IR 05000443/2024010

Biennial Problem Identification and Resolution Inspection Report 05000443/2024010

ML24150A145
Person / Time
Site:	Seabrook
Issue date:	05/29/2024
From:	Matt Young NRC/RGN-I/DORS
To:	Coffey B Florida Power & Light Co
References
IR 2024010
Download: ML24150A145 (1)

Text

SUBJECT:

SEABROOK STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000443/2024010

Dear Bob Coffey:

On April 25, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a p roblem identification and resolution inspection at your Seabrook Station and discussed the results of this inspection with Christopher Robinson, Organization Effectiveness 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 to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.

The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.

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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

B.Coffey 2

If you contest the violations or the significance or severity of the violations 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.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 -0001; with copies to the Regional Administrator, Region I; 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, 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: 05000443/2024010

Enterprise Identifier: I-2024-010- 0002

Licensee: NextEra Energy Seabrook, LLC

Facility: Seabrook Station

Location: Seabrook, New Hampshire

Inspection Dates: March 4, 2024 to April 25, 2024

Inspectors: E. Allen, Resident Inspector N. Eckhoff, Health Physicist C. Khan, Senior Project Engineer S. Rutenkroger, Senior 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

Failure to Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1)

Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71152B Systems NCV 05000443/2024010-01 Resolution Open/Closed The team identified a Green finding and associated NCV of Title 10 CFR Part 50.155(c)(1) for NextEras failure to maintain the capability of the equipment relied on for the mitigation strategies and guidelines required for beyond design basis external events (BDBEE).

Specifically, when the required gated wye staged with FLEX-DG-5 was identified to be missing, NextEra did not initiate corrective action to restore the FLEX-DG-5 (or alternatively,

FLEX-DG-6) to a functional status capable of performing the required mitigation strategies for BDBEE within 45 days and did not supplement the Diverse and Flexible Coping Strategies (FLEX) component with suitable alternate equipment when the 45 days was exceeded.

Failure to Resolve Ongoing Deformation and Cracking of Emergency Feedwater Tubing Support Due to Concrete Wall Deformation Caused by Alkali-Silica Reaction Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71152B Systems NCV 05000443/2024010-02 Identification Open/Closed The team identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, for NextEras failure to promptly correct a condition adverse to quality associated with degradation of an emergency feedwater (EFW) instrumentation tubing support, due to alkali-silica reaction (ASR) related building deformation of the containment enclosure building (CEB).

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 NRC inspection team 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 team assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The team also conducted a five-year review of the condensate storage tank, refueling water storage tank, and high pressure injection system. The corrective actions for the following non-cited violations (NCVs) and licensee event reports were evaluated as part of the assessment: NCV 443/2022- 003- 01, NCV 443/2022-004- 01, NCV 443/2023-002-01, NCV 443/2023-002-02, NCV 443/2023-401-01, NCV 443/2023-401-02, NCV 443/2023-401-03, NCV 443/2023-403-01, LER 443/2023- 001, LER 443/2023-002, LER 443/2023- 003, and LER 443/2023- 005.

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

• Self-Assessments and Audits: The team assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

• Safety Conscious Work Environment: The team assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.

INSPECTION RESULTS

Assessment 71152B Assessment of the Effectiveness of the Problem Identification and Resolution Program

Problem Identification and Resolution (PI&R) Program Effectiveness:

The team determined that NextEra's PI&R program for Seabrook was generally effective and adequately supported nuclear safety and security.

Identification: The team determined that NextEra was generally effective at identification as assessed by NextEras staffs demonstrated ability to identify and enter issues into their PI&R program. However, the team identified a Green NCV due to a failure to correct a condition adverse to quality related to the EFW system in a timely manner due, in part, to not entering an identified condition into the corrective action program. The NCV is documented below.

Prioritization and Evaluation: The team determined that NextEra was generally effective at prioritization and evaluation as assessed by NextEras staffs demonstrated ability to evaluate and prioritize issues entered into their PI&R program.

Corrective Action: The team determined that NextEra was generally effective at corrective action as assessed by NextEras demonstrated ability to determine, track, implement and evaluate timely corrective actions for issues entered into their PI&R program. However, the team identified a Green NCV due t o a failure to implement the diverse and flexible coping strategies (FLEX) program by not correcting missing equipment and not establishing compensatory measures within the required time due, in part, to not effectively scheduling and tracking corrective actions. The NCV is documented below.

Assessment 71152B Assessment of the Use of Industry and NRC Operating Experience

The team determined that NextEra was generally effective at using operating experience as assessed by NextEra's staff's demonstrated process for receiving and dispositioning operating experience, including how applicable operating experience is determined.

Assessment 71152B Assessment of the Effectiveness of Audits and Self-Assessments

The team determined that NextEra was generally effective in performing audits and self-assessments as assessed by a review of a sample of NextEra audits and self-assessments conducted during the period of assessment.

Assessment 71152B Assessment of a Safety Conscious Work Environment

The team determined that NextEra was generally effective in establishing a safety conscious work environment (SCWE) as assessed through discussions and interviews with over 20 NextEra and Seabrook contractor staff. The team reviewed programmatic documents that verified NextEra has an established SCWE program. The team verified that NextEra monitors for a SCWE through self-assessment using their proceduralized Nuclear Safety Culture Monitoring Programs, employee concerns program, and review boards to screen disciplinary actions for potential chilling implications. Finally, the team determined through the discussions and interviews that NextEra and site contract employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

Failure to Maintain FLEX Equipment Consistent with the Requirements of 10 CFR 50.155(c)(1)

Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71152B Systems NCV 05000443/2024010 -01 Resolution Open/Closed The team identified a Green finding and associated NCV of Title 10 CFR Part 50.155(c)(1) for NextEras failure to maintain the capability of the equipment relied on for the mitigation strategies and guidelines required for beyond design basis external events (BDBEE).

Specifically, when the required gated wye staged with FLEX -DG-5 was identified to be missing, NextEra did not initiate corrective action to restore the FLEX-DG-5 (or alternatively, FLEX-DG-6) to a functional status capable of performing the required mitigation strategies for BDBEE within 45 days and did not supplement the FLEX component with suitable alternate equipment when the 45 days was exceeded.

Description:

On October 1, 2023, NextEra identified that the following equipment was missing from FLEX-DG-5: 3" fire hose (50'), 2-1/2" fire hose (25'), and low pressure gated wye (3" X 3" X 2 -1/2") dedicated to the submersible pump. FLEX -DG-5 was declared non-functional and the applicable FLEX specification entered. NextEra later identified on December 5, 2023, that 45 days had been exceeded in which FLEX -DG-5 was out of service due to the missing gated wye, which had not yet been replaced or obtained. FLE X-DG-5 is credited for successful performance of a number of FLEX strategies given a BDBEE. For example, one strategy involves actions to establish alternate sources of makeup to the condensate storage tank using the FLEX-DG-5 submersible pump. FLEX-DG-6 p rovides a backup to FLEX-DG-5 and was available; however, the missing fire hoses and gated wye required for the strategies are only staged on FLEX-DG-5 and do not have a backup staged on FLEX-DG-6.

EN1855.001 states that If equipment is used in a credited FLEX coping strategy and is found to be unsat or unavailable, the out of service equipment shall be tracked in SOMs [log keeping and tracking software/database] and replaced or repaired within 45 days.

EN1855.001 also states that If credited or defense in depth equipment will be unavailable for longer than the associated allowable out of service time, compensatory measures (e.g use of alternate suitable equipment or supplemental personnel) must be in place prior to exceedance of 45/90 days. The 45 days applies to credited FLEX equipment. The 90 days applies to defense in depth FLEX equipment. EN1855.001 contains Form B, FLEX Hose, Fittings And Tools Listing, which is used to determine equipment classification as one of the following: equipment credited in an approved FLEX strategy, equipment supports an approved defense in depth strategy, or equipment is spare equipment in storage as a backup or alternate to be used for replacement as needed. Note 1 equipment is classified as supports FLEX credited strategy.

The 3 to 3 and 21/2 gated wye is listed as Note 1 equipment as credited FLEX equipment and therefore requires a compensatory measure to be in place before exceeding the 45 days. This gated wye does not have a spare or backup listed or described to perform the credited function. Although NextEra identified that the 45 days had been exceeded on December 5, NextEra did not identify that a compensatory measure was required and did not establish a compensatory measure at that time.

The FLEX Hose Trailer has two gated wyes of the same size staged for use, one being credited and the other spare. However, this equipment is used in a different location and setup by a separate team according to the timeline analysis. The limiting timeline requires the task to be completed within two hours and is analyzed to take one hour to perform. Therefore, assuming an event, there was about one hour of margin for troubleshooting and correction to recognize the missing wye, identify the spare, and complete the installation of the equipment.

The Diverse and Flexible Strategies Program Manual specifies that compensatory measures, when required, will be determined based on an evaluation of the circumstances that exist at the time of FLEX equipment unavailability, the expected duration of the unavailability, and the significance of the equipment to the FLEX mitigation strategy. The Manual requires the evaluation to document the adequacy of the compensatory measures implemented and describes examples of possible compensatory measures which may include, but are not limited to: pre-staging portable FLEX equipment, use of alternate suitable equipment, supplemental personnel, and additional administrative control.

The team identified that neither the first AR on October 1, 2023 nor the second AR on December 5, 2023 identified that a compensatory measure was required or described one being established. The team questioned whether a compensatory measure had been established as required by EN 1855.001, and NextEra confirmed that no compensatory measure had been established. The team also identified that the first AR was closed to a work request with a work needed date of January 22, 2024, which was also not in accordance with EN1855.001. Specifically, the procedure requires equipment to be replaced or repaired within 45 days with the additional provision to establish a compensatory measure if/when such corrective action is not achieved. NextEra ultimately replaced the gated wye with one contained in the warehouse inventory 70 days after the first AR was initiated. Given that replacing the wye was readily achievable and that EN1855.001 explicitly requires that even spare FLEX equipment be repaired/replaced as soon as possible, EN1855.001 reasonably required this replacement be accomplished within 45 days.

Corrective Actions: NextEra replaced the missing gated wye 70 days after identifying the missing equipment. NextEra initiated an AR for the failure to replace the wye in a timely manner and failing to establish a compensatory measure prior to exceeding 45 days.

Corrective Action References: AR #2483356

Performance Assessment:

Performance Deficiency: The failure to replace the credited gated wye within 45 days and the failure to establish a compensatory measure prior to exceeding 45 days without the wye staged on the FLEX-DG-5 was reasonably within Seabrooks ability to foresee and correct and should have been prevented, and therefore is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, credited FLEX equipment for an established FLEX strategy was unavailable without an established compensatory measure for longer than the allowed time. The analyzed timeline margin was affected given the uncertainties associated with troubleshooting during a high stress event requiring a refill of the condensate storage tank coupled with a decision whether or not to continue using the turbine driven auxiliary feedwater pump as its source of water lowers to a level potentially damaging the pump. We also noted that the performance deficiency was similar to Example 12.b in Appendix E, in that the amount of time the degraded condition existed exceeded that specified by the FLEX program.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The team determined this finding to be of very low safety significance (Green) in accordance with Exhibit 2. Specifically, the finding involved equipment credited in a Phase 2 FLEX strategy, and although the FLEX function was degraded, the team did not conclude that the mitigating strategy could not be completed in accordance with existing plant procedures within the time allotted. The team made this determination because the spare gated wyes on the FLEX Hose Trailer and in the warehouse were available to identify, obtain, and use, with one hour of analyzed margin.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the AR initiated on October 1, 2023, was closed on October 10, 2023, with no actions specified to a referenced work request. The work request was given a need date of January 22, 2024, which was not in a timely manner commensurate with the safety significance. Spare FLEX equipment is required to be replaced as soon as practical, defense in depth equipment has a higher priority and is required to be restored within 90 days, and credited FLEX equipment has a higher priority still and is required to be restored within 45 days.

Enforcement:

Violation: Title 10 CFR Part 50.155(c)(1) requires, in part, that the equipment relied on for the mitigation strategies and guidelines required by 10 CFR 50.155(b)(1) must have sufficient capacity and capability to perform the functions required by 10 CFR 50.155(b)(1). 10 CFR 50.155(b)(1) requires, in part, the required mitigation strategies for BDBEE be developed, implemented, and maintained, and the strategies must include maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities. Nuclear Energy Institute (NEI)

NEI 12-06, Revision 0 (Ref. 6.79) and Revision 2 (Ref. 6.80), as endorsed by NRC staff in Japan Lessons-Learned Directorate (JLD) Interim Staff Guidance (ISG) JLD-ISG-2012- 01 Revision 0 (Ref. 6.81) and Revision 1 (Ref. 6.82), sets forth a method of complying with 10 CFR 50.155 (originally Orders EA-12- 051 and EA-12- 049, since revoked and superseded by 10 CFR 50.155). Seabrook Station complies with NEI 12- 06, Revision 2, and the requirements for FLEX Equipment availability, including allowable outage time, are described in document DFCS, Diverse and Flexible Coping Strategies (FLEX) Program, Appendix C, FLEX Eq uipment Unavailability. DFCS requires that with one or more FLEX components credited and specified in a table, including FLEX-DG-5 (or alternatively, FLEX-DG-6), not meeting functional requirements, initiate corrective action to restore the equipment to functional status within 45 days and with the restoration time not met to immediately supplement the FLEX component with suitable alternate equipment.

Contrary to the above, the equipment relied on for the mitigation strategies and guidelines required by 10 CFR 50.155(b)(1) did not have sufficient capability to perform the functions required by 10 CFR 50.155(b)(1). Specifically, when the required gated wye staged with FLEX-DG-5 was identified to be missing on October 1, 2023, NextEra did not initiate corrective action to restore the FLEX-DG-5 (or alternatively, FLEX-DG-6) to a functional status capable of performing the required mitigation strategies for BDBEE within 45 days and did not supplement the FLEX component with suitable alternate equipment when the 45 days was exceeded, until replacement 70 days later.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Resolve Ongoing Deformation and Cracking of Emergency Feedwater Tubing Support Due to Concrete Wall Deformation Caused by Alkali-Silica Reaction Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71152B Systems NCV 05000443/2024010 -02 Identification Open/Closed The team identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for NextEras failure to promptly correct a condition adverse to quality associated with degradation of an emergency feedwater (EFW) instrumentation tubing support, due to alkalisilica reaction (ASR) related building deformation of the -

containment enclosure building (CEB).

Description:

On August 13, 2015, NextEra identified that support EF -220 -10, which supports EFW instrumentation tubing, was in contact with the CEB, likely due to the known ASR condition. The instrumentation tubing consists of twelve sensing lines for six flow transmitters associated with the four steam generators. The EFW system must have the capability to automatically detect and terminate flow to a depressurized steam generator to conserve condensate storage tank inventory and limit mass and energy input to the containment from a break. The EFW instrument tubing must also retain integrity for proper operation of the affected EFW flow transmitters to ensure accurate flow indication and allow proper isolation of an EFW injection line in the event of a downstream break.

NextEra performed a qualitative evaluation which concluded that the condition of the support was acceptable because the support and welds were intact with no noted movement. The evaluation also concluded that the support should be reworked to eliminate contact with the CEB. On October 19, 2017, a follow -up walkdown of this support was conducted in accordance with the structures monitoring program (SMP) which documented no notable changes from the previous walkdown in 2015 but noted that the support remained in contact with the CEB. A new qualitative evaluation was performed that concluded the current condition of the support was acceptable but that the support should be reworked to eliminate this contact with the CEB. The support was inspected again in 2019 and 2021, in accordance with the SMP, with no changes identified or documented. On October 12, 2022, during work for an unrelated activity, NextEra identified that this support was deformed and that one of the welds had a tear approximately three inches long. A new qualitative evaluation was performed which concluded that the support remained functional but noted that the 2015 and 2017 evaluations did not consider sustained or impact loading from the CEB and recommended that the support be reworked as soon as possible to reestablish adequate clearance from the CEB wall. The team noted that the support was not reworked in response to this, or any of the previous recommendations.

The team reviewed NextEras documentation regarding this issue and questioned the adequacy of the prior evaluations (including stress/loading due to ASR and seismic events),the completeness of the conditions previously documented, and the timeliness of the corrective action to reestablish adequate clearance with the CEB wall. In responding to the concerns raised by the team, NextEra subsequently identified that there was an additional vertical crack in the tube steel member of support EF-220-10 which was observed to have penetrated the entire thickness of the tube steel resulting in a through-wall crack approximately one inch in length. Based on the additional degradation of the support and the teams questions, NextEra modified the support and reestablished clearance with the CEB wall on March 30, 2024. NextEra also performed a quantitative finite element stress analysis of the support given all required loads, including seismic and ASR induced, which concluded that the support would deform further but remain functional.

Finally, the team noted that NextEra did not initiate a condition report as required during the 2023 SMP inspection when changes were identified compared to the prior SMP inspections in 2021, as well as the degradation identified in 2022 as mentioned above. Specifically, the 2023 SMP inspection documented that the support was deformed, one of the welds was cracked, and there was a crack on the interior of the support. However, the 2023 SMP inspection also documented that there was no change from the prior SMP inspections, which was incorrect because these conditions were not previously documented in the prior SMP inspections. In addition, the 2023 SMP inspection did not recognize or document that the crack on the interior of the support was a change from the degradation identified in 2022.

Corrective Actions: NextEra modified the EFW instrumentation tubing supports to reestablish clearance with the CEB wall and developed an Adverse Condition Monitoring Plan to monitor the gap between the wall and tube support every three months to ensure the instrument tubing is not challenged.

Corrective Action References: AR 2481829

Performance Assessment:

Performance Deficiency: NextEra failed to correct the EFW instrumentation tubing support structure in a prompt and timely manner which was reasonably within NextEras ability to foresee and correct and should have been prevented, and therefore is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the degraded condition adversely impacted design margins of a structural support necessary for EFW operation and resulted in reasonable doubt with respect to the availability and reliability of the EFW system. The support required a modification and a new quantitative analysis to resolve the doubt of operability, similar to Example 3.e of IMC 0612, Appendix E.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The team determined this finding to be of very low safety significance (Green) in accordance with Exhibit 2, because the finding is a deficiency affecting the design or qualification of a mitigating SSC, and the SSC maintained its operability. Specifically, the team reviewed NextEras detailed evaluation that concluded the support remained intact under all design basis conditions and did not disagree with the analysis and conclusions.

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. The team considered the primary cause of the finding to be the failure to initiate a condition report in the 2023 SMP inspection when a new crack was identified on the interior of the support.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to ensure that conditions adverse to quality, such as deficiencies and non-conformances, are promptly identified and corrected.

Contrary to the above, from a time after August 13, 2015, until March 30, 2024, NextEra did not ensure that a condition adverse to quality was promptly corrected. Specifically, NextEra did not implement corrective actions to resolve the contact between support EF-220- 10 and the CEB wall and subsequent degradation of the support weld/tube steel and did not modify the support to reestablish the required seismic clearance.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On April 25, 2024, the inspector s presented the biennial problem identification and resolution inspection results to Christopher Robinson, Organization Effectiveness Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 124852

Documents 219118

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Inspection Type Designation Description or Title Revision or

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2481410

2481513

2481516

2481661

2481701

2481829

2481897

2481950

2481968

2481969

2481970

2481975

2482012

2482017

2482018

2482019

2483186

2483356

71152B Miscellaneous Emergency Item of Interest Number EF301-28. Initial Discover Report

Feedwater Pump and Follow Up Walkdown Reports

Room EF301

71152B Miscellaneous Emergency Item of Interest Number EF301-41, Initial Discover Report

Feedwater Pump and Follow Up Walkdown Reports

Room EF301

71152B Procedures

71152B Procedures AD-AA-08 Nuclear Safety Culture Revision 6

71152B Procedures AD-AA-103 Nuclear Safety Culture Program Revision 26

71152B Procedures DFCS Diverse and Flexible Coping Strategies (FLEX) Program Revision 7

71152B Procedures EN-AA-110 Diverse and Flexible Coping Strategies (FLEX) Program Revision 13

71152B Procedures EN-AA-203-1001 Operability Determinations Revision 41

71152B Procedures EN1855.001 FLEX Equipment Use Control and System Administration Revision 12

71152B Procedures ER-AA-201-2002 System Performance Monitoring Revision 8

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Procedures FSG-6.1 Alternate CST Makeup Equipment Deployment Revision 1

71152B Procedures LI-AA-102-1001 Regulatory Reporting Revision 42

71152B Procedures MA-AA-204-1000 Preventive Maintenance and Surveillance Procedure Revision 21

71152B Procedures NA-AA-06 \\Safety Conscious Work Environment Revision 3

71152B Procedures NA-AA-06 Safety Conscious Work Environment Revision 3

71152B Procedures NA-AA-07 Employee Concerns Program Revision 0

71152B Procedures NA-AA-200-1000 Employee Concerns Program Revision 8

71152B Procedures NA-AA-202-1000, Audit Topic Selection and Scheduling Revision 22

71152B Procedures NA-AA-203-1000 Performance of Nuclear Assurance Audits Revision 25

71152B Procedures NA-AA-204-1000, Findings Revision 11

71152B Procedures NA-AA-211-1000 Nuclear Assurance Corrective Action Revision 8

71152B Procedures NAQA Quality Assurance Manual Revision 56

71152B Procedures OX1462.01 FLEX Equipment Inventory and Readiness Surveillance Revision 13

71152B Procedures PI-AA-100 Condition Assessment and Response Revision 20

71152B Procedures PI-AA-100-1005 Root Cause Analysis Revision 28

71152B Procedures PI-AA-100-1006 Common Cause Evaluation Revision 16

71152B Procedures PI-AA-100-1007 Issue Investigation, Revision 33 Revision 33

71152B Procedures PI-AA-101 Assessment and Improvement Programs Revision 33

71152B Procedures PI-AA-101-1000 Level 2 Independent Assessment Planning, Conduct and Revision 29

Reporting

71152B Procedures PI-AA-101-1001 Level 1 Core Business Assessments Revision 25

71152B Procedures PI-AA-102 Operating Experience Program Revision 20

71152B Procedures PI-AA-102-1000 Significant Operating Experience Report (SOER) and INPO Revision 22

Event Report (IER) Process Implementation

71152B Procedures PI-AA-102-1001 Operating Experience Program Screening and Responding Revision 29

to Incoming Operating Experience

71152B Procedures PI-AA-102-1003 Sharing Operating Experience with Nuclear Industry Revision 18

71152B Procedures PI-AA-104-1000 Condition Reporting Revision 40

71152B Procedures PI-AA-207-1000 Station Self-Evaluation and Trending Analysis Revision 12

71152B Procedures Quality (FPL-1) Revision 27

Assurance

Topical Report

71152B Procedures SMP5.1 Equipment Impacted by Structural Deformation Monitoring Revision 2

Inspection Type Designation Description or Title Revision or

Procedure Date

Walkdowns, Data Collection and Evaluation

71152B Procedures SMPM Structures Monitoring Program Manual Revision 15

71152B Procedures WM-AA-200 Work Management Process Overview Revision 23

71152B Procedures WM-AA-201 Work Order Identification, Screening and Validation Process Revision 40

71152B Procedures WM-AA-203 Online Scheduling Process Revision 23

71152B Procedures WM-AA-203-1000 Online Work Management Scope Control Revision 7

71152B Self-Assessments JNA 22-001 Cyber Security (FLEET)

71152B Self-Assessments SBK Operations

71152B Self-Assessments SBK Security

71152B Self-Assessments SBK 22-007 Maintenance and Work Management

71152B Self-Assessments SBK 23-002 Chemistry, Effluents, and Environmental Monitoring

71152B Work Orders 40763659-01

40784716- 01

40784716- 02

40784718- 01

40784718- 02

40788338- 01

40815596- 01

40816890- 01

40834987- 01

40834987- 02

40834988- 01

40834988- 02

40861258- 01

40866128- 01

40866165- 01

40869527- 01

40869624-01

20