IR 05000443/2022010

Biennial Problem Identification and Resolution Inspection Report 05000443/2022010

ML22348A046
Person / Time
Site:	Seabrook
Issue date:	12/15/2022
From:	Matt Young NRC/RGN-I/DORS
To:	Coffey B Florida Power & Light Co
References
IR 2022010
Download: ML22348A046 (1)

Text

December 15, 2022

SUBJECT:

SEABROOK STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000443/2022010

Dear Bob Coffey:

On November 17, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at Seabrook Station and discussed the results of this inspection with Christopher Robinson, Organizational Effectiveness Site Director, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution 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 problem identification and resolution 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, Digitally signed by Matthew R.

Matthew R. Young Date: 2022.12.15 11:02:14 Young -05'00'

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: 05000443/2022010 Enterprise Identifier: I-2022-010-0012 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station Location: Seabrook, New Hampshire Inspection Dates: October 31, 2022 to November 17, 2022 Inspectors: C. Newport, Senior Resident Inspector M. Hardgrove, Senior Project Engineer C. Khan, Senior Project Engineer B. Sienel, Resident Inspector Approved By: Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety Enclosure

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, 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.

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 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.

• Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the service water system.

• Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

• Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through 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.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness Problem Identification: The inspectors determined that, in general, NextEra identified issues and entered them into the corrective action program at a low threshold.

Problem 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 (CRs) for operability and reportability, categorized CRs by significance, and assigned actions to the appropriate department for evaluation and resolution.

Corrective Actions: 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 several instances of failing to appropriately disposition NRC-identified and self-revealing non-cited violations documented in NRC inspection reports in accordance with established NextEra procedures. A corresponding minor violation is documented in this report.

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 experience 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 performed by both Nuclear Assurance and individual departments 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 33 individuals across multiple departments. 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 inspection team from the Operations, Nuclear Assurance, Quality Control, Engineering, Maintenance, Security, Emergency Preparedness, Chemistry, 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. All 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-conscious work environment issues were adequately implemented.

Inadequate Corrective Action Program Disposition of NRC Issued Violations and 71152B Findings Minor Violation: 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. NextEras corrective action procedures provide guidance on the disposition of NRC issued violations and findings. Specifically, PI-AA-104-1000, Condition Reporting, Revision 36, Attachment 4 states NRC identified or self-revealed Severity Level IV NOVs, non-cited violations (NCVs) or Green findings should be classified as significance level 2 [condition adverse to quality] CAQ. PI-AA-104-1000, Section 4.3.4, CAPCO Screening, states Justification shall be provided in the database forany CAQ SL-2 CR that does not receive an issue investigation and PI-AA-100-1005, Root Cause Analysis, Revision 26, Attachment 15, Nuclear Safety Culture Evaluation, states the nuclear safety culture evaluation is also performed for an issue investigation when addressing a NRC finding.

NRC inspectors identified four examples of CRs associated with documented NRC NCVs that did not receive Nuclear Safety Culture Evaluations per PI-AA-100-1005. One of the CRs associated with an NRC NCV was not correctly classified as a significance level 2 CAQ and did not have an assigned issue investigation or documented justification for why an issue investigation was not conducted. The licensee generated AR 02440933 to document this deficiency.

Screening: The inspectors determined the performance deficiency was minor, in accordance with IMC 0612, Appendix B, as it was not associated with one of the cornerstone attributes and did not adversely affect an associated cornerstone objective.

Enforcement:

This failure to comply with 10 CFR Part 50, Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On November 17, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Christopher Robinson, Organizational Effectiveness Site Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 00142490

Documents 02107269

230580

239360

239491

255254

268343

2311826

2312273

2315493

2343133

2347175

2347274

2352480

2355672

2355672

2355752

2355752

2358122

2361725

2364608

2377657

2378194

2379482

2379909

2380345

2381577

2381777

2382035

2382135

2382301

Inspection Type Designation Description or Title Revision or

Procedure Date

2382944

2383112

2383553

2384419

2384535

2384682

2385004

2385150

2385818

2386420

2386459

2386797

2387547

2387962

2387962

2388308

2388996

2390492

2390563

2390713

2390716

2390718

2390719

2390721

2390722

2391479

2391942

2392123

2392125

2393651

2394438

2394505

2394524

Inspection Type Designation Description or Title Revision or

Procedure Date

2394986

2395488

2395578

2395915

2396140

2397661

2398003

2399021

2399281

2399353

2401319

2401831

2402391

2404429

2404603

2404848

2405010

2405010

2405642

2405960

2406014

2406458

2406645

2406749

2406759

2406823

2406971

2407688

2407894

2408546

2409708

2410904

2412826

Inspection Type Designation Description or Title Revision or

Procedure Date

2413501

2413555

2414159

2415050

2415187

2415800

2416319

2417427

2419868

2422981

2426191

2426258

2427774

2428247

2429966

2431456

2431819

2434445

2434462

2438035

20382033

Corrective Action 02440933

Documents 02442026

Resulting from

Inspection

Procedures EN-AA-203-1001 Operability Determinations/Functionality Assessments Revision 7

ER-AP-116-1000 Boric Acid Corrosion Control Program Revision 7

FPL-2 Quality Assurance Program Description Revision 0

NA-AA-07 Employee Concerns Program Revision 0

OP-AA-108-1000 Operator Challenges Program Management Revision 8

PI-AA-100-1005 Root Cause Analysis Revision 26

PI-AA-100-1007 Issue Investigation Revision 0

PI-AA-104-1000 Condition Reporting Revision 36

Inspection Type Designation Description or Title Revision or

Procedure Date

PI-AA-104-1000- Corrective Action Program and Condition Reporting Revision 2

10000 (CAPCO)

Self-Assessments SBK 20-005,

Operations

SBK 20-007,

Maintenance and

Work Control

SBK 22-003,

Security

SBK 22-006,

Fitness for

Duty/Access

Authorization

SBK-01-01-00,

Engineering

SBK-21-003,

QA/QC self

SBK-21-16-000,

EP

Work Orders 01059392

40103378

40760372

40762942

40788087

219714

222316

10