IR 05000336/2011003

IR 05000336-11-003 & 05000423-11-003, on 04/01/2011 - 06/30/2011, Millstone Power Station, Unit 2 and Unit 3, Operability Evaluations, Surveillance Testing, Event Follow-up

ML112160449
Person / Time
Site:	Millstone
Issue date:	08/03/2011
From:	Diane Jackson NRC/RGN-I/DRP/PB5
To:	Heacock D Dominion Resources
Jackson D E, RGN-I/DRP/PB5/610-337-5306
References
IR-11-003
Download: ML112160449 (57)

Text

REG?<4\,, UNITED STATES

+o""9o" NUCLEAR REGULATORY COMMISSION W;

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA. PA 19406.1415

+***t August 3, 2011 Mr. David Heacock President and Chief Nuclear Officer Dominion Resources 5000 Dominion Boulevard Glen Allen, VA 23060-6711 SUBJECT: MILLSTONE POWER STATION . NRC INTEGRATED INSPECTION REPORT 05000336/20 11 003 AND 050004231201 1003

Dear Mr. Heacock:

On June 30, 2011, 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 August 1,2011, 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 two NRC-identified findings and two self-revealing findings of very low safety significance (Green). Three of these findings were determined to involve violations of NRC-req-uirements. However, because of the very low safety significance and because they have been entered into your corrective action program (CAP), the NRC is treating these{in_dings as non-cited violations (i.fCVs) consistent with Seition 2.3.2.a of the NRC Enforcement Policy'

lf you contest any NCV in this report, you should provide a response within 30 days of the date of this inspectionreport, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document iontrol Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region l; the Director, Offile of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at Millstone. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should piovide a response within 30 days of the date of this inspection report, with the baiis for your disagreement, to the RegionalAdministrator, Region l, and the NRC Senior Resident Inspector at Millstone. 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.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Donald E. Jacks Projects Branch 5 Division of Reactor Projects Docket Nos. 50-336. 50-423 License Nos. DPR-65, NPF-49

Enclosure:

Inspection Report No. 0500033612011003 and O5OOO42312O1 1003 W Attachment: Supplemental Information

REGION I Docket No.: 50-336, 50-423 License No.: DPR-65, NPF-49 Report No.: 05000336/201 1 003 and 05000 4231201 1003 Licensee: Dominion Nuclear Connecticut, Inc.

Facility: Millstone Power Station, Units 2 and 3 Location: P. O. Box 128 Waterford, CT 06385 Dates: April 1 ,2011through June 30, 2011 Inspectors: S. Shaffer, Senior Resident Inspector, Division of Reactor Projects (DRP)

J. Krafty, Resident Inspector, DRP B. Haagensen, Resident Inspector, DRP M. Modes, Senior Reactor Inspector, Division of Reactor Safety (DRS)

T. Moslak, Health Physicist, DRS Approved by: Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Enclosure

Table of Contents suMMARy OF FlNDlNGS........... .........3 1. REACTOR SAFETY ......................6 1R01 Adverse Weather Protection .............6 1R04 Equipment Alignment. .......................7 1R05 Fire Protection............ ......................9 1R08 In-Service Inspection ..... 10 1R11 Licensed Operator Requalification Program.........,.... ........11 1R12 Maintenance Effectiveness .............12 1R13 MaintenanceRiskAssessmentsandEmergentWorkControl...... ......12 1R15 Operability Evaluations ...................13 1R18 Plant Modifications.... ..... 16 1R19 Post-Maintenance Testing .............. 16 1R20 Refueling and Other Outage Activities ............. 1g 1R22 Surveillance Testing ...... 19 IEPO Drill Evaluation........... .....................21 2. RADIATION SAFETY ..................21 2RS01 RadiologicalHazard Assessment and Exposure controls.... ..............21 2RS02 OccupationalALAM Planning and Controts.............. ......24 2RS03 In-Plant Airborne Radioactivity Control and Mitigation ............ ...........26 2RS04 Occupational Dose Assessment.............. ........27 2RS05 Radiation Monitoring Instrumentation.......... .....28 2RS06 Radioactive Gaseous and Liquid Effluent Treatment ........30 4. OTHER ACTIVITlES [OA]....... .....32 4OA1 Performance Indicator (Pl) Verification ......... ....................32 4OA2 ldentification and Resolution of Problems............... ..........32 4OA3 Event Follow-up .............37 4OAO Meetings, including Exit........... .......42 ATTACHMENT: SUPPLEMENTAL I NFORMATION 42 SUPPLEMENTAL INFORMATION........... ...........A-1 KEY POINTS OF CONTACT .A-1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED ....A-2 LIST OF DOCUMENTS REVIEWED A-3 LIST OF ACRONYMS .A-11 Enclosure

SUMMARY OF FINDINGS

lR 0500033612011003, 0500042312011003; 0410112011 - 0613012011; Millstone Power Station

Unit 2 and Unit 3; Operability Evaluations, Surveillance Testing, Event Follow-up.

The report covered a three-month period of inspection by resident and region-based inspectors.

Four Green findings, three of which were non-cited violations (NCV), were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process." The cross-cutting aspects were determined using IMC 0310, "Components Within the Cross Cutting Areas." 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.

Cornerstone: Initiating Events

Green.

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. tH.4(b)l (Section 4OA3)

Cornerstone: Mitigating SYstems

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, rcorrective 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. bominion 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

'B' train lssues." Specifically, the degraded condition caused a loss of operability of the 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 thatissues 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 P'1(d)' (Section 1R15)

.

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVl, rcorrective 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-freq uency 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. tP.1(d)l (Section 1R22)

Cornerstone: Barrier IntegritY

.

Green.

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 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 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 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

Building surveillance test failure in 2009. P.1(d) (Section 4OA3)

REPORT DETAILS

Summarv of Plant Status Millstone Units 2 and 3 began the inspection period operating at 100 percent power. On April 2, 2011, Unit 2 was shutdown to begin refueling outage 2R20. Unit 2 returned to 100 percent power on May 4,2011. On June 20, 2011, Unit 2 reduced power to 30 percent to repair an oil leak on the'C' reactor coolant pump (RCP) motor. Following repairs, Unit 2 increased power to approximately 59 percent power when the plant tripped on low steam generator water level.

Unit 2 returned to 100 percent power on June 23, 2011 . Unit 3 remained at or near 100 percent power for the entire inspection period.

1. REACTORSAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 External Floodinq Inspection

a. Inspection Scope

The inspectors evaluated Dominion's readiness to cope with external flooding at Unit 2 and Unit 3. The inspectors reviewed the Unit 2 and Unit 3 Updated Final Safety Analysis Report (UFSAR) and identified areas that could be affected by external flooding due to a design basis flood. The inspectors reviewed applicable procedures to verify that the actions required in the event of flooding could reasonably be completed, and that the appropriate equipment was pre-staged. The inspectors performed walkdowns of the Unit 2 and Unit 3 intake structures, fire pump houses, and inspected the material condition of flood doors in order to determine if the structures and components were being adequately maintained. Documents reviewed during the inspection are listed in the Attachment.

b.

Findinqs No findings were identified.

.2 Grid Stabilitv - Readiness of Offsite and Alternate AC Power Svstems

a. Inspection Scope

The inspectors reviewed Dominion's Independent System Operator (lSO) New England and Connecticut Valley Electric Exchange (CONVEX) procedures for notifications of abnormal grid conditions to determine if they were adequate to ensure the reliability of alternating cunent (AC) power systems. The inspectors reviewed Dominion's procedures to determine if they addressed inadequate post-trip voltages of the offsite power supply, unknown post trip voltages, reassessment of risk when maintenance activities could affect grid reliability, and required communication between Dominion and ISO New England/CONVEX when changes at the site could impact the transmission system. The inspectors interviewed selected shift managers to determine if they were dmiliar with the procedures for abnormal grid conditions. The inspectors performed a walkdown of the switchyard, main transformers, normal station service transformers, and reserve station service transformers; and performed a review of the system health reports for the switchyard and transformers in order to determine the material condition of the offsite power sources.

b. Findinqs No findings were identified.

.3 Seasonal Site lnsPection

a.

lnspection Scope The inspectors performed a review of Dominion's readiness for hurricane season. The inspectors reviewed selected equipment, instrumentation, and supporting structures to determine if they were configured in accordance with Dominion's procedures, and that adequate controls were in place to ensure functionality of the systems. The inspectors reviewed the Unit 2 and Unit 3 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 2 and Unit 3 intake structures, fire pump houses, flood doors, and flood protection equipment to determine the material condition of installed flood protection equipment, and verify that the portable flood protection equipment was properly staged. The inspectors also reviewed previous CRs and work orders to verify that the deficiencies identified have been corrected. Documents reviewed during the inspection are listed in the Attachment.

b.

Findinqs No findings were identified.

1 R04 Equipment Aliqnment (71111

.1 Partial Svstem Walkdowns

a. Inspection Scope

The inspectors performed three partial system walkdowns during this inspection period.

The inspectors reviewed the documents listed in the Attachment to determine the correct system alignment. The inspectors performed 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 I

following systems were reviewed based on their risk significance for the given plant configuration:

Unit 2

.

Spent Fuel Cooling with the 'A' Low Pressure Safety Injection (LPSI) pump and 'A' Shutdown cooling (SDC) heat exchanger with the core off-loaded in the spent fuel pool on April 13,2011; o 'B' High Pressure Safety Injection (HPSI) train while the 'A' train was out of service (OOS) for testing on May 12,2011; and Unit 3

.

'A' system HPSI with the 'B' train out for testing on May 5, 2011.

b. Findinqs No findings were identified.

.2 Complete Svstem Walkdown (71111.04S

- 1 sample)

a. Inspection Scope

The inspectors completed a detailed review of the alignment and condition of Unit 2 EBFS. The inspectors performed a walkdown of the system to determine whether critical portions, such as circuit breakers and switches, were aligned in accordance with procedures and to identify any discrepancies that may have had an adverse effect on operability. The inspectors also reviewed the system health reports, condition reports, and Maintenance Rule evaluations to determine whether equipment problems were being identified and appropriately resolved. Documents reviewed during the inspection are listed in the Attachment.

b. Findinqs No findings were identified.

1R05 Fire Protection

.1 Fire Protection Tours

a. Inspection Scope

The inspectors performed walkdowns of five 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 o Containment Building, Fire Area C-1; o West DC Switchgear Room, Fire Area A-21;

.

West Battery Room, Fire Area A-23;

.

Auxiliary Building, -5' General Area, Fire Area A-1; and Unit 3 o East Motor Control Center (MCC) and Rod Control Area, Fire Area AB-5' b. Findinqs No findings were identified.

.2 Annual Fire Drill Observation (71111'05A

- 1 sample)

"4.

lnspection Scope To evaluate the readiness of station personnel to fight fires, the inspectors observed Dominion personnel performance during a fire brigade drill on May 13,2011' The drill simulated a fire in the Unit 2 East Cable Vault in the turbine building. The inspectors observed the fire brigade members using protective clothing, turnout gear, self-contained breathing apparatuslnd entering the fire area. The inspectors also observed the fire fighting Jquipment brought to the fire scene to evaluate whether sufficient equipment wis aiailable to effectively control and extinguish the simulated fire' The inspectors the fire evaluated whether the peimanent plant fire hose lines were capable of reaching observed the area and whether hose usage was adequately simulated. The inspectors fire fighting directions and c6mmunications between fire brigade members.

The inspeitorJalso evaluated whether the pre-planned drill scenario was followed and observed the post drill critique to evaluate if the drill objectives we-re satisfied and that any drillweaknesses were discussed. The inspectors evaluated fire brigade performance, including the readiness of the fire brigade to fight fires and the utilization of preplanned strategies.

b. Findinqs No findings were identified.

1R08 ln-Service Inspection

a. Inspection ScoPe ln-Service Insoection Proqram The inspectors reviewed a sample of nondestructive examination activities and discussed the results of the examination with the Dominion corporate Level lll ln-Service Inspection Inspector. There were no volumetric or surface examinations from the previous outage with relevant indications that were analytically evaluated and accepted by Dominion for continued service.

Vessel Head Inspection No vessel head activities were performed during this outage' Weldino and Repair Proqram The inspectors reviewed a complete welding and fabrication package consisting of a revised piping anchor to determine if the welding activities were performed in accordance with American Society of Mechanical Engineers (ASME) Code requirements, or an NRC approved alternative' Boric Acid Control Proqram The inspectors reviewed the boric acid control program with the Dominion engineering lead. The inspectors reviewed the photographic evidence of boric acid leaks with the performed for Dominion engineering lead and discussed various engineering evaluations boric acid found on Riactor Coolant System (RCS) piping and components.

Also, the are identified properly in inspectors verified that degraded or non-conforming conditions Dominion's corrective action program.

Steam Generator (SG) Proqram No in-situ pressure testing'was performed during this inspection. The inspectors compared the estimated Jize and number of tube flaws detected during the current outage against the previous outage operational assessment predictions to assess Domlnion:s prediction capability. The inspectors confirme_d that the SG tube eddy Power current examination scope and e*pansion criteria meet TS requirements, Electric Research Institute Guidelines, and commitments made to the NRC. The inspectors confirmed all areas of potential degradation (based on site-specific experience and industry experience) are being inspected, especially areas which are known to represent potentiil eddy current challenges. The inspectors confirmed that the eddy current probes and equipment are qualified for the expected types of tube degradation and assessed the site specific qualification of one or more techniques.

Because Dominion identified loose parts or foreign material on the secondary side of the SG, the inspectors evaluated Dominion's corrective actions. The inspectors confirmed that Domin'ron has taken/planned appropriate repairs of affected SG tubes, and inspected the secondary side of the SG to remove foreign objects. lf the foreign objects are inaccessible, the inspectors determined whether Dominion has performed an evaluation of the potential effects of object migration and/or tube fretting damage' The inspectors reviewed a random sample of eddy current data in this regard.

b. Findinqs No findings were identified 1R1 1 Licensed Operator Requalification Proqram (71111.11 - 3 samples)

Resident Inspector Quarterlv Review (7 1111.1 1O)a.

lnspection ScoPe The inspectors observed simulator-based licensed operator requalification training for Unit 2 on May 24,2011, and June 7, 2A11, and for Unit 3 on June 7, 2011. 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, "Millstone Operations Guidance and Reference Document." The inspectors compared simulator configurations with actual control board configurations' The inspectors also observed Dominlon 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.

Findinqs No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection ScoPe The inspectors performed one maintenance effectiveness inspection sample of Dominion's evaiuation of degraded conditions for the Unit 2 Charging and Letdown "Maintenance Rule,"

system. The inspectors reviewed Dominion's implementation of the 10 CFR 50.65. ihe inspectors reviewed Dominion's ability to identify and address common cause failures; the applicable maintenance rule scoping document for each system; the current classification of these systems in accordance with 10 CFR 50.65 piragraph (aX1) or (a)(2); and the adequacy oj the performance criteria and goals recent established foi each sysiem, as appropriate. The inspectors also reviewed system health reports, Condition Reports (CR), apparent cause determinations' functionalfailure determinations, and discussed system performance with the responsible iystem engineer. Documents reviewed during the inspection are listed in the Attachment.

b. Findinqs No findings were identified.

1R13 (71111.13 - 9 samPles)

a.

Inspection ScoPe planned activities' The inspectors evaluated online risk managementfor emergent and The inspectors reviewed maintenance risk-evaluations, work schedules, and control room logs to determine if concurrent planned and emergent maintenance or surveillance activitiel adversely affected the plant risk already incurred with out-of service (oos)

-omponents.

Thg,inspectors evaluated whether Dominion took the necessary steps to maintain the control work activities, minimize the probability of initiating events, and The inspectors assessed Dominion's risk functional capability of mitigating systems.

reviewed during the r"n"g"t"ni actiohs during plant walkdowns' Documents and inspeJtion are listed in the Aitachment. The inspectors reviewed the conduct activities:

adequacy of risk assessments for the following maintenance and testing Unit 2 a 2R2O Shutdown Risk Assessment on March 31,2011; a Orange Risk for RCS Drain down to Mid-Loop on April 5,2011; a Orange Risk for North Bus Outage on April 5,2Q11; April a Orante Risk for Replaceme nt of 2 SW-978 (only one train of SW available) on 7,2011; Risk Mitigation Plan for lsophase Bus Duct Seal Bushing Installation on April 19' 2011; o Alternate Plant Configuration for lsolating the 'A' Pressurizer Spray Line; a Yellow Risk for'A' S\i/ pump OOS and ECCS suction valve testing on May 24' 2011; Unit 3 o Emergent risk assessment for a failure of the Sl logic module in the SSPS train

'B' while iwitchyard work was in progress on April 18, 2011; and o Emergent work to replace SW valves 3SWP"V699, 3SWP"V018 and 3SWP*V696 due to de-alloYing.

b. Findinqs No findings were identified.

1R15 Operabilitv Evaluations (71111-15 - 7 samples)

a. lnspection ScoPe The inspectors reviewed seven operability determinations (OD). The inspectors evaluated the ODs against the guidance contained in NRC Regulatory lssue Summary 2OOS-20, Revision tobuidance Formerly Contained in NRC Generic Letter 91-18, "lnformation to Licensees Regarding Two NRC lnspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability'" The inspectors atso discussed the conditions with operators, and system and design engineers, as necessary. Documents reviewed during the inspection are listed in the

. The inspectors reviewed the adequacy of the following evaluations of degraded or non-conforming conditions:

Unit 2 Engineering Technical Evaluation, ETE-MP-2011-0030, addressing a small breach in the control room envelope via a halon piping penetration; Engineering Technical Evaluation, ETE-MP-201 1 -0045, providing use-as-is conclusion on terry turbine shaft pitting; ODM 000202, Operation with 2-RS-252, Loop 1A Pressurizer Spray Header lsolation Valve closed; Unit 3 RAS 000176 l CR41g723, "Fire Shutdown Analysis Time Critical Operator Action (TCOA) to secure RCPs," dated March 28,2Q11; a CR427354, Degraded Condition for MOV 87018 and MOV 8702A RHR lsolations; a ODM000192, "Addressing Increased Hydrogen Pressure in the VCT Creating an

'D' RCP #1 lncrease in UnidentitieO RCS leakage and Increased Leakage From the Seal Leak-off," dated March 17,2011; and

.

1OD000173, "lnitial Operability for Aluminum-Bronze Service Water Valves De-alloying," dated May 25,2011.

Findinqs lntroduction: 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.

Description:

On May 25,2011, through-wall leaks were identified on SW valves 3SWP.V699, 3SWP*V018, and 3SWP.V696. These valves provide cooling water flow to the room air conditioning units that support the 'B' train of containment recirculation spray pumps. The leaks were caused by de-alloying of the aluminum bronze (Al-Br)valve bodies that had not been properly heat-treated to prevent the galvanic leaching of aluminum from the Al-Br metal matrix. Dominion had previously identified the susceptibility of these service water (SW) valves to de-alloying in apparent cause evaluation (ACE) 017509 dated March 30, 2009. Dominion had identified the de-alloying issue, characterized the de-alloying process, and determined that the cause was due to an old design issue where Al-Br valves had been procured without a specified heat-treatment that would have minimized the susceptibility of the valves to the de-alloying process. Dominion concluded in ACE 017509 that, "Based on past experience, this new valve (3SWP.V699) will leak 12to 18 months from installation." Dominion then prioritized all installed SW valves that were susceptible to de-alloying into four tiers based on their susceptibility and risk significance in the extent of condition assessment.

Valves 3SWP.V699, 3SWP*V018, and 3SWP.V696 were prioritized as "tier one" and should have been replaced promptly.

Dominion subsequently initiated CR428785 on May 25, 2011, to address through-wall leakage from these SW valves and completed OD0004211o assess operability and extent of condition. The leaking valves were replaced and the air conditioners (3HVQ.ACUS1B and 3HVQ.ACUS2B) were returned to service on May 26,2011. The repeated failure of 3SWP.V699 and the additionalfailures of 3SWP.VO18 and 3SWP.V696 resulted in the loss of operability and additional unavailability of the 'B' train of containment recirculation spray pumps during valve replacement.

Analysis:

The inspectors determined that the failure to take timely corrective action following identification of a degraded condition was a performance deficiency that was reasonably within Dominion's ability to foresee and prevent, Traditional Enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function, and was not the result of any willful violation of NRC requirements.

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 recirculation 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. In accordance with NRC Inspection Manual Chapter 0609, 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 in a timely fashion to address a known de-alloying issue with SW valves before the condition led to the inoperability and unavailability of the safety-related support systems for the 'B' train of containment recirculation spray pumps [P. 1 (d)].

Enforcement:

10 CFR 50, Appendix B, Criterion XVl, "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 non-conformances are promptly identified and corrected. Contrary to the above, from March 30, 2009, to May 25, 2011, Dominion did not take timely corrective actions to correct the de-alloying of Al-Br SW valves prior to the condition adversely impacting 'B' containment recirculation spray system operability. Dominion took immediate corrective action to replace the three leaking SW valves. Because the issue is of very low safety significance (Green) and has been entered into Dominion's CAP (CR428785), the NRC is treating this finding as an NCV, consistent with the NRC's Enforcement Policy. (NCV 05000423/2011003-01, Failure to Take Timely Corrective Actions for De-alloying of Aluminum Bronze Service Water Valves).

1R18 Plant Modifications

a. lnspection ScoPe To assess the adequacy of the modifications, the inspectors performed walkdowns of selected plant systems and components, interviewed plant staff, and reviewed applicable documents, including procedures, calculations, modification packages, engineering evaluations, drawings, corrective 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 qualificatibn, instrument setpoints, uncertainty calculations, electrical coordination, electrical loads analysis, and equipment environmental qualification) were consistent *itn tn" design and licensing bases. Design assumptions \ryere reviewed to verify that they were technically appropriate and consistent with the UFSAR. For each modification, ihe 10 CFR 50.59 screenings or safety evaluations were reviewed' 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-post-built configuration was acCurately reflected in the design documentation and that modification testing was adequate to ensure the structures, systems, and components would function property. Documents reviewed during the inspection are listed in the

. The following plant modifications were inspected:

Unit2

.

MP2-10-01037-000, "MP2 Motor Driven AFW Pump Bearing Replacement" (permanent);o DM2-00-01 10-01, "lnstallation of High Point Vents on H.P & L.P. Safety lnjection &

Containment Spray Suction Piping" (permanent);

.

DM2-03-0183-09, "Temporary DCN Restoration Additional RTB Meter RelaY Replacement Anomalies" (permanent); and

.

MP2-11-01057, "MP2 MSSV Outlet Boot Design" (permanent).

b.

Findinqs No findings were identified'

1R19 Post-Maintenance Testino

a.

Inspection ScoPe The inspectors reviewed post-maintenance test (PMT) activities to determine whether the pMT adequately demonstrated that the safety-related function of the equipment was satisfied, given the icope 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:

Unit2

.

Sp 26131,"Facility 2 ESF Integrated Test Data Sheet," Revision 010-02, following replacement of the 'B' Emergency Diesel Generator (EDG) channel heads on April 17,2011;

.

Hypot Testing on the lsophase following the lsophase Duct Seal Plate Installation on April 19,2011;

.

SP 2660-001, "AFP Turbine Overspeed Trip TeSt," Revision 005-06, on April 21, 2011 and Sp2619BS-003,'TDAFP Comprehensive Pump Test (MODE 3)," Revision 001-03, on May 2,2011 following the overhaul of the Terry Turbine;

.

Sp 2601C-009, "Chemical and Volume Control System (CVCS) Valve Remote "CVCS Position Indication lST, Facility 2," Revision 000-00, and SP 260'1C-008, Valve Stroke and Timing lST, Facility 2," Revision 000-00, following overhaul of 2-cH-S14;

.

C Sp 760-003, "Battery DB3-201D Discharge Inspection," Revision 002-01, following battery replacement on April 10,2O11;

.

Sp ZilOe, 'MSIV Closure and Main Steam Valve Operational Readiness Testing,"

Revision 011-03, following leak injection repair of 2-MS-1908;

.

SP 2613-8-001 , "Periodic DG Operability Test, Facility 2 (Fast Start, Loaded Run),"

Revision 021-05, following 'B' EDG governor replacement;

.

Sp 2411, "CEA Motion Inhibit Verification," Revision 002-08, following CEAPIDS monitor failure; and Unit 3

.

Sp 36464.1-003, "EDG 'A'Air Start Valves Independence Test," Revision 010, and Sp 3646A.1-001, "EDG 'A' Operability Tests," Revision 018-01, following repair of a jacketwaterleakandreplacementoftheairstartfilter.

b. Findinqs No findings were identified.

1R20 Refuelinq and other outaqe Activities (71111.20 - 1 sample)

Millstone Unit 2 Refuelino Outaqe (2R20)a. Inspection ScoPe Dominion began refueling outage 2R20 on April 2,2011, and completed the outage on May 4, 2011. The inspectors evaluated the outage plan and outage activities to detbrmine if Dominion had considered risk, developed risk reduction and plant configuration control methods, considered mitigation strategies in the event of loss of safety functions, and adhered to licensee and TS requirements. The inspectors observed portions of the shutdown, cooldown, heat up, and start up processes.

Additionaliy, the inspectors performed an initial containment Mode 3 walk down to evaluate the as-found condition of containment. The inspectors also performed a final Mode 3 walk down to ensure that no loose material or debris, which could be transported to the containment sump, were present. The inspectors reviewed CRs to determine if conditions adverse to quality were entered for resolution. Documents reviewed for the inspection are listed in the Attachment. Some of the specific activities the inspectors observed and Performed included:

o scaffolding walkdown for potential interference with sscs; o Reactor shutdown and cool down; o Reactor water level drain down to the reactor flange; o Midloop and reduced inventory operations;

.

Fuel handling, core loading, and fuel element assembly tracking;

.

Containment as-found walk down; e Review of outage risk Plan; e orange Risk - Replacement of service water valve 2swP-978; o Risk Mitigation Plan for the North Bus Outage;

.

Generic Letter 88-17 verification; o Refueling Seal InsPection;

.

Containment as-left walk down; o Reactor Heat-up;

.

Reactor Start-up;

.

Low Power PhYsics Testing; o Reactor power ascension;

.

Unit 2 Generator synchronization to the grid;

.

Review of Work Schedules for Operations, Maintenance, and Security; and o Fatigue Management.

b.

Findinqs No findings were identified.

1R22 Surveillance Testinq (71111.22 - 9 samples)

a. Inspection Scope

The inspectors reviewed surveillance activities to determine whether the testing adequaiely 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 Sp 2610E, "MSIV Closure and Main Steam Valve Operational Readiness Testing,"

Revision 11-02 (lST);a SP 27308-001, "Main Steam Safety Valve Testing," Revision 011; a SP 2613H, "lntegrated Test of Facility 2 Components (ICCE)," Revision 012-Q2; a sP 2602E-001, "Pressurizer Heater Capacity Test," Revision 000-00; a sP 2651N-001, "Main control valves operability Test," Revision 002-09; a Pf 21415A,"MPzInverters 1-4 Tests," Revision 004-02; Unit 3

.

Sp g622.3, "TDAFW Pump Operational Readiness and Quarterly IST Group'B' Pump Tests," Revision 017-03;

.

sP 3556812, "SSPS Train 'B' Operational Test," Revision 012-04; and

.

CP 3802E, "Reactor Coolant gas Sampling and Analysis," Revision 002-01' b.

Findinqs lntroduction: The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Cntenon 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.

Description:

Millstone Unit 2 safety-related inverters 1 through 4 supply po{el to safety-related 121VAC instrument panels. ln April 2011, during refueling outage 2R20, inverters 1 through 4 were found outside the acceptance criteria for the under-frequency and over-frequency transfer limiter test. The over-frequency and under-frequency limits were adjusted bac[< into the acceptance criteria; however, these inverters have had a history of Oritting outside their acceptance criteria. In March 2009, the NRC documented an NCV for the inverters being found frequently out of calibration for over-frequency and under-frequency between 2005 and 2008 (NRC inspection report 05000336&42312009006). Dominion wrote CR333435 which requested a setpoint change to address the issue identified in the NCV. This request was approved in a Request for Engineering Assistance (REA), but has not been funded to date.

Additionally, during the Problem ldentification and Resolution team inspection in February 2010, NRC inspectors noted that three of the inverters had over-frequency and under-frequency transfer limits outside acceptance criteria during testing in October 2009, and that corrective action had not been implemented.

Dominion performed an assessment of the system impact of the over- and under-frequency transfer limits and determined that the equipment supplied by the inverters are designed for a wide range of frequencies, and are insensitive to the small frequency band set by the over- and under-frequency transfer limit setpoints. Dominion concluded that the out-of{olerance over- and under-frequency transfer limits do not present a safety concern and that the inverters remained operable. The inspectors reviewed Dominion's assessment and reached the same conclusion. Dominion's corrective actions will be to perform the detailed analysis necessary to increase the allowable tolerances of the over- and under-frequency setpoints from the current +l- 0.1 Hz .

Analvsis: The inspectors determined that the failure to take timely corrective action to address the repetitive out of calibration over-frequency and under-frequency transfer limits was a performance deficiency that was reasonably within Dominion's ability to foresee and correct, and should have been prevented. Traditional enforcement does not apply since there were no actual safety consequences, impacts on the NRC's ability to perform its regulatory function, or willful aspects of the finding.

The inspectors determined the finding was rnore than minor because it is similar to the more than minor Example '4f' oI NRC lnspection Manual Chapter (lMC) 0612, Appendix E, "Examples of Minor lssues." 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. tP.1(d)l

Enforcement:

10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, and defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from March 2009, until June 2011 , Dominion failed to take timely corrective action to address the repetitive out of calibration conditions associated with the 120 VAC safety related inverters. To date, Dominion has taken corrective action to adjust the over-frequency and under-frequency transfer limits. Because this violation was of very low safety significance and was entered into Dominion's corrective action program (CR426589), this violation is being treated as an NCV, consistent with the NRC's Enforcement Policy. (NCV 0500336/2011003-02 Untimely Corrective Action for Safety Related tnverters Leads to Repetitive Out of Calibration Results)

Emergency Preparedness (EP)lEPO Drill Evaluation Q1114.06 - l sample)

Classification and Notification durinq Requalification Traininq a. Inspection ScoPe The inspectors reviewed the operator's emergency classification and notification completed during Unit 2's requalification training on June 7, 2011. The inspectors verified the classification and notification were accurate and timely.

b.

Findinqs No findings were identified.

RADIATION SAFETY

Gornerstone: Public and Occupational Radiation Safety 2RS01 Radiolooical Hazard Assessment and Exposure Controls (71124'01)

a. Inspection Scope

(1 samPle)

During the period April 1 8,2011 through April 21 ,2011, the inspectors performed the following activities to verify that Dominion was evaluating, monitoring, and controlling radiological hazards for work performed during the 2R20 refueling outage in locked high radiation areas (LHRA) and other radiological controlled areas. lmplementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, Technical Specifications, and with Dominion's procedures' Radioloqical Ha4ards Control and Work Qoveraqe The inspectors identified work performed in radiological controlled areas in Unit 2 and evaluated Dominion's assessment of the radiological hazards. The inspectors evaluated the survey maps, exposure control evaluations, electronic dosimeter dose/dose rate alarm set points, and radiation work permits (RWP) associated with these areas to determine if the exposure controls were acceptable. Specific work activities evaluated included inspection/removal of a damaged incore instrument (lOl) thimble tube (RWP 391) from the lCl plate and reinstalling the lCl plate and Upper Guide Structure (UGS) in the reactor vessel (RWP 302). For these tasks, the inspectors attended the pre-job briefings and discussed the job assignments with the workers. The inspectors also observed (from the centralized monitoring system and during containment tours), the implementation of exposure controls for disassembling/removing scaffolding from containment (RWP 331), re-installing insulation (RWP 326), and demobilization of SG tasks (RWP 307).

The inspectors reviewed the air sample records for samples taken prior to installing SG nozzle dams to determine if the samples collected were representative of the breathing air zone and analyzed/recorded in accordance with established procedures. During tours of the Unit 2 containment building, the inspectors verified that continuous air monitors were strategically located to assure that potential airborne contamination could be timely identified and that the monitors were located in low background areas.

The inspectors toured accessible radiologically controlled areas (RCA) in the Unit 2 containment and with the assistance of a radiation protection technician, performed independent radiation surveys of selected areas to confirm the accuracy of survey data, and the adequacy of postings. Radiation protection technicians were questioned regarding their knowledge of plant radiological conditions for selected jobs, and the associated controls, Additionally, the inspectors reviewed the RWPs developed for other work performed during 2R20 including installation of permanent shielding and diving operations. ln particular, the inspectors reviewed the electronic dosimeter dose/dose rate alarm set points, stated on the RWP, to determine if the setpoints were consistent with the survey indications and plant policy.

lnstructions to Workers By attending pre-job briefings, the inspectors determined that workers performing radiological significant tasks were properly informed of electronic dosimeter alarm setpoints, low dose waiting areas, stay times, and work site radiological conditions. By observing work-in-progress, the inspectors determined that stay times were appropriately monitored by supervision to assure no procedural limit was exceeded.

Jobs observed included inspection of a damaged lCl thimble tube and preparations for moving the UGS.

During tours of containment, the inspectors determined that LHRA and a very high radiation area (VHRA) had the appropriate warning signs and were secured.

Additionally, the inspectors identified that low dose waiting areas were appropriately surveyed, identified, and used by personnel.

The inspectors inventoried the keys to LHRAs to determine if the keys were controlled, as required by procedure' The-inspectors discussed with LHRAs and 1."Oiution protection supervision the procedural controls for accessing "ppropii"t"ly VHRAs and determined that no changes have been made to reduce the effectiveness and level of worker Protection.

materials were During tours of containment, the inspectors confirmed that contaminated prop"ity bagged, surveyed/labeled and segregated from work areas.

The inspectors observed workers using contamination monitors to determine if various tools/equipment from the RCA' were potentially contariinated and met criteria for releasing the materials Radioloqical Hazards Control and Work Coveraqe tube' the By observing preparations for inspecting/removing a damaged lCl thimble protective equipment, had inspectors d-eiermined that workers wore the appropriate.

positive control of dosimetry properly located on their bodies, and were under the radio communication was established between the radiation protection personnel.

Clear properly measured and workers and the centralized monitoring system. stay times were of the workers to assure that exposure supervisory personnel controlled the movements was minimized.

Rad iation Worker Performance that workers complied During job performance observations, the inspectors determined radiological conditions at the work site' witfr n:Wp iequirements and were aware of protection technicians were aware Additionally, the inspectors determined that radiation provided positive control of workers of RWp controls/limits applied to various tasks and to reduce the potential oi'unplanned exposure and personnel contaminations' Problem ldentification and Resolution reports, A review of Nuclear Oversight field observation (2R20 outage snapshots)event reports and associated dose/dose rate alarm reports, personnel contamination negative performance cRs, were conducted to determine if identified problems and and to determine trends were enter"d into Dominion's CAP and evaluated for resolution if an observable pattern traceable to a similar cause was evident' and radiological Relevant cRs, associated with radiation protection control access March 2011, were reviewed hazardassessment, initiated between January 2011 and up activities were being and discussed with bominion staff to determine if the follow their safety conducted in an effective and timely manner, commensurate with significance.

b.

Findinos No findings were identified.

2RS0 2 Occupational ALARA Planninq and Controls

a. Inspection Scope

(1 samPle)

During the period April 1 8,2011 through April 21 ,2011, the inspectors performed the following activities to verify that Dominion was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as reasonably achievable (ALARA) for tasks performed during the Unit 2 refueling outage

2R20 . lmplementation of this program was reviewed against the criteria contained in 10

CFR Part 20, applicable industry standards, and with Dominion's procedures' Radioloqical Work Planninq The inspectors reviewed pertinent information regarding site cumulative exposure history, current exposure trends, and exposure challenges for the Unit 2 outage. The inspectors reviewed various 2R20 Outage ALARA Plans.

The inspectors reviewed the exposure status for tasks performed during the Unit 2 outage and compared actual exposure with forecasted estimates contained in various proje-ct ALARA Plans (AP). ln particular, the inspectors evaluated the effectiveness of ALARA controls for alljobs that were estimated to exceed the 5 person rem limit' These jobs included reactor vessel disassembly/reassembly (AP 2-1 1-01), SG lnspections/maintenance (AP 2-11-Og), scaffolding installation/removal (AP 2-11-13)'insulation removal/installation (AP 2-11-14), and radiation protection support activities (AP 2-11-26).

The inspectors reviewed the Work-ln-Progress ALARA reviews for those jobs whose actual dose approached the forecasted estimate. 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 interviewing site staff, reviewing outage Work-in-progress reviews, and reviewing recent Station ALARA Council (SAC) meeting minutes.

tnctuded was a review of the exposure controls for the 'C' reactor coolant pump (RCP)motor and seal replacement, and scaffolding installation.

Verification of Dose Estimates The inspectors reviewed the assumptions and basis for the 2R20 outage ALARA forecasted exposure. The inspectors also reviewed the revisions made to various outage proleci dose estimates due to a reduced source term (i.e., lower dose rates);e.g.,leactor disassembly/reassembly activities, reactor coolant pump maintenance, and SG maintenance.

with The inspectors evaluated the implementation of Dominion procedures associated forecasted monitoring and re-evaluating dose estimates and allocations when the the actual exposure.

lncluded in the review cumulative exposure for tasks exceeded the effectiveness of ALARA measures, were Work-ln-progress reports, that evaluated SAC to subsequently lower dose including source term conirols, and actions by the goals from the original estimates.

the Additionally, the inspectors reviewed the exposures for the.ten workers receiving nigilst Ooses tor ZOll to confirm that no individual exceeded the regulatory limits or performance indicator thresholds.

Source Term Reduction and Control 2 source term' The inspectors reviewed the status and historical trends for the Unit interviews with the Radiation Protection Manager, fniough review of survey maps and measurements and control strategies' tne inJpectors evaluated recent source term up resin' Specifib strategies being employed included use of macro-porous clean permanent/temporary enhanced opeiational chemistry controls, and installation of shielding.

reviewing pre/post-The inspectors reviewed the effectiveness of temporary shielding by rates' installation radiation surveys for selected components having elevated dose placg{ on the reactor head stand, Shielding packages reviewed included those pressuriier spray piping, SG penetrations, and RCP piping' Job Site lnsPections During plant tours, the inspectors assessed the implementation of ALAM controls tube cutting/removal, RCP rG.iri,tO in ALARA Plans and RWPs, for lCl thimble maintenance, and sG tube inspections, performed during 2R20.

from eddy current The inspectors also observed workers performing SG demobilization questioned regarding testing,'lcl inspections, and scaffolding removal. workers were to their in"ii rino*redge of ;oO lite radiologicaiconditions and ALARA measures applied tasks.

Problem ldentification and Resolution the The inspectors reviewed elements of Dominion's cAP related to implementing the program for timely ALARA program to determine if problems were being entered into the effectiveness of the resolution, the comprehensiveness of the cause evaiuation, and challenges' corrective actions. Specifically, CRs related to programmatic dose plrsonnel contaminaiions, doie/dose rate alarms, and the effectiveness in predicting and controlling worker exposure were reviewed' No findings were identified.

2RS03 In-Plant Airborne Radioactivitv Control and Mitiqation (71124'03)

Inspection ScoPe (1 samPle)performed the During the period April 1 8, 2011 through April21,2011, the inspectors followlng activities to verify that in-planl airborne concentrations of radioactive materials protection devices are are bein'g controlled and monitored, and to verify that respiratory properly-selected and used by qualified personnel._lmplementation of these programs

• "s against the criieria contained in 10 CFR Part2Q, applicable industry "uilruted standards, and with Dominion's procedures.

Enqineerinq Controls The inspectors evaluated the use of portable continuous air monitors (AMS-4)and portable HEpA ventilation systems installed in containment during the 2R20 outage' SG The inspectors determined ihat the monitors were located at work locations; e.9.,

contamination could potentially side openings, in containment where airborne primary-The occur.

inspecto'rs reviewed testing records for portable HEPA ventilation systems to determine that procedural performance criteria were met' Respiratorv Protection The The inspectors reviewed the use of respiratory protection devices worn by workers.

inspectors reviewed air sampling records, SG channel head removable contamination to data, RWPS, and Total Effective Dose Equivalent (TEDE) ALARA DAC evaluations with the determine if the use of respiratory protection devices was commensurate wearing these devices.

fotential external dose that may be received when Problem ldentification and Resolution the The inspectors reviewed elements of Dominion's CAP related to implementing entered into the airborne monitoring program to determine if problems w9r9 being the program for timely-resolution, the comprehensiveness of the cause evaluation, and effeitiveness of the corrective actions- Specifically, CRs related to monitoring of challenges, personnel contaminations, dose aSSeSSments, and the reliability monitoring equipment were reviewed.

b.

Findinqs No findings were identified' 2RS04 Occupational Dose Assessment (7 1 124'04)a.

lnsPection ScoPe (1 samPle)performed the During the period April 1 8,2011 through April 21 ,2011, the inspectors followlng activities to verify the accuracy and operability of personal monitoring of equlpmlnt and the effectiveness in determining a worker's TEDE. lmplementation these programs was evaluated against the criteria contained in 10 CFR Part20' applicablJindustry standards, and with Dominion's procedures.

External Dosimetrv by the The inspectors verified that Dominion's dosimetry processor was accredited inspectors verified NationalVoluntary Laboratory Accreditation Program (NVLAP). The with the types and tnat tne approveddosimeter irradiation categories were consistent bi g'" site's source term. The inspectors reviewed Dominion's audit of the "nergi"r contained in the report' dosimetry processor and the areas identified for improvement to address The inspectors confirmed that Dominion has developed "correction factors" th" ,"rponse differences of electronic dosimeters as compared to thermoluminescent dosimeters (TLD).

lnternal Dosimetrv worker dose The inspectors evaluated the equipment and methods used to assess review were bioassay resulting from the uptake of radioactive materials. lncluded in this pio""O,it"t, whole SoOy equipment (FastScan, AccuScan, portal contamination "ounting results for lionitors) calibration checks and operating procedures, and the analytical 10 CFR Part 61 samPles' to distinguish The inspectors determined that the procedural methods include techniques to assess dose internatiy depositeJ radioisotopes from external contamination, methods pathways from hard-to-measure radioisotopes, and methods to distinguish ingestion from inhalation PathwaYs.

to assess the The inspectors reviewed the results from three whole body counts time, background radiation contribution, and the nuclide library adequacy of the "ounting a committed effective used for assessing O"po'rition.' No inioividual exposure exceeded dose equivalent (CEDE) of 10 mrem.

Declared Preqnant Workers for managing The inspectors reviewed the procedural controls, and associated records, DPW5 were employed declared pregnant;oftrt (DPW) and determined that three exposure results and during the Unit 2 outage. The inspectors reviewed the individual moniioring controls to assure compliance with 10 CFR Part20.

Multi-Dosimetrv Methods dose where The inspectors reviewed Dominion's procedures for monitoring external multi-dosimetry methods significant dose gradients exist at thework site. For 2R20, (EDEX) methods.

The were used, insteid of external effective dose equivalent multiple inspectors reviewed the dosimetric results for jobs where workers wore repair, dosimeters. in"t" jobs included SG nozzle installations, fuel transfer equipment the TLDs worn, and diving operations. The inspectors confirmed that in addition to workers also wore electronic dosimeters, equipped with telemetry, to assure that dose technicians in the centralized fields were promply monitored by radiation'protection monitoring station.

Problem ldentification and Resolution the The inspectors reviewed elements of Dominion's CAP related to implementing entered into the program for dosimetry prolr"r to determine if problems-were being of the cause evaluation, and the effectiveness timely reioluti6n, the comprehensiveness

'specifically, of the corrective actions.

CR related to dose assessments, personnel contaminations, and dose/dose rate alarms were reviewed.

b. Findinqs No findings were identified.

2RS05 Q1124'05-1samPle)a. lnsPection ScoPe (1 samPle)23, 2011 through May 26,.2011, the inspectors performed the During the period May-evaluate following activities to the opelability and accuracy of radiation monitoring of these instrumentation used to detect and quantify effluent releases. lmplementation applicable programs was reviewed against the criterii contained in 10 CFR Parl'20, industry standards, and with Dominion's procedures' gaseous monitoring The inspectors walked down selected portions of the liquid and observe systemi installed in Unit 2 and Unit 3 to assess material condition, and determine the status of system upgrades' maintenance/calibration activities, In Unit 2, the walkdown included portions of the following monitors:

Gaseous Effluent Monitors

.

Building Roof Vent Monitor, RM-8132 NB

.

Fuel Handling Building Exhaust, RM-8145 o Radwaste Building Exhaust, RM-8997 o Auxiliary Building Exhaust, RM-8434

.

Stack Monitor - Wide Range, RM-8169 r Waste Gas Tank Monitor, RM-9095

.

Steam Jet Air Ejector Monitor, RM-5099 Liquid Effluent Monitors

.

Clean Liquid Waste Effluent Monitor, RM-9049 o Aerated Liquid Waste Effluent Monitor, RM-9116

.

Steam Generator Blow-down Monitor, RM'4262 o Condensate Receiving Tank Monitor, RM-9327

.

Reactor Building component cooling water Monitor, RM-6038 In Unit 3, the walkdown included portions of the following monitors:

Gaseous Effluent Monitors o Ventilation Vent Monitor, RE-10A/B

.

Supplemental Leak Collection and Release System (SLCRS) Monitor, RE 19A/B o Engineered Safeguards Building Monitor, RE-49 Liquid Effluent Monitors r Turbine Building Sump Monitor, RE-50

. Liquid Waste Effluent Monitor, RE-70 o Waste Neutralization Sump Monitor, RE-07 Calibration and Testinq Proqram Through record reviews, the inspectors confirmed that the effluent monitoring checks and functional instruments were prop"ity calibiated, and that the required source that the effluent monitor tests had been routinely fierformed. The inspectors verified Dose Calculation alarm set points are esiablished in accordance with the Off Site Manual (ODCM).

Part 61) used to The inspectors reviewed contamination sampling results (per 10 CFR to determine if the calibration sources characterize difficult-to-measure radioisotopes, were representative of the radioisotopes found in the plant's source term' Problem ldentification and Resolution various Nuclear The inspectors reviewed selected cRs, system health reports, and threshold for identifying, evaluating, euality Assurance reports to evaluate Dominion's in this instrumentation' lncluded and resolving problems for the radiation monitoring protection technician errors to review were cRs related to radiation worker and ridiation or use of radiation determine if an observable pattern traceable in the maintenance instruments was evident.

b.

Findinos No findings were identified.

2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124'06 - 1 sample)a. Inspection ScoPe (1 samPle)performed the During the period May 23,201 1 through May 26,2011, the inspectors the gaseous and followi"ng activities to verify that Dominion was properly maintaining properly liquid effluent processing iystems to ensure that radiological releases.were lmplementation of mitigated, monitored, an-d evaluated with respect to public exposure' 10 CFR Parts 20 and these controls was reviewed against the criteria contained in the and Offsite Dose Calculation Manual 50, of Dominionls Radiological-Effluent Monitoring (REMODCM), and with Dominion's procedures' Effluent RePort Reviews Release The inspectors reviewed the 2009 and 2010 Annual Radiological Effluent program was implemented as required by the Reports to verify that the effluents of the ground water protection REMODCM. tnbuoeo in this review w:ere the results census, program, the inclusion of Carbon-14 dose contributions, the current land use 2 and unit 3 gaseous and verification that no significant changes were made to the Unit Safety Analysis Report and liquid release systern-configurationi, as specified in the Final (FSAR) and ODCM descriPtions.

Walkdowns and Observations Unit 3 gaseous The inspectors walked down the major componentsof the unit 2 and complied with the FSAR and liquid r"f""r" ryriems, to verify the system. configurations description, and to evaluate equipment material condition.

and gaseous effluent The inspectors reviewed the most current Unit 2 and Unit 3 liquid test results and 18-month calibration monitor monthly source checks, quarterly functional pumps/isolation valves or records to verify ihat instrumentaiion and associated fans/isolation dampers, respectively, were operable' results for the HEPA The inspectors reviewed the air cleaning systems surveillance test and charcoalfiltration systems installed in Unit 2 and Unit 3' The inspectors confirmed values and the filtration system met that the air flow rates were consistent with the FSAR the accePtance criteria.

Samplinq and Analvsis (SP) and observed The inspectors reviewed the relevant surveillance procedures iodine samples.

Airborne-particulate technicians cottecting weekly air particulate and Stack monitor (RM-8169), using and iodine t"*pf"r i,ere taften fiom the Main Station monitor Sp-2g15. Samples were taken from the Unit2 Enclosure Building roof vent (RM-81 32), using SP-281 44.

determined that During the walkdowns of effluent monitoring systems, the inspectors for monitors that were appro-priate compensatory sampling measurei were implemented measures were in removed from service for maintenance or calibration. compensatory (HVR-19)'ptace for the U-2 Ventilation Vent monitor (RM-8132), Unit 3 SCLRS monitor and Unit 3 Liquid Waste monitor (LWS-RE-70)'

(blind The inspectors reviewed the results of Dominion's inter-laboratory comparison performed by sample) program to verify the accuracy of effluent sample analysis Dominion.

Dose Calculations projections for liquid and The inspectors reviewed monthly, quarterly, and annual dose gaseous effluents performed duiing the past 12 m-o1tlr9-to verify that the effluent was firocesseO and released in accordance with REMODCM requirements and to ensure that The inspectors the licensee properly calculated the offsite dose from effluent releases.

I to 10 CFR 50)confirmed that no p"rforr"n"e indicator (criteria contained in Appendix was exceeded for these releases.

3 to evaluate the The inspectors reviewed liquid discharge permits for Unit.2 and Unit of the documented adequacy of dilution flow, radioactive c-onient, and overall accuracy data.

Ground Water Protection Proqram voluntary Nuclear The inspectors verified that Dominion is continuing to implement the The inspectors reviewed Energy Institute/lndustry Ground water Protection Initiative.

regor!9 (maintained monitoring wett sampie?esutts, trending data, and decommissioning off normal per 10 CfYn SO.ZS tdll to evaluate procLdural compliance and to identify results.

Problem ldentification and Resolution Nuclear Quality The inspectors reviewed selected CRs, system heal-th reports, and evaluating, and Assurance audits to evaluate Dominion'sihreshold for identifying, resolving problems regarding effluent treatment and monitoring.

b. Findinos No findings were identified.

OTHER ACTIVITIES

[oAl

4OA1 Performance Indicator (Pl) \lbrification

Cornerstone: lnitiatinq Events

a.

InsPection ScoPe to verify the The inspectors reviewed Dominion submittals for the Pls listed below and guidance accuracy of ine data reported during that period T.h" Pl definitions "Regulatory Assessment Indicator contained in Nuclear Energy Instituie (NEi) 99-02, each data element' Guideline,', Revision 5, were used to v'erify the basis for reporting portions of the operations logs, monthly ope.rating reports,.and The inspectors reviewed (Lfn) and discussed the methods for compiling and reporting Licensee Euent Reports the Pls with cognizant licensing and engineering personnel.

Unit2

.

Unplanned Scrams per 7000 Critical Hours; o Unplanned Scrams with Complications;

.

Unplanned Transients per 7000 Critical Hours; Unit 3 o Unplanned Scrams per 7000 Critical Hours; o Unplanned Scrams with Complications; and

.

Unplanned Transients per 7000 Critical Hours' b.

Findinqs No findings were identified.

4OA2 tdentification and Resolution of Problems

.1 a.

lnspection ScoPe Resolution of Problems,"

As required by lnspection procedu re 71152, "ldentification and specific human performance and in order to hetp identify repetitive equipment failures or of items entered into issues for follow-up, the inspectors performed a daily screening by reviewing the Dominion's corrective action program. This was accomplished review committee description of each new CR and attending daily management meetings.

b.

Findinqs No findings were identified.

.2 a. Inspection ScoPe (1 samPle)

to the cross-cutting The inspectors reviewed Dominion's current performance relevant Licensee Decisions aspect,'1H.1 (b)l Human Performance, Decision Making.

Dominion uses demonstrate that nuclear safety is an overriding priority, and making and adopts a requirement to demonstrate conservative assumptions in decision pioceed, rather.than a requirement to Gt tn" proposed action is safe in order to action' Dominion conducts demonstrate that it is unsafe in order to disapprove the the validity.of the underlying effectiveness reviews of safety-significant decisions to verify determines how to asiumptions, identifies possible ulintended consequences, and ROP findings with this improve future decisions. Millstone was noted to have three period. The inspectors reviewed associated .ror.-"uttinj aspect in the last assessment observations of staff related cRs, interviewed staff personnel, conducted behavioral sessions^, and developed a case study interactions during several meetings and training 20, 2011' of Dominion's response to the Uni[ Z reactor trip on June b. Findinqs and Observations No findings were identified' trend in the cross-cutting The inspectors determined that Dominion had identified the

) a common cause aspect iH. r tOlt in their CAP (CR4031 1 1 DoTilg! l3!.gonducted and concluded that "no evatuation of the crois-cutting area tH.1ib)l (ccE000164)

Assumptions and Safe common cause, most prevalent cause tdfateb to Conservative The inspectors noted that' Actions was derived frbm the review of these three events."

one finding with a cross-cutting at the end of tne cuirent quarter, Dominion will have only two of the findings are no longer current aspect tH.1(b)l in tnis rep6rting period because a cross-cutting aspect' The and no additionaltinOinSjs hav6 assigned H'1(b)]as was somewhat narrowly inspectors reviewed cc"eooot64 and noteo tnaiinis evaruation concluded that there was no focused on the tnree inoividual findings. while Dominion and determined there was common cause, tney Oroadened the icope of this evaluation some aspect of inadequate a common theme ,"ro$ the three events that included this worker knowledge uppropriate risk recognition. -Th.ey subsequently addressed "no for the three findings (CA170523' common theme by implementing corrective ictions specific issues' cA183044 and CAtoisezl by c-onducting training on the 2 reactor trip that occurred on The inspectors followed Dominion's response to the unit of the Millstone June 20, 2011, as a real time case study in the effectiveness immediately prepared CRs that conservative decision making process. Dominion procedural issues addressed the human performance errors (CR431574 RCE),issues (CR432012) and is presently conducting a root tCi+af 722) andsimulator fidelity inspectors

."ur" evaluation (RCE) of the event. Prior to restarting the reactor, the prior to restart, just-observed a management meeting to implement procedural changes r+i*" training llifl for the crew supporting the restart, and the lessons learned the event for the iraining on criilcat paiameter monitoring (CR431936) conducted after demonstrated an remediation of all shifts. These activities observed in this case study parameter monitoring by appropriate emphasis on conservative decision making, critical In addition, the inspectors observed ob"ruiorr and a tocus on operator fundamentals.

Manager that reemphasized the Supervisor Leadership Training conducted by the Plant supervisors' This safety culture aspects, expectitions and responsibilities of front line on this sample, it included lessons learned irom the response to this event. Based the implications of the trend in the cross-cutting that Dominion has recognized "pp"rrrtH.itOlt. Current efforts to address this aspect are in progress within the

1. i has been completed, Dominion cAP and will be assessed in the future after the RCE prevent recurrence have been and when lessons learned and corrective actions to formulated and imPlemented'

.3 lnspection ScoPe (1 samPle)

to the cross-cutting The inspectors reviewed Dominion's current performance relevant Program' asject ip.t(r)l' Problem ldentification and Resolution, Corrective Action promptly are Dominion ensures that issues potentially impacting nuclear safety are takbn to address safety issues in a timely iO"ntiti"O, fully evaluated, and tfrat actiohs manner, *it their significance. Dominion implements their cAP with a "orr"n"u13t" low threshold for identifying issues. bominion identifies such issues completely, significance' At the accurately, and in a timely manner commensurate with their safety to have three ROP end of the last ROp issessment period, Dominion was noted of the current quarter' findings with this associated cross-cutting aspect and at the end a cross-cutting aspect Dominion will continue to have the samelhree findings with no additionalfindings have been added and tp.1(a)l in this assessment period because quarters' The inspectors in" thi"" original findings occurred within the past four behavioral observations of reviewed related cni, interviewed staff personnel, conducted and developed a case staff interactions ouring several meetings and training sessions, 2011'

i;ey of Dominion', 1."iponte to the unit z reactor trip on June 20, b.

Findinqs and Observations No findings were identified.

fully evaluating The inspectors assessed Dominion's response to the area of identifying, that

,no sateiy Lir"t in a timely manner. The inspectors determined "oor"rsing aspect P'1(a) and Dominion had identified a trend in the safety culture cross-cutting properly evaluated and closed had concluded that the three ROP findings had been inJiviOuatty. Dominion did not perform a common cause assessment for the cross-u;pect [p.1(a)]. During this ROP inspection period, no additionalfindings were "rtti^g identified that involved [P'1 (a)].

lnterviews with Dominion managers indicated that Millstone was planning to further by making address the broader issue of coirective action program effectiveness of their apparent cause irprou"r"nts to their cAP including improving th_e_-quality of evaluations (ACE) and root cause e-valuations (ncr); sJrengthening the effectiveness AcEs and the corrective Action Review Board (CARB); initiating cRs for all rejected for CARB nCfr; and enhancing the minimum iequired qualifications and training lower level CR evaluations members. They alsJwere planning to conduct a sampling of and reducing the extension of corrective to determine if they were missing key trends considered based on the results of the action due dates. other corrective actions will be presently_in progress' The inspectors common cause assessment for this trend that is every year and the noted that Millstone staff initiates a substantial volume of CRs low' There appeared to be threshold for preparing a CR appeared to be appropriately at Millstone.

litile reluctance to oraiting a cR'by the vast majority of the staff trip that occurred on The inspectors followed Dominion's response to the Unit 2 reactor of the Millstone corrective June 20, 2011,as a real time case study in the eff_ectiveness the human action pio""r". Dominion immediately prepared CRs thataddressed and simulator performance errors lCAnySl+ RCE); proceduralissues (CR431722)of the event' Prior to ilO"tity issues CR)01 2, and is presently conducting a RCE meeting to implement restarting tne reactoi, the inspectors observed a management procedural cnanges prior to restart, just-in-time training (JITT) for the crew supporting parameter monitoring conducted the restart, and the lessons learned training on critical of an appropriate threshold after the event for all shifts. These activitiei demonstrated and effective proor"rn identification, an ability to promptly resolve adverse conditions corrective action lmplementation in'responle to this e.vell In addition, the inspectors Plant Manager that observed Supervisor Leadership Training conducted by the responsibilities of front line reemphasized the safety culture aspectsl expectations and to this event' Based on this supervisors that included lessons learned from the response implications of the cross-cutting sample, it appears that Dominion has recognized the Current efforts to address [his theme are in progress and will be tfr"ry1" ip f tilt and corrective actions to assessed in the future after the RCE has been completed prevent recurrence have been implemented'

.4 a.

Inspection ScoPe (1 samPle)progress in The semi-annual trend review's focus was to determine Dominion's corrective action trend correcting negative trends. The inspectors reviewed Dominion's

f;tn"i" quarter 2010 and selected the work management trend-s for review' focus area for over a year' Work management was selected because it has been a site CA173666, CA177780' rne inspect6rs reviewed corrective action assignments ACE 018411' cA177781, and all corrective action assignments from apparent cause several maintenance and planning ih" in.p""tors reviewed the trends and interviewed the issue personnel in order to determine if the corrective action assignment matched and if the corrective actions completely addressed the issue.

b. Assessments and Observations No findings were identified.

in meeting The overall goal of the corrective actions was to address negative trends backlog management' The work management milestones, work order readiness, and has been inspectors ietermined that since February 2011, overall work management between improving. Total backlog per unit has been reduced from 3946 to 3771 and non critical PMs deferred per rolllnO quarter have i"'Orru.iund May 2Ol1: britical oroppeo tro m 24 and 23 respectively in July 2010, to 6 and 0 in May 2011' T4 scope percent for several months' staOiiity has been consistenily at approximately 90 or contractor use will be Dominion has started looking out to T16 to determine if overtime positive, as iefuireO to complete the necessary work. Not all trends have been grace n-er!o{!1ve steadily annualized critical and non critical PMs performed late in the to 31'6 percent increased from 24 percent and 26.5 percent respectively in July 2010, and 34.3 Percent in MaY 2011.

before the work was The inspectors identified that one corrective action was closed out CA173OOO was to evaluate the gap to excellence in schedule adherence' "orpf"i"O.

to plan and complete The work completed was a draft plan to efficiently use resources plans. The assignment was work. The drait plan has several tasks to implement other lt appears closed out without any documentation that the plan had been implemented.

g'ui i6" plan is Oeing'impremented, but the details are not captured under that corrective could not completely verify action. There was one corrective action that the inspectors the work orders removed from iti compretion. CA18b7g0's assignment was to address was closed assignment schedule because tf'"V OiO not miet the milestones. This primarily because of T4 scope stability and implementation week adherence greater than 90 percent.

4OA3 Event Follow-up (71153

- 2 samples)

.1 Dislodqed Bushinos

a. Inspection ScoPe (EPF? negative on April 3,2011, Millstone lJnit2 Enclosure Building Filtration system 4' in Mode pr"$rr" test results failed to meet acceptance criteria while the unit was Building failed its making the Enclosuie Building inoperabie. Since the Enclosure radioactive material could surveillance test, its safety fuiction to control the release of failure was that the sliding not be assured. Dominion determined that the cause for the piping had become stuck and bushings on the main steam safety valve (MSSV) exhaust were not seated ProPerlY.

b. Findinqs B, Criterion XVl, lntroduction: A self-revealing Green NCV of 10 CFR 50, Appendix

,,Corrective Action," was ideritified for Dominion's failure to take prompt corrective action which resulted in a to address the cause of MSSV exhaust pipe bushings not seating, the release of radioactive loss of the Enclosure Building's safety function to control exhaust pipe, and also material. Dominion has since cleaned and lubricated the MSSV qualify and it as part of the implemented a modification to upgrade the MSSV outlet boot Building filtration boundary' plant cool-down in Djscription: on April 3,2011, Millstone Unit 2 was performing a data iat<en on the EBFS test while in Mode 4 indicated that it had not Mode b when the function to control the met its acceptance criteria. The Enclosure Building's safety Dominion determined release of radioactive material could therefore not be assured.

pipe bushings not being- seated that the cause of the failure was eight MSSV exhaust performed properly because they had becomi $uck on the exhaust pipe' Dominion a successful retest on cleaning and lubrication of the MSSV exhaust pipe and.performed test in July 2009 April 26, 2011. The Enclosure Building had also t?19d. its surveillance that the investigation delermined when two MSSV bushings had not seaied. The 2009 a result of the July 3' 2009 lifting of the relief valveJassociated with these bushings as stuck' The iiip n'"0 caused the bushings to slide up the exhaust pipe and become performed' bushings were reseated and a successful retest was a new procedure one of the corrective actions from the 2009 root cause was to develop include lifting of Details were to for the inspection and cleaning of the sliding bushings.

for clearances and the bushing, and to provide necessary tooling and criteria of MSSVs Sliding cfeanliness. proced'ur)e MP27O2F1 0A, "Cleaning and lnspection performed on the Bushings," *". uppioulJ in Nou"tber 2009. However, the work prior to the approval of bushings *", .orii"t"O in October 2009, which occurred sliding bushings p.."0-ur" MZ27O)F10A. As a result, the work orders for the sixteenorders only stated' The work did not contain Oetaifslor properly cleaning the bushings'.

,,verify that the sliding bushing is free to slile on vent siack without excessive binding in not seated, only accordance with MF 2701J-114." Far the eight bushings that were bushing was three of the work orders' comments stated that cleaning of the sliding performed. Dominion's apparent cause evaluation from the April 2011 failure stated that corrective actions from root a contributing cause was,"iineffective implementation of approach may have cause RCE000984; inadequate/inconsisient maintenance cleaning resulted in MSSV sliding bushings hanging up'"

action to clean Analvsis: The inspectors determined the failure to take prompt corrective performance deficiency that was reasonably the sliding bushings in October 2009 was a have been prevented' within Diminion's aOitity to foresee and correct, and should safety consequences' Traditional enforcement doet not apply since there were no actual willful aspects of the impacts on the NRC',s ability to perform its regulatory function, or finding.

Procedure Quality The finding was more than minor because it was associated with the the cornerstone objective to attribute of the garrier Integrity cornerstone and affected protect the public from prouio" reasonable assura-nce that physical design barriers the failure of the radionuclide releases caused by accidents or events. specifically, its surveillance test, and MSSV sliding busninls to seat property caused the EBFS to fail not be assured' its safety function to iontrol the release of radioactive material could in accordance with NRC Inspection The inspectors conducted a Phase 1 screening Manual'chapter (lMC) Attachment 0609.04, "Phase 1 - Initial screening and safety was of very.low Characterization of FinOingt," and determined that the finding of the radiological barrier significance (Green) O"""ir" it only represents a degradation function provided for the auxiliary building' in the Problem The inspectors determined that this finding had a cross-cutting aspect Action Program component, ldentification and Resolution cross-cutting area, corrective action to address the because Dominion did not take appropriale or timely corrective Building surveillance test failure in 2009. tP.1(d)l "corrective Action," states, in part'

Enforcement:

10 cFR 50, Appendix B, Criterion XVl, to quality, such as that measures shall be established to assure that conditions adverse equipment' failures, malfunctions, deficiencies, deviations, and defective materialand corrected' Contrary to the above' and non-contormances are prompily identified and prompt corrective action to from October 2009 until April 2011, Dominion failed to take properly, which address the cause of the trrtssv exhaust pipe bushings not seating of its safety function on caused the inoperability of the Enclosure'Building and a loss the MSSV exhaust April 3, 2011. Dominion took corrective action to clean and lubricate boot and qualify it pipe and also implemented a modification to upgrade the MSSV outlet ld- part of the Enclosure Building filtration boundary. Because this violation was of very CAP (CR420485), this violation low safety significance and was entered into Domihion's Policy' (NCV is being treated as an NCV, consistent with the NRC's Enforcement in Loss of Enclosure 0500336/2011003-03 lnadequate Gorrective Action Results Building's SafetY Function.)

.2 a. lnspection ScoPe

trip on low steam On June 20,2Q11, at 1 1:52 a.m., Unit 2 experienced an automatic feedwater flow geneiator level. The low steam generator level was caused by a loss of when the 'B, steam generator feedwater pump (SGFP) tripped on low suction pressure

'A' SGFP on-line' while the operators irere in the process of bringing the adequacy of operator The inspectors responded to the control room and evaluated the actions in accordance with approved procedures and TS requirements. The-inspectors that the p"trom"o a walkdown of the control room and interviewed personnel to verifypost trip ffi;i;"r stable. The inspectors also reviewed the sequence of events and other plant or equipment anomalies' review report in order to d'etermine if there were any power ascension The inspectors observed the reactor startup and portions of the reviewed CRs to ensure inciuOin'g the starting of the second SGFP. The inspectors conditions adverse io quality associated with this event were entered into Dominion's corrective action program for resolution' b.

Findinqs (Green) was lntroduction: A self-revealing finding (FlN) of very low_safetY significance "Load Changes," when identified for Dominion's failure to follow proceduie OP 2204, starting the 'A' SGFF. Specifically, the operating crew failed to maintain adequate SGFP

'A' SGFP, which led to a trip suction pressure (greatei than 32-5 psig) while starting the low steam generator level' of the 'B' SGFP and subsequent reactoi trip on power to 30 percent to repair

Description:

On June 20,2A11, Millstone Unit 2 reduced an oil leak on the'c' reactor coolant pump (RCP) moto-r, following the repairs, Millstone

'B' SGFP feeding the steam Unit 2 began increising power to 59'percent with the

'A' SGFP pump on-line when generators. operatorjwere in the process of bringing the outside of the operating feed regutating varve irnVloitr"t"ntial pressure t+] oecreased

'g' SGpP speed to increase FRV dp' The band. The operator tnen incorrectly lowered

'B' SGFP speed back to its operator did not get the desired response, and increased 'A' to bring the SGFP in order original value. The operator then increased the speed of pump decreased feed the pump on-line to feed the steam generators. This action to trip on low suction pressure' The resulting suction pressure and caused the'B;SGFP generator level at 11:52 a'm' loss of feedwater flow caused a reactor trip on low steam operator actions.were not Dominion's post trip review identified some instances where "When placing the second as expected. OP iZOq,"Load Changes", step 4'121-tj3l9t' as needed to SGFp in service, fHnOfff-E open dtttM-2,';CONO DEMIN BYP,"

psig (C-05)'" CNM-? was not maintain both SGFp suction pressures greater than 325 pressure was not maintained throttled open by the operating crew unJ SCrp suction SGFP suction pressure dropped above 325 psig, noi*ut it ad6quately monitored.

'B' SGFP suction pressure low below 325 psig at 11:44a.m., and at 11:50 a.m. the crew alarm came in at 260 psig on the plant process computer (PPC). The operating took no corrective action in response to the alarm' procedure OP ln addition, the post trip review also identified that recent revisions to percent reactor power 22e4, which delayed the start of the heater drain pumps until 70 and increased the reactor power band for starting a second SGFP from 45 percent - 50 percent to 45 percent - 65 percent, may not have been appropriate.

the The inspectors noted that oP 2321, "Main Feedwater system," which contains procedure for starting a second SGFP, does not mention monitoring SGFP suction pressure. lt only staies in the initial steps, "Verify the following: Condensatg header noted that JITT for the fr"rrur" greater than 425 psig (C-05).'; The inspectors alsobecause other power power asJension did not include starting the second q9FP, ascension evolutions, such as synchronizing to the grid, were deemed to be more difficult.

Analysis:

The inspectors determined the failure to adequately monitor and take psig was a correctVe action when SGFP suction pressure dropped below 325 performance deficiency that was reasonably within Dominion's ability to foresee and does not apply since correct, and should have been prevented. Traditional enforcement ability to perform its there were no actual safety consequences, impacts on the NRC's regulatory function, or willful aspects of the finding' Chapter The finding is more than minor because it is similar to NRC Inspection Manual "Examples of Minor lssues," Example 4b; in that, a failure to follow O612,App-endix E, procedure led to a reactor trip. This issue is associated with the Human Performance objective to attribute of the Initiating Events cornerstone and affected the cornerstone critical safety limit the likelihood of thlse events that upset plant stability and challenge of the functions during shutdown as well as power operations. Specifically, the failure operators to properly monitor SGFP suction pressure led to a loss of adequate 1 screening in feedwater flow and a reactor trip. The inspectors conducted a Phase (lMC) Attachment 0609'04, "Phase 1 accordance with NRC Inspection Manual Chapter Chara cterization of Findings ," and determined that the finding

- lnitial Screening and significance (Green) because it did not contribute to both the was of very low *ut"ty functions would likelihood of a react,oitrid and the likelihood that mitigation equipment or not be available.

Human The inspectors determined that this finding had a cross-cutting aspect 'l thg component, because Dominion Performance cross-cutting area, Work Practices personnel did not properly follow the load changes procedure' tH.4(b)l no regulatory

Enforcement:

This finding does not involve enforcement action because requ-rcment waiidentified. Dominion entered this issue into their corrective "iolation safe operating action program (CR431 574); conducted training exercises emphasizing actions to take to restore margin if plant envelopesl critical parameters to monitor, and finding does not conditions degrade; and has revised procedure oP 2204.

Because this significance, it is involve a violation of regulatory requiiements and has very low safety identified as a finding. (FlN 05000336/2011003'04 Failure to Follow Procedure for Starting a Second SCfp Results in Reactor Trip)4045 Other Activities

.1 licensee to assess its

The inspectors assessed the activities and actions taken by the nuclear plant fuel readiness to respond to an event simirar to the Fukushima Daiichi capability to mitigate orrug" event. This included

(1) an assessment of the licensee's with a particular emphasis conditions that may result from beyond design basis events, by NRC Security Order Section on strategies retated to the spent flel pool, Js required severe accident management 8.5.b issued February 25,2dQ2, as committed to in assessment of the licensee's guidetines, and as re6uir"O by 19 CFR-50.54(hh);

(2) an as required by 10 CFR 50'63 capability to mitigate ,t"ttn blackout (SBO) conbitions, capability to mitigate and station design bases;

(3) an assessment of the licensee's internal and externalflooding events, as required by station design bases; and

(4) an inspections of important assessment of the tfrorougniess of the walkdowns and needed io titli"t" fire and flood events, which were performed by the "qripr"nt equipment during seismic events licensee to identify any piential loss of function of this possible for the site.

1320660) documented detailed Inspection Report 05000245,3 36,42312011009 (ML1 1 results of this inspection activity'

.2 severe accident

on May 13, 2011, the inspeCtOrS completed a review of the licensee's implemented as a voluntary industry initiative in the management guioetinerlbnMc.l, and updated,

(2) whether 1990,s, to determine tij ivr,etn"r ii'" SAMGs were available place to control and update its the licensee had pro"Ldrr", and processes in -SAMGS' personnel on the use of SAMGs'

(3) the nature and extent of the licensee's training of and(4)licenseepersonnel'sfamiIiaritywithSAMGimplementation.

force chartered by the The results of this review were provided to the NRC task evaluation of the need for Executive Director for operations to conduct a near-term agency actions rorrowing thefukushima Daiichi fuel damage event in Japan' Plant-providc'c1 in an Attachment to a

"iii6 resutts for Millsione Power Station were of Inspection and memorandum to the Chief, Reactor Inspection Bianch,.Division negionat Support, dated May 27,2011 (ML111470361)'4046 Meetinqs. includinq Exit Exit Meetinq Summarv On August 1, 2011 , 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.

ATTACH MENT: SU PPLEMENTAL INFORMATION SUPPLEMENTAL IN FORMATION KEY POINTS OF CONTACT Dominion personnel R. Arquaro U3 Shift Manager L. Armstrong Manager, Training G. Auria Nuclear Chemistry SuPervisor B. Barron Manager, Nuclear Oversight B. Bartron Supervisor, Licensing C. Chapin Assistant OPerations Manager W. Chestnut Supervisor, Nuclear Shift Operations Unit 2 F. Cietek Nuclear Engineer, PRA T. Cleary Licensing Engineer G. Closius Licensing Engineer L. Crone Supervisor, Nuclear Chemistry J. Curling Manager, Protection Services J. Dorosky Health PhYsicist lll M. Finnegan Supervisor, Health PhYsics, ISFSI J. Gauvin Unit 3 ChemistrY Technician A. Gharakhanian Nuclear Engineer lll M. Gobeli Shift Technical Advisor W. Gorman Supervisor, lnstrumentation & Control J. Grogan Assistant OPerations Manager K. Grover Manager, Nuclear OPerations C. Houska l&C Technician A. Jordan Site Vice President J. Kunze Supervisor, Nuclear Operations -Suppgrt J. Laine Manager, Radiation Protection/Chemistry R. MacManus Direct6r, Nuclear Station Safety & Licensing G. Marshall Manager, Outage and Planning M. Martel U3 Shift Manager C. Rheims l&C Engineer R. Riley Supervlsor, Nuclear Shift Operations Unit 3 M. Roche Senior Nuclear Chemistry Technician L. Salyards Licensing, Nuclear Technology Specialist M. Sartain Director, Nuclear Engineering J. Semancik Plant Manager A. Smith Asset Management D. Smith Manager, EmergencY PreParedness S. Smith Manager, Engineering J. Stoddard Unit 3 Shift Manager R. Sturgis Secondary Systems Engineering Supervisor M. Socha Unit 3 Work Control SRO S. Turowski Supervisor, Health Physics Technical Services C. Vournazos lT Specialist, Meteorological Data P. Zahn Operations SuPPort SPecialist LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 0500042312011003-01 NCV Failure to Take Timely Corrective Actions for De-alloying of Aluminum Bronze Service Water Valves (Section 1R15)05000336/2011003-02 NCV Untimely Corrective Action for Safety Related lnverters Leads to Repetitive Out of Calibration Results (Section 1R22)05000336/201 1 003-03 NCV Inadequate Corrective Action Results in Loss of Enclosure Building's Safety Function (Section 4OA3)05000336/201 1 003-04 FIN Failure to Follow Procedure for Starting a Second SGFP Results in Reactor Trip (Section 4OA3)

Closed 05000336/2011-001 LER Enclosure Building Rendered Inoperable Due to Dislodged Bushings 05000245, 336,4231 251 5/1 83 Tl Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5.1)05000336,423125151184 Tl Availability and Readiness Inspection of Severe Accident Management Guidelines (Section 40 A5.2)

LIST OF

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

@inds and High Tides," Revision 010-05

AOP 3569, "severe Weather Conditions," Revision 016-00

,,Response to ISO New England/CONVEX Notifications and Alerts," Revision 004-

C Op 200.g,

ISO New England OP 4, "Action during a Capacity Deficiency," Revision 10.

ISO New England M/LCC 5, "proceduie for Millstone Point Station Generation Reduction,"

Revision 10

SP 2665, "Building Flood Gate Inspections," Revision 005-02

System Health RJport, NSST, RSST and Main Transformer, 1"'Quarter 2011

System Health Report, 345KV Switchyard, 1"'Quarter 2011

System Health Report, Unit 2 and Unit 3 Doors and Barriers, 1"'Quarter 2011

M2 99 13754

53102268158 53102410975

53102355714 53102410976

53102410971 53102410977

53102410973

cR412032

cR381899 cR412033

cR381901 cR412035

cR412022 cR412036

cR412023 cR420060

cR412024 cR420238

cR412026 cR420239

cR412028 cR420495

Section 1R04: EquiPment Aliqnment

9E for FacilitY 1 on APril 3,2O11"

Maintenance Rule Scoping Tables for Enclosure Building Filtration

OP 2301B, "SDC/SFPC Core Off-Loaded," Revision 000-05

oP 2308-002, "HPSI System Valve Alignment, Facility 2," Revision 000-04

Op 2314G-001, "Enclosure Building Filtration System Alignment," Revision 012-01

oP 3308, "Train'A' High Pressure safety Injection," Revision 004-06

system Health Report Enclosure Building Filtration,J " quarter 201 1

,',piping and Instrr.rmentation Diagram containment and Enclosure

203-2602g Sheet 5,

Building Ventilation," Revision 36

203-26015 Sheet 1, "piping & Instrumentation Diagram L.P. Safety Injection

system,"

Revision 37

Cooling & Cleanup

203-26023 Sheet 2, "Piping & Instrumentation Diagram Spent Fuel Pool

System," Revision 30

MREo10817 MREO10952

MREo10866 MRE01 1396

MREo10875 MRE011510

MREo10883 MREO13253

MREO10886 MREO13468

MRE013497 MRE013572

MRE013505 MRE013653

MREO1 3571

Section 1R05: Fire Protection

mstoneUnit2,FireHazardsAnalysis,Revision11

Millstone Unit 2 Firefighting Strategies, April2002

Brigade Drill and Assessment for Unit 2 East Cable Vault

Section 1R08: ln'Service Inspection

Miscellaneous

r.rp, rnc. Engineering Information Record, No. 51-91521 16-000,

"Millstone Unit 2 - 2R2o

n""-r,

ECT Inspection Plan

M2-EV-11-001, Revision 0, "Millstone Unit 2 Steam Generator I ntegritY Degradation

Assessment (2R20)"

Weldinq Packaqe

SA4A-123, Reftion 0, "safety Requirements for Welding, Cutting and Brazin-g"

Wo s31 o23g2sss, "SWLB - Modification of Service Water Spt 60469 - DM2-00, 01-0132110

CMP 701.01, Revision 002-04, "Pre-Job Checklist"

SA-AA-1 1 0, Attachm ent 2, "Job Hazard Assessment"

WM-AA-3O1, Attachment '14, "High Contingency Plan Actions"

Procedures

re"

ER4A-N DE-UT-7O 1, Revision 4, "U ltrasonic Thickness Measurement Proced u

CM-AA-FPA-101, Revision 3, "Control of Combustible and Flammable Materials"

Fleet

ER-AA-RRM-100, Revision 2, "ASME Section Xl Repair/Replacement Program

lmplementation Req uirements"

gi-nn-XOE-\rr-G03, Revision 3, "VT-3 Visual Examination Procedure"

MA-AA-101, Revision 5, "Fleet Lifting and Material Handling"

"supplemental Personnel"

MA-AA-1001, Revision 4,iVisual

Mp-VE-g, Revision 001, Weld Acceptance Criteria for Weldments and Brazed

Joints"

SA-AA-107, Revision 0, "Fall Protection"

SA-AA-108, Revision 0, "Hand and Portable Power Tool safety"

SA-AA-111, Revision 0, "Ladder Safety"

SA-AA-1 18, Revision 2, "Personal Protective Equipment"

SA-AA-119, Revision 2, "safety Signs and Barriers"

SA-AA-123, Revision 0, "Welding, Cutting , and Brazing Safety"

Drawinqs

2003-22200, sH 60469G

tvtpZ eSt 1301A, "Evaluated Simulator Exam"

LORT SE 16, Revision 4

Section 1Rl2: Maintenance Effectiveness

gPumpMotor,ElectricMotor&ContractingCo.,

lnc.

Maintenance Rule Scoping Tables, Charging, Letdown and Boric Acid

quarter 2011

System Health Report,'Chirging, Letdown and Boric Acid, 1"t Quarter 2010 and 1"

MREO10523 MRE01 1 21 7

MREO1 081 7 MREO11377

MREo10827 MRE012159

MREO10852 MREo12314

MREO1091 1 MREo12382

MREO109',l2 MREo12902

MREo10933 MREO13587

MREo10954 MREO13664

MRE011216 MREo13670

Alternateetantcon@ting2-RC-252,pressurizerspraylineisolation Bronze

ETE-Mp-2011-0090, "Structural Integrity Evaluation for MPS3 Dealloyed Aluminum

Valves," Revision 0, dated May 26,2Q11

Millstone Unit 2 & Millstone Unit 3, 2R2O Switchyard Work Risk Management Plan, Revision

1,

March 31, 2011

Millstone Unit 2 Shutdown Safety Assessment (SSA) Checklist April 5, 2011, April7 ,2011

Millstone Unit 2 High Risk Evolution Plan for the 1't Reduction in RCS Inventory

Millstone Unit 3 EOOS Operator's Risk Report, April 14,2011

OP-AA-1 500, "Operational Configuration Control," Revision 5

OP 2301E, "Draining the RCS (ICCE)," Revision O24-O7

OU-M-200, "shutdown Risk Management," Revision 2

ou-M2-201, "shutdown safety Assessment checklist," Revision 1

Pre-2R2Q Shutdown Risk Schedule Review

shutdown Risk contingency Plan Replacement of 2-SW-97B - Orange

Sp 344681 2,"Train 'B;Soli-d State Protection System Operational Test," Revision 012-04

ESI-TP-3 96000049, "345 KV System," Revision 1

cR421347

cR422907

cR422915

cR428600

cR428654

cR428658

wo 53102440496

wo 53102273422

Section 1R15: Operabilitv Evaluations

AOP{551 "Reactor Coolant System Leak," Revision A17-O2

EOP-3505, "Loss of Shutdown booling and/or RCS lnventory," Revision 10-03

EOP-ECA- 1.2, "LOCA Outside of Containment," Revision 008

RAS 000176, "Justification for TCOA to Secure RCPs," Revision 0 dated April4,2011

NRC Memo from John Hannon to Sunil Weerakkody, "subject: Resolution of Questions

2005

concerning Compliance with Section lll.L.2 of Appendix'R"'dated February 10'

ETE-Mp-tg11-0090, "structural Integrity Evaluation for Millstone Unit 3 Dealloyed Aluminum

Bronze Valves," Revision 0 dated May 26,2011

1OD000173, "Millstone Unit 3 Service Water Valves Dealloying Conditior," dated May

28,2011

,,Fire

CR41}T23, Shutdown Analysis Time Critical Operator Action (TCOA) to secure RCPs"

dated March 28,2011

cR428600

cR428654

cR428658

Section 1Rl8: Plant Modifications

@m SafetyValve Vent Piping," Revision 4

203-20150, "Main Steam Relief Valve Discharge to Atmosphere," Revision 9

53102364164

531 023641 65

531 023641 66

531 023641 69

531 02379998

Section 1R19: Post Maintenance Te,stinq

@ry Quarterly Inspection," Revision 001-04

OP 2346C-002, "'B' DG Data Sheet," Revision 001-06

SP 2411A, "CEA Motion Inhibit Verification (deviation)," Revision 002-04

SP 2411B, "PDIL Alarm Verification," Revision 000-04

sP 2613J-001, "'B'Emergency DG LoSS of Load Test," Revision 003

,,periodicbG Slow start Operability Test, Facility 2 (Loaded Run)," Revision 003-

Sp 2613L-001,

53M20300833 53102389917

53M20807099 53102394659

53102283860 53102435234

531 02301 088 53102447327

53102322778

cR432184

cR420696 cR432201

cR422697 cR432228

cR422840 cR432400

cR432098 cR432419

Section 1R20: Refuelinq and Oth.er gutaqq Aqtjvities

, "lTC Measurements," Revision 006-06

EN 21004K, "Low Power Physics Test," Revision 003-00

MP 271281, "Control of Heavy Loads," Revision 010-06

MP 27O4A

A. "Unit 2 Reactor Disassembly and Reassembly," Revision 002-03

OP 22O2A, "Reactor Startup by Dilution lCCE," Revision 000-04

OPS-FH 215, "Refueling Machine Operation," Revision 001-03

SP 21018-001, "Core R6activity Balance Surveillance Form," Revision 010-02

cR420439 cR424939

cR421265 cR425314

cR423437 cR42551 3

cR424910

Section 1R22: Surveillance Testlnq

lReadinessandQuarterlylSTGroup.B,PumpTeStS,,'

Revision 017-03

SP 3622.3-001, Surveillance Form Revision 014-03

sP 3556812, "SSPS Train'.B' Operational Test," Revision 012-04

CR41 2930, "Chemistry procedut'e needs enhancement"

Millstone Nuclear power Station Gamma Spectrum Analysis dated May 27,2011

CP 3802E, "Reactor Coolant gas Sampling and Analysis," Revision 002-01

53102294614 53102299983

53102296198 53102300352

cR422915

cR420164 cR425958

cR422421 cR426589

cR422847 cR426592

cR422907

Procedures

sP 2815, Main station stack WRGM Sampling for lodine and Particulates

Vent

SP 28144, Gaseous Effluents for lodines and Particulates from Unit

SP 3878, Unit 3 Monthly Liquid and Gaseous Effluent Dose Projection

SP 2858, Offsite Dose Noble Gases from Unit 2

SP 2859, Off-Site Dose-lodine and Particulate Releases

RP-AA-502, Groundwater Protection Program

Rp-AA-bO4, Remediation Process for the Groundwater Protection Program

for Carbon-14 Effluents

Rp-AA-524, performinj Sour"" Term Estimates and Dose Calculations

RpM 2.8.S, Sampling alnd Oisposal of Unit 3 Waste Test Tank Berm Water

EN 21235, Millstone-Unit 2 Radiation Monitor High Radiation Setpoints

EN31 153, Millstone Unit 3 Radiation Monitor High Radiation Setpoints

EP-AA-303, Equipment lmportant to Emergency Response

ples

CY-AA-LQC-400- 1 O0O, Confi rmatory Measurements using Bl ind sam

SP 3880, Unit 3 SCLRS Vent Radiation Monitor lnoperable

Radioloqical Hazard Assessment (21 124.01 )

@ High Radiation Area Key Control

RPM 1.5.5, Revision 4, Guidelines for Performance of Radiological Surveys

RPM 1.5.6, Revision 3, Survey Documentation and Disposition

RPM 2.1.1, Revision 5, lssuance and Control of RWPs

RPM 2.4'1, Revision 6, Posting of Radiological Control Areas

RpM 2.S.2, Revision 2, Guidelines for Spent Fuel Pool or Flooded Reactor Cavity Work

RPM 5.2.2, Revision 10, Basic Radiation worker Responsibilities

RPM-GDL-008, Revision 0, EleCtronic Dosimeter Alarm set Points

Rp-M-201, Revision 4, Access Controls for High and Very High Radiation Areas

RP-AA-106, Revision 1, Radiological Work Control Program

RP-AA-124, Revision 2, Dosimetry Discrepancy and ED Alarm

Rp-M-201, Revision 5, Access Controls for High and Very High Radiation Areas

RP-M-203, Revision 0, Radiological Labeling and Marking

RP-AA-222, Revision 0, Radiation Surveys

RP-M-223, Revision 1, Contamination Surveys

ALARA Planninq & Controls (71124'02)

RP-M-103, Revision 0, ALARA Program

RP-M-103-1000, Revision 1, Station ALARA Committee

RP-M-300, Revision 4, ALARA Reviews and Reports

RPM 1.4.2, Revision 2, ALARA Engineering Controls

RPM 1.4.4, Revision 2, Temporary Shielding

RPM 2.1.2, Revision 2, ALARA lnterface with the RWP Process

RPM 5.2.3, Revision 3, ALARA Program and Policy

24.03

fportaoteHEPAFilteredVentilationandVacuumUnits

RPM 2.10.2, Revision 11, Air Sample Counting and Analysis

Catibration/Source/Functional Testinq Records Reviewed:

ln-Plant Effluent Monitors

Unit2

ffiinment Gaseous and Particulate Process Radiation Monitor (RM-8123)

Aerated Liquid Rad waste Process Radiation Monitor (RM-g116)

Waste Gas Process Radiation Monitor (RM-9095)

Reactor Building Closed Cooling Water Radiation Monitor (RM-6038)

clean Liquid Rad waste Process Radiation Monitor (RM-9049)

Unit 3

Contlinment Area High Range Radiation Monitor (3RMS.R1Y05A)

Waste Neutralization Sump Radiation Monitor (3CND-RlYO7)

Ventilation Vent Stack High Range Radiation Monitor (3HVR.RlY10A

Ventilation Vent Stack Normal Range Radiation Monitor (3HVR-RlY10B)

Supplemental Leak Collection and Release System High Range Radiation Monitor

(3HVR.RIY19A)

Liquid Waste Radiation Monitor (3LWS-RlY70)

Turbine Building Floor Drains Radiation Monitor (3DAS-RlY5o)

Air Cleaninq Svstem Testino

@ryBuildingVentilationSystemSurveillanceTests System Surv_eillance Tests

Sp 36141, Unit 3 Supplemental Leak Collection and Release

Sp 2654e, Unit 2 Containment and Enclosure Building Exhaust Filter L-25 HEPA

Filtration Testing

SP 2609D, Unit! Enclosure Building Charcoal/HEPA Filtration Testing

Sp 34498; SLCRS Gaseous Radiation Monitor and Ventilation Vent Stack Calibration

VPROC-OPSo3-Oo1, In-Place Testing of HEPA Filters & Charcoal Absorbers

Other Documents

Monthly, Ouartedy, and Annual Liquid and Gaseous Effluent Dose Assessments

for

Unit 2 and Unit 3 from April 2010 through April 2011

2010 Radioactive Effluent Release Report

Mp-22-REC-BAp01, Revision 26, Radiological Effluent Monitoring and Off-Site Dose

Calculation Manual

Audit 0g-15, Off-site Dose calculation Manual/Radiological Environmental Monitoring

Program (REMODCM)

Occupational Dose Assessment (71 124'04)

npV t.3.8, Revision 8, Criteria for Dosimetry lssue

RPM 1 .3.12, Revision 8, Internal Monitoring Program

RPM 1.3.13, Revision 8, Bioassay Sampling and Analysis

RPM 1 .3.14, Revision 7, Personnel Dose Calculations and Assessments

RPM 1.6.4, Revision 3, Siemens Electronic Dosimetry System

RPM 2.5.8, Revision 3, Stay Time Tracking and Multi-Badging for Special Work

RP-AA-123, Revision 1, Effective Dose Equivalent

RP-AA-150, Revision 1, TLD Performance Testing

Condition Reports

iffi,q6953,418801,41g2go,41g87g,42o476,42o959,421ooo,421o56,421115, 417715' 420139',

21661, 421769, 421906:, 421g15i,, +Z2Zg3, 422281, 422384, 422712, 428440,

}B21OT , 42Sg4B:, 421522, 422894, 422553i, 418694, 409791, 387731,

380555, 370396, 368894

Site ALARA Council Meetinq Minutes

rations&LocalLeakRateTesting,Decon,Shielding

lnstallation & Removal, In-service lnspection, Steam Generator Corrective Maintenance (CM)

CMs &

and preventative Mainienance (PM), iReactor Disassembly/Reassembly, Mechanical

PMs, Instrumentation & Controls Tasks

Miscellaneous Documents

NVLAP Certfication Records, Personnel Dosimetry Performance Testing

Annual Review Report of the 2010 1o cFR Part 61 Radionuclide Analysis

Electronic Dosimeter Dose/Dose Rate Alarm Reports, January 2011 - April 2011

Top Ten Individual Exposure Records for 2011

Portable HEPA Inventory & Test Records

piping

EPRI Standard Radiatioh Monitoring Program Data Summary for Unit 2

Unit 2 Reactor Coolant System 2R20 Clean Up Data

Nuclear oversight Field observation 2R20 Snapshot Reports

2R20 ALARA Plans (AP)/ Work-ln-Proqress (WlP) Reviews

AP 2-11 -01, Reactor Disassembly/Reassembly

AP 2-11-09, Steam Generator PMs & CMs

Ap 2-11-13, Scaffolding lnstallation/Removal, lnstallation of Permanent Scaffolding

AP 2-11-14, Insulation Removal/lnstallation

AP 2-11-26, Radiation Protection Support Activities for 2R20

Section 4OA3: Event Follow'uP

@re of SP 2609E for Facility 1 on April 3,2011

MP 2701J-114, "Main Steam Safety Valve Discharge Piping," Revision 0

Mp27O2Fj0A, "Cleaning and Inspection of MSSVs Sliding Bushings," Revision 000

RCE000984, "EnclosurJ Auitding'Filtration System (EBFS) Negative Pressure Test Failed

Acceptance Criteria

SP 2609E, "EBFS Negative Pressure Test," Revision 009-04

SP 2609EE-001, "EBFS Negative Pressure Test, Facility 1," 008-03

SP 2609EE-002, "EBFS Negative Pressure Test, Facility 2," 001-04

cR420485

53M20807056

53M29208468

LIST OF ACRONYMS

AC Alternating Current

ADAMS Agencywide Documents Access and Management System

ALARA As Low As ReasonablY Achievable

AOP Abnormal Operating Procedure

AP ALARA Plans

ASME American Society of Mechanical Engineers

CAP Corrective Action Program

CEDE Committed Effective Dose Equivalent

CFR Code of Federal Regulations

CLB Current Licensing Basis

CR Condition Report

CVCS Chemicaland Volume Control System

CW Circulating Water

DAC Derived Air Concentration

DG Diesel Generator

DNB Departure from Nucleate Boiling

DNC Dominion Nuclear Connecticut

DPW Declared Pregnant Workers

DRP Division of Reactor Projects

DRS Division of Reactor SafetY

ECCS Emergency Core Cooling SYstem

EDEX External Effective Dose Equivalent

EDG Emergency Diesel Generator

EBFS Enclosure Building Filtration System

EP Emergency PrePared ness

ESAS Engineered Safety-Feature Actuation System

ESF Engineered SafetY Feature

FSAR Final Safety AnalYsis RePort

HEPA High Efficiency Particulate Air

HPSI High Pressure SafetY Injection

HRA High Radiation Areas

rcl lncore lnstrument

r&c lnstrumentation and Control

IMC lnspection Manual ChaPter

IST In-Service Testing

JITT Just-intime-training

LER Licensee Event RePorts

LHRA Locked High Radiation Area

LPSI Low Pressure SafetY Injection

LOCA Loss of Coolant Accident

MCC Motor Control Center

mrem millirem

MSSV Main Steam SafetY Valve

MWTH Megawatts Thermal

NCV Non-Cited Violation

NEI Nuclear Energy lnstitute

NRC Nuclear Regulatory Commission

NVLAP National Voluntary Laboratory Accreditation Program

OD Operability Determ inations

ODCM Off-Site Dose Calculation Manual

oos Out Of Service

PARS Publicly Available Records System

PI Performance Indicator

PI&R Problem ldentification and Resolution

PM Preventive Maintenance

PMT Post Maintenance Testing

RBCCW Reactor Building Closed Cooling Water

RCA Radiologically Controlled Area

RCE Root Cause Evaluation

RCP Reactor Coolant PumP

RCS Reactor Coolant System

REMODCM Radiological Effluent Monitoring and Offsite Dose Calculation Manual

RWP Radiological Work Permit

SAC Site ALARA Council

SDC Shutdown Cooling

SDP Significance Determination Process

SG Steam Generator

SGFP Steam Generator Feedwater PumP

SLCRS Supplemental Leak Collection and Release System

SP Surveillance Procedures

SW Service Water

TEDE Total Effective Dose Equivalent

TLD Thermoluminescent Dosimeter

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

UGS Upper Guide Structure

VHRA Very High Radiation Areas

WO Work Order

WRGM Wide Range Gas Monitor

Attachment