IR 05000443/2010003

IR 05000443-10-003, on 04-01-10 - 06-30-10, Seabrook Station, Unit 1, NRC Integrated Inspection Report

ML102250014
Person / Time
Site:	Seabrook
Issue date:	08/13/2010
From:	Arthur Burritt Reactor Projects Branch 3
To:	Freeman P NextEra Energy Seabrook
burritt al
References
IR-10-003
Download: ML102250014 (29)

Text

ust 13, 2010

SUBJECT:

SEABROOK STATION, UNIT NO.1 - NRC INTEGRATED INSPECTION REPORT 05000443/2010003

Dear Mr. Freeman:

On June 30, 2010, 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 July 1, 2010, with you and other members of your staff.

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

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

The report documents one NRC-identified finding of very low significance (Green) that was determined to involve a violation of NRC requirements. Additionally, one licensee-identified violation of very low safety significance is listed in this report. However, because of the very low safety significance of these two violations and because they were entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs)

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, A TIN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Seabrook Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis of your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Seabrook Station. 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 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).

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

Enclosure:

Inspection Report No. 05000443/2010003 wi Attachment: Supplemental Information

REGION I==

Docket No.: 50-443 License No.: NPF-86 Report No.: 05000443/2b10003 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No.1 Location: Seabrook, New Hampshire 03874 Dates: April 1, 2010 through June 30, 2010 Inspectors: W. Raymond, Senior Resident Inspector J. Johnson, Resident Inspector S. Ibarrola, Reactor Engineer Approved by: Arthur Burritt, Chief Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000443/2010003; 04/0112010-06/30/2010; Seabrook Station, Unit No.1; Plant

Modifications The report covered a three-month period of inspection by resident and regional specialist inspectors. One Green non-cited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using IMC 0609, "Significance Determination Process" (SDP) and the cross-cutting aspect of a finding is determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

A self-revealing non-cited violation of Technical Specification 6.7.1, Procedures and Programs, was identified related to the failure of the A EDG during a maintenance run per EC145293 on April 15, 2010. Specifically, NextEra did not provide adequate work instructions to control temporary test equipment attached to the EDG. This led to the failure of the jacket water cooling system that required operators to shutdown the engine, resulting in unplanned unavailability for the A EDG. The leak was promptly repaired and the EDG restored to a functional status on April 17, 2010. The issue was entered into the corrective action program as condition report 221321.

The finding is more than minor because it is associated with the work control attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate work instructions intended to flow balance the A EDG coolant system during an instrumented run, resulted in unplanned extended unavailability of the A EDG. The inspectors performed a Phase 1 Significance Determination Process (SDP) screening, in accordance with NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, and determined the issue was of very low safety significance because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, and was not potentially risk significant for external events. The finding had a cross-cutting aspect in the area of human performance - resources H.2.c] because the work instructions were not adequate to assure temporary test equipment was properly installed. (Section 1R18)

Other Findings

• A violation of very low safety significance, which was identified by NextEra, was 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 operated at full power for the period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Preparation

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspector completed one seasonal extreme weather conditions inspection sample.

The inspectors assessed NextEra's readiness for the onset of hot weather. The inspectors reviewed the updated final safety analysis report (UFSAR) descriptions for related design features and verified the adequacy of the station procedures for hot weather protection. The inspectors reviewed NextEra's actions per procedure ON1490.09 for seasonal readiness, and procedure OS1200.03 for severe weather.

The inspectors also conducted walkdowns of susceptible systems, specifically the emergency feedwater, electrical distribution and service water 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 Attachment.

b. Findings

No findings of significance were identified .

.2 Readiness of Offsite and Alternate AC Power Systems

a. Inspection Scope

The inspectors completed one summer readiness of offsite and alternate AC power systems inspection sample. The review focused on NextEra procedure OS1246.02, "Degraded Vital AC Power." The inspectors verified that plant features were maintained and procedures for operation were adequate to ensure the continued availability of AC power systems. The inspectors verified that communication protocols with the transmission system operator were adequate to ensure that appropriate information was exchanged when issues arose that could impact the offsite power system. The inspectors also observed NextEra's implementation of OS1246.02 during periods that challenged grid conditions between April 1 and June 30, 2010. The inspection included walkdowns of the onsite normal and emergency AC power systems and the inspectors reviewed deficiencies related to summer readiness of offsite and alternate AC power systems and verified these issues were entered into the corrective action program. The references used for this review are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R04 Eguipment Alignment (71111.04 - 3 samples, 71111.04S -1 sample)

.1 Partial Walkdown

a. Inspection Scope

The inspectors completed three partial system walk down 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. The documents reviewed are listed in the Attachment.

• B emergency diesel generator (EDG) during maintenance and testing of the A EDG on April 14-15, 2010

• Emergency feedwater (EFW) and emergency AC power supplies during maintenance and testing of the A EDG on May 18-19, 2010

• A and B EDG and support systems during planned maintenance for the supplemental emergency power systems (SEPS) on June 21, 2010

b. Findings

No findings of significance were identified .

.2 Complete Walkdown

a. Inspection Scope

The inspectors performed one complete system walk down inspection sample of the containment building spray system 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 Technical Specification (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 were properly labeled; that essential support systems were operational; and that ancillary equipment or debris did not interfere with system performance. The inspectors reviewed applicable piping and instrumentation drawings and system operational lineup procedures. The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

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1R05 Fire Protection (71111.05Q -7 samples, 71111.05A -1 sample)

.1 Quarterly Review of Fire Areas

a. Inspection Scope

The inspectors completed seven 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 firefighting equipment; the 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 Hazard

Analysis.

The documents reviewed are listed in the Attachment.

• SW-F-1-B-Z, Service Water Pump Room, MCC Rooms, 21 ft

• DG-F-1N2N3C-A, Diesel Generator Building, -16, 21, & 51 ft

• RHR-F-1D/1 C-Z, Train A and B RHR vaults - 61 ft

• ET-F-1N1B-A, A Electrical Tunnel East and West End 0 ft

• EFP-F-1A, Emergency Feedwater Pumps 27 ft

• IS-F-1 and DS-F-1, Intake and Discharge Transition Structures

• CT-F-2B, Service Water Cooling Tower Pump Room

b. Findings

No findings of significance were identified .

.2 Annual Inspection

a. Inspection Scope

The inspectors completed one annual fire drill observation inspection sample. The inspectors observed an unannounced fire brigade drill on April 29, 2010, on the 21' elevation of the turbine building. The inspectors observed brigade performance during the drill to evaluate the following: donning and use of protective equipment; fire brigade leader command and control; fire brigade response time; radio communications; and the use of pre-fire plans. The inspectors attended the post-drill critique and reviewed the disposition of issues and deficiencies identified during the drill. The inspectors also verified that all firefighting equipment used during the drill was returned to a condition of readiness.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

.1 Internal Flooding

a. Inspection Scope

The inspectors completed one flood protection measures inspection sample. The inspectors reviewed the flood protection measures designed to protect the emergency feedwater pump room from the effects of internal flooding. The inspectors reviewed NextEra's flooding evaluation for the selected areas, the availability and testing of turbine building flooding alarms and alarm response procedures. The inspectors also performed walk downs of the selected areas to verify that as-found equipment and conditions were consistent with the design basis documents. The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified .

.2 Cables in Underground Vaults

a. Inspection Scope

The inspectors completed one flood protection 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 W06 and W08 that contained cables for the safety-related service water pumps. These vaults were opened as part of the extent of condition review for the licensee identified violation that was described in Section 40A7 of NRC inspection report 05000443/2009005. The inspectors also performed tours of the selected areas to verify that conditions were consistent with the design basis documents. Documents reviewed for this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Resident Inspector Review

a. Inspection Scope

The inspectors completed one quarterly licensed operator requalification program inspection sample. The inspectors observed simulator examinations of licensed operators on June 17, 2010, for scenarios involving transients (loss of electrical power)and design basis events (reactor leakage). The inspectors reviewed operator actions to implement the abnormal and emergency operating procedures. The inspectors examined the operators capability 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 training 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

.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors completed two 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). For the periodic assessment inspection sample, the inspectors reviewed the assessment frequency, the performance criteria, the use of operating experience and corrective actions. The inspectors reviewed system health reports, maintenance backlogs, and MR basis documents. The documents reviewed are listed in the Attachment.

• Fuel handling equipment MR (a)(2) classification with a focus on equipment performance during outage OR#13 (AR207209 and 215416 on 1/16/2009)

• MR (a)(3) periodic evaluation for April 2008 through October 2009

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors completed six 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 inspectors reviewed the availability of opposite train and guarded and protected equipment. The compensatory measures were evaluated against Seabrook Maintenance Manual 4.14, Troubleshooting, and Work Management Manual 10.1, On-Line Maintenance. Risk assessments were conducted using Seabrook's "Safety Monitor", as applicable. The documents reviewed are listed in the Attachment. The inspectors reviewed the maintenance items listed below.

• Planned work associated with enclosure air handling fan 1-EAH-FN-31B on April 6, 2010 (WO 1195836, 613822)

• Emergent work associated with the A EDG on April 15 -17, 2010 (WO 01206145 and 0120175)

• Emergent work associated with the failure of the supplemental power system SEPS-2A on April 22, 2010 (W001196811, CR221641)

• Emergent work associated with FI-Q111 on April 22, 2010 (WO 01210562)

• Emergent work associated with the solid state protection system (SSPS) switch S927 on April 29, 2010 (WO 01207816)

• Planned work associated with circulating water pump CW-P-39A and strainer on May 4 - 7, 2010 (WO 01197699)

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors completed six operability evaluation inspection samples. The inspectors reviewed operability evaluations and condition reports to verify that identified 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. The 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 were reviewed:

• CR218893, operability of containment enclosure boundary with open door P307 on March 15 and March 17, 2010

• CR221185, service water system ocean water and cooling tower train operability with valve SW-V20 inoperable, April 15, 2010

• CR221 006, operability of boric acid tanks with level instruments not scaled correctly on April 16, 2010

• CR220912, operability of B hydrogen recombiner containment penetration over current protection devices on April 30, 2010

• CR 391967, operability of the diesel air handling fan (DAH-FN-25A) following identification of a motor coupling that was re-assembled with a non-quality part on May 26,2010

• CR392285, operability of D service water pump with through wall leak on discharge vent valve on May 28,2010

b. Findings

Findings related to the issues identified in CR218893 are described in Sections 40A3 and 40A7 of this report.

R18 Plant Modifications

.1 Permanent Modification - EC 145292: B EDG Vibrations

a. Inspection Scope

The inspectors completed one permanent modification inspection sample. The inspectors reviewed modification package EC 145292, which modified the right bank turbo charger on the B EDG to reduce vibrations. The review was completed to verify that the design bases and performance capability of the system was not degraded. The inspectors verified the new configuration was accurately reflected in the design documentation, and that the post-modification testing was adequate to ensure the SSCs would function properly. 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 permanent modifications. The 10 CFR 50.59 evaluation associated with this permanent modification was also reviewed. The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified .

.2 Temporarv Modification - EC 145293: A EDG Flow Balancing

a. Inspection Scope

The inspectors completed one temporary modification inspection sample. The inspectors reviewed modification package EC 145293, which attempted to adjust the flow balance on the A emergency diesel generator (EDG) coolant system. The review was completed to verify that the design bases and performance capability of the affected system was not degraded. The inspectors verified the configuration was accurately reflected in the plant documentation, and that the post-modification testing was adequate to ensure affected SSCs would function properly. The 10 CFR 50.59 evaluation associated with this temporary modification was also reviewed. The documents reviewed are listed in the Attachment.

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 EC145293 on April 15, 2010. After operating the diesel for about 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on April 15, NextEra stopped the test when flow balancing did not achieve the desired margin in lubricating oil temperature (CR221320). The inspectors reviewed NextEra actions when the A EDG became inoperable during implementation of EC145293 after a leak developed on the test equipment connected to the engine jacket cooling water (JCW) system (CR221321). The inspectors reviewed the causes for the failure.

b. Findings

Introduction.

A self-revealing non-cited violation of Technical Specification 6.7.1, Procedures and Programs, was identified related to the failure of the A EDG during a maintenance run per EC145293 on April 15, 2010. Specifically, NextEra did not provide adequate work instructions to control temporary test equipment attached to the EDG.

This led to a leak in the jacket water cooling system, which required operators to shutdown the engine, resulting in unplanned unavailability for the A EDG.

Description.

The A EDG was operated during a "maintenance" run from 10:00 a.m. to 4:30 p.m. on April 15 to perform JCW flow balancing in accordance with engineering change EC145293. The engineering change was implemented using work order WO 01206145 that also installed test equipment on April 15 to record engine data. The A EDG was considered inoperable during the flow balance activity but functional because it was capable of responding to a loss of power on emergency bus E5. While preparing to secure from EC145293, the operators performed an emergency shutdown of the EDG at 4:35 p.m. when a leak developed from the JCW pressure impulse line for pressure switch DG-PS-IPLA on the engine (reference CR221321). A temporary test equipment fitting (brass tubing) connecting a transducer to the impulse line had failed causing a jacket water coolant leak that sprayed down the front of the engine. Following the event, NextEra determined that despite the leak, there was reasonable assurance the A EDG would have performed its safety function. The diesel did not reach a condition that caused an automatic trip. An estimated 3 to 5 gallons of coolant was lost from the engine, which had minimal impact on coolant inventory. The leak from the failed fitting was easily isolable from the jacket cooling system by closing the sensing line isolation valve. However, the A EDG was considered inoperable and non-functional from about 4:30 p.m. to 6:30 p.m. during the spill response and recovery from the leak.

After the event a detailed walk down and inspection of wetted components was performed. NextEra identified that lube oil temperature controller DG-TCV-7A-2 was impacted by the spray. Despite the impact, the temperature controller maintained lubricating oil temperatures within normal parameters during a subsequent maintenance run on April 16, 2010. NextEra replaced the affected controller using WO 01210175 and declared the A EDG operable at 10:30 am on April 17, 2010. Although NextEra staff acted promptly following the leak to restore the A EDG to a functional and operable condition, the A EDG incurred more than two hours of unplanned unavailability during the subsequent leak recovery.

NextEra determined that the test equipment installed under EC145293 and WO 01206145 failed due to vibration induced fatigue of the brass metal fitting. The fitting failed because brass material was used instead of the stainless steel tubing specified in the work plan in WO 01206145. Although the fitting was adequate for the jacket water temperature and pressure (about 40 to 50 psi), the fitting with attached transducer was not evaluated for, and could not withstand, the vibrations in the test connection during diesel operation. As a consequence, the A EDG jacket water cooling line was placed in a condition to fail during continued diesel operation with the temporary equipment installed.

The inspectors determined that the work instructions used to implement flow balance measurements were not adequate to ensure the job was completed successfully. Work Order 01206145 contained insufficient guidance on selecting the tubing materials and connecting the test equipment. The work order specified that "tubing used to connect the transducers should be stainless steel or other high pressure tubing," which allowed the use of tubing other than stainless steel that the worker selected from shop supplies.

The work order did not incorporate NextEra's accepted practices contained in the written "I&C Standing Expectations". This document stated that for the connection of temporary equipment to "use only Black Flexible DH 400 Tube (6000 psig) or 1/8 inch stainless steel (8700 psig) for connection to inservice components." Finally, the work order did not considered all relevant conditions specific to installing test equipment on an operating diesel, such as mechanical stress due to engine vibrations or the moment arm created by the transducer mounting configuration.

The worker who connected the test equipment was aware of the "I&C Standing Expectations," but believed he followed the directions to use substitute tubing allowed under the approved work plan. Thus, while the lack of a questioning attitude by the worker was a missed opportunity to have prevented the event, the inspectors concluded that the primary cause of the leak was insufficient guidance in the work package.

Seabrook Technical Specification 6.7.1 requires that written procedures be established and implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, states that maintenance that can affect the performance of safety related equipment should be performed in accordance with written procedures appropriate to the circumstances. The Seabrook Station Work Manual (SSWM) and Maintenance Administrative program (SSMA) were developed pursuant to the above to establish maintenance control measures for safety related components, including the emergency diesel generators. Procedures WM-AA-200, "Work Process" and WM-AA-203,"Work Order Planning," implement the work management program using the work order process. WM-AA-203, Section 4.1 states that the work package should contain all applicable information and requirements for the work group to safely and successfully complete the job. Section 4.8.5 of WM-AA-203 requires work tasks have instructions that provide clear and unambiguous guidance.

Work order W001206145, Task Step 12, directed workers to attach test equipment to the impulse line between DGA-PS-IPLA and DG-V-146A, and to ensure the transducer was at the same elevation as pressure switch DGA-PS-IPLA. The work order did not provide sufficient guidance to assure temporary equipment would be successfully connected without adversely impacting the diesel. The work order specified that stainless steel tubing be used but also allowed other high pressure tubing without controlling installation details. The work instructions did not incorporate accepted practice related to the use of specific tubing, and did not consider engine vibration or address installation details such as the moment arm in the transducer-tubing connection.

Analysis.

The inspectors determined that the inadequate work instruction, which led to the failure of the A EDG jacket water cooling system that resulted in unplanned A EDG unavailability, was a performance deficiency. The inspectors determined that the finding is more than minor because it is associated with the work control attribute of the Mitigating Systems Cornerstone and it affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate work instructions intended to flow balance the A EDG coolant system during an instrumented run, resulted in unplanned extended unavailability of the A EDG. The inspectors performed a Phase 1 Significance Determination Process (SDP) screening, in accordance with NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined the issue was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, and was not potentially risk significant for external events.

This finding had a cross-cutting aspect in the area of human performance - resources (H.2(c)) because the instruction to workers was not adequate to assure the temporary test equipment was properly installed on the diesel cooling system. Specifically, the work order provided vague guidance on the use of tubing, did not consider best practices, did not consider engine vibrations, and did not control installation details.

Enforcement.

Seabrook Technical Specification 6.7.1 requires that written procedure be established and implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, states that maintenance that can affect the performance of safety related equipment should be performed in accordance with written procedures appropriate to the circumstances. Contrary to the above, design change EC145293, implemented by Work Order 01206145 on April 15, 2010 for the A EDG, did not provide adequate instructions to connect temporary equipment without adversely impacting A EDG's availability. This led to a leak in the jacket water cooling system that required operators to shutdown the A EDG, resulting in unplanned unavailability. Because this finding was of very low safety significance and was entered into the corrective action program as Condition Report 221321, this violation is being treated as a non-cited violation (NCV), consistent with section VI,A of the NRC Enforcement Policy. (NCV 05000443/2010003-01, Failure to provide adequate work instructions to install test equipment caused the A EDG to be inoperable).

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors completed seven 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 the maintenance work performed. The inspectors evaluated the test acceptance criteria to verify that the test procedure ensured that the affected systems and components satisfied applicable design, licensing bases and TS requirements. The inspectors also reviewed recorded test data to confirm all acceptance criteria were satisfied during testing. The documents reviewed are listed in the Attachment. The activities reviewed are listed below.

• Retest of the A emergency diesel generator on April 17, 2010, following flow balancing and leak repair per WO 01206145

• Retest of SEPS-2A on April 22, 2010, following repairs to the engine jacket coolant water trip circuit per WO 01196811

• Retest of 13.8 kV Bus 2 synchronization check relay R25 following repair on June 8, 2010, per WO 01383053

• Retest of the enclosure air handling fan (1-EAH-FN-5A) on April 22, 2010, following maintenance to address excessive vibrations per WO 1210576

• Retest of the battery charger (1-EDE-BC-1 D) on April 2, 2010, following maintenance per WO 1203896

• Retest of service water pump (1-SW-P-41 D) on April 2, 2010, following replacement of the shaft sleeve and discharge check valve (1-SW-V-30-M7) per WO 626898

• Retest of the ROMS Communications and CP-295 data for Emergency Plan EAL SU3 Classifications following on May 27, 2010, maintenance per WO 01382165

b. Findings

No findings of significance were identified.

1

R22 Surveillance Testing

a. Inspection Scope

The inspectors completed six surveillance testing inspection samples. The inspectors observed portions of surveillance testing activities for safety-related systems to verify that the system and components were capable of performing their intended safety function, to verify operational readiness, and to ensure compliance with required TS and surveillance procedures. The inspectors attended selected pre-evolution briefings, performed system and control room walk downs, observed operators and technicians perform test evolutions, reviewed system parameters, and interviewed the system engineers and field operators. In order to identify adverse trends the recorded test data was compared to prior test results and procedure and TS requirements. The documents reviewed are listed in the Attachment. The following surveillance activities were reviewed.

• OX1410.02, Quarterly Rod Operability Surveillance, Revision 10, on May 7,2010 (WO 1201121)

• OX1426.05, DG 1B Monthly Operability Surveillance, Revision 17A, on April 28, 2010 (WO 1197257)

• OX1456.01 and OX1456.50, Charging Pump and Valve and ESFAS K616 Quarterly Test (1ST), Revision 10 and 07, on April 27, 2010 (WO 1201188)

• IX1680.922, Solid State Protection System (SSPS) Train B Actuation Logic Test, Revision 12, on April 29, 2010 (WO 1197519)

• OX1436.02, Turbine Driven Emergency Feedwater Pump Quarterly and Monthly Valve Alignment, Revision 13, on June 24,2010 (WO 1201235)

• OX1461.05, SEPS Annual Availability Surveillance, Revision 02, on June 22, 2010 (WO 1198959) .

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

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

40A1 Performance Indicator Verification (71151- 1 sample)

.1 Mitigating Systems Cornerstone

a. Inspection Scope

The inspectors reviewed NextEra information for the Seabrook Safety System Functional Failures performance indicator (PI) to verify the accuracy of the reported data. The inspectors reviewed the PI data for the period from the second quarter of 2009 through the first quarter 2010. 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.

The inspectors reviewed licensee event reports (LERs), operating logs, procedures, and interviewed applicable personnel to verify the accuracy and completeness of the reported data. The inspectors also reviewed the accuracy of the number of critical hours reported.

b. Findings

No findings of significance were identified.

40A2 Identification and Resolution of Problems (71152 - 3 samples)

.1 Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As required 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 items entered into the Seabrook corrective action program (CAP). This review was accomplished by accessing NextEra's computerized database. The documents reviewed are listed in the

.

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 significant 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 through the first quarter 2010.

b. Assessment and Observations No findings of significance were identified. The inspectors did not identify any trends that NextEra had not already identified. Both the NRC and NextEra reviews noted the need for continued focus on human performance. During the NRC exit with station management on July 1, 2010, the inspectors discussed recent NRC observations with human performance themes related to resources, work practices and work control

[reference: Condition Reports (CR) 221321 (A EDG inoperable), 218893 (emergency air clean-up system inoperable-LER10-01), 211216 (steam generator pressure rate trip inoperable), 202762 (loss of MS-V92 environmental qualification), and CRs 206507, 209613 and 209062 (outage activity deficiencies)]. The human performance issues in CR218893 are described further in Sections 40A3 and 40A7 below. The issues described in LERs 05000443/2009-01, 05000443/2009-02 and 05000443/2010-03 also have themes in human performance. The deficiencies identified in CRs 221321 (see Section 1R18.2 above) and 191440 (See NRC Inspection Report 05000443/2009007)further indicate the need to ensure engineering inputs are adequately integrated into work packages during the planning process. NextEra reset the Station Event clock in the first quarter 2010 due to a mispositioned component and missed technical specification surveillance test. NextEra continues to address human performance concerns through procedure enhancement, reinforcement of human performance tools, procedure compliance, and expansion of the dynamic learning initiative in Maintenance to Operations, Chemistry and Radiation Protection .

.3 Annual Review of Operator Workarounds

a. Inspection Scope

The inspectors completed one problem identification and resolution annual inspection sample by completing a review of operator workarounds at Seabrook. The inspectors reviewed Seabrook's open operator workarounds and burdens to assess the cumulative impact of these issues on an operator's ability to implement emergency procedures or respond to plant transients. The inspectors verified that identified workarounds were properly tracked and that corrective maintenance for each issue was appropriately scheduled based on safety significance and the potential impact on plant operation.

The inspectors examined Seabrook procedure NAP-402, "Conduct of Operations,"

K, "Operator Workarounds and Burdens," to verify that the procedure provided the guidance necessary to adequately assess and address the cumulative impact of identified workarounds on the safe operation of the plant. The inspectors reviewed "turnover" information and toured the plant to verify that degraded conditions were appropriately identified and assessed as an operator workaround or burden. The inspector reviewed NexEra's operator workaround recovery plan and actions in progress to reduce the number of operator burdens.

b. Findings

No findings of significance were identified .

.4 Annual Sample: Corrective Actions for B Emergency Diesel Generator (EDG)

Turbocharger Vibration Issues

a. Inspection Scope

The inspectors reviewed the identification, evaluation, and corrective actions taken by NextEra to address B EDG turbocharger vibration issues. This condition was first identified by Nuclear Oversight on April 9, 2009. NextEra entered the issue into the corrective action program as CR 00194370. This inspection sample was completed in conjunction with the NRC review of the corrective actions to address NOV 05000443/2009007*01.

The inspectors reviewed NextEra's root cause evaluation, corrective action reports, performance data (such as vibration history and trending data), and interviewed engineering and operations personnel to evaluate component performance and the effectiveness of NextEra's corrective actions. Documents reviewed are listed in the

.

b. Findings and Observations

No findings of significance were identified. NextEra Nuclear Oversight identified a finding on April 9, 2009, (QR 090*017) after determining that past corrective actions for B EDG turbocharger vibration issues were inadequate. The corrective actions were determined to not be effective based on a past and recent history of increased vibration, bolt failures, bolt loosening, turbocharger related coolant piping weld failures, coolant system leaks and a failure in some instances to document these conditions in the condition reporting system. The failure to resolve long standing and increasing vibration and related issues for the B EDG constituted ineffective corrective action. Previous NRC review of this topic was documented in NRC Inspection Report 05000443/2009007.

The root cause evaluation performed in response to this issue identified that engineering accepted the degraded condition and did not aggressively pursue identification of the source and corrective actions. The evaluation also identified the equipment monitoring process in place was inadequate. NextEra has implemented a fleet system monitoring procedure which addresses when and how to develop an action plan for degraded performance monitoring parameters. This transition enhanced the system monitoring not only of the EDGs, but also addressed any generic implications. NextEra also installed shims to limit turbo*bracket rocking motion and reduce axial vibration. While this modification has successfully reduced vibration, the less*than*optimum fit between the mating surfaces of the turbocharger support bracket and the engine block is still an existing condition.

The inspectors determined that NextEra adequately implemented the corrective action process for the issues identified by Next Era Nuclear Oversight in OR 090-017. The CR package included a root cause evaluation, extent of condition reviews, completed corrective actions and planned corrective actions. The inspectors determined that corrective actions were timely and appropriate to prevent recurrence of the issue.

40A3 Event Follow Up (71153 - 1 sample)

.1 (Closed) LER 05000443/2010-01, Emergency Air Cleanup System Inoperable due to an

Open Door This LER was submitted pursuant to 10 CFR 50.73(a)(2)(i)(B) due to a condition prohibited by technical specifications and 50.73 (a)(2)(v)(C) for a condition that alone could have prevented the fulfillment of the safety function of systems that are needed to control the release of radioactive material.

The Seabrook technical specifications include several requirements for containment enclosure building (CEB) and containment enclosure emergency air cleanup system (CEEACS) operation.

• Technical Specification (TS) 3.6.5.1 requires that, for modes 1 through 4 of plant operation, both trains of CEEACS are operable. Plant operation with one CEEACS train inoperable is permitted for up to seven days; but plant operation with both trains inoperable is not permitted. With both CEEACS trains inoperable in accordance with TS 3.0.3, action must be taken within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery to restore at least one train to operable status or to place the plant in a mode where operation of the CEEACS is not required (mode 5 or 6).

• Surveillance requirement (SR) 4.6.5.1.dA requires CEEACS be capable of producing a negative pressure greater than or equal to 0.25 inches of water in the containment enclosure building within 4 minutes flowing a start Signal.

• TS 3.6.5.2, CEB Integrity, requires that CEB integrity be maintained and that doors into the enclosure area be verified closed except during normal transit entry and exit.

The LER described NextEra's discovery on March 17,2010, that both trains of CEEACS were rendered inoperable when plant staff failed to control an opening in the containment ventilation area boundary. Specifically, for approximately five hours on March 15, 2010, and approximately four hours on March 17, 2010, charging pump room door P307 was propped open to support planned maintenance. This condition rendered both trains of CEEACS inoperable. With the open door, neither train was capable of producing a negative pressure greater than or equal to 0.25 inches of water. Upon discovery, in accordance with TS 3.0.3, NextEra took action to control door P307 and other enclosure boundary doors. This restored CEEACS operability.

NextEra identified two causes for the March 15 and March 17 events. First, work controls were not adequate on March 15, 2010, to ensure the operators were notified prior to opening door P307, so the condition could be appropriately evaluated for TS compliance. On March 17, 2010, the operators were notified of the planned work, but did not appropriately evaluate the effect of the plant conditions on TS compliance, because NextEra did not adequately control design basis guidance documents. The operators used an internal guidance memorandum dated 1990 that incorrectly stated that TS 3.6.5.2 was to be applied to an open containment enclosure boundary door.

The correct guidance that required entry into the action statements for TS 3.6.5.1 was contained in a technical specification clarification document that operators were not aware existed.

The CEEACS provides for filtered, elevated discharge of radioactivity collected in the containment enclosure area following postulated accidents. Although the CEEACS safety function was impacted due to the inadequate controls, the events had very low safety significance because the primary containment barrier remained intact, and the CEEACS function could have been restored upon demand by closing door P307.

The inspectors reviewed the accuracy of the LER and verified compliance with the reportability requirements in 10 CFR 50.73. The LER concerned a condition that was a violation of NRC requirements. The violation is described in Section 40A7 of this report.

NextEra submitted License Amendment Request 10-01 to improve the technical specifications in this area. This LER is closed.

40A6 Meetings. including Exit On July 1, 2010, the resident inspectors presented the results of the first quarter routine integrated inspections to Mr. Paul Freeman and Seabrook Station staff. The inspectors also confirmed with NextEra that no proprietary information was reviewed by inspectors during the course of the inspection.

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

Technical Specification (TS) limiting condition of operation (LCO) 3.6.5.1 requires that both containment enclosure emergency air cleanup systems (CEEACS) be operable and in support of this LCO, surveillance requirement (SR) 4.6.5.1.dA requires CEEACS be capable of producing a negative pressure greater than or equal to 0.25 inches of water in the containment enclosure building within 4 minutes of a start signal. Contrary to the above, NextEra did not ensure that controls needed to maintain the CEEACS operable were in place. Specifically, for approximately five hours on March 15, 2010, and approximately four hours on March 17, 2010, charging pump room door P307 was propped open to support planned maintenance. As a result, both CEEACS systems were inoperable due to the inability to meet TS 4.6.5.1.dA. This violation had very low safety significance for the reasons discussed in Section 40A3 above. This condition was identified in NextEra's corrective action program as AR 218893.

ATIACHMENTS:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Arn, Engineering

J. Ball, Maintenance Rule Coordinator

R. Belanger, Design Engineer

K. Browne, Operations Manager

M. Collins, Design Engineering Manager

P. Freeman, Site Vice President

M. Frink, Quality Assurance Engineer

G. Kim, Risk Analyst

J. Mayer, Vibration Program Owner

T. Manning, Engineering

E. Metcalf, Plant General Manager

B. McAllister, SW Systern Engineer

N. McCafferty, Plant Engineering Manager

R. Noble, Engineering Manager

M. O'Keefe, Licensing Manager

V. Pascucci, Nuclear Oversight Manager

E. Piggot, Unit Supervisor

R. Thurlow, Maintenance Manager

J. Tucker, Security Manager

P. Willoughby, Licensing Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None Opened and Closed:

05000443/2010-01 LER Emergency Air Handling Systern Inoperable Due to Opening in Boundary (Section 40A3.1)

05000443/201003-01 NCV Inadequate instructions to install test equipment caused the A EDG to be inoperable (Section 1R18)

Closed:

None

Discussed

None