IR 05000336/2009002
| ML091340064 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/14/2009 |
| From: | David Lew NRC/RGN-I/DRP/PB6 |
| To: | Christian D Dominion Resources |
| BELLAMY RR | |
| References | |
| EA-09-044, FOIA/PA-2011-0115 IR-09-002 | |
| Download: ML091340064 (38) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 May 14, 2009
Mr. David Christian
Sr. Vice President and Chief Nuclear Officer
Dominion Resources
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT: MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2009002 AND 05000423/2009002 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Christian:
On March 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Millstone Power Station Unit 2 and Unit 3. The enclosed inspection report documents
the inspection results, which were discussed on April 9, 2009, with Mr. A. J. Jordan and other
members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents one self-revealing finding of very low safety significance (Green).
Additionally, a licensee-identified violation determined to be of very low safety significance is
listed in the report. However, because of the very low safety significance and because it is
entered into your corrective action program, the NRC is treating the licensee identified violation
as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If
you contest any NCV in this report, you should pr ovide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Millstone.
In addition, the inspectors reviewed Licensee Event Report 50-423/2008-005, which described
the details associated with the failure to maintain 3FWS*V861, "C" steam generator (SG) drain
line isolation valve fully closed. This valve was relied on to meet technical specification (TS)
containment penetration requirements during fuel movement in the Unit 3 containment from
November 1-3, 2008. This was a violation of TS Section 3.9.4.c., which requires each
penetration providing direct access from the containment atmosphere to the environment be closed by an isolation valve, blind flange, or manual valve or be capable of being closed under administrative control during movement of fuel within the containment building. A risk
evaluation was performed and the issue was determined to be of very low safety significance.
Although this issue constitutes a violation of NRC requirements, the NRC determined that the
failure to completely close the valve was not within Dominion's ability to reasonably foresee and
correct, and as a result, the NRC did not identify a performance deficiency associated with this
condition. The NRC's assessment considered that the valve does not have position indication
to provide an alternate means to verify valve position, there were no past condition reports (CR)
documenting difficulty in closing the valve, the work order (WO) documenting "like for like" valve
replacement in 2007 did not indicate difficulty in operating the valve, and Dominion took
corrective action to close the valve and enter the issue into their corrective action process.
Based on the results of the NRC's inspection and assessment, I have been authorized, after
consultation with the Director, Office of Enforcement, and the Regional Administrator, to
exercise enforcement discretion in accordance with Section VII.B.6 of the Enforcement Policy
and refrain from issuing enforcement for this violation.
In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be
available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS).
ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA by James W. Clifford Acting For/
David C. Lew, Director
Division of Reactor Projects
Docket Nos. 50-336, 50-423 License Nos. DPR-65, NPF-49
Enclosure:
Inspection Report No. 05000336/2009002 and 05000423/2009002
w/Attachment:
Supplemental Information
cc w/encl: J. Price, Vice President, Engineering, Dominion Fleet
A. Jordan, Site Vice President, Millstone Station
C. Funderburk, Director, Nuclear Licensing and Operations Support
L. Morris, Plant Manager, Millstone Station
W. Bartron, Supervisor, Station Licensing
J. Spence, Manager Nuclear Training
L. Cuoco, Senior Counsel
C. Brinkman, Manager, Washington Nuclear Operations
J. Roy, Director of Operations, Massachus etts Municipal Wholesale Electric Company First Selectmen, Town of Waterford
B. Sheehan, Chair, NEAC
P. Rathbun, Vice-Chair, NEAC
E. Wilds, Jr., Ph.D, Director, State of Connecticut SLO Designee
SUMMARY OF FINDINGS
IR 05000336/2009-002, 05000423/2009-002; January 1, 2009 - March 31, 2009; Millstone
Power Station Unit 2 and Unit 3.
The report covered a three-month period of inspection by resident and region-based inspectors.
Two Green findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance
Determination Process." Findings for which the significance determination process (SDP) does not apply may be Green or be assigned a severity level after NRC management review. The
NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Initiating Events
- Green.
A self-revealing finding of very low safety significance (Green) was identified for Dominion's failure to control Unit 3 Steam Generator (SG) levels while operating at power. Specifically, Dominion's failure to control SG levels resulted in a reactor trip while reducing power for a plant shutdown. Dominion entered this issue into their corrective action program (CR113512), and corrective actions included conducting just-
in-time (JIT) training on low power feed station operation for licensed operators prior to reactor start up.
This finding is 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 is 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 Human Performance, Work Control, because Dominion did not coordinate work activi ties, consistent with nuclear safety, by incorporating actions to address the operational impact on control room personnel
[H.3.(b)]. (Section 4OA3.1).
B. Licensee-Identified Violations
One violation of very low safety significance, which was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Units 2 and 3 operated at or near 100 percent power throughout the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Seasonal Site Inspection
a. Inspection Scope
(1 Sample)
The inspectors reviewed Unit 3's readiness for seasonal cold weather. The inspectors
reviewed applicable procedures and performed walkdowns of the heat tracing, hot water
heating system, and space heaters to verify condition of the weather protection
equipment and determine if they were configured in accordance with Dominion
=s procedures. The inspectors reviewed the Unit 3 Updated Final Safety Analysis Report (UFSAR) and Technical Specifications (TS) and compared the analysis with procedure
requirements to ascertain that procedures were consistent with the UFSAR. The
inspectors performed partial walkdowns of the Unit 3 intake structures, service water (SW) systems, intake structure trav eling screens, and condensate surge and storage tanks to determine the adequacy of equipment protection from the effects of seasonal
cold weather. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 External Flooding Inspection
a. Inspection Scope
(1 Sample)
The inspectors evaluated Dominion's protection from the effects of external flooding
conditions at Units 2 and 3. The inspectors reviewed the Final Safety Analysis Report (FSAR) to identify the areas that could be affected by flooding. The inspectors reviewed
applicable procedures to verify that the actions required in the event of flooding could
reasonably be completed. The inspectors conducted a walkdown of the intake
structures and flood doors to determine if the structures were as described in the FSAR
and that the material condition of the structures and components was adequately
maintained. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
(4 Samples)
The inspectors performed four partial system walkdowns during this inspection period.
The inspectors reviewed the documents listed in the Attachment to determine the correct
system alignment. The inspectors conducted a walkdown of each system to determine if the critical portions of the selected systems were correctly aligned, in accordance with
the procedures, and to identify any discrepancies that may have had an effect on
operability. The walkdowns included selected switch and valve position checks, and
verification of electrical power to critical components. Finally, the inspectors evaluated
other elements, such as material condition, housekeeping, and component labeling.
The following systems were reviewed based on their risk significance for the given plant
configuration:
Unit 2
- Train "A" motor driven Auxiliary Feedwater (AFW);
- "B" Emergency Diesel Generator (EDG);
Unit 3
- Train "A" Service Water (SW); and
- "A" EDG.
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown
a. Inspection Scope
(1 Sample)
The inspectors completed a detailed review of the alignment and condition of the Unit 3
containment recirculation spray system. The inspectors conducted a walkdown of the
"B" train of the system to assess critic al equipment, such as breakers and valves, and were found in good condition and proper alignment in accordance with procedures.
The inspectors also conducted a review of outstanding maintenance work orders (WO)
to determine if any deficiencies could significantly affect system function. In addition, the
inspectors reviewed the system health reports and corrective action database to
determine whether equipment problems were being identified and appropriately
resolved. The inspectors also interview ed the system engineer. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Quarterly Fire Protection Walkdowns
a. Inspection Scope
(7 Samples)
The inspectors performed walkdowns of seven fire protection areas. The inspectors
reviewed Dominion's fire protection program to determine the required fire protection
design features, fire area boundaries, and combustible loading requirements for the
selected areas. The inspectors walked down these areas to assess Dominion's control
of transient combustible material and ignition sources. In addition, the inspectors
evaluated the material condition and operational status of fire detection and suppression
capabilities, fire barriers, and any related compensatory measures. The inspectors
compared the existing conditions of the areas to the fire protection program
requirements to determine if all program requirements were being met. Documents
reviewed during the inspection are listed in the Attachment. The fire protection areas
reviewed included:
Unit 2 * "A" and "B" EDG Cubicles 14'-6", Fire Areas A-15/A-16;
- Auxiliary Building Elevation -25'-6" Fire Area A1, Zones B, E, F;
- Intake Structure Fire Area I-1, Zones A, B, and C;
Unit 3
- Auxiliary Building East Floor Area Elevation 24'-6", Fire Area AB-1, Zone C;
- Auxiliary Building West Floor Area Elevation 24'-6", Fire Area AB-1, Zone D;
- Control Building West Switchgear Area, Elevation 4'-6", Fire Area CB-1; and
- Auxiliary Building East and West MCC and Rod Control, Elevation 24'-6", Fire Areas AB-5 and AB-6 Zone A.
b. Findings
No findings of significance were identified.
.2 Annual Fire Drill Observation
a. Inspection Scope
(1 Sample)
Unit 3 The inspectors observed personnel performance during an unannounced fire brigade
drill on March 16, 2009, to evaluate the readiness of station personnel to fight fires. The
drill simulated a fire in the Unit 3 generator exciter and bearing areas. The inspectors
observed the fire brigade members using protective clothing, turnout gear, self-contained
breathing apparatus and entering the fire area. The inspectors also observed the fire
fighting equipment brought to the fire scene to evaluate whether sufficient equipment
was available to effectively control and extinguish the simulated fire. The inspectors
evaluated whether the permanent plant fire hose lines were capable of reaching the fire
area and whether hose usage was adequately simulated. The inspectors observed the
fire fighting directions and communications between fire brigade members. The
inspectors observed the response of control room personnel during the drill. The inspectors also evaluated whether the pre-planned drill scenario was followed and observed the post drill critique to evaluate if the drill objectives were satisfied and that
any drill weaknesses were discussed.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
(1 Sample)
The inspectors reviewed the flood protection measures for equipment in the Unit 3
Recirculation Spray System (RSS) Rooms. The inspectors evaluated Dominion's
protection of safety-related systems from internal flooding conditions. The inspectors
performed a walkdown of the area, interviewed the system engineer, reviewed the
internal flooding evaluation, and verified that preventive maintenance was being
performed on critical flood protection detection equipment to ensure that equipment and
conditions remained consistent with those indicated in the design basis and flooding
evaluation documents. Documents reviewed during the inspection are listed in the
.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
a. Inspection Scope
(1 Sample)
The inspectors observed the as-found condition of the Unit 3 "B" EDG jacket water
cooler and engine air cooler water heat exchangers after they were opened to verify that
any adverse fouling concerns were appropriately addressed. The inspectors reviewed
the results of the inspections against the acceptance criteria contained within the
procedure to determine whether all acceptance criteria had been satisfied. The
inspectors also reviewed the UFSAR to ensure that heat exchanger inspection results
were consistent with the design basis. Documents reviewed during the inspection are
listed in the Attachment.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review
a. Inspection Scope
(2 Samples)
The inspectors observed simulator-based licensed operator requalification training for
Unit 2 on January 21, 2009, and for Unit 3 on January 27, 2009. The inspectors
evaluated crew performance in the areas of clarity and formality of communications, ability to take timely actions, prioritization, interpretation and verification of alarms, procedure use, control board manipulations, oversight and direction from supervisors, and command and control. Crew performance in these areas was compared to
Dominion management expectations and guidelines as presented in OP-MP-100-1000, A Millstone Operations Guidance and Reference Document.
@ The inspectors compared simulator configurations with actual control board configurations. The inspectors also observed Dominion evaluators discuss identified weaknesses with the crew and/or
individual crew members, as appropriate. Documents reviewed during the inspection
are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
(5 Samples)
The inspectors reviewed five samples of Dominion's evaluation of degraded conditions, involving safety-related structures, systems and/or components for maintenance
effectiveness during this inspection period. The inspectors reviewed Dominion's
implementation of the Maintenance Rule. The inspectors reviewed Dominion
=s ability to identify and address common cause failures, the applicable maintenance rule scoping document for each system, the current classi fication of these systems in accordance with 10 CFR 50.65 (a)(1) or (a)(2), and the adequacy of the performance criteria and
goals established for each system, as appropriate. The inspectors also reviewed recent
system health reports, Condition Reports (CR), apparent cause determinations, functional failure determinations, operating logs, and discussed system performance
with the responsible system engineer. Documents reviewed during the inspection are
listed in the Attachment. The specific systems/components reviewed were:
Unit 2
- EDG, "B";
- Pressurizer Heaters;
Unit 3
- Normal Power NSST/RSST; and
- Engineered Safety Feature (ESF) Load Sequencer.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
(7 Samples)
The inspectors evaluated online risk management for emergent and planned activities.
The inspectors reviewed maintenance risk evaluations, work schedules, and control
room logs to determine if concurrent planned and emergent maintenance or surveillance
activities adversely affected the plant risk already incurred with out of service (OOS)
components. The inspectors evaluated whether Dominion took the necessary steps to
control work activities, minimize the probability of initiating events, and maintain the
functional capability of mitigating systems. The inspectors assessed Dominion
=s risk management actions during plant walkdowns. Documents reviewed during the inspection are listed in the Attachment. The inspectors reviewed the conduct and
adequacy of risk assessments for the following maintenance and testing activities:
Unit 2
- January 9, 2009, Yellow risk due to "B" EDG, "B" High Pressure Safety Injection (HPSI) OOS, and high trip risk due to environmental factors;
- February 16, 2009, Green risk with a high trip risk due to Reactor Protection System (RPS) matrix logic and trip path relay te st, the turbine-driven auxiliary feedwater (TDAFW) pump was OOS due to emergent work on 2MS-440 (main steam
instrument isolation valve to PI-4191);
- February 18, 2009, Green risk with a high trip risk due to switchyard work, the "A" essential switchgear OOS, the station air compressor OOS and the "F" air compressor OOS;
- March 26, 2009, Yellow risk due to North Bus Outage high grid risk; Unit 3
- February 25, 2009, Green Risk impacting "A" Quench Spray System (QSS), Safety Injection (SI), and Residual Heat Removal (RHR) pumps due to maintenance on the
room air conditioning (AC) unit, ACUS1A;
- February 27, 2009 Emergent repair of 3CHS*CV8152, outboard letdown isolation valve; and
- March 17 - 20, 2009, failure of normal level control valve 3HDL-LV37B1, resulting in a trip of the "B" heater drain pump and subsequent down power to 90 percent power.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
(6 Samples)
The inspectors reviewed operability determinations (OD). The inspectors evaluated the
ODs against the guidance contained in NRC Inspection Manual Part 9900, Technical
Guidance, "Operability Determinations & Functionality Assessments for Resolution of
Degraded or Nonconforming Conditions Adverse to Quality or Safety." The inspectors also discussed the conditions with operators and system and design engineers, as necessary. Documents reviewed during the inspection are listed in the Attachment. The
inspectors reviewed the adequacy of the following evaluations of degraded or
non-conforming conditions:
Unit 2
- OD 000253 Revision 1, pressurizer proportional heater failure and similar pressurizer back-up heater failures;
- CR324869, Refueling Water Storage Tank (RWST) cross-tied to non-safety related equipment;
- CR326558, Floor Drain Covered in the East End of the "A" EDG Room;
Unit 3
- OD 000247 Rev. 0, 3SIH*V028 was replaced and field weld 43 (FW-43) did not have required Non-Destructive Examination (NDE) performed;
- OD 000248 Rev. 0, Air volume in "B" SIH discharge piping; and
- CR319295, Past operability determination of "B" SIH discharge line.
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
a. Inspection Scope
(4 Samples)
To assess the adequacy of the modifications, the inspectors performed walk downs of
selected plant systems and components, interviewed plant staff, and reviewed
applicable documents, including procedures, calculations, modification packages, engineering evaluations, drawings, correctiv e action program documents, the UFSAR, and TS. For the modifications reviewed, the inspectors determined whether selected
attributes (component safety classification, energy requirements supplied by supporting systems, seismic qualification, instrument set points, uncertainty calculations, electrical coordination, electrical loads analysis, and equipment environmental qualification) were
consistent with the design and licensing bases. Design assumptions were reviewed to
verify that they were technically appropriate and consistent with the UFSAR. For each
modification, the 10 CFR 50.59 screenings or safety evaluations were reviewed, as
described in Section 1R02 of this report. The inspectors also verified that procedures, calculations, and the UFSAR were properly updated with revised design information.
In
addition, the inspectors verified that the as-built configuration was accurately reflected in
the design documentation and that post-modification testing was adequate to ensure the
structures, systems, and components would function properly. A listing of documents reviewed is provided in the Attachment. The following modifications were reviewed:
- (1) Unit 2 permanent modification, Removal of "A" and "B" Diesel Generator Service Water Inlet Strainer.
- (2) Unit 2 temporary modification, re-termination of the power supply of two pressurizer heaters from the back-up electrical supply to the safety related power supply (L106), done to restore the proportional pressurizer heater banks to full capacity
following the failure of two heaters.
- (3) Unit 2 temporary modification, temporary leak encapsulation of body to bonnet leak at M22-CN-543, "B" SG feed pump suction vent
- (4) Unit 3 temporary modification for Supplemental Heating of the Feedwater Isolation Valve Room was reviewed.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
(7 Samples)
The inspectors reviewed seven post-maintenance test (PMT) activities to determine
whether the PMT adequately demonstrated that the safety-related function of the
equipment was satisfied, given the scope of the work specified, and that operability of
the system was restored. In addition, the inspectors evaluated the applicable test
acceptance criteria to evaluate consistency with the associated design and licensing
bases, as well as TS requirements. The inspectors also evaluated whether conditions
adverse to quality were entered into the corrective action program for resolution.
Documents reviewed during the inspection are listed in the Attachment. The following
maintenance activities and PMTs were evaluated:
Unit 2 * "A" Emergency Building Filtration System filter replacement on January 30, 2009;
- Encapsulation of the steam leak on 2-CN-543 condensate vent connection isolation valve on March 6, 2009;
Unit 3
- Control Building AC Booster Pump 3SWP*P2A motor replacement on January 24, 2009; * "A" SG Feed Line Isolation Valve 3FWS*CTV41A air line repair on February 3, 2009;
- T/Tavg Channel 4 Calibration on February 6, 2009, following repairs due to channel failure;
- Stepdown transformer replacement for 120V vital AC bus 3 on February 26, 2009; and
- Station Black Out (SBO) Diesel maintenance on 3/5/09.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
(8 Samples)
The inspectors reviewed eight surveillance activities to determine whether the testing
adequately demonstrated equipment operational readiness and the ability to perform the
intended safety-related function. The inspectors attended pre-job briefings, reviewed
selected prerequisites and precautions to determine if they were met, and observed the
tests to determine whether they were performed in accordance with the procedural
steps. Additionally, the inspectors reviewed the applicable test acceptance criteria to
evaluate consistency with associated design bases, licensing bases, and TS
requirements and that the applicable acceptance criteria were satisfied. The inspectors
also evaluated whether conditions adverse to quality were entered into the corrective
action program for resolution. Documents reviewed during the inspection are listed in
the Attachment. The following surveillance activities were evaluated:
Unit 2
Revision 000-02 on February 2, 2009;
- SP 2605G-008 and SP 2605G-012, "SG Blowdown and Sample Containment Isolation Valve (CIV) Stroke and Timing In Service Testing (IST), Facilities 1 & 2,"
Revision 000-04;
Unit 3
- SP 3616A.1-016, "Local Operation Test of 3MSS*MOV74A & 3MSS*MOV74C," Rev.
000-03 on January 15, 2009;
- SP 3712B-001, "Pressurizer Heater Capacity Surveillance Testing," Rev. 006-03 on January 28, 2009;
- SP 3712NC-001, "Vital Battery Charger Surveillance Load Testing," Rev. 007-01 on January 28, 2009;
- SP 3680.1-003, "Containment Leakage Trending," Rev. 002-01 (Reactor Coolant System (RCS) leakage detection) on February 17, 2009; and
- SP 31002, "Plant Calorimetric," Rev. 010-10 on March 12, 2009.
b. Findings
No findings of significance were identified.
Cornerstone:
1EP6 Drill Evaluation
.1 Classification and Notification During Requalification Training
a. Inspection Scope
(1 Sample)
The inspectors reviewed the operator's emergency classification and notification
completed during Unit 3 requalification training on January 27, 2009. The inspectors
verified the classification and notification were accurate and timely.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone:
Occupational Radiation Safety 2OS1 Access to Radiological Significant Areas (71121.01)
a. Inspection Scope
(10 Samples)
During the period February 23 - 26, 2009, the inspectors conducted the following
activities to verify that the licensee was pr operly implementing physi cal, administrative, and engineering controls for access to locked high radiation areas (LHRA), and other
radiological controlled areas (RCA) during normal power operations, and that workers
were adhering to these controls when working in these areas. Implementation of these
controls was reviewed against the criteria contained in 10 CFR 20, relevant to Millstone
Unit 2 and Unit 3 TS and the licensee's procedures.
This activity represents the completion of 10 samples relative to this inspection area, which partially completes the annual inspection requirement of twenty one.
Plant Walkdown and Radiation Work Permit (RWP) Reviews
- (1) The inspectors toured accessible RCAs in Unit 2 and Unit 3, and with the assistance of a radiation protection technician, performed independent radiation
surveys of selected areas and components, to confirm the accuracy of survey data, and the adequacy of postings. Plant areas inspected included the Auxiliary
Buildings, Waste Buildings, and Fuel Storage Buildings.
- (2) The inspectors identified plant areas where radiological significant work activities were being performed. These activities included making preparations for a Unit 3
spent resin transfer and preparing for transferring high activity Tri-Nuke filters to
a shipping container from the Unit 3 spent fuel pool. The inspectors reviewed the
applicable RWPs and job history files for these activities, to determine if the
radiological controls were acceptable, discussed the status of preparations with
the Unit 3 Radiation Protection Supervisor, and reviewed the electronic
dosimeter dose/dose rate alarm set points to determine if the set points were
consistent with plant policy.
- (3) The inspectors determined that there were no current RWPs for airborne radioactivity areas with the potential for individual worker internal exposures to
exceed 50 mrem. The inspectors reviewed the daily quality control checks performed on various airborne counting instruments (SAC-4, BC-4) to confirm that the instruments were operational.
- (4) The inspectors determined that during 2008, there were no internal dose assessments for any actual internal exposures that reached the reporting
threshold of greater than 10 mrem Committed Effective Dose Equivalent (CEDE).
The inspectors also reviewed data for the five highest exposed individuals for
2008, the dose/dose rate alarm reports, related CRs, and determined that no
exposure exceeded site administrative, regulatory, or performance indicator criteria. Additionally, the inspectors confirmed that no declared pregnant workers
were employed during 2008.
Problem Identification and Resolution
- (5) A review of Nuclear Oversight assessment reports and field observation reports were conducted to determine if dose significant jobs were routinely monitored, radiological protection programs were effectively evaluated, and problems related
to implementing radiological controls were entered into the corrective action
program for resolution.
- (6) CRs associated with radiation protection control access that were initiated between October 2008 and February 2009, were reviewed and discussed with
the licensee staff to determine if the follow-up activities were being conducted in
an effective and timely manner, commensurate with their safety significance.
High Radiation Area and Very High Radiation Area Controls
- (7) Procedures for controlling access to High Radiation Areas (HRA) and Very High Radiation Areas (VHRA) were reviewed to determine if the administrative and
physical controls were adequate. The inspectors determined that a recently
implemented corporate procedure (RP-AA-201, Access Controls for High and
Very High Radiation Areas), provided additional controls over the replaced site
procedure RPM 5.1.3, that was previously implemented. The inspectors also
evaluated access controls for VHRA areas in Unit 3, by reviewing procedure OP
3361A, "Personnel Access Control to the MID System Components Inside
Containment," and interviewing control room personnel.
- (8) Keys to VHRAs stored in the Unit 3 Control Room were inventoried and accessible. LHRAs were verified to be properly secured and posted during plant
tours. Radiation Worker and Radiation Protection Technician Performance
- (9) Several radiological related CRs were reviewed to evaluate if the incidents resulted from repetitive worker errors and to determine if an observable pattern
traceable to a similar cause was evident.
- (10) The inspectors attended daily Unit 3 Radiation Protection department planning meetings to assess the timeliness of information and level of detail provided to
technicians for ongoing tasks. Radiation Protection Technicians and radworkers were questioned regarding their knowledge of plant radiological conditions and associated controls.
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls (71121.02)
a. Inspection Scope
(8 Samples)
During the period February 23 - 26, 2009, the inspectors verified that the licensee was
properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as is reasonably achievable (ALARA) for past activities performed during 2008. Also reviewed were dose controls for current activities and
preparations for the Unit 2 fall (2R19) 2009 refueling outage. Implementation of these
controls was reviewed against the criteria contained in 10 CFR 20, applicable industry
standards, and the licensee's procedures.
Radiological Work Planning
- (1) The inspectors reviewed pertinent information regarding cumulative exposure history, current exposure trends, and ongoing activities to assess past 2008
performance and dose challenges for 2009, including the Unit 2 fall refueling
outage (2R19).
- (2) The inspectors reviewed the exposure data for tasks performed during 2008 and compared actual exposure with forecasted estimates. Included in this review
were the tasks performed during the Unit 3 (3R12) refueling outage, on-line tasks
performed for both operating units, and Unit 2 dry cask loading/storage
operations.
- (3) The inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing
ALARA program elements and interface problems. The evaluation was
accomplished by reviewing recent ALARA Council meeting minutes, ALARA
Evaluations, departmental dose summaries, attending an ALARA Council
meeting, and interviewing the ALARA coordinator.
The inspectors also reviewed the Radiation Protection Department Continuous
Improvement Initiatives and the 5-year ALARA Plan (2007-2011) that identifies
areas for further improving radiological controls.
Verification of Dose Estimates
- (4) The inspectors reviewed the assumptions and basis for the annual 2008 site collective exposure projections for routine power operations and maintenance
activities, and compared the estimated dose with the actual dose received by
workers. The inspectors also reviewed the dose projections for the upcoming
2R19 refueling outage to determine the exposure challenges and preparations
being made for dose significant activities; e.g. thimble tube replacements.
- (5) The inspectors reviewed the licensee's procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for
tasks differed from the actual dose received. The inspectors reviewed the
dose/dose rate alarm reports and exposure data for selected individuals
receiving the highest total effective dose equivalent (TEDE) exposures for 2008
to confirm that no individual exposure exceeded the regulatory limit, or met the
performance indicator reporting guideline.
Jobs-In-Progress
- (6) The inspectors reviewed the RWPs, associated ALARA Evaluations (AE) and observed various preparations for jobs-in-progress performed at Unit 3, including
transferring spent resin to a shipping cask (RWP3-09-17/AE3-09-02), and
transferring spent Tri-Nuke mechanical filters to a waste disposal container (RWP 3-09-42/AE3-09-10).
- (7) The inspectors reviewed recent AEs developed for controlling low dose tasks.
These AEs addressed various Unit 2 maintenance tasks including cleaning tanks
T-20A/B (AE2-09-01), removal of fuel sipping equipment (AE2-09-09), RWST
header vent testing (AE2-09-02), and a Unit 3 containment entry at power to
perform a test on valve 3SIH-V028 (AE3-09-01).
Problem Identification and Resolution
- (8) The inspectors reviewed elements of the licensee's corrective action program related to implementing the ALARA program to determine if problems were being
entered into the program for timely resolution. CRs related to controlling
individual personnel exposure and programmatic ALARA challenges were
reviewed.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
[OA]
4OA1 Performance Indicator (PI) Verification
.1 Cornerstone: Initiating Events
a. Inspection Scope
(2 Samples)
The inspectors reviewed Dominion submittals for the PIs listed below to verify the
accuracy of the data reported during that period. The PI definitions and guidance
contained in Nuclear Energy Institute (NEI) 99-02, A Regulatory Assessment Indicator Guideline,@ Revision 5, were used to verify the basis for reporting each data element.
The inspectors reviewed portions of the operations logs, monthly operating reports, and Licensee Event Reports (LER) and discussed the methods for compiling and reporting
the PIs with cognizant licensing and engineering personnel. Documents reviewed during
the inspection are listed in the Attachment.
Unit 3
- RCS Leak Rate from January 1, 2008 to December 31, 2008; and
- RCS Specific Activity from January 1, 2008 to December 31, 2008.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"
and in order to help identify repetitive equipment failures or specific human performance
issues for follow-up, the inspectors performed a daily screening of items entered into
Dominion's corrective action program. This was accomplished by reviewing the
description of each new CR and attending daily management review committee
meetings. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Annual Sample
Review of Corrective Actions Related to Simulator Testing and Fidelity
a. Inspection Scope
(1 Sample)
The inspectors performed a focused review of the actions taken and planned in
response to CR-108371 (Documentation of Simulator Testing Not Complete). The
review included a sample of simulator tests that occurred during the period of time from
2006 to 2009 on both units. The inspectors reviewed root cause evaluations, associated
CRs, corrective actions taken, technical evaluations, and planned corrective actions.
The inspectors also interviewed personnel and conducted a walkdown of the Unit 2 and
Unit 3 simulators. Documents reviewed during the inspection are listed in the
.
b. Findings and Observations
No findings of significance were identified.
There were some significant deviations between the Unit 2 and Unit 3 core neutronics
model and the reference plants. The licensee is currently taking credit for initial
licensing reactivity manipulations in the simulator.
The Unit 2 and Unit 3 simulator control banks at 100% power (Unit 2 control bank 7, Unit
3 control bank "D") differential rod worth coefficients were significantly less than the
reference plant values in the upper half of the core. These values did not meet the
requirements of ANS/ANSI-3.5-1998 section 4.1.3.2(1) for normal evolutions. This deviation caused the simulator core temperature response to be less than the reference plant during a rapid downpower maneuver.
This deviation could potentially affect operator response during a rapid plant downpower. This deviation was first identified in
2006 and again in 2008 during Licensed Operator Requalification Inspections. The
corrective action specified was to conduct a training needs assessment. The needs
assessment had not yet been completed as of this inspection cycle. In addition, on Unit
3, control bank "C" integral rod worth was 52% higher, and shutdown bank "A" integral
rod worth was 23% higher than the reference plant. These deviations from ANS/ANSI
3.5-1998 were also documented but were neither corrected nor properly addressed in
the training program.
The Unit 2 simulator normal annual startup test had not been completed for refueling
cycle 2R18. This test was later accomplished for 2R19. Simulator core performance
tests had been completed for the beginning of cycle (BOC) conditions but not for middle
of cycle (MOC) or end of cycle (EOC) conditions for 2R19. When taking credit for
operator licensing reactivity manipulations in the simulator, the core performance fidelity
should be verified for the same or similar conditions under which the manipulations are
being credited.
The Unit 2 simulator response for 4160 VAC breaker closure when synchronizing
between two power sources did not closely match the reference plant response. For
example, while conducting an NRC Job Performance Measure (JPM) in the simulator (paralleling the Unit 2 RSST to the "A" EDG per EOP-2541 "Restoring Electrical Power" 23-H step 9), the operator was required to close breaker A302. Breaker
A302 would not close in the simulator until after the sychroscope pointer was aligned at
the 12:00 position. The procedure explicitly requires the operator to close the breaker
when the sychroscope pointer passes the 11:00 position. If the operator performs the
procedure as written, and releases the breaker prior to reaching the 12:00 position (because the pointer is moving slowly), the breaker will not close. The breaker in the
reference plant will close between the 11:00 and 1:00 positions during the time when the
check relay is activated. The same deviation was identified during previous initial
license training (ILT) and licensed operator requalification training (LORT) exams. The
problem had been the subject of a simulator Discrepancy Report (DR) after the 2005
Unit 2 initial licensing exam but the DR was closed without taking any corrective action
or conducting a training needs assessment.
.3 Annual Sample
Unit 3 Radiation Monitors
a. Inspection Scope
(1 Sample)
The inspectors performed a focused review of the Unit 3 radiation monitors in response
to a number of issues associated with the monitors. The review included equipment
issues from 2007 to 2009. The inspectors interviewed the system engineer, reviewed
system health reports, CRs, associated maintenance rule evaluations and apparent
cause evaluations, the (a)(1) action plan for RE16B, and planned corrective actions.
Documents reviewed during the inspection are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
The inspectors identified that failures of maintenance rule performance criteria 105b for radiation monitors that are used to detect a SG tube event were not being tracked.
Specifically, there had been two failures in a 24 month period (criteria is less than four),
neither of which had been recorded. The inspectors also identified that unavailability
hours for performance criteria 1.07 had not been adequately tracked. Specifically, the
system engineer knew that even though the unav ailability hours associated with the loss of both PDP computers did not exceed the performance criteria, the engineer had not
recorded the hours.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (Closed) LER 05000423/2008002-00, Failure of Four Main Steam Safety Valves to Lift
Within the Acceptance Criteria On October 9 and 10, 2008, with the plant at 100% power, four main steam safety
valves failed to lift within the acceptance criteria (+/-3%) of TS 3.7.1.1. Dominion
attributed the failures to corrosive oxide locking action between surface layer materials
of the disk-seat interface, referred to as "oxide locking". After testing, the safety valves
were adjusted within +/-1% of the TS acceptance criteria. Dominion entered this issue
into their corrective action process CR113238. The inspectors reviewed this LER and
associated CRs. No findings were identified. This failure to comply with TS 3.7.1.1
constitutes a violation of minor significance that is not subject to enforcement action in
accordance with the NRC's Enforcement Policy. This LER is closed.
.2 (Closed) LER 05000423/2008005-00, Containment Penetration Not Fully Closed During
Fuel Movement On November 5, 2008, with the plant in Mode 6, operators discovered that 3FWS*V861, "C" SG drain line isolation valve, which was relied on to meet TS containment
penetration requirements during fuel movement in containment, was not fully closed. TS 3.9.4.c requires that each penetration providing direct access from the containment
atmosphere to the environment be closed by an isolation valve, blind flange, or manual valve or be capable of being closed under administrative control during movement of fuel
within the containment building. Dominion's investigation subsequently determined that
the valve had been in this condition during fuel movements inside containment from
0430 on November 1, 2008 until 0915 on November 3, 2008. Operators identified that
the valve was leaking while filling the "C" SG on November 5, 2008. They attempted to
close the valve and were not successful until mechanical leverage was applied.
The inspectors reviewed the LER and Dominion's apparent cause evaluation of the
event. The inspectors determined that the failure to completely close valve 3FWS*V861
was not within Dominion's ability to foresee and correct and was not a performance
deficiency. Valve 3FWS*V861 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 Dominion's 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).
Dominion's 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. This LER is closed.
.3 (Closed) LER 05000423/2008003-00, Automatic Reactor Trip During Shutdown for
Refueling Outage 3R12 On October 11, 2008, Unit 3 received an automatic reactor trip at approximately 30%
power, while the unit was reducing power in preparation for a refueling outage. The
control room operators were in manual control of the feedwater system. The plant was
experiencing SG level oscillations as a resu lt of removing feedwater system components from service. Oscillations increased and the "A" SG reached its high-high setpoint, resulting in an automatic turbine trip and feedwater isolation. "C" and "D" SG levels
shrank to their low-low level setpoint which caused an automatic reactor trip.
The inspectors witnessed Unit 3's reactor trip and observed plant response and operator
actions in order to evaluate the performance of the mitigating systems and the control
room operators. The inspectors also reviewed the post trip review report and root cause
evaluation. Documents reviewed during the inspection are listed in the Attachment.
Introduction
- A self-revealing finding of very low safety significance (Green) was identified for Dominion's failure to control Unit 3 SG levels while operating at power.
Specifically, Dominion's failure to control SG levels resulted in a reactor trip while
reducing power in preparation for a plant shutdown.
Description
- On October 11, 2008, Millstone Unit 3 was reducing power in preparation for its 12 th refueling outage. An operator was stationed at main board 5 to remove the "A" Turbine Driven Feedwater Pump (TDFWP) from service when power was less than
50%. The operator remained in place and responded to numerous SG level oscillations.
TDFWP speed was raised out of the normal range to increase differential pressure (DP)
across the feedwater regulating valves (FRVs) because the operator believed this would
assist in controlling the level oscillations.
Another operator noticed the high DP and brought it to the attention of the unit
supervisor. The unit supervisor stationed this operator at the feed station to restore feed
to steam DP to normal. The operator lowered feed pump speed which caused the FRVs
to open in order to maintain the same flow. As the FRVs opened, feed header pressure
dropped and the operator increased feed pump speed to recover DP. This sent a large
amount of relatively cold water to the SGs before the FRVs could be closed. As the
water in the SGs expanded due to heating, levels in the "A" and "B" SGs reached the
high-high setpoint. This caused a turbine trip and feedwater isolation. "C" and "D" SGs
shrank to the low-low level setpoint, resulting in an automatic reactor trip.
Dominion's root cause evaluation determined that the organization, with respect to monitoring and measuring crew performance, was not effective in implementing programs designed to manage challenges to the operators during a plant shutdown.
While the organization was aware of the challenges in manually operating the feed
station, it did not identify the need to improve the feed station's overall performance via
the corrective action process. Additionally, a decrease in proficiency in manual feed
station operation at low power levels was not identified, lower power feed station
operation was not covered in JIT training, and the feed station operator had not received
JIT training. The root cause evaluation also determined that inadequate rigor for outage
preparation expectations resulted in Operations being challenged prior to and during the
shutdown. Also, the control room operators were distracted by numerous tagging-
related shutdown activities during the shutdown.
Analysis:
The inspectors determined that Dominion's failure to maintain control of Unit 3 SG levels was a performance deficiency. Specifically, the failure to control SG levels
resulted in a reactor trip while reducing power in preparation for a plant shutdown.
Traditional enforcement does not apply because there were no actual safety
consequences, impacts on the NRC's ability to perform its regulatory function, or willful
aspects of the finding.
This finding is 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. Specifically, Dominion's failure to control SG
levels resulted in an automatic reactor trip while reducing power in preparation for a
plant shutdown. The inspectors conducted a Phase 1 screening, in accordance with
IMC 0609, "Significance Determination Process," and determined that the finding is 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
Human Performance, Work Control, because Dominion did not coordinate work
activities, consistent with nuclear safety, by incorporating actions to address the
operational impact on control room personnel [H.3.(b)].
Enforcement
- No violation of regulatory requirements occurred, because the main feed pumps, feed regulating and bypass valves, and SG level control system are not safety-related. Because this finding does not involve a violation of regulatory requirements and
has very low safety significance, it is identified as a finding. Dominion entered this issue
into their corrective action program (CR113512) and corrective actions included
conducting training in low power feed station operation for licensed operators prior to reactor start up. (FIN 05000423/2009002-01, Failure to Control Steam Generator Water Levels Results in Automatic Reactor Trip)
.4 (Closed) LER 05000423/2008006-00, Turbine-Driven Auxiliary Feedwater Pump Steam
Trap Isolation Valves Found Closed On November 24, 2008, Dominion determined that at 0025, with the plant at 18% power, Unit 3 control room operators identified that the TDAFW pump steam trap isolation
valves were closed. The TDAFW pump was declared inoperable and Technical Specification Action Statement (TSAS) 3.7.1.2.c was entered. The valves were promptly opened, steam traps blown down, the TDAFW pump restored to operable status and the
TSAS exited at 0346. Dominion's investigation determined that the valves were
inoperable since November 22, 2008 at 1746, a total of 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />. During this 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />
period, the unit went through two mode changes (Mode 3 to Mode 1). This licensee-
identified finding is a violation of TS 3.0.4 which in part requires that the TDAFW pump
be operable prior to changing operational modes. The enforcement aspects of this
finding are discussed in Section 4OA7. This LER is closed.
4OA5 Other Activities
.1 World Association of Nuclear Operators (WANO) Peer Review Report.
a. Inspection Scope
(1 Sample)
The inspectors reviewed the report for the WANO plant assessment of Millstone Nuclear
Generating Station conducted June 2008. The inspectors reviewed the report to ensure
that issues identified were consistent with the NRC perspectives of Millstone
performance and to verify that the WANO team did not identify any safety significant issues requiring further NRC follow-up.
b. Findings
No findings of significance were identified.
4OA6 Meetings, including Exit
Exit Meeting Summary
On April 9, 2009, the resident inspectors presented the overall inspection results to Mr.
A. J. Jordan, and members of his staff. The inspectors confirmed that no proprietary
information was provided or examined during the inspection.
4OA7 Licensee Identified Violations
The following violation of very low safety significance (Green) or Severity Level IV was
identified by the licensee and is a violation of NRC requirements which meets the criteria
of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation (NCV).
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 findi ng 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.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
G. Auria Nuclear Chemistry Supervisor
- B. Bartron Supervisor, Licensing
- P. Baumann Manager, Security
- C. Chapin Supervisor, Nuclear Shift Operations Unit 2
T. Cleary Licensing Engineer
G. Closius Licensing Engineer
- L. Crone Supervisor, Nuclear Chemistry
J. Dorosky Health Physicist III
- M. Finnegan Supervisor, Health Physics, ISFSI
- R. Griffin Director, Nuclear Station Safety & Licensing
- W. Gorman Supervisor, Instrumentation & Control
J. Grogan Assistant Operations Manager
C. Houska I&C Technician
A. Jordan Site Vice President
- J. Kunze Supervisor, Nuclear Operations Support
- B. Krauth Licensing, Nuclear Technology Specialist
- J. Laine Manager, Radiation Protection/Chemistry
- B. Barron Manager, Nuclear Oversight
- R. MacManus Director, Engineering
- M. O'Connor Manager, Engineering
L. Morris Plant Manager
M. Roche Senior Nuclear Chemistry Technician
- J. Semancik Manager, Operations
A. Smith Asset Management
- S. Smith Supervisor, Nuclear Shift Operations Unit 3
- J. Spence Manager, Training
- S. Turowski Supervisor, Health Physics Technical Services
- C. Vournazos IT Specialist, Meteorological Data
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
Closed
- 05000423/LER-2008-002-00 LER Failure of Four Main Steam Safety Valves to Lift Within the
- Acceptance Criteria (Section 4OA3).
- 05000423/LER-2008-003-00 LER Automatic Reactor Trip During Shutdown for Refueling
- Attachment
- Outage 3R12 (Section 4OA3).
- 05000423/LER-2008-005-00 LER Containment Penetration Not Fully Closed During Fuel
- Movement (Section 4OA3).
- 05000423/LER-2008-006-00 LER Turbine-Driven Auxiliary Feedwater Pump Steam Trap
- Isolation Valves Found Closed (Section 4OA3).
- BASELINE INSPECTION PROCEDURE PERFORMED
- 71121.01 Access Controls to Radiological Significant Areas 2OS1
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
- AOP 2560,"Storms, High Winds and High Tides," Rev. 010-04
- AOP 3569, "Severe Weather Conditions'" Rev. 016-00
- C
- OP 200.13, "Cold Weather Preparations," Rev. 002-02
- DM2-00-0389-06, "Modification to MP2 EDG Security Gate and Flood Door Sill Installation"
- MP 2721C, "Protection and Restoration of Service Water Pump Motor During a PMH," Rev.
- 007-02
- OP 3314G, "Intake Structure Ventilation," Rev. 009-06
- OP 3331B, "Plant Heating," Rev. 011-04
- OP 3352, "Heat Tracing," Rev. 013-03
- SP 2665, "Building Flood Gate Inspections," Rev. 005-05
- 2341A - Fire Doors and Barriers System Health Report 4
th Quarter 2008
- M2 07 03237
- CR121295
- CR318618
- CR318654
- CR326339
Section 1R04: Equipment Alignment
- OP 3322, "Auxiliary Feedwater Train A," Revision 006
- DWG No. 25212-26390 sheet 2
- OP 3326-01, "Train A Service Water System," Rev. 009-03
- OP 3326-02, "Train B Service Water System," Rev. 009-03
- OP 3326-03, "RPCCW A Service Water System Supply," Rev. 004-01
- OP 3326-09, "Service Water System - Control Building Air Cond "A" Supply," Rev. 007
- OP 3326-18, "MCC and Rod Control Area A/C A Service Water System Supply," Rev. 007-01
- OP 3326-23, "Service Water Electrical Checklist," Rev. 007-03
- OP 3346A-001, "EDG A - Cooling Water Valve Lineup," Rev. 007
- OP 3346A-002, "EDG B - Cooling Water Valve Lineup," Rev. 007
- OP 3346A-005, "EDG A - Starting Air Valve Lineup," Rev. 008-02
- OP 3346A-006, "EDG B - Starting Air Valve Lineup," Rev. 009-02
- OP 3346A-007, "EDG A - Crankcase Vacuum Valve Lineup," Rev. 005
- Attachment
- OP 3346A-008, "EDG B - Crankcase Vacuum Valve Lineup," Rev. 005
- OP 3346A-009, "EDG A - Instrument Valve Lineup," Rev. 006-01
- OP 3346A-010, "EDG B - Instrument Valve Lineup," Rev. 007-01
- OP 3346A-011, "EDG A - Electrical Lineup," Rev. 009
- MP-20-WP-GDL20 Attachment 15.1, "Scaffo ld Evaluation for WO53102186740 Unit 2 "B" EDG
Section 1R05: Fire Protection
- Millstone Unit 2 Firefighting Strategies, April 2002
- Millstone Unit 3 Firefighting Strategies, April 2002
- Millstone Unit 3 Nuclear Power Station Fire Protection Evaluation Report, Rev. 16
- 203-SP-M2-SU-1046 Rev 00, Millstone Unit 2 Appendix "R" Compliance Report
Section 1R06: Flood Protection Measures
- Millstone Unit 3 Internal Flooding Evaluation Reactor Plant Aerated Drains (contaminated) System Health Report 4
th quarter 2007 and 2008
- DCR M3-97079, "Containment Recirculation Cubicle Sumps 3DAS-SUMP7A/B Design
- Change," Rev. 1
- Design Criteria/EQ Program Switch Submergence," Rev. 3
- M3-EV-970281, "Technical Evaluation for ECCS Passive Failure Design Criteria," Rev. 3
- M3 05 15754
- M3 06 02859
Section 1R07: Heat Sink Performance
- EN 31084, "Operating Strategy for Service Wa ter System at Millstone Unit 3," Rev. 007
- Service Water Cooled Heat Exchangers Inspection Forms for "B" EDG Heat Exchangers,
- 3EGS*E1B and 3EGS*E2B
- CR323008
Section 1R11: Licensed Operator Requalification Program
- Unit 2 LORT Operating Exercise #2, Degraded Voltage
- MP3 LOIT/LORT, LORT SE46, Rev. 2
- OP-MP-100-1000, A Millstone Operations Guidance and Reference Document.
@
Section 1R12: Maintenance Effectiveness
- C
- PT 1402, "Timing Device Calibration," Rev. 001-03, performed August 14, 2006
- C
- PT 1407, "Panel Meter and Transducer Calibration," Rev. 001-04, performed August 15, 2006
- C
- PT 1410, "5kV and 8kV Cable Tests," Rev.001-03, performed April 25, 2007
- C
- PT 1425 B4, "Relay Type BDD18B Transformer Di fferential," Rev. 1, performed November 3, 2008
- M2-EV-01-0006, "Technical Evaluation for EDG Availability During Testing," Rev. 02
- MP2-ENG-ETAP-04014E2, "MP2 Electrical Distribution system Analysis," Rev. 1
- OP 3346C, "EGLS Individual Load Testing," Rev. 005-01
- PT 31460A, "MO3
- RSST-B, 6.9 KV Non-segregated Bus Test," Rev.002-01, performed August
- 17, 2006
- SP 3646A.16-001, "Train B Loss of Power Test," Rev. 013-01
- SP 3646A.16-002, "Train B Loss of Power Test Failure and Retest Documentation," Rev. 006
- Attachment
- EDG 2346A, B Unavailability March 2007 to February 2009
- EDG and Fuel Oil System, 2346A, B System Health Report 4
th Quarter 2007, 2008
- Eng'd Safeguards Actuation Sys (Sequencer), 3405, System Health Report, 4
th quarter 2007
and 2008
- ESF Load Sequencer Unavailability 2007-2008
- MRule (a)(1) Evaluation for the Normal Power System (2347),
- CR-08-06119, Rev. 00
- MRule (a)(1) Evaluation for the Normal Power System (2347),
- CR-08-06209, Rev. 00
- MRule (a)(1) Evaluation for the Normal Power System (3347),
- CR-07-04550, Rev. 00
- MRule (a)(1) Evaluation for the Emergency Generator Loading Sequencer (3405), CR-07-
- 208, Rev. 0
- MRule Functional Failure Evaluations Evaluation for Unit 2 Pressurizer Proportional Heaters
(07137),
- CR114357 Maintenance Rule Functional Failure Evaluations,
- CR-07-03270,
- CR-07-04550,
- CR-07-05208,
- CR-08-01476,
- CR-08-04403,
- CR-08-05611,
- CR-08-07480,
- CR118400
- Maintenance Rule Functional Failure Evaluations for Unit 2 EDGs,
- CR-07-02244,
- CR-07-03568,
- CR-07-06155,
- CR-07-06624,
- CR-07-11454,
- CR-08-00303,
- CR-08-00305,
- CR-08-00329, CR-
- 08-00330
- Maintenance Rule Functional Failure Evaluations for Unit 2 RSST,
- CR-08-04050,
- CR-08-04269,
- CR-08-06119,
- CR-08-06265
- NSST, RSST, Main Transformers, and Isophase Bus System Health Reports, 3347A, B, C, 4
th quarter 2007, 2
nd , 3 rd , and 4 th quarter 2008
- NSST Unavailability 2007-2008
- ODM for
- CR-08-06265
- RSST, 2347A Fluid Analysis Report for Dissolved Gases 2008, 2009
- RSST, 2347A System Health Report 4
th Quarter 2007 and 2008
- RSST 2347A, Unavailability 2007-2008
- RSST 3347A, Unavailability 2007-2008
- CR-06-00052
- CR-06-01467
- CR-07-04618
- CR-07-06624
- CR-07-07782
- CR-07-08147
- CR-07-08550
- CR-07-12481
- CR-08-00912
- CR-08-06613
- CR-08-07109
- CR-08-08370
- CR118400
- CR322051
- MRE006987
- MRE007244
- MRE007358
- MRE010264
- MRE010309
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
- DCN
- DM2-00-0043-09, "Leak Sealant Repair of Valve 2-MS-440" Attachment
- NF-AA-PRA-370, "Probabilistic Risk Assessment Procedures and Methods:
- PRA Guidance for
- MRule (a)(4)," Rev. 0
- North Bus Outage Implementation Plan, Rev. 0
- WM-AA-100, "Work Management," Rev. 4
- CR323435
Section 1R15: Operability Evaluations
- DCN
- DM2-01-0212-07 Replacement of Spool P24 to the "B" EDG Strainer
- EE-99032, "Maximum Allowable Gas Bubble Size at ECCS High Points," Rev. 02
performed
- IOD000149 Rev. 0, Air volume in "B" SIH discharge piping
- M3-EV-05-0008, "Determination of Allowable ECCS Gas Accumulations in Support of
- Surveillance 4.5.2.b.1," Rev. 2
- 53M30800403
- NUCENG-07-048, "Evaluation of Gas Voids in MP3 SIH Discharge Piping," Rev. 4
- 203-ER-08-0005 MP2 EDG Floor Drain Backwater Valves
- Tech Eval M2-EV-01-0006 "EDG Availability during Testing"
- MRE07137 "Pressurizer heater 3RCS*HTR48 has faulted"
- MRE10244 "Group 2 Proportional heater Reduced Capacity"
- IOD 000150 "Unit 2 Group 2 Pressurizer Heater Capacity Less than Normal"
- CR114357
- CR318967
- CR318997
- CR319295
- CR319371
- CR320282
- CR324239
- CR324869
- CR326019
- CR326558
Section 1R18: Plant Modifications
- C
- OP 200.13, "Cold Weather Preparations," Rev. 002-02
- WC 10, "Temporary Modifications," Rev. 005-07
- Temporary Log dated 1/1/09 Feedwater Isolation Valve Temperatures
- DM-2-00-0054-08 "Removal of "A" and "B" EDG Service Water Inlet Strainer"
- MP58B-00138EM, Rev 3 "Service Water Supply to Diesel Engine Coolers"
- CCN-22
- OP-2346A Rev 27-04 "A" EDG
- ARP-2591A Rev 004-01 "Alarm Response for "A" DG Panel, C-38"
- 50.59 Screen Removal of "A" and "B" EDG Service Water Inlet Strainer
- 50.59 Screen Supplemental Heating for FWIV Room
- DCN:
- DM2-00-0014-09
- 50.59/72.48 Screen for
- DN2-00-0014-09
- DCN:
- DM2-00-0064-09 "Temporary Leak Encapsulation on Body to Bonnet Leak at
- M22-CN-543 "B" SGFP Suction Vent"
- Calc# PIPEWHIP -1802M2 Rev 2, "Assessment of Pipe Whip Restraints, Millstone Unit 2" Attachment Calculation Change Notice PIPEWHIP-1802M2 Rev 2
- Vendor Calc# Bechtel
- PR-L Rev 1, "Main Feedwater Restraint
- MFR 16 and
- MFR 16"
- CR119948
- CR119953
- CR119959
- CR317924
- CR325093
Section 1R19: Post Maintenance Testing
- Bechtel Calculation#
- PR-L "Main Feedwater Pipe Restraint
- MFR 15 and
- MFR 16" Rev 1
- DCR M3-06004, "Unit 3 Vital Inverters Replacement", Rev. 0
- DCN
- DM2-00-0064-09 "Temporary Leak Encapsulation of Body to Bonnet Leak at M22-CN-543
"B" SGFP Suction Vent Valve"
- DM3-00-0027-07, "MP3 Vital Inverter Replacement," Rev. 07
- OP 3346D, "Station Blackout Diesel," Rev. 011-05
- Calc # PIPEWHIP-1802M "Assessment of Whip Restraints, Millstone Unit 2" Rev 2 and CCN 1
- SP 3442A40-001, "T/Tavg Channel 4 Calibration Data Sheet," Rev. 013-06
- SP 3443D21-001, "Protection Set Cabinet IV Operational Test Data Sheet," Rev 018-07
- SP 3626.8-001, "Control Building Air Conditioning Booster Pump 3SWP*P2A Operational Test"
- Readiness Test," Rev. 010-06"
- M3 07 00922
- 53102177167
- 53M30406863
- 53M30711915
- 53M30713534
- 53M30713536
- 53M30808635
- CR325093
- CR325463
- CR325558
- CR325591
Section 1R22: Surveillance Testing
- Section 2OS1/2OS2:
- Access to Radiologically Significant Areas/ALARA Planning and Controls Procedures
- RPM 1.3.8, Rev 8, Criteria for Dosimetry Issue
- RPM 1.3.13, Rev 9, Bioassay Sampling and Analysis
- RPM 1.3.14, Rev 8, Personnel Dose Calculations and Assessments
- RPM 1.6.4, Rev 4, Siemens Electronic Dosimetry System
- RPM 2.1.3, Rev 2, Identification and Control of High Radiological Risk Work Attachment
- RPM 5.2.2, Rev 13, Basic Radiation Worker Responsibilities
- RPM-GDL-008, Rev 0, Electronic Dosimeter Alarm Set Points
- RP-AA-201, Rev 2, Access Controls for High and Very High Radiation Areas
- RP-AA-202, Rev 0, Radiological Posting
- RP-AA-220, Rev 0, Radiological Survey Scheduling
- RP-AA-221, Rev 0, Radiological Survey Records
- RP-AA-222, Rev 0, Radiation Surveys
- RP-AA-226, Rev 0, Airborne Activity Surveys
- RP-AA-230, Rev 0, Personnel Contamination Monitoring and Decontamination
- OP 3316A, Rev 8, Personnel Access Control to the MID System Components Inside Containment
- Quality Assurance Reports Field Observation Report Nos. 9108, 9140, 9201, 9338, 9345, 9212, 8744, 8746, 8737, 8780,09-005, 09-
- Self Assessment Report
- SAR 000819, High Radiation Area (HRA) & Locked High Radiation Area (LHRA) Controls, Gap Analysis
Condition Reports
(Access Controls/ALARA)
- 116937,
- 114914,
- 117796,
- 317011,
- 117550,
- 321230, 322470-1,
- 317349
- ALARA Evaluation Numbers
- 2-09-01, 02-09-02, 02-09-09, 03-09-03, 03-09-10
- ALARA Council Meeting Minutes Meeting Dates: 02/26/2009, 12/18/2008, 09/17/2008
Miscellaneous
- Dose and Dose Rate Alarm Reports for October 2008 through January 2009
- MP2 Thimble Replacement Overview
- Ten Highest Doses received during 2008
- 3R12 Post Outage Report
- Radiation Protection Top Focus Items for 2009
- 2R19 3" Spray Line Cut and Replace Risk Evaluation
Section 4OA1: Performance Indicator (PI) Verification
- CP 3807F, "Operation of the Reactor Plant Sample Sink," Rev. 004-09
- SP 3601F.6, "Reactor Coolant System Water Inventory Measurement," Rev 005-06
- SP 3670.1, "Mode 1-4 Daily and Shiftly Control Room Rounds," for March, September, and
- December 2008
- SP 3855, "Reactor Coolant Analysis for Dose Equivalent I-131," Rev. 007
- SP 3855-001, "Reactor Coolant Analysis for Dose Equivalent I-131," Rev. 007-01
- Dose Equivalent Iodine Spreadsheet, 2008
- Unit 3 Quantitative Radioisotopic Iodine Analysis February 2008 and September 2008
- RCS Leakage Spreadsheet 2008
Section 4OA2: Identification and Resolution of Problems
- Attachment Simulator Testing
- NSEM-4.07, "Nuclear Simulator Engineering Manual, Master Testing Schedule"
- MP2 Simulator Recovery Plan
- RCE108505, "Discrepancies Exit with Unit 2 Simulator Testing Records"
- Unit 2 Simulator Core Performance Test Cycle 19 2008 (all CPTs)
- Unit 2 Scenario Based Testing ES08101a, "SGTL, SGTR with Complications" and SO8202,
"Plant Heatup and Termination of Shutdown Cooling" dated 2/20/2008
- Unit 2 Simulator Transient Tests: T1, "Manual Reactor Trip" dated 11/5/2008, and T4,
"Simultaneous Trip of all RCPs" dated 11/5/2008
- Unit 2 Simulator Steady State Tests Stability Test 100% Power dated 9/10/2008
- Internal Assessment 2008-01 dated 9/19/2008
- Internal Assessment 2008-05
- Unit 3 Simulator Core Performance Tests Cycle 13 (all CPTs)
- CR-07-08202
- CR-08-06997
- CR108371
- CR108505
- CR108838
- CR109159
- CR109817
- CR111110
- CR324101
- CR324772
- CR325250
- CR325305
- CR325584
- CR325620
- CR327009
- CR327201
- CR327592
- CR328186
- Unit 3 Radiation Monitors Maintenance Rule (a)(1) Action Plan for RE16B,
- CR107039
- Maintenance Rule Evaluations for the following CRs:
- CR-07-04412,
- CR-07-04977, CR-07-
- 05812,
- CR-07-09317,
- CR-7-10934,
- CR-07-11455,
- CR-08-00432,
- CR-08-00671,
- CR-08-02554,
- CR-08-02759,
- CR-08-02782,
- CR-08-03343
- Maintenance Rule Scoping Tables for Radiation Monitors, 3404
- Radiation Monitoring, 3404 System Health Report 4
th quarter 2007 and 2008
- ACE013937
- ACE017322
- CR-07-00577
- CR-07-02356
- CR-07-02703
- CR-07-05966
- CR-07-06024
- CR-07-06631
- CR-07-07753
- Attachment
- CR-07-11132
- CR-07-11583
- CR-08-00188
- CR-08-00567
- CR-08-02191
- CR-08-02201
- CR-08-02226
- CR-08-02467
- CR-08-04517
- CR107011
- CR120626
- CR326590
- MRE006964
- MRE007117
- MRE007126
- MRE007237
- MRE007360
- MRE010152
- MRE010237
- MRE010250
- MRE010263
- MRE010267
Section 4OA3: Followup of Events
- CR113238 CR118282
Section 4OA5: Other Activities
- WANO Peer Review Report
LIST OF ACRONYMS
ADAMS Agencywide Documents
Access and Management System
- AE [[]]
DRP Division of Reactor Projects
Attachment
MOC Middle of Cycle
mrem millirem
Attachment
WANO World Association of Nuclear Operators