IR 05000443/2007002
| ML071300506 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/10/2007 |
| From: | Arthur Burritt Reactor Projects Branch 3 |
| To: | St.Pierre G Florida Power & Light Energy Seabrook |
| Burritt A | |
| References | |
| IR-07-002 | |
| Download: ML071300506 (33) | |
Text
SUBJECT:
SEABROOK STATION - NRC INTEGRATED INSPECTION REPORT 05000443/2007002
Dear Mr. St. Pierre,
On March 31, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Nuclear Power Station. The enclosed report documents the inspection results which were discussed on April 10, 2007, with you and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The report documents one NRC-identified finding of very low safety significance (Green). This finding was determined to not involve a violation of NRC requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and 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 (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Arthur L. Burritt, Chief Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86 Enclosure: Inspection Report No. 05000443/2007002 w/ Attachment: Supplemental Information
Mr. Gene S
SUMMARY OF FINDINGS
IR 05000443/2007002; 1/1/2007-3/31/2007; Seabrook Station, Unit 1; Identification and
Resolution of Problems.
The report covered a 13-week period of inspection by resident inspectors and announced inspections by regional health physics . One Green finding was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
C
- Green.
The inspectors identified a finding for Seabrook not adequately evaluating and taking corrective actions to ensure the ability of alternate water sources to provide cooling to the charging pump lube oil coolers. Seabrook did not perform confirmatory tests or develop an engineering basis for acceptability of the system following initiation of condition reports in 2004 and 2005, which documented concerns with the testing and ability of the alternate cooling water system to perform its Updated Final Safety Analysis Report function. In October 2006, the alternate cooling system failed to function due to rust buildup on the discharge check valves which prevented the valves from opening. This did not violate NRC regulations because the alternate cooling system is not safety-related.
This finding was more than minor because it affected the Mitigating Systems cornerstone attribute of equipment performance and the objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. The risk significance was determined through a detailed assessment. The finding was determined to be of very low safety significance (Green) since the inability to implement alternate cooling water would not increase the chance of core damage. The finding has a cross-cutting aspect in the area of problem identification and resolution because Seabrook did not properly evaluate a known deficiency associated with the alternate cooling water system.
Licensee-Identified Violations
None.
iii
REPORT DETAILS
Summary of Plant Status
The plant began the period at rated thermal power and operated at or near full power for the entire report period except for two unplanned power reductions. On January 25, 2007, operators reduced power to 18 percent and took the turbine generator offline to complete maintenance on a rupture disk on Zone 4 of the switchyard SF6 system. Seabrook returned to 100 percent power on January 26, 2007. On March 17 through March 30, Seabrook operated at reduced power (96 to 99 percent) due to elevated temperatures on the generator neutral bus.
On March 30, 2007, Seabrook reduced power to 8 percent and took the turbine generator offline in order to replace the generator neutral bus.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 1 Sample)
a. Inspection Scope
The inspectors reviewed Seabrooks preparation for adverse weather relative to the protection of the electrical switchyard from cold weather. On January 25, 2007, the inspectors reviewed actions taken following a cold weather issue that resulted in unplanned downpower of the plant (see Section 4OA3 for details). The inspectors reviewed corrective actions to the problem, examined extent of condition reviews, and conducted walkdowns of the switchyard. The inspectors reviewed the following condition reports (CR) 07-01860, 07-01278, 07-01399, 07-01533, and 07-01422. The inspectors reviewed deficiencies identified during Seabrook extent of condition walkdowns, and verified these deficiencies were entered into the corrective action program.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Full System Walkdown - Main Steam System (71111.04S - 1 Sample)
a. Inspection Scope
The inspectors conducted a detailed review of the alignment and conditions of the main steam system. The inspectors performed a walkdown to verify the system alignment was maintained in accordance with system drawings and procedures. Control room indications were verified to be appropriate and consistent with Technical Specification requirements and the Updated Final Safety Analysis Report (UFSAR). The inspectors reviewed and evaluated the potential impact on system operation from open work orders, condition reports, and tagged equipment. System health reports were reviewed, verified during the walkdown, and discussed with the system engineer. Documents reviewed are listed in the attachment.
b. Findings
No findings of significance were identified.
.2 Partial System Walkdowns (71111.04Q - 3 Samples)
a. Inspection Scope
The performed the following partial system walkdowns:
C On February 15, 2007, the B train of the charging system while the A train was out-of-service for maintenance on the A charging pump and supply breakers.
C On February 20, 2007, the B train of the residual heat removal (RHR) system while the A emergency diesel generator (EDG) was out-of-service for maintenance. The A EDG provides power to the A RHR system in the event of a loss of offsite power.
C On March 27, 2007, the feedwater system prior to the main generator outage.
The feedwater system was reviewed based on the challenge to the system during the transition from 100 percent power operation to 8 percent power operation.
The inspectors conducted a walkdown of each system to verify that the critical portions of the systems, such as valve positions, switches, and breakers, were correctly aligned in accordance with Seabrook's procedures and to identify any discrepancies that may have had an effect on operability. The inspectors reviewed applicable piping and instrumentation drawings and operational lineup procedures to support the walkdowns and verify proper system alignment. Documents reviewed are listed in the attachment.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
(71111.05Q - 11 Samples)
The inspectors examined several areas of the plant to assess: 1) the control of transient combustibles and ignition sources; 2) the operational status and material condition of the fire detection, fire suppression, and manual fire fighting equipment; 3) the material condition of the passive fire protection features (fire doors, fire dampers, fire penetration seals, etc.); and 4) the compensatory measures for out-of-service or degraded fire protection equipment. The following areas were inspected:
C Control Building Essential Switchgear Rooms Train B, 21' -6".
C Control Building Essential Switchgear Rooms Train A, 21' -6".
C Turbine Building Relay Room, Ground Floor.
C Electrical Tunnel Train A, 0'.
C Electrical Penetration Room Train A, 0'.
C Electrical Tunnel Train B, -26'.
C Electrical Penetration Room Train B, -26'.
C Residual Heat Removal (RHR) A & B Rooms, - 61'.
C Safety Injection Pump A & B Rooms, - 50'.
C Main Steam Feedwater Pipe Chase - West, All elevations.
C Main Steam Feedwater Pipe Chase - East, All elevations.
The verified that the fire areas were maintained in accordance with applicable portions of Fire Protection Pre-Fire Strategies and Fire Hazard
Analysis.
Documents reviewed are listed in the attachment.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures (71111.06 - 1 Sample)
a. Inspection Scope
The reviewed the external flood protective features at the site. The conducted walkdowns of the external structures including the vertical concrete seawall, sheet pile retaining wall, and the stone revetment. The assessed the design against Seabrooks UFSAR and other design basis documents. The reviewed previous inspections and the periodic surveillance procedure. The compared the as-found conditions to ensure that the structures remained able to perform the design basis function. Documents reviewed are listed in the attachment.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Resident Inspectors Review (71111.11Q - 1 Sample)
a. Inspection Scope
The observed the conduct of licensed operators during a simulator training session on March 19, 2007. The reviewed the simulators physical fidelity in order to verify similarities between the Seabrook control room and the simulator. The examined the operators ability to perform actions associated with high-risk activities, the Emergency Plan, previous lessons learned items, and the correct use and implementation of procedures. The observed the training evaluators critique of the operators performance and verified that deficiencies were adequately identified, discussed, and entered into the corrective action program. Documents reviewed are listed in the attachment.
b. Findings
No findings of significance were identified.
.2 2006 Annual Review of Testing Results
a. Inspection Scope
On January 23, 2007, regional conducted an in-office review of licensee annual operating test results for 2006. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process" (SDP). The verified that:
- Crew failure rate was less than 20%. (Crew failure rate was 0%.)
- Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Individual failure rate was 0%.)
- Individual failure rate on the walk-through test was less than or equal to 20%.
(Individual failure rate was 0%.)
- Overall pass rate among individuals for the operating test was greater than or equal to 75%. (Overall pass rate was 100%.)
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
(71111.12Q - 2 Samples)
The inspectors completed two maintenance rule (MR) samples reviewing specific issues associated with failures of a remote safe shutdown indication and a main steam isolation valve.
The inspectors reviewed the application of the MR for the failure of the valve control module card for a main steam isolation valve (MS-V-88). The failure occurred June 30, 2006. The corrective action aspect of these failures was described in NRC Inspection Report 05000443/2006004. The inspectors specifically examined the maintenance preventable functional failure (MPFF) evaluation against the guidance in NUMARC 93-01, "Industry Guideline for Monitoring the effectiveness of Maintenance at Nuclear Power Plants," Revision 2.
The inspectors reviewed the evaluation of a March 2007 failure of a remote safe shutdown steam generator level transmitter. The inspectors reviewed the MPFF evaluation (CR 07-04321), examined troubleshooting and maintenance activities, and interviewed the system engineer to determine work history and industry operating experience. This information was evaluated against the guidance in NUMARC 93-01.
Based on issues identified in the review of the documents, the inspectors also assessed: 1) the application for MR scoping and MR reliability/availability performance criteria; 2) the corrective actions for deficient conditions; 3) the extent-of-condition reviews for common cause issues; and 4) the contribution of deficient work controls or work practices to any degraded conditions.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13 - 7 Samples)
a. Inspection Scope
The inspectors reviewed the scheduling and control of three planned maintenance activities and four emergent work troubleshooting activities in order to evaluate the effect on plant risk. The inspectors conducted interviews with operators, risk analysts, maintenance technicians, and engineers to assess their knowledge of the risk associated with the work, and to ensure that other equipment was properly protected.
The compensatory measures were evaluated against Seabrook procedures, Maintenance Manual 4.14, "Troubleshooting, Revision 0 and Work Management Manual 10.1, "On-Line Maintenance," Revision 3. Specific risk assessments were conducted using Seabrook's "Safety Monitor." The inspectors reviewed the following items.
C On January 16, 2007, the inspectors reviewed the troubleshooting efforts in response to the unplanned tripping open of switchyard breaker 11. The inspectors observed work activities conducted using WO 0702084 and reviewed the emergent risk assessment.
C On January 25, 2007, the inspectors reviewed the troubleshooting efforts in response to loss of SF6 pressure in Zone 4 of the switchyard. The inspectors reviewed the MA 4.14 troubleshooting control form and attended troubleshooting team meetings. The inspectors also reviewed work activities conducted using WO 0703129 to replace the failed rupture disk.
C During the week of February 12, 2007, the inspectors reviewed the plant risk configuration during planned maintenance on motor control center (MCC) 512.
The inspectors examined the impact of MCC-512 through review of panel failure analysis and electrical prints. The operational compensatory measures were also evaluated.
C On February 20, 2007, the inspectors reviewed the plant risk configuration during planned maintenance on the A emergency diesel generator and surveillances on trip critical nuclear instrumentation. The inspectors also reviewed the evaluation and troubleshooting of emergent issues identified during the emergency diesel generator maintenance.
C On February 21 and 22, 2007, the inspectors reviewed troubleshooting efforts in response to a leak in a four-inch tee on cooling water outlet piping for the A emergency diesel generator. The inspectors followed the troubleshooting efforts and repairs by attending meetings and observing field activities. The inspectors reviewed work activities conducted using WO 0705740.
C On March 13, 2007, the inspectors reviewed the plant risk configuration during planned maintenance on the A residual heat removal system and a switchyard breaker, and surveillances associated with the A vital battery, A residual heat removal pump, and the A emergency diesel generator.
C During March, the inspectors reviewed troubleshooting efforts and operational decision making in response to elevated temperatures on the generator neutral bus. Operators reduced power to minimize the temperature increase. The inspectors monitored the rise in temperature, compensatory measures, and operator instructions.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15 - 3 Samples)
a. Inspection Scope
The inspectors reviewed operability evaluations and/or condition reports in order to verify that the identified conditions did not adversely affect safety system operability or plant safety. The evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary 2005-20, Revision to Guidance formerly contained in NRC Generic Letter 91-18, Information to Licensees Regarding two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability and Inspection Manual Part 9900, "Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety." In addition, where a component was determined to be inoperable, the inspectors verified the Technical Specifications (TS) limiting condition for operation implications were properly addressed. The inspectors performed field walkdowns, interviewed personnel, and reviewed the following items:
C CR 07-00764, which evaluated movement of the stuffing box journal sleeve for service water (SW) pump 41C. Seabrook determined that movement of the journal sleeve would be limited by the shaft coupling. The inspectors assessed the potential impact of the movement and subsequent increased stuffing box leakage.
C CR 07-01454, which evaluated glycol leakage from the A Supplemental Emergency Power System (SEPS) diesel during surveillance testing. The inspectors conducted field walkdowns and reviewed historical glycol additions and operator logs.
C CR 07-02985, which evaluated unexpected additives and wear particles in the A emergency diesel generator (EDG) governor oil. The inspectors reviewed the initial and subsequent oil samples on the A and B EDGs.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing (71111.19 - 6 Samples)
a. Inspection Scope
The inspectors reviewed post-maintenance testing (PMT) activities to ensure: 1) the PMT was appropriate for the scope of the maintenance work completed and in accordance with MA 3.5, "Post Maintenance Testing; 2) the acceptance criteria were clear and demonstrated operability of the component; and 3) the PMT was performed in accordance with procedures. The following PMT activities were reviewed:
C On January 7, 2007, WOs 0617359 and 0700407 following replacement of the inboard and outboard motor bearing for control building air fan 14B. The inspectors reviewed both WOs and maintenance support evaluations (MSE)06MSE096 and 07MSE009 which were implemented to increase motor life.
C On January 24, 2007, OX1436.08, Startup Feed Pump Quarterly Surveillance, Revision 9 following repairs addressing startup feed pump inboard and outboard bearing leaks (WO 0634828).
C On January 25, 2007, WO 0703129, which addressed repairs to two rupture disks associated with SF6 gas zone 4 in the 345kV Switchyard.
C On February 1, 2007, WO 0703637, which repositioned the B charging pump inboard shaft deflector ring.
C On February 22, 2007, WO 0705740, which addressed repairs to a four-inch tee in cooling water piping for the A emergency diesel generator.
C On March 16, 2007, OS1006.04, Operation of the Containment Spray System, Revision 8 following tightening of the bolts of the containment building spray heat exchanger lower flange (WO 0704545).
b. Findings
No findings of significance were identified.
1R20 Refueling and Outage Activities (71111.20 - 1 Sample)
.1 Generator Outage Activities
a. Inspection Scope
The inspectors reviewed operational, maintenance, and scheduling activities prior to and during the March 30, 2007 outage to replace the generator neutral bus. The inspectors evaluated Seabrooks ability to assess and manage risk during the outage. Prior to the outage, the inspectors reviewed the outage plan and the risk assessment of the schedule. The observed the downpower of the plant and the shutdown of the turbine and generator. The inspectors reviewed applicable procedures, observed control room activities, conducted walkdowns and interviewed key personnel. Specific documents reviewed during the inspection are listed in the attachment. The inspectors evaluated the activities against Technical Specifications requirements, Seabrooks procedures, and other applicable requirements.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22 - 6 Samples)
a. Inspection Scope
The inspectors observed portions of surveillance testing activities of safety-related systems to verify that the system and components were capable of performing their intended safety function, to verify operational readiness, and to ensure compliance with required Technical Specifications and surveillance procedures.
The inspectors attended selected pre-evolution briefings, performed system and control room walkdowns, observed operators and technicians perform test evolutions, reviewed system parameters, and interviewed the system engineers and field operators. The test data recorded was compared to procedural and technical specification requirements, and to prior tests to identify any adverse trends. The following surveillance procedures were reviewed.
C On January 18, 2007, OX1426.01, DG 1A Monthly Operability Surveillance, Revision 9.
C On February 9, 2007, IX1680.921, Solid State Protection System (SSPS) Train A Actuation Logic Test, Revision 9.
C On February 23, 2007, RS07-01-01, Main Turbine Control Valve Testing, Revision 0, OX1431.03, Main Control Valve Quarterly Test, Revision 8, OX1431.04, Combined Intermediate Valve Quarterly Cycling Test, Revision 7,and OX1431.02, Main Turbine Stop Valves Quarterly Operability Test, Revision 8.
C On March 5, 2007, OX4101.03, RCS Vent Path Block Valve Quarterly, Cold Shutdown, and 18 Month Surveillance Test, Revision 7.
C On March 20, 2007, OX1461.04, SEPS Monthly Availability Surveillance, Revision 0.
C On March 30, ON1035.11, "Main Feed Pump Return to Standby and Shutdown,"
Revision 7.
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications (71111.23 - 1 Sample)
a. Inspection Scope
The inspectors reviewed temporary modification 07-004 and associated implementing documents to verify Seabrooks design basis and affected system operability were maintained. The temporary modification involved installation of a mechanical device to prevent unplanned opening of a disconnect switch. The disconnect switch was manually closed after failure of the motor operated disconnect to operate. The purpose of the switch is to allow maintenance to be performed on breakers and equipment in the electrical switchyard.
The inspectors interviewed engineers and operators, completed field walkdowns, and reviewed Maintenance Manual, MA 4.3A, Temporary Modifications and Temporary Alterations, Rev. 16. The inspectors verified that the temporary modification was completed in accordance with NRC requirements and plant procedures. The procedural requirements included modifications to plant drawings, tagging of plant equipment affected by the temporary modification, and procedural changes. The inspectors verified 10 CFR 50.59 reviews and 10 CFR 50.65(a)(4) risk evaluations were completed correctly.
b. Findings
No findings of significance were identified.
EMERGENCY PREPAREDNESS 1EP6 Drill Evaluation (71114.06 - 2 Samples)
.1 Combined Function Drill
a. Inspection Scope
On March 14, 2007, the inspectors observed combined function drill 07-01, to evaluate the conduct of the drill and adequacy of Seabrook's post-drill critique. The inspectors verified that event classifications and notifications were properly conducted in accordance with NEI 99-02, "Regulatory Assessment Indicator Guideline," Revision 4 and Seabrook's Emergency Response Manual 1.1, "Classification of Emergencies,"
Revision 43. The inspectors observed the technical support center to ensure that priorities were appropriately identified and communicated. The inspectors also verified that identified drill performance problems were entered into the corrective action program through observation of the critique, review of the drill evaluation report, interviews of applicable drill participants, and review of condition reports initiated.
b. Findings
No findings of significance were identified.
.2 Classification and Notification during Requalification Training
a. Inspection Scope
The inspectors reviewed the operators' emergency classification and notification completed during requalification training on March 19, 2007 (See Section 1R11). The inspectors evaluated the results against Seabrook's Emergency Response Manual 1.1, "Classification of Emergencies," Revision 43 and NEI 99-02.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety (OS)
2OS1 Access to Radiologically Signifcant Areas (71121.01 - 11 samples)
a. Inspection Scope
During the period March 5 through 8, 2007, the inspectors conducted the following activities to verify that Seabrook was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas, and other radiologically controlled areas (RCA) during normal power operations, and that workers were adhering to these controls when working in these areas. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, Seabrook Technical Specifications, and Seabrooks procedures.
This activity represents the completion of 11 samples relative to this inspection area partially completing the annual inspection requirement of 21 samples.
Plant Walkdown and RWP Reviews
- (1) The inspectors toured accessible radiologically controlled areas and, with the assistance of a radiation protection technician, performed independent radiation surveys of selected areas and components, to confirm the accuracy of survey data, and the adequacy of postings. Surveys were conducted in the Primary Auxiliary Building (PAB), Waste Processing Building (WPB), Residual Heat Removal Vaults, and Fuel Storage Building.
- (2) The inspectors identified plant areas where radiologically significant work activities were being performed. These activities included scaffolding erection in the (-) 26' mechanical penetration area of the PAB, and various maintenance tasks in the Containment Building. The inspectors reviewed applicable RWPs for these activities, RWP 07-002 and RWP 07-0010; respectively, and the electronic dosimeter dose/dose rate alarm set points, for the associated tasks, to determine if the radiological controls were acceptable and if the setpoints were consistent with plant policy.
- (3) There were no significant dose gradients requiring relocation of dosimetry for the radiologically significant jobs reviewed during this inspection.
- (4) There were no current radiation work permits for airborne radioactivity areas with the potential for individual worker internal exposures of > 50 mrem.
- (5) During 2006, there were no internal dose assessments for any actual internal exposures greater than 50 mrem Committed Effective Dose Equivalent (CEDE).
The reviewed selected CEDE dose assessments for 2006; no CEDE exceeded 10 mrem. The inspectors also reviewed assessments for shallow dose equivalents (SDE) and total effective dose equivalents (TEDE), and determined that no exposure exceeded regulatory criteria.
Problem Identification and Resolution
- (6) A review of Nuclear Oversight assessment reports and daily summary reports was conducted to determine if identified problems were entered into the corrective action program for resolution.
- (7) 13 condition reports, associated with radiation protection control access, initiated between October 1, 2006 and March 5, 2007, were reviewed and discussed with Seabrook staff to determine if the follow-up activities were being conducted in an effective and timely manner, commensurate with their safety significance.
High Radiation Area and Very High Radiation Area Controls
- (8) Procedures for controlling access to High Radiation Areas (HRA) and Very High Radiation Areas (VHRA) were reviewed to determine if the administrative and physical controls were adequate. Included in the review was Health Physics Study/Technical Information Document (HPSTID 97-001) entitled, "Interpretation of Floor Plugs as being "Locked".
- (9) Keys to locked high radiation areas (LHRA) were inventoried and accessible LHRAs were verified to be properly secured and posted during plant tours.
Radiation Worker and Radiation Protection Technician Performance
- (10) Several radiologically related condition reports (see Section 4OA2) were reviewed to evaluate if the incidents resulted from repetitive worker errors with similar causes.
- (11) Radiation Protection Technicians and radworkers were questioned regarding their knowledge of plant radiological conditions and associated controls.
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls (71121.02 - 9 samples)
a. Inspection Scope
During the period March 5 through 8, 2007, the inspectors conducted the following activities to verify that the licensee was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as is reasonably achievable (ALARA) for past activities performed during the fall 2006 refueling outage (OR11). Also, reviewed were the dose controls for current activities and the forecasted dose during power operations for 2007. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Seabrooks procedures.
Radiological Work Planning
- (1) The inspectors reviewed pertinent information regarding cumulative exposure history, current exposure trends, and ongoing activities to assess past (2006)outage (OR-11) performance and dose challenges for 2007.
- (2) The inspectors reviewed the exposure data for tasks performed during the fall 2006 outage and compared actual exposure with forecasted estimates contained in job ALARA reviews (AR). Outage jobs included Reactor Disassembly/Reassembly (AR 06-01), steam generator eddy current testing (AR 06-02), scaffolding installation/removal (AR 6-11), split pin replacement project (AR 06-13), reactor head bare metal inspections (AR 06-14), and ECCS sump modifications (AR 06-15).
- (3) The inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by attending a weekly work planning meeting for radiologically significant tasks and a pre-job briefing for a containment building entry, reviewing recent Radiation Safety Committee meeting minutes, post-job ALARA reviews, Nuclear Oversight Department field observation reports, and interviewing the ALARA coordinator.
The inspectors attended the pre-job briefing for an at power containment entry on March 7, 2007, to conduct various maintenance tasks.
The inspectors also reviewed the Radiation Protection Department Continuous Improvement Initiative that identifies areas for further improvement of radiological controls.
Verification of Dose Estimates
- (4) The inspectors reviewed the assumptions and basis for the annual (2007) site collective exposure projections for routine power operations.
- (5) The inspectors reviewed Seabrooks procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks differed from the actual dose received. The inspectors reviewed the dose/dose rate alarm reports and exposure data for selected individuals receiving the highest TEDE, CEDE, and SDE exposures for 2006 to confirm that no individual exposure exceeded the regulatory limit, or met the performance indicator reporting guideline.
Jobs-In-Progress
- (6) The inspectors observed the pre-job briefing for a containment building entry, on 03/07/2007, in which various maintenance activities were to be performed. The inspectors reviewed the RWP (#07-010) and various visual aids used for communicating the radiological/industrial safety controls applied to containment entries during power operations.
- (7) The inspectors reviewed recent ALARA Evaluations (AE) developed for controlling low dose tasks. Included in this review were AEs for surveying radioactive material shipping boxes, inspecting the letdown valve room for leakage, performing visitor tours in the RCA, and inspecting drain header tailpieces for leakage.
Declared Pregnant Workers
- (8) The inspectors reviewed the procedural controls for managing declared pregnant workers (DPW) and determined that no DPWs were employed at the site since the last inspection of this area in October 2006.
Problem Identification and Resolution
- (9) The inspectors reviewed five
- (5) condition reports related to controlling individual personnel exposure and programmatic ALARA challenges to determine if problems were being entered into the corrective action program for timely resolution. Details of this review are contained in Section 4OA2 of this report.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151 - 4 Samples)
a. Inspection Scope
The inspectors sampled Seabrook submittals for the performance indicators (PIs) listed below for the period from April 2006 through December 2006. PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline, Revision 4, were used to evaluate the accuracy and basis in reporting for each data element.
Initiating Events Cornerstone C Unplanned Scrams per 7,000 Critical Hours C Unplanned Scrams with Loss of Normal Heat Removal C Unplanned Power Changes per 7,000 Critical Hours Mitigating Systems Cornerstone C Safety System Functional Failures The inspectors reviewed plant records such as Licensee Event Reports (LERs),operating logs, procedures, and interviewed applicable Seabrook personnel to verify the accuracy and completeness of Seabrook's PI data.
4OA2 Identification and Resolution of Problems
.1 Routine Condition Report Screening
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the Seabrooks corrective action program. This review was accomplished by accessing Seabrook's computerized database.
b. Findings
No findings of significance were identified.
.2 (Closed) Unresolved Item (URI) 50-443/2006-005-03, Testing of the Alternate Supply of
Water to the Primary Component Cooling System
a. Inspection Scope
The inspectors completed review of Unresolved Item 50-443/2006-005-03, Testing of the alternate supply of water to the primary component cooling system, which was initiated after a review of CR 06-12990 related to the inability to establish alternate cooling to the lube oil coolers for the centrifugal charging pumps (CCPs) during the Fall 2006 outage. Specifically, the CR noted that alternate cooling from the demineralized water (DM) system could not initially be established to the A CCP; subsequently, the DM supply to the B CCP was tested as part of the extent of condition review and similar results were noted. Alternate cooling to both CCPs was eventually established after mechanical agitation of the associated discharge check valves. The issue was left unresolved until Seabrook completed the flow tests for the other sources of alternate cooling, and had completed the causal evaluation. For this inspection, the reviewed the final test results, the causal evaluation, and the accompanying corrective actions.
b. Findings
Introduction:
The inspectors identified a finding of very low safety significance (Green)in that Seabrook did not adequately evaluate and take corrective actions to ensure the ability of alternate cooling water sources to provide cooling to the CCP lube oil coolers.
Description:
The primary component cooling water (PCCW) system is the normal cooling supply for safety-related components, including the CCP lube oil coolers. In 1999, Seabrook completed a design change to provide addition cooling sources for the CCP lube oil coolers. The Seabrook Updated Final Safety Analysis Report (UFSAR),
Section 9.2.2 was revised and states that for increased reliability the DM system and the fire protection (FP) systems can be cross-connected to the PCCW system to make up for leaks from the PCCW system and to specifically provide cooling to the CCP lube oil coolers. Following a seismic event, the cross-connect is backed up by the seismic Category I SW system, using the seismic qualified portion of the FP system.
In October 2006, the DM portion of the alternate cooling system failed to function.
Seabrook concluded that the cause was rust buildup on the discharge check valves which prevented the valves from opening. Failure of these check valves prevents alternate cooling of the CCP lube oil coolers from the SW and FP systems. Therefore, the alternate cooling system could not perform its USFAR described function.
Seabrook had opportunities to identify and correct this degraded condition. In 2004, CR 04-04715 identified that the cross-connect valve between the SW and FP systems (SW-V-120) had never been cycled to determine whether the valve would operate in an emergency situation. The corrective action for this CR was narrow and only focused on operation of the valve instead of verifying the flow path. In 2005, the inspectors raised questions about the need to periodically test the alternate cooling system to the charging pumps. Seabrook initiated a CR (05-11694) and determined that testing was unnecessary based, in part, on the fact that the cross-connect was not safety-related and that the DM valves (the first choice for alternate cooling) had very little chance of corrosion since they were stainless steel and the medium was demineralized water.
The inspectors determined that the evaluation was narrowly focused because it did not fully evaluate the need to test the UFSAR described function of the alternate cooling system.
In response to the October 2006 failure and additional inspectors concerns, Seabrook repaired the discharge check valves and completed tests demonstrating the functionality of the alternate cooling flow paths from the SW system to the A and B CCP lube oil coolers. In addition to the corrective actions already described, Seabrook plans to develop a surveillance procedure to routinely test the alternate cooling flow paths and to review design changes over the last three years to identify any similar conditions that require a routine surveillance.
Seabrooks corrective program in Operating Experience Manual (OE) 2.1,Overview of the Corrective Action Program, Revision 58 states that unexpected or unwanted conditions shall be analyzed and evaluated to identify, understand and correct latent conditions that are precursors of significant conditions that would affect safety and reliability. The performance deficiency is that Seabrook failed to adequately evaluate and take corrective actions in accordance with their program requirements to prevent the unavailability of the alternate cooling water system. Specifically, Seabrook did not properly evaluate and implement adequate actions following initiation of CRs (CR 04-04715 and CR 05-11694) which documented concerns with the testing and ability of the alternate cooling water system to provide cooling to the CCP lube oil coolers.
Analysis:
This finding was more than minor because it affected the Mitigating Systems cornerstone attribute of equipment performance and the objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences.
This issue was determined to be of very low safety significance per Inspection Manual Chapter (IMC) 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations (SDP). The inspectors conducted a SDP phase 2 evaluation because the phase 1 screening determined the finding represented a loss of alternate cooling to the CCP lube oil coolers. This loss of alternate cooling would prevent CCP operation in the high pressure coolant injection mode in the event of a loss of PCCW or service water. A NRC Region 1 senior reactor analyst (SRA) conducted a SDP phase 3 analysis because the phase 2 evaluation determined the finding could be significant. The Region I Senior Reactor Analyst (SRA) conducted a Phase 3 analysis because the Phase 2 analysis indicated that the finding could be significant.
The SRAs phase 3 analysis determined that the success criteria used to develop the Phase 2 notebook was based on the licensees PRA model. That model assumed that a complete loss of PCCW or SW resulted in a probability of a reactor coolant pump (RCP) seal loss of coolant accident (LOCA), with magnitudes ranging from small (84 gpm), to medium (728 gpm), or to large (1920 gpm). The licensees model and the Phase 2 notebook assumed core damage could be prevented within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for small and some medium RCP seal LOCAs, if alternate cooling was supplied and a charging pump started, without recovery of the PCC or SW. The Phase 2 notebook success criterion was different from the NRCs Seabrook Standardized Plant Analysis Review (SPAR) model criteria. The SPAR model would not allow success unless PCC or SW were recovered, to allow long term decay heat removal through high pressure recirculation. As such the alternate cooling was not included in the SPAR model.
Based on this review, the SRA determined that this issue was of very low safety significance (Green) because, based on the Seabrook SPAR model success criteria, the inability to implement alternate cooling would not have increased the chance of core damage.
The finding has a cross-cutting aspect in the area of problem identification and resolution because Seabrook did not properly evaluate a known deficiency associated with the alternate cooling water system. Specifically, Seabrook did not perform confirmatory tests or develop an engineering basis for acceptability of the system following initiation of CRs 04-04715 and CR 05-11694 which documented concerns with the testing and ability of the alternate cooling water system to provide cooling to the CCP lube oil coolers.
Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as FIN 05000443/2007002-01, Inadequate Evaluation of a Deficiency with the Alternate Cooling Water System to the Charging Pumps.
Enforcement:
This performance deficiency did not violate NRC regulations because the alternate cooling system is not safety-related. Consequently, enforcement action does not apply. This finding was of very low safety significance (Green) and has been entered into the Seabrook corrective action program (CR 06-15112).
.3 Access Controls and ALARA Planning and Controls
a. Inspection Scope
The inspectors reviewed the items listed below to evaluate the threshold for identifying, evaluating, and resolving radiological issues. This review was conducted against the criteria contained in 10 CFR 20, Technical Specifications, and the licensees procedures.
- 13 CRs related to access control to radiologically significant areas.
- 5 CRs related to ALARA program implementation.
- 2 nuclear oversight department quality reports.
- nuclear oversight daily quality summary reports generated between October 1, 2006 and March 5, 2007.
- a dosimetry abnormality occurrence.
b. Findings
No findings of significance were identified.
.4 Security Equipment
a. Inspection Scope
(71152 - 1 Sample)
The inspectors reviewed the actions taken by Seabrook to identify the cause(s) and effects of several issues on a portion of the assessment system that have been occurring since installation in October of 2005. The majority of the issues have been associated with the use of a specific feature of the system. The inspectors reviewed various condition reports, site operating procedures and the most recent system testing results to assess if corrective actions were taken and/or planned to correct identified problems. Additionally, the inspectors conducted interviews with plant personnel, including security, instrumentation and control, and engineering, and walked down the system in the impacted locations. The inspectors reviewed logs and the nuisance rate data for the 23 day period of February 12, 2007, through March 6, 2007. Finally, the inspectors reviewed additional condition reports written by Seabrook before and during the inspection to ensure they adequately captured the problems identified.
b. Findings and Observations
No findings of significance were identified. The licensee has assigned a designated system engineer to lead a system optimization team. The system has undergone extensive evaluation, and adjustments to compensate for environmental impacts, and this has provided some positive results. The optimization team has also engaged vendor technician support to assist in system optimization. Finally a procedure has been developed to assist in decision making by the system end users during periods of elevated nuisance rates. The inspectors determined that the root cause evaluation and corrective actions were appropriate.
4OA3 Event Follow-Up (71153 - 3 Samples)
.1 Reactor Down Power to 18%
a. Inspection Scope
As reported above in section 1R01, Adverse Weather Protection, on January 25, 2007, operators reduced reactor power to less than 18 percent power and maintained it between 16 and 18 percent power to allow the turbine to be taken offline. This was done to facilitate repairs to Zone 4 of the switchyard while ensuring worker safety. The inspectors observed the operators preparations for the downpower, the reduction in power, taking the turbine-generator offline, synchronizing the turbine-generator to the electric grid, and the return to full power. The inspectors verified that all plant power changes were completed in accordance with Seabrook procedures. The following documents were reviewed:
C OS1000.06, Power Decrease, Revision 06.
C ON1031.03, Turbine Generator Shutdown, Revision 05.
C ON1031.02, Starting and Phasing the Turbine Generator, Revision 06.
C OS1000.05, Power Increase, Revision 06.
b. Findings
No findings of significance were identified.
.2 (Closed) LER 05000443/2006006-00 and LER 05000443/2006006-01, Plant Shutdown
Due to Inoperable Diesel Generators The inoperable emergency diesel generators were previously reviewed and documented in NRC Inspection Report 0500443/2006016 as a non-cited violation of very low safety significance (Green). The inspectors reviewed the accuracy of the licensee event reports (LERs) and verified compliance with the reportability requirements in 10 CFR 50.73 and NUREG 1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, Revision 2. No additional findings of significance were identified. These LERs are closed.
4OA5 Other Activities
Independent Spent Fuel Storage Installation Inspection
a. Inspection Scope
(60853)
The inspectors reviewed engineering design documents and supporting calculations associated with the design and construction of the Seabrook Independent Spent Fuel Storage Installation (ISFSI) pad. The inspectors discussed design specifications with cognizant personnel and the basis for various design parameters. The inspectors verified that the design and construction details for the ISFSI pad are bounded by the design parameters for the dry cask storage system selected for use at Seabrook.
b. Findings
No findings of significance were identified.
4OA6 Meetings, including Exit
Exit Meeting Summary
The inspectors presented the inspection results to Mr. G. St. Pierre on April 10, 2007, following the conclusion of the period. The licensee acknowledged the findings presented. None of the information reviewed by the s was considered proprietary.
Site Management Visit On March 29, 2007, Ms. Marsha Gamberoni, Deputy Director, Division of Reactor Safety, toured the site and met with Mr. Gene St. Pierre and other members of licensee management.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- P. Allen, Senior Health Physics Technician
- K. Axelson, Project Engineer, Projects
M Bianco, Supervisor, Radiological Waste Services
- B. Buerger, Project Manager, Projects
- R. Campione, Nuclear Oversight Evaluator
- D. Carlino, Special Projects Coordinator, Mechanical Maintenance
- M. Debay, Nuclear Oversight Manager
- D. Flahardy, Radiation Protection supervisor
- P. Freeman, Engineering Director
- D. Hampton, Health Physics Shift Supervisor
- G. Kahn, Project Engineer, Engineering
- M. Kiley, Station Director
- T. Lehmann, Project Lead, Projects
- M. Makowicz, Plant Engineering Manager
- M. OKeefe, Regulatory Compliance Supervisor
- J. Peschel, Regulatory Programs Manager
- B. Plummer, Contractor, Projects
- D. Ritter, Operations Manager
- V. Robertson, Senior Nuclear Analyst, Regulatory Compliance
- M. Scannell, Health Physics Shift Supervisor - Nuclear
- D. Sherwin, Maintenance Manager
- T. Smith, Health Physics Specialist
- R. Sterritt, Health Physics Specialist - Nuclear
- G. St. Pierre, Site Vice President
- R. Thurlow, Radiation Protection Manager
- J. Tucker, Security Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed:
- 05000443/2006006-00 LER Plant Shutdown Due to Inoperable Diesel Generators.
(Section 4OA3.2)
- 05000443/2006006-01 LER Plant Shutdown Due to Inoperable Diesel Generators.
(Section 4OA3.2)
- 05000443/2006005-03 URI Testing of the Alternate Supply of Water to the Primary Component Cooling System (Section 4OA2.2)
Opened and Closed:
- 05000443/2007002-01 FIN Inadequate Evaluation of a Deficiency with the Alternate Cooling Water System to the Charging Pumps. (Section 4OA2.2)