Text

Integrated Inspection Report 05000336/2018004 and 05000423/2018004
	ML19037A138
Person / Time
Site:	Millstone
Issue date:	02/05/2019
From:	Daniel Schroeder; Reactor Projects Branch 2
To:	Stoddard D; Dominion Energy
	Schroeder D
References
	EA-16-090 IR 2018004
	Download: ML19037A138 (25)
	v • d • e

D.

UNITED STATES NUCLEAR REGULATORY COMMISSION ary 5, 2019

SUBJECT:

MILLSTONE POWER STATION - INTEGRATED INSPECTION REPORT 05000336/2018004 AND 05000423/2018004

Dear Mr. Stoddard:

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station (Millstone), Units 2 and 3. On January 17, 2019, the NRC inspectors discussed the results of this inspection with Mr. John Daugherty, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any findings or violations of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49

Enclosure:

Inspection Report 05000336/2018004 and 05000423/2018004

Inspection Report

Docket Numbers: 50-336 and 50-423 License Numbers: DPR-65 and NPF-49 Report Numbers: 05000336/2018004 and 05000423/2018004 Enterprise Identifier: I-2018-004-0061 Licensee: Dominion Energy Nuclear Connecticut, Inc. (Dominion)

Facility: Millstone Power Station, Units 2 and 3 Location: P.O. Box 128 Waterford, CT 06385 Inspection Dates: October 1 to December 31, 2018 Inspectors: J. Fuller, Senior Resident Inspector L. McKown, Resident Inspector C. Highley, Resident Inspector H. Anagnostopoulos, Senior Health Physicist J. Kulp, Senior Reactor Inspector D. Silk, Senior Operations Engineer J. Brand, Reactor Inspector A. Turilin, Reactor Inspector J. DeBoer, Emergency Preparedness Physicist K. Mangan, Senior Reactor Inspector Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Dominions performance at Millstone, Units 2 and 3 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.

No findings or more-than-minor violations were identified.

Additional Tracking Items Type Issue number Title Inspection Status Results Section NOV 05000423/2016-001-01 Repetitive Failures to 71152 Closed Correct Unit 3 Turbine Driven Auxiliary Feedwater Pump Performance (Enforcement Action (EA)-16-090)

TABLE OF CONTENTS

PLANT STATUS

...........................................................................................................................

INSPECTION SCOPES

................................................................................................................

REACTOR SAFETY

..................................................................................................................

RADIATION SAFETY

..............................................................................................................

OTHER ACTIVITIES - BASELINE

..........................................................................................

INSPECTION RESULTS

............................................................................................................

EXIT MEETINGS AND DEBRIEFS

............................................................................................ 15 THIRD PARTY REVIEWS .......................................................................................................... 15

DOCUMENTS REVIEWED

......................................................................................................... 16

PLANT STATUS

Unit 2 began the inspection period in a scheduled refueling outage and raised power to

approximately 19 percent power on November 3 and then shut down on November 4 for an

unplanned outage due to equipment issues. On December 2, during the Unit 2 power

ascension, a Heater Drain Tank Normal Level Control Valve was operating erratically and

reactor power was lowered to approximately 75 percent to complete repairs. Unit 2 then

returned to rated thermal power on December 4.

Unit 3 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess Dominion Energys performance and

compliance with Commission rules and regulations, license conditions, site procedures, and

standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (2 Samples)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the

seasonal cold temperatures at Unit 2 on December 12, 2018, and Unit 3 on

November 15, 2018.

External Flooding (1 Sample)

The inspectors evaluated readiness to cope with external flooding on October 15, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

Unit 2

(1) Partial equipment alignment of shutdown cooling system during containment spray

isolation valve maintenance on October 1, 2018.

Unit 3

(2) Partial equipment alignment of the service water system to reactor plant closed cooling

water heat exchangers during isolation valve maintenance on November 29, 2018.

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 2

pressurizer pressure relief system on November 20, 2018.

71111.05A/Q - Fire Protection Annual/Quarterly

Quarterly Inspection (6 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

Unit 2

(1) Containment (Fire Area C-1 elevations 146, -36, and -22) during routine refueling

outage activities on October 5, 2018

(2) Containment (Fire Area C-1 elevation 386) during welding and grinding activities

associated with flow accelerated corrosion repairs on October 9, 2018

(3) Control room, operator breakroom, and new computer room (Fire Areas A-25, A-26, and

A-27) on November 26, 2018

(4) Auxiliary building general area and safeguard rooms at the -45'6" elevation on

December 9, 2018 (Fire Zones A-1A,A-8A, and Fire Areas A-3, A4)

Unit 3

(5) Cable spreading area spurious fire alarm (Fire Area CB-8) on October 16, 2018

(6) Main steam valve building (Fire Area MSV-1) on October 24, 2018

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated Dominions monitoring and maintenance of the Unit 2 increased

heat load on service water due to a planned invertor modification on October 12, 2018.

71111.08 - Inservice Inspection Activities (1 Sample)

The inspectors evaluated pressurized water reactor non-destructive examination and

welding activities by reviewing the following examinations from October 8 to 18, 2018:

(1) Volumetric Examinations

a) Manual ultrasonic and phase array ultrasonic testing of feedwater welds FWA-C-G-

06-A, FWA-C-G-05-A, and FWA-C-G-04-C.

b) Manual encoded phased array ultrasonic testing of safety injection weld overlays

BSI-C-1001, BSI-C-1003, BSI-C-2001, BSI-C-2003, BSI-C-3000, BSI-C-3002, BSI-

C-4000, and BSI-C-4002.

c) Manual ultrasonic testing of Loop 2 hot leg shutdown cooling line weld BSD-C-2005.

d) Manual ultrasonic testing of safety injection to loop 2A cold leg weld BSI-C-2005 and

loop 2B cold leg weld BSI-C-4006.

e) Manual ultrasonic and phase array ultrasonic testing of welds W11 BPV-C-5039B,

W12 BPV-C-5049B, W1 BPV-C-5029B, and W2 BPV-C-5051B associated with the

PORV 2-RC-402 and 2-RC-404 replacement.

(2) Visual Examinations

a) General visual examination of containment liner.

b) System leakage test (VT2) of reactor head penetration #26, 38, 42, and 72 area

performed in accordance with American Society of Mechanical Engineers (ASME)

Section XI Code Case N-729-4.

c) System leakage test (VT2) of Loop 2B Cold Leg instrument Tap 3 performed in

accordance with ASME Section XI Code Case N-722-1.

d) Remote visual examination (VT-3) of eight shroud assembly tie rods located at

2°/18°, 72°/108°, 162°/198°, and 252°/288° performed in response to industry

operating experience OE #434420.

(3) Surface Examination (PT/MT)

a) Magnetic particle tests of feedwater system welds FWA-C-G-06-A, FWA-C-G-05-A,

and FWA-C-G-04-

C.

b) Liquid penetrant tests of welds W11 BPV-C-5039B, W12 BPV-C-5049B, W1 BPV-C-

29B, and W2 BPV-C-5051B associated with the pressurizer PORV 2-RC-402 and

2-RC-404 replacement. This review involved welding activities associated with a

pressure boundary risk significant system.

(4) The inspectors reviewed the welding activities associated with the replacement of a

portion of line of 18-EBB-6 in accordance with MP2-17-00177 (welds W201 FWA-C-G-

06-A, W202 FWA-C-G-05-A, and W203 FWA-C-G-04-C).

(5) The inspectors reviewed the welding activities associated with the replacement of the

pressurizer PORV 2-RC-402 and 2-RC-404 and associated piping (welds W11 BPV-C-

5039B, W12 BPV-C-5049B, W1 BPV-C-5029B, and W2 BPV-C-5051B).

(6) The inspectors evaluated Dominions boric acid corrosion control program performance.

(7) The inspectors performed an independent walkdown of accessible portions of the

containment liner and moisture barrier.

(8) The inspectors did not review steam generator tube or reactor vessel head examination

activities because none were performed during this refueling outage.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (2 Samples)

The inspectors observed and evaluated operators in the plant simulators during just in time

training for the Unit 2 startup on October 13, 2018, and Unit 3 licensed operator

requalification training on November 27, 2018.

Operator Performance (2 Samples)

The inspectors observed Unit 2 operator performance in the control room during reactor

startup and low power physics testing on November 2, 2018, and Unit 3 operator

performance in the control room during a downpower for turbine valve testing on

November 9, 2018.

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

(Annual)

Operator Requalification Exam Results (Annual) (2 Samples)

The inspectors reviewed and evaluated requalification examination results for Unit 2 (written

and operating test) and Unit 3 (written and operating test) on December 20, 2018.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

(Biennial)

Operator Requalification Program and Operator Performance (Biennial) (1 Sample)

The inspectors reviewed and evaluated operator performance, evaluator performance, and

simulator performance during the Unit 2 requalification examinations completed on

December 6, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Review of the licensees 10 CFR 50.65 (a)(3) Periodic Evaluation for the period of

July 1, 2015 to December 31, 2016

71111.13 - Maintenance Risk Assessments and Emergent Work Control (3 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

Unit 2

(1) Elevated shutdown risk due to performance of A and B train containment spray header

isolation valve invasive maintenance during high decay heat load and decreased reactor

vessel inventory on October 1, 2018

(2) Contingency risk plan for temporary bonnet on 2-CS-16.1A/B during invasive valve

maintenance on October 5, 2018

Unit 3

(3) Emergent high risk when the 15G-14T-2, southern disconnect to Unit 3 normal station

supply transformer breaker, was opened online, which resulted in a single output

breaker in service on October 10, 2018

71111.15 - Operability Determinations and Functionality Assessments (3 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

Unit 2

(1) CR1106817 - Non-Conservatisms in Main Steam Line Break Departure from Nucleate

Boiling Ratio Analysis Methodology on October 11, 2018

(2) Immediate operability determination for A and B pressurizer block valves being closed

due to leakage past pressurizer power operated relief valves on December 3, 2018

Unit 3

(3) CR1107892 - Potential Impact to UFSAR 15.1.5.4 Dose Consequence for Main Steam

Line Break due to Delayed Natural Circulation Cooldown on November 2, 2018

71111.18 - Plant Modifications (4 Samples)

The inspectors evaluated the following temporary or permanent modifications:

Unit 2

(1) Replacement of A and B trains containment spray header isolation valve Anchor

Darling motor operated valve stem on October 1, 2018

(2) C reactor protection system bistable and auxiliary bistable trip units design change

number MP2-15-01097 on October 9, 2018

(3) Cutout and weld repair of access hole in the containment airlock on October 29, 2018

(4) Pressurizer power operated relief valve replacement during the refueling outage

(October - November 2018)

71111.19 - Post Maintenance Testing (3 Samples)

The inspectors evaluated post maintenance testing for the following maintenance/repair

activities:

Unit 2

(1) A emergency diesel generator jacket water and aftercooler heat exchanger

replacement on October 15, 2018

(2) 2-SI-468, Shutdown cooling pump suction relief valve replacement with flange leak

check on October 17, 2018

(3) Local leak rate testing and nondestructive examination associated with modification to

containment airlock penetration on October 29 and 30, 2018

71111.20 - Refueling and Other Outage Activities (2 Samples)

The inspectors evaluated Unit 2 scheduled refueling outage (2R25) activities from October 1

through November 3, 2018, and unplanned forced outage activities from November 4

through November 30, 2018.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Containment Isolation Valve (1 Sample)

(1) SP 2605D-013, Containment Leak Test Type C, Penetration 5(O), 2-CS-4.1B, as

performed on October 6, 2018

Routine (2 Samples)

(1) Unit 2, MOV 1220, Motor Operated Valve Testing as performed under joint owners

group commitments for A containment sump outlet header isolation valve as performed

on October 11, 2018

(2) Unit 2, Train B solid state protection system operational test on December 12, 2018

71114.04 - Emergency Action Level and Emergency Plan Changes (1 Sample)

The inspectors verified that the changes made to the emergency plan were done in

accordance with 10 CFR 50.54(q)(3), and any change made to the Emergency Action

Levels, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any

reduction in effectiveness of the plan. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated the conduct of a routine emergency planning drill for Unit 2 on

December 13, 2018.

Drill/Training Evolution (1 Sample)

The inspectors evaluated and observed the Unit 2 licensed operator requalification

program simulator annual operating examination with two event classifications on

November 14, 2018.

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician

proficiency.

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Implementation of ALARA and Radiological Work Controls (1 Sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the

following activities:

(1) ALARA Plan AP-2-18-01

(2) ALARA Plan AP-2-18-11

(3) ALARA Plan AP-2-18-13

(4) ALARA Plan AP-2-18-26

Radiation Worker Performance (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Use of Respiratory Protection Devices (1 Sample)

The inspectors evaluated respiratory protection.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified Dominions performance indicators submittals listed below for the

period from October 2017 through October 2018. (2 Samples)

(1) OR01: Occupational Exposure Control Effectiveness

(2) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

The inspectors verified Dominions performance indicators submittals listed below for the

period from October 2017 through October 2018. (12 Samples)

Unit 2

(1) MS05: Safety System Functional Failures

(2) MS06: Emergency AC Power System Mitigating System

(3) MS07: High Pressure Injection System Mitigating System

(4) MS08: Heat Removal System

(5) MS09: Residual Heat Removal System

(6) MS10: Cooling Water Support System

Unit 3

(7) MS05: Safety System Functional Failures

(8) MS06: Emergency AC Power System Mitigating System

(9) MS07: High Pressure Injection System Mitigating System

(10) MS08: Heat Removal System

(11) MS09: Residual Heat Removal System

(12) MS10: Cooling Water Support System

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (5 Samples)

The inspectors reviewed Dominions implementation of its corrective action program related to

the following issue:

(1) NRC Notice Of Violation (NOV)05000423/2016001-01, Repetitive Failures to Correct

Unit 3 Turbine Driven Auxiliary Feedwater Pump Performance Issues (EA-16-090)

(2) Corrective action (CA3066486), associated with the repair and replacement activities

associated with the through wall leak on the Unit 2 containment spray recirculation test

header

(3) Condition report CR1098865, Part 21 Notification Westinghouse control rod drive

mechanism (CRDM) Unit 3 Thermal Sleeve Wear

(4) Condition report CR1103594, High Differential Temperature Across RCP Seal

Package, and CR 1039762, A Reactor Coolant Pump Return Controlled Bleed-off

Flow at 0.8 Gallons per Minute

(5) Repetitive degraded performance of Millstone Unit 2 service water train A flow

instrumentation

INSPECTION RESULTS

Observation 71152

Follow-up of selected

issues

NRC Notice Of Violation (NOV)05000423/2016001-01, Repetitive Failures to Correct Unit 3

Turbine Driven Auxiliary Feedwater Pump Performance Issues (EA-16-090)

NRC issued NOV 05000423/2016001-01 (EA-16-090) for Dominions repetitive failure to take

effective corrective actions for a significant condition adverse to quality involving the degradation

of the Unit 3 turbine driven auxiliary feedwater (TDAFW) pump turbine control valve linkage.

Specifically, Dominions corrective actions to correct the TDAFW control system had not fully

considered all potential failure modes such that continued unreliable operation due to linkage and

control systems problems resulted in another overspeed trip in February 2016. Inspectors

previously documented this condition in 2014 under NCV 05000423/2014013-02, a Green NCV

of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, and in violation (VIO)05000423/2014008-02, a White VIO, also of 10 CFR Part 50, Appendix B Criterion XVI,

Corrective Action. Dominions root cause evaluation (RCE-CA3024960) determined the

February 22, 2016, TDAFW overspeed trip was due to a seized cam follower bearing caused by

corrosion due to control valve packing leakage as a result on an oversized stuffing box allowing

excessive play and bypass of the carbon rings and spacers that accelerated packing wear and

resulted in steam/water impingement on the cam follower bearing and linkage.

By letter dated June 3, 2016, Dominion responded to NOV EA-16-090. Dominion committed to

perform a comprehensive evaluation of additional methods to improve design and operating

margins within the TDAFW pump linkage and control system, and to notify the NRC of the results

of the comprehensive evaluation and planned corrective actions. These results were presented

to the NRC via letter 16-204A, dated September 29, 2016. Applicable corrective actions

included: commissioning an independent third party failure modes and effect analysis, and

consulting with industry and vendor representatives to develop appropriate corrective actions;

replacement of the cam follower bearing with a lubricated bearing; replacement of the governor

control valve bonnet with a new stem packing assembly designed, developed, and recommended

by the vendor; changing the governor as-left (starting) rack setting to increase available stem

force at turbine start-up; creating an activity to inspect and lubricate linkage joints, cam follower

bearing, and packing assembly every refueling outage; lowering the turbine speed; replacement

of steam traps with continuous restriction orifices and added daily operators temperature checks

to verify proper operation of the orifices or to initiate blowdown as necessary; and implementing a

design change to install a metal shield to reduce the amount of steam and condensate impact on

the cam follower bearing. The inspectors reviewed the comprehensive evaluation and completed

corrective actions to verify they have been properly implemented.

The inspectors reviewed applicable modifications of the cam follower and metal shield, performed

field walkdowns to verify installation of these components and restriction orifices, verified

procedures and drawings have been revised, and reviewed quarterly surveillance tests and the

full flow tests performed on the TDAFW pump since February 2016. The inspectors noted that no

related overspeed trips have occurred since the implementation of these corrective actions. The

inspectors determined the causes of the problems were reasonably identified and that corrective

actions were completed focused on addressing the problems and intended to prevent recurrence.

No issues of concern were identified.

Observation 71152

Follow-up of selected

issues

Corrective action (CA3066486), associated with the repair and replacement activities associated

with the through wall leak on the unit 2 containment spray recirculation test header

On September 21, 2017, Dominion identified a very small through-wall leak on an ASME Class 2

pressure boundary pipe associated with the emergency core cooling system. The inspectors

reviewed Dominions corrective actions associated with this nonconforming condition including

the ASME Section XI repair and replacement activities during the Unit 2 refueling outage. The

inspectors determined that Dominions corrective action to replace the leaking pipe was

appropriate; however, the inspectors noted that Dominion had several opportunities to identify the

leak prior to September 21, 2017.

The inspectors noted that Dominion initiated condition report CR1067106 on May 3, 2017, in

response to the identification of white residue on the piping insulation during an ASME Section XI

VT-2 leakage inspection. Dominions chemistry department incorrectly stated that the white

residue was not boric acid, but they recommended that the piping insulation be removed for a

closer inspection of the pressure boundary piping. This was not performed and all work orders

were canceled. Dominion documented a relevant indication on the VT-2 inspection report, but

failed to take further corrective actions to identify the source of the leakage. A work order had

been created, but was canceled with no actions taken.

The inspectors noted that Dominion initiated a second condition report related to this through-wall

leak on September 5, 2017, which stated that this was a repeat indication of leakage from

CR1067106; however, Dominion referred back to the previous, incorrect evaluation from

chemistry stating that the white residue was not boric acid. Therefore, Dominion took no further

corrective action at that time to remove the insulation and investigate the leak. The inspectors

noted that the ASME Section XI VT-2 inspection report remained open without an evaluation of

the relevant indication. This was identified by the NRC inspectors as a second missed

opportunity to identify and correct the leak.

Based on questions asked by the NRC resident inspectors and engagement of Dominion senior

management, the insulation was removed and the piping inspected on September 21, 2017.

CR1078830 was then written to document a through-wall leak on the ASME Class 2 pressure

boundary piping and an immediate operability determination was performed followed by

supplemental ultrasonic inspections and leak rate monitoring until the piping was replaced in the

Fall 2018 refueling outage.

The inspectors noted that CR1078830 provided an adequate operability determination but failed

to acknowledge the untimely identification of the condition. The inspectors noted that the

management review screening of CR1078830 called for a lost opportunity evaluation, which if

performed, would have likely identified similar concerns to those described above. However, the

inspectors noted that this lost opportunity evaluation was not performed.

This issue was determined to be of minor significance because the emergency core cooling

system remained operable after Dominion determined that the flaw was within the limits

established by a structural integrity evaluation in accordance with Code Case N-513-3,

Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping,

Section XI, Division 1.

Dominion entered the inspector's observations into their corrective action program as condition

report CR1113486.

Observation 71152

Follow-up of selected

issues

Condition report CR1098865, Part 21 Notification Westinghouse control rod drive mechanism

(CRDM) Unit 3 Thermal Sleeve Wear.

The inspectors assessed Dominions corrective actions associated with CR1098865 to address

the recommendations of NSAL 18-1, Thermal Sleeve Flange Wear Leads to Stuck Control Rod.

This condition was identified at a foreign nuclear power plant and is described in NRC Information Notice 2018-10 (ADAMS Accession No. ML18214A710). The inspectors reviewed Dominions

measurement results completed for Millstone Unit 3 during the 3R18 refueling outage in October

2017 and their technical evaluation of measurement results. The inspectors determined

Dominions response implemented the recommendations, was timely and commensurate with the

safety significance of the issue, and included appropriate corrective actions involving planned

actions to monitor via periodic measurement.

Observation 71152

Follow-up of Selected

Issues

Condition report CR1103594, High Differential Temperature Across RCP Seal Package, and CR

1039762, A Reactor Coolant Pump Return Controlled Bleed-off Flow at 0.8 Gallons per Minute.

The inspectors reviewed Dominions corrective actions that were planned or performed following

the identification of degradation of the seal faces installed in the Unit 3 reactor coolant pumps

(RCPs) documented in CR1103594 and CR1039762. Dominion first identified the degradation

following the failure of the A RCP 3-stage seal in June 2016. New RCP 3-stage seal packages

were installed in the A and D RCP in October 2014, and the B and C RCP in April 2016. The

seals were expected to be in service for up to 10 years before replacement. Following the failure of

the seal, Dominion entered the issue into the corrective action program, replaced the A RCP seal,

and developed actions to troubleshoot and evaluate the cause of the failure. Dominion staff

identified an increasing temperature trend across the other RCP seals and was informed that two

similar seal packages installed at another U.S. nuclear power plant experienced similar problems.

Dominion staff in consultation with the seal manufacturer determined the seal face degradation was

caused by electrical charges passing between the seal plates. Corrective actions included the

installation of RCP motor shaft grounding straps to eliminate shaft induced voltage concerns.

Dominion staff later identified similar temperature trends during the operating cycle following the

completion of the corrective actions. Dominion staff evaluated the temperature rise in the corrective

action program and developed actions to minimize the degradation. Dominions corrective actions

included optimizing seal cooling parameters in order to minimize the degradation mechanism and

monitoring RCP seal temperatures to identify degradation in the seal. Based on the results of this

monitoring program, Dominion staff intend to replace several seals during the next Unit 3 refueling

outage. The inspectors noted that Dominion staff are working with the industry on the seal

degradation to develop the appropriate final corrective actions. The inspectors were informed that

Flowserve personnel have performed additional testing on the seal and concluded that the most

likely cause of the degradation was due to electro-corrosion and is working on a solution within their

corrective action program. Dominions final corrective action to address the RCP seal degradation

is to install a new seal design when the design is complete and tested. The inspectors concluded

that the corrective actions to monitor seal performance and optimize seal cooling parameters while

planning for seal replacement with an improved design in the future was reasonable and

commensurate with the safety significance of the issue.

Observation 71152

Follow-up of selected

issues

Repetitive degraded performance of Millstone Unit 2 service water train A flow instrumentation

The inspectors assessed Dominions corrective actions associated with repetitive degraded

performance of Millstone Unit 2 service water train A flow instrumentation. Dominion began to

observe the instrument intermittently failing low as documented in 2015 in CR579486, in 2016 in

CR1042477 and CR1042902, in 2017 in CR1072632, and in 2018 in CR1107186. The

inspectors reviewed Dominions corrective actions in each case and the establishment of a plant

modification to perform long term restoration.

Based upon the conditions reviewed and corrective actions taken, the inspectors have identified

no more than minor concerns associated with this issue. Dominion appears to have identified

adverse conditions upon inappropriate instrument performance and established corrective actions

in accordance with their safety significance.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 17, 2019, the inspectors presented the quarterly resident inspector inspection

results to Mr. John Daugherty, Site Vice President, and other members of the Millstone staff.

THIRD PARTY REVIEWS

Inspectors reviewed the Institute of Nuclear Power Operations report that was issued during the

inspection period.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Procedures

C OP 200.13, Seasonal Weather Operations, Revision 11

C OP 200.13-003, Unit 3 Cold Weather Preparation Checklist, Revision 001-01

SP 2665, Building Flood Gate Inspections, Revision 005

MP 2701E, Unit 2 Flood Gates Installation and Removal, Revision 000

Miscellaneous

U2 cold weather status of corrective actions check list, dated December 7, 2018

U3 cold weather status of corrective actions check list, dated November 15, 2018

MP2 FSAR Chapter 2, Section 2.5.4.2.3, Intake Flood Protection

71111.04 - Equipment Alignment

Miscellaneous

P&ID 25203-260014 SH 2, Reactor Coolant System, Revision 49

203-26015, PID Low Pressure Safety Injection System, Sheet 1, Revision 50

212-26933, PID Service Water System, Sheet 2, Revision 91

71111.05 - Fire Protection

Procedures

U2-24-FFS-BAP01-CONT, Fire Fighting Strategies for Containment, Revision 003

C SP 600.22, U2 Containment Fire Hose Station Flow Test, Revision 005

Condition Reports

1112858* 1106814 1112508 1112533

1112538 1112541 1112544 1112866

Miscellaneous

U3-24-FFS, Millstone Unit 3 Fire Fighting Strategies, Revision 0

Millstone Unit 3 Fire Protection Evaluation Report, Revision 21.3

71111.07 - Heat Sink Performance

Procedures

SPROC ENG18-2-005, S-SW-181A Summer Valve Position Determination, Revision 1

Miscellaneous

Calculation PA-090-070-01223EE, MS U2 Electrical Heat Release Calculation in the Z1, 480V

West Switchgear Room at Elevation 36 6, Turbine Building, Revision 1

Calculation 12-280, PROTO-HX Model Development of MP2 Room Coolers X-181 A/B and X-

183 and Elevation of 80 F Service Water with Addendum Heat Exchanger Heat Load

Updates for 1, 3, 5 Inverter Replacement, Revision 00

Calculation 92-FFP-00934ES, MPS2 West 480 Volt AC Load Center Heat Gains, Revision 04

Calculation 12-001, MP2 SW Model and Design Bases Analysis with Addendum Heat Load

Changes Due to Inverter Replacement in the East DC Vital Switchgear Room and the

West 480V Switchgear Room, Revision 02

71111.08 - Inservice Inspection Activities

Procedures

ER-AA-CII-102, ASME Section XI Containment Inservice Inspection (Metal/IWE) Program Fleet

Implementation Requirements, Revision 3

ER-AP-BAC-101, Boric Acid Corrosion Control Program (BACCP) Inspections, Revision 12

ER-AA-NDE-UT-706, Ultrasonic Examination for the Detection of Laminar Indications,

Revision 1

ER-AA-NDE-UT-801, Ultrasonic Examination of Ferretic Piping Welds in Accordance with ASME

Section XI, Appendix VIII, Revision 7

ER-AA-NDE-MT-200, ASME Section XI Magnetic Particle Examination Procedure, Revision 5

ER-AA-NDE-UT-742, Encoded Phased Array Ultrasonic Examination of Ferretic and Austenitic

Welds, Revision 3

ER-MP-NDE-UT-816, Manual Phased Array Procedure for Weld Overlaid Similar and Dissimilar

Metal Welds, Revision 1

ER-AA-NDE-VT-604, Visual Examination (VE) for Leakage of PWR Reactor Head Penetrations,

Revision 3

ER-AA-NDE-VT-607, VE Examination of Pressure Retaining welds in Class 1 Components

Fabricated with Alloy 600/82/182 Materials, Revision 2

ER-AA-NDE-VT-608, VT-3 Visual Examination Procedure for Examination Category B-N-1,

Interior of Reactor Vessel, Revision 0

ER-AA-NDE-UT-802, Ultrasonic Examination of Austenitic Piping Welds in Accordance with

ASME Section XI, Appendix VIII, Revision 5

Condition Reports (*initiated in response to inspection)

1012448 1064672 1065914 1099890

1105795 1106136 1106137 1106140

1106237 1106290 1106297 1106308

1106389 1106402 1106471

Maintenance Order/Work Order

53102884929 53103117773 53103120600 53103147770

NDE Reports

M2-UT-18-003, UT Examination Report for FWA-C-G-05-A, dated September 25, 2018

M2-UT-18-004, UT Examination Report for FWA-C-G-05-A, dated September 25, 2018

M2-UT-18-028, UT Examination Report for FWA-C-G-04-C, dated October 13, 2018

M2-UT-18-029, UT Examination Report for FWA-C-G-06-A, dated October 13, 2018

M2-MT-18-001, MT Examination Report for FWA-C-G-05-A, dated September 25, 2018

M2-MT-18-004, MT Examination Report for FWA-C-G-04-C, dated October 13, 2018

M2-MT-18-005, MT Examination Report for FWA-C-G-06-A, dated October 13, 2018

FAC2-Weld-203, UT Examination Report for 18-EBB-6, dated October 13, 2018

FAC2-Weld-201, UT Examination Report for 18-EBB-6, dated October 13, 2018

M2-UTU-18-009, UT Examination Report for BSI-C-1001, dated October 4, 2018

M2-UTU-18-011, UT Examination Report for BSI-C-1003, dated October 4, 2018

M2-UTU-18-006, UT Examination Report for BSI-C-2001, dated October 4, 2018

M2-UTU-18-012, UT Examination Report for BSI-C-2003, dated October 4, 2018

M2-UTU-18-005, UT Examination Report for BSI-C-3000, dated October 4, 2018

M2-UTU-18-008, UT Examination Report for BSI-C-3002, dated October 4, 2018

M2-UTU-18-013, UT Examination Report for BSI-C-4000, dated October 6, 2018

M2-UTU-18-014, UT Examination Report for BSI-C-4002, dated October 6, 2018

BOP-VT-18-041, VT Examination Report for RPV Head Penetrations 26, 38, 42 and 72, dated

October 5, 2018

M2-VT-18-108, VT Examination Report for Loop 2B CL Instrument Tap 3, dated October 2, 2018

BOP-VT-18-042, VT Examination Report for M2H1-CSB - Examined per OE Condition Report

CR1099890, dated October 7, 2018

M2-UT-18-011, UT Examination Report for BSD-C-2005, dated October 6, 2018

M2-UT-18-012, UT Examination Report for BSD-C-2005, dated October 6, 2018

M2-UT-18-007, UT Examination Report for BSI-C-2005, dated October 5, 2018

M2-UT-18-008, UT Examination Report for BSI-C-2005, dated October 5, 2018

M2-UT-18-013, UT Examination Report for BSI-C-4006, dated October 7, 2018

M2-PT-18-006, PT Examination Report for BPV-C-5029B, dated October 8, 2018

M2-PT-18-007, PT Examination Report for BPV-C-5039B, dated October 8, 2018

M2-PT-18-008, PT Examination Report for BPV-C-5049B, dated October 8, 2018

M2-PT-18-009, PT Examination Report for BPV-C-5051B, dated October 8, 2018

M2-UT-18-017, UT Examination Report for BPV-C-5029B, dated October 8, 2018

M2-UT-18-021, UT Examination Report for BPV-C-5029B, dated October 9, 2018

M2-UT-18-019, UT Examination Report for BPV-C-5039B, dated October 8, 2018

M2-UT-18-022, UT Examination Report for BPV-C-5039B, dated October 9, 2018

M2-UT-18-020, UT Examination Report for BPV-C-5049B, dated October 8, 2018

M2-UT-18-023, UT Examination Report for BPV-C-5049B, dated October 9, 2018

M2-UT-18-018, UT Examination Report for BPV-C-5051B, dated October 8, 2018

M2-UT-18-024, UT Examination Report for BPV-C-5051B, dated October 9, 2018

PORV-W1, UT Examination Report for PORV Weld W1, dated October 9, 2018

PORV-W2, UT Examination Report for PORV Weld W2, dated October 9, 2018

PORV-W11, UT Examination Report for PORV Weld W11, dated October 9, 2018

PORV-W12, UT Examination Report for PORV Weld W12, dated October 9, 2018

M2-UT-17-032, UT Examination Report for SI-CF-F-049, dated April 13, 2017

Miscellaneous

NRC Letter, Millstone Power Station, Units Nos. 2 and 3 - Alternative Request RR-04-27 and

IR-3-38, Revision 0, for the Use of Encoded Phased Array Ultrasonic Examination

Techniques in lieu of Radiography (EPID-L-2018-LLR-0011), (ML18252A003), dated

September 17, 2018

Millstone Power Station Unit 2 In-Service Inspection Program - Owner's Activity Report,

Refueling Outage 24, dated June 27, 2017

ETE-MP-2017-1015, Millstone Unit 2 Steam Generator Integrity Degradation Assessment

(2R24), Revision 0

ETE-MP-2017-1060, Millstone Unit 2 Steam Generator Integrity Condition Monitoring and

Operational Assessment Refueling Outage (2R24), Revision 0

ETE-MP-2018-1071, Degradation Assessment Technical Review for not Performing Primary or

Secondary Inspections of the Steam Generators During 2R25, Revision 0

71111.11 - Licensed Operator Requalification Program

Procedures

Unit 2 LORP 2C26 JITT, Reactor Start Up and Low Power Physics Testing Course # 75098,

Dated 12 October, 2018

Unit 2 LORP 2C26 Startup JITT, 2C26 Turbine Overspeed (ICCE), Main Turbine Synch to the

Grid and 2nd SGFP Startup Course # 75099, dated October 12, 2018

OP 2204, Load Changes, Revision 040

SP 3623.2, Turbine Overspeed Protection System Test, Revision 012

Miscellaneous

Reactivity Plan, M3C19 RXMANP03.3, Update 1

71111.12 - Maintenance Effectiveness

Miscellaneous

Periodic 10 CFR 50.65 (a)(3) self-assessment [July 1, 2015 to December 31, 2016];

PIR1059274

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Procedures

OU-AA-200, Shutdown Risk Management, Revision 10

WM-AA-301, Operational Risk Assessment, Revision 20

OU-M2-201, Shutdown Safety Assessment Checklist, Revision 23

MP 2702D1B, Anchor Darling 4 inch and Larger Double Disc Gate Valve Maintenance, Revision

NF-AA-PRA-370, Probable Risk Assessment Procedures and Methods: MRule (a)(4) Risk

Monitor Guidance, Revision 16

Condition Reports

1109048

Work Orders

53102909963 53203148327

Miscellaneous

203-26015, PID Low Pressure Safety Injection System, Sheet 1, Revision 50

2R25 Shutdown Risk Assessment

2R25 Shutdown Risk Schedule Review

Millstone Unit 2 Shutdown Safety Assessment Checklist dated October 1, 2018

Millstone Unit 2 Shutdown Safety Assessment Checklist dated October 5, 2018

EOOS Version 4.1 for Millstone Unit 3 on 10/5/2018

High Risk Plan for Sulfur Fluoride Gas addition to 15G-14T-2, Millstone Unit 3 South Bus Output

Breaker as Implemented on October 5, 2018

71111.15 - Operability Determinations and Functionality Assessments

Condition Reports

1106817 1107892 1107987 1111536

Miscellaneous

ETE-SU-2017-0069, SPS Emergency Diesel Generator Mission Time, Revision 0

71111.18 - Plant Modifications

Procedures

SP-M2-ME-1053, Procurement and Design Specification for MP2 Power Operated Valves 2-

RC-402 and 2-RC-404, Revision 6

SP 2401SE, PORV, Trip Inhibit, Trip Inhibit Annunciator and Matrix Circuit Ground Detection

Functional Test, Revision 002-00

SP 2401BB3, Channel C Wide Range Monitor Start-up Functional Test Data Sheet, Revision

003-00

SP 2401C, RPS Turbine Loss of Load Test with EHC system Initially Tripped Data Sheet,

Revision 009-04

SP 2401D, RPS Matrix Logic and Trip Path Relay Test Data Sheet, Revision 016-00

MP 2702D1B, Anchor Darling 4 Inch and Larger Double Disc Gate Valve Maintenance,

Revision 0

Condition Reports

1100125 1105171 1107996

Maintenance Orders/Work Orders

53102909963 53103042453 53103080132 53103081255

53103081259 53103147770 53203148327

Miscellaneous

Design Equivalent Change Package Number MP2-17-00178, Millstone 2 PORV Replacement,

Revision 0 and Revision 1

ETE-MP-2018-1085, Transmittal of PORV Stroke Time for use in Thermal-Hydraulic Analysis,

Revision 0

Calculation Number 32-5072658-005, Millstone Unit 2 PORV/PSV Relief Piping Transient Loads

Calculation, Revision 5

203-26015, PID Low Pressure Safety Injection System, Sheet 1, Revision 50

DC-18-00131, Containment Spray Header Isolation Valve Stem Replacement, Revision 0

71111.19 - Post-Maintenance Testing

Procedures

ER-AA-NDE-RT-400, Radiographic Examination Procedure, Revision 1

SP 2613A, Periodic DG Operability Test, Facility 1 (Fast Start, Loaded Run), Revision 023

SP 2670, A RBCCW HX D/P Determination, Revision 011-01

Condition Reports

1108817 1110413 1110584

Maintenance Orders/Work Orders

53102842362 53102842741 53103106290 53103118384

203150809

Miscellaneous

Post Maintenance Test Plan for U2 Containment Airlock dated 10/29/18

ETE-MP-2018-1092, MP2 Containment Personnel Air Lock Access Window, Revision 0

71111.22 - Surveillance Testing

Procedures

SP 3446B12, Train B Solid State Protection System Operational Test, Revision 017

Work Orders

53102573331 53102909963 53102909966 53203148327

203148330

Condition Reports

1107290

71114.04: Emergency Action Level and Emergency Plan Changes

Miscellaneous

MP-18-07S, MP-26-EPI-EPMP, Millstone Power Station Emergency Plan, Revision 56

MP-18-08S, MP-26-EPA-REF03, Millstone Unit 3 Emergency Action Level Scheme (I-7 of 8),

Revision 23

71151 - Performance Indicator Verification

Procedures

4Q2017 Derivation and Margin Reports for Millstone Unit 2 Mitigating System Performance