IR 05000443/2020003

Integrated International Report 05000443/2020003

ML20308A232
Person / Time
Site:	Seabrook
Issue date:	11/05/2020
From:	Brice Bickett Reactor Projects Branch 3
To:	Moul D Florida Power & Light Co, NextEra Energy Seabrook
References
IR 2020003
Download: ML20308A232 (15)

Text

November 5, 2020

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - INTEGRATED INSPECTION REPORT 05000443/2020003

Dear Mr. Moul:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. On October 29, 2020, the NRC inspectors discussed the results of this inspection with Mr. Eric McCartney, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

Signed by: NRC-PIV

Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects

Docket No. 05000443 License No. NPF-86

Enclosure:

As stated

Inspection Report

Docket Number:

05000443

License Number:

NPF-86

Report Number:

05000443/2020003

Licensee:

NextEra Energy Seabrook, LLC

Facility:

Seabrook Station, Unit No. 1

Location:

Seabrook, New Hampshire

Inspection Dates:

July 01, 2020 to September 30, 2020

Inspectors:

P. Cataldo, Senior Reactor Inspector

T. Daun, Resident Inspector

B. Fuller, Senior Operations Engineer

S. Wilson, Senior Health Physicist

Approved By:

Brice A. Bickett, Chief

Reactor Projects Branch 3

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Seabrook Station, Unit No. 1, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Seabrook Station began the inspection period operating at 100 percent rated thermal power. There were no operational power changes of regulatory significance for the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment were consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on September 3

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1)

'A' train cooling tower while 'B' train actuation tagged out for acceptance time testing on July 8 (2)

'B' train cooling tower service water during 'A' train maintenance on July 13 (3)

'A' emergency diesel generator during 'B' emergency diesel generator maintenance outage on July 27 and 28

(4) Motor-driven emergency feedwater pump during maintenance on the steam-driven emergency feedwater pump on August 31

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) 'A' vital DC electrical distribution on September 3

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1)

'A' train Motor Control Center Room (SW-F-1B-A) on August 27 (2)

'B' train Motor Control Center Room (SW-F-1C-A) on August 27

(3) Service Water Pump Room (SW-F-1E-Z) on August 27

(4) Emergency Feedwater Pump House (EFP-F-1-A) on September 23 (5)

'A' train Battery Room 1A/1C (CD-F-1D-A/CB-F-1E-A) on September 24

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Control building cable spreading room on September 30

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed-operator performance of the following activities in the control room:

• Alarm response, control room logs and 3-point communications on July 7

'B' emergency diesel generator unloading, breaker opening, and shutdown during monthly surveillance testing on July 27

• Power reduction and turbine valve testing on September 26

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed-operator requalification examination conducted in the plant-reference simulator on July 27

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Inspection of seismic gap seal and review of alkali-silica reaction activities in accordance with the Structures Monitoring Program during the weeks of August 24 and August 31

(2) MS-V-394, 'B' steam generator supply to emergency feedwater pump turbine stroke time trending on September 16

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Emergency diesel generator air start distribution filter element replacement using Loctite 242 for retaining tie-rod threaded ends under WO40689582 on September 24

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Elevated risk during 'B' emergency diesel generator maintenance the week of July 27

(2) Elevated risk due to adverse weather grid conditions and non-performance of emergency diesel generator surveillance on August 10

(3) Elevated risk during supplemental emergency power source generator maintenance and switchyard work on August 17 and 18

(4) Elevated risk during switchyard activities and maintenance affecting the steam-driven emergency feedwater pump on August 31

(5) Emergent work control associated with troubleshooting activity on the 'A' emergency diesel generator following the monthly surveillance on September 14

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1)1B inverter with normal alternating current supply isolated on July 29 (AR2363727)

(2) Non-conforming component installed on 'B' emergency diesel generator during the week of August 6 (AR2359595)

(3) Alkali silica reaction effects on containment isolation valve SB-V-10 identified on August 10 (AR2364917)

(4) MS-V-394, 'B' steam generator supply to emergency feedwater pump on September 8 (AR2360223)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Supplemental emergency power system exhaust modifications including rain shield and silencer (EC29053) on September 28

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (10 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1)

'B' train cooling tower actuation logic testing following relay acceptance testing on July 8

(2) P-505 high pressure retest of turbine impulse chamber pressure following circuit board replacement on July 17 (3)

'A' steam generator pressure channel, PT-515A, circuit card replacement during the week of July 20

(4) Cooling tower makeup pump semi-annual performance run following maintenance on July 22 (5)

'B' emergency diesel generator following maintenance on July 29

(6) Control room/cable spreading room penetration seal following breach and repair on August 10 and 11

(7) Motor operated valve, SW-V-2, following motor replacement on August 13

(8) Supplemental emergency power system following annual maintenance window on August 19

(9) Cooling tower service water pump P-110B following preventive maintenance on August 25

(10) Main steam supply valve to steam-driven emergency feedwater pump following maintenance and repair on August 31

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1)

'B' train cooling tower actuation timing relay acceptance testing on July 8 (2)

'B' train safety injection in-service leakage testing on July 8

(3) Nuclear instrumentation power range channel 42 calibration on August 13 (4)

'A' emergency diesel generator monthly slow start on September 15

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Turbine driven emergency feedwater pump surveillance on September 23

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

(1) The emergency planning aspects of a licensed-operator simulator evaluation was conducted in the plant-reference simulator on July 27. This evaluation included the initiating conditions that resulted in associated emergency classification and notifications in accordance with NextEra's emergency plan.

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

The inspectors evaluated the licensee's radiological hazard assessment program. The following observations were conducted:

(1) Observed the radioactive materials areas at the site including the waste processing area and radioactive materials storage areas

Instructions to Workers (IP Section 03.02) (1 Sample)

The inspectors evaluated radiological protection-related instructions to plant workers. The following observations were conducted:

(1) Pre-job briefing for spent resin transfer; instructions to workers in radiation work permits, pre-job briefings and in-plant signage

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. The following evaluations were conducted:

(1) Observed licensee surveys of potentially contaminated material leaving the radiological control area

(2) Observed workers using personnel contamination monitors when exiting the radiological control area

Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities. The following evaluations were conducted:

(1) Reviewed radiation work permits for spent resin transfers; Significant dose rates occur during spent resin transfers

(2) Verified radiological postings and radiological conditions in both the radiological control area and in unrestricted areas

(3) Observed the licensee's control of highly radioactive components and other items in the spent fuel pool

(4) Observed radiological surveys in 'A' residual heat removal room

(5) Observed radiological surveys and work coverage in the diesel generator building during calibration of radiation detector RM-6507-A (control room west air intake radiation monitor)

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of High Radiation Areas and Very High Radiation Areas. The following evaluations were conducted:

(1) Observed high radiation area controls and verified those controls were effective, and secured when required

(2) Observed the licensee's control of high radiation area keys

(3) Observed the licensee's positive control of the radiation instrument calibrator (locked high radiation area when source exposed)

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician proficiency in the following situations:

(1) Observed radiation workers wearing dosimetry and observing radiation work permit requirements during calibration of the west control room air intake radiation monitor calibration (RM-6507-A)

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Fuel storage building

(2) Control room

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Observed condition and storage of temporary ventilation systems and portable vacuum cleaners. Temporary ventilation systems were not in use at the time of the inspection

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

The inspectors observed the use of respiratory protection devices.

(1) Observed the storage of respiratory protection devices ready for issue

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

(1) Observed availability of control room self-contained breathing apparatus, spare air bottles, and masks; verified respirator qualifications of all operators on-shift

71124.04 - Occupational Dose Assessment

The inspectors evaluated the licensee's occupational dose assessment program.

Source Term Characterization (IP Section 03.01)

The inspector's observations included:

(1) Review of the licensee's evaluation of radioactive source term and adequacy of dosimetry

External Dosimetry (IP Section 03.02) (1 Sample)

The inspectors verified the licensee processes, stores and uses external dosimetry such that assigned occupational doses are representative of actual plant exposures. Observations included:

(1) Storage of external dosimetry and method of multi-pack dosimetry evaluations

Internal Dosimetry (IP Section 03.03) (1 Partial)

The inspectors evaluated the following internal dose assessments for actual internal exposures:

(1)

(Partial)

Reviewed and discussed the licensees sample collection procedures for in-vitro bioassays

71124.05 - Radiation Monitoring Instrumentation

The inspectors evaluated the licensee's radiation monitoring instrument program.

Walkdowns and Observations (IP Section 03.01)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Area radiation monitors in the auxiliary building

(2) Portable ion chambers, telepoles, and AMP-100 instruments ready for use

(3) Portable friskers used at the exit to the radiologically controlled area

(4) Ion chambers in use in the auxiliary and diesel generator buildings (5)gaseous monitors for steam generator blowdown

(6) Remote gaseous and particulate monitors for containment building air

(7) Main stack gaseous and particulate monitors

(8) Post-accident liquid sampling station

Calibration and Testing Program (IP Section 03.02) (15 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Eberline AMS-4, Serial Number 4741

(2) Eberline AMS-4, Serial Number 4739

(3) Mirion AMP-200, Serial Number 7702-001

(4) Mirion AMP-200, Serial Number 7702-027

(5) Eberline RM-14, Serial Number 7692

(6) Eberline RM-14, Serial Number 7657

(7) Mirion Telepole, Serial Number 6606-017

(8) Mirion Telepole, Serial Number 6605-102

(9) Eberline RO-7, Serial Number 562

(10) Eberline RO2/E, Serial Number 5611

(11) Mirion AMP-100, Serial Number 5099-090

(12) Mirion AMP-100, Serial Number 5006-042

(13) Eberline RO-20, Serial Number 203658

(14) Eberline RO-2A/E, Serial Number 3926

(15) Ludlum M177, Serial Number 296004

Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Auxiliary building continuous air monitor RX6592-2 particulate channel

(2) Control room west air intake ventilation radiation monitor R-6507-A calibration

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) For the period July 1, 2019 through June 30, 2020

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) For the period July 1, 2019 through June 30, 2020

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) For the period July 1, 2019 through June 30, 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Negative trend identified with inadequate post-maintenance testing/planning following routine maintenance (AR2337625, AR2250680)

(2) Corrective actions to address licensed operator performance during rod drop event and manual reactor trip on June 6 (AR 2358122, AR 2358982)

INSPECTION RESULTS

Observation: Negative Trend Identified with Inadequate Post Maintenance Testing/Planning Following Maintenance 71152 The inspectors performed a review of a negative trend identified in post maintenance testing inadequacies identified in December 2019 (AR2337625). Inspectors previously identified two instances of work orders where the scope of the post-maintenance testing did not appropriately capture the scope of work performed. The inspectors identified these inadequacies prior to the equipment being returned to service and NextEra modified the work orders to include testing that was appropriate to the maintenance conducted. These instances were captured in AR2334742 and AR2334764. The inspectors reviewed NextEras evaluation related to this negative trend. The inspectors determined that NextEra's actions to address the gaps in appropriately identifying post-maintenance testing required for the scope of work, which included having the Online Work Manager discuss these issues with work planners and the operations personnel responsible for identifying testing requirements, were reasonable.

Observation: Corrective actions to address licensed operator performance during rod drop event and manual reactor trip on June 6 71152 As documented in Seabrook Station - Inspection Report 2020002 (ML20216A506), NRC inspectors identified a violation of inadequate implementation of procedural guidance (NCV 2020002-01) when the control room staff failed to utilize multiple indications and alarms prior to taking action to stabilize the plant which resulted in a four-minute delay in implementing the procedurally required reactor scram. The control room operator did not use all the available indications to diagnose the event, incorrectly focusing his attention on a perceived instrumentation failure. The unit supervisor became involved with the main control board operators response to the event instead of maintaining oversight of all activities and indications in the control room. The event was exacerbated by the minimum staffing of the control room at the time of the rod drop.

NRC inspectors performed a review of NextEras completed and planned corrective actions to address this event.

Corrective actions included, removing the unit supervisor and control room operator from watchstanding duties until the satisfactory completion of individual remediation plans which included individual training on diagnosis and alarm response, simulator training sessions and follow-up interviews with training staff and operations management. The unit supervisor also received training on maintaining a supervisory oversight position and techniques for coaching. The two operators were successfully remediated and returned to normal shift duties.

All operations crews received operator requalification training during the following scheduled segment focusing on the performance gaps identified by this event. Crews were given training scenarios that more closely aligned with the situation encountered on June 6. These scenarios were conducted with Technical Specification minimum staffing and included normal evolutions in progress that would be encountered in the course of a work week in the control room, versus the normal setup of a training scenario with instrument and component failures prior to a main event that requires use of emergency procedures. These normal evolutions were progressed for a period before inserting failures (including control rod drops) to provide practice for the crews in using diverse indications in diagnosis, alarm response, oversight and coaching by shift supervision.

NextEra also added guidance to operations staffing procedures to increase control room staffing above the technical specification minimums when a licensed operator is required to leave the control room. Additionally, the post trip review process was enhanced to ensure timely review and critique of operator response to events is performed.

The licensee implemented a program to utilize personnel from outside the operations department to perform periodic observations of control room and field operators to assess procedure use and adherence, alarm response and coaching.

The inspectors also assessed planned corrective actions and reviews. A training effectiveness review will be completed by the end of 2020, to assess the impact of the segment training and coaching. A Level 1 assessment for sustainability of command and control, diagnosis and alarm response will be performed during the first quarter of 2021.

The inspectors concluded that NextEras corrective actions to address this event were reasonable and appropriate for the circumstances.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 22, 2020, the inspectors presented the radiation protection inspection results to Rob Harrsch, Operations Site Director and other members of the licensee staff.

• On October 29, 2020, the inspectors presented the integrated inspection results to Mr. Eric McCartney, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71124.04

Procedures

HD0961.25

In-Vitro Sample Collection and Preparation

Revision 25

71124.05

Procedures

HD0963.27

Calibration of the Eberline RO-2/RO-2A/RO-20/RO-20AA Ion

Chamber and the Bicron RSO-5 Ion Chamber

Revision 09

71124.05

Procedures

HD0963.48

Calibration of the MGP AMP-100/AMP-200

Revision 01

71124.05

Work Orders

No. 40683385

R-6507-A Control Room West Air Intake Train A

July 14,

20