IR 05000336/2014002

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IR 05000336-14-002, 05000423-14-002; 01/01/2014 - 03/31/2014; Millstone Power Station (Millstone) Units 2 and 3; Operability Determinations and Functionality Assessments
ML14129A244
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 05/07/2014
From: Raymond McKinley
NRC/RGN-I/DRP/PB5
To: Heacock D
Dominion Resources
McKinley R R
References
IR 14-002
Download: ML14129A244 (37)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713

May 7, 2014 Mr. David Heacock President and Chief Nuclear Officer

Millstone Power Station

Dominion Resources 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT: MILLSTONE POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000336/2014002 AND 05000423/2014002

Dear Mr. Heacock:

On March 31, 2014

, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Millstone Power Station, Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on April 22, 2014, with Mr. Stephen E. Scace, Site Vice President, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one violation of NRC requirements, which was of very low safety significance (Green). However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the 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 Millstone. In addition, if you disagree with the cross-cutting aspect assigned to the finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Millstone.

Additionally, as we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter (IMC) 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross-cutting aspect assigned, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Millstone.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRC's Agencywide Documents Access and Management 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 R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects

Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49

Enclosure: Inspection Report 05000336/2014002 and 05000423/2014002 w/Attachment: Supplementary Information

cc w/encl: Distribution via ListServ

ML14129A244 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME JAmbrosini/JA via email SShaffer/SWS RMcKinley/RRM DATE 4/25/14 4/25/14 5/7/14

1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos. 50-336 and 50-423

License Nos. DPR-65 and NPF-49

Report No. 05000336/2014002 and 05000423/2014002 Licensee: Dominion Nuclear Connecticut, Inc.

Facility: Millstone Power Station, Units 2 and 3

Location: P.O. Box 128 Waterford, CT 06385

Dates: January 1, 2014 through March 31, 2014

Inspectors: J. Ambrosini, Sr. Resident Inspector, Division of Reactor Projects (DRP) J. Krafty, Resident Inspector, DRP B. Haagensen, Resident Inspector, DRP E. Andrews, Reactor Engineer, DRP J. Richmond, Senior Reactor Engineer, Division of Reactor Safety (DRS)

H. Anagnostopoulos, Health Physicist, DRS

Approved By: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects

2 Enclosure

SUMMARY

IR 05000336/2014002, 05000423/2014002; 01/01/2014 - 03/31/2014;

Millstone Power Station (Millstone)

Units 2 and 3;

Operability Determinations and Functionality Assessments.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One NRC-identified non-cited violation (NCV) of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process (SDP)," dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, "Aspects Within the

Cross-Cutting Areas," dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XI, "Test Control," because Dominion did not properly evaluate test results outside of the acceptance criteria for the Unit 3 'A' service water (SW) pump. Specifically, on February 23, when the 'A' SW pump did not meet its acceptance criteria for running amps, Dominion did not fully evaluate pump operability under all conditions. Dominion's immediate corrective actions included entering the issue into their corrective action program (CAP) and placing the pump in pull to lock status until the issue could be resolved.

The inspectors determined that Dominion's failure to properly evaluate test results outside of the acceptance criteria for the 'A' SW pump in accordance with the requirements of 10 CFR 50, Appendix B, Criterion XI, to assure that test requirements have been satisfied was a performance deficiency that was within Dominion's ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, without proper evaluation of the test results, Dominion kept a component in service that was later determined to be non-functional. In accordance with IMC 0609.04, "Initial Characterization of Findings," and Exhibit 2 of IMC 0609, Appendix A, "The Significance Determination Process for Findings At-Power," issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification (TS) allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event, and did not represent an actual loss of function of a non-TS train of equipment designated as high safety significant. This finding has a cross-cutting aspect in the area of Human Performance, Design Margins, in that Dominion did not operate and maintain the pump within design margins, where margins are carefully guarded and changed only through a systematic and rigorous process. [H.6] (Section 1R15)

REPORT DETAILS

Summary of Plant Status

Millstone Unit 2 began the inspection period operating at 100 percent power. On January 31, Unit 2 shut down the plant in order to comply with TSs due to inoperable group 1 proportional heaters while the 'B' emergency diesel generator (EDG) was out of service (OOS) for maintenance. Unit 2 returned to 100 percent power on February 3. On February 27, Unit 2 reduced power to 17 percent to address a failed cell in the 201B battery. Unit 2 returned to 100 percent power on February 28.

Millstone Unit 3 operated at or near 100 percent power for the entire inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Dominion's preparations for the onset of a winter storm on February 12. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition.

The inspectors walked down the intake structure to ensure system availability. The inspectors verified that operator actions defined in Dominion's adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Unit 2 SW System while the 'A' SW pump was OOS for maintenance on February 25 Unit 3 Turbine Driven Auxiliary Feedwater (TDAFW) pump while Station Blackout (SBO) diesel was OOS on January 8 Train 'B' SW system while the 'A' SW pump was OOS for maintenance on March 25 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TS, work orders, condition reports (CR), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could

have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Dominion staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On January 28 and 29, the inspectors performed a complete system walkdown of accessible portions of the Unit 3 'A' charging system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability and operability of support systems. The inspectors performed field walkdowns of accessible portions of t he systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CR and work orders to ensure Dominion appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

6 Enclosure 1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns (71111.05Q - 4

samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Dominion controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for OOS, degraded or inoperable fire protection equipment, as applicable, in accordance with procedures.

Unit 2 Diesel Generator Room A, Fire Area A-15 on March 14 Unit 3 Fire Area AB-1, Auxiliary Building on January 7 Fire Area ESF-8, North Motor Driven Auxiliary Feed Pump Cubicle on March 6 Fire Area ESF-9, South Motor Driven Auxiliary Feed Pump Cubicle on March 6

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

The inspectors observed an announced fire drill conducted on January 16, on the Unit 3 East Switchgear room. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Dominion personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:

Proper wearing of turnout gear and self-contained breathing apparatus (SCBA) Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met

7 Enclosure The inspectors also evaluated the fire brigade's actions to determine whether these actions were in accordance with Dominion's fire-fighting strategies.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11Q - 4

samples)

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed a Unit 2 licensed operator simulator emergency drill on February 18, which included a failure of a reactor coolant pump that lead to a reactor trip followed by a loss of offsite power for a sustained period of time. The inspectors also observed Unit 3 licensed operator training on March 6, which included immediate action response to a series of individual events including the failure of pressure transmitter PT-505, an uncontrolled rod withdrawal, a turbine runback, an abnormal steam generator (SG) water level transient, the inadvertent opening of a pressurizer power operated relief valve, a SG atmospheric relief valve, and a pressurizer spray valve, a main steam line break, the loss of vital instrument AC [alternating current] buses 1, 2 and 3, and the loss of safety bus 34C. The inspectors evaluated operator performance during the simulated events and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisors. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift managers and the TS action statements entered by the shift technical advisors. Additionally, the inspectors assessed the ability of the crews and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed full flow testing of the Unit 3 TDAFW pump on January 26. This test is typically performed in Mode 3 and was designated as an Infrequently Conducted or Complex Evolution (ICCE), subject to the provisions described in OP-AA-106, "Infrequently Conducted or Complex Evolutions," when performed in Mode 1.

On February 1, the inspectors observed the Unit 2 reactor startup which is also an ICCE.

The inspectors observed pre-job briefs and focus briefs to verify control requirements of the ICCE were met. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

8 Enclosure

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or components (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that Dominion was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Dominion staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Dominion staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Unit 2 Vital Switchgear Emergency Cooling on March 14 Unit 3 TDAFW Pump on February 17

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Dominion performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Dominion personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Dominion performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Unit 2 Orange risk for emergent work to jumper out a cell of 201B battery on February 26 High risk for Control Element Assembly Position Display System replacement project on March 11 Yellow risk for RSST Load Tap Changer Position Indicator Replacement project testing on March 19 Unit 3 Emergent risk for testing TDAFW pump while SBO OOS on January 10 High risk for total spent fuel pool cooling outage relief valve testing on January 13 Yellow Risk for failure of the SBO diesel when the 'B' EDG was OOS for repairs on March 5

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

Unit 2 OD000558, Lower 4160V switchgear room cooler incorrect tube material on February 14 OD000580, Deformation of the 'A' EDG Heat Exchanger Expansion Joints on March 31 Unit 3 OD000571, TDAFW Pump Tripped During Performance of SP 3622.3 on January 23 OD000577, TDAFW Pump Operability Following Full Flow Surveillance on February 5 ETE-MP-2014-1002, Revision 0, TDAFW Pump Steam Supply Lines, Condensate Accumulation Between 3MSS*AOV31A/B/D and 3MSS*MOV17A/B/D, on March 5 OD000571, Revision 1, TDAFW Pump Tripped During Performance of SP 3622.3 on March 17 CR 542534, 'A' SW Pump Motor Operating Outside of Manufacturer Design on March 31 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Dominion's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Dominion. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XI, "Test Control," for the failure to properly evaluate test results outside of the acceptance criteria for the 'A' SW pump. When the 'A' SW pump did not meet its acceptance criteria, Dominion did not remove the pump from service or perform an adequate evaluation until questioned by the inspectors.

Description.

On February 23, Dominion performed post-maintenance testing on the 'A' SW pump and the pump did not meet its acceptance criteria. The acceptance criteria included the requirement for running amps to be less than or equal to 84.1 amps and the results at the three testing positions were 85, 82, and 85 amps. The 84.1 amp value is the nameplate current value listed on the motor. Operations consulted the engineering department for assistance in disposition of the results and engineering concurred that the acceptance criteria could be changed to 85 amps and the 'A' SW pump returned to an operable state. Engineering concluded that exceeding the motor nameplate current by 0.9 amps would not result in any significant short term motor degradation. Based on engineering's assessment, operations changed the acceptance criteria to 85 amps and declared the 'A' SW pump functional.

The inspectors questioned the basis of this assertion, because the service factor of the

'A' SW pump is 1.0, which would imply that even a small increase in amperage could have adverse consequences to the motor. Dominion generated a CR with the inspector's concerns (CR541081) and upon further investigation found that they had not considered whether the motor will start/accelerate as designed during a degraded bus voltage consideration or what impact there would be on the bus if the motor is running and the station encounters a degraded bus voltage condition. Dominion operators placed the pump in a pull to lock condition and entered Technical Requirements Manual 3.7.4 for having one SW pump non-functional.

Analysis.

The inspectors determined that Dominion's failure to properly evaluate test results outside of the acceptance criteria for the 'A' SW pump in accordance with the requirements of 10 CFR 50, Appendix B, Criterion XI, to assure that test requirements have been satisfied was a performance deficiency that was within Dominion's ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, without proper evaluation of the test results, Dominion returned a component to service that was later determined to be non-functional. In accordance with IMC 0609.04, "Initial Characterization of Findings," and Exhibit 2 of IMC 0609, Appendix A, "The Significance Determination Process for Findings At-Power," issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not 11 Enclosure represent actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event, and did not represent an actual loss of function of a non-TS train of equipment designated as high safety significant.

This finding has a cross-cutting aspect in the area of Human Performance, Design Margins, in that Dominion did not operate and maintain the pump within design margins, where margins are carefully guarded and changed only through a systematic and rigorous process. Specifically, Dominion did not perform a thorough evaluation as required to maintain the functionality of safety-related equipment under all conditions.

[H.6]

Enforcement.

10 CFR 50, Appendix B, Criterion XI, "Test Control," states, in part, that test results shall be documented and evaluated to assure that test requirements have been satisfied. Contrary to the above, from February 23 to March 19, Dominion did not properly evaluate test results outside of the acceptance criteria for the 'A' SW pump.

Dominion's immediate corrective actions included entering the issue into their CAP as CR542534 and placing the 'A' SW pump in pull to lock until the condition could be evaluated and full functionality restored. Because this violation was of very low safety significance (Green), and Dominion entered this issue into their CAP, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000423/2014002-01, Failure to Evaluate Test Results Outside of Acceptance Criteria for 'A' Service Water Pump)

1R18 Plant Modifications (71111.18 - 3

samples) Temporary Modifications

a. Inspection Scope

The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.

Unit 2 TCC-MP-2013-040, Remove Failed RPS T cold Input M2TE-112CB from Service, Revision 1, on January 6 TCC-MP-2014-008, Jumper out cell 27 of battery DB2-201B and De-energize DC [Direct Current] Emergency Lights at Panel D021 on February 27 Unit 3 CR539463 and associated 10 CFR 50.59 applicability review for OD000577 compensatory actions on February 20

12 Enclosure

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19 - 8

samples)

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

Unit 2 'B' EDG governor replacement on January 29 'A' low pressure safety injection pump breaker preventative maintenance and drain valve replacement on February 18 'A' SW pump strainer maintenance on March 10 Removal of flow limiter plate on 2-SW-8.1A, SW flow control valve to 'A' Reactor Building Closed Loop Cooling Water Heat Exchanger on March 31 Unit 3 Repairs to the SBO diesel power supply on January 13 Repairs to a failed weld the TDAFW Pump steam supply bypass line by 3MSS*V877 on January 23 Repairs to the TDAFW pump on January 25 Repairs to the control room chillers (3HVK*CHL1A/B) on February 12

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Dominion procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether 13 Enclosure the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

Unit 2 SP 2610BO-002, TDAFW and Recirculation Check Valve In-service test (IST), Revision 000-06, on February 5 SP 2602A, Reactor Coolant Leakage, Revision 006-03, (RCS Leakage) on February 21 Unit 3 SP 3622.3, TDAFW Pump Operational Test (IST) on January 16 SP 3646A, 'A' EDG Operability Test on January 21 SP 3622.9, Auxiliary Feedwater Pump 3FWA*P2 Full Flow test in MODE 1 (ICCE) on January 26 SP 3680.1, General Trending Procedure (for RCS Leakage), Revision 005-04, on March 18

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Unit 2 Dominion emergency drill on February 18 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Dominion staff in order to evaluate Dominion's critique and to verify whether the Dominion staff was properly identifying weaknesses and entering them into the CAP.

b. Findings

No findings were identified.

14 Enclosure

RADIATION SAFETY

Cornerstone: Public and Occupational Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

During March 10 - 13, 2014, the inspectors reviewed Dominion's performance in assessing the radiological hazards and exposure control in the workplace.

The inspectors used the requirements in 10 CFR 20 and guidance in Regulatory Guide (RG) 8.38, "Control of Access to High and Very High Radiation Areas for Nuclear Plants," TS, and the Dominion procedures that are required by TS as criteria for determining compliance.

a. Inspection Scope

Radiological Hazard Assessment

The inspectors determined if there have been changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether Dominion assessed the potential impact of these changes.

The inspectors reviewed the last two radiol ogical surveys from the Unit 3 Auxiliary Building 4' elevation, the Unit 3 Auxiliary Building 43' elevation, and the Unit 2 Solid Radioactive Waste area. The inspectors evaluated whether the thoroughness and frequency of the surveys were appropriate.

The inspectors conducted walkdowns and independent radiation measurements in the facility, including radioactive waste processing, storage, and handling areas to evaluate material and radiological conditions.

Instructions to Workers

The inspectors selected five containers of non-exempt licensed radioactive materials.

The inspectors assessed whether the containers were labeled and controlled in accordance with 10 CFR 20 requirements. The inspectors reviewed two occurrences where a worker's electronic personal dosimeter malfunctioned or alarmed.

The inspectors evaluated whether workers responded appropriately. The inspectors assessed whether the issue was included in their CAP and whether compensatory dose evaluations were conducted as appropriate.

Contamination and Radioactive Material Control The inspectors observed one location where Dominion monitors potentially contaminated material leaving the radiological control area and inspected the methods used for control, survey, and release of these materials from this area. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors assessed whether the radiation monitoring instrumentation 15 Enclosure used for equipment release and personnel contamination surveys had appropriate sensitivity for the type(s) of radiation present. The inspectors reviewed Dominion's criteria for the survey and release of potentially contaminated material. The inspectors evaluated whether there was sufficient alarm response procedural guidance. The inspectors reviewed Dominion's procedures and records to verify that the radiation detection instrumentation was used at appropriate detection sensitivity. The inspectors selected three sealed sources from the Dominion inventory records and verified whether the sources were accounted for and were tested for loose surface contamination. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with 10 CFR 20 requirements. Radiological Hazards Control and Work Coverage The inspectors evaluated ambient radiological conditions and performed independent radiation measurements during walkdowns of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, radiation work permits, and associated worker briefings. The inspectors examined Dominion's physical and programmatic controls for highly activated or contaminated materials stored within spent fuel and other storage pools. The inspectors assessed whether appropriate controls were in place to preclude inadvertent removal of these materials from the pool. The inspectors examined the posting and physical controls for selected high radiation areas (HRA), locked HRAs, and very high radiation areas (VHRAs) to verify conformance with the occupational performance indicator. Risk-Significant HRA and VHRA Controls The inspectors discussed with the Radiation Protection Manager the controls and procedures for high-risk HRAs and VHRAs. The inspectors assessed any changes to relevant procedures. The inspectors discussed with first-line health physics supervisors the controls in place for special areas that have the potential to become VHRAs during certain plant operations.

Radiation Worker Performance The inspectors reviewed 17 radiological problem reports since the last inspection that attributed the cause of the event to human performance errors. The inspectors

evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by Dominion to resolve the reported problems.

Radiation Protection Technician Proficiency The inspectors reviewed six radiological problem reports since the last inspection that attributed the cause of the event to radiation protection technician error. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by Dominion to resolve the reported problems. Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by Dominion at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by Dominion that involves radiation monitoring and exposure controls. The inspectors assessed Dominion's process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

During March 10 - 13, 2014, the inspectors verified in-plant airborne concentrations are being controlled consistent with as low as reasonably achievable (ALARA) principles, and that the use of respiratory protection devices on-site does not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR 20, the guidance in RG 8.15, "Acceptable Programs for Respiratory Protection," RG 8.25, "Air Sampling in the Workplace," NUREG-0041, "Manual of Respiratory Protection Against Airborne Radioactive Material," TS, and the Dominion's procedures that are required by TS as criteria for determining compliance.

a. Inspection Scope

Inspection Planning

The inspectors reviewed the UFSAR for Millstone Units 2 and 3 to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation

systems or airborne monitoring instrumentat ion. This review included instruments used to identify changing airborne radiological conditions. The review included an overview of the respiratory protection program and a description of the types of devices used. The inspectors reviewed the UFSARs, TS, and emergency planning documents to identify the location and quantity of respiratory protection devices stored for emergency use.

The inspectors reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including SCBA, as well as procedures for air quality

maintenance. Engineering Controls The inspectors reviewed Dominion's use of permanent and temporary ventilation to determine whether Dominion uses ventilation systems as part of its engineering controls 17 Enclosure to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems to reduce dose and assessed whether the systems are used, to the extent practicable, during high-risk activities The inspectors selected two installed ventilation systems used to mitigate the potential for airborne radioactivity. The inspectors evaluated whether the ventilation system operating parameters were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne radioactivity area. The inspectors selected two temporary ventilation system setups used to support work in contaminated areas. The inspectors assessed whether the use of these systems was consistent with Dominion's procedural guidance and the principles of ALARA. The inspectors reviewed airborne monitoring protocols by selecting two installed systems used to monitor and warn of changing airborne concentrations in the plant. The inspectors evaluated whether the alarms and set-points were adequate. The inspectors assessed whether Dominion had established threshold criteria for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.

Use of Respiratory Protection Devices The inspectors reviewed records of air testing for supplied-air devices and SCBA bottles to assess whether the air used in these devices meets or exceeds Grade D quality. The inspectors reviewed plant breathing air supply systems to determine whether they meet the minimum pressure and airflow requirements for the devices in use. The inspectors selected five individuals qualified to use respiratory protection devices, and verified whether they were deemed qualified to use the devices by successfully passing an annual medical examination, respirator fit-test, and relevant respiratory protection training. The inspectors selected three individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device. Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence. The inspectors chose ten respiratory protection devices staged and ready for use in the plant. The inspectors assessed the physical condition of the device components and reviewed records of equipment inspection for each type of equipment. The inspectors selected several of the devices and reviewed records of maintenance on the vital components. The inspectors verified that onsite personnel assigned to repair respiratory protection equipment have received vendor-provided training.

SCBA for Emergency Use The inspectors reviewed the status and surveillance records of selected SCBAs staged in-plant for use during emergencies. The inspectors reviewed Dominion's capability for refilling and transporting SCBA air bottles to and from the control rooms and the operations support center during emergency conditions.

18 Enclosure The inspectors selected four individuals on control room shift crews and from designated departments currently assigned emergency duties to assess whether control room operators and other emergency response and RP personnel were trained and qualified in the use of SCBA. The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task. The inspectors determined whether appropriate mask sizes and types are available for use. The inspectors determined whether on-shift operators had any facial hair that would interfere with the sealing of the mask to the face and whether vision correction mask inserts were available, as appropriate. The inspectors reviewed the past two years of maintenance records for three SCBA units to assess whether any maintenance and repairs on any self-contained breathing apparatuses were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. For those self-contained breathing apparatuses that were ready for use, the inspectors verified that the required, periodic air cylinder hydrostatic testing was documented and up to date. Problem Identification and Resolution The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by Dominion at an appropriate threshold and were properly addressed for resolution in Dominion's CAP. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by Dominion.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate

a. Inspection Scope

The inspectors reviewed Dominion's submittal for the RCS specific activity and RCS leak rate performance indicators for both Unit 2 and Unit 3 for the period of January 1, 2013 through December 31, 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample.

19 Enclosure

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, "Problem Identification and Resolution," the

inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Dominion entered issues into their CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP.

b. Findings

No findings were identified.

.2 Annual Sample:

Safety-Related Circuit Cards Repaired with Non-Safety Related Parts

a. Inspection Scope

The inspectors performed an in-depth review of Dominion's evaluations and corrective actions associated with CR520432 and Apparent Cause Evaluation 019518, for non-safety related (NSR) parts installed in safety-related Westinghouse 7300 series circuit cards. The affected circuit cards performed analog signal processing for inputs into the Solid State Protection System for reactor protection system trip functions and engineered safety feature actuation functions. Specifically, Dominion's technical staff identified that NSR parts had been installed in Millstone Unit 3 cards during card repair and refurbishment performed at Dominion's North Anna Power Station (NAPS) Module Repair Facility.

The inspectors assessed Dominion's problem identification threshold, problem analysis, 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. The inspectors compared the actions taken to the requirements of Dominion's CAP and 10 CFR 50, Appendix B. The inspectors interviewed engineering and maintenance personnel to assess the effectiveness of the implemented corrective actions, the reasonableness of the planned corrective actions, and to evaluat e the extent of any on-going problems.

In addition, the inspectors reviewed ETE-MP-2013-1198, Dominion's Use-As-Is Disposition, the Millstone module repair process, commercial grade dedication process, NAPS Module Repair Facility test procedures, and selected circuit card test results.

20 Enclosure

b. Findings and Observations

No findings were identified.

The Dominion technical staff identified w eaknesses in Dominion's NAPS Module Repair Facility, regarding administrative controls and oversight of safety-related circuit card repairs and the use of NSR parts without the use of a commercial grade dedication process. Dominion had a corrective action in place to suspend using the NAPS Module Repair Facility for repair of Millstone 7300 series circuit cards until adequate administrative controls and procurement requirements could be established. In addition, Dominion supply chain management placed all of the affected spare 7300 cards in restricted stock (e.g., quality assurance hold), pending final resolution. Dominion evaluated the affected installed cards and determined they were acceptable for safety-related use without any additional rework or testing, and without performing any commercial grade dedication evaluations of the NSR parts.

Dominion's Use-As-Is evaluation identified 75 cards which had been repaired and/or refurbished at the NAPS Module Repair Facility over a 9-year period (2005 to 2013).

Dominion stated that the 7300 system had about 600 cards installed. Based on a review of warehouse inventory records, the inspectors determined that about 50 of the 75 repaired cards were currently installed in Millstone Unit 3. The inspectors independently reviewed 7300 system maintenance rule functional failure evaluations from 2003 to present, and identified 2 to 6 card failures per year. Based on the total population of 7300 cards and the number of recorded failures, the inspectors determined that the overall failure rate was low (i.e., 0.6 percent average failure rate per year).

The inspectors concluded that Dominion's Apparent Cause Evaluation and Use-As-Is Disposition were, in part, narrowly focused because they did not identify or evaluate:

number of installed cards which had been repaired with NSR parts length of time that the affected cards had been in-service performance history of the installed affected cards process instrument channels potentially affected commercial grade dedication requirements for the NSR parts Specifically, Dominion had not tracked, trended, or reviewed the performance of the installed cards that had been repaired with NSR parts. Based on interviews, the inspectors determined that Dominion assumed none of the repaired cards had failed, because the overall failure rate of all 7300 cards was believed to be very, very low.

Contrary to Dominion's assumed failure rate for cards with NSR parts, the inspectors identified two instances of repaired cards which had been returned to NAPS for additional repairs after an in-service period of a few years. Therefore, the inspectors concluded that Dominion's assessments were based, in part, on an unverified assumption regarding the failure rate of cards repaired at NAPS because the performance history (e.g., failure rate) of the installed affected cards was not fully understood.

In addition, Dominion had assumed that commercial grade dedication evaluations were not necessary because the repaired cards had satisfactory test results (i.e., NAPS post-repair card testing and subsequent Millstone surveillance testing) and had been 21 Enclosure installed at Dominion with no known/recognized in-service failures. Therefore, the Dominion technical staff had concluded it was not necessary to

(1) identify or evaluate the critical characteristics of the installed NSR parts, or
(2) to determine whether there were any applicable component-level conditioning requirements, such as component-specific burn-in or selection testing, to eliminate unsuitable commercial parts (e.g., components with higher drift, lower tolerance, or higher infant mortality rates).

Therefore, the inspectors concluded that Dominion's determination to not assess commercial grade dedication requirements was also based, in part, on an unverified assumption regarding the failure rate of cards repaired at NAPS because the performance history (e.g., failure rate) of the installed affected cards was not fully understood.

The inspectors determined these weaknesses were minor issues because the number of installed affected cards was less than 10 percent of the total card population and the total card population had an acceptably low failure rate. Therefore, the inspectors concluded that the Dominion technical staff's overall response to this issue was commensurate with the safety significance and the actions taken or planned appeared reasonable to resolve the identified issue.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, "Reactive Inspection Decision Basis for Reactors," for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Dominion made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Dominion's follow-up actions related to the events to assure that Dominion implemented appropriate corrective actions commensurate with their safety significance.

Unit 2 TS required plant shutdown on January 31 due to inoperable group 1 proportional heaters with 'B' EDG OOS for maintenance on January 31 Unit 3 Notification of Enforcement Discretion (NOED) for repairs to the TDAFW Pump on January 26

b. Findings

No findings were identified.

22 Enclosure

Introduction.

The NRC identified an unresolved item (URI) for Dominion's request for enforcement discretion from TS 3.7.1.2(a) limiting condition of operation (LCO) action statement (C) on January 26, 2014, in accordance with IMC 0410, Notices of Enforcement Discretion. Following an overspeed trip of the Unit 3 TDAFW pump during a scheduled surveillance test, Dominion's efforts to complete troubleshooting, repairs and retesting could not be completed in time to comply with TS 3.7.1.2(a) action (C),

which allowed up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to complete repairs before a plant shutdown was required.

Dominion requested additional time to complete the repairs without having to shutdown Unit 3, and the NRC granted a NOED that extended the allowable outage time for an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Discussion. On January 23, 2014, the Unit 3 TDAFW pump failed a required surveillance test. During the starting sequence, the pump tripped on overspeed due to mechanical binding in the turbine governor linkage. Dominion entered TS LCO 3.7.1.2(a) action (C) which provided up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to repair the failed pump before requiring Unit 3 to be shutdown to Mode 3. Troubleshooting efforts revealed that the mechanical linkage between the governor and the turbine control valve (3MSS*MCV5)was binding due to a degraded cam follower bearing and a mechanical link that had been installed incorrectly. Although repairs had been completed, it became apparent that the required post-maintenance tests, including a full flow test at full power, could not be completed prior to the expiration of the LCO on January 26, 2014. Dominion requested enforcement discretion from compliance with TS 3.7.1.2 for a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The NRC reviewed the request in accordance with IMC 0410, NOED, and granted a one-time 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> extension to required action (C) of TS LCO 3.7.1.2(a).

Dominion completed the post-maintenance testing and restored the TDAFW pump to an operable status within the additional time granted.

The NOED specified a list of prerequisites and compensatory actions to mitigate risk that were required to be verified and completed prior to the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> extension becoming effective. Closure of this URI will require review and verification of Dominion's satisfactory completion of the specified requirements in the NOED in coordination with the Special Inspection Team that is inspecting Dominion's performance during this

event. (URI 05000423/2014002-02, NOED Granted by NRC for TDAFW Pump Repairs on January 26, 2014)

4OA5 Other Activities

The table below provides a cross-reference from the 2013 and earlier findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014 will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.

Finding Old Cross-Cutting Aspect New Cross-Cutting Aspect 05000423/2013004 H.1(b) H.14 05000423/2013004 H.2(a) H.6 05000423/2013005 H.1(b) H.14

4OA6 Meetings, Including Exit

On April 22, 2014, the inspectors presented the inspection results to Mr. Stephen E. Scace, Site Vice President, and other members of the Millstone staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Scace Site Vice President

M. Adams Plant Manager L. Armstrong Director, Nuclear Station Safety & Licensing G. Auria Nuclear Chemistry Supervisor

D. Bajumpaa Consulting Engineer

J. Barile Nuclear Engineer III

B. Bartron Supervisor, Licensing
P. Baumann Manager, Nuclear Protection Services J. Bergin Supervisor Nuclear Operations Support

T. Brigham Nuclear Maintenance Supervisor

R. Castillo Emergency Preparedness Specialist I, Communications Evaluator
W. Chestnut Supervisor, Nuclear Shift Operations Unit 2
F. Cietek Nuclear Engineer, PRA T. Cleary Licensing Engineer

G. Closius Licensing Engineer

J. Cote Senior Instructor

L. Crone Supervisor, Nuclear Chemistry
J. Curling Manager, Protection Services
M. Finnegan Supervisor, Health Physics, ISFSI W. Forrest Senior Instructor
W. Gorman Supervisor, Instrumentation & Control

J. Grogan Assistant Operations Manager

C. Janus Maintenance Rule Coordinator L. Kelly Supervisor Procurement Engineering Group J. Laine Manager, Radiation Protection/Chemistry
J. Langan Manager, Nuclear Oversight
G. Marshall Manager, Outage and Planning
M. Nappi Shift Supervisor, Health Physics
M. O'Conner Nuclear Specialist S. O'Hearn Nuclear Engineer III J. Palmer Manager, Training
F. Perry Supervisor, Exposure Control and Instruments
J. Rein Emergency Preparedness Specialist IV, Lead Controller
J. Rigatti Manager, Nuclear Site Engineering
M. Sanders Emergency Preparedness Specialist IV, Evaluator
J. Semancik Director, Nuclear Engineering
D. Smith Manager, Emergency Preparedness
S. Smith Manager, Nuclear Operations
J. Stoddard Supervisor, Nuclear Shift Operations Unit 3
S. Turowski Supervisor, Health Physics Technical Services
C. Vournazos IT Specialist, Meteorological Data
M. Wynn Supervisor, Radiological Analysis

Attachment

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000423/2014002-01

NCV Failure to Evaluate Test Results Outside of Acceptance Criteria For 'A' Service Water Pump

(Section IR15)

Opened

05000423/2014002-02 URI NOED Granted by NRC for TDAFW Pump Repairs on January 26, 2014

(Section 4OA3)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

C
OP 200.13, Cold Weather Preparations, Revision 003-08
C
OP 200.13, Cold Weather Preparations Attachment 6, Identified Issues for Unit 3, Revision
003-08
OP 2268, Cold Weather Operation, Revision 004-07
OP 2315G, Intake Structure Ventilation System, Revision 007-03
OP 2266, Response to Low or High Outside Air Temperature, Revision 001-04

Condition Reports

446391
530509 532442

Section 1R04: Equipment Alignment

Procedures

OP 2326A-001, SW Alignment Verification, Facility 1, Revision 000-09
OP 2326A-002, SW Alignment Verification, Facility 2, Revision 000-08
OP 3322-001, TDAFW Pump and Components Common to Both Trains, Revision 007-09
SP 3622.4-003, TDAFW, Revision 008-09
OP 3304A-001, MB3 Charging and Letdown Lineup, Revision 005-003
OP 3304A-008, Electrical Checklist for Charging and Letdown, Revision 000
OP 3326-001, Train 'A' SW System, Revision 009-04
OP 3326-002, Train 'B' SW System, Revision 010-03

Condition Reports

458915
462681
463806
467004
480249
480792
481792
504223
506697
508359
514331
540342
540749
540771
540807
2793
534467
Attachment Maintenance Orders/Work Orders
53M30717181

Miscellaneous

Chemical and Volume Control System Health Report, 3

rd Quarter 2013

Drawing 2512-26933, Service Water, Revision 4

Section 1R05: Fire Protection

Procedures

CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 9
MP-PROC-ENG-U3-24-FFS-BAP01, Millstone Unit 3 Fire Fighting Strategy, fire area
AB-1 Auxiliary Building
MP-PROC-ENG-U3-24-FFS-BAP01, Millstone Unit 3 Fire Fighting Strategy, fire area
CB-2 East Switchgear Room
MP-PROC-ENG-U3-24-FFS-BAP01, Millstone Unit 3 Fire Fighting Strategy, fire area
ESF-9, South Motor Driven Auxiliary Feed Pump Cubicle
MP-PROC-ENG-U3-24-FFS-BAP01, Millstone Unit 3 Fire Fighting Strategy, fire area
ESF-8, North Motor Driven Auxiliary Feed Pump Cubicle U2-24-FPP-FHA, Millstone Unit 2 Fire Hazards Analysis, Revision 12 U2-24-FFS, Millstone Unit 2 Firefighting Strategies, Revision 0
U3-24-FFS-BAP01-ESF-MAP, ESF Fire Strategy Map, Revision 0

Condition Reports

2565
537646

Miscellaneous

MP Fire Brigade Drill & Assessment

Section 1R11: Licensed Operator Requalification Program

Procedures

SP 3622.9, Auxiliary Feedwater Pump 3FWA*P2 Full Flow Test in Mode 1 (ICCE), Revision 0
OP-AA-106, Infrequently Conducted or Complex Evolutions, Revision 9
AOP 3581, Immediate Actions, Revision (Draft)
AOP 3564, Loss of One Protective system Channel, Revision 010-00
AOP 3571, Instrument Failure Response, Revision 009-07
AOP 3577, Loss of Normal and Offsite Power to 'A' 4.16 KV Emergency Bus, Revision 001-04
AOP 3579, Response to Operations Turbine Runback/Loss of Turbine Load, Revision 001-00
E-0, Reactor Trip or Safety Injection, Revision 027-01
ES-0.1. Reactor Trip Response, Revision 025-00
EOP 2525, Standard Post Trip Actions, Revision 025-00
EOP 2528, Loss of Offsite Power, Loss of Forced Circulation, Revision 025-00
EOP 2540, Functional Recovery, Revision 023-00
EPI-FAP06-002, Millstone Unit 2 Emergency Action Levels, Revision 009

Miscellaneous

SEG#S14205L, Immediate Action
AOP 3581, Revision 0
Attachment

Section 1R12: Maintenance Effectiveness

Procedures

ER-AA-MRL-10, Maintenance Rule Program, Revision 2
ER-AA-MRL-100, Implementing Maintenance Rule, Revision 1
MO-2784, Air Conditioning Units A/C-3 and A/C-4, Revision 000
NF-AA-PRA-101-3060, Probabilistic Risk Assessment Procedures and Methods:
Maintenance Rule Performance Criteria, Revision 0

Condition Reports

331247
422568
516336
521143
542981
2253
534694
531536

Miscellaneous

ACE018648
System Health Report - Auxiliary Feedwater & DWST, Q4-2012
System Health Report - Auxiliary Feedwater & DWST, Q4-2013
System Health Reports - Vita

l Switchgear Emergency Cooling 4

th Quarter 2012 and 2013

Maintenance Rule Evaluations MRE013573
MRE015555
MRE015585
MRE016250 MRE016310
MRE016336
MRE016583
MRE016588
MRE016593
MRE016621
MRE016666
MRE016944
MRE016947
MRE016983
MRE017092
MRE017182
MRE017192

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

MP-13-PRA-FAP01.1, Performing (a)(4) Risk Reviews, Revision 002-01
NF-AA-PRA-370, Probabilistic Risk Assessment Procedures and Methods: PRA Guidance for MRule (a)(4), Revision 15
WM-AA-20, Risk Assessment of Maintenance Activities, Revision 2
WM-AA-100, Work Management, Revision 23
WM-AA-301, Operational Risk Assessment, Revision 10
WM-AA-301, Attachment 4, Managing Medium Risk Significant Activities
WM-AA-301, Attachment 14, High Risk Contingency Plan Actions

Condition Reports

541062

Miscellaneous

EOOS User's Manual EOOS Operator's Risk Report dated January 10, 2014
EOOS Operator's Risk Report dated January 13, 2014
EOOS Operator's Risk Report dated March 5, 2014
High Risk Contingency Plan for jumpering of cell #27 on Battery 201B. High Risk Contingency Plan for CEAPDS Replacement Project High Risk Contingency plan for RSST load tap changer replacement project online work
Attachment

Section 1R15: Operability Evaluations

Procedures

OD000571, Revision 0
OD000571, Revision 1
OD000577, Revision 0
OD000558, Revision 0
MP-20-WP-GDL40, Pre and Post Maintenance Testing, Revision 013-03

Condition Reports

537862
537863
537871
537879
537908
537933
537940
537973
537997
538018
538027
538082
538172
538293
538298
538323
538386
538473
538634
535730
530999
542127
542219
542534
543253
540479
541081

Miscellaneous

ETE-CME-2014-007, MPS2 SW Piping system ('A' EDG) Structural Capacity Assessment for Observed System Transient, Revision 0
ETE-MP-2014-1002, TDAFW Pump Steam Supply Lines, Condensate Accumulation between 3MSS*AOV31A/B/D and 3MSS*MOV17A/B/D, Revision 0
ETE-MP-2013-1263, Technical Basis for Continuous Blowdown of 'A' SG Aux Feedwater Supply Trap 3DTM-TRP16A, Revision 0
ETE-MP-2013-1280, Tube plugging of X182 lower 4160V switchgear cooler

Section 1R18: Plant Modifications

Procedures

OP
AA-102, Operability Determination, Revision 11
SP 2402TG, RCS RTD Cross Calibration, Revision 002-05

Condition Reports

535948
540795
540957
540998
541080

Miscellaneous

CE Power Systems Letter,
MP2-CE-3591, dated April 6, 1976
M2-EV-99-0062, Evaluation of Actions Taken to Reduce 125 VDC Station Battery Loading, Revision 0
NEI 96-07, Guidelines for 10
CFR 50.59 Evaluations, Revision 1
Regulatory Guide 1.187, Guidance for Implementation of 10
CFR 50.59 Changes, Tests and Experiments, dated November 2000 NRC
IMC 0326, Operability Determinations and Functional Assessments for Conditions Adverse to Quality or Safety,
OD000577 50.59 Applicability Review
SP-EE-362, Millstone 2 Station Blackout Safe Shutdown Scenario Document, Revision 02
203-SP-M2-SU-1046, MP2 Appendix R Compliance Report, Revision 1 97-ENG-01775E2, Battery 201B and Charger Associated Cable Device Electrical Verification Calculation, Revision 2
Attachment

Section 1R19: Post-Maintenance Testing

Procedures

OP 2346C-002, 'B' DG Data Sheet, Revision 002-01
OP 3346D, SBO Diesel, Revision 012-06
AD-AA-102, Procedure Use and Adherence, Revision 9
SPROC ENG13-2-005, Online Retest for Deflector Plate Removal, Revision 000-01
SP 2604C, LPSI Pump and Min-Recirc Check Valve IST, Facility 1, Revision 012
SP 2612A-003, 'A' SW Pump and Facility 1 Discharge Check Valve IST, Revision 004-02
SP 2612C-004, 2-SW-8.1A Stroke Timing and Remove Position Indication IST, Revision 001-02
SP 2613B-001, Periodic DG Operability Test, Facility 2 (Fast Start, Loaded Run), Revision 021-09
SP 2613J-001, 'B' EDG Loss of Load Test, Revision 003
SP 2613L-001, Periodic DG Slow Start Operability Test, Facility (Loaded Run), Revision 004-04
SP 2624B-003, 'B' EDG Train 'B' Starting Air Vent Valve IST, Revision 002-01
SP 2670-001, 'A' RBCCW HX D/P Determination, Revision 010-04
SP 2670-007, DG 'B' HX D/P Determination, Revision 001-05
OP 3314F, Control Building Heating, Ventilation, Air Conditioning and Chilled Water, Revision
23-03
SP 3614F.9, Control Room Emergency Filtration Operability Test, Revision 006-08
MP-20-WP-GDL40 Attachment 2, Pre and Post Maintenance Testing, Revision 013-03

Condition Reports

2732
522743
522757
533058
536471
536479
536634
536742
536765
537353
537804
538367
537862
537863
537871
537933
537940
537973
537997
538018
538027
538082
538172
538293
538298
538323
538386
538473
538634
537870
537908
525109
526349
534558
538994
539158
539261
539980
540092
Maintenance Orders/Work Orders 53102261978
53102296789
53102297048
53102335788
53102379741
53102540387
53102545673
53102588753
53102588690
53102595064
53102615975
53102620271
53102642512
53102699760
53102637440
531026504242 53102691890
53102693533
53102477584
53102351569 53102595064
53102659872
53102661949
53102673309
53M2028620
53M20208621
53M20403403
53M20703060
53M20806587
53102553904
53M30608827

Miscellaneous

MP2-13-01163, SW TCV 2-SW-8.1A/B/C Deflector Plate Modification, Revision 0 SAR000486
SAR000841

Section 1R22: Surveillance Testing

Procedures

SP 2610BO-001, 2-MS-201, 2-MS-202 and 2-MS-464 (SV-4188) Stroke and Timing IST, Revision 001-04
Attachment
SP 2610BO-004, AFP Turbine Trip Throttle Valve Exercise Test, Revision 000-01
SP 3622.3, Auxiliary Feedwater Pump 3FWA*P2 Operational Readiness Test, Revision 017-15
SP 3622.3-001, TDAFW Pump Operational Readiness and Quarterly IST Group B Pump Tests, Revision 014-05
SP 3346A, EDG, Revision 025-02
SP 3646A.1-001, EDG 'A' Operability Tests, Revision 018-07
SP 3622.9, Auxiliary Feedwater Pump 3FWA*P2 Full Flow test in MODE 1 (ICCE), Revision
000-00
SP 3680.1, General Trending Procedure, Revision 005-04
SP 3680.1-003, Containment Leakage Trending, Revision 002-01

Condition Reports

537862
537863
537871
537879
537908
537933
537940
537973
537997
538018
538027
538082
538172
538293
538298
538323
538386
538473
538634

Miscellaneous

RCS Leakage Report, Millstone Unit 3 for March 18, 2014
Maintenance Orders/Work Orders
53102652167
53102652136

Section 1EP6: Drill Evaluation

Procedures

MP-PROC-OPS-EOP-2540C1, Functional Operations Recovery of RCS Inventory Control, Revision 004-01
MP-26-EPI-FAP06-006, EOF Protective Action Recommendations, Revision 3

Condition Reports

540693

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedures

C
OP 200.14, Containment Entry, Revision 004-10
OP 2209A, Refueling Operations, Revision 027-07
OP 2305C, SFP Demin Resin Replacement, Revision 000-00
OP 2338C, SRT Resin Transfer and Dewatering, Revision 001-09
OP 3338A, Radioactive Solid Waste, Revision 011
OPS-FH 210, Spent Fuel Pool Operations, Revision 001-03
OPS-FH 310, MP3 Spent Fuel Pool Operations, Revision 001-04
RP-AA-107, Radioactive Contamination Control Program, Revision 4
RP-AA-108, Radioactive Material Control Program, Revision 2
RP-AA-109, Radiological Survey Program, Revision 0
RP-AA-201, Access Controls for High and Very High Radiation Areas, Revision 7
RP-AA-222, Radiation Surveys, Revision 1
RP-AA-223, Contamination Surveys, Revision 3
Attachment
RP-AA-225, Unrestricted Release of Material, Revision 4
RP-AA-230, Personnel Contamination Monitoring and Decontamination, Revision 7
RP-AA-270, Providing RP Coverage During Work, Revision 0
RP-AA-274, Radiation Work Permits, Revision 1 RPM 2.5.2, Guidelines for Spent fuel Pool or Flooded Reactor Cavity Work, Revision 004
RPM 2.7.1, Entry to Unit 2 Containment, Revision 005-01
RPM 2.8.1, Initial Entry to Unit 3 Containment, Revision 003-02
RP-MP-201-2001, Millstone Unit 3 MIDS Very High Radiation Areas, Revision 1
Audits, Self-Assessments, and Surveillances Audit 10-07: Radiological Protection and Process Control Program, September 23, 2010 Audit 12-06: Radiological Protection/Process Control Program/Chemistry, September 20, 2012

Condition Reports

509388
515165
531907
507402
515208
534063
508512
515829
25852
508667
515833
534411
509449
516197
534835
510610
517042
537258
511023
518183
539663
511417
519737
540188
511426
523168
540413
511454
24069
514615
529217

Miscellaneous

MP-HP-14002, 2014 Confirmation of Annual Inventory Reconciliation National Source Tracking System, January 15, 2015 RPM 2.12.1-003, Millstone Source Leak Test, November 18, 2013
Sealed Source Inventory dated December 2013

Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation

Procedures

RP-AA-104, Internal Radiation Exposure Control Program, Revision 1
RP-AA-224, Airborne Radioactivity Surveys, Revision 1
RP-AA-226, Alpha Monitoring, Revision 3
RP-AA-243, Portable HEPA Ventilation Units, Revision 0 RPM 2.2.6, Continuous Air Monitors, Revision 015 RPM 2.2.12, Unit 2 Containment Continuous Air Radiation Monitors, Revision 007-01
RPM 2.4.3, DOP Testing of Portable HEPA Filtered Ventilation and Vacuum Units, Revision
005-01 RPM 2.10.2, Air Sample Counting and Analysis, Revision 014-02
RP-08-02, Millstone Power Station Beta-Gamma DAC Fraction Action Level, Revision 001-02

Condition Reports

518687
509630
Attachment Miscellaneous 13-09417, Breathing Air Quality Report from Trace Analytics, LLC
13-25412, Breathing Air Quality Report from Trace Analytics, LLC
MP-HPO-11065, Basis for Airborne Tritium Collection Efficiency Factors, November 1, 2011
MP-HPO-99148, Documentation of RPM 2.10.2 Attachment 3 Values, July 29, 1999
Results of recent 10 CFR Part 61 radio-analytical analysis

Section 4OA1: Performance Indicator Verification

Condition Reports

495964
489536
438213
426906

Miscellaneous

CP 2802N, Primary System Sampling and Analysis, Revision 001-05
NF-AA-NSA-101-5009, RCS Leak Rate Monitoring, Revision 1
SP 2602A, Reactor Coolant Leakage, Revision 006-03
SP 3061F.6, RCS Water Inventory Measurement, Revision 006-07
COP 200.15, RCS Leakage Trending and Investigation, Revision 001-01

Section 4OA2: Problem Identification and Resolution

Procedures

D-ICM-MR-NAL-01, Repair and Testing of 7300 Process Cards
NAL-G01, Revision 0
D-MDAP-0030, Standard Practices for the Module Repair Facility, Revision 3 and 5
MP-08-MP-GDL06, Millstone Module Repair Process, Revision 1 and 2
MP-08-MP-GDL06A, Millstone Standard Practices for the Module Repair Facility, Revision 0
MS-AA-PTE-401, Procurement Technical Evaluation Determination, Revision 6
MS-AA-PTE-401-1004, Commercial Grade Dedication, Revision 2
Licensing and Design Basis Documents
EQDP-ESE-13, Westinghouse Process Protection System Equipment Qualification Data Package, Revision 5
Calculations, Analysis, and Engineering Evaluations
ACE 019518, Non-Safety Related Parts Installed in 7300 Circuit Cards, dated July 11, 2013
ETE-MP-2013-1198, Use-As-Is Disposition for Westinghouse 7300 System Circuit Boards repaired at North Anna Power Station Module Repair Facility, Revision 0
PTE-9004446, Procurement Technical Evaluation for 7300 System Circuit Board, Version 07

Condition Reports

and Corrective Action Documents CA265450

CA269002
449368
520983
CA266966
CA275026
457248
522619 CA266967
MRE017048
464388
525288 CA267546
422907
501295
534246
CA267547
422915
503961
534356
CA267549
430769
513486
542124
CA267550
433650
515181
447833 CA268681
520432
Attachment

Work Orders

53102578578

Miscellaneous

Electric Power Research Institute (EPRI)
NP-5652, Guideline for Utilization of Commercial Grade Items, dated June 1988 EPRI
NP-6406, Guidelines for Technical Evaluation of replacement Items, dated December
1989 EPRI
TR-102260, Supplemental Guidance for EPRI
NP-5652, dated March 1994 Maintenance Rule Functional Failure Summary Report for Millstone Unit-3 7300 System, from January 1, 2003 to March 5, 2014 Millstone Unit-3 Reactor Protection Sy stem Health Report, 4th Quarter 2013 Southern Testing Services Procedure 2356-DP-01, Dedication for Operational Amplifier LM725AH, Revision. 0 Spectrum Technologies Test Procedure GP0052, Acceptance Testing and
Dedication of Transistors, Revision 3 Supply Chain Management Restricted Stock Report for 7300 Circuit Boards, dated March 5, 2014
WCAP-8587, Methodology for Qualifying Safety Related Equipment, Revision 1
Attachment

LIST OF ACRONYMS

CFR Title 10 of the

Code of Federal Regulations

ALARA as low as reasonably achievable
CAP Corrective Action Program
CFR Code of Federal Regulations
CR condition reports
DRP Division of Reactor Projects
DRS Division of Reactor Safety
EDG emergency diesel generator
HRA high radiation area
ICCE infrequently conducted or complex evolution
IMC Inspection Manual Chapter
IST in-service test
LCO Limiting Condition of Operation
NAPS North Anna Power Station
NCV non-cited violation
NEI Nuclear Energy Institute
NOED Notice of Enforcement Discretion
NRC Nuclear Regulatory Commission
NSR non-safety related
OOS out of service
RCS reactor coolant system
RG regulatory guide
SBO station blackout
SCBA self-contained breathing apparatus
SG steam generator
SSC structure, system, or component
SW service water
TDAFW turbine driven auxiliary feedwater
TS technical specifications
UFSAR Updated Final Safety Analysis Report

URI unresolved item

VHRA very high radiation area