IR 05000443/2010005
| ML110450047 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/14/2011 |
| From: | Arthur Burritt Reactor Projects Branch 3 |
| To: | Freeman P NextEra Energy Seabrook |
| BURRITT AL | |
| References | |
| IR-10-005 | |
| Download: ML110450047 (31) | |
Text
SUBJECT:
SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/20 1 0005
Dear Mr. Freeman:
On December 31,2010, 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 January 6, 2011, 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, observed activities, and interviewed personnel.
The report documents a 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 Vl.A.1 of the NRC Enforcement Policy.
lf 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, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region l; 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 characterization 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 l, and the NRC Resident Inspector at the Seabrook Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
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.oov/readino-rm/adams.html (the Public Electronic Reading Room).
Sincerely
.,,1
'4: ) Ji, i {i,*
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, L.i '"t L,
Docket No.
License No:
Enclosure:
cc w/encl:
Arthur L. Burritt, Chief Projects Branch 3 Division of Reactor Projects 50-443 NPF-86 lnspection Report No. 0500044312010005 wi Attachment: Supplemental Information Distribution via ListServ
SUMMARY OF FINDINGS
lR 05000443/2010005;1010112010-1213112010; Seabrook Station, Unit No. 1; Routine lntegrated Report.
The report covers 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.
Other Findinos Violations of very low safety significance, which were identified by NextEra, have been reviewed by the inspectors. Corrective actions taken or planned by NextEra have been entered into NextEra's corrective action program. The violations and the corrective action tracking number are listed in Section 4OAT of this report.
REPORT DETAILS
Summary of Plant Status
Seabrook operated at full power for the period.
1. REACTOR SAFEry
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity lR01 Adverse Weather Preparation (71111.01 - 1 sample)
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors completed one seasonal extreme weather condition inspection sample.
The inspectors reviewed the NextEra readiness for the onset of cold weather condiiions.
The inspectors reviewed Seabrook's updated final safety analysis report (UFSAR)regarding design features, and verified the adequacy of ihe stition procedures foi adverse weather protection. The inspectors reviewed NextEra actions per procedure ON1490.06 for winter readiness and procedure OS1200.03 for severe weather. The inspectors also conducted walkdowns of susceptible systems, specifically feedwater /
emergency feedwater, service water, and various electrical systems. The inspectors reviewed previously identified deficiencies related to extremsweather preparation and verified that the issues were appropriately dispositioned through the corrective action program. The documents reviewed for this inspection are listed in the Attachment.
Findinos b.
No findings were identified.
f
R04 Eouipment Alionment
.1 PartialWalkdown
a.
lnspection 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.
' The A EDG and associated support systems during the planned operability run of the B EDG on October 25,2010.
' The electrical alignment of the standby diesel generators and the 345KV electrical system during crane work in the switchyard from November 1 - 23,2010.
tR05
.1 a.
' A train safety injection during surveillance of the B train safety injection system on November 10, 2010.
Findinqs No findings were identified.
Fire Protection (71111.05Q - 3 samples)
Quarterlv Review of Fire Areas:
Inspection Scope The inspectors completed three 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.
. PAB-F-1C-A (Primary Auxiliary Building (PAB) 7 foot)
. RHR-F-3B-Z (RHR Vault A, -31 foot), RHR-F-4B-Z (RHR Vault A, 20 foot),
RHR-F-4A-22 (RHR Vault B, 20 foot)
. MS-F-1A-Z (Main Steam / Feed Enclosure East 3, 7, &27 ft)b.
Findinos No findings were identified.
f
R11 Licensed Operator Requalification Proqram
.1 Quarterlv Resident Inspector Review
a.
lnspection Scope The inspectors completed one quarterly licensed operator requalification program inspection sample. The inspectors reviewed operator actions to implement the abnormal and emergency operating procedures on October 5 and 12,2010. The inspectors examined the operators capability to perform actions associated with high-risk activities, the Emergency Plan, previous lessons fearned items, and the corect 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 physicalfidelity in order to verify similarities between the Seabrook control room and the simulator. Documents reviewed are listed in the
.
FindinS No findings were identified.
b.
.2 a.
Inspection Scope On January 3,2011, one NRC region-based inspector conducted an in-office review of results of licensee-administered annual operating tests for 2010. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix l, "Operator Requalification Human Pe*ormance Significance Determination Process (sDp)". The inspector verified that:
' Crew failure rate was less than 20 percent. (The crew failure rate was 0.0 percent.)
' Individual failure rate on the dynamic simulator test was less than or equal io 20 percent. (The individualfailure rate was 0.0 percent.)
' lndividual failure rate on the walk{hrough test was fess ihan or equal to 20 percent.
(The individual failure rate was 0.0 percent.)
' Individual failure rate on the comprehensive written exam was less than or equal to 20 percent. (The comprehensive written exam was administered in 2009. The Individualfailure rate was 0.0 percent.)
' Overall pa_ss rate among individuals for all portions of the exam was greater than or equalto 75 percent. (The overall pass rate was 100 percent.)
b.
Findinqs No findings were identified.
lR12 Maintenance Effectiveness (71111.j2e - 2 samples)
a. Inspection Scope
The inspectors completed two maintenance effectiveness inspection samples. The inspectors reviewed performance-based probtems and compl'eted performance and condition history reviews for the selected in-scope structures, systems or components (SSCs) listed below to assess the effectiveness of the maintenince program. Reviews focused on: proper Maintenance Rule (MR) scoping in accordance witfilO CFR 50.65; characterization of reliability issues; tracking system and component unavailability; 10 CFR 50.65 (aX1) and (a)(2) classifications; identifying and addressing common cause failures, trending key parameters, and the appropriateness of perfirmance criteria for SSCs classified (aX2) as well as the adequacy of goals and corrective actions for SSCs classified (aX1). For the periodic assessment inspection sample, the inspectors reviewed the assessment frequency, the performance ciiteria, the use of operaiing experience and corrective actions. The inspectors reviewed system health reporti, maintenance backlogs, and MR basis documents. The documents reviewed are listed in the Attachment.
' Enclosure building air handling (EAH) system classified as Maintenance Rule (aX2)with a focus on component aging and degradation due to exposure to environmental contaminants (AR 585376585376
' Seismic Category l Structures classified as Maintenance Rule (a)(Z) with a focus on the structures monitoring program completed per Engineering Procedure PEG04 and ED36180 (ARs 574120,581434 and 199563)b.
Findinqs No findings were identified.
lR13 Maintenance Risk Assessments and Emerqent Work Control (71111.13 - 5 samples)
a. Inspection Scope
The inspectors completed five 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 guarded and protected equipment. The compensatory measures were evaluated against Seabrook procedures, Maintenance Manual 4.14,"Troubleshooting,"
Revision 0 and Work Management Manual 10.1, "On-Line Maintenance," Revision 3.
Specific risk assessments were conducted using Seabrook's "Safety Monitor", as applicable. The documents reviewed are listed in the Attachment. The inspectors reviewed the maintenance items listed below.
. Planned work associated with 45 kV line 363 combined with emergent work associated with main generator step up transformer C phase ground on October 31, 2010 (wo 1186699).
. Planned modification associated with work in the 345 kV switchyard during the period of November 1-18, 2010 (WO 40040244).
. Emergent maintenance and testing associated with the enclosure air handling filter EAH-F-69 on October 3,2010 WO 40045424).
. Planned work associated with EFW and RHR maintenance on October 26 and27, 2010 (WO 1209780 and WO 1209759).
. Planned work associated with the cross tie of unit sub 51 and 52 on November 2-3, 2010 (wo 11988190 / 1198186).
c.
Findinqs No findings were identified.
lR15 Operabilitv Evaluations (71111.15 - 4 samples)a.
lnspection Scope The inspectors completed four 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 lssue 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 Asseisments for Resolution of Degraded or Nonconforming Conditions Adverse to Quatity or Safety." In addition, where a component was determined to be inoperabfe, theinspectori verified that TS limiting condition for operation implications were properly addiessed. The documents reviewed are listed in the Attachment. The inspectors aiso performed field walk downs and interviewed personnel involved in identifying, evaluating or correcting the identified conditions. The following items were reviewed:
' CR 583804, operabifity of the service water cooling towerA train during extended period of operation without a freeze protection circuit, October 7,2010.
' CR 585696, operability of the startup feedwater pump as part of the auxiliary feedwater system with the suction pipe from the condensate storage tank below code allowable minimum wallthickness, October g, 2010.
' CR 584192, past operability of the enclosure air handling system with a degraded filter EAH-F69 and exposure to volatile organic compounds, October 29,2010.
' cR 579900, operability of emergency feed water pump p37A with seat leakage past steam supply isolation valve MS-V3g3, october 1, 2010.
b.
Findinqs No findings were identified.
lR18 Plant Modifications (71ii1.18 - 1 sampte)
.1 Temporarv Modification - SY phase 2 Hi pot Bushinqs
a.
lnspection Scope The inspectors completed one temporary modification inspection sample. The inspectors reviewed modification package EC145280 (CRN-003) thatinstalled Hi pot bushings and supports as part of the 345 kV electrical switchyard phase 2 reliability upgrade. The inspectors reviewed the engineering bases supporting the new configuration and verified the configuration was accurately reflected in plant documentatio_n. The inspectors verified that 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 i{entifying and resolving problems associated with temporary modifications (reference CR 596384). The 10 CFR 50.59 evaluation associated witn inis temporary modification was also reviewed. The documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
I lR19 Post-Maintenance Testino (71111.19 - 4 samples)
a. Inspection Scope
The inspectors completed four 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 boric acid transfer pump on October 26,2010, following replacement of the pump perWO 400473964.
. Retest of steam generator blowdown valve 1-SB-V-11 on November 9, 2010, following replacement of 1-SB-FY-1902-8 (solenoid for 1-SB-V-11) perWO 1 186626.
. Retest of atmospheric steam dump valve MS-PV-3001 following maintenance on 12-13,2010, per WO 1382208.
. Retest of steam generator blowdown valve 1-SB-V-10 on December 16, 2010, following maintenance per WO 1 186627.
b.
Findinos No findings were identified.
lR22 Surveillance Testinq (71111.22-5 samples)a.
lnspection Scope The inspectors completed five 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. The test data recorded was compared to procedural and TS requirements, and to prior tests to identify any adverse trends. The documents reviewed are listed in the Attachment. The following surveillance activities were reviewed:
. OX1436.08, Startup Feed Pump Quarterly Surveillance, Revision 12, October 19, 2010 (wo 01209404):
. OX1456.01, Charging Pump A & B Quarterly Flow And Valve Stroke Test And 18 Month Remote Position Indication Verification, Revision 1 1, October 27,2010 (WO 01209784);
' OX 1410.02, Quarterly Rod Operability Surveillance on November 12,2010 (WO 1210792):
' RX 0720.0, Spent Fuel Pool Criticality Surveillance on November 18, 2O1O (WO 01192002); and
' OX 1405.07, Safety lnjection Quarterly and 18 Month Pump Flow and Valve Test on November 10,2010 (WO 1210738).
The inspectors reviewed deficiencies related to surveillance testing and verified that the lssues were entered into the corrective action program. The documents reviewed are listed in the Attachment.
b.
Findinos No findings were identified.
RADIATION SAFETY
Cornerstones: Occupational and Public Radiation Safety
2RS0 5 Radiation Monitorino Instrumentation
a. Inspection Scope
During the period November 14,2010, the inspectors conducted the following activities to evaluate the operability and accuracy of radiation monitoring instrumentation used to ensure a safe work environment, and to detect and quantify radioactive process streams and effluent releases. lmplementation of these programs was compared to the criteria contained in 10 CFR 20, applicable industry standards, and NextEra's procedures.
Walkdown of Process and Effluent Monitorinq Svstems The inspectors, with the assistance of a plant systems engineer, walked down selected portions of the, area, liquid and gaseous monitoring systems to assess material condition and the status of system upgrades. The walk-down included portions of the containment air monitor (RM-6529), reactor coolant system (RCS) letdown monitor (RM-6520),7'-PAB area monitor (RM-6541), steam generator blowdown monitors (RM-6510111112113), plant vent monitor (RM-6528), 25'-PAB air monitor (RM-SKD-162),and storm drain monitor (RM-6454),
Calibration of Portable Survev lnstruments. Area Monitors. Electronic Dosimeters and Air Samplers.
The inspectors reviewed the operating procedures, calibration reports, and current source activities/dose rate characterizations for the in-service Shepard Model 81-12 calibrator (No. 7015), used for calibrating survey instruments and electronic dosimeters.
The inspectors also reviewed the calibration cross check records for the Shepard Model 89 irradiator used for performing source checks on high range survey instruments.
The inspectors reviewed the calibration records for selected survey meters, electronic dosimeters, and contamination monitors including small article monitors (SAM 9A, SAM-12), personal contamination monitors (Argos 4AlB & SPM-906), portable instruments (RM-14, ASP-2, telepole, Fluke -451, Ludlum 19), electronic dosimeters (DMC-2000),and laboratory counting instruments (Tennelec XLB, Canberra SSAPC).
The inspectors observed a technician performing an electronic calibration of a contamination monitoring instrument (R-14), and daily operational checks of various instruments including contamination monitors (SAM-9 & SAM-12, RM-14), various hand held survey instruments (Fluke Model 451P & 4518, Ludlum 19, ASP-2, MGP-1 Telepole, and Bicron MicroRem), personnel contamination monitors (ARGOS -4 NB, SPM-906), and counting room instruments (Ludlum-2200 alpha counter, Ludlum-12 air sample counter). The inspectors confirmed that procedural requirements were met and the instrument had the required accuracy.
During walkdowns in various plant areas, the inspectors confirmed that available monitoring instruments were calibrated, that daily source checks had been performed, and that the instruments were operational. lnstruments checked included handheld survey instruments, electronic dosimeters, air monitors, and contamination monitors.
The inspectors reviewed contamination sampling results (10 CFR 61 radionuclide analyses) used to characterize difficult-to-measure radioisotopes, to determine if the calibration sources were representative of the radioisotopes found in the plant's source term. Whole body counting system records and contamination monitor set points were reviewed to determine if this data was incorporated in system setup to ensure that difficult-to-measure radioisotopes were accounted for when making measurements.
Laboratory Instrumentation:
The inspectors reviewed the calibration records, daily source checks and maintenance records for selected gamma spectroscopy systems (Detectors Nos. 1, 2, 3, 4, 5,7,8 and 9) and scintillation counters (Perkin-Elmer TriCarb 2700 and TriCarb 2910) to verify that the instruments were calibrated and properly maintained. The inspectors confirmed that the check sources used aligned with the plant's isotopic mix.
Whole Bodv Counters:
The inspectors reviewed the calibration, daily quality control data, and operating procedure for the FastScan whole body counting system. The inspectors determined that appropriate radioactive source phantoms were used in making calibrations and that calibration sources were representative of radioisotopes found in the plants' source term.
Plant Process and Post-Accident Monitorino Instrumentation The inspectors reviewed the calibration records for the high range containment radiation monitors, (RM-6576 A/B), waste liquid discharge monitor (RM-6509), plant vent wide range monitor (RM-6528), incore seal table monitor (RM-6534), and control room rad monitor (RM-6550). The inspectors determined that the electronic and radiation source calibrations were appropriately conducted and that the alert and high alarm setpoints were properly established.
Problem ldentification and Resolution:
The inspectors reviewed selected condition reports (CR), a Nuclear Quality Assessment audit, and field observation reports to evaluate NextEra's threshold for identifying, evaluating, and resolving problems in implementing the radiation monitoring instrumentation. lncluded in this review were CRs related to radiation worker and radiation protection technician errors to determine whether there was an observable error pattern in the maintenance or use of radiation instruments.
b.
Findinos No findings were identified.
4. OTHER ACTTVlTIES (OA)
4OA1 Performance Indicator Verification
.1 OccupationalExposureControlEffectiveness
a. lnspection Scope The inspectors reviewed implementation of NextEra's Occupational Exposure Control Effectiveness Performance Indicator (Pl) Program. Specifically, the inspectors reviewed dosimetry abnormality occurrence reports, CRs, and associated documents, for occurrences involving locked high radiation areas, very high radiation areas, and unplanned exposures against the criteria specified in Nuclear Energy Institute (NEl) 99-02, Regulatory Assessment Performance lndicator Guideline, to verify that all occurrences that met the NEI criteria were identified and reported as performance indicators. The period covered in this review was October 2009 through October 2010.
This inspection activity represented the completion of one
- (1) sample relative to this inspection area; completing the annual inspection requirement.
Findinqs No findings were identified.
RETS/ODCM Radiolosical Effluent Occurrences Inspection Scope The inspectors reviewed relevant effluent release reports for the period October 2009 through October 1, 2010, for issues related to the public radiation safety performance indicator as specified in NEI 99-02. The NEI criteria for this performance indicator includes radiological effluent release occurrences that exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ 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 represented the completion of one
- (1) sample relative to this inspection area; completing the annual inspection requirements.
Findinqs No findings were identified.
b.
.2 a.
b.
40.42
.1 a.
ldentification and Resolution of Problems (71152 - 3 samples)
Review of ltems Entered into the Corrective Action Proqram Inspection Scope As required by lnspection Procedure71152, "ldentification 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
.
Findinqs No findings were identified.
Semi-annual Review to ldentifv Trends lnspection Scope As required by Inspection Procedure71l52, "Problem ldentification and Resolution," the inspectors performed a semi-annual review of site issues to identify trends that milnt indicate the existence of more significant safety issues. The inspectors included in tnis review, repetitive or closely-related issues documented by NextEra outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, system health reports, and maintenance or corrective action program backlogs. The inspectors also reviewed the Seabrook corrective action program databaie for the second and third quarters of 7010, to assess CRs written in variius subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2'1). The inspectors also reviewed the NeitEra quarterly trend report for the second quarter of ZOiO to verify that NextEra was appropriately evaluating and trending adverse conditions in accordance with procedure PI-AA-2A7, "Trend Coding and
Analysis.
"
Assessment and Observations No findings of significance were identified. The inspectors did not identify any trends that NextEra had not identified. The inspectors reviewed the operations, maintenance and chemistry department inputs into the quarterly trend reports and a sample of issues and events that occuned over the past two quarters that were documented in the corrective action program. The inspectors verified that NextEra appropriately considered identified issues as emerging trends, and in some cases, verified the adequacy of the actions completed or planned to address the identified trends' NextEra noted the need for continued focus on human performance. During meetings with station management in December 2010, the inspectors discussed recent NRC observations in the human performance area related to procedure adequacy, work practices and control of work [reference: Condition Reports (CR) 585992 (SW-P41D inoperable), and 584192 / 585376 (control of EAH during painting activities)1._ NextEra has also documented an adverse trend in Operations department human performance b.
b.
.3 a.
based on errors that occurred in the third quarter of 2010 (CR594198) and has initiated a common cause evaluation to review this trend. The issue in CR585992 is described further in Section 4OA7 below. The issue described in CR199563 also relates to Human Performance/resources regarding the adeq uacy of procedu re im plementation.
NextEra continues to address site wide human performance concerns through procedure enhancement, reinforcement of human performance tools, procedure compliance, and the dynamic learning initiative in Maintenance, Operations, Chemistry and Radiation Protection.
Annual Sample - Ground Water Protection lnspection Scope During the period December 6 - 9, 2010, the inspectors evaluated the effectiveness of the NextEra's corrective action program in response to the past identification of water, containing tritium, leaking through the wall liner of the cask loading arealtransfer canal liner and its eventual migration into site ground water. Specifically, the inspectors reviewed all condition reports, contractor evaluations, self-assessments, NextEra procedures, and technical studies that were generated after the initiating event in 1999 to identify and repair the source of the leakage and to monitor and characterize the migration of the contaminated leakage into soil located within the site's protected area.
Backqround In September 1999, elevated tritium concentrations were identified in ground water that was seeping into the containment annulus. NextEra interpreted this to indicate that tritium contaminated ground water, from an undetermined location, was leaking into the containment annulus. Subsequently, NextEra evaluated possible leak sources and determined that the cask loading area/transfer canal, adjacent to the Spent Fuel Pool (SFP) was leaking into the SFP tell tale drain collection lines, when the transfer canal was filled with water (in preparation for refueling activities). No leakage occurred when the transfer canalwas drained. This intermittent leakage contaminated the surrounding concrete which resulted in diffusion of tritiated water into ground water beneath and adjacent to the Fuel Handling Building (FHB). The leakage was not directly to ground water, but to the interstitial space between the stainless steel SFP liner and the concrete building foundation, eventually diffusing through the concrete to the surrounding soil. To mitigate this leak, the interstitial space was drained and a coating was applied to the SFP liner to stop the leak.
From the initial identification of the leak to date, programmatic actions evolved to identify and stop the apparent source, control the in-leakage of groundwater into site buildings by using dewatering systems, monitor and trend ground water tritium concentrations, and expand the investigation to identify other potential tritium sources. Specific actions included establishing a project team to identify/repair the source, implement a ground water sampling program, retain an independent consultant to develop a ground water (hydrological) model to characterize ground water flow and tritium distribution/migration, and establish a Groundwater Protection Committee to monitor the overall program and make recommendations for additional actions.
Source ldentification and Repairs Following a series of tests, in which the cask loading arealtransfer canal water level was correlated with leakage rate, NextEra determined that cracks in the transfer canal liner plate welds were the leakage pathway and that leakage only occurred when the transfer canal was filled with water (normally in preparation for transferring fuel assemblies). As corrective action, a protective coating was applied to the liner, which effectively stopped the leakage.
Following the 2009 refueling outage, the liner's coating was determined to be deteriorated; slumping of the coating was visually evident. However, no leakage was evident. The coating was replaced in the fall of 2010 and subsequent testing also indicated that no leakage was occurring.
Dewaterinq Svstems In addition to the liner repair activities, NextEra implemented a building dewatering program by regularly withdrawing ground water in the areas surrounding the fuel handling building, primary auxiliary building, and containment. Five dewatering locations were established including: 1) containment enclosure area,2) primary auxiliary building, 3) emergency feed water pump house, 4) B-residual heat removal equipment vault, and 5) B-electrical tunnel. Through controlled dewatering at these five points, NextEra systematically monitored and removed tritium contaminated ground water that migrated into subsurface regions adjacent to building foundations. By measuring tritium concentrations and the quantities of the water discharged to the storm drain system, NextEra established a controlled, monitored discharge pathway to assess the tritium released.
Ground Water Samplinq Proqram The ground water sampling program is a proactive program that has evolved and matured since tritium was first identified at Seabrook in 1999. A ground water monitoring network of 27 monitoring wells was established to track and trend the concentrations and migration of the tritium. Following the use of available on-site wells in 2000 for initial measurements, NextEra/FPL installed 15 dedicated monitoring wells in 20Q4, 4 in 2007 and 2008, 3 outside the protected area in 2009, and 5 more inside the protected area in 2010. NextEra samples the wells at specified frequencies. The samples are then analyzed for tritium and non-radiological chemical components. From this data, the down gradient ground water flow and tritium distribution at the site are characterized and ground water flow variations that may result from tidal and seasonal influences are identified.
Tritium is the only radioisotope identified in water samples taken from the monitoring wells. NextEra analyzed for tritium at concentrations well below the regulatory required lower limit of detection (LLD) of 2000 picoCuries/liter (pCiil), achieving LLDs of < 600 pCi/l. Of the 15 monitoring wells installed in 2004, only 5 had initial tritium indications and these wells have shown declining tritium concentrations. Currently, only one well (SW-1) is showing a positive concentration slightly above 2000 pCi/l and all other wells are showing less than minimum detectable (< 600 pCiil). SW-1 is located outside the fuel handling building and primary auxiliary building. Fluctuations in monitoring well tritium concentrations have infrequently occurred and can be attributed to changes in weather precipitation levels that result in leaching of legacy tritium entrained in structural concrete. This phenomenon was obseryed in June 2009, when the results of two monitoring wells (SD-1 and BD-2) indicated values above background.
These wells are southwest of SW-1 and tritium migration to SD-1 and BD-2 is consistent with site hydrology and elevated ground water levels, resulting from significant snow melt and rainfall. Similarly, tritium identified in the Unit 2 tunnel has been attributed to plume fluctuations. There has been no indication of tritium getting into the ground water sampling wells from the tunnel. No tritium has been detected in ground water samples taken outside the protected area.
Independent Consultant The services of independent consultants were retained to provide in-depth evaluations of site characteristics through expansion of the ground water sampling program and development of a hydrological site conceptual model (SCM). Through development of the SCM, the geologic and hydro-geologic conditions of the site are characterized, ground water elevation (gradient) data is collected, ground water quality is evaluated from the vertical and horizontal extent, and other possible sources of tritium into ground water are examined.
b.
Assessment and Observations No findings were identified. The inspectors'assessment of NextEra performance relative to identification, evaluation and corrective actions for this issue are discussed below.
Assessment - Effectiveness of Problem ldentification Specific procedural criteria have been established to assure that any potential leak or spill of radioactive material, that could potentially affect ground water quality, is addressed by the corrective action program. However, NextEra has consistently generated condition reports at a conservative threshold below the criteria to assure that any off normal condition is promptly addressed by the corrective action program.
Since identifying the contaminated water in the containment annulus in 1999, a large volume of (> 100) condition reports have been generated to address various aspects of the ground water protection program.
Assessment - Effectiveness of Prioritization and Evaluation of lssues Thorough and timely evaluations have been performed of ground water related issues.
NextEra has retained the services of contracted specialists to better understand site hydrology and tritium distribution, evaluate the effectiveness of corrective actions, and develop future strategies.
NextEra has appropriately responded to the initial cask loading arealtransfer canal leakage by conducting tests to identify leak locations, evaluating leak control measures, and performing repairs to stop the leak to mitigate the introduction of tritium into soil within the site protected area. NextEra has appropriately investigated potential tritium migration paths into cable vaults, building sumps and tunnels. An isolated lapse in tritium controlwhile pumping unit 2 tunnelwater had inconsequential safety significance
.4 due to the very low concentrations involved, and was insignificant relative to the account
of total tritium releases to the environment.
Additionally, NextEra has and is continuing to expand the investigation into other potential sources of tritium and increase understanding of site ground water hydrology.
Future projects include developing a numerical ground water flow and transport three-dimensional model, performing a storm drain inspection, and upgrading monitoring wells.
Building upon the current ground water protection program, NextEra is developing a buried piping integrity program to assure that the structural and leakage integrity of all buried piping containing radioactive fluids is evaluated and maintained. For example, the waste liquid discharge piping has recently been hydrotatically tested and found to have no leakage. Other piping inspections are under development.
NextEra has also evaluated operating experiences at other nuclear facilities to identify the potential for a similar incident to occur at Seabrook. Operating experiences were captured in condition reports, evaluated and lessons learned applied to site programs.
As a result of the actions taken in response to the root cause evaluation for the transfer canal liner leakage in 1999, Seabrook implemented early the recommendations contained in NEI-07-07, "lndustry Ground Water Protection lnitiative."
Assessment - Effectiveness of Corrective Actions NextEra has implemented effective corrective actions in mitigating and monitoring ground water contamination. The initial leak from the cask loading arealtransfer canal liner has been repaired, a ground water sampling program has been established, and strategies have been developed to identify any additional sources of tritium that could contaminate ground water.
Summarv The safety consequence of tritium entering the site ground water has low safety significance, since monitored concentrations are small and no pathway exists for site ground water to communicate with drinking water supplies. None of the data indicates any significant impact to the site or environs due to the previous tritium leak from the fuel transfer canal. However, NextEra has placed a high priority on monitoring and controlling radioactive fluid sources that could potentially contaminate ground water to strengthen public confidence that radioactive materials are being properly controlled.
NextEra has taken the actions necessary to control and assess current ground water conditions, and have expanded their investigation and monitoring capabilities to identify and address future occurrences.
Application of ASME Code Cases N513 and N523 to Mitioation of Service Water Class 3 Pipe Deqradation Inspection Scope The inspectors visually observed the three instances where ASME Code Cases (CC)
N513 and N523 were applied and examined the corrective action documentation and a.
b.
procedural controls for each of the code case applications. Included in the inspection scope were AR 392285392285 AR 209357209357and AR 209078209078 Additionally, for AR 593728593728 on ultrasonic testing (UT) for wall thickness measurement of a condensate pipe segment for CR-585696, the UT technique and procedure were also reviewed.
The Seabrook Station Procedure MA 10.2, Rev 0 titled "Online Repairs of Non-lsolable Leaks" and portions of the Procedure EN-AA-203-1001, Rev 3 for "Operability Determinations/Functionality Assessments" were included in the scope of the inspection.
The inspectors compared the observations and review results to CC N513 and N523 and to the NRC Regulatory lssue Summary 2005-20, Rev 1, Technical Guidance on "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality."
Findinqs and Observations No findings were identified.
The American Society of Mechanical Engineers (ASME) Code Cases (CC) N513 and N523 provide methods for temporary acceptance of flaws, flaw mitigation, and control of leakage for thru wall flaws in ASME Class 2 and Class 3 moderate energy piping where the temperature and pressure do not exceed 200 deg-F or 275 psi pressure.
Observation of the installed modifications and review of the drawings for the three repair modifications per CC N513 for SW pipe, 1-SW-1814-1-156-24 (PMCap), 1-SW-1827-01-153-24" (blind flange), and 1-SW-1827-06-156-2" (encapsulation) found these to be robust components in conformance with the ASME Code requirements.
The NRC Regulatory lssue Summary (RlS) 2005-2Q, Rev 1, Technical Guidance on "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality" was issued on April 16, 2008. However, the plant procedure MA 10.2 Rev 0, titled "Online Repairs of Non-lsolable Leaks" in current use was issued on May 5, 2006 and was not updated after the issue of the RlS, revision 1. While no significant differences were noted by the inspectors between MA 10.2 and the RIS revision, MA 10.2 did refer to an outdated reference for operability (procedure OE 4.5) rather than the current Operability Procedure in use, EN-AA-203-1001. NextEra acknowledged these observations and initiated CR AR 01601758 to provide for review of MA-10.2 and to initiate corrective actions.
Meetinqs. lncludinq Exit On January 6,2011, the resident inspectors presented the results of the fourth 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.
4C.A7 Licensee-ldentified Violations The following violations of NRC requirements were identified by NextEra. The violations were determined to have very low significance (Green) and to meet the criteria of Section 2.3.2 of the NRC Enforcement Policy for being dispositioned as a non-cited violations.
4c.46 Technical Specification 6.7.1and Regulatory Guide 1.33 requires that operating activities be implemented in accordance with written procedures. Seabrook procedure OS1016.05, Step 4.2.26, requires the operator to place the train B standby service water (SW) pump (SW-P41D) control switch in "normal" following cooling tower operations.
Contrary to the above, on October 8,2010, the operator left the control switch for SW-P41D in "pullto-lock" after transferring the train B cooling loop from the tower back to the ocean. The train B SW pump was non-functionalfor about t hour 40 minutes until another operator identified the discrepancy during a control board walkdown. The finding had very low safety significance because it did not involve a loss of safety function or impact the safety function for a time greater than the allowed outage time in Technical Specification 3.7.4. Specifically, SW-P41D was non-functional but recoverable by operator action from the main control board. The violation was licensee identified and entered into the corrective action program as AR 585992585992
ATTACHMENTS:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
B. Bouton
Design Engineer
V. Brown
Senior Licensing Analyst
B. Brown
Design Engineering Supervisor
J. Buyak
Senior Radiation Protection Technician
M. Collins
Design Engineering Mgr
D. Egonis
Engineer, Eng Programs
P. Freeman
Site Vice President
A. Giotas
Chemistry Supervisor
R. Guthrie
Plant Systems Engineer
S. Hammel
UT Level lll
P. Harvey
Chairman, Ground Water Protection Committee
R. Healy
l&C Supervisor
S. Jaster
Chemistry Analyst
M. Leone
Licensed Operator Requalification Training
B. McAlister
SW System Engineer
Plant General Manager
W. Meyer
Radiation Protection Manager
R. Noble
Engineering Director
M. O'Keefe
Licensing Manager
V. Pascucci
Nuclear Oversight Mgr
D. Perkins
Radiation Protection Supervisor
D. Robinson
Chemistry Manager
M. Scannel
Health Physicist
J. Sobotka
Design Engineering Supervisor
J. Walsh
Plant Engineer
T. Vassallo
Design Engineer
I
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None Opened and Closed:
None Closed:
None
Discussed
None