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# | {{Adams | ||
| number = ML072220286 | |||
| issue date = 08/10/2007 | |||
| title = IR 05000336-07-003 and 05000423-07-003, on 04/04/07 - 06/30/07, Millstone, Units 2 and 3, Inservice Inspection, Maintenance Effectiveness, Post-Maintenance Testing, and Surveillance Testing | |||
| author name = Powell R J | |||
| author affiliation = NRC/RGN-I/DRP/PB5 | |||
| addressee name = Christian D A | |||
| addressee affiliation = Dominion Resources, Inc | |||
| docket = 05000336, 05000423 | |||
| license number = DPR-065, NPF-049 | |||
| contact person = Powell R J, RI/DRP/610-337-6967 | |||
| document report number = IR-07-003 | |||
| document type = Inspection Report, Letter | |||
| page count = 63 | |||
}} | |||
{{IR-Nav| site = 05000336 | year = 2007 | report number = 003 }} | |||
=Text= | |||
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I475 ALLENDALE ROADKING OF PRUSSIA, PENNSYLVANIA 19406-1415 August 10, 2007Mr. David A. ChristianSr. Vice President and Chief Nuclear Officer Dominion Resources 5000 Dominion Boulevard Glenn Allen, VA 23060-6711 | |||
SUBJECT: MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT05000336/2007003 AND 05000423/2007003 | |||
==Dear Mr. Christian:== | |||
On June 30, 2007, the US Nuclear Regulatory Commission (NRC) completed an inspection atyour Millstone Power Station, Unit 2 and Unit 3. The enclosed inspection report documents the inspection results, which were discussed on July 10, 2007, with Mr. J. Alan Price, Site Vice President, and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license. | |||
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.This report documents two NRC-identified findings and two self-revealing findings of very lowsafety significance (Green). All of these findings were determined to involve violations of NRC requirements. However, because of their very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), consistent with Section VI.A.1 of the NRC's Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: | |||
Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Millstone Power Station.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in the Mr. D. Christian2NRC Public Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | |||
Sincerely,/RA/Raymond J. Powell, ChiefReactor Projects Branch 5 Division of Reactor ProjectsDocket Nos.:50-336, 50-423License Nos.:DPR-65, NPF-49 | |||
===Enclosure:=== | |||
Inspection Report 05000336/2007003 and 05000423/2007003 | |||
===w/Attachment:=== | |||
Supplemental Informationcc w/encl:J. A. Price, Site Vice President, Millstone StationC. L. Funderburk, Director, Nuclear Licensing and Operations Support D. W. Dodson, Supervisor, Station Licensing L. M. Cuoco, Senior Counsel C. Brinkman, Manager, Washington Nuclear Operations J. Roy, Director of Operations, Massachusetts Municipal Wholesale Electric Company First Selectmen, Town of Waterford B. Sheehan, Co-Chair, NEAC E. Woollacott, Co-Chair, NEAC E. Wilds, Director, State of Connecticut SLO Designee J. Buckingham, Department of Public Utility Control G. Proios, Suffolk County Planning Dept. | |||
R. Shadis, New England Coalition Staff G. Winslow, Citizens Regulatory Commission (CRC) | |||
S. Comley, We The People D. Katz, Citizens Awareness Network (CAN) | |||
R. Bassilakis, CAN J. M. Block, Attorney, CAN P. Eddy, Electric Division, Department of Public Service, State of New York M. Balboni, Deputy Secy, New York State Energy Research and Development Authority J. Spath, SLO Designee, New York State Energy Research and Development Authority M | |||
=SUMMARY OF FINDINGS= | |||
IR 05000336/2007003, 05000423/2007003; 04/01/2007 - 06/30/2007; Millstone Power Station,Unit 2 and Unit 3; Inservice Inspection, Maintenance Effectiveness, Post-Maintenance Testing, and Surveillance Testing.The report covered a 3-month period of inspection by resident inspectors and announcedinspections by regional inspectors. Four Green non-cited violations (NCVs) were identified. | |||
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.A. | |||
===NRC-Identified and Self-Revealing Findings=== | |||
===Cornerstone: Initiating Events=== | |||
: '''Green.''' | |||
The inspectors identified that Dominion did not follow Boric Acid CorrosionControl program procedures. Specifically, plant personnel failed to adequately perform boric acid leak evaluations as required by Dominion procedure DNAP-1004, "Boric Acid Corrosion Control Program." This finding was determined to be an NCV of 10 CFR 50, | |||
Appendix B, Criterion V, "Instructions, Procedures, and Drawings." Dominion's corrective actions for this issue included a general area cleaning program to remove boric acid residue from target components and ensuring the Boric Acid Corrosion Control program includes clear documentation of evaluations for both the leaking component and any associated target component(s).This finding was more than minor because it was associated with the humanperformance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, | |||
"Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue did not result in exceeding the Technical Specification limit for identified reactor coolant system (RCS) leakage or affect other mitigating systems resulting in a total loss of their safety function. Additionally, this finding is similar to IMC 0612, Appendix E, example 4a, in that the licensee routinely failed to perform engineering evaluations on similar issues; i.e., boric acid leaks. The performance deficiency had a cross-cutting aspect in the area of human performance, work practices component, because Dominion did not ensure personnel followed procedures. [H.4.(b)] (Section IR08)iv | |||
===Cornerstone: Mitigating Systems=== | |||
: '''Green.''' | |||
A self-revealing finding was identified when Dominion did not ensure anadequate work procedure was available for maintenance performed on the Unit 2 'C' | |||
charging pump on May 5, 2007, resulting in a failure of the pump on June 11, 2007. | |||
Specifically, the work procedure did not give specific guidance for assembly and installation of the suction poppet valve in accordance with direction provided in the vendor technical manual. On June 11, 2007, the 'C' charging pump failed and was declared inoperable due to a seized plunger shaft. This finding was determined to be an NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings." | |||
Dominion's corrective actions for this issue included repair and retest of the 'C' charging pump, revising the work procedure to include vendor recommendations, and training for maintenance personnel on assembly and installation of charging pump poppet valves.The finding was more than minor because it was associated with the procedural qualityattribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of human performance, resources component, because Dominion did not ensure that a complete, accurate, and adequate work procedure was available for maintenance performed on a safety-related component. [H.2.(c)] (Section 1R12)Green. The inspectors identified that Dominion did not adequately evaluate surveillancetest results to ensure test acceptance criteria had been met on May 10, 2007. | |||
Specifically, the inspectors identified that the 'C' charging pump pulsation dampener surveillance test had cited incorrect data and had been accepted as satisfactorily complete, though the test data was outside of the surveillance acceptance criteria. This finding was determined to be an NCV of 10 CFR 50, Appendix B, Criterion XI, "Test Control." The surveillance was successfully re-performed on May 13, 2007. Dominion's corrective actions for this issue included revising the surveillance to clarify test requirements and required reading for operations personnel on how to adequately document and review surveillance test data.The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify out of specification data could result in the failure to identify inoperable equipment. The inspectors also concluded that if the failure to properly evaluate charging pump discharge dampener test data was not corrected, a more significant concern could exist in that failure of the dampener has previously resulted in a loss of all charging due to the migration of nitrogen from a failed discharge pulsation dampener to the common suction piping for all three charging pumps (as described in NRC inspection reports v05000336/2006002 and 05000336/2006006). The inspectors conducted a Phase 1SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of problem identification and resolution, corrective action program component, because Dominion did not identify out of specification test data. [P.1.(a)] (Section 1R19)Green. A self-revealing finding was identified when Dominion incorrectly performed asafety-related surveillance procedure. Specifically, Operations mistakenly performed a biennial surveillance test that verified remote vent valve position by opening a nitrogen vent path and verifying a decrease in accumulator pressure for the Unit 3 'A' safety injection (SI) accumulator instead of the planned quarterly surveillance. As a result, the | |||
'A' SI accumulator was inadvertently depressurized to below the TS value. This finding was determined to be an NCV of TS 6.8.1, "Procedures." Dominion's corrective actions for this issue included restoring accumulator pressure, performing an apparent cause evaluation to determine the underlying causes associated with the error, training the personnel involved, and scheduling human performance training for Operations during training cycle 07-03. The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, | |||
"Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross cutting aspect in the area of human performance, work practice component, because Dominion's human error prevention techniques such as holding a pre-job brief and peer checking were not used to ensure the surveillance was properly performed. [H.4.(a)] (Section 1R22). | |||
===B.Licensee-Identified Violations=== | |||
None. | |||
Enclosure | |||
=REPORT DETAILS= | |||
Summary of Plant StatusUnit 2 operated at or near 100 percent power for the entire inspection period. | |||
Unit 3 began the inspection period operating at approximately 100 percent power. On April 6, 2007, Unit 3 performed a shutdown in preparation for Refueling Outage (RFO) 3R11. | |||
Following completion of RFO activities, Unit 3 achieved criticality on May 18, 2007. Unit 3 reached 100 percent power on May 22, 2007. From May 22, 2007, through the end of the inspection period, the Unit 3 operated at or near 100 percent power.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01) | |||
====a. Inspection Scope==== | |||
(One site sample)The inspectors performed a review of severe weather preparations during the onset ofthe hurricane season to evaluate the site's readiness for seasonal susceptibilities. The inspectors reviewed Dominion's preparations for severe weather and the protection of safety-related systems, structures and components (SSCs). The inspection ensured that the selected equipment, instrumentation, and supporting structures were configured in accordance with Dominion's procedures and that adequate controls were in place to ensure functionality of the systems. The inspectors reviewed the Unit 2 and Unit 3 Final Safety Analysis Report (FSAR) and Technical Specifications (TS) and compared the analysis with procedural requirements to determine whether procedures were consistent with the FSAR. The inspectors performed partial system walkdowns of the Unit 2 and Unit 3 intake structures, service water systems, intake structure traveling screens and emergency diesel generators (EDGs) to determine the adequacy of equipment protection from the effects of hurricanes. The inspectors verified that operator actions defined in the adverse weather procedures maintained readiness of essential systems and that adequate operator staffing was specified. Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
2Enclosure1R04Equipment Alignment (71111.04).1Partial System Walkdowns | |||
====a. Inspection Scope==== | |||
(Two Unit 2 and two Unit 3 samples)The inspectors performed four partial system walkdowns during this inspection period. The partial equipment alignment inspections were completed during conditions when the equipment was of increased safety significance such as would occur when redundant equipment was unavailable during maintenance or adverse conditions; or after equipment was recently returned to service after maintenance. The inspectors conducted a walkdown of each system to verify that the critical portions of selected systems were correctly aligned in accordance with applicable procedures and to identify any discrepancies that may have had an effect on operability. The inspectors verified that equipment alignment problems that could cause initiating events, impact mitigating system availability or function, or affect barrier functions, were identified and resolved. | |||
The following systems were reviewed based on their risk significance for the given plant configuration:Unit 2*Auxiliary feedwater (AFW) system during switchyard maintenance on April 27, 2007; and*Charging system 'A' and 'B' charging pumps during 'C' charging pump correctivemaintenance on June 13, 2007.Unit 3*Reactor coolant system (RCS) level instrumentation during reduced inventoryoperations on April 12, 2007; and*'A' EDG due to the 'B' EDG being out-of-service on April 15, 2007.Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report. | |||
====b. Findings==== | |||
No findings of significance were identified..2Complete System Walkdown | |||
====a. Inspection Scope==== | |||
(One Unit 2 sample)The inspectors completed a detailed review of the alignment and condition of the Unit 2service water system. The inspectors conducted a walkdown of the system to verify that the critical portions, such as valve positions, switches, and breakers, were aligned in accordance with procedures and to identify any discrepancies that may have had an effect on operability. | |||
3EnclosureThe inspectors also conducted a review of outstanding maintenance work orders toverify that the deficiencies did not significantly affect the Unit 2 service water system function. In addition, the inspectors discussed system health with the system engineer and reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved. Documents reviewed for this inspection activity are listed in the SupplementalInformation Attachment to this report. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R05}} | |||
==1R05 Fire Protection (71111.05).1Quarterly Sample Review== | |||
====a. Inspection Scope==== | |||
(Six Unit 2 and six Unit 3 samples)The inspectors performed twelve walkdowns of fire protection areas during theinspection period. The inspectors reviewed Dominion's fire protection program to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. The inspectors walked down these areas to assess Dominion's control of transient combustible material and ignition sources. In addition, the inspectors evaluated the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors then compared the existing conditions of the areas to the fire protection program requirements to ensure all program requirements were being met. The fire protection areas reviewed included:Unit 2*Auxiliary Building, West Main Steam Safety Valve Room, 38'6" Elevation (FireArea A-8, Zone E);*Auxiliary Building, West Electrical Penetration Area, 14'6" Elevation (Fire AreaA-8, Zone D);*Auxiliary Building, East Piping Penetration Area, -25'6" and -5'0" Elevation (FireArea A-10, Zone A);*Auxiliary Building, East Electrical Penetration Area, 14'6" Elevation (Fire AreaA-10, Zone B);*Auxiliary Building, East Main Steam Safety Valve/Blowdown Tank Room, 38'6"Elevation (Fire Area A-10, Zone C); and*Auxiliary Building, Boric Acid Batch Tank/Chemical Addition Tank, 14'6"Elevation (Fire Area A-12, Zone A).Unit 3*Containment, -24'6" Elevation (Fire Area RC-1); | |||
*Containment, -3'8" Elevation (Fire Area RC-1); | |||
4Enclosure*Containment, 24'6" Elevation (Fire Area RC-1);*Containment , 51'4" Elevation (Fire Area RC-1); | |||
*North EDG Enclosure, 24'6" and 37'0" Elevation (Fire Area EG-31); and | |||
*South EDG Enclosure, 24'6" and 37'0" Elevation (Fire Area EG-4).Documents reviewed for this inspection activity are listed in the Attachment to thisreport. | |||
====b. Findings==== | |||
No findings of significance were identified..2Annual Fire Drill Observation | |||
====a. Inspection Scope==== | |||
(One Unit 3 sample)Unit 3The inspectors observed personnel performance during a fire brigade drill onJune 19, 2007, to evaluate the readiness of station personnel to fight fires. The drill simulated a fire in the Unit 3 'A' EDG room. The inspectors observed the fire brigade members using protective clothing, turnout gear, and self-contained breathing apparatus and entering the fire area in a controlled manner. The inspectors also observed the fire fighting equipment brought to the fire scene to evaluate whether sufficient equipment was available to effectively control and extinguish the simulated fire. The inspectors evaluated whether the permanent plant fire hose lines were capable of reaching the fire area and whether hose usage was adequately simulated. The inspectors observed the directions of the fire brigade team leader and communications between fire brigade members. The inspectors verified that the pre-planned drill scenario was followed and reviewed the post drill critique items to evaluate if the drill objectives were satisfied and that any drill weaknesses were identified.Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
5Enclosure1R07Heat Sink Performance (71111.07A) | |||
====a. Inspection Scope==== | |||
(One Unit 3 sample)The inspectors reviewed one sample associated with the safety-related 'C' reactor plantclosed cooling water (RPCCW) heat exchanger inspection and testing activities to identify any degraded performance or potential for common cause problems that could increase plant risk. The inspectors observed the as-found condition of the heat exchanger once it was opened to verify that any adverse fouling concerns were appropriately addressed. The inspectors reviewed the results of the inspections performed in accordance with Dominion procedures. The inspectors reviewed the inspection results against the acceptance criteria contained within the procedure to determine whether all acceptance criteria had been satisfied. The inspectors also reviewed the FSAR to ensure that heat exchanger inspection results were consistent with the design basis. The inspectors verified that adverse conditions identified by Dominion were appropriately entered into Dominion's corrective action program. Documents reviewed for this inspection activity are listed in the Attachment to thisreport. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R08}} | |||
==1R08 Inservice Inspection (71111.08)== | |||
====a. Inspection Scope==== | |||
(Five Unit 3 samples)The inspectors assessed the inservice inspection (ISI) activities using the criteriaspecified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI. The inspectors reviewed documentation and interviewed personnel to verify that the activities were performed in accordance with the ASME requirements. The sample selection was based on the inspection procedure objectives and risk priority of those components and systems where degradation would result in a significant risk increase of core damage.During the Unit 3 RFO, 3R11, the inspectors made direct observations of portions of thefollowing procedures and examinations on code class 1 components: *Gas Tungsten Arc Welding weld overlay, pressurizer surge nozzle;*Liquid penetrant surface examination of pressurizer 'B' safety nozzle overlay; and*Visual examination of reactor vessel head bare metal, and various penetrationsincluding #61 and #21.The inspectors also reviewed the examination results and the certifications of theindividuals responsible for performing both the exams and analyzing the results. The 6EnclosureWelder Maintenance Logs documentation on the PCI contract welders was alsoreviewed. The inspectors reviewed data packages for the following examinations: *ASME Section XI, Appendix VIII Performance Demonstration Initiative ultrasonicexamination of pressurizer 'C' safety nozzle weld overlay;*Bare head visual inspection summary report; | |||
*Reactor head penetration ultrasonic examinations, including coveragelimitations;*Ultrasonic examinations of reactor vessel inlet nozzle-to-shell welds, W23 &W31; and*Automated UT of PWR Vessel Shell Welds, W10 & W12.The inspectors confirmed that the examinations were performed in accordance withapproved procedures and that the results were reviewed and evaluated by certified Level III nondestructive examination (NDE) personnel. The inspectors interviewed staff about evaluations and repairs for weld conditions on the'B' safety nozzle including evaluations of indications identified by informational surfaceexaminations. The inspectors noted that site personnel utilized their condition report engineering dispositioning process to resolve and plan the repair scope. The inspectors reviewed one indication dispositioned as unacceptable according to theASME IWB-3514 criteria on weld MSS-30-FW-6 (Condition Report (CR)-07-03974). The indication was evaluated by the site welding engineer and subsequently reworked by grinding and blending to remove the indication. The remaining wall thickness was verified by ultrasonic testing, and the post-repair weld magnetic particle test was acceptable. The inspectors interviewed the Dominion NDE Level III staff in regards to QualityControl (QC) presence during reactor head bare metal visual examinations. The inspectors reviewed the QC observations report and discussed the results with site staff. | |||
One observation included that Dominion site staff incorporated QC recommendations to include a subject matter expert as part of onsite staff performing visual testing examinations. For the boric acid corrosion control program (BACC), the inspectors reviewed the resultsof the first 3R11 Mode 3 walkdown visual testing. The inspectors also reviewed corrective action program CRs generated for leakages identified both during the current and previous outages. The following components leakage screenings/evaluations were reviewed: residual heat removal system (RHS)*V009, 3SIH*AV8882, 3CHS*RV835, 3SIH*RV8870 and 3RHS*RV37B. The inspectors noted that Dominion had recently developed and trained program staff on a new database program used to collect information on components with boric acid leakage. The inspectors completed a direct visual walkdown of areas of containment to assess Dominion's ability to identify sources and targets of boric acid leakage. Based on a review of boric acid leak evaluation activities from 3R11, a finding of very low safety significance was identified, as described below. | |||
7EnclosureThe inspectors also reviewed a sample of issue reports from various NDE activities toassess Dominion's effectiveness in problem identification and resolution and determined that they are identifying ISI and NDE issues at an appropriate threshold and entering them into the corrective action program. The inspector sampled issue reports from the | |||
{{a|3R11}} | |||
==3R11 and the 3R10 refueling outages, and a short duration outage from== | |||
January-February, 2007.Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
=====Introduction.===== | |||
The inspectors identified that Dominion did not follow Boric Acid CorrosionControl program procedures. Specifically, plant personnel failed to adequately perform boric acid leak evaluations as required by Dominion procedure DNAP-1004, "Boric Acid Corrosion Control Program." This finding was of very low safety significance (Green)and determined to be a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings." | |||
=====Description.===== | |||
Dominion procedure DNAP-1004, "Boric Acid Corrosion Control Program,"required that all identified boric acid leaks be reported in the site corrective action system. Additionally, Dominion procedure DNAP 1004, Attachment 1, "Boric Acid Corrosion Control Program Screening," provided severity threshold criteria for performing engineering evaluations of the identified boric acid leaks. The procedure specified that personnel should be trained to not disturb or remove the suspected boric acid deposit before a maintenance threshold screening is performed. The procedure also stated in Attachment 2, "Evaluation Methodology," to determine the safety significance of all the affected components. During the Unit 3 refueling outage 3R11, in several instances, evaluations were not completed, or the evaluations did not include all the required information specified by the procedure. Leak evaluation forms for components identified with boric acid leaks did not consistently include the identification of the evaluator or date the evaluation was performed; reference the CR initiated from the current outage's mode 3 walkdown; document condition trending for the leaking components; or, reference whether qualified VT-2 inspections of affected components had been performed as part of the evaluation process. Examples were:*'A' residual heat removal (RHR) system loop outboard drain 3RHS*V009. Dominion had identified and tagged it for cleaning, but had not performed an inspection of the components located underneath the leak (target components). | |||
Subsequent to the NRC inspectors reporting a boric acid accumulation that had leaked through the grating below, Dominion cleaned the affected components without first documenting the leakage, or evaluating the components' material susceptibility to effects of the leakage.*'B' RHR suction header containment relief 3RHS*RV37B. This valve wasreplaced during the 2007 refueling outage. The removed valve was bench tested and found to be inoperable during the lift test. Work orders written in March and October of 2005 referenced boric acid leaks at the threaded nozzle joint and on the spherical bearing of an attached strut. Leakage present in the 8Enclosurephotographs for the fasteners and body of the as-found valve during the 2007refueling outage were not addressed in a CR or evaluated for prior operability concerns. *Boron recovery tank 'B' inlet header isolation, 3BRS-V846. Dominionphotographed the leakage during the 2007 refueling outage, but had not documented a CR since the 2005 refueling outage (CR-05-04388). The 2005 CR did not have an attached screening form to assess whether an evaluation was required to be performed, as required by procedure.*Reactor coolant loop '4' drain isolation, 3RCS*AV8037D (V211). Dominionphotographed boric acid on the fasteners and flange during the 2007 refueling outage, and documented CR-07-03509 as being a duplicate condition report to CR-05-11061. No further evaluation was performed based on the current leakage, which could possibly have affected the work scope planned in 2005 for | |||
{{a|3R11}} | |||
==3R11 . | |||
=====Analysis.===== | |||
== | |||
The performance deficiency associated with this finding was that licenseeactivities affecting quality were not accomplished in accordance with procedure DNAP-1004, in that, in several instances, the licensee failed to perform boric acid leak evaluations as required. Dominion's corrective actions for this issue included a general area cleaning program to remove boric acid residue from target components and ensuring the BACC program includes clear documentation of evaluations for both the leaking component and any associated target component(s).This finding was more than minor because it was associated with the humanperformance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue did not result in exceeding the TS limit for identified RCS leakage or affect other mitigating systems resulting in a total loss of their safety function. Additionally, this finding is similar to IMC 0612, Appendix E, example 4a, in that the licensee routinely failed to perform engineering evaluations on similar issues; i.e., boric acid leaks. The performance deficiency had a cross-cutting aspect in the area of humanperformance, work practices component, because Dominion personnel did not follow procedures. | |||
9EnclosureEnforcement. 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, andDrawings" requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, and drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Dominion procedure DNAP-1004, Attachment 1, "Boric Acid Corrosion Control Program Screening," provided threshold criteria for performing engineering evaluations on boric acid leaks; and, Attachment 2, "Evaluation Methodology" provided information to be included in the evaluation. Contrary to the above, on several occasions during April and May, 2007, Dominion failed to accomplish boric acid leak evaluations in accordance with procedure DNAP-1004. However, because this issue was determined to be of very low safety significance (Green) and has been entered into the licensee's corrective action program in condition report CR-07-04184, this violation is being treated as a NCV consistent with section VI.A.1 ofthe NRC Enforcement Policy. (NCV 05000423/2007003-01, Failure to PerformEvaluations on Boric Acid Leaks)1R11Licensed Operator Requalification Program (71111.11Q) | |||
====a. Inspection Scope==== | |||
(One Unit 1 and one Unit 2 sample)The inspectors observed one simulator training scenario of a Unit 2 licensed operatorclassroom training on June 12, 2007, and one Unit 3 licensed operator simulator training on June 21, 2007. The inspectors verified that the training evaluators adequately addressed that the applicable training objectives had been achieved. Additionally, the inspectors assessed whether the simulator adequately reflected the plant's response, operator performance met Dominion's procedural requirements, and the simulator instructor's critique identified crew performance issues. Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R12}} | |||
==1R12 Maintenance Effectiveness (71111.12)== | |||
====a. Inspection Scope==== | |||
(Two Unit 2 samples) | |||
The inspectors reviewed two samples of Dominion's evaluation of degraded conditions,involving safety-related SSCs for maintenance effectiveness during this inspection period. The inspectors reviewed licensee implementation of the Maintenance Rule (MR), 10 CFR 50.65, and verified that the conditions associated with the referenced CRs were appropriately evaluated against applicable MR functional failure criteria as found in licensee scoping documents and procedures. The inspectors also discussed these issues with the system engineers and MR coordinators to verify that they were appropriately tracked against each system's performance criteria and that the systems were appropriately classified in accordance with MR implementation guidance. | |||
10EnclosureThe following conditions were reviewed:Unit 2*Service water leak from red rubber gasket joint on supply line to 'A' EDG on April19, 2007 (CR-07-01788); and*'C' charging pump repair following a failure of the pump on June 11, 2007 (CR-07-06525).Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report. | |||
====b. Findings==== | |||
=====Introduction.===== | |||
A self-revealing finding was identified when Dominion did not ensure anadequate work procedure was available for maintenance performed on the Unit 2 'C' charging pump on May 5, 2007, resulting in a failure of the pump on June 11, 2007. | |||
Specifically, the work procedure did not give specific guidance for assembly and installation of the suction poppet valve in accordance with direction provided in the vendor technical manual. On June 11, 2007, the 'C' charging pump failed and was declared inoperable due to a seized plunger shaft. This finding was of very low safety significance (Green) and determined to be an NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."Description. On June 11, 2007, with the plant operating at 100 percent power,operations personnel noted charging header flow had lowered from its normal value of 43.5 gallons per minute (gpm) to 29 gpm. Operators in the control room secured the running charging pump, declared the 'C' charging pump inoperable, and entered abnormal operating procedure (AOP) 2512, "Loss of Charging." The operators verified no leaks were occurring in containment and that the trend in pressurizer level decrease was consistent with normal reactor coolant pump seal leak-off with no charging pumps in service. The operators also performed bladder checks on the discharge pulsations dampeners for all three charging pumps to ensure gas binding was not the cause of the lowering charging flow, started the 'A' charging pump, and quarantined the 'C' charging pump. Charging header flow returned to normal and operators exited the AOP.Normal charging pump operation uses the pumping action of three plungers to increasewater pressure to 2350 psig to pump borated water in the reactor vessel, which is at 2250 psig. The three plungers are driven from a common eccentric shaft connected to a motor and work together to increase water pressure to overcome RCS pressure. | |||
During normal plant operations there are three charging pumps available and each is capable of injecting the desired concentration of boric acid into the vessel. Dominion determined that the cause of the lowering charger header flow was that one ofthree plungers for the 'C' charging pump was bound inside the pump drive assembly shaft. Upon further investigation, during the licensee's apparent cause evaluation (ACE), it was determined that the fastener connecting the suction poppet valve to the valve body associated with this plunger had become detached and was then crushed 11Enclosureinto smaller pieces by the reciprocating action of the plunger. After several days of thefastener being broken into smaller pieces by the plunger, one of the fastener pieces had wedged itself between the plunger and the shaft of the pump drive assembly causing the plunger to become bound to the shaft. The ACE determined the cause of the fastener becoming detached from the valve body was due to inadequate maintenance performed on the pump during maintenance activities on May 5, 2007. Specifically, the work procedure did not give specific guidance for assembly and installation of the suction poppet valve in accordance with direction provided in the vendor technical manual. During the inspectors review of the event, the inspectors noted an additional contributingcause to the pump being run to failure. On June 9, 2007, operators noted an abnormal noise from the suction of the drive pump assembly. The operators noted the condition in the control room logs and contacted the system engineer. After describing the noise to the system engineer, the engineer recommended to the operators to isolate and secure the 'C' charging pump, and start one of the standby pumps. Operations personnel, however, evaluated the system performance as normal and decided to continue running the 'C' charging pump. The inspectors concluded that Dominion had missed an opportunity to secure the pump prior to the pump being run to failure. Dominion generated CR-07-06897 to document the inspectors observation.Analysis. The performance deficiency associated with this finding was that aninadequate work procedure which was approved and used during a maintenance activity on a safety-related pump, resulting in a failure of the pump. Dominion's corrective actions for this issue included repair and retest of the 'C' charging pump, revising the work procedure to include vendor recommendations and training for maintenance personnel on assembly and installation of charging pump poppet valves.The finding was more then minor because it was associated with the procedure qualityattribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the finding is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.This performance deficiency had a cross-cutting aspect in the area of humanperformance, resources component, because Dominion did not ensure that a complete, accurate and adequate work procedure was available for maintenance performed on a safety-related component.Enforcement. 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, andDrawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, 12Enclosureprocedures, or drawings. Contrary to the above, Dominion did not ensure an adequatework procedure was available for maintenance conducted on the 'C' charging pump on May 5, 2007. However, because the finding was of very low safety significance (Green)and has been entered into the corrective action program in condition report CR-07-06525, this violation is being treated as an NCV, consistent with section VI.A.1 of theNRC Enforcement Policy. (NCV 05000336/2007003-02, Inadequate Work Procedurefor the Unit 2 'C' Charging Pump Results in Pump Failure) | |||
{{a|1R13}} | |||
==1R13 Maintenance Risk Assessments and Emergent Work Control== | |||
{{IP sample|IP=IP 71111.13}} | |||
====a. Inspection Scope==== | |||
(Three Unit 2 and six Unit 3 samples)The inspectors reviewed nine samples of the adequacy of maintenance riskassessments for emergent and planned activities during the inspection period. The inspectors utilized the equipment-out-of-service quantitative risk assessment tool to evaluate the risk of the plant configurations and compared the results to Dominion's stated risk. The inspectors verified that Dominion entered appropriate risk categories and implemented risk management actions as necessary. The inspectors verified the conduct and adequacy of scheduled maintenance risk assessments for plant conditions affected by performance of the following maintenance and testing activities:Unit 2*Reserve station service transformer (RSST) supply line insulator replacement onApril 12, 2007; *Troubleshooting spurious generator field ground alarms on April 24, 2007; and | |||
*Emergent risk assessment of Unit 3 loss of offsite power impact to Unit 2operation on April 25, 2007.Unit 3*3R11 cumulative shutdown risk management on April 1, 2007;*Shutdown risk assessment on April 7, 2007, and April 8, 2007; | |||
*Reduced inventory operations on April 11, 2007; | |||
*Emergent risk assessment during severe weather on April 15, 2007; | |||
*Emergent risk assessment for unplanned orange shutdown risk associated withpower availability on April 25, 2007; and*Reduced inventory operations on May 1, 2007.Documents reviewed for this inspection the Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R15}} | |||
==1R15 Operability Evaluations (71111.15)== | |||
====a. Inspection Scope==== | |||
(Two unit 2 and three Unit 3 samples)13EnclosureThe inspectors reviewed five operability determinations associated with degraded ornon-conforming conditions to ensure that operability was justified and that mitigating systems or those affecting barrier integrity remained available and no unrecognized increase in risk had occurred. The inspectors also reviewed compensatory measures, as appropriate, to ensure that the measures, as appropriate, were in place and were appropriately controlled. The inspectors reviewed licensee performance to ensure all related TS and FSAR requirements were met. The inspectors reviewed the following degraded or non-conforming conditions:Unit 2*Degraded intake structure floor drain used for service water pipe break floodprotection (CR-07-03322); and*Evaluation of fairbanks morse engine 10 CFR 21 report 2007-10-00 (CR-07-03568).Unit 3*New inverters '2' and '4' have high frequency noise causing false counts onsource range nuclear instruments and gamma metric instrumentation (CR-07-04924);*Degraded spent fuel pool storage rack locations (CR-07-05197); and | |||
*Degraded 'A' EDG intercooler heat exchanger (CR-07-06800).Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R17}} | |||
==1R17 Permanent Plant Modifications (71111.17A)== | |||
====a. Inspection Scope==== | |||
(Two Unit 3 samples)The inspectors reviewed two permanent plant modifications on Unit 3. The inspectorsperformed a walkdown of the relevant areas, as appropriate, and reviewed the FSAR, licensing and design basis documents, and the engineering dispositions. These reviewswere conducted to ensure | |||
: (1) the modified components remained consistent with the assumptions indicated in the design basis documents, | |||
: (2) that system availability, reliability, and functional capability were maintained, and | |||
: (3) no unrecognized conditions that were introduced as a result of the modifications. The following permanent plant modifications were reviewed:Unit 3*Charging pump alternate minimum flow modification (DCM 3-2A); and 14Enclosure*Installation of ferrite beads to dampen noise affects on source range nuclearinstruments and gamma metric instrumentation (DM3-00-0163).Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
No findings of significance were determined. | |||
{{a|1R19}} | |||
==1R19 Post-Maintenance Testing (71111.19)== | |||
====a. Inspection Scope==== | |||
(Three Unit 2 and six Unit 3 samples)The inspectors reviewed nine samples of post-maintenance tests (PMTs) during thisinspection period. The inspectors reviewed these activities to determine whether the PMT adequately demonstrated that the safety-related function of the equipment was satisfied given the scope of the work specified and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to verify consistency with the associated design and licensing bases, as well as TSrequirements. The inspectors also verified that conditions adverse to quality were entered into the corrective action program for resolution. The following maintenance activities and their associated PMTs were evaluated:Unit 2*'C' channel of containment pressure is erratic and unreliable (M2-07-03190);*Re-pack of the 'C' charging pump (M2-07-03275); and | |||
*'C' charging pump repair following pump failure (M2-07-04329).Unit 3*Packing replacement of loop stop valves 3RCS*8001A and 3RCS*8002A (M3-06-02617);*Inverter '2' and inverter '4' replacement (M3-07-06740); | |||
*Charging pump alternate minimum flow modification (M3-05-09947); | |||
*Valve 3SIH*V5 rework (M3-07-06253); | |||
*'B' service water check valve replacement (M3-05-06229); and | |||
*Reactor internal lifting rig clamp replacement (M3-05-14215).Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
=====Introduction.===== | |||
The inspectors identified that Dominion did not adequately evaluatesurveillance test results to ensure test acceptance criteria had been met on May 10, 2007. Specifically, the inspectors identified that the 'C' charging pump pulsation dampener surveillance test had cited incorrect data and had been accepted as satisfactorily complete, though the test data was outside of the surveillance acceptance criteria. This finding was of very low safety significance (Green) and determined to be an NCV of 10 CFR 50, Appendix B, Criterion XI, "Test Control." | |||
=====Description.===== | |||
On May 10, 2007, the inspectors reviewed surveillance form SP 2664-003,"Charging Pump 'C' Pulsation Dampener Test," as part of a PMT review for maintenance that had been performed on the 'C' charging pump. The inspectors noted that the acceptance criteria for the charging pump discharge pressure had not been met given the data recorded in the procedure. | |||
Specifically, the final extrapolated pump discharge pressure was determined to be greater than the initial pulsation dampener precharge pressure, when in fact the recorded data indicated otherwise. During conduct of the surveillance, review of the surveillance results, and final approvalof the surveillance, approximately five operations personnel had accepted this data as being satisfactory. Following the observation, the inspectors notified system engineering and operations personnel of this discrepancy, and they agreed that the acceptance criteria had not been met. The surveillance was successfully re-performed on May 13, 2007.Analysis. The performance deficiency associated with this inspector identified findinginvolved an inadequate evaluation of surveillance test results to ensure test acceptance criteria had been met. Dominion's corrective actions for this issue included revising the surveillance to clarify test requirements and required reading for operations personnel on how to adequately document and review surveillance test data.The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify out of specification data could result in the failure to identify inoperable equipment. The inspectors also concluded that if the failure to properly evaluate charging pump discharge dampener test data was not corrected, a more significant concern could exist in that failure of the dampener has previously resulted in a loss of all charging due to the migration of nitrogen from a failed discharge pulsation dampener to the common suction piping for all three charging pumps (as described in NRC inspection reports 05000336/2006002 and 05000336/2006006).The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609,Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green)because the issue is not a design or qualification deficiency, does not represent the loss 16Enclosureof a system safety function or safety function of a single train, and does not screen aspotentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of problemidentification and resolution, corrective action program component, because Dominion did not identify out of specification test data. | |||
=====Enforcement.===== | |||
10 CFR 50, Appendix B, Criterion XI, "Test Control," states, in part, thattest results shall be documented and evaluated to assure that test requirements have been satisfied. | |||
Contrary to the above, Dominion failed to adequately evaluate the surveillance data so as to identify that the surveillance acceptance criteria had not been met. However, because this finding is of very low safety significance (Green) and has been entered into the licensee's corrective action program in condition report CR-07-05345, this violation is being treated as a NCV, consistent with Section VI.A.1 of theNRC Enforcement Policy. (NCV 05000336/2007003-03, Failure to AdequatelyEvaluate Surveillance Test Data) | |||
{{a|1R20}} | |||
==1R20 Refueling and Outage Activities== | |||
{{IP sample|IP=IP 71111.20}} | |||
====a. Inspection Scope==== | |||
(One Unit 3 sample)Dominion began the Unit 3 RFO 3R11 on April 6, 2007, and returned the unit to fullpower operation on May 22, 2007. The inspectors evaluated the outage plan and outage activities to confirm that Dominion had appropriately considered risk, had developed risk reduction and plant configuration control methods, had considered mitigation strategies in the event loss of safety functions occurred, and had adhered to license and TS requirements. The inspectors observed portions of the shutdown, cooldown, heatup, and the startup procedure processes. Additionally, the inspectors conducted an initial containment walkdown to evaluate the as-found condition of the containment to ensure no loose material or debris which could be transported to the containment sump was present. The inspectors verified that conditions adverse to quality were entered into the corrective action program for resolution. Some of the specific activities the residents observed included:*Reactor shutdown and cooldown;*Steam generator safety valve simmer testing; | |||
*Reactor water level drain down to the reactor flange; | |||
*Reduced inventory operations; | |||
*RCS fill and vent; | |||
*Pressurizer 600 weld overlays; | |||
*Restoration of the RSST; | |||
*Core barrel heavy load lift and heavy load analysis; | |||
*Fuel handling, core loading, and fuel element assembly tracking; | |||
*RCS pressure, level, and temperature instrumentation operability; | |||
*Containment as-left walkdown; | |||
*Mode '0' valve work; | |||
*Reactor heatup; | |||
*Reactor startup; 17Enclosure*Low power physics testing;*Reactor power ascension; and | |||
*Main turbine over speed testing.Documents reviewed for this inspection activity are listed in the Attachment.b.FindingsNo findings of significance were determined. | |||
{{a|1R22}} | |||
==1R22 Surveillance Testing (71111.22)== | |||
====a. Inspection Scope==== | |||
(Three Unit 2 and six Unit 3 samples)The inspectors reviewed nine samples of surveillance activities to determine whether thetesting adequately demonstrated equipment operational readiness and the ability to perform its intended safety-related function. The inspectors attended pre-job briefs, verified that selected prerequisites and precautions were met and that the tests were performed in accordance with the procedural steps. Additionally, the inspectors evaluated the applicable test acceptance criteria to verify consistency with associated design bases, licensing bases, and TS requirements, and that the applicable acceptance criteria were satisfied. The inspectors also verified that conditions adverse to quality were entered into the corrective action program for resolution. The following surveillance activities were evaluated:Unit 2*'A' EDG surveillance test (SP-2613K);*Containment spray system '2' containment isolation valve in-service test (IST)(SP-2606C); and*AFW system feedwater regulating valve stroke timing IST (SP-26120CO).Unit 3*'A' engineered safety feature/loss of power (LOP) surveillance test (SP-3646A.17);*'A' train LOP surveillance test (SP-3646A.15); | |||
*Main steam valve simmer surveillance test (SP-3712G); | |||
*Reactor coolant system cooldown surveillance test (SP-3601G.2); | |||
*Low power physics surveillance test (SP-31008); and | |||
*'A' safety injection accumulator vent valve IST (SP 3610B.2).Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report. | |||
====b. Findings==== | |||
=====Introduction.===== | |||
A self-revealing finding was identified when Dominion incorrectlyperformed a safety-related surveillance procedure. Specifically, Operations mistakenly performed a biennial surveillance test that verified remote vent valve position by opening a nitrogen vent path and verifying a decrease in accumulator pressure for the Unit 3 'A' safety injection (SI) accumulator in addition to the planned quarterly surveillance. As a result of performing the biennial procedure vice the planned quarterly surveillance, the | |||
'A' SI accumulator was inadvertently depressurized to below the TS value. This finding was of very low safety significance and determined to be an NCV of TS 6.8.1, "Procedures."Description. On May 16, 2007, in Mode 3, Operations was performing section 4.11 ofprocedure SP 3610B.2, "Low Pressure Safety Injection Valve Operability Test - Train A." | |||
The purpose of this test was to verify that the 'A' SI accumulator vent valves met the design and IST stroke time requirements. In addition to the planned quarterly surveillance, Operations mistakenly performed the biennial surveillance that verified remote vent valve position by opening a vent path and verifying a decrease in accumulator pressure. As a result, the 'A' SI accumulator was inadvertently depressurized to below the TS allowed value. Operability of the SI accumulator was restored once operations personnel isolated the accumulator vent path and re-pressurized the accumulator to within the TS allowed range. Dominion performed an ACE and determined the cause of the event was related tohuman performance. Specifically, Dominion did not conduct a pre-job brief prior to the surveillance to ensure Operations personnel clearly understood the steps involved in the test and the expected plant response. The inspectors also noted that no peer checking was used which could have provided an additional level of control. The operating crew believed the surveillance operator was planning on performing the quarterly portion of the surveillance and not the biennial remote position indication verification. Dominion also determined that the surveillance operator did not fully consider changing plant conditions following the refueling outage mode changes involved in the startup and the requirements to maintain SI accumulators operable.Analysis. The performance deficiency associated with this finding is that Dominion didnot properly implement a safety-related surveillance procedure to test the 'A' SI accumulator vent valves. Dominion's corrective actions for this issue included restoring accumulator pressure, performing an ACE to determine the underlying causes associated with the error, training the personnel involved, and scheduling human performance training for Operations during training cycle 07-03.The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the 19Enclosureissue is not a design or qualification deficiency, does not represent the loss of a systemsafety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This performance deficiency had a cross-cutting aspect in the area of humanperformance, work practice component, because Dominion's human error prevention techniques such as holding a pre-job brief and peer checking were not used to ensure that a surveillance was properly performed.Enforcement. TS 6.8.1, "Procedures," requires, in part, that written procedures beimplemented covering surveillance activities on safety-related equipment. Contrary to the above, on May 16, 2007, Dominion incorrectly implemented surveillance procedure SP 3610B.2, Revision 013-08, "Low Pressure Safety Injection Valve Operability Testing | |||
- Train A," Section 4.11, "Quarterly Stroke Time Test of 3SIL*SV8875A-H." As a result, the 'A' SI accumulator was inadvertently depressurized to below the TS 3.5.1, "Accumulators," allowed value of 636 psia for approximately 27 minutes until the required pressure was restored. However, because this finding was of very low safety significance (Green) and was entered into Dominion's corrective action program in condition report CR-07-05596, this violation is being treated as an NCV, consistent withsection VI.A.1 of the NRC Enforcement Policy. (NCV 05000423/2007003-04, Failure toImplement Safety-Related Surveillance Procedure Resulted in 'A' Safety Injection Accumulator Inoperability)1R23Temporary Plant Modifications (71111.23) | |||
====a. Inspection Scope==== | |||
(One Unit 3 sample)The inspectors reviewed one sample of a temporary modification involving temporarypower being available during inverter '2' and '4' replacement for Unit 3. The inspectors verified that the modification did not adversely affect the function of the safety system. | |||
The inspectors reviewed this temporary modification and its associated 10 CFR 50.59 screening against the FSAR and TS to ensure the modification did not adversely affect the system operability or availability. Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
20EnclosureCornerstone: Emergency Preparedness [EP]1EP6Drill Evaluation (71114.06) | |||
====a. Inspection Scope==== | |||
(One Unit 2 and one Unit 3 sample)The inspectors observed a Unit 2 licensed operator training emergency planning drill onJune 12, 2007, and a Unit 3 licensed operator training emergency planning drill on June 21, 2007. The inspectors observed the operating crews performance at the simulator and emergency response organization performance at the site emergency operations center and technical support center. The inspectors verified that the classification, notification and protective action recommendations were accurate and timely. Additionally, the inspectors assessed the ability of Dominion's evaluators to adequately address operator performance deficiencies identified during the exercise. Documents reviewed for this inspection activity are listed in Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified.2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Control to Radiologically Significance Areas (71121.01) | |||
====a. Inspection Scope==== | |||
(Eleven Site Samples)During the period April 23-26, 2007, the inspector conducted the following activities toverify that Dominion was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas and other radiologically controlled areas, and that workers were adhering to these controls when working in these areas during the Unit 3 refueling outage and during power operations at Unit 2. | |||
Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, Unit 2 and Unit 3 TS, and Dominion's procedures. This inspection activity represents completion of eleven | |||
: (11) samples relative to this inspection area.Plant Walkdown and Radiation Work Permit (RWP) Reviews*During the Unit 3 refueling outage, the inspector identified exposure significantwork areas in the Unit 3 containment building. The inspector reviewed radiation survey maps and RWPs associated with these areas to determine if the radiological controls were acceptable. Work areas included the refueling canal, pressurizer cubicle, D-steam generator cubicle, and containment sump area. *The inspector performed independent surveys of selected areas in the Unit 3containment building, auxiliary building, and engineered safeguards building to 21Enclosureconfirm the accuracy of survey maps, the adequacy of postings, and that TSlocked high radiation areas (LHRA) and very high radiation areas (VHRA) were properly secured and posted. Areas in containment surveyed included; the seal table, steam generator cubicles, pressurizer spray/relief lines, reactor cavity drain line, and locked gates to the regenerative heat exchanger room. Additionally, surveys were performed in Unit 2, including the auxiliary building, radwastestorage building, and fuel storage building.*In evaluating RWPs, the inspector reviewed electronic dose/dose rate alarmsetpoints, and alarm reports, to determine if the setpoints were consistent with survey indications and plant policy. The inspector verified that workers were knowledgeable of the actions to be taken when a dosimeter alarms or malfunctions for tasks being conducted under selected RWPs. Work activities reviewed included core barrel lift for an ISI (RWP 304/3), removing internals from steam generator cross-over valve 3RCS*MV 8003D (RWP 354/1), pressurizer relief line welding (RWP 400/1) and management tours (RWP 219/2).*The inspector reviewed Personnel Contamination Reports (PCR) and theassociated dose assessments. The inspector determined that no contamination resulted in an internal dose exceeding 10 mrem.Jobs-In-Progress Review*The inspectors observed the preparations and various work stages for severaltasks including raising the core barrel to perform ISI, removal of the internals for steam generator cross over valve 8003D and pressurizer relief line weld overlay. | |||
The inspectors attended the pre-job briefing for the core barrel lift (Work Order 9510526) and for removal of the 8003D valve internals (Work Order 05-14584)to determine that radiological controls were adequately communicated to the workers.*The inspectors determined that additional dosimetry and area monitoring wasimplemented for dose significant jobs including issuing extremity dosimetry to personnel for removing the internals for valve 8003D, due to significant dose gradients, and installing teledosimetry instrumentation to monitor dose fields during the core barrel lift. High Risk Significant, High Dose Rate, and VHRA Controls*The inspector reviewed the preparations made for various potentially high doserate jobs including the initial removal of the core barrel from the reactor vessel, reactor head inspections and steam generator eddy current testing (ECT). On April 23, 2007, the inspector attended the pre-job briefing for raising the core barrel for performing in-service inspections, reviewed the associated RWP (No. | |||
304/3), and Work Order (No. 9510526), and observed the activity through the use of a video monitoring system. | |||
22Enclosure*The inspector inventoried keys to VHRAs and TS LHRAs stored at the Unit 3Control Point and in the Control Room to verify that all keys were accounted for. | |||
During tours of Unit 2, the inspector verified that all keys to locked high radiation areas were accounted for at the control point.*The inspector verified that Unit 3 VHRAs, such as the under vessel hatchwayand the incore instrument area, were properly secured and posted and that surrounding area dose rates and postings met regulatory criteria.Radiation Worker and Radiation Protection Technician Performance*Several radiologically related CRs were reviewed to evaluate if the incidentsresulted from repetitive worker errors and to determine if an observable pattern traced to a similar cause was evident. *Radiation Protection technicians and radworkers were questioned regarding theirknowledge of plant radiological conditions and associated controls.Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified. 2OS2ALARA Planning and Controls (71121.02) | |||
====a. Inspection Scope==== | |||
(Seven Unit 3 samples)During the period April 23 - 26, 2007, the inspector conducted the following activities toverify that Dominion was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as reasonably achievable(ALARA) for tasks conducted during the Unit 3 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Dominion's procedures. This inspection activity represents completion of seven | |||
: (7) samples relative to this inspection area. Radiological Work PlanningThe inspector reviewed pertinent information regarding Unit 3 outage exposure history,current exposure trends, and ongoing activities to assess current performance and outage exposure challenges. The inspector determined the site's 3-year rolling collective average exposure and compared it to current trends. The inspector reviewed the refueling outage work scheduled during the inspectionperiod and the associated work activity exposure estimates. Scheduled work included; reactor head inspections, core barrel ISI, pressurizer relief line weld repair, steam generator internal inspections, containment sump modification, valve repairs, and 23Enclosurevarious 10 year in-service inspections. The inspector compared the current actual doseaccrued for these activities with the initial exposure estimates.Additionally, the inspector reviewed the ALARA Reviews, Work-In-Progress ALARAReviews, ALARA Challenge Board presentations, and ALARA pre-job briefing materials that addressed estimating and controlling dose for other outage activities. Jobs reviewed included: fuel removal, insulation removal, scaffolding installation, reactor disassembly, steam generator eddy current testing, and steam generator secondary side inspections. The inspector evaluated the effectiveness of exposure mitigation requirements specifiedin RWPs and associated ALARA reviews. Jobs reviewed include reactor vessel disassembly (RWP 301/302/303, AR 3-07-01), steam generator eddy current testing (RWP 306, AR 3-07-02), motor-operated valve maintenance (RWP 354, AR 3-07-11), | |||
and scaffolding installation (RWP 231/331, AR 3-07-13).The inspector evaluated the departmental interfaces between radiation protection,operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by reviewing recent ALARA Council meeting minutes and ALARA Challenge Board presentations. | |||
The inspector also attended two pre-job briefings, a daily Plan-of-the-Day meeting, and a daily management outage status meeting to assess interdepartmental coordination. Through job site observations and radiation survey measurements, the inspectordetermined if work activity planning included the use of temporary shielding, system flushes, and operational considerations; i.e., scheduling work when steam generators were filled, to further minimize worker exposure. The inspector reviewed temporary shielding requests and performed independent measurements on various system components including: the pressurizer relief lines, reactor vessel level indication system, containment sump modification area, and various reactor building and auxiliary building work areas to determine if temporary shielding was appropriately used. Verification of Dose Estimates and Exposure Tracking SystemsThe inspector reviewed the assumptions and basis for the annual site collectiveexposure and the Unit 3 refueling outage dose projection.The inspector reviewed Dominion's method for adjusting exposure estimates, andre-planning of work when actual dose approached estimated dose. The inspector reviewed ALARA Council meeting minutes regarding expanding the scope of valve inspections/repairs following a boric acid walkdown that would require allocating additional dose to the BACC project.The inspector reviewed Dominion's exposure tracking system to determine whether thelevel of dose tracking detail, exposure report timeliness, and distribution was sufficient to support the control of outage project exposures. Included in this review were departmental dose compilations and individual dose records. | |||
24EnclosureJob Site Inspection and ALARA ControlsThe inspector observed maintenance activities being performed in containment,including sump modification, pressurizer relief line welding, core barrel lift, and 8003D valve repairs. The inspector verified that the appropriate radiological controls were implemented, including: pre-job briefings, radiation protection technician coverage, contamination mitigation, proper dosimetry, and that workers were knowledgeable of radiological conditions. Source Term Reduction and ControlThe inspector reviewed the current status and historical trends of the Unit 3 source term.Through interviews with the Radiation Protection and Chemistry Manager and the ALARA Supervisor, the inspector evaluated Dominion's source term measurements and control strategies. The inspector reviewed reactor coolant chemistry data to evaluate the effectiveness of post-shutdown source term reduction efforts. Specific strategies being employed included filtration, system flushes, installation of temporary shielding, and chemistry controls. Radiation Worker PerformanceThe inspector observed radiation worker and radiation protection technicianperformance for selected tasks. Tasks observed included: core barrel lift for performing in-service testing, replacing internals in 3RCS*MV8003D, containment sump modifications, pressurizer relief line weld repair, and steam generator secondary side inspections. The inspector determined that the individuals were aware of radiological conditions and access controls that applied to their tasks. The inspector reviewed condition reports related to radiation worker and radiationprotection technician errors and PCR to determine if an observable pattern traceable to a common cause was evident. Declared Pregnant WorkersThe inspector determined that no declared pregnant workers were employed to performoutage related activities in the radiologically controlled areas.Problem Identification and ResolutionThe inspector reviewed elements of Dominion's corrective action program related toimplementing the radiological controls program to determine if problems were being entered into the program for resolution. Details of this review are contained in Section | |||
{{a|4OA2}} | |||
==4OA2 of this report. Documents reviewed for this inspection activity are listed in the Attachment.== | |||
====b. Findings==== | |||
25EnclosureNo findings of significance were identified. | |||
==OTHER ACTIVITIES== | |||
[OA]4OA1Performance Indicator (PI) Verification (71151) | |||
====a. Inspection Scope==== | |||
(Two Unit 2 samples)Cornerstone: Barrier IntegrityThe inspectors reviewed two samples of Dominion's program to gather, evaluate, andreport information on the two PIs associated with the Barrier Integrity cornerstone of the reactor safety strategic performance area. The inspectors used the guidance provided in the Nuclear Energy Institute 99-02, Revision 4 "Regulatory Assessment Indicator Guideline," to assess the accuracy of Dominion's reporting of the PI data. The inspectors reviewed Dominion's monthly operating reports, operations logs, NRC inspection reports, and any associated corrective action program condition reports. The inspectors verified the accuracy and completeness of the reported data for the following PIs:*"Reactor coolant system specific activity" between January 1, 2006, andMarch 31, 2007; and,*"Reactor coolant system leak rate" between January 1, 2006, andMarch 31, 2007.Documents reviewed for this inspection activity are listed in the Attachment.b.FindingsNo findings of significance were identified.4OA2Identification and Resolution of Problems (71152).1Review of Items Entered into the Corrective Action ProgramAs required by Inspection Procedure 71152, "Identification and Resolution of Problems,"and in order to identify repetitive equipment failures or specific human performance issues for followup, the inspectors performed a daily screening of items entered into Dominion's corrective action program. This was accomplished by reviewing the description of each new CR and attending daily management review committee meetings. Documents reviewed for this inspection activity are listed in the Attachment..2Semi-Annual Review to Identify Trends | |||
====a. Inspection Scope==== | |||
(One Site Sample)The inspectors performed a semi-annual review including Dominion's corrective actionprogram documents to identify trends that could indicate the existence of a more 26Enclosuresignificant safety issue. The review also included Unit 2 and Unit 3 PI monthly reports,CRs, system health reports, plant health reports, quality assurance audits, self-assessment reports, and NRC inspection reports. The inspectors review was focused on repetitive equipment problems, human performance issues, and program implementation issues. The results of the trend review by the inspectors were compared with the results of normal baseline inspections. The inspectors review considered a six-month period of January 2007 through June 2007. Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings and Observations==== | |||
The inspectors did not identify trends that indicated the existence of a more significantsafety issue. The inspectors have observed less than adequate implementation of standards for human error prevention techniques, procedural compliance, and procedural adequacy during their inspection activities and have documented several findings in these areas in the first two quarters of 2007. The inspectors also noted that Dominion identified, in June 2007, an extensive backlog (approximately 700 CRs) of elective corrective action program condition reports. Dominion acknowledged the inspectors concerns and stated they were in the process of developing a plan to correct the backlog in the corrective action program.The resident inspectors noted in the 4 th quarter 2006 NRC integrated inspection report(IR 05000336/2006005 and IR 05000423/2006005) that there appeared to be an adverse trend in the number of scaffolding deficiencies. No adverse conditions relative to scaffolding were identified during this inspection period (See Section 4OA2.3.a for additional information)..3Annual Sample Review (Three Unit 2 Samples) Adverse Trend in Scaffold Installations Affecting Equipment | |||
====a. Inspection Scope==== | |||
The inspectors reviewed the licensee's actions relative to an adverse trend with respectto scaffold construction, as noted in the 4 th quarter 2006 integrated inspection report. That report documented a self-revealing NCV for scaffolding that prevented a Unit 2 main steam isolation valve (MSIV) from closing during surveillance testing. The report also contained a licensee-identified violation for scaffolding constructed on top of the safety-related high energy line break (HELB) blowout panel for the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump room.During this inspection period, the inspectors performed a focused PI&R sample on thecorrective actions that the licensee has taken to prevent recurrence. The inspectors reviewed the procedures used for the installation and removal of scaffolds, a sample of work orders for existing scaffolds, the licensee event reports (LERs) associated with the two specific issues described above and all of the associated scaffolding CRs initiated since January 1, 2007. The inspectors interviewed personnel associated with the scaffold process, and conducted a walk-down of both units to inspect a sample of the 27Enclosurescaffolds in-place around safety-related components. Documents reviewed for thisinspection activity are listed in the Supplemental Information attachment to this report. | |||
====b. Findings and Observations==== | |||
No findings of significance were identified. The inspectors noted that Dominion hasincorporated into procedure MP-20-WP-GDL20, Attachment 15, "Scaffolding," detailed instructions and cautions with respect to the construction of scaffolding near equipment. | |||
15.1, "Scaffold Evaluation," of the same procedure had a checklist for use by the scaffold planner and the operations/engineering departments for pre-installation and post-installation walkdowns of the area. In addition, the scaffolds are re-inspected by the lead scaffold individual at least quarterly. The inspectors did note that there were a large number of scaffolds that had beenin-place for an extended period of time. At least thirty of the scaffolds in the plant during this inspection were greater that two years old; at least half of those were greater than five years old and one was in place for over ten years. The inspectors determined that none of the scaffolds affected the nearby equipment.Unit 2 Partial Loss of Instrument Air Root Cause | |||
====a. Inspection Scope==== | |||
Based on a plant specific risk assessment and resident inspector input, the inspectorsselected CR-06-01796, "Reactor Trip due to Instrument Air Loss," as a PI&R sample for a detailed follow-up review. On February 23, 2006, Millstone Unit 2 reactor was manually tripped due to a transient caused by a partial loss of instrument air. At the time, a minor maintenance activity was in-progress to replace a pipe support clamp on a two-inch copper instrument air header pipe, when a nearby 1/2 inch air pipe separated from the header. The loss of air pressure resulted in a steam generator feed pump trip and subsequent manual trip of the reactor. This CR documented Dominion's root cause evaluation and corrective actions for a reactor trip due to a loss of instrument air.The inspectors assessed Dominion's problem identification threshold, cause analyses,extent of condition reviews, compensatory actions, and the prioritization and timeliness of Dominion's corrective actions to determine whether Dominion was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report. | |||
====b. Findings and Observations==== | |||
No findings of significance were identified. The inspectors determined that Dominion'soverall response to the issue was comprehensive and timely. The inspectors noted that Dominion's evaluation and follow-up corrective actions were partially implemented by a significance level-1 CR and root cause evaluation completed March 29, 2006, and 28Enclosurepartially implemented by a lower level MR functional failure (a)(1) evaluation, completedMay 8, 2006.The inspectors identified several weaknesses in Dominion's root cause evaluation thatappeared to have been adequately addressed by the subsequent lower level MR evaluation. Root cause evaluation weaknesses included: | |||
*Focused on performance of maintenance activity and copper pipe joint failure;*Did not identify any previous Millstone Unit 2 internal operating experience; and | |||
*Concluded that no effective action could be taken to identify other susceptiblecopper air pipe joints.In contrast, the lower level MR (a)(1) evaluation identified: | |||
*Cause of the reactor trip was an improperly evaluated/engineered 1982 designchange (old design issue) that added excess flow check valves into the air headers;*Significant previous Millstone Unit 2 operating experience on instrument air jointfailures, including 2 previous reactor trips, between 1976 and 1982, caused by similar air pipe joint failures; and*Identified risk informed approach to mitigate future failures, by reworking jointsassociated with reactor trip sensitive air loads.The inspectors determined that several weaknesses existed with regards to thecorrective actions associated with the root cause evaluation. However, because the MR (a)(1) evaluation was comprehensive and timely, the inspectors concluded that the overall corrective actions were adequate and addressed the issue. | |||
29EnclosureUnit 2 - Multiple Unplanned LCO 3.0.3 Entries in 2006 | |||
====a. Inspection Scope==== | |||
The inspectors reviewed Dominion's actions in response to multiple unplanned entriesinto Limiting Condition for Operation (LCO) 3.0.3 during 2006. Entry into LCO 3.0.3 should be a rare occasion since the entry is typically based on a loss of function of a safety-related SSC in which the specific system's TS action statement do not contain requirements. The inspectors reviewed the LCO 3.0.3 entries to determine if the entries were appropriate and if the entries shared a common root cause. In addition, the inspectors reviewed how Dominion's corrective action process addressed each issue. | |||
The inspectors interviewed responsible system engineers and operators.Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings and Observations==== | |||
No findings of significance were identified. The inspectors reviewed four cases during2006 for which LCO 3.0.3 was entered. In each case, the LCO 3.0.3 entry was appropriate. However, the inspectors identified that improvements could be made to the process for reviewing reference documents when design changes are made. In two of the four cases, incomplete documentation of a design change was cited as the cause of the condition leading to the LCO 3.0.3 entry..4ALARA Planning and Controls | |||
====a. Inspection Scope==== | |||
(One Unit 3 sample)The inspector reviewed 10 condition reports, 2 radiation protection departmentself-assessments, 5 Nuclear Oversight field observation reports, and a 3R11 ALARA Behaviors summary report, relating to keeping personnel exposure ALARA during the Unit 3 refueling outage, to evaluate the threshold for identifying, evaluating, and resolving radiological control problems. This review was conducted against the criteria contained in 10 CFR 20, TS, and Dominion's procedures. Additional documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.b.Findings and ObservationsNo findings of significance were identified. | |||
30Enclosure4OA3Event Followup (71153) (10 samples).1Unit 3 Unidentified RCS Leakage | |||
====a. Inspection Scope==== | |||
On April 1, 2007, Operations identified that the threshold of unidentified RCS leakagehad exceeded the values specified in a NRC confirmatory action letter (CAL) issued on March 27, 2007. The CAL required Dominion to evaluate unidentified RCS leakage above certain thresholds and to determine whether the leakage was potentially from the pressurizer. If Dominion could not determine that the leakage was not from the pressurizer within 72 hours, then a reactor plant shutdown would be required. On April 3, 2007, operations and engineering department personnel determined that the RCS leakage was not from the pressurizer. The inspectors reviewed Dominion's evaluation and agreed with the conclusion.Documents reviewed for this inspection activity are listed in the Attachment.b.FindingsNo findings of significance were identified..2Unit 3 Notice of Unusual Event - Loss of Normal Power in Mode 0 | |||
====a. Inspection Scope==== | |||
On April 25, 2007, at 10:47 a.m., with the reactor de-fueled in Mode 0, the stationresponded to a loss of offsite power event at Millstone Unit 3. The event was caused by a CONVEX (Connecticut Valley Electrical Exchange) switching error resulting in disconnecting offsite power from Millstone Unit 3. Operations entered Emergency Operating Procedure (EOP) 3501, "Loss of all AC Power (Mode 5,6, and Zero)," and EOP 3505, "Loss of Shutdown Cooling and/or RCS Inventory." Operations verified that the 'A' EDG automatically started and operated as designed. Operations then took manual action to start the 'A' spent fuel pool cooling pump from the 'A' EDG powered vital bus. At 11:01 a.m., the Shift Manager classified the event as an Unusual Event, based on off-site power not being available within 15 minutes and the 'A' vital bus powered from the 'A' EDG. The station terminated the Unusual Event declaration after the electrical lineup was restored to a stable lineup following restoration of offsite power. | |||
The inspectors responded to the control room and evaluated the adequacy of operator actions and Unusual Event declaration. The inspectors assessed the station's emergency response performance from the control room and in the field. In addition, the inspectors performed walkdowns in the service water intake structure, auxiliary building, and spent fuel pool building to verify vital equipment was operating properly.Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
===.3 Discovery of RCS Valve Packing Gland Follower Degradation=== | |||
====a. Inspection Scope==== | |||
On May 11, 2007, Dominion identified that RCS valve V185, the pressurizer leveltransmitter 459 isolation, exhibited boric acid corrosion of the packing gland follower. | |||
Dominion conducted an extent of condition review and identified an additional RCS valve, V184, the pressurizer level transmitter 460 isolation, also exhibited boric acid corrosion of the packing gland follower. The inspectors reviewed Dominion's corrective actions for the specific degraded valves and reviewed Dominion's BACC program since the condition of these valves had not been discovered as part of the BACC program discovery phase. Dominion replaced the packing gland follower on V184 and V185 with an equivalent design component. On May 15, 2007, the inspectors and Region I staff discussed the BACC program withDominion personnel given that the Dominion BACC had not identified the RCS valve degradation earlier in the outage during the discovery phase. The inspectors noted that the Dominion BACC program had identified, evaluated, and corrected a significant population of boric acid issues during the outage. However, the inspectors also noted that a more systematic approach in conducting the discovery phase of the BACC program (e.g., a detailed review of recent maintenance on RCS valves in containment)could have led to the identification of the condition of V184 and V185 during the BACC discovery phase. The inspectors verified that the need to enhance the BACC program was being tracked as a Site Vice President Level 1 issue.Documents reviewed for this inspection activity are listed in the Attachment. | |||
====b. Findings==== | |||
No findings of significance were identified..4(Closed) LER 05000336/2006006-00 & LER 05000336/2006006-01, Scaffolding Built forWork on Main Steam Isolation Valve (2-MS-64A) Prevented the Valve from Closing.On October 7, 2006, with the plant in Mode 3, scaffolding prevented the '1' MSIV fromfully closing during surveillance testing. The scaffold interference was removed within an hour of discovery. The scaffold was built on August 25, 2006, when the unit was in Mode 1, to support planned maintenance during the refueling outage which started on October 6, 2006. The MSIVs are required to close automatically upon receipt of a main steam isolation signal, to prevent blow-down of the steam generators during a steam line break downstream of the MSIVs. The valves are closed manually in the event of a steam generator tube rupture. | |||
32EnclosureThe issue was documented in NRC Inspection Report 05000336/2006005 as aself-revealing NCV. The inspectors determined that the corrective actions taken by Dominion to prevent recurrence appeared adequate. The original LER, and the subsequent revision, were reviewed and no additional findings were identified. These LERs are closed..5(Closed) LER 05000336/2006008-00, Scaffold Impairment of Turbine Driven Auxiliary Feedwater (TDAFW) Pump Room HELB Blowout Panel.On December 21, 2006, with the plant in Mode 1 at 100 percent power, the licenseeidentified that scaffolding was erected on top of the HELB blow-out panel for the TDAFW pump room. The scaffolding had been constructed on December 11, 2006. | |||
The scaffolding would have restricted the ability of the blow-out panel to perform the safety function of lifting in the event of a HELB event and the failure to lift could have resulted in the breaching of the wall separating the TDAFW pump room from the motor driven auxiliary feedwater pump room. The scaffolding was removed approximately four hours later, returning all of the AFW pumps to an operable status.The issue was documented in NRC Inspection Report 05000336/2006005, as alicensee-identified NCV. The inspectors determined that the corrective actions taken by Dominion to prevent recurrence appeared adequate. The LER was reviewed and no additional findings were identified. This LER is closed..6(Closed) LER 05000423/2007001-00, Failure of Two Main Steam Safety Valves to Liftwithin the Acceptance Criteria.On April 5, 2007, with the plant in Mode 1 and 100 percent power, two main steamsafety valves (MSSVs) failed to lift within the (+/- 3 percent) acceptance criteria during a planned test. Specifically, MSSV 3MSS*RB22B lifted at 1221.3 psig (1.3 psig above the allowable limit, approximately 3.1 percent), and MSSV 3MSS*RB22D lifted at 1232.8 psig (12.8 psig above the allowable limit, approximately 3.8 percent). Dominion attributed the failure of the MSSVs to lift within the required pressure range was due to a corrosive oxide locking action between the surface layer materials of the disc-seat interface. The inspectors reviewed this LER and associated CR to verify that Dominion's causal analysis and corrective actions were adequate. No findings of significance were identified. This LER is closed..7(Closed) LER 05000423/2007002-00, Loss of Offsite Power Caused by TransmissionSystem Operator while Defueled.On April 25, 2007, with the plant shutdown and defueled, a loss of offsite poweroccurred due to an offsite transmission system operator switching error. Specifically, the station 345 KV ring bus breaker 15G-13T-2 was inadvertently opened instead of the planned 15G-15T-2 breaker during a evolution intended to remove an offsite line from service. The inspectors reviewed this LER and associated condition report to verify that Dominion's causal analysis and corrective actions were adequate. | |||
33EnclosureThe inspector determined that no violations of regulatory requirements occurred. ThisLER is closed..8(Closed) Unresolved Item (URI) 05000336/2006010-01, NRC to Review Considerationof EDG Frequency Affects on Design Bases Calculations.The inspectors reviewed the URI documented in Inspection Report05000336/20060010. The URI was opened to assess if the minimum EDG frequency, as specified in the Unit 2 TS, should be accounted for in the minimum pump flow and head test acceptance criteria for pumps that could potentially be powered from this electric source. The inspection team noted that at reduced EDG output frequencies, the pump motor rotation speed is reduced. This would result in a lower developed pump flow and head. | |||
The inspectors found that the licensee's TS acceptance criteria for EDG frequency was60 hz +/- 1.2 hz. The inspectors determined that this acceptance criteria is verified on a 18 month bases during surveillance testing when the EDG is operated in isochronous mode. The inspectors also reviewed the EDG operating procedure and found the operating procedure requires that operators adjust EDG frequency to 60 hz when in isochronous operation. Additionally, the inspectors found that when the EDG receives an auto start signal, a digital 60 hz signal is sent to the governor control circuit regardless of the status of the EDG or the manual speed setting. Finally, the ability of the operators to adjust EDG frequency above 60 hz is tested quarterly via synchronizing procedures with the grid. The inspector concluded that the ability of operators to control EDG frequency and maintain it at 60 hz is proceduralized, tested, and easily accomplished.The inspector also reviewed the testing requirements and supporting designdocumentation for the Unit 2 service water pump. This pump was selected by the Component Design Basis Inspection team and the associated flow and head test acceptance criteria was the basis for the URI. The inspector found that the test acceptance criteria had sufficient margin (over 7 percent) to account for potential inaccuracies in the service water system computer modeling. These errors could include pump flow and head inputs. Additionally, the inspector determined that the licensee monitors the model via actual flow and head measurements. The results confirm that the model is more accurate than the 7 percent assumed error. The inspectors determined that no violations of regulatory requirements occurred. ThisURI is closed. | |||
===.9 (Closed) URI 05000336/2006010-02,=== | |||
NRC to Review Licensee Evaluation of Removalof Check Valve CS-26 Internals.The URI was opened to evaluate if the current licensing basis would require that theinternals of CS-26 be removed in order to reduce the overall risk to the Unit 2 Core Damage Frequency and to review Dominion's evaluation of the need to keep the internals in the valve. | |||
34EnclosureThe check valve is in the flow path of the minimum flow recirculation line for bothdivisions of Unit 2's containment spray pumps, high pressure safety injection pumps and low pressure safety injection pumps. Should the valve fail to open, when required, it would represent a potential common cause failure mechanism for all the pumps. The inspector concluded that the failure of a check valve to open would be considered a passive failure. The plant's licensing basis does not require that passive failures be considered until the recirculation phase of an accident. Because this check valve is not needed during this phase of an accident, a failure is not considered as part of the design basis. The inspector noted that the valve is verified operable during several quarterly pumpsurveillance tests. Additionally, the inspector reviewed the inspection Dominion performed on the internals of the check valve in October 2006 and verified the valve was working properly. This inspection is performed every 18 months. Finally, the inspector verified Dominion had entered the issue into their corrective action program in CR-06-05010 and had completed an evaluation of the need for the check valve in the system. The inspector found that Dominion had concluded that the valve internals could be removed and has preliminarily scheduled the work associated with the removal for the next refueling outage. The inspector determined that no violations of regulatory requirements occurred. ThisURI is closed..10(Closed) URI 05000336/2007002-01, Maintenance Rule (a)(1) Evaluation of Unit 2 VitalSwitchgear Emergency Cooling Failure.This URI was opened to reviewed Dominion's MR (a)(1) evaluation for the vitalswitchgear cooling system following the determination that air conditioning (A/C) unit A/C-3 B51 and A/C-4 B61 had an insufficient refrigerant charge as documented in corrective action program CR-06-01138 dated November 21, 2006. In accordance with MP-24-MR-FAP710, "Maintenance Rule Functional Failures and Evaluations," the evaluation concluded that there was no functional failure because the failures were considered design deficiencies that could not have been prevented by post modification testing or predictive maintenance. The inspectors conducted additional interviews with Dominion staff to better understand controls on the implementation of design changes into maintenance procedures and practices. The inspectors concluded that the air conditioner design requirements were properly incorporated into station procedures and that the issue was properly classified in Dominions maintenance rule program. The inspectors determined that no violations of regulatory requirements occurred. ThisURI is closed. | |||
35Enclosure4OA5Other Activities.1Temporary Instruction (TI) 2515/166 - Pressurized Water Reactor Containment SumpBlockage | |||
====a. Inspection Scope==== | |||
The inspectors performed the inspection in accordance with TI 2515/166. The TI wasdeveloped to support the NRC review of licensee activities in response to NRC Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors (PWR)." Specifically, the inspectors verified the implementation of the modifications and procedure changes were consistent with the proposed actions committed to in the GL response. The inspectors reviewed a sample of the licensing and design documents to verify that they were either updated or in the process of being updated to reflect the modifications. A sample of material specifications, testing and surveillance procedures, and calculations were reviewed to verify that they were updated to reflect the effects of the modification, and the new requirements for the containment sumps and debris generation sources. The inspectors performed a walkdown of the strainer installation to verify it was performed in accordance with the approved design change package. Finally, the inspectors verified that all choke-points were accounted for by the licensee's calculations that could prevent water from reaching the recirculation sump during a design basis accident. | |||
b.Evaluation of Inspection Requirements | |||
:The TI requires the inspectors to evaluate and answer the following questions: | |||
1.Did the licensee implement the plant modifications and procedure changescommitted to in their GL 2004-02 response?The inspectors verified that actions implemented by the licensee as described inresponse to GL 2004-02 were complete as it related to the installation of the sump screen and evaluation of potential debris sources. Additionally, the inspectors found that procedures to programmatically control potential debris generation sources were updated. The inspectors noted that the sump surface area that was installed had a smaller surface area than was discussed in the GL response; however, updated calculations supported the smaller size. Dominion intends to update the Millstone Unit 3 GL 2004-02 response to reflect these changes. The inspectors noted that Dominion had not completed downstream effects evaluation or the effects of chemical precipitants on the strainer head loss at the time of the inspection. 2.Has the licensee updated its licensing basis to reflect the corrective actionstaken in response to GL 2004-02? The inspectors verified that changes to the facility or procedures, as described inthe FSAR, that were identified in the licensee's GL 2004-02 response were reviewed and documented in accordance with 10 CFR 50.59 and the licensee 36Enclosurehad obtained NRC approval prior to implementing those changes that requiresuch approval as stated in 10 CFR 50.59. Dominion had submitted and received permission to change the recirculation pump start signal via licensee amendment number 233. Although this action was not mentioned in the GL response, it was needed to ensure sufficient net positive suction head was available for the recirculation system. Additionally, the inspectors noted that Dominion had submitted a TS amendment to change the inspection surveillance required by TS 4.5.2. The amendment was under review by the NRC at the time of the inspection. Finally, the inspectors verified that Dominion intends to update the Millstone Unit 3 licensing bases to reflect the final modification and associated procedure changes taken in response to GL 2004-02.The TI will remain open to allow for the review of portions of the GL response that havenot been completed. Specifically, Dominion had not completed their downstream effects analysis or chemical precipitant analysis. The results of these analyses have the potential to impact the final size of the strainer, licensing basis and programmatic procedures. Therefore, the inspection will be considered incomplete until the results are reviewed and accepted. Dominion plans to evaluate the strainer for adequacy once the test results that quantify the head loss are known. The NRC has set a December 2007 deadline, as specified in GL 2004-02, for the completion of these evaluations. | |||
====c. Findings==== | |||
No findings of significance were identified.4OA6Meetings, Including ExitOccupational Radiation Safety Exit Meeting SummaryOn April 26, 2007, the inspector presented the overall inspection results toMr. Alan Price, Site Vice President, and other members of his staff, who acknowledged the findings. The inspector asked Dominion whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.Inservice Inspection Exit Meeting SummaryOn April 26, 2007, the inspectors presented the overall inspection results toMr. Alan Price, Site Vice President, and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary information reviewed during the inspection period was returned to Dominion. | |||
37AttachmentDeputy Regional Administrator Site VisitOn June 25, 2007, a site visit was conducted by Mr. Marc L. Dapas, Deputy RegionalAdministrator for the NRC Region I office. During Mr. Dapas' visit, he toured the plant and met with Dominion managers.Integrated Report Exit Meeting SummaryOn July 10, 2007, the inspectors presented their overall findings to members ofDominion's management led by Mr. Alan Price, Site Vice President, and other members of his staff who acknowledged the findings. Two separate updates to the inspection results were presented to Mr. D. Dodson by telephone on July 19, 2007, and later on July 27, 2007. The inspectors confirmed that proprietary information reviewed during the inspection period was returned to Dominion.ATTACHMENT: | |||
=SUPPLEMENTAL INFORMATION= | |||
==KEY POINTS OF CONTACT== | |||
===Licensee personnel=== | |||
: [[contact::G. Allen - Plant Equipment OperatorJ. Armstrong]], Fire Protection Supervisor | |||
: [[contact::M. Bain]], Shift Manger | |||
: [[contact::R. Bracall]], Manager, Nuclear Maintenance | |||
: [[contact::C. Chapin]], Shift Manager | |||
: [[contact::G. Closius]], Licensing Engineer | |||
: [[contact::D. Delcore]], Supervisor, Health Physics Operations | |||
: [[contact::C. Dempsey]], Assistant Plant Manager | |||
: [[contact::D. Dodson]], Supervisor, Licensing | |||
: [[contact::M. Gagnon]], Plant Equipment Operator | |||
: [[contact::R. Griffin]], Director, Nuclear Station Safety & Licensing | |||
: [[contact::P. Grossman]], Manager, Nuclear Engineering | |||
: [[contact::C. Janis]], MR Coordinator | |||
: [[contact::A. Jordan]], Plant Manager | |||
: [[contact::K. Kirkman]], Operations | |||
: [[contact::E. Laine]], Manager, Radiological Protection & Chemistry | |||
: [[contact::R. MacManus]], Director - Nuclear Engineering | |||
: [[contact::T. Moore]], Service Water Systems Engineer | |||
: [[contact::M. Nappi]], Supervisor, Radiation Protection - ALARA | |||
: [[contact::F. Perry]], Senior Radiation Protection Technician (contracted) | |||
: [[contact::J. Preston]], Plant Equipment Operator | |||
: [[contact::A. Price]], Site Vice President | |||
: [[contact::A. Smith]], EDG Systems Engineer | |||
: [[contact::S. Turowski]], Supervisor-HP Technical Services | |||
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED== | |||
Opened05000423/2515/166TIPressurized Water Reactor ContainmentSump Blockage (4OA5.1) | |||
===Opened and Closed=== | |||
05000423/2007003-01NCVFailure to Perform Evaluations on BoricAcid Leaks (Section 1R08)05000336/2007003-02NCVInadequate Work Procedure for the Unit 2'C' Charging Pump Results in Pump Failure | |||
(Section 1R12)05000336/2007003-03NCVFailure to Adequately Evaluate SurveillanceTest Data (Section 1R19) | |||
A-2Attachment05000423/2007003-04NCVFailure to Implement Safety-RelatedSurveillance Procedure Resulted in the 'A' | |||
Safety Injection Accumulator Inoperability | |||
(Section 1R22) | |||
===Closed=== | |||
: [[Closes finding::05000336/FIN-2006010-01]] URINRC to review consideration of EDGfrequency affects on design bases | |||
calculations (Section 4OA3.8) | |||
: [[Closes finding::05000336/FIN-2006010-02]]URINRC to review licensee evaluation ofremoval of check valve CS-26 internals | |||
(Section 4OA3.9) | |||
: [[Closes finding::05000336/FIN-2007002-01]] URIMaintenance Rule (a)(1) Evaluation of Unit2 Vital Switchgear Emergency Cooling | |||
: Failure (Section 4OA3.10) | |||
: [[Closes LER::05000336/LER-2006-006]]-00LERScaffolding Built for Work on Main SteamIsolation Valve (2-MS-64A) Prevented the | |||
: Valve from Closing (Section 4OA3.4) | |||
: [[Closes LER::05000336/LER-2006-006]]-01LERScaffolding Built for Work on Main SteamIsolation Valve (2-MS-64A) Prevented the | |||
: Valve from Closing (Section 4OA3.4) | |||
: [[Closes LER::05000336/LER-2006-008]]-00LERScaffold Impairment of Turbine DrivenAuxiliary Feedwater Pump Room HELB | |||
: Blowout Panel (Section 4OA3.5) | |||
: [[Closes LER::05000423/LER-2007-001]]-00LERFailure of Two Main Steam Safety Valves toLift within the Acceptance Criteria (Section | |||
: 4OA3.6) | |||
: [[Closes LER::05000423/LER-2007-002]]-00LER Loss of Offsite Power Caused byTransmission System Operator while | |||
: Defueled (Section 4OA3.7) | |||
==LIST OF DOCUMENTS REVIEWED== | |||
==Section 1R01: Adverse Weather ProtectionProceduresAOP-3569, Rev 016-00, Severe Weather ConditionSP-2665, Rev 005-01, Building Flood Gate Inspections== | |||
: SP-2615, Rev 006-00, Flood Level Determination | |||
: OP 200.6, Rev 002-1, Storms and other Hazardous Phenomena Preparation and Recovery | |||
: A-3AttachmentOther DocumentsUnit 2 Technical SpecificationsUnit 3 Technical Specifications Unit 2 UFSAR | |||
: Unit 3 UFSAR | |||
==Section 1R04: Equipment AlignmentProceduresMP-16-MMM, Organizational EffectivenessMP-16-CAP-SAP01, Rev 002-01, Condition Report Initiation== | |||
: OP-2322, Rev 026-03, Auxiliary Feedwater System Lineup | |||
: OP-3446A, Rev 022-01, Emergency Diesel Generator | |||
: OP-3260I, Rev 000, RCS Inventory Tracking | |||
: OP-3216, Rev 008-06, Reactor Coolant System Drain (IPTE) | |||
: OP-2326A Rev 000-02, Service Water Alignment Verification | |||
: SP 2664, Rev 002-08, Charging Pump Pulsation Dampener TestCondition Reports07-06525, 07-06615, 07-06756, 07-05225, 07-05053, 07-6897 | |||
: Work OrdersM2-07-03275 | |||
: Other DocumentsVTM 25203-309-002A, Reciprocating Charging PumpsMP2703C9, Rev 005-03, Charging Pump Liquid End Maintenance Unit 2 Control Room logs for June 9, 2007 thru June 11, 2007 | |||
: PPC data for charging pump flow for months of April, May and June | |||
: FSAR Chapter 14 Analysis for Charging System | |||
: FSAR Chapter 9.7 Service Water System | |||
==Section 1R05: == | |||
: Fire ProtectionOther DocumentsMillstone Nuclear Power Station Unit 3 Fire Protection Evaluation ReportFPI 50-001, Revision 010-00, Fire Brigade Drill Assessment Data Sheet Millstone Unit 3 Fire Dill Scenario for 6/19/2007, Fire in the "A" EDG Room | |||
==Section 1R07: Heat Sink PerformanceWork OrdersM3-06-02923, M3-07-07304== | |||
: A-4AttachmentCondition Reports07-06058Section 1R08: Inservice Inspection ProceduresMP-24-BACC-PRG, Rev 000-01, Millstone Station Boric Acid Corrosion Control Program,MP-24-BACC-FAP03, Rev 000-01, Millstone Station Boric Acid Corrosion Control ProgramEvaluationsMP-24-BACC-FAP01-003, Millstone Unit 3 Bottom Mounted Nozzle Inspection FormWork OrdersM3-06-02508, M3-02-00346, M3-05-04786, M3-05-15980, M3-07-05971, M3-06-03604, M3-05-15827, M3-07-06026Condition Reports07-03974, 07-03865, 07-03515, 07-03604, 06-02088, 05-07753, 05-11061, 07-04776,07-00703, 05-12048, 05-13383, 05-12048, 05-12023, 07-04309, 07-04150, 05-04388, | |||
: 07-00712, 07-01109, 07-04184, 07-03848, 07-00889, 07-03865Personnel CertificationsPCI Energy Services NDE Level II Personnel Certificate, Visual Testing, Penetrant TestingDominion Supplemental NDE Personnel Certification Review Checklist | |||
: PCI Energy Services ASME WPQs, various welders Task Qualification Record, Boric Acid Corrosion EvaluatorOther DocumentsHead Penetration UT Coverage above/below J-groove weld spreadsheetISI Unresolved Indication Report, AWO M3-06-08221 | |||
: Pressurizer 'B' Safety Nozzle Weld Overlay Process Traveler with Sacrificial Layer, PressurizerNozzle Overlay, Rev. 0PCI Energy Services Weld Repair Data Sheets, Traveler 03-X-5648-B-T-OL1 | |||
: Wesdyne International Ultrasonic Calibration Sheet, Pressurizer Safety 'B', 0 | |||
o Wesdyne International 'B' Safety Overlay Baseline Contour Profile Document | |||
: PCI Energy Services Report of NDE Liquid Penetrant Examination, | |||
: PT-900701-002, 021, 003,020, | |||
: 004001, 006 PCI Energy Services Nonconformance Report, NCR No. 900701-02 | |||
: PCI Energy Services NDE Liquid Penetrant Examination, Weld No. 03-X-5650-D-T-OL1 | |||
: Westinghouse | |||
: MRS-SSP-2096 Millstone Unit 3 Structural Weld Overlay Dominion Boric Acid Corrosion Control Program, | |||
: DNAP-1004, Rev.'s 0-6 | |||
: AREVA NDE Procedure Visual Examination for Leakage of Reactor Head Penetrations,54-ISI-367-07AREVA NDE Procedure Remote Underwater Visual Inspection of Reactor PressureVessels,Vessel Internals and Components in Pressurized Water ReactorsAREVA NDE Procedure 54-ISI-801-02, Automated UT of PWR Vessel Shell Welds, dated2/14/2006AREVA NDE Procedure 54-ISI-855-04, Automated Ultrasonic Examination of Reactor | |||
: VesselNozzle to Shell Welds & Inner Radius Regions From the Nozzle Bore, dated 2/14/2006 | |||
: A-5Attachment2/28/03 Answer to Order for Interim Inspection Requirements for RPVH's at Pressurized WaterReactors2/23/07 Supplemental Information Regarding Request | |||
: IR-2-46 for Relaxation of Requirementsof Order | |||
: EA-03-009 Regarding Reactor Pressure Vessel Head Penetrations5/16/06 Relaxation of the Requirements of Order | |||
: EA-03-009 Regarding Reactor PressureVessel Head Inspections, Request | |||
: IR-2-463R11 Outage/ALARA Challenge Board Presentation on RV Head Stand Modification and RVHead Inspections3R11 Outage/ALARA Challenge Board Presentation on | |||
: RV 10 year ISI Inspection & BottomMounted Nozzles InspectionAlternative for the Weld Overlay of Pressurizer Nozzle Welds - Response to Request forAdditional InformationWestinghouse Drawing No. 10058C82, Millstone Unit 3 Pressurizer Safety/Relief Nozzle SWOLDesignMillstone Unit 3 Steam Generator Condition Monitoring and Operational Assessment RefuelingOutage 11, M3-EV-07-0016, Rev. 0Millstone Unit 3 - 2007 10 Year RV ISI Logistics Drawing 801724E, Sheet 4 of 15, Rev. 001 | |||
: Millstone Unit 3 Steam Generator Integrity Degradation Assessment R11, M3-EV-07-0006,Rev. 1Millstone, Units 2 and 3, Request for Additional Information, Bulletin 2002-01, Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity, 60-Day Response | |||
: 3R11 List of BACC AWO's, not packing or cleaning | |||
: BACCP Screening, 3RHS*V009 | |||
: Millstone Unit 3 Refueling Outage Boric Acid Corrosion Inspections 3R11 | |||
==Section 1R11: Licensed Operator Requalification ProgramOther DocumentsUnit 3 Licensed Operator Simulator Training Lesson Plan for June 21, 2007Unit 2 Evaluated Simulator Session== | |||
: ES07301B | |||
==Section 1R12: Maintenance EffectivenessProceduresMP-24-MR-FAP730, Rev 000-03, Maintenance Rule Goal Setting and MonitoringS2-EV-98-0060, Revision 1, Pipe Linings in the== | |||
: MP2 Service Water SystemCondition Reports07-01788, 07-00737 | |||
: Other DocumentsMillstone Unit 2 Maintenance Rule Scoping Table, Service WaterRoot Cause Evaluation M-07-00737, Service Water Leak from Red Rubber Gasket Joint inSupply to "A" EDG, Unit 2 | |||
==Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProcedures== | |||
: A-6AttachmentOP-3260A, Rev 016-01, Conduct of OutageOP-3215, Rev 007-05, Response to Intake Structure Degraded Condition | |||
: SP-3665.2, Rev 008-01, Intake Structure Condition Determination | |||
: MP-13-PRA-FAP01.1, Rev 002-02, Performing a 4 Risk Review | |||
: AOP-2504A, Rev 003-08, Loss of Non-Vital Instrument Panel | |||
: VR-11Condition Reports07-03503, 07-04514, 07-04546 | |||
: Work OrdersM2-07-02969 | |||
: Other DocumentsEquipment Out-Of-Service Risk Assessment ToolUnit 2 Technical Specifications | |||
==Section 1R15: Operability EvaluationsProceduresSP 2664, Rev 002-08, Charging Pump Pulsation Dampener TestMP2703C9, Rev 005-03, Charging Pump Liquid End Maintenance== | |||
: MP-16-MMM, Organizational EffectivenessMP-16-CAP-SAP01, Rev 002-01, Condition Report Initiation | |||
: MP-00-0590, Evaluation for corrective maintenance on Charging Pump | |||
: MP-07-03275, 'C' Charging Pump AssemblyWork OrdersM2-07-03275 | |||
: Condition Reports07-06525, 07-06615, 07-06756, 07-05225, 07-05053, 07-6897, 07-03322, 07-03568, 07-05073,07-04921, 07-05197, 07-09680Other DocumentsMP2-002-06, Operability Determination for Charging SystemFairbanks Morse Engine 10CFR21 Report 2007-10-00 | |||
: Unit 2 UFSAR 8.3 | |||
: Unit 2 T.S. 3.8.1.1/3.8.1.2 | |||
: RECO | |||
: MP2-807-07, Degraded Intake Structure Floor Drain Used for SW Pipe Break FloodProtectionRECO | |||
: MP3-007-07, New Vital Inverters 3VBA*INV2 and 3VBA*INV4 Have High FrequencyNoise Affecting SR NI and Gamma Metric InstrumentationTechnical Evaluation M3-EV-07-0020, Inventor 2 and 4 Operability | |||
: RECO/OD | |||
: MP3-008-07, Two Composite Stainless Steel and Boral Sheets Have BecomeDetachedNuclear Instrumentation Lesson Plans Unit 3 TS 3.9.1.3, Spent Fuel Pool - Reactivity Unit 3 TS 3.9.1.4, Spent Fuel Pool - Storage Pattern | |||
: A-6AttachmentVTM 25203-309-002A, Reciprocating Charging PumpsUnit 2 Control Room logs for June 9, 2007 thru June 11, 2007 | |||
: Unit 2 PPC data for charging pump flow for months of April, May and June Unit 2 FSAR Chapter 14 analysis for Charging System | |||
==Section 1R17: Permanent Plant ModificationsCondition Reports07-05185, 07-04914Other DocumentsDM3-00-0163-07, Gamma Metrics Source Range Instrument Noise Suppression(3NME*CHAN2)== | |||
: MELP CorrectionDM3-00-0166-07, Westinghouse NIS Source Range 32 Channel Noise Suppression(3NMS*DWR032)DCM 3-2A, Rev 011-01, Charging System Alternate Minimum Flow Line Modifications | |||
: VIAC2 Supplied From New Invertor 2 | |||
: Unit 3 50.59/72.48 Screen Form Unit 3 FSAR Chapter 3.10, Seismic Qualification of Seismic Category I Instrumentation andElectrical EquipmentTechnical Evaluation M3-EV-07-0020, Revision 0, Inverter 2 and 4 Operability | |||
: RECO | |||
: MP3-007-07, New Vital Inverters 3VBA*INV2 and 3VBA*INV4 have High FrequencyNoise Affecting SR NI and Gamma MetricsUnit 3 Nuclear instrument lesson Plans | |||
==Section 1R19: Post-Maintenance TestingProceduresOP 2304E21, Rev 000-00, 'C' Charging Pump and Discharge Check== | |||
: IST, OperatingOP 2304E21-001, Rev 00-00, "C" Charging Pump and Discharge Check IST, Operating | |||
: SP-2402PC, Rev 002, Channel "C" Spec 200 Safety Parameters Functional Test Data Sheet | |||
: SP-2402BR, Rev 000, Channel "C" Pressurizer Pressure Rack Calibration Data Sheet | |||
: SP-2403DC, Rev 000-07, Channel "C" Containment Pressure Calibration | |||
: SP-2664-3, Rev 001-02, Charging Pump "C" Pulsation Dampener Test | |||
: SP-2664, Rev 002-08, Charging Pump Pulsation Dampener Test | |||
: SP-2664, Rev 001-03, Charging Pump 'C' Pulsation Dampener TestCondition Reports07-05345 | |||
: A-7AttachmentWork OrdersM3-06-02617, M3-07-06740, M3-05-09947, M3-07-06253, M3-05-06229, M3-05-14215, M2-07-03275, M2-07-03190, M2-07-03201 | |||
==Section 1R20: Outage and Other ActivitiesProceduresOP 3201, Rev 020-013, Plant HeatupOP 3202, Rev 020-00, Reactor Startup== | |||
: OP 3203, Rev 018-07, Plant Startup | |||
: OP 3207, Rev 013-03, Reactor Shutdown | |||
: OP 3208, Rev 020-19, Plant Cooldown | |||
: OP 3209A, Rev 008-00, Estimated Critical Conditions | |||
: OP 3210B, Rev 009-02, Refueling Operations | |||
: OP 3210A, Rev 013-16, Refueling Preparations | |||
: OP 3216, Rev 008-07, RCS Drain | |||
: OP 3217, Rev 006-02, RCS System Fill | |||
: OP 3218, Rev 007-05, RCS Fill and Sweep | |||
: OP 3250.01, Rev 010-10, Individual Loop Drain and Fill | |||
: OP 3260A, Rev 016-01, Conduct of Outages | |||
: OP 3260A-004, Rev 014-01, Shutdown Safety Assessment Checklist | |||
: OP 3203A, Rev 010-02, Spent Fuel Bridge | |||
: OP 3303D, Rev 011-06, Fuel Handling Tools | |||
: OP 3345, Rev 016-00, 125V DC | |||
: EOP 3501, Rev 014-01, Loss of All AC in Modes 5,6, and 0 | |||
: EOP 3505, Rev 010-02, Loss of Shutdown Cooling and or Inventory Control | |||
: EOP 3505A, Rev 006-00, Loss of Spent Fuel Pool Cooling | |||
: FP02.1, Rev 001-06, Shutdown Risk Management | |||
: MP 3704B Control of Heavy Loads | |||
: MP-24-HL-PRG Heavy LoadsCondition Reports07-03165, 07-03167, 07-03284, 07-03321, 07-03478, 07-03479, 07-03567, 07-03653, 07-03661, 07-03710, 07-03716, 07-03733, 07-03842, 07-03512, 07-04184, 07-04201, 07-04340, | |||
: 07-04514, 07-04551, 07-04590, 07-04619, 07-04786, 07-04801, 07-05226Other Documents96-ENG-1252-C3 MP3 Structural Evaluation of RPV Head Drop (41') 3R11 Outage Risk Management Plan Dominion Response to Generic Letter 88-17, Reduced Inventory and Mid-Loop Conditions | |||
: NRC Generic Letter 87-12, "Loss of RHR while the RCS is Partially Filled | |||
: NUREG-1269, Loss of RHR, Diablo Canyon | |||
: NRC Generic Letter 88-17, Loss of Decay Heat Residual Heat Removal | |||
: NUREG-1410, Loss of Vital AC Power and RHR System during Mid-Loop Operations | |||
: NUREG-1449, Shutdown and Low-Power Operations at Commercial Nuclear Power Plants inthe United States | |||
==Section 1R22: Surveillance Testing== | |||
: A-8AttachmentProceduresOP-2346A, Rev 026-06, "A" Emergency Diesel GeneratorM3-05-14054, Main Steam Safety Valve Simmer Testing | |||
: MP-05-DC-FAP01.1-005, Rev 002-01, Train A [engineered safety features] ESF with LOP Test | |||
: SP-2613K, Rev 003-04, Diesel Generator Slow Start Operability Test, Facility 1 | |||
: SP-2619G, Rev 002-00, AC Electrical Sources Inoperability | |||
: SP-2624A, Rev 002-04, "A" Emergency Diesel Generator Auxiliaries Inservice Testing | |||
: SP-2670, Rev 010-04, Saltwater Cooled HX D/P Determination | |||
: SP-3646A.15, Rev 016-02, Train A Loss of Power Test (IPTE) | |||
: SP-3646A.17, Rev 016-02, Train A with Loss of Power Test (IPTE) | |||
: SP-3712G, Rev 008-01, Main Steam Code Safety Valve Surveillance Testing (IPTE) | |||
: SP-3601G.2, Rev 008-03, RCS and Pressurizer Heatup and Cooldown Rate | |||
: SP-3601G.2-002, Rev 008, Pressurizer Heatup and Cooldown Rate and Surge LineTemperature MonitoringSP-3601G.2-001, Rev 005, RCS Heatup and Cooldown Rate | |||
: SP-3610B.2, Rev 2, Accumulator Vent Valves | |||
: SP 31008, Rev 004-01, Lower Power Physics Testing (IPTE) | |||
: SP 2606C, Rev 010-00, | |||
: CS-4.1A Valve Tests, Facility 1 | |||
: SP 2610CO, Rev 000-03, 2-FW-43A and 2-FW-43B Failure Mode and Stroke Timing ISTDrawingsDWG. 25212-39241, Sheet 189, Rev 7, Emergency Generator Load SequencingP&ID 25203-26015, sheet1, Containment Spray SystemCondition Reports07-03710, 07-03256, 07-03257, 07-03478, 07-05596 | |||
: Other DocumentsLetter from Dresser Consolidated to Dominion dated 2/16/2007 Re: Certification ofCompliance/Conformance of Hydroset S/N | |||
: HS-641Unit 2 TS 3.4.9.1 and Bases, Pressure/Temperature Limits Unit 2 TS 6.1.9, Component Cyclic or Transient Limit Unit 2 TS 3.6.3, Containment Isolation Valves Unit 2 TRM 3.4.9.2 and Bases, Pressurizer | |||
==Section 1R23: Temporary Plant ModificationsOther DocumentsSPROC== | |||
: ENG07-3-001, Rev 000, DCR M3-06004 inverter ReplacementWC 10-004, Rev 000-03, Temporary Modification Control Sheet | |||
: DCM 3-2A, Rev 011-01, Unit 3 Vital Inverters Replacement | |||
: DCM 03-007A, Rev 015-02, MP3 Vital Inverter 2 Replacement | |||
: A-8Attachment | |||
==Section 1EP6: Drill EvaluationOther DocumentsUnit 3 Drill Exercise Plan for 6/21/2007 DrillUnit 2 Drill Exercise Plan for 6/12/2007 DrillSection 2OS1:== | |||
: Access Control to Radiologically Significance Areas and | |||
==Section 2OS2: ALARA Planning and ControlsProceduresRPM 1.3.8, Rev 8, Criteria for Dosimetry IssueRPM 1.3.12, Rev 8, Internal Monitoring Program== | |||
: RPM 1.3.13, Rev 8, Bioassay Sampling and Analysis | |||
: RPM 1.3.14, Rev 7, Personnel Dose Calculations and Assessments | |||
: RPM 1.4.1, Rev 7, ALARA Reviews and Reports | |||
: RPM 1.4.2, Rev 2, ALARA Engineering Controls | |||
: RPM 1.4.4, Rev 2, Temporary Shielding | |||
: RPM 1.5.2, Rev 4, High Radiation Area Key Control | |||
: RPM 1.5.5, Rev 4, Guidelines for Performance of Radiological Surveys | |||
: RPM 1.5.6, Rev 3, Survey Documentation and Disposition | |||
: RPM 1.6.4, Rev 3, Siemens Electronic Dosimetry System | |||
: RPM 2.1.1, Rev 5, Issuance and Control of RWPs | |||
: RPM 2.1.2, Rev 2, ALARA Interface with the RWP Process | |||
: RPM 2.4.1, Rev 6, Posting of Radiological Control Areas | |||
: RPM 2.10.2, Rev 11, Air Sample Counting and Analysis | |||
: RPM 5.2.2, Rev 10, Basic Radiation Worker Responsibilities | |||
: RPM 5.2.3, Rev 3, ALARA Program and Policy | |||
: RPM-GDL-008, Rev 0, Electronic Dosimeter Alarm Set PointsCondition Reports07-00925, 07-03426, 07-01940, 07-02141, 07-02651, 07-02856, 07-03299, 07-03730, | |||
: 07-03738, 07-04358ALARA Council Meeting NotesMeetings conducted: 04/11/07, 04/12/07, 04/18/07, 04/20/07 | |||
: Nuclear Oversight Department Field Observation (NODFOB) Reports07-008, 07-010, 07-006, 07-027, 07-034 | |||
: ALARA Reviews3-07-01, Reactor Disassembly3-07-02, Steam Generator Eddy Current Inspection (S/G-B&D) | |||
: 3-07-05, ISI Weld Inspections & Boric Acid Corrosion Control Program | |||
: 3-07-11, MOV Maintenance | |||
: 3-07-13, Scaffold Installation & Removal | |||
: 3-07-14, Insulation Removal | |||
: A-8AttachmentALARA Pre-Job Briefing MaterialsReactor DefuelingInsulation Removal Routine Maintenance Reactor Disassembly Scaffolding Installation Steam Generator Eddy Current Testing Steam Generator Secondary Side Cleaning & InspectionRadiation Protection Department Self-AssessmentsMP-SA-06-48, Release of Material from Radiologically Controlled Area BoundariesMP-SA-07-12, Radiological Protection Accredited TrainingOther DocumentsNo M3-07-00, Personnel Contamination Report3R11 Reactor Cavity Decontamination Plan Unit 3 Source Term Data | |||
: 3R11 ALARA Behaviors Report (Summaries from 3R11 Work Observation Focus Card) | |||
: Dose & Dose Rate Alarm Report for the period April 1 - 25, 2007Section 4OA1 - Performance Indicator (PI) VerificationProceduresSP 2619A, Rev 044-09, Control Room Daily Surveillance, Modes 1 & 2SP 2831, Rev 008-04, Reactor Coolant Gros Specific Activity Determination | |||
: SP 2830, Rev 007-02, Sampling Reactor Coolant for Dissolved Oxygen, Chloride and FluorideAnalysisOther DocumentsMillstone Unit 2 RCS leakage data sheet from January 1, 2006 thru March 31, 2007Millstone Unit 2 RCS Activity data sheet from January 1, 2006 thru March 31, 2007Section 4OA2 - | |||
: Identification and Resolution of ProblemsProceduresC-MP-720A, Scaffold Erection, Use and Removal, Rev 003-01MP-20-WP-GDL20, Work Order Preparation, Rev 16 | |||
: MP-SA-07-31, Formal Self-Assessment Report for Fire Protection System | |||
: MP-SA-07-06, Informal Self-Assessment Plan/Report for 2006/7Condition Reports06-01457, 06-01791, 06-01796, 06-01846, 06-02067, 06-02245, 06-02544, 06-03091, 06-05342, 06-05479, 06-05481, 06-05482, 06-06921, 06-07783, 06-08327, 06-08367, 06-09944, | |||
: 07-06694, 05-07367, 06-09203, 06-12526, 06-12555, 07-05826, 07-05276, 07-05371, 07- | |||
: 05376, 07-05445, 01-00904, 07-03937, 07-03447, 06-10100, 06-07999, 05-13883 | |||
: A-8AttachmentWork OrdersM2-06-02234, M2-06-03895, M2-06-03896, M2-06-03898,M2-02-06224-8,M3-04-01088M2-05-09339, M3-01-18643, M3-04-00484Other DocumentsDM2-00-0183-06, Unit 2 Instrument Air Excess Flow Valve RemovalMaintenance Rule (a)(1) Evaluation for Instrument Air Function 1.01, dated May 23, 2006 | |||
: MP2 PRA Instrument Air Model Notebook, revision 2 | |||
: Root Cause Evaluation M-06-01796, Reactor Trip due to Instrument Air Loss Effectiveness Review for Root Cause Evaluation | |||
: CR-06-01796, dated April 5, 2007 | |||
: Licensee Event Report 05000336/2006-002-00, Manual Reactor Trip of both Feed Pumpsfollowing a Loss of Instrument AirSystem Health Reports for Instrument Air, 2006 Quarters 1 thru 4, and 2007 Quarter 1 | |||
: System Health reports for Unit 2 Maintenance Rule (a)(1) systems | |||
==Section 4OA3: Followup of Events and Notices of Enforcement DiscretionProceduresMP-26-EPA-REF03, Rev 008, Loss of PowerEOP-3501, Rev 014-01, Loss of All== | |||
: AC Power (Mode 5, 6, and Zero) | |||
: EOP-3505, Rev 010-02, Loss of Shutdown Cooling and/or RCS Inventory | |||
: EOP-35 | |||
: GA-1, Rev 001-00, Energizing MCC 32-3T | |||
: SP-2671, Rev 006-08, OMOC Duty Officer Requirement Following Unplanned Reactor Trip,Reactor Transient, or ESF ActuationOP-3314F, Rev 020-08, Control Building Heating Ventilation Air Conditioning and Chill Water | |||
: OP-3346A, Rev 022-01, Emergency Diesel GeneratorCondition Reports06-00233, 06-05351, 06-06057, 06-09203, 06-11527, 06-11638, 05-07367, 06-09203,06-12526, 06-12555, 07-05826, 07-03104, 07-04514, 07-03256, 07-03167, 07-01325Other DocumentsCT-07-03256, Valve 3MSS*RV22D Failed As-found Set Pressure TestingEngineering Record of Correspondence 25212-ER-07-0038 dated 4/3/07 | |||
: Engineering Record of Correspondence 25212-ER-07-0038 dated 4/5/07 | |||
: NCV 05000336/2006005-04, Failure to Identify Scaffolding Rendered the #1 SG MSIVInoperableNCV 05000336/2006005, Licensee Identified, Failure to Implement Adequate CorrectiveActions to Prevent Recurrence with Respect to Scaffolding Affecting Safety-Related EquipmentEvent Review Team Report, Millstone 3 Loss of Offsite Power Event, April 25, 2007 | |||
: Millstone Unit 2 Technical Specifications Operator Logs, January 9, 2006 | |||
: MP-SA-07-31, Dominion Formal Self-Assessment for Fire Protection System | |||
: MP-SA-07-06, Dominion Informal Self-Assessment of Quality Review for Past Design Changes Millstone Unit 2/Unit 3 2007 Qtr 1 System Health Reports Millstone Unit 2/Unit 3 2007 Qtr 1 Plant Health Reports | |||
: LER 2006-006-00 & -01, Scaffolding Built for Work on Main Steam Isolation Valve | |||
: A-8Attachment(2-MS-64A) Prevented the Valve from ClosingLER 2006-008-00, Scaffold Impairment of Turbine Driven Auxiliary Feedwater Pump RoomHELB Blowout PanelLER 2007-001-00, Failure of Two Main Steam Safety Valves to Lift within the AcceptanceCriteriaLER 2007-002-00 , Loss of Offsite Power Caused by Transmission System Operator whileDefueledNRC Confirmatory Action Letter to Dominion dated March 27, 2007 | |||
==Section 4OA5: Other ActivitiesProceduresOP 2346A, "A" Emergency Diesel Generator, Rev 026-06MS 12179-123a, Removable Thermal Insulation, Rev 1== | |||
: SP 2612A, "A" SW Pump and Facility 1 Discharge Check Valve IST, Rev 002-00 | |||
: SP 2612A, "A" Service Water Pump Tests, Rev 010-02 | |||
: SP 2613G, Facility 1 ESF Integrated Test Data Sheet, Rev 008 | |||
: SP 3612A.1, Containment Inspections, Rev 016 | |||
: SP 3612A.1, Containment Sump Inspection, Rev 005 | |||
: SP-ME-691, General Thermal Insulation Design and InstallationCondition Reports07-04117 | |||
: Other Documents108788-US(B)-372, Simplified Containment Recirculation Spray System (RSS) NPSH andSuction Hydraulic Analysis Without Debris Transport, Rev 0 | |||
: 2179-249, Determination of Max. Water Level Inside Containment Following a LOCA, Rev 3 | |||
: CALC 05-ENG-04155C3, MPS Determination of Latent Debris Inside Containment, Rev 0-2, 3 | |||
: DCM 03 Attachment 9, Rev 014-03, Design Engineering Screening Evaluation | |||
: DCR M3-05003, Replacement of [emergency core cooling system] ECCS Sump Strainer perGL 2004-02, | |||
: GSI 191, Rev 0Dominion Nuclear Connecticut, Inc., Virginia Electric and Power Company, Millstone PowerStation Units 2 and 3, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, NRC Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, 90 Day Response, dated March 4, 2005Dominion Nuclear Connecticut, Inc., Virginia Electric and Power Company, Millstone PowerStation Units 2 and 3, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, NRC Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, dated September 1, 2005PT 21416H1, MP 2 "A" Diesel Generator (H7A) Woodward 2301A Replacement andAdjustment, Rev 002-02PT 21416H3, MP2 "A" Diesel Generator (H7A) Woodward Digital Reference Unit Installationand Adjustments, Rev 002-02PT 21416G1, MP2 Diesel Generator Woodward 2310A Bench Test, Rev 002 | |||
: A-8AttachmentPT 21416G2, | |||
: MP-2 Diesel Generator Woodward Digital Reference Unit (DRU) Bench Test, Rev002-02 Unit 3 Updated Final Safety Analysis Report | |||
: 06-838, Letter from USNRC to Dominion, Millstone Power Station, Unit NO. 3 Issuance ofAmendment (No. 233) RE: Recirculation Spray SystemTemporary Instruction (TI) 2515/166 - Pressurized Water Reactor Containment Sump Blockage | |||
: 06002757, 2008 Project Plan for Check Valve 2-CS-26 | |||
: 203-ER-98-0301, Design Basis for Safety Related Pump Testing, Rev 06 | |||
: 98-ENG-02697M2, Service Water Pumps Acceptance Curve, Rev 0-01 | |||
: ED 21221, Swing Check Valve Inspection Data Sheet Sketch, performed Oct 18, 2006 | |||
: M2-EV-99-0014, IST Pump Performance Testing Acceptance Criteria, Rev 4 | |||
: VTM 25203-138-006, Woodward Governor, Rev 1 | |||
==LIST OF ACRONYMS== | |||
3R11Unit 3 refueling outageA/Cair conditioning | |||
ACEapparent cause evaluation | |||
AFWauxiliary feedwater | |||
ALARAas low as reasonably achievable | |||
AOPabnormal operating procedure | |||
ASMEAmerican Society of Mechanical Engineers | |||
BACCboric acid corrosion control | |||
CALConfirmatory Action Letter | |||
: [[CFRC]] [[ode of Federal Regulations]] | |||
: [[CONVEX]] [[Connecticut Valley Electrical Exchange]] | |||
CRcondition report | |||
DRPDivision of Reactor Projects | |||
DRSDivision of Reactor Safety | |||
EDGemergency diesel generator | |||
EOPemergency operating procedure | |||
FSARFinal Safety Analysis Report | |||
GLgeneric letter | |||
gpmgallons per minute | |||
HELBhigh energy line break | |||
IMCinspection manual chapter | |||
ISIinservice inspection | |||
ISTinservice test | |||
LCOlimiting condition for operation | |||
LERlicensee event report | |||
LHRAlocked high radiation area | |||
LOPloss of power | |||
MRmaintenance rule | |||
MSIVmain steam isolation valve | |||
MSSVmain steam safety valve | |||
NCVnon-cited violation | |||
NDEnondestructive examination | |||
NRCNuclear Regulatory Commission | |||
A-8AttachmentPCRpersonnel contamination reportPIperformance indicator | |||
PMTpostmaintenance testing | |||
PWRpressurized-water reactor | |||
QCquality control | |||
RCSreactor coolant system | |||
RFOrefueling outage | |||
RHRresidual heat removal system | |||
RPCCWreactor plant closed cooling water | |||
RSSTreserve station service transformer | |||
RWPradiation work permit | |||
SSCsystems, structures and components | |||
SDPsignificance determination process | |||
SIsafety injection | |||
TDAFWturbine-driven auxiliary feedwater | |||
TItemporary instruction | |||
TStechnical specification | |||
UFSARupdated final safety analysis report | |||
: [[VHRA]] [[very high radiation area]] | |||
}} | |||
Revision as of 08:39, 10 February 2019
| ML072220286 | |
| Person / Time | |
|---|---|
| Site: | Millstone |
| Issue date: | 08/10/2007 |
| From: | Powell R J NRC/RGN-I/DRP/PB5 |
| To: | Christian D A Dominion Resources |
| Powell R J, RI/DRP/610-337-6967 | |
| References | |
| IR-07-003 | |
| Download: ML072220286 (63) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I475 ALLENDALE ROADKING OF PRUSSIA, PENNSYLVANIA 19406-1415 August 10, 2007Mr. David A. ChristianSr. Vice President and Chief Nuclear Officer Dominion Resources 5000 Dominion Boulevard Glenn Allen, VA 23060-6711
SUBJECT: MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT05000336/2007003 AND 05000423/2007003
Dear Mr. Christian:
On June 30, 2007, the US Nuclear Regulatory Commission (NRC) completed an inspection atyour Millstone Power Station, Unit 2 and Unit 3. The enclosed inspection report documents the inspection results, which were discussed on July 10, 2007, with Mr. J. Alan Price, Site Vice President, and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.This report documents two NRC-identified findings and two self-revealing findings of very lowsafety significance (Green). All of these findings were determined to involve violations of NRC requirements. However, because of their very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), consistent with Section VI.A.1 of the NRC's Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.:
Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Millstone Power Station.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in the Mr. D. Christian2NRC Public Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/Raymond J. Powell, ChiefReactor Projects Branch 5 Division of Reactor ProjectsDocket Nos.:50-336, 50-423License Nos.:DPR-65, NPF-49
Enclosure:
Inspection Report 05000336/2007003 and 05000423/2007003
w/Attachment:
Supplemental Informationcc w/encl:J. A. Price, Site Vice President, Millstone StationC. L. Funderburk, Director, Nuclear Licensing and Operations Support D. W. Dodson, Supervisor, Station Licensing L. M. Cuoco, Senior Counsel C. Brinkman, Manager, Washington Nuclear Operations J. Roy, Director of Operations, Massachusetts Municipal Wholesale Electric Company First Selectmen, Town of Waterford B. Sheehan, Co-Chair, NEAC E. Woollacott, Co-Chair, NEAC E. Wilds, Director, State of Connecticut SLO Designee J. Buckingham, Department of Public Utility Control G. Proios, Suffolk County Planning Dept.
R. Shadis, New England Coalition Staff G. Winslow, Citizens Regulatory Commission (CRC)
S. Comley, We The People D. Katz, Citizens Awareness Network (CAN)
R. Bassilakis, CAN J. M. Block, Attorney, CAN P. Eddy, Electric Division, Department of Public Service, State of New York M. Balboni, Deputy Secy, New York State Energy Research and Development Authority J. Spath, SLO Designee, New York State Energy Research and Development Authority M
SUMMARY OF FINDINGS
IR 05000336/2007003, 05000423/2007003; 04/01/2007 - 06/30/2007; Millstone Power Station,Unit 2 and Unit 3; Inservice Inspection, Maintenance Effectiveness, Post-Maintenance Testing, and Surveillance Testing.The report covered a 3-month period of inspection by resident inspectors and announcedinspections by regional inspectors. Four Green non-cited violations (NCVs) were identified.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Initiating Events
- Green.
The inspectors identified that Dominion did not follow Boric Acid CorrosionControl program procedures. Specifically, plant personnel failed to adequately perform boric acid leak evaluations as required by Dominion procedure DNAP-1004, "Boric Acid Corrosion Control Program." This finding was determined to be an NCV of 10 CFR 50,
Appendix B, Criterion V, "Instructions, Procedures, and Drawings." Dominion's corrective actions for this issue included a general area cleaning program to remove boric acid residue from target components and ensuring the Boric Acid Corrosion Control program includes clear documentation of evaluations for both the leaking component and any associated target component(s).This finding was more than minor because it was associated with the humanperformance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A,
"Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue did not result in exceeding the Technical Specification limit for identified reactor coolant system (RCS) leakage or affect other mitigating systems resulting in a total loss of their safety function. Additionally, this finding is similar to IMC 0612, Appendix E, example 4a, in that the licensee routinely failed to perform engineering evaluations on similar issues; i.e., boric acid leaks. The performance deficiency had a cross-cutting aspect in the area of human performance, work practices component, because Dominion did not ensure personnel followed procedures. [H.4.(b)] (Section IR08)iv
Cornerstone: Mitigating Systems
- Green.
A self-revealing finding was identified when Dominion did not ensure anadequate work procedure was available for maintenance performed on the Unit 2 'C'
charging pump on May 5, 2007, resulting in a failure of the pump on June 11, 2007.
Specifically, the work procedure did not give specific guidance for assembly and installation of the suction poppet valve in accordance with direction provided in the vendor technical manual. On June 11, 2007, the 'C' charging pump failed and was declared inoperable due to a seized plunger shaft. This finding was determined to be an NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings."
Dominion's corrective actions for this issue included repair and retest of the 'C' charging pump, revising the work procedure to include vendor recommendations, and training for maintenance personnel on assembly and installation of charging pump poppet valves.The finding was more than minor because it was associated with the procedural qualityattribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of human performance, resources component, because Dominion did not ensure that a complete, accurate, and adequate work procedure was available for maintenance performed on a safety-related component. [H.2.(c)] (Section 1R12)Green. The inspectors identified that Dominion did not adequately evaluate surveillancetest results to ensure test acceptance criteria had been met on May 10, 2007.
Specifically, the inspectors identified that the 'C' charging pump pulsation dampener surveillance test had cited incorrect data and had been accepted as satisfactorily complete, though the test data was outside of the surveillance acceptance criteria. This finding was determined to be an NCV of 10 CFR 50, Appendix B, Criterion XI, "Test Control." The surveillance was successfully re-performed on May 13, 2007. Dominion's corrective actions for this issue included revising the surveillance to clarify test requirements and required reading for operations personnel on how to adequately document and review surveillance test data.The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify out of specification data could result in the failure to identify inoperable equipment. The inspectors also concluded that if the failure to properly evaluate charging pump discharge dampener test data was not corrected, a more significant concern could exist in that failure of the dampener has previously resulted in a loss of all charging due to the migration of nitrogen from a failed discharge pulsation dampener to the common suction piping for all three charging pumps (as described in NRC inspection reports v05000336/2006002 and 05000336/2006006). The inspectors conducted a Phase 1SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of problem identification and resolution, corrective action program component, because Dominion did not identify out of specification test data. [P.1.(a)] (Section 1R19)Green. A self-revealing finding was identified when Dominion incorrectly performed asafety-related surveillance procedure. Specifically, Operations mistakenly performed a biennial surveillance test that verified remote vent valve position by opening a nitrogen vent path and verifying a decrease in accumulator pressure for the Unit 3 'A' safety injection (SI) accumulator instead of the planned quarterly surveillance. As a result, the
'A' SI accumulator was inadvertently depressurized to below the TS value. This finding was determined to be an NCV of TS 6.8.1, "Procedures." Dominion's corrective actions for this issue included restoring accumulator pressure, performing an apparent cause evaluation to determine the underlying causes associated with the error, training the personnel involved, and scheduling human performance training for Operations during training cycle 07-03. The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A,
"Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross cutting aspect in the area of human performance, work practice component, because Dominion's human error prevention techniques such as holding a pre-job brief and peer checking were not used to ensure the surveillance was properly performed. [H.4.(a)] (Section 1R22).
B.Licensee-Identified Violations
None.
Enclosure
REPORT DETAILS
Summary of Plant StatusUnit 2 operated at or near 100 percent power for the entire inspection period.
Unit 3 began the inspection period operating at approximately 100 percent power. On April 6, 2007, Unit 3 performed a shutdown in preparation for Refueling Outage (RFO) 3R11.
Following completion of RFO activities, Unit 3 achieved criticality on May 18, 2007. Unit 3 reached 100 percent power on May 22, 2007. From May 22, 2007, through the end of the inspection period, the Unit 3 operated at or near 100 percent power.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01)
a. Inspection Scope
(One site sample)The inspectors performed a review of severe weather preparations during the onset ofthe hurricane season to evaluate the site's readiness for seasonal susceptibilities. The inspectors reviewed Dominion's preparations for severe weather and the protection of safety-related systems, structures and components (SSCs). The inspection ensured that the selected equipment, instrumentation, and supporting structures were configured in accordance with Dominion's procedures and that adequate controls were in place to ensure functionality of the systems. The inspectors reviewed the Unit 2 and Unit 3 Final Safety Analysis Report (FSAR) and Technical Specifications (TS) and compared the analysis with procedural requirements to determine whether procedures were consistent with the FSAR. The inspectors performed partial system walkdowns of the Unit 2 and Unit 3 intake structures, service water systems, intake structure traveling screens and emergency diesel generators (EDGs) to determine the adequacy of equipment protection from the effects of hurricanes. The inspectors verified that operator actions defined in the adverse weather procedures maintained readiness of essential systems and that adequate operator staffing was specified. Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.
b. Findings
No findings of significance were identified.
2Enclosure1R04Equipment Alignment (71111.04).1Partial System Walkdowns
a. Inspection Scope
(Two Unit 2 and two Unit 3 samples)The inspectors performed four partial system walkdowns during this inspection period. The partial equipment alignment inspections were completed during conditions when the equipment was of increased safety significance such as would occur when redundant equipment was unavailable during maintenance or adverse conditions; or after equipment was recently returned to service after maintenance. The inspectors conducted a walkdown of each system to verify that the critical portions of selected systems were correctly aligned in accordance with applicable procedures and to identify any discrepancies that may have had an effect on operability. The inspectors verified that equipment alignment problems that could cause initiating events, impact mitigating system availability or function, or affect barrier functions, were identified and resolved.
The following systems were reviewed based on their risk significance for the given plant configuration:Unit 2*Auxiliary feedwater (AFW) system during switchyard maintenance on April 27, 2007; and*Charging system 'A' and 'B' charging pumps during 'C' charging pump correctivemaintenance on June 13, 2007.Unit 3*Reactor coolant system (RCS) level instrumentation during reduced inventoryoperations on April 12, 2007; and*'A' EDG due to the 'B' EDG being out-of-service on April 15, 2007.Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.
b. Findings
No findings of significance were identified..2Complete System Walkdown
a. Inspection Scope
(One Unit 2 sample)The inspectors completed a detailed review of the alignment and condition of the Unit 2service water system. The inspectors conducted a walkdown of the system to verify that the critical portions, such as valve positions, switches, and breakers, were aligned in accordance with procedures and to identify any discrepancies that may have had an effect on operability.
3EnclosureThe inspectors also conducted a review of outstanding maintenance work orders toverify that the deficiencies did not significantly affect the Unit 2 service water system function. In addition, the inspectors discussed system health with the system engineer and reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved. Documents reviewed for this inspection activity are listed in the SupplementalInformation Attachment to this report.
b. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05).1Quarterly Sample Review
a. Inspection Scope
(Six Unit 2 and six Unit 3 samples)The inspectors performed twelve walkdowns of fire protection areas during theinspection period. The inspectors reviewed Dominion's fire protection program to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. The inspectors walked down these areas to assess Dominion's control of transient combustible material and ignition sources. In addition, the inspectors evaluated the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors then compared the existing conditions of the areas to the fire protection program requirements to ensure all program requirements were being met. The fire protection areas reviewed included:Unit 2*Auxiliary Building, West Main Steam Safety Valve Room, 38'6" Elevation (FireArea A-8, Zone E);*Auxiliary Building, West Electrical Penetration Area, 14'6" Elevation (Fire AreaA-8, Zone D);*Auxiliary Building, East Piping Penetration Area, -25'6" and -5'0" Elevation (FireArea A-10, Zone A);*Auxiliary Building, East Electrical Penetration Area, 14'6" Elevation (Fire AreaA-10, Zone B);*Auxiliary Building, East Main Steam Safety Valve/Blowdown Tank Room, 38'6"Elevation (Fire Area A-10, Zone C); and*Auxiliary Building, Boric Acid Batch Tank/Chemical Addition Tank, 14'6"Elevation (Fire Area A-12, Zone A).Unit 3*Containment, -24'6" Elevation (Fire Area RC-1);
- Containment, -3'8" Elevation (Fire Area RC-1);
4Enclosure*Containment, 24'6" Elevation (Fire Area RC-1);*Containment , 51'4" Elevation (Fire Area RC-1);
- North EDG Enclosure, 24'6" and 37'0" Elevation (Fire Area EG-31); and
- South EDG Enclosure, 24'6" and 37'0" Elevation (Fire Area EG-4).Documents reviewed for this inspection activity are listed in the Attachment to thisreport.
b. Findings
No findings of significance were identified..2Annual Fire Drill Observation
a. Inspection Scope
(One Unit 3 sample)Unit 3The inspectors observed personnel performance during a fire brigade drill onJune 19, 2007, to evaluate the readiness of station personnel to fight fires. The drill simulated a fire in the Unit 3 'A' EDG room. The inspectors observed the fire brigade members using protective clothing, turnout gear, and self-contained breathing apparatus and entering the fire area in a controlled manner. The inspectors also observed the fire fighting equipment brought to the fire scene to evaluate whether sufficient equipment was available to effectively control and extinguish the simulated fire. The inspectors evaluated whether the permanent plant fire hose lines were capable of reaching the fire area and whether hose usage was adequately simulated. The inspectors observed the directions of the fire brigade team leader and communications between fire brigade members. The inspectors verified that the pre-planned drill scenario was followed and reviewed the post drill critique items to evaluate if the drill objectives were satisfied and that any drill weaknesses were identified.Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
No findings of significance were identified.
5Enclosure1R07Heat Sink Performance (71111.07A)
a. Inspection Scope
(One Unit 3 sample)The inspectors reviewed one sample associated with the safety-related 'C' reactor plantclosed cooling water (RPCCW) heat exchanger inspection and testing activities to identify any degraded performance or potential for common cause problems that could increase plant risk. The inspectors observed the as-found condition of the heat exchanger once it was opened to verify that any adverse fouling concerns were appropriately addressed. The inspectors reviewed the results of the inspections performed in accordance with Dominion procedures. The inspectors reviewed the inspection results against the acceptance criteria contained within the procedure to determine whether all acceptance criteria had been satisfied. The inspectors also reviewed the FSAR to ensure that heat exchanger inspection results were consistent with the design basis. The inspectors verified that adverse conditions identified by Dominion were appropriately entered into Dominion's corrective action program. Documents reviewed for this inspection activity are listed in the Attachment to thisreport.
b. Findings
No findings of significance were identified.
1R08 Inservice Inspection (71111.08)
a. Inspection Scope
(Five Unit 3 samples)The inspectors assessed the inservice inspection (ISI) activities using the criteriaspecified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. The inspectors reviewed documentation and interviewed personnel to verify that the activities were performed in accordance with the ASME requirements. The sample selection was based on the inspection procedure objectives and risk priority of those components and systems where degradation would result in a significant risk increase of core damage.During the Unit 3 RFO, 3R11, the inspectors made direct observations of portions of thefollowing procedures and examinations on code class 1 components: *Gas Tungsten Arc Welding weld overlay, pressurizer surge nozzle;*Liquid penetrant surface examination of pressurizer 'B' safety nozzle overlay; and*Visual examination of reactor vessel head bare metal, and various penetrationsincluding #61 and #21.The inspectors also reviewed the examination results and the certifications of theindividuals responsible for performing both the exams and analyzing the results. The 6EnclosureWelder Maintenance Logs documentation on the PCI contract welders was alsoreviewed. The inspectors reviewed data packages for the following examinations: *ASME Section XI, Appendix VIII Performance Demonstration Initiative ultrasonicexamination of pressurizer 'C' safety nozzle weld overlay;*Bare head visual inspection summary report;
- Reactor head penetration ultrasonic examinations, including coveragelimitations;*Ultrasonic examinations of reactor vessel inlet nozzle-to-shell welds, W23 &W31; and*Automated UT of PWR Vessel Shell Welds, W10 & W12.The inspectors confirmed that the examinations were performed in accordance withapproved procedures and that the results were reviewed and evaluated by certified Level III nondestructive examination (NDE) personnel. The inspectors interviewed staff about evaluations and repairs for weld conditions on the'B' safety nozzle including evaluations of indications identified by informational surfaceexaminations. The inspectors noted that site personnel utilized their condition report engineering dispositioning process to resolve and plan the repair scope. The inspectors reviewed one indication dispositioned as unacceptable according to theASME IWB-3514 criteria on weld MSS-30-FW-6 (Condition Report (CR)-07-03974). The indication was evaluated by the site welding engineer and subsequently reworked by grinding and blending to remove the indication. The remaining wall thickness was verified by ultrasonic testing, and the post-repair weld magnetic particle test was acceptable. The inspectors interviewed the Dominion NDE Level III staff in regards to QualityControl (QC) presence during reactor head bare metal visual examinations. The inspectors reviewed the QC observations report and discussed the results with site staff.
One observation included that Dominion site staff incorporated QC recommendations to include a subject matter expert as part of onsite staff performing visual testing examinations. For the boric acid corrosion control program (BACC), the inspectors reviewed the resultsof the first 3R11 Mode 3 walkdown visual testing. The inspectors also reviewed corrective action program CRs generated for leakages identified both during the current and previous outages. The following components leakage screenings/evaluations were reviewed: residual heat removal system (RHS)*V009, 3SIH*AV8882, 3CHS*RV835, 3SIH*RV8870 and 3RHS*RV37B. The inspectors noted that Dominion had recently developed and trained program staff on a new database program used to collect information on components with boric acid leakage. The inspectors completed a direct visual walkdown of areas of containment to assess Dominion's ability to identify sources and targets of boric acid leakage. Based on a review of boric acid leak evaluation activities from 3R11, a finding of very low safety significance was identified, as described below.
7EnclosureThe inspectors also reviewed a sample of issue reports from various NDE activities toassess Dominion's effectiveness in problem identification and resolution and determined that they are identifying ISI and NDE issues at an appropriate threshold and entering them into the corrective action program. The inspector sampled issue reports from the
3R11 and the 3R10 refueling outages, and a short duration outage from
January-February, 2007.Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
Introduction.
The inspectors identified that Dominion did not follow Boric Acid CorrosionControl program procedures. Specifically, plant personnel failed to adequately perform boric acid leak evaluations as required by Dominion procedure DNAP-1004, "Boric Acid Corrosion Control Program." This finding was of very low safety significance (Green)and determined to be a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."
Description.
Dominion procedure DNAP-1004, "Boric Acid Corrosion Control Program,"required that all identified boric acid leaks be reported in the site corrective action system. Additionally, Dominion procedure DNAP 1004, Attachment 1, "Boric Acid Corrosion Control Program Screening," provided severity threshold criteria for performing engineering evaluations of the identified boric acid leaks. The procedure specified that personnel should be trained to not disturb or remove the suspected boric acid deposit before a maintenance threshold screening is performed. The procedure also stated in Attachment 2, "Evaluation Methodology," to determine the safety significance of all the affected components. During the Unit 3 refueling outage 3R11, in several instances, evaluations were not completed, or the evaluations did not include all the required information specified by the procedure. Leak evaluation forms for components identified with boric acid leaks did not consistently include the identification of the evaluator or date the evaluation was performed; reference the CR initiated from the current outage's mode 3 walkdown; document condition trending for the leaking components; or, reference whether qualified VT-2 inspections of affected components had been performed as part of the evaluation process. Examples were:*'A' residual heat removal (RHR) system loop outboard drain 3RHS*V009. Dominion had identified and tagged it for cleaning, but had not performed an inspection of the components located underneath the leak (target components).
Subsequent to the NRC inspectors reporting a boric acid accumulation that had leaked through the grating below, Dominion cleaned the affected components without first documenting the leakage, or evaluating the components' material susceptibility to effects of the leakage.*'B' RHR suction header containment relief 3RHS*RV37B. This valve wasreplaced during the 2007 refueling outage. The removed valve was bench tested and found to be inoperable during the lift test. Work orders written in March and October of 2005 referenced boric acid leaks at the threaded nozzle joint and on the spherical bearing of an attached strut. Leakage present in the 8Enclosurephotographs for the fasteners and body of the as-found valve during the 2007refueling outage were not addressed in a CR or evaluated for prior operability concerns. *Boron recovery tank 'B' inlet header isolation, 3BRS-V846. Dominionphotographed the leakage during the 2007 refueling outage, but had not documented a CR since the 2005 refueling outage (CR-05-04388). The 2005 CR did not have an attached screening form to assess whether an evaluation was required to be performed, as required by procedure.*Reactor coolant loop '4' drain isolation, 3RCS*AV8037D (V211). Dominionphotographed boric acid on the fasteners and flange during the 2007 refueling outage, and documented CR-07-03509 as being a duplicate condition report to CR-05-11061. No further evaluation was performed based on the current leakage, which could possibly have affected the work scope planned in 2005 for
==3R11 .
Analysis.
==
The performance deficiency associated with this finding was that licenseeactivities affecting quality were not accomplished in accordance with procedure DNAP-1004, in that, in several instances, the licensee failed to perform boric acid leak evaluations as required. Dominion's corrective actions for this issue included a general area cleaning program to remove boric acid residue from target components and ensuring the BACC program includes clear documentation of evaluations for both the leaking component and any associated target component(s).This finding was more than minor because it was associated with the humanperformance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the issue did not result in exceeding the TS limit for identified RCS leakage or affect other mitigating systems resulting in a total loss of their safety function. Additionally, this finding is similar to IMC 0612, Appendix E, example 4a, in that the licensee routinely failed to perform engineering evaluations on similar issues; i.e., boric acid leaks. The performance deficiency had a cross-cutting aspect in the area of humanperformance, work practices component, because Dominion personnel did not follow procedures.
9EnclosureEnforcement. 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, andDrawings" requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, and drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Dominion procedure DNAP-1004, Attachment 1, "Boric Acid Corrosion Control Program Screening," provided threshold criteria for performing engineering evaluations on boric acid leaks; and, Attachment 2, "Evaluation Methodology" provided information to be included in the evaluation. Contrary to the above, on several occasions during April and May, 2007, Dominion failed to accomplish boric acid leak evaluations in accordance with procedure DNAP-1004. However, because this issue was determined to be of very low safety significance (Green) and has been entered into the licensee's corrective action program in condition report CR-07-04184, this violation is being treated as a NCV consistent with section VI.A.1 ofthe NRC Enforcement Policy. (NCV 05000423/2007003-01, Failure to PerformEvaluations on Boric Acid Leaks)1R11Licensed Operator Requalification Program (71111.11Q)
a. Inspection Scope
(One Unit 1 and one Unit 2 sample)The inspectors observed one simulator training scenario of a Unit 2 licensed operatorclassroom training on June 12, 2007, and one Unit 3 licensed operator simulator training on June 21, 2007. The inspectors verified that the training evaluators adequately addressed that the applicable training objectives had been achieved. Additionally, the inspectors assessed whether the simulator adequately reflected the plant's response, operator performance met Dominion's procedural requirements, and the simulator instructor's critique identified crew performance issues. Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
(Two Unit 2 samples)
The inspectors reviewed two samples of Dominion's evaluation of degraded conditions,involving safety-related SSCs for maintenance effectiveness during this inspection period. The inspectors reviewed licensee implementation of the Maintenance Rule (MR), 10 CFR 50.65, and verified that the conditions associated with the referenced CRs were appropriately evaluated against applicable MR functional failure criteria as found in licensee scoping documents and procedures. The inspectors also discussed these issues with the system engineers and MR coordinators to verify that they were appropriately tracked against each system's performance criteria and that the systems were appropriately classified in accordance with MR implementation guidance.
10EnclosureThe following conditions were reviewed:Unit 2*Service water leak from red rubber gasket joint on supply line to 'A' EDG on April19, 2007 (CR-07-01788); and*'C' charging pump repair following a failure of the pump on June 11, 2007 (CR-07-06525).Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.
b. Findings
Introduction.
A self-revealing finding was identified when Dominion did not ensure anadequate work procedure was available for maintenance performed on the Unit 2 'C' charging pump on May 5, 2007, resulting in a failure of the pump on June 11, 2007.
Specifically, the work procedure did not give specific guidance for assembly and installation of the suction poppet valve in accordance with direction provided in the vendor technical manual. On June 11, 2007, the 'C' charging pump failed and was declared inoperable due to a seized plunger shaft. This finding was of very low safety significance (Green) and determined to be an NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."Description. On June 11, 2007, with the plant operating at 100 percent power,operations personnel noted charging header flow had lowered from its normal value of 43.5 gallons per minute (gpm) to 29 gpm. Operators in the control room secured the running charging pump, declared the 'C' charging pump inoperable, and entered abnormal operating procedure (AOP) 2512, "Loss of Charging." The operators verified no leaks were occurring in containment and that the trend in pressurizer level decrease was consistent with normal reactor coolant pump seal leak-off with no charging pumps in service. The operators also performed bladder checks on the discharge pulsations dampeners for all three charging pumps to ensure gas binding was not the cause of the lowering charging flow, started the 'A' charging pump, and quarantined the 'C' charging pump. Charging header flow returned to normal and operators exited the AOP.Normal charging pump operation uses the pumping action of three plungers to increasewater pressure to 2350 psig to pump borated water in the reactor vessel, which is at 2250 psig. The three plungers are driven from a common eccentric shaft connected to a motor and work together to increase water pressure to overcome RCS pressure.
During normal plant operations there are three charging pumps available and each is capable of injecting the desired concentration of boric acid into the vessel. Dominion determined that the cause of the lowering charger header flow was that one ofthree plungers for the 'C' charging pump was bound inside the pump drive assembly shaft. Upon further investigation, during the licensee's apparent cause evaluation (ACE), it was determined that the fastener connecting the suction poppet valve to the valve body associated with this plunger had become detached and was then crushed 11Enclosureinto smaller pieces by the reciprocating action of the plunger. After several days of thefastener being broken into smaller pieces by the plunger, one of the fastener pieces had wedged itself between the plunger and the shaft of the pump drive assembly causing the plunger to become bound to the shaft. The ACE determined the cause of the fastener becoming detached from the valve body was due to inadequate maintenance performed on the pump during maintenance activities on May 5, 2007. Specifically, the work procedure did not give specific guidance for assembly and installation of the suction poppet valve in accordance with direction provided in the vendor technical manual. During the inspectors review of the event, the inspectors noted an additional contributingcause to the pump being run to failure. On June 9, 2007, operators noted an abnormal noise from the suction of the drive pump assembly. The operators noted the condition in the control room logs and contacted the system engineer. After describing the noise to the system engineer, the engineer recommended to the operators to isolate and secure the 'C' charging pump, and start one of the standby pumps. Operations personnel, however, evaluated the system performance as normal and decided to continue running the 'C' charging pump. The inspectors concluded that Dominion had missed an opportunity to secure the pump prior to the pump being run to failure. Dominion generated CR-07-06897 to document the inspectors observation.Analysis. The performance deficiency associated with this finding was that aninadequate work procedure which was approved and used during a maintenance activity on a safety-related pump, resulting in a failure of the pump. Dominion's corrective actions for this issue included repair and retest of the 'C' charging pump, revising the work procedure to include vendor recommendations and training for maintenance personnel on assembly and installation of charging pump poppet valves.The finding was more then minor because it was associated with the procedure qualityattribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the finding is not a design or qualification deficiency, does not represent the loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.This performance deficiency had a cross-cutting aspect in the area of humanperformance, resources component, because Dominion did not ensure that a complete, accurate and adequate work procedure was available for maintenance performed on a safety-related component.Enforcement. 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, andDrawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, 12Enclosureprocedures, or drawings. Contrary to the above, Dominion did not ensure an adequatework procedure was available for maintenance conducted on the 'C' charging pump on May 5, 2007. However, because the finding was of very low safety significance (Green)and has been entered into the corrective action program in condition report CR-07-06525, this violation is being treated as an NCV, consistent with section VI.A.1 of theNRC Enforcement Policy. (NCV 05000336/2007003-02, Inadequate Work Procedurefor the Unit 2 'C' Charging Pump Results in Pump Failure)
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
(Three Unit 2 and six Unit 3 samples)The inspectors reviewed nine samples of the adequacy of maintenance riskassessments for emergent and planned activities during the inspection period. The inspectors utilized the equipment-out-of-service quantitative risk assessment tool to evaluate the risk of the plant configurations and compared the results to Dominion's stated risk. The inspectors verified that Dominion entered appropriate risk categories and implemented risk management actions as necessary. The inspectors verified the conduct and adequacy of scheduled maintenance risk assessments for plant conditions affected by performance of the following maintenance and testing activities:Unit 2*Reserve station service transformer (RSST) supply line insulator replacement onApril 12, 2007; *Troubleshooting spurious generator field ground alarms on April 24, 2007; and
- Emergent risk assessment of Unit 3 loss of offsite power impact to Unit 2operation on April 25, 2007.Unit 3*3R11 cumulative shutdown risk management on April 1, 2007;*Shutdown risk assessment on April 7, 2007, and April 8, 2007;
- Reduced inventory operations on April 11, 2007;
- Emergent risk assessment during severe weather on April 15, 2007;
- Emergent risk assessment for unplanned orange shutdown risk associated withpower availability on April 25, 2007; and*Reduced inventory operations on May 1, 2007.Documents reviewed for this inspection the Attachment.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope
(Two unit 2 and three Unit 3 samples)13EnclosureThe inspectors reviewed five operability determinations associated with degraded ornon-conforming conditions to ensure that operability was justified and that mitigating systems or those affecting barrier integrity remained available and no unrecognized increase in risk had occurred. The inspectors also reviewed compensatory measures, as appropriate, to ensure that the measures, as appropriate, were in place and were appropriately controlled. The inspectors reviewed licensee performance to ensure all related TS and FSAR requirements were met. The inspectors reviewed the following degraded or non-conforming conditions:Unit 2*Degraded intake structure floor drain used for service water pipe break floodprotection (CR-07-03322); and*Evaluation of fairbanks morse engine 10 CFR 21 report 2007-10-00 (CR-07-03568).Unit 3*New inverters '2' and '4' have high frequency noise causing false counts onsource range nuclear instruments and gamma metric instrumentation (CR-07-04924);*Degraded spent fuel pool storage rack locations (CR-07-05197); and
- Degraded 'A' EDG intercooler heat exchanger (CR-07-06800).Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modifications (71111.17A)
a. Inspection Scope
(Two Unit 3 samples)The inspectors reviewed two permanent plant modifications on Unit 3. The inspectorsperformed a walkdown of the relevant areas, as appropriate, and reviewed the FSAR, licensing and design basis documents, and the engineering dispositions. These reviewswere conducted to ensure
- (1) the modified components remained consistent with the assumptions indicated in the design basis documents,
- (2) that system availability, reliability, and functional capability were maintained, and
- (3) no unrecognized conditions that were introduced as a result of the modifications. The following permanent plant modifications were reviewed:Unit 3*Charging pump alternate minimum flow modification (DCM 3-2A); and 14Enclosure*Installation of ferrite beads to dampen noise affects on source range nuclearinstruments and gamma metric instrumentation (DM3-00-0163).Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
No findings of significance were determined.
1R19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
(Three Unit 2 and six Unit 3 samples)The inspectors reviewed nine samples of post-maintenance tests (PMTs) during thisinspection period. The inspectors reviewed these activities to determine whether the PMT adequately demonstrated that the safety-related function of the equipment was satisfied given the scope of the work specified and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to verify consistency with the associated design and licensing bases, as well as TSrequirements. The inspectors also verified that conditions adverse to quality were entered into the corrective action program for resolution. The following maintenance activities and their associated PMTs were evaluated:Unit 2*'C' channel of containment pressure is erratic and unreliable (M2-07-03190);*Re-pack of the 'C' charging pump (M2-07-03275); and
- 'C' charging pump repair following pump failure (M2-07-04329).Unit 3*Packing replacement of loop stop valves 3RCS*8001A and 3RCS*8002A (M3-06-02617);*Inverter '2' and inverter '4' replacement (M3-07-06740);
- Charging pump alternate minimum flow modification (M3-05-09947);
- Valve 3SIH*V5 rework (M3-07-06253);
- 'B' service water check valve replacement (M3-05-06229); and
- Reactor internal lifting rig clamp replacement (M3-05-14215).Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
Introduction.
The inspectors identified that Dominion did not adequately evaluatesurveillance test results to ensure test acceptance criteria had been met on May 10, 2007. Specifically, the inspectors identified that the 'C' charging pump pulsation dampener surveillance test had cited incorrect data and had been accepted as satisfactorily complete, though the test data was outside of the surveillance acceptance criteria. This finding was of very low safety significance (Green) and determined to be an NCV of 10 CFR 50, Appendix B, Criterion XI, "Test Control."
Description.
On May 10, 2007, the inspectors reviewed surveillance form SP 2664-003,"Charging Pump 'C' Pulsation Dampener Test," as part of a PMT review for maintenance that had been performed on the 'C' charging pump. The inspectors noted that the acceptance criteria for the charging pump discharge pressure had not been met given the data recorded in the procedure.
Specifically, the final extrapolated pump discharge pressure was determined to be greater than the initial pulsation dampener precharge pressure, when in fact the recorded data indicated otherwise. During conduct of the surveillance, review of the surveillance results, and final approvalof the surveillance, approximately five operations personnel had accepted this data as being satisfactory. Following the observation, the inspectors notified system engineering and operations personnel of this discrepancy, and they agreed that the acceptance criteria had not been met. The surveillance was successfully re-performed on May 13, 2007.Analysis. The performance deficiency associated with this inspector identified findinginvolved an inadequate evaluation of surveillance test results to ensure test acceptance criteria had been met. Dominion's corrective actions for this issue included revising the surveillance to clarify test requirements and required reading for operations personnel on how to adequately document and review surveillance test data.The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify out of specification data could result in the failure to identify inoperable equipment. The inspectors also concluded that if the failure to properly evaluate charging pump discharge dampener test data was not corrected, a more significant concern could exist in that failure of the dampener has previously resulted in a loss of all charging due to the migration of nitrogen from a failed discharge pulsation dampener to the common suction piping for all three charging pumps (as described in NRC inspection reports 05000336/2006002 and 05000336/2006006).The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609,Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green)because the issue is not a design or qualification deficiency, does not represent the loss 16Enclosureof a system safety function or safety function of a single train, and does not screen aspotentially risk significant due to a seismic, flooding, or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of problemidentification and resolution, corrective action program component, because Dominion did not identify out of specification test data.
Enforcement.
10 CFR 50, Appendix B, Criterion XI, "Test Control," states, in part, thattest results shall be documented and evaluated to assure that test requirements have been satisfied.
Contrary to the above, Dominion failed to adequately evaluate the surveillance data so as to identify that the surveillance acceptance criteria had not been met. However, because this finding is of very low safety significance (Green) and has been entered into the licensee's corrective action program in condition report CR-07-05345, this violation is being treated as a NCV, consistent with Section VI.A.1 of theNRC Enforcement Policy. (NCV 05000336/2007003-03, Failure to AdequatelyEvaluate Surveillance Test Data)
1R20 Refueling and Outage Activities
a. Inspection Scope
(One Unit 3 sample)Dominion began the Unit 3 RFO 3R11 on April 6, 2007, and returned the unit to fullpower operation on May 22, 2007. The inspectors evaluated the outage plan and outage activities to confirm that Dominion had appropriately considered risk, had developed risk reduction and plant configuration control methods, had considered mitigation strategies in the event loss of safety functions occurred, and had adhered to license and TS requirements. The inspectors observed portions of the shutdown, cooldown, heatup, and the startup procedure processes. Additionally, the inspectors conducted an initial containment walkdown to evaluate the as-found condition of the containment to ensure no loose material or debris which could be transported to the containment sump was present. The inspectors verified that conditions adverse to quality were entered into the corrective action program for resolution. Some of the specific activities the residents observed included:*Reactor shutdown and cooldown;*Steam generator safety valve simmer testing;
- Reactor water level drain down to the reactor flange;
- Reduced inventory operations;
- RCS fill and vent;
- Pressurizer 600 weld overlays;
- Restoration of the RSST;
- Core barrel heavy load lift and heavy load analysis;
- Fuel handling, core loading, and fuel element assembly tracking;
- RCS pressure, level, and temperature instrumentation operability;
- Containment as-left walkdown;
- Mode '0' valve work;
- Reactor heatup;
- Reactor startup; 17Enclosure*Low power physics testing;*Reactor power ascension; and
- Main turbine over speed testing.Documents reviewed for this inspection activity are listed in the Attachment.b.FindingsNo findings of significance were determined.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
(Three Unit 2 and six Unit 3 samples)The inspectors reviewed nine samples of surveillance activities to determine whether thetesting adequately demonstrated equipment operational readiness and the ability to perform its intended safety-related function. The inspectors attended pre-job briefs, verified that selected prerequisites and precautions were met and that the tests were performed in accordance with the procedural steps. Additionally, the inspectors evaluated the applicable test acceptance criteria to verify consistency with associated design bases, licensing bases, and TS requirements, and that the applicable acceptance criteria were satisfied. The inspectors also verified that conditions adverse to quality were entered into the corrective action program for resolution. The following surveillance activities were evaluated:Unit 2*'A' EDG surveillance test (SP-2613K);*Containment spray system '2' containment isolation valve in-service test (IST)(SP-2606C); and*AFW system feedwater regulating valve stroke timing IST (SP-26120CO).Unit 3*'A' engineered safety feature/loss of power (LOP) surveillance test (SP-3646A.17);*'A' train LOP surveillance test (SP-3646A.15);
- Main steam valve simmer surveillance test (SP-3712G);
- Reactor coolant system cooldown surveillance test (SP-3601G.2);
- Low power physics surveillance test (SP-31008); and
- 'A' safety injection accumulator vent valve IST (SP 3610B.2).Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.
b. Findings
Introduction.
A self-revealing finding was identified when Dominion incorrectlyperformed a safety-related surveillance procedure. Specifically, Operations mistakenly performed a biennial surveillance test that verified remote vent valve position by opening a nitrogen vent path and verifying a decrease in accumulator pressure for the Unit 3 'A' safety injection (SI) accumulator in addition to the planned quarterly surveillance. As a result of performing the biennial procedure vice the planned quarterly surveillance, the
'A' SI accumulator was inadvertently depressurized to below the TS value. This finding was of very low safety significance and determined to be an NCV of TS 6.8.1, "Procedures."Description. On May 16, 2007, in Mode 3, Operations was performing section 4.11 ofprocedure SP 3610B.2, "Low Pressure Safety Injection Valve Operability Test - Train A."
The purpose of this test was to verify that the 'A' SI accumulator vent valves met the design and IST stroke time requirements. In addition to the planned quarterly surveillance, Operations mistakenly performed the biennial surveillance that verified remote vent valve position by opening a vent path and verifying a decrease in accumulator pressure. As a result, the 'A' SI accumulator was inadvertently depressurized to below the TS allowed value. Operability of the SI accumulator was restored once operations personnel isolated the accumulator vent path and re-pressurized the accumulator to within the TS allowed range. Dominion performed an ACE and determined the cause of the event was related tohuman performance. Specifically, Dominion did not conduct a pre-job brief prior to the surveillance to ensure Operations personnel clearly understood the steps involved in the test and the expected plant response. The inspectors also noted that no peer checking was used which could have provided an additional level of control. The operating crew believed the surveillance operator was planning on performing the quarterly portion of the surveillance and not the biennial remote position indication verification. Dominion also determined that the surveillance operator did not fully consider changing plant conditions following the refueling outage mode changes involved in the startup and the requirements to maintain SI accumulators operable.Analysis. The performance deficiency associated with this finding is that Dominion didnot properly implement a safety-related surveillance procedure to test the 'A' SI accumulator vent valves. Dominion's corrective actions for this issue included restoring accumulator pressure, performing an ACE to determine the underlying causes associated with the error, training the personnel involved, and scheduling human performance training for Operations during training cycle 07-03.The finding was more than minor because it was associated with the humanperformance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors conducted a Phase 1 SDP screening in accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the 19Enclosureissue is not a design or qualification deficiency, does not represent the loss of a systemsafety function or safety function of a single train, and does not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This performance deficiency had a cross-cutting aspect in the area of humanperformance, work practice component, because Dominion's human error prevention techniques such as holding a pre-job brief and peer checking were not used to ensure that a surveillance was properly performed.Enforcement. TS 6.8.1, "Procedures," requires, in part, that written procedures beimplemented covering surveillance activities on safety-related equipment. Contrary to the above, on May 16, 2007, Dominion incorrectly implemented surveillance procedure SP 3610B.2, Revision 013-08, "Low Pressure Safety Injection Valve Operability Testing
- Train A," Section 4.11, "Quarterly Stroke Time Test of 3SIL*SV8875A-H." As a result, the 'A' SI accumulator was inadvertently depressurized to below the TS 3.5.1, "Accumulators," allowed value of 636 psia for approximately 27 minutes until the required pressure was restored. However, because this finding was of very low safety significance (Green) and was entered into Dominion's corrective action program in condition report CR-07-05596, this violation is being treated as an NCV, consistent withsection VI.A.1 of the NRC Enforcement Policy. (NCV 05000423/2007003-04, Failure toImplement Safety-Related Surveillance Procedure Resulted in 'A' Safety Injection Accumulator Inoperability)1R23Temporary Plant Modifications (71111.23)
a. Inspection Scope
(One Unit 3 sample)The inspectors reviewed one sample of a temporary modification involving temporarypower being available during inverter '2' and '4' replacement for Unit 3. The inspectors verified that the modification did not adversely affect the function of the safety system.
The inspectors reviewed this temporary modification and its associated 10 CFR 50.59 screening against the FSAR and TS to ensure the modification did not adversely affect the system operability or availability. Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
No findings of significance were identified.
20EnclosureCornerstone: Emergency Preparedness [EP]1EP6Drill Evaluation (71114.06)
a. Inspection Scope
(One Unit 2 and one Unit 3 sample)The inspectors observed a Unit 2 licensed operator training emergency planning drill onJune 12, 2007, and a Unit 3 licensed operator training emergency planning drill on June 21, 2007. The inspectors observed the operating crews performance at the simulator and emergency response organization performance at the site emergency operations center and technical support center. The inspectors verified that the classification, notification and protective action recommendations were accurate and timely. Additionally, the inspectors assessed the ability of Dominion's evaluators to adequately address operator performance deficiencies identified during the exercise. Documents reviewed for this inspection activity are listed in Attachment.
b. Findings
No findings of significance were identified.2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Control to Radiologically Significance Areas (71121.01)
a. Inspection Scope
(Eleven Site Samples)During the period April 23-26, 2007, the inspector conducted the following activities toverify that Dominion was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas and other radiologically controlled areas, and that workers were adhering to these controls when working in these areas during the Unit 3 refueling outage and during power operations at Unit 2.
Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, Unit 2 and Unit 3 TS, and Dominion's procedures. This inspection activity represents completion of eleven
- (11) samples relative to this inspection area.Plant Walkdown and Radiation Work Permit (RWP) Reviews*During the Unit 3 refueling outage, the inspector identified exposure significantwork areas in the Unit 3 containment building. The inspector reviewed radiation survey maps and RWPs associated with these areas to determine if the radiological controls were acceptable. Work areas included the refueling canal, pressurizer cubicle, D-steam generator cubicle, and containment sump area. *The inspector performed independent surveys of selected areas in the Unit 3containment building, auxiliary building, and engineered safeguards building to 21Enclosureconfirm the accuracy of survey maps, the adequacy of postings, and that TSlocked high radiation areas (LHRA) and very high radiation areas (VHRA) were properly secured and posted. Areas in containment surveyed included; the seal table, steam generator cubicles, pressurizer spray/relief lines, reactor cavity drain line, and locked gates to the regenerative heat exchanger room. Additionally, surveys were performed in Unit 2, including the auxiliary building, radwastestorage building, and fuel storage building.*In evaluating RWPs, the inspector reviewed electronic dose/dose rate alarmsetpoints, and alarm reports, to determine if the setpoints were consistent with survey indications and plant policy. The inspector verified that workers were knowledgeable of the actions to be taken when a dosimeter alarms or malfunctions for tasks being conducted under selected RWPs. Work activities reviewed included core barrel lift for an ISI (RWP 304/3), removing internals from steam generator cross-over valve 3RCS*MV 8003D (RWP 354/1), pressurizer relief line welding (RWP 400/1) and management tours (RWP 219/2).*The inspector reviewed Personnel Contamination Reports (PCR) and theassociated dose assessments. The inspector determined that no contamination resulted in an internal dose exceeding 10 mrem.Jobs-In-Progress Review*The inspectors observed the preparations and various work stages for severaltasks including raising the core barrel to perform ISI, removal of the internals for steam generator cross over valve 8003D and pressurizer relief line weld overlay.
The inspectors attended the pre-job briefing for the core barrel lift (Work Order 9510526) and for removal of the 8003D valve internals (Work Order 05-14584)to determine that radiological controls were adequately communicated to the workers.*The inspectors determined that additional dosimetry and area monitoring wasimplemented for dose significant jobs including issuing extremity dosimetry to personnel for removing the internals for valve 8003D, due to significant dose gradients, and installing teledosimetry instrumentation to monitor dose fields during the core barrel lift. High Risk Significant, High Dose Rate, and VHRA Controls*The inspector reviewed the preparations made for various potentially high doserate jobs including the initial removal of the core barrel from the reactor vessel, reactor head inspections and steam generator eddy current testing (ECT). On April 23, 2007, the inspector attended the pre-job briefing for raising the core barrel for performing in-service inspections, reviewed the associated RWP (No.
304/3), and Work Order (No. 9510526), and observed the activity through the use of a video monitoring system.
22Enclosure*The inspector inventoried keys to VHRAs and TS LHRAs stored at the Unit 3Control Point and in the Control Room to verify that all keys were accounted for.
During tours of Unit 2, the inspector verified that all keys to locked high radiation areas were accounted for at the control point.*The inspector verified that Unit 3 VHRAs, such as the under vessel hatchwayand the incore instrument area, were properly secured and posted and that surrounding area dose rates and postings met regulatory criteria.Radiation Worker and Radiation Protection Technician Performance*Several radiologically related CRs were reviewed to evaluate if the incidentsresulted from repetitive worker errors and to determine if an observable pattern traced to a similar cause was evident. *Radiation Protection technicians and radworkers were questioned regarding theirknowledge of plant radiological conditions and associated controls.Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
No findings of significance were identified. 2OS2ALARA Planning and Controls (71121.02)
a. Inspection Scope
(Seven Unit 3 samples)During the period April 23 - 26, 2007, the inspector conducted the following activities toverify that Dominion was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as reasonably achievable(ALARA) for tasks conducted during the Unit 3 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Dominion's procedures. This inspection activity represents completion of seven
- (7) samples relative to this inspection area. Radiological Work PlanningThe inspector reviewed pertinent information regarding Unit 3 outage exposure history,current exposure trends, and ongoing activities to assess current performance and outage exposure challenges. The inspector determined the site's 3-year rolling collective average exposure and compared it to current trends. The inspector reviewed the refueling outage work scheduled during the inspectionperiod and the associated work activity exposure estimates. Scheduled work included; reactor head inspections, core barrel ISI, pressurizer relief line weld repair, steam generator internal inspections, containment sump modification, valve repairs, and 23Enclosurevarious 10 year in-service inspections. The inspector compared the current actual doseaccrued for these activities with the initial exposure estimates.Additionally, the inspector reviewed the ALARA Reviews, Work-In-Progress ALARAReviews, ALARA Challenge Board presentations, and ALARA pre-job briefing materials that addressed estimating and controlling dose for other outage activities. Jobs reviewed included: fuel removal, insulation removal, scaffolding installation, reactor disassembly, steam generator eddy current testing, and steam generator secondary side inspections. The inspector evaluated the effectiveness of exposure mitigation requirements specifiedin RWPs and associated ALARA reviews. Jobs reviewed include reactor vessel disassembly (RWP 301/302/303, AR 3-07-01), steam generator eddy current testing (RWP 306, AR 3-07-02), motor-operated valve maintenance (RWP 354, AR 3-07-11),
and scaffolding installation (RWP 231/331, AR 3-07-13).The inspector evaluated the departmental interfaces between radiation protection,operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by reviewing recent ALARA Council meeting minutes and ALARA Challenge Board presentations.
The inspector also attended two pre-job briefings, a daily Plan-of-the-Day meeting, and a daily management outage status meeting to assess interdepartmental coordination. Through job site observations and radiation survey measurements, the inspectordetermined if work activity planning included the use of temporary shielding, system flushes, and operational considerations; i.e., scheduling work when steam generators were filled, to further minimize worker exposure. The inspector reviewed temporary shielding requests and performed independent measurements on various system components including: the pressurizer relief lines, reactor vessel level indication system, containment sump modification area, and various reactor building and auxiliary building work areas to determine if temporary shielding was appropriately used. Verification of Dose Estimates and Exposure Tracking SystemsThe inspector reviewed the assumptions and basis for the annual site collectiveexposure and the Unit 3 refueling outage dose projection.The inspector reviewed Dominion's method for adjusting exposure estimates, andre-planning of work when actual dose approached estimated dose. The inspector reviewed ALARA Council meeting minutes regarding expanding the scope of valve inspections/repairs following a boric acid walkdown that would require allocating additional dose to the BACC project.The inspector reviewed Dominion's exposure tracking system to determine whether thelevel of dose tracking detail, exposure report timeliness, and distribution was sufficient to support the control of outage project exposures. Included in this review were departmental dose compilations and individual dose records.
24EnclosureJob Site Inspection and ALARA ControlsThe inspector observed maintenance activities being performed in containment,including sump modification, pressurizer relief line welding, core barrel lift, and 8003D valve repairs. The inspector verified that the appropriate radiological controls were implemented, including: pre-job briefings, radiation protection technician coverage, contamination mitigation, proper dosimetry, and that workers were knowledgeable of radiological conditions. Source Term Reduction and ControlThe inspector reviewed the current status and historical trends of the Unit 3 source term.Through interviews with the Radiation Protection and Chemistry Manager and the ALARA Supervisor, the inspector evaluated Dominion's source term measurements and control strategies. The inspector reviewed reactor coolant chemistry data to evaluate the effectiveness of post-shutdown source term reduction efforts. Specific strategies being employed included filtration, system flushes, installation of temporary shielding, and chemistry controls. Radiation Worker PerformanceThe inspector observed radiation worker and radiation protection technicianperformance for selected tasks. Tasks observed included: core barrel lift for performing in-service testing, replacing internals in 3RCS*MV8003D, containment sump modifications, pressurizer relief line weld repair, and steam generator secondary side inspections. The inspector determined that the individuals were aware of radiological conditions and access controls that applied to their tasks. The inspector reviewed condition reports related to radiation worker and radiationprotection technician errors and PCR to determine if an observable pattern traceable to a common cause was evident. Declared Pregnant WorkersThe inspector determined that no declared pregnant workers were employed to performoutage related activities in the radiologically controlled areas.Problem Identification and ResolutionThe inspector reviewed elements of Dominion's corrective action program related toimplementing the radiological controls program to determine if problems were being entered into the program for resolution. Details of this review are contained in Section
4OA2 of this report. Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
25EnclosureNo findings of significance were identified.
OTHER ACTIVITIES
[OA]4OA1Performance Indicator (PI) Verification (71151)
a. Inspection Scope
(Two Unit 2 samples)Cornerstone: Barrier IntegrityThe inspectors reviewed two samples of Dominion's program to gather, evaluate, andreport information on the two PIs associated with the Barrier Integrity cornerstone of the reactor safety strategic performance area. The inspectors used the guidance provided in the Nuclear Energy Institute 99-02, Revision 4 "Regulatory Assessment Indicator Guideline," to assess the accuracy of Dominion's reporting of the PI data. The inspectors reviewed Dominion's monthly operating reports, operations logs, NRC inspection reports, and any associated corrective action program condition reports. The inspectors verified the accuracy and completeness of the reported data for the following PIs:*"Reactor coolant system specific activity" between January 1, 2006, andMarch 31, 2007; and,*"Reactor coolant system leak rate" between January 1, 2006, andMarch 31, 2007.Documents reviewed for this inspection activity are listed in the Attachment.b.FindingsNo findings of significance were identified.4OA2Identification and Resolution of Problems (71152).1Review of Items Entered into the Corrective Action ProgramAs required by Inspection Procedure 71152, "Identification and Resolution of Problems,"and in order to identify repetitive equipment failures or specific human performance issues for followup, the inspectors performed a daily screening of items entered into Dominion's corrective action program. This was accomplished by reviewing the description of each new CR and attending daily management review committee meetings. Documents reviewed for this inspection activity are listed in the Attachment..2Semi-Annual Review to Identify Trends
a. Inspection Scope
(One Site Sample)The inspectors performed a semi-annual review including Dominion's corrective actionprogram documents to identify trends that could indicate the existence of a more 26Enclosuresignificant safety issue. The review also included Unit 2 and Unit 3 PI monthly reports,CRs, system health reports, plant health reports, quality assurance audits, self-assessment reports, and NRC inspection reports. The inspectors review was focused on repetitive equipment problems, human performance issues, and program implementation issues. The results of the trend review by the inspectors were compared with the results of normal baseline inspections. The inspectors review considered a six-month period of January 2007 through June 2007. Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings and Observations
The inspectors did not identify trends that indicated the existence of a more significantsafety issue. The inspectors have observed less than adequate implementation of standards for human error prevention techniques, procedural compliance, and procedural adequacy during their inspection activities and have documented several findings in these areas in the first two quarters of 2007. The inspectors also noted that Dominion identified, in June 2007, an extensive backlog (approximately 700 CRs) of elective corrective action program condition reports. Dominion acknowledged the inspectors concerns and stated they were in the process of developing a plan to correct the backlog in the corrective action program.The resident inspectors noted in the 4 th quarter 2006 NRC integrated inspection report(IR 05000336/2006005 and IR 05000423/2006005) that there appeared to be an adverse trend in the number of scaffolding deficiencies. No adverse conditions relative to scaffolding were identified during this inspection period (See Section 4OA2.3.a for additional information)..3Annual Sample Review (Three Unit 2 Samples) Adverse Trend in Scaffold Installations Affecting Equipment
a. Inspection Scope
The inspectors reviewed the licensee's actions relative to an adverse trend with respectto scaffold construction, as noted in the 4 th quarter 2006 integrated inspection report. That report documented a self-revealing NCV for scaffolding that prevented a Unit 2 main steam isolation valve (MSIV) from closing during surveillance testing. The report also contained a licensee-identified violation for scaffolding constructed on top of the safety-related high energy line break (HELB) blowout panel for the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump room.During this inspection period, the inspectors performed a focused PI&R sample on thecorrective actions that the licensee has taken to prevent recurrence. The inspectors reviewed the procedures used for the installation and removal of scaffolds, a sample of work orders for existing scaffolds, the licensee event reports (LERs) associated with the two specific issues described above and all of the associated scaffolding CRs initiated since January 1, 2007. The inspectors interviewed personnel associated with the scaffold process, and conducted a walk-down of both units to inspect a sample of the 27Enclosurescaffolds in-place around safety-related components. Documents reviewed for thisinspection activity are listed in the Supplemental Information attachment to this report.
b. Findings and Observations
No findings of significance were identified. The inspectors noted that Dominion hasincorporated into procedure MP-20-WP-GDL20, Attachment 15, "Scaffolding," detailed instructions and cautions with respect to the construction of scaffolding near equipment.
15.1, "Scaffold Evaluation," of the same procedure had a checklist for use by the scaffold planner and the operations/engineering departments for pre-installation and post-installation walkdowns of the area. In addition, the scaffolds are re-inspected by the lead scaffold individual at least quarterly. The inspectors did note that there were a large number of scaffolds that had beenin-place for an extended period of time. At least thirty of the scaffolds in the plant during this inspection were greater that two years old; at least half of those were greater than five years old and one was in place for over ten years. The inspectors determined that none of the scaffolds affected the nearby equipment.Unit 2 Partial Loss of Instrument Air Root Cause
a. Inspection Scope
Based on a plant specific risk assessment and resident inspector input, the inspectorsselected CR-06-01796, "Reactor Trip due to Instrument Air Loss," as a PI&R sample for a detailed follow-up review. On February 23, 2006, Millstone Unit 2 reactor was manually tripped due to a transient caused by a partial loss of instrument air. At the time, a minor maintenance activity was in-progress to replace a pipe support clamp on a two-inch copper instrument air header pipe, when a nearby 1/2 inch air pipe separated from the header. The loss of air pressure resulted in a steam generator feed pump trip and subsequent manual trip of the reactor. This CR documented Dominion's root cause evaluation and corrective actions for a reactor trip due to a loss of instrument air.The inspectors assessed Dominion's problem identification threshold, cause analyses,extent of condition reviews, compensatory actions, and the prioritization and timeliness of Dominion's corrective actions to determine whether Dominion was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that Dominion'soverall response to the issue was comprehensive and timely. The inspectors noted that Dominion's evaluation and follow-up corrective actions were partially implemented by a significance level-1 CR and root cause evaluation completed March 29, 2006, and 28Enclosurepartially implemented by a lower level MR functional failure (a)(1) evaluation, completedMay 8, 2006.The inspectors identified several weaknesses in Dominion's root cause evaluation thatappeared to have been adequately addressed by the subsequent lower level MR evaluation. Root cause evaluation weaknesses included:
- Focused on performance of maintenance activity and copper pipe joint failure;*Did not identify any previous Millstone Unit 2 internal operating experience; and
- Concluded that no effective action could be taken to identify other susceptiblecopper air pipe joints.In contrast, the lower level MR (a)(1) evaluation identified:
- Cause of the reactor trip was an improperly evaluated/engineered 1982 designchange (old design issue) that added excess flow check valves into the air headers;*Significant previous Millstone Unit 2 operating experience on instrument air jointfailures, including 2 previous reactor trips, between 1976 and 1982, caused by similar air pipe joint failures; and*Identified risk informed approach to mitigate future failures, by reworking jointsassociated with reactor trip sensitive air loads.The inspectors determined that several weaknesses existed with regards to thecorrective actions associated with the root cause evaluation. However, because the MR (a)(1) evaluation was comprehensive and timely, the inspectors concluded that the overall corrective actions were adequate and addressed the issue.
29EnclosureUnit 2 - Multiple Unplanned LCO 3.0.3 Entries in 2006
a. Inspection Scope
The inspectors reviewed Dominion's actions in response to multiple unplanned entriesinto Limiting Condition for Operation (LCO) 3.0.3 during 2006. Entry into LCO 3.0.3 should be a rare occasion since the entry is typically based on a loss of function of a safety-related SSC in which the specific system's TS action statement do not contain requirements. The inspectors reviewed the LCO 3.0.3 entries to determine if the entries were appropriate and if the entries shared a common root cause. In addition, the inspectors reviewed how Dominion's corrective action process addressed each issue.
The inspectors interviewed responsible system engineers and operators.Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified. The inspectors reviewed four cases during2006 for which LCO 3.0.3 was entered. In each case, the LCO 3.0.3 entry was appropriate. However, the inspectors identified that improvements could be made to the process for reviewing reference documents when design changes are made. In two of the four cases, incomplete documentation of a design change was cited as the cause of the condition leading to the LCO 3.0.3 entry..4ALARA Planning and Controls
a. Inspection Scope
(One Unit 3 sample)The inspector reviewed 10 condition reports, 2 radiation protection departmentself-assessments, 5 Nuclear Oversight field observation reports, and a 3R11 ALARA Behaviors summary report, relating to keeping personnel exposure ALARA during the Unit 3 refueling outage, to evaluate the threshold for identifying, evaluating, and resolving radiological control problems. This review was conducted against the criteria contained in 10 CFR 20, TS, and Dominion's procedures. Additional documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.b.Findings and ObservationsNo findings of significance were identified.
30Enclosure4OA3Event Followup (71153) (10 samples).1Unit 3 Unidentified RCS Leakage
a. Inspection Scope
On April 1, 2007, Operations identified that the threshold of unidentified RCS leakagehad exceeded the values specified in a NRC confirmatory action letter (CAL) issued on March 27, 2007. The CAL required Dominion to evaluate unidentified RCS leakage above certain thresholds and to determine whether the leakage was potentially from the pressurizer. If Dominion could not determine that the leakage was not from the pressurizer within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, then a reactor plant shutdown would be required. On April 3, 2007, operations and engineering department personnel determined that the RCS leakage was not from the pressurizer. The inspectors reviewed Dominion's evaluation and agreed with the conclusion.Documents reviewed for this inspection activity are listed in the Attachment.b.FindingsNo findings of significance were identified..2Unit 3 Notice of Unusual Event - Loss of Normal Power in Mode 0
a. Inspection Scope
On April 25, 2007, at 10:47 a.m., with the reactor de-fueled in Mode 0, the stationresponded to a loss of offsite power event at Millstone Unit 3. The event was caused by a CONVEX (Connecticut Valley Electrical Exchange) switching error resulting in disconnecting offsite power from Millstone Unit 3. Operations entered Emergency Operating Procedure (EOP) 3501, "Loss of all AC Power (Mode 5,6, and Zero)," and EOP 3505, "Loss of Shutdown Cooling and/or RCS Inventory." Operations verified that the 'A' EDG automatically started and operated as designed. Operations then took manual action to start the 'A' spent fuel pool cooling pump from the 'A' EDG powered vital bus. At 11:01 a.m., the Shift Manager classified the event as an Unusual Event, based on off-site power not being available within 15 minutes and the 'A' vital bus powered from the 'A' EDG. The station terminated the Unusual Event declaration after the electrical lineup was restored to a stable lineup following restoration of offsite power.
The inspectors responded to the control room and evaluated the adequacy of operator actions and Unusual Event declaration. The inspectors assessed the station's emergency response performance from the control room and in the field. In addition, the inspectors performed walkdowns in the service water intake structure, auxiliary building, and spent fuel pool building to verify vital equipment was operating properly.Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
No findings of significance were identified.
.3 Discovery of RCS Valve Packing Gland Follower Degradation
a. Inspection Scope
On May 11, 2007, Dominion identified that RCS valve V185, the pressurizer leveltransmitter 459 isolation, exhibited boric acid corrosion of the packing gland follower.
Dominion conducted an extent of condition review and identified an additional RCS valve, V184, the pressurizer level transmitter 460 isolation, also exhibited boric acid corrosion of the packing gland follower. The inspectors reviewed Dominion's corrective actions for the specific degraded valves and reviewed Dominion's BACC program since the condition of these valves had not been discovered as part of the BACC program discovery phase. Dominion replaced the packing gland follower on V184 and V185 with an equivalent design component. On May 15, 2007, the inspectors and Region I staff discussed the BACC program withDominion personnel given that the Dominion BACC had not identified the RCS valve degradation earlier in the outage during the discovery phase. The inspectors noted that the Dominion BACC program had identified, evaluated, and corrected a significant population of boric acid issues during the outage. However, the inspectors also noted that a more systematic approach in conducting the discovery phase of the BACC program (e.g., a detailed review of recent maintenance on RCS valves in containment)could have led to the identification of the condition of V184 and V185 during the BACC discovery phase. The inspectors verified that the need to enhance the BACC program was being tracked as a Site Vice President Level 1 issue.Documents reviewed for this inspection activity are listed in the Attachment.
b. Findings
No findings of significance were identified..4(Closed) LER 05000336/2006006-00 & LER 05000336/2006006-01, Scaffolding Built forWork on Main Steam Isolation Valve (2-MS-64A) Prevented the Valve from Closing.On October 7, 2006, with the plant in Mode 3, scaffolding prevented the '1' MSIV fromfully closing during surveillance testing. The scaffold interference was removed within an hour of discovery. The scaffold was built on August 25, 2006, when the unit was in Mode 1, to support planned maintenance during the refueling outage which started on October 6, 2006. The MSIVs are required to close automatically upon receipt of a main steam isolation signal, to prevent blow-down of the steam generators during a steam line break downstream of the MSIVs. The valves are closed manually in the event of a steam generator tube rupture.
32EnclosureThe issue was documented in NRC Inspection Report 05000336/2006005 as aself-revealing NCV. The inspectors determined that the corrective actions taken by Dominion to prevent recurrence appeared adequate. The original LER, and the subsequent revision, were reviewed and no additional findings were identified. These LERs are closed..5(Closed) LER 05000336/2006008-00, Scaffold Impairment of Turbine Driven Auxiliary Feedwater (TDAFW) Pump Room HELB Blowout Panel.On December 21, 2006, with the plant in Mode 1 at 100 percent power, the licenseeidentified that scaffolding was erected on top of the HELB blow-out panel for the TDAFW pump room. The scaffolding had been constructed on December 11, 2006.
The scaffolding would have restricted the ability of the blow-out panel to perform the safety function of lifting in the event of a HELB event and the failure to lift could have resulted in the breaching of the wall separating the TDAFW pump room from the motor driven auxiliary feedwater pump room. The scaffolding was removed approximately four hours later, returning all of the AFW pumps to an operable status.The issue was documented in NRC Inspection Report 05000336/2006005, as alicensee-identified NCV. The inspectors determined that the corrective actions taken by Dominion to prevent recurrence appeared adequate. The LER was reviewed and no additional findings were identified. This LER is closed..6(Closed) LER 05000423/2007001-00, Failure of Two Main Steam Safety Valves to Liftwithin the Acceptance Criteria.On April 5, 2007, with the plant in Mode 1 and 100 percent power, two main steamsafety valves (MSSVs) failed to lift within the (+/- 3 percent) acceptance criteria during a planned test. Specifically, MSSV 3MSS*RB22B lifted at 1221.3 psig (1.3 psig above the allowable limit, approximately 3.1 percent), and MSSV 3MSS*RB22D lifted at 1232.8 psig (12.8 psig above the allowable limit, approximately 3.8 percent). Dominion attributed the failure of the MSSVs to lift within the required pressure range was due to a corrosive oxide locking action between the surface layer materials of the disc-seat interface. The inspectors reviewed this LER and associated CR to verify that Dominion's causal analysis and corrective actions were adequate. No findings of significance were identified. This LER is closed..7(Closed) LER 05000423/2007002-00, Loss of Offsite Power Caused by TransmissionSystem Operator while Defueled.On April 25, 2007, with the plant shutdown and defueled, a loss of offsite poweroccurred due to an offsite transmission system operator switching error. Specifically, the station 345 KV ring bus breaker 15G-13T-2 was inadvertently opened instead of the planned 15G-15T-2 breaker during a evolution intended to remove an offsite line from service. The inspectors reviewed this LER and associated condition report to verify that Dominion's causal analysis and corrective actions were adequate.
33EnclosureThe inspector determined that no violations of regulatory requirements occurred. ThisLER is closed..8(Closed) Unresolved Item (URI)05000336/2006010-01, NRC to Review Considerationof EDG Frequency Affects on Design Bases Calculations.The inspectors reviewed the URI documented in Inspection Report05000336/20060010. The URI was opened to assess if the minimum EDG frequency, as specified in the Unit 2 TS, should be accounted for in the minimum pump flow and head test acceptance criteria for pumps that could potentially be powered from this electric source. The inspection team noted that at reduced EDG output frequencies, the pump motor rotation speed is reduced. This would result in a lower developed pump flow and head.
The inspectors found that the licensee's TS acceptance criteria for EDG frequency was60 hz +/- 1.2 hz. The inspectors determined that this acceptance criteria is verified on a 18 month bases during surveillance testing when the EDG is operated in isochronous mode. The inspectors also reviewed the EDG operating procedure and found the operating procedure requires that operators adjust EDG frequency to 60 hz when in isochronous operation. Additionally, the inspectors found that when the EDG receives an auto start signal, a digital 60 hz signal is sent to the governor control circuit regardless of the status of the EDG or the manual speed setting. Finally, the ability of the operators to adjust EDG frequency above 60 hz is tested quarterly via synchronizing procedures with the grid. The inspector concluded that the ability of operators to control EDG frequency and maintain it at 60 hz is proceduralized, tested, and easily accomplished.The inspector also reviewed the testing requirements and supporting designdocumentation for the Unit 2 service water pump. This pump was selected by the Component Design Basis Inspection team and the associated flow and head test acceptance criteria was the basis for the URI. The inspector found that the test acceptance criteria had sufficient margin (over 7 percent) to account for potential inaccuracies in the service water system computer modeling. These errors could include pump flow and head inputs. Additionally, the inspector determined that the licensee monitors the model via actual flow and head measurements. The results confirm that the model is more accurate than the 7 percent assumed error. The inspectors determined that no violations of regulatory requirements occurred. ThisURI is closed.
.9 (Closed) URI 05000336/2006010-02,
NRC to Review Licensee Evaluation of Removalof Check Valve CS-26 Internals.The URI was opened to evaluate if the current licensing basis would require that theinternals of CS-26 be removed in order to reduce the overall risk to the Unit 2 Core Damage Frequency and to review Dominion's evaluation of the need to keep the internals in the valve.
34EnclosureThe check valve is in the flow path of the minimum flow recirculation line for bothdivisions of Unit 2's containment spray pumps, high pressure safety injection pumps and low pressure safety injection pumps. Should the valve fail to open, when required, it would represent a potential common cause failure mechanism for all the pumps. The inspector concluded that the failure of a check valve to open would be considered a passive failure. The plant's licensing basis does not require that passive failures be considered until the recirculation phase of an accident. Because this check valve is not needed during this phase of an accident, a failure is not considered as part of the design basis. The inspector noted that the valve is verified operable during several quarterly pumpsurveillance tests. Additionally, the inspector reviewed the inspection Dominion performed on the internals of the check valve in October 2006 and verified the valve was working properly. This inspection is performed every 18 months. Finally, the inspector verified Dominion had entered the issue into their corrective action program in CR-06-05010 and had completed an evaluation of the need for the check valve in the system. The inspector found that Dominion had concluded that the valve internals could be removed and has preliminarily scheduled the work associated with the removal for the next refueling outage. The inspector determined that no violations of regulatory requirements occurred. ThisURI is closed..10(Closed) URI 05000336/2007002-01, Maintenance Rule (a)(1) Evaluation of Unit 2 VitalSwitchgear Emergency Cooling Failure.This URI was opened to reviewed Dominion's MR (a)(1) evaluation for the vitalswitchgear cooling system following the determination that air conditioning (A/C) unit A/C-3 B51 and A/C-4 B61 had an insufficient refrigerant charge as documented in corrective action program CR-06-01138 dated November 21, 2006. In accordance with MP-24-MR-FAP710, "Maintenance Rule Functional Failures and Evaluations," the evaluation concluded that there was no functional failure because the failures were considered design deficiencies that could not have been prevented by post modification testing or predictive maintenance. The inspectors conducted additional interviews with Dominion staff to better understand controls on the implementation of design changes into maintenance procedures and practices. The inspectors concluded that the air conditioner design requirements were properly incorporated into station procedures and that the issue was properly classified in Dominions maintenance rule program. The inspectors determined that no violations of regulatory requirements occurred. ThisURI is closed.
35Enclosure4OA5Other Activities.1Temporary Instruction (TI) 2515/166 - Pressurized Water Reactor Containment SumpBlockage
a. Inspection Scope
The inspectors performed the inspection in accordance with TI 2515/166. The TI wasdeveloped to support the NRC review of licensee activities in response to NRC Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors (PWR)." Specifically, the inspectors verified the implementation of the modifications and procedure changes were consistent with the proposed actions committed to in the GL response. The inspectors reviewed a sample of the licensing and design documents to verify that they were either updated or in the process of being updated to reflect the modifications. A sample of material specifications, testing and surveillance procedures, and calculations were reviewed to verify that they were updated to reflect the effects of the modification, and the new requirements for the containment sumps and debris generation sources. The inspectors performed a walkdown of the strainer installation to verify it was performed in accordance with the approved design change package. Finally, the inspectors verified that all choke-points were accounted for by the licensee's calculations that could prevent water from reaching the recirculation sump during a design basis accident.
b.Evaluation of Inspection Requirements
- The TI requires the inspectors to evaluate and answer the following questions:
1.Did the licensee implement the plant modifications and procedure changescommitted to in their GL 2004-02 response?The inspectors verified that actions implemented by the licensee as described inresponse to GL 2004-02 were complete as it related to the installation of the sump screen and evaluation of potential debris sources. Additionally, the inspectors found that procedures to programmatically control potential debris generation sources were updated. The inspectors noted that the sump surface area that was installed had a smaller surface area than was discussed in the GL response; however, updated calculations supported the smaller size. Dominion intends to update the Millstone Unit 3 GL 2004-02 response to reflect these changes. The inspectors noted that Dominion had not completed downstream effects evaluation or the effects of chemical precipitants on the strainer head loss at the time of the inspection. 2.Has the licensee updated its licensing basis to reflect the corrective actionstaken in response to GL 2004-02? The inspectors verified that changes to the facility or procedures, as described inthe FSAR, that were identified in the licensee's GL 2004-02 response were reviewed and documented in accordance with 10 CFR 50.59 and the licensee 36Enclosurehad obtained NRC approval prior to implementing those changes that requiresuch approval as stated in 10 CFR 50.59. Dominion had submitted and received permission to change the recirculation pump start signal via licensee amendment number 233. Although this action was not mentioned in the GL response, it was needed to ensure sufficient net positive suction head was available for the recirculation system. Additionally, the inspectors noted that Dominion had submitted a TS amendment to change the inspection surveillance required by TS 4.5.2. The amendment was under review by the NRC at the time of the inspection. Finally, the inspectors verified that Dominion intends to update the Millstone Unit 3 licensing bases to reflect the final modification and associated procedure changes taken in response to GL 2004-02.The TI will remain open to allow for the review of portions of the GL response that havenot been completed. Specifically, Dominion had not completed their downstream effects analysis or chemical precipitant analysis. The results of these analyses have the potential to impact the final size of the strainer, licensing basis and programmatic procedures. Therefore, the inspection will be considered incomplete until the results are reviewed and accepted. Dominion plans to evaluate the strainer for adequacy once the test results that quantify the head loss are known. The NRC has set a December 2007 deadline, as specified in GL 2004-02, for the completion of these evaluations.
c. Findings
No findings of significance were identified.4OA6Meetings, Including ExitOccupational Radiation Safety Exit Meeting SummaryOn April 26, 2007, the inspector presented the overall inspection results toMr. Alan Price, Site Vice President, and other members of his staff, who acknowledged the findings. The inspector asked Dominion whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.Inservice Inspection Exit Meeting SummaryOn April 26, 2007, the inspectors presented the overall inspection results toMr. Alan Price, Site Vice President, and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary information reviewed during the inspection period was returned to Dominion.
37AttachmentDeputy Regional Administrator Site VisitOn June 25, 2007, a site visit was conducted by Mr. Marc L. Dapas, Deputy RegionalAdministrator for the NRC Region I office. During Mr. Dapas' visit, he toured the plant and met with Dominion managers.Integrated Report Exit Meeting SummaryOn July 10, 2007, the inspectors presented their overall findings to members ofDominion's management led by Mr. Alan Price, Site Vice President, and other members of his staff who acknowledged the findings. Two separate updates to the inspection results were presented to Mr. D. Dodson by telephone on July 19, 2007, and later on July 27, 2007. The inspectors confirmed that proprietary information reviewed during the inspection period was returned to Dominion.ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- G. Allen - Plant Equipment OperatorJ. Armstrong, Fire Protection Supervisor
- M. Bain, Shift Manger
- R. Bracall, Manager, Nuclear Maintenance
- C. Chapin, Shift Manager
- G. Closius, Licensing Engineer
- D. Delcore, Supervisor, Health Physics Operations
- C. Dempsey, Assistant Plant Manager
- D. Dodson, Supervisor, Licensing
- M. Gagnon, Plant Equipment Operator
- R. Griffin, Director, Nuclear Station Safety & Licensing
- P. Grossman, Manager, Nuclear Engineering
- A. Jordan, Plant Manager
- K. Kirkman, Operations
- E. Laine, Manager, Radiological Protection & Chemistry
- R. MacManus, Director - Nuclear Engineering
- T. Moore, Service Water Systems Engineer
- F. Perry, Senior Radiation Protection Technician (contracted)
- J. Preston, Plant Equipment Operator
- A. Price, Site Vice President
- S. Turowski, Supervisor-HP Technical Services
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened05000423/2515/166TIPressurized Water Reactor ContainmentSump Blockage (4OA5.1)
Opened and Closed
05000423/2007003-01NCVFailure to Perform Evaluations on BoricAcid Leaks (Section 1R08)05000336/2007003-02NCVInadequate Work Procedure for the Unit 2'C' Charging Pump Results in Pump Failure
(Section 1R12)05000336/2007003-03NCVFailure to Adequately Evaluate SurveillanceTest Data (Section 1R19)
A-2Attachment05000423/2007003-04NCVFailure to Implement Safety-RelatedSurveillance Procedure Resulted in the 'A'
Safety Injection Accumulator Inoperability
(Section 1R22)
Closed
- 05000336/FIN-2006010-01 URINRC to review consideration of EDGfrequency affects on design bases
calculations (Section 4OA3.8)
- 05000336/FIN-2006010-02URINRC to review licensee evaluation ofremoval of check valve CS-26 internals
(Section 4OA3.9)
- 05000336/FIN-2007002-01 URIMaintenance Rule (a)(1) Evaluation of Unit2 Vital Switchgear Emergency Cooling
- Failure (Section 4OA3.10)
- 05000336/LER-2006-006-00LERScaffolding Built for Work on Main SteamIsolation Valve (2-MS-64A) Prevented the
- Valve from Closing (Section 4OA3.4)
- 05000336/LER-2006-006-01LERScaffolding Built for Work on Main SteamIsolation Valve (2-MS-64A) Prevented the
- Valve from Closing (Section 4OA3.4)
- 05000336/LER-2006-008-00LERScaffold Impairment of Turbine DrivenAuxiliary Feedwater Pump Room HELB
- Blowout Panel (Section 4OA3.5)
- 05000423/LER-2007-001-00LERFailure of Two Main Steam Safety Valves toLift within the Acceptance Criteria (Section
- 4OA3.6)
- 05000423/LER-2007-002-00LER Loss of Offsite Power Caused byTransmission System Operator while
- Defueled (Section 4OA3.7)
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather ProtectionProceduresAOP-3569, Rev 016-00, Severe Weather ConditionSP-2665, Rev 005-01, Building Flood Gate Inspections
- SP-2615, Rev 006-00, Flood Level Determination
- OP 200.6, Rev 002-1, Storms and other Hazardous Phenomena Preparation and Recovery
- A-3AttachmentOther DocumentsUnit 2 Technical SpecificationsUnit 3 Technical Specifications Unit 2 UFSAR
- Unit 3 UFSAR
Section 1R04: Equipment AlignmentProceduresMP-16-MMM, Organizational EffectivenessMP-16-CAP-SAP01, Rev 002-01, Condition Report Initiation
- OP-2322, Rev 026-03, Auxiliary Feedwater System Lineup
- OP-3446A, Rev 022-01, Emergency Diesel Generator
- OP-3260I, Rev 000, RCS Inventory Tracking
- OP-3216, Rev 008-06, Reactor Coolant System Drain (IPTE)
- OP-2326A Rev 000-02, Service Water Alignment Verification
- SP 2664, Rev 002-08, Charging Pump Pulsation Dampener TestCondition Reports07-06525, 07-06615, 07-06756, 07-05225, 07-05053, 07-6897
- Work OrdersM2-07-03275
- Other DocumentsVTM 25203-309-002A, Reciprocating Charging PumpsMP2703C9, Rev 005-03, Charging Pump Liquid End Maintenance Unit 2 Control Room logs for June 9, 2007 thru June 11, 2007
- PPC data for charging pump flow for months of April, May and June
- FSAR Chapter 14 Analysis for Charging System
- FSAR Chapter 9.7 Service Water System
Section 1R05:
- Fire ProtectionOther DocumentsMillstone Nuclear Power Station Unit 3 Fire Protection Evaluation ReportFPI 50-001, Revision 010-00, Fire Brigade Drill Assessment Data Sheet Millstone Unit 3 Fire Dill Scenario for 6/19/2007, Fire in the "A" EDG Room
Section 1R07: Heat Sink PerformanceWork OrdersM3-06-02923, M3-07-07304
- A-4AttachmentCondition Reports07-06058Section 1R08: Inservice Inspection ProceduresMP-24-BACC-PRG, Rev 000-01, Millstone Station Boric Acid Corrosion Control Program,MP-24-BACC-FAP03, Rev 000-01, Millstone Station Boric Acid Corrosion Control ProgramEvaluationsMP-24-BACC-FAP01-003, Millstone Unit 3 Bottom Mounted Nozzle Inspection FormWork OrdersM3-06-02508, M3-02-00346, M3-05-04786, M3-05-15980, M3-07-05971, M3-06-03604, M3-05-15827, M3-07-06026Condition Reports07-03974, 07-03865, 07-03515, 07-03604, 06-02088, 05-07753, 05-11061, 07-04776,07-00703, 05-12048, 05-13383, 05-12048, 05-12023, 07-04309, 07-04150, 05-04388,
- 07-00712, 07-01109, 07-04184, 07-03848, 07-00889, 07-03865Personnel CertificationsPCI Energy Services NDE Level II Personnel Certificate, Visual Testing, Penetrant TestingDominion Supplemental NDE Personnel Certification Review Checklist
- PCI Energy Services ASME WPQs, various welders Task Qualification Record, Boric Acid Corrosion EvaluatorOther DocumentsHead Penetration UT Coverage above/below J-groove weld spreadsheetISI Unresolved Indication Report, AWO M3-06-08221
- Pressurizer 'B' Safety Nozzle Weld Overlay Process Traveler with Sacrificial Layer, PressurizerNozzle Overlay, Rev. 0PCI Energy Services Weld Repair Data Sheets, Traveler 03-X-5648-B-T-OL1
- Wesdyne International Ultrasonic Calibration Sheet, Pressurizer Safety 'B', 0
o Wesdyne International 'B' Safety Overlay Baseline Contour Profile Document
- PCI Energy Services Report of NDE Liquid Penetrant Examination,
- PT-900701-002, 021, 003,020,
- 004001, 006 PCI Energy Services Nonconformance Report, NCR No. 900701-02
- PCI Energy Services NDE Liquid Penetrant Examination, Weld No. 03-X-5650-D-T-OL1
- MRS-SSP-2096 Millstone Unit 3 Structural Weld Overlay Dominion Boric Acid Corrosion Control Program,
- DNAP-1004, Rev.'s 0-6
- AREVA NDE Procedure Visual Examination for Leakage of Reactor Head Penetrations,54-ISI-367-07AREVA NDE Procedure Remote Underwater Visual Inspection of Reactor PressureVessels,Vessel Internals and Components in Pressurized Water ReactorsAREVA NDE Procedure 54-ISI-801-02, Automated UT of PWR Vessel Shell Welds, dated2/14/2006AREVA NDE Procedure 54-ISI-855-04, Automated Ultrasonic Examination of Reactor
- A-5Attachment2/28/03 Answer to Order for Interim Inspection Requirements for RPVH's at Pressurized WaterReactors2/23/07 Supplemental Information Regarding Request
- IR-2-46 for Relaxation of Requirementsof Order
- EA-03-009 Regarding Reactor Pressure Vessel Head Penetrations5/16/06 Relaxation of the Requirements of Order
- EA-03-009 Regarding Reactor PressureVessel Head Inspections, Request
- IR-2-463R11 Outage/ALARA Challenge Board Presentation on RV Head Stand Modification and RVHead Inspections3R11 Outage/ALARA Challenge Board Presentation on
- RV 10 year ISI Inspection & BottomMounted Nozzles InspectionAlternative for the Weld Overlay of Pressurizer Nozzle Welds - Response to Request forAdditional InformationWestinghouse Drawing No. 10058C82, Millstone Unit 3 Pressurizer Safety/Relief Nozzle SWOLDesignMillstone Unit 3 Steam Generator Condition Monitoring and Operational Assessment RefuelingOutage 11, M3-EV-07-0016, Rev. 0Millstone Unit 3 - 2007 10 Year RV ISI Logistics Drawing 801724E, Sheet 4 of 15, Rev. 001
- Millstone Unit 3 Steam Generator Integrity Degradation Assessment R11, M3-EV-07-0006,Rev. 1Millstone, Units 2 and 3, Request for Additional Information,Bulletin 2002-01, Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity, 60-Day Response
- 3R11 List of BACC AWO's, not packing or cleaning
- BACCP Screening, 3RHS*V009
- Millstone Unit 3 Refueling Outage Boric Acid Corrosion Inspections 3R11
Section 1R11: Licensed Operator Requalification ProgramOther DocumentsUnit 3 Licensed Operator Simulator Training Lesson Plan for June 21, 2007Unit 2 Evaluated Simulator Session
- ES07301B
Section 1R12: Maintenance EffectivenessProceduresMP-24-MR-FAP730, Rev 000-03, Maintenance Rule Goal Setting and MonitoringS2-EV-98-0060, Revision 1, Pipe Linings in the
- MP2 Service Water SystemCondition Reports07-01788, 07-00737
- Other DocumentsMillstone Unit 2 Maintenance Rule Scoping Table, Service WaterRoot Cause Evaluation M-07-00737, Service Water Leak from Red Rubber Gasket Joint inSupply to "A" EDG, Unit 2
Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProcedures
- A-6AttachmentOP-3260A, Rev 016-01, Conduct of OutageOP-3215, Rev 007-05, Response to Intake Structure Degraded Condition
- SP-3665.2, Rev 008-01, Intake Structure Condition Determination
- MP-13-PRA-FAP01.1, Rev 002-02, Performing a 4 Risk Review
- AOP-2504A, Rev 003-08, Loss of Non-Vital Instrument Panel
- VR-11Condition Reports07-03503, 07-04514, 07-04546
- Work OrdersM2-07-02969
- Other DocumentsEquipment Out-Of-Service Risk Assessment ToolUnit 2 Technical Specifications
Section 1R15: Operability EvaluationsProceduresSP 2664, Rev 002-08, Charging Pump Pulsation Dampener TestMP2703C9, Rev 005-03, Charging Pump Liquid End Maintenance
- MP-16-MMM, Organizational EffectivenessMP-16-CAP-SAP01, Rev 002-01, Condition Report Initiation
- MP-00-0590, Evaluation for corrective maintenance on Charging Pump
- MP-07-03275, 'C' Charging Pump AssemblyWork OrdersM2-07-03275
- Condition Reports07-06525, 07-06615, 07-06756, 07-05225, 07-05053, 07-6897, 07-03322, 07-03568, 07-05073,07-04921, 07-05197, 07-09680Other DocumentsMP2-002-06, Operability Determination for Charging SystemFairbanks Morse Engine 10CFR21 Report 2007-10-00
- Unit 2 UFSAR 8.3
- Unit 2 T.S. 3.8.1.1/3.8.1.2
- RECO
- MP2-807-07, Degraded Intake Structure Floor Drain Used for SW Pipe Break FloodProtectionRECO
- MP3-007-07, New Vital Inverters 3VBA*INV2 and 3VBA*INV4 Have High FrequencyNoise Affecting SR NI and Gamma Metric InstrumentationTechnical Evaluation M3-EV-07-0020, Inventor 2 and 4 Operability
- RECO/OD
- MP3-008-07, Two Composite Stainless Steel and Boral Sheets Have BecomeDetachedNuclear Instrumentation Lesson Plans Unit 3 TS 3.9.1.3, Spent Fuel Pool - Reactivity Unit 3 TS 3.9.1.4, Spent Fuel Pool - Storage Pattern
- A-6AttachmentVTM 25203-309-002A, Reciprocating Charging PumpsUnit 2 Control Room logs for June 9, 2007 thru June 11, 2007
- Unit 2 PPC data for charging pump flow for months of April, May and June Unit 2 FSAR Chapter 14 analysis for Charging System
Section 1R17: Permanent Plant ModificationsCondition Reports07-05185, 07-04914Other DocumentsDM3-00-0163-07, Gamma Metrics Source Range Instrument Noise Suppression(3NME*CHAN2)
- MELP CorrectionDM3-00-0166-07, Westinghouse NIS Source Range 32 Channel Noise Suppression(3NMS*DWR032)DCM 3-2A, Rev 011-01, Charging System Alternate Minimum Flow Line Modifications
- VIAC2 Supplied From New Invertor 2
- Unit 3 50.59/72.48 Screen Form Unit 3 FSAR Chapter 3.10, Seismic Qualification of Seismic Category I Instrumentation andElectrical EquipmentTechnical Evaluation M3-EV-07-0020, Revision 0, Inverter 2 and 4 Operability
- RECO
- MP3-007-07, New Vital Inverters 3VBA*INV2 and 3VBA*INV4 have High FrequencyNoise Affecting SR NI and Gamma MetricsUnit 3 Nuclear instrument lesson Plans
Section 1R19: Post-Maintenance TestingProceduresOP 2304E21, Rev 000-00, 'C' Charging Pump and Discharge Check
- SP-2402PC, Rev 002, Channel "C" Spec 200 Safety Parameters Functional Test Data Sheet
- SP-2402BR, Rev 000, Channel "C" Pressurizer Pressure Rack Calibration Data Sheet
- SP-2403DC, Rev 000-07, Channel "C" Containment Pressure Calibration
- SP-2664-3, Rev 001-02, Charging Pump "C" Pulsation Dampener Test
- SP-2664, Rev 002-08, Charging Pump Pulsation Dampener Test
- SP-2664, Rev 001-03, Charging Pump 'C' Pulsation Dampener TestCondition Reports07-05345
- A-7AttachmentWork OrdersM3-06-02617, M3-07-06740, M3-05-09947, M3-07-06253, M3-05-06229, M3-05-14215, M2-07-03275, M2-07-03190, M2-07-03201
Section 1R20: Outage and Other ActivitiesProceduresOP 3201, Rev 020-013, Plant HeatupOP 3202, Rev 020-00, Reactor Startup
- OP 3203, Rev 018-07, Plant Startup
- OP 3207, Rev 013-03, Reactor Shutdown
- OP 3208, Rev 020-19, Plant Cooldown
- OP 3209A, Rev 008-00, Estimated Critical Conditions
- OP 3210B, Rev 009-02, Refueling Operations
- OP 3210A, Rev 013-16, Refueling Preparations
- OP 3216, Rev 008-07, RCS Drain
- OP 3217, Rev 006-02, RCS System Fill
- OP 3218, Rev 007-05, RCS Fill and Sweep
- OP 3250.01, Rev 010-10, Individual Loop Drain and Fill
- OP 3260A, Rev 016-01, Conduct of Outages
- OP 3260A-004, Rev 014-01, Shutdown Safety Assessment Checklist
- OP 3203A, Rev 010-02, Spent Fuel Bridge
- OP 3303D, Rev 011-06, Fuel Handling Tools
- OP 3345, Rev 016-00, 125V DC
- EOP 3505, Rev 010-02, Loss of Shutdown Cooling and or Inventory Control
- EOP 3505A, Rev 006-00, Loss of Spent Fuel Pool Cooling
- FP02.1, Rev 001-06, Shutdown Risk Management
- MP 3704B Control of Heavy Loads
- MP-24-HL-PRG Heavy LoadsCondition Reports07-03165, 07-03167, 07-03284, 07-03321, 07-03478, 07-03479, 07-03567, 07-03653, 07-03661, 07-03710, 07-03716, 07-03733, 07-03842, 07-03512, 07-04184, 07-04201, 07-04340,
- 07-04514, 07-04551, 07-04590, 07-04619, 07-04786, 07-04801, 07-05226Other Documents96-ENG-1252-C3 MP3 Structural Evaluation of RPV Head Drop (41') 3R11 Outage Risk Management Plan Dominion Response to Generic Letter 88-17, Reduced Inventory and Mid-Loop Conditions
- NRC Generic Letter 87-12, "Loss of RHR while the RCS is Partially Filled
- NUREG-1269, Loss of RHR, Diablo Canyon
- NRC Generic Letter 88-17, Loss of Decay Heat Residual Heat Removal
- NUREG-1410, Loss of Vital AC Power and RHR System during Mid-Loop Operations
- NUREG-1449, Shutdown and Low-Power Operations at Commercial Nuclear Power Plants inthe United States
Section 1R22: Surveillance Testing
- A-8AttachmentProceduresOP-2346A, Rev 026-06, "A" Emergency Diesel GeneratorM3-05-14054, Main Steam Safety Valve Simmer Testing
- SP-2613K, Rev 003-04, Diesel Generator Slow Start Operability Test, Facility 1
- SP-2624A, Rev 002-04, "A" Emergency Diesel Generator Auxiliaries Inservice Testing
- SP-3646A.15, Rev 016-02, Train A Loss of Power Test (IPTE)
- SP-3646A.17, Rev 016-02, Train A with Loss of Power Test (IPTE)
- SP-3712G, Rev 008-01, Main Steam Code Safety Valve Surveillance Testing (IPTE)
- SP-3601G.2, Rev 008-03, RCS and Pressurizer Heatup and Cooldown Rate
- SP-3601G.2-002, Rev 008, Pressurizer Heatup and Cooldown Rate and Surge LineTemperature MonitoringSP-3601G.2-001, Rev 005, RCS Heatup and Cooldown Rate
- SP-3610B.2, Rev 2, Accumulator Vent Valves
- SP 2606C, Rev 010-00,
- CS-4.1A Valve Tests, Facility 1
- SP 2610CO, Rev 000-03, 2-FW-43A and 2-FW-43B Failure Mode and Stroke Timing ISTDrawingsDWG. 25212-39241, Sheet 189, Rev 7, Emergency Generator Load SequencingP&ID 25203-26015, sheet1, Containment Spray SystemCondition Reports07-03710, 07-03256, 07-03257, 07-03478, 07-05596
- Other DocumentsLetter from Dresser Consolidated to Dominion dated 2/16/2007 Re: Certification ofCompliance/Conformance of Hydroset S/N
- HS-641Unit 2 TS 3.4.9.1 and Bases, Pressure/Temperature Limits Unit 2 TS 6.1.9, Component Cyclic or Transient Limit Unit 2 TS 3.6.3, Containment Isolation Valves Unit 2 TRM 3.4.9.2 and Bases, Pressurizer
Section 1R23: Temporary Plant ModificationsOther DocumentsSPROC
- ENG07-3-001, Rev 000, DCR M3-06004 inverter ReplacementWC 10-004, Rev 000-03, Temporary Modification Control Sheet
- DCM 3-2A, Rev 011-01, Unit 3 Vital Inverters Replacement
- DCM 03-007A, Rev 015-02, MP3 Vital Inverter 2 Replacement
- A-8Attachment
Section 1EP6: Drill EvaluationOther DocumentsUnit 3 Drill Exercise Plan for 6/21/2007 DrillUnit 2 Drill Exercise Plan for 6/12/2007 DrillSection 2OS1:
- Access Control to Radiologically Significance Areas and
Section 2OS2: ALARA Planning and ControlsProceduresRPM 1.3.8, Rev 8, Criteria for Dosimetry IssueRPM 1.3.12, Rev 8, Internal Monitoring Program
- RPM 1.3.13, Rev 8, Bioassay Sampling and Analysis
- RPM 1.3.14, Rev 7, Personnel Dose Calculations and Assessments
- RPM 1.4.4, Rev 2, Temporary Shielding
- RPM 1.5.2, Rev 4, High Radiation Area Key Control
- RPM 1.5.5, Rev 4, Guidelines for Performance of Radiological Surveys
- RPM 1.5.6, Rev 3, Survey Documentation and Disposition
- RPM 1.6.4, Rev 3, Siemens Electronic Dosimetry System
- RPM 2.4.1, Rev 6, Posting of Radiological Control Areas
- RPM 2.10.2, Rev 11, Air Sample Counting and Analysis
- RPM 5.2.2, Rev 10, Basic Radiation Worker Responsibilities
- RPM-GDL-008, Rev 0, Electronic Dosimeter Alarm Set PointsCondition Reports07-00925, 07-03426, 07-01940, 07-02141, 07-02651, 07-02856, 07-03299, 07-03730,
- 07-03738, 07-04358ALARA Council Meeting NotesMeetings conducted: 04/11/07, 04/12/07, 04/18/07, 04/20/07
- ALARA Reviews3-07-01, Reactor Disassembly3-07-02, Steam Generator Eddy Current Inspection (S/G-B&D)
- 3-07-05, ISI Weld Inspections & Boric Acid Corrosion Control Program
- 3-07-11, MOV Maintenance
- 3-07-13, Scaffold Installation & Removal
- 3-07-14, Insulation Removal
- A-8AttachmentALARA Pre-Job Briefing MaterialsReactor DefuelingInsulation Removal Routine Maintenance Reactor Disassembly Scaffolding Installation Steam Generator Eddy Current Testing Steam Generator Secondary Side Cleaning & InspectionRadiation Protection Department Self-AssessmentsMP-SA-06-48, Release of Material from Radiologically Controlled Area BoundariesMP-SA-07-12, Radiological Protection Accredited TrainingOther DocumentsNo M3-07-00, Personnel Contamination Report3R11 Reactor Cavity Decontamination Plan Unit 3 Source Term Data
- 3R11 ALARA Behaviors Report (Summaries from 3R11 Work Observation Focus Card)
- Dose & Dose Rate Alarm Report for the period April 1 - 25, 2007Section 4OA1 - Performance Indicator (PI) VerificationProceduresSP 2619A, Rev 044-09, Control Room Daily Surveillance, Modes 1 & 2SP 2831, Rev 008-04, Reactor Coolant Gros Specific Activity Determination
- SP 2830, Rev 007-02, Sampling Reactor Coolant for Dissolved Oxygen, Chloride and FluorideAnalysisOther DocumentsMillstone Unit 2 RCS leakage data sheet from January 1, 2006 thru March 31, 2007Millstone Unit 2 RCS Activity data sheet from January 1, 2006 thru March 31, 2007Section 4OA2 -
- Identification and Resolution of ProblemsProceduresC-MP-720A, Scaffold Erection, Use and Removal, Rev 003-01MP-20-WP-GDL20, Work Order Preparation, Rev 16
- MP-SA-07-31, Formal Self-Assessment Report for Fire Protection System
- MP-SA-07-06, Informal Self-Assessment Plan/Report for 2006/7Condition Reports06-01457, 06-01791, 06-01796, 06-01846, 06-02067, 06-02245, 06-02544, 06-03091, 06-05342, 06-05479, 06-05481, 06-05482, 06-06921, 06-07783, 06-08327, 06-08367, 06-09944,
- 07-06694, 05-07367, 06-09203, 06-12526, 06-12555, 07-05826, 07-05276, 07-05371, 07-
- 05376, 07-05445, 01-00904, 07-03937, 07-03447, 06-10100, 06-07999, 05-13883
- A-8AttachmentWork OrdersM2-06-02234, M2-06-03895, M2-06-03896, M2-06-03898,M2-02-06224-8,M3-04-01088M2-05-09339, M3-01-18643, M3-04-00484Other DocumentsDM2-00-0183-06, Unit 2 Instrument Air Excess Flow Valve RemovalMaintenance Rule (a)(1) Evaluation for Instrument Air Function 1.01, dated May 23, 2006
- MP2 PRA Instrument Air Model Notebook, revision 2
- Root Cause Evaluation M-06-01796, Reactor Trip due to Instrument Air Loss Effectiveness Review for Root Cause Evaluation
- CR-06-01796, dated April 5, 2007
- Licensee Event Report 05000336/2006-002-00, Manual Reactor Trip of both Feed Pumpsfollowing a Loss of Instrument AirSystem Health Reports for Instrument Air, 2006 Quarters 1 thru 4, and 2007 Quarter 1
- System Health reports for Unit 2 Maintenance Rule (a)(1) systems
Section 4OA3: Followup of Events and Notices of Enforcement DiscretionProceduresMP-26-EPA-REF03, Rev 008, Loss of PowerEOP-3501, Rev 014-01, Loss of All
- AC Power (Mode 5, 6, and Zero)
- EOP-3505, Rev 010-02, Loss of Shutdown Cooling and/or RCS Inventory
- GA-1, Rev 001-00, Energizing MCC 32-3T
- SP-2671, Rev 006-08, OMOC Duty Officer Requirement Following Unplanned Reactor Trip,Reactor Transient, or ESF ActuationOP-3314F, Rev 020-08, Control Building Heating Ventilation Air Conditioning and Chill Water
- OP-3346A, Rev 022-01, Emergency Diesel GeneratorCondition Reports06-00233, 06-05351, 06-06057, 06-09203, 06-11527, 06-11638, 05-07367, 06-09203,06-12526, 06-12555, 07-05826, 07-03104, 07-04514, 07-03256, 07-03167, 07-01325Other DocumentsCT-07-03256, Valve 3MSS*RV22D Failed As-found Set Pressure TestingEngineering Record of Correspondence 25212-ER-07-0038 dated 4/3/07
- Engineering Record of Correspondence 25212-ER-07-0038 dated 4/5/07
- NCV 05000336/2006005-04, Failure to Identify Scaffolding Rendered the #1 SG MSIVInoperableNCV 05000336/2006005, Licensee Identified, Failure to Implement Adequate CorrectiveActions to Prevent Recurrence with Respect to Scaffolding Affecting Safety-Related EquipmentEvent Review Team Report, Millstone 3 Loss of Offsite Power Event, April 25, 2007
- Millstone Unit 2 Technical Specifications Operator Logs, January 9, 2006
- MP-SA-07-31, Dominion Formal Self-Assessment for Fire Protection System
- MP-SA-07-06, Dominion Informal Self-Assessment of Quality Review for Past Design Changes Millstone Unit 2/Unit 3 2007 Qtr 1 System Health Reports Millstone Unit 2/Unit 3 2007 Qtr 1 Plant Health Reports
- LER 2006-006-00 & -01, Scaffolding Built for Work on Main Steam Isolation Valve
- A-8Attachment(2-MS-64A) Prevented the Valve from ClosingLER 2006-008-00, Scaffold Impairment of Turbine Driven Auxiliary Feedwater Pump RoomHELB Blowout PanelLER 2007-001-00, Failure of Two Main Steam Safety Valves to Lift within the AcceptanceCriteriaLER 2007-002-00 , Loss of Offsite Power Caused by Transmission System Operator whileDefueledNRC Confirmatory Action Letter to Dominion dated March 27, 2007
Section 4OA5: Other ActivitiesProceduresOP 2346A, "A" Emergency Diesel Generator, Rev 026-06MS 12179-123a, Removable Thermal Insulation, Rev 1
- SP 2612A, "A" SW Pump and Facility 1 Discharge Check Valve IST, Rev 002-00
- SP 2612A, "A" Service Water Pump Tests, Rev 010-02
- SP 3612A.1, Containment Inspections, Rev 016
- SP-ME-691, General Thermal Insulation Design and InstallationCondition Reports07-04117
- Other Documents108788-US(B)-372, Simplified Containment Recirculation Spray System (RSS) NPSH andSuction Hydraulic Analysis Without Debris Transport, Rev 0
- 2179-249, Determination of Max. Water Level Inside Containment Following a LOCA, Rev 3
- CALC 05-ENG-04155C3, MPS Determination of Latent Debris Inside Containment, Rev 0-2, 3
- DCM 03 Attachment 9, Rev 014-03, Design Engineering Screening Evaluation
- GSI 191, Rev 0Dominion Nuclear Connecticut, Inc., Virginia Electric and Power Company, Millstone PowerStation Units 2 and 3, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, NRC Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, 90 Day Response, dated March 4, 2005Dominion Nuclear Connecticut, Inc., Virginia Electric and Power Company, Millstone PowerStation Units 2 and 3, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, NRC Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, dated September 1, 2005PT 21416H1, MP 2 "A" Diesel Generator (H7A) Woodward 2301A Replacement andAdjustment, Rev 002-02PT 21416H3, MP2 "A" Diesel Generator (H7A) Woodward Digital Reference Unit Installationand Adjustments, Rev 002-02PT 21416G1, MP2 Diesel Generator Woodward 2310A Bench Test, Rev 002
- A-8AttachmentPT 21416G2,
- MP-2 Diesel Generator Woodward Digital Reference Unit (DRU) Bench Test, Rev002-02 Unit 3 Updated Final Safety Analysis Report
- 06-838, Letter from USNRC to Dominion, Millstone Power Station, Unit NO. 3 Issuance ofAmendment (No. 233) RE: Recirculation Spray SystemTemporary Instruction (TI) 2515/166 - Pressurized Water Reactor Containment Sump Blockage
- 06002757, 2008 Project Plan for Check Valve 2-CS-26
- 203-ER-98-0301, Design Basis for Safety Related Pump Testing, Rev 06
- 98-ENG-02697M2, Service Water Pumps Acceptance Curve, Rev 0-01
- ED 21221, Swing Check Valve Inspection Data Sheet Sketch, performed Oct 18, 2006
- M2-EV-99-0014, IST Pump Performance Testing Acceptance Criteria, Rev 4
- VTM 25203-138-006, Woodward Governor, Rev 1
LIST OF ACRONYMS
3R11Unit 3 refueling outageA/Cair conditioning
ACEapparent cause evaluation
AFWauxiliary feedwater
ALARAas low as reasonably achievable
AOPabnormal operating procedure
ASMEAmerican Society of Mechanical Engineers
BACCboric acid corrosion control
CALConfirmatory Action Letter
CRcondition report
DRPDivision of Reactor Projects
DRSDivision of Reactor Safety
EDGemergency diesel generator
EOPemergency operating procedure
FSARFinal Safety Analysis Report
GLgeneric letter
gpmgallons per minute
HELBhigh energy line break
IMCinspection manual chapter
ISIinservice inspection
ISTinservice test
LCOlimiting condition for operation
LERlicensee event report
LHRAlocked high radiation area
LOPloss of power
MRmaintenance rule
MSIVmain steam isolation valve
MSSVmain steam safety valve
NCVnon-cited violation
NDEnondestructive examination
NRCNuclear Regulatory Commission
A-8AttachmentPCRpersonnel contamination reportPIperformance indicator
PMTpostmaintenance testing
PWRpressurized-water reactor
QCquality control
RFOrefueling outage
RHRresidual heat removal system
RPCCWreactor plant closed cooling water
RSSTreserve station service transformer
RWPradiation work permit
SSCsystems, structures and components
SDPsignificance determination process
SIsafety injection
TDAFWturbine-driven auxiliary feedwater
TItemporary instruction
TStechnical specification
UFSARupdated final safety analysis report