IR 05000443/2021001

Integrated Inspection Report 05000443/2021001

ML21119A260
Person / Time
Site:	Seabrook
Issue date:	05/04/2021
From:	Brice Bickett NRC/RGN-I/DORS
To:	Moul D Florida Power & Light Co, NextEra Energy Seabrook
References
IR 2021001
Download: ML21119A260 (23)

Text

May 4, 2021

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - INTEGRATED INSPECTION REPORT 05000443/2021001

Dear Mr. Moul:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Seabrook Station, Unit No. 1. On April 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. Brian Booth, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations 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 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, Unit No. 1.

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, Unit No. 1.

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 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

Signed by: Brice A. Bickett Brice A. Bickett, Chief Reactor Projects Branch 3 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: 05000443/2021001 Enterprise Identifier: I-2021-001-0053 Licensee: NextEra Energy Seabrook, LLC Facility: Seabrook Station, Unit No. 1 Location: Seabrook, New Hampshire Inspection Dates: January 01, 2021 to March 31, 2021 Inspectors: C. Newport, Senior Resident Inspector T. Daun, Resident Inspector P. Cataldo, Senior Reactor Inspector S. Wilson, Senior Health Physicist Approved By: Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Operating Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Seabrook Station, Unit No. 1, 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 Evaluate Functionality for Degraded Fire Barrier Seals Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.15 Systems NCV 05000443/2021001-01 Complacency Open/Closed The inspectors identified a Green finding and associated non-cited violation of Seabrook Station Facility Operating License Condition 2.F when the station did not appropriately assess functionality of degraded fire rated seals. As a result, degradation, which required repair, resulted in the limiting condition of operation defined in Technical Requirement 11 to not be met and the required actions of Technical Requirement 11 not being implemented for a period of 30 days.

Human Performance Event Leads to B Service Water Cooling Tower Fan Inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems NCV 05000443/2021001-02 Challenge the Open/Closed Unknown The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification 6.7.1.a Procedures, because NextEra personnel failed to follow the requirements of work order 40757992. Specifically, on January 7, 2021, Seabrook maintenance personnel did not follow relevant work instructions which resulted in excessive particulate in the gearbox oil of the B service water cooling tower fan. This particulate plugged the internal lubrication spray nozzle and relief valve, resulting in over-pressurization of the gearbox and the failure of the gearbox oil pressure switch seal and resultant lube oil leak. This directly resulted in the inoperability and unavailability of the B service water cooling tower fan for approximately 80 additional hours.

Remote Shutdown System Indicator Exceeded Allowable Value for Time Longer than Permitted by the Technical Specifications.

Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000443/2021001-03 Open/Closed A self-revealed Severity Level IV non-cited violation of Technical Specification 3.3.3.5,

Remote Shutdown System Monitoring Instrumentation was identified when the reactor coolant system loop 1 wide range cold leg temperature indicator at the remote shutdown panel failed high and was not identified for two weeks.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000443/2020-002-00 Remote Shutdown System 71153 Closed Indicator Exceeded Allowable Value for Time Longer than Permitted by the Technical Specifications

PLANT STATUS

Seabrook Station began the inspection period operating at 100 percent rated thermal power. There were no operational power changes of regulatory significance 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk-significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the inspection procedures.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk- significant systems from impending severe weather on March 2

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) B emergency diesel generator realignment after testing on January 26

(2) A residual heat removal system prior to B residual heat removal system maintenance on March 1

(3) A emergency diesel generator during B emergency diesel generator emergent inoperability due to temperature control valve failure on March 4

(4) Start-up feedwater pump during turbine-driven emergency feedwater pump testing on March 23

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Cable spreading room (CB-F-2A-A) on January 27

(2) Primary auxiliary building (PAB-F-3A-Z) on February 26

(3) Primary auxiliary building (PAB-F-1A-Z) on March 10

(4) Tank farm (TF-F-1-0) and service water pipe chase on March 17

(5) Service water pump house (SW-F-1E-Z) on March 20

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

(1) The inspectors evaluated the on-site fire brigade training and performance during an unannounced fire drill on February 17

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Primary auxiliary building charging valve room on March 1

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance of the following activities in the control room:

• Fire drill response on February 17

• Emergency diesel generator alignment and start-up on March 5

• Control room response to alarms during routine daily evolutions on March 20

• Control room observations, engineered safety features actuation system testing, emergency feedwater run, and safety injection accumulator level calibration on March 23

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

(1) The inspectors observed and evaluated licensed operator crew performance evaluation training in the simulator on March 18

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) Rod control return to Maintenance Rule a(2) status during the week of January 11

(2) Start-up feedwater pump during the week of March 22

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (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 risk during service water cooling tower switchgear room maintenance on January 20

(2) Elevated risk due to condensate pump maintenance on February 4

(3) Elevated risk during energized work inside the main control board for socket replacement on the D reactor coolant pump standpipe indicator light on February 18

(4) Elevated risk during supplemental emergency power system outage on February 22

(5) Elevated risk during emergency feedwater pump surveillance testing on March 23

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) Service water pinhole leak (AR 02379730) on January 4

(2) Service water cooling tower fan 51B oil leak (AR 02380345) on January 12

(3) Alkali-silica reaction structural deformation stage 3 exceedances (AR 02276197) on February 8

(4) B emergency diesel generator temperature control valve linkage binding (ARs

===2385596, 2385893) on March 4

(5) Degraded fire penetration seals in primary auxiliary building (ARs 2383434, 2383435, 2383436, 2383437, 2383438, 2383439, 2383440) on March 10

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) ===

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) B steam generator atmospheric dump valve nitrogen regulator repair on January 6

(2) B residual heat removal flow control valve FCV-610 maintenance on January 6

(3) B supplemental emergency power system coolant pressure switch replacement on February 22

(4) B emergency diesel generator jacket water temperature control valve DG-TCV-7B-1 repairs due to binding linkage arm on March 5

(5) B primary component cooling water agastat relay calibration on March 9

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Bus 6 4.16kV loss of voltage protection quarterly surveillance testing on January 25

(2) B emergency diesel generator operability run on March 1

(3) Slave relay testing for turbine-driven emergency feedwater actuation on March 23

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

(1) B residual heat removal pump quarterly in-service test surveillance on March

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 through reviews of site Part 61 analysis and radiation protection analysis of source term

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

The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas and reviewed the following:

(1) Radiation Work Permits

• 20-0001, 20-0105, 20-0131, 20-0106, 21-0013 Electronic Alarming Dosimeter Alarms

• Dose rate alarm due to electronic interference July 15, 2020

• Dose rate alarm at 70.5 mrem per hour due to worker getting too close to source on August 5, 2020

• Dose rate alarm due to dosimeter going through package x-ray machine at security September 20, 2020

Radiological Hazards Control and Work Coverage (IP Section 03.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities:

(1) Radiological work permit 21-0013 for areas with airborne radioactivity High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (1 Sample)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) Spent fuel pool storage of highly radioactive material

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 reviewed licensee's external dosimetry program including National Voluntary Laboratory Accreditation Program (NVLAP) certification documentation of the dosimetry processor. Dosimeters are processed by a NVLAP accredited processor and each type of personnel dosimeter used was consistent with the types and energies of the radiation present

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the internal dosimetry program implementation and reviewed the following:

(1) Whole Body Counts

• Declared pregnant worker body count results dated October 19, 2020

• The licensee uses the GEM 56 personal contamination monitor to screen personnel in leu of whole body counts. The screening process is implemented to ensure the licensees respiratory protection and engineering controls are effective in reducing internal contamination via inhalation or ingestion In-Vitro Internal Monitoring

• None were available during this inspection

(2) Dose Assessments Performed Using Air Sampling and Derived Air Concentration-Hour Monitoring

• Air sample during spent fuel filter change on March 16 revealed 1.08 DAC-hr particulate however, due to short duration and minor exposure, no dose was assigned

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

The inspectors evaluated the following special dosimetric situation:

(1) Licensees implementation of requirements to manage radiation protection of declared pregnant workers for one worker

(2) The application of NRC-approved external dosimetry methods (i.e. effective dose equivalent external), shallow dose equivalent and neutron dose assessments

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

Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors ensured that radioactive materials were controlled, labeled and secured against unauthorized removal.

(1) Inspectors observed temporary radioactive material storage areas in sea-land containers stored outside the main radiologically controlled area

(2) Inspectors evaluated the licensees control and leak test evaluations of the sealed sources in the licensees possession that present the greatest radiological risk

Radioactive Waste System Walkdown (IP Section 03.02 (2 Samples)

The inspectors conducted a virtual walkdown of accessible portions of the solid radioactive waste system to ensure that the selected system was correctly configured and able to perform its intended function.

(1) Inspectors remotely observed the accessible portions of the solid radioactive waste process

(2) Inspectors remotely observed accessible portions of the liquid radioactive waste system for processing of radiologically controlled area drains and evaluated system configuration and functionality

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors verified the licensee characterizes and classifies radioactive waste.

(1) The inspectors evaluated the licensees characterization and classification of radioactive waste associated with waste manifest number 20-046

(2) The inspectors evaluated the licensees characterization and classification of radioactive waste associated with waste manifest number 20-047

Shipping Records (IP Section 03.05) (2 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review.

(1) Class B waste radioactive material shipment; Type A container (8-120 cask), unique shipment identifier number 20-046 containing primary resin

(2) Class B waste radioactive material shipment; Type A container (8-120 cask), unique shipment identifier number 20-047 containing primary resin

OTHER ACTIVITIES - BASELINE

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

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) ===

(1) For the period January 1, 2020 through December 31, 2020 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02)

(1 Sample)

(1) For the period January 1, 2020 through December 31, 2020

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (1 Sample)

(1) For the period January 1, 2020 through December 31, 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

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

(1) Evaluation of 'B' main steam to the 'A' emergency feedwater pump isolation valve (MS-V-394) performance issues associated with the nitrogen supply and nitrogen regulating system

(2) Cooling tower service water piping internal corrosion and coating degradation

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000443/2020-002-00, Remote Shutdown System Indicator Exceeded Allowable Value for Time Longer than Permitted by the Technical Specifications (ADAMS accession: ML20240A330). The inspection conclusions associated with this LER are documented in this report under inspection results.

INSPECTION RESULTS

Failure to Evaluate Functionality for Degraded Fire Barrier Seals Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.15 Systems NCV 05000443/2021001-01 Complacency Open/Closed The inspectors identified a Green finding and associated non-cited violation of Seabrook Station Facility Operating License Condition 2.F when the station did not appropriately assess functionality of degraded fire rated seals. As a result, degradation, which required repair, resulted in the limiting condition of operation defined in Technical Requirement 11 to not be met and the required actions of Technical Requirement 11 not being implemented for a period of 30 days.

Description:

On February 3, 2021, during building deformation equipment impact walkdowns in support of the Structures Monitoring Program, Seabrook Station personnel identified seven fire seals that showed signs of delamination around pipes that penetrated the wall between the primary auxiliary building and the waste processing building. On February 9, 2021 seven condition reports (CR) were initiated for the seals. These CRs identified the seals as fire rated Bisco seals and photographs were attached to the each CR.

All seven CRs were evaluated by the operating shift as not constituting a new or degraded condition that involves the ability of a non-TS structure, system, or component to perform its specified current license basis (CLB) function and therefore a functionality assessment was not required. On February 10, 2021, the seven CRs were reviewed at the Management Review Committee and each assigned a 30 day action to evaluate and reconcile as necessary. On March 9, 2021 engineering completed the evaluation action assigned by the Management Review Committee and determined the fire seals were failed per the surveillance requirements for the Technical Requirement Fire Rated Assembly Penetration Seals inspection procedure (MX0599.02) and also determined that all seven seals are required seals in accordance with the Seabrook fire protection program.

The station initiated a CR on March 13, 2021 that identified the timeline gap that existed from the identification of the degraded seals on February 3 until the engineering review was completed on March 9 which resulted in a continuous fire watch not being implemented as required. This CR was screened as a severity level 3 and assigned a corrective action to provide a refresher brief to shift managers on the screening requirements for fire seals.

The inspectors questioned aspects of Seabrooks classification, evaluation, and corrective actions associated with this issue. The CR, AR2386797, written on March 13 did not identify that on February 3 a CR was not generated when the fire seals were discovered delaminated as required by Seabrook's procedure PI-AA-104-1000, Condition Reporting, Section 4. While the CR on March 13 did identify that a functionality screening was not performed as required, the actions taken were limited to implementing the required fire watch and briefing shift managers on the requirement for performing functionality screening for required fire seals. The inspectors noted that while Seabrook's procedure EN-AA-203-1001, Operability Determinations/Functionality Assessments, Section 4.1.2 requires the shift manager perform functionality screening on degraded components that are described in the current licensing basis, no actions were taken to understand or address the cause associated with not performing the functionality assessment on February 9. Additionally, no actions were taken to understand or address the cause associated with not initiating an Action Request when the degraded condition of the fire seals were first identified on February 3. The inspectors also questioned the significance level (SL) assigned to CR AR2386797 based on the definitions contained in PI-AA-104-1000. SL3 is defined as events that involve less significant functions and components that have low or no impact on core damage frequency while SL2 are events with moderate consequences or that have a probability of serious consequences and may require issue investigation. Attachment 4 of PI-AA-104-1000 provides examples of different SLs. Inspectors determined that CR AR2386797 met SL2 criteria by two separate 4 examples, example 8 for programmatic breakdown indicated by a significant gap in program design or implementation of a regulatory required program, and example 22 for Appendix R fire protection license basis violation.

The underlying performance deficiency of not performing the functionality assessments, while identified by the licensee, became NRC-identified once the licensee failed to properly classify, evaluate, and correct the procedural non-compliances with PI-AA-104-1000 and EN-AA-203-1001 procedures. Based on inspector questions, CR AR2387547 was initiated for the proficiency gaps and screened to a SL2 with an organizational effectiveness investigation to ensure the most probable/likely cause is appropriately determined and effective corrective actions developed.

Corrective Actions: Corrective actions included declaring the fire seals not functional and entering the appropriate actions in the Technical Requirements Manual and implementing the required fire watches until the fire seals were replaced. Extent of condition actions included reviewing all other CRs that were initiated as a result of the Structures Monitoring Program walkdowns to validate no other degraded conditions for structure, system, or components described in the Seabrook's CLB were present from those inspections without an appropriate operability or functionality assessment.

Corrective Action References: 2387547, 2386797, 238659, 238660, 238662, 238663, 238664, 238665, 238666

Performance Assessment:

Performance Deficiency: The inspectors determined that Seabrook's failure to perform a functionality screening on CRs for a structure, system, or component described in the CLB that is affected by degradation was a performance deficiency that was reasonably within Seabrook's ability to foresee and prevent and should have been corrected. Specifically, Seabrook did not perform a functionality screening as required by EN-AA-104-1001 on seven CRs that described delamination of seven fire seals described in the Technical Requirements Manual which is in Seabrook's CLB. As the result of this performance deficiency, the required actions of the Technical Requirements Manual were not implemented, which included a continuous fire watch, for 30 days after the condition was first entered into the corrective action program.

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 seven fire seals would have impacted the ability of the seals to perform their function which affected the fire barrier's functionality. (IMC0612 Appendix E example 2.d)

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. This issue screened to very low safety significance (Green) in Phase 1, Task 1.4.4. Fire Confinement, Question A was answered no because inspectors determined that the degraded fire confinement element would continue to provide adequate fire endurance to prevent fire propagation through the fire confinement element given the combustible loading and location of equipment important to safe shutdown in the fire area. Specifically, NextEra performed an evaluation that adequately demonstrated that the location of a fire based on normal combustible calculations would be over 60 feet away from the barrier of concern, hot gasses from a fire in this zone would have to fill a large volume before getting low enough to reach the compromised seals, and if the hot gas layer did the reach the degraded seals, they would still offer a good measure of protection based on the tortuous pathway through them.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, there were multiple opportunities within the organization that could have identified the missed functionality assessments for the fire seals. Engineering, operations, and management oversight all missed the opportunity to question the impact and acceptability of the degradation of the fire seals between non-safety-related and safety-related equipment.

Enforcement:

Violation: Seabrook Station, Unit 1 Facility Operating License Condition 2.F requires, in part, for NextEra to implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report, the Fire Protection Program Report, and the Fire Protection and Safe Shutdown Capability report, as supplemented. Supplement 7 of the Safety Evaluation Report approved NextEra's request to establish fire protection program limiting conditions for operation and action statements that provide a level of protection equivalent to that provided by the fire protection sections of the Westinghouse Standard Technical Specifications. This commitment was incorporated into Section 9.5-1 of the 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. 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 February 3, 2021, Seabrook Station personnel identified seven fire rated sealing devices that were determined not to be functional and the required actions of Technical Requirement 11 were not performed for a period of 30 days.

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

Human Performance Event Leads to B Service Water Cooling Tower Fan Inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems NCV 05000443/2021001-02 Challenge the Open/Closed Unknown The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification 6.7.1.a Procedures, because NextEra personnel failed to follow the requirements of work order 40757992. Specifically, on January 7, 2021, Seabrook maintenance personnel did not follow relevant work instructions which resulted in excessive particulate in the gearbox oil of the B service water cooling tower fan. This particulate plugged the internal lubrication spray nozzle and relief valve, resulting in over-pressurization of the gearbox and the failure of the gearbox oil pressure switch seal and resultant lube oil leak. This directly resulted in the inoperability and unavailability of the B service water cooling tower fan for approximately 80 additional hours.

Description:

Seabrook Station utilizes a mechanical draft evaporative cooling tower system to dissipate shutdown and accident heat loads in the event that the normally utilized ultimate heat sink (seawater) intake and discharge tunnels suffer from seismically induced damage.

As part of this cooling tower system, three large cooling tower fans draw ambient air through service water inventory being sprayed through spray nozzles to remove the latent heat of the cooling water transferred from plant systems.

On January 7, 2021, following a scheduled gearbox oil change of one of the three fans, B service water cooling tower fan SW-FN-51B, a leak developed on the housing of the gearbox oil pressure switch resulting in the service water cooling tower being declared inoperable for a period of approximately 80 additional hours while repair activities were conducted. A causal evaluation conducted by Seabrook Station determined that excessive particulate in the gearbox plugged the internal lubrication spray nozzle and relief valve, resulting in over-pressurization of the gearbox and the failure of the gearbox oil pressure switch seal and resultant leak. The causal evaluation also determined that the maintenance conducted on the B service water cooling tower fan gearbox was not in alignment with station standards and expectations due to deviations from the prescribed work order work steps. Specifically, maintenance personnel re-filled and added oil through the drain line instead of directly through the gearbox oil fill line, did not perform a full gearbox oil flush, and failed to adequately question an unexpected condition of heavy debris build-up on the lube oil heater inside of the gearbox. Seabrook Stations causal evaluation determined that it is likely that the debris on the heater was dislodged during the non-standard method of adding oil through the drain line and exacerbated by not performing a full system flush after the oil was initially added. The dislodged debris clogged the lube oil spray nozzle and relief valve and ultimately lead to over-pressurization of the system and the failure of the pressure switch seal.

Corrective Actions: After the leak was identified and the system repaired and restored to operability, NextEra personnel performed a causal analysis of the event and initiated multiple corrective actions including training for maintenance department personnel, revision to work order instructions, forensic analysis on the gearbox oil, and evaluation of gearbox oil change frequency.

Corrective Action References: 02380345

Performance Assessment:

Performance Deficiency: The inspectors determined that Seabrook maintenance personnels failure to appropriately follow work order 40757992 was a performance deficiency within Seabrooks ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance 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 human performance event associated with the B service water cooling tower fan led to the inoperability of the service water cooling tower basin for approximately 80 additional hours.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Inspectors determined the finding to be of very low safety significance (Green) since the inoperability of the service water cooling tower basin due to the failure of the B service water cooling tower fan did not result in the service water cooling tower basin losing its PRA functionality.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, Seabrook maintenance personnel re-filled and added oil through the drain line instead of directly through the gearbox oil fill line, did not perform a full gearbox oil flush, and failed to adequately question an unexpected condition of heavy debris build-up on the lube oil heater inside of the gearbox.

Enforcement:

Violation: Seabrook Technical Specification 6.7 Procedures and Programs, Section 6.7.1.a requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, Section 9.a. requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on January 7, 2021, Seabrook maintenance personnel failed to appropriately follow the requirements of work order 40757992. Specifically, Seabrook maintenance personnel re-filled and added oil through the drain line instead of directly through the gearbox oil fill line, did not perform a full gearbox oil flush, and failed to adequately question an unexpected condition of heavy debris build-up on the lube oil heater inside of the gearbox. Because this violation is of very low safety significance (Green) and NextEra entered the issue into their corrective action program, this violation is being treated as a non-cited violation consistent with the NRC Enforcement Policy.

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

Observation: Annual Follow-up: Evaluation of MS-V-394 Performance Issues 71152 The inspectors performed a review of the nitrogen manifold and nitrogen supply system associated with MS-V-394, the B main steam to the A emergency feedwater pump isolation valve. Performance issues with the nitrogen regulating manifold have resulted in degradation in the ability of the valve to close in support of its containment isolation safety function. The inspectors verified that the valve closure time, while degraded, stayed within required limits.

Additionally, the inspectors reviewed NextEras efforts in troubleshooting the degraded performance to prevent it from re-occurring.

The inspectors determined that NextEras actions to identify and address the degraded performance of the nitrogen manifold associated with MS-V-394 have been appropriate for the circumstances and reasonable.

Observation: Annual Follow-up: Cooling Tower Service Water Piping Internal 71152 Corrosion and Coating Degradation The inspectors reviewed corrective action and work management documents that described the identification and evaluation of corrosion nodules located on the inside of the elbow in piping downstream of the A cooling tower service water pump, P-110A. These nodules were detailed in action report (AR) 02311189, initiated in April 2019, and ultrasonically examined under work order 40578064. These nodules were re-inspected, re-assessed and trended under work order 40673648, and resulted in the generation of AR 2341837, in January 2020, due to the identification of an adverse trend in one location (out of nine), identified as Location No. 6, with a piping wall loss of 0.075 inches over a 9-month period. The inspectors assessed the licensees subsequent actions to identity, evaluate and correct this problem of pipe wall thinning in the A cooling tower service water discharge piping at these discrete nodule locations in accordance with applicable regulatory and corrective action program requirements. The inspectors reviewed:

(1) Licensee operability evaluation, which evaluated flooding and design basis flow considerations, consistent with EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 34;

(2) Non-destructive examinations, including those performed under ASME Code Case N513-3, and associated structural evaluations and code-required minimum wall thickness determinations, conducted to work order requirements and ES1807.049, Ultrasonic Phased Array, Revision 1; reviewed ultrasonic measurements from the nine, affected locations, and trend data for the examinations conducted in April 2019, January/March/June/July/October 2020, and January 2021;

(3) The preventive maintenance activity frequency (ultrasonic evaluations) was changed to three months based on increased corrosion rates, in one of nine locations (Location #6); the activity required performance of ultrasonic testing examinations every three months, to meet the requirements of Preventive Maintenance Item No. 76286;

(4) Work order 40707046, which detailed the planned, internal Belzona coating repair, to be conducted during the upcoming Fall 2021 refueling outage, with subsequent piping replacement scheduled to be performed during OR25, currently scheduled for Fall 2027; and

(5) Updated service water system inspection, maintenance, repair and replacement updates and summaries, detailed in Plant Engineering Guidelines PEG-94, Service Water Inspection and Repair Trending, Revision 13.

The inspectors determined that the overall response to the internal corrosion and coating degradation associated with the A cooling tower service water discharge piping was generally consistent with the licensees strategy for service water system management as outlined in PEG-94.

The inspectors further determined that the issue of flow turbulence and its apparent impact on internal coatings, particularly Belzona, and especially in areas of piping that had experienced previous internal coating and/or base metal repairs, were identified in multiple, internal documents. In particular, as far back as 2011, the NRC had evaluated the issue of internal coating degradation and subsequent corrosion of internal base metal, as detailed in AR 01637922, NRC Inspection Report 2011-005, and licensee actions following the loss of coating in-service water piping that impacted the emergency diesel generator jacket water heat exchanger, as documented in AR 01694951. The inspectors noted that although Belzona (1321 S-Metal) had been identified by the licensee to have a service life of approximately 15 years, they have correctly concluded that coating life is variable, and therefore have applicable inspection and strategic guidance regarding coating inspection and assessment contained in PEG-94. The inspectors noted that one corrective action from AR 01694951 has been identified and included in PEG-94 as an important and required attribute for inspecting, assessing, trending and decision-making for internal, non-cement linings, such as Belzona. However, the licensee has characterized Belzona as a coating that is susceptible to rapid degradation in areas of high turbulence, resulting in known piping degradation that required several repair and replacements of affected service water system piping and components. As a result of this inspection, the licensee generated AR 02388340.

This request will evaluate if recurrent liner degradation and through-wall leaks have been reviewed in the aggregate. More importantly, the licensee will assess if Belzona remains appropriate as an internal coating to prevent corrosion of carbon steel piping, especially in piping locations that experience high turbulent flows.

The inspectors also identified a potential inconsistency between licensee design and procedure documents. Specifically, the inspectors reviewed engineering change (EC)274750, which authorized the use of Belzona coatings on-site, and EC 288598, which referenced this original acceptance EC during replacement of the Belzona-lined piping section currently experiencing wall loss, downstream of A cooling tower service water pump P-110A, which occurred in 2017. The inspectors noted that the original EC (274750)contained information for repairs of Belzona-to-Belzona coatings, and this repair required a minimum overlap of three

(3) inches, assuming a particular surface finish was attained to ensure proper adhesion. However, in practice, MS0517.012, Application and Repair of Protective Coating(s), Revision 22, especially for holiday (a void or discontinuity) repairs of coatings, as outlined in Form D, required a minimum overlap of one-quarter (1/4) inches. The licensee generated a condition report to address this observation within their corrective action program under AR 02382406. Additionally, AR 02388338 was generated, to further evaluate the apparent inconsistency in overlap requirements between the implementing procedure (MS0517.012) and the authorizing design change EC 274750, regarding Belzona coatings.

Overall, the inspectors observed that Seabrook has in place a long-term corrective action plan associated with the service water system. The inspectors noted that Seabrook is committed to the systematic replacement of original, concrete-lined carbon steel piping, and other piping sections internally coated with materials such as Belzona, with AL6XN, a super alloy with improved resistance from corrosion and turbulence-induced degradation.

Additionally, the inspectors determined that, based on a review of corrective action documents, Seabrooks management of piping corrosion and coating degradation and failures have been generally identified, assessed and resolved within the corrective action program.

Remote Shutdown System Indicator Exceeded Allowable Value for Time Longer than Permitted by the Technical Specifications.

Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71153 Applicable NCV 05000443/2021001-03 Applicable Open/Closed A self-revealed Severity Level IV non-cited violation of Technical Specification 3.3.3.5, Remote Shutdown System Monitoring Instrumentation was identified when the reactor coolant system loop 1 wide range cold leg temperature indicator at the remote shutdown panel failed high and went unnoticed for two weeks.

Description:

As reported in LER 2020-02 (ML20240A330), during a monthly remote shutdown system channel check surveillance on July 4, 2020, the loop 1 wide range cold leg temperature indicator was discovered to have failed high. There are two wide range cold leg temperature indications on the remote shutdown panel, one from loop 1 and one from loop

4. Loop 4 wide range cold leg temperature at the remote shutdown panel and control room

cold leg temperature indicators all remained operable. Review of the electronic chart recorder for the loop 1 cold leg temperature indicator at the remote shutdown panel showed that the instrument failure occurred on June 19, 2020.

Technical Specification surveillance requirement 4.3.3.5.1.a requires channel checks to be performed between the remote shutdown panel and the control room on a 30 day frequency with an acceptance criteria that they agree within 35 degrees Fahrenheit. Technical Specification 3.3.3.5 requires both channels to be the minimum operable. With a single channel not operable, the licensee is allowed seven days to restore the channel to operable or shutdown the unit to hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The inspectors reviewed the remote shutdown panel indicator failure history and did not identify failure trends that would be indicative of a performance-based trend that would have been reasonably within the licensee's ability to foresee and correct.

The inspectors reviewed the surveillance frequency required for remote shutdown panel instruments since the surveillance frequency is greater than the allowed outage time of the associated instrument. Inspectors noted that the surveillance frequency was in line with their approved operating license.

The inspectors reviewed Seabrooks conduct of operations procedure and determined that the identification of the failed instrument was not reasonable for the licensee to identify prior to the conduct of the required surveillance check on July 4, 2020.

Corrective Actions: The immediate corrective actions included troubleshooting and repair of the instrument and returning the loop 1 wide range temperature indicator to service.

Additionally, the licensee implemented corrective actions to change the surveillance frequency to 7 days to align with the allowed outage time for instrumentation.

Corrective Action References: 02361725

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.

Specifically, inspectors determined that the cause of the condition described in LER 2020-002 was not the result of not meeting a specific standard or requirement nor was there a trend of failures that was identified that would have been indicative of a performance-based trend. Moreover, the inspectors noted that the licensee had voluntarily implemented an increased surveillance frequency so that future failures would be identified prior to exceeding the technical specification allowed outage time.

Enforcement:

The ROPs significance determination process does not specifically consider a violation without a finding in its assessment of licensee performance. Therefore, it is necessary to address this violation using traditional enforcement.

Severity: The inspectors determined that the violation was a condition prohibited by technical specifications of very low safety significance (SLIV) since it resulted inappreciable potential safety consequences, and meets the criteria described in Enforcement Policy Section 2.3.2 for disposition as a non-cited violation.

Violation: Technical Specification 3.3.3.5, Remote Shutdown System Monitoring Instrumentation, requires that a minimum of two wide range cold leg temperature channels shown in Table 3.3-9, item 3.a be operable while in Mode 1, 2, and 3 or restore the inoperable channel to operable status within 7 days, or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above, the loop 1 wide range cold leg temperature channel at the remote shutdown panel was not operable from June 19, 2020 to July 4, 2020 without taking the applicable actions to return the channel to operable status or shutdown to hot standby.

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

EXIT MEETINGS AND DEBRIEFS

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

• On February 11, 2021, the inspectors presented the Radiation Protection Rad Waste and Transportation remote inspection results to Mr. Eric McCartney, Site Vice President and other members of the licensee staff.

• On March 18, 2021, the inspectors presented the Radiation Protection Rad Hazard Assessment and Control and Occupational Dose Assessment inspection results to Mr. Brian Booth, Site Vice President and other members of the licensee staff.

• On April 13, 2021, the inspectors presented the integrated inspection results to Mr. Brian Booth, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Corrective Action AR2386797, AR2387547, AR2383434, AR2383435,

Documents AR2383436, AR2383437, AR2383438, AR2383439,

AR2383440

Procedures EN-AA-203-1001 Operability Determinations / Functionality Assessments Revision 34

PI-AA-100-1007 Issue Investigation Revision 23

PI-AA-104-1000 Condition Reporting Revision 26

Work Orders 40709282

20