IR 05000443/2012002
| ML12129A059 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/08/2012 |
| From: | Arthur Burritt Reactor Projects Branch 3 |
| To: | Freeman P NextEra Energy Seabrook |
| BURRITT, AL | |
| References | |
| IR-12-002 | |
| Download: ML12129A059 (39) | |
Text
May 8, 2012
SUBJECT:
SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2012002
Dear Mr. Freeman:
On March 31, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. The enclosed inspection report documents the inspection results, which were discussed on April 9, 2012, 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 Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
No NRC-identified or self-revealing findings were identified during this inspection.
However two licensee-identified violations which were determined to be of very low safety significance is listed in this report. Because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs 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 I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at 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 for 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 NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Arthur L. Burritt, Chief Reactor Projects Branch 3 Division of Reactor Projects
Docket No. 50-443 License No: NPF-86
Enclosure:
Inspection Report No. 05000443/2012002
w/ Attachment: Supplemental Information
REGION I==
Docket No.:
50-443
License No.:
Report No.:
Licensee:
NextEra Energy Seabrook, LLC
Facility:
Seabrook Station, Unit No.1
Location:
Seabrook, New Hampshire 03874
Dates:
January 1, 2012 through March 31, 2012
Inspectors:
W. Raymond, Senior Resident Inspector J. Johnson, Resident Inspector J. DeBoer, Resident Inspector J. Noggle, Senior Health Physicist T. Moslak, Health Physicist S. Hammann, Senior Health Physicist R. Montgomery, Project Engineer L. Scholl, Senior Reactor Inspector P. Cataldo, Senior Resident Inspector
Approved by:
Arthur L. Burritt, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Enclosure TABLE OF CONTENTS
1.
REACTOR SAFETY.............................................................................................................. 4 1R01 Adverse Weather Protection....................................................................................... 4 1R04 Equipment Alignment.................................................................................................. 4 1R05 Fire Protection............................................................................................................. 5 1R06 Flood Protection Measures......................................................................................... 6 1R07 Heat Sink Performance............................................................................................... 7 1R11 Licensed Operator Requalification Program............................................................... 7 1R12 Maintenance Effectiveness......................................................................................... 8 1R13 Maintenance Risk Assessments and Emergent Work Control................................... 9 1R15 Operability Determinations and Functionality Assessments....................................... 9 1R18 Plant Modifications.................................................................................................... 10 1R19 Post-Maintenance Testing........................................................................................ 11 1R22 Surveillance Testing.................................................................................................. 11 1EP4 Emergency Action Level and Emergency Plan Changes......................................... 12 1EP6 Drill Evaluation.......................................................................................................... 12 2.
RADIATION SAFETY.......................................................................................................... 12 2RS1 Radiological Hazard Assessment and Exposure Controls........................................ 13 2RS2 Occupational ALARA Planning and Controls............................................................ 15 2RS4 Occupational Dose Assessment............................................................................... 16 4.
OTHER ACTIVITIES........................................................................................................... 18 4OA1 Performance Indicator Verification............................................................................ 18 4OA2 Problem Identification and Resolution...................................................................... 18 4OA3 Follow-Up of Events and Notices of Enforcement Discretion.................................... 22 4OA5 Other Activities.......................................................................................................... 22 4OA6 Meetings, Including Exit............................................................................................ 24 4OA7 Licensee-Identified Violations................................................................................... 24 ATTACHMENT: SUPPLEMENTARY INFORMATION................................................................ 25 SUPPLEMENTARY INFORMATION........................................................................................ A-1 LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED..................................... A-1 LIST OF DOCUMENTS REVIEWED........................................................................................ A-2 LIST OF ACRONYMS............................................................................................................. A-11
Enclosure
SUMMARY OF FINDINGS
IR 05000443/2012002; 01/01/2012-03/31/2012; Seabrook Station, Unit No. 1, Routine
Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRCs 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 Findings
Two violations of very low safety significance identified by NextEra were reviewed by the inspectors. Corrective actions taken or planned by NextEra have been entered into NextEras corrective action program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Seabrook operated at 85% power during the entire inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Impending Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of NextEras readiness for the impending adverse weather conditions on February 29 - March 1, 2012. The review focused on the service water system and the emergency diesel generators (EDGs). The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and technical specifications to determine what design features would protect these systems, and to ensure NextEra personnel had adequately prepared for adverse weather challenges. The inspectors reviewed station procedures, including NextEras severe weather procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to verify that no issues existed that could challenge the operability of the systems during adverse weather. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
==1R04 Equipment Alignment
==
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following system:
- Vital Battery 1-EDE-B-1D cross tie and return to service following maintenance on January 5, 2012
- Diesel Generator (DG) Train A during planned maintenance activities on the DG Train B on January 23, 2012
- Emergency Feedwater System restoration following surveillance testing on 1-FW-P-37-B on February 21, 2012
- B residual heat removal system following return from maintenance on February 28, 2012 The inspectors selected these systems based on their risk-significance for the current plant configuration or following realignment. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On January 23 to 25, 2012, the inspectors performed a complete system walkdown of accessible portions of the main steam (MS) system to verify the equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment lineup procedures, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether NextEra staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure NextEra appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
==1R05 Fire Protection
==
.1 Resident Inspector Quarterly Walkdowns
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that NextEra controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures:
- Turbine Building 21 ft on January 20, 2012
- Turbine Building 50 ft on January 23, 2012
- B Train DG Building on January 23, 2012
- Containment Enclosure Ventilation 21 ft on January 25, 2012
- Turbine Building 75 ft on February 1, 2012
- Primary Auxiliary Building 35 ft on February 22, 2012
- Main Steam Feedwater Enclosure 3 ft on February 29, 2012
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed a fire brigade drill scenario conducted on March 9, 2012, that involved a fire in the main generator on the turbine building 75 ft elevation. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that NextEra personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:
- Proper wearing of turnout gear and self-contained breathing apparatus
- Proper use and layout of fire hoses
- Employment of appropriate fire-fighting techniques
- Sufficient fire-fighting equipment brought to the scene
- Effectiveness of command and control
- Search for victims and propagation of the fire into other plant areas
- Smoke removal operations
- Utilization of pre-planned strategies
- Adherence to the pre-planned drill scenario
- Drill objectives met
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site internal flooding analysis, and plant procedures to verify that the NextEras flooding mitigation plans and equipment are consistent with the design requirements and the risk analysis assumptions. The inspectors also reviewed the corrective action program to determine if NextEra identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on the main steam and feedwater pipe chase area to verify the adequacy of equipment seals located below the flood line, floors and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
b. Findings
No findings were identified.
==1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
==
The inspectors reviewed the A EDG jacket water heat exchanger, DG-E-42A, thermal performance to determine its readiness and availability to perform its safety functions.
The inspectors reviewed the design basis for the component. The inspectors assessed the results of previous inspections of the A EDG jacket water heat exchanger. As applicable, the inspectors discussed the results of the most recent inspection with engineering staff and assessed documentation of the as-found and as-left conditions.
The inspectors observed actual performance tests for heat exchanger/sinks or reviewed the data/reports from the performance tests for any obvious problems or errors. The inspectors verified that NextEra initiated appropriate corrective actions for identified deficiencies. The inspectors also verified, if any tubes were plugged, the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Licensed Operator Simulator Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on February 13, 2012, which included a response to an airborne security event coincident with a loss of offsite power. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by licensed operations personnel. However, this was considered a training exercise and was not credited as an input into the Drill and Exercise Performance, Performance Indicator per NEI 99-02. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Observations of Licensed Operator Performance in the Control Room
a. Inspection Scope
The inspectors observed licensed performance in the main control room during periods of heightened activity or risk. The inspectors observed testing of the turbine valves on February 9, 2012, and temperature instruments affecting reactor control on March 6, 2012, and plant load changes in response to adjustments in generator stator cooling on January 20 and February 2, 2012. The inspectors evaluated operator performance relative to control board manipulations, response to off-normal conditions and the use of operating procedures. The inspectors assessed the clarity and effectiveness of communications, use of error prevention techniques, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the technical specification action statements entered by licensed operations personnel. Additionally, the inspectors assessed the ability of the crew to identify and document crew performance problems.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC performance and reliability. The inspectors reviewed system health reports, maintenance backlogs, and MR basis documents to ensure that NextEra was identifying and properly evaluating performance problems within the scope of the maintenance rule. As applicable, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by NextEra staff was reasonable; for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2); and, the inspectors independently verified that appropriate work practices were followed for the SSCs reviewed. Additionally, the inspectors ensured that NextEra staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
- Heat trace system with a focus on maintaining minimum temperatures on safety related and emergency operating procedure support system pipe and tubing
- Condensate polishing system performance with a focus on equipment failures resulting in unplanned reactor transients and shutdown
- Service water system unavailability during valve maintenance
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that NextEra performed the appropriate risk assessments prior to removing equipment for work.
The inspectors selected these activities based on potential risk significance. As applicable for each activity, the inspectors verified that NextEra personnel performed risk assessments as required by 10 CFR 60.65(a)(4) and applicable station procedures, and that the assessments were accurate and complete. When NextEra performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met:
- Planned work associated with the emergency air handling fan (1-EAH-FN-5-B)combined with a battery capacity test on vital battery 1-EDE-BC-1D and generator stator cooling system cleaning on January 3, 2012
- Planned work associated with switchyard and charging system maintenance combined with an emergent loss of 345KV line 394 on February 8-9, 2012
- Planned work associated with the electric driven emergency feedwater pump operability testing combined with supplemental emergency power system battery maintenance on February 21, 2012
- Planned work associated with the residual heat removal and electrical distribution systems on February 28-March 1, 2012
- Planned work associated with the restoration of vital battery 1-EDE-BC-1B on March 9, 2012
- Emergent work associated with generator stator coolant pump 60B on March 29, 2012
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
- CR1720010, operability of the A train solid state protection system (SSPS) due to a degraded relay K252A for the nuclear instrument protection channel II (NI-N-42) on December 29, 2011
- CR1730493, operability of steam generator 11C due to a steam leak on the secondary side of the steam generator on January 2, 2012
- CR1721604, operability of the reactor protection system with incorrect transmitter response times on January 5, 2012
- CR 1731646, operability of the electrical distribution system based on Event Notification EN47636, vulnerability in under voltage protection scheme, on February 6, 2012
- CR1746851, operability of the service water system with leakage in underground piping on March 21, 2012
The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to NextEras evaluations to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by NextEra. The inspectors determined, where appropriate, compliance with assumptions in the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.
The modifications were reviewed to verify that changes in the operating parameters for the non-safety related generator stator cooling system would not increase plant risk due to initiating events (reactor trip) and other adverse plant conditions. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
- Relay K252A in Train A Solid State Protection System replacement on January 2, 2012
- Air Handling Fan (EAH-FN-5B) planned maintenance on January 3, 2012
- Residual Heat Removal Valve RH-V611 repairs on February 29, 2012
- Atmospheric Steam Discharge Valve 1-MS-PV-3002 solenoid replacement on March 5, 2012
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and NextEra procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
- OX1426.26, DG-1A Semi Annual Operability Surveillance, on January 9, 2012
- OX1406.02, Containment Spray Pump and Valve Quarterly Operability,18 Month Position Indication and Comprehensive Pump Testing, on January 9, 2012
- CX0901.18, Spray Additive Tank (CBS-TK-13) Sodium Hydroxide Concentration, on January 12, 2012
- OX 1416.05, Service Water Cooling Tower Pumps Quarterly and 2 Year Comprehensive Test,on January 12, 2012
- OX1416.04, Service Water system Comprehensive Testing, on February 10, 2012
- OX1401.02, RCS Steady State Leak Rate Calculation, on February 13-24, 2012
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The NSIR headquarters staff performed an in-office review of the latest revisions of
various Emergency Plan Implementing Procedure (EPIP) revisions, located under
ADAMS accession number ML12010A023 as listed in the Attachment.
NextEra transmitted the EPIP revisions to the NRC pursuant to the requirements of
10 CFR 50, Appendix E, Section V, Implementing Procedures. The NRC review was
not documented in a safety evaluation report and did not constitute approval of licensee-
generated changes; therefore, this revision is subject to future inspection
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine NextEra emergency drill on January 24 and 25, 2012 to identify any weaknesses and deficiencies in the classifi-cation, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the simulator and technical support center drill critiques to compare inspectors observations with those identified by NextEra staff in order to evaluate NextEras critique and to verify whether NextEra staff was properly identifying weaknesses and entering them into the corrective action program.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational/Public Radiation Safety (PS)
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed the performance indicators for the Radiation Safety cornerstone, recent operational occurrences and the latest quality assurance (QA)audit of the Radiation Protection program.
Radiological Hazard Assessment The inspectors reviewed any changes to plant operations that may result in a significant new radiological hazard for onsite workers or members of the public since the last inspection. The inspectors verified that NextEra had assessed the potential impact of these changes and had implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard.
Recent radiological surveys from more than six plant areas were reviewed by the inspectors to evaluate the thoroughness and frequency of the surveys and that they were appropriate based on the radiological hazards.
The inspectors conducted walk-downs and performed independent radiation surveys of the facility, including radioactive waste processing, storage, handling areas, to evaluate the existing radiological conditions and the efficacy of the associated radiological postings and controls.
The inspectors observed and evaluated the following radiological risk-significant work activity: containment access during plant operating conditions (a locked high radiation area).
With respect to the above work activity, the inspectors verified that appropriate prework surveys were performed and were sufficient to identify and quantify the radiological hazards and to establish adequate protective measures. In addition, the inspectors reviewed applicable radiological surveys associated with this work activity to determine if hazards were properly identified, including the following: identification of hot particles, the presence of alpha emitters, the potential for airborne radioactive materials, the hazards associated with work activities that could negatively affect the radiological conditions, and any significant radiation field dose gradients that could result in non-uniform exposures of the body.
Instructions to Workers The inspectors observed various radioactive material containers and verified that they were labeled and controlled in accordance with 10 CFR Part 20 requirements.
Radiation work permits (RWPs) associated with the radiological risk-significant work activity listed above, were evaluated by the inspectors to identify what work control instructions or control barriers were specified and that plant-specific technical specification high radiation area requirements were met, including the use of applicable electronic personal dosimeter (EPD) alarm setpoints that were specified in conformance with survey indications and plant policy.
Contamination and Radioactive Material Control The inspectors conducted observations at the main radiological controlled area (RCA)egress location to observe the performance of personnel surveying and releasing material for unrestricted use to verify that those activities were performed in accordance with plant procedures and the procedures were sufficient to control the spread of contamination and prevent unintended release of radioactive materials from the site.
The inspectors reviewed NextEras criteria for the survey and release of potentially contaminated material and verified that the radiation detection instrumentation was being used at its most effective sensitivity capability.
The inspectors selected three sealed sources from NextEras inventory records and verified that the required semi-annual leak tests were performed. The inspectors verified that there have been no changes in the inventory of sources currently listed in the National Source Tracking System.
Radiological Hazards Control and Work Coverage
During tours of the facility and review of the work activity listed above, the inspectors evaluated the ambient radiological conditions and verified that existing conditions were consistent with posted surveys, RWPs, and worker briefings, as applicable.
During this work activity performance observations, the inspectors verified the adequacy of radiological controls, such as required surveys (including system breach radiation, contamination, and airborne surveys), radiation protection job coverage, contamination controls, and NextEras means of using EPDs in high noise areas as high radiation area (HRA) monitoring devices.
The inspectors verified that radiation monitoring devices were placed on the individuals body appropriately to monitor dose from external radiation sources.
The inspectors reviewed one RWP for work within potential airborne radioactivity areas with the potential for individual worker internal exposures. The inspectors evaluated the airborne radioactivity controls and monitoring, including potentials for significant airborne radioactivity levels.
The inspectors examined NextEras physical and programmatic controls for highly activated or contaminated materials (nonfuel) stored within the spent fuel pool and verified that appropriate controls were in place to preclude inadvertent removal of these materials from the pool.
Tours within the RCA were conducted by the inspectors to evaluate radiological postings and physical controls for HRAs and very high radiation areas (VHRAs) with respect to regulatory requirements.
Radiation Worker Performance During observation of the work activity listed above, the inspectors observed radiation worker performance with respect to applicable radiation protection work requirements to determine if workers were aware of the significant radiological conditions in their workplace and their work performance was within the RWP control/limit requirements specified for the work performed.
The inspectors reviewed several radiological problem reports since the last inspection that identified the cause of the event to be human performance errors to determine if there was an observable pattern traceable to a similar cause and if this perspective matched the corrective action approach taken by NextEra to resolve the reported problems.
Radiation Protection Technician Proficiency During observation of the work activity listed above, the inspectors evaluated the performance of radiation protection technicians with respect to radiation protection work requirements and determined that technicians were aware of the radiological conditions in their workplace and that the RWP controls/limits and their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities.
The inspectors reviewed several radiological problem reports since the last inspection that identified the cause of the event to be radiation protection technician error to determine if there was an observable pattern traceable to a similar cause and if this perspective matched the corrective action approach taken by NextEra to resolve the reported problems.
Problem Identification and Resolution The inspectors verified that problems associated with radiation monitoring and exposure control were being identified by NextEra at an appropriate threshold and were properly addressed for resolution in NextEras corrective action program.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspectors reviewed pertinent information regarding plant collective exposure history, current exposure trends, ongoing or planned activities in order to assess current performance and exposure challenges, and the reviewed the plants 3-year rolling average (TYRA) collective exposure.
The inspectors reviewed plant historical data associated with source term measurements and associated plant dose rate trends. Based on NextEras long-term collective radiation exposure goals, the inspectors reviewed their source term reduction ALARA five-year plans.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA. The procedures reviewed Included a review of processes used to estimate and track exposures from specific work activities.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures as low as is reasonably achievable (ALARA), including a review of processes used to estimate and track exposures from specific work activities.
Source Term Reduction and Control Through a review of NextEras records, the inspectors evaluated the historical trends and current status of significant tracked plant source terms known to contribute to elevated facility aggregate exposure and reviewed NextEras contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors reviewed the results of radiation protection program audits related to internal and external dosimetry (i.e., licensees quality assurance (QA) audit).
The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) report on the vendors most recent results to determine the status of the vendors external dosimetry program.
NextEras procedures associated with dosimetry operations and dose evaluations were reviewed and verified that NextEra has established procedural requirements for determining when external and internal dosimetry is required.
External Dosimetry
National Voluntary Laboratory Accreditation Program (NLVLAP) Accreditation
The inspectors verified that NextEras personnel dosimeters that require processing are NVLAP accredited. This review included the approved irradiation test categories for the type of personnel dosimeter used (thermoluminescent dosimeters (TLD)) that are consistent with the types and energies of the radiation present, and use of the dosimeters.
Passive Dosimeters (OSL)
The onsite storage of personnel dosimeters was evaluated by the inspectors to verify the appropriate background exposure monitoring of dosimeters was accounted for when not in use.
Active Dosimeters (Electronic Dosimeters)
The inspectors reviewed NextEras use of a correction factor to address the response of the electronic dosimeter (ED) as compared to TLDs for situations when the ED data was used to assign personnel dose.
Internal Dosimetry
Routine Bioassay (in vivo)
NextEras use of passive monitoring using portal monitors for screening intakes was reviewed for adequacy to detect internally deposited radio nuclides.
Positive whole body count records for 2011 were reviewed and verified that no detectable internal dose assessments were determined above 10 mrem.
Special Bioassay (in vitro)
During 2011, there were no internal dose assessments requiring in vitro monitoring for inspection review.
The inspectors reviewed and assessed the adequacy of NextEras program for dose assessments based on airborne monitoring. This review verified that flow rates and/or collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs) were obtained. The inspectors reviewed the adequacy of procedural guidance used to assess dose when, if using respiratory protection, NextEra applied protection factors. There were no dose assessments that used airborne monitoring for 2011 to review.
Special Dosimetric Situations
Declared Pregnant Workers The inspectors verified that NextEra informs workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.
There were no declared pregnant workers and, therefore, no applicable exposure records to review for 2011.
Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures
The inspectors reviewed the adequacy of NextEras methodology for monitoring external dose in situations in which non-uniform fields are expected or large dose gradients will exist (e.g., diving activities and steam generator jumps) to include criteria for determining dosimetry placement or the use of multibadging.
Shallow Dose Equivalent
During 2011, there were no shallow dose equivalent dose assessments for inspection review.
Neutron Dose Assessment
The inspectors reviewed NextEras neutron dosimetry program, including dosimeter types and/or neutron survey instrumentation.
Problem Identification and Resolution The inspectors verified that problems associated with occupational dose assessment were identified by NextEra at an appropriate threshold and were properly processed for resolution in NextEras corrective action program.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Initiating Events Performance Indicators (3 samples)
a. Inspection Scope
The inspectors reviewed NextEras submittal of the following initiating events performance indicator results for the period of January 2011 through December 2011:
- Unplanned Scams per 7,000 Critical Hours
- Unplanned Scams with Complications
- Unplanned Power Changes per 7000 Critical Hours
To determine the accuracy of the performance indicator data reported for this period, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed NextEras operating logs, licensee event reports (LERs), procedures, and interviewed applicable personnel to validate the accuracy of the submittals. The inspectors also reviewed the accuracy of the number of critical hours reported or the period.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that NextEra entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample:
General Electric (GE) Model CR-120B Control Relay Failures
a. Inspection Scope
The inspectors performed an in-depth review of NextEras failure analysis and corrective actions associated with condition reports 1614198, 1683406 and 1696937 that documented failures of model CR-120B control relays manufactured by GE.
Specifically, on September 2, 2011, a 120 VAC GE model CR-120B relay failed during bench testing. The relay remained in the energized position after voltage to the operating coil had been removed. Five other relays procured under the same purchase order had also experienced similar failures to reset to the de-energized position during bench tests.
The inspectors assessed NextEras problem identification threshold, causal analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of NextEras corrective actions to determine whether NextEra was appropriately identifying, characterizing, and correcting problems associated with this issue. The inspectors compared the actions taken to the requirements of NextEras corrective action program and Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action. In addition, the inspectors reviewed documentation associated with this issue, including condition and failure analysis reports, and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions and the actions planned to complete full resolution of the issue.
b. Findings and Observations
No findings were identified.
The GE relays had been procured as commercial grade components and approved for use as equivalent replacements for existing relays that had become obsolete and no longer available. Minor modification (MMOD) 02-0521, Replacement Models for Type J-Series Relays, implemented the review and approval of the GE relays for use in both safety-related and nonsafety-related applications. NextEra utilized a third party vendor, National Technical Systems (NTS), to provide testing and engineering support during the qualification process.
Following the relay failures during bench testing, NextEra appropriately entered the condition into the corrective action program and implemented thorough causal evaluations, extent of condition reviews and a reportability evaluation. As part of the failure analysis, NextEra provided relays to two consulting companies (NTS and Exelon Power Labs) for testing and evaluation. Both companies concluded that residual magnetism following energization of the relay operating coils was the cause of failure.
The force of the residual magnetism was sufficient to hold the relays in the energized position after voltage was removed from the operating coil.
NextEra also took actions to determine where the suspect relays had been installed in plant systems and performed an evaluation to ensure the failure mode identified for the relays would not result in a loss of safety function for any systems. A similar evaluation was also performed for all applications for which the relays had been approved for use (but not yet installed) as suitable replacements for the existing relays. As a result of this review, NextEra determined there was one application where the installation of defective relay could have resulted in a safety significant failure of the emergency diesel generator air handling (DAH) system. The NextEras assessment concluded that the installation of a suspect relay in this system would constitute a substantial safety hazard and, therefore, reported the relay deficiency to the NRC as required by 10 CFR Part 21, Reporting of Defects and Noncompliance. Plant staff performed a walk down and confirmed that a GE Model CR-120B relay had not been installed in the DAH control circuit and that the original style relay was still installed. Therefore, there was no current concern with the operability of the DAH system.
NextEra also put a hold on the use of in-stock spare CR-120B relays for use in the plant unless the relays had been extensively tested and evaluated and approved for a specific application by engineering. The failure evaluation actions are also continuing in an effort to determine why certain relays/relay lots are susceptible to this build-up of unacceptable levels of residual magnetism. Corrective actions remain open to track the need for any additional actions that may be necessary once the cause of the residual magnetism is fully understood.
The inspectors determined NextEras overall response to the issue was commensurate with the safety significance, was timely, and included appropriate interim corrective actions. The inspectors also determined that the actions taken and planned were reasonable to resolve the CR-120B control relay failure to reset issue.
.3 Annual Sample: Air-Operated Valve Feedback Linkage Maintenance Deficiencies
a. Inspection Scope
In November 2007, a Bailey positioner linkage disconnected on a primary component cooling water (PCCW) valve and caused a temperature excursion. This issue was determined to be a condition adverse to quality as documented in Condition Reports (CR) 07-15319 and 07-15292, and associated apparent cause evaluations. The failure was attributed to human performance errors during air-operated valve (AOV)maintenance, in that
- (1) technicians did not ensure the threaded rod of the linkage assembly was fully engaged in the turnbuckles, or
- (2) the lock nuts were not adequately tightened. Additionally, the maintenance procedure for the PCCW valve lacked specific details regarding the linkage assembly. NextEra subsequently
- (1) performed extent of condition reviews of similar valves,
- (2) developed planned maintenance activities to verify linkage assemblies were appropriately installed and tightened;
- (3) revised PCCW procedure IS 1616.490 to enhance guidance on installation and configuration of linkage assemblies;
- (4) provided remedial training to maintenance personnel; and,
- (5) evaluated planned maintenance activities for the existing PCCW valves to verify the inspections assured the valves remained operable. NextEra developed Maintenance Support Evaluation (MSE) 08-MSE-058 to provide the design basis for existing air-operated valves in the plant and address differences in various positioner linkage assembly configurations.
The inspectors performed walkdowns of various systems, including the main steam system, and assessed Seabrooks (FPLE) previously-completed cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions, resulting from the 2007 PCCW event. The inspectors evaluated whether Seabrook personnel had properly identified, characterized, and corrected problems associated with this issue, and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of NextEra's corrective action program (CAP) and 10 CFR 50, Appendix B.
The inspectors performed field walkdowns and interviewed NextEra personnel to assess the effectiveness of the implemented corrective actions.
b. Findings
No findings were identified.
During plant inspections tours, the inspectors noted inconsistencies regarding the positioner assembly locking mechanisms associated with main steam valves; specifically, in the use of lock nuts and lock washers used to ensure the linkage rods remained tight. These inconsistencies resulted in the identification of three, separate and distinct performance deficiencies, and are described and dispositioned from an enforcement perspective below.
- (1) The inspector noted that five of six main steam dump valves, and the B and C main steam atmospheric dump valves, had at least one end of the threaded linkage rod locked with a jam nut and star washer. The inspector noted that these configurations were consistent with the
- (1) specific instructions in the vendor technical manual, which requires, during assembly activities, to Lock all linkage components in place, and (2)the intent of the vendor manual, which recommends the use of lockwire and pre-formed holes in both the turnbuckle and the threaded linkage rod, to positively lock the linkage assembly in place. The inspectors also determined that yearly preventive maintenance tightness checks, provided reasonable assurance of continued valve functionality.
However, on steam dump valve MS-PV-3017, there was a single jam nut on either end of the linkage rod with no lock washer, which represented a continued vulnerability to potential loosening of the linkage and loss of valve functionality, especially in a high vibration environment. NextEra generated work orders to install star washers on this valve and remaining steam dump valves, where needed, and verified that the linkage for MS-PV-3017 was properly tightened.
- (2) NextEra had revised PCCW maintenance procedures following the 2007 event, and in 2008, committed to evaluate other preventive maintenance activities to ensure adequate guidance was provided for assembly of feedback and positioner linkage assemblies. However, following a review of selected maintenance procedures in November 2011, the inspectors noted a number of procedures provided inconsistent or inadequate guidance to assure positive locking of linkage assemblies. For example, maintenance procedures MS0519.46, IS1652.330, and IS0652.960, contained no references to lock nuts and lock washers, or lock wire as provided in the vendor maintenance kits. However, although these procedures lacked sufficient guidance, the current field condition of the atmospheric dump valves, and all but one main steam dump valve, were adequate to ensure continued operability or functionality.
- (3) MSE 08-MSE-058 provides the engineering basis for functionality of valves with various positioner assembly configurations. The MSE contained guidance that allowed linkage configurations that were inconsistent with the vendor manual. Specifically, the vendor manual references the use of lock wire to provide positive locking of the linkage rod. The MSE allowed for the optional use of a flat washer, which provides no pre-load to prevent loosening, and the optional use of a star washer to prevent loosening.
Further, neither the vendor manual nor the maintenance procedures contain reference to the threaded linkage rod being reverse-threaded. The design document guidance did not reflect other engineered methods to assure positive locking as identified in the operating experience for plant events, which were caused by the same failure mode and human performance issues experienced at Seabrook in 2007.
The inspectors determined that all three issues were not more than minor, because although they were related to the design control and procedure quality attributes of the Mitigating System Cornerstone, its objective to ensure the capability of systems to respond to initiating events was not significantly or adversely affected. Specifically, the functionality of the affected valves with various linkage configurations had not been affected in the intervening years between November 2007 and November 2011. As such the inspectors determined that the functionality of the various affected valves was assured through the performance of preventive maintenance tightness checks of each affected valves linkage configuration. NextEra performed these PMs at frequencies ranging from monthly to annually. As a result, in accordance with NRC IMC 0612, the above issues constituted violations of minor significance that are not subject to enforcement action in accordance with the Enforcement Policy. NextEra entered the inspector's observations into the CAP as CR 1708951.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report (LER) 05000443/2011-003-00: Offsite AC Source
Inoperable during Diesel Generator Operation
LER 2011-03, dated February 14, 2012, reported a determination per 10 CFR 50.73(a)(2)(i)(B) that Seabrook had operated in a condition prohibited by Technical Specifications (TSs). The plant design includes two independent offsite AC sources: (1)one circuit through the unit auxiliary transformer (UAT) and
- (2) a second source through the reserve auxiliary transformer (RAT) to both trains of emergency buses. Operability of the RAT supply is contingent upon the ability of the electrical system to perform a fast transfer from the UAT to the RAT upon opening of the UAT supply breaker. NextEra determined in December 2011 that a previously unrecognized condition existed.
Specifically, that when the emergency diesel generator (EDG) is operating and parallel with offsite power, the fast transfer capability from the UAT to the RAT supply is not available, rendering the offsite AC source inoperable. This condition was determined to have existed on at least two occasions and rendered the offsite AC source inoperable for a period longer than permitted by TS 3.8.1.1.
The inspectors reviewed the accuracy of the LER and verified compliance with the reportability requirements in 10 CFR 50.73 and NUREG 1022. The LER concerned a condition that was a violation of NRC requirements established in TS 3.8.1.1 due to the unavailability of the UAT to RAT fast transfer feature during operation with the EDG in parallel with offsite power resulting in a failure to meet the limiting condition for operation (LCO). The failure to comply with the TS requirements constitutes a violation of NRC requirements. The enforcement aspects of this issue are discussed in Section 4OA7.
The inspectors did not identify any new issues during the review of the LER. This LER is closed.
4OA5 Other Activities
.1 Independent Spent Fuel Storage Installation (60855, 60855.1)
a. Inspection Scope
The inspectors interviewed personnel and reviewed documents and records associated with the operation of the Seabrook Station Independent Spent Fuel Storage Installation (ISFSI). Also, documents associated with past loadings of dry cask canisters were reviewed to ensure that the Certificate of Compliance (CoC) and Technical Specifications (TS) were met. The inspectors met with reactor engineering personnel to review the fuel selection, placement configuration, and inventory process and associated documentation for the last ISFSI loading campaign. The inspectors interviewed site radiation protection personnel and reviewed ISFSI related radiation protection procedures, radiation work permits (RWPs), and environmental monitoring programs to verify compliance with the CoC, TS, and ISFSI site boundary dose criteria specified in 10 CFR 72.104. The inspectors reviewed the Seabrook Station training program to ensure personnel were trained to perform their designated tasks. The inspectors performed a walkdown of the ISFSI pad to inspect the horizontal storage modules (HSMs) and verified the absence of any transient combustibles on the pad and in the vicinity of the HSMs.
b. Findings
No findings were identified.
.2 International Atomic Energy Agency (IAEA) Operational Safety Review Team (OSART)
Assessment - June 6 - June 23, 2011
a. Inspection Scope
The International Atomic Energy Agency is an independent intergovernmental, science and technology-based organization, in the United Nations family, that serves as the global focal point for nuclear cooperation. One of the services provided is an independent assessment of licensee performance by senior staff members from the IAEA member states. This assessment team is called an Operational Safety Review Team, or OSART. The focus of the review by the OSART is on the safety and reliability of plant operation through review of the operation of the plant and the performance of NextEras management and staff. The NRC believes that it would be beneficial for the US Nuclear power industry to continue to volunteer and participate in the OSART missions. To help ensure that U.S. licensees participate in the operational safety assessment review team missions, the NRC has decided to and will grant a one-time regulatory inspection credit (a reduction in the baseline program) for those baseline programs that overlap with the OSART review as directed and outlined in Manual Chapter 2515, Section 08.05, Baseline Inspection Credit for Operational Safety Review Team Effort, dated September 24, 2009.
Between June 6 and June 23, 2011, NextEra personnel debriefed the inspectors about issues identified by the OSART assessment team on a daily basis. The inspectors also participated in weekly OSART team leader debriefs and the OSART team exit on June 23, 2011. The inspectors used the information provided during the daily and weekly debriefs and the final OSART exit meeting to screen the issues identified by OSART for immediate safety concerns. None were identified.
NRC inspectors reviewed both a draft and final version of the OSART report. Inspectors screened the issues documented in the reports to identify issues that required additional NRC review in accordance with the reactor oversight process. Issues identified as requiring additional NRC follow-up will be reviewed by inspectors during routine baseline inspection activities. Findings identified will be documented in applicable NRC inspection reports.
Based on the results of the inspectors review and assessment of the scope of OSART activities through the daily and weekly debriefs and the review of the draft and final OSART mission report, NRC Region I management approved for Seabrook, with two exceptions, full regulatory inspection credit in the baseline inspection procedures described in Section 08.04 of Inspection Manual Chapter (MC) 2515. The two exceptions to full regulatory credit were in the following areas: problem identification and resolution (PI&R) (IP 71152) and emergency planning (IP 71114 and IP 71151). For the PI&R area the inspectors determined that the breadth of review was not sufficient to warrant full credit, and, therefore, 25% (vs. 50%) credit was approved. For emergency planning the two applicable inspection procedures are performed every two years. The procedures were last performed in December 2011, and will not be performed again until 2013. The inspectors determined that due to the timing of the issuance of the final OSART mission report, providing credit for inspections that will not be performed until 2013, did not meet the intent of the credit guidelines established in IMC 2515 Section 08.04; therefore, no inspection credit was approved for the emergency planning area.
In total the NRC will provide NextEra 158 hours0.00183 days <br />0.0439 hours <br />2.612434e-4 weeks <br />6.0119e-5 months <br /> of baseline inspection credit out of the 221 hours0.00256 days <br />0.0614 hours <br />3.654101e-4 weeks <br />8.40905e-5 months <br /> that were defined by MC 2515 as potentially within the scope of the OSART assessment. The NRC has made the final OSART report publicly available on the NRC website, Agency Documents Access and Management System (ADAMS) accession number ML12081A105.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On April 9, 2012, the inspectors presented the inspection results to Mr. P. Freeman and other members of the Seabrook Station staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by NextEra and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as NCVs.
.1 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that
measures shall be established to assure that that conditions adverse to quality are promptly identified and corrected. Contrary to the above, NextEra did not assure that a previously identified hold down clamp and missing chaffing material on the B emergency diesel generator (EDG) fuel oil return was promptly corrected. Specifically, as part of an October 2008 extent of condition for a similar condition discovered on the A EDG, the missing clamp and chaffing material was planned to be installed but was not. In November 2011, during a surveillance test of the B EDG, a leak occurred due to vibration induced fretting of the fuel oil return line. Though NextEras engineering and maintenance walkdown procedure provided direction intended to identify the missing clamp and chaffing material, NextEra determined that the direction was ineffective in identifying the condition adverse to quality on the B EDG. This performance deficiency was identified in the corrective action program as Condition Report 1710841. The inspectors determined that this finding was of very low safety significance (Green)because it did not represent an actual loss of safety function or contribute to external event core damage sequences. Since the issue was of very low safety significance and was entered into the corrective action program it is considered a licensee-identified, non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
.2 Technical Specification 3.8.1.1, "A.C. Sources," requires as a minimum, the following
A.C. electrical power sources shall be operable:
- (a) two physically independent circuits between the offsite transmission network and the onsite Class 1E Distribution System, and
- (b) two separate and independent diesel generators. TS 3.8.1.1 Action a. requires that with one of the required offsite AC electrical power sources and one of the required independent diesel generator power sources inoperable, operators must demonstrate the operability of the remaining A.C. source by performing TS surveillance requirement (SR) 4.8.1.1.1a. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. Contrary to the above on October 31, 2011, for 110 minutes, and from January 10 to 17, 2011, when both the A EDG and one of the required offsite power sources were inoperable, NextEra did not perform TS SR 4.8.1.1.1a. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
In both instances, the offsite AC source via the RAT was not declared inoperable and the applicable TS action was not entered because NextEra did not recognize the impact of the EDG operation on the fast transfer feature in the TS Bases change process.
Specifically, NextEra did not ensure appropriate technical evaluations were performed to review change implications against all normal plant configurations. This finding is of very low safety significance (Green) per IMC 0609 because the issue did not result in a total loss of safety function and did not contribute to both a transient initiator and the likelihood that mitigating functions would be unavailable. Specifically a fast transfer would occur following an opening of the EDG breaker if the bus and RAT were in synchronism. If the bus and RAT were not in synchronism, the RAT breaker would close when residual bus voltage relays actuated. Since the issue is of very low safety significance and was entered into the corrective action program as AR 1718306, the issue is considered a licensee-identified, non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- K. Boehl, Health Physics Analyst
- B. Brown, Supervisor, Civil Engineering
- V. Brown, Senior Licensing Analyst
- B. Buerger, ISFSI Project Manager
- M. Collins, Manager, Design Engineering
- L. Hansen, Plant Engineering
- J. Kotkowski, Electrical Design Supervisor
- P. Freeman, Site Vice President
- N. Levesque, Plant Engineering
- K. Mahoney, Senior Reactor Engineer
- B. McAllister, Senior Nuclear Engineer
- W. Meyer, Radiation Protection Manager
- M. OKeefe, Licensing Manager
- D. Robinson, Chemistry Manager
- M. Scannell, Senior Radiation Protection Analyst
- G. Sessler, System Engineer
- R. Sterritt, ALARA Coordinator
- E. Trump, Senior Nuclear Engineering Analyst
- R. Thurlow, Health Physics Supervisor - NU
- J. Tucker, Nuclear Security Site Manager
- T. Vehec, Plant General Manager
- T. Waechter, Operations Manager
- P. Woodhams, Project Manager
- M. Woods, Fire Protection Engineer
- present at ISFSI exit meeting.
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
None
Opened
None
Closed
- 05000443/2011-003-00 LER Offsite AC Source Inoperable during Diesel Generator Operation (Section 4OA3 / 4OA7)