ML24247A112
| ML24247A112 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/26/2023 |
| From: | Sarah Elkhiamy NRC/RGN-I/DORS |
| To: | C-10 Research & Education Foundation |
| References | |
| Download: ML24247A112 (1) | |
Text
Documentation of Meeting between C -10 and NRC Region I regarding questions on Quarterly Reports for Calendar Year 2023 Members of the NRC Region I staff met virtually with members of C-10 to respond to questions submitted by the group for the 2023 quarterly inspection reports. The discussions were held on the following dates: October 24, 2023 (1st quarter inspection report), March 19, 2024 (2 nd and 3rd quarter inspection reports), and August 7, 2024 (4 th quarter inspection report). 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 letters as satisfactorily answered.
Attached C-10 letter s inquiring about 1st thru 4th Quarter 2023 Inspection Reports
July 26, 2023
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
David Lew, Regional Administrator, Region 1 Director, Office of Enforcement 475 Allendale Road Suite 102 King of Prussia, PA 19406-1415
Travis Daun, Senior Resident Inspector Seamus Flanagan, Resident Inspector Seabrook Station 626 Lafayette Road Seabrook, NH 03874
Mel Gray, Branch Chief - Engineering Branch 1
Nicole Warnek, Senior Project Engineer Projects, Branch 2
Joseph DeBoer, Senior Project Engineer Projects, Branch 2
Matt Young, Chief, Reactor Projects, Branch 2
Nik Floyd, Senior Reactor Inspector, Region 1
Sarah Elkhiamy, Senior Project Manager, Region 1
SUBJECT:
Response to NRC 1st Quarter Integrated Inspection Report, NRC Cover letter dated May 11, 2023 (ML23129A193)
Greetings:
This letter is written in response to the above Integrated Inspection Report. We look forward to receiving your responses to the following questions, comments and concerns we have highlighted in this letter.
The NRC introductory cover letter states, No findings or violations of more than minor significance were identified during this inspection. Having reviewed the details reported in this IIR, we cannot agree that all the findings are of only minor significance.
Would you please explain the meaning of the term finding? (See first beginning paragraph, page 8) It seems a finding is different from a violation. We did consult the NRC Inspection Manual Chapter 0609 and Chapter 0612. These address findings.
Is it the case that under the Significant Determination Process, the definition of findings is different from how it is used in this 2023 1 st Quarter IIR report?
Following are our specific areas of concern.
Page 5: (71111.15 (4): Electrical vaults W09 and W10 and circulating water/service water pumphouse structures are identified as exceeding their building deformation threshold limits.
Since the inception of the 2016 License Amendment Process, NextEra has re peatedly stated that Alkali Silica Reaction degradation was not a problem because it would be kept within the box (ASLB 2018 hearing transcript p. 521) of stated margins of structural integrity. (see pages 415 -
416 ASLB hearing transcript) September 2019, we have decades of margin before we would hit that threshold. Only five years of the now -27 more years of contemplated operation of Seabrook Station have elapsed since 2019, and we learn in this report that 10 structures are already exceeding their building deformation threshold limits. How is this not more than minor?
According to this IIR, before this report period there were already seven Seabrook structures identified as needing physical modification or additional analysis to comply with their current license/design basis. As of this report, the NRC placed three additional buildings into the POD/Prompt Operability Determination list (AR 0227 6197). The report states they recently exceeded established thresholds in the two electrical vaults and the circulating water/service water pumphouse. As of now, there are ten Seabrook structures that are acknowledged as exceeding their current license/design basis. How is this not of more than minor significance??
Further, while it is acknowledged in the inspection report that certain of the ten structures are in need of physical modifications to bring them back into conformity with their license/design basis, it is also stated that several may just need to be reanalyzed. This seems to mean that the licensee can change the parameters of what constitutes conformity to the plants license/design basis (see page 7, Evaluation of Three Structures in the Operability Determination, NextEra revised the operability determination Also see page 8, first paragraph, future e xpansion is expected to remain within the new established operability determination limit. ) Our understanding is that the NRC rewrote the Operability Determinations, creating a new document dated February 1, 2023. Is it correct that NRC/NextEra can, at will, change the requirements and by doing so can add margin? Also, the new version of Operability Determination, dated 2/1/2023, is not appearing on ADAMS. Can you direct us to where we can access this document? A more general question: how does revising the operability determination demonstrate capability to perform intended function?
Page 8: Evaluation of Three Structures in the Operability Determination. The operability determination evaluations also considered impacts to rebar stress and concluded the rebar stress was not approaching the yield limit. Would you advise if this determination was made based on calculations alone, or on field measurements (if so how where those conducted? )
Page 8: Evaluation of Three Structures in the Operability Determination. Would you please confirm how the new limits are calculated by NextEra, reviewed by the NRC, and what the basis is for accepting or rejecting? This is in reference to this excerpt: future expansion is expected to remain within the new established operability determination limits past the next scheduled monitoring inspection with margin. Please explain how you are determining future expansion. Ar e you merely extrapolating from past data? Is the extrapolation linear? Also, are all new ASR areas subject to be held to these new limits, or just newly found areas such as these three?
Page 8: Status of the Containment Internals Structure. Distress in the containment reactor pit floor, which is now in process of a root cause analysis procedure, to be completed in the summer of 2023: why is there apparent ongoing difficulty in determini ng and stating the cause of this damage? It seems, over the period of a few inspections, that there is a difference of opinion as to the cause of this damage. It seems clear, even with the contradictory causal factors cited, that at least some of the damage is due to ASR. If that is the case, does this not put this area into Tier 3, which then requires inspection every six months? How can this be accomplished if the area can be inspected only during refueling shutdowns? Through which analytical method or field observation has it been determined that the root cause is (low cycle) fatigue loading caused by thermal stress fluctuation as opposed to ASR?
Page 8: Timing of Corrective Actions This paragraph explains that there are ten structures now in NextEras Operability Determination Process that do not meet the NRC -approved methodology documents requirements. Five of these structures have been in ODP since 2019 and several due dates were extended multiple times. All of these five require physical modification. The paragraph states that the operative procedure (PI -AA-104-1000) calls for cited repairs in the Corrective Action Program to be completed within one to two refueling cycles, which are 18 months in length as you are aware. One intrinsic problem is that there are, apparently, no specific, fixed time deadlines in NRC regulations for NextEra to complete the identified repairs/solutions to listed problems if they are not written as a violation at a higher level than green. The report states that all the ten structures have been demonstrated to be functional with a supporting technical basis, but that such technical approaches were not intended to replace the approved methodology. NextEra has indicated that it plans to com plete the work by 2026, years beyond the NRCs stated required timeframe. Does this mean that NextEra can and has changed the analysis numbers to add margin? Is that what supporting technical basis means? Clearly, this completion timeframe is not within the normal ODP. Again, how is this not more than minor?
Page 9: ASR Monitoring and Expansion Trends. The inspectors noted that several of the extensometer locations were projected to exceed the licensed through-thickness expansion limit before the expiration of renewed Seabrook operating license in 2050, but based on current rates, the projected time to exceedance is greater than 10 years. Is this a result of the NRC inspector doing their own calculation to forecast out 10+ years, or NextEra? Our understanding in general, and mentioned earlier in this paragraph, is that projections need only be made to the next inspection interval, so who is responsible for trending out to the 2050 license end date?
A related question: Is NextEra performing elastic modulus tests on the cores extracted during extensometer installation procedure? As found in the transcript of 2018 Atomic Committee on Reactor Safety (ACRS) meeting (ML18348B117), NextEra reviewed the large -scale testing program data and literature data for multiple properties and determined that reduction in modulus of elasticity was the best material parameter to determine ASR expansion to -date.
We understand that all of you are extremely busy attempting to oversee and regulate Seabrook Station to the best of your ability. That said, we deduce from this inspection report that the situation at the plant is not the best - ASR seemingly moving significantly faster than anticipated, the licensee not keeping up with the Corrective Actions in a timely manner, failures to properly report issues and ongoing problems (containment reactor pit) and another example, at least ten recurrent through-wall water leaks.
We at C-10 empathize with your work burden, while at the same time feeling strongly that the above questions and the further information that your answers will provide are vital in keeping the public informed on the situation at Seabrook Station. Thank you for your anticipated responses!
Sincerely, Patricia Lang Skibbee
C-10 Board of Directors President/Research Team 978 502 4782
October 30, 2023 via electronic mail
To: U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
David Lew, Regional Administrator, Region 1 Director, Office of Enforcement 475 Allendale Road Suite 102 King of Prussia, PA 19406-1415 Travis Daun, Senior Resident Inspector Seamus Flanagan, Resident Inspector Seabrook Station 626 Lafayette Road Seabrook, NH 03874
cc: Mel Gray, Branch Chief - Engineering, Branch 1 Nicole Warnek, Senior Project Engineer Project, Branch 2 Joseph DeBoer, Senior Project Engineer Projects, Branch 2 Matt Young, Chief, Reactor Projects, Branch 2,Division of Operating Reactor Safety Niklas Floyd, Senior Reactor Inspector,Region 1 Sarah Elkhiamy, Senior Project Manager, Region 1
SUBJECT:
C-10 Research & Education Foundation communication regarding ML23220A209 Seabrook Station - Integrated Inspection Report 05000443/2023002
Dear Seabrook Station NRC Inspectors:
C-10 has reviewed the 2nd quarter Integrated Inspection Report and there are three areas of the document that prompted us toreach out to you for further information.
Topic 1: The finding Failur e to Establish Continuous Fire Watch on Fire Door documented on page 10.
Context 1.1: This was classified as an NCV and described as a cross-cutting issue in the Teamwork category,since itdemonstrated a lack of communication/coordination among NextEra staffwork teams.
In this case, firedoor C107 was leftopen for extension cords to go through the door opening tosupply electricityfor work being done on the other side of the door.Per the IIR No fire watch was seen at the door or in the essential switchgear room or the stairwell the door goes to.
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-6646 Page 1of 2 The NRC inspectors notified the Control Room. The workgr oup was briefed by the contr ol room on the requir ement to station a continuous firewatch while the door was open for the cords but when the work group left,they removed allthe cords but missed one that was stillin the door. This was leftunnoticed by the work group untilthe inspectors discover ed it.The failure to establish a continuous fire watch violated section 11 of the Technical Requirements Manual, which requires such fire watch be established within one hour of the breached fire door.
C-10 believes thisdemonstrates a lack not only of communication, but of disregard of basic safety procedure.
Question 1.1:
Can the NRC share with C-10 the explanation that NextEra provided as to how this mistake occurred, and how they plan to improve on itmoving forward considering the briefing from the control room immediately prior to this mistake occurring, did not appear to sufficiently prevent it?
Context 1.2:
C-10 keeps a record of allfire safety violations atSeabrook Station. Alarmingly during the twelve-month period from July 1,2022 through June 30, 2023, the NRC cited NextEra for three separate fire safety violations (ML22304A180,ML23030A482,
ML23220A209 ).The fact that these occurred in a relatively short period of time is indicative of an ongoing pattern. As we understand it,these previous violations would have entered the Corrective Action Program, and required a Root Cause Analysis and Corrective Action Plan be completed by NextEra.
Question 1.2 What is the long-term solution to what appears to be a disturbingly regular occurrence of repeated fire safety violations atSeabrook Station? Will the NRC be applying a higher level of scrutiny to NextEras Root Cause Analyses and Corrective Action Plans on this newest NCV, given that the previous Corrective Action Plans have clearly not produced an improved result or prevention of future violation?
Topic 2: The failure of NextEra to follow regulations (in three separate instances) regarding their failure to report issues to the NRC within eight hours (or whichever amount of time is applicable to the incident) of occurrence.
Context 2.1:
On three occasions within the inspection period - April 12, 2023 and two separate times on May 6,2023 - valid actuation signals were triggered within various plant systems.
NextEra states that it didn tthink these were reportable incidents because the plant was at zero power atthose times. However 10 CFR 50.72 requires that such incidents be reported within eight hours of occurrence even when the plant isat zero power. Similar to the fire-safety issues outlined above, thisis also indicative of a pattern.
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/ www.c-10.org/(978)465-6646 Page 2 of3 Question 2.1:
Will NextEra be investigating whether there have been additional mistakes made by Seabrook Station Employees related to mandated reporting to the NRC that are not yet known tothe NRC and therefore also not by the public? This seems like itcould be a logical part of the Root Cause Analysis, to determine if itis a systemic issue or more of an issue with certain individual personnel repeating the mistake.
Topic 3: Item 2 in the section 71 111.15 - Operability Determinations and Functionality Assessments.
Context 3.1:
B emergency diesel following incorr ect fluid addition to crankcase oil sump (AR 02458425) on April 23, 2023. This error is not explained with any detail or cited as a violation in the Inspection Results section, but itseems to us to be of great significance given that itcould impact the operability of the emergency diesel generator.
Question 3.1.1:
How was this error discovered?
Question 3.1.2:
Was there an operational issue with the generator resulting from the adding of the incorrect fluid?
Question 3.1.3:
What action can/will the NRC accept from NextEra to prevent future errors of this type?
Question 3.1.4:
We understand that there are some areas of work within a nuclear plant which require a partner system or require that a certain-level supervisor be present to observe, so that one person is not left alone in certain work situations. Itmakes sense that requiring the presence of two or more workers allows the opportunity for them to aid/monitor each other.Is this fluid addition scenario one of those work situations in which two or more workers must be present? Ifyes, were the required personnel present during this work?
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.or g
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/ www.c-10.org/(978)465-6646 Page 3 of3 March 12,2024 viaelectronicmail
To: U.S. NuclearRegulatory Commission Attn: Document ControlDesk Washington, DC 20555-0001
David Lew, Regional Administrator,Region1 Director,OfficeofEnforcement 475 AllendaleRoad Suite102 King ofPrussia,PA 19406-1415
TravisDaun, Senior Resident Inspector Eben Allen,ResidentInspector Seabrook Station 626 LafayetteRoad Seabrook, NH 03874
cc: Mel Gray, Branch Chief-Engineering,Branch 1 Nicole Warnek, SeniorProjectEngineer Project,Branch 2 Joseph DeBoer, Senior Emergency Preparedness Inspector Matt Young, Chief,ReactorProjects,Branch 2,DivisionofOperating Reactor Safety NiklasFloyd, SeniorReactor Inspector,Region1 Sarah Elkhiamy, SeniorProjectManager, Region 1
SUBJECT:
C-10 Research &Education Foundation communication regarding ML23307A018 Seabrook Station-IntegratedInspectionReport 05000443/2023003
Dear Seabrook StationNRC Inspectors:
C-10 hasreviewed the 3rdquarterIntegratedInspectionReport and thereare threeareas ofthe document thatprompted us toreach out toyou forfurtherinformation.
Item1 -(Page 6): InspectionReview (IPSection 02.01-02.03)(1 Sample) 71114.04(Page 6):NextEra submitted seven proposed changes tothe Emergency Action Leveland Emergency Plan. Itisstatedin the reportthatthis evaluationdoes not constituteNRC approval.
Questions:
1.1:Do any of theseproposed changes overlapwithchanges proposed intheLicense Amendment Request forCommon Emergency Plan fromOctober 2022 (ML22278A031)
(withsubsequent documents submittedby FLP providingadditionalinformation:
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-66461 ML22343A254 inDecember 2022,ML23219A102 inAugust 2023, and ML23332A005 in November 2023)?
1.2: Our understanding isthatthese changes would have been put intoeffect immediately by NextEra, and thatthe NRC willreviewthem duringthe Annual EP Safety Inspection,the resultsofwhich willbe publishedin theinspectionreportthat follows.Is that correct,oristheNRC reviewof these itemsnow complete?
Item2: 71152A (Page 9) Observation: Review of NextEras Evaluation and Corrective Actions ofSafety-Related Structures Affected by Alkali-SilicaReaction (ASR): Status of theConsolidated Prompt Operability Determination (POD)
Questions 2.1: Which structuresdo not meet demand-to-capacity ratio?
2.2: When iscombining structuresthatdo not meet the demand-to-capacity ratio acceptable?
2.3: What was thenature ofthe physicalmodificationsthatwere made thatrestored the margin tothe Mechanical Penetration Area?
Item3 (Page 10):711152A Observation: Review ofNextEras Evaluation and Corrective Actions ofSafety-Related Structures Affected by Alkali-SilicaReaction (ASR); Evaluation ofTwo Structures inthe POD
Context 3.1:CorrectiveActionsindicatesthatASR margins have been exceeded inthetwo structuresthatwere inspected. In thiscase theinspectorsdetermined theplanned corrective actionswere tophysicallymodify(aka retrofit)thestructurestobringstructuralelements intoconformance withthe licensingand design basis.The inspectorsnoted the planned retrofitapproachesand concepts were primarilytargetedtoincrease thestructuralcapacity forthe exceeded limitstateandwere not based on increasing oralteringthestructural stiffness.Theretrofitdesignsalsoconsidered the need forcontinued access to monitorfor the effectsofASR afterretrofit.
Questions:
3.1.1:Why were only2 structuresinspectedout ofallthe structuresidentifiedashaving ASR?
3.1.2:Inspectors were only ableto walkdown the accessibleportionsof thePOD structures;what about the inaccessibleparts?How and when are theymonitored?
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-6646Page2of4 Context 3.2:The inspectorsfurtherdetermined the POD evaluations considered impacts to rebarstress and concluded the rebar stresswas eithernotapproaching theyield limitor establishedenhanced monitoring consistentwith ASR-related license conditionsto show that rebaryieldingwould be detected.
Questions:
3.2.1:What type ofenhanced monitoring willshow rebar yield?
3.2.2:When/if the enhanced monitoring shows rebar yieldto thepoint thatitsoutof margin, what isthe course ofaction?
Context 3.3 (Page 11):Structuraldamping forthe safe shutdown earthquake unusual load combination increased from 7 percent inthelicensing basisto 10 percent inthePOD. The inspectorsnoted a damping levelof10 percent isallowed by the standard inAmerican Societyof CivilEngineers 43,Seismic Design CriteriaforStructuresSystems and Components in Nuclear Facilities,basedon the corresponding levelof crackingand high stresslevelsinthe structureunder the safe shutdown earthquake load.
The engineering standards referenced inthe IIRfrom The American Society of Civil Engineers 43, Seismic Design CriteriaforStructures,Systems and Components inNuclear FacilitiesstateThegoal ofthisstandard isto ensure thatnuclear facilitiescanwithstandthe effectsofearthquake ground-shaking withdesired performance.
Our review ofthe standard citedinthe reportconcluded thatthereis no mention ofalkali silicareactionoritsimpact on structuresinnuclear facilities.The10percent damping level thatisallowed by thestandard isspecifictoconcrete performing withindesign standards and notimpacted byASR. Ifstandards are tobe used, more currentstandards which are peer-reviewed and offeredby expert professionalsocieties,American Concrete Institute (ACI)Committee Report 349.3R, EvaluationofExistingNuclear Safety-Related Concrete Structures,andAmerican SocietyforTesting and Materials (ASTM) Standard C856-11, StandardPracticeforPetrographic Examination ofHardened Concreteare highly recommended.
C-10 isconcerned thatthe truenature ofASR on structuralintegrityisnotaccounted for.It appears thatNextEra isonlycomparing the currentresultto thelatestmonitoring record inspection.So,the 1.1.ratioor crackgrowth arenot absolute values thatgo back to the mandated startofmonitoring (notthe date monitoringwas implemented). Questions:
Questions:
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-6646Page3of4 3.3.1:Itappears thatthe criterioniscontinuallyrevisedduring every inspectionbased onlyon the previous inspection.Is thiscorrect?
3.3.2:How are NextEra and the NRC documenting and tracking theabsolute growth of thecracks to monitortotalcracking and expansion progression?
What we learnedin thisreportwith respectto ASR isthatbuildingsare now being retrofittedto meet design basis,inspection intervalsarebeing increased, calculationbases are being shifted and arenot executed ina timelymanner according tothe agreed upon schedule. What does the trendinganalysisdata indicatefor thecurrent timelineofwhen operabilitylimitswillbereached?
Atthe in-personJune 2023 Annual PublicSafety Meeting, NRC inspectors statedthat some structuresinthe POD are trendingto exceed the allowable limitsinmore than 10 years but before2050. What isthe currentstatus ofNextEras plan toaddress thislooming timeframe?
Ina meeting with C-10 on October 24, 2023 the NRC inspectors explained thatre-analyzingis a stopgap before structuremodifications,but thatitcantgo on forever.Ifretrofittingwillnotbe complete until2026 (approximately 2 years from now), what isguaranteeing the safetyof these structuresand the citizensresidinginthe EPZ and beyond for thenext 2 years?
Thank you foryour consideration on these items and we look forward toyour responses.
KindestRegards,
Sarah Abramson Executive Director C-10 Research & Education Foundation 11Chestnut St.,Amesbury, MA 01913 Ph:(978) 465-6646 Email: sarah@c-10.org
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-6646Page4of4 May 21, 2024 viaelectronicmail
To: U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Attn: TravisDaun, Senior Resident Inspector Eben Allen,Resident Inspector Seabrook Station 626 Lafayette Road Seabrook, NH 03874
Cc: Matt R. Young, Chief ProjectsBranch 2Division ofOperating Reactor Safety David Lew, 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 InspectionReport 05000443/2023004 (ML24043A002)
Dear Seabrook StationNRC Inspectors:
C-10 has reviewed the 2023 4th quarterIntegrated InspectionReport and thereare four areas ofthe document thatprompted us toreach out toyou forfurtherinformation.
Item 1:Motor oilissue timeline We would liketorequest some clarityregardingthemotor oilissueand associated timelineforresolution.
A. Can you please advise ifthesedates are correct,and ifnotwhat thecorrect dates are?
On page 6the reportstates thatan OperabilityDetermination was performed followingreplacement ofmotor oilon RHR Pump A on November 14, 2023.
However, furtherdown on the same page the reportstatesthat a post-maintenance test was conducted November 1, 2023, following replacement of motor oilon RHR Pump A.
On page 9the reportstates thatthe motor oilon RHR Pump A was replaced on October 10, 2023 and thata sample ofthe oilwas sent offfor analysis.However thereport then statesthatthe oilanalysiswas received inSeptember 2023.
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-6646Page1of2 While itwas discouraging tolearn thatthe apparent cause for theuse ofthe incorrect typeof oil(decanting oilintomis-labeled container(s)) was identifiedas a trend, itwas encouraging toknow thata better system isnow inplace.
B. How is the NRC monitoring that thisbettersystem isbeing followed by plant staff?
Item 2:Review of Seabrooks Evaluation and Corrective Actions for Radiation Monitoring System Failures (71152A)
On page 10 the reportnotes thatthere have been 9 failuresbetween 2021 -2023 of one or more of the containment gaseous radioactivitymonitors. Itfurtherstates that thestationhas been investigating along term actionto replace theirradiation monitoring system.
A. Given the number offailures,has the NRC provided NextEra withguidance on a timeline toimplement a new radiationmonitoring system?
B. Does the NRC requirea certain levelofreliabilityforsuch radiationmonitoring systems, such as a limittohow many failuresthissystem can endure in a certain time period before action isrequired by the licensee?
C. For clarity,istheintentofNextEra toreplace allradiationmonitors on siteat the plant,or justthose containment gaseous radioactivitymonitors? We are very interested inunderstanding the reliabilityandcurrent statusof the real-time radiation monitoring ofthe airthat isdone on-siteoutdoors atSeabrook Station.
Item 3:Remedial Training and Re-examinations On page 4 itwas noted that theinspectors evaluated the effectivenessof remedial trainingconducted by thelicensee, and reviewed the adequacy of re-examinations for licensedoperators who did not pass a required requalificationexamination.
A. How common isitforlicensed operators to failtheexamination and require requalificationatSeabrook Station,and how does Seabrook Station compare to other licensees in thisarea?
Item 4:Observation: Semiannual Trend Review On page 9 itwas noted that the inspectors evaluated the operator challenges program includingan audit ofcontrolroom deficiencies,control board notifications,and operator workarounds.
A. What type of deficienciesand workarounds are acceptable inthe controlroom?
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-6646Page2of3 B. Further down the reportnotes thatthe stationhas made significantprogress toward correcting long standing video alarms in thecontrol room. What was the issue withthe video alarms and how much more work isnecessary toresolve the issue and consider itclosed?
Thank you foryour 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
C-10Research&EducationFoundation/11ChestnutSt.,AmesburyMA01913/www.c-10.org/(978)465-6646Page3of3