IR 05000443/2019002

Integrated Inspection Report 05000443/2019002

ML19217A286
Person / Time
Site:	Seabrook
Issue date:	08/05/2019
From:	Brice Bickett NRC Region 1
To:	Moul D Florida Power & Light Co
References
IR 2019002
Download: ML19217A286 (21)

Text

ust 5, 2019

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - INTEGRATED INSPECTION REPORT 05000443/2019002

Dear Mr. Moul:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. On July 30, 2019, the NRC inspectors discussed the results of this inspection with Mr. Eric McCartney, Site Vice President, and other members of your staff.

The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. The inspectors documented a licensee-identified violation which was determined to be Severity Level IV in this report. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or 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. 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.

Sincerely,

/RA/

Brice A. Bickett, Chief Reactor Projects Branch 3 Docket No. 05000443 License No. NPF-86

Enclosure:

As stated

Inspection Report

Docket Number: 05000443 License Number: NPF-86 Report Number: 05000443/2019002 Enterprise Identifier: I-2019-002-0053 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No. 1 Location: Seabrook, NH Inspection Dates: April 01, 2019 to June 30, 2019 Inspectors: P. Cataldo, Senior Resident Inspector E. Allen, Resident Inspector T. Daun, Resident Inspector J. Ambrosini, Sr. Emergency Preparedness Inspector J. DeBoer, Senior Project Engineer N. Floyd, Senior Reactor Inspector J. Furia, Senior Health Physicist Approved By: Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Seabrook Station, Unit No. 1 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. Licensee-identified non-cited violations are documented in report Section: 71153.

List of Findings and Violations Emergency Planning Audit Did Not Evaluate Interface With Offsite Response Organizations Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.1] - Resources 71114.05 Preparedness NCV 05000443/2019002-01 Open/Closed The inspector identified a Green, non-cited violation of 10 CFR 50.54(t)(2) because NextEra staff did not include an evaluation of the adequacy of the interfaces with State and local governments in a review of emergency preparedness program elements in Audit Report SBK-17-007 dated July 24, 2017. Specifically, audit personnel did not provide offsite officials with an opportunity to provide their view of the adequacy of the interface to the audit team, resulting in this interface not being evaluated.

Emergency Plan Required Drills Inadequately Documented Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.8] - Procedure 71114.05 Preparedness NCV 05000443/2019002-02 Adherence Open/Closed The inspector identified a Green, non-cited violation of 10 CFR 50.54(q)(2), because NextEra did not maintain the effectiveness of the stations emergency plan. Specifically, NextEra did not follow procedure EP-AA-101-1000, Nuclear Division Drill and Exercise, Revision 23 that requires, for crediting drills embedded inside of larger scale exercises, the drills shall be documented in the exercise report and the status of the drill objectives shall be marked as satisfactory (SAT), SAT with comments or not met. From 2017 to 2018, NextEra did not document objective evidence in their exercise reports of the completion of Health Physics and Core Damage Assessment drills embedded into larger exercises.

Additional Tracking Items None

PLANT STATUS

Seabrook Station began the inspection period operating at 100 percent rated thermal power. There were no operational power changes of regulatory significance for the remainder of 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 plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

(1) The inspectors evaluated summer readiness of offsite and alternate alternating current power systems

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 'B' train service water alignment for SW-V-53 replacement on April 18

(2) 'B' emergency diesel generator return-to-service on May 28

(3) 'A' emergency diesel generator during 'B' emergency diesel generator maintenance outage from June 3-5

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of the

'B' emergency diesel generator systems on June 24

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) 'A' residual heat removal vault (RHR-F-1B) on April 22

(2) 'A' residual heat removal vault (RHR-F-3B) on April 22

(3) 'A' residual heat removal vault (RHR-F-4B) on April 22

(4) Discharge transition structure (DS-F-1-) during the week of June 17

(5) Intake transition structure (IS-F-1-0) during the week of June 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)

The inspectors observed and evaluated the following performance activities in the control room:

• Pre-evolution and start up brief for condensate pump 30B on April 2

• Startup activities and alarm response for condensate pump 30B on April 5

• Operation and pressurization of the safety injection system accumulator on May 8 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed-operator requalification examination in the simulator on May 20

71111.12 - Maintenance Effectiveness Quality Control (IP Section 02.02)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) 'B' steam generator atmospheric steam dump valve solenoid replacement on April 30 Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Seismic monitor maintenance and troubleshooting on April 6 and April 11

(2) Performance monitoring of coolant charging system check valves on June 20

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Risk assessment associated with condensate pump 30B replacement activities on April 2

(2) Emergent repairs associated with CC-V-4 on April 25

(3) 'A' solid state protection system surveillance testing on May 16

(4) Switchyard activities and supplemental emergency power system maintenance activities on May 20

(5) Switchyard activities and 'B' emergency diesel generator maintenance outage from June 3-5

(6) Switchyard activities and 'A' emergency diesel generator maintenance from June 17-18

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Emergency feedwater pump building seismic analysis error identified in original calculation (AR 02301508)

(2) Safety injection pump oil cooler leakage (AR02308269)

(3) 'A' service water strainer bypass line leakage (AR2312909)

(4) Cooling tower service water pump 110A discharge piping degradation (AR02311189)

(5) Emergency feedwater system operability due to scaffolding construction issues (AR2312311)

(6) Control and emergency diesel generator building below-grade walls structural evaluation with alkali-silica reaction loading (AR 02315042)

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) End-of-life replacement of primary component cooling water expansion tank level transmitter on April 22 (EC289417)

(2) 'A' service water strainer bypass line leak repair on May 15 (EC293162)

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post-maintenance tests:

(1) Emergency feedwater pump house tornado damper maintenance on April 11

(2) Post-maintenance testing of SW-V-53 following replacement on April 19

(3) Safety injection test header isolation solenoid valve replacement on May 24

(4) 'B' cooling tower service water pump discharge valve maintenance on May 31

(5) 'B' emergency diesel generator following maintenance outage from June 3-5

(6) 'A' atmospheric steam dump valve solenoid air leak repair on June 12

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

(1) Full stroke testing of atmospheric steam dump valves on June 10

Surveillance Tests (other) (IP Section 03.01) (5 Samples)

(1) Nuclear instrumentation N-4 detector saturation curve determination on April 24

(2) Emergency power sequencer operability testing on April 29

(3) Solid state protection system logic testing on May 2

(4) CC-V-1282 check valve non-intrusive exercise test on June 12

(5) Diesel generator 1B monthly operability surveillance on June 24

71114.02 - Alert and Notification System Testing Inspection Review (IP Section 02.01-02.04)

The inspectors evaluated the following maintenance and testing of the alert and notification system for Seabrook Station from April 8-11:

• For the period April 1, 2017 to March 31, 2019

71114.03 - Emergency Response Organization Staffing and Augmentation System Inspection Review (IP Section 02.01-02.02)

The inspectors evaluated the readiness of the Emergency Preparedness Organization at Seabrook Station from April 8-11:

• For the period April 1, 2017 to March 31, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

• CRC# 2309 - NM 11700, Emergency Preparedness Responsibilities of Primary, Subject to Call and Secondary Emergency Response Organization Members, Revision 38

• CRC# 2315 - Emergency Response Organization Training Program Description Revision 02

• CRC# 2320 - ER 3.1, Technical Support Center Operations, Revision 67

• CRC# 2322 - ER 3.3, Emergency Operations Facility Operations, Revision 63

• CRC# 2324 - ER 3.5 , Joint Information Center Operations, Revision 41 This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness Inspection Review (IP Section 02.01 - 02.11)

The inspectors evaluated the maintenance of the emergency preparedness program at Seabrook Station from April 8-11:

• For the period April 1, 2017 to March 21, 2019

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02)

The inspectors evaluated:

• The emergency planning aspects of a licensed-operator simulator evaluation was conducted in the Unit 1 plant-reference simulator on May 20. This evaluation included the initiating conditions that resulted in associated emergency classification and notifications in accordance with the NextEra emergency plan.

71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (IP Section 02.01)

The inspectors evaluated radiological hazards assessments and controls.

The inspectors conducted independent radiation measurements during walkdowns of the facility and reviewed the radiological survey program, air sampling and analysis, continuous air monitor use, recent plant radiation surveys for radiological work activities, and any changes to plant operations since the last inspection, to verify survey adequacy of any new radiological hazards for onsite workers or members of the public.

71124.02 - Occupational ALARA Planning and Controls Radiological Work Planning (IP Section 02.01)

The inspectors evaluated the licensees radiological work planning.

The inspectors selected the following radiological work activities for review based on exposure significance:

• RWP 18-02, Steam Generator Eddy Current Testing & Tube Plugging

• RWP 18-01, Reactor Vessel Disassembly & Reassembly

• RWP 18-03, Steam Generator Secondary Maintenance

71124.04 - Occupational Dose Assessment External Dosimetry (IP Section 02.02)

The inspectors reviewed dosimetry NVLAP accreditation, onsite storage of dosimeters, the use of correction factors to align electronic personal dosimeter results with NVLAP dosimetry results, dosimetry occurrence reports, and corrective action program documents for adverse trends related to external dosimetry.

Internal Dosimetry (IP Section 02.03) (1 Sample)

The inspectors evaluated the internal dosimetry program implementation.

The inspectors reviewed internal dosimetry procedures, whole body counter measurement sensitivity and use, adequacy of the program for whole body count monitoring of plant radionuclides or other bioassay technique, adequacy of the program for dose assessments based on air sample monitoring and the use of respiratory protection, and internal dose assessments for any actual internal exposure.

Source Term Categorization (IP Section 02.01) (1 Sample)

The inspectors reviewed the plant radiation characterization (including gamma, beta, alpha, and neutron) being monitored. The inspector verified the use of scaling factors to account for hard-to-detect radionuclides in internal dose assessments.

Special Dosimetric Situations (IP Section 02.04) (1 Sample)

The inspectors evaluated the following special dosimetric situation:

The inspectors reviewed worker notification of the risks of radiation exposure to the embryo/fetus, the dosimetry monitoring program for declared pregnant workers, external dose monitoring of workers in large dose rate gradient environments, and dose assessments performed since the last inspection that used multi-badging, skin dose or neutron dose assessments.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) ===

For the period April 1, 2018 through March 31, 2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

For the period April 1, 2018 through March 31, 2019 EP01: Drill/Exercise Performance (IP Section 02.12) (1 Sample)

For the period April 1, 2018 to March 31, 2019

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

For the period April 1, 2018 to March 31, 2019 EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

For the period April 1, 2018 to March 31, 2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

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

• Review of alkali-silica reaction impact on concrete structures

Semiannual Trend Review (IP Section 02.02) (1 Sample)

The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of more significant safety issues.

INSPECTION RESULTS

Observation: Semi-Annual Trend Review 71152 The inspectors reviewed NextEras corrective action program for trends that might be indicative of more significant safety issues. The inspectors reviewed condition reports, level one assessments, system health reports, and control room/panel deficiencies. In particular, the inspectors evaluated the condition reports generated during the first half of 2019 to identify any negative trends in equipment and human performance, as well as problem identification and resolution.

The inspectors focused primarily on the overall identification of potential adverse trends identified through

(1) initial screening performed by the corrective action program coordinators for the applicable departments, and

(2) the identification of potential trends or cognitive trends, which reveal potential performance declines in particular areas, and is conducted by the management review committee. The inspectors focused on this initial screening and follow-up reviews, because these responsibilities were revised in January 2019, following the formal removal of the previously-mandated quarterly trend analysis and reporting, and conducted under PI-AA-207-1000, Revision 11, Station Self-Evaluation and Trending

Analysis.

The inspectors contrasted the issues identified during their review of condition reports for the first half of 2019, with those equipment reliability issued tracked via the engineering system health reporting program, as well as human performance and problem identification and resolution issues addressed as potential adverse or cognitive trends identified by NextEra staff, and subsequent level one assessments for other aspects of station performance. The inspectors verified actions were consistent with the corrective action program requirements, as well as the trending procedure previously discussed.

For example, the inspectors reviewed assessments performed following the B emergency diesel generator maintenance outage, which addressed identified post-maintenance critique items, as well as a fire protection assessment, conducted to verify that the fire protection program implementation was performed to meet specific fire-related regulatory requirements.

Based on the overall results of the semiannual trend review, the inspectors determined that issues were appropriately evaluated by NextEra staff for potential trends and resolved within the scope of the corrective action program and other requisite procedures.

Observation: Review of Alkali-Silica Reaction Impact on Concrete Structures 71152 NRC inspectors performed a periodic site visit to Seabrook Station to review NextEras monitoring of alkali-silica reaction (ASR) on affected reinforced concrete structures, per their 10 CFR 50.65 Maintenance Rule Structures Monitoring Program, and NextEras corrective action process. The inspectors verified on a sampling basis that significant changes or different presentations of ASR on the affected structures were appropriately considered for impact on the Seabrook prompt operability determinations for the affected structures. In addition, the inspectors performed independent walkdowns of ASR-affected areas and reviewed reports of recently collected measurement data, including combined crack index, in-plane expansion, through-wall expansion, and building deformation monitoring elements, to verify that the structures were within the established acceptable monitoring parameters.

The inspectors also assessed whether NextEra staff were completing structural evaluations in accordance with the Structures Monitoring Program and the methodology document approved by the NRC. Since 2010, Seabrook structures affected by ASR were characterized as operable, but degraded and non-conforming, and were evaluated by open prompt operability determinations within NextEras corrective action program. The NRC staff approved License Amendment Request 16-03 and issued Amendment No. 159 on March 11, 2019, which accepted a methodology for evaluation of ASR-affected concrete at Seabrook. The inspectors reviewed the status of the open operability determinations related to ASR as well as NextEras action plan to close them. The inspectors noted that some of the operability determinations related to specific structures, five in total, remain open until further corrective action is completed. These actions include additional monitoring, reanalysis, and the potential for structural modification. Based on discussions with NextEra staff, the estimated completion date for the remaining structural evaluations was the end of June 2019.

The inspectors reviewed a sample of calculations and structural evaluations to verify that NextEra staff appropriately analyzed ASR loading on the reinforced concrete structures in accordance the methodology in the approved license amendment. Specifically for this inspection, the inspectors reviewed the evaluation of the Primary Auxiliary Building. The inspectors noted that the results of this calculation identified three localized areas that did not meet the acceptable design criteria once the load factor for ASR loading was applied.

NextEra staff wrote a condition report to address the non-conformance and completed a prompt operability determination to ensure the structure remained capable of performing its design function. The inspectors reviewed the operability determination and performed an independent walkdown of the structure. The inspectors did not observe any indications of loading distress or other structural integrity issues as evident by the absence of structural cracks. NextEra enhanced the monitoring of this structure through additional displacement measurements at an increased frequency. NextEra planned corrective actions to take core samples in the localized areas to further assess the potential extent of ASR and to re-evaluate the structure based on the results of those samples.

The inspectors concluded that NextEra staff continue to monitor reinforced concrete structures in accordance with Seabrook program procedures. Furthermore, the inspectors concluded that the structural evaluations were completed in accordance with the approved methodology document, the structures remained capable of performing their intended function by meeting the established monitoring limits, and issues were appropriately identified and evaluated.

Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR 50.9(a) requires that information required by the Commissions regulations to be maintained by the licensee shall be complete and accurate in all material respects. Title 10 CFR 73.56(o)(2)(i) requires, in part, that licensees shall maintain records of the information that must be collected under 10 CFR 73.56(d) that results in the granting of unescorted access or certifying of unescorted access authorization. 10 CFR 73.56(d)(i), in part, requires that any individual who is applying for unescorted access or unescorted access authorization shall disclose the personal history information that is required by the licensee's access authorization program, including any information that may be necessary for the reviewing official to make a determination of the individual's trustworthiness and reliability. Title 10 CFR 73.56(d)(7) requires that the licensee's reviewing official shall evaluate the entire criminal history record of an individual who is applying for unescorted access or unescorted access authorization to determine whether the individual has a record of criminal activity that may adversely impact his or her trustworthiness and reliability.

Contrary to the above, from July 8, 2013 to May 29, 2019, NextEra maintained information, that was required by the Commissions regulations to be maintained, that was not complete and accurate in all material respects. Specifically, an individual who applied for unescorted access authorization failed to disclose his complete history record as part of the personal history information reviewed by the licensee to make a determination of the individuals trustworthiness and reliability. Namely, on July 8, 2013, when filling out a personal history questionnaire, the individual omitted information about an April 29, 2013 arrest. The information was material to the NRC because the licensee granted unescorted access authorization to the individual until May 29, 2019, based, in part, on this inaccurate information.

Significance/Severity: Severity Level IV. The inspectors determined that the issue was a Severity Level IV violation and is being treated as a non-cited violation, consistent with Sections 2.3.2 and 6.9 of the Enforcement Policy. In particular, the inspectors considered that this violation pertaining to inaccurate information was an isolated occurrence that did not call into question the licensees ability to meet the overall performance objective of the access authorization program, as stated in 10 CFR 73.56(c), that individuals granted unescorted access authorization do not constitute an unreasonable risk to public health and safety or the common defense and security, including the potential to commit radiological sabotage.

Specifically, criminal history is only one part of an individuals personal information evaluated for access authorization and an arrest, on its own, is not necessarily a disqualifying occurrence. Additionally, the individual, while onsite, remained under the licensees continual behavior observation program, was not involved in any operational errors that affected plant safety, and did not pose a security concern.

Corrective Action References: 02319518 Emergency Planning Audit Did Not Evaluate Interface With Offsite Response Organizations Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.1] - 71114.05 Preparedness NCV 05000443/2019002-01 Resources Open/Closed The inspector identified a Green, non-cited violation of 10 CFR 50.54(t)(2) because NextEra staff did not include an evaluation of the adequacy of the interfaces with State and local governments in a review of emergency preparedness program elements in Audit Report SBK-17-007 dated July 24, 2017. Specifically, audit personnel did not provide offsite officials with an opportunity to provide their view of the adequacy of the interface to the audit team, resulting in this interface not being evaluated.

Description:

The inspector reviewed Audit Report SBK-17-007 dated July 24, 2017 and observed that the report did not document an annual evaluation for adequacy of interfaces with offsite response organizations. Title 10 to CFR 50.54(t) requires audits to assess and document the offsite agency interface. Outreach to State and local governments are necessary to evaluate the adequacy of interfaces between NextEra and State and local governments (one of the evaluation areas) and to allow these agencies communication opportunities to help the auditor document the status of the relationship.

Based on discussion with the auditors, the inspector concluded that NextEra elected to conduct a limited-scope audit based upon the verbiage in 10 CFR 50.54(t)(1)(ii), which states licensees may extend the audit to 24 months vice 12 months, based on an assessment by NextEra against performance indicators. NextEra elected to use the NRC Emergency Preparedness Performance Indicators that were not appropriate in this case, because those performance indicators do not assess the emergency planning program performance elements regarding: emergency response facility availability; completeness of emergency preparedness duty roster personnel training; quality of response to declared plant emergencies; timeliness of corrective action closure; a measure of state and local interface; and, percentage of drill objectives successfully demonstrated. Performance indicators developed to assess the preceding list of emergency planning program elements would provide justification to extend the 12 month program review required by 50.54(t)(1)(i) to 24 months as allowed by 50.54(t)(1)(ii), had the indicators demonstrated acceptable performance.

Therefore, the inspector concluded that NextEra did not conduct an adequate evaluation of the interface between the Seabrooks emergency preparedness organization and State and local government officials as required by 10 CFR 50.54(t)(2) because it was removed from the 2017 audit scope.

Corrective Actions: NextEra entered these issues into their corrective action program and plan to perform revisions to the implementing procedure to prevent recurrence.

Corrective Action References: 02310004, 02309994, 02215882

Performance Assessment:

Performance Deficiency: The inspector determined that not performing a review of the emergency planning program elements, including an evaluation for the adequacy of the interface with State and local governments as required by 10 CFR 50.54(t)(2) on a 12-month interval was a performance deficiency that was within NextEras ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Offsite EP attribute of the Emergency Preparedness cornerstone. The inspectors determined the performance deficiency was more than minor because it was associated with the offsite emergency preparedness attribute of the Emergency Preparedness Cornerstone and affected the cornerstone objective to ensure NextEras capability to implement adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate measures to protect the health and safety of the public could be adversely affected if communication and coordination problems between NextEra and State and local governments are not detected and corrected by appropriate performance indicators and periodic audits.

Significance: The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP. The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1, 2, and 3, worksheets (effective date October 7, 2016); and the corresponding IMC 0609 Appendix B, Emergency Preparedness Significance Determination Process, step 3.2b, the performance deficiency was determined to have very low safety significance (Green)because it was a noncompliance with NRC requirements.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

NextEra elected to conduct a limited scope audit due to a misinterpretation of the regulation and the unavailability of sufficient resources to support a full-scale audit.

Enforcement:

Violation: Title 10 CFR 50.54(t) requires, in part, a review of emergency preparedness program elements including an evaluation for adequacy of the interfaces with State and local governments at intervals not to exceed 12 months or at least once every 24 months based on an assessment by the licensee against performance indicators.

Contrary to the above, from July 2016 to July 2017, NextEras review of emergency preparedness program elements did not include an evaluation for adequacy of the interfaces with State and local governments or an assessment against adequate performance indicators. Specifically, the review conducted under Audit Report SBK 17-007 did not provide offsite response organizations the opportunity to provide information about the adequacy of their interface with NextEra.

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

Emergency Plan Required Drills Inadequately Documented Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.8] - 71114.05 Preparedness NCV 05000443/2019002-02 Procedure Open/Closed Adherence The inspector identified a Green, non-cited violation of 10 CFR 50.54(q)(2), because NextEra did not maintain the effectiveness of the stations emergency plan. Specifically, NextEra did not follow procedure EP-AA-101-1000, Nuclear Division Drill and Exercise, Revision 23 that requires, for crediting drills embedded inside of larger scale exercises, the drills shall be documented in the exercise report and the status of the drill objectives shall be marked as satisfactory (SAT), SAT with comments or not met. From 2017 to 2018, NextEra did not document objective evidence in their exercise reports of the completion of Health Physics and Core Damage Assessment drills embedded into larger exercises.

Description:

The inspector reviewed reports of drills and exercises conducted by NextEra between 2017 and 2018, and compared the records to the requirements of the Seabrook emergency plan. The inspector determined that NextEra was required to document Health Physics drills on a semi-annual basis and Core Damage Assessment drills on an annual basis. The inspector evaluated quarterly drill reports for 2017 and 2018 and concluded that NextEra did not document objective evidence that the drills were performed satisfactorily in accordance with procedure EP-AA-101-1000-10001, Nuclear Division Drill and Exercise Objectives and Demonstration Criteria, Revision 11. In all reviewed examples, NextEra did not include the status of the drill objectives demonstration criteria in the associated exercise reports as required by EP-AA-101-1000, Nuclear Division Drill and Exercise Procedure, Revision 23. NextEra was able to provide a limited sample of player and controller logs that provided some insight to the inspector that portions of the drills were being performed; however, these logs are not required to be retained as plant records and the status of the demonstration criteria were not being incorporated into the final, larger-scale exercise reports, as required by the emergency plan implementing procedures.

Corrective Actions: NextEra entered these issues into their corrective action program and plan to perform revisions to the implementing procedure to prevent recurrence.

Corrective Action References: 02310197, 02310004

Performance Assessment:

Performance Deficiency: The inspector determined that taking credit for the completion of Health Physics and Core Damage Assessment drills that were embedded into larger exercises, without adequately documenting objective, supporting evidence of their completion into the final exercise report as required by the emergency plan and its implementing procedures is a performance deficiency that was within NextEras ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone. The inspectors determined the performance deficiency was more than minor because it was associated with the emergency response organization performance (drills and exercises) cornerstone attribute and adversely affected the Emergency Preparedness Cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. NextEras ability to take adequate measures to protect the health and safety of the public is degraded when NextEra does not document and critique performance of drills and exercises to ensure emergency response organization proficiency.

Significance: The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP. The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1, 2, and 3, worksheets (effective date October 7, 2016); and the corresponding IMC 0609 Appendix B, Emergency Preparedness Significance Determination Process, step 3.2b, the performance deficiency was determined to have very low safety significance (Green)because it was a noncompliance with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The planning standard function was not lost because NextEra did conduct drills in some instances but did not provide adequate documentation stating that successful demonstration criteria was met.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. NextEra did not follow their procedures which specified that in order to take credit for embedded drills in larger exercises that it should be documented in their final exercise report with supporting, objective evidence.

Enforcement:

Violation: Title 10 CFR 50.54(q)(2) requires, in part, that a power reactor (NextEra) follow and maintain the effectiveness of an emergency plan which meets the requirements of 10 CFR Part 50, Appendix E and the planning standards of 10 CFR 50.47(b). Planning standard 10 CFR 50.47(b)(14) requires, in part, that periodic drills will be conducted to develop and maintain key skills. Seabrook Station Emergency Plan Section 12.1.2 states, in part, that accident assessment and health physics drills will be performed to assess the emergency response organizations effectiveness to respond to a radiological emergency.

NextEra fleet procedure EP-AA-101-1000, Nuclear Division Drill and Exercise Procedure, Revision 23 requires that the status of objectives and embedded drills are being satisfied in larger exercise reports. Procedure EP-AA-101-1000-10001, Nuclear Division Drill and Exercise Objectives and Demonstration Criteria, Revision 11, requires that drill and exercise objectives and demonstration criteria be evaluated and documented when demonstrated.

Contrary to the above, between 2017 and 2018, NextEra did not meet the requirements in 10 CFR 50.54(q)(2) to follow and maintain the effectiveness of the Seabrook emergency plan and planning standard 10 CFR 50.47(b)(14) that requires, in part, that periodic drills will be conducted to develop and maintain key skills. Specifically, the Seabrook Station Emergency Plan Section 12.1.2, procedure EP-AA-101-1000 and procedure EP-AA-101-1000-1001 were not met, when NextEra did not sufficiently document core damage assessment drills and health physics drills necessary to demonstrate key emergency response organization skills.

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 July 30, 2019, the inspectors presented the integrated inspection results to Mr. Eric McCartney, Site Vice President, and other members of the licensee staff.

• On April 11, 2019, the inspectors presented the PI&R semi-annual sample on ASR to Eric McCartney, Site Vice President and other members of the licensee staff.

• On April 16, 2019, the inspectors presented the Emergency Preparedness Program inspection debrief to Eric McCartney, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Calculations SBSAG-5EF- Emergency Feedwater Pump House Building Seismic Revision 0

CALC Analysis

Engineering 170443-CA-09 Evaluation of Control and Diesel Generator Building Revision A

Evaluations

71114.04 Procedures CRC# 2309 - NM Emergency Preparedness Responsibilities of Primary, Revision 38

11700 Subject to Call and Secondary Emergency Response

Organization Members

CRC# 2315 Emergency Response Organization Training Program Revision 02

Description

CRC# 2320 - ER Technical Support Center Operations Revision 67

3.1

CRC# 2322 - ER Emergency Operations Facility Operations Revision 63

3.3

CRC# 2324 - ER Joint Information Center Operations Revision 41

3.5

71114.05 Corrective Action AR 02215882 July 19,

Documents 2017

AR 02223956 September

7, 2018

AR 02309994 April 10,

2019

AR 02310004 April 10,

2019

AR 02310117 April 11,

2019

AR 02310197 April 11,

2019

AR 02310204 April 11,

2019

AR 02310359 April 12,

2019

Procedures EP-AA-101-1000 Nuclear Division Drill and Exercise Procedure Revision 23

Inspection Type Designation Description or Title Revision or

Procedure Date

EP-AA-101-1000- Nuclear Division Drill and Exercise Objectives and Revision 11

10001 Demonstration Criteria

NA-AA-202-1000 Audit Topic Selection and Scheduling Revision 13

SSREP Seabrook Station Radiological Emergency Plan Revision 75

71152 Miscellaneous Structures Monitoring Program Manual Revision 7

- ASR POD Closure Summary 04/08/2019

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