IR 05000443/2012008
| ML12209A319 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/27/2012 |
| From: | Arthur Burritt Reactor Projects Branch 3 |
| To: | Walsh K NextEra Energy Seabrook |
| Burritt A | |
| References | |
| IR-12-008 | |
| Download: ML12209A319 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION uly 27, 2012
SUBJECT:
SEABROOK STATION UNIT 1- NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000443/2012008
Dear Mr. Walsh:
On June 28, 2012, the United States Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit 1. The enclosed report documents the results of this inspection, which were discussed on June 28, 2012 with you and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
From June 6 - 23, 2011, Seabrook Station participated in an International Atomic Energy Agency Operational Safety Review Team evaluation. The results of this evaluation were made publicly available on March 21, 2012 (ML12081A105). As such, in accordance with NRC Inspection Manual Chapter 2515, Section 08.05, the inspection hours for this biennial problem identification and resolution inspection were reduced by approximately 25 percent.
Based on the samples selected for review, the inspectors did not identify any findings during this inspection. The inspectors concluded that problems were, in most cases, properly identified, evaluated, and resolved in the corrective action program. NextEra personnel identified problems and entered them into the corrective action program at a low threshold. NextEra prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were implemented in a timely manner. The inspectors determined that in general, NextEra appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. Additionally, the inspectors concluded that self-assessments, audits, and other internal NextEra assessments reviewed during the inspection were typically critical, thorough, and effective in identifying issues. 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 Projects Branch 3 Division of Reactor Projects Docket Nos.: 50-443 License Nos.: NPF-86
Enclosure:
Inspection Report 05000443/2012008 w/Attachment: Supplemental Information
REGION I==
Docket Nos.: 50-443 License Nos.: NPF-86 Report Nos.: 05000443/2012008 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit 1 Location: Seabrook, New Hampshire 03874 Dates: June 11, 2012 - June 28, 2012 Team Leader: Carey Bickett, Senior Project Engineer, Division of Reactor Projects Inspectors: Elise Burket, Reactor Inspector, Division of Reactor Safety Nathan Lafferty, Project Engineer, Division of Reactor Projects Approved by: Arthur L. Burritt, Chief Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000443/2012008; 06/11/2012 - 06/28/2012; Seabrook Station, Unit 1; Biennial Baseline
Inspection of Problem Identification and Resolution.
This NRC team inspection was performed by three 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.
Problem Identification and Resolution The inspectors concluded that NextEra was generally effective in identifying, evaluating, and resolving problems. NextEra personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. NextEra appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that NextEra typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.
Based on those items selected for review, the inspectors concluded that, in general, NextEra adequately identified, reviewed, and applied relevant industry operating experience to Seabrook Station operations. Additionally, the inspectors determined that NextEras self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues. The inspectors also concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
From June 6 - 23, 2011, Seabrook Station participated in an International Atomic Energy Agency Operational Safety Review Team evaluation. The results of this evaluation were made publicly available on March 21, 20121. As such, in accordance with NRC Inspection Manual Chapter 2515, Section 08.05, the inspection hours for this biennial problem identification and resolution inspection were reduced by approximately 25 percent.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described NextEras corrective action program at Seabrook Station. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and NextEra procedures PI-AA-204, Condition Identification and Screening Process, Revision 16, and PI-AA-205, Condition Evaluation and Corrective Action, Revision 15. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed action requests selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended Initial Screening Team and Management Review Committee meetings. The inspectors selected items from the following functional areas for review:
engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed work orders, a sample of active clearances, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency feedwater system and the emergency diesel generators. Additionally, the inspectors reviewed a sample of action requests written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that NextEra entered conditions adverse to quality into their corrective action program as appropriate.
The evaluation report can be found in ADAMS under accession number ML12081A105.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of action requests issued since the last NRC biennial Problem Identification and Resolution inspection completed in October 2010. The inspectors also reviewed action requests that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability evaluations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed NextEras completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed action requests for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed NextEras timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of action requests associated with selected non-cited violations, findings, and licensee-identified violations to verify that NextEra personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate NextEras actions related to the emergency feedwater system.
b.
Assessment
- (1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that NextEra identified problems and entered them into the corrective action program at a low threshold. NextEra staff at Seabrook Station initiated approximately 25,000 action requests between October 2010 and May 2012. The inspectors observed Seabrook staff at Initial Screening Team and Management Review Committee meetings appropriately questioning and challenging action requests to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that NextEra trended equipment and programmatic issues, and appropriately identified problems in action requests. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, NextEra personnel promptly initiated action requests and/or took immediate action to address the issues.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, NextEra appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
NextEra screened action requests for operability and reportability, categorized the action requests by significance, and assigned actions to the appropriate department for evaluation and resolution. The action request screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of action requests reviewed, the inspectors noted that the guidance provided by NextEra corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors did note one observation in NextEras evaluation of the following issue:
In accordance with Seabrooks Updated Final Safety Analysis Report, during a steam generator tube rupture with a loss of offsite power, operators must be able to manually isolate a failed open atmospheric steam dump valve within 20 minutes to minimize radiological consequences. In January 2011, the station wrote action request 1609948 to evaluate operating experience that could potentially affect this time-critical action.
Based on this operating experience, the station concluded that the force required to close the block valve during this event may be higher than originally thought.
Additionally, the station determined that there was no testing method to evaluate closing times under conditions that would be experienced during this design basis event. The station developed a routine work action assignment, due in May 2013, to determine if operators can meet the time critical requirement to close the block valves given the new conditions. The in-progress notes for this action stated that the station was working with the industry to provide a generic solution to the testing issue. However, the action request never evaluated whether operators would still be able to complete the time-critical action given the new conditions.
The station performed an evaluation and determined that the operators would be able to complete this time critical action within the 20 minute limit discussed in the Updated Final Safety Analysis Report. The evaluation determined that the force required to close the valve would likely be less due to the decreasing pressure in the faulted steam generator. In addition, the station conducted a job performance measure to verify the approximate time it would take an operator to complete this task. Operators were able to simulate closing the block valves within approximately nine minutes for the valves that were farthest from the control room, and five minutes for the valves closest to the control room.
NextEra procedure PI-AA-205, Condition Evaluation and Corrective Action, Section 4.3.5, requires that condition evaluations be conducted to the extent necessary to understand the condition and develop adequate corrective actions. In this case, the station did not fully evaluate whether operators could complete a time-critical action based on new information obtained via operating experience. The inspectors independently evaluated this issue for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues.
Because Seabrook ultimately determined that operators would still be able to complete this action within the 20 minutes specified in the Updated Final Safety Analysis Report, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. NextEra documented this issue in action request 1779955.
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, NextEra identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations, findings, and licensee-identified violations since the last problem identification and resolution inspection were timely and effective.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of action requests associated with review of industry operating experience to determine whether NextEra appropriately evaluated the operating experience information for applicability to Seabrook Station and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that NextEra adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b.
Assessment The inspectors determined that in general, NextEra appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that in most cases, operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. However, the inspectors did note one observation related to documenting evaluations of operating experience in the corrective action program.
NextEra procedure PI-AA-201-1001, Operating Experience Program Screening and Responding to Incoming Operating Experience Guideline, Revision 9, states that all operating experience evaluations shall be completed within 60 days. The only exceptions to this are evaluations of Institute of Nuclear Power Operations level three event reports, which are to be completed within 30 days. During the inspection, the team identified instances where NextEra either assigned due dates for evaluations, or extended initial due dates, beyond this 60-day limit. Examples include the following:
Action requests 66020 and 26494, which document NRC Information Notices 2005-15 and 2007-14, respectively. NextEra created action request 66020 in 2005, with a routine work assignment to complete the evaluation in November 2012. NextEra created action request 26494 in 2007, with a routine work assignment to complete the evaluation in December 2016. Following inspector identification of these examples, the station completed a review of any open action requests that addressed NRC Information Notices and discovered three additional action requests with untimely applicability evaluations. NextEra documented this issue in action request 1779678, including a corrective action to complete the evaluations by July 20, 2012.
Action request 1611787, which documents operating experience obtained at a motor operated valve users group meeting. NextEra entered this operating experience into their corrective action program in January 2011 as a routine work tracking item to be completed by February 2011. In August 2011, Nuclear Oversight identified this evaluation was not completed and initiated action request 1676747 with a new due date of March 2013 to complete the evaluation.
NextEra documented this issue in action request 1779319, including a corrective action to complete the evaluation by July 31, 2012.
The inspectors independently evaluated this issue for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors did not identify any events at Seabrook that may have been mitigated by the use of this operating experience. Additionally, the inspectors concluded that this issue was not programmatic as the evaluations were limited to one department. As such, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if NextEra entered problems identified through these assessments into the corrective action program, when appropriate, and whether NextEra initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
b. Assessment The inspectors concluded that self-assessments, audits, and other internal NextEra assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that NextEra personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. NextEra completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Seabrook Station. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC, and observed a station Nuclear Safety Culture Meeting.
The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that NextEra entered issues into the corrective action program when appropriate.
b. Assessment During interviews, Seabrook staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies, and stated that they were willing to raise safety issues. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. The Nuclear Safety Culture Meeting included representatives from each department on site, and participants were actively engaged during the meeting. Based on these limited interviews and observations, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On June 28, 2012, the inspectors presented the inspection results to Mr. Kevin Walsh and other members of the Seabrook staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
K. Walsh Site Vice President
T. Vehec Plant General Manager
K. Boehl ALARA Coordinator
P. Brangiel Principal Engineering Analyst (Plant Engineering)
P. Brown Motor Operated Valve Engineer
V. Brown Senior Licensing Analyst
J. Connolly Director of Engineering
D. Egonis Programs Engineer
J. Griffin Security Analyst
T. Jennis Senior Mechanic
J. Johnson Emergency Feedwater System Engineer
G. Kilby Licensing Engineer
M. Leone Training Supervisor
D. McGonigle Design Engineering
S. Morrisey Electrical Maintenance Supervisor
C. Moynihan Senior Analyst
J. Normandin Security Corrective Action Program Coordinator
D. Robinson Chemistry Department Manager
R. Samson Mechanical Maintenance Superintendent
S. Samstag Assistant Operations Manager Work Management
G. Sessler Principal Engineer
T. Smith Radiation Protection Supervisor
J. Sobotka Mechanical Design Engineering Supervisor
B. Stacey Senior Analyst Maintenance Department
T. Waechter Operations Manager
B. Whyte Electrical Maintenance Supervisor
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
None