IR 05000443/2022001

Integrated Inspection Report 05000443/2022001

ML22122A081
Person / Time
Site:	Seabrook
Issue date:	05/02/2022
From:	Matt Young Division of Operating Reactors
To:	Coffey B Florida Power & Light Co
Young M
References
IR 2022001
Download: ML22122A081 (14)

Text

May 2, 2022

SUBJECT:

SEABROOK STATION - INTEGRATED INSPECTION REPORT 05000443/2022001

Dear Mr. Coffey:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station. On April 21, 2022, the NRC inspectors discussed the results of this inspection with Mr. Brian Booth, 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, Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety

Docket No. 05000443 License No. NPF-86

Enclosure:

As stated

Inspection Report

Docket Number:

05000443

License Number:

NPF-86

Report Number:

05000443/2022001

Licensee:

NextEra Energy Seabrook, LLC

Facility:

Seabrook Station

Location:

Seabrook, New Hampshire

Inspection Dates:

January 1, 2022 to March 31, 2022

Inspectors:

C. Newport, Senior Resident Inspector

T. Daun, Resident Inspector

Approved By:

Matt R. Young, Chief

Projects Branch 2

Division of Operating Reactor Safety

SUMMARY

The NRC continued monitoring the licensees performance by conducting an integrated inspection at Seabrook Station, 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 and remained at or near full power 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 performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

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) B emergency diesel generator after monthly surveillance run on March 1

(2) DC distribution system during transfer of 'D' 125VDC bus to its alternate battery supply and back to its normal battery supply on March 1

(3) A safety injection after quarterly flow and valve test on March 23

(4) A turbine driven emergency feedwater pump after quarterly surveillance run on March 24

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) Primary auxiliary building (PAB-F-3A-Z) on January 4 (2)

'A emergency diesel generator building (DG-F-2A-A) on February 14

(3) Cable spreading room (CB-F-2A-A) on March 1

(4) Unit 1 service water cooling tower (CT-F-2B-A) on March 20

(5) Primary auxiliary building electrical chase (PAB-F-1G-A) on March 28

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the on-site fire brigade training and performance during an unannounced drill on March 22

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) 'A' and 'B' essential switchgear rooms on February 24

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:

• Main turbine valve testing on February 11

• Safety injection accumulator back leakage seating evolution on February 14

• Control rod operability testing on February 17

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 January 28

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) Radiation monitoring system and associated a(1) action plan on March 8

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 unit auxiliary transformer and reserve auxiliary transformer relay calibrations on January 13

(2) Yellow risk during 'B' emergency diesel generator semi-annual surveillance and inspection on January 25

(3) Elevated risk during service water tower actuation logic testing on March 1

(4) Elevated risk during 345kV line 369 outage on March 15

(5) Yellow risk during A turbine driven emergency feedwater pump surveillance and switchyard work on March 24

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) SB-V-5 failed to stroke within expected range (AR 02418461) on February 10 (2)

'A' safety injection accumulator back leakage (AR 02418795) on February 14

(3) Control building air trouble alarm (AR 02394323) on March 4 (4)

'B' containment building spray pump decreasing discharge differential pressure trend (AR 02418551) on March 17 (5)

'B' emergency diesel generator starting air system failure (AR 02426043) on March 30

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Swap of vital 125VDC power panel PP-113A breaker to new panel position

(2) Replacement of 25Y1 relay with new style relay for the 'A' emergency diesel generator

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1)

'C' primary component cooling water pump and motor following oil changes on January 11 (2)

'B' emergency diesel generator semi-annual fast start following inspection on January 25 (3)

'B' centrifugal charging pump coupling lubrication and testing on February 3

(4) Safety injection discharge cross connect valve (SI-V-112) following motor-operated valve inspection and lubrication on February 17

(5) A essential switchgear ventilation fan CBA-FN-19 belt replacement on March 29 (6)

'B' emergency diesel generator following replacement of barring device relay on March 31

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1)

'A' emergency diesel generator monthly surveillance on January 10

(2) Supplemental emergency power system quarterly surveillance on January 20

(3) Bus 6 unit auxiliary transformer synch check relay calibration on January 26

(4) Service water cooling tower makeup pump operability 18-month surveillance on March 10

In-service Testing (IP Section 03.01) (1 Sample)

(1) 'A' residual heat removal quarterly flow and valve stroke test on January 11

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the conduct of a routine, full participation emergency planning drill on February

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===

(1) For the period January 1, 2021 through December 31, 2021

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) For the period January 1, 2021 through December 31, 2021

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) For the period January 1, 2021 through December 31, 2021

===71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03)===

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

(1) Evaluation of licensed reactor operator staffing levels

(2) Evaluation of preventative maintenance schedule changes and work planning processes

INSPECTION RESULTS

Observation: Licensed Reactor Operator Staffing Levels 71152A The inspectors performed a review of staffing levels of licensed reactor operators after the unexpected retirement and departure of several licensed reactor operators. The inspectors reviewed NextEras plans for restoration of the desired number of licensed reactor operators and NextEras plans for the use of licensed senior reactor operators to stand reactor operator watch positions when necessary, and verified that NextEras plan is currently maintaining minimum required licensed operator staffing levels.

Observation: Evaluation of Preventative Maintenance Schedule Changes and Work Planning Processes 71152A The inspectors performed a review of NextEras work control processes and efforts to streamline their preventative maintenance schedules and periodicity. As part of this review, the inspectors attended daily and weekly work planning meetings, reviewed corrective action documents, reviewed planning and justification documents for preventative maintenance schedule changes, and discussed these items with site work planning staff.

The inspectors noted three examples of preventative maintenance items that were improperly classified with a functional importance determination of non-critical (FID-N), a classification that allows for planned preventative maintenance work to not be completed if no deficiencies have been noted against the system. The three examples involved components that were not normally energized or actuated and as such, would not manifest a deficiency that would be documented in the corrective action program and trigger preventative maintenance to be performed. Each of these three components were used to either mitigate the impacts of a flooding event or by operators to take action in the event of a flooding event in various spaces in the plant. Each of the three FID-N classified maintenance items passed their associated surveillance tests when subsequently tested. The inspectors also noted an example of preventative maintenance important to safety and/or with risk significance being extended with insufficient justification. In 2019, the four pump discharge and suction pressure gauge calibration preventative maintenance activities for both trains of containment building spray were extended from a periodicity of 18 months to 4 years. NextEra justified the change after a review of the last four completions of each of the preventative maintenance activities noted only one case of instrument drift. While these instruments are not used by operations during normal or emergency plant operations, they do provide data used to justify operability during scheduled system surveillance testing.

Finally, the inspectors noted that site daily work planning meetings and communications often lacked clarity. Examples included, in several cases, daily planned work added or cancelled with short notice, daily site PRA risk classified as yellow when the primary risk driver for the yellow risk categorization not planned or performed and several instances where daily PRA risk increased on short notice, even though the drivers for the increase in risk consisted of planned maintenance activities known to the organization well in advance.

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On April 21, 2022, the inspectors presented the integrated inspection results to Mr. Brian Booth, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Corrective Action

Documents

2420138

2420180

Miscellaneous

Operator Aid #93-

21

Tr. B Vital DC Batteries and Chargers

09/13/2017

Procedures

OS1048.16

Vital Bus 11D Operation

Revision 18

OX1405.07

Safety Injection Quarterly and 18 Month Pump Flow and

Valve Test

Revision 23

OX1426.19

Aligning DG 1B Controls for Auto Start

Revision 7

OX1436.02

Turbine Driven Emergency Feedwater Pump Quarterly and

Monthly Valve Alignment

Revision 35

Work Orders

40776798

40779667

40779680

71111.05

Drawings

CB-F-2A-A

Control Building-Cable Spreading Rooms and Mechanical

Rooms (Sheet 7 of 12)

04/04/2014

PAB-F-1G-A

PAB Vertical Electrical Chase (Sheet 19 of 20)

04/20/2001

Procedures

FP-AA-104

Fire Protection Program

Revision 6

FP-AA-104-1003

Fire Response

Revision 3

OS1200.00

Response to Fire or Fire Alarm Actuation

Revision 28

OS1200.00A

Fire Hazards Analysis for Affected Area/Zone - Appendix A

Revision 26

71111.06

Corrective Action

Documents

2418585

2420493

Miscellaneous

C-S-1-21805

CW System Seismic Indiced Flooding in TB and Impact on

A ESWGR

Revision 0

Work Orders

40762974

71111.12

Corrective Action

Documents

2415013

2416319

2421536

71111.13

Corrective Action

Documents

2421502

Procedures

IS1672.902

Service Water Train B Tower Actuation Logic Test

Revision 1

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

OP-AA-102-1003

Guarded Equipment

Revision 40

OP-AA-104-1007

Online Aggregate Risk

Revision 7

WM-AA-100

Risk Management Program

Revision 3

WM-AA-100-1000

Work Activity Risk Management

Revision 22

71111.15

Corrective Action

Documents

2199973

2394323

2416196

2418461

2418551

2418795

2418881

2426043

Drawings

1-SI-B20450

Safety Injection System Low Head Injection (Accumulators)

Detail

2/05/2007

Procedures

OX1456.81

Operability Testing of IST Valves

Revision 41

Work Orders

40773154

40779376

40816313

71111.18

Corrective Action

Documents

00195174

2360336

Engineering

Changes

00144967

DG-1A Relay 25Y1 Replacement

Revision 002

Work Orders

294978

71111.19

Corrective Action

Documents

2417929

2419087

2423106

2426043

Drawings

1-NHY-310857-

e94-8b

Emerg Diesel Gen 1-B Start Circuit No. 1 Schematic

Diagram

Revision 7

1-NHY-310857-

e94-8c

Emerg Diesel Gen 1-B Start Circuit No. 2 Schematic

Diagram

Revision 10

11871652

Wiring Diagram Power Unit

Revision 14

Procedures

LS0569.16

Diagnostic Testing of Rising Stem MOVs

Revision 29

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

MS0523.48

Sheave Alignment and Belt Tensioning

Revision 3

OS1026.09

Operation of DG 1B

Revision 35

OX1456.01

Charging Pump A & B Quarterly Flow and Valve Stroke Test

and 18 Month Remote Position Indication Verification

Revision 18

Work Orders

40738401

40770880

40802707

40821523

40821594-02

40821594-03

40821594-04

71111.22

Corrective Action

Documents

2415794

2416677

2416679

2416778

2419424

2420981

Procedures

LS0563.31

UAT Synchronism Check Relay PM

Revision 3

OX1416.18

Portable Tower Makeup Pump Operability 18 Month

Surveillance Test

Revision 0

Work Orders

40764039

40766967

40770424

40770425

71151

Miscellaneous

LIC-21005

Documentation Supporting the Seabrook Station NRC 1st

Quarter 2021 Performance Indicator Submittal

04/27/2021

LIC-21006

Documentation Supporting the Seabrook Station NRC 2nd

Quarter 2021 Performance Indicator Submittal

07/27/2021

LIC-22001

Documentation Supporting the Seabrook Station NRC 4th

Quarter 2021 Performance Indicator Submittal

2/28/2022

LIC-22004

Documentation Supporting the Seabrook Station NRC 3rd

Quarter 2021 Performance Indicator Submittal

2/17/2022

71152A

Corrective Action

2340882

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

2390449

2401831

2418515