IR 05000443/2013005
| ML19205A376 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/24/2019 |
| From: | NRC/OGC |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-443-LA-2, ASLBP 17-953-02-LA-BD01, RAS 55106 | |
| Download: ML19205A376 (35) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC ASLBP No. 17-953-02-LA-BD01 (Seabrook Station, Unit 1)
Hearing Exhibit Exhibit Number: NRC027 Exhibit Title: Letter from Glenn T. Dentel, NRC, to Kevin Walsh, NextEra, Seabrook Station, Unit No. 1 - NRC Integrated Inspection Report 05000443/2013005, (Jan. 30, 2014)
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 30, 2014
SUBJECT:
SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2013005
Dear Mr. Walsh:
On December 31, 2013, 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 January 17, 2014, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection no findings of significance were identified. However, a licensee-identified violation, which was determined to be of very low safety significance, is listed in Section 40A7 of this report. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Seabrook Station.
As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting aspects identified in CY 2014 will be coded under the latest revision to IMC 0310. Cross-cutting aspects identified in the last six months of 2013 using the previous terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the CY 2014 mid-cycle assessment review. In accordance with 10 Code of Federal Regulations (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 50-443 License No: NPF-86
Enclosure:
Inspection Report No. 05000443/2013005 w/ Attachment: Supplemental Information
REGION I==
Docket No.: 50-443 License No.: NPF-86 Report No.: 05000443/2013005 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No.1 Location: Seabrook, New Hampshire 03874 Dates: October 1, 2013 through December 31, 2013 Inspectors: P. Cataldo, Senior Resident Inspector C. Newport, Resident Inspector W. Cook, Senior Reactor Analyst B. Dionne, Senior Health Physicist J. Gilliam, Acting Resident Inspector D. Silk, Senior Operations Engineer Approved by: Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY
IR 05000443/2013005; 10/01/2013-12/31/2013; Seabrook Station, Unit No. 1, Routine
Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
No findings were identified.
Other Findings
A violation of very low safety significance that was identified by NextEra was reviewed by the inspectors. Corrective actions taken or planned by NextEra have been entered into NextEras corrective action program (CAP). This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Seabrook operated at full power for the entire assessment period, with the exception of minor down powers to perform scheduled turbine valve testing. Documents reviewed for each section of this inspection report are listed in the Attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of NextEras readiness for the onset of seasonal cold temperatures on November 18, 2013. The review focused on the emergency feedwater pump house, turbine building, and the service water (SW) cooling tower. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), the seasonal readiness memorandum, and the corrective action program (CAP)to determine specific temperatures or other seasonal weather that could challenge these systems, and to ensure NextEra personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including NextEras seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.
b. Findings
No findings were identified.
.2 External Flooding
a. Inspection Scope
During the week of December 16, 2013, the inspectors performed an inspection of selected external flood protection measures for Seabrook Station. The inspectors reviewed TSs, procedures, design documents, and the UFSAR, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of external areas of the plant, including the diesel generator building, turbine building, and primary auxiliary building, to ensure that NextEras flood protection measures were in accordance with design specifications. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if NextEra had established adequate measures to protect against external flooding events.
b. Findings
No findings were identified.
.3 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed NextEras preparations for the onset of cold weather and high winds on November 26, 2013. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the emergency feedwater pump house and the SW cooling tower to ensure system availability. The inspectors verified that operator actions defined in NextEras adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Equipment alignment of Vital Bus 11A while 11B was cross-tied to battery D and battery B was out of service on October 2, 2013 B residual heat removal (RHR) return to service (RTS) on November 27, 2013 A emergency diesel generator (EDG) jacket water heat exchanger SW outlet valve RTS on December 11, 2013 A SW during replacement of the C SW pump motor on December 13, 2013 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether NextEra staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 2 samples)
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 verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
'A' EDG DG-F-1A-A, DG-F-2A-A, DG-F-3E-A, DG-F-3C-A, DG-F-3A-Z on November 14, 2013 Primary Auxiliary Building (PAB) F-1A-Z 7'/-6'/-26' on November 20, 2013
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if NextEra identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the internal tank farm area of the PAB to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the A EDG jacket water heat exchanger to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified NextEras commitments to NRC Generic Letter 89-13. The inspectors observed actual performance tests for the heat exchangers and/or reviewed the results of previous inspections of the A EDG jacket water and similar heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that NextEra initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on October 23, 2013, which included simulated degraded equipment and subsequent equipment failures that resulted in escalating degraded plant conditions that ensured implementation of emergency operating procedures by the operating crew, as well as implementation of the emergency plan. This emergency plan implementation included classification of specific events that warranted an Alert Event Declaration. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the 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 technical specification action statements entered by the control room supervisor.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed general control room activities, including alarm response and control room shift turnovers, conducted on November 9, 2013 and December 23, 2013.
Additionally, the inspectors observed monthly surveillance testing of the B EDG conducted on November 12, 2013 and December 23, 2013. The inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
.3 Licensed Operator Requalification Biennial Review
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, and Inspection Procedure Attachment 71111.11B, Licensed Operator Requalification Program.
Examination Results The operating tests for the weeks of October 21, 2013 and October 28, 2013 were reviewed for quality and performance.
On December 6, 2013 the results of the annual operating tests were reviewed to determine if pass fail rates were consistent with the guidance of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process. The review verified that the failure rate (individual or crew) did not exceed 20%.
1 out of 53 operators failed at least one section of the Annual Examination. The overall individual failure rate was 1.9%.
0 out of 9 crews failed the simulator test. The crew failure rate was 0.0%.
Written Examination Quality The inspectors reviewed two written examinations that were administered during the weeks of October 21 and 28, 2013, for qualitative and quantitative attributes as specified in Appendix B of Attachment 71111.11B, Licensed Operator Requalification.
Operating Test Quality Twenty-two job performance measures (JPMs) and six scenarios were reviewed for qualitative and quantitative attributes as specified in Appendix C of 71111.11B, Licensed Operator Requalification Program.
Licensee Administration of Operating Tests The dynamic simulator examinations and JPMs administered during the week of October 28, 2013, were observed. These observations included facility evaluations of Shift Crew A and Staff Crew 1 during three dynamic simulator examinations and individual performance of five JPMs.
Examination Security The inspector assessed whether facility staff properly safeguarded examination material.
JPMs, scenarios, and written examinations were checked for excessive overlap of test items.
Remedial Training and Re-Examinations The remediation plans for one crew failure and one individual JPM failure from the 2011 requalification examination were reviewed to assess the effectiveness of the remedial training.
Conformance with Operator License Conditions Medical records for ten license holders were reviewed to assess conformance with license conditions.
Proficiency watch standing records were reviewed for the third quarter of 2013.
The reactivation plans for five senior reactor operator license holders and three reactor operator license holders were reviewed to assess the effectiveness of the reactivation process.
Simulator Performance Simulator performance and fidelity was reviewed for conformance to the reference plant control room. A simulator deficiency report was also reviewed to ensure facility staff addressed identified modeling problems. Simulator test documentation was also reviewed.
Problem Identification and Resolution A review was conducted of recent operating history documentation found in inspection reports, NextEras CAP, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from the CAP which indicated possible training deficiencies, to verify that they had been appropriately addressed. The senior resident inspector was consulted for insights regarding licensed operators performance.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that NextEra was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and verified that the (a)(2)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 (a)(2). Additionally, the inspectors ensured that NextEra staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.
Chemical and volume control system Evaluation of stroke time changes on EDG SW heat exchanger outlet isolation valve, SW-V-16 Evaluation of EDG entry fire door latch failures
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. 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 the appropriate risk assessments prior to removing equipment for work. The inspectors selected 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 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When NextEra performed emergent work, the 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 stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Battery cross-tie on October 7, 2013 B RHR pump slave relay testing on November 26, 2013 Chemical volume and control system surveillance testing and SW system maintenance on December 10, 2013 Safety Bus 5 degraded voltage relay testing and charging system maintenance on December 13, 2013
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Operability of 1B 125 VDC battery on October 3, 2012 Cooling tower SW pump P-110A oil fill cap found ajar on October 22, 2013 Refueling water storage tank aligned to a not fully qualified seismic pipe on November 8, 2013 SW-P-41A in-service test flow band incorrect on November 13, 2013 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 properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to NextEras 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.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, as applicable, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
1-RC-TB-451 temporary setpoint change for a pressurizer low temperature alarm Engineering change (EC) 278785, SW pipe support modification in support of OR16
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
The inspectors evaluated the permanent modifications listed below, and verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modifications. In addition, the inspectors reviewed applicable modification documents, including associated engineering changes, correspondence with the vendor, industry operating experience, environmental and seismic qualifications, as well as the 10 CFR 50.59 documentation and post-modification testing results, as applicable.
EC 274301, Emergency Power System power supply overvoltage protection EC 271074, replacement of GE synchronization check relay
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, 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.
1-RH-FCV-618 positioner replacement on October 16, 2013 Loop B SW basin level indicator calibration on October 31, 2013 1C battery charger maintenance and RTS on November 22, 2013 A EDG SW heat exchanger isolation valve maintenance on November 22, 2013 Primary air handler damper actuator rebuild on November 26, 2013
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and NextEra procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy 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 the required safety functions. The inspectors reviewed the following surveillance tests:
A SW discharge valve quarterly in-service surveillance test (IST) on October 17, 2013 (IST)
Reactor coolant system (RCS) leak rate surveillance test on October 24, 2013 (RCS leak rate)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine NextEra emergency drill on October 9, 2013 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by NextEra staff in order to evaluate NextEras critique and to verify whether NextEra staff was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
During the period December 2 to December 5, 2013, the inspectors verified that gaseous and liquid effluent processing systems are maintained so radioactive discharges are properly reduced, monitored, and released. The inspectors also verified the accuracy of the calculations for effluent releases and public doses.
The inspectors used the requirements in 10 CFR Part 20; 10 CFR 50.35(a) TSs; 10 CFR Part 50 Appendix A - Criterion 60 Control of Release of Radioactivity to the Environment and Criterion 64 Monitoring Radioactive Releases; 10 CFR 50 Appendix I Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion As Low as is Reasonably Achievable (ALARA) for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 10 CFR 50.75(g) Reporting and Recordkeeping for Decommissioning Planning; 40 CFR Part 141 Maximum Contaminant Levels for Radionuclides; 40 CFR Part 190 Environmental Radiation Protection Standards for Nuclear Power Operations; RG 1.109 Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents; RG 1.21 Measuring, Evaluating, Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste; RG 4.1 Radiological Environmental Monitoring for Nuclear Power Plants; RG 4.15 Quality Assurance for Radiological Monitoring Programs; NUREG 1301 Offsite Dose Calculation Manual (ODCM) Guidance: Standard Radiological Effluent Controls; applicable Industry standards; and licensee procedures required by TSs/ODCM as criteria for determining compliance.
The inspectors observed the collection and preparation of one environmental sample from an on-site groundwater monitoring well. The inspectors selected two SSCs (storm drains and spent fuel leak detection system) that could interface with ground water. The inspectors assessed whether NextEra has implemented a sampling and monitoring program sufficient to provide early detection of leakage from these SSCs to ground water.
The inspectors reviewed any significant changes made by NextEra to the ODCM as the result of changes to the land census, long-term meteorological conditions (three year average), or modifications to the sampler stations since the last inspection. The inspectors reviewed technical justifications for any changed sampling locations to verify that NextEra performed the required reviews.
The inspectors reviewed the results of the NextEra Analytical Laboratory vendors inter-laboratory and intra-laboratory comparison program to verify the adequacy of environmental sample analyses performed by the vendor laboratory. The inspectors assessed whether the results included the media/radionuclide mix were appropriate for the facility.
Problem Identification and Resolution Inspectors assessed whether problems associated with the effluent monitoring and control program are being identified by NextEra at an appropriate threshold and are properly addressed for resolution in the CAP. In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented. One corrective action involving the Groundwater Protection Program (GWPP) was not completed in a timely manner and is described in Section 4OA5 of this report.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program
a. Inspection Scope
During the period December 2 to December 5, 2013, the inspectors verified that the radiological environmental monitoring program (REMP) quantifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program.
The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50 Appendix A Criterion 60 - Control of Release of Radioactivity to the Environment; 10 CFR 50 Appendix I Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion ALARA for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 40 CFR Part 190 Environmental Radiation Protection Standards for Nuclear Power Operations; 40 CFR Part 141 Maximum Contaminant Levels for Radionuclides; the guidance in RGs 1.23 Meteorological Measurements Program for Nuclear Power Plants, RG 4.1 Radiological Environmental Monitoring Programs for Nuclear Power Plants; RG 4.15 Quality Assurance for Radiological Monitoring Programs; NUREG 1301 ODCM Guidance: Standard Radiological Effluent Controls; applicable industry standards; and licensee procedures as criteria for determining compliance.
The inspectors determined if NextEra has made significant changes to their effluent release points.
Records of any abnormal gaseous or liquid tank discharges were reviewed to ensure the abnormal discharges were monitored by the discharge point effluent monitor. When discharges were made with inoperable effluent radiation monitors, or if unmonitored leakage occurred, the inspectors ensured that an evaluation was performed, as required.
For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors ensured that an evaluation was performed to determine the type and amount of radioactive material that was discharged. The inspectors verified that surveys were performed to include consideration of hard-to-detect radionuclides. The inspectors determined whether or not NextEra had completed offsite notifications (State, local, and if appropriate, the NRC), as provided in the Groundwater Protection Initiatives implementing procedures.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Safety System Functional Failures (1 sample)
a. Inspection Scope
The inspectors sampled NextEras submittals for the Safety System Functional Failures performance indicator (PI) for the period of October 1, 2012 to September 30, 2013. To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73. The inspectors reviewed NextEras MR records, maintenance WOs, CRs, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index (2 samples)
a. Inspection Scope
The inspectors reviewed NextEras submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2012 to September 30, 2013:
Residual heat removal system (MS09)
MSPI cooling water system (MS10)
To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed NextEras condition reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
During the period of December 2 to December 5, 2013, the inspectors sampled NextEras submittals for the occupational exposure control effectiveness PI for the period of the fourth quarter 2012 through the third quarter 2013. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the PI data reported.
To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with radiation protection staff, the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed condition reports, electronic personal dosimetry dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences.
b. Findings
No findings were identified.
.4 Radiological Effluent Occurrences (1 sample)
Inspection Scope During the period of December 2 to December 5, 2013, the inspectors sampled NextEras submittals for the radiological effluent TS/ODCM radiological effluent occurrences PI for the period from the fourth quarter 2012 through the third quarter 2013. The inspectors used PI definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, to determine the accuracy of the PI data reported.
The inspectors reviewed NextEras corrective action report database and selected individual reports generated since this indicator was last reviewed, to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors also reviewed NextEras methods for quantifying gaseous and liquid effluents and determining effluent dose.
Findings No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that NextEra entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Review of Corrective Actions for Alkali-Silica Reaction Affected
Structures
a. Inspection Scope
Between November 12 to November 14, 2013, NRC inspectors from Region I and a reactor engineer from the Division of License Renewal, NRR, witnessed testing conducted at the Ferguson Structural Engineering Laboratory (FSEL) at the University of Texas - Austin in support of the Seabrook Alkali-Silica Reaction (ASR) Project Corrective Action Plan. Specifically, the inspectors witnessed strength testing of anchor bolts in a large-scale ASR-affected concrete specimen performed in accordance with MPR Anchor Testing Procedure 09, Conduct Unconfined Tension Test on Expansion Anchors.
The inspectors also observed installation of a number of anchor bolts conducted in accordance with MPR Anchor Testing Procedure 03, Install Hilti Kwik Bolt Expansion Anchors, and Procedure 12, Install Drillco Maxi-Bolt Undercut Anchors. Following the completion of anchor bolt testing, the inspectors witnessed the cutting of large-scale anchor test specimen AN-02 into four sections to investigate the depth/progression of observed bifurcation cracking induced by ASR expansion.
During the week of November 18, 2013, inspectors were on-site to review the results of the June 2013 Combined Crack Indexing (CCI) measurements. Inspectors reviewed and discussed with the responsible Seabrook engineers the collected data and engineering evaluations associated with the June 2012 six-month interval monitoring results. Data sheets and associated records are attachments to internal Seabrook document Foreign Print (FP) 100831, Revision 0, ASR Expansion Measurements.
b. Findings and Observations
No findings were identified.
The inspectors observed proper procedural adherence and appropriate quality assurance oversight of testing conducted at the FSEL facility. Testing was performed by graduate students and supervised by a UT-Austin research assistant. Quality control engineering oversight was performed by an MPR project engineer responsible for 10 CFR 50, Appendix B, implementation and periodic audits and assessments of testing activities. The inspectors witnessed formal communications and independent reader/verifier and performer coordination by testing personnel. All test results were electronically recorded and overseen by FSEL and MPR supervisory personnel.
The preliminary results of this first stage of ASR-affected specimen anchor testing (ASR-affected specimens fabricated on May 24, 2012 and displaying CCIs values of between 1.0 and 1.31 mm/m) identified no significant degradation from the control anchor test results taken in November 2012, on specimen AN-07. Segmentation of anchor test specimen AN-02, which was performed to investigate the depth of the bifurcation cracking, identified that the surface cracks terminated approximately 8-9 inches into the specimen. In discussions with NextEra staff, inspectors determined that the bifurcation cracking was not unanticipated, based upon the specimen design (absence of through-wall steel bar reinforcements/stirrups). However, inspectors determined that the growth and depth of these types of surface cracks will continue to be monitored by NextEra for both impact on test specimen performance and possible implications for Seabrook Station ASR-affected structures.
The June 2013 CCI data analysis and conclusions are summarized in FP 100831 and below:
416 of 445 measurement lines (93%) show crack length changes of 0.002 inch or less compared to baseline measurements.
17 (3%) show length changes of 0.003 inch (5 vertical and 4 horizontal on exterior surfaces, 8 vertical on interior wall locations.
9 (1.6%) measurements show length changes of 0.004 inch or greater (3 vertical and 1 horizontal exterior and 4 vertical on interior walls.
The average maximum expansion of 0.02% or less (from the baseline measurement, using the combined crack index) represents 1/10th of 0.20% strain value associated with published expansion strain limits for a typical concrete structures.
3 measurement lines show length changes of contraction between 0.007 and 0.008 inch compared to the baseline. The negative change measurements appear to be the result of gage pin displacement.
Based upon the above data analysis, NextEra staff concluded: 1) no significant changes have occurred in the 26 monitored locations after 18 months of data collection; 2) the type of structure on site does not significantly impact the observed variations in measured expansion; 3) thermal effects on seasonal measurements are noticeable; and 4) continued monitoring is warranted to assess trends.
Inspector review of the data identified no additional issues or concerns. As noted in FP100831, based upon examination of eight new locations under the Phase 3 ASR walkdowns, four new locations were added to the six-month CCI monitoring program due to CCI values exceeding the 1.0 mm/m threshold. In accordance with the Structures Monitoring Program, EDS 36180, Revision 4, these four locations will require a structural evaluation to assess available margin.
.3 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by NextEra outside of the CAP, such as trend reports, PIs, major equipment problem lists, system health reports, MR assessments, and maintenance or CAP backlogs. The inspectors also reviewed NextEras CAP database for the third and fourth quarters of 2013 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report review (Section 4OA2.1). The inspectors reviewed NextEras quarterly trend report for the third quarter of 2013, and selected departmental reports conducted under procedure PI-AA-207-1000, Station Self-Evaluation and Trending Analysis, Revision 0, to verify that NextEra personnel were appropriately evaluating and trending adverse conditions in accordance with this and other applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of departments that provide input into the quarterly trend reports, which included maintenance and engineering departments. This review included a sample of issues and events that occurred over the course of the past two quarters to objectively determine whether issues were appropriately determined to be newly identified as open or continued to be tracked as open adverse trends, potential adverse trends, or management awareness areas. The inspectors verified that these issues were addressed within the scope of the CAP, or through department review and documentation in the quarterly trend report for overall assessment. For example, the inspectors noted that consistent with the occurrence of a significant service water leak in the third quarter associated with Strainer No. 11, NextEra had appropriately identified this issue under the degraded component section of the trend report based on exceeding a statistical control threshold. However, the inspectors noted that other NextEra processes had captured the underlying issues related to service water system challenges including associated corrective actions, and was therefore consistent with the trend report not warranting additional evaluation.
Additionally, based on previous issues that had been identified and tracked in the corrective action database, the inspectors noted an apparent trend in procedure use and adherence. More importantly, NextEra had appropriately captured the increase in human performance issues associated with procedure use and adherence as a potential adverse trend in their trending analysis report for increased attention.
.4 Annual Sample: Follow-up of Corrective Actions for the Loss of Bus 5 during OR15
a. Inspection Scope
The inspectors performed an in-depth review of NextEras root cause analysis and corrective actions associated with condition report AR 1808492, loss of Bus 5 during clearance, which occurred during refueling outage OR15, in October 2012.
The inspectors assessed NextEras problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether NextEra personnel were appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of PI-AA-205, Condition Evaluation and Corrective Action and 10 CFR 50, Appendix B.
b. Findings and Observations
No findings were identified.
The inspectors reviewed selected CAP records and did not identify any additional issues. The inspectors determined NextEras overall response to the issue was commensurate with the safety significance, was generally timely, and included appropriate compensatory actions. The inspectors determined that the actions taken were reasonable to resolve both the initial clearance deficiencies and subsequent loss of emergency response communication data due to other unrelated failures that occurred due to the loss of safety Bus 5.
Additionally, the inspectors noted that NextEras quarterly trend reports have captured adverse trending related to clearance requests. This identification, as evidenced by exceeding a statistical threshold of condition reports associated with clearance requests throughout 2013, resulted in additional assessment within the CAP and the station trending program. The inspectors verified the additional corrective action reviews were appropriate for the circumstances to address the specific adverse conditions associated with the tagging and clearance deficiencies identified by NextEra personnel. The inspectors verified that the issues that caused the identification of the adverse trend associated with clearance requests, were not related to the original cause of the loss of safety Bus 5, and did not invalidate the corrective actions implemented to prevent recurrence.
4OA5 Other Activities
.1 Operational Safety Review Team (OSART) Report Review
a. Inspection Scope
The inspectors reviewed the final report of the International Atomic Energy Agencys OSART follow-up visit to Seabrook Station that occurred on June 3 to June 7, 2013.
The June 2013 visit was the follow-up assessment from the original review of Seabrook that was conducted in June 2011. The inspectors reviewed this report to ensure that any issues identified were consistent with NRC perspectives of NextEra performance and to determine if the OSART team identified any significant safety issues that required further NRC follow-up under the Reactor Oversight Process.
b. Findings
No findings were identified.
.2 Groundwater Protection Initiative (GPI)
a. Inspection Scope
The inspectors reviewed reported groundwater monitoring results and changes to NextEras written program for identifying and controlling contaminated spills/leaks to groundwater to determine if NextEra has implemented the GPI as intended.
b. Findings and Observations
No Findings were identified.
One observation was identified concerning compliance with the voluntary Nuclear Energy Institute GPI.
NEI 07-07 Industry Initiative Groundwater Protection Program dated August 2007 contains an acceptance criteria 1.1.e which states UFSAR to be updated with information from Hydrological Investigation Report. NextEras Fleet procedure EV-AA-100-1001 step 4.2 2.B c requires that Each site shall ensure that the Updated Safety Analysis Report is in agreement with the characteristics of the site hydrology and geology. (NEI 07-07 1.1 e). NextEra updated the Seabrook Station Groundwater Completion Report on August 22, 2012. A subsequent review was performed of the Hydrological Investigation Report and it was determined by the licensee that an update to UFSAR was needed. No update to the UFSAR has been performed (AR 01924442).
This issue is considered minor as it does not affect safety-related SSCs nor impact any radiological monitoring requirements.
4OA6 Meetings, Including Exit
On January 17, 2014, the inspectors presented the inspection results to Mr. Kevin Walsh, Site Vice President, and other members of the Seabrook Station staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee-Identified Violation
The following violation of very low safety significance (Green) was identified by NextEra and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV.
10 CFR Part 50.65, paragraph a(4), Requirement for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, states, in part, that the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. NextEra procedure WM 10.1. On-Line Maintenance, Section 3.3.1, requires that an evaluation of the risk impact of planned maintenance tasks be performed. Contrary to the above, on September 24, 2012, NextEra failed to adequately assess and manage the impact to plant risk during a planned maintenance activity. Specifically, NextEra identified during internal reviews that they had failed to recognize an elevated online maintenance risk level (Yellow)during the performance of the 1-EDE-B-1-B Battery Service Test due to incorrect coding in NextEras PRAX risk model program. The inspectors determined NextEras failure to assess and manage risk during the period when the Battery Service Test was reasonably within NextEras ability to foresee and correct, and was identified as a performance deficiency. This performance deficiency is more than minor, and considered a finding, because it is associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because this finding represents a violation of 10 CFR Part 50.65 Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Section a(4), the inspectors used IMC 0609, Appendix K, Flowchart 1 Assessment of Risk Deficit, to analyze the finding. The regional Senior Reactor Analyst determined the incremental core damage probability (ICDP) for the surveillance period (~5-10 minutes) to be several orders of magnitude below the 1E-6 threshold due to the short duration of the systems unavailability. As this finding is not related to Risk Management Actions only, and the ICDP Risk Deficit is not >1E-6, the inspectors determined that the finding is of very low safety significance (Green). The issue was entered into NextEras CAP as AR 1906782.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- K. Walsh, Site Vice President
- T. Vehec, Plant General Manager
- V. Brown, Senior Licensing Engineer
- M. Chevalier, Radiation Protection Supervisor
- J. Connolly, Site Engineering Director
- K. Douglas, Maintenance Director
- P. Dullea, Principal Chemist Specialist
- D. Flahardy, Radiation Protection Manager
- A. Giotas, Chemistry Specialist
- M. Lake, Chemistry Technician
- M. Leone, Operations Training Supervisor - Continuing
- M. Ossing, Licensing Manager
- V. Pascucci, Nuclear Oversight Manager
- D. Robinson, Chemistry Manager
- D. Strands, Chemistry Supervisor
- M. Strum, Principal Radiological Engineer, AREVA
- S. Wellhoffer, Nurse Manager RN
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
None