IR 05000443/2022010
| ML22348A046 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/15/2022 |
| From: | Matt Young Division of Operating Reactors |
| 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, 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:
Report Number:
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
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 Findings 71152B 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
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
00142490
2107269
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
Procedure
Type
Designation
Description or Title
Revision or
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
Procedure
Type
Designation
Description or Title
Revision or
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
Procedure
Type
Designation
Description or Title
Revision or
Date
2413501
2413555
2414159
2415050
2415187
2415800
2416319
2417427
2419868
2422981
2426191
2426258
2427774
2428247
2429966
2431456
2431819
2434445
2434462
2438035
20382033
Corrective Action
Documents
Resulting from
Inspection
2440933
2442026
Procedures
Operability Determinations/Functionality Assessments
Revision 7
Boric Acid Corrosion Control Program
Revision 7
FPL-2
Quality Assurance Program Description
Revision 0
Employee Concerns Program
Revision 0
Operator Challenges Program Management
Revision 8
Root Cause Analysis
Revision 26
Issue Investigation
Revision 0
Condition Reporting
Revision 36
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PI-AA-104-1000-
10000
Corrective Action Program and Condition Reporting
(CAPCO)
Revision 2
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,
Work Orders
01059392
40103378
40760372
40762942
40788087
219714
222316