IR 05000443/2007004
ML073190257 | |
Person / Time | |
---|---|
Site: | Seabrook ![]() |
Issue date: | 11/13/2007 |
From: | Arthur Burritt Reactor Projects Region 1 Branch 4 |
To: | Peschel J, St.Pierre G Florida Power & Light Energy Seabrook |
Burritt A | |
References | |
EA-07-244 IR-07-004 | |
Download: ML073190257 (31) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 13, 2007
SUBJECT:
SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2007004
Dear Mr. St. Pierre,
On September 30, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at the Seabrook Station, Unit No. 1. The enclosed report documents the inspection findings discussed on October 4, 2007, with Mr. M. Kiley 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.
Based on the results of this inspection, no findings of significance were identified.
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 the 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 4 Division of Reactor Projects Docket No. 50-443 License No: NPF-86 Enclosure: Inspection Report No. 05000443/2007004 w/ Attachment: Supplemental Information
Mr. Gene S
SUMMARY OF FINDINGS
IR 05000443/2007004; 07/1/2007-09/30/2007; Seabrook Station, Unit No. 1; Routine Integrated
Report.
The report covered a three-month period of inspection by resident inspectors and announced inspections by regional specialist inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
None.
Licensee-Identified Violations
None.
iii
REPORT DETAILS
Summary of Plant Status
Seabrook Station (Seabrook) began the period at rated thermal power and operated at or near full power for the entire report period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
a. Inspection Scope
The inspectors completed the two adverse weather protection inspection samples listed below.
- The inspectors reviewed FPL's response to an impending adverse weather event. The inspectors toured plant areas and monitored area temperatures to verify the adequacy of hot weather protection measures when ambient temperatures increased above 90° F between July 31 and August 4, 2007. The inspectors verified that FPL implemented actions in accordance with procedures ON1490.09, Summer Readiness Surveillance, ON1490.10, Operational Status Check of Station Ventilation/Cooling Systems, and ON1046.70, Generator Step Up Transformer Auxiliaries Operation. The inspectors walked down equipment in the essential switchgear rooms, the switchyard and the emergency diesel generators to verify hot weather protection was effective. The inspectors also reviewed FPL actions to implement OS1246.02, Degraded Vital AC Power (Plant Operating), when the grid operator declared a capacity deficiency alert.
- The inspectors performed a detailed review of FPLs seasonal readiness procedures and preparations for hurricane season and extreme cold weather.
Station procedures and system health reports were reviewed and systems subject to hurricane conditions and/or extreme cold weather were walked down to assess reliability and availability of those systems during hurricanes and extreme cold weather. The inspectors focused on the readiness of the essential switchgear rooms, diesel generator rooms, switchyard and emergency feedwater (EFW) pumps.
The inspectors also reviewed deficiencies previously identified during the implementation of adverse weather protection and verified that FPL had entered these deficiencies into the corrective action program for resolution. The references used during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors completed three partial walkdown inspection samples. The inspectors performed a walkdown of each system to verify that the critical portions of the systems, such as valve, switches, and breakers, were correctly aligned in accordance with FPLs procedures. The inspectors compared the system lineups to applicable piping and instrumentation drawings and operational lineup procedures. Documents reviewed are listed in the Attachment. The inspectors performed partial system walkdowns on the three systems listed below
- A emergency feedwater (EFW) pump when the B EFW pump was out of service for testing on July 10, 2007.
- 1A/1C 125 Vdc station batteries when the 1D station battery was out of service for testing on July 24, 2007.
- B emergency diesel generator (EDG) when the A EDG was out of service for maintenance on August 2, 2007.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
.1 Quarterly Walkdowns
a. Inspection Scope
The inspectors completed ten fire protection quarterly walkdown inspection samples.
The inspectors assessed FPLs control of transient combustibles and ignition sources; the operational status and material condition of the fire detection, fire suppression, and manual fire fighting equipment; the material condition of the passive fire protection features; and the compensatory measures for out-of-service or degraded fire protection equipment. The following ten areas were inspected:
- EDG Building Train A, 21'-6";
- EDG Building Train B, 21'-6";
- A Residual Heat Removal Vault, all elevations;
- A Essential Switchgear Room, 21'-6";
- B Essential Switchgear Room, 21'-6";
- Primary Auxiliary Building, 53';
- Primary Auxiliary Building, charging pump cubicles;
- Fuel Storage Building, 7' elevation;
- Fuel Storage Building, 10' elevation; and
- Fuel Storage Building, 21-6 elevation.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
Internal Flooding Area. The inspectors completed one internal flooding inspection sample. Based on a review of the UFSAR, the inspectors selected the main steam and feedwater pipe chase tunnels and adjoining areas for the review. For these areas the inspectors verified the condition of water tight doors and cable tray seals by plant walkdown. The inspectors verified the adequacy of abnormal and emergency operating procedures for coping with internal flooding in the main steam and feedwater pipe chase tunnels and adjoining areas and that identified flood control deficiencies were entered into the corrective action program.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance (71111.07A - 1 sample, 71111.07B - 2 samples)
.1 Annual Review
a. Inspection Scope
The inspectors completed one annual heat sink performance inspection sample. The inspectors reviewed FPLs program for monitoring the B EDG jacket water heat exchanger DG-E-42B. The inspectors reviewed data used by the system engineer to trend the heat exchanger in accordance with FPLs commitments to Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." The inspectors also reviewed a sample of condition reports to verify that heat exchanger monitoring and maintenance issues were identified and corrected. The references used for this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Biennial Review
a. Inspection Scope
The inspectors reviewed FPLs program for maintenance, testing, and monitoring of risk significant heat exchangers (HXs). The inspectors verified that the FPLs HX monitoring program conformed to FPL commitments to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." In addition, the inspectors evaluated whether any potential common cause heat sink performance problems could affect multiple HXs in mitigating systems or result in an initiating event. Based on risk significance and prior inspection history the HXs listed below were selected for review.
- A Emergency Diesel Generator (EDG) Jacket Water Cooler HX (DG-E-42-A)
The inspectors reviewed system health reports, engineering evaluations, design specifications and calculations, and chemical control methods to ensure that the selected components conformed to FPLs commitments to Generic Letter 89-13. The inspectors also compared the surveillance test and inspection results to the established acceptance criteria to verify that the results were acceptable and that the HXs operated in accordance with design.
The inspectors walked down the selected HXs, the SW forebay area, and the cooling tower area to assess the material condition of these systems, structures, and components. Finally, the inspectors discussed system health reports, methods of controlling biotic fouling, and the methods for ensuring heat exchanger operability with the service water and heat exchanger system engineers.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Resident Inspectors Review
a. Inspection Scope
The inspectors observed the performance of licensed operators during a simulator demonstration examination on September 12, 2007. The inspectors reviewed the simulator physical fidelity to verify similarities between the Seabrook control room and simulator. The inspectors assessed operator performance associated with high-risk activities, the Emergency Plan, previous lessons learned items, and the correct use and implementation of procedures. The inspectors observed the training evaluator critique of the operator performance and verified that deficiencies were adequately identified, discussed, and entered into the corrective action program. The documents reviewed for this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified
1R12 Maintenance Effectiveness (71111.12Q - 2 Samples)
a. Inspection Scope
The inspectors performed two quarterly maintenance effectiveness inspection samples.
The inspectors evaluated maintenance rule implementation for two systems: the enclosure building air handling (EAH) system and the charging (CS) system. The documents reviewed for this inspection are listed in the Attachment. For each system the inspectors reviewed the following items: the application of maintenance scoping and reliability and availability performance criteria; the corrective actions for deficient conditions; the extent-of-condition reviews for common cause issues; and the contribution of deficient work controls or work practices to degraded conditions. The inspectors also assessed corrective actions and maintenance rule functional failure evaluations based on 10 CFR 50.65 requirements and the guidance in Nuclear Management and Resources Council (NUMARC) 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 2.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a. Inspection Scope
The inspectors completed five maintenance risk assessment and emergent work control inspection samples. The inspectors reviewed the scheduling and control of one planned maintenance activity and four emergent work troubleshooting activities to evaluate the impact on plant risk. The inspectors performed 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 used to mitigate plant risk during maintenance were evaluated against FPLs procedures, Maintenance Manual 4.14, Troubleshooting, Revision 0 and Work Management Manual 10.1, On-Line Maintenance, Revision 3.
Specific risk assessments were performed using FPL's Safety Monitor a computer software application that allows plant personnel to evaluate the impact of changes in plant configuration on accident risk. The inspectors reviewed the risk associated with the planned and emergent work activities described below.
- Troubleshooting activities for a main steam isolation valve (MSIV) alarm and indication problem on July 12, 2007.
- Inspection and testing of the A emergency diesel generator (EDG) during maintenance overhaul on August 2, 2007.
- Troubleshooting and repair of a glycol leak on the supplemental emergency power system per WO 0728177 and CR 07-11483 on August 31, 2007.
- Troubleshooting and repair activities for a leak on A service water line 1801-04 on September 5, 2007.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors completed four operability evaluation inspection samples. The inspectors reviewed the condition reports listed below 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 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 that the impact on technical specification (TS) limiting conditions for operation were properly addressed. The inspectors performed field walkdowns and interviewed personnel. The following items listed below were reviewed.
- CR 07-09943 that evaluated the potential for reverse flow in the control building air system (CBA).
- CR 07-09853 that evaluated the operability fan 1-DAH-FAN-26B for the B EDG relative to substitute parts that were installed in the motor starter cubicle.
- CR 07-11520 that evaluated the operability of the A service water line 1801-04 upon discovery of a through-wall leak in the supply piping to the A component cooling water heat exchanger.
- CRs 07-11726, 07-11758, 07-11783, 07-11828, and 07-11829 that evaluated the operability of main steam drain line 5917-06 and feed water drain line 4633-07 after both were damaged by an aerial lift.
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modification
.1 Annual Review
a. Inspection Scope
The inspectors completed one annual review permanent modification inspection sample.
The inspectors reviewed design change 06MMOD-0514, "Seabrook Fuel Storage Building (FSB) Cask Handling Crane Single Failure Proof Upgrade Modification". This upgraded the existing FSB cask handling crane, 1-FH-RE-1, to a single failure proof design in accordance with NUREG 0654, Criteria for Protective Actions for Severe Accidents. The inspectors reviewed the design of the new crane lifting system and controls, including the mechanical qualifications, electrical design, and modifications made to the exiting structures. Walkdowns of the FSB were performed to verify compliance with the design documents. The inspectors reviewed the post-modification testing for the design change, including the cask handling crane functional test, the load cell calibration, and the crane load test. The inspectors also performed interviews with engineers and project staff and reviewed FPLs 10 CFR 50.59 safety evaluation screening for the modification. Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors completed six post-maintenance testing inspection samples. The inspectors reviewed post-maintenance testing (PMT) activities to ensure that the PMT was appropriate for the scope of the maintenance in accordance with FPL procedures MA 3.5, Post-Maintenance Testing; the acceptance criteria were clear and demonstrated operability of the affected component; and the PMT was performed in accordance with procedures. The inspector reviewed the following PMT activities.
- A EDG testing completed on August 4, 2007, following a maintenance overhaul controlled by 27 WOs that included both preventative and corrective maintenance items.
- A EDG surveillance test OX1426.01 completed on August 4, 2007, following maintenance conducted in accordance with WO 0703353.
- Supplemental emergency power system testing completed on August 23, 2007, following completion of a planned maintenance outage.
- A RHR system testing on August 28, 2007, after completion of planned system modifications.
- A VT-2 examination and operational hydrostatic testing of service water line 1801-04 on September 14, 2007, following completion of a weld repair on that line.
- Fuel storage building cask handling crane functional testing on September 13, 2007, per ES-07-01-06 following crane modifications.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors completed six surveillance testing inspection samples. The inspectors witnessed performance of and/or reviewed test data for the risk-significant STs to assess whether the SSCs tested satisfied TS, UFSAR, and procedure requirements. The inspectors verified that test acceptance criteria were clear, consistent with design documentation and demonstrated operational readiness; that test instrumentation had current calibrations and the range and accuracy for the application; and that tests were performed, as written, with applicable prerequisites satisfied. The STs reviewed are listed below. Documents reviewed for the inspection are listed in the Attachment.
- RS1739, Incore to Excore AFD Surveillance, Revision 7, on July 9, 2007.
- OX1436.03, Electric Emergency Feedwater Pump Q, 18 Month and Comprehensive Test, Revision 9, on July 10, 2007.
- OX1456.49, Train B ESFAS Slave Relay K615 Quarterly Go Test, Revision 7, on July 11, 2007.
- LX0556.04, 1D Station Battery Service Test, Revision 3, on July 17, 2007.
- EX1804.031, Portable Tower Makeup Pump Operability 18 Month Surveillance Test, Revision 04, on July 23, 2007.
- OX1426.03, Emergency Power Sequencer 18 Month Operability Test, Revision 7, on August 1, 2007.
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications
a. Inspection Scope
The inspectors completed one temporary plant modification inspection sample. To complete the sample the inspectors reviewed temporary alteration no. TALT07-0332.
The purpose of this modification was to provide temporary power in the fuel storage building during the completion of upgrades to the cask handling crane. The inspectors verified that the details of the modification itself and that the process used for its implementation did not adversely affect operator implementation of emergency and abnormal operating procedures or the capability of risk significant systems to meet their design basis as described in the UFSAR and TS. The inspectors reviewed any associated 10 CFR 50.59 evaluations and screenings and walked down the modification to verify that it was installed in accordance with design documents and that FPL controlled the modification implementation in accordance with station procedures. The inspectors also examined the combined affect of this modification and other outstanding temporary modifications on plant operations and reviewed FPLs actions to address problems with the temporary modification process that were identified in the corrective action program.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System (ANS) Evaluation
a. Inspection Scope
The inspectors performed an onsite review to assess the maintenance and testing of the Seabrook ANS. During this inspection, the inspectors interviewed site EP staff responsible for implementation of the ANS testing and maintenance. Condition reports (CRs) pertaining to the ANS were reviewed for causes, trends, and corrective actions.
The inspectors reviewed FPL's original ANS design report to ensure compliance with those commitments for system maintenance and testing. Planning Standard 10 CFR 50.47(b)(5) and the related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings of significance were identified.
1EP3 Emergency Response Organization (ERO) Staffing and Augmentation System
a. Inspection Scope
A review of ERO augmentation staffing requirements and the process for notifying the ERO was performed to ensure the readiness of key staff for responding to an event and to ensure timely facility activation. The inspectors reviewed procedures, CRs, and call-in drills associated with the ERO notification system. The inspectors also interviewed personnel responsible for testing the ERO augmentation process. The inspectors compared qualification requirements to the training records for a sample of ERO members. The inspectors verified that the EP department staff received required training as specified in the emergency plan. Planning Standard 10 CFR 50.47(b)(2) and related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings of significance were identified.
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes
a. Inspection Scope
Since the last NRC inspection of this program area, Emergency Plan Revisions 51, 52, 53, and 54 were implemented based on FPL's determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. The inspectors performed a sampling review of the Emergency Plan changes and changes to other lower-tier emergency plan implementing procedures to evaluate for any potential decreases in the effectiveness of the Emergency Plan. This review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. These changes remain subject to future NRC inspection in their entirety.
b. Findings
Seabrook EALs are based on the scheme described in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, November 1980 (NUREG-0654). In 1994 FPL added the following mode applicability note to EALs 6b, 6e, and 6f using the provisions of 10 CFR 50.54(q): This initiating condition does not apply in Modes 5 and 6 or when the reactor is defueled. During an EAL review conducted in 2007 in response to RIS 2007-01, Clarification of NRC Guidance for Maintaining a Standard Emergency Action Level Scheme, FPL determined that the mode applicability note added in 1994 was inappropriate. The note was inappropriate because, when it was added, the affected EALs no longer adhered to the NUREG-0654 EAL scheme.
RIS 2007-01 highlighted similar inappropriate uses of 10 CFR 50.54(q) to modify EAL schemes. The RIS stated that if a licensee identified a decrease in emergency plan effectiveness caused by EAL changes completed through the inappropriate application of 10 CFR 50.54(q), the NRC expected the licensee to immediately take action to achieve compliance with regulations. NRC EGM-07-003, Enforcement Guidance Memorandum - Disposition of Violations of 10 CFR 50.47(b)(4) for Failure to Maintain a Standard Emergency Action Level Scheme, stated that the NRC would consider enforcement discretion for licensees who identified a decrease in emergency plan effectiveness that the NRC determined was non-willful and that resulted from EAL changes described in RIS 2007-01.
The EGM specified three conditions for discretion. First, the licensee had to complete the necessary EAL changes by May 13, 2007. Second, discretion was appropriate if the necessary EAL changes were limited to the Unusual Event or Alert classification levels.
Third, enforcement discretion would be considered on a case-by-case basis for changes that affected the Site Area Emergency or General Emergency levels.
FPL did not complete the necessary changes to EALs 6b, 6e, and 6f until June 1, 2007 (Seabrook Emergency Plan Revision 54), and EAL 6e and 6f were for the Site Area Emergency level. Because FPL did not complete the necessary changes before May 13, 2007, and two of the three affected EALs were at the Site Area Emergency level, this issue will require further NRC management review and is being documented as an unresolved item (URI 05000443/2007004-01, FPL did not maintain NUREG-0654 EAL scheme).
1EP5 Correction of Emergency Preparedness Weaknesses
a. Inspection Scope
The inspectors reviewed self-assessments and audit reports to assess FPLs ability to evaluate Seabrooks program and its performance. The inspectors reviewed EP-related CRs initiated between January 2006 and August 2007, including planned and implemented corrective actions. The inspectors also reviewed EP drill reports, self-assessments, Quality Assurance surveillance reports, and the required 10 CFR 50.54(t)audits performed for 2006. Planning Standard, 10 CFR 50.47(b)(14) and the related requirements of 10 CFR 50, Appendix E were used as reference criteria.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access to Radiologically Significant Areas (71121.01 - 1 sample)
a. Inspection Scope
During the period September 4 to 6, 2007, the inspectors performed the following activity to verify that FPL properly implemented physical, administrative, and engineering controls for access to locked high radiation areas, 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 TSs, and FPL procedures. This activity represents the completion of one sample relative to this inspection area.
- (1) On September 4, 2007, the inspectors evaluated the administrative, physical, and engineering controls for operating the Shepard Model 81 beam (400 Curie)irradiator, used for calibrating portable radiation monitoring instruments. The inspectors attended the pre-job briefing, reviewed the Radiation Work Permit (07-004, Task 1), verified that the electronic dosimetry dose/dose rate alarm setpoints were appropriate, observed the technician perform pre-use safety interlock checks, reviewed the irradiator operations log/ maintenance history, and observed the technician operate the irradiator for instrument calibrations.
b. Findings
No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 9 samples)
a. Inspection Scope
During the period September 4 to 6, 2007, the inspectors performed the following nine activities to evaluate the operability and accuracy of radiation monitoring instrumentation, and the adequacy of the respiratory protection program relative to maintaining and issuing self-contained breathing apparatus (SCBA). Implementation of these programs was reviewed against the criteria contained in 10 CFR 20. These activities represent the completion of nine samples relative to this inspection area.
- (1) The inspectors reviewed the UFSAR to identify area, process, and emergency monitors that are installed at Seabrook for the protection of workers, and reviewed the current calibration records for selected instrumentation, including the volume control tank area monitor (RM-6540), the incore seal table radiation monitor (RM 6534), spent fuel area monitor (RM-6549), and the waste gas process area monitor (RM-6551). The inspectors discussed with the systems engineer the area monitoring system health report and instrument reliability trends.
- (2) The inspectors selected hand-held radiation instruments, air monitors, contamination monitors, and electronic dosimeters currently in use in the plant, and reviewed the associated calibration records. Included in this review were the calibration records for selected electronic dosimeters (DMC-2000), radiation survey instruments (RO-20, RSO-5, ASP-2, FH-40, E-140N), contamination monitors (RM-14, SAM-9, ARGO4AB-Zeus 46, SPM-906), counting room instruments (Tennelec 175 & 43431, Ludlum 2200), and air monitors (AMS-4).
- (3) The inspectors observed a technician performing the pre-use safety checks on the Shepard Model 81 beam irradiator, reviewed the source(s) activity/dose rate data, and observed the technician perform calibrations of RSO-5 (Serial No.
B176B), FH40 (Serial No. 13504), ASP-2 (Serial No. 1194), and RO-20 (Serial No. 3658).
- (4) The inspectors evaluated FPL's program for assuring quality in the radiation monitoring instrumentation and respiratory protection programs by reviewing audits (Nos. SBK -06-01 & 02, SBK-07-04), selected daily quality summary reports for the period January 2005 to August 2007, nuclear assurance field observation reports (07-0047, 07-0060, 06-0047, 05-0130), and 18 condition reports related to these program areas. The inspectors determined if problems were identified in a timely manner, the extent of condition and cause evaluation were performed, previous radiation surveys remained valid, and corrective actions were appropriate to preclude repetitive problems.
- (5) The inspectors determined that there were no incidents of personnel internal exposure that resulted in a committed effective dose equivalent CEDE>50 mrem that would require an in-depth evaluation of whole body counting and bioassay techniques. However, the inspectors reviewed whole body counting instrument calibration and daily quality control data to confirm that the instrumentation was operable and available for use. Additionally, the inspectors reviewed the most current Part 61 analysis of the site's dry active waste stream for difficult-to-measure radioisotopes and determined that the isotopic mix did not significantly change from past analyses and that current whole body counting system parameters do not need to be changed.
- (6) The inspectors reviewed relevant condition reports initiated since the last inspection to determine if radiation worker and radiation protection technician errors that resulted from training deficiencies or human factors were evident and if the resulting corrective actions were adequate.
- (7) The inspectors verified calibration dates and observed a technician perform daily source checks on a variety of instruments including portable survey instruments (RSO-5, FH40, ASP2, RO-20), gas flow proportional counters (Tennelec 175 &
43431), an alpha counter ( Ludlum 2200), contamination survey monitors (RM-14, SAM-9), and personnel contamination monitors (ARGOS, SPM 906).
- (8) The inspectors evaluated the adequacy of the respiratory protection program regarding the maintenance and issuance of self-contained breathing apparatus (SCBA) to emergency response personnel. Training and qualification records were reviewed for licensed operators, radiation protection personnel, and fire brigade members, who would be required to wear SCBAs in the event of an emergency. Four SCBAs staged for use in the control room and three SCBAs staged in the turbine building were physically checked and the maintenance and hydrostatic/regulator test records for other selected SCBAs were also reviewed.
- (9) The inspectors reviewed the calibration records of the SCBA regulator testing equipment, verified that technicians were qualified to maintain and test regulators, reviewed the testing procedure, and observed a technician performance test two regulators. The inspectors also verified that air used to fill the SCBAs met the Grade D quality criteria of the Compressed Gas Association.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
a. Inspection Scope
The inspectors reviewed FPL submittals from the second quarter of 2006 to the second quarter of 2007 for the Seabrook performance indicators (PIs) listed below. To verify the accuracy of the PI data reported during this period, the data was compared to the PI definition and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Revision 5.
Cornerstone: Mitigating System
- High pressure safety injection mitigating systems performance index (MSPI)
- Auxiliary feedwater system MSPI
- Residual heat removal system MSPI
- Support cooling water system MSPI The inspectors reviewed the consolidated data entry MSPI derivation reports for the unavailability and unreliability indexes (UAI and URI) for the monitored systems; the monitored component demands and demand failure data for the monitored systems; and the train and system unavailability data for the monitored systems. The inspectors verified the accuracy of the data by comparing it to corrective action program records, control room operators logs, maintenance rule performance and scope reports, system performance/health reports, the reactor trips database, the equipment/operability issues database, the site operating history database, key performance indicator summary records, operating data reports and the MSPI basis document.
Emergency Prepardness Cornerstone
- Drill and exercise performance
- Emergency response organization (ERO) drill participation
- Alert notification system (ANS)
The inspectors reviewed FPLs process for identifying the data for the three emergency preparedness PIs listed above. Classification, notification and protective action opportunities were reviewed from licensed operator simulator sessions and site ERO drills and exercises. Attendance records for drill and exercise participation were reviewed for completeness and accuracy. Test results of the ANS testing were also reviewed.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As specified by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into Seabrooks CAP. The review was accomplished by accessing the computerized database for CRs. In accordance with the baseline inspection modules the inspectors also selected a sample of items across all seven cornerstones for additional follow-up and review. The inspectors assessed Seabrooks threshold for problem identification, the adequacy of the cause analyses, extent of condition review, operability determinations, and the timeliness of the specified corrective actions.
.2 Annual Sample: Review of Seismic Gap Fire Penetration Seal Issues
a. Inspection Scope
The inspectors selected condition reports (CR) CR 04-03296 and 06-02905 for detailed review. CR 04-03296 documented a number of seismic gap fire penetration seal failures requiring repair and requested a one hundred percent review of the seals because of those failures. CR 06-02905 documented identification of degraded seismic gap fire penetration seals in the containment enclosure ventilation area (CEVA).
Specific documents reviewed are listed in the Attachment. To determine whether FPL was appropriately identifying, characterizing and correcting these problems, the inspectors assessed FPLs problem identification threshold, cause analyses, extent of condition reviews, operability determinations and the prioritization and timeliness of corrective actions.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that FPL properly implemented their CAP to address these issues. The apparent cause evaluations were detailed and thorough. The operability determination provided justification for continued operation. Corrective actions and recommendations for seismic gap fire penetration seals appeared appropriate. FPL continued to implement scheduled corrective actions at the time of this inspection. Inspector walkdowns of a sample of accessible seismic gap fire penetration seals in the CEVA did not identify additional degraded seals.
4OA3 Event Follow Up
.1 (Closed) LER 05000443/2007002-00, Incorrect valve Stroke Time Renders Emergency
Feedwater Pump Inoperable The inoperable emergency feedwater pump issue was previously reviewed and documented in NRC Inspection Report 0500443/200706 as a non-cited violation of very low safety significance (Green). The inspectors reviewed the accuracy of the licensee event report (LER) 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. This LER is closed.
4OA5 Other Activities
.1 Independent Spent Fuel Storage Installation
a. Inspection Scope
The inspectors reviewed construction documents and records associated with the construction of the Seabrook independent spent fuel storage installation (ISFSI) pad.
Documents reviewed are listed in the Attachment. The inspectors discussed construction activities with cognizant personnel. The inspectors toured the construction site and observed work activities. The inspectors verified that the construction details for the ISFSI pad were bounded by the design parameters for the dry cask storage system selected for use at Seabrook. The inspectors also verified that the design specifications for the ISFSI pad were met in the construction documentation.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
The resident inspectors presented the inspection results to Mr. M. Kiley on October 4, 2007. FPL acknowledged that none of the material reviewed by the inspectors during the period was proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
R. Belanger Plant Engineer
D. Berko Assistant Plant Manager
- B. Buerger Project Manager, Projects
- J. Buyak Senior Radiation Protection Technician, (Respiratory Protection)
- D. Carlino Special Projects Coordinator, Mechanical Maintenance
D. Flahardy RP Technical Supervisor
- G. Flanders Senior Radiation Protection Technician, (Instrumentation)
P. Freeman Engineering Director
- R. Guthrie Systems Engineer, Radiation Monitoring System
G. Kilby Regulatory Compliance Engineer
M. Kiley Plant Manager
- T. Lehmann Project Lead, Projects
M. Makowicz Plant Engineering Manager
B. McCormack System Engineer
E. Metcalf Operations Manager
- K. Nuzzo Planner, Projects
M. OKeefe Regulatory Compliance Supervisor
D. Perkins Rad Services Supervisor
- J. Peschel Manager, Regulatory Programs
- V. Robertson Senior Nuclear Analyst, Regulatory Compliance
G. Sessler System Engineer
M. Scannell Senior Health Physicist
D. Sherwin Maintenance Manager
G. St. Pierre Site Vice President
R. Thurlow Radiation Protection Manager
E. Trump Fire Protection Systems Engineer
J. Tucker Security Manager
P. Wells Corporate Director of Licensing & Performance Improvement
P. Willoughby Regulatory Compliance Engineer
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000443/2007004-01 URI FPL did not maintain NUREG-0654 EAL scheme
Closed
- 05000443/2007002 LER Incorrect Valve Stroke Time Renders Emergency Feedwater Pump Inoperable. (Section 4OA3)