IR 05000443/2020010
| ML20328A148 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/01/2020 |
| From: | Brice Bickett Reactor Projects Branch 3 |
| To: | Moul D Florida Power & Light Co |
| References | |
| IR 2020010 | |
| Download: ML20328A148 (13) | |
Text
December 1, 2020
SUBJECT:
SEABROOK STATION, UNIT NO. 1 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000443/2020010
Dear Mr. Moul:
On November 5, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Seabrook Station, Unit No. 1 and 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.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
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: Brice A. Bickett
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:
Report Number:
Enterprise Identifier: I-2020-010-0030
Licensee:
NextEra Energy Seabrook, LLC
Facility:
Seabrook Station, Unit No. 1
Location:
Seabrook, NH
Inspection Dates:
October 19, 2020 to November 05, 2020
Inspectors:
M. Draxton, Senior Project Engineer
D. Beacon, Resident Inspector
T. Daun, Resident Inspector
R. Vadella, Project Engineer
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 a biennial problem identification and resolution 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
Type Issue Number Title Report Section Status LER 05000443/2020-001-00 LER 2020-001-00 for Seabrook Station, Manual Reactor Trips due to Control Rod Bank Unexpectedly Inserting 71153 Closed
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the emergency feedwater system.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000443/2020-001-00, Manual Reactor Trips due to Control Rod Bank Unexpectedly Inserting (ADAMS Accession No. ML20209A542). Inspectors reviewed the root cause evaluation and associated corrective actions for the two events reported. Inspectors determined that the corrective actions taken or in progress were appropriate and commensurate with their safety significance. The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensees ability to foresee and correct and therefore was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program
Identification: The inspectors determined that NextEra identified issues and entered them into the corrective action program at a low threshold. During plant walk downs, there was evidence of continued focus to improve the look and condition of the plant. The inspectors identified a few deficiencies not previously identified and captured in NextEras corrective action program. NextEra promptly entered each issue into their corrective action program and took actions to evaluate and address. All issues were determined to be of minor significance.
Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that NextEra appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. NextEra appropriately screened condition reports (ARs) for operability and reportability, categorized ARs by significance, and assigned actions to the appropriate department for evaluation and resolution.
Correcting Problems: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. In most cases, NextEra implemented corrective actions to resolve problems in a timely manner. However, the inspectors noted some challenges with the tracking and the timely close-out of corrective actions (CAs) for conditions adverse to quality (CAQ). See below for details concerning this observation.
Assessment 71152B Operating Experience, Self-Assessments and Audits
Use of Operating Experience: The team determined that NextEra appropriately evaluated industry operating experience for its relevance to the facility. NextEra appropriately incorporated both internal and external operating into plant procedures and processes, as well as lessons learned for training and pre-job briefs.
Self-Assessments and Audits: The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team concluded that NextEra had an effective self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment
The team interviewed a total of 38 individuals: 13 in focus groups and 25 in one-on-one interviews. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety-conscience work environment. The personnel interviewed were randomly selected by the inspectors from the Operations, Engineering, Maintenance, Security, Information Technology, Emergency Preparedness, and Radiation Protection work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP)
Coordinator to assess their perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and selected case files.
All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated they were adequately trained and proficient on initiating notifications. All interviewees were aware of the licensee's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety culture issues were adequately implemented.
Observation: Tracking of Corrective Actions 71152B The inspectors noted an area of vulnerability to ensuring adequate and timely close-out of corrective actions once the associated ARs were closed to work order (WO), work request (WR), or the procedure change request (PCR) processes. PI-AA-01, Corrective Action Program and Condition Reporting, provides implementation guidance for NextEra that directs corrective actions to be completed in accordance with due dates that are assigned commensurate with their significance and assigned priority and discusses the critical attributes for a successful corrective action program, specifically: completion of activities prior to due dates, effective resolution of problems, maintenance of low backlogs of open evaluations and actions, effective monitoring and management oversite, and meaningful feedback to condition report initiators.
The inspectors determined that these critical attributes have the potential to be challenged because PI-AA-104-1000, Condition Reporting, allows CAs associated with conditions adverse to quality to be closed to an approved WO/WR/PCR, provided that the CA is not associated with a significance level 1 AR, not an inoperable, nonfunctional, operable/function but degraded, or operable/functional but non-conforming, as long as a cross-reference is made to the AR, and the WO, WR, and PCR is assigned the correct category per PI-AA-104-1000. (4.3.5.F).
The inspectors identified several examples of untimely CA for CAQ after the associated condition report was closed to a WO, WR, or PCR processes. The most significant example identified by the inspectors involved condition report AR2283006 which documented boric acid in contact with the bonnet studs on the inlet isolation valve in the charging system.
NextEra previously completed an evaluation of the condition and concluded that continued operation was acceptable until refueling outage OR20 and the bonnet gasket should be replaced at that time. AR2285040 was written to identify this condition and was closed to work request WR94184073. WR94184073 was subsequently converted to work order WO40626697 to be worked during refueling outage OR20 in April 2020. WO40626697 was later deferred from OR20 to OR21 without replacing the bonnet gasket or completing a corrective action program evaluation, as required by the corrective action. Following the inspectors questions, NextEra updated the evaluation to support operation until OR21 when the bonnet gasket will be replaced (AR02374481). The inspectors noted that in preparation for the NRC problem identification and resolution inspection, NextEra completed a self-assessment (AR02369293) that identified a similar observation to the inspectors in that CAs closed to other products (i.e. PCRs, WOs) were not always being tracked to completion which has led to untimely corrective action completion in some cases. The self-assessment also noted that this was similar to a gap identified in a 2018 self-assessment (AR02369984).
The inspectors also identified several examples in which WR/WO associated with CAs for CAQ were assigned an incorrect priority. Specifically,
- (1) AR2359680 (CAQ CA) was closed to Priority 3 WR94027409/ Priority 3 WO40097004;
- (2) AR2344818 (CAQ CA) was closed to Priority 3 WO40438884; and
- (3) AR2346954 (CAQ CA) was closed to Priority 3 WO40630759. Per procedure PI-AA-104-1000, the condition reports should have been closed to a Priority 1 or 2 WO. This would help ensure timely corrective action.
Inspectors determined that none of the examples above would have screened as a more than minor performance deficiency.
Corrective Action Reference: AR02369984, AR2375560
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 5, 2020, the inspectors presented the biennial problem identification and resolution 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
Calculations
FPLS001-CALC-
001
FSB Structure & Crane Seismic Analysis
Revision 1
Corrective Action
Documents
2102315, 2114500, 2114669, 2120705, 2120781, 2161197,
2193235, 2202295, 2202419, 2206799, 2215578, 2215882,
216482, 2223796, 2237903, 2240426, 2242832, 2244654,
248447, 2251379, 2254462, 2271141, 2272572, 2273164,
273203, 2273539, 2275048, 2275846, 2276046, 2276550,
276605, 2277289, 2277619, 2277869, 2278035, 2279103,
280030, 2280165, 2280762, 2281088, 2281235, 2281560,
282260, 2282344, 2282807, 2282875, 2282942, 2282945,
282957, 2283003, 2283017, 2283094, 2283513, 2283779,
284272, 2284291, 2284861, 2284913, 2289758, 2290176,
290711, 2291977, 2293389, 2294392, 2295921, 2296877,
296982, 2297071, 2297502, 2298187, 2300075, 2303124,
2303545, 2306313, 2307275, 2307829, 2308576, 2308739,
2308818, 2309994, 2309997, 2310197, 2310204, 2310448,
2312411, 2312582, 2312826, 2312915, 2312943, 2314257,
2314959, 2316855, 2317439, 2318284, 2318670, 2318841,
22208, 2323392, 2323887, 2326660, 2331784, 2334168,
2334174, 2334453, 2337349, 2337771, 2338268, 2338782,
2339051, 2339725, 2339802, 2340103, 2340235, 2340501,
2340512, 2340570, 2341442, 2341446, 2342578, 2342723,
2342737, 2342742, 2342858, 2342927, 2343044, 2345241,
2345447, 2347175, 2347521, 2347999, 2348811, 2349731,
2350694, 2350892, 2350996, 2351276, 2351360, 2351411,
2352676, 2352992, 2353368, 2353621, 2354168, 2354526,
2354817, 2355761, 2356917, 2357047, 2357164, 2357712,
2357846, 2358122, 2358417, 2358821, 2358986, 2359720,
2359999, 2360018, 2360223, 2360418, 2360852, 2361274,
2362099, 2362111, 2362876, 2363728, 2363859, 2364081,
2364090, 2364616, 2364826, 2364992, 2365301, 2365809,
2365811, 2366227, 2366501, 2367047, 2367223, 2367618,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2368501, 2369293, 2371736
2310004-01
Potential for NRC Green NCV Violation
2345447-03
NAA Finding - Incorrect QL Components Used in FP System
2353438-01
Incorrect QC Inspection Method Used
2357696-02
1-SA-SKD-137-A Tripped on Main Motor Overload while
being put as lead compressor
2361725-04
RC-TI-9410 Failed High
08/06/2020
2368126-04
Abnormal start of Diesel Generator 'A'
10/22/2020
Corrective Action
Documents
Resulting from
Inspection
2372439, 2372445, 2373891, 2373907, 2374290, 2374481,
2374587, 2374613
Engineering
Changes
284865
294713
Miscellaneous
20-Q1 Site Nuclear Safety Culture Meeting Minutes
03/12/2020
20-Q2 Site Nuclear Safety Culture Meeting Minutes
06/18/2020
Site Management Review Meeting
10/06/2020
2192471
PTN Internal OE - Unplanned U3 Reactor Trip (AR2192198)
03/20/2017
275803
Evaluation of NRC IN 2018-09: Electrical Arc Flash Caused
by Foreign Mtl
08/13/2018
282432
Evaluation of NRC IN 2018-11: Kobe Steel QA Record
Falsification
09/27/2018
286414
ABB Transformer Part 21
10/17/2018
296982
Evaluation for Part 21: AMTEK Components Provided as
Safety-Related
01/08/2019
2306313
Evaluation for NRC IN 2019-01: Inadequate Evaluation of
Temporary Alterations
05/17/2019
2334453
Evaluation for NRC IN 2019-09: Spent Fuel Cask Movement
Issues
06/24/2020
2338493
Evaluation of NRC IN 2019-10: Failures of Eaton/Cutler
Hammer A200 Contact
2/16/2019
Operability
Evaluations
248447
RC-V-116 Exceeded ASME/TS Limits for As-Found Test
2/27/2018
Procedures
Nuclear Safety Culture
Revision 4
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Nuclear Safety Culture Program
Revision 17
Operability Determinations/Functionality Assessments
Revision 34
Nuclear Division Drill and Exercise Procedure
Revision 27
Maintenance Rule Functional Failure Determination
Revision 4
Equipment Reliability
Revision 12
Management of Critical Components and Single Point
Vulnerabilities (SPVS)
Revision 11
HD0958.19
Evaluation of Dosimetry Abnormalities
Revision 40
LX0558.05
4.16 kV Breaker Swapout and TOC (52H) Inspection
Revision 7
EMPLOYEE CONCERNS PROGRAM
Revision 26
Audit Topic Selection and Scheduling
Revision 17
Certification of Quality Control Inspection Personnel
Revision 8
NWS-T-80
NWS Procedure for Set Pressure & Seat Tightness Testing
of FPL Energy - Seabrook Station Crosby 6M6 Pressurizer
Safety Valves
Revision 3
OS1000.04
Plant Cooldown from Hot Standby to Cold Shutdown
Revision 67
Corrective Action Program and Condition Reporting
Revision 4
Root Cause Analysis
Revision 22
Issue Investigation
Revision 23
Level 1 Core Business Assessments
Revision 20
Condition Reporting
Revision 26
Station Self-Evaluation and Trending Analysis
Revision 12
RP 13.2
Storage of Highly Radioactive Material in the Reactor Cavity
of Spent Fuel Pool
Revision 8
Radiation Protection Conduct of Operations Procedure
Revision 8
Radiation Worker Instruction and Responsibilities
Revision 10
High Radiation Area Controls
Revision 12
WM-AA-100-1000 Work Activity Risk Management
Revision 19
WM-AA-201-
1000-10001
Quarterly Audit of Work Management Performance
Revision 4
Radiation Work
Permits (RWPs)
20-0009
Operations Routine Rounds and Inspections
Revision 0
Self-Assessments 02312772
Nuclear Safety Culture Assessment
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2349060
Potential Trend with HU Errors
03/11/2020
2369293
Preparation for the NRC Problem Identification and
Resolution Inspection
289133
NAA Assessment of departmental critique of QA Programs
and Records Management Audit Exit Meeting
290045
OR19 Lessons Learned (ISI)
25512
2019 Mid-Cycle Assessment Report
2331727
AR Initiation vs. Number of Badged Employees
2345568
Condition Report Corrective Action Closure Quality
2364643
Review of Seabrook Station Equipment Failure Investigations
SBK 17-007
07/24/2017
SBK 18-007
07/24/2018
SBK 18-008
Nuclear Assurance Report: Work Management and Outage
Management
08/10/2018
SBK 18-010
Chemistry, Effluents and Environmental Monitoring Programs 12/26/2018
SBK 19-001
QA Programs and Records Management
04/04/2019
SBK 19-002
Engineering Design
04/24/2019
SBK 19-006
07/24/2019
SBK 19-007
Nuclear Assurance Report - Performance Improvement
01/09/2020
SBK 19-008
Fire Protection
2/20/2020
SBK 20-001
Nuclear Assurance Report: Security/Cyber Security
05/04/2020
SBK 20-002
Radiation Protection / Radwaste Programs
06/29/2020
SBK 20-003
Nuclear Assurance Report: Fitness for Duty/Access
Authorization
07/07/2020
SBK 20-004
08/20/2020
Work Orders
40441339, 40453257, 40453674, 40574999, 40608330,
40611465, 40620602, 40632797, 40661868, 40664968,
40668138, 40669833, 40723055, 40729694, 40735057