IR 05000443/2012004

IR 05000443-12-004; 07/01/2012 - 09/30/2012; Seabrook Station, Unit No. 1; Mitigating System, Emergency Preparedness, Occupational Radiation Safety

ML12319A399
Person / Time
Site:	Seabrook
Issue date:	11/14/2012
From:	Arthur Burritt Reactor Projects Branch 3
To:	Walsh K NextEra Energy Seabrook
BURRITT, AL
References
IR-12-004
Download: ML12319A399 (43)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ber 14, 2012

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2012004

Dear Mr. Walsh:

On September 30, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. The enclosed inspection report documents the inspection results which were discussed on October 3, 2012 with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one self-revealing and two NRC-identified findings of very low safety significance (Green). These findings were determined to involve violations of NRC requirements. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance, and because it was entered into your corrective action program (CAP), the NRC is treating the finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRCs Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Seabrook Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Seabrook Station.

In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.htmL (the Public Electronic Reading Room).

Sincerely, /RA by Leonard Cline Acting for/ Arthur L. Burritt, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86

Enclosure:

Inspection Report No. 05000443/2012004 w/ Attachment: Supplemental Information

REGION I== Docket No.: 50-443 License No.: NPF-86 Report No.: 05000443/2012004 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No.1 Location: Seabrook, New Hampshire 03874 Dates: July 1, 2012 to September 30, 2012 Inspectors: J. Greives, Acting Senior Resident Inspector W. Raymond, Senior Resident Inspector K. Dunham, Acting Resident Inspector M. Jennerich, Resident Inspector J. Noggle, Sr. Health Physicist T. Burns, Reactor Inspector J. Furia, Sr. Health Physicist P. Cataldo, Senior Resident Inspector Approved by: Arthur Burritt, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000443/2012004; 07/01/2012 - 09/30/2012; Seabrook Station, Unit No. 1; Mitigating

System, Emergency Preparedness, Occupational Radiation Safety.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three non-cited violations (NCVs) of very low safety significance (Green). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within Cross-Cutting Areas. 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 4, dated December 2006.

Cornerstone: Mitigating System

Green.

The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion V, Procedures, because NextEra did not ensure that adequate separation was maintained between temporary scaffolding and safety-related equipment. Specifically, the inspectors identified numerous scaffolds installed in the plant with less than the minimum standoff distance to safety-related equipment specified in NextEra procedures and no engineering evaluation to support the deviation. NextEra entered this NCV into their CAP as CR 1804255.

This performance deficiency was considered more than minor because it affected the protection against external factors attribute of the Mitigating Systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, NextEra routinely did not evaluate scaffold installations when insufficient separation to safety-related equipment was provided. Additionally, it was similar to example 4.a in IMC 0612, Appendix E, Examples of Minor Issues, which states that the issue of failing to appropriately evaluate scaffold installation as required by procedures is more than minor if the licensee routinely failed to perform engineering evaluations. The issue was evaluated in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power and determined to be of very low safety significance (Green) since it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event. This finding is related to the cross-cutting area of Human Performance - Work Practices because NextEra personnel did not follow scaffold installation procedures when they routinely installed scaffold within one-half inch of safety-related equipment without an engineering evaluation. [H.4.(b)]. (Section 1R20)

Cornerstone: Emergency Preparedness

Green.

A self-revealing NCV of 10 CFR 50.47(b)(5) and the requirements of Section lV.D.3 of Appendix E to 10 CFR 50 was identified on June 13, 2012, because NextEra did not notify the state of Massachusetts within 15 minutes of declaring an emergency at the Seabrook Station. Specifically, the inspectors determined that NextEra did not maintain the sites off-site notification process in a manner that ensured that the RSPS function described by 10 CFR 50.47(b)(5) could be met with the multiple equipment malfunctions that occurred between June 12 and June 14, 2012. The issue was entered into NextEras corrective action program as CR 1775909.

The performance deficiency was considered more than minor because it was associated with the Emergency Preparedness (EP) cornerstone attributes of Procedure Quality and Facilities and Equipment, and affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, EP equipment was not treated as equipment important to safety and thus marginal equipment performance with regard to the NAS was tolerated, and the notification process implementing procedure was cumbersome such that it did ensure timely notification when presented with equipment failures. The inspectors assessed the issue, related to the notification process, using the Emergency Preparedness Significance Determination Process (Appendix B to IMC 0609) and determined the finding to be of very low safety significance (Green). This finding is related to the cross-cutting area of Problem Identification and Resolution - CAP because NextEra did not consistently enter issues with communications equipment necessary for EP purposes into the stations CAP such that immediate corrective actions could be taken to ensure the RSPS function was met [P.1(a)] (Section 1EP6)

Cornerstone: Occupational Radiation Safety

Green.

Inspectors identified an NCV of Technical Specification (TS) 6.7.1.a, Procedures and Programs, which requires that written procedures be established and implemented, to include administrative procedures, which includes radiation protection procedures.

Specifically, procedure HD 0965.10, Respirator Fit Testing Using TSI Portacount Plus, Revision 10, did not specify a calibration frequency requirement for the respirator fit test equipment. The equipment vendor recommended annual calibration frequency, which was exceeded by over two years, and the current as-found condition of the specified equipment when tested was found out of calibration. This issue was entered into NextEras CAP as CR 1785134.

This performance deficiency was determined to be more than minor, because it was associated with program and process attribute of the Occupational Radiation Safety cornerstone and affected its objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the respirator fit testing was being used to certify respirator protection factors of workers which were relied upon to provide protection of workers due to airborne radioactivity during the previous refueling outage. Additionally, it was similar to example 6.b in IMC 0612, Appendix E, Examples of Minor Issues, which states that failing to calibrate radiation instruments was more than minor if the as-found condition was not within the acceptance criteria for the calibration and did not provide a conservative measurement. The issue was evaluated using IMC 0609, Significance Determination Process (SDP), and was determined to be of very low safety significance.

Specifically, when evaluated with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the performance deficiency was not an ALARA issue, did not involve an overexposure or a potential overexposure, and did not impact NextEras ability to assess dose. The inspectors determined that this finding had a cross-cutting aspect in the area of Problem Identification and Resolution - CAP because NextEra did not identify that vendor recommended calibration requirements had not been met or evaluated when this equipment was returned by the vendor for routine cleaning. [P.1(a)] (Section 2RS3)

Other Findings

A violation of very low safety significance identified by NextEra was reviewed by the inspectors.

Corrective actions taken or planned by NextEra have been entered into their CAP. This violation and corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Seabrook operated at 85% power at the start of the period and experienced a reactor trip on September 14, 2012, following a failure of the C main feedwater regulating valve controller.

Following the reactor trip, Unit 1 remained shutdown for a planned refueling outage.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors performed a review of NextEras readiness for heavy rains and high winds on September 18, 2012. The review focused on site housekeeping and its potential impact on off-site power and the supplemental emergency power system (SEPS) diesel generators. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications, the shutdown risk profile, and the CAP to determine what systems were most risk significant given plant conditions, and to ensure NextEra personnel had adequately prepared for any potential challenges due to adverse weather. The inspectors reviewed station procedures, including NextEras severe weather procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during adverse weather conditions.

Documents reviewed for each section of this inspection report are listed in the .

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Diesel generator (DG) train B during planned maintenance activities on DG train A on July 05, 2012 Residual heat removal (RHR) train A during planned maintenance activities on RHR train B on July 11, 2012 Spent fuel pool cooling during full core offload on September 26, 2012 The inspectors selected these systems based on their risk-significance for the current plant configuration or following realignment. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.

b. Findings

No findings were identified. ==1R05 Fire Protection