ML22304A100
| ML22304A100 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/01/2022 |
| From: | Matt Young NRC/RGN-I/DORS |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2022003 | |
| Download: ML22304A100 (1) | |
See also: IR 05000443/2022003
Text
November 1, 2022
Bob Coffey
Executive Vice President, Nuclear Division
and Chief Nuclear Officer
Florida Power & Light Company
700 Universe Blvd.
Mail Stop: EX/JB
Juno Beach, FL 33408
SUBJECT: SEABROOK STATION - INTEGRATED INSPECTION REPORT
Dear Bob Coffey:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Seabrook Station. On October 13, 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.
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.
B. Coffey 2
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 (CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Digitally signed by Matthew
Matthew R. R. Young
Date: 2022.11.01 08:36:14
Young -04'00'
Matt R. Young, Chief
Projects Branch 2
Division of Operating Reactor Safety
Docket No. 05000443
License No. NPF-86
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
x Non-Sensitive x Publicly Available
x SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DORS RI/DORS RI/DORS
NAME CNewport SElkhiamy MYoung
DATE 10/31/22 10/28/22 10/28/22
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000443
License Number: NPF-86
Report Number: 05000443/2022003
Enterprise Identifier: I-2022-003-0041
Licensee: NextEra Energy Seabrook, LLC
Facility: Seabrook Station
Location: Seabrook, New Hampshire
Inspection Dates: July 1, 2022 to September 30, 2022
Inspectors: C. Newport, Senior Resident Inspector
T. Daun, Resident Inspector
S. Veunephachan, Health Physicist
Approved By: Matt R. Young, Chief
Projects Branch 2
Division of Operating Reactor Safety
Enclosure
SUMMARY
The NRC continued monitoring the licensees performance by conducting an integrated
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 Implement Required Compensatory Measures for Nonfunctional Fire Detection
Instrumentation
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.13] - 71111.05
Systems NCV 05000443/2022003-01 Consistent
Open/Closed Process
The inspectors identified a Green finding and associated non-cited violation of Seabrook
Station Facility Operating License Condition 2.F when the licensee failed to perform required
compensatory hourly fire patrol rounds in the 'A' safety injection pump room in accordance
with their approved fire protection program procedures. The station implemented an alternate
compensatory action which was not evaluated, procedurally directed, or designed with
appropriate risk insights.
Additional Tracking Items
None.
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PLANT STATUS
Seabrook Station began the inspection period operating at 100 percent rated thermal power and
remained at or near full power for 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 activities described in IMC 2515,
Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification
and Resolution, observed risk-significant activities, and completed on-site portions of IPs. 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
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-
significant systems from impending severe weather including sustained high
temperatures on July 24
External Flooding Sample (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated flood protection barriers, mitigation plans, procedures, and
equipment are consistent with the licensees design requirements and risk analysis
assumptions for coping with external flooding on September 15
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Spent fuel storage building ventilation system during fuel bundle moves on July 11
(2) 'A' emergency diesel generator during supplemental emergency power system diesel
generator maintenance outage on August 23
(3) Emergency feedwater system following maintenance and testing on September 20
3
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1) 'A' safety injection equipment room (RHR-F-2A-Z/RHR-F-2B-Z) on July 8
(2) Primary auxiliary building piping penetration area (PAB-F-1A-Z) on August 3
(3) Primary auxiliary building ventilation rooms and hallway (PAB-F-3B-Z) on August 4
(4) Primary auxiliary building southeast corner (PAB-F-2A-Z) on August 10
(5) Service water pump house (SW-F-1E-Z) on September 27
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
(1) Refueling water and spray additive tank farm on September 22
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1) The inspectors observed and evaluated licensed operator performance of the
following activities in the control room:
- Control rod operability testing on August 9
- 'B' emergency diesel generator start, loading, and unloading and reactor
coolant system dilution on August 29
- Control rod realignment on September 30
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated a licensed operator requalification
examination conducted in the plant-reference simulator on September 12
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components remain capable of performing their intended function:
(1) Failure of B vital switchgear fire damper CBA-DP-142 on August 9
(2) Service air compressors and automatic isolation valves on September 29
4
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1) Elevated risk during B residual heat removal maintenance on July 14
(2) Elevated fire risk while one safe shutdown train unavailable on August 8
(3) Elevated risk during supplemental emergency power system major maintenance
outage on August 22
(4) Elevated risk during A turbine driven emergency feedwater pump surveillance runs
on September 29
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Elevated ocean intake temperatures (AR 02434251) on August 15
(2) Service water cooling tower alkali-silica reaction inspection results nearing threshold
limits (AR 02434877) on August 23
(3) 'D' battery charger relay failure (AR 02435796) on September 14
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) Critical infrastructure winter protection modification
(2) Replacement of fan heaters in the 'A' and 'B' cooling tower fan motors
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1) Service water cooling tower basin level detector replacement on July 8
(2) 'A' containment building spray maintenance on July 11
(3) A control building air chiller failure on July 24
(4) Supplemental emergency power system major maintenance outage on August 22
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(5) 'D' battery charger following visual inspections and rectifier card replacement on
September 1
(6) A centrifugal charging pump auxiliary lube oil pump seal replacement on
September 13
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
(1) Emergency siren bi-weekly functional testing on August 11
(2) B emergency diesel generator monthly surveillance testing on August 29
(3) Supplemental emergency power system monthly availability surveillance testing on
September 19
In-service Testing (IP Section 03.01) (1 Sample)
(1) A safety injection containment isolation quarterly valve stroke testing on
September 21
FLEX Testing (IP Section 03.02) (1 Sample)
(1) Flex fuel transfer pump (460B) operational testing and flow rate verification on
August 30
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
(1) The inspectors observed the conduct of a scheduled, full participation emergency
planning drill on August 17
RADIATION SAFETY
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated environmental monitoring equipment and observed
collection of environmental samples
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the implementation of the licensees radiological
environmental monitoring program
6
GPI Implementation (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated the licensees implementation of the Groundwater
Protection Initiative program to identify incomplete or discontinued program elements
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
(1) For the period July 1, 2021 through June 30, 2022
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
(1) For the period July 1, 2021 through June 30, 2022
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
(1) For the period July 1, 2021 through June 30, 2022
INSPECTION RESULTS
Failure to Implement Required Compensatory Measures for Nonfunctional Fire Detection
Instrumentation
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.13] - 71111.05
Systems NCV 05000443/2022003-01 Consistent
Open/Closed Process
The inspectors identified a Green finding and associated non-cited violation of Seabrook
Station Facility Operating License Condition 2.F when the licensee failed to perform required
compensatory hourly fire patrol rounds in the 'A' safety injection pump room in accordance
with their approved fire protection program procedures. The station implemented an alternate
compensatory action which was not evaluated, procedurally directed, or designed with
appropriate risk insights.
Description: On July 2, 2022, fire detection zone 6, associated with the 'A' safety injection
pump room, locked into trouble and would not reset. The station took immediate action to
place the zone 6 area on hourly fire rounds as directed by the station's Technical
Requirement (TR) 12 for Fire Detection Instrumentation. TR 12, action b states, in part, with
more than one-half of the Type X fire detection instruments in any fire zone or group
nonfunctional, establish a fire watch patrol to inspect zone(s) or group(s) with the
nonfunctional instrument(s) hourly. These actions were documented in Condition Report
02431237.
On July 8, 2022, NRC inspectors reviewed the action tracking log for fire impairments and
noted that there was a text note that indicated the fire watch to check for smoke or fire from a
zone two levels above the safety injection pump room. This room provided the ability to look
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down to the safety injection pump room but allowed a view of less than half of the entire
safety injection pump room. The inspectors immediately contacted the operations shift
manager to inquire if an evaluation had been done analyzing the appropriateness of this
change to the required compensatory action. The shift manager directed the restoration of the
approved compensatory action as required by TR 12 and wrote Condition Report 02431456.
It was concluded that the alternate compensatory measure was not evaluated and that it did
not account for the license requirements implemented by TR 12.
Corrective Actions: The station immediately directed the fire watch patrol to start entering the
zone with the nonfunctional detectors. The station also issued a shift order providing direction
to the fire brigade leaders and shift operations managers that the compensatory actions
directed by the Technical Requirements Manual shall be implemented as written unless a
formal evaluation is performed.
Corrective Action References: Condition Reports 02431237, 02431456, 02412826
Performance Assessment:
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Protection Against External Factors 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 failure to perform multiple hourly fire watch tours
as a compensatory measure for fire detector instrument failures would have impacted fire
brigade response and did not ensure the safety injection system would remain available to
perform its accident mitigating function to inject water into the reactor coolant system during a
safety injection initiation and other safety functions during a postulated fire event.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors determined
the fire finding category was associated with fixed fire protection systems and had a low
degradation rating because less than ten percent of the smoke and heat detectors associated
with the vault were nonfunctional and a roving fire patrol did tour portions of the vault adjacent
to the affected area. Even though the response time of the fire brigade was impacted, the
response time was mitigated by other defense-in-depth elements. Specifically, there was
functional fire detection instrumentation in all adjacent locations to the 'A' safety injection
pump room and area combustible loading limits were not exceeded. Based on this, the
inspectors determined that the finding was of very low safety significance (Green).
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic
approach to make decisions. Risk insights are incorporated as appropriate.
Enforcement:
Violation: Seabrook Station, Unit 1 Facility Operating License Condition 2.F requires, in part,
for NextEra to implement and maintain in effect all provisions of the approved fire protection
program as described in the Updated Final Safety Analysis Report, the Fire Protection
Program Report, and the Fire Protection and Safe Shutdown Capability report, as
supplemented. Supplement 7 of the Safety Evaluation Report approved NextEra's request to
establish fire protection program limiting conditions for operation and action statements that
provide a level of protection equivalent to that provided by the fire protection sections of the
Westinghouse Standard Technical Specifications. This commitment was incorporated into
Section 9.5-1 of Seabrooks Updated Final Safety Analysis Report which states, in part,
8
limiting conditions for operation, action statements, and surveillance requirements for the fire
protection program are prescribed in the Seabrook Station Technical Requirements Manual.
The Seabrook Station Technical Requirements Manual, TR 12, Fire Detection
Instrumentation, establishes the limiting condition for operation for installed fire detection
instrumentation. TR 12 prescribes the actions for more than one-half of the Type X fire
detection instruments in any zone or group being nonfunctional as establishing an hourly fire
watch patrol to inspect the zone or group with the nonfunctional instruments hourly. Contrary
to the above, during the period July 2, 2022, to July 8, 2022, Seabrook Station had more than
one-half of the fire detection instruments in zone 6 of the residual heat removal vault
nonfunctional and did not establish an adequate hourly fire watch patrol to inspect the zone or
group with the nonfunctional instruments hourly.
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 August 25, 2022, the inspectors presented the radiological environmental monitoring
program inspection results to Brian Booth, Site Vice President and other members of the
licensee staff.
- On October 13, 2022, the inspectors presented the integrated inspection results to Brian
Booth, Site Vice President and other members of the licensee staff.
9
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Corrective Action 02389833
Documents 02432367
02432447
02432494
02432663
Drawings 9763-F-101652 Main Steam & Feedwater Pipe Chase (East) Concrete Revision 7
Miscellaneous FPL-081-RR-002 Seabrook Station Flooding Hazards Reevaluation Report Revision 1
Procedures OS1023.57 Cable Spreading Area, Essential Switchgear Area and Revision 18
Electrical Tunnel Area Ventilation System Operation
71111.04 Corrective Action 0585309
Documents 1888886
Drawings 1-MAH-B20497 Miscellaneous Air Handling Fuel Storage Building Detail Revision 10
Procedures OS1023.63 Fuel Storage Building Ventilation System Operation Revision 19
OX1426.01 DG 1A Monthly Operability Surveillance Revision 54
OX1426.18 Aligning DG 1A Controls For Auto Start Revision 6
71111.05 Corrective Action 02431456
Documents 02433626
Resulting from 02434022
Inspection 02436563
Drawings SW-F-1E-Z Service & Circ Water Pump House Revision 36
Procedures FP 2.4 Fire Watches and Fire Patrols Revision 7
Work Orders 0319603
71111.12 Corrective Action 02419320
Documents 02420914
02423469
02429090
02430932
02433672
02433753
Work Orders 40083148
40809650
10
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.13 Corrective Action 02435091
Documents
Procedures OP-AA-102-1003 Guarded Equipment Revision 42
71111.15 Corrective Action 02426781
Documents 02434251
02434877
Work Orders 40832157
71111.18 Corrective Action 02436182
Documents
Procedures EN-AA-202-1004 Fire Protection Screening Revision 13
OP-OS-1090-09 Winter Readiness Revision 3
71111.19 Corrective Action 02432518
Documents 02432613
Procedures IS1672.211 Service Water Cooling Tower Basin Water Level Loop B Revision 10
Calibration
MN0523.35 Delaval Oil Pump Model A313A Maintenance Revision 1
OS1023.51 Control Room Ventilation and Air Conditioning System Revision 29
Operation
OX1423.28 Control Room Air Conditioning System Quarterly Revision 7
Surveillance
OX1456.37 Train A ESFAS Slave Relay K644 Go Test Revision 8
Work Orders 40719470
40762107
40786186
40788740
40821130
40835341
71111.22 Corrective Action 02435505
Documents 02435513
Procedures OX1405.11 SI Containment Isolation Valve Quarterly Stroke Tests Revision 11
OX1426.05 DG 1B Monthly Operability Surveillance Revision 55
OX1461.04 SEPS Monthly Availability Surveillance Revision 17
OX1462.06 FLEX Fuel Transfer Pump 460B Periodic Testing Revision 7
11
Inspection Type Designation Description or Title Revision or
Procedure Date
SIR.10 WPS-3000 and WPS-4008 Siren Bi-Weekly Functional Test Revision 9
SIR.40 Inadvertent or Suspected Activation of the Public Alert & Revision 2
Notification System (PANS)
Work Orders 40762969
40804186
40804294
40804339
71151 Corrective Action 02424902
Documents
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