IR 05000443/2006006

IR 05000443-06-006; Florida Power & Light Energy Seabrook, LLC; 11/27/2006 Through 12/07/2006; Seabrook Nuclear Power Station

ML070170193
Person / Time
Site:	Seabrook
Issue date:	01/16/2007
From:	Paul Krohn NRC/RGN-I/DRP/PB6
To:	St.Pierre G Florida Power & Light Energy Seabrook
Krohn P, RI/DRP/PB6/610-337-5120
References
IR-06-006
Download: ML070170193 (20)

Text

ary 16, 2007

SUBJECT:

SEABROOK NUCLEAR POWER STATION - PROBLEM IDENTIFICATION AND RESOLUTION (PI&R) INSPECTION REPORT NO. 05000443/2006006

Dear Mr. St. Pierre:

On December 7, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Seabrook Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on December 7, 2006, with you and members of your staff during an exit meeting.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, the inspection team concluded that the Florida Power and Light Energy Seabrook, LLC (FPL) implementation of the corrective action program at Seabrook was consistent and generally effective. The team determined that FPL staff had a low threshold for identifying problems, and issues were prioritized and evaluated commensurate with their safety significance. Corrective actions were typically implemented in a timely manner and addressed the identified causes of the problems. Lessons learned from industry operating experience were reviewed and applied when appropriate, and audits and self-assessments were critical with appropriate actions taken to address identified issues in most cases.

This report documents one NRC-identified finding of very low safety significance (Green). The finding was associated with a failure to promptly identify an adverse condition associated with credited accident analysis assumptions. The station failed to promptly identify the incorrect application of emergency core cooling system (ECCS) termination criteria that had been used for a power uprate interim design analysis for an inadvertent safety injection (SI) actuation event. This finding was determined to be a violation of NRC requirements. However, because the violation was of very low safety significance and because it was entered into your corrective action program, the NRC is treating this as a Non-Cited Violation (NCV), in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny this NCV, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to

Mr. Gene S the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC, 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC, 20555-0001; and the NRC Resident Inspector at the Seabrook Nuclear Power Plant.

In accordance with 10 CFR 2.390 of the NRCs 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 Publically Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Paul G. Krohn, Chief Projects Branch 6 Division of Reactor Projects Docket Nos. 50-443 License Nos. NPF-86 Enclosure: Inspection Report No. 05000443/2006006 w/Attachment: Supplemental Information

Mr. Gene S

SUMMARY OF FINDINGS

IR 05000443/2006006; 11/27/2006 - 12/07/2006; Seabrook Station, Unit 1; Biennial

Baseline Inspection of the Identification and Resolution of Problems; one violation was identified in the area of problem identification.

This team inspection was performed by four regional inspectors and one resident inspector.

One finding of very low safety significance (Green) was identified during this inspection.

The finding was classified as a Non-Cited Violation (NCV). 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 made Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 3, dated July 2000.

Identification and Resolution of Problems The team concluded that the implementation of the corrective action program (CAP) at Seabrook was generally effective. The team determined that Seabrook station had a low threshold for identifying problems and entering them in the corrective action program. Once entered into the system, items were screened and prioritized in a timely manner using established criteria. The station properly evaluated items entered into the corrective action program commensurate with their safety significance. Corrective actions addressed the identified causes and were typically implemented in a timely manner based upon significance. The team observed that the station was generally effective in reviewing and applying operating experience information from industry. Overall, FPL audits and assessments that were reviewed were critical, and appropriate actions were taken to address identified issues. On the basis of interviews conducted during the inspection, the team found station employees at the site expressed the willingness and freedom to enter safety concerns into the CAP.

Inspectors identified one Green NCV during this inspection. The NCV was associated with a failure to promptly identify a condition adverse to quality associated with analysis assumptions credited by the station an inadvertent safety injection (SI) event.

Cornerstone: Initiating Events

Green.

The inspectors identified a NCV of 10 CFR 50, Appendix B, Criterion XVI,

Corrective Action, in that FPL failed to promptly identify a condition adverse to quality associated with incorrect design assumptions used for the licensing basis in the stations stretch power uprate. Specifically, the station failed to promptly identify a discrepancy between emergency operating procedures (EOPs) implementation and the assumed emergency core cooling system (ECCS) termination criteria that had been used for a power uprate interim design analysis for an inadvertent SI actuation event.

ii

Consequently, FPL operated outside the interim analysis basis accepted per an NRC Safety Evaluation Report (SER) and challenged conclusions documented in that credited interim design basis. FPL entered this issue into their corrective action program and additional evaluation by the station determined that the issue remained bounded by original plant design basis conclusions and did not meet NRC reportability thresholds during this interim analysis time period.

This finding was more than minor because it was associated with the design control attribute of the initiating events cornerstone and impacted the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. The finding is also similar to the more than minor examples in MC 0612, Appendix E, examples 3.j and 3.k. Inspectors evaluated this finding using Phase of IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, and determined the finding to be of very low safety significance because it; did not affect loss of coolant accident initiators; did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available; and did not increase the likelihood of an external event. (Section 4OA2.a(3))

Licensee-Identified Violations

None.

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REPORT DETAILS

4OA2 Problem Identification and Resolution (PI&R) (Biennial - IP 71152B)

.1 Assessment of the Corrective Action Program

a. Inspection Scope

The inspection team reviewed the procedures describing FPLs corrective action program (CAP) at Seabrook. FPL identified problems for evaluation and resolution by initiating condition reports (CRs) in their condition reporting system. The team evaluated the methods for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the team interviewed plant staff and management to determine their understanding of and involvement with the corrective action program. The condition reports and other documents reviewed, as well as key personnel contacted, are listed in the attachment to this report.

The team reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Program (ROP) to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The team selected items from the maintenance, operations, engineering, emergency preparedness, physical security, radiation safety, and oversight programs to ensure that FPL appropriately addressed problems identified in each functional area.

The team selected a risk-informed sample of CRs that had been issued since the last NRC PI&R inspection conducted in November 2004. The team considered risk insights from the NRCs and Seabrook stations risk analyses to focus the sample selection and plant tours on risk-significant systems and components. The corrective action review was expanded to five years for evaluation of the service water system.

The team selected items from various processes used at Seabrook to verify that they were appropriately considered for entry into the CAP. Specifically, the team reviewed a sample of operability determinations, engineering system health reports, and completed surveillance tests. The team also reviewed work orders for selected components to determine if station personnel entered issues identified during the performance of preventive maintenance into the CAP.

The inspection team reviewed CRs to assess whether FPL adequately evaluated and prioritized identified problems. The issues reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. For significant conditions adverse to quality, the team reviewed FPLs corrective actions to preclude recurrence. The team observed meetings of the Condition Review Oversight Group (CROG), in which station management reviewed new CRs for prioritization and assignment, and evaluated root cause evaluations and selected apparent cause evaluations including associated corrective action assignments. The team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems.

The team reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for repetitive problems to determine whether previous corrective actions were effective. The team also reviewed FPL timeliness in implementing corrective actions and their effectiveness in precluding recurrence for significant conditions adverse to quality. The team reviewed corrective actions associated with selected NCVs and findings to determine whether the station properly evaluated and resolved these issues.

b. Assessment and Findings Identification of Issues Inspectors identified one Green NCV in the area of problem identification. The finding was associated with a failure to promptly identify a condition adverse to quality associated with analysis assumptions used for an inadvertent SI event.

In general, the team considered the identification of problems at Seabrook to be appropriate. The condition reporting process, both computer-based and manual, facilitates the initiation, tracking, and trending of condition reports. Approximately 15,000 condition reports were written each year. There was a low threshold for the identification of issues and, in most cases, problems identified during plant activities were entered into the CAP when appropriate. However, the team found that time-critical operator action issues identified in 2004 and 2005 associated with the analysis of the inadvertent ECCS initiation event were not promptly identified and corrected. As a result, the station operated outside the interim design basis analysis credited per an NRC SER. This finding is discussed in detail in the findings section of this inspection report.

Prioritization and Evaluation of Issues No findings of significance were identified in the area of prioritization and evaluation of issues.

The team determined that, in general, FPL appropriately prioritized and evaluated issues commensurate with the safety significance of the issue. Condition reports were screened for operability and reportability, categorized by significance (A through E), and assigned to a department for evaluation and resolution. The CROG appropriately considered human performance issues, radiological safety concerns, repetitiveness, and adverse trends in their reviews. The team did identify two weaknesses with respect to properly prioritizing and evaluating condition reports:

C The inspectors identified a sample of condition reports that failed to appropriately classify repetitive performance issues and component failures as repeat conditions.

Therefore, these associated issues were not coded as repeat conditions in the CAP and bypassed the stations ability to trend issues and raise station awareness. Two examples of this were CR 05-01544, which documented six examples of workers working on live wires due to drawing discrepancies; and CR 06-07045, which documented battery charger personnel issues. These issues were not labeled as repeat issues due to specific CAP procedural definitions on what constituted a repetitive issue. CR 06-14761 was previously issued by the station to address this issue and will incorporate the inspection team observations.

C The inspectors identified that the station did not properly evaluate CR 06-12561 for maintenance rule functional failure applicability. The inspectors identified through review of CR 06-12561 that the station had properly evaluated a battery charger failure for operability aspects; however, the station did not evaluate this CR for maintenance rule functional failure aspects. The station issued CR 06-15447 and evaluated the maintenance rule functional failure aspects for this specific battery charger failure.

The inspectors found that the cause analyses reviewed were thorough and appropriately considered extent of condition, generic issues, and previous occurrences. CROG reviews were detailed and ensured that corrective actions addressed the identified causes. For significant conditions adverse to quality, the station identified corrective actions to prevent recurrence.

Effectiveness of Corrective Actions No findings of significance were identified in the area of effectiveness of corrective actions.

The team concluded that identified corrective actions were generally appropriate to resolve identified issues, and were typically completed in a timely manner. However, one weakness was noted with respect to effectiveness of long-term corrective actions:

C During the review of CR 06-09995, inspectors identified that a long-term corrective action associated with the nuclear instrumentation (NI) system had been inappropriately changed. The NI system had a previous maintenance rule a(1)improvement plan, and associated corrective actions, to improve and maintain the system in good condition. One of those long-term corrective actions, intended to maintain the system in good condition, shortened the frequency of detector replacement to every seven years, in accordance with vendor guidance to prevent future detector failures. However, in 2003, a station preventative maintenance (PM)optimization program changed the detector replacement frequency back to 12 years, contrary to the previous expert panel recommendations, and without the stations MR expert panel approval. There was no immediate impact on the NI system due to this PM deferral.

c. Findings

Failure to promptly identify a condition adverse to quality associated with accident analysis assumptions used for an inadvertent ECCS initiation at power event.

Introduction:

The inspectors identified a green, non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that, FPL failed to promptly identify a condition adverse to quality associated with a discrepancy between implementation of EOPs and design analysis assumptions used for the licensing basis in the stations stretch power uprate.

Description:

During March 2004, FPL Seabrook submitted an application to the NRC containing an amendment request for a stretch power uprate that would increase reactor power by 5.2 percent. During this amendment technical review, the NRC requested additional information regarding selected technical issues, including FPLs analysis of the inadvertent ECCS initiation at-power event. FPL supplied supplemental information by letter SBK-05054, dated February 25, 2005 (ML050610159). NRC accepted the information and approved the stretch power uprate, dated February 28, 2005 (ML050140453), based on the Interim Design Analysis and a license condition to be addressed by the station the next refueling outage. This interim analysis described FPLs method to terminate an inadvertent ECCS initiation event which was based on time-critical operator actions to secure high head injection. Seabrook operator actions credited for termination of the inadvertent ECCS initiation event were not consistent with NRC review criteria of the ECCS termination event. Specifically, the NRC accepted criteria for termination of the event is considered no net mass injection into the reactor coolant system (RCS) and the station incorrectly assumed that operator actions to terminate high head injection were the only necessary steps to event termination.

Prior to FPL submitting the Interim Analysis, Seabrook Station, in December 2004, had previously closed CR 04-09310 that identified a weakness with respect to tracking time critical operator actions and ensuring the station was able to meet all credited operator actions with respect to its design basis. FPL created an engineering evaluation, EE 04-024, Time Critical Operator Responses, that described all credited operator actions including an inadvertent ECCS initiation event. In this evaluation, station engineering appropriately documented termination criteria that included operator actions for securing injection and establishing letdown for the ECCS initiation at-power event.

The station, however, never applied the station engineering information to the power uprate application and failed to verify existing EOPs and training sessions were consistent with this engineering evaluation.

While operating at uprated power during the Interim Analysis period in June 2005, operator crew simulator performance testing and response times for inadvertent ECCS at-power events were greater than assumed for operator time critical tasks. There was no condition report issued at this time nor is it evident that the operations staff was aware of or trained on the appropriate termination criteria that had been identified in the engineering evaluation dated December 2004.

During September 2005, the station oversight group identified the potential issue of an incorrect ECCS termination criteria that could place the station outside its licensing basis while operating under an interim analysis. The station did conclude that the wrong ECCS termination criteria had been used for the Interim

Analysis.

However, FPL did not address potential reportability aspects while operating under the Interim Analysis nor identify and address ineffective corrective actions associated with the issue.

The inspectors determined that FPLs failure to promptly identify the incorrect ECCS inadvertent design analysis assumption was a performance deficiency that warranted a significance evaluation.

Analysis:

The difference between implementation of the EOPs during an inadvertent ECCS initiation at-power event and the interim analysis assumptions had the potential to place the plant outside its accepted licensing basis. It was reasonable that FPL should have identified and corrected this deficiency as several opportunities were available prior to and while operating under an interim design analysis during the first operating cycle of the stretch power uprate period. Traditional enforcement does not apply since there were no actual safety consequences or potential for impacting the NRCs regulatory function, and the finding was not the result of any willful violation of NRC requirements or FPLs procedures.

The inspectors determined that this finding was more than minor because it was associated with the design control attribute of the Initiating Events cornerstone, and impacted the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. The finding is also similar to more than minor examples in MC 0612, Appendix E, examples 3.j and 3.k. Specifically, the failure to promptly identify a disconnect between existing EOPs and a design assumption for an inadvertent SI actuation event had the potential to challenge the stations ability to prevent the pressurizer from going water solid and creating a more significant operating event. Additional evaluation by the station determined that the issue remained with design basis conclusions and did not meet NRC reportability thresholds during the interim analysis time period. The station updated EOPs and the ECCS inadvertent actuation analysis. Inspectors evaluated this finding using Phase 1 of IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, and determined the finding to be of very low safety significance (Green) because it; did not affect loss of coolant accident initiators; did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available; and did not increase the likelihood of an external event.

Enforcement:

10 CFR 50 Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, and nonconformances are promptly identified and corrected. Contrary to this, from mid-2004 until late 2005, FPL failed to promptly identify a condition adverse to quality associated with a disconnect between existing EOPs and ECCS termination criteria used for an inadvertent ECCS at-power actuation analysis.

Consequently, during the interim design analysis credited per an NRC Safety Evaluation Report, FPL operated outside the credited analysis assumptions and challenged design basis conclusions. Because this issue is of very low safety significance and has been entered into the FPLs corrective action program (CR 06-15363), this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 05000443/2006006-01, Failure to promptly identify incorrect analysis assumptions used for an inadvertent ECCS initiation at-power event.)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team reviewed a sample of operating experience (OE) issues for applicability to Seabrook station and FPLs associated actions for those issues. Inspectors reviewed various documents to ensure that underlying problems associated with each issue were appropriately considered for resolution in accordance with the corrective action process.

The team also reviewed a sample of action plans for maintenance rule a(1) systems, to see how operating experience was being implemented in the maintenance rule program.

b. Assessment and Findings No findings of significance were identified in the area of operating experience.

The inspectors found that the station appropriately considered operating experience information for applicability, and took corrective and preventive actions as needed. The responsible site personnel screened OE issues from various sources for applicability to Seabrook and wrote CRs for additional reviews and corrective actions as necessary.

Operating experience information was integrated into site routine activities, such as training materials and plant procedures.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of corrective action assessment audits, including the most recent audit of the CAP, CAP trend reports, Quality Assurance audits, departmental self-assessments, and assessments conducted by independent organizations. A specific list of documents reviewed is included in the attachment to this report.

Inspectors performed these reviews to determine if FPL entered problems identified through these assessments into the CAP, when appropriate, and whether FPL initiated corrective actions to address identified deficiencies. Inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified findings and observations made during the inspection.

The team also reviewed the 2005 FPL safety conscious work environment (SCWE)survey results, dated September 2005, and the station SCWE corrective action plan.

This was a FPL fleet-wide survey followed up by Seabrook station-specific corrective actions.

b. Assessment and Findings No findings of significance were identified.

The team observed that from the samples reviewed, overall, audits and assessments were critical and appropriate actions were taken to address identified issues.

Additionally, the inspection team did not identify any results that were inconsistent with the survey results and the stations SCWE corrective action plan.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews and discussions with station personnel, the team assessed the SCWE at Seabrook station. Specifically, the inspectors assessed whether workers were willing to enter issues into the corrective action program or raise safety concerns to their management and/or the NRC. The inspectors conducted individual interviews and held discussions with staff and supervisors regarding use of the corrective action program, work processes, and other problem identification and resolution activities. The team reviewed the Seabrook Employee Allegation and Resolution (EAR) program to determine if employees were aware of the program and were using it to raise concerns.

The team also reviewed a sample of the EAR files to ensure that issues were entered into the corrective action program.

b. Assessment No findings of significance were identified.

The team determined that the plant staff was aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised, or knew of anyone who had failed to raise issues. All persons interviewed had an adequate knowledge of the CAP and EAR.

The threshold for entering concerns in the program appeared appropriate and the program administrator willing accepted not only safety concerns but also other work place concerns. Based on these reviews and interviews, the team concluded that there was no evidence of an unacceptable SCWE.

4OA6 Meetings, including Exit

Exit Meeting Summary

On December 7, 2006, the team presented the inspection results to Mr. Gene St. Pierre, Seabrook Site Vice President, and other members of the staff, who acknowledged the findings. The inspectors confirmed that no proprietary information reviewed during inspection was retained by the team.

ATTACHMENT: Supplemental Information

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. St. Pierre - Site Vice President

J. Peschel - Regulatory Programs Manager

M. DeBay - Oversight Manager

M. Ossing - Engineering Support Manager

J. Sobotka - Performance Improvement Manager

A. Chesno - Technical Maintenance Manager

K. Douglas - Work Process Manager

R. White - Security Supervisor

G. Kotkowski - Electrical Design Supervisor - Design Engineering

V. Robertson - Nuclear Analyst

S. Hale - Project Manager

T. Pucko - Engineering Support

A. Paliulis - Mechanical Engineering

G. Kilby - Regulatory Compliance

R. Guthrie - System Engineering

J. Ball - Maintenance Rule Program Coordinator

K. Fox - System Engineering

J. Johnson - System Engineering

J. Finnigan - Operations

R. Jamison - Fire Protection Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

050000443/2006006-01 NCV 10 CFR 50, Appendix B, Corrective Actions, Failure to promptly identify incorrect analysis assumptions used for an inadvertent ECCS initiation at-power event.