UNITED STATES

NUCLEAR REGU LATORY COMMISSION

REGION I

4T5ALLENDALE ROAD

KING OF PRUSSIA, PENNSYLVANIA 19406-1415

May 12, LOIL

Mr. Paul Freeman

Site Vice President

Seabrook Nuclear Power Plant

NextEra Energy Seabrook, LLC

c/o Mr. Michael O'Keefe

P.O. Box 300

Seabrook, NH 03874

SUBJECT: SEABROOK STATION, UNIT NO. 1 . NRC INTEGRATED INSPECTION

REPORT 05000443/201 1002

Dear Mr. Freeman:

On March 31, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection

at Seabrook Station, Unit No. 1. The enclosed report documents the inspection findings

discussed on April 7,2011, with you and other members of your staff.

These inspections examined activities conducted under your license as they relate to safety and

compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

The report documents two NRC-identified violations that were determined to be of very low

safety significance. However, because of the very low safety significance and because the

issues were entered into your corrective action program, the NRC is treating the findings as

non-cited violations (NCV) consistent with Section Vl.A.1 of the NRC Enforcement Policy.

lf you contest any NCV in this report, you should provide a response within 30 days of the date

of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional

Administrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001; and the NRC Resident lnspector at the Seabrook

Station. In addition, if you disagree with the characterization of any finding 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 RegionalAdministrator, Region l, and the NRC Resident Inspector at

the Seabrook Station. The information you provide will be considered in accordance with

lnspection Manual Chapter 0305.
P. Freeman

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure, and your response (if any), will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

Docket No.

License No:

Enclosure:

cc w/encl:

50-443

NPF-86

lnspection Report No. 050004431201 1002

w/ Attachment: Supplemental lnformation

Distribution via ListServ

ArthuiL. Burritt, Chief

Division of Reactor Projects
P. Freeman 2

ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure, and your response (if any), will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.oov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Arthur L. Burritt, Chief

Projects Branch 3

Division of Reactor Projects

Docket No. 50-443

License No: NPF-86

Enclosure: InspectionReportNo.0500044312011002

w/ Attachment: Supplemental lnformation

Distribution w/encl: (via e-mail)

W. Dean. RA

D. Lew. DRA

D. Roberts, DRP

J. Clifford, DRP

C. Miller, DRS

P. Wilson, DRS

A. Burritt, DRP

L. Cline, DRP

A. Turilin, DRP

C. Douglas, DRP

W. Raymond, DRP, SRI

J. Johnson, DRP, Rl

A. Cass, DRP, OA

S. Bush-Goddard, Rl OEDO

M. Ashley, NRR

M. Clark, OGC

J. Bowen, NRR

A. DeFrancisco. ORA

R. Conte, DRS

RidsNrrPMSeabrook Resource

RidsNrrDorl Lpl 1 -2Resource

ROPreportsResource

SUNSI Review Gomplete: ALB (Reviewer's Initials)

DOCUMENT NAME: G:\DRP\BRANCH3\l NSPECTION\REPORTS\ISSUED\SEA 1 1 02. DOCX

After declaring this document "An Official Agency Record" it will be released to the Public.

To rcceive a copy ol this document, indicate in the box: 'C' = Copy without attachmenVenclosure 'E' = Copy with attachmenVenclosure "N' = No copy

ML1 1 1330689

WRaymondialb for

05t12t11 05t12t11 05112111
Docket No.:

License No.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

1

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

50-443

NPF-86

05000443/2011002

NextEra Energy Seabrook, LLC

Seabrook Station, Unit No.1

Seabrook, New Hampshire 03874

January 1, 2011, through March 31, 2011

W. Raymond, Senior Resident Inspector

J. Johnson, Resident Inspector

A. Turilin, Project Engineer

T. Moslak, Health Physicist

L. Scholl, Senior Reactor Inspector

J. DeBoer, Reactor Engineer

Arthur L. Burritt, Chief

Projects Branch 3

Division of Reactor Projects

Enclosure
2

TABLE OF CONTENTS

SUMMARY OF F|ND|NGS............ .........3

REPORT DETATLS.. .............5

1. REACTOR SAFETY... ....................5

1R01 Adverse Weather Preparation ............5

1R04 Equipment Alignment ........5

1R05 Fire Protection .......... ........6

1R06 Flood Protection Measures ................7

1R1 1 Licensed Operator Requalification Program ............ ............8

1R12 Maintenance Effectiveness ........ ........8

1R13 Maintenance Risk Assessments and Emergent Work Control ............13

1R15 Operability Evaluations ....................14

1R18 Plant Modifications ..........14

1R19 Post-Maintenance Testing ...............15

1R22 Surveillance Testing .......15

2. RADTATION SAFETY ...................16

2RS02 Occupational ALARA Planning and Controls .............. ........16

2RS03 In-Plant Airborne Radioactivity Control and Mitigation ........... ............17

4. OTHER ACT|V|T|ES.............. ...... 19

4OA1 Performance Indicator Verification ....................19

4OA2 ldentification and Resolution of Problems .............. ............19

4OA3 Event Followup ...............20

40A6 Meetings, Including Exit........... .........21

ATTACHMENTS: SUPPLEMENTAL lNFORMAT|ON........... ............. A-21

KEY POINTS OF CONTACT ............. A-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED .... A-1

LIST OF DOCUMENTS REVIEWED ............ ..,.,. A-2

LtsT oF ACRONYMS............... ......... A-7

Enclosure
3

SUMMARY OF FINDINGS

f R 0500044312011002:0110112011-0313112011; Seabrook Station, Unit No. 1; Maintenance

Effectiveness.

The report covered a three-month period of inspection by resident and regional specialist

inspectors. Two Green findings were identified. The significance of most findings is indicated

by their color (Green, White, Yellow, or Red) and determined using lnspection Manual Chapter

(lMC) 0609, "Significance Determination Process" (SDP). The cross cutting aspect of a finding

is determined using the guidance in IMC 0310, "Components Within the Cross-Cutting Areas."

Findings for which the SDP does not apply may be Green or be assigned a severity level after

NRC management review. The NRC's program for overseeing the safe operation of

commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"

Revision 4, dated December 2006.

Gornerstone: Mitigating Systems

. Green. lnspectors identified a non-cited violation of 10 CFR 50.65(aX1 ) because

NextEra did not adequately monitor the condition of an in-scope structure under the

Maintenance Rule (MR). Specifically, NextEra did not evaluate the results of their

periodic inspections of the condition of the Control Building (CB) to determine the extent

and rate of degradation to the structure. Further, in August 2010 after NextEra identified

CB concrete strength degradation that called into question the effectiveness of that

structures preventative maintenance program, NextEra did not classify the CB as MR

(aX1). NextEra entered the degraded structural concrete issue into its corrective action

program to address the extent of condition and establish a mitigation strategy (ARs

57412Q and 581434)Ior all in-scope structures. NextEra also initiated AR 1636419 to

complete the evaluation for placing the CB into (a)(1) status.

o This performance deficiency is more than minor because if left uncorrected, the

condition could have resulted in the loss of function for the CB structure due to

degrading concrete material properties of structures and systems designed to mitigate

design basis events. The finding had very low safety significance because despite

degraded concrete conditions and loss of design margin, the CB structure remained

operable. The inspectors performed a Phase 1 Significance Determination Process

(SDP) screening, in accordance with NRC Inspection Manual Chapter (lMC) 0609,

Attachment 4, and determined the issue was of very low safety significance (Green)

because the finding was not a design or qualification deficiency, did not result in an

actual loss of safety function, was not a loss of barrier function, and was not potentially

risk significant for external events. This finding had a cross-cutting aspect in the area of

problem identification and resolution, evaluation (P.1(c)) because NextEra did not

ensure issues adverse to quality potentially impacting nuclear safety were promptly

identified and evaluated. Specifically, NextEra did not thoroughly evaluate indications of

concrete degradation for the CB to determine the extent and rate of degradation to the

structure, and once concrete degradation due to alkali-silica-reaction (ASR) distress was

identified, NextEra did not evaluate the issue within the context of the MR program to

assure the condition of structures was controlled to maintain design margins. (Section

1R12)

Enclosure
4

Green. Inspectors identified a non-cited violation of 10 CFR 50.65(bX2) because

NextEra did not include certain Seabrook buildings as in-scope structures under the MR

program. Specifically, NextEra did not classify the intake transition structure (lTS) and

the discharge transition structure (DTS) as in-scope structures in the MR database, and

as a result did not include them in the periodic inspections completed under the

structures monitoring program per PEG04 from 1995 to 2009. NextEra initiated a MR

scoping screening worksheet per procedure NAP 415 and upon consideration of the

design basis information concluded both transition structures should be in-scope per 10

CFR 50.65(aX1). The NAP 415 scoping results were accepted by the MR Expert Panel

on March 15,2011. NextEra initiated CR 1629504 to enter the issue into the Corrective

Action Program (CAP) and determine the extent of condition.

The performance deficiency is more than minor because if left uncorrected, given the

indications of ASR identified in these concrete structures, not monitoring the ITS and

DTS structures for degradation could result in the loss of function of structures

supporting systems used to mitigate design basis events, used in the emergency

operating procedures, or whose loss could result in a reactor trip. The inspectors

performed a Phase 1 Significance Determination Process (SDP) screening, in

accordance with NRC Inspection Manual Chapter (lMC) 0609, Attachment 4, and

determined the issue was of very low safety significance (Green) because the finding

was not a design or qualification deficiency, did not result in an actual loss of safety

function, was not a loss of barrier function, and was not potentially risk significant for

external events. This finding did not have a cross cutting aspect because the most

significant contributor to the performance deficiency was not reflective of current

licensee performance. (Section 1R12)

Enclosure
5

REPORT DETAILS

Summarv of Plant Status

Seabrook operated at full power for the entire period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Preparation (71111.01 - 1 sample)

a. lnspection Scope

The inspectors completed one impending weather condition inspection sample. The

inspectors reviewed NextEra's readiness for the onset of severe winter weather

conditions that impacted the site from January 10 to 1 3, 2011. The review included

consideration of the A emergency diesel generator (EDG) outage in conjunction with a

snow storm on January 12,2011. The inspectors reviewed the Seabrook updated final

safety analysis report (UFSAR) regarding design features, and verified the adequacy of

procedures for adverse weather protection. The inspectors reviewed NextEra's actions

per procedure OS1200.03 for severe weather. The inspectors also conducted walk

downs of normal and backup electrical systems and the emergency feedwater and

service water systems. The inspector reviewed NextEra's evaluation and contingency

actions for potential orange risk conditions for the A EDG outage in conjunction with the

winter storm. The inspectors reviewed previously identified deficiencies related to

extreme weather preparation and verified that issues were appropriately dispositioned

through the corrective action program. Documents reviewed for this inspection are listed

in the Attachment.

b. Findinqs

No findings were identified.

1R04 Equipment Alionment (71111.04 - 4 samples; 71111.045 - 1 sample)

PartialWalkdown

Inspection Scope

The inspectors completed four partial system walkdown inspection samples for the plant

systems listed below. The inspectors verified that valves, switches, and breakers were

correctly aligned in accordance with NextEra's procedures and that conditions that could

affect system operability were appropriately addressed. The inspectors reviewed

applicable piping and instrumentation drawings and system operational lineup

procedures. The documents reviewed are listed in the Attachment.

r The B EDG and associated support systems during a planned A EDG overhaul

conducted between January 10,2011 and January 14,2Q11.

.1

Enclosure
6

. The A and B emergency feedwater system following maintenance and testing on

February 23, 2011.

r A EDG and support systems during a planned outage of the B EDG on January 27

through February 3, 2011.

r A emergency core cooling system components while residual heat removal pump

RH-P-88 was inoperable due to maintenance on RH-FCV-61 1 on March 1, 2Q11.

b. Findinqs

No findings were identified.

.2 Complete Svstem Walkdown

a. Inspection Scope

The inspectors performed one complete system walkdown inspection sample for the

primary component cooling water (PCCW) system. The inspection verified the system

was properly aligned and capable of performing its safety function. To ascertain the

required system configuration, the inspectors reviewed plant procedures, system

drawings, the UFSAR, and the technical specifications (TS). The inspectors walked

down the accessible portions of the system to verify overall material condition; that

valves were correctly positioned; electrical power was available; major system

components were properly labeled; essential support systems were operational; and that

ancillary equipment or debris did not interfere with system performance. The inspectors

reviewed applicable piping and instrumentation drawings and system operational lineup

procedures. The documents reviewed are listed in the Attachment.

b. Findinqs

No findings were identified.

1R05 Fire Protection (71111.05Q - 5 samples,7111 1.05A - 1 sample)

.1 Quarterlv Review of Fire Areas

a. Inspection Scope

The inspectors completed five quarterly fire protection inspection samples. The

inspectors examined the areas of the plant listed below to assess: the control of

transient combustibles and ignition sources; the operational status and material

condition of the fire detection, fire suppression, and manual firefighting equipment; the

material condition of the passive fire protection features; and the compensatory

measures for out-of-service or degraded fire protection equipment. The inspectors also

verified that the fire areas were maintained in accordance with applicable portions of Fire

Protection Pre-Fire Strategies and Fire Hazard Analysis. The documents reviewed are

listed in the Attachment.

Diesel Generator (DG) Rooms DG-F-1A-A, DG-F-2A-A, DG-F-3C-A, DG-F-18-A,

DG-F-2B-A, DG-F-3D-A.

A Electrical tunnel (0 ft), ET-F-1A-A.

Enclosure
7

. Fuel Storage Building (64 ft), FSB-F-1-A.

o Primary Auxiliary Building (25 ft).

o Primary Auxiliary Building (7 ft).

b. Findinqs

No findings were identified.

.2 Annual Inspection

a. Inspection Scope

The inspectors completed one annualfire drill observation inspection sample. The

inspectors observed an announced fire brigade drill on March 1,2011, on the 64 foot

elevation of the fuel storage building. The inspectors observed brigade performance

during the drill to evaluate the following: donning and use of protective equipment; fire

brigade leader command and control; fire brigade response time; radio communications;

and the use of pre-fire plans. The inspectors attended the post-drill critique and

reviewed the disposition of issues and deficiencies identified during the drill. The

inspectors verified qualifications of the fire brigade members. The inspectors also

verified that allfirefighting equipment used during the drillwas returned to a condition of

readiness.

b. Findinos

No findings were identified.

1 R06 Flood Protection Measures (71111.06 - 1 sample)

a. Inspection Scope

The inspectors completed one flood protection measures inspection sample. The

inspectors reviewed the flood protection measures designed to protect the primary

auxiliary building 25 ft elevation and other safety-related equipment from the effects of

internal flooding. The inspectors reviewed NextEra's flooding evaluation for the selected

areas, and the design basis documents and flood response procedures. The inspectors

performed walkdowns of the selected areas to verify that as-found equipment and

conditions were consistent with the design basis documents. The inspectors reviewed

the condition of seals, level alarms and other equipment credited in the flood analysis.

The documents reviewed are listed in the Attachment.

b. Findinqs

No findings were identified.

Enclosure
8

1R11 Licensed Operator Requalification Proqram (71111.1 1Q - 1 sample)

Quarterlv Resident Inspector Review

a. Inspection Scope

The inspectors completed one quarterly licensed operator requalification program

inspection sample. The inspectors reviewed operator implementation of the abnormal

and emergency operating procedures on January 19,2011. The inspectors examined

the operators capability to perform actions associated with high-risk activities, the

Emergency Plan, previous lessons learned items, and the correct use and

implementation of procedures. The inspectors observed and reviewed the training

evaluator's critique of operator performance and verified that deficiencies were

adequately identified, discussed, and entered into the corrective action program. The

inspectors reviewed the simulator's physical fidelity in order to verify similarities between

the Seabrook control room and the simulator. The documents reviewed are listed in the

Attachment.

b. Findinqs

No findings were identified.

1R12 Maintenance Effectiveness (71111.12Q - 3 samples)

a. Inspection Scope

The inspectors completed three maintenance effectiveness inspection samples. The

inspectors reviewed performance-based problems and completed performance and

condition history reviews for the selected in-scope structures, systems or components

(SSCs) listed below to assess the effectiveness of the maintenance program. Reviews

focused on: proper Maintenance Rule (MR) scoping in accordance with 10 CFR 50.65;

characterization of reliability issues; tracking system and component unavailability;

10 CFR 50.65 (aX1) and (a)(2) classifications; identifying and addressing common

cause failures, trending key parameters, and the appropriateness of performance criteria

for SSCs classified (a)(2) as well as the adequacy of goals and corrective actions for

SSCs classified (aX1). The inspectors reviewed system health reports, maintenance

backlogs, and MR basis documents. The documents reviewed are listed in the

Attachment.

o Emergency Feedwater System (EFW) classified as MR (a)(2) with a focus on

component performance impacting unavailability and reliability (AR 579871,219494).

r The structures monitoring program per 10 CFR 50.65(aX2) with a focus on the

Control Building and the Service Water and Circulating Water Systems (ARs 574120,

581434, 1629504).

o Containment Building Spray (CBS) system classified as MR (aX2) with a focus on

component performance impacting unavailability and reliability (AR 1612480).

During the inspection of the structures monitoring program, the inspectors reviewed

NextEra's evaluation and action plan for chronic wetted conditions on several plant

structures. The inspectors also assessed NextEra's review of the effectiveness of the

Enclosure
b.

I

preventative maintenance for affected structures based on the degradation caused by

the chronic wetted conditions

NextEra identified visual indications of chronic groundwater infiltration in several plant

buildings with the control building exhibiting the most extensive indications. The

indications included mineral deposits, scaling, popouts and patterned cracking.

Waterproof membranes had been attached to the exterior of below grade structures to

control ground water infiltration at Seabrook, but based on the extensive indications of

infiltration, the membranes appear to be damaged.

ln August 2A10, in support of license renewal per 10 CFR Part 54, NextEra expanded its

investigation of the chronic groundwater infiltration. NextEra analyzed concrete core

samples taken from the areas of the CB external walls that had the most extensive

patterned cracking and identified changes in the concrete's material properties. The

analysis results showed moderate to severe alkali-silica-reaction (ASR) with reductions

in the concrete compressive strength and the modulus of elasticity that required further

evaluation (ARs 574120 and 581434). NextEra completed an operability determination

for the CB (reference NRC Inspection Report 05000443/2010-004) and concluded that

the CB remained operable with a 50% reduction in design margin.

Findinqs

Inadequate Monitorinq of ln-Scope Structures per 10 CFR 50.65(aX1)

lntroduction. An NRC-identified non-cited violation of 10 CFR 50.65(a)(1) was identified

because NextEra did not adequately monitor the condition of an in-scope structure under

the MR. Specifically, NextEra did not evaluate the results of their periodic inspections of

the condition of the Control Building to determine the extent and rate of degradation to

the structure. Further, in August 2010 after NextEra identified CB concrete strength

degradation that called into question the effectiveness of that structures preventative

maintenance program, NextEra did not classify the CB as MR (aX1).

Description. 10 CFR 50.65(a)(1) requires that licensees monitor the performance or

condition of structures, systems, or components in a manner sufficient to provide

reasonable assurance that these structures, systems, and components are capable of

fulfilling their intended functions. NextEra did not monitor the condition of the CB in a

manner that provided reasonable assurance that the CB remained capable of fulfilling its

intended function. Specifically, NextEra did not fully evaluate the acceptability of the

degraded conditions identified during periodic inspections of the CB structure. As a

result, ASR degradation of the CB concrete, which could reduce the concrete strength to

less than its design basis requirements, was not identified or evaluated by NextEra until

core bores were taken and analyzed in August 2010 as part of Seabrook license renewal

initiatives.

Pursuant to 10 CFR 50.65, the MR, in 1995 NextEra implemented plant engineering

guideline PEG04, Building/Structures Surveillance Inspections, to evaluate the condition

of structures that were in-scope for the MR. PEG04 Section 4.1.1 stated that

inspections are "intended fo preserve and protect structural integrity," "ensure

deficiencies are corrected in a timely manner" and "be sensitive to degrading conditions

such that corrective actions can be taken before loss of function occurs." Since the

inception of the PEG04 program in 1995, observed deficiencies were recorded and

.1

Enclosure
10

tracked, but no evaluation was performed to determine whether a "major structural

deficiency," as defined in Section 4.1 .3, had occurred. NextEra evaluations prior to 2010

were inadequate because visual indications of concrete degradation were not

investigated to fully assess the condition of the structure. Had methods available in

industry standards been used, for example American Concrete lnstitute (ACl) Standard

349, the underlying mechanism causing the CB structural degradation could have been

identified.

NextEra identified the need to improve the structures monitoring program in 2009.

Based on industry initiatives in 2009 (AR 199563), NextEra replaced the structures

monitoring program under PEG04 by Engineering Standard Procedure 36180 and

implemented a baseline inspection of structures in September 2010, one month after the

core bores were completed as part of license renewal. Procedure 36180 incorporated

the enhanced (quantified) criteria described in American Concrete lnstitute Standard ACI

349.3R to evaluate degraded concrete conditions for acceptability. Procedure 36180

included the three{iered evaluation criteria of ACI 349 Section 5.0 for investigating and

assessing conditions found detrimental to the structure.

When the results of the August 2010 control building core bores identified ASR

degradation, NextEra did not evaluate the structure within the context of the MR. The

inspectors determined that, although in August 2010 NextEra had concluded that the

ASR degradation in progress in the CB exterior concrete walls had not reduced CB

strength and flexibility to less than its design requirements, NextEra was required to

evaluate and classify the building as (a)(1) until they could demonstrate the condition of

the structure was effectively controlled and monitored through preventive maintenance.

Specifically, to perform this evaluation in the context of the MR, NextEra needed to

determine the extent and rate of the ASR degradation in the control building concrete.

NextEra entered the degraded structural concrete issue into its corrective action

program to address the extent of condition and establish a mitigation strategy (ARs

574120 and 581434) for all in-scope structures. NextEra also initiated AR 1636419 to

complete the evaluation for placing the CB into (a)(1) status.

Analvsis. The inspectors determined that not evaluating the results of the periodic

inspections of the condition of the CB to determine the extent and rate of degradation to

the structure, and once a time dependent degradation mechanism was identified not

evaluating the structure for MR (a)(1) status was a performance deficiency. This

performance deficiency is more than minor because if left uncorrected, the condition

could have resulted in the loss of function for the CB structure due to degrading concrete

material properties of structures and systems designed to mitigate design basis events.

The finding had very low safety significance because despite degraded concrete

conditions and loss of design margin, the CB structure remained operable. The

inspectors performed a Phase 1 Significance Determination Process (SDP) screening, in

accordance with NRC lnspection Manual Chapter (lMC) 0609, Attachment 4, "Phase 1 -

Initial Screening and Characterization of Findings," and determined the issue was of very

low safety significance (Green) because the finding was not a design or qualification

deficiency, did not result in an actual loss of safety function, was not a loss of barrier

function, and was not potentially risk significant for external events.

This finding had a cross-cutting aspect in the area of problem identification and

resolution, evaluation (P.1(c)) because NextEra did not ensure issues adverse to quality

Enclosure
.2

11

potentially impacting nuclear safety were promptly identified and evaluated. Specifically,

NextEra did not thoroughly evaluate indications of concrete degradation for the CB to

determine the extent and rate of degradation to the structure, and once concrete

degradation due to ASR distress was identified, NextEra did not evaluate the issue within

the context of the MR program to assure the condition of structures was controlled to

maintain design margins.

Enforcement. 10 CFR 50.65(aX1) requires that licensees monitor the performance or

condition of structures, systems, or components in a manner sufficient to provide

reasonable assurance that these structures, systems, and components are capable of

fulfilling their intended functions. Although 10 CFR 50.65(a)(2) provides an exception to

this rule, this exception applies only where the licensee has demonstrated that the

performance or condition of a structure is being effectively controlled through

performance of appropriate preventive maintenance. Contrary to section 50.65(a)(1),

NextEra failed to monitor the condition of the CB in a manner sufficient to provide

reasonable assurance that the CB remained capable of fulfilling its intended function.

Section 50.65(a)(1) applies because NextEra had not demonstrated, under section

50.65(a)(2) that the condition of the CB was effectively controlled through appropriate

preventive maintenance. Because this finding was of very low safety significance and

was entered into the corrective action program as Condition Report 1636419, this

violation is being treated as a non-cited violation (NCV), consistent with section Vl.A of

the NRC Enforcement Policy. (NCV 05000443/2011002-01, Failure to monitor the

condition of the Gontrol Building per 10 CFR 50.65(aXl)).

Failure to Scope Structures into MR per 10 CFR 50.65(bX2)

lntroduction. An NRC identified non-cited violation of 10 CFR 50.65(bX2) was identified

because NextEra did not include certain Seabrook buildings as in-scope structures

under the MR program. Specifically, NextEra did not classify the intake transition

structure (lTS) and the discharge transition structure (DTS) as in-scope structures in the

Maintenance Rule (MR) database, and as a result did not include them in the periodic

inspections completed under the structures monitoring program per PEG04 from 1995 to

2009.

Description. 10 CFR 50.65(bX2) requires that the scope of the monitoring program

specified in 10 CFR 50.65(a)(1) shall include safety related and non-safety related

structures, systems, and components that are (i) relied upon to mitigate accidents or

transients or are used in plant emergency operating procedures (EOPs); or (ii) whose

failure could prevent safety-related structures, systems, and components from fulfilling

their safety-related function; or (iii) whose failure could cause a reactor scram or

actuation of a safety-related system.

The NRC inspectors noted that the ITS and DTS were not considered in-scope in the

MR as shown in the MR program and dathbase. The ITS provides a surge volume for

the flow path that delivers ocean water to the service water (SW) system and the

circulating water (CW) system. The DTS provides a surge volume for the flow path that

discharges ocean water from the SW and CW systems. The inspectors determined that

both the SW system (MR functions SW-01, SW-02, SW-03, SW-04, SWB-01) and CW

system (MR functions CW-01, CW-02, CW-03, CWB-01) as well as the associated

structures (wholly or in part) were in-scope per 10 CFR 50.65(a)(1). The transition

structures provide ocean water to the SW system which in turn provides cooling water to

Enclosure
12

remove reactor decay heat and cool systems used in the emergency operating

procedures to mitigate design basis events. Further, the transition structures provide

ocean water to the CW system, whose failure could cause a plant trip.

NRC inspector walk downs of the transition structures noted degraded conditions in the

structural concrete (chronic wetting, patterned cracking) similar to conditions identified in

the CB. These conditions were determined to be indicative of concrete experiencing

ASR. As part of the extent of condition evaluation for the degraded concrete conditions

identified in the CB, NextEra scheduled concrete core testing for the ITS and DTS in the

Summer of 2011. NextEra's operability evaluation for the CB degraded conditions

concluded that that structure remained operable. The identified concrete conditions in

the CB were worse than the conditions seen in other ground water impacted structures

at the site, including the transition structures. NextEra determined the transition

structures remained operable based on information presently available. NRC continues

to review NextEra actions to evaluate the impact of ASR on Seabrook concrete

structures.

NextEra did not identify a basis for why the ITS/DTS was excluded from the MR

structures monitoring program when the scoping evaluations were completed in mid1995. ln 2011 , based on inspector observations, NextEra initiated a MR scoping

screening worksheet per procedure NAP 415 and upon consideration of the design basis

information concluded both transition structures should be in-scope per 10 CFR

50.65(a)(1). The NAP 415 scoping results were accepted by the MR Expert Panel on

March 15, 2011. NextEra initiated CR 1629504 to enter the issue into the CAP and

determine the extent of condition.

Analvsis. The inspectors determined that not classifying the ITS and DTS as in-scope

when the MR program was initiated in 1995 was a performance deficiency. With these

structures not in-scope or included in the periodic inspections of the structures

monitoring program, NextEra did not monitor the condition of the structures to determine

the extent and rate of identified degradation. The performance deficiency is more than

minor because if left uncorrected, given the indications of ASR identified in these

concrete structures, not monitoring the ITS and DTS structures for degradation could

result in the loss of function of structures supporting systems used to mitigate design

basis events, used in the emergency operating procedures, or whose loss could result in

a reactor trip.

The inspectors performed a Phase 1 Significance Determination Process (SDP)

screening, in accordance with NRC Inspection Manual Chapter (lMC) 0609, Attachment

4, "Phase 1 - Initial Screening and Characterization of Findings," and determined the

issue was of very low safety significance (Green) because the finding was not a design

or qualification deficiency, did not result in an actual loss of safety function, was not a

loss of barrier function, and was not potentially risk significant for external events.

This finding did not have a cross cutting aspect because the most significant contributor

to the performance deficiency was not reflective of current licensee performance.

Enforcement. 10 CFR 50.65(bX2) requires that the scope of the monitoring program

specified in 10 CFR 50.65(aX1) shall include safety related and non-safety relates

structures, systems, and components that are (i) relied upon to mitigate accidents or

transients or are used in plant emergency operating procedures (EOPs); or 1ii; whose

Enclosure
13

failure could prevent safety-related structures, systems, and components from fulfilling

their safety-related function; or (iii) whose failure could cause a reactor scram or

actuation of a safety-related system. Contrary to section 50.65(bX2), NextEra did not

classify the ITS and DTS as in-scope per 10 CFR 50.65(aX1) and did not monitor the

condition of the structures in a manner sufficient to provide reasonable assurance that

the structures remained capable of fulfilling its intended function. Because this finding

was of very low safety significance and was entered into the corrective action program

as Condition Report 1636419, this violation is being treated as a non-cited violation

(NCV), consistent with section Vl.A of the NRC Enforcement Policy. (NCV

05000443/2011002-02, Failure to classify and monitor the service water and

circulating water transition structures as in-scope per 10 CFR 50.65(bX2)).

1 R13 Maintenance Risk Assessments and Emerqent Work Control (71111 .13 - 5 samples)

lnspection Scope

The inspectors completed five maintenance risk assessment and emergent work control

inspection samples. The inspectors reviewed the scheduling and control of planned and

emergent work activities in order to evaluate the effect on plant risk. The inspectors

conducted interviews with operators, risk analysts, maintenance technicians, and

engineers to assess their knowledge of the risk associated with the work, and to ensure

that other equipment was properly protected. The inspectors reviewed the availability of

opposite train guarded and protected equipment. The compensatory measures were

evaluated against Seabrook procedures, Maintenance Manual 4.l4,"Troubleshooting,"

Revision 0 and Work Management Manual 10.1, "On-Line Maintenance," Revision 3.

Specific risk assessments were conducted using Seabrook's "Safety Monitor", as

applicable. The inspectors reviewed the maintenance items listed below. The

documents reviewed are listed in the Attachment.

o Planned work associated with the A EDG overhaul between January 10,2011 and

January 14,2011 (WO 1202426).

o Emergent work associated with the B EDG due to a glycol leak on the DG-P-231B

suction combined with pending severe weather on February 1, 2011 (WO

40066771).

. Planned work associated with flow control valve, RH-FCV-61 1, which rendered the

B train residual heat removal pump (RH-P-8-B) inoperable, combined with

switchyard high pot testing on March 1,2011 (WO 1186748).

. Planned work associated with 345 kV Switchyard Project 52, which rendered Bus 2

out of service, on March 14-30,2011 (WO4040244).

. Planned work that used the turbine building crane to mobilize equipment and which

increased the risk of a plant transient on March 7,2011 (WO 01197072).

Findinqs

No findings were identified.

Enclosure
14

1R15 Operabilitv Evaluations (71111.15 - 6 samples)

a. Inspection Scope

The inspectors completed six operability evaluation inspection samples. The inspectors

reviewed operability evaluations and condition reports to verify that identified conditions

did not adversely affect safety system operability or overall plant safety. The evaluations

were reviewed using criteria specified in NRC Regulatory lssue Summary 2005-20,

"Revision to Guidance formerly contained in NRC Generic Letter 91-18, Information to

Licensees Regarding two NRC Inspection Manual Sections on Resolution of Degraded

and Nonconforming Conditions and on Operability''and lnspection Manual Part 9900,

"Operability Determinations and Functionality Assessments for Resolution of Degraded

or Nonconforming Conditions Adverse to Quality or Safety." In addition, where a

component was determined to be inoperable, the inspectors verified that TS limiting

condition for operation implications were properly addressed. The documents reviewed

are listed in the Attachment. The inspectors also performed field walk downs and

interviewed personnel involved in identifying, evaluating or correcting the identified

conditions. The following items were reviewed:

. Past operability of the A EDG after an over current trip of the diesel room supply fan

DAH-FN-2SB supply breaker, January 3-7,2011 (CR 1604014).

. Operability of the A EDG with an indicated generator over voltage condition during a

load rejection test on January 16,2011 (CR1609346).

. Operability of the A shutdown bank position indication per technical specification

limiting condition for operation (LCO) 3.1.3.2 when the group 1 demand indicator

failed during rod operability testing on February 11,201 1 (CR 1619182).

. Operability of the service water system based on identified degradation in the A train

discharge piping downstream of valve SW-V20 on March 23-29,2011 (CR 1632409,

1633034).

. Operability of the service water system and cooling tower train due to thru wall leak

valve SW-V20, January 26,2011 (AR1612061).

. Past operability of the control room enclosure air handling system due to incomplete

testing as identified on February 9, 2011 (AR1617755).

b. Findinqs

No findings were identified.

1R18 Plant Modifications (71111.18 - 1 sample)

.1 Permanent Modification - EC 156655: EDG Temperature Switch Upqrade

a. Inspection Scope

The inspectors completed one permanent modification inspection sample. The

inspectors reviewed modification package EC 156655 that replaced the temperature

switches on the B EDG. The review was completed to confirm that the design bases

and performance capability of the system were not degraded. The inspectors verified

the new configuration was accurately reflected in the design documentation, and that the

post-modification testing was adequate to ensure that affected SSCs would function

Enclosure
15

properly. The inspectors also interviewed plant staff, and reviewed issues entered into

the corrective action program to verify that NextEra was effective at identifying and

resolving problems associated with temporary modifications. The documents reviewed

are listed in the Attachment.

b. Findinqs

No findings were identified.

1R19 Post-Maintenance Testinq (71111.19 - 5 samples)

a. lnspection Scope

The inspectors completed five post-maintenance testing (PMT) inspection samples.

The inspectors observed portions of PMT activities in the field to verify the tests were

performed in accordance with the approved procedures. The inspectors assessed test

adequacy by comparing test methodology to the scope of the maintenance work

performed. The inspectors evaluated the test acceptance criteria to verify that the test

procedure ensured that the affected systems and components satisfied applicable

design, licensing bases and TS requirements. The inspectors also reviewed recorded

test data to confirm all acceptance criteria were satisfied during testing. The documents

reviewed are listed in the Attachment. The activities reviewed are listed below:

r Retest of A EDG on January 14, 2011, following replacement of the electronic

governor per WO 1186827.

. Retest of A EDG on January 16-17 , 2011, following replacement of the air start

solenoid valve per WO 1172721.

o Retest of reactor coolant temperature controller RC-T-41 1A on February 14, 2Q11,

following replacement of the 7300 system card per WO 40065448.

o Retest of B EDG on February 2, 2011, following repair of a glycol leak discovered on

the suction to DG-P-1211231-8 during a maintenance run per WO 1186715.

. Retest of vital battery charger 1-EDE-BC-1-C on February 18,2011, following

maintenance per WO 1211468.

b. Findinqs

No findings were identified.

1R22 Surveillance Testinq (71111.22 - 4 samples)

a. Inspection Scope

The inspectors completed four surveillance testing inspection samples. The inspectors

observed portions of surveillance testing activities for safety-related systems to verify

that the system and components were capable of performing their intended safety

function, to verify operational readiness, and to ensure compliance with required TS and

surveillance procedures. The inspectors attended selected pre-evolution briefings,

performed system and control room walk downs, observed operators and technicians

perform test evolutions, reviewed system parameters, and interviewed the system

Enclosure
16

engineers and field operators. The test data recorded was compared to procedural and

TS requirements, and to prior tests to identify adverse trends. The documents reviewed

are listed in the Attachment. The following surveillance activities were reviewed:

. EX1808.013, Control Room Emergency Makeup Air and Filtration Subsystem 18

Month Surveillance, Revision 12, October 19,2010 (WO 01210620).

. OX1436.03, Electric EFW Pump Quarterly Operability Surveillance (lST), Revision

15, February 21 ,201 1 (WO 40038512).

o OX1456.41, Train A ESFAS Slave Relay K740 K741

12, January 10,2011 (WO 01384264).

. OX 1405.07 , Safety Injection Quarterly and 18 Month

February 10, 2010 (WO 40036953).

Quarterly Go Test, Revision

Pump Flow and Valve Test on

b.

2.

The inspectors also reviewed deficiencies related to surveillance testing and verified that

the issues were entered into the corrective action program. The documents reviewed

are listed in the Attachment.

Findinqs

No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2RS02 Occupational ALARA Plannino and Controls (71124.02)

a. Inspection Scope

During the period January 24-27 , 2011,the inspector conducted the following activities

to verify that NextEra was properly implementing operational, engineering, and

administrative controls to maintain personnel exposure as low as is reasonably

achievable (ALARA) in making preparations for the spring refueling outage (OR-14).

lmplementation of this program was reviewed against the criteria contained in 10 CFR

20, applicable industry standards, and NextEra's procedures.

Radioloqical Work Planninq

The inspector reviewed the preparations for radiologically significant tasks during the

spring 2011 refueling outage (OR 14). Included in this review was the ALARA reviews

(AR) for alljobs with a dose estimate greater than 5 person-rem. These jobs included

reactor vessel disassembly/re-assembly (AR 1 1-01), steam generator (S/G) eddy current

testing/tube plugging (AR 1 1-02), S/G secondary side maintenance (AR 1 1-03), and

reactor vessel nozzle inspections (AR 1 1-13).

In performing this review, the inspector evaluated contamination control measures, use

of portable ventilation systems, use of temporary shielding, and the control of system

drain-downs. Additionally, the inspector evaluated the departmental interfaces between

radiation protection, operations, maintenance crafts, and engineering to identify missing

ALARA program elements and potential interface problems. The evaluation was

Enclosure
17

accomplished by reviewing recent radiation safety committee meeting minutes, nuclear

oversight reports, and interviewing the site radiation protection Manager and the ALARA

supervisor regarding the OR 14 preparations,

b. Findinqs

No findings were identified.

2RS03 ln-Plant Airborne Radioactivitv Control and Mitiqation (71124.03)

a. Inspection Scope

During the period January 24-27 ,2011, the inspector conducted the following activities

to verify that in-plant airborne concentrations of radioactive materials were controlled

and monitored, and to verify that the practices and use of respiratory protection devices

were proper.

lmplementation of these programs was evaluated against the criteria contained in 10

CFR 20, applicable industry standards, and NextEra's procedures.

Enqineerinq Controls

The inspector verified that NextEra used installed ventilation systems as part of its

engineering controls (in lieu of respiratory protection devices) to control airborne

radioactivity. The inspector reviewed procedural guidance for use of the control room air

handling system (CRA) and determined that the system was operable. The inspector

reviewed surveillance testing procedures and related data to confirm that the CRA

airflow capacity, flow path, and charcoaliHEPA filter efficiencies met regulatory criteria

and were consistent with maintaining concentrations of airborne radioactivity as low as

practicable. The inspector verified the system configuration by walking down

components with the cognizant system engineer and the NSSS supervisor.

The inspector evaluated the use of in-plant continuous air monitors to determine if the

monitors were appropriately located in areas where airborne radioactivity could

potentially result from normal plant operations and that the systems were operable. With

the assistance of a senior radiation technician the inspector observed weekly source

checks of monitors (particulate and noble gas detectors) located in the primary auxiliary

building, waste processing building, spent fuel storage building, and control room, and

determined that the alarm set points were appropriately established.

Through review of relevant procedures and analytical data, the inspector determined that

NextEra had established an alpha and transuranic radiation monitoring program.

Included in this program were trigger points for conducting additional measurements to

assure that the airborne concentrations were properly characterized and that bioassay

measurements were taken, should the need arise.

Use of Respiratorv Protection Devices

The inspector observed the respirator fit testing of one individual to determine if the

testing was appropriately conducted per the procedural guidance. Additionally, the

inspector confirmed that the individual tested had completed the requisite training and

was medically qualified to wear a respirator.

Enclosure
b.

18

The inspector examined various negative pressure, self-contained and supplied air

respiratory protection devices and determined that these devices were certified for use

by the National Institute for Occupational Safety and HealthiMine Safety and Health

Administration (N IOSH/MSHA).

The inspector reviewed the records of air testing for supplied service air devices and

self-contained breathing apparatus (SCBA). The air used in these devices appropriately

exceeded the quality requirements for Grade D quality.

Self-Contained Breathinq Apparatus for Emerqencv Use

The inspector evaluated the adequacy of the respiratory protection program regarding

the maintenance and issuance of SCBAs to emergency response personnel. Training

and qualification records were reviewed for at least three licensed operators from each

of the operating shifts, and for selected radiation protection personnel who would wear

SCBAs in the event of an emergency.

The inspector observed technicians perform functional inspections on three SCBAs

staged in the Control Room and two SCBAs staged on the turbine deck. Maintenance,

hydrostatic test records, and flow test records for selected SCBAS, staged in other plant

areas, were reviewed. The method of refilling SCBA cylinders was evaluated and the

compressor air sample results were reviewed to confirm that air quality met CGA G-7.1,

Grade E (2004) standards.

The inspector observed a technician perform functional testing of two SCBA regulators

to confirm that flow rates and alarm set points were properly set. The inspector verified

that technicians performing maintenance on SCBAs were trained and certified by the

vendor to conduct the activities.

Through review of training lesson plans and interviews, the inspector confirmed that

individuals qualified to wear SCBAs were also trained to replace spent air cylinders.

Problem ldentification and Resolution

Through review of condition reports and nuclear oversight daily quality summaries and

audits, the inspector verified that problems associated with the control and mitigation of

in-plant airborne radioactivity were identified at an appropriate threshold and properly

addressed for resolution in the corrective action program.

Findinqs

No findings were identified.

Enclosure
19

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151- 3 samples)

b. Findinqs

No findings were identified.

4OA2 ldentification and Resolution of Problems (71152 - 1 sample)

Initiatino Events Cornerstone

Insoection Scope

The inspectors sampled NextEra submittals for the Initiatlng Events cornerstone

performance indicators (Pls) listed below for the period from January 2010 through

December 2010. To verify the accuracy of the Pl data reported during that period, the

inspectors used the Pl definitions and guidance contained in NEI 99-02, "Regulatory

Assessment Indicator Guideline," Revision 6.

. Unplanned Scrams per 7,000 Critical Hours

. Unplanned Scrams with Complications

. Unplanned Power Changes per 7,000 Critical Hours

The inspectors reviewed licensee event reports (LERs), operating logs, procedures, and

interviewed applicable personnel to verify the accuracy and completeness of the data.

The inspectors also reviewed the accuracy of the number of critical hours reported.

.1 Review of ltems Entered into the Corrective Action Proqram

As required by Inspection Procedure 71152, "ldentification and Resolution of Problems,"

and in order to help identify repetitive equipment failures or specific human performance

issues for follow-up, the inspectors performed a daily screening of all items entered into

NextEra's CAP. This was accomplished by reviewing the description of each new

condition reports and attending daily management review committee meetings.

Documents reviewed are listed in the Attachment.

Annual Sample: Submerqed Electrical Cables

Inspection Scope

The inspectors performed a focused inspection to review NextEra's actions to evaluate

and correct conditions under which safety-related electrical cables were not being

operated in an environment for which they were designed. Specifically, numerous

cables were found to have been operating while submerged in water. This issue was

documented as a licensee identified violation in NRC Inspection Report

05000443/2009005 and was entered into the corrective action program as condition

report 21 1808.

.2

a.

Enclosure
b.

20

The inspectors interviewed the responsible plant engineering staff to understand

NextEra's actions taken as well additional planned actions for resolving the issue. The

inspectors reviewed work orders associated with safety-related cable vault inspections

and corrective actions taken to resolve issues documented in condition reports initiated

as a result of the inspections. The inspectors also reviewed engineering evaluations

involving submerged cable issues as well as fleet and station cable condition monitoring

program procedures. The documents reviewed are listed in the Attachment.

Findinqs and Observations

No findings were identified.

The inspectors found that NextEra completed appropriate actions to resolve the issue

with safety-related cable operation in a submerged environment. Actions have been

taken to monitor and dewater cable vaults on a frequency that will maintain water level in

the cable vaults below that of the lowest safety-related cable passing through the vaults.

The inspection frequency for each vault was determined based on the initial vault

inspection results. The inspectors confirmed that repetitive preventive maintenance

tasks were established to implement the inspection program. The inspectors also noted

that instructions to maintain the cables in a dry environment have been included in

PEG-265, Plant Engineering Guideline - Cable Condition Monitoring Program, Rev. 0.

The inspectors determined that the evaluations of the submerged cable conditions were

thorough and included appropriate considerations for extent of condition. The inspectors

reviewed NextEra's corrective actions and determined that they were appropriate,

adequately addressed the identified deficiencies and were accomplished in a timely

manner.

Event Followup (71153 - 1 sample)

Response to Notification of Unusual Event (NOUE) Declaration

Inspection Scope

The NRC inspectors responded to the declaration of a fire emergency inside the

protected area on March 28, 2011. At 1 1;43 a.m., Seabrook Station declared an NOUE

for a fire in the protected area that was not extinguished within 15 minutes, under

emergency action level category HU 2. The fire had no visible flames (smoke only).

The source of smoke was an equipment elevator power supply located in the

Emergency Core Cooling System (ECCS) equipment vault located in a stair tower

leading to the B train equipment room. The non-safety related elevator is for equipment

transfer between elevations in the equipment vault. The event was terminated at 12:43

p.m., and subsequent investigation revealed no plant equipment damage beyond a

power transformer that supplies the affected elevator. No fire extinguishing agent was

applied, no outside fire assistance was required and no personal injuries were reported.

NextEra determined that there was no evidence of tampering. The inspectors conducted

walk downs of plant equipment to confirm the adequacy of NextEra's response and the

condition of nearby safety-related equipment. The inspectors also reviewed the

adequacy of NextEra's emergency and fire response actions. NextEra entered the issue

into its corrective action program for evaluation and corrective actions (CR1634521).

40A3

a.

Enclosure
21

b. Findinqs

No findings were identified.

4OAO Meetinos. Includinq Exit

On April 7, 2011, the resident inspectors presented the results of the fourth quarter

routine integrated inspection to Mr. Paul Freeman and other Seabrook Station staff. The

inspectors also confirmed with NextEra that no proprietary information was reviewed by

inspectors during the course of the inspection.

ATTACHMENTS: SUPPLEMENTAL INFORMATION

Enclosure
A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personne

J. Ball, Maintenance Rule Coordinator

B. Brown, Supervisor, Civil Engineering

V. Brown, Senior Licensing Analyst

M. Collins, Manager, Design Engineering

W. Cox, Radiological Engineer

R. Gutherie, Plant System Engineer

F. Haniffy, Senior Radiation Protection Analyst

L. Hansen, Plant Engineering

N. Levesque, Plant Engineering

E. Metcalf, Plant General Manager

W. Meyer, Radiation Protection Manager

M. O'Keefe, Licensing Manager

M. Nadeau, System Engineer, Control Building Air Handling

D. Perkins, Supervisor, Radiation Protection Technical Services

T. Vassallo, Principal Engineer - Nuclear

J. Walsh, Nuclear Steam Supply System, Supervisor

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed:

05000443i2011002-01

05000443/2011002-02

Closed:

None

Discussed

None

NCV

NCV

Failure to Monitor Condition of Control

Building per 1 0CFR50.65(a)(1 )

Failure to Classify and Monitor the Ocean

Transition Structures as In-Scope per

10cFR50.65(bX2)

Attachment
A-2

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

OS1200.03, Sever Weather Conditions, Revision 18

Daily Status Reports

Station Operating Logs - various

Section 1R04: Equipment Aliqnment

OX1426.19, Aligning DG 1B Controls For Auto Start, Revision 3

OS1026.13, Operating The DG 1B Fuel Oil System, Revision 10

OS1026.10, Operating The DG 1 B Lube Oil System, Revision 1 1

OS1026.12, Operating The DG 1 B Starting Air System, Revision 1 1

OS1026.1 1 , Operating The DG 1 B Jacket Cooling Water System, Revision 08

OX1436.03, Electric Driven EFW Pump Valve Alignment, Revision 14

OX1439.02. Turbine Driven Emergency Feedwater Pump Quarterly and Monthly Valve

Alignment, Revision 16

Plant Engineering Action Plan Register

Clearance 1 -RH-FCV-61 1 -1 1 09-01

TS 3.8.1.1 Electrical Power Systems

Drawings 820685 and 820688

Work Order 40038552, 1186748, 1 1 86748

UFSAR Section 6.8

Station Operating Logs - various

Section 1R05: Fire Protection

Fire Protection Pre Fire Strategies

Fire lmpairment List

MX0599.06, 6-Month Surveillance And Post-Maintenance Inspection Of Technical

Requirements Fire-Rated Doors, Revision 04

TR1 1 -3.7.9.5, Fire Rated Assemblies

UFSAR Section 9.5.1 Fire Protection Systems

UFSAR Section 13.2.2.9 Fire Protection Personnel

Technical Requirement 11, Fire Rated Assemblies

Fire Protection Pre-fire Strategies

DBD-FP-06, Fire Rated Doors, Dampers, Conduit Wrap, & Heat Shields, Revision 2

OS1200.004, Fire Hazards Analysis for Affected Area I Zone - Appendix A

OS1200.00, Response to Fire or Fire Alarm Actuation, Revision 15

wo 40072651

FPl.43 Management Expectations For Fire Drill Performance, Revision 2

FP 4.1 Fire Protection Program Training and Qualifications, Revision 7

FP 5.1 Fire Brigade Response, Revision 6

Training Review Committee minutes dated February 2011

Fire Drill Evaluations for 2O1O

Fire Drill Evaluation dated March 1, 2011

Station Operating Logs - various

Section 1R06: Flood Protection

UFSAR Section 9.3.3.3 and Section 3.4

DBD-PB-1, "Design Bases Document Plant Barriers"

Report No. TP-7, Seabrook Station moderate energy Line Break Study

Drawing 9763-F-805370, 9763-F-1 01 51 1, 9763-F-102214

Attachment
A-3

Pl D- 1 -WLD -820221, D20223

PAB Flooding Study Figures 4.1 and 4.2

MA 5.7, "Station Barriers, Penetration Seals, and Fire Barrier Wrap," Revision x

Report TP-7 , Seabrook Station Moderate Energy Line Break Study, Revision 5

PAB Floor Plan El. 25'0", Drawing PAB 201

PAB Floor Plan El. -26'0", Drawing PAB 202

Section 1R11: Licensed Operator Requalification Prosram

OS1290.03, Response to a Security Event, Revision 10

Licensed Operator Requalification Training Guide L3542C

Emergency Operating Procedures E-0, ECA-0.0

Form ER 2.08, Seabrook Station State Notification Fact Sheet

Form EPDP-O3A, EP Cornerstone Reporting and Information Form

Section 1Rl2: Maintenance Rule lmplementation

System Health Reports - EFW and SW Systems

Maintenance Rule Performance and Scope Report

Maintenance Rule EFW-05 Unavailability

Plant Engineering Action Register

Condition Reports 1 6239504, 584768, 585586, 219494, 597871,

Cond ition Reports 201 0-201 1

System Health Report - CBS system

Maintenance Rule Performance and Scope Report

AR: 221 050, 222004, 391 1 05, 5888 1 7, 21 4447, 586924, 575036, 57 41 1 1, 1 61 1 682,

Q706449,161 1805

Calculation: C-S-1-84104, 57057 , 57041, 23903, 83806

PID-1-CBS-D202331

UFSAR Section 6.2, Containment Systems

Work Requests 2010-201 1

Station Operating Logs - various

Section 1R13: Maintenance Risk and Emerqent Work

M-Rule a(4) Risk Assessment Reports

SM 7.10, Maintenance Rule Program, Revision 1

WM 10.1, On-Line Maintenance, Revision 8

WM-AA-1000, Work Activity Risk Management Process

NAWM, Work Management Manual, Revision 56

Work Order 1202426, 40040244

Station Operating Logs - various

Condition Report 1 626965

Section 1 R15: Operabilitv Evaluations

MA 4.144, Troubleshooting Cause and Effect Diagram

OS1023.74, Maintenance of Safety Related HVAC Systems - Compensatory Ventilation

Procedure, Revision 10

LS0562.27, Diesel Generator Voltage Indicating Loop Calibration, Revision 1

Drawing ILD-1-EDE-V-9700, Diesel Generator 1A Voltage, Revision 14

1S1638.913, V-9700 Diesel Generator-1A Voltage Indicating and Recording Calibration,

Revision 6

Engineering Evaluation - Load rejection test data during performance of Work Order

1186827

Attachment
A-4

Plant Computer Displays for Meteorological Data from December 26-31 ,2010

Prompt Operability Determinations for CRs 1612061,1632409, 1633034

Calculation C-S-1-45855, Revision 1 and Revision 2, Code Case N-513-3 Pipe Wall

Flaw Evaluation for SW-1814-001 piping

Work Order 4003698701, 40064596

ODM, Operational Decision Making for Service Water Piping Leak (AR 1633034)

POD, Prompt Operability Determination for CR 1612061

Ultrasonic Thickness Examination Report 1 -SW-1 814-01-156-24

SBK 10-009, Control Room Habitability Program

LAR 07-02, License Amendment Request

TS 3.7.6 Control Room Subsystem Emergency Makeup Air and Filtration

TS 6.7.6 Procedures and Programs, Control Room Envelope Habitability Program

EC: 145189

Calculation No: 200917-S-017, Revision 0

Station Operating Logs - various

Section 1Rl8: Plant Modifications

EC156655, 144992

01MMOD565

Foreign Print 20590, 20594

Pf D-1 -DG-B-20466, 20465, 20463

WO: 1210521, 1210516

AR: 1 61 6032, 1614198, 1 61 3934, 1614163, 1 61 3961 , 1 61 3769, 1614434, 1614741, 1 61 4908

1 -NHY-5081 35 Configuration Setting Document

1-NHY-506402 Diesel Generator 1B Lube Oil Control System Control Loop Diagram

1-NHY-506406 Diesel Generator Jacket Cooling Water Control Loop Diagram

LTR 0326-0052-02lndependent Third Party Review of Seabrook Station EDG Temperature

Switch Upgrade

LAR Panel-DG-CP-76, UA-9568, LocalAlarm Response, Revision 54

DBD-DG-O1 Design Basis Document - Diesel Generator, Revision 4

Section 1Rl9: Post Maintenance Testins

1S1630.902, Diesel Generator 1A Governor Tuning, Revision 04

Work Orders 1 172721, 1 186827

1S1630.902, Diesel Generator 1A Governor Tuning, Revision 05

Condition Report 1609346

|X1662.410 RC-T-411A, Loops 1 Delta T/Tavg Protection, Revision 11

wo 4006677 1, 1208338, 40036969, 1207287

AR 1 61 3834, 1 61 3900, 1 61 4886, 1 61 5550, 1 61 9851, 1619852, 1612230, 1610521, 1 61 0758,

1605742,1610340

Technical Specification - various

DRR 94-064 DG Cooling Water System Gasket Replacement, Revision 1

Plant Engineering Action Plan Register - diesel generator,

Station Operating Logs - various

Section 1R22: Surveillance Testinq

Technical Specification 6.7.6.d

Technical Specification 3.7 .1.2

Technical Requirement 28

Work Orders 01210620, 40038552, 4003851 2, 40038477, 40038479, 40036959,

40037328

Attachment
A-5

Station Operating Logs - various

C-S-1-50013 Sl Pump (S|-P-6A/B) IST Uncertainties

C-S-1-57054 Safety Injection Pumps, Sl-F-91 8, 922 IST Uncertainties

Section 2RS02: OccupationalALARA Planninq and Controls and

Section 2RS03: In-Plant Airborne Radioactiriitv Control and Mitiqation

Procedures:

HN0955.08, Operation of the RDMS Portable Particulate & Gas Continuous Air Monitor, Rev 9

HD0955.53, Use of AMS-4, Rev 1

HD0963.45, Calibration and Minor Repair of AMS-4, Rev 0

HD0965.01, Respiratory Protection Quality Assurance and Maintenance Program, Rev 15

HD0965.08, Breathing Air Certification, Rev 12

HD0965.10, Respirator Fit Testing Using the TSI Portacount Plus, Rev 13

HD0965.12, Respiratory Equipment lssue and Use, Rev 29

HN0958.13, Generation and Control of Radiation Work Permits, Rev 31

HD0965.14, Use of the PosiCheck 3, Rev 5

HD0965.02, Repair, Inspection, Inventory, and Maintenance of Respiratory Equipment, Rev 20

|X1660.710, Control Room Air lntake Train A or B Radiation Monitor Calibration, Rev 08

HX0955.32, RDMS Set-point Determination for RP Monitors, Rev 26

OX1423.27, Control Room Area Ventilation System Surveillance, Rev 4

OX1423.29, Train A CBA East Air Intake Radiation Monitor Go Test, Rev 1

OX1423.30, Train A CBA West Air Intake Radiation Monitor Go Test, Rev 1

OX1423.31, Train B CBA East Air lntake Radiation Monitor Go Test, Rev 0

OX1423.32, Train B CBA West Air Intake Radiation Monitor Go Test, Rev 0

MX0516.07, Control Room Area Ventilation Filter Testing, Rev 1

1N1660.99, Portable Continuous Atmosphere Radiation Monitor Calibration, Rev 6

Condition Reports: 00394673, 01612431,01612430, 01613213, 01612430,01612431,

00394673, 00394421

Nuclear Oversiqht Dailv Qualitv Summarv Reports/Audits:

Daily Quality Summary Report for the period 11112010 through 112112011

SBK-1 0-01 2, Radiation Protection Program Audit

SBK-1 0-045, Radiation Protection Instrumentation Audit

Calibration Records Reviewed: AMS-4: Serial Nos. 990, 741, 979, 742

SCBA Packs lnspected (Requlator No./Cvlinder No.)

Control Room: MW1 28061/1 0660, MV1 97032 16229, MW1 3333013945

Turbine Bld g : APAB27 641 I 6344, ANAD06 37 69 I 6202

SCBA Personnel Qualification Reports:

Operations Department

Radiation Protection Department

Miscellaneous Documents:

Job Performance Measure GT1074j, MMR Firehawk SCBA or MMR Firehawk M7 SCBA

HPSTID 09-008, Use of the Mururoa BP Type V4 FV Delta Suit

Health Physics Review of lsotopic Mixture 10-01

SCBA Hydrostatic Test Records

Compressor Air Quality Records

Training Certifications for SCBA Technicians

Attachment
OR14 ALARA Plans (AP):

AR 1 1-01, Reactor vessel disassembly/re-assembly

AR 11-02, Steam generator (S/G) eddy current testing/tube plugging

AR 11-03, S/G secondary side maintenance

AR 1 1-13, Reactor vessel nozzle inspections

Section 4042: ldentification and Resolution of Problems

Procedures:

ER-AA-106, NextEra Nuclear Fleet Cable Condition Monitoring Program, Rev. 1

LS0564.36, Very Low Frequency (VLF) Hi-Pot lnsulation Resistance Testing and Tan-Delta,

Rev.0

PEG-265, Plant Engineering Guideline - Cable Condition Monitoring Program, Rev. 0

Condition Reports: 001551 , 211357,211808,213341,213720,214212, 215431 , 217395,

21 7 408, 21 7 I 42, 220250, 220 428, 223283, 3937 7 4, 395483, 39549 1

Work Orders: 40039687, 40043256, 40043257

Miscellaneous Documents

BM-ELEC-MV-MNHLE, Work Instruction - Medium Voltage Electrical Manhole and Vault

Inspections

Cable Program Health Report, 4h Quarter 2010

Engineering Evaluation94-41, Submerged Electrical Cables and Supports, January 1, 1995

L-2007-067, Response to NRC Generic Letter 2007-01, May 06, 2007

Attachment
A-7

ADAMS

ALARA

AR

ASME

CAP

CB

CBS

cc

CR

CRA

CW

DG

DTS

EC

ECCS

EDG

EFW

EOP

tMc

IP

ITS

LER

MR

NCV

NEI

NOUE

NRC

PARS

PCCW

PI

PMT

SCBA

SDP

S/G

ssc

SW

TS

UFSAR

WO

LIST OF ACRONYMS

Agency-wide Documents Access and Management System

As Low As is Reasonably Achievable

Action Request

American Society of Mechanical Engineers

Corrective Action Program

Control Building

Containment Building Spray

(ASME) Code Case

Condition Report

Control Room Air Handling System

Circulating Water

Diesel Generator

Discharge Transition Structure

Engineering Change

Emergency Core Cooling System

Emergency Diesel Generator

Emergency Feedwater

Emergency Operating Procedure

Inspection Manual Chapter

Inspection Procedure

Intake Transitions Structure

Licensee Event Report

Maintenance Rule

Non-cited Violation

Nuclear Energy lnstitute

Notice of Unusual Event

U.S. Nuclear Regulatory Commission

Publicly Available Records

Primary Component Cooling Water

Performance Indicator

Post-maintenance Testing

Self Contained Breathing Apparatus

Significance Determination Process

Steam Generator

Structures, Systems or Components

Service Water

Technical Specifications

Updated Final Safety Analysis Report

Work Order

Attachment