IR 05000443/2022003

Reissued Integrated Inspection Report 05000443/2022003

ML22326A180
Person / Time
Site:	Seabrook
Issue date:	11/22/2022
From:	Matt Young Division of Operating Reactors
To:	Coffey B Florida Power & Light Co
References
IR 2022003
Download: ML22326A180 (1)

Text

November 22, 2022

SUBJECT:

SEABROOK STATION - REISSUED INTEGRATED INSPECTION REPORT 05000443/2022003

Dear Bob Coffey:

The U.S. Nuclear Regulatory Commission (NRC) identified an administrative error in NRC Inspection Report 05000443/2022003 dated November 1, 2022 (ADAMS Accession Number ML22304A100). Specifically, the performance deficiency assigned to the Green non-cited violation 2022003-01, Failure to Implement Required Compensatory Measures for Nonfunctional Fire Detection Instrumentation, was erroneously omitted from the report. As a result, the NRC has reissued the report in its entirety with that section added to correct the error.

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, 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:

05000443/2022003

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

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 Aspect Report Section Mitigating Systems Green NCV 05000443/2022003-01 Open/Closed

[H.13] -

Consistent Process 71111.05 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.

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.

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

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

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 (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

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

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) 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,

INSPECTION RESULTS

Failure to Implement Required Compensatory Measures for Nonfunctional Fire Detection Instrumentation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000443/2022003-01 Open/Closed

[H.13] -

Consistent Process 71111.05 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 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:

Performance Deficiency: The inspectors determined that Seabrooks failure to establish an appropriate compensatory hourly fire patrol, or use a formal process to evaluate an alternate compensatory action, was a performance deficiency. This performance deficiency was reasonably within the licensees ability to foresee and prevent and should have been corrected.

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, 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.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Corrective Action

Documents

2389833

2432367

2432447

2432494

2432663

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

Electrical Tunnel Area Ventilation System Operation

Revision 18

71111.04

Corrective Action

Documents

0585309

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

Documents

Resulting from

Inspection

2431456

2433626

2434022

2436563

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

Documents

2419320

2420914

2423469

2429090

2430932

2433672

2433753

Work Orders

40083148

40809650

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.13

Corrective Action

Documents

2435091

Procedures

OP-AA-102-1003

Guarded Equipment

Revision 42

71111.15

Corrective Action

Documents

2426781

2434251

2434877

Work Orders

40832157

71111.18

Corrective Action

Documents

2436182

Procedures

EN-AA-202-1004

Fire Protection Screening

Revision 13

OP-OS-1090-09

Winter Readiness

Revision 3

71111.19

Corrective Action

Documents

2432518

2432613

Procedures

IS1672.211

Service Water Cooling Tower Basin Water Level Loop B

Calibration

Revision 10

MN0523.35

Delaval Oil Pump Model A313A Maintenance

Revision 1

OS1023.51

Control Room Ventilation and Air Conditioning System

Operation

Revision 29

OX1423.28

Control Room Air Conditioning System Quarterly

Surveillance

Revision 7

OX1456.37

Train A ESFAS Slave Relay K644 Go Test

Revision 8

Work Orders

40719470

40762107

40786186

40788740

40821130

40835341

71111.22

Corrective Action

Documents

2435505

2435513

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

Inspection

Procedure

Type

Designation

Description or Title

Revision or

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 &

Notification System (PANS)

Revision 2

Work Orders

40762969

40804186

40804294

40804339

71151

Corrective Action

Documents

2424902