IR 05000443/2022502
| ML22270A233 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/28/2022 |
| From: | Daniel Schroeder Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Coffey B Florida Power & Light Co |
| Schroeder D | |
| References | |
| IR 2022502 | |
| Download: ML22270A233 (12) | |
Text
September 28, 2022
SUBJECT:
SEABROOK STATION - EMERGENCY PREPAREDNESS INSPECTION REPORT 05000443/2022502
Dear Bob Coffey:
On August 19, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station. On September 1, 2022, the NRC inspectors discussed the results of this inspection with Brian Booth, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Seabrook Station. 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Daniel L. Schroeder, Chief Security, Emergency Preparedness, and Incident Response Branch Division of Radiological Safety and Security
Docket No. 05000443 License No. NPF-86
Enclosure:
As stated
Inspection Report
Docket Number:
05000443
License Number:
Report Number:
Enterprise Identifier: I-2022-502-0000
Licensee:
NextEra Energy Seabrook, LLC
Facility:
Seabrook Station
Location:
Seabrook, New Hampshire
Inspection Dates:
August 15, 2022 to August 19, 2022
Inspectors:
J. Ambrosini, Senior Emergency Preparedness Inspector
P. Cataldo, Senior Reactor Inspector
T. Daun, Resident Inspector
C. Newport, Senior Resident Inspector
Approved By:
Daniel L. Schroeder, Chief
Security, Emergency Preparedness, and Incident Response Branch
Division of Radiological Safety and Security
SUMMARY
The NRC continued monitoring the licensees performance by conducting an emergency preparedness 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
Siren Activation Points Not as Described in Federal Emergency Management Agency Alert and Notification System Design Report Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000443/2022502-01 Open/Closed None (NPP)71114.02 The inspectors identified a Green non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(5). Specifically, the licensee failed to ensure the alert and notification system siren program complied with the approved Federal Emergency Management Agency Alert and Notification System Design Report. This non-compliance affected a bi-weekly silent test conducted on July 12, 2022, and resulted in an inadvertent actuation of the ten sirens located on the New Hampshire beaches of Rye, North Hampton,
Hampton, and Seabrook.
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 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.
REACTOR SAFETY
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system following the inadvertent actuation of the beach sirens during planned silent testing on July 12, 2022, during the week of August 15,
OTHER ACTIVITIES - BASELINE
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) Unplanned emergency plan siren activation on July 12,
INSPECTION RESULTS
Siren Activation Points Not as Described in Federal Emergency Management Agency Alert and Notification System Design Report Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness
Green NCV 05000443/2022502-01 Open/Closed
None (NPP)71114.02 The inspectors identified a Green non-cited violation of 10 CFR 50.47(b)(5). Specifically, the licensee failed to ensure the alert and notification system siren program complied with the approved Federal Emergency Management Agency Alert and Notification System Design Report. This non-compliance affected a bi-weekly silent test conducted on July 12, 2022, and resulted in an inadvertent actuation of the ten sirens located on the New Hampshire beaches of Rye, North Hampton, Hampton, and Seabrook.
Description:
The Seabrook Station Nuclear Power Plant Alert and Notification System Design Report, Addendum 7, dated June 2013, describes siren design, testing, and maintenance activities. The report discusses the siren activation locations in Massachusetts and New Hampshire, including primary and backup activation locations, with a detailed description of the functions available in each location. Of note is the description of the primary siren activation location in Rockingham County, New Hampshire, which discusses its ability to use a preprogrammed sequence in its siren encoder (E2010) to transmit a recorded digital message that instructs people, through the public address system in the ten sirens at the beaches of Rye, North Hampton, Hampton, and Seabrook, New Hampshire, to turn on their radios for messages broadcast on the emergency alert system. When activated, the system will broadcast this message through the siren public address system function eight times as the siren rotates to ensure full coverage. The other activation locations have a different version of the encoder (E969) and have the capability to broadcast voice messages to the sirens, but not automatically. Instead, the E969 encoder requires the operator to enter a manual sequence of commands to activate the sirens instead of using preprogrammed call keys. Rockingham County has a spare E969 encoder that acts as a backup in case of any problems with its E2010 encoder and which can perform all the functions of the E2010, albeit without the help of preprogrammed call keys to expedite the process.
In 2009, Seabrook Station completed upgrades to the siren front panel circuitry to allow remote monitoring of the status of each siren. With this upgrade, the licensee can monitor the required surveillance testing from their onsite siren maintenance shop instead of traveling to verify operation of each siren at its installed location. During the 2009 siren upgrade, Seabrook programmed an additional E2010 encoder for use at its onsite siren maintenance shop with the same programming as the Rockingham County encoder to act as a spare if Rockingham County had any issues with its E2010 encoder. The E2010 encoder located in the Seabrook Station siren shop was an exact duplicate of the one in Rockingham County, with identical preprogrammed call keys that had the ability to activate the New Hampshire sirens, including the recorded voice message that could broadcast to people on the beach to alert them of an emergency onsite.
This additional programming was not necessary for use by Seabrook personnel since the siren encoder onsite was only for testing, not for siren activation. While regulations do not prohibit having a duplicate system, the siren system design report does not describe this spare encoder and does not rely on it for redundancy. Instead, the design report considers three backups to the E2010: the E969 at Rockingham County; siren activation at the backup activation point; or activation at the local town level. Additionally, there is a completely different and redundant backup system to alert the public of an emergency, the Code Red Emergency Communications Network, which acts as a reverse 911 system to notify people in the emergency planning zones.
During the bi-weekly silent siren test on July 12, 2022, there was an inadvertent actuation of the siren system which broadcast the recorded voice message alerting people on the beach that there was an emergency at Seabrook Station and directing them to listen to the radio for additional information. The technician performing the test cancelled the message upon realizing the error, so the message did not repeat eight times while going through its full siren rotation, but it did falsely announce an emergency at the power plant which caused confusion over whether people should evacuate the beaches.
Procedure SIR.10, "WPS-3000 and WPS-4008 Siren Bi-weekly Functional Test," describes how to perform this required surveillance. Revision 8 was in use at the time of the July 12, 2022, test and describes the process for the State activation locations in New Hampshire and Massachusetts to send a silent test signal to the sirens under their control. Then the station siren monitoring point initiates a system poll from the E2010 siren encoder located at Seabrook Station to verify that the siren is functional and responded appropriately to the silent test. During the July 12, 2022, test, the siren technician inadvertently pressed one of the preprogrammed call keys while polling the sirens. This preprogrammed call key activated the voice message to the beach sirens which performed as designed by broadcasting the message, although not as intended by the silent test procedure.
The siren system remained functional and capable of alerting the public to emergencies at Seabrook Station throughout the events of July 12, 2022. Notwithstanding, the inadvertent actuation of the ten beach sirens caused confusion in the public, as well as with State and local officials, as all tried to understand the situation at Seabrook Station and whether they should evacuate the beaches. Since most communications procedures are set up to alert the public of emergencies at the station and not to communicate the lack of an emergency situation, there was a delay in ensuring all interested parties had correct information.
Corrective Actions: Seabrook staff entered the issue into the corrective action program for further review and analysis. They made changes to siren testing procedures to provide additional guidance in the event of an inadvertent actuation to streamline communications with State and local officials to ensure the public has accurate information. Additionally, Seabrook removed the programming from the preset call keys at the E2010 encoder at the onsite siren maintenance shop so it can only act as a test unit and not result in accidental siren activation in the future.
Corrective Action References: CR 02431819
Performance Assessment:
Performance Deficiency: The inspectors determined that the siren program was not in compliance with the requirements in the Federal Emergency Management Agency Alert and Notification System Design Report, which is a performance deficiency that was reasonably within the ability of the licensee to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the licensee's use of a preprogrammed encoder as an unofficial backup system to the designated siren activation points caused the ten beach sirens to actuate when the siren technician inadvertently pressed the wrong button.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Table 2 worksheet (issue date December 13, 2019), and the corresponding Appendix B, Emergency Preparedness Significance Determination Process. The performance deficiency was determined to have very low safety significance (Green) because, although there was a latent error in the encoder programming, all 121 sirens in the emergency planning zone remained functional and capable of alerting the public to an emergency at Seabrook Station.
Cross-Cutting Aspect: No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b). 10 CFR 50.47(b)(5) requires, in part, the means to provide early notification and clear instruction to the populace within the plume exposure pathway emergency planning zone have been established.Section IV.D.3 of Appendix E to 10 CFR Part 50 requires, in part, the licensee demonstrate the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway emergency planning zone, and that the design objective of the prompt public alert and notification system shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway emergency planning zone within approximately 15 minutes. To do this, Seabrook implements the program in the Seabrook Station Nuclear Power Plant Alert and Notification System Design Report, Addendum 7, dated June 2013, which describes siren design, testing, and maintenance activities.
Contrary to the above, from the time of the siren upgrade program in 2009 until the inadvertent actuation of sirens on July 12, 2022, Seabrook had the ability to activate the sirens preprogrammed into their onsite siren encoder. While every other means of activating the sirens is described in the siren design report, this ability for the station to activate the sirens with the push of a single button onsite is not described or credited. When the siren technician inadvertently pushed the incorrect button during scheduled silent testing, the ten beach sirens actuated.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Evaluation of Unplanned Emergency Plan Siren Activation on July 12, 2022 71152A Seabrook Station has an alert and notification system which has the capability to complete initial public notification within the plume exposure pathway of the emergency planning zone, the ten-mile radius around the reactor site, in the event of an emergency at the station. The alert and notification system consists of 121 pole-mounted, fixed sirens installed throughout the emergency planning zone, with 94 sirens in New Hampshire and 27 in Massachusetts.
On July 12, 2022, Seabrook Station performed routine, bi-weekly, silent testing of these 121 sirens. During this testing, errors led to the actuation of ten sirens on the beaches of New Hampshire and the transmission of a message to the public through these sirens, which told them to evacuate the beaches due to a problem at Seabrook Station.
The inspectors reviewed the stations immediate corrective actions to ensure the alert and notification system remained capable of fulfilling its purpose to notify the public in an actual emergency, which included revising the testing procedure to include additional precautions and concurrent validations and increased supervision at the site and County test facility, and revising the procedure used to respond to an inadvertent actuation to incorporate feedback from State and local stakeholders. Additionally, the station conducted remediation training of the siren technician involved in the inadvertent actuation, installed a protective cover to the actuation switch at the onsite siren maintenance shop and at the County test facility, and performed a causal evaluation to review the event. The inspectors conducted additional inspection when the station completed its causal investigation. This follow-up inspection included observing the resumed siren testing under the new procedural guidance and a review of the alert and notification system design, maintenance, and testing programs using NRC Inspection Procedure 71114.02, "Alert and Notification System Evaluation."
The inspectors noted Seabrook has procedures in place for inadvertent siren actuation, including SIR.40, "Inadvertent or Suspected Activation of a Public Alert and Notification System," and ODI.94, "Report of a Siren Activation, Siren Failure or a Loss of Emergency Operations Facility Communications." Following the July 12, 2022, inadvertent actuation, Seabrook updated these procedures to strengthen the guidance and process for communications offsite, particularly in the case of a false alarm. The inspectors noted there was some delay between the time Seabrook became aware of the inadvertent siren actuation and confirmation to the public that the message was sent in error and there was no emergency at Seabrook. During this time station personnel and offsite response organization officials were actively engaged in troubleshooting the siren actuation and determining the best way to communicate this information to the public without unnecessarily alarming members of the public who did not hear the initial message. Although there was a delay in communicating the information to the public, the inspectors did not identify any additional violations.
The inspectors concluded that there is reasonable assurance that the licensee can implement its emergency plan to protect public health and safety in the event of an emergency at Seabrook. The inadvertent actuation was not the result of an error in the alert and notification system testing, maintenance, or design that would have prevented Seabrook from notifying the public in the case of an actual event. Notwithstanding, the inspectors noted a design deficiency which is documented in the inspection results section of this report, section 71114.02.
Timeline of Key Events
0925 Technician onsite at Seabrook begins bi-weekly siren testing, requesting New Hampshire primary siren activation control point (Rockingham County Dispatch Center) to initiate a silent test to all sirens. The technician then initiates a system poll test to verify all sirens received the appropriate signals. This poll is completed with satisfactory results.
1048 Technician proceeds with Massachusetts portion of test, requesting the Massachusetts primary siren activation control point (Massachusetts Emergency Management Agency (MEMA)) to initiate a silent test to all sirens.
1050 Technician initiates system poll test of Massachusetts sirens, but inadvertently pushes the button to actuate the ten sirens located along the New Hampshire seacoast prior to performing the poll test.
1051 Public address system on ten beach sirens along New Hampshire coast broadcasts message:
Attention, attention, there is a problem at Seabrook Nuclear Power Station.
The beaches are closed. Leave the beach area at once and turn on your radio for more information.
The technician is onsite at Seabrook Station and cannot hear the message on the beach but sees that the poll test is not returning expected results. The technician cancels the poll test which also terminates the broadcast message.
1055 Seabrook security receives reports of calls from local residents to station inquiring about the siren actuation.
Seabrook staffs their outage control center to begin troubleshooting activities to determine cause of actuation.
1056 Rockingham County Dispatch Center calls siren technician, questioning siren activation. Technician informs them of the inadvertent activation.
1059 MEMA calls siren technician, questioning siren activation. Technician informs them of inadvertent actuation.
1106 Seabrook Station contacts New Hampshire Commissioner of Department of Safety, MEMA supervisor, and the NRC resident inspectors to inform them of the inadvertent actuation.
1110 New Hampshire distributes public safety answering point email to ensure 911 operators are aware of inadvertent siren actuation in case of public inquiry.
1142 New Hampshire initiates a reverse 911 call to the emergency planning zones informing the public of the inadvertent siren actuation.
1202 Rockingham County Sherriffs office uses beach siren system to broadcast a message saying to disregard the earlier siren message.
1234 New Hampshire issues a press release on the inadvertent actuation.
1249 New Hampshire sends wireless emergency alert to the emergency planning zones.
1348 Integrated Public Alert and Warning System wireless emergency alert sent to emergency planning zones.
1620 Seabrook completes initial troubleshooting activities and stands down in outage control center.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 1, 2022, the inspectors presented the emergency preparedness inspection results to Brian Booth, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Seabrook Station Nuclear Power Plant Alert and Notification
System Design Report, Addendum 7
06/2013
Procedures
ODI.94
Report of Siren Activation, Siren Failure or a Loss of the
Emergency Operations Facility (EOF) Communications
Revision 10
SIR.40
Inadvertent or Suspected Activation of the Public Alert and
Notification System (PANS)
Revision 2