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05000336/FIN-2010005-03Licensee-Identified Violation2010Q4TS 3.7.2.1 states that the TDAFW pump has an allowable outage time of 72 hours. TS 4.0.1 requires that the licensee shall declare the TDAFW pump to be inoperable if the pump fails a surveillance test required by TSs. Contrary to this requirement, the TDAFW pump failed a surveillance test on June 30, 2010, and was inoperable for a period of approximately 54 days, which exceeded the TS allowable outage time. Dominion was not aware of the surveillance test failure until an extent of condition review triggered by another failed surveillance test on August 19, 2010, revealed that the TDAFW pump had failed the earlier test. Upon discovery, Dominion restored operability by repairing 3FWA RV45 and placed the condition in the CAP (CR392003 and CR392155). This finding is of very low safety significance because the TDAFW pump was available to fulfill its safety function during the period of time that it was inoperable.
05000336/FIN-2010006-01Broken Jacket Water Banjo Bolt Adversely Impacted EDG 3B Operability2010Q1An unresolved item (URI) was identified because additional information from Dominion and additional NRC review and evaluation is needed to assess the existence of a performance deficiency and its associated characterization (i.e., more than minor, and whether the issue constitutes a violation).During the conduct of 3B EDG routine testing on February 11, 2010, a significant JW system leak occurred at a JW fitting to one of the 14 EDG cylinders. These fittings are referred to as banjo bolts due to their physical configuration resembling a bolt through the body of a banjo. On July 22, 2009, Dominion initiated CR 343051 to address minor JW leakage from the No. 13 cylinder on EDG 38. Dominion estimated the leak rate at approximately 60 drops per minute and determined that it did not have the potential to impact EDG operability. Dominion closed the CR to WO 53102270827. On September22, 2009, operators tagged out EDG 38 for preventive maintenance on the service waterside of the heat exchangers (WO 53102241548). Maintenance completed the planned work on the EDG and operators completed their pre-job briefing for EDG postmaintenance testing. As operators were clearing tags and aligning the EDG for testing, maintenance called to report that during the performance of EDG minor maintenance under WO 53102283391 (to check the leak tightness of No. 13 cylinder banjo bolt), they had discovered that the gasket appeared crushed or the JW fitting could be possibly cracked. They recommended that an immediate repair be pursued. Since the JW banjo bolt tightness check was performed as minor maintenance and not planned into the work window, there were no contingency parts on hand and a corrective maintenance work order was not ready in case of scope expansion. The emergent failure required draining the JW system and resulted in extending the EDG 38unavailability beyond the original planned unavailability (although still within the technical specification allowed outage time). On September 22, 2009, maintenance repaired the JW leak by replacing a degraded banjo bolt on No. 13 cylinder using the original banjo bolt WO 53102270827. Maintenance documented an unanticipated failure of the broken banjo bolt in the WO package. Operations and maintenance supervision reviewed and closed WO 53102270827 with no additional actions taken. On February 11, 2010, operations noted excessive JW leakage from No.3 cylinder during the EDG 3B monthly test, immediately declared the EDG inoperable, performed a controlled shutdown of the EDG, and initiated CR 368610. The team walked down EDG38 shortly after it was shut down and noted that operations had made an appropriate operability decision based on amount of JW that spilled on the floor and the magnitude of the JW leak rate with the EDG shutdown. Dominion determined that the JW leak was from a cracked banjo bolt. The cracked banjo bolt resulted in approximately 20 hours of unplanned unavailability on EDG 38. Maintenance replaced the banjo bolt on NO.3cylinder and operations declared the EDG operable on February 12 following postmaintenance testing. On February 22, 2010, maintenance replaced the banjo bolts on all 14 cylinders on EDG 38, resulting in approximately ten more hours of EDG unavailability. On February 23, 2010, preliminary results from a magnetic particle inspection of the removed EDG 38 banjo bolts revealed seven additional cracked bolts (CR 369856). On February 23, 2010, maintenance replaced all the banjo bolts on the redundant EDG 3A to address the extent-of-condition. Dominion\\\'s initial review of the banjo bolts removed from EDG 3A did not identify any degraded bolts similar to those removed from EDG 38.The team noted that Dominion took prompt and appropriate corrective actions following the emergent banjo bolt failure on February 11; however, the team identified that Dominion had not initiated a corrective action CR in September 2009 when they had identified the first failed banjo bolt. The team noted that this represented a missed opportunity to evaluate the deficiency within Dominion\\\'s CAP, and may have precluded the emergent EDG unavailability in February 2010. Specifically, Dominion procedure PIAA-200, Corrective Action, Attachment 1, listed examples of conditions that require a CR, several of which were applicable to the unanticipated failure of the banjo bolt ,including 1) deficiencies or adverse conditions identified during performance of work, 2)a component failure that is outside of what would normally be expected, and 3)documentation of equipment failures. The team identified that Dominion did not initiate anew CR for the increased JW leakage that potentially impacted EDG operability or for the failed bolt in September 2009, did not re-open and re-screen the July 2009 CR (CR343051), and did not initiate a CR to perform a Maintenance Rule (MR) functional failure evaluation for the banjo bolt failure. The team noted that the failure to initiate a CR for the failed banjo bolt was a missed opportunity because Dominion proactively addressed other JW leaks on EDG 3B during an additional planned unavailability in December 2009 that required draining the JW system. If Dominion had evaluated the banjo bolt failure within their CAP, they may have inspected a sample of banjo bolts and/or proactively replaced all the banjo bolts on the 3B EDG during the December work window. On February 24, Dominion initiated CR 369962 to perform a MR evaluation for the banjo bolt failure discovered in September 2009. Based on the team\\\'s concerns, Dominion initiated CR 370566 for not identifying the degraded JW banjo bolt condition in the CAP in September 2009 and to evaluate their work order documentation review process to address potential generic concerns in this area. The team determined that the degraded condition identified in September 2009 (the broken banjo bolt) was unanticipated and represented an operability concern in contrast to the relatively minor JW leak identified in July 2009. Also the team was concerned that the failure to document the September 2009 failure and take actions to prevent recurrence could have allowed the February 2010 failure during surveillance testing. However, the team concluded that additional information is needed to fully evaluate and characterize the potential performance deficiency. An unresolved item is an issue of concern about which more information is required to determine if a performance deficiency exists, if the performance deficiency is more than minor, or if the issue of concern constitutes a violation. Therefore, this issue will be treated as an URI. Information necessary to complete the NRC\\\'s review is as follows: The failure mechanism of the banjo bolts, including common cause(s); Dominion\\\'s assessment of EDG 3B prior operability (Le., prior to the February 11monthly test), including the associated reportability determination; Confirmation of maintenance history for banjo bolts on both EDG 3A and 3B(Le., preventive maintenance such as torquing, repairs for leaks, replacement, etc.); Assessment regarding the extensive degradation of banjo bolts on EDG 3B (9 out of14) vs. none on EDG 3A; and Dominion\\\'s assessment/communication regarding 10 CFR Part 21 applicability. Upon availability of the above information, additional NRC review will be required to independently assess Dominion\\\'s associated causal analyses for the issue, and determine the appropriate characterization. Specifically, the NRC will assess 1) whether the issue was reasonably within Dominion\\\'s ability to foresee and correct prior to February 2010,2) the banjo bolt failure mechanism, 3) EDG fault exposure, and 4) any associated violations. (URI 05000423/2010006-01, Broken Jacket Water Banjo Bolt Adversely Impacted EDG 3B Operability)
05000336/FIN-2010006-02Licensee-Identified Violation2010Q110 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from July 24, 2008, to July 24, 2009, Dominion did not take adequate corrective action to identify and correct a degraded Unit 2 TDAFW pump steam trap to preclude a repeat overspeed trip during TDAFW pump start-up due to excessive moisture in the steam supply line. Dominion identified the deficiency during a TDAFW valve ST, promptly initiated CR 342844, and performed a thorough and self-critical ACE. This issue was apparent during plant start-up (Le., during TDAFW starts in Mode 3), when moisture accumulation would be increased. During power operation, procedural controls were effective in removing moisture in the steam supply line as demonstrated during past surveillance tests while operating at power. The finding was more than minor because it impacted the equipment performance attribute of the Mitigating Systems cornerstone and the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). In accordance with NRC Inspection Manual Chapter (IMC) 0609, Attachment4, the team performed a Phase 1 Significance Determination Process screening. Based on Table 4a in IMC 0609, Attachment 4, the team determined that the finding was of very low safety significance because it was not a design or qualification deficiency, 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 the technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating events
05000336/FIN-2010008-01Failure to Control Fire Fighting Strategies2010Q3The team identified a non-cited violation of Millstone Unit 2 Operating License Condition 2.C.(3), and Unit 3 Operating License Condition 2.H, for the failure to implement all provisions of the approved Fire Protection Programs. Specifically, Dominion did not implement adequate review, approval and distribution of fire fighting strategies to provide for the adequate development and maintenance of effective strategies. As a result, the team found that Dominion did not provide adequate guidance in the fire fighting strategies for several areas that included the Unit 2 8 emergency diesel generator (EDG) room, and the Unit 3 west switchgear room. This issue was entered into Dominion\\\'s corrective action program as condition report (CR) 388786. The team determined that the failure to administratively control fire fighting strategies as required by the fire protection program was a performance deficiency. This finding was more than minor because it adversely affected the availability and capability objectives of the protection against external events (i.e., fire) attribute under the Mitigating Systems Cornerstone. Specifically, the above examples would likely cause delays in manual fire fighting activities and, therefore, adversely affected the defense-in-depth aspect of the fire protection program to limit fire damage by quick suppression of those fires that occur. The team performed a Phase 1 SDP screening, in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected fire prevention and administrative controls, and was screened to very low safety significance (Green) because this failure to control fire fighting strategies was determined to represent a low degradation rating. This finding had a cross-cutting aspect in the area of human performance because Dominion failed to ensure complete and accurate fire fighting strategies were available to the fire brigade to support timely extinguishment of fires.
05000336/FIN-2010008-02Failure to Protect Safe Shutdown Equipment From the Effects of Fire2010Q3The team identified a cited violation of 10 CFR Part 50, Appendix R, Section III.G.2 for the failure to protect required post-fire safe shutdown components and cabling to ensure one of the redundant trains of equipment remains free from fire damage. In lieu of providing the required separation, Dominion utilized unapproved operator manual actions to mitigate component malfunctions or spurious operations caused by a single fire induced circuit fault (hot short, open circuit or short to ground). Dominion has entered this issue into the corrective program for resolution. The team found the manual actions to be reasonable interim compensatory measures pending final resolution by Dominion. Dominion\'s failure to protect components credited for post-fire safe shutdown from fire damage caused by single spurious actuation is considered a performance deficiency. The performance deficiency was more than minor because it affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to an external event to prevent undesirable consequences in the event of a fire. Specifically, the use of operator manual actions during post-fire shutdown is not as reliable as normal systems operation which could be utilized had the separation requirements of 10 CFR 50, Appendix R, Section III.G.2 been met and therefore prevented fire damage to credited components and/or cables. The team used IMC 0609, Appendix F, Rre Protection Significance Determination Process (SDP), Phase 1 and an SRA conducted Phase 3 evaluation, to determine that this finding was of very low safety significance (Green). The team determined the finding had a low degradation rating because the manual actions were reviewed by the team and were found to be acceptable interim compensatory measures (pending licensee actions to resolve the non-compliances or obtain exemptions) because they did not require complicated actions, adequate time was available to accomplish the actions and the actions were properly included in the appropriate abnormal operating procedures. This finding had a cross cutting aspect in the area of problem identification and resolution associated with the corrective action program because Dominion did not completely and accurately identify deficiencies related to single spurious actuations of credited post-fire safe shutdown components.
05000336/FIN-2010011-01Security2010Q3
05000336/FIN-2010402-01Security2010Q3
05000336/FIN-2010402-02Security2010Q3
05000336/FIN-2010402-03Security2010Q3
05000336/FIN-2011002-01Failure to Prevent Safety Related Cables from Being Submerged2011Q1A self-revealing Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified for Dominion\'s failure to maintain safety related cables in an environment for which they were designed. Specifically, 480V safety related cables, which are not qualified for continuous submergence, were found submerged in a cable vault since approximately October 20, 2010, to March 14, 2011. Dominion took immediate corrective action to remove the water from the cable vault and entered the issue into their corrective action program (CAP). The inspectors determined that the finding was more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the inspectors noted that the insulation of continuously submerged cables would degrade more than dry or periodically wetted cables, which would lead to failures. The finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency which resulted in a loss of operability or functionality, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time, did not represent an actual loss of safety function of one or more non-Technical Specification trains of equipment designated as risk-significant for greater than 24 hours, and was not potentially risk significant due to a seismic, flooding or severe weather initiating event. The inspectors determined that the finding had a cross-cutting aspect in the Problem Identification and Resolution crosscutting area, Operating Experience component, because Dominion did not effectively implement Operating Experience to prevent submergence of safety related cables. (P.2(b))
05000336/FIN-2011002-02lmproper Restoration of Air Conditioning Equipment Following Maintenance Results in Inoperability of \'B\' Train of Recirculation Spray System2011Q1A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for Dominion\'s failure to properly restore 3HVQ*ACUS2B, Containment Recirculation Pumps and Coolers Area \'B\' Air Conditioning Unit, following maintenance. This resulted in approximately an additional 24 hours of inoperability of the \'B\' train of the recirculation spray system (RSS). Dominion entered the issue into their corrective action program. The inspectors determined that the 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, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Dominion\'s failure to follow the written instructions in the tagging cover sheet caused the \'B\' train of RSS to be inoperable for approximately an additional 24 hours. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time, did not represent an actual loss of safety function of one or more non-Technical Specification trains of equipment designated as risk-significant for greater than 24 hours, and was not potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that the finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because operations personnel did not follow the instructions on the tagging cover sheet when returning the air conditioning unit to service. (H.4(b))
05000336/FIN-2011003-01Failure to Take Timely Corrective Actions for De-alloying of Aluminum Bronze Service Water Valves2011Q2The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, corrective Action, for Dominion\'s failure to take timely corrective actions for a condition adverse to quality involving the degradation and subsequent through-wall leakage of Unit 3 service water valves 3SWP.V699 (3HVQ.ACUS1B Bypass Valve), 3SWP.VO18 (3HVQ.ACUS2B Unit Cooler Inlet Valve), and 3SWP*V696 (3HVQ.ACUS2B Unit Cooler Outlet Valve). Specifically, Dominion did not adequately implement a schedule for prioritizing and completing corrective actions on affected aluminum bronze components, which were known to be susceptible to de-alloying, commensurate with the safety significance of the degraded condition. As a result, through-wall leaks developed on these valves and resulted in unplanned loss of operability and additional unavailability of the safety-related support systems for the \'B\' train of containment recirculation spray pumps. Dominion took immediate corrective action to replace the three leaking service water (SW) valves (CR428785). The inspectors determined that this issue was more than minor because it is similar to the more than minor example, 4.F, of IMC 0612, Appendix E, Examples of Minor lssues. Specifically, the degraded condition caused a loss of operability of the \'B\' train of the containment iecirculation spray system. Additionally, the finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring-the availability of systems that respond to initiating events to prevent undesirable consequences. ln accordance with NRC lnspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent an actual loss of system 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. The finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not ensure that issues potentially impacting nuclear safety were corrected in a timely manner commensurate with their safety significance. Specifically, Dominion failed to adequately implement corrective actions to address a known de-alloying issue with SW valves before ihe condition led to the unplanned loss of operability and additional unavailability of the safety-related support systems for the \'B\' train of containment recirculation spray pumps.
05000336/FIN-2011003-02Untimely Corrective Action for Safety Related lnverters Leads to Repetitive Out of Calibration Results2011Q2The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, corrective Action, for Dominion\'s failure to take timely corrective action to address repetitive out of calibration conditions associated with safety-related 120 VAC Unit 2 inverters. To date, Dominion has taken corrective action to adjust the over-frequency and under-frequency transfer limits (CR426589). The inspectors determined the finding was more than minor because it is similar to the more than minor Example \'4f\' of NRC lnspection Manual Chapter (lMC) 0612, Appendix E, Examples of Minor issues. Additionally, the issue is more than minor because the performance deficiency can be reasonably viewed as a precursor to a significant event; in that, the history of over- and under-frequency limits drifting out of tolerance could lead to the unavailability of safety-related equipment powered from the inverters. The inspectors conducted a Phase 1 screening in accordance with NRC IMC Attachment 0609.04, Phase 1 - lnitial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action in a timely manner to address the repetitive out of calibration conditions with the 120 VAC safety related inverters.
05000336/FIN-2011003-03Inadequate Corrective Action Results in Loss of Enclosure Building\'s Safety Function2011Q2A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl, Corrective Action, was identified for Dominion\'s failure to take prompt corrective action to address the cause of main steam safety valve (MSSV) exhaust pipe bushings not seating, which resulted in a loss of the Enclosure Building\'s safety function to control the release of radioactive material. Dominion took corrective action to clean and lubricate the MSSV exhaust pipe and also implemented a modification to upgrade the MSSV outlet boot and qualify it as part of the Enclosure Building filtration boundary (cR420485). The finding was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure of the MSSV sliding bushings to seat properly caused the Enclosure Building Filtration System (EBFS) to fail its surveillance test, and its safety function to control the release of radioactive material could not be assured. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it only represents a degradation of the radiological barrier function provided for the auxiliary building. The inspectors determined that this finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action to address the Enclosure Building surveillance test failure in 2009.
05000336/FIN-2011003-04Failure to Follow Procedure for Starting a Second SGFP Results in Reactor Trip2011Q2A self-revealing finding (FlN) of very low safety significance (Green) was identified for Dominion\'s failure to follow procedure OP 2204, Load Changes, when starting the \'A\' steam generator feedpump (SGFP). Specifically, the operating crew failed to maintain adequate SGFP suction pressure (greater than 325 psig) while starting the \'A\' SGFP, which led to a trip of the \'B\' SGFP and subsequent reactor trip on low steam generator level. Dominion entered this issue into their corrective action program (CR431574); conducted training exercises emphasizing safe operating envelopes, critical parameters to monitor, and actions to take to restore margin if plant conditions degrade; and has revised procedure OP 2204. The finding is more than minor because it is similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor lssues, Example 4b; in that, a failure to follow procedure led to a reactor trip. This issue is associated with the Human Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure of the operators to properly monitor SGFP suction pressure led to a loss of adequate feedwater flow and a reactor trip. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (lMC) Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel did not properly follow the load changes procedure.
05000336/FIN-2011004-01Failure to Electrically Isolate Dissimilar Metal Flanged Joint Leads to Forced Shutdown Due to Service Water Leak2011Q3A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for Dominion\\\'s failure to properly electrically isolate service water (SW) flanged joints of dissimilar metals. This caused a more rapid corrosion rate when a defect occurred in the lining of the carbon steel pipe and eventually led to a SW leak. On September 3, 2011, Dominion was forced to shut down Unit 2 when the spool leaked in excess of the limit allowed in authorized relief from American Society of Mechanical Engineers (ASME) code requirements. Dominion repaired the spool and electrically isolated the flanged joint. Dominion entered this issue into their corrective action program (CAP) CR441302. 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. The finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency that did not result in loss of operability, 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 safety function of one or more non-technical specification trains of equipment designated as risk significant per 10 CFR 50.65, and did not screen as risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel proceeded in the face of uncertainty andlor unexpected circumstances when they had difficulty installing the isolating sleeves in the flanged joint.
05000336/FIN-2011005-01Licensee-Identified Violation2011Q4Technical Specification 4.0.4 states, in part, that entry into an operational Mode shall not be made unless the surveillance requirement(s) .associated with the limiting condition for operation has been performed within the stated surveillance interval. Contrary to the above, while performing RPS matrix and trip path testing during the Unit 2 start-up on July 24, 2009, Dominion closed the TCSs and rendered the CEA drive system capable of CEA withdrawal without first demonstrating that the TCSs were operable. Dominion entered this issue into their corrective action program (CR442964) and is revising the surveillance procedure. This violation is of very low safety significance because the performance of the surveillance verified the operability of the TCSs.
05000336/FIN-2011008-01Multiple Examples of Procedural Violations and Inadequate Procedures Relating to Control Room Crew Performance During a Plant Transient2011Q2A self-revealing finding was identified involving the failure of Millstone personnel to carry out their assigned roles and responsibilities and inadequate reactivity management during main turbine control valve testing on February 12, 2011, which contributed to the unanticipated reactor power increase. Specifically, the Millstone Unit 2 operations crew failed to implement written procedures that delineated appropriate authorities and responsibilities for safe operation and shutdown and a procedure for controlling reactor reactivity. In addition, the licensee failed to establish written procedures for the Reactor Protection System (RPS) Variable High-Power Trip (VHT), and for power operation and transients involving multiple reactivity additions. The finding has preliminarily been determined to be White, or of low to moderate safety significance. The finding is also associated with two apparent violations of NRC requirements specified by Technical Specifications. There were no immediate safety concerns following the transient because the event itself did not result in power exceeding license limits or fuel damage. Additionally, interim corrective actions were taken, which included removing the Millstone Unit 2 control room crew involved in the transient from operational duties pending remediation, and establishment of continuous management presence in the Millstone Unit 2 control room while long term corrective actions were developed. Dominion entered this issue, including the evaluation of extentof- condition, into the corrective action program (CR413602) and performed a root cause evaluation (RCE). The finding is more than minor because the performance deficiency (PD) was associated with the human performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Additionally, the PD could be viewed as a precursor to a significant event. Because the finding primarily involved human performance errors, probabilistic risk assessment tools were not well suited for evaluating its significance. The team determined that the criteria for using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, were met, and the finding was evaluated using this gUidance, as described in Attachment 4 to this report. Based on the qualitative review of this finding, regional management concluded the finding was preliminary of low to moderate safety significance (preliminary White). The team determined that the PD resulted from several causes; however, the team concluded that the primary cause was ineffective reinforcement of Dominion standards and expectations. The team also concluded that this finding had a cross-cutting aspect in the Human Performance area, Decision Making component, because Dominion licensed personnel did not make the appropriate safety-significant decisions, especially when faced with uncertain or unexpected plant conditions to ensure safety was maintained. This includes formally defining the authority and roles for decisions affecting nuclear safety, communicating these roles to applicable personnel, and implementing these roles and authorities as designed.
05000336/FIN-2011008-02Improper Operation of Turbine Control Valves During Testing2011Q2The team identified a self-revealing finding of very low safety significance (Green) for improper operation of the turbine controls during turbine control valve testing. Specifically, the inspectors identified that control room operators failed to correctly implement surveillance procedure SP-2651 N, Main Control Valve Testing. Incorrect operation of the turbine controls caused an unplanned power increase from 88 percent to 96 percent. Dominion entered this issue into the corrective action program (CR415094). The team determined that this finding was more than minor because it was similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Example 4b, in that the incorrect operation of the turbine load selector pushbutton caused a plant transient. The finding was associated with the human performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The team concluded that the finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. The team also determined that the finding had a cross-cutting aspect in the Human Performance area, Resources component, because Dominion did not provide adequate training of personnel and sufficient qualified personnel (H.2(b)).
05000336/FIN-2011201-01Security2011Q1
05000336/FIN-2012003-01Inadequate Operability Determination for 3FWS*CTV41 Feedwater Isolation Valve Hydraulic Actuators2012Q2An NRC identified finding of very low safety significance (Green) was identified for Dominions failure to adequately assess the operability of the Unit 3 Feedwater isolation valves, 3FWS*CTV41A, B, C and D in accordance with OP-AA-102-1001, Development of Technical Guidance Basis to Support Operability Determinations, and C OP 200.18, Time Critical Operator Action Validation and Verification. Specifically, Dominion did not properly validate or credit manual operator actions to isolate the main feedwater lines during a feedline break inside containment as a compensatory measure for degraded hydraulic valve actuators. Dominion entered this issue into their corrective action program (CAP) as condition report number 478020, and conducted a reanalysis of the operability determination. The finding is more than minor because it is similar to NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, Example 3.k; in that the inadequate assessment of operability resulted in a condition where there was a reasonable doubt on the operability of the feedwater isolation function and the feedwater isolation valves. This issue is associated with the Equipment Control 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, Dominion did not explicitly take credit for manual operator actions to trip the main feedwater pumps as a compensatory measure for the degraded capability of the 3FWS*CTV41 feedwater isolation valves to perform their safety function during a feedline break event inside containment. The inspectors determined this finding was not a design qualification deficiency resulting in a loss of functionality or operability, did not represent an actual loss of safety function of a system or train of equipment, and was not potentially risksignificant due to a seismic, fire, flooding, or severe weather initiating event. Therefore, the finding is considered to be of very low safety significance. The inspectors did not assign a cross cutting aspect to this finding because the finding was not reflective of current performance. Operability determination OD000237 was completed in 2009 and OP-AA-102-1001 does not require periodic reassessment of active operability determinations.
05000336/FIN-2012003-02Licensee-Identified Violation2012Q2The following violation of very low safety significance (Green) was identified by Dominion and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. Technical Specification 3.3.2 states, in part, that The Engineered Safety Features Actuation System instrumentation channels and interlocks shown in Table 3.3-3 shall be operable with their Trip Setpoints set consistent with the values shown in the Nominal Trip Setpoint column of Table 3.3-4. TS 3.3.3.4 states in part that these accident monitoring channels shall be operable. Contrary to these requirements, all main steam line steam generator pressure transmitters were reinstalled after maintenance using gaskets that were not environmentally qualified for use in an accident environment, thereby rendering these transmitters inoperable from January 17 through February 9, a condition prohibited by TS. Dominion identified the condition and immediately entered TS 3.0.3. Dominion replaced the gaskets and restored full EQ qualification to all main steam line pressure transmitters while complying with the action statements of TS 3.0.3, and entered the issue into the corrective action program as condition report CR462222.
05000336/FIN-2012004-01Inadequate Post Maintenance Test Directions following Design Change to 3HVC FN1B2012Q3The 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-2012004-02Corrective Action to Prevent Recurrence Ineffective to Preclude Repetition of a Significant Condition Adverse to Quality2012Q3A 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-2012005-01Failure to Adequately Implement Flooding EALs2012Q4The 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-2012005-02Failure to Establish Proper Test Controls for the Wide Range Logarithmic Post Accident Neutron Flux Monitors2012Q4The 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-2012005-03Gaps in West 480V Switchgear HELB Barrier May Impact Safety Related Equipment2012Q4On 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-2012005-04Unsealed Penetrations in Flood Barriers May Impact Safety Related Equipment in a Design Basis Flood2012Q4On 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-2012007-01Inadequate Assumptions Used in Emergency Motor Control Center Control Circuit Voltage Drop Calculation2012Q2The team identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion lll, Design Control, because Dominion had not verified the adequacy of their design with respect to the Unit 2 emergency motor control center (MCC) control circuit voltage drop calculation. Specifically, Dominion did not account for various parameters that affect available voltage at motor starter contactors including fuse resistance, minimum control power transformer (CPT) size, maximum control circuit cable length, actual quantity of control circuit contacts, and containment temperature during a design basis accident (DBA). As a result, the worst case circuit conditions for determining acceptable contactor voltage were not evaluated. Dominion entered the issue into the corrective action program and performed an operability assessment of the most bounding circuit and determined that sufficient voltage would be available to meet its design basis function. The performance deficiency was determined to be more than minor because it was associated with the design 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. The team evaluated the finding in accordance with IMC 0609, Significance Determination Process, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The finding was determined to be of very low safety significance because the design deficiency was confirmed not to result in loss of operability or functionality. The team determined that this finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program because Dominion did not thoroughly evaluate the problem when it was identified and entered into the corrective action program in 2009
05000336/FIN-2012010-01Failure to Take Timely Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation Valves2012Q3The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, for Dominions failure to take timely corrective actions for conditions adverse to quality involving the degradation of the closing capability of four Unit 3 main feedwater isolation valves. Dominion has deferred correcting this condition adverse to quality for over a period of six years (three refueling outages), and correction of the degraded condition is currently scheduled for the next refueling outage (April 2013). 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 NRC IMC 0612, Appendix E, Examples of Minor Issues. 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 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. The inspectors determined this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Decision Making component, because Dominion did not use conservative assumptions in decision making when delaying the repairs.
05000336/FIN-2012010-02Failure to Take Prompt and Effective Corrective Actions to Address TDAFW Pump Trip Latch Mechanism Degradation2012Q3The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, for Dominions failure to take prompt and effective corrective actions for conditions adverse to quality involving degradation of the Unit 3 turbine driven auxiliary feedwater (TDAFW) pump trip latch mechanism. Dominion did not identify the cause of the trip latch mechanism degradation until after multiple surveillance test failures had occurred. In response to questions from NRC inspectors, Dominion performed additional troubleshooting and determined that the linkage was not properly lubricated, and the linkage impact gap was out of adjustment. Dominion lubricated and adjusted the linkage, and declared the TDAFW pump operable after a successful retest. The inspectors determined that this issue was more than minor because it is similar to the more than minor example 4.f of Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues. Additionally, the finding was more than minor because it is associated with the Equipment Performance 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 (i.e., core damage). The finding was determined to be of very low safety significance (Green) because the finding does not represent a loss of system and/or function, does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time, and does 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 the licensees Maintenance Rule program for greater than 24 hrs. The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not thoroughly evaluate the problem such that the resolution addressed the causes.
05000336/FIN-2012010-03Failure to Perform Effectiveness Reviews for Formal Self-Assessments2012Q3The inspectors identified a finding (FIN) of very low safety significance (Green) for Dominions failure to perform procedurally required effectiveness reviews for numerous formal self-assessments. Consequently, Dominion missed opportunities to identify potential corrective actions for resolution in the corrective action program. Dominion has entered the issue into the corrective action program (CR482135). The inspectors determined that this finding was more than minor because it is similar to IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, example 3.j; in that, it represents a programmatic deficiency that could lead to worse errors if uncorrected. This finding was of very low safety significance (Green) because the finding does not represent a loss of system and/or function, does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time, and does not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program for greater than 24 hrs. This finding is not associated with an NRC Reactor Oversight Process cornerstone. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion personnel failed to follow procedures.
05000336/FIN-2012503-01Failure to Adequately lmplement Fuel Clad Barrier EALs2012Q4The NRC identified a non-cited violation (NCV) associated with emergency preparedness planning standard 10 CFR 50.47(b)(4), and the requirements of Sections lV.B and lV.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 not providing operations procedures for obtaining reactor coolant samples once a safety injection signal has occurred. These deficiencies adversely affected the ability of the licensee to properly classify events involving the loss of the fuel clad fission product barrier. The inspection team determined that the failure by Dominion to provide the proper operating procedures for operators to adequately implement their respective unit\\\'s EALs 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 emergency response organization (ERO) attribute of the Emergency Preparedness 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 evaluated this finding using the Emergency Preparedness Significance Determination Process (Appendix B to IMC 0609) and determined the finding to be of very low safety significance (Green). Appendix B to IMC 0609, Section 5.4, and Table 5.4-1, were used to reach this determination. The inspector determined that this finding involved an example where an EAL has been rendered ineffective such that any Site Area Emergency would not be declared for a particular off-normal event, but because of other EALs, an appropriate declaration could be made in a degraded manner (e.9., delayed). The finding is related to the crosscutting area of Problem ldentification and Resolution, Corrective Action Program, in that Dominion personnel did not take appropriate corrective actions to address a Risk- Significant Planning Standard (RSPS) issue completely, accurately, and in a timely manner commensurate with the safety significance (P.1(d)). Specifically, Dominion did not place this issue into the corrective action program and take appropriate action until prompted by the NRC team\\\'s findings.
05000336/FIN-2013002-01Inadequate Post Maintenance Testing Following PORV Maintenance2013Q1The 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-2013003-01Failure to implement Annunciator Response Procedure for a Loss of Ventilation during a Battery Charge2013Q2The 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-2013003-02Failure to Establish Measures for the Identification and Control Design Interfacesand for Coordinating among Participating Design Organizations2013Q2The 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-2013003-03Failure to Make a 10 CFR 50.72(b)(3)(v) Report for a Major Loss of EmergencyAssessment Capability for Stack Radiation Monitor2013Q2The 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-2013003-04Licensee-Identified Violation2013Q2On 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-2013003-05Licensee-Identified Violation2013Q2On 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-2013004-01Inadequate Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation Valves2013Q3The 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-2013004-02\"Inadequate Operability Determination for the Turbine Drive Auxiliary Feedwater (TDAFW) Pump\"2013Q3The 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-2013004-03Licensee-Identified Violation2013Q310 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-2013004-04Licensee-Identified Violation2013Q3TS 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-2013004-05Licensee-Identified Violation2013Q310 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-2013005-01Implementation of NEI 99-01 Guidance2013Q4A 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-2013005-02Inadequate Alternative Shutdown Procedure2013Q4The 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-2013005-04Licensee-Identified Violation2013Q4TS 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-2013005-05Licensee-Identified Violation2013Q4TS 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-2013007-01Failure to Verify 480VAC MCC Starters Had Adequate Control Voltage to Operate Under All Design Conditions2013Q1The team identified a finding of very low safety significance involving a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, in that Dominion did not verify that Unit 3 safety-related motor control center (MCC) starters had adequate control voltage to operate under all design conditions. Specifically, Dominion did not use the minimum voltage that would be available at Unit 3 MCCs during the most limiting block starting of large electrical loads during a Unit 3 loss of coolant accident (LOCA) as the design input for the minimum voltage under which an MCC starter was required to operate, to ensure that the starter\'s contactor would close when Unit 2 off-site power is cross-tied to Unit 3. In response, Dominion entered the issue into their corrective action program and issued an Operations Standing Order to ensure that the off-site electrical distribution system would not be placed in a configuration that would allow a lower minimum voltage than what was previously analyzed for the MCC starters until the issue was resolved. The finding was more than minor because it was similar to Example 3.j of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, because without verification that the components would operate at the lowest potential voltage possible, the team had reasonable doubt with the operability of the associated components. In addition, the finding was associated with the Design Control attribute of the Mitigating Systems cornerstone and affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, a Region I Senior Reactor Analyst (SRA) conducted a detailed risk evaluation. Since the ability of the MCC starters to function under the worst case conditions could not be verified during the inspection period, a detailed risk evaluation was determined to be appropriate. Results of the evaluation demonstrated that the initiating event frequency was substantially below 1E-6, and therefore, the SRA concluded the finding to be of very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Performance, Decision Making, because, in the design of a Unit 3 480 volts alternating current (VAC) MCC starter modification, Dominion did not use a conservative or bounding value as a design input for the minimum voltage under which a component might be required to operate. (IMC 0310, Aspect H.1(b))
05000336/FIN-2013010-01Inadequate Alternative Shutdown Procedure2013Q3The 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.
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