, in part, that test results shall be documented and evaluated to assure the test requirements have
been satisfied. Contrary to the above, on June 20, 2007, Dominion failed to identify that
the Unit 2 "A" charging pump pressure decay test had documented an unacceptable test
time frame of 12 minutes when compared to the minimum one hour time required per the
surveillance acceptance criteria. This surveillance was originally approved as satisfactory
until identified by the inspectors. Corrective actions for this issue included briefings to
provide additional coaching and heighten awareness to the Unit 2 crews, a review of
actual surveillance computer data and review of subsequent surveillances to ensure
system operability, and the creation of a trend CR including other related human
performance errors such as
NCV 05000336/2007003-03. Since
this finding is of very low safety significance (Green) and had been entered into the
licensee's corrective action program (CR-08-00817), this violation is being treated as a
NCV 05000336/2008002-02, Failure to Identify Unacceptable Unit 2 Charging Pump
Surveillance Test Data). .2 Failure to Identify a Service Water Bypass Flow Path following a Failed
CFR 50, Appendix B, Criterion XVI, "Corrective Action," for Dominion's failure to identify a condition adverse to quality after
the "B"
TS IST. Specifically, on March 9, 2008, Dominion declared the
"B"
IST flow surveillance. Dominion based this
declaration on the incorrect assumption that the failed pump dp was indicative of faulty
test equipment vice an actual equipment issue.
Description. On March 8, 2008, at 9:28 p.m., operations entered
IST for the "B" SW pump in accordance
with
IST, Facility 1," Revision 002-01. On March 9,
2008, at 12:30 a.m., the
SW pump, and "A" SW pump and discharge
check valve was completed. Operations identified that the "B" SW pump dp of 47.8 psid
had exceeded the established IST acceptance criteria of 45.7 psid. Operations
appropriately identified in step 4.1.11c that these results were unsatisfactory and
maintained the pump in an inoperable status. Operations noted in their logs that attempts
were made to adjust Facility 1 service water flow within the allowable band, however, the
"B"
CBM) technician to be
providing valid data. The "A"
IST results were
reviewed and accepted since the values were within the allowed acceptance criteria
although the pump dp appeared higher than normal. Based on satisfactory "A"
TS 3.7.4.1 was exited with the "A" SW pump operating and aligned to Facility
and "C" SW pump operating and aligned to Facility 2 at 5:40 a.m. on March 9, 2008.
20Dominion initiated
CR
was assigned a significance level N (lowest significance and identified as a condition not
adverse to quality). The shift manager's comment section noted that this issue appeared
to be an issue with the instrumentation used during the surveillance since it was difficult to
understand pump dp exceeding the maximum value unless instrumentation was suspect.
The
SW pump was considered inoperable based on the failed test
results (submitted at 4:51 a.m., on March 9, 2008).
On March 9, 2008, at 8:30 p.m., Dominion conducted a management conference call and
concluded that the "B"
IST due to faulty flow monitoring equipment.
Although the CBM technician verified that the flow instrumentation was providing valid
data, Dominion concluded that faulty flow monitoring equipment would have also
explained the higher than normal "A"
were therefore invalid. Operations subsequently declared the "B" SW pump operable and
started the "B"
SW pump
inoperable since the
SW pump had been used as a post
maintenance test following its previous overhaul.
On March 10, 2008, at 6:21 p.m., Dominion determined that the high Facility 1 "B" SW dp
was caused by back pressure from the running Facility 2 "C" SW pump through the shut
"B" swing pump cross connect valve (2-SW-97B). As a result of this valve leaking by,
approximately 500 gallon per minute of Facility 2 service water flow was being bypassed
into the Facility 1 train. Dominion subsequently shut 2-SW-97A to ensure SW Facility
train separation was maintained and entered
pumps were then considered inoperable. On March 11, 2008, at 11:27 a.m., Dominion
exited
On March 11, 2008, the inspectors determined that Dominion did not have an adequate
basis to declare the "B"
IST invalid after the unsatisfactory test results on
March 9, 2008, following the management conference call. The inspectors determined
that while the "B"
IST,
operations improperly subsequently concluded that the data was not correct based on
past instrumentation performance. The inspectors concluded that since the CBM
technician had actually verified the flow instrumentation was working properly, Dominion
had specific information which directly conflicted with their conclusion; therefore, the
station did not act in a conservative manner. The inspectors identified that it was
reasonable for Dominion to identify the cause of the high "B" SW pump dp prior to
declaring the system operable. The inspectors determined that with the "B" SW pump
inservice for Facility 1, a SW bypass flow path existed from Facility 2 (through the shut
2-SW-79B valve and through the open 2-SW-79A valve into Facility 1). The inspectors
identified that upon a loss of Facility 1, a significant portion of the "C" SW pump's flow
would be have been diverted to the Facility 1 header reducing flow to the redundant
Facility 2 train.
21Analysis. This finding was more than minor because it was associated with the equipment performance attribute of the Mitigating System cornerstone, and affected the
cornerstone's objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core damage).
Specifically, Dominion concluded that a "B"
IST containing unacceptable dp
data was invalid based, in part, on an inability to interpret the results (i.e. high d/p and
nominal flow). Consequently, the "B" SW pump was inappropriately declared operable
and the actual degraded condition was not promptly identified and corrected. This finding
is of very low safety significance (Green) because it did not result in a confirmed loss of
SW train operability.
This finding has a cross-cutting aspect in the area Human Performance, Decision Making
Component, because Dominion did not use conservative assumptions in restoring "B" SW
pump operability following a failed IST surveillance. H.1(b).
Enforcement.
XVI, "Corrective Action," states, in part, that measures shall be established to assure that conditions adverse to quality are
promptly identified and corrected. Contrary to the above, on March 9, 2008, following a
failed "B"
- IST [[]]
SW surveillance, Dominion did not identify, evaluate or correct the cause
prior to restoring the system to operable status. Dominion concluded that the test was
invalid based on the belief the data was invalid due to flow instrumentation monitoring
issues and not an actual SW equipment issue despite conflicting information. As a result,
a safety-related SW system was restored to operable status and degraded service water
by-pass flow condition reintroduced. Corrective actions for this issue included
implementing an alternate plant configuration to ensure train separation, performing an
SW temperature at which the
"B"
SW-97B leakage
repair in the 2R18 refueling outage. Because this finding is of very low safety significance
(Green) and was entered into the licensee's corrective action program (CR-08-02383),
this violation is being treated as an
EP) 1EP6 Drill Evaluation (71114.06 - 2 Samples)
.1 Classification and Notification During Requalification Training
a. Inspection Scope The inspectors reviewed the operators' emergency classification and notification
completed during requalification Unit 3 training on January 29, 2008. The inspectors
verified the classification, notification, and protective action recommendations were
accurate and timely.
2 b. Findings
No findings of significance were identified.
.2 Combined Functional Drill
a. Inspection Scope The inspectors observed the conduct of a Unit 3 licensed operator training emergency
planning drill on March 18, 2008. The inspectors observed the operating crew
performance at the simulator and the emergency response organization performance at
the technical support center and emergency operations facility. The inspectors evaluated
the classification, notification, and protective action recommendations for accuracy and
timeliness. Additionally the inspectors assessed the ability of Dominion's evaluators to
adequately address operator performance deficiencies identified during the exercise.
b. Findings
No findings of significance were identified.
1EP7 Force-On-Force Exercise Evaluation (71114.07)
a. Inspection Scope (1 Sample) The inspectors observed licensee performance in the Technical Support Center during
one site emergency preparedness drill conducted in conjunction with a Force-On-Force
exercise, documented in inspection report 05000336/2008201 and 05000423/2008201.
The inspectors observed communications, event classification and notification activities by
the simulated shift personnel for Units 2 & 3 during the drill on March 25, 2008. The
inspectors verified the classification, notification and protective action recommendations
were accurate and timely. The inspectors also observed portions of the post drill critique
to determine whether any deficiencies were also identified by Dominion evaluators.
b. Findings
No findings of significance were identified. 2.
- RADIAT [[]]
- ION [[]]
OS1 Access to Radiological Significant Areas (71121.01)
a. Inspection Scope (11 Samples) During the period February 11-15, 2008, the inspectors conducted the following activities
to determine whether the licensee was properly implementing physical, administrative,
23and engineering controls for access to locked high radiation areas, and other radiological controlled areas (RCA) during normal power operations, and that workers were adhering
to these controls when working in these areas. Implementation of these controls was
reviewed against the criteria contained in
TS, and Dominion procedures. This activity represents the completion of 11 samples relative to this inspection area
partially completing the annual inspection requirement of 21. Plant Walk down and Radiation Work Permit (RWP) Reviews (1) The inspectors toured accessible RCAs in Unit 2 and Unit 3 and, with the assistance of a radiation protection technician, performed independent radiation surveys of selected areas and components, to confirm the accuracy of survey
data, and the adequacy of postings. Surveys were conducted in the Auxiliary
Buildings, Waste Buildings, and Fuel Storage Buildings. (2) The inspectors identified plant areas where radiologically significant work activities were being performed. These activities included obtaining a Unit 3 spent resin
sample, performing maintenance on a Unit 3 charging pump, and performing
radiography on Unit
for these activities to determine if the radiological controls were acceptable,
attended pre-job briefings, and reviewed the electronic dosimeter dose/dose rate
alarm set points to determine if the set points were consistent with plant policy. (3) The inspectors determined that there were no current RWPs for airborne radioactivity areas with the potential for individual worker internal exposures to
exceed 50 mrem. (4) During 2007, there were no internal dose assessments for any actual internal exposures that reached the reporting threshold of greater than 10 mrem
Committed Effective Dose Equivalent (CEDE). The inspectors also reviewed data
for the five highest exposed individuals for 2007, and the dose/dose rate alarm
reports and determined that no exposure exceeded site administrative, regulatory,
or performance indicator criteria. Additionally, the inspectors confirmed that no
declared pregnant workers were employed during 2007. Problem Identification and Resolution (5) A review of assessment reports and field observation reports was conducted to determine if problems related to implementing radiological controls were entered
into the corrective action program for resolution. (6) Nine CRs, associated with radiation protection control access, initiated between October, 2007, and January, 2008, were reviewed and discussed with the licensee
staff to determine if the followup activities were being conducted in an effective
and timely manner, commensurate with their safety significance.
24High Radiation Area (HRA) and Very High Radiation (VHRA) Area Controls
(7) Procedures for controlling access to
VHRAs were reviewed to determine if the administrative and physical controls were adequate. The
inspectors determined that a recently implemented corporate procedure
(RP-AA-201, "Access Controls for High and Very High Radiation Areas"), provided
additional controls over the replaced site procedure RPM 5.1.3, that was
previously implemented. (8) Keys to locked high radiation areas (LHRA) stored at the control points and in the Unit 3 Control Room were inventoried and accessible
- LH [[]]
RA's were verified to be
properly secured and posted during plant tours. (9) The inspectors reviewed corporate procedure
AA-260, "Control of Radiography," and attended the pre-job briefing for performing radiography on Unit
SW piping. The inspectors determined whether access controls, including
postings, technician coverage, and site notifications, were appropriate for the
- HRA s that would occur during radiography. Radiation Worker and Radiation Protection Technician Performance (10) Several radiological related
CRs were reviewed to evaluate if the incidents resulted from repetitive worker errors to determine if an observable pattern traceable to a
similar cause was evident. (11) Radiation protection technicians and radworkers were questioned regarding their knowledge of plant radiological conditions and associated controls.
b. Findings No findings of significance were identified.
ALARA Planning and Controls (71121.02)
a. Inspection Scope (8 Samples) During the period February 11-15, 2008, the inspectors conducted the following activities
to determine whether the licensee was properly implementing operational, engineering,
and administrative controls to maintain personnel exposure as low as is reasonably achievable (ALARA) for past activities performed during 2007. Also reviewed were the
dose controls for current activities and the preparations being made for the spring (2R18)
2008 refueling outage. Implementation of these controls was reviewed against the criteria
contained in 10 CFR 20, applicable industry standards, and Dominion procedures.
25Radiological Work Planning (1) The inspectors reviewed pertinent information regarding cumulative exposure history, current exposure trends, and ongoing activities to assess past (2007)
performance and dose challenges for 2008, including the spring refueling outage
(2R18). (2) The inspectors reviewed the exposure data for tasks performed during 2007 and compared actual exposure with forecasted estimates. Included in this review were
the tasks performed during the Unit 3 (3R11) outage, on-line tasks performed for
both operating units, and dry cask loading/storage operations. (3) The inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance, and engineering to identify missing
- ALA [[]]
program elements and interface problems. The evaluation was accomplished by
reviewing recent
- ALA [[]]
- ALA [[]]
RA evaluations, departmental dose summaries, attending a 2R18 pre-outage
challenge board for steam generator eddy current testing, and interviewing the
- ALA [[]]
RA coordinator. The inspectors also reviewed the Radiation Protection
Department continuous improvement initiatives and the 5-year
- ALA [[]]
RA Plan
(2007-2011) that identifies areas for further improving radiological controls. Verification of Dose Estimates (4) The inspectors reviewed the assumptions and basis for the annual (2007) site collective exposure projections for routine power operations and maintenance
activities and compared the estimated dose with the actual dose received by
workers. The inspectors also reviewed the dose projections for the 2R18 refueling
outage to determine if there were significant deviations from the actual exposures
received for various tasks in past outages. (5) The inspectors reviewed Dominion procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks
differed from the actual dose received. The inspectors reviewed the dose/dose
rate alarm reports and exposure data for selected individuals receiving the highest
total effective dose equivalent (TEDE) exposures for 2007 to confirm that no
individual exposure exceeded the regulatory limit, or met the performance indicator
reporting guideline. Jobs-In-Progress (6) The inspectors reviewed the RWPs, attended the pre-job briefings, and observed various aspects of jobs-in-progress performed at Unit 3, including obtaining a
spent resin sample (RWP 3-08-17), charging pump repair (RWP 3-08-30), and
radiography on
RWP 3-08-25). The inspectors also reviewed the
documentation and discussed preparation for transferring spent resin into a
shipping cask at Unit 2.
26 (7) The inspectors reviewed recent
- ALA [[]]
RA evaluations developed for controlling low dose tasks. These evaluations addressed Unit 3 charging pump maintenance and
Unit 3 containment entries at power for venting the safety injection system. Problem Identification and Resolution (8) The inspectors reviewed elements of the licensee's corrective action program related to implementing the
- ALA [[]]
RA program to determine if problems were being
entered into the program for timely resolution. Eight CRs related to controlling
individual personnel exposure and programmatic
- ALA [[]]
RA challenges were
reviewed.
b. Findings No findings of significance were identified. 4.
- OTHER [[]]
- ACTIVI [[TIES [OA]]]
PI) Verification (71151) .1 Cornerstone: Barrier Integrity a. Inspection Scope (4 Samples)
The inspectors reviewed Dominion submittals for the PIs listed below to verify the
accuracy of the data reported during that period. The PI definitions and guidance
contained in
ARegulatory Assessment Indicator Guideline,@ Revision 5, were used to verify the basis for reporting each data element. The inspectors reviewed portions of the operations logs, monthly operating reports, Licensee Event Reports (LERs),
surveillances, and discussed the methods for compiling and reporting the PIs with
cognizant licensing and engineering personnel. Documents reviewed during this
inspection are listed in the Attachment. Unit 2 * "Reactor coolant system specific activity" between April 1, 2007 and December 31, 2007; and * "Reactor coolant system leak rate" between April 1, 2007 and December 31, 2007. Unit 3 * "Reactor coolant system specific activity" between January 1, 2007 and December 31, 2007; and * "Reactor coolant system leak rate" between January 1, 2007 and December 31, 2007.
27b. Findings No findings of significance were identified. 4OA2 Identification and Resolution of Problems (71152 - 2 Annual Samples) .1 Review of Items Entered into the Corrective Action Program a. Inspection Scope As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"
and in order to help identify repetitive equipment failures or specific human performance
issues for followup, the inspectors performed a daily screening of items entered into
Dominion's corrective action program. This was accomplished by reviewing the
description of each new CR and attending daily management review committee meetings.
Documents reviewed are listed in the Attachment.
b. Findings No findings of significance were identified. .2 Annual Sample - Review of Gases in the Unit 2 "B"
- EDG Jacket Water Cooling System a. Inspection Scope The inspectors performed a focused review of the actions taken and planned in response to a number of "B"
- EDG jacket water cooling system expansion tank overflow events. The review included a recent event that occurred in February 2008. The inspectors reviewed the causal evaluations contained in the associated
- CR s, corrective actions that have been taken, ongoing troubleshooting efforts, and planned corrective actions. The inspectors also interviewed personnel and performed a plant walkdown of the Unit 2
- EDG s. b. Findings and Observations No findings of significance were identified. The inspectors noted the expansion tank overflow issue has existed for several years as documented in a number of
- CR [[s between 2003 and February 2008. The licensee has determined that the most likely cause of the tank overflowing is the introduction of combustion gases into the jacket water system due to leakage past a copper gaskets where the fuel injector, air start valve, and cylinder indicator adapters are threaded into the cylinder liners. The same issue has not been experienced with the "A"]]
- EDG in that it does not occur during every monthly surveillance run and there were no events identified in 2006. The inspectors noted that the condition does not appear to be as significant as that experienced at other plants where trips of
EDGs occurred due to a resultant fluctuation in jacket cooling water
28pump discharge pressure. The licensee has taken a number of actions that have not yet been successful in resolving the issue. Licensee actions have included replacement of all gaskets in 2005 and again in 2007 as well as the installation of sight glasses in the system to allow monitoring for the presence of gas bubbles. Additionally, the inspectors verified that surveillance and maintenance procedures have been updated to include relevant operating experience information involving aspects such as gasket installation instructions and monitoring of the EDG jacket water system parameters during operation. The inspectors confirmed that the licensee was continuing to evaluate this issue in an effort to identify additional corrective actions that may be taken to confirm and correct the
cause of the expansion tank overflows. Ongoing actions being considered are
documented in CR 08-01137 and include: * investigating the development and use of a lapping tool that could be used to improve the seating surface at the mechanical joint between the adapters and the cylinder
liners; * continuing the troubleshooting data collection for at least several more months; * performance of an independent peer review to assess the issue; * evaluating the potential need to replace the cylinder liners based on the results of the peer review and the results of seat lapping evaluation and/or performance; and * obtaining additional information from the vendor to improve adapter installation techniques. The inspectors found that although the issue has not had a significant impact on the ability
of the EDG to perform its safety function, appropriate additional licensee actions to
identify and correct the cause of the overflow events are continuing.
.3 Annual Sample - Unit 3 Main Turbine Control Valve Testing and Load Set Operation a. Inspection Scope The inspectors performed a focused review of the actions taken in response to an overpower condition that occurred during turbine valve testing in November 2007. The inspectors interviewed personnel involved in the corrective actions and reviewed the causal evaluations contained in the associated CR, completed corrective actions, and the results of the subsequent test conducted in February 2008. b. Findings and Observations No findings of significance were identified.
The inspectors reviewed Dominions corrective actions resulting from the investigations
which included: reducing reactor power to 90 percent for control valve testing to minimize
turbine response and resulting reactor power fluctuations due to small changes in grid
29frequency, closely monitoring turbine first stage pressure and adjusting turbine load to maintain first stage pressure, and making changes to the test procedure to incorporate
the results of the apparent cause investigations. The inspectors concluded that
Dominion's corrective actions were adequate. 4OA6 Meetings, including Exit Exit Meeting Summary
On April 8, 2008, the resident inspectors presented the overall inspection results to
Mr. Alan Price, and other members of his staff. The inspectors confirmed that no
proprietary information was provided or examined during the inspection.
- ATTACH [[]]
- MENT [[:]]
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- ATION [[]]
- KEY [[]]
- POINTS [[]]
- OF [[]]
CONTACT Licensee personnel
G. Auria Nuclear Chemistry Supervisor
B. Bartron Supervisor, Licensing
J. Cambell Manager, Security
F. Cietek Maintenance Management/Asset Strategy
T. Cleary Licensing Engineer
G. Closius Licensing Engineer
L. Crone Supervisor, Nuclear Chemistry
- III [[]]
R. Griffin Director, Nuclear Station Safety & Licensing
W. Gorman Supervisor, Instrumentation & Control
J. Grogan Assistant Plant Manager
C. Houska I&C Technician
A. Jordan Site Plant Manager
J. Kunze Supervisor, Nuclear Operations Support
B. Krauth Licensing, Nuclear Technology Specialist
J. Laine, Manager, Radiation Protection/Chemistry
J. Langan Manager, Nuclear Oversight
P. Luckey, Manager, Emergency Preparedness
R. MacManus Director, Engineering
H. McKenney Supervisor, Nuclear Engineering
M. O'Connor Manager, Engineering
D. Presuitti Fire Analyst, Asset Production
A. Price Site Vice President
M. Roche Senior Nuclear Chemistry Technician
J. Semancik Manager, Operations
S. Smith Supervisor, Nuclear Shift Operations Unit 3
J. Spence Manager, Training
IT Specialist, Meteorological Data
A-2LIST
- OF [[]]
- ITEMS [[]]
- AND [[]]
DISCUSSED Opened
None Opened and Closed
05000336/2008002-01 FIN Failure to Evaluate a Unit 2 Charging System Non-conforming Condition against the Current
Licensing Bases (Section 1R15)05000336/2008002-02 NCV Failure to Identify Unacceptable Unit 2 Charging Pump
Surveillance Test Data (Section 1R22)05000336/2008002-03 NCV Failure to Identify a Service Water Bypass Flow Path
following a Failed
- LIST [[]]
- OF [[]]
- DOCUME [[]]
- NTS [[]]
- REVIEW [[]]
OP-2336A, Station Drains and Sumps
OP 3352, Heat Tracing, Rev. 013-02
Primary Equipment Operator Outside Logs, 2/12/08
CR-06-07697
OP-2340E21, Revision 000-04, "C" Charging Pump Maintenance
EDG B-Instrument Valve Lineup, Rev. 007-01
OP3346B-2, Valve Lineup for "B" Diesel Fuel System, Rev. 4
OP3346B-007, B Diesel Fuel Oil Electrical Alignment, Rev. 000
Millstone Unit 3 Emergency Diesel Generator Health Report, 2nd & 3rd Quarter 2007.
A-3CR-07-04159
CR-08-00419 Work Orders: M3020337
M3030831
M3031424
M3050160
M3050814
M3051016 M3051051 M3051762
M3060379
M3060623
M3060944
M3060952 M3060968 M3070296
M3070626
M3070927
M3070942
M3070944 M3071440 M3071455
M3071508
M3071705
M3080037
M3980032
A-4Section 1R05: Fire Protection
FHA Unit 2 "Fire Hazards Analysis" Fire Area A-13
FHA Unit 2 "Fire Hazards Analysis" Fire Area A-14
FHA Unit 2 "Fire Hazards Analysis" Fire Area A-15
FHA Unit 2 "Fire Hazards Analysis" Fire Area A-16
FHA Unit 2 "Fire Hazards Analysis" Fire Area I-1 Zone A
EN 31084, Operating Strategy for Service Water System at Millstone Unit 3, Rev. 007
M3-EV-02-0031, Technical Evaluation for Service Water Heat Exchanger Monitoring Millstone
Unit 3, Rev. 2
Fire Protection Evaluation Report, Millstone Nuclear Power Station Unit 3
Section 1R06: Flood Protection Measures
ER-04-0035 Calculation PBD-10B-1
Calculation Number 12179-P(R)-1194
CR-04-03704
Section 1R07: Heat Sink Performance SP 3626.13, Service Water Heat Exchanger Fouling Determination, Rev. 021-00, performed 2/2/08
SP 3626.13, Service Water Heat Exchanger Fouling Determination, Rev. 021-00, performed
2/10/08
EN 31084, Operating Strategy for Service Water System at Millstone Unit 3, Rev. 007
CR-07-02093
CR-07-04204
CR-07-04294
CR-07-04673
Work Orders: M30610651,
- 3HVQ [[]]
ACUS1B Heat Exchanger Inspection, Performed 6/20/07
M30701961,
- 3HVQ [[]]
ACUS1B Eddy Current Testing During 3R, Performed 3/7/07
Section 1R11: Licensed Operator Requalification Program Unit 2 Simulator Exam on January 29, 2008 Section 1R12: Maintenance Effectiveness
CR-08-00112
CR-07-12005
CR-07-11588
CR-07-11518
CR-07-09409
CR-07-07844
CR-07-07631
CR-07-06525 CR-07-00616
CR-07-04858
CR-07-07655
CR-07-08585
CR-07-09904
CR-08-01069
CR-07-11516
CR-07-08774 CR-07-08732
CR-07-08731
CR-07-08730
CR-07-08729
CR-07-05526
CR-07-05113
CR-07-04844
CR-07-04498
CR-06-10759
A-5CR-06-09865
- CR -07-11781 Auxiliary Feedwater System System Health Reports, 1st through 4th Quarters 2007 Millstone Unit 2 Maintenance Rule Scoping Table
- CV [[]]
CS-Volume Control (11/14/2007)
Millstone Unit 3 Maintenance Rule (a)(1) Evaluation for the Auxiliary Feedwater System (3322),
Rev. 1
Millstone Unit 3 Maintenance Rule (a)(2) Disposition for the Auxiliary Feedwater Sysyem (3322),
Rev. 0
Maintenance Rule Scoping Table for Auxiliary Feedwater, 2/14/08
UFASR Chapter 14 Section 14.6, Decreases in Reactor Coolant Inventory
RP-5, Operability Determinations (Rev 006-01)
Millstone Unit 3 Maintenance Rule (a)(1) Evaluation for the Service Water System (3326)
Service Water System Health Report Fourth Quarter 2007
Operability Determination MP3-007-08
Unit 2 Internal Flooding Evaluation
Work Order M30602421 Section 1R13 Maintenance Risk Assessments and Emergent Work Control
CR-07-08221
CR-07-09478
CR-08-00162
CR-08-00732
Unit 2 Operator Logs date 1/11/2008
PRA-FAP01.1, Performing (a)(4) Risk Reviews, Rev. 002-04
Millstone Power Station Operational Focus Report, 2/13/08
Plan of the Week (T-0) by FEG, Week 0807
Section 1R15: Operability Evaluations Operability Determination
- 2060 PS [[]]
IA"
SSC Affected by the Degraded or Non-Conforming
Condition - ("B" Charging Pump Cycling)
PZR Blockhouse Modification Affect on PZR Safety Valve
Setpoints
PZR Blockhouse Modification Affect on PZR Safety Valve
Setpoints
CR-08-01810
CR-08-00639
A-6Section 1R18: Plant Modifications
- IAW [[]]
DCN DM3-00-
0010-08
OA 8, Housekeeping of Station Buildings, Facilities, Equipment, and Grounds, Rev. 007-03
OP 3310B, Accumulator Low Pressure Safety Injection, Rev. 014-14
212-26913 Sheet 1, Piping & Instrumentation Diagram High Pressure Safety Injection, Rev. 27
50.59 Screening DM3-00-0010-08
CR-07-04711
CR-07-04723
- AMO 11M203519, Priority 1 Maintenance associated with "B" EDG troubleshooting/repair Post Repair/Replacement Component Leakage Test for M3-07-00831 & M3 07 00833
- SPROC [[]]
ENG07-3-006, Functional Test of HVQ Units Pressure Control Valves, Rev. 000
Work Orders: M30700831,
ACU 2A Freon Pressure Control Valve
M30700833,
ACU 2A Freon Pressure Control Valve
M30801809, Heat Exchanger Inlet Pressure Control Valve Section 1R22: Surveillance Testing
SP 3601F.6, Reactor Coolant System Water Inventory Measurement, Rev. 005-05, Performed
1/15/08
SW Pump and Facility 1 Discharge Check Valve IST
CR-08-00545
CR-08-00653
- DN [[]]
AP-0509, Revision 8, Dominion Nuclear Procedure Adherence and Usage
M2-EV-98-0227, Revision 0, Technical Evaluation for Single Failure Vulnerability Review Section
CFD 08-02, March 18, 2008 CR-08-02722
Section 2: Radiation Safety
RPM 1.3.13, Bioassay Sampling and Analysis, Rev. 8
ALARA Engineering Controls, Rev. 2
A-7RPM 1.6.4, Siemens Electronic Dosimetry System, Rev.
ALARA Interface with the RWP Process, Rev. 2
RPM 2.1.3, Identification and Control of High Radiological Risk Work, Rev. 2
SA-07-60, Radiation Worker Practices at RCA Exits
Field Observation Report Nos. 6351,07-070, 07-014,07-074, 07-077,
CR-07-06128
CR-07-06271
CR-07-06670
CR-07-07990
CR-07-08300
CR-07-08540
CR-07-08670
CR-07-10789
CR-07-11974
CR-07-05589
CR-07-06325
CR-07-06512
CR-07-06794
CR-07-06952
CR-07-07948
CR-07-10540
- ALA [[]]
RA Evaluations: Nos. 3-08-04, 2-08-02, 3-08-05, 3-08-04, 3-08-06, 2-08-01, 3-08-01, 3-08-
03, 3-08-02
- ALA [[]]
RA Council Meeting Minutes: 01/31/2008, 12/14/2007, 07/09/2007
Challenge Board Meeting Handouts/Action Items for 2R18 Projects: Steam Generator Eddy
Current Testing and I&C Tasks
Troubleshooting Plan for
Dose and Dose Rate Alarm Reports for October 2007 through January 2008
Section 40A1: Performance Indicator (PI) Verification
RCS Leak Rate Determination, Rev. 006-00 SP 2619A-001, Control Room Daily Surveillance, Modes 1&2, Rev. 045-03
SP 2830 Sampling Reactor Coolant for Dissolved Oxygen, Chloride and Fluoride Analysis, Rev.
007-02
DEI-131, Rev. 006-02
SP 3670.1-001, Mode 1-4 Daily and Shiftly Control Room Rounds, Rev. 025-01
A-8SP 3680.1-003, Containment Leakage Trending, Rev. 002-01 SP 3802E, Reactor Coolant Gas Sampling and Analysis, Rev. 001-03
SP 3855, Reactor Coolant Analysis for Dose Equivalent I-131, Rev. 006-00
SP 3855-001, Reactor Coolant Analysis for Dose Equivalent I-131, Rev. 007-00
CR-08-00490
- OP [[]]
- CR -08-01732 Fairbanks Morse Owner's Group Draft Position - Exhaust Gas Leakage In the Jacket Water Cooling System of Opposed Piston Engines, dated July 24, 2006
- NRC Information Notice 2004-15, Dual-Unit Scram at Peach Bottom Units 2 and 3, dated July 22, 2004 Operability Evaluation
DG Slow Start Operability Test, Facility 2 (Loaded Run), Rev, 003-03, performed March 5, 2008 Vendor Manual 25203-138-002, Installation, Operation and Maintenance of Emergency Diesel Engine, Rev. 2 Work Orders: M20701994 M20709828
A-9LIST
- OF [[]]
- ADA [[]]
- ALA [[]]
RA as low as reasonably achievable
- CE [[]]
DE committed effective dose equivalent
CFR Code of Federal Regulations
CLB current licensing basis
CR condition report
dp differential pressure
DRP Division of Reactor Projects
- EC [[]]
CS emergency core cooling system
EDG emergency diesel generator
- HP [[]]
SI High Pressure Safety Injection
I&C Instrumentation and Control
IMC inspection manual chapter
IST in-service test
- LH [[]]
RA Locked High Radiation Areas
mrem millerem
NCV non-cited violation
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
OA Other Activities
- PA [[]]
RS Publicly Available Records System
PI performance indicator
PI&R problem identification and resolution
- PO [[]]
- PS [[]]
ID pounds square inch differential
RAI request for additional information
RCA Radiological Controlled Area
- RS [[]]
ST reserve station service transformer
RWP radiological work permit
SDP significance determination process
SIH safety injection high
SIS safety injection system
- TE [[]]
- TM [[]]
LP thermal margin low pressure
TS technical specification
A-10UFSAR Updated Final Safety Analysis Report
- VH [[]]