IR 05000443/2023004: Difference between revisions
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No findings or violations of more than minor significance were identified during this inspection. | No findings or violations of more than minor significance were identified during this inspection. | ||
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 at 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. | 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 at 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, Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety | Sincerely, Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety | ||
| Line 74: | Line 74: | ||
==INSPECTION SCOPES== | ==INSPECTION SCOPES== | ||
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs 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. | Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs 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 IP 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on -site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. | Samples were declared complete when the IP 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on -site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. | ||
| Line 141: | Line 141: | ||
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample) | Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample) | ||
: (1) The inspectors observed and evaluated licensed operator performance in the control room during the following: | : (1) The inspectors observed and evaluated licensed operator performance in the control room during the following: | ||
* Main turbine electro- hydraulic control oil pump adjustments on November 15, 2023 | * Main turbine electro-hydraulic control oil pump adjustments on November 15, 2023 | ||
* Quartly operability tting ember 2023 | * Quartly operability tting ember 2023 | ||
| Line 279: | Line 279: | ||
The licensee performed oil analysis on all bulk oil storage and confirmed all bulk oil and found no discrepancies. The licensee discontinued the use of secondary containers for oil storage and have updated issue instructions that require all oil to be obtained only from original source bulk storage containers. Both the A residual heat removal pump motor oil and B primary component cooling water pump motor oil were drained, flushed, and replaced with Mobile DTE Medium ISO 46. | The licensee performed oil analysis on all bulk oil storage and confirmed all bulk oil and found no discrepancies. The licensee discontinued the use of secondary containers for oil storage and have updated issue instructions that require all oil to be obtained only from original source bulk storage containers. Both the A residual heat removal pump motor oil and B primary component cooling water pump motor oil were drained, flushed, and replaced with Mobile DTE Medium ISO 46. | ||
Screening: The inspectors determined the performance deficiency was minor. The performance deficiency did not adversely affect the Mitigating Systems cornerstones objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Seabrook conducted an engineering analysis and determined that the lower viscosity oil did not negatively impact the reliability of the pump motors and only posed a long- term degradation concern. | Screening: The inspectors determined the performance deficiency was minor. The performance deficiency did not adversely affect the Mitigating Systems cornerstones objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Seabrook conducted an engineering analysis and determined that the lower viscosity oil did not negatively impact the reliability of the pump motors and only posed a long-term degradation concern. | ||
=====Enforcement:===== | =====Enforcement:===== | ||
| Line 286: | Line 286: | ||
Observation: Review of Seabrooks Evaluation and Corrective Actions for 71152A Radiation Monitoring System failures The inspectors performed a review of various failures of process and area radiation monitors which have resulted in repeated out-of-service time and compensatory actions. The inspectors reviewed Seabrooks causal evaluations, implemented corrective actions, and preventive maintenance frequency. | Observation: Review of Seabrooks Evaluation and Corrective Actions for 71152A Radiation Monitoring System failures The inspectors performed a review of various failures of process and area radiation monitors which have resulted in repeated out-of-service time and compensatory actions. The inspectors reviewed Seabrooks causal evaluations, implemented corrective actions, and preventive maintenance frequency. | ||
Seabrook Stations maintenance rule program, required by 10 CFR 50.65, credits three radiation monitors; RM-6526- 1 (containment particulate), RM-6526- 2 (containment gas), and RM-6548 (backup containment gas) to meet the technical specification function to be capable of detecting a one gallon per minute increase in unidentified leakage within one hour. This maintenance rule function is monitored at a system level and has an established performance goal of less than six failures in a 24 month period. Detecting and monitoring reactor coolant system leakage into the containment area, and quickly separating the identified leakage from the unidentified leakage provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public. Seabrook Stations Technical Specification 3.4.6.1 requires instruments of diverse monitoring principles to be operable to provide confidence that small amounts of unidentified leakage are detected in time to allow actions to place the plant in a safe condition when reactor coolant system leakage indicates possible reactor coolant pressure boundary degradation. One containment atmosphere radioactivity monitor (gaseous or particulate) is required as well as the containment drainage sump level monitoring system. | Seabrook Stations maintenance rule program, required by 10 CFR 50.65, credits three radiation monitors; RM-6526-1 (containment particulate), RM-6526-2 (containment gas), and RM-6548 (backup containment gas) to meet the technical specification function to be capable of detecting a one gallon per minute increase in unidentified leakage within one hour. This maintenance rule function is monitored at a system level and has an established performance goal of less than six failures in a 24 month period. Detecting and monitoring reactor coolant system leakage into the containment area, and quickly separating the identified leakage from the unidentified leakage provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public. Seabrook Stations Technical Specification 3.4.6.1 requires instruments of diverse monitoring principles to be operable to provide confidence that small amounts of unidentified leakage are detected in time to allow actions to place the plant in a safe condition when reactor coolant system leakage indicates possible reactor coolant pressure boundary degradation. One containment atmosphere radioactivity monitor (gaseous or particulate) is required as well as the containment drainage sump level monitoring system. | ||
The inspectors noted continual failures of one or more of these containment gaseous radioactivity monitors with five failures in 2021, three in 2022, and one additional in 2023. | The inspectors noted continual failures of one or more of these containment gaseous radioactivity monitors with five failures in 2021, three in 2022, and one additional in 2023. | ||
| Line 292: | Line 292: | ||
Two of the failures in 2022 were classified as maintenance rule functional failures and were counted against the performance goals. While these failures have not exceeded the performance goals established in 10 CFR 50.65(a)(2), they have posed a burden on the operating crews. Inspectors also determined that the ability to accurately monitor unidentified leakage was not challenged during these failures because the containment drainage sump level monitoring system remained in service during these periods. Based on the performance improvement in 2023, inspectors determined that actions taken by the station have been reasonable but will continue to monitor performance of these radiation monitors. | Two of the failures in 2022 were classified as maintenance rule functional failures and were counted against the performance goals. While these failures have not exceeded the performance goals established in 10 CFR 50.65(a)(2), they have posed a burden on the operating crews. Inspectors also determined that the ability to accurately monitor unidentified leakage was not challenged during these failures because the containment drainage sump level monitoring system remained in service during these periods. Based on the performance improvement in 2023, inspectors determined that actions taken by the station have been reasonable but will continue to monitor performance of these radiation monitors. | ||
The inspectors determined that Seabrook's immediate actions to these failures have been appropriate for the circumstances and reasonable. While inspectors did not identify any cases where appropriate actions were not taken in response to a failed radiation monitor, inspectors noted that the on- shift operators have been repeatedly challenged with having to employ compensatory actions to validate normal radiological conditions. The station has been investigating a long-term action to replace their radiation monitoring system which will improve the reliability of the radiation monitoring system as a whole and help to alleviate this operator burden. | The inspectors determined that Seabrook's immediate actions to these failures have been appropriate for the circumstances and reasonable. While inspectors did not identify any cases where appropriate actions were not taken in response to a failed radiation monitor, inspectors noted that the on-shift operators have been repeatedly challenged with having to employ compensatory actions to validate normal radiological conditions. The station has been investigating a long-term action to replace their radiation monitoring system which will improve the reliability of the radiation monitoring system as a whole and help to alleviate this operator burden. | ||
==EXIT MEETINGS AND DEBRIEFS== | ==EXIT MEETINGS AND DEBRIEFS== | ||
| Line 348: | Line 348: | ||
2474867 | 2474867 | ||
2474972 | 2474972 | ||
Drawings C-S-1-83619- Allowable Boundary Valve Leakage for Cooling Tower Revision 1 | Drawings C-S-1-83619-Allowable Boundary Valve Leakage for Cooling Tower Revision 1 | ||
CALC Operation | CALC Operation | ||
PID-1-SW- Service Water System Nuclear Detail Revision 52 | PID-1-SW-Service Water System Nuclear Detail Revision 52 | ||
B20795 | B20795 | ||
Miscellaneous FP53593 RHR Pumps Instructions and Maintenance Manual | Miscellaneous FP53593 RHR Pumps Instructions and Maintenance Manual | ||
Revision as of 15:19, 5 October 2024
| ML24043A002 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/12/2024 |
| From: | Matt Young Division of Operating Reactors |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2023004 | |
| Download: ML24043A002 (1) | |
Text
February 12, 2024
SUBJECT:
SEABROOK STATION - INTEGRATED INSPECTION REPORT 05000443/2023004
Dear Bob Coffey:
On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station. On January 31, 2024, the NRC inspectors discussed the results of this inspection with David Sluszka, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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 at 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, Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety
Docket No. 05000443 License No. NPF-86
Enclosure:
As stated
Inspection Report
Docket Number: 05000443
License Number: NPF-86
Report Number: 05000443/2023004
Enterprise Identifier: I-2023-004- 0035
Licensee: NextEra Energy Seabrook, LLC
Facility: Seabrook Station
Location: Seabrook, New Hampshire
Inspection Dates: October 1, 2023 to December 31, 2023
Inspectors: T. Daun, Senior Resident Inspector E. Allen, Resident Inspector J. Demarshall, Senior Operations Engineer N. Eckhoff, Health Physicist T. Hedigan, Operations Engineer
Approved By: Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety
Enclosure
SUMMARY
The U.S. NRC continued monitoring the licensees performance by conducting an integrated inspection at Seabrook Station, 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None
PLANT STATUS
Seabrook Station began the inspection period operating at 100 percent rated thermal power and remained at or near full power for the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs 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 IP 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on -site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather (IP Section 03.01) (1 Sample)
- (1) During the weeks of November 13, 2023 and November 20, 2023, inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of reduced temperatures experienced during the winter months for the following systems:
- emergency feedwater
- mn fat
- Equitlignment
Ce Wkdow(IPtion 03.) (1 Sam
( The ipectors evted systonfirions duriomekdow t
'A'onttlng system between Oct, 2023 and Nber 2023
- Fire Precti
re Arkdown andpection (IPti01) (5 Se
The ipectors evted tmti ofire protti prram byonducti wkdown and perfming a rioifyrogr comianc eunctiity, merition,periness of tliire areas:
( Cooli mc equientm - east end (CT-F- -A)
October 17, 2023
- (2) Service and circulating water pump house (SW-F-1E-Z) on October 17, 2023
- (3) 'B' diesel generator room DG202 (DG-F-2B-1) on October 17, 2023
- (4) 'B' service water pump house electrical room (SW-F-1C-A) on November 28, 2023
- (5) Piping penetration area (PP-F-2A-Z) on November 29, 2023
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating tests administered November through December 2023 and the biennial written examinations administered November through December 2023.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered November through December 2023.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the licensees annual requalification operating test administered the week of November 13, 2023.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examina tion Security
The inspectors evaluated the ability of the licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re - examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re - examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed op erators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during the following:
- Main turbine electro-hydraulic control oil pump adjustments on November 15, 2023
- Quartly operability tting ember 2023
censrorequificion Trng/E*inationsIPtion 03.0 (1 Sam
( The ipectorserv and uaticens atequalifici inatictn t plant -rerenceim onr,023
- Menancefftivs
MenancefftivenessIPtion 03.01) (2 Se
The ipectors evted t efftivsf maienance tourthe fling strtes, systs,sn cabl rformi their iended functi:
( Content radiion monitorsunctila)(1) plan actions Dber 2023
( Contrfubricating oilsor safy-rated pum and mors emb 21, 2023
- Menance Risksssmts and Emgentk Contr
Risksssmt and MentIPti01) (5 Se
The ipectors evted t accacyomsf risk assessmentsor t fling planned and emgentork activiti to enseonfirion c and opriekontrse addrs:
( Ylisking 'A'italt norm battery sy breakerpecti October 11, 2023
( Eliski kiltienance and ttiOct 27, 2023
( Emgentktr for flt drain lontror the 'A' 'B' seats on Nember 13,023
( Emgentktr forteameak onC' rt drtank Nber 2023
( Riskanagement actisor high riskorkssociitthe 'B' hydrlicl pump (HF -P - -B)penseplementNber 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) 'D' steam generator pressure channel calibration failure (AR02467994) on October 25, 2023
- (2) Emergency feedwater with failure of the transformer for the 'B' flow control valve to 'D' steam generator (AR02471828) on November 8, 2023
- (3) 'A' residual heat removal following replacement of motor oil with incorrect type (AR02471178) on November 14, 2023
- (4) Service water system with excessive leakby of the 'A' service water cooling tower isolation valve (AR02474972) on December 28, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Process protection cabinet power supply upgrade for CP-1 on October 23, 2023
- (2) Replacement of steam generator pressure loop 7300 card with redesigned 7300 card on November 15, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (IP Section 03.01) (5 Samples)
- (1) CP-1 power supply replacement on October 23, 2023
- (2) 'A' residual heat removal pump motor following oil change on November 1, 2023
- (3) 'A' control room air conditioning system following compressor trip on November 15, 2023
- (4) Replacement of 7300 bistable card for steam generator high negative rate trip on November 16, 2023
- (5) 'B' cooling tower service water pump discharge valve following repair work on December 1, 2023
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) Electric emergency feedwater pump quarterly and monthly valve verification on November 29, 2023
- (2) 'D' 125 volt battery bank discharge test on December 22, 2023
In-service Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Turbine driven emergency feedwater pump quarterly and monthly valve alignment on October 19, 2023
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the conduct of a routine, full participation emergency planning drill on October 18,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (8 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Radiation monitor (RM)-6543 seven foot south end area monitor
- (2) Radiation monitor (RM)-6547 charging pump room area monitor
- (3) Ludlum Model 12 (serial #298290) in use in the primary auxiliary building
- (4) Fluke Model 451 (serial #0042) in use in the primary auxiliary building
- (5) Eberline AMS-4 (serial #12951) in the fuel storage building
- (6) Ludlum Model 177 (serial #295988) in the fuel storage building
- (7) Tele-pole II (serial #232920-041) in use during Radwaste shipment
- (8) Radiation monitor (RM)-6568 containment enclosure air exhaust monitor
Calibration and Testing Program (IP Section 03.02) (13 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Radiation monitor 6481 main steam line radiation monitor
- (2) ThermoFisher model RO-20A (serial #114867)
- (3) Ludlum model 177 (serial # 295997)
- (4) Mirion argos-4AB (serial #105)
- (5) Ludlum model 177 (serial #295997)
- (6) Small article monitor (serial #199)
- (7) Mirion cronos small article monitor (serial #1212-227)
- (8) Canberra gamma exit monitor 5 (serial #29826)
- (9) Mirion argos-4AB (serial #132)
- (10) Radiation monitor 6520 reactor coolant letdown gross activity monitor
- (11) Radiation monitor 6538 residual heat removal pump area
- (12) Mirion argos-4AB (serial #107)
- (13) Radiation monitor 6576A containment post loss of coolant accident monitor Effluent Monitoring Calibration and Testing Program (IP Section 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) R-6528 plant vent wide range gas radiation monitor
- (2) Radiation monitor 6509 waste liquid test tanks discharge monitor
71124.08 - Radioactive Solid Waste Processing and
Radioactive Material Handling, Storage, and Transportation
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed the preparation of radioactive shipment 23-040 of dry active waste on October 17,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity (IP Section 02.10)===
- (1) For the period October 1, 2022 through September 30, 2023
BI02: RCS Leak Rate (IP Section 02.11) (1 Sample)
- (1) For the period October 1, 2022 through September 30, 2023
OR01: Occupational Exposure Control Effectiveness (IP Section 02.15) (1 Sample)
- (1) For the period October 1, 2022 through September 30, 2023
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences (IP Section 02.16) (1 Sample)
- (1) For the period October 1, 2022 through September 30, 2023
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Evaluation of area and process radiation monitor performance issues
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (IP Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue
INSPECTION RESULTS
Observation: Semiannual Trend Review 71152S The inspectors reviewed Seabrooks corrective action program for trends that might be indicative of more significant safety issues. The inspectors reviewed condition reports, level one assessments, system health reports, and control room/panel deficiencies. In particular, the inspectors evaluated the operator challenges program including an audit of control room deficiencies, control board notifications, and operator workarounds.
Based on the overall results of the semiannual trend review, the inspectors determined that issues were appropriately evaluated by Seabrook staff for potential trends and resolved within the scope of the corrective action program and other requisite procedures. Inspectors did note the station has made significant progress toward correcting long standing video alarms in the control room significantly reducing operator burden. A minor violation was also documented as part of this trend related to the control of quality related oil used in safety-related components.
Minor Violation: Failure to Control Quality Related Oil for Safety-Related Motors 71152S A violation of 10 CFR 50, Appendix B, Criterion VII Identification and Control of Materials, Parts, and Components was identified when the incorrect lubricating oil was added to the safety-related A residual heat removal pump motor and the safety-related B primary component cooling water pump motor. Both pump motors require Mobile DTE Medium ISO 46 as prescribed by the original equipment manufacturer. Upon an oil change on the A residual heat removal pump motor on October 10, 2023, an oil sample was taken and sent to a vendor as part of Seabrooks predictive maintenance monitoring program. Upon receipt of the oil analysis back from the vendor in September 2023, it was discovered that the oil viscosity was lower than expected. The station entered this condition into their corrective action program and sampled the secondary container labeled as Mobile DTE Medium ISO 46 that the quality assurance records indicated the oil was obtained from for the A residual heat removal pump motor. Upon analysis it was discovered that the secondary container contained Mobile DTE 732 ISO 32. An extent of condition review was conducted, and the licensee determined that the same secondary storage container was used to obtain oil for an oil change on the B primary component cooling water pump motor on September 7, 2023.
The licensee performed oil analysis on all bulk oil storage and confirmed all bulk oil and found no discrepancies. The licensee discontinued the use of secondary containers for oil storage and have updated issue instructions that require all oil to be obtained only from original source bulk storage containers. Both the A residual heat removal pump motor oil and B primary component cooling water pump motor oil were drained, flushed, and replaced with Mobile DTE Medium ISO 46.
Screening: The inspectors determined the performance deficiency was minor. The performance deficiency did not adversely affect the Mitigating Systems cornerstones objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Seabrook conducted an engineering analysis and determined that the lower viscosity oil did not negatively impact the reliability of the pump motors and only posed a long-term degradation concern.
Enforcement:
This failure to comply with Title 10 CFR 50, Appendix B, Criterion VII Identification and Control of Materials, Parts, and Components, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Review of Seabrooks Evaluation and Corrective Actions for 71152A Radiation Monitoring System failures The inspectors performed a review of various failures of process and area radiation monitors which have resulted in repeated out-of-service time and compensatory actions. The inspectors reviewed Seabrooks causal evaluations, implemented corrective actions, and preventive maintenance frequency.
Seabrook Stations maintenance rule program, required by 10 CFR 50.65, credits three radiation monitors; RM-6526-1 (containment particulate), RM-6526-2 (containment gas), and RM-6548 (backup containment gas) to meet the technical specification function to be capable of detecting a one gallon per minute increase in unidentified leakage within one hour. This maintenance rule function is monitored at a system level and has an established performance goal of less than six failures in a 24 month period. Detecting and monitoring reactor coolant system leakage into the containment area, and quickly separating the identified leakage from the unidentified leakage provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public. Seabrook Stations Technical Specification 3.4.6.1 requires instruments of diverse monitoring principles to be operable to provide confidence that small amounts of unidentified leakage are detected in time to allow actions to place the plant in a safe condition when reactor coolant system leakage indicates possible reactor coolant pressure boundary degradation. One containment atmosphere radioactivity monitor (gaseous or particulate) is required as well as the containment drainage sump level monitoring system.
The inspectors noted continual failures of one or more of these containment gaseous radioactivity monitors with five failures in 2021, three in 2022, and one additional in 2023.
Two of the failures in 2022 were classified as maintenance rule functional failures and were counted against the performance goals. While these failures have not exceeded the performance goals established in 10 CFR 50.65(a)(2), they have posed a burden on the operating crews. Inspectors also determined that the ability to accurately monitor unidentified leakage was not challenged during these failures because the containment drainage sump level monitoring system remained in service during these periods. Based on the performance improvement in 2023, inspectors determined that actions taken by the station have been reasonable but will continue to monitor performance of these radiation monitors.
The inspectors determined that Seabrook's immediate actions to these failures have been appropriate for the circumstances and reasonable. While inspectors did not identify any cases where appropriate actions were not taken in response to a failed radiation monitor, inspectors noted that the on-shift operators have been repeatedly challenged with having to employ compensatory actions to validate normal radiological conditions. The station has been investigating a long-term action to replace their radiation monitoring system which will improve the reliability of the radiation monitoring system as a whole and help to alleviate this operator burden.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 31, 2023, the inspectors presented the health physics instrumentation, radioactive material shipment preparation, and occupational and public portions of the performance indicator verification inspections inspection results to Chris Robinson, Organization Effectiveness Director, and other members of the licensee staff.
- On January 31, 2024, the inspectors presented the integrated inspection results to David Sluszka, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Drawings 1-CBS-B20233 Containment Spray System Revision 38
Procedures OS1006.01 Fill and Vent of CBS and RHR System Revision 16
OX1406.02 Containment Spray Pump and Valve Quarterly Operability Revision 27
71111.05 Calculations MS-MISC-49 Service Water Pumphouse Revision 7
MS-MISC-54 Verification of Combustibles in Fire Zones of Mechanical 06/16/1986
Penetration Area
Corrective Action 02473348
Documents
Drawings CT-F-2B-A Cooling Tower Mech. Equip. Rooms - East End
DG-F-2B-1 Diesel Generator Building 'B' Generator Room - DG202
PP-F-2A-Z Piping Penetration Tunnels
SW-F-1C-A Water Pump House B Train Motor Control Center Room
SW-F-1E-Z Service and Circ. Water Pump House
Procedures FP62296 Fire Protection Prefire Strategies Revision 45
71111.12 Corrective Action 02381369
Documents 02392738
2404043
2414224
2418709
2439446
2470799
2471178
2474294
Procedures MA 4.9 Control and Storage of Equipment and Materials Revision 21
Work Orders 40773723
40816310
40828717
40844327
40869755
40886782
40889968
Inspection Type Designation Description or Title Revision or
Procedure Date
40955429
71111.13 Corrective Action 02472094
Documents 02472895
Work Orders 40946703
40956290
40956945
71111.15 Corrective Action 02467994
Documents 02471178
2471828
2474867
2474972
Drawings C-S-1-83619-Allowable Boundary Valve Leakage for Cooling Tower Revision 1
CALC Operation
PID-1-SW-Service Water System Nuclear Detail Revision 52
B20795
Miscellaneous FP53593 RHR Pumps Instructions and Maintenance Manual
Procedures EN-AA-203-1001 Operability Determinations Revision 41
Work Orders 40738441
40869547
40886782
40955368
71111.18 Drawings 1-NHY-310942 Process Protection Cabinet Power Supply MM-CP-1 Revision 2
Engineering 286645 7300 System Printed Circuit Board Upgrades Revision 3
Changes 297025 7300 Power Supply Upgrades Revision 4
299068 SG Pressure Loop FW-P-525 7300 Card Replacement Revision 0
Procedures ER-AA-122-1001 Printed Circuit Board Life Cycle Management Plan Revision 6
71111.24 Corrective Action 02467994
Documents 02468027
2468533
2469744
2473437
Drawings 1-SW-B20794 Service Water Nuclear Detail System 05/04/2023
FP62415 Liquid Chiller Wiring Diagram Revision 1
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedures LX0556.98 Battery Performance Test Revision 15
OX1416.06 Service Water Discharge Valves Quarterly Test And 18 Revision 13
Month Position Verification
OX1423.28 Control Room Air Conditioning System Quarterly Revision 7
Surveillance
OX1436.02 Turbine Driven Emergency Feedwater Pump Quarterly and Revision 37
Monthly Valve Alignment
OX1436.03 Electric EFW Pump Quarterly, 18 Month/30 Days Cold Revision 30
Shutdown And Comprehensive Pump Tests, And Monthly
Valve Verification Surveillance
OX1456.81 Operability Test of IST Valves Revision 44
OX1456.86 Operability Testing of IST Pumps Revision 31
Work Orders 40594786
40848519
40869685
40869795
40869884
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