IR 05000443/2023002

Integrated Inspection Report 05000443/2023002

ML23220A209
Person / Time
Site:	Seabrook
Issue date:	08/08/2023
From:	Matt Young NRC/RGN-I/DORS
To:	Coffey B Florida Power & Light Co
References
IR 2023002
Download: ML23220A209 (1)

Text

August 8, 2023

SUBJECT:

SEABROOK STATION - INTEGRATED INSPECTION REPORT 05000443/2023002

Dear Bob Coffey:

On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station. On July 24, 2023, 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. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the 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 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. 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, Digitally signed by Matthew R. Matthew R. Young Date: 2023.08.08 Young 13:26:00 -04'00'

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: 05000443/2023002 Enterprise Identifier: I-2023-002-0035 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station Location: Seabrook, New Hampshire Inspection Dates: April 1, 2023 to June 30, 2023 Inspectors: T. Daun, Senior Resident Inspector C. Newport, Senior Resident Inspector S. Flanagan, Acting Resident Inspector P. Cataldo, Senior Reactor Inspector N. Eckhoff, Health Physicist Approved By: Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety Enclosure

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

Failure to Establish Continuous Fire Watch on Fire Door Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.4] - 71111.05 Systems NCV 05000443/2023002-01 Teamwork Open/Closed 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 establish a continuous fire watch on fire door C107 which was open in the A essential switchgear room.

Failure to Make Required 50.72(b)(3) Notifications Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000443/2023002-02 Open/Closed The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.72(b)(3)(iv) with three examples when NextEra failed to make three required event notifications.

Additional Tracking Items

None.

PLANT STATUS

Seabrook Station began the inspection period in refueling outage 22 (OR22) that commenced on March 31, 2023. On May 12, 2023, as the station was returning to 100 percent power, a heater drain pump failed requiring a rapid down power to 48 percent power for repairs. On May 14, 2023, the station returned to 100 percent power. Seabrook remained at or near 100 percent rated thermal power 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 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

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

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal high temperatures for the following system: service water and control building heating ventilation and air conditioning

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (5 Samples)

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

(1) Reactor water level instruments during decreased reactor pressure vessel water inventory for vessel disassembly on April 6, 2023

(2) 'B' shutdown cooling system during decreased water inventory in reactor vessel on April 7, 2023

(3) Spent fuel pool cooling system following core offload to spent fuel pool on April 10, 2023

(4) 'A' cooling tower service water with 'B' cooling tower service water out-of-service for maintenance on April 11, 2023

(5) 'B' residual heat removal system after aligning for emergency core cooling on May 5, 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) Containment building operating deck (C-F-3-Z) on April 13, 2023

(2) Containment building middle level (C-F-2-Z) on April 21, 2023

(3) Containment building lower level (C-F-1-Z) on April 27, 2023

(4) 'A' switchgear room (CB-F-1A-A) on June 1, 2023

(5) Primary auxiliary building ventilation rooms (PAB-F-3B-Z) on June 12, 2023

Fire Brigade Drill Performance (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the on-site fire brigade training and performance during an unannounced fire drill on May 19, 2023

71111.06 - Flood Protection Measures

Flooding (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the control building cable spreading room on June 8, 2023

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 'B' primary component cooling water heat exchanger

===71111.08P - In-service Inspection Activities (PWR) The inspectors verified that the reactor coolant system boundary, risk significant piping system boundaries, and the containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing activities from April 10, 2023 through April 29, 2023.

PWR In-service Inspection Activities - Nondestructive Examination (NDE) and Welding Activities (IP Section 03.01) ===

(1)

• Manual ultrasonic and visual examinations of the -26' containment liner during repairs at the 220-240 azimuth (NDE Report SB1-IWE-23-239)

• Manual ultrasonic examination of 6-inch safety injection pipe-to-elbow welds S1-0251-07-02 and 03 (NDE Report SB1-UT-23-034 and 035)

• Visual examination of pressurizer heater sleeves (NDE Report SB1-VT-23-043)

• Visual examination of control rod drive mechanism canopy sleeve and clamp (NDE Report under WO 40807466-01)

• Class 1 welding activities and progressive liquid penetrant examinations associated with the steam generator bowl drain replacement under NRC-approved relief request 4RA-22-01 (ML23073A156) and engineering change EC297778

• Magnetic particle examination of pressurizer skirt weld (NDE Report SB1-MT-23-002)

• Liquid penetrant inspection following welding of Class 2 piping high point vent of 'A' charging pump (EC298147, and WO 40854907-01)

• Verification of the performance of structural examinations of containment in accordance with IWE requirements, and associated with the 15-year 10 CFR 50 Appendix J, Type A Integrated Leak Rate Test (WO 40803307, EX1803.001 "Reactor Containment Integrated Leakage Rate Test - Type A,"

Revision 12)

PWR In-service Inspection Activities - Vessel Upper Head Penetration Inspection Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the licensee conducted the following reactor vessel upper head penetration inspections and addressed any identified defects appropriately:

(1) Reactor pressure vessel head bare metal visual examination of penetrations 2, 3, 66, 76, 77, and 78 (NDE Report SB1-VT-23-055)

PWR In-service Inspection Activities - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1)

• Boric acid identified on 1-CS-FT-160 (AR 02405971)

• Boric acid identified on 1-RH-V59 (AR 02453747)

• Boric acid identified downstream of 1-CS-V17 (AR 02449495)

• Boric acid identified on flange of 1-RH-E-9B (AR 02453006)

• Boric acid identified on swing-check 1-RH-V29 (AR 02453748)

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 reactor coolant system heatup, reactor startup, approach to criticality, and low power physics testing in May 2023

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator training conducted in the plant reference simulator on June 14, 2023

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Control room building air system in accordance with the Maintenance Rule Program on June 8, 2023

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following structures, systems, and components remains capable of performing their intended function:

(1) Quality control verifications are properly specified in accordance with the Quality Assurance Program and are implemented as specified during outage work activities

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) Elevated (shutdown) risk during reduced reactor coolant inventory on April 5, 2023

(2) Risk management actions required for containment closure in Mode 5 on April 6, 2023

(3) Risk management actions associated with all ocean service water and one cooling tower service water out-of-service for maintenance on April 11, 2023

(4) Elevated (yellow) risk during emergency diesel generator 'B' planned maintenance window the week of June 6, 2023

(5) Elevated (yellow) risk during emergency diesel generator 'A' planned maintenance window the week of June 20, 2023

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) 'B' emergency bus failure and restoration (AR 02454289) on April 12, 2023

(2) 'B' emergency diesel following incorrect fluid addition to crankcase oil sump (AR

===02458425) on April 23, 2023

(3) Emergency feedwater check valve cycling (AR 02458869*) on May 30, 2023

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) ===

(1) The inspectors evaluated OR22 activities from April 1, 2023 through May 7, 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 (PMT) (IP Section 03.01)

(1) 'A' centrifugal charging pump following rotating element replacement on April 16, 2023

(2) 'B' containment sump isolation valve encapsulation tank as left leak rate test following installation of manways following valve inspection on April 17, 2023

(3) 'B' diesel generator sequencer power supply replacements on April 30, 2023

(4) 'D' vital inverter after replacement on June 1, 2023

(5) 'B' emergency diesel generator after the planned maintenance window on June 9, 2023

(6) 'A' emergency diesel generator after the planned maintenance window on

June 26, 2023 Surveillance Testing (IP Section 03.01) (3 Samples)

(1) 'A' auto safety injection, phase 'A' containment isolation, containment ventilation isolation and main steam isolation actuation surveillance test on April 3, 2023

(2) Reactor containment integrated leakage rate test on April 29, 2023

(3) 'B' emergency diesel generator engineered safeguards test on May 2, 2023

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

(1) 'B' centrifugal charging comprehensive pump test on April 7, 2023

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Local leak rate testing chemical and volume control normal letdown penetration X37A on April 21, 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 June 14,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant related radiological hazards and the radiation protection requirements intended to protect workers from those hazards

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Observed egress of personnel and material at the radiologically controlled area alternate access point, along with technician response to personal contamination alarms

(2) Observed counting of survey material in a low background area to ensure accuracy of survey results

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Observed surveying of work area after pipe cut during steam generator bowl work

(2) Observed surveys after valve removal in demineralizer alley

(3) Outage reactor vessel disassembly and reassembly as low as reasonably achievable plan - package number 23-01

(4) Outage reactor head peening as low as reasonably achievable plan - package number 23-02 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Locked high radiation areas in the primary auxiliary building

(2) Locked high radiation area controls for under the reactor vessel head during reactor head peening

(3) Observed a briefing for valve work performed in a locked high radiation area Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Primary auxiliary building cleanup filter PAH-F-16

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Temporary ventilation used in the waste storage building

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Whole body counts related to AR 02455099

(2) Reviewed calibration records of whole body count equipment

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Neutron dosimetry program

(2) Declared pregnant worker program

OTHER ACTIVITIES - BASELINE

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

MS05: Safety System Functional Failures (IP Section 02.04) ===

(1) For the period April 1, 2022 through March 31, 2023

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) For the period April 1, 2022 through March 31, 2023

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) For the period April 1, 2022 through March 31, 2023

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

(1) The inspectors reviewed the Seabrook corrective action program for trends that might be indicative of more significant safety issues

71153 - Follow Up of Events and Notices of Enforcement Discretion Reporting (IP Section 03.05)

(1) Reportability follow up on actuation of the 'B' emergency diesel generator emergency power sequencer

(2) Reportability follow up on actuation of the reactor program system during digital rod position indication system surveillance testing

INSPECTION RESULTS

Failure to Establish Continuous Fire Watch on Fire Door Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.4] - 71111.05 Systems NCV 05000443/2023002-01 Teamwork Open/Closed 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 establish a continuous fire watch on fire door C107 which was open in the A essential switchgear room.

Description:

On June 1, 2023, during a walkdown of the essential switchgear room NRC inspectors identified that fire door C107 was held open by extension cords pinched in the door. No fire watch was seen at the door or in either the essential switchgear room or the stairwell the door goes to. The inspectors immediately notified the control room. The control room confirmed a continuous fire watch should have been established by the work group and dispatched the fire brigade leader to investigate.

It was discovered that work was being performed in the stairwell that required power cords to be run from the essential switchgear room to the stair well for electrical power. The work group was briefed by the control room on the requirement to station a continuous fire watch while the door was open for the cords but when the work group left, they removed all the cords but missed one that was still in door. This was left unnoticed by the work group until the inspectors discovered it.

This fire door falls under the licensees Technical Requirements 11 for Fire Rated Assemblies which prescribes the actions for one or more fire rated sealing devices being nonfunctional as establishing a continuous fire watch on at least one side of the affected assembly within one hour or verify the functionality of fire detectors on at least one side of the nonfunctional assembly and establish an hourly fire watch patrol. The appropriate compensatory action for this degraded fire door was determined by the licensee to be a continuous fire watch on at least one side of the affected assembly.

Corrective Actions: Corrective actions included entering the appropriate actions in the Technical Requirements Manual and implementing the required continuous fire watch until the degraded fire barrier had been restored. NextEra also wrote an AR for which directs an evaluation for the reason and to provide coaching to the work group. (AR2459087)

Corrective Action References: 2459087

Performance Assessment:

Performance Deficiency: The inspectors determined that Seabrook's failure to establish appropriate compensatory measures for a degraded fire rated assembly as required by the Technical Requirements Manual was a performance deficiency that was reasonably within Seabrooks ability to foresee and correct and should have been prevented. Specifically, a continuous fire watch was not established when fire door C107 was degraded.

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 degraded condition identified with the open fire door would have adversely impacted the essential switchgear room's fire barrier functionality.

(IMC0612 Appendix E example 2.d)

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 this issue to be of very low safety significance, Green, in Phase 1, Task 1.4.4.F, Fire Confinement, because the degraded fire barrier only adversely impacted one fire area and did not impact any other adjoining fire areas.

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Lack of communication or understanding between work personnel that ordered the continuous fire watch and the assigned personnel to the fire watch resulted in a misunderstanding of duties and responsibilities of the position.

Enforcement:

Violation: Seabrook Station, Unit 1 Facility Operating License Condition 2.F requires, in part, NextEra to implement and maintain 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 the Seabrook 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, Technical Requirement 11, Fire Rated Assemblies, establishes the limiting condition for operation, in part, to be all sealing devices in fire rated assemblies shall be functional while the equipment protected by the fire rated assemblies is required to be operable. The Technical Requirement 11 prescribes the actions for one or more fire rated sealing devices being nonfunctional as establishing a continuous fire watch on at least one side of the affected assembly within one hour or verify the functionality of fire detectors on at least one side of the nonfunctional assembly and establish an hourly fire watch patrol. Contrary to the above, on June 1, 2023, Seabrook did not establish required compensatory actions of Technical Requirement 11.

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

Failure to Make Required 50.72(b)(3) Notifications Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71153 Applicable NCV 05000443/2023002-02 Applicable Open/Closed The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.72(b)(3)(iv) with three examples when NextEra failed to make three required event notifications.

Description:

On April 12, 2023, while Seabrook Station was in Mode 6 at zero percent power, a valid actuation signal of the B emergency diesel generator emergency power sequencer occurred due to a loss of power to the B emergency Bus E6. The loss resulted from spurious operation of emergency power sequencer remote manual override relays that opened the unit auxiliary transformer feeder breaker to bus E6. Subsequently, the loss of power to bus E6 resulted in a valid actuation of an emergency power sequencer starting signal to the B emergency diesel generator. At the time of this event, the B emergency diesel generator was removed from service for scheduled maintenance and therefore, did not start.

Within eight hours of the event occurring inspectors questioned the licensee on the reportability of the event but at the time the licensee determined the event was not reportable because the emergency diesel generator was tagged out-of-service. The inspectors reviewed NUREG-1022, Rev.3, Event Report Guidelines, and noted Section 3.2.6 example 3 states, The event is reportable because the actuation logic for the emergency diesel generator start was completed, even though the emergency diesel generator did not power the safety buses.

On May 6, 2023, at 15:52 with Seabrook Station in Mode 3 at zero percent power, while performing digital rod position indication system surveillance testing, shutdown bank 'E' stopped withdrawing. In response, the reactor trip breakers were manually opened, initiating a valid actuation of the reactor protection system. Subsequently on May 6, at 22:53 while continuing to perform digital rod position indication system surveillance testing, shutdown bank 'C 'stopped inserting. Reactor trip breakers were manually opened, initiating a valid actuation of the reactor protection system. Initially the operators had determined these two reactor protection system actuations were not reportable. On May 11, 2023 the resident inspectors questioned why two events were not reported as required by 10 CFR 50.72(b)(3)(iv)(A) "Eight Hour Reports", for the valid actuation of the reactor protection system.

Corrective Actions: AR 02458443 was generated to perform common cause evaluation and make the missed reports as required by 10 CFR 50.72. NextEra reported the valid actuation of the 'B' emergency diesel generator emergency power sequencer and the two valid actuations of the reactor program system as required by 50.72 (EN 56564 and EN 56565) on June 8, 2023.

Corrective Action References: ARs 02458443, 02454289, 02456934, 02456952, 02459323, 02454246

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency. Failing to submit the event notifications as required by 10 CFR 50.72 within the required time was a performance deficiency that was reasonably within NextEras ability to foresee and correct and should have been prevented. The inspectors reviewed the condition for Reactor Oversight Process significance and concluded there was no associated finding. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more than minor, a cross-cutting aspect is not assigned to this violation in accordance with IMC 0612.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

Severity: This violation was assessed using Section 2.2.4 of the NRCs Enforcement Policy.

Using the example listed in Section 6.9.d.9, A licensee fails to make a report required by 10 CFR 50.72, the issue was determined to be a Severity Level IV violation.

Violation: 10 CFR 50.72(b)(3)(iv)(A), "Eight Hour Reports," requires the licensee to notify the NRC for any event or condition that results in valid actuation of any of the systems listed in paragraph (b)(3)(iv)(B) of this section, except when the actuation results from and is part of a pre-planned sequence during testing or reactor operation. Contrary to the above, NextEra did not notify the NRC within eight hours of the occurrence of a condition at Seabrook Unit 1 as evidenced by the following examples:

(1) On April 12, 2023 NextEra did not notify the NRC within eight hours of the occurrence of a condition at Seabrook Unit 1 that resulted in a valid actuation of the 'B' emergency diesel generator emergency power sequencer.

(2) On May 6, 2023 at 15:52 NextEra did not notify the NRC within eight hours of the occurrence of a condition at Seabrook Unit 1 that resulted in a valid actuation of the reactor program system.

(3) On May 6, 2023 at 22:53 NextEra did not notify the NRC within eight hours of the occurrence of a condition at Seabrook Unit 1 that resulted in a valid actuation of the reactor protection system.

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

Observation: Semi-Annual Trend Review 71152S The inspectors evaluated a sample of issues and events that occurred over the first and second quarters of 2023. The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by NextEra for potential trends at a low threshold, and resolved within the scope of the corrective action program.

EXIT MEETINGS AND DEBRIEFS

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

• On April 14, 2023, the inspectors presented the 71124.01 inspection results to Brian Booth, Site Vice President, and other members of the licensee staff.

• On April 20, 2023, the inspectors presented the 71111.08P inspection results to Jeff Sobotka, Engineering Director, and other members of the licensee staff.

• On May 25, 2023, the inspectors presented the 71124.03 and 71124.04 inspection results to Brian Booth, Site Vice President, and other members of the licensee staff.

• On July 24, 2023, the inspectors presented the integrated inspection results to Brian Booth, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures OP-AA-102-1002 Seasonal Readiness Revision 40

Work Orders 40617315

40738017

4078192

40804835

40834945

40835181

71111.04 Corrective Action 02196368

Documents

Drawings PID-1-RH- Residual Heat Removal System Overview Revision 003

B20660

PID-1-SF-F20482 Spent Fuel Pool Cooling and Clean Up System Detail Revision 11

Miscellaneous DBD-SF-01 Spent Fuel Pool Cooling, Purification, and Cleanup System Revision 3

Procedures OS1000.04 Plant Cooldown From Hot Standby to Cold Shutdown Revision 72

OS1000.12 Operation with RCS at reduced Inventory Revision 19

OS1001.11 Reactor Coolant System Shutdown Level Instrumentation Revision 17

OS1001.12 Draining the Reactor Coolant System for Vessel Head Revision 23

Removal

OS1013.04 Residual Heat Removal Train B Startup and Operation Revision 38

OS1016.05 Service Water Cooling Tower Operation Revision 40

OS1016.12 Contingency Cooling Tower Pump Restoration During Revision 2

Cooling Tower Maintenance

71111.05 Corrective Action 02459087

Documents

Resulting from

Inspection

Procedures FP 5.1 Fire Brigade Response Revision 07

FP-AA-104 Fire Protection Program Revision 6

FP-AA-104-1003 Fire Response Revision 3

OS1200.00 Response to Fire or Fire Alarm Actuation Revision 28

OS1200.05 Response to EFW Pump House Fire Revision 00

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.06 Corrective Action 00120752

Documents

Drawings 1-NHY-310431 Control Building, General Electrical Arrangement Revision 30

Procedures MA5.7 Station Barriers, Penetration Seals, and Fire Wrap Revision 20

71111.07A Corrective Action 02454023

Documents 02454415

2454487

Miscellaneous FPLE-213 Final Eddy Current Inspection Report For: PCCW E-17B 04/13/2023

Work Orders 40806953

40829216

71111.11Q Procedures OP-AA-100-1000 Conduct of Operations Revision 38

OP-AA-1000 Conduct of Infrequently Performed Tests or Evolutions Revision 19

OS1000.02 Plant Startup From Hot Standby To Minimum Load Revision 47

OS1000.07 Approach to Criticality Revision 16

RS1735 Reactivity Calculations Revision 10

RS1737 Post Refuel Low Power Physics Testing Revision 14

71111.12 Corrective Action 02432518

Documents 02453360

2454004

2455093

2455101

2456467

2545140

Drawings PID-1-CBA- Control Building Air Conditioning System Safety Related Revision 8

B20307 Chilled Water System Train A

Procedures ER-AA100-2002 Maintenance Rule Program Administration Revision 13

Work Orders 40363937

40719515

40829214

40876569

40876632

237635

71111.13 Corrective Action 02453437

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 02453447

2453483

2453553

2453595

2453649

2453704

Procedures OP-AA-102-1003 Guarded Equipment Revision 46

OS1016.11 Contingency Ocean Pump Restoration for SW Work Revision 12

Activities with Ocean Service Water Pumps Not in Service

OS1056.03 Containment Penetrations Revision 16

OS1401.12 RCS Reduced Inventory Containment Integrity Verification Revision 5

WM-AA-203-1006 Critical Maintenance Management Revision 18

Work Orders 40844256

71111.15 Corrective Action 02447144

Documents 02453822

2454246

2454289

2454290

2454753

2454778

2458425

2458457

2458527

2459800

Corrective Action 02458869

Documents

Resulting from

Inspection

Drawings 1-NHY-310102, 4160V Bus 1-E6 RAT Inc Line Three Line Diagram Revision 7

Sh A72a

1-NHY-310102, 4160V Bus 1-E6 RAT Inc Line Close Schematic Revision 14

Sh A72b

1-NHY-310102, 4160V Bus 1-E6 RAT Inc Line Trip Schematic Revision 9

Inspection Type Designation Description or Title Revision or

Procedure Date

Sh A72c

1-NHY-310102, 4160V Bus 1-E6 P.T.S. Schematic Diagram Revision 10

Sh A73e

1-NHY-310102, 4160V Bus 1-E6 P.T.S. Auxiliary Contacts Revision 10

Sh A73f

1-NHY-310102, 4160V Bus 1-E6 PT'S. Schematic Diagram Revision 7

Sh A73h

Work Orders 40803551

40803602

40882367

40883359

71111.18 Drawings 9763-F-101402 Containment Concrete Mat Sections Revision 14

9763-F-101462 Containment Liner Bottom Plate Revision 8

9763-F-805139 Containment Liner Floor Leak Chase Piping System Piping Revision 10

Arrangement

FP01925-06 Seabrook Station Unit No. 1 Bottom Leak Chase - Erection Revision 0

Engineering 298541 Design Change Package for Containment Boundary Change Revision 0

Changes to Include Embedded Liner Leak Chase System

Miscellaneous 445860-SBSAG- Containment Shell Structure Axisymmetric Analysis Revision 0

7CS2-CALC

9763.006-80-1 Containment Design Specification Revision 8

CS-23-CALC Containment Embedded Liner Leak Chase System Revision 0

Structural Evaluation

71111.20 Corrective Action 02454401

Documents 02454409

Miscellaneous OR22 Outage Safety Review Supporting Documentation,

Seabrook Nuclear Plant

Procedures ON1090.04 Containment Entry Revision 43

OS1000.03 Plant Shutdown From Minimum Load To Hot Standby Revision 40

OS1000.04 Plant Cooldown From Hot Standby To Cold Shutdown Revision 71

OS1000.06 Power Decrease Revision 30

OX1406.12 18 Month Containment And Containment Spray Revision 17

Recirculation Sump Surveillance

Inspection Type Designation Description or Title Revision or

Procedure Date

SM 7.31 Shutdown Safety Review And Safety Assessment Revision 02

71111.24 Corrective Action 02317995

Documents 02411459

2454285

2454455

2454623

2454629

2454753

2455034

2456062

2456181

2456182

2459359

2459413

2459415

2459684

2459690

2460574

2460704

2460764

Drawings 1-NHY-300229 Installation of Electrical Raceway and Supports Revision 2

1-NHY-310108 Emergency Power Sequencer System Schematic Diagram Revision 6

Procedures ES1804.056 CBS-TK-101A and CBS-TK-101B Encapsulation Tank Revision 1

Leakage Rate Test

EX1803.001 Reactor Containment Integrated Leakage Rate Test - Type Revision 12

A

EX1803.003 Reactor Containment Type B and C Leakage Rate Tests Revision 19

LS0567

MS0539.28 A-EDG Coolant Recirculation, Draining and Refilling Revision 19

MS0539.54 B-EDG Coolant Recirculation, Draining and Refilling

OX1426.03 Emergency Power Sequencer 18 month Operability Test Revision 11

OX1426.32 Diesel Generator 1B 36 Month Operability Surveillance Revision 29

OX1456.92 Centrifugal Charging Comprehensive Pump Test Revision 19

Inspection Type Designation Description or Title Revision or

Procedure Date

OX1456.92 Centrifugal Charging Comprehensive Pump Test Revision 19

OX1456.93 Train B SI, Phase A, CVI & MSI Actuation 18 Month Revision 27

Surveillance

OX1456.96 Train A SI, Phase A, CVI & MSI Actuation 18 Month Revision 24

Surveillance

Work Orders 40394846

40427243

40605097

40728214

40782885

40803307

40803583

40806895

40806896

40807046

40807047

40807052

40807117

40807583

40811961

40825215

40844205

40844321

40844718

40845313

40854907

40877477

40879331

20