ML24354A232
| ML24354A232 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/19/2024 |
| From: | Matt Young Division of Operating Reactors |
| To: | C-10 Research & Education Foundation |
| References | |
| IR 2024001, IR 2024002 | |
| Download: ML24354A232 (1) | |
Text
ML24354A232 Documentation of meeting between C-10 Research and Education Foundation and the NRC Region I regarding questions on the Seabrook 1st and 2nd Quarter 2024 Integrated Inspection Reports, 05000443/2024001 (ML24134A006) and 05000443/2024002 (ML24219A267) respectively.
On Tuesday November 19, 2024, members of the NRC Region I staff met virtually with members of C-10 to respond to questions submitted by the group on the Seabrook 1st and 2nd quarter 2024 inspection reports. The members of C-10 were satisfied with the answers and discussion with the resident inspectors and technical staff from the region. This documents all questions raised by C-10 in their letter as satisfactorily answered.
Attached:
- 1. C-10 letter asking questions about the Seabrook 1st and 2nd Quarter 2024 Integrated Inspection Reports, dated October 30, 2024
- 2. Reactor oversight process reference material PowerPoint
C-10 Research & Education Foundation / 11 Chestnut St., Amesbury MA 01913 / www.c-10.org / (978) 465-6646 Page 1 of 2 October 30, 2024 via electronic mail To:
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Attn: Travis Daun, Senior Resident Inspector Eben Allen, Resident Inspector Paul Cataldo, Senior Reactor Inspector Nik Floyd, Senior Reactor Inspector Seabrook Station 626 Lafayette Road Seabrook, NH 03874 Cc:
Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety Raymond Lorson, Regional Administrator, Region I Mel Gray, Chief, Engineering Branch 1 Nicole Warnek, Senior Project Engineer Project, Branch 2 Sarah Elkhiamy, Senior Project Manager, Region 1
Subject:
C-10 Research & Education Foundation communication regarding Seabrook Station -
Integrated Inspection Reports 05000443/2024001 (ML24134A006) and 05000443/2024002 ML24219A267 Seabrook Station NRC Inspectors:
C-10 has reviewed the Q1/24 & Q2/24 Integrated Inspection Reports and there are a few items, listed below, that prompted us to reach out to you and request further information.
Item 1: Q1 Integrated Inspection Report 05000443/2024001 (ML24134A006)
Green NCV 05000443/2024001-01 Open/Closed: Failure to Promptly Identify and Correct a Condition Adverse to Quality for Gas Accumulation in Containment Building Spray Piping The Performance Assessment>Screening section (p11) states The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern.
The Enforcement>>Violation section clearly illustrates that the licensee failed to promptly identify and correct a condition adverse to quality.
This citation illustrates that plant workers were monitoring the appropriate piping for voids. Unfortunately they misdiagnosed the monitoring data and failed to take the steps necessary to eliminate the voids in the piping. In reviewing letters previously sent by C-10 to the NRC in response to prior inspection reports, it seems there is a consistent trend at Seabrook Station of plant workers making errors that have increasingly worrisome safety implications.
Question 1: C-10 is concerned that the increased occurrence of errors and citations caused by plant workers represents a larger safety risk than the individual occurrences. What steps can/is the NRC taking to ensure that the Licensee is providing the appropriate training and managerial oversight to plant workers for tasks that have safety implications of any type?
C-10 Research & Education Foundation / 11 Chestnut St., Amesbury MA 01913 / www.c-10.org / (978) 465-6646 Page 2 of 3 Item 2: Q1 Integrated Inspection Report 05000443/2024001 (ML24134A006)
Green NCV 05000443/2024001-02 Open/Closed: Failure to Adequately Evaluate the Reactor Pit Slab During Reanalysis of the Containment Internal Structures to Incorporate Alkali-Silica Reaction Loads As stated in the Description of the citation (p12) the reactor pit area is a seismic category I concrete structure and is categorized as part of the CIS. The inspection report clearly states that the structural integrity of the reactor pit area - inclusive of the slab - is critical to ensure the safe operation of the plant, the safety of plant employees, and the public safety of those living in Seabrook and the surrounding EPZ.
The description also includes data around the fact that ASR was first identified in the reactor cavity pit area in 2014, that the Licensee was cited in 2021 (ML22040A204) because they did not evaluate the structural indications in accordance with their structural monitoring program.
Now, in 2024, ten years since ASR was first identified in the area, the inspectors observed that the licensee did not credit the <reactor pit> slab as part of the seismic lateral load path and did not contribute to the overall seismic capacity of the structure.
This failure by NextEra occurred despite the fact that NRC inspectors had previously indicated that they wanted NextEras analysis to include the reactor pit slab because the slab is part of the CIS, a seismic category I structure, and is to maintain its integrity because it is credited to support the 13 attached ductwork and not impact the safety-related reactor in-core instrumentation located below it.
The Performance Assessment>Screening section (p13) states The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, unanalyzed loading of the slab and additional loads from ASR challenged the structural integrity of the slab where failure could impact in-core instrumentation and result in reactor coolant system leakage.
Question 2: Given the recurring failure of the licensee to properly manage ASR in the reactor pit area, what steps is the NRC taking to ensure that these types of violations (which have serious potential safety implications for inspectors, employees and the public) do not continue to occur?
Item 3: Q2 Integrated Inspection Report 05000443/2024002 (ML24219A267) 71153: Minor Performance Deficiency: Operator Performance During Solar Magnetic Disturbance Inspectors determined that failure to follow procedural guidance to commence load reduction once GIC current exceeded the allowable limit was a performance deficiency that was preventable. (p8)
C-10 Observation: This finding is one more example of a preventable performance deficiency on the part of a plant worker (or workers) at Seabrook Station (see question 1). While the individual finding is deemed minor by the inspectors, it is the overall trend and potential impact to public safety that is of most concern to C-10.
C-10 Research & Education Foundation / 11 Chestnut St., Amesbury MA 01913 / www.c-10.org / (978) 465-6646 Page 3 of 3 Results and Information Excluded from ML24219A267 This report lists exit meetings where results for three separate inspections (Radiation Safety, Independent Spent Fuel Storage Installation, and Integrated) were presented to the Licensee staff (p8). Per the Documents Reviewed section (p 9-12), Corrective Action Documents resulted from the following inspection procedures completed in Q2/24:
71111.01: Adverse Weather Protection: Seasonal Extreme Weather Sample (IP Section 03.01) (2 Samples) 71111.05: Fire Protection: Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples) 71111.24: Testing and Maintenance of Equipment Important to Risk (IP Section 03.01) (6 Samples) 71153: Follow Up of Events and Notices of Enforcement Action (IP Section 03.03) (1 Sample)
This report is lacking the results from the Radiation Safety Inspection, the Independent Spent Fuel Storage Installation Inspection and the inspection details that lead to the need for corrective actions related to inspection procedures 71111.01, 71111.05 and 71111.24.
Question 3:
- a. Were the results for the inspections listed above published in separate documents? If so, what are the ML numbers?
- b. If not published separately, why were the results omitted from ML24219A267? This is particularly concerning to C-10 given the multiple issues found during prior inspections over the last year related to fire safety, weather, and equipment.
Thank you for your consideration on these items and we look forward to your responses.
Kindest Regards, Sarah Abramson Executive Director C-10 Research & Education Foundation 11 Chestnut St., Amesbury, MA 01913 Ph: (978) 465-6646 Email: sarah@c-10.org
Reactor Oversight Process Reference Material for C-10 Meeting November 19, 2024
2023-2024 P.1 (Identification) - 1 P.2 (Evaluation) - 1 P.3 (Resolution) - 2 2023-2024 H.3 (Change Management) - 1 H.4 (Teamwork) - 2 H.6 (Design Margins) - 1 H.11 (Challenge the Unknown) - 1 H.14 (Conservative Bias) - 1 2023-2024 5
2023-2024 1
2023-2024 4
Also:
1 Severity Level 4 Traditional Enforcement Violation (Impact to the Regulatory Process for failing to make 50.72 report)