IR 05000443/2009005

IR 05000443-09-005, on 09/30/2009 - 12/31/2009, Seabrook Station Unit 1, Routine NRC Integrated Inspection Report

ML100400234
Person / Time
Site:	Seabrook
Issue date:	02/09/2010
From:	Arthur Burritt Reactor Projects Branch 3
To:	Freeman P NextEra Energy Seabrook
BURRITT, AL
References
IR-09-005
Download: ML100400234 (54)

Text

UNITED STATES

SUBJECT:

SEABROOK STATION, UNIT NO.1 - NRC INTEGRATED INSPECTION REPORT 05000443/2009005

Dear Mr. Freeman:

On December 31, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit NO.1. The enclosed report documents the inspection findings discussed on January 12,2010, with you and other members of your staff.

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

The inspectors reviewed selected procedures and records, obsierved activities, and intervieWed personnel.

The report documents one licensee-identified violation that was determined to be of very low safety significance. However, because of the very low safety significance and because the issue was entered into your corrective action program, the NRC is treating the finding as a non cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy.

If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATIN: Document Control Desk, Washington, DC 20555"'()001 ; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement. United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at the Seabrook Station. In addition, if you disagree with the charal:ierization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at the Seabrook Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

I I I 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 electroni<;ally for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's 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).

I I

Sln~ d-Arthur L. Burritt, Chief Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86 Enclosure:

Inspection Report No. 05000443/2009005 wI Attachment: Supplemental Information co w/encl: Distribution via ListServ

SUMMARY OF FINDINGS

IR 05000443/2009005; 09/30/2009-12/31/2009; Seabrook Station, Unit No.1; Routine

Integrated Report.

The report covered a three-month period of inspection by resident and 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.

No findings of significance were identified.

Other Findings

A violation of very low safety significance, which was identified by NextEra, has been reviewed by the inspectors. Corrective actions taken or planned by NextEra have been entered into NextEra's corrective action program. This violation and the corrective action tracking number are listed in Section 40A7 of this report.

REPORT DETAILS

Summary of Plant Status

Seabrook. Unit No.1 (Seabrook) was shutdown for a planned refueling outage that began on October 1, 2009. NextEra {NE) completed refueling, testing and maintenance activities during the outage. This included loading new fuel in the reactor, inspeGting reactor vessel welds, inspecting the steam generators, and installing new components in the 345KV electrical swltchyard. The reactor was taken critical on November 9, and the generator was synchronized

. to the grid. Seabrook operated at 65 percent power pending an evaluation of main turbine torsional vibrations and was shutdown to cold shutdown on Decl9mber 6 to replace the A low pressure turbine rotor. Seabrook reactor was taken critical on December 16, 2009, and the generator was connected to the grid on December 17. The generator was periodically removed from the grid from December 17 to 23 to balance the turbine. The generator was synchronized to the grid on December 23 and the unit returned to 100 percent power on December 26. 2009.

Seabrook operated at full power for the remainder of the period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems:. Barrier Integrity and Emergency Preparedness

1R01 Adverse Weather Preparation

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors completed one seasonal extreme weather conditions inspection sample.

The inspectors assessed NextEra readiness for the onset of cold weather conditions.

The inspectors reviewed the updated final safety analysis report (UFSAR) descriptions for related design features and verified the adequacy of the station procedures for adverse weather protection. The inspectors reviewed NextEra actions per procedure ON1490.09 for seasonal readiness, and procedure 051200.03 for severe weather. The inspectors also conducted walkdowns of susceptible systems, specifically the service water, emergency feedwater and 4 KV electrical systems. The inspectors reviewed deficiencies related to extreme weather preparation and verified the issues were entered into the corrective action program. The references used for this review are listed in the

.

b. Findings

No findings of significance were identified.

==1R04 Equipment Alignment (71111.04 - 4 samples, 71111.045 - 1 sample) Partial Walkdown a.

==

Inspection Scope

.1 The inspectors completed four partial system walkdown inspection samples for the plant

systems listed below. The inspectors verified that valves, switches, and breakers were correctly aligned in accordance with Seabrook's procedures and that conditions that could affect system operability were appropriately addressed. The inspectors reviewed applicable piping and instrumentation drawings and system operational lineup procedures. Documents reviewed for this inspection are listed in the Attachment.

• B service water (SW) aligned to the cooling tower on October 20, 2009, during the planned unavailability of the A SW system;

• Reactor vessel cooling, makeup supplies and vessel level monitoring on October 31, 2009, during operations in mid-loop;

• Residual heat removal (RHR) on October 2-3, 2009, for the planned initiation of shutdown cooling and use for low temperature over pressure protection; and

• RHR on November 5-6, 2009, following re~alignment for use as an emergency core cooling system in standby.

b. Findings

No findings of significance were identified.

. 2 Complete Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown inspection of the chemical and volume control system (CVCS-safety injection) to verify the system was properly aligned and capable of performing its safety function. To ascertain the required system configuration, the inspectors reviewed plant procedures, system drawings, the UFSAR, and the TS. The inspectors walked down the accessible portions of the system to verify overall material condition; that valves were correctly positioned; that electrical power was*

available; that major system components WE!re properly labeled; that essential support systems were operational; and that ancillary equipment or debris did not interfere with system performance. The inspectors reviewed applicabll:t piping and instrumentation drawings and system operational lineup procedures. Documents reviewed for this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1 R05 Fire Protection (71111.050 - 6 samples) Quarterly Review of Fire Areas:

a. Inspection Scope

The inspectors completed six quarterly fire protection inspection samples. The inspectors examined the areas of the plant listed below to assess: the 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

.1 material condition of the passive fire protection features; and the compensatory

measures for out-of-service or degraded fire protection equipment. The inspectors verified that the fire areas were maintained in accordance with applicable portions of Fire Protection Pre-Fire Strategies and Fire Hazclrd Anaiysis. Documents reviewed are listed in the Attachment.

• C~F~3-Z (Containment 25 ft)

• C-F-1-Z (Containment (-) 26 ft)

• C-F-2-Z (Containment 0 ft)

• FSB-F-1-A (Fuel Storage Building 7 ft, 10ft, and 21 ft)

• PAB-F-2C-Z (Primary Auxiliary Building 25 ft)

• PAB-F-3A-Z (Primary Auxiliary Building 53 ft)

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors completed one flood protecti-on,measures inspection sample. The inspectors reviewed the flood protection measures designed to protect safety and risk significant systems from the effects of flooding. The inspectors reviewed NextEra's program to inspect cables located in underground vaults. The inspectors accompanied NextEra personnel to observe cable vault conditions for water submergence; material condition of splices and support structures; and, the operation and effectiveness of dewatering activities. The inspectors observed inspections of cable vaults, including Vault W05 that contained cables for safety related service water pumps SW-P-41 A and SW-P-41 C. The inspectors also performed tours of the selected areas to verify that as found equipment and conditions were consistent with the deSign basis documents.

Documents reviewed for this inspection are fisted in the Attachment

b. Findings

See section 40A7 of this report for a discussion of one licensee-identified violation related to this inspection area.

R07 Heat Sink Performance

a. Inspection Scope

The inspectors completed one heat sink perFormance inspection sample. Specifically the inspectors reviewed the performance of the A closed cooling water heat exchanger to verify that the heat exchanger could fulfill its design function. The inspectors reviewed thermal performance monitoring (WO 0509597), trending data for heat exchanger temperatures and fouling factors, and ES1850.017, "SW Heat Exchanger Program."

The inspectors interviewed the system engineer to evaluate the process used to monitor the heat exchanger and commitments in Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." The inspectors conducted system walk downs and reviewed condition reports to verify that iSSUE~S associated with the heat exchanger were identified and corrected.

b. Findings

No findings of significance were identified.

1

R08 Inservice Inspection

a. Inspection Scope

The purpose of this inspection was to review and assess the effectiveness of the NextEra's Inservice Inspection (lSI) program for monitoring degradation of the reactor coolant system (RCS) boundary, risk significant piping system boundaries, and the containment boundary. The inspectors revi'ewed the inservice inspection activities using the criteria specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI and applicable NI~C regulatory requirements.

The inspectors selected a sample of non-destructive examination (NDE) activities to verify compliance with the requirements of ASME Section XI. The inspectors also reviewed selected samples of completed non-destructive examination procedures and inspection test reports to verify compliance with the ASME Code,Section XI. The inspectors selected samples included modification, repair and replacement activities that involved use of the welding process on pressure boundary risk significant systems. The sample selection was based on the inspection procedure objectives, risk significance and sample availability. The inspectors reviewed examination procedures, procedure and personnel qualifications and examination test results. The inspectors also reviewed samples of examination reports and eleven condition reports (CR) initiated during lSI examinations to evaluate NextEra's effectiveness in the identification and resolution of problems.

The inspectors reviewed the procedures used to perform visual examinations for indications of boric acid leaks from pressure retaining components including the vessel upper head penetrations and their connections to the drive mechanisms. The inspectors reviewed the test results of these examinations and performed an inspection walkdown of the zero and -26 foot elevations to evaluate the effectiveness of the boric acid corrosion control exams performed by NextEra. The inspectors reviewed a sample of test reports and condition reports initiated as a result of tl1ese inspections. The inspectors reviewed selected CR's that identified both active and inactive leak locations that could result in degradation of safety significant components. The inspectors reviewed samples of operability evaluations, engineering evaluations and corrective actions provided for active and inactive boric acid leaks Bind verified that they were consistent with the requirements of the ASME Code and 10 CFR 50, Appendix B, Criterion XVI, Corrective Action.

The inspectors observed the performance of three NDE activities in process and reviewed documentation and examination reports for an additional three nondestructive examinations. Non-destructive test processes inspected included visual (VT), magnetic particle (MT), radiographic (RT), penetrant (PT), eddy current (ECT), and ultrasonic (UT)testing.

Examinations Inspected:

• UT of weld CS 0355~01 29, charging system, drawin~~ 1-Y-800355 151, examination procedure ES 03-01-22.

• PT test of weld 51 0272-09 03, safety injection

(51) system, drawing 1-NHY-800272 lSI, examination procedure ES 1807.002.

• MT test of weld RCE-10 Pressurizer SKIRT, Reactor Coolant, integrally welded attachment, drawing 1-NHY-650006 Isr~ examination procedure ES 1807.003.

• RT of field welds F0201, F0209 and F0210, butt welels of RHR system piping, drawing EC 145123-2000.

• ECT of steam generator tubes in SG A (tube R49C67), C (tube R51 C51, R48C96, R27C61) and D (R46C51).

• VT of reactor pressure vessel bottom mounted instrument penetrations The inspectors interviewed the inservice inspection program engineer to assess the scope of containment boundary examinations and the extent of management over-sight for the activity during this outage. The inspectors performed a walk-down of portions of the containment liner on the 0 ft, 25 ft and - 26 ft elevations to inspect the condition of the coating on the primary containment liner including the lowest intersection of the containment wall with the floor. The evaluation was performed to determine if evidence of mechanical damage or leakage was apparent. The Inlspectors observed no notable mechanical damage or indication of leakage during the performance of this ASME Section XI Section IWE evaluation. The inspectors reviewed examination reports and condition reports initiated as a result of NextEra's examination of the liner and coating performed during this outage. Corrective action specified for conditions identified were evaluated by the inspectors to verify that the engineerin~J organization was involved in providing evaluation and disposition.

The inspectors reviewed the steam generator (SG) Degradation Assessment (DA) to verify that NextEra had reviewed and incorporated the msults of the previous outage Degradation Assessment, Operational Assessment (OA) and Condition Monitoring (CM)

Assessment. The inspectors reviewed these assessments to confirm that the proper inspection scope was planned and performed during this outage. The inspectors also selected three ECT examination technique specification sheets (ETSS) to verify that the examination techniques applied were qualified for the detection of degradation mechanisms identified during the assessment completed for this outage. The inspectors reviewed the test data for a sample of tubes that exceeded the acceptance criteria for wall thinning. These tubes were subsequently removed from service by "plugging" and the tube inspection sample was increased in accordancE~ with the expansion plan. The inspectors verified the expanded sample was completed and that no additional tubes that exceeded the acceptance criteria were identified.

The inspectors reviewed documentation for two rework/repair activities that required the development of an ASME Section XI repair plan with the use of welding processes to complete the repair. The work requests (WR) that detailed these repairlreplacement activities were:

• WR 00625947 01, Remove and Replace service water flanged pipe reducer on discharge of service water pump 1-SW~P-41-A. Replacement of service water spool

.1 piece SW~1B01, Drawing MSE-OB0230-2001, field welds #F1012, 1013, 1014 and

1015 were required.

• WR 00628168 Removal and replacement of RHR th~~rmal mixing "tee" and associated pipe. Field welds F0201, 0209, and 0210 were required for fabrication and installation in line #1-RH-158-02-601-8 shown 011 Sketch EC 145123-2000.

The inspectors reviewed the ASME Section XI repair pll::!nS, replacement material, weld procedure specifications and qualifications, welder quali'flcations, weld filler metals, non destructive tests acceptance criteria and post work testing for each activity, as applicable.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Regualification Program (71111.110 - 1 sample, 71111.11A -- 1 sample)

Quarterly Resident Inspectors Review

a. Inspection Scope

The inspectors completed one quarterly licensed operator requalification program inspection sample. Specifically, the inspectors observed simulator examinations of licensed operators on November 17, 2009, for scenarios involving transients and design basis events. The inspectors reviewed operator actions to implement the abnormal and emergency operating procedures. The inspectors 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 inspectors observed and reviewed the trainil1g evaluator's critique of operator performance and verified that deficiencies were adequately identified, discussed, and entered into the corrective action program. The inspectors reviewed the simulator's physical fidelity in order to verify similarities between the Seabrook control room and the simulator. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

. 2 Annual Regualification Examination Review

a. Inspection Scope

The following inspection activities were performed using NUREG 1021, Rev. 9, "Operator Licensing Examination Standards for Power RE~actors," Inspection Procedure 7111111, "Licensed Operator Requalification Program," Appendix A "Checklist for Evaluating Facility Testing Material," Appendix B "Suggested Interview Topics," and Appendix C "Checklist for Evaluating Plant-Referenced Simulators Operating Under 10 CFR 55.46{c) AND (d)."

A review was conducted of recent operating history documentation found in inspection reports, licensee event reports, and NextEra's corrective action program. The inspectors also reviewed specific events from the corrective action program that indicated possible training deficiencies, to verify that they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operator' performance.

The operating tests for the week of December 14, 2009, were reviewed for quantitative attributes and overall quality. Observations were made of the dynamic simulator examinations and job performance measures (JPM) administered during the week of December 14, 2009. These observations included facility evaluations of crew and individual performance during the dynamic simulator scenario examinations and individual performance of five JPMs. In-office reviews of the written examinations for Crews C, D, and F were conducted to verify compliance with the guidance of NUREG 1021. Operating and written examination test items were reviewed to verify an acceptable level of overlap to ensure overall examination integrity.

On December 29, 2009, the results of the annual operating tests and the written examinations for 2009 were reviewed to confirm that pass fail rates were consistent with the guidance of NUREG~1 021, Revision 9, "Operator Licensing Examination Standards for Power Reactors" and NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process (SDP). The review verified the following:

• Crew pass rates were greater than 80%. (Pass rate was 100%)

• Individual pass rates during the simulator examinations were greater than 80%.

(Pass rate was 100%)

• Individual pass rates on the job performance measures of the operating exam were greater than 80%. (Pass rate was 97.9 %)

• Individual pass rates on the written exam were greater than 80%. (Pass rate was 100%)

• More than 751lj() of the individuals passed all portions of the exam. (The overall requalification examination pass rate was 97.9%)

The remediation plans for one individual's performance deficiencies were also reviewed to assess the effectiveness of the remedial training.

Eight SRO license activations were reviewed to ensure that 10 CFR 55.53 license conditions and applicable program requirements were met. Also, watch standing records were verified for four staff SRO licenses. A sample of ten individual and medical examinations/records was reviewed for compliance with license conditions, including NRC regulations.

Two operators (one reactor operator and one senior reactor operator) and four instructors were interviewed for feedback on their training program and the quality of training received. Also. trainee comments and the associated responses were reviewed for training in phases 0803 and 0904 to assess the training feedback process.

Simulator performance and fidelity were observed during the administration of JPMs and simulator scenario examinations during the week of December 14,2009. A recent control room modification was compared with the associated simulator modification to assess fidelity. Simulator testing records were reviewed against the guidance in ANSI/ANS':3.5-1998, "Nuclear Power Plant Simulators for Use in Operator Training and Examination. "

b. Findings

No findings of significance were identified.

1

R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors completed three maintenance effectiveness inspection samples.

The inspectors reviewed performance-based problems or completed performance and condition history reviews involving selected in-scope structures, systems or components (SSCs) to assess the effectiveness of the maintenance program. Reviews focused on:

proper Maintenance Rule (MR) scoping in accordance with 10 CFR 50.65; characterization of reliability issues; tracking system and component unavailability; 10 CFR 50.65 (a)(1) and (a)(2) classifications; identifying and addressing common cause failures, trending key parameters, and the appropriateness of performance criteria for SSCs classified (a)(2) as well as the adequacy of goals and corrective actions for SSCs classified (a)(1). The inspectors reviewed system health reports, maintenance backlogs, and MR basis documents. Other documents reviewed for the inspection are listed in the

. The following samples were reviewed:

• Supplemental emergency power system maintenance rule (a)(2) classification, with a focus on engine and electrical and control system performance (AR197779197779 197884)

• ED-4/13.8 kV Vac system maintenance rule (a)(2) classification, with a focus on breaker performance and corrective actions to address bJockingdiodes(AR191631191631

. 014356)

• Main steam system maintenance rule (a)(2) classification, with a focus on main steam isolation performance (AR 202606202606 202630).

b. Findings

No findings of significance were identified.

1 R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 7 samples)

a. Inspection Scope

The inspectors completed seven maintenance risk assessment and emergent work control inspection samples. The inspectors reviewed the scheduling and control of planned and emergent work 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-Une Maintenance," Revision 5.

Specific risk assessments were conducted using Seabrook's "Safety Monitor."

Documents reviewed are listed in the Attachment. The inspectors reviewed the maintenance items listed below.

I

• Planned work associated with 345 kV Line 394 outage, relay room work and switchyard modifications with commissioning of Bus 5 per 09DCR002, WO I

01195817

• Emergent work associated with service water system pipe liner defects and repair I

perWO 00628145 and 00628148 (AR207412207412

I

• Emergent work associated with the B RHR mixing-T pipe defect and repair per WO 00628128 (AR206338206338

• Emergent work associated with service water system pipe through wall leak and repair per WO 01198488 and 94002507 {AR209078}

I

• Emergent work associated with the mechanical stress improvement application for the reactor vessel nozzle at azimuth 158 degrees pe:r WO 01198476 (EC145179)

• Planned work associated with emergenGY bus 1-EDE-SWG-5 including availability of opposite train protected and guarded equipment per WO 1169163

• Planned work to replace SW-P-41A pump and motor per WO 1189955 during plant operation on the cooling tower

b. Findings

No findings of significance were identified.

1

R15 Operability Evaluations

a. Inspection Scope

The inspectors completed four operability evaluation inspection samples. The I

inspectors reviewed operability evaluations and condition reports to verify that identified I.

conditions did not adversely affect safety system operability or overall 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 that TS limiting condition for operation implications were properly addressed. Documents reviewed are listed in the Attachment. The inspectors also performed field walk downs and interviewed personnel involved in identifying, evaluating or correcting the identified conditions. The following items listed below were reviewed.

• CR206338, RHR system acceptability for operation following identification of a flaw on line RH-158-02-601-8

• CR207352, containment building spray (CBS) system acceptability for operation following identification of a flaw on line CBS-1210-11-1301-12

• CR207921, acceptability of core reload per TS 3.4.10 following flaw identification on reactor vessel nozzle at azimuth 158 degrees and evaluation per ASME Section XI IWB3640

,.

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.1 *

CR209357, service water system acceptability for operation following identification of through wall leak on pipe SW-1827-1-153 (SW-S10)

b. Findings

No findings of significance were identified.

1

R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors completed one plant modification inspection sample. The inspectors reviewed the design change package for the switchyard reliability project upgrade. This modification improved the switchyard by adding new 345 kV breakers and providing a supply to the reserved auxiliary transformer from 345 kV Buses 1 and 3. The inspectors verified that the design bases, licensing bases, and performance capability of the 345 kV system was not degraded by the modification. The inspE~ctors also verified that the new configuration was accurately reflected in the design documentation, and that post modification testing was adequate to ensure~ that the affected structures, systems, and components would function properly after modification installation. The inspectors interviewed plant staff, and reviewed issues entered into the corrective action program to verify that NextEra was effective at identifying and resolving problems associated with plant modifications. The 10 CFR 50.59 evaluation associated with the switchyard reliability project was also reviewed. Other documents reviewed for this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

. 2 Temporary Modifications

a. Inspection Scope

The inspectors completed one plant modification inspection sample. The inspectors reviewed a modification package for service water line SW-1814-1-156 and its seismic supports to verify that the design bases, licensing bases, and performance capability of the system was not degraded by the modification. The inspectors verified the new configuration was accurately reflected in the design documentation and that the post modification testing was adequate to ensure the structurE~s, systems, and components would function properly. The inspectors interviewed plant staff, and reviewed issues entered into the corrective action program to determine whether NextEra was effective at identifying and resolving problems associated with temporary modifications. The 10 CFR 50.59 evaluation associated with this temporary modification was also reviewed.

The documents used in this review are listed in the Attachment.

b. Findings

No findings of significance were identified.

.1 1 R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors completed nine post-maintenance testing (PMT) inspection samples.

The inspectors observed portions of PMT activities in the field to verify the tests were performed in accordance with the approved procedures. The inspectors assessed the test adequacy by comparing the test methodology to the scope of mai(1tenance work performed..The inspectors evaluated established test acceptance criteria to verify that the reviewed test procedures ensured that systems and components satisfied applicable design, licensing bases and technical specification (TS) requirements. The inspectors also reviewed the recorded data to confirm applicable acceptance criteria were satisfied during testing. Documents reviewed are listed in the Attachment. The activities reviewed are listed below.

• Retest following the modification of A diesel generator lube oll temperature control valve 1-DG-V-29B on October 02,2009, WO 00626428

• Retest of emergency feedwater (EFW) flow control valve FW-FV-4244-A following planned maintenance on October 12,2009. W01169500

• Retest of reactor and turbine trip functions as part of the turbine digital electrohydraulic control (DEHC) site acceptance testing on November 1-25, 2009.

WO 01189548

• Retest of Charging Pump 1-CS-P-2-A following motor replacement on October 31, 2009, WO 628996

• Retest following maintenance on vital inverter 1-EDE-I-1-A-01 on October 31, 2009, WO 1168951

• Post work test for RHR valve 1-RH-V-14 following replacement of thermal overload protection on October 22, 2009, WO 1170564

• Retest following maintenance on the reactor trip breakers on November 2,2009, WO 1168210

• Retest following maintenance on Feedwater valve FVV-FV-42348 to repair actuator oil leak on October 26.2009, WO 1189131

• Retest following repair of the B RHR line 1-RH-158-02 on November 5, 2009, WO 628168

b. Findings

No findings of significance were identified.

1

R20 Refueling and Outage Activities

Refueling Outage OR13

a. Inspection Scope

The inspectors completed one refueling and outage activities inspection sample. The inspectors reviewed the operational, maintenance, and testing activities for the thirteenth refueling outage (OR13) starting on October 1,2009. The references used to this inspection are listed in the Attachment.

I I

j i

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Review of Outage Plan I

The inspectors reviewed the outage plans to evaluate NextEra's ability to assess and manage the outage risk. The inspectors reviewed the outage risk assessment provided in Engineering Evaluation EE-09-007.

I

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Monitoring of Plant Shutdown and Cool down Activities The inspectors reviewed NextEra action to shut the plant down in accordance with plant procedures. The inspectors observed completion of various activities required to place I

the plant in a cold shutdown condition to assess operator performance, communications, command and control and procedure adherence. The inspectors reviewed operator adherence to TS required cooldown limits.

The inspectors also conducted inspection tours of plant areas not normally accessible during plant power operations to verify the integrity of structures, piping and supports, I

and to confirm that systems appeared functional.

l I Reactor Fuel Reload and Inspection Activities and Reactivity Control I

The inspectors verified that refueling activities were conducted in accordance with I

procedures OS1000.09 and RS0721. The inspectors independently verified on a sampling basis that requirements for core alteration were met. The inspectors observed NextEra actions during core alterations to assure core reactivity was controlled. The inspectors observed activities from the control room, the reactor cavity and the spent fuel pool at various times. The inspectors verified that fuel m;:wement was tracked in accordance with the fuel movement schedule. The inspectors verified NextEra action to meet the reqUirements of TS 3.9 for refueling operations, including the requirements for boron concentration and core monitoring using the source range monitors. The inspectors observed communications and coordination of activities between the control room and the refueling stations while fuel handling activitles were in progress.

Outage Risk The inspectors reviewed daily shutdown risk assessments during refueling outage OR13 to verify that NextEra addressed the outage impact on defense-In-depth for the critical safety functions: electrical power availability, inventory control, decay heat removal, reactivity control, and containment. The inspectors reviewed how NextEra provided adequate defense~in~depth for each safety function and implemented the planned contingencies in order to minimize overall risk where redundancy was limited or not available. The inspectors periodically reviewed risk updates accounting for schedule changes and unplanned activities.

Control of Heavv Loads The inspectors reviewed NextEra's activities to control the lift of heavy loads in accordance with plant procedures and the commitments to NUREG 0612. The inspectors observed the lift preparations and lift activities to verify adherence to established procedures and controls. The inspectors used an operating experience smart sample as a reference for this review.

Clearance Activities and Configuration Control The inspectors reviewed a sample of risk significant clearance activities and verified tags were properly hung and/or removed, equipment was appropriately configured per the clearance reqUirement, and that the clearance did not impact equipment credited to meet the shutdown critical safety functions.

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Inventory Control The inspectors reviewed NextEra actions to establish, monitor and maintain the proper water inventory in the reactor during the outage, and in the reactor and spent fuel pool after flooding the reactor cavity for refueling activities. The inspectors reviewed the plant system flow paths and configurations established for reactor makeup and reactivity control, and verified the configurations were consistent with the outage plan.

Reduced Inventory and Mid-Loop Condition§ The inspectors reviewed NextEra's procedures to implement commitments from Generic Letter 88-17 and confirmed, by sampling, that the controls were in place and adequate.

The inspectors reviewed outage activities that were conducted during periods when there was a short time-Io-boil to assure adequate controls were in place. Periodically, during the decreased inventory and mid-loop conditions, the inspectors verified that the configurations of the plant systems were in accordance with the commitments. During mid-loop operations. the inspectors observed NextEra'g control of distractions to assure the operator could maintain the required reactor vessel level.

Foreign Material Exclusion The inspectors reviewed the implementation of Seabrook procedures for foreign material exclusion control (FME) for the open reactor vessel, reactor cavity and spent fuel pool.

The inspectors reviewed NextEra actions to verify that FME issues were documented and resolved.

Electrical Power The inspectors verified that the status of electrical systems met TS requirements and the outage risk control plan. The inspectors verified that compensatory measures were implemented when electrical power supplies were impacted by outage work activities and that credited backup power supplies were available.

RHR System Monitoring The inspectors observed spent fuel pool (SFP) and reactor decay heat removal system status and operating parameters to verify that the cooling systems operated properly.

The review included periodic review of SFP and reactor cavity level, temperature, and RHR flow. The inspectors reviewed system status to verify the proper system alignment was established for vessel and cavity level measurement.

Containment Control The inspectors reviewed NextEra activities during the outage to control primary containment closure and integrity, and to prepare the containment for closure prior to plant restart. The inspectors performed tours of aJllevels in the containment throughout the outage and prior to plant startup per procedure OS 1 015.18 to review NextEra's cleanup and demobilization controls in areas where work was completed to assure that tools, materials and debris were removed. This review focused on the control of transient combustibles and the removal of debris that could impact the performance of safety systems.

Monitoring Plant Heat up, Approach to Critical and Startup The inspectors observed operator performance during the plant startup activities conducted between November 1 and 14,2009. The inspl:lction consisted of control room observations, plant tours and a review of the operator logs, plant computer information, and station procedures. The inspectors observed pre-job briefs for key I

i evolutions. The inspectors reviewed the preparations for changes in operating modes.

The reactor was taken critical on November 9 at 2: 16 a.m., and entered operational Mode 1 at 8: 13 a.m. The inspectors verified, on a sampling basis, that TS, license conditions, and other requirements for mode.changes were met. The inspectors verified RCS integrity throughout the restart process by periodically reviewing RCS leakage calculations and by review of systems that monitor conditions inside the containment.

Problem Identification and Resolution The inspectors verified that NextEra was identifying outa!~e related issues and had entered them into the corrective action program. The inspectors also reviewed a sample of the corrective actions to verify they were appropriate to resolve the identified issues.

b. Findings

No findings of significance were identified.

. 2 Maintenance Outage F013

a. Inspection Scope

The inspectors completed one refueling and outage activities inspection sample. The inspectors reviewed the operational, maintenance, and testing activities for the forced outage (F013) that started on December 6, 2009. The references used for this inspection are listed in the Attachment.

Monitoring of Plant Shutdown and Cooldown Activities The inspectors reviewed NextEra action to shut the plant down in accordance with plant procedures. The inspectors observed completion of various activities required to place the plant in a cold shutdown condition to assess operator performance, communications, command and control and procedure adhen:mce. The inspectors reviewed operator adherence to TS required cooldown limits.

Electrical Power The inspectors verified that the status of electrical systems met TS requirements and the outage risk control plan. The inspectors verified that compensatory measures were implemented when electrical power supplies were impacted by outage work activities and that credited backup power supplies were available.

RHR System Monitoring The inspectors observed reactor decay heat removal sys;tem status and operating parametersto verify that the cooling systems operated properly. The review included periodic review of RHR flow. The inspectors reviewed system status to verify the proper system alignment was established for reactor and pressurizer level measurement.

Monitoring Plant Heat ul? Approach to Critical and Startu.Q The inspectors observed operator performance and reviE!wed plant startup activities conducted between December 14 and 26, 2009. The inspection consisted of control room observations, plant tours and a review of the operator logs, plant computer information, and station procedures. The inspectors observed pre-job briefs for key evolutions. The inspectors reviewed the preparations for changes in operating modes.

The reactor was taken critical on December 16 at 5:25 p.m., and entered operational Mode 1 at 11: 17 p.m. The inspectors verified, on a sampling basis, that TS, license conditions, and other requirements for mode changes were met. The inspectors verified RCS integrity throughout the restart process by periodically reviewing RCS leakage calculations and by review of systems that monitor conditions inside the containment.

Problem Identification and Resolution The inspectors verified that NextEra was identifying outage related issues and had entered them into the corrective action program. The inspectors reviewed a sample of the corrective actions to verify they were appropriate to rE~solve the identified issues.

b. Findings

No findings of significance were identified.

1

R22 Surveillance Testing

a. Inspection Scope

The inspectors completed frve surveillance testing inspection samples. The inspectors observed portions of surveillance testing activities for safHty-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 TS and surveillance procedures. The inspectors attended selectod 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 op,erators. The test data recorded was compared to procedural and TS requirements, and to prior tests to identify adverse trends. The following surveillance activities were reviewed:

• EX1804.047, Reactor Coolant System Pressure Isolation Valve Leakage Rate Tests on October 22 and November 6,2009;

• OX1405.13, Train A Safety Injection Comprehensive Pump Test on October 6, 2009;

• OX1401.02, RCS Leak Rate Calculation, on November 15~30, 2009;

• RS1748, Subcritical Physics Testing, on November 6-7,2009; and

• OX1426.20/32, Diesel Generator 1N1 B '18 Month Operability and Engineered Safeguards Pump and Valve Response Time Testing on November 2-5, 2009.

The inspectors reviewed deficiencies related to surveillance testing and verified that the issues were entered into the corrective action program. Documents reviewed for this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

Annual Licensed Operator Requalification

.1 The inspectors completed one drill evaluation inspection sample. On November 17,

2009, the inspectors observed a drill from the control room simulator during annual licensed operator requalification training. The inspectors evaluated the drill performance relative to developing event classifications and notifications. The inspectors reviewed the Seabrook Emergency Initiating Condition Matrix. ThE~ inspectors referenced Nuclear Energy Institute 99-02, "Regulatory Assessment PI Guideline," Revision 5, and verified that NextEra correctly counted the drill's contribution to the NRC PI for drill and exercise performance.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

20S1 Access to Radiological Significant Areas (71121.01 - 11 samples)

a. Inspection Scope

During the period October 19 - 22, 2009, the inspectors conducted the following activities to verify that NextEra was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas, and other radiological controlled areas (RCA) during the refueling outage (ORi3), 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 TS, and NextEra's procedures.

.

This activity represents the completion of eleven sample~; relative to this inspection area, Plant Walkdown and RWP Reviews The inspectors identified exposure significant work areas in the containment building and primary auxiliary building (PAB) for ongoing outage activities. Tasks in the containment building.included ECT of steam generator tubes, core barrel transfer to the reactor vessel, maintenance on valve CS-V-180, cavity decontamination in preparation for taking measurements of the B~hot leg reactor nozzle. and various support work including demobilization of steam generator tasks. Tasks in the PAB included weld repairs to B RHR system mixing tee. The inspectors reviewed the radiation work permits (RWP) and the radiation survey maps associated with these work areas to determine if the radiological controls were acceptable.

The inspectors toured accessible radiological controlled areas located in the Containment Building, Primary Auxiliary BUilding, Decay Heat Vaults, Fuel Storage Building. and Waste Processing Building, with radiation protection supervision. The inspectors performed independent radiation surveys in thl9se areas to confirm the accuracy of survey maps and the adequacy of postings and barricades.

In reviewing RWPs, the inspectors evaluated electronic dosimeter (ED) locations on personnel and dose/dose rate alarm set points to determine if ED placement was in the highest dose field and that the set points were consistent with the area radiological conditions and plant policy. The inspectors verified that the workers were knowledgeable of the actions to be taken when the electronic dosimeter alarms or malfunctions for tasks being performed under selected RWPs.

Problem Identification and Resolution I.

The inspectors reviewed elements of NextEra's corrective action program related to j.

controlling access to radiological controlled areas to dete rmine if problems were entered into the program for resolution. The inspectors reviewed daily quality summaries, a radiation control program audit, and condition reports.

Additionally, the inspectors reviewed dose and dose rate alarm reports, personnel contamination event reports, whole body counting data, dose extension authorizations, and dosimetry abnormality occunrence reports to verify that causes were determined, for the incidents related to worker performance and contamination control, and that no relevant performance indicator or regulatory limit was exeeeded.

Jobs-I n-Progress The inspectors observed aspects of various outage related tasks being performed during this inspection period to verify that radiological controls. such as required surveys, area

!.

postings, job coverage, air sampling,and pre,-job RWP briefings were appropriately conducted; personnel dosimetry was appropriately worn; and that workers were I

k*nowledgeable of work area radiological conditions. Tasks observed included core i

barrel transfer, preparations for reactor cavity draindown/decontamination, steam generator ECT demobilization, and preparations for taking B-reactor hot leg nozzle measurements.

The inspectors evaluated the exposure mitigation requirements, specified in ALARA reviews (AR), and associated RWPs, and compared actual worker cumulative exposure to estimated dose for tasks associated with these work activities. Jobs reviewed included reactor vessel disassembly/reassembly (AR 09-01), steam generator ECT (AR 09-02), steam generator secondary side maintenance (AR 09-03), in-service inspections (AR 09-04), cavity decon (AR 09-05), valve maintenance (AR 09-07), scaffolding installation/removal (AR 09-11), and RHR mixing tee repairs (AR 09-13).

High Risk Significant. High Dose Rate HRA, and VHRA Controls The inspectors discussed with the Radiation Protection Manager and senior technicians high radiation area (HRA) and very high radiation area (VHRA) controls and procedures.

These special areas included under reactor vessel areas and spent fuel transfer routes in containment, spent resin sluicing paths and spent resin storage locations in the primary auxiliary building, and irradiated hardware stored in the spent fuel pool. The inspectors evaluated the pre-requisite communications, procedural authorizations, and operational controls that must be implemented prior to conducting activities in these plant areas. The inspectors verified that any changes to relevant NextEra procedures did not substantially reduce the effectiveness and level of worker protection.

Keys to locked high radiation areas (LHRA) and VHRAs, maintained at the radiation protection main and alternate control pOints were inventoried, and accessible LHRAs were verified to be properly secured and posted during plant tours.

Radiation Worker/Radiation Protection Technician Performance The inspectors-observed radiation worker and radiation protection technician performance by attending various pre-job/RWP briefings, observing activities in progress, and questioning individuals regarding their knowledge of radiological controls and contamination control measures applied to their tasks when working in the RCA.

The inspectors reviewed conditions reports related to radiation worker and radiation protection technician errors to determine if an observablEI pattern traceable to a common cause was evident.

b. Findings

No findings of significance were identified.

20S2 ALARA Planning and Controls (71121.02 - f5 samples)

a. Inspection Scope

During the period October 19 - 22, 2009, the: inspectors conducted the following activities to verify that NextEra was properly imptementing operational, engineering, and administrative controls to maintain personnel exposure as low as is reasonably achievable (ALARA) for tasks conducted during the refueling outage (OR13).

Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and NextEra's procedures.

This inspection activity represents completion of six

(6) samples relative to this inspection area.

Radiological Work Planning The inspectors reviewed pertinent information regarding the site's cumulative exposure history, current exposure trends, and ongoing activities to assess current performance and exposure challenges. The inspectors determined thE~ plant's 3-year rolling collective average exposure and concluded that the site is ranked in the top performance quartile for U.S. pressurized water reactors.

The inspectors reviewed the refueling outage work scheduled during the inspection period and the associated work activity exposure estimates. Scheduled work included steam generator tube eddy current testing (ECT), reactor core barrel transfer, reactor cavity draindown/decontamination, B RHR system mixing tee piping repairs, B reactor hot leg nozzle measurements and valve maintenance. As part of this review, the inspectors evaluated the dose estimates for these jobs and reviewed the associated ALARA Plans. The inspectors also reviewed the procedures associated with maintaining worker dose ALARA and with estimating and tracking work activity specific exposures.

The inspectors reviewed the daily OR13 Project Dose Summary Report that detailed the worker estimated and actual exposures through October 22,2009, for jobs performed during the refueling outage.

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 interviewing the Radiation Protection Manager and the ALAHA Coordinator, reviewing Radiation Safety Committee meeting minutes, reviewing outage-related NI",c1ear Assurance Daily Quality Summary Reports, observing jobs-in~progress, and attending the pre-job briefing for reactor cavity decontamination.

The inspectors determined that work activity planning included the use of remote audio/video monitoring, temporary shielding, system flushes, relocation of isolated sources away from occupied work areas, and operational considerations to further minimize worker dose. In doing this evaluation, the inspectors reviewed temporary shielding requests, cavity decontamination pre-requisites, and shutdown chemistry requirements.

Verification of Dose Estimates and Exposure TrackIng Systems The inspectors reviewed the assumptions and basis for the current annual collective exposure estimates for the operating cycle and refueling outage and compared this to actual exposure data. The inspectors reviewed NextEra's method for adjusting exposure estimates, and re-planning work, based on work progress.

The inspectors reviewed NextEra's exposure tracking system to verify that the level of dose tracking detail, exposure report timeliness, and exposure report distribution was sufficient to support the control of collective and individual exposures. Included in review were electronic dose and dose rate alarm reports, daily dose reports for ongoing activities, and identification of the highest indrvidual dose receptors.

Job Site Inspection and ALARA Control The inspectors observed maintenance and operational activities being performed for steam generator tube ECTltube plugging, reactor cavity decontamination, containment building demobilization, repairs to the B-RHR mixing tee, and preparations for taking measurements of the B reactor hot leg nozzle to verify that pre-requisite radiological controls were implemented and workers were knowledgeable of work area radiological conditions and ALARA practices.

Source Term Reduction Control The inspectors reviewed the current status and historical trends of the site's source terms. Through interviews with the Chemistry Supervisor and Radiation Protection Manager, the inspectors evaluated the effectiveness of NextEra's source term control strategy. Specific strategies being employed by NextEra included post-shutdown peroxide flushes of the reactor coolant system, use of a macro-porous resin for coolant cleanup, use of submersible filtration systems for reactor cavity cleanup, relocating irradiated components away from work areas, and use of temporary shielding for various tasks.

Radiation Worker Performance The inspectors observed radiation worker and health physics technician performance during core barrel transfer, cavity decontamination, and steam generator ECT at the centralized monitoring station. The inspectors determined whether the workers were aware of current radiological conditions, access controls, and that the skill level was sufficient with respect to effectively performing their tasks and implementing proper ALARA practices.

The inspectors attended the pre-job briefing for an exposure significant task, reactor cavity decontamination. The inspectors determined that roles and responsibilities were identified, that the sequencing of various activities were iterated, and that lessons learned from past cavity decontamination tasks were reviewed.

The inspectors reviewed condition reports, related to radiation worker and radiation protection technician errors, and personnel contamination reports (PCR) to determine if an observable pattern traceable to a similar cause was evident.

Declared Pregnant Workers The inspectors determined that there were no declared pregnant workers performing outage related activities in the RCA during the inspection period.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01 - 3 samples)

a. Inspection Scope

During the period December 7-10,2009, the inspectors c:onducted the following activities to verify that NextEra was properly maintaining the gaseous and liquid processing systems to ensure that radiological releases were properly mitigated, monitored, and evaluated with respect to public exposure. Implementation of these controls was reviewed against the criteria contained in the 10 CFR 20 and 50, Technical Specifications, the site Off-site Dose Calculation Manual (ODCM), and NextEra's procedures. This inspection activity represents completion of three samples relative to this inspection area.

The inspectors reviewed the 2007 and 2008 Annual Radioactive Effluent Release Reports to verify that the effluent programs were implemEmted as required by the Off-site Dose Calculation Manual (ODCM). As part of this review, changes made to the ODCM were evaluated to determine if the changes affected NextEra's ability to maintain effluent doses as low as is reasonably achievable (ALARA).

The inspectors walked down the major components of the gaseous and liquid effluent monitoring systems, with a senior chemist, to verify that tl1e system configuration complied with the FSAR description, and to evaluate equ~pment material condition.

Radiation monitors inspected included the following:

Uq uid Monitors:

RM-6521, Turbine Building Surnp RM-6519, Steam Generator Slowdown Flash Tank RM-6473, Condenser Polisher RM-6515. Primary Component Cooling Water RM-6509, Liquid Radwaste Gas Monitors:

RM-CP-510, Turbine Gland Seal Condenser Exhaust RM-6505, Condenser Air Removal RM-6503, Waste Gas Compressor Inlet RM-6504; Hydrogen Compressor Discharge RM-6528. Plant Vent (Wide Range Gas Monitor)

The inspectors reviewed the associated procedures and observed technicians collecting weekly air particulate. iodine and noble gas grab sample!; from the plant vent effluent radiation monitor and preparing a liquid waste discharge permit.

The inspectors reviewed the most current liquid and gaseous effluent monitor calibration results to verify that the instrumentation met the operability acceptance criteria. and that associated flow instruments and isolation valves were operable. Liquid monitor calibration data reviewed included the waste test tank (WTT) discharge flow isolation valves (1WL-FCV-1458-1/2), WTT radiation monitor (RM-6509), and the turbine building sump radiation monitor (RM-6521). Gaseous effluent instrumentation reviewed included the plant vent radiation monitor (RM-6528), condenser air evacuator (RM~6505), waste gas compressor monitor (RM-6503), and hYljrogen gas compressor discharge monitor (RM-6504).

The inspectors reviewed the air cleaning system surveill;:;!lnce test results for HEPA (high efficiency particulate absolute) and charcoal filtration systems, to ensure the components met their acceptance criteria. The inspectors confirmed that the air flow rates were consistent with the ODCM values. Data reviewed included the containment recirculation filtration (1-CAH-F-8), containment air purge filtration (1-CAP-F-40), primary auxiliary building exhaust ventilation filtration (1-PAB-F~16), and fuel storage building cleanup filtration (1-FAH-F-41).

The inspectors reviewed selected liquid and gas discharge permits for recent releases.

The inspectors confirmed that, prior to any batch release, effluent samples were taken and analyzed, off-site doses were calculated, and the associated radiation monitor alarm set points were appropriate to mitigate an off normal discharge. The inspectors confirmed that hard-to-detect radioisotopes. identified in 10 CFR 61 analyses, were accounted for in preparing the discharge permits.

The inspectors reviewed monthly, quarterly. and annual dose projections for liquid and gaseous effluents performed during the past 12 months to verify that the effluent was processed and released in accordance with ODCM requirements. The inspectors also confirmed that no RETS/ODCM performance indicator criteria was exceeded for this time period.

The inspectors reviewed the calibration records and daily quality control records for the counting room gamma spectroscopy and scintillation counting instrumentation to determine if the required lower limits of detection {LLD} were achievable and that effluent samples were adequately quantified and evaluated. The inspectors reviewed the results of NextEra's inter-laboratory cross check program to verify the quality and accuracy of effluent sample analysis performed by NextEra.

The inspectors reviewed relevant condition reports, nuclear assurance daily quality summary reports, quarterly radiation monitoring system health reports, and a nuclear quality assurance audit to evaluate NextEra's threshold for identifying, evaluating, and resolving problems in implementing the RETS/ODCM. This review was conducted against the criteria contained in 10 CFR Parts 20 and 50, the ODCM, and NextEra's procedures.

The inspectors verified that the radiological liquid and gaseous effluent dose calculation software, used for the generation of discharge permits, was included in the corporate validation and verification (V&V) program, to ensure that the software currently in use provided accurate dose projections.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

40A1 Performance Indicator Verification (71151 - 6 samples)

a. Inspection Scope

The inspectors reviewed NextEra information from the third quarter of 2008 to the third quarter of 2009 for the Seabrook performance indicators (Pis) listed below: To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in NEI 99-02; "Regulatory Assessment Indicator Guideline," Revision 5, was used to verify the basis in reporting each data element.

Cornerstone: Mitigating System

The inspectors reviewed NextEra submittals and data for the Seabrook mitigating systems performance index (MSPI) Pis listed below.

• High Pressure Injection MSPI

• Heat Removal Systems MSPI

• Residual Heat Removal MSPI The inspectors reviewed the consolidated MSPI data entry 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 equipmenVoperabHity issues database, the site operating history database, key performance indicator summary records, operating data reports and the MSPI basis document.

Cornerstone: Barrier Integrity

• Reactor Coolant System leakage

!

I' j.

The inspectors reviewed RCS leak rate data as part of their daily monitoring of I

plant status. The inspectors reviewed the dl3termination of an RCS leak rate on I

November 15-30, 2009, per procedure OX1401.02. The inspectors reviewed LERs,

[

operating logs, procedures, and interviewed applicable personnel to verify the accuracy and completeness of the reported data.

I

Cornerstone: Occupational Radiation Safety

I

• Occupational Exposure Control Effectiveness I

The inspectors reviewed implementation of NextEra's Occupational Exposure Control Effectiveness PI Program. Specifically, the inspectors reviewed condition reports, and I

associated documents, for occurrences involving locked high radiation areas, very high

!

radiation areas, and unplanned exposures against the criteria specified in NEI 99*02, Regulatory Assessment Performance Indicator Guideline, to verify that all occurrences that met the NEI criteria were identified and reported as performance indicators. This inspection activity represents the completion of one sample relative to this inspection area; completing the annual inspection requirement.

Cornerstone: Public Radiation Safety

• RETS/ODCM Radiological Effluent Occurrences The inspectors reviewed relevant effluent release condition reports for the period October 1, 2008 through November 30, 2009, for issues related to the public radiation safety PI, which measures radiological effluent release occurrences that exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr of!~an dose for liquid effluents; 5mrads/qtr gamma air dose, 10 mrad/qtr beta air dose, and 7.5 mrads/qtr for organ dose for gaseous effluents. This inspection activity represents the completion of one sample relative to this inspection area; completing the annual inspection requirement.

The inspectors reviewed the following documents to ensure NextEra met all requirements of the performance indicator from the fourth quarter 2008 through the third quarter 2009:

• Monthly projected dose assessment results due to radioactive liquid and gaseous effluent releases; and

• Quarterly projected dose assessment re~surts due to radioactive liquid and gaseous effluent releases; and dose assessment procedures.

b. Findings

No findings of significance were identified.

40A2 Identification and Resolution of Problems (1"1152 - 2 samples)

.1 Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As required by Inspection Procedure 71152, "Identificatic.n 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 items entered into the Seabrook corrective action program (CAP). This review was accomplished by accessing NextEra's computerized database.

b. Findings

No findings of significance were identified.

. 2 Semi-annual Review to Identify Trends

a. Inspection Scope

As required by Inspection Procedure 71152, "Problem Identification and Resolution," the inspectors performed a review of the Seabrook CAP and associated documents to identify trends that may indicate existence of safety signi'ficant issues. The inspectors' review was focused on repetitive equipment and corrective maintenance issues, but also considered the results of daily CAP item screening. The inspectors compared their results with the results contained in the Seabrook CAP Quarterly Trend Reports.

b.

Assessment and Observations NO findings of significance were identified. The inspectors did not identify any trends that NextEra had not already identified.

. 3 Annual Sample -- Low Strength bolts in RHR System

a. Inspection Scope

The inspectors reviewed the identification. evaluation, and actions taken by NextEra at Seabrook Station to address the risk due to missing surveillance of the SG and Pressurizer manway Class 1 bolting material. This condition was first identified on June 9, 2009, during a nuclear oversight audit of the in~service inspection program.

Previous NRC review of this topic was documented in IR OS000443/2009003.

b. Findings and Observations

NextEra obtained a relief from NRC from the requirements of ASME Code subparagraph IWA-5141(a). NRC granted Alternative Request 2AR-04, and approved use of ASME Code Case N-616 in lieu of the original requirement. However, the Code Case imposes some restrictions, and one of these restrictions is that jf the bolting'is corrosion resistant, and the bolting materials contain a minimum of 10% chromium, then bolt inspections can be performed without removing the insulation. Although, the bolting material for the bolts in question were SA-193 Gr. 87 (studs) and SA-194 Gr. 7 (nuts), it did not contain 10%

chromium as required by the Code Case. Thus, bolt inspections should have been conducted with the insulation removed. Because this was not done NextEra did not satisfy the VT2 surveillance requirement imposed by the TS 4.0.S{a). This deficiency was documented in CR00198881, The inspectors determined that NextEra adequately implemented the corrective action process following the discovery of the issue. NextEra completed an appropriate operability evaluation and initiated corrective action to satisfy the code requirement. A detailed analysis and risk evaluation was performed to determine corrective actions.

The evaluation concluded that the missed surveillance did not impact plant operations.

However, WR 94001194 was issued to perform the VT2 on these bolts. The inspections, completed during OR13, did not identify any unacceptable conditions. The I

inspectors determined that corrective actions were timely and appropriate to prevent I

recurrence of the issue.

I 40A3 Event Follow Up (71153 - 2 Samples)

.1 Reactor Protection System Actuation on Steam Generator Low Water Level

a. Inspection Scope

I On October 1, 2009, the operators cooled down the plant in preparation for OR13. At I'

10:41 p.m. with the plant at 260 degrees in MODE 4, a reactor protection system (RPS)actuation occurred due to low water levels in the A and C SGs. RPS actuated when the operators failed to adequately control SG levels during the plant cooldown. The RPS t

actuation did not cause a plant transient because the reactor trip breakers were already opened and the emergency feedwater system was removed from service.

NextEra's cause analysis determined that in preparation to secure a reactor coolant pump (Rep), the operators raised SG levels in anticipation of level shrink within the SG.

Level was raised to 40% (narrow range) using automatic feed water controls and allowed to stabilize. The operators then added more feedwater using manual feedwater control to further raise 5G level. The additional relatively cool water caused an unexpected level shrink and the RPS actuation. The operators responded to restore SG levels and entered the action statement for TS 3.4.1.3.b while SG levels were below 14%. The operators recovered SG levels at approximately 11 :07 p.m.

The inspectors reviewed operator actions to recover the affected SG level, reviewed the plant system response and the operator use of plant normal and abnormal operating procedures during the event, and examined the corrective actions to address SG level control. The inspectors reviewed NextEra's root cause evaluation included as part of AR 206507206507 The event evaluation considered: the event cause, extent of condition, risk and consequence assessment, evaluation of plant response. and the operator performance.

The causes for the event included the operator's failure to properly control steam generator level (direct cause), and the operator's failure to adequately implement operating procedure 051000.15 when cooling down the plant (root cause). The inspectors reviewed the bases for NextEra's determination that safety systems functioned as designed and that the plant responded as designed. The inspectors reviewed NextEra's actions to enhance operations procedures, training, and performance. Documents reviewed for this inspection ar,s listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 (Closed) LER 05000443/2009001. Reactor Protection System Actuation on Steam

Generator Low Water Level This LER was submitted in accordance with 10 CFR 50. jr3(a)(2)(iv)(A) to report the valid actuation of RPS on October 1, 2009 (eight-hour event notification EN#45403). NRC review of this event is described in Section 40A3.1 above. The inspectors reviewed the accuracy of the 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 findings of significance werel identified and no violations of NRC requirements occurred. This LER is closed.

40A5 Other Activities

.1 Inspection Results for TI2515/172, RCS Dissimilar Metal Butt Welds (DMBWs)

a. Inspection Scope

Temporary Instruction (TI) 2515/172 requires confirmation that owners of pressurized water reactors (PWRs) have implemented the industry guidelines of the Materials Reliability Program (MRP)-139 regarding nondestructive examination and evaluation of certain dissimilar metal welds in reactor coolant systems containing Alloy 600/82/182.

The TI requires documentation of status of compliance with the MRP in this inspection report. The status of compliance and, responses to specific questions presented in the TI are included in Attachment B to this feeder report.

In summary, Seabrook Station completed the MRP required ultrasonic testing examination of all applicable remaining dissimilar metal butt welds in accordance with the ASME Code Section XI, Appendix VIII, Performance Demonstrations for Ultrasonic Examination Systems. Performance demonstration initiative (PDI) qualified automated UT procedures were used to perform the examination from the inside diameter of the dissimilar metal welds. The MRP-139 applicable OMBWs that were completed this outage consisted of four reactor coolant system (RCS) hot leg (Hl) outlet nozzles and four cold leg (Cl) inlet nozzles on the reactor vessel (RV).

In response to the discovery of an indication in the RCS D HL outlet nozzle at vessel 158 degree location, NextEra provided an A5ME Section X'*'WB-3600 flaw analysis. The analysis was documented in Seabrook Engineering Evaluation EE-09-016 and, in conjunction with the application of the stress improvement process (SI). supported operation for at least the next 18 months at which time the post SI specified volumetric examination will be performed.

In addition to the ASME analYSis, Seabrook elected to perform the 51 process on the RCS D HL outlet nozzle to mitigate potential growth of the flaw and defer the post SI process UT examination until OR14 in the Spring of 201'1. The performance of the volumetric UT examination specified by the MRP following the application of the SI process was considered a hardship. NextEra was permitted deviation from MRP requirements by Revision 3 to Materials Gu~deline Implementation Protocol. NEJ 03-08 Addendum E. In support of this postponement, NextEra prepared engineering evaluation EE-09-017 that provided the basis for deviaticJn from the MRP requirement to perform the examination prior to return to service. In lieu of the requirement for the post mitigation pre-service examination for both axial and circumferential indications from the inside diameter (lD) ofthe nozzle, the examination will be performed during OR14 (Spring 2011). The deviation applies to the Seabrook ReS D HL outlet nozzle to safe end weld at vessel 158 degree location. NextEra's commitment to perform the complete UT pre-service examination of the subject outlet nozzle tel safe end DMBWin OR14 will result in full compliance with MRP-139.

. 2 Independent Spent Fuel Storage Installation (lSFSI) Monitoring Controls (60855.1)

a. Scope

The inspectors reviewed routine operations and monitoring of the ISFSI. The inspectors walked down the ISFSI with a senior radiation protection technician. The inspectors performed independent dose rate measurements of the storage modules, confirmed the locations of dosimetry on the facility perimeter, and confirmed module temperatures were within the required limits. The inspectors also reviewed past temperature records for the ISFSI modules and environmental (ISFSI) dOSimetry data. Radiological control activities for the ISFSI wer~ evaluated against 10 CFR 20, ISFSI TS, and NextEra's procedures.

b. Findings

No findings of significance were identified.

. 3 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors performed observations of security force personnel and activities to ensure that the activities were consistent with site security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours. These quarterly resident inspector observations of security force' personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

40A6 Meetings. including Exit The inspectors presented the inspection results to Mr. Paul Freeman, Site Vice President, and Seabrook Station staff at the conclusion of the inspection on January 12, 2010. NextEra acknowledged the conclusions and observations presented. The inspectors also confirmed with NextEra that no proprietary information was reviewed by inspectors during the course of the inspection and that the content of this report includes no proprietary information.

40A7 Licensee-Identified Violations The following violation of NRC requirements was identified by NextEra, was determined to have very low significance (Green) and to meet the crif.eria of Section VI of the NRC Enforcement Policy, NUREG-1600, for beintl dispositione~d as a non-cited violation.

10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, NextEra did not assure that the dE/sign basis for safety-related buried cables was correctly translated into specifications, drawings, procedures, and instructions. Specifically, NextEra did not maintain safety-related underground cables in an environment for which they were designed. The cables were found submerged. This was identified in the corrective action program as 211808 to initiate review of the current manhole and cable monitoring programs, and to initiate long-term corrective actions.

This finding is of very low safety significance! (Green) because it did not represent an actual loss of safety function or contribute to external event core damage sequences.

AlTACHMENTS:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

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Licensee personnel

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R. Arn, Engineering

J. Ball. Maintenance Rule Coordinator

R. Belanger, Design Engineer

M. Bianco, Radiological Waste Services Supervisor

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B. Brown, Plant Engineer

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V. Brown, Senior Licensing Analyst

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K. Browne, Assistant Operations Manager

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B. Buerger, Nuclear Projects

J. Buyak, Senior Radiation Protection Technician, (Respiratory Protection)

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R. Campione, Nuclear Oversight Supervisor

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R. Campo, Plant Engineer

W. Cash, Chemistry Manager

T. Cassidy, Training Support Supervisor

D. Chang, Tagging Support

R. Couture, Reactor Engineer

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W. Cox, Radiological Waste Services, Senior Technical Analyst

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J. Crowley, I&C Superintendent

R. Duarte, Operations Training Supervisor

J. Esteves, Design Engineer Systems

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D. Feeney, Mechanical Maintenance

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D. Flahardy. RP Technical Supervisor

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P. Freeman, Site Vice President

R. Guthrie, Systems Engineer, Radiation Monitoring System

D. Hampton, Radiation Protection Specialist

F. Hannify, Radiological Waste Services. Senior Technical Analyst

D. Hickey, Radiation Protection Supervisor

M. Hansen, Maintenance Manager

R. Jamison, Design Engineer, Electrical

G. Kann, Dry Cask Storage Project Engineer

S. Kessinger, Work Control Supervisor

R. Logue, Senior Radiation Protection Technician, (Instrumentation)

G. Kim, Risk Analyst

M. Leone, Operations Training Instructor

E. Metcalf, Plant General Manager

M. Lipman, Plant Technician

T. Manning, Engineering

D. Master, Plant Engineer

B. McAllister, SW System Engineer

N. McCafferty, Plant Engineering Manager

W. Meyer, Radiation Protection Manager

D. Merrill, Maintenance Technical Superintendent

E. Metcalf, Plant General Manager

E. Momm, Acting Training Manager

M. O'Keefe, Licensing Manager

K. Mahoney, Reactor Engineer

R. Noble, Engineering Manager

M. Ossing, Engineering Support Manager

V. Pascucci, Quality Assurance Manager

D. Perkins, Rad Services Supervisor

E. Piggot, Unit Supervisor

R. Plante, Maintenance Supervisor

B. Plummer, Nuclear Projects Manager

N. Pond, Tagging Coordinator

K. Purington, Reactor Operator

K. Randall, Reactor Engineer

1. Rossengal, RHR System Engineer

M. Russell, Operations Clerk

M. Scannell, Senior Health Physicist

W. Schmidt, Electrical Maintenance

G. Sessler, EDG System Engineer

J, Soucie, Nuclear Plant Operator

G. St. Pierre, Vice President - Support

M. Taylor, Unit Superviso~

R. Thurlow. Corporate Radiation Protection Manager

J. Tucker, Security Manager

J. Varga, Reactor Operator

J. Walsh, evcs System Engineer

N. Walts, Unit Supervisor

S. Wellhofer, Site Nurse

R. White, Security Supervisor

K. Wright. Training Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed:

05000443/2009001 LER Reactor Protection System Actuation on Steam Generator Low Water Level (Section 40A3.2)