IR 05000443/2011004

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IR 05000443-11-004; 07/01/2011-09/30/2011; Seabrook Station, Unit No. 1; Routine Integrated Report; Fire Protection; Operability Evaluations
ML11308B437
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 11/04/2011
From: Arthur Burritt
Reactor Projects Branch 3
To: Freeman P
NextEra Energy Seabrook
Burritt A
References
IR-11-004
Download: ML11308B437 (33)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406-1415 November 4, 201i Mr. Paul Freeman Site Vice President Seabrook Nuclear Power Plant NextEra Energy Seabrook, LLC c/o Mr. Michael O'Keefe P.O. Box 300 Seabrook, NH 03874 SUBJECT: SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/201 1 004

Dear Mr. Freeman:

On September 30, 2011, 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 10,2011, 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 Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The report documents one NRC-identified finding of very low significance (Green) that was determined to involve a violation 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 they are entered into your corrective action program, the NRC is treating these findings as NCVs, consistent with Section 2.3.2 of the NRC Enforcement Policy. lf 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 l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at (Site Name). 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 l, and the NRC Resident Inspector at Seabrook. ln accordance with 10 cFR 2.390 of the NRC's "Rules of Practice," a copy of this letter' its enclosure, and your response (if any), will be available electronically for public inspection in the NRC public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at (the Public Electronic Reading Room)'Arthur L. Burritt, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86 Enclosure:lnspectionReportNo'0500044312011004 w/ Attachment:

Supplemental Information cc w/encl: Distribution via ListServ

Sincerely,

SUMMARY OF FINDINGS

lR 0500044312011004; 0710112011-09/3012011;

Seabrook Station, Unit No. 1; Routine Integrated Report; Fire Protection;

Operability Evaluations.

This report covered a three-month period of inspection by resident and regional specialist inspectors.

One Green finding was identified.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (lMC) 0609, ,,significance Determination process" (SDP). The cross cutting aspects for the findings were detLrmined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings for which the SDp does not apply may be Gieen, or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is describeO in tlUnEG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating

SYstems

Green.

The inspectors identified a non-cited violation (NCV) of Technical Specification (TS){l tathat requires that written procedures be established and implemented, including administrative procedures that define authorities and responsibilities for safe operation.-pecifically, NextEra identified a degraded condition in the fire protection system on July 15, 2011, Out iiO not properly or thoroughly evaluate the fire protection system performance as required by NextEra proiedure gN-nn-ZOg-1001 . As corrective action, NextEra completed an operability"evaluation that identified degraded fire protection system performance under certain operatingLconditions for which NextEra implemented administrative controls that would prevent the degraded Performance.

The performance deficiency was more than minor because a reasonable doubt of operability existed untilfurther engineering evaluations were completed to demonstrate adequate fire system performanc" ,id"r oeJign basis conditions.

The finding affected the Mitigating Systems"orn"rrione objective to ensure the availability, reliability and capability of systems that respond to initiating events in order to prevent core damage. The issue was evaluated using Appendix F of IMC 0669, "significance Determination Process" (SDP), and was determined to be of very low safety signifiiance (Green) because the finding had minimal impact on fire system performance.

te finding had a cross cutting aspect in the area of problem identification and resolution, p.1(c), becausl NextEra personnel did not adequately implement the operability determination process to ensure that fire system performance was thoroughly evaluated for operability to assure timely and appropriate corrective actions were completed' (Section 1 R15)

Other Findings

A violation of iery low safety significance identified by NextEra was reviewed by the inspectors'

Corrective actions taken or ptaineO by NextEra have been entered into NextEra's corrective action program. This violation and corrective action tracking number are listed in Section 4oA7 of this report.

4

REPORT DETAILS

Summarv of Plant Status Seabrook Station operated at full power during the period'1. REACTORSAFETY Gornerstones:

Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111'01 - 2 samples).1 External Floodino a. Inspection ScoPe During the period August 15-23, 2Q11, the inspectors performe.d an inspection of the external flood proteciron measuies for Seabrook Station. The inspectors reviewed the Updated finat'safety Analysis Report (UFSAR), Chapter 2.4'2.2,.which depicted the design flood levets anO protection'areas containing safety-related equipment, to identify areas that may be affected by external flooding.

fhe inspectors conducted a general site walkdown of the fuel stoiage building, thelssential switchgear building, and the emergency Jieset generator (EbG) building to ensure that NextEra erected flood protection r"urr15, in accordance with design specifications.

The inspectors also reviewed operating procedures for mitigating-external flooding during severe weather to determine if NextE]ri planned or established adequate measures to protect against external flooding events. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findinqs No findings were identified' Readiness for lmpendino Adverse Weather Conditions a. lnspection ScoPe During the period August 24-27,2011, inspectors reviewed NextEra's readiness to protect rist< signiiicani systems during the period Yl"l. Hurricane lrene was projected to impact the site area. The inspectors-verified that NextEra prepare-d-and responded to the severe weather conditions in accordance with procedure OS1200'03, "Severe Weather Conditions." The inspectors also reviewed corrective actions for problems identified durinj the inspection.

The inspection included walk downs of plant areas including the n6rmal and emergency Ai etgglqt distribution systems including the supplemental emergency power supplies (SEPS), the service water and screen wash systems, and emergency feedwater systems'The inspectors reviewed the UFSAR regarding design features' and verified the adequacy of the station procedures for ievere weather protection'..

The inspectors reviewed pr"uioust-iO"ntitl"O deficiencies related to extreme weather preparation and.2 5 verified that the issues were appropriately dispositioned through the corrective action program.b. Findinos No findings were identified'

1R04 Equipment

Aliqnment (71111.04Q - 3 samples).1 Partial Svstem Walkdowns a. Inspection ScoPe The inspectors performed partial walkdowns of the systems listed below. The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at ihe time they were inspected.

Tl're inspectors review-ed applicable operating procedures, system diagrams, the UFSAR, technical specifications, and the impact oT ongoing worX -activities Jn redundant trains of equipment in order to identify conditions tn-at cJutO have impacted system performance of their intended safety functions.

The inspectors also performed fieid walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.

The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there wgre .Lo deficiencies' The inspectors als6 reviewed whether NextEra staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization' o B emergency diesel generator (EDG) during inspection and test of the A EDG on August 15,2011. B train emergency feedwater (EFW) system during inoperability of the A EFW sYstem on August 25,2011 o B EDG during inoperability of the A EDG on September 19 and 20,2011 b. Findinqs No findings were identified'

1R05 Fire Protection

(71111.05Q - 2 samples).1 Resident lnspector Quarterlv Walkdowns a. Inspection ScoPe The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features.

The inspectors verified that NextEra controlled combustible materials and ignition sources in accordance with administrative procedures.

The inspectors veriiied that fire protection and suppression equipment was available for use as specified i1 the area pre-fire plan, and passive fire barriers were maintained in good maierial condition.

The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded' or inoperable tire protection equipmeni, as applicable, in accordance with procedures'

6. Primary Auxiliary

Building (-)26' elevation on August 8,2011. Primary Auxiliary Building (-)6' elevation on August 8,2011 b. Findinqs No findings were identified.

An issue related to fire protection system performance is discussed in Section 1R15 below.

1R06 Flood Protection

Measures (71111'06 - 1 sample).1 lnternal Floodinq Review a. Inspection ScoPe The inspectors reviewed the flood protection measures designed to protect the control building-cabie spreading room 50 ft elevation and other safety-related equipment from-the effects of internalflioding.

The inspectors reviewed NextEra's flooding evaluation for the selected areas, the design basis documents and flood response procedures' The inspectors performed a walkdown of the selected areas to verify that as-found equipment and conditions were consistent with the design basis documents.

The inspectors reviewed the condition of seals, level alarms and other equipment credited in the flood analYsis.b. Findinos No findings were identified.

1R07 Heat Sink Performance

(71111'07 - 1 sample)a. Inspection ScoPe The inspectors reviewed the 201 1 testing of the B diesel generator jacket water heat exchanger E4zBto verify that the heat exchanger could fulfill its design function.

The inspectors reviewed theimal performance monitoring trending data for heat exchanger temperatures and fouling factors, and ES1850.017,;SW Heat Exchanger Program"'

The inspectors interviewed chemistry personnel and the system engineer to evaluate the process used to monitor tne rreit exchanger and commitments in Generic Letter 89-13','service Water System Problems Affecting Safety-Related Equipment." The inspectors conducted system walkdowns and reviewed condition reports to verify that issues associated with the heat exchanger were identified and corrected' b. Findinqs No findings were identified.

7 1R1 1 Licensed operator Requalification Proqram (71111

.1 1Q - 1 sample)a. lnspection

ScoPe The inspectors reviewed operator implementation of the abnormal and emergency operating procedures on August 9,2011. The inspectors evaluated operator performance during the simJator iraining, which included a reactor shutdown with loss of cooling and the iailure of select components to operate as required' The inspectors verified .orpi"iion of risk significant operator actions, including the use of abnormal and emergency operating proceJures.

The inspectors assessed the effectiveness of communications, im[lementation of actions in response to alarms and degrading plant conditions, and t'he oversight and direction provided by the control room supervisor' The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the techhical specification action statements entered by the shift technical adviir. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems'b. Findinqs No findings were identified.

1R12 Maintenance

Effectiveness (71111.12Q - 1 sample)a. Inspection ScoPe The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC performance and reliability.

The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that NextEra was identifying and properly evaluating performance problems within.the scope of the maintenance rule' For each sampte seledted, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (aX2)performance criteria established by NextEra staff was reasonable.

As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to 1i1121. Additionally, the inspectors ensured that NextEra staff was iolntitying and addressing common cause failures that occurred within and across maintenance rule system boundaries'. Cooling water system with focus on emergency diesel generator heat exchanger Performance and fouling.b. Findinqs No findings were identified.

I 1R13 a.(71111.13 - 5 samPles)Inspection ScoPe The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that NextEra performed tfre appropriate 6sk asslssments prior to removing equipment for work. The inspectors selecied these activities based on potential risk significance relative to the reactor safety cornerstones.

As applicable for each activity, the inspectors verified that NextEra personnel performed'risk assessments as required by 19 CFR 50'65(aX4)and that the assessments were accurate and complete.

When NextEra performed emergent Work'ine inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the 1sk assessment.

The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when afplicable, to verify risk analysis assumptions were valid and applicable requirements were met.. A emergency diesel generator routine surveillance during emergent adverse grid conditions on July 11,2011 (CR166821 1)o planned maintenance for the emergency feedwater and enclosure air handling systems resulting in orange risk combinations on August 23-25' 2011 (wo 01382686)I Planned maintenance for the A emergency diesel generator, emergency feedwater and reserve auxiliary transformer that resulted in the orange risk combinations on september 19-20, 2b1 1 (WO 40077891 and 01 207794)o planned maintenance for the emergency feedwater and 345 KV offsite power line 369 supplying that result the in oraige risk combinations on September 21-22' 2011 (WO 40073287 and 01186862). planned maintenance affecting the 345 kV offsite power line 369 and the 480 V unit substation 61 power supply on September 26-28,2011 (WO 01197008)Findinos No findings were identified.

1R15 Operabilitv

Determinations and Functionalitv Assessments (71111.15 - 4 samples)a. lnspection ScoPe The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

o AR166g013, reduced cooling water flow to the emergency diesel generators caused by marine fouling in the emergency diesel generator jacket cooling water heat exchangers service water supply on July 9,2011 o AR1671288, high plant area temperatures caused by extreme environmental ambient temperatures on July 21,2011 b.

b.9. AR1676974, removal of the pressure reducing valves from the fire protection system fire hose reels on August 22,2011. AR166 2416, pressurizer code safety valve (1-RC-V1 1 7) seat leakage on June 20, 2011 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was property justified and the subject component or system remained available such that no unrecognired increase in risk occurred.

The inspectors compared the operability and design iriteria in the appropriate sections of the technical specifications and UFSAR to NextEra's evaluations to determine whether the components or systems were operable.Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by NextEra. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

Findinqs Inadequate operabilitv Determination - AR 1668219, 1676974 lntroduction.

The inspectors identified a Green non-cited violation (NCV) of Technical Specfbatlo. (TS) 6.7.1.a that requires that written procedures be established and implemented, inciuding administrative procedures, as described in Regulatory Guide 1.i3, that define authorities and responsibilities for safe operation.

Specifically, NextEra identified nonconforming and degraded conditions in the fire protection system on July 1 5, 2011 , (AR1668219), but did not properly evaluate fire protection system funttional performance as required by NextEra procedure EN-AA-203-1001 (AR1676e74).

Description.

The Seabrook fire protection (FP) system is described in UFSAR Section g5l Jhe UFSAR Appendix A Fire Hazards Analysis, UFSAR Appendix R Fire protection of Safe Sh'utdown Capability, and in the technical requirements manual (TRM). The FP water supply system was designed to provide sufficient flow for a period of two hours to the largest sian-dpipe/sprinkler header serving a safety related area (i.e., an emergency diesel generator)concurrent with operation of 2 fire hose stations flowing at 500 gfm t5ectionsF.3.E.O(b)and F.3.E.2(e)].

Service water booster pump, SW-p374, fiovides a backup water.supply to standpipes in Category I Buildings in the event that a seismic event damages the main fire protection water supply.On July 11, 2011, NextEra issued AR1668219 to document two instances of past changes made to the fire protection system that were not adequately documented and/or evalulted.

Design change ggDCRolC removed pressure reducing valves and vent/drain valves from standpipes lnat supply station hose reels, but failed to evaluate the impact of higher fire hose flows on the fire system performance y1!er design conditions' Further, th6 Seabrook fire fighters (Fire Brigade) had obtained higher capacity nozzles for use at the hose stations, Out OiO not identify these changes to Engineering and did not evaluate the impact of these changes on FP system performance.

Specifically, the changes were not evaluated for the implct on the performance of service water booster pump SW-p374, the fire water stoiage tank capacity, and the performance of the main fire pumps to provide design flows.

10 The deficiencies described in AR1668219 were presented to the Operation Shift Manager on July 15,2011, to provide an operability assessment' The SM concluded that there was "no operabliity impact because there would be increased flow margin relative to the original design". Actions were assigned to Engineering to evaluate the current configuraiions and incorporate the changes into the design basis. Upon review of the AR1668219 on August 11 , 2011 , the NRC inspectors determined that the operability assessment taiteO sufficient technical basis to conclude there was no impact on rp .yrt"r performance.

Although NextEra adequately assessed the impact of the changei relative to the increased flow at the hose stations, the assessment did not consider how the increased flows at the hose reels would impact flows to the rest of the FP system, or other potential impacts on the fire water supply' The assessment did not consider whether the fire system could provide adequate flow at required Pressure for a period of two hours assuming concurrent operation of 2 ftre hose stations with the iargest demand standpipe/spirinkler headerserving a safety related area in operation' proced ure EN-AA-203-1 00 1, "operability Determ inations/Functional Assessments," provides requirements for evaluation of nonconforming and degraded conditions and requires in Section 2.0.2thatfunctional assessments (FAs) be performed for systems unt .orponents (SSCs) that perform specified functions jn the TRM. The Seabrook fire f rotection system is described in technical requirements (TR) 7, 8,9, 10, 11 and 12'ine proceOure further requires in Section 4.2.2.8 that the Shift Manager evaluate the Oegr;OeO SSC per EN-AA-203-1001, Section 4.5, Functionality Assessments,(FA)'

Seition 4.5.1 requires that, if an SSC is determined to remain operable based on the Shift Manager's assessment, the Shift Manager shall assign a responsible group (engineering)to complete a iunctional assesiment that is to be documented per nttJ"nr"ni{i, Grid"nce for Completion of FA. The inspectors determined that the evaluations NextEra performed on July 15,2011, for the indentified fire protection system deficiencies diO not perform th-e functionality assessment required by NextEra procedure EN-AA-203-1 001'After the NRC concerns regarding the July 1 5,2011, fire protection operability assessment were discussed with NextEra on August 1 1 , NextEra issued AR 1676974 that requested Engineering complete a functionality assessment in accordance with EN-AA-203-1001 to assess th6 impact of the FP system changes on FP system performance.

Based on the results of a functionality assessment subsequently completed.

on August 22,2011, NextEra concluded that the fire protection system remained functional when ptant insiatled equipment was used to respond to the FP system design basis condition' However, concerns were identified regarding the use of the higher capacity replacement ntozzlesin place of the originally installed plJnt equipment' Engineering's evaluation for the replacement nozzles d'etermined that ihe nozzles caused higher system flows that would adversely impact the fire tank capacity in a design basis fire' Specifically' the main fire tanks would be drained sooner thah tne 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> assumed in the licensing basis under design basis conditions.

Further, NextEra identified concerns with potential run-out of P374 under certain conditions if NextEra used that pump to respond to a beyond design basis fire'Sfecifically, tfre enjineering evaluaiion determined thatP374 did not have sufficient capacity to supportihe two 2.S incn hoses/nozzles that would be used when offsite fire 11 fighters (Town of Seabrook)respond to the site during a beyond design bases fire'NextEra also identified a concern that the capacity of the main fire water pumps may be exceeded if two 2.5 inch hoses lnozzles were connected to the FP system during a beyond design bases fire response using offsite personnel' NextEra determined that the use of higher capaciiy equipment would-be acceptable as long as the system capacity was considered by thL station fire brigade and FP system parameters were controlled within the limits established by plant procedures.

NextEra documented the fire system conditions/limitations in the st-aiion log on August 22,2011 (OD/FA 11-0007), and initiated a ,,read and-si!n,, training ptan to infirm all operator and fire brigade member of the limitations.

NextEr"a plans further analyses of the FP system using a hydraulics model to better "u"irut"'tne impacts of using higher 1ow equipment' The inspectors reviewed the licensee's administrative controls to assure the functionality of the FP system and determined they were adequate'Analygis.

The inspectors determined that not properly implementing procedure EN-AA-203-1001 for gre Oeg;OLJ tonOition discussed above was a performance deficiency' This performance OJiicl"ncy was considered more than minor based on a comparison with Examples 3.j "nO g.L of Appendix E of IMC 0612' Specifically' the performance deficiency was more than minor because a reasonable doubt of operability existed until further engineering evaluations were completed to demonstrate adequate performance of the fire protection-syitem under design'basis conditions.

As such, the finding affected the Mitigating Systems cornerstone obj6ctive to ensure the availability, reliability and capability of systemi that respond to initiating events in order to prevent core damage'The issue was evalult"o uri'ig lMc 0609, "slgnificance Determination Process" (SDP), and was determined to be of very low safety significance.

Specifically, when evaluated under IMC 0009, nppendix f, the performahceleficiency (failure to.properly review undocumented/unevaluated changes that impact FP system hydraulic perf.ormance)affects the,,Fixed Fire protection system caiegory." A low degradation rating is assigned since the reduction in suppression flow iatefor a design basis safe shutdown fire was expected to be less than i 0% below the design rated value for the largest hydraulic demand, in"trOing an allowance for manual hose stream' This issue did not affect the likelihood that a fire might occur. The finding screens to Green with no further analysis.

The finding had across cutting aspect in the area of problem identification and resolution, correctivJ u"tion program, belause NextEra personnel did not thoroughly evaluate problems such that resolutions address causes, including prope.r-lv classifying' prioritizing anO evatuating affected systems for operability (P'1(c))'

Specifically' NextEra did not adequatety evaluite the opeiability of the fireprotection system considering the unevaluated system changes identified on Juty 11.2011,.nor did NextEra ' ensure corrective actions to supp5rt functionality were completed in a timely manner'Enforcement.

Technical specification 6.7.1'a, Procedures and Programs' requires written procedures be established and implemented, including administrative procedures as described in negu-talor' CuiOe 1.33, that define authorities and responsibilities for safe operation.

prJceoure eu-RR-203-1001 defines responsibirities and requirements for completing functionality assessments to establish the acceptability of continued plant operation when SSCs are found to be degraded' Contra.ry to the above' NextEra did not adhere to the NextEra Procedure EN-AA-203-1001 requirements for completing functionality "rr"rirents when the fire protection

y.stefn was identified as potential degraded on July ls, iott Specificatty, trtextEra did not complete and document a functionality assessment in accordance with EN-AA -203^10A1 Section 4'5 after the shift manager made the call that the system remained functional on July 15' 2011' This 12 resulted in the delayed identification, assessment and correction of a condition that impacted fire system performance under certain conditions' Because the finding is of very low safety significance and was entered into NextEra's corrective action program (CR1O7O97+1, tnii violation is being treale{ ?? -T.ryCV, consistent with Section 2'3'2'a of the NRC Enforcement Policy. (N-cv 05000443 I 2011004'01, Inadequate FunctionalityAssessmentforFireProtectionSystem)'

1R18 Plant Modifications

(71111.18 - 1 sample).1 TemPorarv Modifications a. Inspection ScoPe The inspectors reviewed the modification to the B Train Control Building Chilled Air system per EC273g06 to determine whether the modifications affected the functions of systems that are important to safety. The inspectors reviewed the engineering change documentation anO post-modification testing iesults, and conducted field walkdowns of the modification.

The inspector reviewed iriplementation of the changes through work package WO 4010g30S.

The inspector verified.that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the Control Building Chilled Air (CBA) system'b. Findinqs No findings were identified.

1R19 Post-Maintenance

Testinq (71111'19 - 7 samples)a. Inspection ScoPe The inspectors reviewed the post-maintenance tests for the maintenance activities listed belowtoverifythatproceduresandtestactivitiesensuredsystemoperabilityand functional capability.

The inspectors reviewed the test procedure to verify that the procedure "t"qu"t"f' tested ihe safety functions that may have been affected by the maintenanc" ,.tiuity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved' The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions' o Service water pump 41A motor breaker electrical inspections and calibrations per WO 400677A7 andWO 01210426 on August 18' 2011 r Supplemental emergency power system (SEPS) maintenance and inspections per WO 40068106 on August 25,2Q11. Component cooling water system thermal barrier pump maintenance per WO 01 1891 42 on SePtember 7 ,2011 o component cooling water system t!er1a.l iarrier heat exchanger isolation valve CC-V1095 maintenance pei WOO1ZO2l45 on September 7,2011 o A emergency diesel generator maintenance per wo 401 11423 on september 21'2011 13. Enclosure building air handling fan EAH-F318 power supply maintenance per WOs 40074302 and 01 197008 on September 27,2011. Service water pump p41D discharge isolation valve maintenance per WO 40113004 and 01 172578 on SePtember 30, 2011 b. Findinos No findings were identified'

1R22 Surveillance

Testinq (71111-22 - 5 samples)a. Inspection ScoPe The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant S'SCs to assess whether test results satisfied technical specificationt, il't" UFSAR, and NextEra procedure requirements' The inspectors verified tnat tesiacceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the ,"ng" and aicuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied' Upon test completion' the inspectors considered whether the test results supported that equipment was capable of performing t6eiequlred safety functions.

The inspectors reviewed the following surveillance tests: o oX1416.05, service water cooling Tower Pumps Quarterly and 2 Year ComPrehensive Test on JulY 15,2011 o lX 16g0.931, SSPS Train A Mode 1 Actuation Logic Test on Aug_ust 25,2011. cs0910.01, Primary system sampling at cP-1664 on August 23,2011 o oX1 401.02., RCS L-eak Rate calculations in August 22-26,2!11

_. EX1g03.003, Reactor containment Type B and c Leakage Rate Tests on August 9, 2011 b. Findinqs No findings were identified.

14 Gornerstone:

Emergency Preparedness lEPO Drill Evaluation (71114.06 - 2 samples).1 Emerqencv Preparedness Drill Observation a. Inspection ScoPe The inspectors evaluated the conduct of a routine NextEra emergency drill on September 14,2011 to identify any weaknesses and deficiencies in the classification, notification, and protective action i"com*endation development activities' The inspectors oOr"r"J portions of emergency preparedness drill 1 1-03 to evaluate the performance of the emergency

'."rpoit" organization and the adequacy of NextEra's post-drill critique.

The inspectors observed emergency response operations in the technical supbort center and emergency operations.facility to determine whether the event classiiication, notifications, and protective action recommendations were performed in accordance with procedures.

The inspectors also attended the station drill critique to .orp"i" inipector observations with those identified by NextEra staff in order to evaluate NextEra's critique and to verify whether the NextEra staff was properly identifying weaknesses and entering them into the corrective action program'b. Findinqs No findings were identified.

.2 Traininq Observations

a. InsPection ScoPe The inspectors observed a drillfrom the control room simulator during licensed operator requalification training on August 8,2011, which required emergency p.lan implementaiion Oy an-operati-on, "i"*. NextEra planned for this evolution to be evaluated "no in"tuo"d in performance indicator data regarding drill-and exercise performance.

The inspectors observed event classification and notification activities performed ov tne tr"*. The inspectors also attended the post-evolution critique for the scenario.

The focus of the inspectors' activities was to note any weaknesses and deficiencie, in tn" crew's performance and ensure that NextEra evaluators noted the same issues and entered them into the corrective action program'b. Findinqs No findings were identified' 15 2. RADIATION SAFETY Cornerstone:

Occupational Radiation Safety 2RSO1 a.(71124.01)

Inspection ScoPe During the period september 12-15, 2011, the inspector conducted the following activities to verify that NextEra was evaluating, monitoring, and controlling radiological hazards for work performed in the on-site calibration facility, a high radiation area (HRA)'lmptementation oi these controls was reviewed against the criteria contained in 10 CFR Part 2O,technical specifications, and the NextEra procedures' Radioloqical Hazards Control and Work Coveraqe The licensee uses a dedicated on-site facility for calibrating radiation monitoring instruments.

Housed in the facility is a Shepherd Model 81 beam irradiator.

The irradiator contains four

(4) Cs-13i sources, having 12mCi, 24Q mCi, 12 Ci' and 400 Ci activities.

The inspector observed the technician implement access controls and pre-operational checks ior using the irradiator.

These controls included: o Obtaining two keys, one to enter the locked, stand-alone, facility (located onsite in the protecied area, in a dedicated, locked fenced area, away from the main buildings)and another to operate the irradiator.

The facility has two separated "L"., the remote operating area and the area where the source is located. tfre OuitOing is classified, and posted, as a "radiological controlled area," thereby requirlng the associated radiation work permit (RWf) .administrative controlsl dosimetry, entry through a turnstile, and frisking for contamination prior to exiting the building'o lmplementing tire HRA contiols for entering the facility.

These included being on the correct R=Wp, having the required dosimetry (alarming and thermoluminescent doslmeter 1tt-O1;, obtaining a pre-entry briefing' and filling out the necessary PaPerwork.. Performing daily iand prior to use) safety checks on the irradiator' These checks included: o Ensure the tower assembly cover is locked closed o Verify that the air compressor is operating properly o Verify that the irradiator operating light is lit when a source is exposed o Ensure that the yellow alert lightis lit when the 12 Ci source is exposed o Ensure that the ied high teveitigfrt is lit when the 400 Ci source is exPosed o Ensure that the source operating light, outside the chamber door (in the separate,operatingroom)illuminateswl.gnanysourceisexposed o Verity inat tire tZ iCi rorr"" drops back into its shielded container and un ulrrr sounds when the photoelectric beam is broken, located at the entrancetotheSourceroom,byanobjectpassingthroughit oVerifythatindividualsfriskbeforeexitingthebuilding 16. Additionally, the inspector verified that semi-annual safety and maintenance checks have been performeJ as required by procedure HD0955'19' entitled "Use of the rvrooer ai SnLpn"rd Beam lrradiator"-and reviewed Condition Reports relatedtoirradiatoroperation/maintenanceissues.

b. Findinqs No findings were identified'

Cornerstone:

Public Radiation Safety 2RSO7 a. Inspection ScoPe During the period september 12-15,2011, the inspector conducted the following activities to verify tnai Nextera imptemlnted the if n4p consistent with the technical specification, uno the off-site dose calculation manual (oDcM) to validate that radioactive effluent releases met the design objectives of Appendix I to 10 cFR Part 50.This inspection activity represents completion of one sample relative to this inspection procedure,completingtheassociatedbienniaIrequirement.

The inspector reviewed the 2009 and 2010 Annual Radiological Environmental operating Reports and the 2010 Annual Land Use Census Report and associated census analysis to verify that the "nuiront"ntal monitoring programs were implemented as required bY the ODCM'Theinspectorwalkeddownfour(ofeight)air.samp.lingstations(Nos'AP-02'AP-03'AP-04 and AP-09), two (of three) ,""*ui"i sampling stations (No' WS-01 and WS-51)' two (of two) tisn sampting stationi (FH-03 anO fH-se), one (of one) milk station (Nos' TM-15), one (of seven) vegetation t-Taiin! ;9q"1 !T91 oi' zz (ot 27) on-site monitorins wells (Nos. BD-1, BD-2,BD 3, BDj: Bb-6, scj' sP-1 sD-2' sD-3' sD-s' sw-s' sw-6, SW-10, BU-10, su-11, BU-11, ilV-1;ilv-2' TW-3 SW-1', SW-2', and sw-3)' two (of three) off-site wells (Nos. wcj3 ano wc-t4) and 14.(of 69) TLD monitoring stations (Nos. TL-1,11--2, ii-+, TL-5, TL-6,it-l,t-b'T!-9' it-tz'tL-13' TL-14'7L-15' TL-16'and TL-32). The inspector oetermineo that sampling was conducted as described in the oDcM ano retaieo pio""outes.

r6e inspector evaluated the sampling equipment material conditions and calibration recoibs, when applicable' The inspector confirmed that the air sampling locations

  • "r"ln "*"t having hign XO and D/Q.wind sectors' and the TLDs were tocJted in areas with the highest potentialfor public radiation exposure'As part of the walk down, the inspector observed the technician collect and prepare for analysis "i, pu.ti"ur"te/iodine filter samples, milk, vegetation and water samples' and verified that environmental sampling was representative of the release pathways' as specified in the ODCM, and that tui..,fting techniques and sample submittalfor analysis were in accordance with procedures' The inspector reviewed the calibration/maintenance records for eight air samplers and verified that the air flow calibration equipment was currently calibrated' 17 Based on direct observation and review of records, the inspector verified that the meteorological instrumentation was operable, calibrated, and maintained in accordance with the guidance contained in the updated final safety analysis report (UFSAR) section 2.3.3.3,$eabrook Station Technical Requirement22 - Meteorological Instrumentation, NRC Regulatory Guides 1.23 Rev. 0 and Regulatory Guide 1.97 Rev. 3, and the associated NexiEra procedures.

The inspector verified that the meteorological data readout and recording instruments in the control room and at the tower were operable for wind direction, wind speed, air temperature, and delta temperature.

The inspector confirmed that redundani instrumentation was available and that the annualized recovery rate for meteorological data was greater than 90 percent.The inspector reviewed condition reports and Nuclear Oversight field observation reports and audits relevant to the REMP requirements, to evaluate the threshold for which issues are entered into the corrective action program, the adequacy of subsequent evaluations, and the effectiveness of the resolution.

The inspector also reviewed monthly radiological effluents technical specification (RETS)/ODCM effluent-occurrence reportsto evalulte the adequacy and timeliness of performance indicator information.

The inspector reviewed the quarterly results of NextEra's inter-laboratory comparison program to verify the accuracy of NextEra's environmental air filter, charcoal cartridge, wat6r, biota, and milk sample analyses.

Additionally, the inspector reviewed the annual quality assurance audit of 'NlexEra's vendor providing environmental analytical services.The inspector reviewed changes made by NextEra to the ODCM as a result of changes to the land use census or sampler station modifications since the last inspection.

The inspector also reviewed technicaljustifications for any change in sampling location (or frequency)and verified NextEra performed the reviews required to ensure that the changes diO not affect its ability to monitor the radiological condition of the environment.

The inspector confirmed that NextEra is implementing an onsite groundwater sampling and monitoring program sufficient to detect leakage from plant systems, structures and components.

lnduled in this review was an evaluation of potential leakage from the storm drain system, spent fuel leak detection, plant drainage system and Waste Liquid Drain and associated leak detection methods.b. Findinqs No findings were identified.

OTHER ACTIVITIES

4OA1 Performance

lndicator verification (8 samples) (71151).1 Barrier lnteqritv Cornerstone a. Inspection ScoPe The inspectors reviewed NextEra's data for the Barrier integrity cornerstone performance indicators (Pl) listed below to verify the accuracy of the information reported to the NRC forihe period covering the fourth quarter of 20]_0 through the third quarter 2011. pl definitions and guidance contained in NEI 99-02, "Regulatory Assessment lndicator Guideline,'iRevision 5, were used to verify the basis for each reported element. The inspectors reviewed licensee event reports (LERs), operating logs, procedures, and interviewed applicable personnel to verify the accuracy and completeness of ihe reported data. 'The inspectors also reviewed the accuracy of the number of critical hours reported.. RCS Leakage o RCS Activity b. Findinqs No findings were identified.

.2 a. Inspection

ScoPe The inspectors reviewed NextEra data for the Mitigating systems performance index Pls listed below to verify the accuracy of the information reported to theNRC for the period covering the fourth quarter of ZOiO through the third quarter 2011. Pl definitions and guidance contained in NEI gg-02, "Regulatory Assessment lndicator Guideline," Revision 5, were used to verify the baiis for reporting each data element' The inspectors reviewed licensee event reports (LERs), operating logs, procedures' and interviewed applicable personnel to verify the accuracy and completeness of the reported data for the following Pls'. High Pressure Injection System MSPI. EmergencY AC SYstem MSPI o Heat Removal SYstem MSPI o Residual Heat Removal System MSPI o Cooling Water SYstem MSPI b. Findinqs No findings were identified.

.3 19 RETS/ODCM

Radioloqical Effluent Occurrences Inspection ScoPe The inspector reviewed relevant effluent release reports for the period August 2010 through August 2011, for issues related to the RETS/ODCM radiological effluent o""uri"nc"6 performance indicator as specified in NEI 99-02. The NEI criteria for reporting data related to this performance indicator includes radiological effluent release occurrences that exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ dose for liquid effluents; Smrads/qtr gamma air dose, 10 mrad/qir beta air dose, and 7'5 mrads/qtr for organ dose for gaseous effluents.

Findinos No findings were identified.

ldentification and Resolution of Problems (71152 - 2samples)Inspection ScoPe As required by lnspection procedu re 71152, "Problem ldentification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that NextEra entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed'aiverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors pe*ormed a daily screening of items entered into the corrective action program and periodically atiended condition report screening meetings'Findinqs No findings were identified.

Inspection ScoPe The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids, disabled alarms, and open main control room deficiencies to identify impacts on emergency operating procedure operator actions, and any impact on mitigating systems performance or iniitiating event frequency' The inspectors evaluated w[etirer station personnel had identified, assessed, and reviewed operator workarounJt "t specified in 'seabrook procedure OP-AA-108, "Oversight and Control of OPerator Burdens'" The inspectors reviewed NextEra's process for identifying, prioritizing and resolving main control room distractions to minimize operator burdens. The inspectors also reviewed the system used to track these issues and recent NextEra self assessments of the progi"t. The inspectors toured the control room and discussed current operator a.b.4c.A2.1 a..2 b.a.

b.20 workarounds with operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

Findinqs and Observations No findings were identified.

The inspectors determined that the issues reviewed did not adversel/affect the capability of the operators to implement abnormal or emergency operating procedures.

The inspectors also determined that NextEra entered operator workarounds and burdens into the corrective action program at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.

.3 b.Inspection

Scope The inspectors reviewed the identification, evaluation, and corrective actions related to NextEra's discovery of degradation in SFP material that affected SFP reactivity and to changes NextEra made to-tne analytical methods it used to analyze reactivity-conditions in tfrJSfp. NextEra's actions for these issues were initiated as a result of a fleet self-assessment documented in AR 222265222265Assessment and Observations No findings were identified.

The inspectors' assessment of NextEra performance relative td identification, evaluation and corrective actions for this issue are discussed below. No immediate criticality safety issues were identified based on the conservative assumptions used in the design analysis and actual degradation observed less than that assumed in the analYses.Effectiveness of Problem ldentification ntrolforthestorageofspentfuelthatwas.consistent with the design "n"lyr"r of record and that fuel was configured in the spent fuel and new fuel vaults in configuration consistent with the established controls.

The administrative controlsirvere based on analytical methods to assure a rack design for criticality control that limits the effective muitiplication factor, k"n, to < 0.95 without credit for soluble boron. NextEra has generated condition reports at a conservative threshold to assure that rack degradation 6onditions were addressed by the corrective action program. ln response-to a fleet self-assessment, NextEra identified the need to update the Seabrook license and design bases for spent fuel storage and took actions to revise UFSAR g.1 and Figure g.1-22io better reflect the analytical methods used to address boral and boraflex degradation, and the administrative controls on fuel placement' Effectiveness of Prioritization and Evaluation of lssues . .degradation mechanisms' NextEra evaluated operating

"*p"ri"n""s at other facilities to identify the potential for further rack degradation at Sea-brook.

NextEra used contracted specialists to monitor rack deiradation and to analyze rack reactivity to assure the criticality analyses bounded the actual condition in the pool. NextEra developed analytical strategies to account for further degradation.

In response to the fleet self-assessment related to the license and design baiis for spent fuel storage, NextEra considered the extent of condition and 21 determined there the sFp issue was unique and that were no other issues involving a nonconservative technical specification or licensing basis.Effectiveness of Corrective Actions ctive actions for monitoring degradation - -mechanisms in spent fuel racks. NextEra actions continued under the Boral Monitoring frogrur to trend the boral conditions in the spent fuel pool' The results reported in the June 2011 Boral Monitoring Report show that boral conditions remain bounded by the aisumption used in the criiicality analysis.

In response to a fleet self-assessment, NextEra issued UFSAR Change Request uFcR 10-026 to revise UFSAR 9'1 and Figure g.1-22to better reflect the analytical methods used to address boral and boraflex Jegradation; and,

(ii) NextEra initiateO a criticality analysis in 2011 to support a new license amendment request'However, prior to the initiatives in 2010, NextEra had not taken timely actions to assure tne iicensing basis remained current wiin tne design basis- Although NextEra made"n"ng", toine SFP design basis in 1998, the UFSAR had not been revised prior to UFCR 10-026 to address-the new administrative controls or reflect the analytical assumptions used related to boraflex neutron absorbtion.

similarly, the fuel placement curves in TS 3.9. 1 3 in effect on september 30, 2011 , reflects the design basis issued as Amendment 6 in 1gg1 . TS 3.g.13 had not been updated to reflect the changes made to the design basis analysis made in 1998 and 2oo2 due to rack degradation, and is nonconservative withiespect to those analyses.

Although NextEra initiated actions to revise the sFp ticensinjbasis via LARs 01--12 and 04-05, NextEra should have taken more timely action p"p i'n" guidance in NRC Administrative Letter 98-10 to address a nonconservative Technical-Specification.

NextEra is addressing this issue by a license amendment requesipianneo'ror submittal in late 2Q11. The inspectors determined that the failure to update in" UfSRn and TS to account for the SFP degradation was not more than minor performance deficiency because, as discussed above' NextEra had initiated administrative controls that ensured that the spent fuel rack condition did not violate technical specification requirements and as such the performance deficiency was not a precursor to a significant event, would not become more significant if left uncorrected and O'O n6t adversely affect a reactor safety cornerstone objective' (71153 - 2 samPle)40A3.1 (closed) LER 05000443/201 1-001 , Noncompliance with Technical specification for Leakage detection Instruments Licensee Event Report 2011-Ol dated May 20, 201 1 reported a determination per 10 cFR b0.73(aX2)iilte)tn"t Seabrook had operated in a condition prohibited by Technical Speciticatioi'r.

fiStl. NextEra deteimined in March 2011 that the containment backup gaseous radiation monitor RM-6548 did not meet the seismic requirements and thus was not qualified for monitoring reactor coolant system pressure boundary leakage per TS limiting conOition for operati6n (LCO) 3'6'!'-1 t.-On. several occasions prior to the discovery of the o"n"iln"y, NextEra relied on RM-6548 to satisfy the TS 9-6,1 1 requirements while the primary r1{i{ion monitor was out of service' RM-6548 was instaled as plant d"tid;h;nge 89DCR046 on February 2, 1990' The radiation monitor design lacked tutt slls"mic quaification because RM-654-8 readouts did not have signal isolators to assure the indications remained functionalfollowing operational basis earthquakes.

ln the Configuration installed per 89DCR046, RM-6548 readouts were 22 susceptible to failures within other monitors or faults on the data loop common to the monitor. Design change EC271B7 0 was implemented on May 1,2011, to upgrade fM-654g by instaliing etecirical signal isolation devices and a seismically qualified RM-23 indicator to control room panel RM-CP-180A' The inspectors reviewed the accuracy of the LER.and verified compliance with the reportability requirements in 10 CFR -SO.Za. This issue was a violation of Seabrook TS LCO 3.4.6.1. The violation was caused by the failure to provide a leakage detection monitor.upubt" of performing its function following an operating basis seismic event'The failure to compiy with thJTS requirements con_stitutes a violation of NRC requirements that is'discussed further in Section

4OA7 of this report. This LER is closed.

.2 The inspectors provided site coverage during one.adverse weather event' The inspectors reviewed NextEra's actiois to protect risk significant systems from Hurricane lrene on nugust Z7-29,2011 . The inspeciion included a review of the status of plant safety and electrical systems, monitoring of site environmental conditions and walk downs of plant areas. The inspectors verified that NextEra responded to the severe weather conditions in accordance with procedure os1200'03, "severe weather Conditions." The inspectors reviewed site conditions and hazards against the emergency plan criteria for classifying events. The storm had no significant impact on the ptant or site. The inspectors revi6wed corrective actions for problems identified during the inipection and examined Next Era's extent of condition review for these issues.4OA5 OtherActivities (60855'1 - 1 sample).1 a. Inspection ScoPe The inspectors reviewed routine operations and monitoring of the ISFSI' The inspectors walked down the ISFSI to evaluate its material condition, performed independent dose rate measurements of the storage modules, and confirmed module temperatures were within the required limits. The iispectors als_oreviewed plant equipment operator logs for ISFSI surveillances and environmental (lSFSl) dosimetry records' Radiological control activities for the ISFSI were evaluated against 10 CFR Parl20,ISFSI Technical Specifications, and NextEra's procedures' b. Findinqs No findings were identified' 4OAO Meetinqs.

lncludinq Exit On Octobe r 10,2ei1, the inspectors presented the results of the third quarter integrated inspections to Mr. P. Freeman and seabrook station staff. The inspectors also confirmed with NextEra that no proprietary information was reviewed by inspectors during the course of the inspection' 23 4C.A7 Licensee-ldentified Violations The following violation of very low safety significance (Green) was identified by NextEra and is a violition of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV.TS LCO 3.4.6.1, "RCS Leakage Detection Systems," requires three leakage detection systems be operable, including a containment sump level monitoring system' a containment atmosphere partilulate radiation monitoring system a1d a containment atmosphere gaseous radiation monitoring system. The TS allow plant operation for up to thirty Oays-witn one leakage detection system inoperable, and requires a plant shutdown in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if more than one leakage detection system is inoperable.

Contrary to the above, Seabrook operated for greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> on October 5, 2010, December 15,2010, January 4, 2011 and March 10, 2011, with both particulate and gaseous radiation monitors inoperable.

On each occasion, RM6548 was credited for RCS teafage detection for more than 6 but less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The finding affected the Initiating Erients cornerstone in that a system used to identify reactor coolant system leakage right not have been functionaifollowing a operational basis earthquake' The backup gas monitor remained functional but lac*ed full qualification, as described in Section +Ong above. This finding is of very low safety significance (Green) per IMC 0609 because the issue did iot result in a total loss of safety function and did not contribute to both a transient initiator and the likelihood that mitigating functions would be unavailable.

Since the issue is of very low safety significance and was entered into the corrective action program as AR 1633042, the issue is considered a licensee-identified, non-cited viola-tion (NCV) consistentwith Section2'3.2'a of the NRC Enforcement PolicY.ATTACHMENTS:

=SUPPLEMENTARY

INFORMATION=

KEY POINTS OF CONTACT

Licensee Personnel

B. Brown, Supervisor, Civil Engineering
V. Brown, Senior Licensing

AnalYst

K. Browne, Plant General Manager
J. Esteves, Plant Engineering
P. Freeman, Site Vice President
P. Gurney, Reactor Engineering

Supervisor

M. Collins, Manager, Design Engineering
L. Hansen, Plant Engineering
P. HarveY, REMP Manager
N. Levesque, Plant Engineering
A. Merrill, Reactor Engineer
M. Nadeau, System Engineer, Control Building Air Handling
M. O'Keefe, Licensing

Manager

D. Perkins, Radiological

Engineer

K. Randall, Reactor Engineer
D. Robinson, ChemistrY

Manager

M. Scannel, Radiological

Engineer

G. Sessler, Plant Engineering
R. Thurlow, Health Physics Supervisor - NU
J. Walsh, Nuclear Steam Supply System, Supervisor
T. Waechter, Assistant

Operations

Manager

B. Woodland, Plant Engineering

Supervisor

Opened/Closed

05000443 12011004-01

NCV

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Closed

05000443/201

001 LER Inadequate

Functionality

Assessment

for Fire Protection

SYstem Noncompliance

with Technical

Specification

for Leakage Detection

lnstruments (Section 4OA3'1 )Attachment

LIST OF DOCUMENTS