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05000336/FIN-2012004-012012Q3MillstoneInadequate Post Maintenance Test Directions following Design Change to 3HVC FN1BThe inspectors identified an NCV of 10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, of very low safety significance (Green) for Dominions failure to adequately specify post maintenance test (PMT) requirements for the control room ventilation exhaust fan 1B (3HVCFN1B) following replacement of the breaker starter on June 19, 2012. Specifically, Dominion did not provide sufficient direction to the operations staff in the control room regarding the correct retest procedure or acceptance criteria to complete an adequate PMT. As a result, 3HVCFN1B was retested and returned to an operable status despite the inability of this fan to respond to a control building isolation (CBI) actuation signal. Subsequently, on June 21, 2012, train B heating and ventilation control room (HVC) was declared inoperable after the HVC system failed routine surveillance test SP 3614F.1-002, Control Room Emergency Filtration System Operability Test. Dominion identified that the auxiliary contacts for the 42x relay had not been correctly installed in the breaker for 3HVCFN1B, which would have prevented the automatic starting of the fan during a CBI signal. The PMT acceptance criteria, specified in design change MP3-11-01065 and translated into work order 53102451547 had been met but were not adequate to retest the breaker. Dominion entered this issue into their CAP as CR 492783. The finding is more than minor because it affected the Design Control attribute of the control room ventilation boundary barrier for the Barrier Integrity cornerstone. Additionally, the performance deficiency was similar to example 5.b in Appendix E of Manual Chapter 0612, Examples of Minor Issues. In accordance with IMC 0609, Significant Determination Process, the inspectors performed a Phase 1 analysis and determined that the finding was of very low significance because the finding represented a degradation of the control room radiological barrier function but not degradation against smoke or toxic gas. This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because Dominion failed to maintain accurate and up to date procedures and work packages for PMTs following installation of the design change to replace the breaker for 3HVCFN1B.
05000336/FIN-2012004-022012Q3MillstoneCorrective Action to Prevent Recurrence Ineffective to Preclude Repetition of a Significant Condition Adverse to QualityA self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified when the corrective action to prevent recurrence of a significant condition adverse to quality did not preclude repetition of the event. Specifically, Dominion generated a corrective action to prevent recurrence during a root cause evaluation (RCE) for a reactor power transient that occurred in February 2011 and a similar event occurred in November 2011, which was determined to be a repeat of the February 2011 event. Dominion entered this issue into their corrective action program (CAP) as condition report (CR) 488587. This finding was more than minor because if left uncorrected, it has the potential to lead to a more significant safety concern. The inspectors determined that this finding was associated with the Mitigating System Cornerstone and was reactivity control systems degradation related to reactivity management due to command and control issues identified in Dominions RCEs for both the February and November 2011 events. Additional screening through the SDP directed the inspectors to Appendix M Significance Determination Process Using Qualitative Criteria. Based upon the results of this evaluation and taking into account mitigating factors associated with additional corrective actions taken following the November 2011 event, and Dominions acceptable performance during the November 2011 through September 2012 time period, the NRC has concluded that the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address significant conditions adverse to quality and preclude their repetition.
05000336/FIN-2012005-012012Q4MillstoneFailure to Adequately Implement Flooding EALsThe inspectors identified an NCV associated with emergency preparedness (EP) planning standard 10 CFR 50.47(b)(4), and the requirements of Sections IV.B and IV.C of Appendix E to 10 CFR Part 50. Specifically, Dominion did not maintain in effect the Millstone Units 2 and 3 emergency action level (EAL) schemes by failing to provide an effective measuring instrument for determining flooding water levels. These deficiencies adversely affected the ability of the licensee to properly classify events involving a major flood condition. Dominion entered the issue into their corrective action system (CR501482) and provided additional means to determine flood water levels. The finding is more than minor because it is associated with the Facilities and Equipment attribute of the EP Cornerstone and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The inspectors determined the finding to be of very low safety significance (Green) because an EAL has been rendered ineffective such that a Notification of Unusual Event (NOUE) would not be declared for a flooding event, but because of other EALs, an appropriate declaration could be made in a degraded manner. The finding has a cross-cutting aspect in the area of Human Performance, Resources, in that Dominion personnel did not take provide appropriate procedures to address a Risk-Significant Planning Standard (RSPS) issue completely, accurately, and in a timely manner commensurate with the safety significance because Dominion did not provide a means of reliably and accurately assessing flooding levels that could reach 19 feet above mean sea level.
05000336/FIN-2012005-022012Q4MillstoneFailure to Establish Proper Test Controls for the Wide Range Logarithmic Post Accident Neutron Flux MonitorsThe inspectors identified an NCV of 10 CFR 50, Appendix B, Criteria XI, Test Control, associated with the Barrier Integrity cornerstone. Specifically, Dominion did not ensure that the wide range logarithmic post accident neutron monitor system was properly calibrated as required by Technical Specification (TS) 3.3/4.3.6, Accident Monitoring Instrumentation, to ensure all surveillance test acceptance criteria had been fully met on August 10, 2011. Dominion entered the issue into their corrective action system (CR442297) and repaired and realigned the Gamma Metrics LOG WR Monitor instrument drawer, and retrained the instrument and controls (I&C) department regarding surveillance and test control procedures. This finding was determined to be more than minor because it is associated with the human performance attribute of the barrier integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding) protect the public from radionuclide releases caused by accidents or events. The finding was determined to be of very low significance (Green) because the issue only affected the fuel barrier. This finding has a cross-cutting aspect in the area of human performance, work practices component because the licensee did not ensure that surveillance work activities were appropriately reviewed by supervision.
05000336/FIN-2012005-032012Q4MillstoneGaps in West 480V Switchgear HELB Barrier May Impact Safety Related EquipmentOn June 7, 2012, with Unit 2 at 100 percent power, Dominion determined that a series of gaps in a HELB barrier rendered the equipment in the west 480V switchgear room inoperable. Dominion entered TS 3.8.2.1, TS 3.8.2.1(a) action C, and TS 3.3.3.5 action A. The openings were sealed and the switchgear room was returned to operable status at 1605 on June 8, 2012. Dominion determined that this condition may have existed since initial construction. In the past, Unit 2 has implemented compensatory cooling to the west switchgear room when normal ventilation was OOS. Compensatory cooling includes opening one of the doors to the switchgear room. This could allow the steam from the HELB to impact safety related equipment in other areas. The inspectors determined that there was a performance deficiency in that Dominion did not ensure that the gaps in switchgear room HELB barrier were sealed. Additional information is necessary for the inspectors to determine if the issue is more than minor. The information required is the determination of safety related equipment that would be affected by the HELB. This information will be available upon completion of Dominions detailed formal analysis. Upon receipt of the above information, the NRC will assess whether the performance deficiency is more than minor.
05000336/FIN-2012005-042012Q4MillstoneUnsealed Penetrations in Flood Barriers May Impact Safety Related Equipment in a Design Basis FloodOn October 15, 2012, during walkdowns performed in response to the NRCs 10 CFR 50.54(f) letter while Unit 2 was shutdown in Mode 5, Dominion identified several unsealed electrical conduits connecting the SW pump room in the intake structure to the turbine building. During a design basis flood, this condition had the potential to cause flooding of the turbine building such that all auxiliary feedwater pumps could be rendered inoperable. Dominion has also identified other unsealed penetrations in the design basis flood zone. Dominion took prompt corrective actions to seal the identified penetrations. These deficiencies may have existed since initial construction. The inspectors determined that there was a performance deficiency in that Dominion did not ensure that the electrical conduits were sealed to provide adequate flood protection. Additional information is necessary for the inspectors to determine if the issue is more than minor. The information required is as follows: 1. Determine if the conduits that were not sealed at the Unit 2 flood boundary were sealed on the other end; 2 Determine the aggregate impact of potential flooding from all leak paths on the safety function of affected components. Upon receipt of the above information, the NRC will assess whether the performance deficiency is more than minor.
05000336/FIN-2013002-012013Q1MillstoneInadequate Post Maintenance Testing Following PORV MaintenanceThe inspectors identified a Green NCV of 10 CFR 50 Appendix B, Criterion XI, Test Control, for Dominions failure to perform an adequate post maintenance test (PMT) on 2-RC- 404, the Unit 2 B power operated relief valve (PORV). Specifically, a stroke test of the valve under hot conditions was not performed prior to entering Mode 3. Since the valve was observed to be leaking, Dominion cooled down the plant to repair the PORV and performed the specified PMTs including the valve stroke under hot conditions. Dominion entered the issue into their corrective action program (CAP), CR506539. The finding is more than minor because it is associated with the Human Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Dominions PMT of the PORV did not adequately demonstrate the valves capability to stroke under all operating conditions. The finding was of very low safety significance (Green) because the finding did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its technical specification (TS) allowed outage time, did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with Dominions maintenance rule program for greater than 24 hours, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event. The finding had a cross-cutting aspect in Human Performance, Work Control, because Dominion did not adequately incorporate actions to address the impact of work activities on plant operation. Specifically, Dominion incorrectly concluded that the PORV functional test was not required prior to entering Mode 3.
05000336/FIN-2013003-012013Q2MillstoneFailure to implement Annunciator Response Procedure for a Loss of Ventilation during a Battery ChargeThe inspectors identified an NCV of Technical Specification (TS) 6.8.1, Procedures and Programs, for failing to implement Annunciator Response Procedure (ARP) OP-3353VP1B1-4 (BATT ROOM 1, 3, 5, EXHAUST FAN FLOW LOW) and stop the equalizing battery charge that was occurring on three batteries to prevent the buildup of hydrogen gas in the Unit 3 east switchgear room when room ventilation was stopped. After a period of two hours, Dominion stopped the equalizing charge and entered the issue into their CAP as CR511856 and CR519744. The performance deficiency is more than minor because it affected the protection against external factors attribute of the mitigating systems cornerstone and affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events, such as fire, to prevent undesirable consequences (i.e. core damage). Specifically, Dominion failed to properly implement the ARP which allowed the potential build-up of hydrogen gas to occur in the east switchgear room. A hydrogen fire in the east switchgear room would have disabled numerous safety-related systems and potentially injured personnel during a time when the plant was in a yellow shutdown risk state based on RCS decay heat removal and power availability. The inspectors determined this finding to be of very low safety significance (Green) because train B was protected and RHR loop B was in operation providing core cooling. Train B components and systems were physically isolated in the west switchgear room. The finding has a cross-cutting aspect in the area of Human Performance, Work Practices, because Dominion did not effectively communicate expectations regarding personnel following procedures.
05000336/FIN-2013003-022013Q2MillstoneFailure to Establish Measures for the Identification and Control Design Interfacesand for Coordinating among Participating Design OrganizationsThe inspectors noted a self-revealing Green NCV of 10 CFR 50, Criterion III, Design Control, when Dominions did not adequately implement established measures for the identification and control of design interfaces and for coordinating among participating design organizations. Specifically, Dominion failed to properly require a temporary modification for a work activity that met the design requirements of CM-AA-TCC-204, Temporary Configuration Changes, when workers installed an air line jumper that caused an AOV to open and led to an uncontrolled loss of RCS inventory. Dominion entered the issue into their CAP as CR511856. The finding is more than minor because it is associated with the design control attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, Dominion failed to properly implement a temporary modification which ultimately led to the uncontrolled loss of RCS inventory. The finding was of very low safety significance (Green) because the charging system had sufficient capacity to maintain pressurizer level, the leakage would not have caused the loss of the running residual heat removal (RHR) pump for a substantial period of time, and at least one steam generator (SG) remained available. The finding had a cross-cutting aspect in Human Performance, Work Practices, because Dominion failed to ensure supervisory and management oversight of work activities such that nuclear safety is supported. Specifically, the station did not maintain control of activities in accordance with plant procedures.
05000336/FIN-2013003-032013Q2MillstoneFailure to Make a 10 CFR 50.72(b)(3)(v) Report for a Major Loss of EmergencyAssessment Capability for Stack Radiation MonitorThe inspectors identified a Severity Level IV NCV of 10 CFR 50.72(b)(3)(xiii) for the failure to make the required initial notification to the NRC within eight hours of a major loss of monitoring capability. On April 16, Dominion declared the main station stack radiation monitor inoperable but did not report this to the NRC until the inspectors questioned the control room operators on April 18. Dominion evaluated the condition and made the required notification (NRC event report number 48941) on April 18, 2013, and entered the issue into their corrective action program (CAP) as CR512007. The inspectors determined that Dominion did not notify the NRC of a major loss of emergency assessment capabilities event in the time required by 10 CFR 50.72. The inspectors determined the finding was subject to traditional enforcement because Dominions failure to make a required report could potentially impact the NRCs regulatory function. This finding is similar to the one described in NRC Enforcement Policy, Section 6.9.d(9), A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, which corresponds to Severity Level IV. In accordance with guidance contained in IMC 0612, Power Reactor Inspection Reports , Section 07.03, cross-cutting aspects are not assigned to traditional enforcement violations.
05000336/FIN-2013003-042013Q2MillstoneLicensee-Identified ViolationOn March 19, Dominion received laboratory results for the A train CREFS charcoal filter sample on Unit 3 that had been taken on March 13. The results indicated that the methyl iodide penetration for the charcoal sample was 4.46 percent, which exceeded the TS requirement of 2.5 percent. Dominion determined that the A CREFS had been inoperable from March 13 to March 21, which exceeded the seven day allowed outage time. Because Dominion could not recognize the inoperability of the A CREFS until after the charcoal test results were available they did not take actions contrary to the requirements of TS 3.7.7. Traditional enforcement applies in accordance with IMC 0612, Sections 0612-09 and 0612-13, and Enforcement Policy Section 2.2.4.d, because the inspectors did not identify an associated performance deficiency. The inspectors determined this to be a SLIV violation of TS 3.7.4 in accordance with Enforcement Policy Section 6.1.d. This condition is reportable under 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by TS and as a result Dominion submitted LER 05000423/2013-004-00 and entered the issue into their CAP as CR508567.
05000336/FIN-2013003-052013Q2MillstoneLicensee-Identified ViolationOn February 15, operators discovered that the insulating cover on Unit 3 was not properly secured over the 3MSS*PT526 B SG pressure transmitter, but did not declare the system inoperable until February 19 due to a lack of understanding of the equipment qualification needs of the transmitter. TS 3.3.2 allows the pressure transmitter to be inoperable for 6 hours before tripping the channel. Contrary to this, Dominion did not take appropriate action to trip the channel for a period of four days. This finding impacted the Mitigating Systems cornerstone and screened to Green in accordance with the screening questions from IMC 0609, Appendix A, Exhibit 2. Dominion entered the issue into their CAP as CR505990 and submitted LER 05000423/2013-001-00.
05000336/FIN-2013004-012013Q3MillstoneInadequate Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation ValvesThe inspectors identified a cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for Dominions continued failure to take timely and effective corrective actions for conditions adverse to quality involving the degradation of the closing capability of four Unit 3 main feedwater isolation valves. Dominion had deferred correcting this condition over a period of six years (three refueling outages) which the inspectors noted in NCV 05000423/2012010-01, a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. Dominion has since deferred repairs from the April 2013 refueling outage until the October 2014 outage. The violation is cited because Dominion has failed to restore compliance or demonstrate objective evidence of plans to restore compliance at the first opportunity in a reasonable period of time following initial identification in 2007 and documentation in 2012 NRC inspection reports. Dominion entered the issue into their CAP as CR507299 and plans to modify the valves in the 2014 refueling outage. The inspectors determined this issue was more than minor because it is similar to the more than minor examples, 4.f and 4.g of IMC 0612, Appendix E, Examples of Minor Issues. Specifically, Dominion did not correct a condition adverse to quality in a timely manner and resulted in a situation that impacted the operability of the feedwater isolation valves. Additionally, the finding is more than minor because it is associated with the design control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstones objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. The inspectors determined that the finding was of very low safety significance (Green) because the issue did not represent an actual open pathway in the physical integrity of the reactor containment. In the event of a ruptured feedwater line, the train A main feedwater regulating valves and bypass valves would remain capable of closing to isolate feedwater flow. This finding had a cross-cutting aspect in the Human Performance area, Resources component, because Dominion did not maintain long term plant safety by minimizing longstanding equipment issues and ensuring maintenance and engineering backlogs which are low enough to support safety. Specifically, Dominion deferred the feedwater isolation valve replacement project from 3RFO15 to 3RFO16 because the design change could not be issued to support online work on the project required prior to the outage. Additionally, there were a number of outstanding technical issues for the design change that were not resolved in time despite the condition existing since 2007.
05000336/FIN-2013004-022013Q3Millstone\"Inadequate Operability Determination for the Turbine Drive Auxiliary Feedwater (TDAFW) Pump\"The inspectors identified a finding (FIN) for Dominions failure to complete an adequate and timely operability determination as required by OP-AA-102, Operability Determination, to assess governor control oscillations following completion of maintenance on the turbine driven auxiliary feedwater (TDAFW) pump 3FWA*P2 on May 17, 2013. The inspectors determined that the failure to adequately evaluate pump operability was a performance deficiency that was within Dominions ability to foresee and correct. Dominion entered this issue into their corrective action program (CAP) as CR528526 and repaired the TDAFW pump governor on August 12, 2013, prior to return to power following the reactor shutdown on August 9, 2013. The inspectors determined the performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Failure to adequately assess operability resulted in a decrease in the reliability of the auxiliary feedwater (AFW) system to mitigate events. In addition, the performance deficiency is similar to examples 1.a and 2.a of IMC 0612, Appendix E, Examples of Minor Issues. The inspectors determined that the finding was of very low safety significance (Green) because the performance deficiency did not represent a loss of system safety function or a loss of safety function of a single train for greater than its Technical Specification allowed outage time. This finding has a cross-cutting aspect in the area of Human Performance, in that Dominion uses conservative assumptions in decision making and adopts a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action.
05000336/FIN-2013004-032013Q3MillstoneLicensee-Identified Violation10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures, or drawings. Contrary to the above, on March 7, 2013, Dominion failed to maintain a HELB door closed during the TDAFW pump surveillance and rendered both trains of AFW inoperable for approximately 30 minutes. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings at Power. Dominion entered the issue into their CAP (CR507412).
05000336/FIN-2013004-042013Q3MillstoneLicensee-Identified ViolationTS 3.8.2.1 requires, in part, that when 480V Emergency Load Center 22E is inoperable, it must be restored to operable status within 8 hours or be in COLD SHUTDOWN within the next 36 hours. Contrary to the above, from initial construction until June 8, 2012, the bus 22E was inoperable due to a gap in the HELB barrier. This gap would allow high energy steam to enter the switchgear rooms, causing the electrical equipment inside to potentially fail. The inspectors determined that there was a performance deficiency in that Dominion did not recognize the inoperability of the 22E bus as a result of the historical gap and take the appropriate actions as required by TS. This finding is of very low safety significance as determined by a detailed risk assessment using SAPHIRE 8 and a modified main steam line break outside of containment event tree from the Millstone 2 SPAR model. Specifically, the risk analysis reviewed three possible main steam line break sources in the turbine building near the West 480V Switchgear Room. The assumed one year exposure period was broken down into a period of 66 days when alternate cooling was in effect for the West 480V Switchgear Room and two days when it was in effect for the East 480V Switchgear Room. The frequencies of the associated steam line breaks were determined from a recent EPRI steam line break technical report, given the assumed leak location and the estimated length of associated piping. With the gaps in the HELB barrier and assuming a steam line break, the West 480V switchgear was assumed to fail. When alternate cooling was used for the West 480V Switchgear Room, if the steam line was not isolated, both trains of DC switchgear were also assumed to fail due to high temperature/humidity. When the East Switchgear alternate cooling was used, it was assumed that failure of all safety-related 480V power would have occurred due to high temperature/humidity. Dominion sealed the gap upon discovery in June 2012 and has entered this issue into the CAP (CR478194).
05000336/FIN-2013004-052013Q3MillstoneLicensee-Identified Violation10 CFR 50 Appendix B, Criterion III, Design Control, states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this, from initial construction until November 16, 2012, Dominion failed to ensure that Unit 2 safety related equipment would perform their safety function during a 22 foot MSL design basis flood event concurrent with a 26.5 foot MSL standing wave in the intake structure. Specifically, the unsealed electrical conduits and other openings would have allowed water to bypass Dominions flood protection features and could have affected the functionality of the safety related AFW and HPSI pumps and the PORVs. Dominion entered the issue into their corrective action process as CR491792 and sealed the conduits. Dominion performed an analysis that modeled the postulated effects of the compromised flood barriers. The evaluation postulated the time based impact of the design basis Probable Maximum Hurricane (PMH) tidal surge, using data (including wave runup above the still water heights) from Table 2.5-1 of the UFSAR, with and without the concurrent +26.5 ft MSL water level in the intake structure. The calculation estimated the height of water in the turbine, control, and auxiliary buildings rooms containing equipment necessary to maintain safe hot shutdown using: physical plant layout (floor areas and elevations, internal access doors and postulated water flow paths); water flow estimates; relative height of the identified leakage points; and critical water levels where equipment could be compromised. The engineering calculations demonstrated no impact to equipment needed to perform during the design basis flood without the concurrent intake structure standing wave. However, there was a potential to affect the functionality of the auxiliary feedwater pumps, the PORVs and the high pressure injection system if the standing wave condition occurred, as assumed, for one hour concurrent with the design basis maximum storm surge. The inspectors and a Region I senior risk analyst (SRA) reviewed the associated engineering calculations and technical evaluation. The Region I SRAs conducted and peer reviewed a detailed risk evaluation which they discussed with Office if Nuclear Reactor Regulation, Division of Risk Assessment staff. The SRAs determined that the finding was of very low safety significance with an estimated increase in core damage frequency of less than one in one million reactor years (Green). This was based on available frequency information and on the possibility of some credit for core damage mitigation equipment due to conservative assumptions, as follows: Dominion included significant conservatisms in their calculation and evaluation, which tend to overestimate the chance of damage to mitigation equipment, such as: including wave runup above the assumed still water heights; the one hour duration of intake structure water level at + 26.5 ft MSL due to the postulated standing wave; the height at which equipment damage would occur; and the assumed size of the identified flood barrier breaches. Dominion took no credit for operator actions to protect the important equipment either prior to or during a predicted extreme weather event. Plant procedures for these types of weather conditions discuss pre-staging equipment (sand bags, portable pumps and generators) and personnel to respond to limit the impact of potential flooding on important equipment.
05000336/FIN-2013005-012013Q4MillstoneImplementation of NEI 99-01 GuidanceA URI was identified because additional NRC review and evaluation was needed to determine whether Dominion adequately implemented the guidance of NUMARC NESP-007, Methodology for Development of EALs, to establish initiating conditions for two EALs applicable to Mode 6 operations. This is considered a URI because more information is needed, specifically the clarification and interpretation of existing guidance by the NRCs Office of Nuclear Security and Incident Response (NSIR), in order to determine if the issue constitutes a violation. During a review of both units EAL schemes, the NRC identified two EALs applicable in mode 6 during a loss of RHR flow when there was no direct RCS temperature indication (that was representative of core temperatures) available to determine if the initiating conditions had been met for an Unusual Event or an Alert. Upon discovery of this issue, the inspectors discussed it with staff from NSIR. The NSIR staff preliminarily indicated that this issue appeared to be an industry-wide generic issue in that there was a lack of specified instrumentation for assessing core temperature during refueling if there was a loss of RHR flow. Therefore, given the apparent lack of a specified standard to assess the initiating conditions for these EALs, the inspectors delayed pursuing enforcement action pertaining to Dominions adherence to 10 CFR 50.47(b)(4) and Sections IV.B and IV.C of Appendix E to 10 CFR Part 50. While assessing the adequacy of Dominions extent of condition review for two prior NCVs related to the operators ability to implement the EAL scheme, the inspectors identified two EALs applicable to both units during a loss of cooling flow while in Mode 6. During this condition, there was no direct indication available to determine if the initiating conditions had been met. Specifically, in Mode 6 during a loss of RHR flow there would also be a loss of core temperature indication because the only available instrumentation is in the RCS loops (With the vessel head removed, the core exit thermocouples are no longer available and there is no temperature indication for the refueling cavity). The initiating conditions for an Unusual Event ( Uncontrolled RCS temperature increase > 10F ) and an Alert ( Uncontrolled RCS temperature increase > 10F that results in RCS temperature > 200F ) cannot be assessed due to the loss of RHR flow through the core causing the instrumentation to become unrepresentative of actual core temperature. Upon discovery of this issue, the inspectors discussed it with NRC staff from NSIR. The NSIR staff preliminarily concluded that this issue appeared to be an industry-wide generic issue in that there was a lack of specified RCS core temperature indication during refueling if there is a loss of RHR flow. The inspectors will coordinate with NSIR to review the adequacy of Dominions implementation of the guidance in NEI 99-01. Pending review of this issue, this item is an Unresolved Item (URI 05000336/2013005- 01 and 05000423/2013005-01, Implementation of NEI 99-01 Guidance)
05000336/FIN-2013005-022013Q4MillstoneInadequate Alternative Shutdown ProcedureThe inspectors identified an NCV of Millstone Unit 2 Operating License Condition 2.C. (3) for failure to implement and maintain all aspects of the approved Fire Protection Program (FPP). Specifically, Dominion had not adequately implemented an alternative shutdown procedure, as required by 10 CFR 50, Appendix R, Section III.L.3 and the approved FPP. The procedure for a Unit 2 fire, which could lead to control room abandonment, did not ensure the electrical distribution system was correctly configured prior to re-energizing alternating current (AC) buses. As a result, an over-current condition could occur and trip the 4 kilovolt (kV) supply breaker complicating safe shutdown operations and delaying AC bus recovery. In response to this issue, Dominion promptly revised their fire safe shutdown operating procedure prior to the end of the inspection to correct this deficiency. This finding was more than minor because it was associated with the protection against external factors (e.g., fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding in accordance with IMC 0609, Appendix F, Fire Protection SDP. This finding affected the post-fire safe shutdown category and was determined to have a high degradation rating because the alternative shutdown procedure lacked adequate instructions to ensure correct equipment alignment. A Phase 3 SDP analysis determined that this finding was of very low safety significance (Green) because the best estimate of core damage frequency (? CDF) was in the mid E-7 per year range. This finding did not have a cross-cutting aspect because it was considered to not be indicative of current licensee performance.
05000336/FIN-2013005-042013Q4MillstoneLicensee-Identified ViolationTS 6.8.1, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33. Contrary to this requirement, on May 15, 2013, Dominion failed to correctly implement procedure OP 3312A, Containment Personnel Air Lock Operation, 3CS*Hatch1, to ensure that the equalizing valve for the Unit 3 outer access door was maintained in a closed configuration while the inner access hatch was opened. As a result, a loss of containment integrity occurred when the plant was in mode 4. The operators entered TS 3.6.1.1 and verified the equalizing valve had been closed, thereby restoring containment integrity within one hour required as required by TS 3.6.1.1 and 3.6.1.3. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings at Power. Dominion entered this issue into their CAP as CR 515704 and subsequently reported the loss of safety function to the NRC in LER-2013-005-00 as required under 10 CFR 50.73(a)(2)(v)(C).
05000336/FIN-2013005-052013Q4MillstoneLicensee-Identified ViolationTS 3.6.6.2, Secondary Containment, requires secondary containment to be operable. If inoperable, secondary containment shall be restored to operable within 24 hours or the unit shall be in at least HOT STANDBY within 6 hours and in COLD SHUTDOWN within the following 30 hours. Contrary to this requirement, from 1:57 AM on November 17, 2012, when security performed its test of the Unit 3 roll-up door, until 12:51 PM on November 21, 2012, when the door was fully closed (4 days, 9 hours, 12 minutes), secondary containment was inoperable. Because Dominion did not recognize this condition as rendering secondary containment inoperable until January 28, 2013, they did not take action in accordance with their TS. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings at Power. Dominion entered the issue into their CAP as CR 507822 and reported the loss of safety function and condition prohibited by TS as required under 10 CFR 50.73(a)(2)(v)(C) and 10 CFR 50.73(a)(2)(i)(B).
05000336/FIN-2013010-012013Q3MillstoneInadequate Alternative Shutdown ProcedureThe team identified an apparent violation of Millstone Unit 2 Operating License Condition 2.C. (3) for failure to implement and maintain all aspects of the approved Fire Protection Program (FPP). Specifically, Dominion had not adequately implemented an alternative shutdown procedure, as required by 10 CFR 50 Appendix R Section III.L.3 and the approved FPP. The procedure for a Unit 2 fire which could lead to control room abandonment did not ensure the electrical distribution system was correctly configured prior to re-energizing AC buses. As a result, an over-current condition could occur and trip the 4kV supply breaker complicating safe shutdown operations and delaying AC bus recovery. In response to this issue, Dominion promptly revised their fire safe shutdown operating procedure prior to the end of the inspection to correct this deficiency. This finding was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The team performed a Phase 1 Significance Determination Process (SDP) screening in accordance with NRC Inspection Manual Chapter 0609, Appendix F, and Fire Protection Significance Determination Process. This finding affected the post-fire safe shutdown category, and was determined to have a high degradation rating because the alternative shutdown procedure lacked adequate instructions to ensure correct equipment alignment. Therefore, the team concluded that a more appropriate and accurate characterization of the risk significance of this issue would be obtained by performing a Phase 3 SDP analysis because the Phase 2 SDP analysis does not explicitly address alternative safe shutdown fire scenarios. The Phase 3 SDP analysis cannot be accurately calculated until additional cable routing and ignition source information is presented by Dominion and is necessary to develop the fire scenarios that would require the alternative shutdown procedure to be implemented. This finding did not have a cross-cutting aspect because it was a legacy issue and was considered to not be indicative of current licensee performance.
05000336/FIN-2014003-012014Q2MillstoneFailure to Maintain Adequate Procedure For RCS Drain/FillThe inspectors identified a Green NCV of TS 6.8.1, Procedures, for Dominions failure to maintain an adequate procedure for reactor filling and draining that incorporates guidance contained in NRC Generic Letter 88-17. Specifically, OP2301E, Draining the RCS, permitted operation in a reduced RCS inventory condition without ensuring redundant means of level indication contrary to the inventory control requirements of OU-M2-201, Shutdown Safety Assessment Checklist. The failure to maintain an adequate procedure for operating in reduced inventory conditions is a performance deficiency. The inspectors determined this performance deficiency is more than minor because it is associated with the Initiating Events cornerstone attribute of equipment performance and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, inadequate procedural guidance increased the likelihood that operators could experience a loss of level indication during the reduced inventory condition. The inspectors evaluated the significance of the finding using IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, and the issue screened to a Phase 2 analysis. Using the guidance contained in IMC 0609, Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, the inspectors worked with regional and headquarters senior reactor analysts to determine the issue screened to Green. The inspectors determined this issue had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, where individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the latent error of considering L-112 and LI-112 as independent level instruments even though a single failure impacted both instruments contributed to the issue.
05000336/FIN-2014003-022014Q2MillstoneFailure to Utilize Respiratory Protection as Specified in Work Control DocumentsA self-revealing Green NCV of Technical Specification (TS) 6.8.1; Regulatory Guide 1.33, Appendix A; Radiation Work Permits (RWP); and as low as reasonably achievable (ALARA) procedures was identified for Dominions failure to utilize respiratory protection, as required by the applicable RWP and associated ALARA evaluation for work on replacement of valve 2-SI-227 on April 20, 2014. This failure resulted in an unplanned intake of radioactive material for one worker. Dominion subsequently enforced the respiratory protection requirements to complete the work and entered this issue into their corrective action program (CAP) as condition report (CR) 546439. Failure to use respiratory protection during machining work as required by Dominion procedure was a performance deficiency that was reasonably within Dominions ability to foresee and correct. The inspectors determined that the performance deficiency was more than minor because it affected the Radiation Safety Occupational Radiation Safety Cornerstone attribute of Program and Process associated with exposure/contamination controls, because it resulted in the unintended internal exposure of a worker. A crosscutting aspect of Human Performance, Conservative Bias, was associated with the finding. Specifically, radiation protection staff did not adhere to the RWP requirements.
05000336/FIN-2014003-032014Q2MillstoneFailure to Adequately Maintain EALsThe inspectors identified a Green NCV associated with emergency preparedness planning standard Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(4) and the requirements of Sections IV.B and IV.C of Appendix E to 10 CFR 50. Specifically, Dominion did not maintain the Millstone Units 2 and 3 emergency action level (EAL) schemes for assessing a loss of forced flow cooling during refueling operations. Dominion entered this issue into the CAP and implemented temporary corrective actions which included procedure changes to direct operators to the shutdown safety assessment checklists to determine representative reactor coolant system (RCS) temperature increases in order to assess the initiating conditions (ICs) for this situation. The inspectors determined that the failure by Dominion to provide site specific criteria for operators to adequately implement the EALs for a loss of forced flow cooling during refueling was a performance deficiency that was reasonably within their ability to foresee and prevent. The finding is more than minor because it is associated with the Procedure Quality attribute of the Emergency Planning Cornerstone and affected 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. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was an issue where two EAL ICs had been rendered ineffective such that an Unusual Event and an Alert would not be declared, or declared in a degraded manner for a loss of forced flow cooling during refueling. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, in that Dominion did not implement a CAP with a low threshold for identifying issues. Dominions self-assessment for two previous NCVs regarding EAL deficiencies failed to identify the lack of specific criteria to assess the ICs for EALs EU1.2 and EA2.1 for a loss of forced cooling flow during refueling.
05000352/FIN-2018001-022018Q1LimerickEmergency Diesel Generator Combustion Air OverheatingA self-revealed Green NCV of LGS Unit 1 TS 6.8.1 and TS 3.8.1.1 was identified when Exelon failed to properly maintain an operating procedure to maintain a fail-safe design feature for the EDGs which led to the D12 EDG combustion air overheating and caused the EDG to be inoperable for greater than its TS allowed outage time.
05000353/FIN-2018001-012018Q1LimerickFailure of Emergency Diesel Generator Lube Oil Pipe Nipple FittingA self-revealed Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and LGS Unit 2 technical specification (TS) 3.8.1.1 was identified when Exelon failed to correct a degraded lube oil pipe nipple fitting on the D22 emergency diesel generator (EDG) when maintenance was performed to address leakage which caused inoperability of the EDG for greater than its TS allowed outage time.
05000387/FIN-2018001-012018Q1SusquehannaLicensee-Identified ViolationThis violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.Violation: Susquehanna Unit 1 TS section 5.4.1 requires that written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Susquehannas implementing instruction NDAP-QA-0503, General Housekeeping, Transient Material and Internal Cleanliness, Revision 45 implements aspects of the Regulatory Guide administrative procedures requirements. NDAP-QA-0503 section 6.1.5.h requires, in part, that transient equipment shall be located such that it will not impact safety related equipment during a seismic event. Locate all items at a distance greater than the height of the item from safety related equipment. Additionally, TS 3.5.1 Action Statement I directs immediate entry into Limiting Condition for Operation (LCO)3.0.3 if one core spray subsystem is inoperable with one low pressure coolant injection (LPCI) subsystem inoperable. LCO 3.0.3 requires action to be taken within 1 hour to place the unit in MODE 2 within 7 hours and MODE 3 within 13 hours.Contrary to the above, from December 1, 2017 to December 3, 2017, Susquehanna staged a 540 pound, ten foot long replacement pipe on 34 inch high stands within 34 inches of the safety related Unit 1, B Core Spray room cooler. Susquehanna concluded that the room cooler was inoperable because the pipe could have reasonably contacted and damaged the flexible conduit for the power cable to the room cooler during a seismic event. Additionally, from 7:48 a.m. on December 2, 2017 to 1:35 p.m. on December 3, 2017, maintenance was performed on the Unit 1, division 2 LPCI swing bus motor generator which rendered the division 2 LPCI system inoperable. During this time, Susquehanna did not perform the required actions of LCO 3.0.3 and remained in MODE 1.Significance/Severity Level: This violation is of very low safety significance (Green), since this finding did not represent a loss of system, a loss of function of at least a single train for greater than its TS allowed outage time, or a loss of a non-TS train. Corrective Action Reference(s): CR-2017-20227; CR-2018-01717; CR-2018-02250
05000412/FIN-2014003-012014Q2Beaver ValleyFailure to Follow Procedure Results in Inoperable SI AccumulatorA self-revealing NCV of technical specification (TS) 5.4.1 was identified because the unit 2 B safety injection (SI) accumulator was made inoperable when FENOC operators did not follow procedural requirements to align nitrogen to the accumulator. Specifically, the operators did not align the nitrogen header to the accumulator prior to opening the valve to repressurize the accumulator. The inspectors noted that this resulted in the accumulator pressure falling below the TS pressure limit which required FENOC to declare the accumulator inoperable. FENOCs corrective actions included immediately realigning the system, restoring accumulator pressure and entering the issue into their corrective action program, CR 2014-09260. The performance deficiency is more than minor because it is associated with the configuration control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOC did not have reasonable assurance that the nitrogen pressure in the B SI accumulator was sufficient to ensure injection into the core during an accident due to the misalignment of the nitrogen header. This finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because FENOC operators did not recognize the possibility of mistakes and did not implement appropriate error reduction tools while attempting to re-pressurize the B SI accumulator. (H.12)
05000412/FIN-2014004-012014Q3Beaver ValleyInadequate Plant Startup Procedure Led to Manual Reactor TripA self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings was identified for FENOCs failure to have an adequate plant startup procedure. Specifically, 2OM-52.4A, Raising Power from 5% to Full Load Operation, did not adequately address plant startup with one condensate pump in operation. This led to an inability to adequately control steam generator (SG) level when the second condensate pump was started which required the operators to trip the reactor. FENOC is in the process of implementing corrective actions to revise procedure 2OM-52.4A and to address the human performance errors associated with this event. Additionally, FENOC entered the issue into their corrective action program as condition report (CR) 2014-09256. The finding is more than minor because it is associated with the procedure quality and human performance attributes of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure led to SG level fluctuations that could not be adequately controlled when the second condensate pump was started, and required the operators to trip the reactor. The inspectors determined that this finding is of very low safety significance (Green), because while it did result in a reactor trip, it did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. The finding has a cross-cutting aspect in Human Performance, Challenge the Unknown, because FENOC operators did not stop when faced with uncertain conditions. Specifically, the adequacy of the procedure was not sufficiently questioned when the plant was not in the normal start up configuration of two running condensate pumps nor later when the condensate pump discharge header pressure low alarm occurred.
05000412/FIN-2015002-022015Q2Beaver ValleyFailure to Perform Maintenance in accordance with Licensee Maintenance ProcessA self-revealing finding was identified for FENOCs failure to perform maintenance on the Unit 2 feedwater heater drain system in accordance with FENOCs maintenance process, NOP-WM-4006, Conduct of Maintenance. Specifically, FENOC did not adjust the A first point feedwater heater normal and high level control valve (LCV) controllers to their specified setpoints. As a result, the A heater and separator drain pumps tripped and this led to an unplanned power reduction from 100 percent to 60 percent reactor power on April 12, 2015. FENOCs corrective action included adjusting the setpoints of the LCV controllers to their specified setpoints and entering the issue into their corrective action program as condition report 2015-05088. The performance deficiency was more-than-minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Additionally, the performance deficiency was similar to example 4.b in IMC 0612 Appendix E, in that failing to follow procedure caused a reactor transient. This finding was determined to be of very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Training, because FENOC failed to ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, FENOC did not ensure that knowledge was adequate to perform maintenance on the A first point feedwater heater LCVs (H.9).
05000412/FIN-2016002-022016Q2Beaver ValleyInadequate Compensatory Measures to Ensure the Effectiveness of an EALThe inspectors identified an NCV of 10 CFR 50.54(q)(2) for FENOCs failure to follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b)(4). Specifically, following the failure of the area radiation monitor (ARM) for the Unit 2 primary auxiliary building 773 elevation on April 23, 2016, FENOC did not establish adequate compensatory measures to ensure the effectiveness of the emergency action level (EAL) for loss of control of radioactive material, RU2. FENOCs immediate corrective actions included establishing appropriate compensatory measures for RU2, communicating the standards of EAL compensatory measures to radiation protection technicians verbally and via narrative logs, and entering this issue into their CAP as CR 2016-05975. The performance deficiency is more-than-minor because it is associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone, and adversely affected the cornerstone objective to ensure that FENOC is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, FENOCs failure to establish adequate compensatory measures for an out-of-service ARM could have resulted in exceeding a NOUE EAL threshold for a loss of control of radioactive material without the condition being recognized until further degradation in the level of plant safety occurs. This finding was determined to be of very low safety significance (Green) since it was example of an ineffective EAL, such that a notification of unusual event (NOUE) would not be declared or would be declared in a degraded manner. This finding has a cross-cutting aspect in Human Performance, Documentation, because FENOC did not ensure that plant activities are governed by comprehensive procedures (H.7).
05000423/FIN-2013005-032013Q4MillstoneInadequate Operability Determination for TDAFW Pump Overspeed TripThe inspectors identified a Green Finding (FIN) for the failure to follow Dominion Procedure OP-AA-102, Operability Determinations, and establish adequate compensatory measures to restore reliability to the Unit 3 Turbine Driven Auxiliary Feedwater (TDAFW) Pump following overspeed trips on November 4 and December 18, 2013. The inspectors determined that the performance deficiency was within Dominions ability to foresee and correct. Dominion entered this issue into their corrective action program (CAP) (CR531536, CR532536 and CR535411), established additional compensatory measures to address degraded pump reliability, and scheduled additional maintenance activities to more thoroughly investigate the cause of the overspeed trips. The inspectors determined the performance deficiency was more than minor because it affected the equipment performance attribute of the mitigating systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Failure to adequately establish effective compensatory measures resulted in a decrease in the reliability of the auxiliary feedwater (AFW) system to mitigate events. The inspectors determined that, after further compensatory measures were established, the TDAFW pump maintained its operability, the AFW system maintained all safety functions, and the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance, in that Dominion did not use conservative assumptions in decision making and did not adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action.
05000423/FIN-2014002-012014Q1MillstoneFailure to Evaluate Test Results Outside of Acceptance Criteria For A Service Water PumpThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XI, Test Control, because Dominion did not properly evaluate test results outside of the acceptance criteria for the Unit 3 A service water (SW) pump. Specifically, on February 23, when the A SW pump did not meet its acceptance criteria for running amps, Dominion did not fully evaluate pump operability under all conditions. Dominions immediate corrective actions included entering the issue into their corrective action program (CAP) and placing the pump in pull to lock status until the issue could be resolved. The inspectors determined that Dominions failure to properly evaluate test results outside of the acceptance criteria for the A SW pump in accordance with the requirements of 10 CFR 50, Appendix B, Criterion XI, to assure that test requirements have been satisfied was a performance deficiency that was within Dominions ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, without proper evaluation of the test results, Dominion kept a component in service that was later determined to be non-functional. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification (TS) allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event, and did not represent an actual loss of function of a non-TS train of equipment designated as high safety significant. This finding has a cross-cutting aspect in the area of Human Performance, Design Margins, in that Dominion did not operate and maintain the pump within design margins, where margins are carefully guarded and changed only through a systematic and rigorous process.
05000423/FIN-2014002-022014Q1MillstoneNOED Granted by NRC for TDAFW Pump Repairs on January 26, 2014The NRC identified an unresolved item (URI) for Dominions request for enforcement discretion from TS 3.7.1.2(a) limiting condition of operation (LCO) action statement (C) on January 26, 2014, in accordance with IMC 0410, Notices of Enforcement Discretion. Following an overspeed trip of the Unit 3 TDAFW pump during a scheduled surveillance test, Dominions efforts to complete troubleshooting, repairs and retesting could not be completed in time to comply with TS 3.7.1.2(a) action (C), which allowed up to 72 hours to complete repairs before a plant shutdown was required. Dominion requested additional time to complete the repairs without having to shutdown Unit 3, and the NRC granted a NOED that extended the allowable outage time for an additional 48 hours. On January 23, 2014, the Unit 3 TDAFW pump failed a required surveillance test. During the starting sequence, the pump tripped on overspeed due to mechanical binding in the turbine governor linkage. Dominion entered TS LCO 3.7.1.2(a) action (C) which provided up to 72 hours to repair the failed pump before requiring Unit 3 to be shutdown to Mode 3. Troubleshooting efforts revealed that the mechanical linkage between the governor and the turbine control valve (3MSS*MCV5) was binding due to a degraded cam follower bearing and a mechanical link that had been installed incorrectly. Although repairs had been completed, it became apparent that the required post-maintenance tests, including a full flow test at full power, could not be completed prior to the expiration of the LCO on January 26, 2014. Dominion requested enforcement discretion from compliance with TS 3.7.1.2 for a period of 72 hours. The NRC reviewed the request in accordance with IMC 0410, NOED, and granted a one-time 48 hour extension to required action (C) of TS LCO 3.7.1.2(a). Dominion completed the post-maintenance testing and restored the TDAFW pump to an operable status within the additional time granted. The NOED specified a list of prerequisites and compensatory actions to mitigate risk that were required to be verified and completed prior to the 48 hour extension becoming effective. Closure of this URI will require review and verification of Dominions satisfactory completion of the specified requirements in the NOED in coordination with the Special Inspection Team that is inspecting Dominions performance during this event.
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