IR 05000336/2016003

Integrated Inspection Report 05000336/2016003 and 05000423/2016003

ML16312A014
Person / Time
Site:	Millstone
Issue date:	11/04/2016
From:	Eugene Dipaolo Reactor Projects Branch 2
To:	Stoddard D Dominion Resources
DiPaolo E
References
IR 2016003
Download: ML16312A014 (43)

Text

{{#Wiki_filter:UNITED STATES ovember 4, 2016

SUBJECT:

MILLSTONE POWER STATION - INTEGRATED INSPECTION REPORT 05000336/2016003 AND 05000423/2016003

Dear Mr. Stoddard:

On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station (Millstone), Units 2 and 3. On October 5, 2016, the NRC inspectors discussed the results of this inspection with Mr. John Daugherty, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Millstone. In addition, if you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Millstone. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, /RA/ Eugene M. DiPaolo, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49

Enclosure:

Inspection Report 05000336/2016003 and 05000423/2016003 w/Attachment: Supplementary Information

REGION I== Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49 Report Nos. 05000336/2016003 and 05000423/2016003 Licensee: Dominion Nuclear Connecticut, Inc. (Dominion) Facility: Millstone Power Station, Units 2 and 3 Location: P.O. Box 128 Waterford, CT 06385 Dates: July 1 through September 30, 2016 Inspectors: J. Ambrosini, Sr. Resident Inspector, Division of Reactor Projects (DRP) L. McKown, Resident Inspector, DRP C. Highley, Resident Inspector, DRP H. Anagnostopoulos, Health Physicist, Division of Reactor Safety (DRS) J. Schussler, Project Engineer, DRP J. Kulp, Senior Reactor Engineer, DRS K. Warner, Project Engineer, DRP J. DeBoer, Emergency Preparedness Specialist, DRS Approved By: Eugene M. DiPaolo, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000336/2016003, 05000423/2016003; 07/01/2016 - 09/30/2016; Millstone

Power Station (Millstone), Units 2 and 3; Licensed Operator Requalification and Maintenance Effectiveness.

This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. The inspectors identified two non-cited violations (NCVs), both of which were of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of Technical Specification (TS) 6.8.1.a, for Dominions failure to implement procedures as required by Regulatory Guide 1.33, Revision 2, Appendix A.1, Administrative Procedures, during the performance of watch turnover. This resulted in multiple operators across multiple crews in both Unit 2 and 3 standing watch without performing a review of the applicable standing orders for up to 4 months from March to July 2016. Dominion entered the condition in their corrective action program (CAP) as condition report (CR)1042287.

The inspectors determined that the finding was more than minor because if left uncorrected the performance deficiency could lead to a more significant event. Specifically, the operators did not review TS amendments, emergency action level classifications, emergency operating procedures, and plant computer issues impacting the plant prior to taking watch. Without reviewing the standing orders to understand the information contained within, operators could potentially take improper actions to control the plant during evolutions and abnormal conditions.

The finding was determined to be of very low safety significance (Green) because it did not affect design or qualification of a mitigating structure, system, and component (SSC), did not represent a loss of system function, and did not involve external event mitigation systems. The inspectors determined that the finding has a cross-cutting aspect in the Human Performance cross-cutting area associated with Field Presence, where leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations.

Specifically, Dominion leadership observations in the control room or management review of monthly standing order audits could have discovered the deviation from standards and expectations. [H.2] (Section 1R11)

Cornerstone: Initiating Events

Green.

The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(b)(1), for Dominions failure to include the safety-related Unit 2 Pressurizer Safety Valve, Acoustic Valve Monitoring System (AVMS) SSC within the scope of the maintenance rule program. Specifically, Dominion removed the Millstone Unit 2 AVMS, which is required to remain functional during and following a design bases event to provide indication to operators in the control room of significant abnormal degradation of the reactor coolant pressure boundary and monitor for loss of coolant due to an open safety relief valve, from the scope of the maintenance rule monitoring program. Dominion has documented this condition in their CAP as CR1049493.

The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Dominions removal of AVMS from maintenance rule performance and condition monitoring and the failures observed have resulted in the complete loss of availability and reliability of each channel of AVMS such that they cannot perform their intended function. The finding was determined to be of very low safety significance (Green) because the conditions associated with the most applicable design basis event are bound by the small break loss of coolant accident (LOCA)analysis and did not affect other systems used to mitigate a LOCA. This finding has a cross-cutting aspect in the Human Performance cross-cutting area associated with Procedure Adherence, in that Millstone Maintenance Rule Expert Panel (MREP) members did not follow the Dominion maintenance rule program implementing procedure, ER-AA-MRL-100, which provides guidance for scoping systems into the maintenance rule. [H.8] (Section 1R12)

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period at 100 percent power. On August 5, 2016, Dominion took Unit 2 offline to facilitate repairs of a breaker in the switchyard. Operators held power at approximately 10 to 13 percent until Eversource completed the repairs which allowed Unit 2 to come back online. Unit 2 reached 100 percent power on August 8. On August 11, Unit 2 experienced the loss of two circulating water pumps due to a failure of the uninterruptible power supply for the variable frequency drive for the circulating pumps following a lightning strike.

Operators took manual action to trip the reactor in response to the resultant degrading condenser vacuum. Unit 2 returned to 100 percent power on August 14 and remained at or near 100 percent power for the duration of the inspection period.

Unit 3 began the inspection period at 100 percent power and remained at or near there for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Dominions preparations for the onset of a tropical depression on September 2, at Units 2 and 3. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the emergency diesel generators (EDGs) and service water (SW) system to ensure system availability and a general site walkdown of all external areas of the plant to observe the condition of the flood gates, water flood doors, and general area missile hazards. The inspectors verified that operator actions defined in Dominions adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Unit 2 A and B reactor building component cooling water (RBCCW) on August 24 Unit 3 A EDG during B EDG sequencer maintenance on July 11 A quench spray system following system restoration on September 21 B safety injection (SI) system during A SI train maintenance and surveillances on September 28 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TSs, work orders, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Dominion staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On September 1, the inspectors performed a complete system walk down of the Unit 3 chemical and volume control system to ensure proper system alignment and identification of any material conditions that have the potential to affect functionality of the system. The inspectors reviewed emergency operating procedures, drawings, and the UFSAR to verify that the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems.

The inspectors performed field walk downs of accessible portions of the systems to verify as-built system configuration matched plant documentation. The inspectors confirmed that systems and components were aligned correctly, environmentally qualified, and protected against external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs to ensure Dominion appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified. ==1R05 Fire Protection