ML18330A081
| ML18330A081 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/14/2018 |
| From: | NRC |
| To: | |
| References | |
| 17-953-02-LA-BD01 | |
| Download: ML18330A081 (17) | |
See also: IR 05000443/2018003
Text
SeabrookLANPEm Resource
From: R1DRSMAIL RESOURCE
Sent: Wednesday, November 14, 2018 7:55 AM
To: Poole, Justin
Subject: SEABROOK STATION, UNIT NO. 1: INTEGRATED INSPECTION REPORT
Attachments: SB IR18003_FINAL .pdf
SEABROOK STATION, UNIT NO. 1: INTEGRATED INSPECTION REPORT 05000443/2018003
ADAMS ACCESSION NO. ML18318A009
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Subject: SEABROOK STATION, UNIT NO. 1: INTEGRATED INSPECTION REPORT
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BOULEVARD, SUITE 100
KING OF PRUSSIA, PA 19406-2713
November 13, 2018
Mr. Mano Nazar
President and Chief Nuclear Officer
Nuclear Division
NextEra Energy Seabrook, LLC
Mail Stop: EX/JB
700 Universe Blvd.
Juno Beach, FL 33408
SUBJECT: SEABROOK STATION, UNIT NO. 1 - INTEGRATED INSPECTION REPORT
Dear Mr. Nazar:
On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Seabrook Station, Unit No. 1 (Seabrook). On October 25, 2018, the NRC
inspectors discussed the results of this inspection with Mr. Eric McCartney, Vice President -
Northern Region and other members of your staff. The results of this inspection are
documented in the enclosed report.
NRC inspectors documented one Severity Level IV violation with no associated finding in this
report. The NRC is treating the violation as a non-cited violation (NCV) consistent with
Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the NCV, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC
Resident Inspector at Seabrook.
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room
in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Fred L. Bower, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Docket No. 50-443
License No. NPF-86
Enclosure:
Inspection Report 05000443/2008003
cc w/encl: Distribution via ListServ
- SUNSI Review ; Non-Sensitive ; Publicly Available
Sensitive Non-Publicly Available
OFFICE RI/DRP RI/DRP RI/DRP
NAME PCataldo/SE SElkhiamy FBower
DATE 11/13/2018 11/13/2018 11/13/2018
1
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 50-443
License Number: NPF-86
Report Number: 05000443/2018003
Enterprise Identifier: I-2018-003-0067
Licensee: NextEra Energy Seabrook, LLC (NextEra)
Facility: Seabrook Station, Unit No. 1 (Seabrook)
Location: Seabrook, NH
Inspection Dates: July 1, 2018 to September 30, 2018
Inspectors: P. Cataldo, Senior Resident Inspector
P. Meier, Resident Inspector
E. Burket, Reactor Inspector
J. Furia, Senior Health Physicist
N. Floyd, Senior Reactor Inspector
Approved By: Fred Bower, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Enclosure
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring NextEras performance
at Seabrook by conducting the baseline inspections described in this report in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. A self-revealing
finding is summarized in the table below.
List of Findings and Violations
Pressurizer Safety Valve Outside of Technical Specification Limits
Cornerstone Severity Cross-Cutting Inspection
Aspect Results
Section
Not Applicable Severity Level (SL) IV Not Applicable 71153
NCV 05000443/2018003-01 Follow-up of
Opened/Closed Events and
Notices of
Enforcement
Discretion
A self-revealing SL IV non-cited violation of Technical Specification (TS) 3.4.2.2, All
pressurizer code safety valves shall be OPERABLE with a lift setting of 2485 psig +/- 3%, was
identified when one of the pressurizer code safety valves failed as-found set point testing.
Specifically, it was determined that the safety valve had a high as-found set point pressure
after the valve was removed from service during the previous refueling outage in April, 2017
(OR18) and the inoperable condition existed for a period of time longer than the allowed TS
ACTION time.
Additional Tracking Items
Type Issue number Title Inspection Status
Report
Section
LER 05000443/2018-001-00 Pressurizer Safety Valve 71153 Closed
Outside of Technical
Specification Limits
Discovered During As-Found
Set Point Testing
3
PLANT STATUS
Seabrook Station began the inspection period operating at 100 percent rated thermal power and
on September 30, 2018, operators commenced a shutdown, from 93 percent power, for planned
refueling and maintenance outage 19 (RFO19) that commenced on October 1, 2018.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures in effect
at the beginning of the inspection unless otherwise noted. Currently approved inspection
procedures with their attached revision histories are located on the public website at
http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the inspection procedure requirements most
appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed
plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine
reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed
selected procedures and records, observed activities, and interviewed personnel to assess
NextEras performance and compliance with Commission rules and regulations, license
conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather (1 Sample)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the
sustained high temperatures during the week of July 2nd.
71111.04 - Equipment Alignment
Partial Walkdown (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) A emergency diesel generator return-to-service on July 9
(2) B service water system during planned maintenance on the A service water system on
August 16
(3) A residual heat removal system before a B residual heat removal pump and valve
surveillance on August 28
(4) A service water and cooling water systems before a B cooling water tower pump
surveillance on August 30
4
71111.05AQ - Fire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) A essential switchgear (CB-F-1A-A) on September 13
(2) Turbine building ground floor (TB-F-1A-Z, TB-F-1-0) on September 13
(3) B residual heat removal vault, all levels (RHR-F-4A-Z) on September 17
(4) B residual heat removal vault, all levels (RHR-F-1A-Z, RHR-F-2A-Z, RHR-F-3A-Z,
RHR-F-1C-Z) on September 17
(5) Fire pump rooms (FPH-F-1A-A, FPH-F-1B-A, FPH-F-1C-A) on September 19
71111.06 - Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the primary auxiliary
building, 25' elevation, on September 13.
71111.07 - Heat Sink Performance (1 Sample)
The inspectors evaluated NextEras monitoring and maintenance of B emergency diesel
generator heat exchanger thermal performance test.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated requalification training in the simulator on August 27.
This training involved lessons learned from previous steam generator level control issues, most
notably the level control issues that resulted in the April 2017 reactor trip.
Operator Performance (1 Sample)
The inspectors observed and evaluated activities associated with the following licensed
operator performance in the control room:
(1) Alarm response and various instrumentation and control maintenance activities on July 19
(2) Various alarm response to ongoing maintenance, and coordination with fire protection
for entry into technical requirements manual due to fire door inoperability on August 29
(3) Alarm response and the swap from ocean service water to the cooling water tower in
preparation for the cooling water tower pump surveillance on August 30
(4) Fast start surveillance of the A emergency diesel generator, deboration of reactor
coolant system to maintain power, and control room maintenance activities associated
with instrumentation and control equipment on September 10
(5) Shutdown activities and entry into refueling outage 19 on September 30
5
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Atmospheric steam dump valve maintenance to address nitrogen leaks, in August and
September 2018.
(2) Troubleshooting activities associated with recurrent electrical grounds on the electrical
distribution system, which have occurred throughout the operating cycle.
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Risk associated with battery charger C testing, vital inverter 1E issues, and A cooling
water tower valve maintenance and surveillance from July 10-17
(2) Emergent work and risk associated with ground on busses supplied by vital inverter 1E
(A train) during a B train work week from August 6-9
(3) Risk associated with A service water system inoperability for planned valve
maintenance on August 16
(4) Risk associated with the supplemental emergency power supply planned maintenance
outage from August 20-23
(5) Risk associated with aligning for the B cooling water tower system from the B service
water system on August 30
71111.15 - Operability Determinations and Functionality Assessments (4 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Unit auxiliary transformer 2A liquid flow loss (AR2272500) on July 5
(2) Vital inverter 1E issues (AR2281601) on July 10
(3) Containment enclosure emergency exhaust switch low flow alarm (AR2272500) on
July 18
(4) Structural evaluation of the mechanical penetration area north and south wall on
September 13
71111.17T - Evaluations of Changes, Tests and Experiments (25 Samples)
The inspectors evaluated the following from June 18, 2018 to August 17, 2018:
10 CFR 50.59 Evaluations
(1) Eval 15-002, SSPS Circuit Board Replacement, dated 3/9/15
(2) Eval 15-003, EC 282582, New Service Water Pump House Barrier 1 Missile Barrier,
Revision 1
(3) Eval 15-004, Seabrook Cycle 18 Reload, dated 9/18/15
6
(4) Eval 16-002, Temporary Jumper Across 1-EDE-B-1-A Cell #43, dated 11/4/16
(5) Eval 16-004, Change to OS1023.10, Service Water Pump House Ventilation System
Operation, to Allow Manual Control of the Pump House Ventilation System,
Revision 0
(6) Eval 18-001, Containment Model Update for NSAL-11-5 and NSAL-14-2, dated 3/12/18
10 CFR 50.59 Screening/Applicability Determinations
(1) BC16-01, Correct DNBR Value in TS 3/4.4.1 RCS Bases Section, dated 1/17/17
(2) EC 283978, Risk Informed Frequency Change for DG-ESFAS Integrated Test, dated
8/20/15
(3) EC 284280, Increase in RCS Loop Tavg to Average Tavg Deviation Alarm Setpoint,
dated 9/15/15
(4) EC 287106, Condensate Storage Tank Approaching Level Low, dated 10/20/16
(5) EC 287319, 345 kV SF6 Bus 1 Upgrade and GS11 Removal, dated 9/18/16
(6) EC 288116, Replace SW-P-41-A Motor with Rewound Motor, dated 5/18/17
(7) EC 288964, SW Pump Motor Current Instantaneous Trip Setpoint Increase, dated
10/17/17
(8) EC 289531, Permanent Installation of Seismic Temporary Structures, dated 10/19/17
(9) EC 289886, Update UFSAR Section 9.4 for CBA Heat Load, dated 10/5/17
(10) EC 290437, RC-V-23 MOV Motor Replacement, dated 2/20/18
(11) EC 290933, P-9 Setpoint Revision in Support of EOC Cycle 19 Coastdown, dated
4/6/18
(12) PCR 1903625, Reserve Auxiliary Transformer Auxiliaries Operation, dated 5/26/16
(13) PCR 2036771, Operability Testing of IST Valves, dated 4/1/15
(14) PCR 2053030, Diesel Generator 1B 18 Month Operability Surveillance, dated 6/9/15
(15) PCR 2072219, Loop 1 Delta T/Tavg 7300 NTC Card Relay Testing, dated 2/18/16
(16) PCR 2075330, Power Increase, dated 9/24/15
(17) PCR 2178140, Operation at Power, dated 1/5/17
(18) PCR 2208297, SW-P-110 Pump Head Curve Verification, dated 7/12/17
(19) PCR 2252508, Response to Natural Phenomena Affecting Plant Operations, dated
3/6/18
71111.18 - Plant Modifications (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) Modification of service water pipe support (EC 286395) in July
71111.19 - Post Maintenance Testing (5 Samples)
The inspectors evaluated post maintenance testing for the following maintenance/repair
activities:
(1) Cooling water tower spray bypass valve SW-V-139 maintenance on July 12
(2) B vital DC battery replacement from July 22 through August 7
(3) Leading edge flow meter calibration and repair on August 10
(4) Supplemental emergency power supply maintenance from August 20-23
(5) A atmospheric steam dump valve maintenance on August 31
7
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) C vital battery charger capacity test from July 10-16
(2) Refueling water storage tank trip actuating device operability test on July 16
(3) Moderator temperature coefficient surveillance on July 17
In-service (1 Sample)
(1) A service water isolation valve to secondary loads, SW-V-4, following thermal overload
replacement on August 16
RADIATION SAFETY
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation
Radioactive Material Storage (1 sample)
The inspectors observed radioactive waste container storage areas and verified the postings
and controls and that NextEra had established a process for monitoring the impact of long-
term storage of the waste.
Radioactive Waste System Walkdown (1 sample)
The inspectors walked down: accessible portions of liquid and solid radioactive waste
processing systems; abandoned-in-place radioactive waste processing equipment; and,
current methods and procedures for dewatering waste.
Waste Characterization and Classification (1 sample)
The inspectors identified radioactive waste streams and reviewed radio-chemical sample
analysis results to support radioactive waste characterization. The inspectors reviewed the
use of scaling factors and calculations to account for difficult-to-measure radionuclides.
Shipment Preparation (1 sample)
The inspectors reviewed the records of shipment packaging, surveying, labeling, marking,
placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers
provided to the driver, and NextEra verification of shipment readiness.
Shipping Records (1 sample)
The inspectors reviewed selected non-excepted package shipment records.
8
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification (3 Samples)
The inspectors verified NextEras performance indicators submittals listed below for the
period from July 1, 2017 through June 30, 2018:
(1) Emergency AC power systems
(2) High pressure injection systems
(3) Heat removal systems
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (2 Samples)
The inspectors reviewed the NextEras implementation of its corrective action program
related to the following issues:
(1) Various issues related to the meteorological tower
(2) Review of alkali-silica reaction impact on concrete structures
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
(1) LER 05000443/2018-001-00, Pressurizer Safety Valve Outside of Technical
Specification Limits Discovered During As-Found Set Point Testing (ADAMS accession:
ML18095A683). The circumstances surrounding this licensee event report are
documented in report section Inspection Results.
INSPECTION RESULTS
Observation 71152(1) Annual Follow-
up of Selected Issues
The inspectors selected for follow-up, a negative trend of issues related to the meteorological
tower (MET Tower) since it is important for emergency planning dose assessment and used to
implement protective action recommendations. Specifically, NextEra identified decreasing
availability and reliability of the MET tower at the beginning of 2018. Despite the negative
trend, the redundancy incorporated into the design and the availability of the back-up MET
tower ensured that the emergency plan could be implemented throughout the time it took to
address the concerns.
The inspectors noted that the decreasing trend began following upgrades to the MET tower
components in 2014. The most evident recurring issues were related to temperature
fluctuations and reliability. Upon further investigation, NextEra determined loose junction box
connections were a significant contributor. In addition, based on vendor recommendations,
certain preventative maintenance practices were improved. These two corrective actions
increased the towers reliability with respect to temperature indications.
9
In the winter of 2017 and 2018, NextEra noted that the wind vane, which is used to determine
the wind direction, stopped working following significant storms. The wind speed indicator also
stopped working following a more recent winter storm in 2018. Each time NextEra promptly
repaired the components, however, NextEra recognized this negative trend, as these
components are designed for significant winter storms. The inspectors noted that measures to
investigate and to prevent the issues from recurring are ongoing. Although the exact causes
remain to be determined, NextEra is working with the MET tower vendor to ensure the quality
control of the replacement parts are as expected.
Preventive maintenance is performed every 6 months and includes calibrations, inspections,
and parts replacement as required. In addition, routine checks and calibrations are performed
on a bi-weekly and the control room operators monitor the MET tower indications each shift.
The inspectors concluded that NextEra properly identified and evaluated issues found by these
regular checks in accordance with the stations corrective action program. The inspectors
assessed that corrective actions to fix issues with the MET tower are performed in a timely
manner commensurate with the safety significance of the issue and no issues of concern with
problem identification and resolution were identified.
Observation 71152(2) Annual Follow-up
of Selected Issues
The NRC performed a periodic site visit to Seabrook Station to review NextEras monitoring of
alkali-silica reaction (ASR) on affected reinforced concrete structures, per their 10 CFR 50.65
Maintenance Rule Structures Monitoring Program and corrective action program. The
inspectors verified on a sampling basis that significant changes, if any or different
presentations of ASR on the affected structures were appropriately considered for impact on
the applicable Seabrook prompt operability determinations. In addition, the inspectors
performed independent walkdowns of ASR-affected areas and reviewed reports of recently
collected measurement data, including combined crack index, in-plane expansion, through-
wall expansion, and building deformation monitoring elements, to verify that the structures
were within the established, acceptable monitoring parameters.
NextEra staff continued to complete structural calculations to evaluate the future impact of
ASR on the reinforced concrete structures in accordance with the structures monitoring
program. The Mechanical Penetration Area North and South exterior walls were identified to
not qualify in accordance with ACI 318-71 structural design code when predicted ASR loading
was applied using NextEras methodology document. The methodology for evaluating
ASR-affected concrete is currently under review by the NRC staff, as part of the August 1,
2016, License Amendment Request (16-03). The remainder of the structure met the structural
design code with predicted ASR loading applied. The Mechanical Penetration Area houses
various safety-related systems and components, including piping and valves between the
containment structure and surrounding buildings. NextEra staff wrote a condition report to
address the non-conformance of the Mechanical Penetration Area, which included a separate
prompt operability determination.
The inspectors performed a review of the prompt operability determination and corrective
actions for the Mechanical Penetration Area. The inspectors also performed an independent
walkdown of the structure and did not observe any indications of loading distress or other
structural integrity issues as evident by the absence of structural flexure cracks. The
inspectors noted areas where lateral displacement of the North and South exterior walls, due
to ASR expansion in the concrete backfill, caused some distortion of platform and steel
10
walkways and verified that adjacent equipment was not impacted. NextEra staff planned to
perform more frequent inspections of the Mechanical Penetration Area North and South walls
to monitor lateral displacement. Based on discussions with NextEra staff, the inspectors noted
that a planned modification is being developed as a long-term corrective action to restore
compliance with the design code and Seabrooks methodology document. The inspectors
determined that NextEras conclusions that the structure is capable of performing its intended
functions was technically supported.
During review of the prompt operability determination for the Mechanical Penetration North
and South exterior walls, the NRC inspectors identified that the document contained incorrect
information for maintaining the operability of the structure. Specifically, the established
threshold monitoring limits for lateral displacement of the north and south walls was incorrect.
The operability determination stated an increase of 50 percent above baseline measurements
was acceptable; however, the associated structural evaluation supported a limit of 20 percent
increase above baseline. NextEra staff generated a condition report, AR 02280269, to revise
the prompt operability determination with the correct value. The documentation error was
determined to be minor because the current deformation remains well below the acceptable
limit with margin, and the walls are being monitoring on a two-month frequency. In addition,
the inspectors noted that the contractor performing the measurements uses the limits from the
structural evaluation (i.e., 20 percent) when reporting the monitoring results, such that this
criteria would have been highlighted for evaluation.
The inspectors discussed the status of the Containment Enclosure Ventilation Area (CEVA)
modification with NextEra staff. This structure was previously identified as not conforming with
the structural design code utilizing the Seabrook methodology document (discussed in NRC
Inspection Report 05000443/2017004; ADAMS Accession Number ML18043A821). The
inspectors noted that NextEra staff completed the engineering change package that described
the planned repairs to the wall, but had not started physical implementation of the structural
modification. The inspectors reviewed the lateral displacement measurements from March
and June 2018 to verify the structure maintained its structural stability and noted there had
been no apparent changes in the displacement since the previous measurements, in October
2017.
NextEra staff completed its delamination validation study as part of preparations for the CEVA
North wall modification. The study was in response to NRC inspector questions during a
previous inspection in November 2017, to verify that delamination was only occurring in the
cover concrete (discussed in NRC Inspection Report 05000443/2017004; ADAMS Accession
Number ML18043A821). NextEra conducted a sample of concrete bore holes, exposed a
local area of rebar, and performed impact-echo testing, a non-destructive test method that
uses sound waves to detect flaws within the concrete. NextEra staff confirmed that the
delaminations on the CEVA North wall were limited to the cover concrete layer (near surface)
and were a result of loading on the wall. The inspectors discussed the results with NextEra
staff and independently observed the conditions of the core bores and rebar with no anomalies
identified.
The inspectors concluded that NextEra staff monitored reinforced concrete structures in
accordance with Seabrook procedures, the structures remained capable of performing their
safety function by meeting the established monitoring limits, and issues were appropriately
identified and evaluated in accordance with the corrective action program; therefore, no issues
of concern were identified.
11
Pressurizer Safety Valve Outside of Technical Specification Limits
Cornerstone Severity Cross-cutting Aspect Report
Section
Not Applicable Severity Level IV Not Applicable 71153
NCV 05000443/2018-003-01 Follow-up of
Closed Events and
Notices of
Enforcement
Discretion
A self-revealing Severity Level IV NCV of Technical Specifications 3.4.2.2, All pressurizer
code safety valves shall be OPERABLE with a lift setting of 2485 psig +/- 3%, was identified
when one of the pressurizer code safety valves failed as-found set point testing. Specifically,
it was determined that the safety valve had a high as-found set point pressure after the valve
was removed from service during the previous refueling outage in April, 2017 (OR18) and the
inoperable condition existed for a period of time longer than the allowed T.S. ACTION time.
Description: Seabrook Station reported the failure of a pressurizer code safety valve on
April 5, 2018 in LER 2018-001-01 (ML18095A683). The valve was tested and failed the
applicable acceptance criteria on February 6, 2018. It was installed in the plant from
October 17, 2015 until April 8, 2017. The as-found set point pressure was 6.1 percent, which
is greater than the technical specifications limiting condition for operation of 3 percent.
Pressurizer code safety valves cannot be tested on line. Therefore, they are normally
removed from service during a refueling outage and replaced with a different set of valves
that were previously tested, inspected, and adjusted in accordance with established
maintenance procedures. The removed valves are sent to a qualified offsite vendor for
completion of the technical specification surveillance testing at a later date. Although the
identical pressurizer code safety valve failed testing after removal, it is assumed the condition
existed prior to the as-found testing. Since it was installed and in service on a fully
operational plant for over a year (October 17, 2015, through April 8, 2017) it is assumed the
valve was inoperable for greater than the allowed action statement time of 15 minutes for one
inoperable pressurizer code safety valve, after which the plant must be in HOT STANDBY
within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Therefore,
TS 3.4.2.2 was violated since these actions were not completed.
Corrective Actions: NextEra performed an investigation to determine the cause of the failed
pressurizer code safety valve and excessive set point drift, however, nothing conclusive was
determined. NextEra found some spring characteristics had changed, but were still within
specifications. However, the spring was replaced with a new one. Additionally, the
corresponding valve maintenance procedure was revised to add more conservative
thresholds and evaluation criteria to determine if subsequent springs are suitable for future
service. The resident inspectors validated the procedure changes.
Corrective Action References: AR 2248447
Performance Assessment:
The inspectors determined the violation was not reasonably foreseeable and preventable by
NextEra and therefore is not a performance deficiency.
Enforcement:
12
This is a violation of technical specifications and, therefore, must be evaluated using
traditional enforcement.
Violation: Technical Specification 3.4.2.2 requires that all pressurizer code safety valves shall
be OPERABLE with a lift setting of 2485 psig +/- 3 percent in Modes 1, 2, and 3. With one
pressurizer code safety valve inoperable, either restore the inoperable valve to OPERABLE
status within 15 minutes or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least HOT
SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, from October 17, 2015, to April 8, 2017, NextEra operated in mode 1
with an inoperable pressurizer code safety valve greater than the allowed action time.
Severity: Severity Level IV
Disposition: This violation is being treated as a Non-Cited Violation, consistent with
Section 2.3.2 of the Enforcement Policy.
The disposition of this violation closes LER 05000293/2018-001-00.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
x On June 21, 2018, the inspectors presented the initial results of the IP 71111.17T inspection
to Mr. Chris Domingos, Site Director, and other members of NextEra staff.
x On July 25, 2018, the inspectors presented the updated results of the IP 71111.17T
inspection to Mr. Kenneth Brown, Licensing Manager, and other members of NextEra staff.
x On August 24, 2018, the inspectors presented the radiation safety inspection results to
Mr. Dennis Hickey, Radiation Protection Operations Supervisor, and other members of
NextEra staff.
x On September 6, 2018, the inspectors presented the final IP 71111.17T inspection results to
Mr. Kenneth Brown, Licensing Manager, and other members of NextEra staff.
x On September 13, 2018, the inspectors presented the Problem Identification and Resolution
annual sample inspection results to Mr. Eric McCartney, Vice President - Northern Region,
and other members of NextEra staff.
x On October 25, 2018, the inspectors presented the quarterly resident inspector inspection
results to Mr. Eric McCartney, Vice President - Northern Region, and other members of the
NextEra staff.
13
DOCUMENTS REVIEWED
71111.17T
Procedures
EN-AA-203-1201, 10 CFR Applicability and 10 CFR 50.59 Screening Reviews, Revision 12
EN-AA-203-1202, 10 CFR 50.59 Evaluation, Revision 1
Condition Reports
2065342 2164482 2172149 2175451 2181667 2209312
2218253 2227537 2257560 2257562 2257565 2257571
2261721 2262171
Calculations
9763-3-ED-00-14-F, Calculation of 2 Hour Loss of AC Load Profile for 58 Cell Configuration for
Battery 1-EDE-B-1-A, Revision 18
C-S-1-5003, I&C Heat Load Calculation, Revision 6
SBK-1FJF-18-150, Seabrook High Burnup AST Verification - Cycle 18 NDR and Cycle 19 NDR,
Revision 0
Engineering Evaluation
Probabilistic Evaluation of Barrier 1 Tornado Missile Barrier Gap Area at Service Water Pump
House Southeast Alcove, dated 4/18/16
Miscellaneous
MTF 17-006, Material Transfer Form for Cycle 18 Offload, dated 3/22/17
ML18158A220, Interim Guidance for Dispositioning Severity Level IV Violations with No
Associated Performance Deficiency, dated 6/15/18