The following violation of very low safety significance (
Severity Level IV) was identified by NextEra and was a violation of NRC requirements that meets the criteria of Section VI of the
NRC Enforcement Policy,
NUREG-1600, for being dispositioned as an non cited violation.
Technical Specification 6.7.1 and
Regulatory Guide 1.33 requires that maintenance activities be implemented in accordance with written procedures. The Seabrook work control procedures MA 4.5 (Configuration Control) and MA 4.3 (
Temporary Modifications and Temporary Alterations) were written per the above. MA 4.5 allows changes to an electrical circuit during maintenance troubleshooting activities, but requires implementation of the modification process per MA 4.3 once troubleshooting is complete. On August 3, 2009, the licensee identified that the environmental qualification (
EQ) configuration of the D
MSIV control circuits had been degraded on July 30, 2009 while recovering from a faulty test circuit discovered during the quarterly
MSIV stroke test in which the valve became partially closed. While troubleshooting the
MSIV test circuit, the configuration was changed by disconnecting the connector as allowed under MA 4.5. However, plant workers did not implement a
temporary modification per MA4.3 as required after completing the troubleshooting. Had the modification process been entered, the impact of the change on environmental qualification would have been addressed. By not following MA 4.5/4.3, the licensee failed to maintain an electrical circuit configuration that preserved environmental qualification. Upon discovery, the licensee declared the
MSIV inoperable and entered
TS 3.7.1.5. The connector was reattached restoring the
EQ qualification of the electrical circuit, and a slide link was opened to maintain the slow close valve in the retract position. The impact of the circuit modification was acceptably addressed in engineering assessment
TAR for
AR 202762202762and modification
EC145071. The finding had very low safety significance because it did not involve a loss of safety function or impact the safety function for a time greater than the allowed outage time in the technical specifications. An engineering assessment determined that the
MSIV remained
operable but degraded from July 30 to August 3 despite the loss of environmental qualification. The violation was licensee identified and entered into the corrective action program as
AR 202762202762
