IR 05000336/2018003: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:D.
{{#Wiki_filter:November 2, 2018
 
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 2, 2018


==SUBJECT:==
==SUBJECT:==
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Sincerely,
Sincerely,
/RA/
/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
 
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:===
===Enclosure:===
Inspection Report 05000336/2018003 and 05000423/2018003
Inspection Report 05000336/2018003 and 05000423/2018003  


==Inspection Report==
==Inspection Report==
Docket Numbers: 50-336 and 50-423 License Numbers: DPR-65 and NPF-49 Report Numbers: 05000336/2018003 and 05000423/2018003 Enterprise Identifier: I-2018-003-0077 Licensee: Dominion Energy Nuclear Connecticut, Inc. (Dominion Energy)
Docket Numbers:
Facility: Millstone Power Station (Millstone), Units 2 and 3 Location: P.O. Box 128 Waterford, CT 06385 Inspection Dates: July 1 to September 30, 2018 Inspectors: J. Fuller, Senior Resident Inspector L. McKown, Resident Inspector C. Highley, Resident Inspector K. Mangan, Senior Reactor Inspector H. Anagnostopoulos, Senior Health Physicist L. Dumont, Reactor Inspector B. Haagensen, Senior Resident Inspector Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
50-336 and 50-423  
 
License Numbers:
DPR-65 and NPF-49  
 
Report Numbers:
05000336/2018003 and 05000423/2018003  
 
Enterprise Identifier: I-2018-003-0077  
 
Licensee:  
 
Dominion Energy Nuclear Connecticut, Inc. (Dominion Energy)  
 
Facility:  
 
Millstone Power Station (Millstone), Units 2 and 3  
 
Location:  
 
P.O. Box 128  
 
Waterford, CT 06385  
 
Inspection Dates:
July 1 to September 30, 2018  
 
Inspectors:
J. Fuller, Senior Resident Inspector
L. McKown, Resident Inspector
C. Highley, Resident Inspector
K. Mangan, Senior Reactor Inspector  
 
H. Anagnostopoulos, Senior Health Physicist  
 
L. Dumont, Reactor Inspector  
 
B. Haagensen, Senior Resident Inspector  
 
Approved By:
Daniel L. Schroeder, Chief  
 
Reactor Projects Branch 2  
 
Division of Reactor Projects  


=SUMMARY=
=SUMMARY=
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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.
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.


List of Findings and Violations Failure to Assure that Safety-Related Service Water Piping Conformed to the Procurement Documents Cornerstone         Significance                                 Cross-cutting Inspection Aspect        Results Section Mitigating         Green                                         None          71111.15 Systems            NCV 05000336/2018003-01 Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the American National Standards Institute (ANSI) B31.1 code, a condition of the purchase order, and was installed in the plant.
===List of Findings and Violations===
Failure to Assure that Safety-Related Service Water Piping Conformed to the Procurement Documents Cornerstone Significance Cross-cutting Aspect Inspection Results Section Mitigating Systems Green NCV 05000336/2018003-01 Closed  
 
None 71111.15 The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the American National Standards Institute (ANSI) B31.1 code, a condition of the purchase order, and was installed in the plant.


=PLANT STATUS=
=PLANT STATUS=
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==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.04 - Equipment Alignment==
===Partial Walkdown (3 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains at Unit 2:


==71111.04 - Equipment Alignment    Partial Walkdown==
(1) 'B' high pressure safety injection pump discharge flowpath in the auxiliary building on July 11, 2018
{{IP sample|IP=IP 71111.04|count=3}}
: (2) Boric acid system on August 21, 2018 (3) 'A', 'B', and 'C' service water pump discharge at the intake building on September 4, 2018
 
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains at Unit 2:
: (1) 'B' high pressure safety injection pump discharge flowpath in the auxiliary building on July 11, 2018
: (2) Boric acid system on August 21, 2018
: (3) 'A', 'B', and 'C' service water pump discharge at the intake building on September 4, 2018


==71111.05A/Q - Fire Protection Annual/Quarterly     Quarterly Inspection==
==71111.05A/Q - Fire Protection Annual/Quarterly==
{{IP sample|IP=IP 71111.05A/Q|count=5}}
===Quarterly Inspection (5 Samples)===
The inspectors evaluated fire protection program implementation in the following selected areas:


The inspectors evaluated fire protection program implementation in the following selected areas:
Unit 2
Unit 2
: (1) A, B, and C safeguards pump rooms (Fire Areas A-8A, A-3 and A-4) on July 11, 2018
: (1) A, B, and C safeguards pump rooms (Fire Areas A-8A, A-3 and A-4) on July 11, 2018
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: (5) East floor area of engineered safety features building at elevation 4' 6" (Fire Area ESF-4)on September 25, 2018
: (5) East floor area of engineered safety features building at elevation 4' 6" (Fire Area ESF-4)on September 25, 2018


==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance   Operator Requalification==
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
{{IP sample|IP=IP 71111.11|count=2}}
===Operator Requalification (2 Samples)===
 
The inspectors observed and evaluated Unit 2 control room simulator operator requalification training associated with a loss of all AC power while in Mode 5 on September 6, 2018.
The inspectors observed and evaluated Unit 2 control room simulator operator requalification training associated with a loss of all AC power while in Mode 5 on September 6, 2018.


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The inspectors observed Unit 3 operator performance while swapping trains of control building chilled water and reactivity manipulations on August 1, 2018.
The inspectors observed Unit 3 operator performance while swapping trains of control building chilled water and reactivity manipulations on August 1, 2018.


==71111.12 - Maintenance Effectiveness   Quality Control==
==71111.12 - Maintenance Effectiveness==
{{IP sample|IP=IP 71111.12|count=1}}
===Quality Control (1 Sample)===
 
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issue:
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issue:
: (1) Unit 3 reactor protection system Rakset 2 card (PQY-403A) power supply card item equivalency evaluation on August 31, 2018.
: (1) Unit 3 reactor protection system Rakset 2 card (PQY-403A) power supply card item equivalency evaluation on August 31, 2018.
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{{IP sample|IP=IP 71111.13|count=7}}
{{IP sample|IP=IP 71111.13|count=7}}


The inspectors evaluated the risk assessments for the following planned and emergent work activities:
The inspectors evaluated the risk assessments for the following planned and emergent work activities:  
 
Unit 2
Unit 2
: (1) Inspection of in-process pre-outage scaffold erection in the turbine building combined with other planned medium (B service water pump maintenance outage) and high risk activities (switchyard work) on August 29, 2018
: (1) Inspection of in-process pre-outage scaffold erection in the turbine building combined with other planned medium (B service water pump maintenance outage) and high risk activities (switchyard work) on August 29, 2018
: (2) Open phase project cable pulls into main control room control boards through fire penetration seals on September 10, 2018
: (2) Open phase project cable pulls into main control room control boards through fire penetration seals on September 10, 2018
: (3) Emergent elevated risk when 'A' service water pump discharge strainer backwash failed to auto start with high differential pressure detected on September 10, 2018
: (3) Emergent elevated risk when 'A' service water pump discharge strainer backwash failed to auto start with high differential pressure detected on September 10, 2018
: (4) Elevated risk associated with B emergency diesel generator out of service and station blackout diesel unavailable during functionality testing on September 13, 2018 Unit 3
: (4) Elevated risk associated with B emergency diesel generator out of service and station blackout diesel unavailable during functionality testing on September 13, 2018  
 
Unit 3
: (5) High risk plan for line 348 out of service for repair of hot spot at Haddam 11C substation on August 22, 2018
: (5) High risk plan for line 348 out of service for repair of hot spot at Haddam 11C substation on August 22, 2018
: (6) Elevated risk associated with maintenance in containment - pressurizer spray bypass valve and equipment environmental qualification temperature transmitter card on August 29, 2018
: (6) Elevated risk associated with maintenance in containment - pressurizer spray bypass valve and equipment environmental qualification temperature transmitter card on August 29, 2018
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{{IP sample|IP=IP 71111.15|count=6}}
{{IP sample|IP=IP 71111.15|count=6}}


The inspectors evaluated the following operability determinations and functionality assessments:
The inspectors evaluated the following operability determinations and functionality assessments:  
 
Unit 2
Unit 2
: (1) Condition Report 1096849 - revision to atmospheric dump valve capacity on August 28, 2018
: (1) Condition Report 1096849 - revision to atmospheric dump valve capacity on August 28, 2018
: (2) Condition Reports 1104311, 1104353, 1104480, 1104725, and 1104822 - 'A' and 'B' service water piping weld indications identified on August 29, 2018 Unit 3
: (2) Condition Reports 1104311, 1104353, 1104480, 1104725, and 1104822 - 'A' and 'B' service water piping weld indications identified on August 29, 2018  
 
Unit 3
: (3) Condition Reports 1101173 and 1101191 - common mode impact of failure of A train motor control center rod control area service water booster pump during 'A' train service water surveillance testing on July 9, 2018
: (3) Condition Reports 1101173 and 1101191 - common mode impact of failure of A train motor control center rod control area service water booster pump during 'A' train service water surveillance testing on July 9, 2018
: (4) Condition Report 1101277 - 'A' emergency diesel generator intermittent ready to load failure on July 10, 2018
: (4) Condition Report 1101277 - 'A' emergency diesel generator intermittent ready to load failure on July 10, 2018
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{{IP sample|IP=IP 71111.19|count=8}}
{{IP sample|IP=IP 71111.19|count=8}}


The inspectors evaluated post maintenance testing for the following maintenance/repair activities:
The inspectors evaluated post maintenance testing for the following maintenance/repair activities:  
Unit 2
 
: (1) 'B' service water pump motor and discharge check valve (2-SW-1B) post maintenance testing on September 2, 2018
Unit 2  
: (2) 'B' emergency diesel generator post maintenance testing associated with planned replacement of 2DG-95B, control air solenoid operated valve assembly, on September 13 and 14, 2018 Unit 3
 
: (3) 'A' emergency diesel generator governor tuning following identification of intermittent ready to load failure on July 10, 2018
(1) 'B' service water pump motor and discharge check valve (2-SW-1B) post maintenance testing on September 2, 2018 (2) 'B' emergency diesel generator post maintenance testing associated with planned replacement of 2DG-95B, control air solenoid operated valve assembly, on September 13 and 14, 2018  
 
Unit 3  
 
(3) 'A' emergency diesel generator governor tuning following identification of intermittent ready to load failure on July 10, 2018
: (4) Repair and replacement of degraded buried auxiliary condensate piping identified during planned underground piping inspection on August 6, 2018
: (4) Repair and replacement of degraded buried auxiliary condensate piping identified during planned underground piping inspection on August 6, 2018
: (5) Post maintenance testing for failure of Rakset 2 card PQY-403A power supply on August 27, 2018
: (5) Post maintenance testing for failure of Rakset 2 card PQY-403A power supply on August 27, 2018
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The inspectors evaluated scheduled Unit 2 refueling outage (2R25) activities from September 27 through September 30, 2018. The outage, and implementation of this inspection procedure, continues in the fourth quarter.
The inspectors evaluated scheduled Unit 2 refueling outage (2R25) activities from September 27 through September 30, 2018. The outage, and implementation of this inspection procedure, continues in the fourth quarter.


==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:   Routine==
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance tests:  
 
===Routine===
{{IP sample|IP=IP 71111.22|count=4}}
{{IP sample|IP=IP 71111.22|count=4}}


Unit 2
Unit 2  
: (1) 'B' high pressure safety injection pump and minimum flow recirculation check valve testing on July 11, 2018
 
: (2) Main steam safety valve testing on September 25, 2018 Unit 3
(1) 'B' high pressure safety injection pump and minimum flow recirculation check valve testing on July 11, 2018
: (2) Main steam safety valve testing on September 25, 2018  
 
Unit 3
: (3) SP 3612A.1 - containment inspection surveillance on August 29, 2018
: (3) SP 3612A.1 - containment inspection surveillance on August 29, 2018
: (4) SP 3670.4 - quarterly station blackout preventive maintenance testing on September 13,
: (4) SP 3670.4 - quarterly station blackout preventive maintenance testing on September 13,


==RADIATION SAFETY==
==RADIATION SAFETY==
==71124.04 - Occupational Dose Assessment   Source Term Characterization==
==71124.04 - Occupational Dose Assessment==
{{IP sample|IP=IP 71124.04|count=1}}
===Source Term Characterization (1 Sample)===
 
The inspectors evaluated Dominion Energys source term characterization.
===The inspectors evaluated Dominion Energys source term characterization.
External Dosimetry===
{{IP sample|IP=IP 71124.04|count=1}}


===External Dosimetry (1 Sample)===
The inspectors evaluated Dominion Energys external dosimetry program.
The inspectors evaluated Dominion Energys external dosimetry program.


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==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
 
==71152 - Problem Identification and Resolution==
==71152 - Problem Identification and Resolution   Semiannual Trend Review==
===Semiannual Trend Review (1 Sample)===
{{IP sample|IP=IP 71152|count=1}}
 
The inspectors reviewed Dominion Energys corrective action program for trends that might be indicative of a more significant safety issue.
The inspectors reviewed Dominion Energys corrective action program for trends that might be indicative of a more significant safety issue.


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==INSPECTION RESULTS==
==INSPECTION RESULTS==
Failure to Assure that Safety-Related Service Water Piping Conformed to the Procurement Documents Cornerstone         Significance                                 Cross-         Report cutting        Section Aspect Mitigating           Green                                         None            71111.15 Systems              NCV 05000336/2018003-01 Closed The inspectors identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the ANSI B31.1 code, a condition of the purchase order, and was installed in the plant.
Failure to Assure that Safety-Related Service Water Piping Conformed to the Procurement Documents Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000336/2018003-01 Closed  
 
None 71111.15 The inspectors identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the ANSI B31.1 code, a condition of the purchase order, and was installed in the plant.


=====Description:=====
=====Description:=====
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Violation: 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, states in part, measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.
Violation: 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, states in part, measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.


Procurement document (purchase order 45768656) specified that all materials, fabrication and testing shall be in accordance with the requirements of ANSI B31.1, 1973 edition, no addenda...
Procurement document (purchase order 45768656) specified that all materials, fabrication and testing shall be in accordance with the requirements of ANSI B31.1, 1973 edition, no addenda...  
 
Paragraph 136.4.2 of ANSI B31.1, Power Piping, 1973 edition states in part that cracks and lack of fusion on the surface of welds is unacceptable.
Paragraph 136.4.2 of ANSI B31.1, Power Piping, 1973 edition states in part that cracks and lack of fusion on the surface of welds is unacceptable.


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Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.


71152 Observation Semi-Annual Trend Review The inspectors reviewed a sample of condition reports over the last 18 months that identified out of tolerance measuring and test equipment (M&TE). For the sample reviewed, the inspectors reviewed the licensees corrective actions, which included M&TE evaluation records. The M&TE evaluation records included the usage log to ensure that the out of tolerance condition did not invalidate a previously performed measurement or test associated with an activity affecting quality. Moreover, the inspectors noted that the licensee had appropriately entered out of tolerance M&TE into the corrective action program as required by their internal procedures.
Observation 71152 Semi-Annual Trend Review The inspectors reviewed a sample of condition reports over the last 18 months that identified out of tolerance measuring and test equipment (M&TE). For the sample reviewed, the inspectors reviewed the licensees corrective actions, which included M&TE evaluation records. The M&TE evaluation records included the usage log to ensure that the out of tolerance condition did not invalidate a previously performed measurement or test associated with an activity affecting quality. Moreover, the inspectors noted that the licensee had appropriately entered out of tolerance M&TE into the corrective action program as required by their internal procedures.


71152 Observation                                  Annual Follow-up of Selected Issues Condition Reports 3029256 and 107137, Supplemental Leak Collection and Release System (SLCRS) Damper and Duct Vibration Dampener Failures.
Observation 71152 Annual Follow-up of Selected Issues Condition Reports 3029256 and 107137, Supplemental Leak Collection and Release System (SLCRS) Damper and Duct Vibration Dampener Failures.


The inspectors determined that following identification of the failed damper and boots, Dominion Energy took adequate corrective actions to correct the deficiencies. Specifically, Dominion Energy replaced the failed damper and repaired the tears in the rubberized fabric duct vibration dampeners. Additionally, the inspectors concluded that the root cause analysis performed was thorough and identified appropriated root and contributing causes.
The inspectors determined that following identification of the failed damper and boots, Dominion Energy took adequate corrective actions to correct the deficiencies. Specifically, Dominion Energy replaced the failed damper and repaired the tears in the rubberized fabric duct vibration dampeners. Additionally, the inspectors concluded that the root cause analysis performed was thorough and identified appropriated root and contributing causes.
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The inspectors reviewed the root cause evaluation and noted that Dominion Energy staff identified a root cause and two contributing causes which led to the failure. However, the inspectors identified that there were no planned or completed corrective actions for one of the contributing causes. Specifically, Dominion Energy staff identified a contributing cause for the damper failure which stated that Dominion Energy staff had not monitored the damper for degrading performance. The evaluation listed an existing procedure that could be used to monitor performance but Dominion Energy staff subsequently determined that the procedure could not be performed on line. The inspectors determined that there were no other actions created to address the identified contributing cause. Following identification of the issue, Dominion Energy staff intended to review the contributing cause and determine if other actions could address the identified contributing cause. The inspectors noted Dominion Energy staff had completed corrective actions to replace the damper which corrected the condition adverse to quality.
The inspectors reviewed the root cause evaluation and noted that Dominion Energy staff identified a root cause and two contributing causes which led to the failure. However, the inspectors identified that there were no planned or completed corrective actions for one of the contributing causes. Specifically, Dominion Energy staff identified a contributing cause for the damper failure which stated that Dominion Energy staff had not monitored the damper for degrading performance. The evaluation listed an existing procedure that could be used to monitor performance but Dominion Energy staff subsequently determined that the procedure could not be performed on line. The inspectors determined that there were no other actions created to address the identified contributing cause. Following identification of the issue, Dominion Energy staff intended to review the contributing cause and determine if other actions could address the identified contributing cause. The inspectors noted Dominion Energy staff had completed corrective actions to replace the damper which corrected the condition adverse to quality.


71152 Observation                                Annual Follow-up of Selected Issues The inspectors assessed Dominion Energys problem identification and resolution actions associated with Millstone Unit 2 RPS module deficiencies previously identified by the licensee, to determine whether Dominion Energys staff was appropriately identifying, characterizing, and correcting the issues.
Observation 71152 Annual Follow-up of Selected Issues The inspectors assessed Dominion Energys problem identification and resolution actions associated with Millstone Unit 2 RPS module deficiencies previously identified by the licensee, to determine whether Dominion Energys staff was appropriately identifying, characterizing, and correcting the issues.


Since the third quarter of 2015, subsequent System Health Report ratings associated with Unit 2 RPS have improved due to no new failed RPS bistable trip unit modules. Dominion Energys actions to resolve previously identified Unit 2 RPS module deficiencies have been adequate, which included the strategy to reverse engineer and replace obsolete RPS bistable trip unit modules during the next refuel outages.
Since the third quarter of 2015, subsequent System Health Report ratings associated with Unit 2 RPS have improved due to no new failed RPS bistable trip unit modules. Dominion Energys actions to resolve previously identified Unit 2 RPS module deficiencies have been adequate, which included the strategy to reverse engineer and replace obsolete RPS bistable trip unit modules during the next refuel outages.


71152 Observation                                Annual Follow-up of Selected Issues The inspectors performed a review of the licensees responses, programs, procedures, and corrective action program entries associated with Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. The inspectors review was focused on the implementation of condition monitoring and mitigation of gas voiding. The review included issues documented outside the normal correction action program in corrective maintenance work orders, component status reports, and procedure changes. The inspectors review nominally considered the period of January 2016 through September 2018.
Observation 71152 Annual Follow-up of Selected Issues The inspectors performed a review of the licensees responses, programs, procedures, and corrective action program entries associated with Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. The inspectors review was focused on the implementation of condition monitoring and mitigation of gas voiding. The review included issues documented outside the normal correction action program in corrective maintenance work orders, component status reports, and procedure changes. The inspectors review nominally considered the period of January 2016 through September 2018.


The inspectors determined that Dominion Energy, in general, is in compliance with their responses to the generic communication. Adverse conditions identified in accordance with established programs are entered within the corrective action program and corrective actions are implemented in accordance with their safety significance including but not limited to procedure changes and plant modifications. Based upon the conditions reviewed and corrective actions taken the inspectors have identified no more than minor concerns nor has Dominion Energy established a problem resolution process outside of the corrective action program which could adversely impact the capability of the station to correct identified conditions adverse to quality.
The inspectors determined that Dominion Energy, in general, is in compliance with their responses to the generic communication. Adverse conditions identified in accordance with established programs are entered within the corrective action program and corrective actions are implemented in accordance with their safety significance including but not limited to procedure changes and plant modifications. Based upon the conditions reviewed and corrective actions taken the inspectors have identified no more than minor concerns nor has Dominion Energy established a problem resolution process outside of the corrective action program which could adversely impact the capability of the station to correct identified conditions adverse to quality.
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71111.15 - Operability Determinations and Functionality Assessments
71111.15 - Operability Determinations and Functionality Assessments
Condition Reports
Condition Reports
486877                 1104311               1104353             1104480
486877
1104725                 1104822
1104311
1104353
1104480
1104725
1104822
Maintenance Orders/Work Orders
Maintenance Orders/Work Orders
203227119             53203227387            53203227475
203227119
203227387
203227475
Miscellaneous
Miscellaneous
203-26008, Sheet 2, Piping and Instrument Diagram Service Water, Revision 114
203-26008, Sheet 2, Piping and Instrument Diagram Service Water, Revision 114
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203-20150, A or B train service water supply from intake structure, Revision 28
203-20150, A or B train service water supply from intake structure, Revision 28
Section 3.34, Class JGD, or Specification SP-ME-668
Section 3.34, Class JGD, or Specification SP-ME-668
Receipt inspection records for piping spool JGD-1-25
Receipt inspection records for piping spool JGD-1-25  
 
T-02559-S2, MPS Cooldown/CST Analysis Data, Revision 0
T-02559-S2, MPS Cooldown/CST Analysis Data, Revision 0
A-MP-FE-005, Millstone Point Unit 2 CST Inventory Analysis, Revision 0
A-MP-FE-005, Millstone Point Unit 2 CST Inventory Analysis, Revision 0
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SP2624B, B emergency diesel Generator Auxiliaries Inservice Testing, Revision 002-07
SP2624B, B emergency diesel Generator Auxiliaries Inservice Testing, Revision 002-07
Condition Reports
Condition Reports
1104027             1104066               1104821
1104027
1104066
1104821
Maintenance Orders/Work Orders
Maintenance Orders/Work Orders
53M20701303         53103056696           53203224057          53203225383
53M20701303
203226879         53203227915
53103056696
203224057
203225383
203226879
203227915
Miscellaneous
Miscellaneous
Post-Maintenance Test Plan for WO 53103056696, dated 9/5/2018
Post-Maintenance Test Plan for WO 53103056696, dated 9/5/2018
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SP 3612A.1-001, Containment Inspection, Revision 015-01
SP 3612A.1-001, Containment Inspection, Revision 015-01
Condition Reports
Condition Reports
1104310             1104313               1104320
1104310
1104313
1104320
Miscellaneous
Miscellaneous
Completed surveillance form for B HPSI Pump and Check Valve IST, Facility 1 on July 11,
Completed surveillance form for B HPSI Pump and Check Valve IST, Facility 1 on July 11,
2018
2018  
 
71152 - Problem Identification and Resolution
71152 - Problem Identification and Resolution
Procedures
Procedures
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SLCRS Negative Pressure Verification Train A Trend 5/11/10 to 10/13/17
SLCRS Negative Pressure Verification Train A Trend 5/11/10 to 10/13/17
MP 3704A-600, Mechanical Preventative Maintenance, Revision 0
MP 3704A-600, Mechanical Preventative Maintenance, Revision 0
RCE 3029256 Root Cause Evaluation - Supplemental Leak Collection and Release System
RCE 3029256 Root Cause Evaluation - Supplemental Leak Collection and Release System  
      (SLCRS) Negative Pressure Surveillance Failed to Meet Acceptance Criteria on 4/9/16
(SLCRS) Negative Pressure Surveillance Failed to Meet Acceptance Criteria on 4/9/16
VTM 25212-594-001, Air and Motor Operated Dampers, Revision 0
VTM 25212-594-001, Air and Motor Operated Dampers, Revision 0
95-ENG-1139 M3, Max. Allowable Penetration in Secondary Containment Boundary, Revision 0
95-ENG-1139 M3, Max. Allowable Penetration in Secondary Containment Boundary, Revision 0
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MA-AA-400, Measuring and Test Equipment, Revision 8
MA-AA-400, Measuring and Test Equipment, Revision 8
Condition Reports
Condition Reports
CA3025314             1033408             1045255               1063575
CA3025314
1063792               1064325             1070828               1071377
1033408
1073475               1082596             1094848               1098287
1045255
1098759               1101028             1101055               1101065
1063575
1101251               1101255             1101649               1101760
1063792
1102125               1102668             1103260
1064325
1070828
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1094848
1098287
1098759
1101028
1101055
1101065
1101251
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1101760
1102125
1102668
1103260
Work Orders
Work Orders
53102407011           53102932891         53103116895
53102407011
53102932891
53103116895
Drawings
Drawings
103226, Sheet 1, Schem Diag. PC Assy. Aux Bistable Trip Module, RPS, Revision F
103226, Sheet 1, Schem Diag. PC Assy. Aux Bistable Trip Module, RPS, Revision F
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Reactor Protection System Health Report, Quarter 2, 2016
Reactor Protection System Health Report, Quarter 2, 2016
Reactor Protection System Health Report, Quarter 4, 2016
Reactor Protection System Health Report, Quarter 4, 2016
Reactor Protection System Health Report, Quarter 2, 2017
Reactor Protection System Health Report, Quarter 2, 2017  
 
Reactor Protection System Health Report, Quarter 4, 2017
Reactor Protection System Health Report, Quarter 4, 2017
Reactor Protection System Health Report, Quarter 2, 2018
Reactor Protection System Health Report, Quarter 2, 2018

Latest revision as of 09:49, 5 January 2025

Integrated Inspection Report 05000336/2018003 and 05000423/2018003
ML18311A293
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 11/02/2018
From: Daniel Schroeder
Reactor Projects Branch 2
To: Stoddard D
Dominion Energy
Schroeder D
References
IR 2018003
Download: ML18311A293 (18)


Text

November 2, 2018

SUBJECT:

MILLSTONE POWER STATION - INTEGRATED INSPECTION REPORT 05000336/2018003 AND 05000423/2018003

Dear Mr. Stoddard:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station (Millstone), Units 2 and 3. On October 11, 2018, the NRC inspectors discussed the results of this inspection with Mr. John Daugherty, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

The finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRCs Resident Inspector at Millstone. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 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 05000336/2018003 and 05000423/2018003

Inspection Report

Docket Numbers:

50-336 and 50-423

License Numbers:

DPR-65 and NPF-49

Report Numbers:

05000336/2018003 and 05000423/2018003

Enterprise Identifier: I-2018-003-0077

Licensee:

Dominion Energy Nuclear Connecticut, Inc. (Dominion Energy)

Facility:

Millstone Power Station (Millstone), Units 2 and 3

Location:

P.O. Box 128

Waterford, CT 06385

Inspection Dates:

July 1 to September 30, 2018

Inspectors:

J. Fuller, Senior Resident Inspector

L. McKown, Resident Inspector

C. Highley, Resident Inspector

K. Mangan, Senior Reactor Inspector

H. Anagnostopoulos, Senior Health Physicist

L. Dumont, Reactor Inspector

B. Haagensen, Senior Resident Inspector

Approved By:

Daniel L. Schroeder, Chief

Reactor Projects Branch 2

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Dominion Energys 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.

List of Findings and Violations

Failure to Assure that Safety-Related Service Water Piping Conformed to the Procurement Documents Cornerstone Significance Cross-cutting Aspect Inspection Results Section Mitigating Systems Green NCV 05000336/2018003-01 Closed

None 71111.15 The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the American National Standards Institute (ANSI) B31.1 code, a condition of the purchase order, and was installed in the plant.

PLANT STATUS

Unit 2 and 3 operated at or near rated thermal power for the entire inspection period, except that on September 13, 2018, Unit 2 began a coast down to a scheduled refueling outage that started on September 27,

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

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains at Unit 2:

(1) 'B' high pressure safety injection pump discharge flowpath in the auxiliary building on July 11, 2018

(2) Boric acid system on August 21, 2018 (3) 'A', 'B', and 'C' service water pump discharge at the intake building on September 4, 2018

71111.05A/Q - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

Unit 2

(1) A, B, and C safeguards pump rooms (Fire Areas A-8A, A-3 and A-4) on July 11, 2018
(2) Auxiliary building (elevation 14' 6") east and west DC switchgear rooms (Fire Areas A-20 and A22) and associated 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> fire watch due to fire suppression system being out of service for planned battery inspections on September 10, 2018 Unit 3
(3) Observation of plant equipment operator response to MP3 fire pump house fire/trouble control room alarm and inspection of fire pump house (Fire Zone FP-1) on August 22, 2018
(4) Station blackout diesel (Fire Area SBO-1) on September 13, 2018
(5) East floor area of engineered safety features building at elevation 4' 6" (Fire Area ESF-4)on September 25, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (2 Samples)

The inspectors observed and evaluated Unit 2 control room simulator operator requalification training associated with a loss of all AC power while in Mode 5 on September 6, 2018.

The inspectors observed and evaluated Unit 3 control room simulator licensed operator requalification training associated with loss of offsite power on July 31, 2018.

Operator Performance (2 Samples)

The inspectors observed Unit 2 operator performance on plant downpower, annunciator response procedure for process radiation monitor hi hi/fail, shift turnover, and control room rounds on July 13, 2018.

The inspectors observed Unit 3 operator performance while swapping trains of control building chilled water and reactivity manipulations on August 1, 2018.

71111.12 - Maintenance Effectiveness

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issue:

(1) Unit 3 reactor protection system Rakset 2 card (PQY-403A) power supply card item equivalency evaluation on August 31, 2018.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

Unit 2

(1) Inspection of in-process pre-outage scaffold erection in the turbine building combined with other planned medium (B service water pump maintenance outage) and high risk activities (switchyard work) on August 29, 2018
(2) Open phase project cable pulls into main control room control boards through fire penetration seals on September 10, 2018
(3) Emergent elevated risk when 'A' service water pump discharge strainer backwash failed to auto start with high differential pressure detected on September 10, 2018
(4) Elevated risk associated with B emergency diesel generator out of service and station blackout diesel unavailable during functionality testing on September 13, 2018

Unit 3

(5) High risk plan for line 348 out of service for repair of hot spot at Haddam 11C substation on August 22, 2018
(6) Elevated risk associated with maintenance in containment - pressurizer spray bypass valve and equipment environmental qualification temperature transmitter card on August 29, 2018
(7) Emergent high risk of opening one of two station output breakers online on September 27, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

Unit 2

(1) Condition Report 1096849 - revision to atmospheric dump valve capacity on August 28, 2018
(2) Condition Reports 1104311, 1104353, 1104480, 1104725, and 1104822 - 'A' and 'B' service water piping weld indications identified on August 29, 2018

Unit 3

(3) Condition Reports 1101173 and 1101191 - common mode impact of failure of A train motor control center rod control area service water booster pump during 'A' train service water surveillance testing on July 9, 2018
(4) Condition Report 1101277 - 'A' emergency diesel generator intermittent ready to load failure on July 10, 2018
(5) Condition Report 1102610 - intermediate range neutron flux level high channel 1 sequence of events recorder indication in on August 1, 2018
(6) Condition Report 1105120 - received multiple main board alarms for 'A' emergency diesel generator on September 12, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary modification:

(1) Unit 2 pressurizer proportional heater modification inside containment on September 18, 2018

71111.19 - Post Maintenance Testing

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

Unit 2

(1) 'B' service water pump motor and discharge check valve (2-SW-1B) post maintenance testing on September 2, 2018 (2) 'B' emergency diesel generator post maintenance testing associated with planned replacement of 2DG-95B, control air solenoid operated valve assembly, on September 13 and 14, 2018

Unit 3

(3) 'A' emergency diesel generator governor tuning following identification of intermittent ready to load failure on July 10, 2018

(4) Repair and replacement of degraded buried auxiliary condensate piping identified during planned underground piping inspection on August 6, 2018
(5) Post maintenance testing for failure of Rakset 2 card PQY-403A power supply on August 27, 2018
(6) Containment isolation valve CDS*CTV40A, chilled water return header, sliding link failure and repair during quarterly surveillance testing on September 10, 2018
(7) Corrective maintenance on 'C' reactor plant chilled water chiller control linkage following failure to load on September 11, 2018
(8) Power supply replacement following 'A' emergency diesel generator annunciator failure on September 13, 2018

71111.20 - Refueling and Other Outage Activities

The inspectors evaluated scheduled Unit 2 refueling outage (2R25) activities from September 27 through September 30, 2018. The outage, and implementation of this inspection procedure, continues in the fourth quarter.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine

Unit 2

(1) 'B' high pressure safety injection pump and minimum flow recirculation check valve testing on July 11, 2018

(2) Main steam safety valve testing on September 25, 2018

Unit 3

(3) SP 3612A.1 - containment inspection surveillance on August 29, 2018
(4) SP 3670.4 - quarterly station blackout preventive maintenance testing on September 13,

RADIATION SAFETY

71124.04 - Occupational Dose Assessment

Source Term Characterization (1 Sample)

The inspectors evaluated Dominion Energys source term characterization.

External Dosimetry (1 Sample)

The inspectors evaluated Dominion Energys external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated Dominion Energys internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated Dominion Energys performance for special dosimetric situations.

OTHER ACTIVITIES - BASELINE

71152 - Problem Identification and Resolution

Semiannual Trend Review (1 Sample)

The inspectors reviewed Dominion Energys corrective action program for trends that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (3 Samples)

The inspectors reviewed Dominion Energys implementation of its corrective action program related to the following issue:

(1) Condition Reports 3029256 and 107137, Supplemental Leak Collection and Release System (SLCRS) Damper and Duct Vibration Dampener Failures on July 19, 2018
(2) Reactor Protection System (RPS) module deficiencies on August 6, 2018
(3) Millstone Power Station Response to Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems on September 17,

INSPECTION RESULTS

Failure to Assure that Safety-Related Service Water Piping Conformed to the Procurement Documents Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000336/2018003-01 Closed

None 71111.15 The inspectors identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the ANSI B31.1 code, a condition of the purchase order, and was installed in the plant.

Description:

On August 29, 2018, during a walk down of the Millstone Unit 2 service water piping, the NRC inspectors identified two areas of concern on the 24 diameter, B service water pump discharge strainer assembly piping (spool number JGD-1-25). One area of concern was in the slip-on flange weld connecting the pipe to the strainer and the other area was in the slip-on flange weld connected to 2-SW-2B (B service water pump discharge stop valve). The inspectors visually observed crack-like, linear indications at the weld start/stop locations. At the time of the inspection, the subject piping was out of service due to unrelated scheduled maintenance on the B service water pump and discharge check valve. The other two trains of service water were in service and protected while the B train was out of service.

Technical specifications require that two of the three service water pumps remain operable.

The B service water pump is a safety-related swing pump that can supply water to either of the two service water headers.

Spool JGD-1-25 was receipt inspected on September 5, 2012, and installed on March 18, 2014. The as-built condition of the spool piece was certified by the supplier to be in conformance with the ANSI B31.1, - 1973 code and a certificate of conformance was provided to the licensee. The licensees receipt inspection plan did not require the inspector to visually check the fillet weld quality.

After the NRC identified the concern, the licensees quality control inspector and weld supervisor visually inspected the welds and recommended a liquid penetrant (PT)examination be performed. The licensee initiated Condition Report 1104311 to document the potential weld issues.

On August 30, 2018, the PT exam identified rejectable indications. The licensee initiated Condition Report 1104353 and generated Work Order 53203227119 to provide a weld metal repair disposition, weld data sheet, and American Society of Mechanical Engineers (ASME)

Section XI repair / replacement plan.

On August 31, 2018, the licensee began the excavation of the indications and determined that they were through the entire depth of the fillet weld and approximately 8.75 in circumferential length. The licensee performed a code weld repair, a final visual and PT inspection, and returned the B service water pump to service on September 2, 2018. During the extent of condition review, the licensee identified that another 24 spool, spool number JGD-1-4, contained a 1 long area of lack of fusion along the weld toe. Condition Report 1106916 was written to identify and correct the lack of fusion.

The licensee completed a structural integrity assessment of the as-found welds and determined that the service water piping would have been able to perform its intended safety function for all design loading conditions.

Corrective Actions: The licensee removed the weld defects, completed a weld repair, and performed a final visual and PT examination. The licensee also completed a structural integrity assessment of the as-found welds and determined that the service water piping would have been able to perform its intended safety function for all design loading conditions.

The licensee also created corrective action assignments to evaluate the adequacy of their receipt inspection process, conduct an extent of condition review, and evaluate the issue under 10 CFR Part 21 requirements.

Corrective Action References: The licensee initiated Condition Reports 1104311, 1104353, 1106916 and Work Order 53203227119.

Performance Assessment:

Performance Deficiency: The licensee failed to meet the requirements of 10 CFR Part 50, Appendix B, Criterion VII, because the licensee failed to assure that safety-related service water piping conformed to ANSI B31.1, Power Piping, 1973 edition, which was specified by the procurement documents. The weld defects were reasonably within the licensees ability to identify and correct prior to acceptance and installation.

Screening: The failure to assure that safety-related service water piping conformed to code requirements was associated with the reactor safety Mitigating Systems cornerstone attribute of Equipment Performance because the installation of a pipe spool that did not meet the ANSI B31.1 code requirements adversely affected the cornerstone objective to ensure the availability of the service water system. The through-weld defects caused the B service water pump train to remain unavailable and nonconforming pending a code repair or structural integrity assessment. This issue is similar to example 5.c of IMC 0612, Appendix E, Examples of Minor Issues; in that, the nonconforming pipe spool was installed on March 18, 2014, and was regularly relied upon to provide water to the safety-related service water headers from 2014 to 2018.

Significance: The inspectors assessed the significance of the finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was a deficiency affecting the qualification of a single train of a mitigating system, where the remaining trains of the system maintained operability or functionality despite the single degraded train.

Therefore, the inspectors determined the finding to be of very low safety significance (Green).

Cross-Cutting Aspect: No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect current licensee performance.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, states in part, measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.

Procurement document (purchase order 45768656) specified that all materials, fabrication and testing shall be in accordance with the requirements of ANSI B31.1, 1973 edition, no addenda...

Paragraph 136.4.2 of ANSI B31.1, Power Piping, 1973 edition states in part that cracks and lack of fusion on the surface of welds is unacceptable.

Contrary to the above, the licensee failed to assure that the purchased material conformed to the procurement documents. Specifically, the licensee failed to assure that welds on service water piping spool JGD-1-25, item 42 of Purchase Order 45768656, were free from cracks and lack of fusion on the surface.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Observation 71152 Semi-Annual Trend Review The inspectors reviewed a sample of condition reports over the last 18 months that identified out of tolerance measuring and test equipment (M&TE). For the sample reviewed, the inspectors reviewed the licensees corrective actions, which included M&TE evaluation records. The M&TE evaluation records included the usage log to ensure that the out of tolerance condition did not invalidate a previously performed measurement or test associated with an activity affecting quality. Moreover, the inspectors noted that the licensee had appropriately entered out of tolerance M&TE into the corrective action program as required by their internal procedures.

Observation 71152 Annual Follow-up of Selected Issues Condition Reports 3029256 and 107137, Supplemental Leak Collection and Release System (SLCRS) Damper and Duct Vibration Dampener Failures.

The inspectors determined that following identification of the failed damper and boots, Dominion Energy took adequate corrective actions to correct the deficiencies. Specifically, Dominion Energy replaced the failed damper and repaired the tears in the rubberized fabric duct vibration dampeners. Additionally, the inspectors concluded that the root cause analysis performed was thorough and identified appropriated root and contributing causes.

The inspectors reviewed the root cause evaluation and noted that Dominion Energy staff identified a root cause and two contributing causes which led to the failure. However, the inspectors identified that there were no planned or completed corrective actions for one of the contributing causes. Specifically, Dominion Energy staff identified a contributing cause for the damper failure which stated that Dominion Energy staff had not monitored the damper for degrading performance. The evaluation listed an existing procedure that could be used to monitor performance but Dominion Energy staff subsequently determined that the procedure could not be performed on line. The inspectors determined that there were no other actions created to address the identified contributing cause. Following identification of the issue, Dominion Energy staff intended to review the contributing cause and determine if other actions could address the identified contributing cause. The inspectors noted Dominion Energy staff had completed corrective actions to replace the damper which corrected the condition adverse to quality.

Observation 71152 Annual Follow-up of Selected Issues The inspectors assessed Dominion Energys problem identification and resolution actions associated with Millstone Unit 2 RPS module deficiencies previously identified by the licensee, to determine whether Dominion Energys staff was appropriately identifying, characterizing, and correcting the issues.

Since the third quarter of 2015, subsequent System Health Report ratings associated with Unit 2 RPS have improved due to no new failed RPS bistable trip unit modules. Dominion Energys actions to resolve previously identified Unit 2 RPS module deficiencies have been adequate, which included the strategy to reverse engineer and replace obsolete RPS bistable trip unit modules during the next refuel outages.

Observation 71152 Annual Follow-up of Selected Issues The inspectors performed a review of the licensees responses, programs, procedures, and corrective action program entries associated with Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. The inspectors review was focused on the implementation of condition monitoring and mitigation of gas voiding. The review included issues documented outside the normal correction action program in corrective maintenance work orders, component status reports, and procedure changes. The inspectors review nominally considered the period of January 2016 through September 2018.

The inspectors determined that Dominion Energy, in general, is in compliance with their responses to the generic communication. Adverse conditions identified in accordance with established programs are entered within the corrective action program and corrective actions are implemented in accordance with their safety significance including but not limited to procedure changes and plant modifications. Based upon the conditions reviewed and corrective actions taken the inspectors have identified no more than minor concerns nor has Dominion Energy established a problem resolution process outside of the corrective action program which could adversely impact the capability of the station to correct identified conditions adverse to quality.

EXIT MEETINGS AND DEBRIEFS

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

On October 11, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. John Daugherty, Site Vice President, and other members of the Millstone staff.

DOCUMENTS REVIEWED

71111.04 - Equipment Alignment

Miscellaneous

203-26017 SH3, P&ID Boric Acid System, Revision 0

71111.05 - Fire Protection

Condition Reports

1103869

Miscellaneous

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

Millstone Unit 3 Fire Protection Evaluation Report, Revision 21.3

71111.11 - Licensed Operator Requalification Program

Procedures

OP 2204, Load Changes, Revision 040

ARP 2590E-135, Process monitor Radiation Hi Hi/Fail, Revision 001-04

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Procedures

OP-MP-601, Protected Equipment, Revision 28

Miscellaneous

EOOS Version 4.1 for Millstone Unit 2 on September 13, 2018

EOOS Version 4.1 for Millstone Unit 3 on August 29, 2018

EOOS Version 4.1 for Millstone Unit 3 on September 27, 2018

High risk plan for line 348 out of service on August 22, 2018

High risk plan for MP2 Open Phase Project, dated August 23, 2018 for work performed on

September 10, 2018

71111.15 - Operability Determinations and Functionality Assessments

Condition Reports

486877

1104311

1104353

1104480

1104725

1104822

Maintenance Orders/Work Orders

203227119

203227387

203227475

Miscellaneous

203-26008, Sheet 2, Piping and Instrument Diagram Service Water, Revision 114

203-20194, Sheet 3527, Spool Piece JGD-1-25 above ground service water discharge to

turbine & aux building IC-680, Revision 3

203-20150, A or B train service water supply from intake structure, Revision 28

Section 3.34, Class JGD, or Specification SP-ME-668

Receipt inspection records for piping spool JGD-1-25

T-02559-S2, MPS Cooldown/CST Analysis Data, Revision 0

A-MP-FE-005, Millstone Point Unit 2 CST Inventory Analysis, Revision 0

71111.18 - Plant Modifications

Procedures

MP2-18-00201, Temporary Removal of Failed Pressurizer Proportional Heater, Revision 0

71111.19 - Post-Maintenance Testing

Procedures

SP3442J01, RCS Wide Range Pressure, Revision 008

SP2613P, B Emergency diesel Generator Hot Restart, Revision 003

SP2624B, B emergency diesel Generator Auxiliaries Inservice Testing, Revision 002-07

Condition Reports

1104027

1104066

1104821

Maintenance Orders/Work Orders

53M20701303

53103056696

203224057

203225383

203226879

203227915

Miscellaneous

Post-Maintenance Test Plan for WO 53103056696, dated 9/5/2018

71111.20 - Refueling and Other Outage Activities

Procedures

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

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

OP 2301E, Draining the RCS (ICCE), Revision 032

MP 2704AA1, Unit 2 Reactor Head Removal and Installation (ICCE), Revision 002-00

Miscellaneous

Shutdown Risk Review Checklist for 2R25

Memo dated September 25, 2018; 2R25 Shutdown Risk Schedule Review

71111.22 - Surveillance Testing

Procedures

SP 2604AO, HPSI Pump Inservice Testing, greater than 1,750 psia, Facility 1, Revision 007

SP 21157, HPSI System and ECCS Suction Leakage Test, Revision 011

SP 3670.4, Quarterly Station Blackout Preventive Maintenance, Revision 035-00

SP 3612A.1-001, Containment Inspection, Revision 015-01

Condition Reports

1104310

1104313

1104320

Miscellaneous

Completed surveillance form for B HPSI Pump and Check Valve IST, Facility 1 on July 11,

2018

71152 - Problem Identification and Resolution

Procedures

SP 3614I.3, SLCRS Negative Pressure Verification - Train A, Revision 006-03, performed

10/13/17

SP 3614I.3, SLCRS Negative Pressure Verification - Train B, Revision 8, performed 11/10/17

SP 3670.4-002, Monthly PMs, Revision 19, performed 6/9/18

SLCRS Negative Pressure Verification Train B Trend 5/11/10 to 11/10/17

SLCRS Negative Pressure Verification Train A Trend 5/11/10 to 10/13/17

MP 3704A-600, Mechanical Preventative Maintenance, Revision 0

RCE 3029256 Root Cause Evaluation - Supplemental Leak Collection and Release System

(SLCRS) Negative Pressure Surveillance Failed to Meet Acceptance Criteria on 4/9/16

VTM 25212-594-001, Air and Motor Operated Dampers, Revision 0

95-ENG-1139 M3, Max. Allowable Penetration in Secondary Containment Boundary, Revision 0

212-26952, Sht. 1, ESF and MSV Buildings Ventilation, Revision 21

212-26952, Sht. 2, ESF and MSV Buildings Ventilation, Revision 16

212-26948, Sht. 1, Reactor Building Ventilation, Revision 42

212-26948, Sht. 2, Reactor Building Ventilation, Revision 28

212-26948, Sht. 7, Reactor Building Ventilation, Revision 23

ER-AA-10, Equipment Reliability Process, Revision 5

ER-AA-AMP-101, Implementation of Activities Performed by License Renewal Aging

Management Coordinators, Revision 9

ER-AA-PRS-1010, Preventive Maintenance Task Basis & Maintenance Strategy, Revision 10

MA-AA-400, Measuring and Test Equipment, Revision 8

Condition Reports

CA3025314

1033408

1045255

1063575

1063792

1064325

1070828

1071377

1073475

1082596

1094848

1098287

1098759

1101028

1101055

1101065

1101251

1101255

1101649

1101760

1102125

1102668

1103260

Work Orders

53102407011

53102932891

53103116895

Drawings

103226, Sheet 1, Schem Diag. PC Assy. Aux Bistable Trip Module, RPS, Revision F

Miscellaneous

ETE-CME-2015-1004, Basis of GL 2008-01 ECCS, DHR & CS Gas Accumulation Surveillance

Program, Revision 1

MP2-15-01097, MP2 RPS Bistable Trip Units, Auxiliary Trip Units, ant Trip Test Cable

Assemblies Replacement, Revision 003

IC-1224, Procurement Specification for Reactor Protection System Bistable Trip Modules,

Auxiliary Trip Modules, and Test Cable Assemblies for Millstone Unit 2, Revision 1

VTM2-150-007A, Bistable Auxiliary Trip Unit Modules Technical Manual, Revision B

Reactor Protection System Health Report, Quarter 3, 2015

Reactor Protection System Health Report, Quarter 2, 2016

Reactor Protection System Health Report, Quarter 4, 2016

Reactor Protection System Health Report, Quarter 2, 2017

Reactor Protection System Health Report, Quarter 4, 2017

Reactor Protection System Health Report, Quarter 2, 2018

ML110540393

ML092960560