ML023120116
| ML023120116 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/07/2002 |
| From: | Brian Mcdermott NRC/RGN-I/DRP/PB6 |
| To: | Warner M North Atlantic Energy Service Corp |
| References | |
| IR-02-005 | |
| Download: ML023120116 (37) | |
See also: IR 05000443/2002005
Text
November 7, 2002
Mr. Mark E. Warner
Site Vice President
c/o Mr. James M. Peschel
Seabrook Station
P.O. Box 300
Seabrook, NH 03874
SUBJECT: SEABROOK STATION - NRC INSPECTION REPORT 50-443/02-05
Dear Mr. Warner:
On September 28, 2002, the NRC completed an inspection at the Seabrook Station. The
enclosed report documents the inspection findings which were discussed on October 7, 2002,
with Mr. J. Vargas and other members of your staff.
This 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.
Based on the results of this inspection, the inspectors identified two issues of very low safety
significance (Green). The findings were determined to be violations of NRC requirements
involving inadequate corrective actions and security personnel readiness. However, because of
their low safety significance and because they have been entered into your corrective action
program, the NRC is treating these issues as Non-Cited violations, in accordance with Section
VI.A.1 of the NRCs Enforcement Policy. If you deny these Non-Cited violations, you should
provide a response with the basis for your denial, within 30 days of the date of this inspection
report, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington,
D.C. 20555-0001, with copies to the Regional Administrator, Region I, and the Director, Office
of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-001,
and the NRC Resident Inspector at the Seabrook Station.
The NRC has increased security requirements at Seabrook Station in response to terrorist acts
on September 11, 2001. Although the NRC is not aware of any specific threat against nuclear
facilities, the NRC has issued an Order and several threat advisories to commercial power
reactors to strengthen licensees' capabilities and readiness to respond to a potential attack.
The NRC continues to inspect the licensee's security controls and its compliance with the Order
and current security regulations.
Mr. Mark E. Warner 2
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Brian J. McDermott, Chief
Projects Branch 6
Division of Reactor Projects
Docket No. 50-443
License No: NPF-86
Enclosure: NRC Inspection Report No. 50-443/02-05
Attachment 1: Supplemental Information
cc w/encl:
J. A. Stall, FPL Senior Vice President, Nuclear & CNO
J. M. Peschel, Manager - Regulatory Programs
G. F. St. Pierre, Station Director - Seabrook Station
R. S. Kundalkar, FPL Vice President - Nuclear Engineering
D. G. Roy, Nuclear Training Manager - Seabrook Station
D. Bliss, Director, New Hampshire Office of Emergency Management
D. McElhinney, RAC Chairman, FEMA RI, Boston, Massachusetts
R. Backus, Esquire, Backus, Meyer and Solomon, New Hampshire
D. Brown-Couture, Director, Nuclear Safety, Massachusetts Emergency Management Agency
S. McGrail, Director, Massachusetts Emergency Management Agency
R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts
M. Metcalf, Seacoast Anti-Pollution League
D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
S. Comley, Executive Director, We the People of the United States
W. Meinert, Nuclear Engineer, Massachusetts Municipal Wholesale Electric Company
R. Shadis, New England Coalition Staff
P. Brann, Assistant Attorney General
M. S. Ross, Attorney, Florida Power and Light Company
Office of the Attorney General
Town of Exeter
Board of Selectmen
Mr. Mark E. Warner 3
Distribution w/encl: (VIA E-MAIL)
H. Miller, RA
J. Wiggins, DRA
H. Nieh, EDO Coordinator
S. Richards, NRR (ridsnrrdlpmlpdi)
B. McDermott, DRP
K. Jenison, DRP
G. Dental, SRI - Seabrook
J. R. White, DRS
D. C. Lew, DRS
J. C. Linville, DRS
L. T. Doerflein, DRS
R. J. Conte, DRS
T. Moslak, DRS
P. Frechette, DRS
N. McNamara, DRS
Region I Docket Room (with concurrences)
DOCUMENT NAME: C:\ORPCheckout\FileNET\ML023120116.wpd
After declaring this document An Official Agency Record it will be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with
attachment/enclosure "N" = No copy
OFFICE RI/DRP RI/DRP E RI/DRP
NAME GDentel/KMJ for/ K Jenison B McDermott
DATE 11/07/02 11/07/02 11/07/02
OFFICIAL RECORD COPY
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-443
License No.: NPF-86
Report No.: 50-443/2002-05
Licensee: North Atlantic Energy Service Corporation
Facility: Seabrook Station, Unit 1
Location: Post Office Box 300
Seabrook, New Hampshire 03874
Dates: June 30, 2002 to September 28, 2002
Inspectors: Glenn Dentel, Senior Resident Inspector
Javier Brand, Resident Inspector
David Kern, Senior Resident Inspector, Beaver Valley
Kenneth Jenison, Senior Project Engineer
Antone Cerne, Senior Resident Inspector, Millstone Unit 3
Thomas Moslak, Health Physicist
Paul Frechette, Security Specialist
Gregory Smith, Senior Security Specialist
Martha Barillas, Reactor Engineer
Approved by: Brian J. McDermott, Chief
Projects Branch 6
Division of Reactor Projects
SUMMARY OF FINDINGS
IR 05000443-02-05; North Atlantic Energy Service Corporation (FPL Energy Seabrook, LLC as
of November 1, 2002); on 06/30-09/28/2002; Seabrook Station, Unit 1. Surveillance Testing
and Response to Contingency Events.
The inspection was conducted by resident inspectors, a reactor engineer, a senior project
engineer, a health physics inspector, and security specialists. The inspectors identified two
Green findings that were also determined to involve non-cited violations. The significance of
most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,
Significance Determination Process (SDP). Findings for which the SDP does not apply may
be Green or be assigned a severity level after NRC management review. The NRCs program
for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector Identified Findings
Cornerstone: Mitigating Systems
C Green. The inspectors identified a Non-Cited Violation of 10 CFR 50, Appendix B,
Criterion XVI Corrective Action, in that corrective actions were not adequate for
degraded electrical connections found on rectifier bank #1 for the B Emergency Diesel
Generator (EDG) in October 2001. The degraded rectifier bank connections were
characterized as serious by industry standards for thermography and required prompt
corrective maintenance. The licensees corrective actions did not adequately evaluate
whether the cause was applicable to rectifier bank #2. In July 2002, during
troubleshooting efforts for problems with the B EDG, two additional serious hot
connections were discovered on rectifier bank #2.
The finding was considered more than minor because if the finding was left uncorrected,
the degraded connections could have degraded further and impacted the reliability of
the EDG. The finding was determined to be of very low safety significance (Green)
since the hot connections did not result in an actual failure of the EDG. Because the
finding is of very low safety significance and the finding was captured in the licensees
corrective action program, this finding is being treated as a Non-Cited Violations,
consistent with Section VI.A.1 of the NRC Enforcement Policy. (Section 1R22)
Cornerstone: Physical Protection
C Green. An in-office review by Region I security specialists identified a non-cited
violation of 10 CFR 73.55(b.1.i) and the requirements of Seabrook Physical Security
Plan. On July 25, 2002, a member of the Security Response Force failed to respond to
an intrusion alarm and was subsequently found inattentive while on duty.
Failure of the response force member to respond to the intrusion alarm in a manner to
assure conformance with the requirements of the Seabrook Station Physical Security
Plan and Procedures was determined to have very low safety significance using the
Interim Physical Significance Determination Process. The finding involved a
ii
vulnerability of Safeguards Systems or Plans, but no actual intrusion occurred and there
have not been more than two similar findings in the past four quarters. (Section 3PP3)
B. Licensee Identified Violations
A violation of very low safety significance, which was identified by the licensee, has been
reviewed by the inspector. Corrective actions taken or planned by the licensee have
been entered into the licensees corrective action program. This violation and its
corrective action tracking number are listed in Section 4OA7 of this report.
iii
TABLE OF CONTENTS
Page
SUMMARY OF FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
1. REACTOR SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1R01 Adverse Weather Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1R04 Equipment Alignment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1R05 Fire Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1R11 Licensed Operator Requalification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1R12 Maintenance Rule Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
1R13 Maintenance Risk Assessments and Emergent Work Evaluation . . . . . . . . . . 6
1R14 Personnel Performance During Non-routine Plant Evolutions . . . . . . . . . . . . . 7
1R15 Operability Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
1R17 Permanent Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
1R19 Post-Maintenance Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
1R22 Surveillance Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
1R23 Temporary Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
1EP6 Drill Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
2. RADIATION SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
2PS2 Radioactive Material Processing and Transportation . . . . . . . . . . . . . . . . . . . 17
3. SAFEGUARDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3PP3 Response to Contingency Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3PP4 Security Plan Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
4. OTHER ACTIVITIES [OA] . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
4OA1 Performance Indicator Verification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
4OA2 Identification and Resolution of Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
4OA3 Event Follow-Up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
4OA6 Meetings, including Exit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
4OA7 Licensee Identified Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
ATTACHMENT 1
SUPPLEMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
iv
Report Details
SUMMARY OF PLANT STATUS:
The plant operated at approximately 100% power for the duration of the inspection period.
1. REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity [R]
1R01 Adverse Weather Protection
.1 Hurricane/Severe Weather Preparations
a. Inspection Scope
The inspectors reviewed Seabrooks preparations for weather related risks associated
with tornados, hurricanes, and high winds. The inspectors performed walkdowns of
systems including the service water building and the emergency feedwater pump house
to evaluate the material condition of tornado dampers, doors, and seals. On August 9,
2002, the inspectors observed testing of tornado dampers. The inspectors reviewed the
following Seabrook Station documents:
C OS1200.03, Severe Weather Conditions, Rev. 10
C NM 11800, Hazardous Condition Response Plan, Rev. 9
C CR 01-12479, Testing of Tornado Dampers
C WO 01B9987, CBA Tornado Damper Testing and Cleaning
C USFAR Section 1.2, 2.3, 2.4
The inspectors also verified that the NRC Regulatory Issue Summary 2000-15,
Recommendations for Ensuring Continued Safe Plant Operation and Minimizing
Requests for Enforcement Discretion during Extreme Weather Conditions was properly
evaluated and procedures were updated.
b. Findings
No findings of significance were identified.
.2 Effects of Hot Weather
a. Inspection Scope
The inspectors reviewed the effects on plant equipment and the stations response to
increased ambient temperatures during June through August 18, 2002. The inspectors
reviewed CR 02-12420 and CR 02-12419, which documented several alarms caused by
the increased ambient temperature, and verified that the effect on the plant was of minor
significance and properly captured in the corrective action program.
The inspectors reviewed applicable data documenting repeated high temperature
alarms and performed partial walkdowns of the affected areas and the control room. In
2
addition, the inspectors interviewed control room operators and the instrumentation and
control supervisor to assess their understanding of the effect of the heat wave on plant
equipment and associated alarms. The following challenges were documented and
evaluated by the station.
- Battery rooms A, B, and D high temperature alarms
- Cooling tower basin bulk average temperature alarms
- Emergency feedwater pump house high temperature
In addition, the inspectors reviewed CR 02-12987, which documented potential
vulnerabilities introduced by the large error band (+/- 10 degrees Fahrenheit) of the local
area temperature indicators. These indicators are used to confirm compliance with area
temperature requirements specified in Technical Specification (TS) 4.7.10. The
inspectors verified that the TS limits were not exceeded based on other, independent
instruments.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Full System Walkdown - Service Water System
a. Inspection Scope
The inspectors performed a full system walkdown of the service water (SW) system,
involving equipment in both trains, associated main control room valve position
indication, and associated piping and in-line components.
The inspectors used the piping and instrumentation drawings for the SW system, the
system health report, the system design bases document, and a list of system related
condition reports and open work orders, to verify the material condition of the inspected
equipment. In addition, the inspectors used the following completed valve lineup
procedures to verify the position of a sample of selected system valves.
- OX1416.01 Service Water System Fill and Vent, Forms A, B, and C, Rev. 7.
- OS1016.01 Monthly Service Water Valve Verification, Rev. 9.
b. Findings
No findings of significance were identified.
3
.2 Full System Walkdown - A Emergency Diesel Generator and Support Systems
a. Inspection Scope
The inspectors performed a full system walkdown of the A Emergency Diesel
Generator (EDG) and partial system walkdowns of several support systems including
the equipment associated with the main control room EDG indicators and associated
piping and in-line components.
The inspectors referenced Seabrook Piping and Instrumentation Drawings for the EDG
fuel oil system, EDG air start system, service water system, and electrical distribution
system. In addition, the inspectors reviewed a list of EDG related condition reports and
a selection of automated work orders to verify the material condition of the inspected
equipment.
b. Findings
No findings of significance were identified.
.3 Partial System Walkdown - Instrument Air System
a. Inspection Scope
The inspectors performed a partial system walkdown of the instrument air system to
verify system alignment during installation and testing of Design Change Request (DCR)
00-0014, Instrument Air Dryer Replacement, (see Section 1R17). Installation of the
DCR involved configuration changes which connected the new dryer (SKD-18B) and a
temporary air dryer to the instrument air system. This system was selected for
alignment verification due to the increased likelihood for a reactor trip initiating event
during DCR installation.
The inspectors reviewed the following documents to determine proper equipment
alignments.
C Procedure ON1042.01, Operation of the Compressed Air System, Rev. 8
- Procedure ON1242.01, Loss of Instrument Air, Rev. 7
- Drawing 1-IA-20636, Instrument Air, Rev. 2
C Drawing 1-IA-20637, Instrument Air, Rev. 12
C Drawing 1-IA-20638, Instrument Air, Rev. 11
- Drawing 1-IA-20639, Instrument Air, Rev. 10
- Drawing 1-SA-20650, Service Air, Rev. 20
C Temporary Modification 01-0007, Temporary Air Dryer, Rev. 1
Additionally, the inspectors reviewed and evaluated impact on instrument air system
operation for selected open work orders, design change packages, engineering
evaluations, and corrective action program condition reports. The system health report
was reviewed and open issues were discussed with the system engineer.
b. Findings
4
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
The inspectors examined several areas of the plant to assess: 1) the control of transient
combustibles and ignition sources; 2) the operational status and material condition of
the fire detection, fire suppression, and manual fire fighting equipment; 3) the material
condition of the passive fire protection features (fire doors, fire dampers, fire penetration
seals, etc.); and 4) the compensatory measures for out-of-service or degraded fire
protection equipment. The following areas were inspected:
C B Essential Switchgear Room-Control Building, 21'6" elevation
C A Emergency Diesel Generator Building, all elevations - multiple occasions
C B Emergency Diesel Generator Building, all elevations - multiple occasions
C A High Head Safety Injection Pump Room-Primary Auxiliary Building, 7'0" elevation
C B High Head Safety Injection Pump Room-Primary Auxiliary Building, 7'0" elevation
C A and C Battery Rooms-Control Building, 21'6" elevation
C B and D Battery Rooms-Control Building, 21'6" elevation
C Cable Spreading Room-Control Building, 50'0" elevation
The inspectors reviewed the following documents:
C Fire Protection Pre-Fire Strategies
C FP2.1 Control of Ignition Sources, Rev. 5
C FP2.2 Control of Combustible Materials, Rev. 6
C OX0443.12 Fire Protection Dry Pipe Spray and Sprinkler Systems 18 Month
Inspection, Rev. 6
C Compensatory List of Fire Protection Equipment out-of-service
C Fire Protection Equipment Layout Drawings.
C Technical Requirements Manual Sections 2.7 to 2.12
C Selected CRs and Work Orders
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification
a. Inspection Scope
On August 15, 2002, the inspectors observed operator training focusing on human
performance of time critical tasks. The inspectors reviewed the operators ability to
correctly evaluate the training scenario and implement the emergency plan. The
inspectors also evaluated whether or not deficiencies were identified and discussed
during critiques.
b. Findings
5
No findings of significance were identified
1R12 Maintenance Rule Implementation
.1 Enclosure Air Handling (EAH) Damper Failure
a. Inspection Scope
The inspectors evaluated Maintenance Rule (MR) implementation pertaining to an
enclosure air handling (EAH) ventilation damper (EAH-DP-30B) failure that occurred on
August 29, 2002. The damper failed to open as required upon starting its associated
fan for monthly surveillance testing. The damper failure was due to failure of its
normally energized solenoid valve (EAH-FY-30B). The inspectors verified that system
performance was monitored and evaluated as required by 10 Code of Federal
Regulations (CFR) 50.65, Requirements for Monitoring the Effectiveness of
Maintenance of Nuclear Power Plants. The inspectors performed field walkdowns and
a review of historical EAH damper related CRs. The inspectors also performed a review
of historical data documenting solenoid valves failures to access the general
performance of these valves including the effects of aging. In addition, the inspectors
interviewed various licensee personnel including the several system engineers and
evaluated the licensees operability and reportability evaluation documented in CR 02-
12902. The following documents were reviewed:
C CR 02-12902, EAH-DP-30B failed to open upon starting fan EAH-FN-4B;
C IS0603.005, Equipment qualification for ASCO Solenoid Valves, Rev. 4;
C Work Order 0227324 issued to investigate damper EAH-DP-30B failure;
C NUREG-1275, Vol.6, Operating Experience Feedback Report Solenoid-Operated
Valve Problems;
C List of historical CRs documenting solenoid valves and ventilation dampers failures.
b. Findings
No findings of significance were identified.
.2 Instrument Air System
a. Inspection Scope
The inspectors evaluated MR implementation for the instrument air system. The system
was placed in MR category (a)(1) on March 7, 2002, due to unreliable air dryer
performance. Specific attributes reviewed included MR scoping, characterization of
failed structures, systems, and components (SSCs), MR risk categorization of SSCs,
SSC performance criteria or goals, and appropriateness of corrective actions. The
inspectors verified that system performance was monitored and evaluated as required
by 10 Code of Federal Regulations (CFR) 50.65, Requirements for Monitoring the
Effectiveness of Maintenance of Nuclear Power Plants. The inspectors interviewed
engineers, observed system testing, and reviewed various documents including:
C Instrument Air System Performance Report dated July 2002;
6
C MR (a)(1) Improvement Plan for Instrument Air Dryer IA-SKD-18B, Rev. 0;
C Instrument Air System MR Performance and Scope Report, Rev. 1;
C CR 01-07313, 01-13574, 01-12718, 01-11776, 01-10564, 02-03059, and 02-11619.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a. Inspection Scope
The inspectors reviewed the scheduling and control of maintenance activities in order to
evaluate the effect on plant risk. The inspectors reviewed the routine planned
maintenance and emergent work for the following equipment removed from service.
C On July 18, 2002, the inspectors reviewed the risk associated with restoration of the
A battery following discharge testing. The inspectors attended the pre-evolution
briefing, observed the work activity, and verified the proper use of procedures. When
the normal battery supply breaker did not close as expected (CR 02-11408), the
inspectors verified that operators minimized the risk associated with a battery
configuration.
C On August 6, 2002, the inspectors reviewed the risk assessment for the days work
activities. The equipment removed from service included the A cooling tower fan,
two switch yard breakers, the A EDG and the A residual heat removal (RHR)
pump. The inspectors evaluated the controls placed on the risk significant activities
and active measures taken to reduce the risk. For example, the inspectors verified
the surveillance test, which resulted in inoperability of the EDG and RHR pump, was
not performed at the same time as active work in the switch yard (risk for loss of
offsite power).
C On August 13, 2002, the inspectors reviewed the risk associated with spurious trips
of the Tewksbury offsite power line on August 10 and 13. The inspectors examined
the operators actions to evaluate risk and actions taken by maintenance technicians
to prevent further trips. The inspectors reviewed CRs 02-12194, 02-12279 and 01-
00507, interviewed maintenance technicians and the system engineer, and reviewed
various electrical prints.
C On August 19, 2002, the inspectors reviewed the risk associated with inspections of
vendor supplied electrical wire terminations on the A EDG panels (CP-75A and B).
The inspectors observed the work activity, interviewed field personnel, verified the
proper use of procedures, and reviewed the associated work order (WO 0225256).
The inspectors also reviewed the engineering evaluation documented under CR 02-
12142 and associated corrective actions for some broken strands and loose wires
identified during the inspection of both EDG cabinets.
C On August 30, 2002, the inspectors reviewed the risk associated with emergent work
to investigate the failure of EAH damper (EAH-DP-30B) and to implement repairs.
7
The inspectors performed field walkdowns, reviewed the associated work order (WO)
0227324, and verified the proper use of procedures.
C On September 17, 2002, the inspectors reviewed the risk associated with inspections
and actions to correct deficiencies in the B and C secondary component cooling
water pumps oil bubblers. The inspectors performed field walkdowns, interviewed the
pump specialist, and reviewed CR 02-13505. In addition, the inspectors verified that
the evaluation of this issue included an adequate extent of condition review and
assessment of generic implications.
b. Findings
No findings of significance were identified.
1R14 Personnel Performance During Non-routine Plant Evolutions
.1 Spent Fuel Pool Dive and Strainer Gasket Replacement
a. Inspection Scope
On September 11 to 16, 2002 the inspectors reviewed the activities associated with the
gasket replacement for the spent fuel pool skimmers. The replacement required the
use of qualified divers and the installation of a temporary platform for the divers. The
inspectors examined the controls placed on the divers by reviewing procedure
HN0960.01, Radiological Safety Requirements for Diving Operations, Rev. 23, and by
interviewing the divers, operators, the job supervisor, maintenance engineers and
technicians, and radiation protection personnel. In addition, the inspectors attended
several pre-job briefs, reviewed the WO 00C5355, and assessed the controls of foreign
material and temporary equipment.
b. Findings
No findings of significance were identified.
8
.2 Control Room Annunciator Power Failure
a. Inspection Scope
On September 9, the inspectors reviewed the operators activities associated with the
unexpected loss of power to hard wired annunciator panel UA-51 documented under CR
02-13247. The inspectors performed field walkdowns, interviewed operators, and
examined the Seabrook Station Alarm Response Procedures associated with this panel
to assess the effect on plant safety. The inspectors also reviewed the Emergency
Response Manual, Section 1.1 to confirm the determination that the loss of the
annunciators did not require an entry into an emergency action level.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
.1 Incorrectly Installed Electrical Connection on the Emergency Diesel Generator Control
Panel
a. Inspection Scope
The inspectors reviewed CR 02-11097, which evaluated the effects of a shorted
connection in the A EDG, in order to determine that the identified condition did not
adversely affect safety system operability or plant safety. The shorted connection,
which the licensee attributed to a human performance error, occurred on July 10, while
the "A" EDG was out of service for scheduled maintenance activities. The inspectors
verified the TS limiting condition for operation implications were properly addressed, and
that an adequate extent of condition review was performed. Seabrook Station
Administrative Procedure OE 4.5, "Operability Determination," and NRC Generic Letter 91-18, "Resolution of Degraded and Nonconforming Conditions" were used to evaluate
the licensees operability determination.
b. Findings
No findings of significance were identified.
.2 Emergency Power Sequencer Switch Found in the Test Position
a. Inspection Scope
The inspectors reviewed the Operability Determination (OD) prepared on August 1,
2002 to address the degraded equipment conditions documented in two condition
reports, (CRs) 02-11857, which discusses the trip of battery charger 1-EDE-BC-1B, and
CR 02-11865, which identifies a condition where the test switches in the emergency
power sequencer (EPS) on both safety trains were found to be in an abnormal position
(the TEST mode). The CRs are related by the facts discovered during the investigation
of the loss of the battery charger, which noted that an EPS output relay had spuriously
9
energized, causing the battery chargers power supply input breaker to trip open. Since
the EPS test switches were determined to have been out of position since May 2002,
the OD was initiated to evaluate this condition with respect to the functionality of each
EPS, the possibility of a causal relationship between the mis-positioned switches and
the failed relay, and the potential for either the energized relay or a relay driver card
malfunction to adversely affect the EPS function.
The inspectors reviewed the WOs 0224585 and 0224586 issued to conduct the
troubleshooting activities to determine the cause of the loss of battery charger 1-EDE-
BC-1B and subsequently witnessed testing and repair activities in the train B EPS to
establish that the problem was caused by an intermittent failure of a relay driver card.
The inspectors also reviewed the record for the operational surveillance (OX1426.20) for
the testing in May 2002 of one EDG and its associated EPS. The inspectors verified
consistency between the surveillance test logic and details in the OD regarding the EPS
design features that allow proper sequencing of the EDG loads with the sequencer
switch position in TEST. The applicable electrical schematic diagrams (e.g., FP 31427)
for the battery charger supply power, related EPS relays and wiring were reviewed and
discussed with the cognizant licensee instrumentation, and control personnel involved in
the troubleshooting and repair activities.
The inspectors evaluated the Seabrooks justification for continued operation,
addressing the problems identified in both CRs that necessitated the required operability
determination. The inspectors verified that the post-maintenance test and operational
surveillance (OX1426.03) of the train B EPS validated the troubleshooting results,
corrective actions, and overall determination regarding operability of the EPS function.
b. Findings
No findings of significance were identified.
.3 Emergency Diesel Generator Issues
a. Inspection Scope
The inspectors reviewed the following conditions in order to determine that the
conditions did not adversely affect safety system operability or plant safety. In addition,
where a component was determined to be inoperable, the inspectors verified the TS
limiting condition for operation implications were properly addressed. Seabrook Station
Administrative Procedure OE 4.5, Operability Determination, and NRC Generic Letter 91-18, Resolution of Degraded and Nonconforming Conditions were used to evaluate
the licensees operability determinations. The inspectors performed field walkdowns,
interviewed personnel, and reviewed the following items:
- CR 02-10604, B EDG jacket water leak at the right bank turbocharger. The
inspectors reviewed the evaluation, interviewed the system engineer, evaluated the
impact of a small jacket water leak, and examined the effects of a sustained leak for
a 24-hour period. The inspectors also evaluated the expected accident loading for
the EDG since the size of the leak appeared load dependent. In addition, the
10
inspectors reviewed the available indications of a jacket leak and prescribed operator
actions in response to those indications.
determination of the rectifier selector switch, maintenance technicians identified wires
that separated from a lug. Subsequent inspections of the A and B EDGs identified
other loose or not optimal connections. The inspectors reviewed the past operability
evaluation concentrating on the seismic qualification, the extent of condition review
evaluation, and actions taken to correct the deficiencies.
b. Findings
No findings of significance were identified.
.4 Unit Substation Electrical Breaker Found in Incorrect Position
a. Inspection Scope
The inspectors reviewed CR 02-10945, which discusses the incorrect racked out
position of unit substation breaker 61, to determine if the as found condition had any
adverse effect on any of the offsite electrical power supplies to Seabrook Station. The
inspectors reviewed the licensees evaluation to determine the cause of the breaker
being found in the incorrect position.
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed DCR 00-0014, Instrument Air Dryer Replacement, design
change notice (DCN) number two to verify that system design bases, licensing bases,
and performance capability were not degraded by the DCR. The inspectors observed
selected instrument air dryer SKD-18B testing activities to ensure operability of the
instrument air system and to verify that plant risk was not adversely impacted. The
inspectors monitored installation of a temporary air dryer as a contingency for continued
system operation during SKD-18D installation and testing. The inspectors observed
pre-evolution briefings, interviewed various station personnel, witnessed a portion of the
post-installation testing, and reviewed selected design documents including those listed
below. The DCR incorporated changes to address a recent industry loss of an
instrument air event and met the requirements of North Atlantic Design Control (NADC)
Manual, Rev. 19.
C DCR 00-0014, Instrument Air Dryer Replacement, DCN 2
C DCR 00-0014 installation schedule
C Work Order 01C0451, Post-Installation Testing of Instrument Air Dryer Skid SKD-
18B, Rev. 0
11
C NADC Manual, Rev. 19
C North Atlantic Work Management Program, Rev. 17
C Seabrook Updated Final Safety Analysis Report Sections 8.3.1.4, 9.3.1.2.a, 9.3.1.5,
and 10.4.10.2, Rev. 7
C Calculation SBC-565, Diesel Generator Fuel Oil Tank Vortexing Evaluation dated
April 1, 1993
C Calculation 760-11, Diesel Generator Fuel Oil Storage System Capacity dated
December 21, 1984
C Calculation C-S-1-E-0161, Diesel Generator Maximum Allowable Fuel Oil
Consumption Rate, Rev. 11
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the on-line maintenance assessment forms, and several post-
maintenance testing (PMTs) activities to ensure: 1) the PMT was appropriate for the
scope of the maintenance work completed; 2) the acceptance criteria were clear and
demonstrated operability of the component; and 3) the PMT was performed in
accordance with procedures. The following PMTs were reviewed:
- On July 10, LSO563.58, Trip Check Procedure for The Diesel Generator Switchgear
Breakers, Rev. 1, following the preventive maintenance replacement of several
safety-related relays associated with the A EDG. The inspectors also reviewed
condition reports, CR 02-11114 and CR 01-11160, which documented minor
deficiencies identified during the testing.
- On July 16, the function stroke of the C atmospheric dump valve following corrective
maintenance on the valve positioner completed per WO 0222395. The inspectors
also reviewed several condition reports, which documented minor deficiencies
identified during the testing.
- On July 26 through July 29, numerous tests of the B EDG were conducted using
various combinations of installed rectifier banks and the operability surveillance
OX1426.05, DG 1B Monthly Operability Surveillance, following the performance of
several associated work orders that addressed rectifier bank condition, synchronizing
relay operability and other supporting maintenance activities.
and the operability surveillance OX1426.05, DG 1B Monthly Operability
Surveillance, Rev. 8 following replacement of the #1 rectifier bank (WO 0223733)
and the rectifier selector switch (WO 0223721) in the B EDG control panel.
- On September 25 and 26, OX1412.02, PCCW Train B Quarterly Operability, 18
Month Position Indication, And Comprehensive Pump Testing, Rev. 8, following
12
corrective maintenance inspection and leak repair of the D primary component
cooling water pump seal water piping. The inspectors also reviewed the applicable
on-line maintenance assessment evaluation.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
.1 Miscellaneous Surveillance Tests
a. Inspection Scope
The inspectors observed portions of several surveillance tests for safety-related systems
to verify that the system and components were capable of performing their intended
safety function, to verify operational readiness, and to ensure compliance with required
TSs and surveillance procedures.
The inspectors attended some of the pre-evolution briefings, performed system and
control room walkdowns, observed operators and technicians perform test evolutions,
reviewed system parameters, and interviewed the system engineers and field operators.
The following surveillance procedures were reviewed:
C On July 9, IX1668.341, SI-P-937 Containment Pressure Protection Channel I
Operational Test, Rev. 6;
C On July 12, LS0563.68, Diesel Generator Bus Undervoltage Relay Inspection,
Testing and PM, Rev. 1;
C On July 23, IX1680.922, Solid State Protection System Train B Actuation Logic
Test, Rev. 8;
C On July 25, LX0563.01, Reactor Coolant Pump Undervoltage Quarterly
Surveillance, Rev. 3;
C On September 17, CS0910.01, Primary Systems Sampling at SS-CP-166A, Rev. 9
and CX0901.02, Determination of Dose Equivalent I-131, Rev. 10.
13
b. Findings
No findings of significance were identified.
.2 Emergency Diesel Generator Surveillance Testing
a. Inspection Scope
The inspectors reviewed licensee performance related to the following surveillance
tests, involving periodic operability verification of the EDGs:
C OX1426.01, DG 1A Monthly Operability Surveillance
C OX1426.18, Aligning DG 1A Controls for Auto Start
C OX1426.20, Diesel Generator 1A 18 Month Operability Surveillance
C OX1426.21, Diesel Generator 1B 18 Month Operability Surveillance
The test records for the 18-month operability surveillance of the A and B EDGs,
conducted in May 2002, were reviewed. The surveillance records were checked for
evidence of the satisfactory performance testing of both trains of EDG equipment, when
subjected to postulated accident signals, and EDG design events consistent with the TS 4.8.1.1.2f requirements. The inspectors examined the sequence of the test
performance and the system lineup for the conduct of each successive test event. The
inspectors verified that the surveillance records included proper notation of the test
equipment used, documentation of the required procedural step performance, and
evidence of the resolution of test exceptions.
The inspectors also reviewed and evaluated the operational preparations for
surveillance testing of the A EDG on July 30 and 31, 2002. The surveillance was
conducted based upon questions raised regarding common mode concerns relating to
recent problems with the B EDG surveillance test performance. [Note: the results of an
NRC Special Inspection of the problems observed, and resulting period of inoperability
for the B EDG was documented in NRC Inspection Report 50-443/02-10.] Work
Orders associated with the A EDG surveillance run were reviewed and the records of
the successful completion of surveillance procedures OX1426.01 and OX1426.18 were
verified to provide adequate documentation of the TS 4.8.1.1.2 a.5, 6, and 7
requirements. The inspectors discussed the performance results of the A EDG
operational test with the cognizant operations and engineering personnel to confirm
consideration of the test data in the continuing review of the impact of the B EDG
surveillance problems and to verify appropriate Seabrook management attention to the
EDG TS compliance ramifications (reference: Condition Report 02-11795).
b. Findings
No findings of significance were identified.
14
.3 Emergency Diesel Generators - Hot Connections
a. Inspection Scope
On July 26, 2002, during a maintenance run of the B EDG following problems with
reactive load fluctuations, engineers identified two unusual hot connections through the
use of thermography. NRC Inspection Report 50-443/02-10 documented the special
inspection team review of the reactive load swings. The inspectors reviewed the results
from a previous surveillance test on the B EDG conducted on October 17, 2001, which
also identified two hot connections. The inspectors reviewed the corrective actions for
the October 2001 event and their relation to the identified hot connection in July 2002
through interviewing various system engineers and examining the following documents:
C CR 01-10979 Two hot connections in control cabinet 1-DG-CP-76A (B EDG) -
October 2001
C CR 01-12362 Thermography Program Issues
C CR 02-11735 Two hot connections in control cabinet 1- DG-CP-76A (B EDG) - July
2002
C ES1807.016, Thermography Program, Rev. 2
C OX1426.05, DG 1B Monthly Operability Surveillance, Rev. 8
C WO 0223733 Replace/Repair Rectifier #1 for 10DG-1-B
C WO 0223721 Replace Rectifier Selector Switch
b. Findings
Introduction
The inspectors identified that Seabrooks corrective actions and extent of condition
reviews were not adequate for two hot connections found in the B EDG control panel
in October 2001. Failure to have adequate corrective actions contributed to not
identifying two additional hot connections that were discovered following problems with
the B EDG control panel in July 2002. This issue was assessed as having very low
safety significance (Green) and was determined to be a non-cited violation of 10 CFR
50, Appendix B, Criterion XVI Corrective Action.
Description
On October 17, 2001, Seabrook identified two hot connections associated with rectifier
bank #1 in the B EDG control panel. This was the first full thermography performed on
the B EDG control panel. The two hot connections were classified as serious based
on the temperature deviation from normal per the program guidance documents. The
issue was captured in the corrective action system (CR 01-10979) and immediate
actions were taken to correct the condition. The evaluation identified original
construction deficiencies that caused the hot connection and corrective actions included
some checks of the wiring.
The inspectors identified the corrective actions did not include a full review of B EDG
with rectifier bank #2 in-service. The local control panel for each EDG has two rectifier
banks, with only one bank in service at a time. The rectifier bank in service is typically
15
alternated on a monthly basis. Although it was the first full thermography, Seabrook did
not recognize that rectifier bank #2 potentially also had the same condition, which could
degrade and affect the reliability of the EDG. In addition, one of the two rectifier banks
on the A EDG had also not been analyzed with thermography.
On July 26, 2002, engineers identified two additional serious hot connections as part of
a troubleshooting effort following problems with reactive load fluctuations on the B
EDG. The hot connections were associated with rectifier bank #2 and located on a
termination (crimp lug barrel) of cable F1A near diode CR4 and on a termination of
cable P2A near the rectifier bank selector switch SW1. Engineers later determined that
the hot connections were not the most probable cause of the reactive load swings.
Although the serious hot connections were not identified as the most probable cause,
the hot connections could have affected the reliability of the EDG.
Analysis
Seabrooks failure to have adequate corrective actions for degraded electrical
connections found on rectifier bank #1 for the B EDG is considered a performance
deficiency since the corrective action program is required to assure the cause of
significant conditions is determined and corrective action taken to preclude repetition.
The licensees corrective actions did not adequately evaluate whether the cause was
applicable to rectifier bank #2. In July 2002, during troubleshooting efforts for problems
with the B EDG, two additional serious hot connections were discovered on rectifier
bank #2.
The finding was considered more than minor because if the finding was left uncorrected,
the degraded connections could have degraded further and impacted the reliability of
the EDG. Using Appendix A, Phase 1 of Manual Chapter MC 0609, the finding was
determined to be of very low safety significance (Green) since the hot connections did
not result in actual failure of the EDG. This analysis was based on the assumption that
the hot connections did not cause the B EDG reactive load fluctuation observed in July
2002 and described in NRC Inspection Report 50-443/02-10.
The failure to have adequate corrective actions and extent of condition reviews is an
item affecting the problem identification and resolution cross cutting area. (Section
4OA2)
Enforcement
Traditional enforcement does not apply because the issue did not have any actual safety
consequence or potential for impacting the NRCs regulatory function and was not the
result of any willful violation of NRC requirements or Seabrooks procedures.
10 CFR 50, Appendix B, Criterion XVI Corrective Action requires for a significant
condition adverse to quality, measures shall assure the cause of the condition is
determined and corrective action taken to preclude repetition. The hot connections on
the EDG control panel were considered significant since they could affect the EDG
controls and therefore the reliability of the EDG. Contrary to this requirement, Seabrook
failed to have adequate corrective actions to preclude recurrence of the deficiency.
16
Because this violation was of very low safety significance and Seabrook entered this
finding into its corrective action program (CR 02-14103), this violation is being treated as
a Non-Cited Violation consistent with section VI.A.1 of the NRC Enforcement Policy
(NCV 50-443/02-05-01).
1R23 Temporary Plant Modifications
a. Inspection Scope
On September 20, the inspectors reviewed temporary alteration 02-003 associated with
the installation of a temporary pneumatic gag to hold a charging and volume control
system valve (1-CS-V-521) in the open position to allow testing of a system circuit
breaker. The inspectors reviewed associated implementing documents including CR
02-13501 and loop diagram 1-NHY-506275, Rev. 17, to verify the design basis and that
the affected system/component operability was maintained.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness (EP)
1EP6 Drill Evaluation
a. Inspection Scope
On August 21, the inspectors observed portions of the Combined Functional Emergency
Preparedness Drill, 02-02, to evaluate the conduct of the drill and adequacy of the
Seabrooks critique. The inspectors verified that event classification and notification
were properly conducted and priorities were communicated in the technical support
center. The inspectors also verified that identified problems were entered into the
corrective action program through observation of the critique, review of the drill
evaluation report, and review of the list of CRs initiated.
The inspectors reviewed CR 02-13215, which documented a condition identified by the
inspectors, regarding the proper level of involvement by coaches and controllers during
critical evolutions. In addition, the inspectors reviewed CR 02-13203, which
documented a condition identified by the inspectors regarding the procedural
requirement to use data provided by the off-site emergency operations facility software
rather than the control room software when determining the projected off-site dose
calculation.
17
b. Findings
No findings of significance were identified.
2. RADIATION SAFETY
Cornerstone: Public Radiation Safety (PS)
2PS2 Radioactive Material Processing and Transportation
.1 System Walkdown
a. Inspection Scope
The inspectors walked down accessible portions of the radioactive liquid and solid waste
collection/processing systems, and radwaste storage locations, with a Nuclear Systems
Operator and the Health Physics Technical Supervisor, respectively, to determine if:
systems and facilities were consistent with descriptions contained in the Updated Final
Safety Analysis Report (UFSAR); to evaluate general material conditions; and to identify
changes to the systems. Systems visually inspected included portions of the Asphalt
Solidification System, Boron Recovery System, and Steam Generator Blowdown
System. Radwaste storage locations visually inspected included the Waste
Concentrates Tank Room, Spent Resin Sluice Filter Room, Resin Centrifuge Room,
Unit-2 Cooling Tower, and Radioactive Materials Storage Building.
During the walkdowns, the inspectors also reviewed the following:
C the status of any non-operational waste process equipment and the adequacy of
administrative and physical controls for those systems;
C changes made to radioactive waste processing systems and the potential radiological
impact, including safety evaluations, of these changes;
C current processes for transferring radioactive waste resin and sludge to shipping
containers and the mixing and sampling of the waste;
C radioactive waste/material storage and handling practices;
C sources of radioactive waste at the station; and,
C the general condition of facilities and equipment.
The review was against the criteria contained in the UFSAR, Technical Specifications,
the Process Control Plan (PCP), 10 CFR Parts 20, 61, 71, applicable Branch Technical
Positions, and the Seabrook procedures.
b. Findings
No findings of significance were identified.
18
.2 Waste Characterization and Classification
a. Inspection Scope
The inspectors reviewed the following matters:
C radio-chemical sample analysis results for the radioactive waste streams;
C the development of scaling factors for difficult to detect and measure radio nuclides;
C methods and practices to detect changes in waste streams;
C classification and characterization of waste relative to 10 CFR 61.55 and 10 CFR
61.56;
C implementation of applicable Branch Technical Positions on waste classification;
concentration averaging, waste stream determination, and sampling frequency;
C current waste streams and their processing relative to descriptions contained in the
UFSAR and the stations PCP; and
C current processes for transferring radioactive waste resin and sludge discharges into
shipping/disposal containers to determine the adequacy of sampling.
The review was against the criteria contained in the UFSAR, PCP, applicable Branch
Technical Positions, 10 CFR Parts 20, 61, 71, and licensee procedures.
b. Findings
No findings of significance were identified.
.3 Shipment Records and Documentation
a. Inspection Scope
The inspectors selected and reviewed records associated with five (5) non-excepted
shipments of radioactive material made since the previous inspection of this area. The
shipments were Nos.01-006, 01-009,02-003, 02-010, and 02-036. The following
aspects of the radioactive waste packaging and shipping activities were reviewed:
C Implementation of applicable shipping requirements including completion of waste
manifests;
C Implementation of the specifications in applicable Certificates of Compliance, for the
approved shipping casks including limits on package contents;
C Classification and characterization of waste relative to 10 CFR 61.55 and 61.56;
C Implementation of 10 CFR 20, Appendix G;
C Labeling of containers;
C Placarding of transport vehicles;
C Conduct of vehicle checks;
C Providing of driver emergency instructions;
C Completion of shipping paper/disposal manifest;
The review was against criteria contained in 10 CFR Parts 20, 61, 71, applicable
Department of Transportation requirements, as contained in 49 CFR Parts 170-189;
station procedures; and applicable disposal site licenses and related correspondence.
19
b. Findings
No findings of significance were identified.
3. SAFEGUARDS
Cornerstone: Physical Protection [PP]
3PP3 Response to Contingency Events
.1 Response Force Member Inattentive to Duty
a. Inspection Scope
The inspectors conducted an in-office review of the circumstances involving a failure of
a Response Force Member to respond to an Intrusion Alarm, as a result of being
inattentive to duty, on July 25, 2002. The following documents were reviewed:
C Seabrook Station Physical Security Plan, Revision 29, December 18, 2001
C Seabrook Station Contingency Plan, Revision 13, January 11, 2002
C Condition Report 02-05891, April 30, 2002, NRC perceived inattentive to duty
C Condition Report 02-10104, June 14, 2002, Security Officer inattentive to duty
C Condition Report 02-10541, June 25, 2002, Explore negative trends in Security
Officers being inattentive to duty
C Condition Report 02-11729, July 25, 2002, Security Officer inattentive to duty
The review was against applicable requirements contained in 10 CFR 73.55,
Requirements for physical protection of licensed activities in nuclear power reactors
against radiological sabotage, and the Seabrook Physical Security Plan, Revision 29,
dated December 18, 2001.
b. Findings
Introduction
The inspectors identified a finding having very low safety significance (Green) involving
the failure of a Seabrook Station armed response force member to respond to an
intrusion alarm, as a result of being inattentive while on duty on July 25, 2002. This
finding was considered a non-cited violation of the NRC-approved Physical Security
Plan for the Seabrook facility as required by 10 CFR 73.55, Requirements for physical
protection of licensed activities in nuclear power reactors against radiological sabotage.
20
Description
At approximately 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br />, on July 25, 2002, Central Alarm Station (CAS) operator
attempted to contact a security response officer (an armed responder) by radio to direct
the individual to respond to a vital area door alarm, which is a possible indication of
intrusion. The security officer did not answer the radio call, and did not respond to the
vital area door alarm. A security supervisor who heard the radio transmission
responded to the indicated vital area door, and appropriately resolved the alarm
condition. The supervisor subsequently went to the ready room and found the response
force member inattentive to duty.
On the basis of radio communications, the inspectors determined that this condition
existed for no more than thirty minutes.
Analysis
The security response officers failure to meet specific conditions of the NRC-approved
Physical Security Plan, relative to being alert and immediately available for response,
constitutes a performance deficiency. The cause of this matter was reasonably within
Seabrooks ability to foresee and correct; and should have been prevented. However,
the occurrence did not represent an immediate safety concern since an alternate
responder properly assessed the alarm and appropriately resolved the alarm condition.
No actual intrusion occurred.
Traditional enforcement does not apply because the issue did not have any actual safety
consequence or potential for impacting the NRCs regulatory function. While the matter
does not currently appear to be the result of any willful violation of NRC requirements or
Seabrook Stations procedures, this finding will be re-evaluated in accordance with
NRCs Enforcement Policy if deliberateness is later determined.
The finding involved an occurrence relative to the licensees Physical Security program
that was contrary to NRC regulations and the NRC approved Physical Security Plan.
The matter is more than minor in that the issue is associated with the Response to
Contingency Events attribute of the Safeguards cornerstone; and affected the objective
of this cornerstone since failure to comply with the requirements of the Physical Security
Plan may compromise the licensees ability to provide high assurance that the physical
protection system can protect against the design basis threat of radiological sabotage.
The response force officers failure to maintain alertness and be immediately available
for response in accordance with the Physical Security Plan, was determined to have
very low safety significance (Green) using the Interim Physical Protection Significance
Determination Process (Appendix E, Manual Chapter 0609). Specifically, the finding
involved a Vulnerability of Safeguards Systems or Plans. However, in this case, no
actual intrusion occurred; and there have not been greater than two similar findings in
the last four quarters. A second similar licensee identified violation is described in
Section 4OA7.
Enforcement
21
10 CFR 73.55(b)(1)(i) requires all licensees to maintain safeguards in accordance with
Commission regulations and the licensees security plan. Seabrook Station License
Condition 2.E, Physical Security, requires in part, the licensee to fully implement and
maintain in effect all provisions of the physical security plan previously approved by the
Commission, and all amendments and revisions to such plans. Section 10.1 of the
Seabrook Physical Security Plan, Revision 29, dated December 18, 2001, states that
armed responders will be immediately available for response. The Physical Security
Plan also states, in Section 2.6.7, that specific duties of security personnel are
described in Seabrook Station Administrative Procedures. Section 4.1.3 of the
Seabrook Station Security Department Instruction SDI 0042, Security Posts and Recall
of Security Personnel, requires security personnel to remain alert and prevent
unauthorized entry to protected and vital areas.
Contrary to the above, a response force officer was inattentive to duty in the ready room
at approximately 2130, on July 25, 2002 and consequently, failed to remain alert and
immediately available for response. Specifically, the security response officer failed to
respond to a vital area door alarm, a possible indication of intrusion; and was
subsequently observed to be inattentive to duty, by a security supervisor.
Seabrook documented this issue in its corrective action program as Condition Report
02-11729, and initiated immediate actions to preclude recurrence, including initiation of
a formal root cause assessment. This finding is considered a non-cited violation having
very low safety significance (Green). (NCV 50-443/02-05-02)
.2 Periodic Inspection of Response to Contingency Events
a. Inspection Scope
The following activities were conducted to determine the effectiveness of Seabrook
Stations Response to Contingency Events, as measured against the requirements of
10 CFR 73.55 and the Seabrook Station Safeguards Contingency Plan:
C On September 12, 2002, a review of documentation associated with the licensees
force-on-force exercise program was conducted. The review included documentation
and critiques for exercises conducted since the first quarter of 2002 when the
exercises were resumed post September 11, 2001.
C On September 11, 2002, performance testing of the Seabrook Station intrusion
detection systems was conducted. This testing was accomplished by touring the
entire perimeter and selected areas of potential vulnerability in the intrusion detection
system. During the walkdown of the intrusion detection system, nine specific
locations were selected for testing. Observations were made of a Seabrook Station
Security Force Member performing crawl, jump and run testing at these nine
locations.
C On September 10, 2002, a review was conducted of the Seabrook Station defensive
strategy, response time lines, target sets and relevant implementing procedures.
22
C On September 10, 2002, three tabletop exercises were conducted. The mock
adversary was provided entry location and target set information by the inspector.
The response force was directed by a Central Alarm Station Operator. A senior
member of the Seabrook Station Operations staff provided relevant operations
information during the evolution of the exercises.
b. Findings
No findings of significance were identified.
.3 Response to Contingency Events
The Office of Homeland Security (OHS) developed a Homeland Security Advisory
System (HSAS) to disseminate information regarding the risk of terrorist attacks. The
HSAS implements five color-coded threat conditions with a description of corresponding
actions at each level. NRC Regulatory Information Summary (RIS) 2002-12a, dated
August 19, 2002, "NRC Threat Advisory and Protective Measures System," discusses
the HSAS and provides additional information on protective measures to licensees.
a. Inspection Scope
On September 10, 2002, the NRC issued a Safeguards Advisory to reactor licensees to
implement the protective measures described in RIS 2002-12a in response to the
Federal government declaration of threat level "orange." Subsequently, on
September 24, 2002, the OHS downgraded the national security threat condition to
"yellow" and a corresponding reduction in the risk of a terrorist threat.
The inspector interviewed licensee personnel and security staff, observed the conduct of
security operations, and assessed licensee implementation of the threat level "orange"
protective measures. Inspection results were communicated to the region and
headquarters security staff for further evaluation.
b. Findings
No findings of significance were identified.
3PP4 Security Plan Changes
a. Inspection Scope
An in-office review was conducted of changes to the Physical Security Plan (Revisions
28 and 29), Safeguards Contingency Plan (Revisions 12 and 13) and Training and
Qualification Plan (Revisions 12, 13, and 14) submitted to the NRC on April 5, 2001,
January 11, 2002, and March 22, 2002 in accordance with the provisions of
10 CFR 50.54(p). The review was conducted to confirm that the changes were made in
accordance with 10 CFR 50.54(p), and did not decrease the effectiveness of the plan.
b. Findings
23
No findings of significance were identified.
4. OTHER ACTIVITIES [OA]
4OA1 Performance Indicator Verification
.1 (Closed) URI 50-443/01-08-03: Emergency Preparedness Performance Indication -
Evaluating Exceeding the 15 Minutes for Classifications
In NRC Inspection Report 50-443/01-08, the inspectors identified Seabrook guidance
that potentially would consider classification of events greater than 15 minutes
acceptable for the emergency preparedness performance indicator. Seabrook
submitted a frequently asked question (FAQ) to resolve the issue. Seabrook has since
withdrawn the FAQ and revised their internal performance indicator guidance in
accordance with Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment
Performance Indicator Guideline, Rev. 2.
The inspectors reviewed the procedure Emergency Preparedness Performance
Indicators (EPDP-03), Rev. 9 and concluded that the corrective actions addressed the
issue. The inspectors determined based on a review of a sample of the 2002
performance indicator (PI) data that the actual guidance was not utilized to accept
greater than 15 minute classifications. Therefore, the data submitted to the NRC was
unchanged and no violation of NRC requirements was identified.
.2 Safety System Functional Failures
a. Inspection Scope
The inspectors reviewed the PI data for safety system functional failures to determine
whether NEI 99-02 was properly implemented. The inspectors reviewed the data
collected, PI definitions, and 10 CFR 50.73 requirements described in detail in NUREG
1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, Rev. 2. The inspectors
verified the accuracy of the reported data through reviews of the Licensee Event
Reports submitted during the period of September 2001 to August 2002.
b. Findings
No findings of significance were identified.
24
.3 Reactor Coolant System Activity
a. Inspection Scope
The inspectors reviewed the PI data for reactor coolant system activity to determine
whether NEI 99-02 was properly implemented during the period of June 2001 to June
2002. The inspectors verified the calculations and observed the reactor coolant system
sample and analysis using CS0910.01 and CX0901.02 (See Section 1R22). The
inspectors reviewed the following documents in the evaluation of the PI data:
C UFSAR Section 1.8 Conformance to NRC Regulatory Guides;
C Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases
of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50,
Appendix I, Rev. 1;
C JD0999.910, Reporting Key Performance Indicators Per NEI 99-02, Rev. 0;
C RCS sample results given in iodine 131 to 135 and as dose equivalent iodine;
C TS 3.4.8, Specific Activity
b. Findings
No findings of significance were identified.
.4 Reactor Coolant System Leakage
a. Inspection Scope
The inspectors reviewed the PI data for reactor coolant system leakage to determine
whether NEI 99-02 was properly implemented during the period of June 2001 to June
2002. The inspectors reviewed a sample (April, May, and June data) of the data used to
determine the maximum monthly leakage. The inspectors reviewed and observed
operator use of procedure OX1401.02, RCS Steady State Leak Rate Calculation,
Rev. 6. The inspectors also reviewed the RCS leakage TS requirements and verified
the PI calculation.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Processing and Shipping of Radioactive Material
a. Inspection Scope
The inspectors reviewed Nuclear Oversight Department (Quality Assurance)
audits/surveillance reports, and Health Physics Department self-assessments relating to
the radioactive waste handling, processing, storage, and shipping programs, including
the Process Control Plan. The inspectors also reviewed twenty (20) Condition Reports
(CRs) related to the control of radioactive material initiated between January 2001 and
25
August 2002 to evaluated Seabrooks threshold for identifying, evaluating, and resolving
problems in implementing these programs. This review was conducted against the
criteria contained in 10 CFR Parts 20 and 71.101. The following documents were
reviewed:
QUALITY ASSURANCE SURVEILLANCE REPORTS/AUDITS:
C QASR 01-0171 Assessment of Mixed Waste
C QASR 02-0019 Assessment of Radiological Waste Services move of a
High Integrity Container to a Transfer Cask
C QASR 02-0095 Health Physics Activities during OR08
C Audit No. 00-A07-01 Radwaste/Process Control Program
C Audit No. 98-A07-01 Radwaste/Process Control Program
HEALTH PHYSICS DEPARTMENT SELF-ASSESSMENTS:
C SA 01-0045 Processing of Green-Is-Clean Trash
C SA 02-0074 HP/Radwaste Biannual Condition Report Trend Analysis
b. Findings
No findings of significance were identified.
.2 October 2001 Reactor Trip due to Control Rod Drop - Problem Identification and
Resolution Sample
a. Inspection Scope
The reactor trip and past issues leading to the trip were discussed in NRC Inspection
Reports 50-443/01-010,01-011, and 02-03. The inspectors had previously reviewed the
root cause and corrective actions identified in the CR 01-10868. During this review, the
inspectors examined the additional corrective actions completed under CR 01-12250.
The inspectors verified that remote inspections of the control rod drive mechanisms
were conducted, reviewed the videotape, and interviewed the engineers that conducted
the examination. Additionally, the inspectors independently reviewed chemistry
sampling data to determine if any trend was identified to further substantiate the root
cause of the reactor trip.
b. Findings
No findings of significance were identified.
26
.3 Emergency Diesel Generators - Hot Connections
The inspectors identified a finding related to inadequate corrective actions and extent of
condition reviews. The finding is documented in Section 1R22.
4OA3 Event Follow-Up
.1 Reactive Load Fluctuation on the B Emergency Diesel Generator
a. Inspection Scope
On July 24, Seabrook experienced reactive load fluctuation on the B EDG during
normal monthly surveillance testing. Operators declared the EDG inoperable. The
inspectors observed troubleshooting activities through: 1) attendance at various
planning meeting; 2) interviews with engineers and maintenance technicians; 3)
walkdowns of the EDG system; and 4) observations of several EDG maintenance runs.
The overall evaluation of the event was completed by a special inspection team and
documented in NRC Inspection Report 50-443/02-010.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
.1 License Transfer
On October 25, 2002, the NRC approved the transfer of the operating licensee for
Seabrook Station from North Atlantic Energy Service Corporation to FPL Energy
Seabrook, LLC. On November 1, the transfer was completed. Although this inspection
was performed while North Atlantic Energy Service Corporation was the license holder,
this report was issued and addressed to the new licensee holder, FPL Energy Seabrook,
LLC.
4OA6 Meetings, including Exit
.1 Exit Meeting Summary
The inspectors presented the inspection results to Mr. J. Vargas on October 7, 2002,
following the conclusion of the period. The licensee acknowledged the findings
presented. The licensee did not indicate that any of the information presented at the
exit meeting was proprietary.
.2 Site Management Visit
On September 26 and 27, Mr. Hubert Miller, Regional Administrator, Region I and
Mr. R. Crlenjak, Deputy Division Director, Division of Reactor Safety, toured the site and
met with Mr. Ted Feigenbaum and other members of Seabrooks management.
27
Mr. Brian McDermott, Branch Chief, Division of Reactor Projects, Branch 6 visited the
site September 24 to 27 and accompanied Mr. Miller and Mr. Crlenjak.
On July 22 to 24, Mr. Douglas Starkey, Project Manager, Nuclear Reactor Regulation
toured the site and met with members of the Seabrooks staff.
4OA7 Licensee Identified Violations
The following violation of very low significance (Green) was identified by the licensee
and is a violation of NRC requirements which meets the criteria of Section VI of the NRC
Enforcement Policy, NUREG-1600, for being dispositioned as NCV.
- 10 CFR 73.55(b)(1)(i) requires all licensees to maintain safeguards in accordance
with Commission regulations and the licensees security plan. Section 10.1 of the
Seabrook Physical Security Plan, Revision 29, dated December 18, 2001, states that
armed responders will be immediately available for response. On June 14, 2002, an
armed responder was inattentive to duty, as described in the licensees corrective
action program Condition Report 02-10104. Though this matter involved a
vulnerability of Safeguards Systems or Plans, in this case no actual intrusion
occurred, and there have not been greater than two similar findings in the last four
quarters. Accordingly, this matter is being treated as a non-cited violation.
ATTACHMENT 1
SUPPLEMENTAL INFORMATION
a. Key Points of Contact
Licensee:
B. Plummer, Operations Manager
T. Nichols, Technical Support Manager
D. Sherwin, Maintenance Manager
J. Pandolfo, Security Manager
R. Hickok, NRC Coordinator
M. OKeefe, Regulatory Compliance Supervisor
C. Berry, Corrective Action/Human Performance Program Manager
M. Bianco, Radwaste Supervisor
W. Cash, Health Physics Department Manager
F. Hannify, Radwaste Technical Supervisor
W. Leland, Chemistry/Health Physics Group Manager
E. Metcalf, Plant Engineering Assistant Manager
J. More, Nuclear Systems Operator
R. Thurlow, Health Physics Technical Supervisor
D. Robinson, Chemistry Supervisor
T. Smith, Rad Technical Specialist (Training)
A. Stall, President Nuclear Production, Florida Power and Light
G. St. Pierre, Station Director
E. Moore, Security Supervisor
J. Peschel, Manager, Regulatory Programs
J. Sobotka, Manager, Oversight
P. Ryan, Supervisor, Security Operations
b. Items Opened, Closed, and Discussed
Opened and Closed:
50-443/02-05-01 NCV Inadequate corrective actions and extent of condition
reviews for two hot connections found in the EDG control
panel (Section 1R22).
50-443/02-05-02 NCV Failure to maintain safeguards in accordance with 10 CFR
73.55(b.1.i) and the licensees security plan (Section
3PP3).
Closed:
50-443/01-08-03 URI Emergency Preparedness Performance Indication -
Evaluating Exceeding the 15 Minutes for Classifications
(Section 4OA1.1)
Attachment 1 (Cont.)
c. List of Acronyms
ADAMS Agencywide Documents Access and Management System
CR Condition Report
DCN Design Change Notice
DCR Design Change Request
DG Diesel Generator
EDG Emergency Diesel Generator
EPS Emergency Power Sequencer
FAQ Frequently Asked Question
MR Maintenance Rule
NEI Nuclear Energy Institute
PARS Publicly Available Records
PCP Process Control Plan
PI Performance Indicator
PMT Post-maintenance Testing
SDP Significance Determination Process
SSC Structure, System, and Component
TS Technical Specifications
UFSAR Updated Final Safety Analysis Report
d. Partial List of Documents Reviewed
PROCEDURES:
ES0825.01, Rev. 0 Abandoned and Infrequently Used Equipment
RP 13.1, Rev. 18 Radiological Controls for Material
WN0598.072, Rev. 3 Shipment of Radioactive Material
HD0958.32, Rev. 14 Release of Material From Radiological Controls
HD0963.41, Rev. 8 Calibration of Nuclear Enterprises SAM-9
CP 5.1, Rev. 15 Isotopic Characterization of Radwaste
CS0918.02, Rev. 5 Radwaste Analysis Methods
WD0598.069, Rev. 0 Storage of Radioactive Material/Waste Controlled by the Waste
Services Department
HD0958.38, Rev. 23 Evaluation of Isotopic Mix
SELF-ASSESSMENTS:
SA 01-0045 Processing of Green-Is-Clean Trash
SA 02-0074 HP/Radwaste Biannual Condition Report Trend Analysis
QUALITY ASSURANCE SURVEILLANCE REPORTS/AUDITS:
QASR 01-0171 Assessment of Mixed Waste
QASR 02-0019 Assessment of Radiological Waste Services move of a High
Integrity Container to a Transfer Cask
QASR 02-0095 Health Physics Activities during OR08
Audit No. 00-A07-01 Radwaste/Process Control Program
Audit No. 98-A07-01 Radwaste/Process Control Program
Attachment 1 (Cont.)
CONDITION REPORTS:
02-11981, 02-11875, 02-11874, 02-11873, 02-11797, 02-11796, 02-11627, 02-11616,
02-09445, 02-08226, 02-06973, 02-05600, 02-02716, 02-01917, 01-12722, 02-01135,
01-12423, 01-11716, 01-01973, 01-01588,
02-05891, April 30, 2002, NRC perceived inattentive to duty
02-10104, June 14, 2002, Security Officer inattentive to duty
02-10541, June 25, 2002, Explore negative trend in Security Officers being inattentive to
duty
02-11729, July 25, 2002, Security Officer inattentive to duty
SHIPPING MANIFESTS:
Ship No.01-006, Dewatered Filter Cartridges, 98 Ci, LSA II, Class C
Ship No.01-009, Dewatered Resin, 41 Ci, LSA II, Class B
Ship No.02-003, Dewatered Resin, 35 Ci, LSA II, Class B
Ship No.02-010, Dewatered Resin, 36 Ci, LSA II, Class B
Ship No.02-036, Dewatered Filter Cartridges, 39 Ci, LSA II, Class C
HEALTH PHYSICS STUDY/TECHNICAL INFORMATION DOCUMENT:
HPSTID 93-008 Radiological and Safety Evaluation for Storage of Spent Resin in
Water in the Waste Processing Building
HPSTID 91-003 Use of the Nuclear Enterprise Small Article Monitor for
Determining Compliance with Seabrook Station Contamination
Release Limits
HPSTID 90-005 NEA Small Article Monitor Evaluation and Set-Up
OTHER:
Change Management Plan - Waste Liquid Processing Vendor System Replacement
Engineering Evaluation EE-02-001, Rev. 0 - Comparison of the Duratek and Nukem
Liquid Processing Systems
Process Control Plan, Rev. 31
Radwaste Training Qualification Matrix
Seabrook Station Physical Security Plan, Rev. 29, December 18, 2001
Seabrook Station Contingency Plan, Revision 13, January 11, 2002
SECURITY DOCUMENTS:
Safeguards Event Reports for the last three quarters of 2002
Seabrook Station Contingency Plan
Seabrook Station Physical Security Plan
Drill and Exercise documentation for first three quarters of 2002