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	Quarter	Site	Title	Description
05000336/FIN-2008002-02	2008Q1	Millstone	Failure to Identify Unacceptable Unit 2 Charging Pump Surveillance Test Data (Section 1R22)	Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control, for Dominions failure to adequately evaluate surveillance test results to ensure test acceptance criteria had been met on June 20, 2007. Specifically, the inspectors identified that the A charging pump pulsation dampener surveillance test had incorrect data (i.e., testing duration time) and had been accepted as satisfactorily complete, although the test data was outside the surveillance acceptance criteria. The test, in part, demonstrated that nitrogen gas from a failed charging pump discharge dampener would not migrate into the common suction line prior to the credited operator action to shut the pumps suction valve. A subsequent review determined the surveillance test data was incorrect and the A charging pump was operable. Dominions corrective actions for this issue included briefings to provide additional coaching and heighten awareness to the Unit 2 operations shift crews, a review of actual surveillance computer data and review of subsequent surveillances to ensure system operability, and the creation of a trend condition report including other related human performance errors (CR-08-03220). This finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to identify out of specification data could result in the failure to identify inoperable equipment. The inspectors also concluded that if the failure to properly evaluate charging pump discharge dampener test data was not corrected, a more significant concern could exist (i.e. common mode failure of charging). The finding was determined to be of very low significance (Green), because it was a deficiency confirmed not to result in loss of safety function. The performance deficiency had a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program component, because Dominion did not identify out of specification test data (P.1(a)). (Section 1R22
05000336/FIN-2008002-03	2008Q1	Millstone	Failure to Identify a Service Water Bypass Flow Path following a Failed IST (Section 1R22)	Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for Dominions failure to identify a condition adverse to quality after the B service water (SW) pump failed a Technical Specification in-service test (IST). Specifically, on March 9, 2008, Dominion declared the B Service Water (SW) pump operable, despite a failed IST flow surveillance. Dominion based this declaration on the incorrect assumption that the failed pump differential pressure (dp) was indicative of faulty test equipment vice an actual equipment issue. On March 10, 2008, Dominion determined that the unacceptable B SW dp was caused by back pressure from the running C SW pump through the shut B swing pump cross connect valve (2-SW-79B). The inspectors identified that Dominion did not have a reasonable basis to consider the IST invalid based on the information available at the time. Corrective actions for this issue included implementing an alternate plant configuration to ensure train separation, performing an assessment to evaluate past operability and to establish a bounding service water temperature at which the B service water pump would be considered inoperable, and incorporating the 2-SW-97B leakage repair in the 2R18 refueling outage. This finding was more than minor because it was associated with the equipment performance attribute of the Mitigating System cornerstone, and affected the cornerstones objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, Dominion concluded that the B SW pump IST containing unacceptable dp data was invalid based, in part, on an inability to justify the results (i.e. high dp and nominal flow). Consequently, the B SW pump was inappropriately declared operable and the actual degraded condition was not promptly identified and corrected. This finding is of very low safety significance (Green) because it did not result in a confirmed loss of service water train operability. This finding has a cross-cutting aspect in the area Human Performance, Decision Making Component, because Dominion did not use conservative assumptions in restoring B SW pump operability following a failed IST surveillance (H.1(b)). (Section 1R22
05000336/FIN-2008003-01	2008Q2	Millstone	Fire Protection Deficiency Resulting in Potential Loss of All Charging Pumps	The NRC identified a Green NCV of the Millstone Unit 3 operating license, Condition 2.H, Fire Protection, in that Dominion failed to appropriately evaluate and correct in a timely manner a fire protection program deficiency. Specifically, Dominion failed to assure that one train of charging would remain free of fire damage for fire scenarios that could produce spurious closure of a volume control tank (VCT) outlet or charging pump suction motor operated valves. This issue was first identified by Dominion in September 2004, but plans to thoroughly evaluate the issue relative to the fire protection program were extended on several occasions. Dominion initiated compensatory measures to minimize the likelihood of a fire in the affected area, to maximize the availability of the C charging pump, and to determine a long term resolution. This finding is more than minor because it is associated with the External Factors attribute (fire) of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the availability of the charging system was not ensured for nine fire scenarios. Using IMC 0609, Appendix F, Fire Protection Significance Determination Process, the inspectors conducted a Phase 1 screening, and a combination of Phase 2 and 3, to determine that this finding was of very low safety significance (Green), with an estimated total core damage frequency (CDF) of 1 in 1,400,000 years in the range of 7E-7 per reactor operating year. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Dominion extended the due dates to perform a thorough evaluation of the issue. (P.1(c)) (Section 1R05.2
05000336/FIN-2008003-02	2008Q2	Millstone	Inadequate Maintenance Instructions Causes Reactor Coolant System Unidentified Leakage in Excess of Technical Specification Limits	The inspectors identified a Green NCV of 10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for Dominions failure to provide adequate maintenance instructions for replacing the gaskets on the B low pressure safety injection (LPSI) pump suction line. Specifically, the work order did not contain torque requirements; as a result, the flanged joint was over-torqued and caused the flexitallic gasket to fail. Debris from the gasket prevented the B LPSI pump suction isolation valve from closing, and caused a reactor coolant system leak in excess of Technical Specification limits. Dominion declared an Unusual Event. Dominion replaced the gasket and repaired the valve. The performance deficiency was Dominions failure to provide adequate maintenance instructions for assembling the flanged connection, including appropriate torque values. This finding is more than minor because it is associated with the Human Performance attribute of the Initiating Event 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. The inspectors conducted a Phase 1 screening in accordance with IMC 0609, Appendix G, Shutdown Operations Significance Determination Process; a quantitative assessment (Phase 2) was required because the finding increased the likelihood of a loss of RCS inventory. The Phase 2 analysis resulted in the finding being screened as having very low safety significance (Green) because the change in core damage frequency was in the range of low 1E-7. The finding has a cross cutting aspect in the area of Human Performance, Resources, because Dominion did not ensure complete, accurate, and up-to-date work packages for the replacement of the gaskets in the B LPSI pump suction line. (H.2(c)) (Section 4OA3.1)
05000336/FIN-2008003-03	2008Q2	Millstone	Licensee-Identified Violation	The following violation of very low safety significance (Green) was identified by Dominion and is a violation of NRC requirements, which meet the criteria in Section VI.A.1 of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV. A listing of documents reviewed is provided in Attachment A. Millstone Unit 2 TS 3.1.1.3, Boron Dilution, requires a maximum of two charging pumps capable of injecting into the RCS whenever the temperature of one or more of the RCS cold legs is less than 300 F. Contrary to the above, on April 13, 2008, from approximately 2:00 a.m. to 8:18 a.m., all three charging pumps were aligned and capable of injection into the RCS while in Mode 6. This finding was entered into Dominions CAP (CR-08-03934). The details of this issue were discussed in Section 4OA3.4 of this report
05000336/FIN-2008004-01	2008Q3	Millstone	Failure to Identify the Correct Internal Trim Package for Valve 2-HD-103A Results in Reactor Trip	A self-revealing finding of very low safety significance (Green) was identified for Dominions failure to identify the correct internal trim package (cage) for the Millstone Unit 2 feedwater heater level control valves (2-HD-103A/B). Specifically, on multiple occasions, Dominion personnel had the opportunity to initiate a condition report to document discrepancies associated with cage assemblies. Most recently, the wrong cage was installed in 2-HD-103A, which resulted in level oscillations in the 2A feedwater heater, necessitating a manual reactor trip. Dominion entered this issue into their corrective action program (CR-08-07451) and installed the correct internal trim package in valve 2-HD-103A. This finding was more than minor because it 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 inspectors conducted a Phase 1 screening, in accordance with IMC 0609, Significance Determination Process, 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 area of Problem Identification and Resolution, Corrective Action Program, because Dominion did not identify the issue completely, accurately, and in a timely manner. (P.1(a)) (Section 40A3.1)
05000336/FIN-2008004-02	2008Q3	Millstone	Failure to Take Adequate Corrective Action to Prevent Lifting of a Steam Generator Safety Valve	A self-revealing, Green, non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for Dominions failure to take effective corrective actions to prevent lifting of a steam generator safety valve following a simultaneous reactor and turbine trip from full power at Unit 2, as described in the Unit 2 Final Safety Analysis Report. Specifically, a momentary power loss to the VR-11 and VR-21 120V power supplies caused a delay in the generation of the quick open signal to the condenser steam dump valves and atmospheric dump valves, resulting in the lifting of the safety valve. Dominion entered this issue into their corrective action program (CR-08-07476) and changed the power supply to the quick open signal inputs to the steam dumps and atmospheric dump valves to a vital power supply. This finding was more than minor because it affected the Equipment Performance Attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability. The inspectors conducted a Phase 1 screening, in accordance with IMC 0609, Significance Determination Process and determined that this finding was of very low safety significance (Green). Specifically, the finding did not contribute to the likelihood of a primary loss of coolant accident, did not contribute to both the likelihood of a reactor trip and the unavailability of mitigating equipment, and did not increase the likelihood of a fire or internal/external flood. The inspectors determined that this finding had a cross cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because the licensee did not take appropriate corrective action to address the unnecessary lifting of the safety valve in a timely manner, commensurate with its safety significance and complexity. (P.1(d)) (Section 40A3.2)
05000336/FIN-2009002-01	2009Q1	Millstone	Licensee-Identified Violation	TS 3.0.4 states, in part, that entry into an operational mode shall not be made when the conditions for the Limiting Condition for Operation are not met and the associated action requires a shutdown if they are not met within a specified time interval. Contrary to this, from November 22, 2008 at 17:46 until November 24, 2008 at 03:46, Unit 3 did not meet the conditions for TS 3.7.1.2, AFW system due to an isolated steam trap, and transitioned from mode 3 to mode 1. Dominion restored the AFW system to operability and entered the issue into their corrective action process, CR120030. This finding is of very low safety significance because the finding does not involve a loss of system safety function or a loss of safety functions of a single train for greater than its TS allowed outage time
05000336/FIN-2009002-02	2009Q1	Millstone	Containment Penetration Not Fully Closed During Fuel Movement	The inspectors reviewed the LER and Dominions apparent cause evaluation of the event. The inspectors determined that the failure to completely close valve 3FWSV861 was not within Dominions ability to foresee and correct and was not a performance deficiency. Valve 3FWSV861 does not have position indication. The operator who closed the valve and the operator who performed the independent verification did not have an alternate means to verify that the valve was completely closed. Additionally, when the valve was identified to be leaking while filling the SG, it was only able to be completely closed when mechanical leverage was applied. A review of previous work orders (WOs) revealed that the valve was replaced like for like in 2007 due to seat leakage. A different packing was used which required more force to consolidate. Also, the packing gland was torqued per procedure when, previously, the packing was tightened using good mechanical practices. Because of these changes, more force would be required to operate the valve; however, there was no indication in the 2007 WO that the valve was difficult to operate. A review of the CRs associated with this valve did not indicate any previous problems in operating the valve. Because of these details, the inspectors concluded that the inability to fully close valve 3FWS*V861 could not have reasonably been avoided or detected by Dominions quality assurance program or other related control measures. The inspectors also performed a Phase1 SDP analysis and determined the violation to be of very low safety significance (Green). Dominions corrective actions included closing the valve, entering the issue into their corrective action process (CR 117527), changing the position verification procedure to specify physical verification versus visual, and plans to modify the valve during the next refueling outage to improve the stroking function. Therefore, in accordance with Section VII.B.6 of the Enforcement Policy, the NRC has chosen to exercise enforcement discretion and not issue a violation for this issue.
05000336/FIN-2009003-01	2009Q2	Millstone	Failure to Survey a Contaminated Component	An NRC-identified finding of very low safety significance (Green) was identified for Dominions failure to effectively survey, label, and control contaminated tools and equipment. Specifically, Dominion failed to perform adequate surveys to identify a hose fitting having a contact dose rate measurement of 160 mrem per hour as required by 10CFR 20.1501. Dominion entered this issue into their corrective action program asCR322737.This finding was more than minor because it was associated with the program and process attribute of the Radiation Safety cornerstone and affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. By not surveying and labeling the hose fitting, workers could have received unplanned exposure when not informed of the radiological hazard present. The finding has a cross cutting aspect in the area of work practices, because the licensee did not assure that personnel follow procedures H.4(b). Specifically, procedure RPM 2.4.2, Radiological Control of Material and Vehicles, was not properly implemented to assure compliance with 10 CFR 20 requirements
05000336/FIN-2009003-02	2009Q2	Millstone	Licensee-Identified Violation	10 CFR 50 Appendix B, Criterion III, Design Control states, in part, that measures shall be established to assure that the applicable regulatory requirements and the design basis, for those structures systems, and components, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this, in April2007, Dominion removed relief valves 3CHS*RV8510A and B from the charging system alternate minimum recirculation flow path. This modification connected non-seismic American Society of Mechanical Engineers (ASME) B31.1 piping to safety related ASME Code Class 2 piping without an appropriate means of isolation. Dominion produced evaluations that demonstrated that the ASME B31.1 piping would not rupture in a seismic event and entered the issue into their corrective action process, CR 333528. This finding is of very low safety significance because the finding is a design or qualification deficiency confirmed not to result in loss of operability or functionality
05000336/FIN-2009003-03	2009Q2	Millstone	Licensee-Identified Violation	License Condition 2.H for Unit 3 states, in part, that Dominion shall implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR. The Fire Protection Evaluation Report of the FSAR requires Dominion to comply with Branch Technical Position (BTP) CMEB 9.5-1, position C.5.c for alternative or dedicated shutdown capability. The BTP CMEB 9.5-1, positionC.5.c(1) requires in part that, During the post fire shutdown, the reactor coolant system process variables is maintained within those predicted for a loss of normal AC power, and the fission product boundary integrity is not affected. Contrary to this, from initial plant operation until Unit 3 entered cold shutdown conditions on October 12, 2008, implementing the alternative shutdown method while a SI Sactuation occurred during certain postulated fires requiring control room evacuation, could result in a water-solid pressurizer and water relief through the pressurizer safety relief valves. The pressurizer safety relief valves are not qualified for water relief and may fail to open. This finding was entered into Dominions Corrective Action Program (CR 107561). Dominion promptly established compensatory actions consistent with Unit 3s fire protection program requirements on August 29, 2008,when the fire protection program nonconformance was identified. Dominion subsequently completed a plant modification to the safety injection circuits during the Fall 2008 refuel outage and eliminated the potential for a single spurious actuation of the SIS resulting in pressurizer overfill. This finding is more than minor because it is associated with the external factors attribute (fire) of the Initiating Events 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, a control room fire requiring evacuation while a spurious SIS injection signal occurred could have caused the pressurizer to fill solid and pressurizer safety relief valves to relieve water. The inspectors used Phase 3 of the NRCs IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP), to determine that this finding was of very low safety significance (Green)
05000336/FIN-2009004-01	2009Q3	Millstone	Inadequate and Untimely Corrective Actions Causes Reactor Trip	A self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to provide timely and effective corrective actions for known degraded conditions on the Unit 2 VR-11 and VR-21 120-volt AC non-vital instrument power supplies. Specifically, VR-11 and VR-21 were known to cycle on and off repeatedly whenever an electrical disturbance on the grid affected the input supply voltages from their respective regulating transformers. The degraded condition on the instrument buses had not been corrected despite numerous prior opportunities and Ultimately led to a reactor trip on July 3, 2009. Dominion entered this issue into their corrective action program (CR340569 and CR340579). Interim corrective actions included the installation of dedicated uninterruptable power supplies (UPS) for the Electro-Hydraulic Control (EHC) system and feedwater level control system loads prior to reactor startup. Final corrective actions to install a larger UPS to power the VR-11 and VR-21 DC buses are under engineering evaluation. This finding is more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Dominion did not implement effective interim corrective actions, nor did they take timely final corrective actions to prevent recurrence of the power cycling of the VR-11 and VR-21 instrument buses in time to prevent a reactor trip on July 3, 2009. The inspectors performed a Phase 1 screening, in accordance with fMC 0609, Significance Determination Process, and determined that the finding is of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity P.1.d
05000336/FIN-2009004-02	2009Q3	Millstone	Inadequate Procedures Caused a Leak from the Charging Header into the Auxiliary Building Drain System	A violation of 10 CFR 50, Appendix 8, Criteria V dispositioned as an NCV was identified for Dominion\'s failure to provide adequate operating procedures that were appropriate for the circumstances to operate the Unit 2 charging pumps during reactor shutdown. Specifically, on July 9, 2009, the operators were required to raise pressurizer level while drawing a bubble in the pressurizer in preparation for transitioning from mode5 to mode 4. Dominion started the 8 positive displacement charging pump without first opening the charging header isolation valves and damaged two relief valves in the charging line. Neither of the operating procedures in use for this evolution required the charging header isolation valves to be opened. This event was more than minor because if left uncorrected, the performance deficiency had a potential to lead to a more significant safety concern. This finding is associated with the equipment performance attribute of the mitigating systems cornerstone. The finding has a cross-cutting aspect in the area of human performance, maintaining complete accurate and up-to-date procedures, because Dominion did not provide an operating procedure that was appropriate for accomplishing the task under the circumstances (H.2.c).
05000336/FIN-2009004-03	2009Q3	Millstone	Unit 2 A Reactor Coolant Pump Seal Cooler Weld	During a recent Problem Identification and Resolution Inspection, the inspectors reviewed Dominion\'s conformance with the specifications of ASME Code Section XI and Section III relative to repair of a pressure boundary leak condition that affected the A RCP seal cooler piping, a ASME Class I component. Dominion identified a weld leak affecting the Millstone Unit 2, A RCP seal cooler piping on July 13, 2009, an ASME Class I component. The affected piping is 1.5aD and is part of the reactor coolant pressure boundary. The repair was initiated in accordance with ASME Section XI, which directed Dominion to ASME Section III for weld repair completion and post repair non-destructive examination. On July 17, 2009, Dominion completed the repair welding, and subsequently returned the plant to power on July 25, 2009. Aspects concerning Dominion\'s performance with regard to this repair activity remain to be reviewed and assessed to ascertain conformance with the applicable ASME Code and NRC regulatory requirements. URI 05000336/2009004-03.
05000336/FIN-2009004-04	2009Q3	Millstone	Licensee-Identified Violation	10 CFR Part 50.54(q), Conditions of licenses, states in part, A holder of a nuclear power reactor operating license under this part, or a combined license under part 52of this chapter after the Commission makes the finding under 52.1 03(g) of this chapter, shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of this part. Contrary to this requirement, on several occasions in December 2008 and January 2009, the Emergency Medical Technician (EMT) position was not staffed as required by the Emergency Plan. Prior to 2007, the Millstone Power Station fire brigade was an independent organization responsible for meeting the qualified EMT Emergency Plan requirement. In 2007, the site fire brigade became part of the Operations Department and Plant Equipment Operators (PEO) became responsible for meeting the EMT requirement. This change to the organizational structure impacted the Emergency Plan in that some of the PEOs did not maintain their EMT qualifications. This resulted in the EMT position not being staffed on multiple occasions in December 2008 and January 2009. The Dominion Emergency Plan requires the EMT position to be staffed on a continuous basis. This finding is of very low safety significance based on a SDP Phase 1 screen utilizing IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process. Upon identifying the issue, Dominion entered the issue into their corrective action program as CR 0712258to capture the non-compliance with the Emergency Plan. The finding is licensee-identified because it was discovered by Dominion during a self evaluation in2007 (CR-07-12258).
05000336/FIN-2009004-05	2009Q3	Millstone	Licensee-Identified Violation	10 CFR Part 50.54(q), Conditions of licenses, states in part, The nuclear power reactor licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet the standards of 50.47(b) and the requirements of Appendix E to this part. Contrary to this requirement, Dominion\\\'s replacement of the dedicated site fire brigade with designated personnel with collateral duties was not evaluated for a possible decrease in effectiveness of the Emergency Plan. This change impacted the Emergency Plan in that it facilitated the EMT position not being staffed on multiple occasions. Therefore, Dominion should have performed a 50.54(q) screening to evaluate the potential impact to the Emergency Plan. The finding is licensee-identified because it was discovered by Dominion during an audit in 2008. Upon identifying the issue, Dominion entered the issue into their corrective action program as CR 08-00691. The deficiency was evaluated using the traditional enforcement process since the failure to screen the organizational change could adversely impact the NRCs ability to carry out its regulatory mission. Because this finding is of very low safety significance and has been entered into the corrective action program this finding is being treated as a Severity Level IV Non-Cited Violation of 10 CFR 50.54(q).
05000336/FIN-2009005-01	2009Q4	Millstone	TS Surveillance Channel Calibration of ICCMS Not Performed	The inspectors identified a Green, non-cited violation (NCV) of Millstone PowerStation Technical Specification (TS) surveillance requirement 4.3.3.8 for Dominion\'s failure to perform a channel calibration of the Unit 2 Inadequate Core Cooling Monitoring System (ICCMS) every 18 months. Dominion entered the issue into their corrective action program and concluded that the ICCMS was operable. Dominion performed a risk assessment of the missed surveillance in accordance with TS 4.0.3, and determined that the completion of the surveillance could be delayed up to the 18 month surveillance interval without a significant increase in risk. This finding was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone, and affected the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding) protect the public from radionuclide releases caused by accidents or events. Specifically, in 1997, Dominion incorrectly revised surveillance procedure SP 2407A so that it no longer met the requirements of TS surveillance requirement 4.3.3.8. The inspectors determined the finding was of very low safety significance (Green) because it was associated with a fuel barrier of the Barrier Integrity cornerstone. This finding did not have a cross-cutting aspect because the performance deficiency occurred in 1997, and was not indicative of current performance
05000336/FIN-2009005-02	2009Q4	Millstone	Implementation of Design Change Results in an Unplanned Shutdown of Reactor	A self-revealing, Green finding (FIN) was identified for Dominion\'s failure to take Adequate precautions and adequately schedule maintenance on a Unit 2 motor-operated disconnect (MOD) associated with the main transformer. The maintenance on the MOD disrupted a switch connection and caused increasing conductor temperatures, which forced Dominion to perform an unplanned shutdown of the Unit 2 reactor. Dominion has taken corrective action to modify the appropriate procedures and has entered this issue into their corrective action program (CR 351109).This finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors performed a Phase 1screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined the finding was of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available. Enforcement action did not apply because the performance deficiency did not involve a violation of a regulatory requirement. Because this finding did not involve a violation of regulatory requirements, and has very Ipw safety significance (Green), it has been identified as a finding (FIN). This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Dominion did not appropriately incorporate risk insights and work scheduling of activities consistent with nuclear safety. H.3(a
05000336/FIN-2009005-03	2009Q4	Millstone	RCS Drain Down Loss of Configuration Control	A Green, self-revealing non-cited violation (NCV) of Millstone Technical Specification (TS) 6.8.1 (a), Procedures, was identified for Dominion\'s failure to adequately implement procedures during partial draining of the reactor coolant system(RCS) in preparation for defueling the reactor. Dominion did not properly align the reactor vessel vent path prior to partially draining the RCS as required by Dominion procedure OP-2301E, Draining the RCS (ICCE). Immediate corrective actions included stopping the drain down and verifying the valve alignment. Dominion entered this issue into the corrective action program (CR 351853).This finding was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective to limit the likelihood of those events that challenge critical safety functions during shutdown operations. Specifically, the operators failed to properly position 2-RC447to vent to the reactor vessel during partial drain down of the reactor vessel. The inspectors determined the significance of this finding using NRC Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significant Determination Process. This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Dominion failed to define and effectively communicate expectations regarding procedural compliance, and personnel follow procedures. H.4(b
05000336/FIN-2009005-04	2009Q4	Millstone	Inadequate and Untimely Corrective Actions Causes Loss of Annunciators and Declaration of a NOUE	A Green, self-revealing finding (FIN) was identified for Dominion\'s failure to complete effective corrective actions for known degraded conditions associated with theVR-11 and VR-21 120-volt AC non-vital instrument power supplies. This condition led to a loss of annunciators and declaration of a Notification of Unusual Event (NOUE) on November 15, 2009. Dominion took immediate action to expedite the installation of an uninterruptible power supply (UPS) for VR-11 and VR-21.This finding was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance(Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. No violation of regulatory requirements occurred, because the annunciator system is non-safety related. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. P.1(d
05000336/FIN-2010002-01	2010Q1	Millstone	Licensee-Identified Violation	Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide1.33. Contrary to this, Dominion\'s procedure MP2704U, Containment Personnel Airlock, was inadequate because it was not established with sufficient detail to complete interlock restoration. As a result, the containment airlock interlock was not properly reset at the end of the refueling outage on November 13, 2009. On December 2, 2009, containment integrity was not maintained when the improperly reset interlock allowed both airlock doors to be briefly open during a containment entry while Unit 2 was at 100 percent power. Dominion immediately closed the door and entered the issue into their corrective action process, CR 360277. The finding is of very low safety significance because both airlock doors were only open briefly 1 minute) and there were no other degraded plant conditions that would have created a safety concern during the time the airlock doors were open
05000336/FIN-2010003-01	2010Q2	Millstone	Failure to Properly Identify and Correct a Degraded Governor Condition in the Unit 2 \'A\' EDG	A self-revealing, NCV of 1 0 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for Dominion\'s failure to properly evaluate a condition adverse to quality involving the Unit 2 \'A\' emergency diesel generator (EDG). Dominion did not properly evaluate a degraded condition of the \'A\' EDG, which led to its inoperability from May 12,2010, to May 17, 2010. Dominion took immediate corrective action to replace the EDG govemor. The inspectors determined this finding was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Dominion\'s inadequate evaluation of the degraded condition of the \'A\' EDG governor after the March 17, 2010, surveillance test did not result in effective corrective action to address the cause of the rapid load increase. As a result, the \'A\' EDG was declared inoperable when it again experienced a rapid load increase during its surveillance on May 12, 2010. The inspectors determined the significance of the finding using IMC 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 represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time. The inspectors determined that 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 its decision making when they could not conclude that the EDG load fluctuations would not recur (H.1 (b )).
05000336/FIN-2010003-02	2010Q2	Millstone	Failure to Properly Plan Work Activities for the Unit 2 \'D\' Circulating Water Bay Outage Results in Manual Reactor Trip.	A self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to properly plan work activities associated with the Unit 2 \'D\' circulating water (CW) bay outage in accordance with Dominion procedure WM-M- 3000, Managing Complex Work. The work plan failed to properly sequence work activities to prevent fouling of the \'C\' CW screens. The subsequent fouling of the \'C\' CW travelling screen resulted in an automatic trip of the \'C\' CW pump. Loss of the \'C\' CW pump, coupled with the unavailability of the \'D\' CW pump, required the operators to manually trip the reactor. Dominion entered this issue into their corrective action program (CR370363). This finding is more than minor because it was similar to NRC IMC 0612, Appendix E, Examples of Minor Issues, Example 4b, in that the implementation of the inadequate work plan caused the loss of the \'C\' CW pump, and required the operators to manually trip the reactor. The inspectors determined this 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. Specifically, the work plan for the \'D\' CW bay outage did not properly sequence the work, which led to the loss of the \'C\' CW pump and required the operators to manually trip the reactor. The inspectors determined the significance of the finding using IMC 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 Control component, because Dominion did not appropriately plan the bay cleaning and demucking (removal of scraped material) work activity to address the risk of the activity to impact the other CW bays (H.3(a)).
05000336/FIN-2010003-03	2010Q2	Millstone	Failure to Make a 10 CFR 50.72 (b )(3)(v) Report for an Inoperable Unit 3 Secondary Containment	The inspectors identified a Severity Level IV NCV of 10 CFR 50.72(b)(3)(v); in that, Dominion failed to make a timely 10 CFR 50.72 eighthour report to the NRC for a condition that, at the time of discovery, could have prevented secondary containment from fulfilling its safety function. On May 27, 2010, operations personnel found both sets of the auxiliary and service building tunnel exhaust dampers open which could have prevented secondary containment from fulfilling its safety function. Operations declared secondary containment inoperable, closed the auxiliary building tunnel exhaust dampers to restore operability, and initiated a 10 CFR 50.72 report. The inspectors determined that Dominion\\\'s failure to make a 10 CFR 50.72 eight-hour report to the NRC regarding the inoperable secondary containment as a condition that could have prevented it from fulfilling its safety function was a performance deficiency. The inspectors determined that traditional enforcement applied, since the failure to make a required report could adversely impact the NRC\\\'s ability to perform its regulatory function. In accordance with the NRC Enforcement Policy, Supplement I - Reactor Operations, Example D.4, a failure to make a required Licensee Event Report (LER) is categorized as a Severity Level IV violation. The inspectors determined that this finding had a cross-culling aspect in the Human Performance cross-culling area, Decision Making component, because Dominion did not use conservative assumptions in their decision-making when they could not demonstrate that secondary containment would have fulfilled its safety function (H.1(b)).
05000336/FIN-2010003-04	2010Q2	Millstone	Charging Pump Overheating and Cavitation during RCS Loop Vacuum Fill	A self-revealing, NCVof 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for Dominion\'s failure to have an adequate procedure for operating the Unit 3 charging pumps. Specifically, Dominion operating procedure (OP) 3304A, Charging and Letdown, did not require verification of Reactor Plant Closed Cooling Water (RPCCW) flow to the seal water heat exchanger, which resulted in overheating of the \'B\' charging pump during a reactor coolant system (RCS) vacuum fill on May 1, 2010. Dominion has created corrective actions to make procedural enhancements to OP-3304A, Charging and Letdown, and OP-3353.MB1C, Main Board Annunciator Response. The inspectors determined this finding was more than minor because it was associated with the Configuration 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. The inspectors performed an initial screening of the finding in accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations - Significance Determination Process, Checklist 3, PWR Cold Shutdown and Refueling Operation; RCS Open and Refueling Cavity Level < 23\' Or RCS Closed and No Inventory in Pressurizer; Time to Boiling < 2 hours, and determined that the finding was of very low safety significance (Green) because all of the shutdown safety function guidelines were met. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Dominion relied on the work control process to assure that the RPCCW cooling water was in service to the seal water heat exchanger at the time that the RCS vacuum fill was scheduled. Specifically, the work control process was insufficiently robust to ensure that cooling water was supplied to the seal water heat exchanger during charging pump operations (H.3(b)).
05000336/FIN-2010003-05	2010Q2	Millstone	Reactor Trip Caused by Loss of Positive Control of Steam Generator Level	A self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to correct a long-standing stability problem with control of the Unit 3 feedwater regulating bypass valves (FRBVs). Operation at low power conditions has resulted in excessive steam generator (SG) level oscillations while in automatic control and unintended equipment response when attempting to control SG level in manual control. The inadequate design of the SG level control system for low power operations was identified by numerous condition reports dating back to 2002, but had not been corrected. Dominion entered this issue into their corrective action program (CR381435, CR384014). The finding is more than minor because it was similar to NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, Example 4b, in that the failure to correct a condition adverse to quality resulted in a reactor trip. The inspectors determined that the finding was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, the long standing condition of the FRBVs\' inability to control SG level at low power operations led to an automatic reactor trip. The inspectors performed an initial screening of the finding in accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined the finding was of very low safety significance (Green) because it did not affect both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that the finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective action to address the longstanding adverse conditions associated with control of the FRBVs (P.1 (d)).
05000336/FIN-2010004-01	2010Q3	Millstone	Failure to Promptly Identify and Correct the Source of a Unit 2 RCS Pressure Boundary Leak	The inspectors identified a Green, NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for Dominion\'s failure to promptly identify and correct the source of a reactor coolant system (RCS) pressure boundary leak from July 3, 2009, through July 13, 2009. Dominion subsequently repaired the leak and returned to 100 percent power. The inspectors determined that Dominion\'s failure to promptly identify and correct the cause of pressure boundary leakage is a performance deficiency that was reasonably within Dominion\'s ability to foresee and correct and should have been prevented. This issue is more than minor because the issue is similar to NRC Inspection Manual Chapter (IMC) 0612, Appendix E, and minor example 2.g. The inspectors determined that the issue affected the Initiating Events 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. The inspectors concluded that this condition, assuming the worst case degradation, would not have affected other mitigating systems resulting in a total loss of their safety function. Accordingly, the finding was determined to be of very low safety significance (Green) using IMC 609, Attachment 0609.004, Phase 1 Screening Worksheet. The inspectors determined that this issue had a crosscutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not identify the pressure boundary leakage completely, accurately, and in a timely manner commensurate with its safety significance. (P.1 (a))
05000336/FIN-2010004-02	2010Q3	Millstone	Failure to Perform an ASME Code-compliant Radiographic Examination on a Class 1 Weld on the Unit 2 \'A\' RCP Seal Cooler Piping	The inspectors identified a Severity Level IV, NCV of 10 CFR 50.55a(2)( c)( 1) and 10 CFR 50.55a(3), when Dominion did not perform an ASME Code compliant radiographic examination for a leak in a Class 1 weld on the Unit 2 \'A\' RCP seal cooler piping before returning the system to service. Dominion was out of compliance with 10 CFR 50.55a(2)(c)(1), 10 CFR 50.55a(3), and Section III of the American Society of Mechanical Engineers (ASME) Code between July 24, 2009, and November 10,2009. The NRC granted verbal relief from the 10 CFR 50.55a(2)(c)(1), 10 CFR 50.55a(3), and the ASME Code requirements on November 10, 2009. Subsequently, the relief request was approved, in writing, by the NRC on April 26, 2010. In accordance with IMC 0612, Appendix B, Section 1-2, this finding had the potential to impact the NRC\'s ability to perform its regulatory function because Dominion verbally informed the NRC on July 17, 2009, that they would repair the affected component in accordance with ASME Code requirements. However, due to Dominion\'s misinterpretation of the ASME Code, Dominion did not subsequently inform the NRC of its inability to meet Code requirements (i.e. perform a Code compliant radiographic examination of the affected weld) before returning the plant to service. As a result, Dominion\'s actions had impeded the NRC\'s ability to evaluate and determine the efficacy of the licensee\'s actions. The issue was characterized as Severity Level IV because it is similar to the example provided in the NRC Enforcement Policy Section 6.1.d.2, in that, it involved a violation of NRC requirements that resulted in a condition evaluated as having very low safety significance (i.e., Green) by the Significance Determination Process (SDP). The inspector determined that this issue had a crosscutting aspect in the Human Performance cross-cutting area, Decision Making component, because Dominion did not use conservative assumptions in their decision making when they concluded that Code relief from the NRC would not be necessary to accomplish the repair. (H.1 (b))
05000336/FIN-2010004-03	2010Q3	Millstone	Failure to Implement Timely Corrective Actions for a Degraded Unit 2 FRV Results in Manual Reactor Trip	A self-revealing finding of very low safety significance (Green) was identified for Dominion\'s failure to implement timely corrective actions for a degraded Unit 2 feedwater regulating valve (FRV) in accordance with procedure PI-AA-200, Corrective Action. Specifically, two weeks after the issue was first identified, the #2 FRV further degraded causing Dominion to trip the reactor when the #2 steam generator (SG) level could not be adequately controlled. Dominion subsequently repaired the FRV and returned the plant to 100 percent power. The inspectors determined that Dominion\'s failure to implement timely corrective actions for a degraded #2 FRV in accordance with procedure PI-AA-200, Corrective Action, was a performance deficiency. This finding is more than minor because it was similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Example 4f, in that the failure to correct a condition adverse to quality led to a reactor trip. The finding was associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Dominion\'s failure to implement timely corrective actions for the #2 FRV caused the operators to manually trip the reactor when the #2 SG level could not be controlled. 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 take appropriate corrective action to address the degraded #2 FRV in a timely manner, commensurate with its safety significance. (P.1(d)).
05000336/FIN-2010004-04	2010Q3	Millstone	Licensee-Identified Violation	10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, 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 these instructions, procedures, or drawings. Contrary to this, Dominion had no documented procedure for bypassing undervoltage protection for the vital buses. As a result, on October 7, 2009, Dominion bypassed the undervoltage protection for the vital buses and rendered both EDGs inoperable for approximately seven hours. Upon discovery, Dominion restored the undervoltage protection and entered the issue into their corrective action program (CR351389). The finding is of very low safety significance because of the short duration of the inoperability, and because both EDGs could be manually started from the Control Room.
05000336/FIN-2010004-05	2010Q3	Millstone	Licensee-Identified Violation	TS 3.6.6.2 requires that if secondary containment is inoperable, it must be restored to operable status within 24 hours or the plant must be shutdown. Contrary to this, from May 13, 2010, until May 27, 2010, two sets of auxiliary building tunnel exhaust dampers were open, which rendered secondary containment inoperable. Upon discovery, Dominion immediately restored operability by closing one set of dampers and placed the issue into their corrective action program (CR382686). The finding is of very low safety significance because it only represented a degradation of the radiological barrier function for the auxiliary building.
05000336/FIN-2010004-06	2010Q3	Millstone	Licensee-Identified Violation	10 CFR 50 Appendix B, Criterion III, Design Control requires, in part, that measures shall be established to assure that the applicable design basis for structures, systems, and components, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this, from approximately 1995 until August 13, 2010, Dominion failed to ensure that the design basis for the reactor coolant system was maintained when it specified and installed flex hoses with an insufficient pressure rating. Upon discovery, Dominion entered the issue into their corrective action program (CR 390963), shutdown the plant, and replaced the hoses with flex hoses of the proper pressure rating. The finding is of very low safety significance because a failure of the hose would have resulted in a leak that was within the capability of the charging pumps.
05000336/FIN-2010004-07	2010Q3	Millstone	Licensee-Identified Violation	TS 3.7.1.2 LCO (c) requires the TDAFW pump to be operable in Mode 1. If the pump is not operable, Action Statement (c) directs restoration within 72 hours after which a plant shutdown to Mode 3 in six hours is required. Contrary to this requirement, on August 23, 2010, the TDAFW pump failed its quarterly surveillance test and a review of prior surveillance tests indicated that the pump had been inoperable since June 30, 2010 (a period of 54 days). Dominion had not properly evaluated the results of the previous surveillance test. During both of these tests, the TDAFW pump failed to produce an acceptable discharge flow rate because the charging pump discharge relief valve, 3FWA*RV45, leaked by its seat. Upon discovery, Dominion declared the TDAFW pump inoperable and promptly repaired the relief valve. Dominion entered the issue into their corrective action program (CR392003), and restored the TDAFW pump to an operable condition. The finding is of very low safety significance because the TDAFW pump was later determined to be available to support core heat removal during the period when the relief valve was degraded.
05000336/FIN-2010005-01	2010Q4	Millstone	Failure to Provide an Adequate Procedure for Backwashing Condenser Water Boxes	A self-revealing finding (FIN) of very low significance was identified for Dominion\'s failure to provide an adequate procedure for backwashing the Unit 2 condenser water boxes in accordance with procedure MP-05-MMM, Manuals, Procedures, Guidelines, Handbooks and Forms. Specifically, in implementing the procedure, the A circulating water (CW) pump automatically ramped down to zero speed shortly after securing the B CW pump. This resulted in a loss of condenser vacuum, which caused an automatic turbine trip. The turbine trip caused an automatic reactor trip. Dominion entered the issue into their corrective action program (CAP) and revised the operating procedure (OP) 2325D. The finding is more than minor because it was similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Example 4b, in that an inadequate procedure led to a reactor trip. The finding was associated with the Procedure Quality attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Dominion\'s failure to provide an adequate procedure for backwashing Unit 2 condenser water boxes resulted in the variable frequency drive (VFD) logic securing the only CW pump running in that condenser, and subsequently caused a reactor trip. 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, Resources component, because Dominion did not provide an accurate and up-tO-date procedure for the backwashing of the Unit 2 water boxes.
05000336/FIN-2010005-02	2010Q4	Millstone	Failure to Take Adequate Corrective Actions For a Broken Jacket Water Banjo Bolt on the 3 B EDG	The inspectors identified a Green, NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that, Dominion did not take adequate corrective action following the identification of a degraded condition. Specifically, maintenance personnel identified a broken jacket water fitting (banjo bolt) on the Unit 3, B emergency diesel generator (EDG), but a condition report (CR) was not initiated. Subsequently, an additional similarly degraded fitting resulted in extended unavailability on the Unit 3, B EDG. In response, Dominion entered the issue into the CAP and replaced the broken jacket water fitting. The finding is 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. The inspectors 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 (TS) allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not ensure that issues potentially impacting nuclear safety were promptly identified, fully evaluated, and that actions were taken to address safety issues in a timely manner, commensurate with their safety significance. Specifically, Dominion did not initiate a CR in September 2009 for a degraded condition on the safety-related Unit 3, B EDG.
05000336/FIN-2010005-03	2010Q4	Millstone	Licensee-Identified Violation	TS 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-2010006-01	2010Q1	Millstone	Broken Jacket Water Banjo Bolt Adversely Impacted EDG 3B Operability	An 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-2010006-02	2010Q1	Millstone	Licensee-Identified Violation	10 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-2010011-01	2010Q3	Millstone	Security
05000336/FIN-2011002-01	2011Q1	Millstone	Failure to Prevent Safety Related Cables from Being Submerged	A 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-2011002-02	2011Q1	Millstone	lmproper Restoration of Air Conditioning Equipment Following Maintenance Results in Inoperability of \'B\' Train of Recirculation Spray System	A 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-2011003-01	2011Q2	Millstone	Failure to Take Timely Corrective Actions for De-alloying of Aluminum Bronze Service Water Valves	The 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-2011003-02	2011Q2	Millstone	Untimely Corrective Action for Safety Related lnverters Leads to Repetitive Out of Calibration Results	The 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-2011003-03	2011Q2	Millstone	Inadequate Corrective Action Results in Loss of Enclosure Building\'s Safety Function	A 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-2011003-04	2011Q2	Millstone	Failure to Follow Procedure for Starting a Second SGFP Results in Reactor Trip	A 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-2011004-01	2011Q3	Millstone	Failure to Electrically Isolate Dissimilar Metal Flanged Joint Leads to Forced Shutdown Due to Service Water Leak	A 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-2011005-01	2011Q4	Millstone	Licensee-Identified Violation	Technical 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-2012003-01	2012Q2	Millstone	Inadequate Operability Determination for 3FWS*CTV41 Feedwater Isolation Valve Hydraulic Actuators	An 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, 3FWSCTV41A, 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 3FWSCTV41 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-2012003-02	2012Q2	Millstone	Licensee-Identified Violation	The 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.

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