IR 05000443/2023004

Integrated Inspection Report 05000443/2023004

ML24043A002
Person / Time
Site:	Seabrook
Issue date:	02/12/2024
From:	Matt Young Division of Operating Reactors
To:	Coffey B Florida Power & Light Co
References
IR 2023004
Download: ML24043A002 (1)

Text

February 12, 2024

SUBJECT:

SEABROOK STATION - INTEGRATED INSPECTION REPORT 05000443/2023004

Dear Bob Coffey:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station. On January 31, 2024, the NRC inspectors discussed the results of this inspection with David Sluszka, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety

Docket No. 05000443 License No. NPF-86

Enclosure:

As stated

Inspection Report

Docket Number:

05000443

License Number:

NPF-86

Report Number:

05000443/2023004

Licensee:

NextEra Energy Seabrook, LLC

Facility:

Seabrook Station

Location:

Seabrook, New Hampshire

Inspection Dates:

October 1, 2023 to December 31, 2023

Inspectors:

T. Daun, Senior Resident Inspector

E. Allen, Resident Inspector

J. Demarshall, Senior Operations Engineer

N. Eckhoff, Health Physicist

T. Hedigan, Operations Engineer

Approved By:

Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety

SUMMARY

The U.S. 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

No findings or violations of more than minor significance were identified.

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, 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

Seasonal Extreme Weather (IP Section 03.01) (1 Sample)

(1) During the weeks of November 13, 2023 and November 20, 2023, inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of reduced temperatures experienced during the winter months for the following systems:

• emergency feedwater

• service water

• main feedwater

71111.04 - Equipment Alignment

Complete Walkdown (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the 'A' containment building spray system between October 25, 2023 and November 14, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (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) Cooling tower mechanical equipment room - east end (CT-F-2B-A) on October 17, 2023

(2) Service and circulating water pump house (SW-F-1E-Z) on October 17, 2023

(3) 'B' diesel generator room DG202 (DG-F-2B-1) on October 17, 2023

(4) 'B' service water pump house electrical room (SW-F-1C-A) on November 28, 2023

(5) Piping penetration area (PP-F-2A-Z) on November 29, 2023

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating tests administered November through December 2023 and the biennial written examinations administered November through December 2023.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered November through December 2023.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the licensees annual requalification operating test administered the week of November 13, 2023.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security

The inspectors evaluated the ability of the licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

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 in the control room during the following:

• Main turbine electro-hydraulic control oil pump adjustments on November 15, 2023

• Quarterly rod operability testing on November 16, 2023

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 November 6, 2023

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) Containment gas radiation monitors functional failures and (a)(1) plan actions on December 21, 2023

(2) Control of lubricating oils for safety-related pumps and motors on December 21, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (5 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) Yellow risk during 'A' vital inverter normal battery supply breaker inspection on October 11, 2023

(2) Elevated risk during 345 kilovolt line maintenance and testing on October 27, 2023

(3) Emergent work control for failure of the heater drain level control for the 'A' and 'B' low pressure condensate heaters on November 13, 2023

(4) Emergent work control for steam leak on 'C' reheater drain tank on November 20, 2023

(5) Risk management actions for high risk work associated with the 'B' hydraulic fluid pump (HF-P-54-B) compensator replacement on November 30, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) 'D' steam generator pressure channel calibration failure (AR02467994) on October 25, 2023

(2) Emergency feedwater with failure of the transformer for the 'B' flow control valve to 'D' steam generator (AR02471828) on November 8, 2023

(3) 'A' residual heat removal following replacement of motor oil with incorrect type (AR02471178) on November 14, 2023

(4) Service water system with excessive leakby of the 'A' service water cooling tower isolation valve (AR02474972) on December 28, 2023

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) Process protection cabinet power supply upgrade for CP-1 on October 23, 2023

(2) Replacement of steam generator pressure loop 7300 card with redesigned 7300 card on November 15, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (IP Section 03.01) (5 Samples)

(1) CP-1 power supply replacement on October 23, 2023

(2) 'A' residual heat removal pump motor following oil change on November 1, 2023

(3) 'A' control room air conditioning system following compressor trip on November 15, 2023

(4) Replacement of 7300 bistable card for steam generator high negative rate trip on November 16, 2023

(5) 'B' cooling tower service water pump discharge valve following repair work on December 1, 2023

Surveillance Testing (IP Section 03.01) (2 Samples)

(1) Electric emergency feedwater pump quarterly and monthly valve verification on November 29, 2023

(2) 'D' 125 volt battery bank discharge test on December 22, 2023

In-service Testing (IST) (IP Section 03.01) (1 Sample)

(1) Turbine driven emergency feedwater pump quarterly and monthly valve alignment on October 19, 2023

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the conduct of a routine, full participation emergency planning drill on October 18,

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (8 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Radiation monitor (RM)-6543 seven foot south end area monitor

(2) Radiation monitor (RM)-6547 charging pump room area monitor

(3) Ludlum Model 12 (serial #298290) in use in the primary auxiliary building

(4) Fluke Model 451 (serial #0042) in use in the primary auxiliary building

(5) Eberline AMS-4 (serial #12951) in the fuel storage building

(6) Ludlum Model 177 (serial #295988) in the fuel storage building

(7) Tele-pole II (serial #232920-041) in use during Radwaste shipment

(8) Radiation monitor (RM)-6568 containment enclosure air exhaust monitor

Calibration and Testing Program (IP Section 03.02) (13 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Radiation monitor 6481 main steam line radiation monitor

(2) ThermoFisher model RO-20A (serial #114867)

(3) Ludlum model 177 (serial # 295997)

(4) Mirion argos-4AB (serial #105)

(5) Ludlum model 177 (serial #295997)

(6) Small article monitor (serial #199)

(7) Mirion cronos small article monitor (serial #1212-227)

(8) Canberra gamma exit monitor 5 (serial #29826)

(9) Mirion argos-4AB (serial #132)

(10) Radiation monitor 6520 reactor coolant letdown gross activity monitor

(11) Radiation monitor 6538 residual heat removal pump area

(12) Mirion argos-4AB (serial #107)

(13) Radiation monitor 6576A containment post loss of coolant accident monitor

Effluent Monitoring Calibration and Testing Program (IP Section 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) R-6528 plant vent wide range gas radiation monitor

(2) Radiation monitor 6509 waste liquid test tanks discharge monitor

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Shipment Preparation (IP Section 03.04)

(1) The inspectors observed the preparation of radioactive shipment 23-040 of dry active waste on October 17,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

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

(1) For the period October 1, 2022 through September 30, 2023

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

(1) For the period October 1, 2022 through September 30, 2023

OR01: Occupational Exposure Control Effectiveness (IP Section 02.15) (1 Sample)

(1) For the period October 1, 2022 through September 30, 2023

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences (IP Section 02.16) (1 Sample)

(1) For the period October 1, 2022 through September 30, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 03.03)

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

(1) Evaluation of area and process radiation monitor performance issues

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (IP Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue

INSPECTION RESULTS

Observation: Semiannual Trend Review 71152S The inspectors reviewed Seabrooks 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 operator challenges program including an audit of control room deficiencies, control board notifications, and operator workarounds.

Based on the overall results of the semiannual trend review, the inspectors determined that issues were appropriately evaluated by Seabrook staff for potential trends and resolved within the scope of the corrective action program and other requisite procedures. Inspectors did note the station has made significant progress toward correcting long standing video alarms in the control room significantly reducing operator burden. A minor violation was also documented as part of this trend related to the control of quality related oil used in safety-related components.

Minor Violation: Failure to Control Quality Related Oil for Safety-Related Motors 71152S A violation of 10 CFR 50, Appendix B, Criterion VII Identification and Control of Materials, Parts, and Components was identified when the incorrect lubricating oil was added to the safety-related A residual heat removal pump motor and the safety-related B primary component cooling water pump motor. Both pump motors require Mobile DTE Medium ISO 46 as prescribed by the original equipment manufacturer. Upon an oil change on the A residual heat removal pump motor on October 10, 2023, an oil sample was taken and sent to a vendor as part of Seabrooks predictive maintenance monitoring program. Upon receipt of the oil analysis back from the vendor in September 2023, it was discovered that the oil viscosity was lower than expected. The station entered this condition into their corrective action program and sampled the secondary container labeled as Mobile DTE Medium ISO 46 that the quality assurance records indicated the oil was obtained from for the A residual heat removal pump motor. Upon analysis it was discovered that the secondary container contained Mobile DTE 732 ISO 32. An extent of condition review was conducted, and the licensee determined that the same secondary storage container was used to obtain oil for an oil change on the B primary component cooling water pump motor on September 7, 2023.

The licensee performed oil analysis on all bulk oil storage and confirmed all bulk oil and found no discrepancies. The licensee discontinued the use of secondary containers for oil storage and have updated issue instructions that require all oil to be obtained only from original source bulk storage containers. Both the A residual heat removal pump motor oil and B primary component cooling water pump motor oil were drained, flushed, and replaced with Mobile DTE Medium ISO 46.

Screening: The inspectors determined the performance deficiency was minor. The performance deficiency did not adversely affect the Mitigating Systems cornerstones objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Seabrook conducted an engineering analysis and determined that the lower viscosity oil did not negatively impact the reliability of the pump motors and only posed a long-term degradation concern.

Enforcement:

This failure to comply with Title 10 CFR 50, Appendix B, Criterion VII Identification and Control of Materials, Parts, and Components, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Review of Seabrooks Evaluation and Corrective Actions for Radiation Monitoring System failures 71152A The inspectors performed a review of various failures of process and area radiation monitors which have resulted in repeated out-of-service time and compensatory actions. The inspectors reviewed Seabrooks causal evaluations, implemented corrective actions, and preventive maintenance frequency.

Seabrook Stations maintenance rule program, required by 10 CFR 50.65, credits three radiation monitors; RM-6526-1 (containment particulate), RM-6526-2 (containment gas), and RM-6548 (backup containment gas) to meet the technical specification function to be capable of detecting a one gallon per minute increase in unidentified leakage within one hour. This maintenance rule function is monitored at a system level and has an established performance goal of less than six failures in a 24 month period. Detecting and monitoring reactor coolant system leakage into the containment area, and quickly separating the identified leakage from the unidentified leakage provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public. Seabrook Stations Technical Specification 3.4.6.1 requires instruments of diverse monitoring principles to be operable to provide confidence that small amounts of unidentified leakage are detected in time to allow actions to place the plant in a safe condition when reactor coolant system leakage indicates possible reactor coolant pressure boundary degradation. One containment atmosphere radioactivity monitor (gaseous or particulate) is required as well as the containment drainage sump level monitoring system.

The inspectors noted continual failures of one or more of these containment gaseous radioactivity monitors with five failures in 2021, three in 2022, and one additional in 2023.

Two of the failures in 2022 were classified as maintenance rule functional failures and were counted against the performance goals. While these failures have not exceeded the performance goals established in 10 CFR 50.65(a)(2), they have posed a burden on the operating crews. Inspectors also determined that the ability to accurately monitor unidentified leakage was not challenged during these failures because the containment drainage sump level monitoring system remained in service during these periods. Based on the performance improvement in 2023, inspectors determined that actions taken by the station have been reasonable but will continue to monitor performance of these radiation monitors.

The inspectors determined that Seabrook's immediate actions to these failures have been appropriate for the circumstances and reasonable. While inspectors did not identify any cases where appropriate actions were not taken in response to a failed radiation monitor, inspectors noted that the on-shift operators have been repeatedly challenged with having to employ compensatory actions to validate normal radiological conditions. The station has been investigating a long-term action to replace their radiation monitoring system which will improve the reliability of the radiation monitoring system as a whole and help to alleviate this operator burden.

EXIT MEETINGS AND DEBRIEFS

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

• On October 31, 2023, the inspectors presented the health physics instrumentation, radioactive material shipment preparation, and occupational and public portions of the performance indicator verification inspections inspection results to Chris Robinson, Organization Effectiveness Director, and other members of the licensee staff.

• On January 31, 2024, the inspectors presented the integrated inspection results to David Sluszka, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Drawings

1-CBS-B20233

Containment Spray System

Revision 38

Procedures

OS1006.01

Fill and Vent of CBS and RHR System

Revision 16

OX1406.02

Containment Spray Pump and Valve Quarterly Operability

Revision 27

71111.05

Calculations

MS-MISC-49

Service Water Pumphouse

Revision 7

MS-MISC-54

Verification of Combustibles in Fire Zones of Mechanical

Penetration Area

06/16/1986

Corrective Action

Documents

2473348

Drawings

CT-F-2B-A

Cooling Tower Mech. Equip. Rooms - East End

DG-F-2B-1

Diesel Generator Building 'B' Generator Room - DG202

PP-F-2A-Z

Piping Penetration Tunnels

SW-F-1C-A

Water Pump House B Train Motor Control Center Room

SW-F-1E-Z

Service and Circ. Water Pump House

Procedures

FP62296

Fire Protection Prefire Strategies

Revision 45

71111.12

Corrective Action

Documents

2381369

2392738

2404043

2414224

2418709

2439446

2470799

2471178

2474294

Procedures

MA 4.9

Control and Storage of Equipment and Materials

Revision 21

Work Orders

40773723

40816310

40828717

40844327

40869755

40886782

40889968

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

40955429

71111.13

Corrective Action

Documents

2472094

2472895

Work Orders

40946703

40956290

40956945

71111.15

Corrective Action

Documents

2467994

2471178

2471828

2474867

2474972

Drawings

C-S-1-83619-

CALC

Allowable Boundary Valve Leakage for Cooling Tower

Operation

Revision 1

PID-1-SW-

B20795

Service Water System Nuclear Detail

Revision 52

Miscellaneous

FP53593

RHR Pumps Instructions and Maintenance Manual

Procedures

EN-AA-203-1001

Operability Determinations

Revision 41

Work Orders

40738441

40869547

40886782

40955368

71111.18

Drawings

1-NHY-310942

Process Protection Cabinet Power Supply MM-CP-1

Revision 2

Engineering

Changes

286645

7300 System Printed Circuit Board Upgrades

Revision 3

297025

7300 Power Supply Upgrades

Revision 4

299068

SG Pressure Loop FW-P-525 7300 Card Replacement

Revision 0

Procedures

ER-AA-122-1001

Printed Circuit Board Life Cycle Management Plan

Revision 6

71111.24

Corrective Action

Documents

2467994

2468027

2468533

2469744

2473437

Drawings

1-SW-B20794

Service Water Nuclear Detail System

05/04/2023

FP62415

Liquid Chiller Wiring Diagram

Revision 1

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

LX0556.98

Battery Performance Test

Revision 15

OX1416.06

Service Water Discharge Valves Quarterly Test And 18

Month Position Verification

Revision 13

OX1423.28

Control Room Air Conditioning System Quarterly

Surveillance

Revision 7

OX1436.02

Turbine Driven Emergency Feedwater Pump Quarterly and

Monthly Valve Alignment

Revision 37

OX1436.03

Electric EFW Pump Quarterly, 18 Month/30 Days Cold

Shutdown And Comprehensive Pump Tests, And Monthly

Valve Verification Surveillance

Revision 30

OX1456.81

Operability Test of IST Valves

Revision 44

OX1456.86

Operability Testing of IST Pumps

Revision 31

Work Orders

40594786

40848519

40869685

40869795

40869884

40886782

40905804

40951648

40953096

40955368

40957895

252724