UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

REGION I 

2100 RENAISSANCE BLVD., SUITE 100 

KING OF PRUSSIA, PA 19406-2713 

February 6, 2015 

Mr. Dean Curtland 

Site Vice President 

Seabrook Nuclear Power Plant 

NextEra Energy Seabrook, LLC 

c/o Mr. Michael Ossing 

P.O. Box 300 

Seabrook, NH 03874 

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

REPORT 05000443/2014005 

Dear Mr. Curtland: 

On December 31, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an 

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

inspection results, which were discussed on January 29, 2015, with you and other members of 

your staff. 

The inspection 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. 

This report documents three violations of NRC requirements, which were of very low safety 

significance (Green). However, because of the very low safety significance, and because they 

are entered into your corrective action program (CAP), the NRC is treating these findings as 

non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you 

contest the non-cited violations 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 I; the Director, Office of Enforcement, United States Nuclear 

Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at 

Seabrook Station. In addition, if you disagree with the cross-cutting aspect assigned to any 

finding, or a finding not associated with a regulatory requirement 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 Regional Administrator, Region I, and the NRC Resident Inspector at 

Seabrook Station. 

 
D. Curtland 2 

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs “Rules 

of Practice,” a copy of this letter, its enclosure, and your response (if any) will be available 

electronically for public inspection in the NRC’s Public Document Room or from the Publicly 

Available Records component of the NRC’s Agencywide Documents Access Management 

System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/readingrm/adams.html (the Public Electronic Reading Room). 

Sincerely, 

 /RA/ 

 Glenn T. Dentel, Chief 

Reactor Projects Branch 3 

Division of Reactor Projects 

Docket No. 50-443 

License No: NPF-86 

Enclosure: Inspection Report No. 05000443/2014005 

 w/ Attachment: Supplemental Information 

cc w/encl: Distribution via ListServ 
D. Curtland 2 

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs “Rules 

of Practice,” a copy of this letter, its enclosure, and your response (if any) will be available 

electronically for public inspection in the NRC’s Public Document Room or from the Publicly 

Available Records component of the NRC’s Agencywide Documents Access Management 

System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/readingrm/adams.html (the Public Electronic Reading Room). 

Sincerely, 

 /RA/ 

 Glenn T. Dentel, Chief 

Reactor Projects Branch 3 

Division of Reactor Projects 

Docket No. 50-443 

License No: NPF-86 

Enclosure: Inspection Report No. 05000443/2014005 

 w/ Attachment: Supplemental Information 

cc w/encl: Distribution via ListServ 

Distribution w/encl: (via e-mail) 

D. Dorman, RA 

D. Lew, DRA 

H. Nieh, DRP 

M. Scott, DRP 

R. Lorson, DRS 

J. Trapp, DRS 

G. Dentel, DRP 

R. Barkley, DRP 

M. Draxton, DRP 

C. Highley, DRP 

P. Cataldo, DRP, SRI 

C. Newport, DRP, RI 

A. Cass, DRP, Resident AA 

K. MorganButler, RI, OEDO 

RidsNrrPMSeabrook Resource 

RidsNrrDorlLpl1-2 Resource 

ROPreports Resource

DOCUMENT NAME: G:\DRP\BRANCH3\Inspection\Reports\Draft\2014 (ROP15)\SB IR14005 Rev Final.docx 

ADAMS Accession No.: ML15037A172 

 SUNSI Review 

 Non-Sensitive 

 Sensitive 

 Publicly Available 

 Non-Publicly Available 

OFFICE RI/DRP RI/DRP RI/DRP 

NAME RBarkley/rb PCataldo/pc via email GDentel/gd 

DATE 02/6/15 02/5/15 02/6/15 

OFFICIAL RECORD COPY 
1 

Enclosure 

U.S. NUCLEAR REGULATORY COMMISSION 

REGION I 

Docket No.: 50-443 

License No.: NPF-86 

Report No.: 05000443/2014005 

Licensee: NextEra Energy Seabrook, LLC 

Facility: Seabrook Station, Unit No.1 

Location: Seabrook, New Hampshire 03874 

Dates: October 1, 2014 through December 31, 2014 

Inspectors: P. Cataldo, Senior Resident Inspector 

C. Newport, Resident Inspector 

 T. O’Hara, Reactor Inspector 

 W. Cook, Senior Reactor Analyst 

 D. Silk, Senior Operations Engineer 

 R. Barkley, Senior Project Engineer 

 B. Dionne, Health Physicist 

Approved by: Glenn T. Dentel, Chief 

 Reactor Projects Branch 3 

 Division of Reactor Projects 
2 

Enclosure 

TABLE OF CONTENTS 

SUMMARY .................................................................................................................................... 3

REPORT DETAILS ....................................................................................................................... 5

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

1R01 Adverse Weather Protection ...................................................................................... 5

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

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

1R11 Licensed Operator Requalification Program ............................................................... 7

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

1R13 Maintenance Risk Assessments and Emergent Work Control ................................ 12

1R15 Operability Determinations and Functionality Assessments .................................... 12

1R18 Plant Modifications .................................................................................................... 13

1R19 Post-Maintenance Testing ....................................................................................... 14

1R22 Surveillance Testing ................................................................................................. 14

2. RADIATION SAFETY .......................................................................................................... 15

2RS3 In-Plant Airborne Radioactivity Control and Mitigation ............................................. 15

2RS4 Occupational Dose Assessment .............................................................................. 16

2RS5 Radiation Monitoring Instrumentation ...................................................................... 16

4. OTHER ACTIVITIES ............................................................................................................ 19

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

4OA2 Problem Identification and Resolution ..................................................................... 20

4OA6 Meetings, Including Exit ............................................................................................ 26

ATTACHMENT: SUPPLEMENTARY INFORMATION................................................................ 26

SUPPLEMENTARY INFORMATION ........................................................................................ A-1

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

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

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

LIST OF ACRONYMS ............................................................................................................. A-12

 
3 

Enclosure 

SUMMARY 

IR 05000443/2014005; 10/01/2014-12/31/2014; Seabrook Station, Unit No. 1; Maintenance 

Effectiveness and Radiation Monitoring Instrumentation 

This report covered a three-month period of inspection by resident inspectors and announced 

inspections performed by regional inspectors. Inspectors identified three findings of very low 

safety significance (Green), which were classified as NCVs. The significance of most findings is 

indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined 

using Inspection Manual Chapter (IMC) 0609, “Significance Determination Process,” dated 

June 2, 2011. Cross-cutting aspects are determined using IMC 0310, “Components Within 

Cross-Cutting Areas,” dated October 28, 2011. All violations of NRC requirements are 

dispositioned in accordance with the NRC’s Enforcement Policy, dated July 9, 2013. The 

NRC’s program for overseeing the safe operation of commercial nuclear power reactors is 

described in NUREG-1649, “Reactor Oversight Process,” Revision 5. 

Cornerstone: Barrier Integrity 

• Green. The inspectors identified an NCV of 10 CFR 50 Appendix B Criterion XVI, Corrective 

Actions, of very low safety significance because NextEra staff did not promptly identify nine 

visual indications of structural problems representing conditions adverse to quality. These 

problems were observed by NextEra staff during a maintenance rule (MR) walkdown of the 

Fuel Storage Building (FSB) on November 20, 2014, and documented in walkdown notes 

as conditions warranting entry into the corrective action program (CAP). However these 

problems were not entered into the CAP to identify them as conditions adverse to quality 

until questioned by the inspectors. NextEra staff took corrective actions to enter the issues 

into their CAP in AR10206192, AR02016238, AR02016225 and AR020168863 and initiated 

AR02014116 for not promptly identifying these problems. 

This performance deficiency was considered to be more than minor because it is associated 

with the Barrier Integrity Cornerstone objective to provide reasonable assurance that 

physical design barriers protect the public from radionuclide releases caused by accidents 

or events, and affected the attribute of design control – structural integrity. Specifically, the 

inspectors determined the finding was more than minor because four of the conditions 

exceeded American Concrete Institute (ACI) 349.3R-96 "Tier II structural criteria,” which 

indicated they require further technical evaluation and analysis to validate the existing 

conditions or repair to preserve structural function. This issue was evaluated in accordance 

with IMC 0609, Appendix A, “The Significance Determination Process for Findings AtPower,” Exhibit 3, “Barrier Integrity Screening Questions,” and screened as very low safety 

significance (Green) because the observed FSB degradation did not adversely impact 

structural or radiological barrier functions of the building. This finding is related to the crosscutting area of Human Performance - Procedure Adherence because individuals did not 

follow CAP process, procedures, and work instructions [H.8]. (Section 1R12) 

• Green. The inspectors identified a violation of 10 CFR 50 Appendix B Criterion XVI, 

Corrective Actions, of very low safety significance because NextEra did not promptly identify 

a condition adverse to quality in December 2013 that involved a deviation from expected 

settling assumptions in the Seabrook Station design basis for the FSB. FSB elevation 

measurements were received by NextEra staff in December 2010 and in December 2013 

indicating that settling at some locations of the FSB was occurring. NextEra staff did not 
4 

Enclosure 

enter this condition, a condition adverse to quality, into their CAP until December 8, 2014, in 

response to questions from the inspectors. NextEra initiated AR02011698 to enter this issue 

in the CAP and AR02014116 to address their staff not entering this issue previously into the 

CAP. 

This performance deficiency was considered to be more than minor because it is associated 

with the Barrier Integrity Cornerstone objective to provide reasonable assurance that 

physical design barriers protect the public from radionuclide releases caused by 

accidents or events, and adversely affected the attribute of design control – structural 

integrity. Specifically, the inspectors concluded that the structural integrity of the FSB was 

potentially adversely affected because measured settling of the structure deviated from 

assumed design basis values. Also, this condition exceeded the ACI 349.3R-96 “Tier II 

structural criteria” of the Structures Monitoring Program and requires a structural evaluation. 

This issue was evaluated in accordance with IMC 0609, Appendix A, “The Significance 

Determination Process for Findings At-Power,” Exhibit 3, “Barrier Integrity Screening 

Questions,” and screened as very low safety significance (Green) because the observed 

degradation does not adversely impact structural or radiological barrier functions for the 

FSB. This finding is related to the cross-cutting area of Human Performance - Design 

Margins. The organization did not maintain the FSB within design margins and did not 

utilize the systematic and rigorous corrective action process. [H.6]. (Section 1R12) 

Cornerstone: Occupational Radiation Safety 

• Green. The inspectors identified a Green NCV of TS 6.7.1.a, “Procedures and Programs,” 

because NextEra failed to conduct appropriate periodic calibration of neutron survey 

instruments. Specifically, since 1996, NextEra assumed that an operability check of certain 

neutron survey instruments using an internal alpha check source would provide a calibration 

equivalent to that performed to a traceable neutron source of a known neutron flux, contrary 

to the periodic calibration frequency requirements specified in the Seabrook Station 

Radiation Protection Manual. NextEra’s immediate corrective actions included capturing 

this issue in its CAP (AR 01969397), calibrating all of the neutron survey instruments in 

question, and revising the neutron survey instrument operating procedure to require annual 

calibrations. 

This performance deficiency was determined to be more than minor because it adversely 

affected the Occupational Radiation Safety Cornerstone to ensure the adequate protection 

of the worker from radiation exposure. Additionally, it was similar to example 6.b in IMC 

0612, Appendix E, “Examples of Minor Issues,” which states that the performance deficiency 

is more than minor if a radiation protection instrument was not calibrated properly, and when 

recalibrated the as-found condition of the instrument was not within acceptance criteria for 

calibration and the accuracy was non-conservative. The issue was evaluated in accordance 

with IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination 

Process," and determined to be of very low safety significance (Green) since it was not an 

as low as is reasonably achievable (ALARA) issue and did not involve an overexposure or 

a potential overexposure and it did not affect any significant neutron exposures of plant 

personnel. The inspectors determined there was no cross-cutting aspect associated with 

this finding since it was not representative of current NextEra performance. Specifically, in 

accordance with IMC 0612, the causal factors associated with this finding occurred outside 

the nominal three-year period of consideration and were not considered representative of 

present performance. (Section 2RS5) 

 
5 

Enclosure 

REPORT DETAILS 

Summary of Plant Status

Seabrook operated at full power for the quarter, with the exception of a down-power to 94 

percent, on October 3, 2014, for performance of main turbine control valve testing. Documents 

reviewed for each section of this inspection report are listed in the Attachment. 

1. REACTOR SAFETY 

 Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 

1R01 Adverse Weather Protection (71111.01 – 1 sample) 

 Readiness for Seasonal Extreme Weather Conditions 

a. Inspection Scope

The inspectors performed a review of NextEra’s readiness for the onset of seasonal 

cold temperatures. The review focused on the emergency feedwater pump house, 

condensate storage tank, turbine building, service water (SW) cooling tower, and 

miscellaneous heating systems. The inspectors reviewed the Updated Final Safety 

Analysis Report (UFSAR), technical specifications (TSs), the seasonal readiness 

memorandum, and the CAP to determine specific temperatures or other seasonal 

weather that could challenge these systems, and to ensure NextEra personnel had 

adequately prepared for these challenges. The inspectors reviewed station procedures, 

including NextEra’s seasonal weather preparation procedure and applicable operating 

procedures. The inspectors performed walkdowns of selected systems to ensure station 

personnel identified issues that could challenge the operability of the systems during 

cold weather conditions. 

b. Findings

No findings were identified. 

1R04 Equipment Alignment 

.1 Partial System Walkdowns (71111.04Q – 4 samples) 

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: 

• ‘B’ safety injection system return to service on November 4, 2014 

• Startup feed pump return to service on November 19, 2014 

• ‘B’ train of control building air handling chilled water system unit 230A, during ‘A’ train 

unit 230B maintenance on December 1, 2014 

• ‘A’ and ‘B’ SW cooling tower while ocean SW out of service (OOS) for ‘A’ pump 

replacement on December 16, 2014 
6 

Enclosure 

The inspectors selected these systems based on their risk-significance relative to the 

reactor safety cornerstones at the time they were inspected. The inspectors reviewed 

applicable operating procedures, system diagrams, the UFSAR, TSs, work orders 

(WOs), condition reports (CRs), and the impact of ongoing work activities on redundant 

trains of equipment in order to identify conditions that could have impacted system 

performance of their intended safety functions. The inspectors also performed field 

walkdowns of accessible portions of the systems to verify system components and 

support equipment were aligned correctly and were operable. The inspectors examined 

the material condition of the components and observed operating parameters of 

equipment to verify that there were no deficiencies. The inspectors also reviewed 

whether NextEra staff had properly identified equipment issues and entered them into 

the CAP for resolution with the appropriate significance characterization. 

b. Findings

No findings were identified. 

.2 Full System Walkdown (71111.04S – 1 sample) 

a. Inspection Scope

During December 11 to 12, 2014, the inspectors performed a complete system 

walkdown of accessible portions of the ‘B’ emergency diesel generator (EDG) system 

to verify the existing equipment lineup was correct while the licensee was working on 

equipment on the ‘A’ train. The inspectors reviewed operating procedures, drawings, 

equipment line-up check-off lists, and the UFSAR to verify the system was aligned to 

perform its required safety functions. The inspectors also reviewed electrical power 

availability, component lubrication and equipment cooling, hanger and support 

functionality, and the operability of support systems. The inspectors performed field 

walkdowns of accessible portions of the systems to verify system components and 

support equipment were aligned correctly and operable. The inspectors examined the 

material condition of the components and observed operating parameters of equipment 

to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample 

of related action requests (ARs) and WOs to ensure NextEra appropriately evaluated 

and resolved any deficiencies. 

b. Findings

No findings were identified. 

1R05 Fire Protection 

 Resident Inspector Quarterly Walkdowns (71111.05Q – 5 samples) 

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material 

condition and operational status of fire protection features. The inspectors verified that 

NextEra controlled combustible materials and ignition sources in accordance with 

administrative procedures. The inspectors verified that fire protection and suppression 
7 

Enclosure 

equipment was available for use as specified in the area pre-fire plan, and passive fire 

barriers were maintained in good material condition. The inspectors also verified that 

station personnel implemented compensatory measures for OOS, degraded or 

inoperable fire protection equipment, as applicable, in accordance with procedures. 

• Turbine building fire areas/zones (TB-F-1A-Z, TB-F-1B-Z, TB-F-1C-Z, and TB-F-1-0) 

on October 17, 2014 

• Control building fire areas/zones (CB-F-3A-A, CB-F-3B-A, and CB-F-3C-A) on 

October 21, 2014 

• Turbine building fire areas/zones (TB-F-3-0 and TB-F-3-Z) on October 27, 2014 

• Control building fire areas/zones (CB-F-1D-A, CB-F-1E-A, CB-F-1F-A, and 

CB-F-1G-A) on December 4, 2014 

• Control building fire area/zone (CB-F-1A-A) on December 20, 2014 

1R11 Licensed Operator Requalification Program (71111.11Q and 71111.11A – 3 samples) 

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training during the conduct of a 

10 CFR 55.59 required requalification examination on December 2, 2014, which 

included spurious main steam isolation valve closure and a failure of the reactor to 

automatically trip. The inspectors evaluated operator performance during the simulated 

event and verified completion of risk significant operator actions, including the use of 

abnormal and emergency operating procedures. The inspectors assessed the clarity 

and effectiveness of communications, implementation of actions in response to alarms 

and degrading plant conditions, and the oversight and direction provided by the control 

room supervisor. The inspectors verified the accuracy and timeliness of the emergency 

classification made by the shift manager and the TS action statements entered by the 

shift technical advisor. Additionally, the inspectors assessed the ability of the crew and 

training staff to identify and document crew performance problems. 

b. Findings

No findings were identified. 

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed EDG 1B operability surveillance testing on November 1, 2014, 

main steam isolation valve testing on November 7, 2014 and SW valve timing testing on 

November 25, 2014. The inspectors observed test performance to verify that procedure 

use, crew communications, and coordination of activities between work groups similarly 

met established expectations and standards. 

b. Findings

No findings were identified. 
8 

Enclosure 

.3 Licensed Operator Requalification

a. Inspection Scope

On December 22, 2014, one NRC region-based inspector conducted an in-office 

review of results of licensee-administered annual operating tests for 2014, for 

Seabrook Station, Unit No.1 operators. (The biennial requalification written examination 

was not administered in 2014.) The inspection assessed whether failure rates were 

consistent with the guidance of NRC Manual Chapter 0609, Appendix I, and “Operator 

Requalification Human Performance Significance Determination Process.” The review 

verified that the failure rate (individual or crew) did not exceed 20%. 

• 2 out of 47 operators failed at least one section of the Annual Exam. The overall 

individual failure rate was 4.3% 

• 0 out of 9 crews failed the simulator test. The crew failure rate was 0.0% 

b. Findings

No findings were identified. 

1R12 Maintenance Effectiveness (71111.12 – 3 samples) 

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of 

maintenance activities on structure, system, and component (SSC) performance and 

reliability. The inspectors reviewed system health reports, CAP documents, 

maintenance WOs, and MR basis documents to ensure that NextEra was identifying 

and properly evaluating performance problems within the scope of the MR. For each 

sample selected, the inspectors verified that the SCC was properly scoped into the 

MR in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria 

established by NextEra staff was reasonable. As applicable, for SCCs classified as 

(a)(1), the inspectors assessed the adequacy of the goals and corrective actions to 

return these SSCs to (a)(2). Additionally, the inspectors ensured that NextEra staff was 

identifying and addressing common cause failures that occurred within and across MR 

system boundaries. 

• Fuel Storage Building (FSB) structural monitoring results. 

b. Findings

.1 Failure to Identify Conditions Adverse to Quality in the Fuel Storage Building Structure

Introduction: The inspectors identified a non-cited violation of 10 CFR 50 Appendix B 

Criterion XVI, Corrective Actions, of very low safety significance (Green) because 

NextEra staff did not promptly identify nine visual indications of structural problems 

representing conditions adverse to quality. These problems were observed by NextEra 

staff during a MR walkdown of the FSB on November 20, 2014, and documented in 

walkdown notes as conditions warranting entry into the corrective action process (CAP). 
9 

Enclosure 

However these problems were not entered into the corrective action program (CAP) 

to identify them as conditions adverse to quality until questioned by the inspectors. 

Description: NextEra’s Engineering Department Procedure 36180, Revision 5, 

“Structural Monitoring Program,” provides guidance to NextEra staff for completing 

periodic structural examinations to implement the requirements of 10 CFR 50.65. This 

procedure incorporates tiered examination criteria from ACI 349.3R-96, “Evaluation of 

Existing Nuclear Safety Related Concrete Structures” to guide NextEra staff in 

identifying visual indications of structural problems that warrant further evaluation. 

Procedure 36180, Revision 5, Paragraph 5.2.1 states that measurable discontinuities 

exceeding specified ACI ‘Tier II” quantitative limits shall be considered unacceptable and 

that further evaluation should consider the use of other inspection, testing or analytical 

tools to obtain condition and functional information of the structures in question. 

On December 18, 2014, in response to a request for the results of the last MR walkdown 

of the FSB, the inspectors received and reviewed the walkdown notes prepared by 

NextEra staff on November 20, 2014, after completing MR structural walkdowns in eight 

rooms within the FSB. The inspectors observed that NextEra staff documented nine 

visual conditions which they indicated needed to be entered into the CAP as Action 

Reports (ARs) but were not entered at that time. Additionally, NextEra staff indicated 

that four of the conditions exceeded the Tier II criteria and warranted further evaluation 

and examination to develop corrective actions. These four conditions documented a 

crack in a column exceeding 0.04 inches, a diagonal crack in an integral stairwell wall 

exceeding 0.04 inches, and multiple indications of cracks in a curb and spalled concrete 

supporting the east side of the deck in the New Fuel Storage Area (NFSA). The 

inspectors also identified NextEra staff had not issued a work order for this walkdown 

activity as per the guidance in their MR procedure. 

NextEra staff completed corrective actions to enter the issues into their CAP in 

AR10206192, AR020216238, AR020216225 and AR020168863 for further examination 

and evaluation. In initial review of these conditions, NextEra staff concluded that each of 

these structural elements remained functional. NextEra staff planned to conduct a Root 

Cause evaluation of the causes of these conditions in AR 2014325. 

Analysis: The inspectors determined that NextEra staff did not promptly identify the 

nine visual indications of structural problems as conditions adverse to quality by entering 

the issues into their CAP. This was a performance deficiency. It was reasonable to 

enter these issues into the CAP because NextEra staff documented in their MR 

walkdown notes that these conditions warranted entry into the CAP. 

This performance deficiency was considered to be more than minor because it is 

associated with the Barrier Integrity Cornerstone objective to provide reasonable 

assurance that physical design barriers protect the public from radionuclide releases 

caused by accidents or events, and affected the attribute of design control – structural 

integrity. Specifically, the inspectors determined the finding was more than minor 

because four conditions exceeded “Tier II” structural criteria, which indicated they 

required further investigation and evaluation to determine the causes. 
10 

Enclosure 

The issue was evaluated in accordance with IMC 609, Appendix A, “The Significance 

Determination Process for Findings At-Power,” Exhibit 3, “Barrier Integrity Screening 

Questions,” and screened as very low safety significance (Green) because the observed 

FSB degradation did not adversely impact structural or radiological barrier functions of 

the building. The finding is related to the cross-cutting area of Human Performance - 

Procedure Adherence because individuals did not follow CAP process, procedures, and 

work instructions [H.8]. 

Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions; states, in part, 

that “measures shall be established to assure that conditions adverse to quality, such 

as failures, malfunctions, deficiencies, deviations, defective material and equipment, 

and non-conformances are promptly identified and corrected.” Contrary to the above 

NextEra identified nine structural integrity conditions in FSB structures, but did not 

promptly enter the issues into their CAP on November 20, 2014, for structural 

evaluations until identified by the inspectors. NextEra staff took corrective actions 

to enter the issues into their CAP in AR02016225, AR020168863, AR02016238, 

AR10206192 and AR02014116 in January 2015. This violation is being treated as an 

NCV, consistent with Section 2.3.2 of the Enforcement Policy. The conditions and the 

violation were entered into the licensee’s corrective action process in the ARs listed. 

(NCV 05000443/2014005-01, Failure to Identify Conditions Adverse to Quality in 

the Fuel Storage Building Structure) 

.2 Fuel Storage Building Measurements

Introduction: The inspectors identified a violation of 10 CFR 50 Appendix B Criterion 

XVI, Corrective Actions, of very low safety significance (Green) because NextEra did 

not promptly identify a condition adverse to quality in December 2013, that involved a 

deviation from design assumptions regarding structure settling in the Seabrook Station 

design basis for the FSB. Specifically, FSB elevation measurements were received by 

NextEra staff in December 2013, which indicated settling was occurring in some 

locations of the FSB. NextEra staff did not enter this condition into their CAP until 

December 8, 2014, and did not further investigate the condition. 

Description: The Seabrook Station UFSAR Section 3.8.5.7 indicates that for seismic 

Category 1 structure foundations such as the FSB, no preoperational or in-service 

surveillance is required related to settling because these structures, which are founded 

on sound rock, do not have any potential areas of settlement or displacement which 

should be monitored. The inspectors reviewed reports received by NextEra staff 

providing the results of elevation readings taken from 2010 and 2013. These reports 

indicated elevation readings of -0.052” (reference point 15) in December 2010, and 

an elevation reading of -.102” (reference point 17) in December of 2013, indicating 

settlement. The measurement tolerance on the reported elevations was +/- 0.00012.” 

 
11 

Enclosure 

These measurements were received by NextEra staff in December 2010 and 

December 2013, as part of their initiative to monitor the FSB structure. These results 

indicated that FSB settlement was occurring in some measured locations, and these 

results would deviate from the site design basis as described in the Seabrook UFSAR, 

Section 3.8.5.7. In response to the inspectors’ inquiries regarding design allowances for 

building settlement, NextEra staff initiated AR02011698 on December 8, 2014, to identify 

this condition and track to completion an overall evaluation of the FSB structure. 

The inspectors also noted that NextEra Procedure 36180, “Structural Monitoring 

Program,” Revision 05, paragraph 5.2.1, described conditions which, if exceeded, 

required further evaluation. This procedure stated that passive settlements or 

deflections greater than the original design limits warranted evaluation. This procedure 

further stated that active settlements that are observed in a structure must be treated 

carefully as the source of cracking may continue to act or intensify. The inspectors 

concluded data indicating FSB settlement was available to NextEra staff, involved a 

condition that exceeded their “Tier II” criteria and warranted evaluation as part of their 

periodic MR activities. However this data was not identified in MR or structures system 

health report documents reviewed by the inspectors. NextEra initiated AR02011698 on 

December 8, 2014, to enter this condition into their CAP and AR AR02014116 to 

document not identifying this as a condition adverse to quality. NextEra assessed that 

the condition did not adversely impact the structural or radiological barrier functions for 

the FSB. 

Analysis: The inspectors determined that NextEra’s staff failure to identify a condition 

adverse to quality, involving measured FSB settlement in some locations that involved 

a deviation from expected settling assumptions in the Seabrook design basis, as 

described in Seabrook Station UFSAR, Section 3.8.5.7, was a performance deficiency 

within NextEra’s ability to foresee and correct. 

The performance deficiency was more than minor because it affected the Barrier 

Integrity Cornerstone objective to provide reasonable assurance that physical design 

barriers protect the public from radionuclide releases caused by accidents or events, 

and the condition adversely affected the Cornerstone Attribute of Design Control – 

structural integrity because data indicted some locations of the FSB were settling 

which would deviate from the design basis as described in the Seabrook UFSAR, 

Section 3.8.5.7. This issue was evaluated in accordance with IMC 0609, Appendix A, 

“The Significance Determination Process for Findings At-Power,” Exhibit 3, “Barrier 

Integrity Screening Questions,” and screened as very low safety significance (Green) 

because the observed degradation does not adversely impact structural or radiological 

barrier functions for the FSB. This finding is related to the cross-cutting area of Human 

Performance - Design Margins. Specifically, the organization did not maintain the FSB 

within design margins and did not utilize the systematic and rigorous corrective action 

process [H.6]. 

Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions; states, in part, 

that “measures shall be established to assure that conditions adverse to quality, such 

as failures, malfunctions, deficiencies, deviations, defective material and equipment, 

and non-conformances, are promptly identified and corrected.” Contrary to the above, 

NextEra did not promptly identify FSB elevation values, when available in December 

2010 and December 2013, as conditions adverse to quality because they represented 

deviations from design basis assumptions and did not perform evaluations of the effect 
12 

Enclosure 

of the elevation readings on the FSB. NextEra initiated AR02011698 on December 8, 

2014, to enter this condition into their CAP and AR AR02014116 to document not 

identifying this as a condition adverse to quality. This violation is being treated as an 

NCV, consistent with Section 2.3.2 of the Enforcement Policy. NextEra entered the 

condition into their corrective action process in the identified ARs. (NCV 

05000443/2014005-02, Failure to Identify and Evaluate FSB Settlement Data 

and the Design Basis) 

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 – 4 samples) 

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the 

maintenance and emergent work activities listed below to verify that NextEra performed 

the appropriate risk assessments prior to removing equipment for work. The inspectors 

selected these activities based on potential risk significance relative to the reactor safety 

cornerstones. As applicable for each activity, the inspectors verified that NextEra 

personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the 

assessments were accurate and complete. When NextEra performed emergent work, 

the inspectors verified that operations personnel promptly assessed and managed plant 

risk. The inspectors reviewed the scope of maintenance work and discussed the results 

of the assessment with the station’s probabilistic risk analyst to verify plant conditions 

were consistent with the risk assessment. The inspectors also reviewed the TS 

requirements and inspected portions of redundant safety systems, when applicable, to 

verify risk analysis assumptions were valid and applicable requirements were met. 

• ‘D’ battery charger cross-tie operations and capacity testing during switchyard 

maintenance on October 1, 2014 

• ‘A’ EDG fuel leak repair on October 15, 2014 

• Emergent issues on ‘A’ EDG during offsite power line 394 outage on October 20, 

2014 

• ‘B’ EDG digital reference unit and electronic governor replacement on October 30, 

2014 

b. Findings

No findings were identified. 

1R15 Operability Determinations and Functionality Assessments (71111.15 – 4 samples) 

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or nonconforming conditions: 

• Open ‘B’ phase heater element for CBA-H-372 on October 1, 2014 

• ‘A’ EDG cumulative deficiencies on October 20, 2014 

• ‘B’ EDG Windrock Engine analyzer report on December 16, 2014 

• Degraded mechanical penetration room seals on December 19, 2014 
13 

Enclosure 

The inspectors selected these issues based on the risk significance of the associated 

components and systems. The inspectors evaluated the technical adequacy of the 

operability determinations to assess whether TS operability was properly justified and 

the subject component or system remained available such that no unrecognized. 

increase in risk occurred. The inspectors compared the operability and design criteria in 

the appropriate sections of the TSs and UFSAR to NextEra’s evaluations to determine 

whether the components or systems were operable. Where compensatory measures 

were required to maintain operability, the inspectors determined whether the measures 

in place would function as intended and were properly controlled by NextEra. The 

inspectors determined, where appropriate, compliance with bounding limitations 

associated with the evaluations. 

b. Findings

No findings were identified. 

1R18 Plant Modifications (71111.18 – 2 samples) 

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed the temporary modifications listed below to determine whether 

the modifications affected the safety functions of systems that are important to safety. 

The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing 

results, and conducted field walkdowns of the modifications to verify that the temporary 

modifications did not degrade the design bases, licensing bases, and performance 

capability of the affected systems. 

• SB-V-9 leak repair temporary modification on December 4, 2014 

b. Findings

No findings were identified. 

.2 Permanent Modifications

a. Inspection Scope

The inspectors evaluated a modification to vital Bus 6 implemented by Engineering 

Change 271074, “Bus 6 Sync Check Relay Device 25R Replacement.” The inspectors 

verified that the design bases, licensing bases, and performance capability of the 

affected systems were not degraded by the modification. In addition, the inspectors 

reviewed modification documents associated with the upgrade and design change, 

including associated engineering changes, calculations, communication with the vendor, 

and industry operating experience. 

b. Findings

No findings were identified. 
14 

Enclosure 

1R19 Post-Maintenance Testing (71111.19 – 7 samples) 

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities 

listed below to verify that procedures and test activities ensured system operability and 

functional capability. The inspectors reviewed the test procedure to verify that the 

procedure adequately tested the safety functions that may have been affected by the 

maintenance activity, that the acceptance criteria in the procedure was consistent with 

the information in the applicable licensing basis and/or design basis documents, and 

that the procedure had been properly reviewed and approved. The inspectors also 

witnessed the test or reviewed test data to verify that the test results adequately 

demonstrated restoration of the affected safety functions. 

• Safety injection pump 6A static breaker testing on September 9, 2014 

• ‘A’ EDG fuel leak repair on October 16, 2014 

• SW pump P-41D packing maintenance on October 27, 2014 

• Reactor coolant pump 62V UV relay on-line setpoint verification on October 28, 2014 

• ‘B’ EDG 24-hour run failure on October 29, 2014 and retest on November 2, 2014 

• Control building air conditioning unit 230B testing following maintenance on 

December 1, 2014 

• ‘B’ primary component cooling water (PCCW) discharge check valve following 

internal inspection on December 10, 2014 

b. Findings

No findings were identified. 

1R22 Surveillance Testing (71111.22 – 2 samples) 

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of 

selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, 

and NextEra procedure requirements. The inspectors verified that test acceptance 

criteria were clear, tests demonstrated operational readiness and were consistent with 

design documentation, test instrumentation had current calibrations and the range and 

accuracy for the application, tests were performed as written, and applicable test 

prerequisites were satisfied. Upon test completion, the inspectors considered whether 

the test results supported that equipment was capable of performing the required safety 

functions. The inspectors reviewed the following surveillance tests: 

• Emergency power sequencer operability surveillance on October 2, 2014 

• ‘B’ SW cooling tower pump and discharge valve quarterly test on November 25, 2014 

(IST) 

b. Findings

No findings were identified.
15 

Enclosure 

2. RADIATION SAFETY 

Cornerstone: Occupational Radiation Safety 

2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 – 1 sample) 

a. Inspection Scope

From December 8 to 11, 2014, inspectors reviewed the control of in-plant airborne 

radioactivity and the use of respiratory protection devices. The inspectors used the 

requirements in 10 CFR Part 20, the guidance in RG 8.15, RG 8.25, NUREG-0041, 

and procedures required by TSs as criteria for determining compliance. 

Inspection Planning

The inspectors reviewed the UFSAR, TSs, and emergency planning documents to 

identify the location and quantity of respiratory protection devices stored for emergency 

use. 

Engineering Controls

The inspectors reviewed airborne monitoring protocols associated with four installed 

ventilation systems, and associated airborne monitor alarm set-points. 

Use of Respiratory Protection Devices

The inspectors reviewed records of air testing for supplied-air devices and self-contained 

breathing air (SCBA) bottles; and qualification records for five individuals for use of 

respiratory protection devices. 

Use of Respiratory Protection Devices

There were no opportunities to observe workers using respiratory protection devices 

during the inspection period. 

The inspectors reviewed: 

• the training curricula for users of respiratory protection devices 

• ten respiratory protection devices staged and ready for use in the plant 

• records of inspection and maintenance repairs for each type of respiratory protection 

device 

• training qualifications for onsite personnel assigned to repair respiratory protection 

equipment 

 
16 

Enclosure 

SCBA for Emergency Use

The inspectors reviewed: 

• the method used for refilling and transporting SCBA air bottles to and from the 

control room and the operations support center 

• the past two years of maintenance records for three SCBA units 

• the periodic air cylinder hydrostatic testing surveillance documentation 

b. Findings

No findings were identified. 

2RS4 Occupational Dose Assessment (71124.04 – 1 sample) 

a. Inspection Scope

The inspectors reviewed the monitoring and assessment of occupational dose by 

NextEra. The inspectors used the requirements in 10 CFR Part 20, the guidance 

in RG 8.13, RG 8.36, RG 8.40, TSs, and procedures required by TSs as criteria for 

determining compliance. 

Internal Dosimetry

The inspectors selected three whole body counts (WBCs) and evaluated whether 

the counting system was used to ensure appropriate sensitivity for the potential 

radionuclides of interest and included a sufficient radionuclide reference library identify 

the gamma-emitting radionuclides expected at the site. The inspectors evaluated how 

NextEra accounts for non-gamma emitting radionuclides in their internal dose 

assessments. 

NextEra has not documented any internal dose assessments using WBC results during 

the period reviewed. 

b. Findings

No findings were identified. 

2RS5 Radiation Monitoring Instrumentation (71124.05) 

a. Inspection Scope

From December 8 to 11, 2014, inspectors reviewed NextEra’s performance in assuring 

the accuracy and operability of radiation monitoring instruments used for occupational 

radiation safety. The inspectors used the requirements in 10 CFR 20; 10 CFR 50, 

Appendix I; TSs; offsite dose calculation manual; applicable industry standards; and 

procedures required by TSs as criteria for determining compliance. 

 
17 

Enclosure 

Portable Survey Instruments, Area Radiation Monitors (ARMs), Electronic Dosimetry, 

and Air Samplers/Continuous Air Monitors

The inspectors reviewed calibration documentation for at least one of each type of 

instrument. For portable survey instruments and ARMs, the inspectors reviewed 

detector measurement geometry and calibration methods for each type. 

The inspectors selected four portable survey instruments that did not meet acceptance 

criteria during calibration or source checks, and reviewed the corrective actions taken for 

instruments found out of calibration. 

b. Findings

Introduction. The inspectors identified a Green NCV of TS 6.7.1.a, “Procedures and 

Programs,” because NextEra failed to conduct appropriate periodic calibration of neutron 

survey instruments. Specifically, since 1996, NextEra assumed that an operability check 

of certain neutron survey instruments using an internal alpha check source would 

provide a calibration equivalent to that performed to a traceable neutron source of a 

known neutron flux, contrary to the periodic calibration frequency requirements specified 

in the Seabrook Station Radiation Protection Manual. 

Description. At Seabrook Station, the REM 500 neutron survey instrument is used for 

conducting neutron radiation surveys to ensure adequate protection of workers. Since 

1996, the licensee assumed that an operability check performed prior to each instrument 

use, using an internal radioactive source that emitted alpha particles, would provide an 

equivalent calibration to that performed using a National Institute of Science and 

Technology (NIST) traceable neutron source. As a result, the licensee did not calibrate 

the REM-500 neutron survey instruments by comparing the instrument response to a 

known acceptable neutron radiation flux. The operability response checks that had been 

performed since 1996 did not ensure the instrument performance was within established 

calibration acceptance criteria. 

During the month of August 2013, REM 500 neutron survey instrument serial number 

108 was used for performing five surveys during Independent Spent Fuel Storage 

Installation (ISFSI) cask loading, transport and storage work activities. The last 

successful operability check on the REM 500 neutron survey instrument, using the built 

in alpha check source, was August 6, 2013. This neutron survey instrument was 

previously calibrated by the manufacturer using a NIST calibrated neutron source on 

August 9, 2002. 

In July 2014, NextEra sent this instrument to the manufacturer for calibration due to an 

out of tolerance operability check. In August 2014, the manufacturer reported the “asfound” condition of this neutron meter to be outside the calibration acceptance criteria 

of +20%. The “as-found” results indicated this survey instrument had a non-conservative 

low response of -43%, -17%, -22% and -34% at the 1.04, 12.7, 101.5 and 1,000 mrem/hr 

delivered dose rates, respectively. Based on review of all of the neutron survey 

instrument calibration results, other REM 500 instruments were also outside of the 

calibration acceptance criteria, while successfully passing the operability response 

checks, confirming that the previous practice of using an alpha source operability check 

was not sufficient to ensure adequate calibration of the REM 500 neutron survey 

instruments. 
18 

Enclosure 

NextEra performed an impact evaluation to determine the possible consequences of the 

REM 500 Serial number 108 instrument use since the last successful operability check. 

The use of this instrument in August 2013 for ISFSI surveys resulted in establishing 

inaccurate and non-conservative neutron radiation dose rates for the spent fuel dry cask 

loading campaign work activities. The non-conservative neutron radiation dose rates 

did not result in any adverse impact on assessing occupational dose associated with 

neutrons. After the issue was identified by the inspectors, NextEra entered it into their 

corrective action program (AR 01969397), sent all affected REM 500 neutron meters to 

the manufacturer for calibration, revised the applicable instrument procedure to include 

a requirement to calibrate the instrument to a NIST traceable neutron source annually, 

and performed an impact evaluation on the out-of-calibration instruments past use. 

Analysis. The inspectors determined that failing to conduct appropriate periodic 

calibration of neutron survey instruments was a performance deficiency within NextEra’s 

ability to foresee and correct. Specifically, since 1996, NextEra assumed that an 

operability check of certain neutron survey instruments using an internal alpha check 

source would provide a calibration equivalent to that performed to a traceable neutron 

source of a known neutron flux, contrary to the periodic calibration frequency 

requirements specified in the Seabrook Station Radiation Protection Manual. This 

performance deficiency was determined to be more than minor because it adversely 

affected the Occupational Radiation Safety cornerstone to ensure the adequate 

protection of the worker from radiation exposure. Additionally, it was similar to 

example 6.b in IMC 0612, Appendix E, “Examples of Minor Issues,” which states that the 

performance deficiency is more than minor if a radiation protection instrument was not 

calibrated properly and when recalibrated the as-found condition of the instrument was 

not within acceptance criteria for calibration and the accuracy was non-conservative. 

The issue was evaluated in accordance with IMC 0609, Appendix C, "Occupational 

Radiation Safety Significance Determination Process," and determined to be of very 

low safety significance (Green) since it was not an ALARA issue and did not involve an 

overexposure or a potential overexposure and it did not affect any significant neutron 

exposures of plant personnel. The inspectors determined there was no cross-cutting 

aspect associated with this finding since it was not representative of current NextEra 

performance. Specifically, in accordance with IMC 0612, the causal factors associated 

with this finding occurred outside the nominal three-year period of consideration and 

were not considered representative of present performance. 

Enforcement. Technical Specification 6.7.1.a, “Procedures and Programs,” requires 

written procedures be established and implemented, including administrative procedures 

described in RG 1.33. RG 1.33 requires sites to establish and maintain radiation 

protection procedures. Seabrook Radiation Protection Manual, Revision 67, Figure 

1-3-1 specifies a semi-annual calibration frequency for portable survey instruments. 

Contrary to the above, the inspectors identified that the REM 500 portable neutron 

survey instruments were not appropriately calibrated on a semi-annual frequency. 

Specifically, the REM 500 portable neutron survey instrument in question had not been 

properly calibrated since August 9, 2002. After the issue was identified by the 

inspectors, NextEra entered it into their corrective action program (AR 01969397), 

sent all affected REM 500 neutron meters to the manufacturer for calibration, revised 

the applicable instrument procedure to include a requirement to calibrate the instrument 

to a NIST traceable neutron source annually, and performed an impact evaluation on the 

out-of-calibration instruments past use, which indicated no significant impact on 
19 

Enclosure 

assessing occupational neutron dose. Because this finding was of very low safety 

significance and was documented in the licensee’s corrective action program, this 

violation is being treated as an NCV, consistent with the NRC Enforcement Policy. 

(NCV 05000443/2014005-03, Failure to Periodically Calibrate REM-500 Neutron 

Survey Instruments)

4. OTHER ACTIVITIES 

4OA1 Performance Indicator Verification (71151) 

.1 Mitigating Systems Performance Index (3 samples) 

a. Inspection Scope 

The inspectors reviewed NextEra’s submittal of the Mitigating System Performance 

Index for the following systems for the period of November 1, 2013 to October 31, 2014: 

• Safety System Functional Failures (MS05) 

• Residual Heat Removal System (MS09) 

• Cooling Water System (MS10) 

To determine the accuracy of the performance indicator (PI) data reported during those 

periods, the inspectors used definitions and guidance contained in NEI Document 99-02, 

Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors 

also reviewed NextEra’s operator narrative logs, mitigating systems performance index 

derivation reports and basis documents, event reports, and NRC integrated inspection 

reports to validate the accuracy of the submittals. 

b. Findings

No findings were identified. 

.2 Occupational Exposure Control Effectiveness (1 sample) 

a. Inspection Scope

During December 8 to 11, 2014, the inspectors sampled licensee submittals for the 

occupational exposure control effectiveness PI for the period from the fourth quarter 

2013 through the third quarter 2014. The inspectors used PI definitions and guidance 

contained in the Nuclear Energy Institute (NEI) Document 99-02, “Regulatory 

Assessment Performance Indicator Guideline,” Revision 7, to determine the accuracy of 

the PI data reported. 

The inspectors reviewed condition reports, electronic personal dosimetry dose alarms, 

dose reports, and dose assignments for any intakes that occurred during the time period 

reviewed to determine if there were potentially unrecognized PI occurrences. 

b. Findings

No findings were identified. 
20 

Enclosure 

.3 Radiological Effluent Occurrences (1 sample) 

a. Inspection Scope

During December 8 to 11, 2014, the inspectors sampled licensee submittals for 

the radiological effluent TS/Offsite Dose Calculation Manual radiological effluent 

occurrences PI for the period from the fourth quarter 2013 through the third quarter 

2014. The inspectors used PI definitions and guidance contained in the NEI Document 

99-02, “Regulatory Assessment Performance Indicator Guideline,” Revision 7, to 

determine the accuracy of the PI data reported. 

The inspectors reviewed NextEra’s corrective action report database and reviewed 

reports generated since this indicator was last reviewed to identify any potential 

occurrences such as unmonitored, uncontrolled, or improperly calculated effluent 

releases that may have impacted offsite dose. The inspectors also reviewed the 

licensee’s methods for quantifying gaseous and liquid effluents and determining 

effluent dose. 

b. Findings

No findings were identified. 

4OA2 Problem Identification and Resolution (71152 – 3 samples) 

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, “Problem Identification and Resolution,” 

the inspectors routinely reviewed issues during baseline inspection activities and plant 

status reviews to verify that NextEra entered issues into the CAP at an appropriate 

threshold, gave adequate attention to timely corrective actions, and identified and 

addressed adverse trends. In order to assist with the identification of repetitive 

equipment failures and specific human performance issues for follow-up, the inspectors 

performed a daily screening of items entered into the CAP and periodically attended 

condition report screening meetings. 

b. Findings 

No findings were identified. 

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by Inspection 

Procedure 71152, “Problem Identification and Resolution,” to identify trends that might 

indicate the existence of more significant safety issues. In this review, the inspectors 

included repetitive or closely-related issues that may have been documented by NextEra 

outside of the CAP, such as trend reports, performance indicators, major equipment 

problem lists, system health reports, MR assessments, and maintenance or CAP 
21 

Enclosure 

backlogs. The inspectors also reviewed NextEra’s CAP database for the third and fourth 

quarters of 2014 to assess action requests/condition reports written in various subject 

areas (equipment problems, human performance issues, etc.), as well as individual 

issues identified during the NRCs daily condition report review (Section 4OA2.1). The 

inspectors reviewed Seabrook Station’s Self-Evaluation and Trending Analysis Report 

for third quarter of 2014, conducted under PI-AA-207-1000, Station Self-Evaluation and 

Trending Analysis, Revision 1, to verify that NextEra personnel were appropriately 

evaluating and trending adverse conditions in accordance with applicable procedures. 

b. Findings and Observations 

No findings were identified. 

The inspectors evaluated a sample of departments that are required to provide input into 

the quarterly trend reports, which included Operations and Maintenance. This review 

included a sample of issues and events that occurred over the course of the past two 

quarters to objectively determine whether issues were appropriately considered or ruled 

as emerging or adverse trends, and in some cases, verified the appropriate disposition 

of resolved trends. The inspectors verified that these issues were addressed within the 

scope of the CAP, or through department review and documentation in the quarterly 

trend report for overall assessment. For example, while potential adverse trends that 

are included in the quarterly trend reports are often identified through the use of 

statistical methods to identify statistically significant issues that reach a predetermined 

threshold, cognitive trends are often identified by staff or collectively during review by the 

Management Review Committee while screening ARs. The inspectors noted that quite 

often, cognitive trends are not ultimately documented in the trend report as they are 

appropriately assigned trend codes, but do not screen into the report based on the 

established thresholds. One such example involved multiple alarms associated with 

the loose parts monitoring system (LPMS), which revealed some potential equipment 

problems as the source. These LPMS issues were identified in action requests, had 

trend codes applied, but were dispositioned within the work control system. Another 

example involved several trips of breaker thermal overloads for various loads that were 

entered into the CAP and ultimately resolved through the work management system. 

While these issues were processed through the CAP and the work management system, 

the inspectors noted they were assigned trend codes to ensure they could be identified 

as potential trends through the use of statistical tools and enable the staff an opportunity 

to properly assess these issues, if applicable, within the trending process. The 

inspectors also noted that a multitude of fire protection deficiencies had occurred 

throughout the past two quarters, ranging from fire door issues, fire seal delaminations, 

and fire alarm circuit problems, and verified that the trend reports had appropriately 

identified these fire deficiencies as an adverse trend in the third quarter report. As a 

result, the inspectors concluded that NextEra’s trending process, as well as the CAP 

(through the use of trend codes) had the appropriate sensitivity and thresholds to identify 

and assess adverse trends. 

During review of the trend report, the inspectors assessed the appropriateness of an 

adverse trend that was closed out in the third quarter report in the area of work control 

supervisor human errors. The inspectors noted that this trend shared common attributes 

with fourth quarter human performance issues (see Section 1R22) associated with an 

emergency power sequencer (EPS) surveillance, particularly related to personnel not 
22 

Enclosure 

being present during pre-job briefs. However, the inspectors noted extensive and 

appropriate corrective actions had resulted in overall improvement in the area of 

pre-job briefs and supervisory oversight, notwithstanding anecdotal evidence supplied 

by this discrete EPS human performance issue that occurred in the fourth quarter. 

Also, the inspector noted corrective actions for this fourth quarter EPS issue included 

communication of improved management expectations, which were considered 

reasonable and appropriate. Overall, the inspectors verified that individual issues and 

trends discussed in this section were evaluated and determined to be of minor safety 

significance and, as documented in Section 1R22 of this report, determined that the 

human performance issues did not result in the identification of regulatory findings. 

.3 Annual Sample: Operability Determinations 

a. Inspection Scope

The inspectors performed an in-depth review of NextEra’s corrective actions for 

longstanding weaknesses in the performance of operability determinations, conducted 

under NextEra procedure EN-AA-203-1001, Operability Determinations/Functionality 

Assessments, Revision 18. While inspectors had previously evaluated issues regarding 

operability determinations in the root cause analysis (AR1919736) and associated 

corrective actions for the SW leak in August 2013, the inspectors on several occasions, 

had identified weaknesses in various attributes of the operability determination (OD) 

process. As a result, the inspectors assessed several ODs to ensure consistency with 

the applicable procedure. In particular, the inspectors assessed the documented basis 

for operability, any supporting information that was considered and/or discounted, as 

well as comments provided by the management review committee, and evaluated these 

actions to the requirements of NextEra’s CAP and 10 CFR 50, Appendix B. In addition, 

the inspectors interviewed NextEra personnel to assess the effectiveness of the 

implemented corrective actions. 

b. Findings and Observations 

No findings were identified. 

The inspectors evaluated several ARs generated since the August 2013 service water 

leak operability issue was identified as noted above. This review focused on various 

aspects of the operability process to assess the effectiveness and scope of corrective 

actions. This included bases and supporting information for immediate operability 

evaluations as detailed in the CAP; if applicable, prompt operability evaluations and 

associated documentation and bases; and MRC’s review of operability statements and 

actions to address weaknesses, if identified. Some examples included: 

- AR 01953499: MRC identified condition report for Operations to revise operability 

screening 

- AR 01971462: ‘A’ Boric acid transfer pump trip 

- AR 01987810: ‘B’ Emergency diesel generator exhaust silencer pipe support 

corrosion 

- AR 01997819: ARs required rescreening by shift manager 

- AR 01997929: Self-assessment regarding timeliness of prompt operability 

determinations and functionality assessments 

- AR 02000487: ‘A’ emergency diesel generator loose air intake manifold cap screws 
23 

Enclosure 

The inspectors identified improvements in the functioning of MRC to return operability 

determinations that did not contain adequate rigor or provide appropriate bases in 

support of operability. In addition, the inspectors verified that the operability screenings 

of specific ARs reviewed for this assessment contained appropriate information that 

supported operability, and that these determinations were performed in accordance with 

applicable procedures. 

.4 Annual Sample: Review of Corrective Actions for Alkali-Silica Reaction Affected 

Structures

a. Inspection Scope

During the week of October 20, 2014, NRC inspectors from Region I and a structural 

engineer from the Division of License Renewal, NRR, witnessed testing conducted at the 

Ferguson Structural Engineering Laboratory at the University of Texas – Austin (UTAustin) in support of the Seabrook Alkali-Silica Reaction (ASR) Project Corrective Action 

Plan. Specifically, the inspectors observed the load testing of reinforcement anchorage 

(lap splice) beam No. A3, performed on October 22, 2014. The inspectors verified 

compliance with associated testing program procedures and quality assurance/control 

requirements; discussed recent testing results and the overall status of the test program, 

including projected milestones with the responsible staff; ensured testing results were 

appropriately reflected into current open Prompt Operability Determinations (PODs) for 

ASR-affected Seabrook structures; and, examined the newly fabricated instrument beam 

and associated monitoring devices. 

During this inspection period, the inspectors were also on-site to review station activities 

related to routine sampling and analysis of groundwater. Groundwater sampling is being 

conducted by the licensee to: 1) monitor the movement of tritium contamination 

inadvertently released via a spent fuel pool (SFP) cask handling/dewatering area liner 

leak that was identified in mid-1999; 2) monitor for potentially “aggressive” groundwater 

that may have an adverse impact on below grade reinforced concrete structures; and, 3) 

satisfy commitments to NEI 07-07, “Industry Ground Water Protection initiative,” 

guidance as it pertains to monitoring site hydrology and migration of ground 

contaminants. The inspectors reviewed groundwater well sample results and discussed 

past, current and future groundwater monitoring activities with the Seabrook Station 

Chemistry Manager. 

b. Findings

No findings were identified. 

Groundwater Monitoring Review Observations

The inspectors observed that the scope of NextEra’s groundwater monitoring program 

has evolved over the past 15 years. An expanded groundwater sampling effort was 

initiated following the discovery of a SFP cask handling/dewatering area liner leak in 

September 1999. Groundwater radionuclide monitoring (principally tritium) continues to 

the present due to this legacy issue. The results of this monitoring program are reported 

to the NRC on an annual basis. Currently, a total of 27 monitoring wells located within 

the site boundary are sampled annually and the quantification of any measurable 
24 

Enclosure 

radionuclides is reported to the NRC in the Annual Radionuclide Effluent Release 

Report. This annual report includes a listing of the groundwater monitoring wells 

(by identifier and location) and the associated radionuclide activity concentration 

(picocuries/liter) measured for each sample location. The most recent published report 

(2013 sample results) is dated April 29, 2014 (ML14121A399). Following resolution of 

the SFP leak, NextEra initiated a dewatering campaign in 2004 to contain and mitigate 

the tritium plume. This groundwater dewatering effort included removal of groundwater 

in-leakage from the containment enclosure area, primary auxiliary building, emergency 

feed water pump house, residual heat removal equipment vault, and the ‘B’ electrical 

tunnel. Water removed from these areas has totaled, at times, over 3000 gallons per 

day (gpd). Along with the Unit 1 dewatering campaign, approximately 32,000 gpd is 

pumped from the Unit 2 containment building area and discharged via the monitored 

(for radionuclides) storm water drainage system. Pumping groundwater from Unit 2 has 

assisted in the containment of the Unit 1 tritium plume and preventing its migration off 

site (reference Seabrook Station’s Final Applicant’s Environment Report- Operating 

License Renewal Stage, ML101590092). 

In support of license renewal activities and the current Structures Monitoring Program 

(SMP), NextEra implemented additional groundwater sampling of five on-site wells 

(SW-1, SW-2, SW-3, SD-1 and SD-2). The SMP groundwater sampling and associated 

chemical analysis supports NRC guidelines for monitoring for potential “aggressive” 

groundwater conditions consistent with NUREG 1801, “Generic Aging Lessons Learned 

(GALL) Report,” Section XI.S7, and “Regulatory Guide 1.127, Inspection of WaterControl Structures Associated with Nuclear Power Plants.” “Aggressive” groundwater is 

identified in the GALL report as having measured pH <5.5, chlorides >500 ppm, or 

sulfates >1500 ppm. “Aggressive” groundwater potentially neutralizes normally high 

alkali content concrete and can contribute to the oxidation of carbon steel reinforcing 

bars. The initial sampling for aggressive groundwater was conducted in September 

2009 and continued into the first quarter of 2011. Based on the indications of chlorides, 

Seabrook is sampling for four consecutive quarters every five years in accordance with 

NextEra’s SMP groundwater monitoring program. 

The inspectors determined that the NextEra staff planned to conduct their next series of 

four quarterly samples beginning in July 2014. The initial SMP groundwater sampling in 

September 2009 indicated that wells SW-1, SW-2, and SW-3 contained potentially 

aggressive groundwater based on a chloride content range of 2,300 to 2,600 ppm; 

however, the sulfate content was only 34 to 92 ppm and the pH 5.8 to 6.7. The 

inspector learned from the Chemistry Manager that during the baseline groundwater 

monitoring period (early 2010), a buried SW pipe leak occurred in a section buried 

between Units 1 and 2, spilling several hundreds of gallons of ocean water into the 

surrounding soils before being isolated. The inspectors observed that the groundwater 

monitoring data illustrated the affected wells (BD-6, SD-5, SW-1, SW-2 and SW-3) had 

chloride content spikes that ranged from 2,600 to 19,000 ppm and are attributable to the 

seawater contamination. Typical saltwater (ocean) chloride content is in the 19,000 to 

20,000 ppm range. Further inspector review of the sample data and associated site 

hydrological studies identified that the below grade concrete structures more likely to be 

impacted by the ocean water spill from 2010 were associated with Unit 2 (SW-3, SD-5, 

BD-6). The two wells (SW-2 and SD-5) with chloride spikes as high as 19,000 ppm in 

the 3rd quarter of 2010 had decreased to 770 ppm and 15,000 ppm by the 1st quarter of 
25 

Enclosure 

2011. The Unit 1 fuel storage building (SW-1) and waste processing building (SW-4) 

monitoring wells indicated some continued elevated chloride levels, but was trending 

downward due to the ongoing dewatering efforts. 

In 2008, NextEra contracted for a hydrological survey, consistent with the guidelines 

published in NEI 07-07, “Industry Ground Water Protection Initiative – Final Guidance 

Document.” The results of the initial hydrological study were documented in a 

proprietary report. Based upon the commencement of pumping of groundwater from 

a site construction dewatering well (designated well emergency feedwater (EFW)) in 

October 2013, NextEra plans to update their 2008 hydrological survey, consistent with 

NEI 07-07 guidelines, to identify the impact of this recent dewatering effort on groundwater radiological plume migration. Based upon plant walk-through observations by 

the inspectors, the EFW well pumping regime (dewatering at a rate of between 14-15 

gallons per minute) has significantly reduced the water infiltration into the adjacent ‘B’ 

Electrical Tunnel. The inspector noted that the water being removed from the EFW well 

was being discharged to the site storm water drainage system where it was continuously 

monitored prior to release to the environment. 

Based upon discussions with NextEra personnel, the monitoring wells SW-1 and SW-3 

(located within close proximity to the Unit 1 spent fuel pool) were identified as sentinel 

wells (considered the best indicators of the groundwater tritium contamination plume) 

and typically had indicated between 2,000 to 5,000 picocuries/liter tritium. The water 

being pumped from the EFW construction dewatering well averaged between 1200 to 

1600 picocuries/liter tritium. None of the wells on-site were being used for potable 

(drinking) water and all of the wells were indicating radioactivity levels significantly 

below the US Environmental Protection Agency (EPA) drinking water limit of <20,000 

picocuries/liter. 

In summary, the inspectors concluded that NextEra’s various groundwater sampling 

and monitoring processes were in conformance with current regulatory requirements, 

standards, and station commitments. In addition to the elevation differences (the site 

grade is 20 feet above mean sea level), the historic monitoring data and trend results 

provided reasonable assurance that the groundwater currently being pumped from 

onsite monitoring wells or removed for below grade structures is freshwater infiltrating 

from initial construction/excavation exposed aquifers and not saltwater from the 

surrounding tidal saltwater marshes. 

UT-Austin Testing Program Observations

The inspectors witnessed the performance of load testing of reinforcement anchorage 

(e.g. lap splice) beam No. A3. Beam A3 was fabricated on July 9, 2013, and had 

undergone controlled accelerated ASR aging per the UT-Austin testing program since 

that time. Beam expansion measurements and core sample material property testing 

data obtained a few days prior to the October 22 load test by NextEra identified the 

following: core compressive strength 3470 psi (compared to the 28-day cylinder 

strength of 4500 psi); core Modulus of Elasticity (Ec) 850 ksi (compared to the 28-day 

cylinder Ec of 3980 ksi); xy-strain (߳xy) 0.06 percent; and, z-strain (߳z) 2.02 percent. 

Beam A3 was tested in accordance with MPR Project 0326-0063, Procedure 5-7, 

“Structural Testing of Shear and Anchorage Specimens,” Revision 2, dated 5/28/2014. 

Beam failure occurred at a load of approximately 271,000 pounds (compared to 
26 

Enclosure 

control beam A7 that failed at 251,000 pounds). No testing anomalies were identified. 

Preliminary review of the large specimen load testing results indicated that beam 

structural performance (measured by load carrying capacity prior to failure) was 

generally inversely proportional to the extracted cores’ material properties determined 

just prior to testing. Specifically, concrete core test results indicated reduced 

compressive strength and reduced Modulus of Elasticity, but the overall test specimen 

structural performance remained unaffected or slightly improved. ASR-affected 

specimens tested, to date, exhibited increased rigidity proportional to the increased 

degree of (or time subjected to) ASR aging. Overall, the inspectors observed proper 

procedural adherence, appropriate test coordination and proper communications 

exhibited by the testing staff, supervisory personnel and quality assurance overseers. 

Based upon the large specimen monitoring and testing completed, to date, the NextEra 

staff has concluded that it is necessary to modify the test program to address the 

apparent plateauing of the x- and y-plane expansion and the associated continuing 

expansion in the z-direction (through-wall) of all large test specimens. Deep pin 

(cast in-place) expansion measurements in all three planes have been used to compare 

the xy-plane combined crack index (CCI) data for validation. Based upon the observed 

plateauing of xy-strain (determined by deep pin direct measurement) in all of the large 

test specimens, the NextEra staff has preliminarily concluded that the CCI method will 

be of minimal value for long-term ASR monitoring. Consequently, an additional large 

specimen beam was fabricated in June 2014 and instrumented with three different types 

of extensometers to validate future application/installation of extensometers in Seabrook 

Station ASR-affected reinforced concrete structures. An extensometer is an instrument 

that measures the amount of movement (e.g., expansion or elongation) in a particular 

direction. The NextEra staff indicated that the testing program’s instrument beam 

extensometer outputs will be compared to the installed deep pin expansion measurements to identify the most reliable and accurate device for long term z-strain ASR 

monitoring. 

Based upon overall testing program progress, to date, NextEra staff projected to have 

the large specimen reinforcement anchorage and shear testing completed by the third 

quarter of 2015. Following the completion of testing, NextEra currently plans to 

summarize the results in a written report, update the current Seabrook Station 

ASR-affected reinforced concrete building structural evaluations and PODs, revise 

the Seabrook Structures Monitoring Program, and submit a license amendment, if 

appropriate, in 2016. The inspectors concluded that the current ASR-affected structures 

PODs remained valid and continued to provide reasonable assurance of operability 

because none of the testing program results or insights gained, to date, undermined 

the engineered margins or assumptions used in the PODs. 

4OA6 Meetings, Including Exit

On January 29, 2015, the inspectors presented the inspection results to Mr. Dean 

Curtland, Site Vice President, and other members of the Seabrook Station staff. The 

inspectors verified that no proprietary information was retained by the inspectors or 

documented in this report. 

ATTACHMENT: SUPPLEMENTARY INFORMATION
A-1 

Attachment 

SUPPLEMENTARY INFORMATION 

KEY POINTS OF CONTACT 

Licensee Personnel

D. Curtland, Site Vice President 

R. Dodds, Plant General Manager 

P. Allen, Radiation Protection Technician 

B. Brown, NextEra Engineering 

V. Brown, Senior Licensing Engineer 

J. Buyak, Radiation Protection Technician 

J. Connolly, Site Engineering Director 

K. Douglas, Maintenance Director 

P. Dundin, Operations Shift Manager 

D. Flahardy, Radiation Protection Manager 

D. Hampton, Nuclear Oversight Auditor 

J. Klempa, System Engineer 

E. Kotkowski, Control room operator 

B. McAllister, Nuclear Engineer 

L. Michaud, Work Week Manager 

M. Nadeau, Radiation Protection Dosimetry Supervisor 

M. Ossing, Licensing Manager 

E. Pigott, Operations Training Supervisor-Continuing Training 

D. Ritter, Operations Director 

D. Robinson, Chemistry Manager 

T. Smith, Radiation Protection Supervisor 

T. Waechter, Nuclear Plant Shift Manager 

N. Watts, Senior Reactor Operator 

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED 

Opened/Closed

05000443/2014005-01 NCV Failure to Identify and Evaluate Class 1 Structural 

Conditions Adverse to Quality (Section 1R12) 

 

05000443/2014005-02 NCV Failure to Identify and Evaluate FSB Deviation 

from Design Basis (Section 1R12) 

 

05000443/2014005-03 NCV Failure to Periodically Calibrate REM-500 Neutron 

Survey Instruments (Section 2RS5) 
A-2 

Attachment 

LIST OF DOCUMENTS REVIEWED 

Section 1R01: Adverse Weather Protection

Procedures

OP-AA-102-1002, Seasonal Readiness, Revision 5 

OS1200.03, Severe Weather Conditions 

Condition Reports

01989778 01992418 02000138 

Miscellaneous

Seasonal Readiness Memo to Mano Nazar dated 9/24/14 

UFSAR Section 8 

Section 1R04: Equipment Alignment

Procedures

OS1005.05, Safety Injection System Operation, Revision 26 

OS1016.05, Service Water Cooling Tower Operation, Revision 28 

OS1026.11, Operating DG 1B Jacket Cooling Water System, Revision 10 

OS1023.51, Control Room Ventilation and Air Conditioning System Operation, Revision 22 

OX1405.07, Safety Injection Quarterly and 18 Month Pump Flow and Valve Test, Revision 13 

OX1436.20, Startup Feed Pump Monthly Valve Operability Surveillance, Revision 2 

Condition Reports

01869005 02004748* 02004780* 02013363* 02013369 

* NRC identified 

Maintenance Orders/Work Orders

40234817 40245048 40111372 40196116 40042857 94109967* 

94109969 94072242 

Drawings

1-CBA-B20308, Control Building Air Conditioning System Safety Related Chilled Water System 

 Train ‘B’ Detail, Revision 7 

1-DG-B20463, Diesel Generator Lube oil System Train ‘B’ Detail, Revision 20 

1-DG-B20464, Diesel Generator Fuel Oil System Train ‘B’ Detail, Revision 17 

1-DG-B20465, Diesel Generator Starting Air System Train ‘B’ Detail, Revision 25 

1-DG-B20466, Diesel Generator Cooling Water System Train ‘B’ Detail, Revision 22 

1-DG-B20467, Diesel Generator Intake Exhaust & Crankcase Vacuum System Train ‘B’ Detail, 

 Revision 8 

Section 1R05: Fire Protection

Miscellaneous

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1A-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1D-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1E-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1F-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1G-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-3A-A 
A-3 

Attachment 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-3B-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-3C-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1A-Z 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1B-A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1C-Z 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1-0 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-3-0 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-3-0 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-2-F-Z 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-3-Z 

Section 1R11: Licensed Operator Requalification Program

Procedures

ER 1.1, Classification of Emergencies, Revision 52 

ER 1.2, Emergency Action Plan Activation, Revision 61 

OX1426.23, Emergency Diesel Generator 1B 24 Hour Load Test and Hot Restart Surveillance, 

Revision 18 

OX1430.02, Main Steam Isolation Valve Quarterly Test, Revision 16 

Maintenance Orders/Work Orders

40279900 

Miscellaneous

Seabrook Technical Specifications 

Section 1R12: Maintenance Effectiveness

Procedures

MA 3.5, Post Maintenance Testing, Revision 14 

OS1046.18, 4.16 KV Breaker Racking Operations, Revision 11 

OX1456.21, Train A ESFAS Slave Relay K601 Quarterly Go Test, Revision 10 

PI-AA-104-1000, Corrective Action, 07/18/14 

Technical Procedure 36180, Structural Monitoring Program, Revision 4, 7/29/13 

Technical Procedure 36180, Structural Monitoring Program, Revision 5, 10/14/14 

Action Requests

02014116* 

02014120* 

02011698* 

02011698 

01921217 

01920005 

01992998 

00196973 

01986980 

01831660 

01617960 

00197551 

01992998 

01977456 

00581434 

00396307 

00004916 

00197551 

00196973 

01986980 

04-05036 

02016192* 

02016238* 

02016225* 

02016863* 

*ARs initiated in response to this inspection 
A-4 

Attachment 

Engineering Evaluations, Analyses, Calculations & Standards:

ACI 349.3R-02, Evaluation of Existing Nuclear Safety-Related Concrete Structures, 

Reapproved 2012 

Apparent Cause Evaluation for AR 196973 

Apparent Cause Evaluation Report for AR 1977456 

Revised Safety Culture Evaluation for CR1976944, 1977233 and 1977456 

Seabrook Station Maintenance Rule (a)(1) Improvement Plan For CE-01, CB-01, CS-01, CT-01, 

CST-01, DGB-01, EF-01, EM-01, FB-01, ITS/DTS-01, MF-01, SWB-01, PB-01, RV-01 and 

WB-01, Degradation of Concrete, Revision 05, 9/18/2014; AR581434, AR1664399, 

AR1636419, AR1687932-(a)(1) Plan, AR1757861, AR1804477, AR1952162 

Seabrook Calculation FB-18, Revision 6, Title: Mats & Walls Below Grade, Fuel Storage 

 Building 

Engineering Change Documents:

EC 0000249139 002, Spent Fuel Pool Gate Latch Modification – AR 00396307, 10/4/11 

36180, Rev.2, SMP FORM 2, Structural Deficiency Report – Initial Discovery: 

CST-SVR-D-001, 11/7/13 CST-SVR-D-002, 11/7/13 CST-SVR-D-003, 11/7/13 

CB105-D-001, 11/7/13 CB105-D-002, 11/7/13 CP101-D-001, 10/10/13 

CP101-D-002, no date CP101-D-003, 10/10/13 CP101-D-003, no date 

PB207-D-001, 6/29/11 PB206-D-001, 6/28/11 MF102-D-001, 9/20/11 

36180, Rev.2, SMP FORM 3, Structural Deficiency Report – Engineering Staff Review: 

CST-SVR-D-001, 11/7/13 CST-SVR-D-002, 11/7/13 CST-SVR-D-003, 11/7/13 

CB105-D-001, 11/7/13 CB105-D-002, 11/7/13 CP101-D-001, 10/21/13 

CP101-D-002, 10/21/13 CP101-D-003, 10/21/13 PB207-D-001, 7/20/11 

PB206-D-001, 7/20/11 MF102-D-001, 10/18/11 

36180, Rev.2, SMP FORM 4, Structural Deficiency Report – Follow-up Inspection: 

MF102-D-001, MF102-D-002, MF102-D-003, MF102-D-004 

Program Documents:

NextEra Energy Seabrook, Technical Procedure, Structural Monitoring Program, 36180, 

Revision 5, 10/14/14 

NextEra Energy Seabrook, Technical Procedure, Structural Monitoring Program, 36180, 

Revision 4, 7/29/13 

Procedures:

NextEra Energy, Nuclear Fleet Administrative Procedure, PI-AA-104-1000, 

CORRECTIVE ACTION, 07/18/14 

Operability Determinations:

Prompt Operability Determination for AR581434, Revision 000 

Prompt Operability Determination for AR581434, Revision 001 

Prompt Operability Determination for AR581434, Revision 002 
A-5 

Attachment 

Vendor Inspection Contract:

Contractor Metrology Inspection Services Within the Cooling Pool of the FSB, 12/16/13 

Work Orders: 

0543784, 7/10/06, 1-BM-INSP-BLDG-INTG-FSB-000 Building Maintenance 

Miscellaneous Documents:

Seabrook Station UFSAR, Revision 16, Section 3.8, Page 148 – 153, 

Design Of Structures, Components, Equipment AND Systems, Design of Category I 

Structures U.S. Nuclear Regulatory Commission, Regulatory Guide 1.13, 

Spent Fuel Storage Facility Design Basis, Revision 2, March 2007 

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

OP-AA-102-1003, Guarded Equipment, Revision 5 

Miscellaneous

Maintenance Rule (a)(4) Risk Profile for Work Week 1439-05 

Maintenance Rule (a)(4) Risk Profile for Work Week 1442-08 

Maintenance Rule (a)(4) Risk Profile for Work Week 1443-09 

Condition Reports

02000207 

Maintenance Orders/Work Orders

40279916 

Miscellaneous

PRA-301, MR (a)(4) Process for On-Line Maintenance Group Instruction, Revision 0 

WM-AA-100-1000, Work Activity Risk Management, Revision 1 

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 19 

OX1461.03, SEPS Operational Readiness Status Surveillance, Revision 01 

OX1446.01, AC Power Source Weekly Operability Surveillance, Revision 23 

Condition Reports

00017982 00018003 01868380 01986793 01995888 01998684 

02000487 02000545 02000743 02000743 02003027 02003067 

02003427 02013363 02013369 02013417 02013442 02013457 

02013458 

Maintenance Orders/Work Orders

40191176 40287143 40347648 40347646 40346051 
A-6 

Attachment 

Miscellaneous

Foreign Print FP 22620, Seismic Test Report, Issue No. 6 

Plant Engineering Action Plan Register, EDG-B Main Bearings #7 and #8 Vibration Indication 

 During Engine Analysis Collection 

PM Technical Basis – New PM Activity to Replace Heaters on 1-CBA-H-371 and 372 

Periodically, Dated 2/27/08 

Section 1R18: Plant Modifications

Procedures

MS0526.09, On Stream Leak Repairs, Revision 6 

Condition Reports

00394022 01907792 01944267 01944282 02003019 02004186 

02004461 02004690 02005370 

Maintenance Orders/Work Orders

01383187 40204470 

Miscellaneous

Engineering Change 282744, 1-SB-V-9 Temporary Leak Repair, Revision 3 

FP100873, 1-SB-V-9 Team Inc. Clamp Design Calculations, Revision 1 

Drawings

1-NHY-310102, 4160 Bus 1-E6 RAT Incoming Line, Sheet A72m, Revision 0 

1-NHY-310102, 4160 Bus 1-E6 RAT Incoming Line, Sheet A72n, Revision 3 

1-NHY-310102, 4160 Bus 1-E6 Potential Xfmrs, Sheet A73j, Revision 1 

1-SB-B20626, Steam Generator Blowdown (Blowdown Flash), Revision 18 

Section 1R19: Post-Maintenance Testing

Procedures

LS0558.03, 4.16KV Motor – Routine Testing, Inspection and PM, Revision 9 

LS0563.23, Type IAC Overcurrent Relay Inspection, Testing and PM, Revision 9 

LS0563.186, Trip Relay Checks, Revision 0 

LS0564.34, 4160 Volt Static Motor Testing, Revision 8 

MS0523.56, Ingersoll-Dresser Ocean Service Water Pump removal and Installation, 

Revision 12 

MS0539.37, Emergency Diesel Generator Engine Cylinder Head Maintenance, Revision 8 

OS1016.04, Service Water Train B Operation, Revision 19 

OS1023.51, Control Room Ventilation and Air Conditioning System Operation, Revision 22 

OX1405.07, Safety Injection Quarterly and 18 Month Pump Flow and Valve Test, Revision 13 

OX1412.02, PCCW Train B Quarterly Operability, 18 month Position Indication, and 

 Comprehensive Pump Testing, Revision 20 

OX1426.26, EDG 1A Semiannual Operability Surveillance, Revision 17 

OX1456.26, Train A ESFAS Slave Relay K610 Quarterly Go Test, Revision 7 

OX1656.81, Operability Testing of IST Valves, Revision 19 

OX1426.23, Emergency Diesel Generator 1B 24 Hour Load Test and Hot Restart Surveillance, 

Revision 18 

 
A-7 

Attachment 

Condition Reports

01969615 01991632 01992923 01998684 01999416 02003706 

02003768 02003900 02004037 02004187 

Maintenance Orders/Work Orders

01047450 40279688 40279790 40279791 40279792 40279794 

40279900 40281987 40325695 40325696 40332384 40337807 

40347648 40347769 

Miscellaneous

2MSE235-00, Alternate Materials for Check Valve Disc Washer 

DRR 92-060, Walworth Disc Washer Material Substitution and Sizing 

MS0519.65, Walworth 16-, 18-, 20- and 24-Inch swing check valve maintenance 

Seabrook Station UFSAR, Revision 16 

Drawings

1-NHY-310882, Reactor Coolant Pump 1-P-1D Three Line Diagram, Sheet A24a, Revision 10 

1-NHY-310882, Reactor Coolant Pump 1-P-1D Trip Contacts, Sheet A24c, Revision 5 

1-NHY-310882, Reactor Coolant Pump 1-P-1D Protection Schematic, Sheet A24d, Revision 7 

1-NHY-310882, Reactor Coolant Pump 1-P-1D Auxiliary Contacts, Sheet A24e, Revision 5 

1-NHY-310882, Reactor Coolant Pump 1-P-1D, Sheet A24k, Revision 2 

1-NHY-310882, Reactor Coolant Pump 1-P-1D, Sheet A241, Revision 1 

Section 1R22: Surveillance Testing

Procedures

OX1412.02, Revision 20, PCCW Train B Quarterly Operability, 18 month Position Indication, 

and Comprehensive Pump Testing 

OX1416.05, Service Water Cooling Tower Pump Quarterly and 2 Year Comprehensive Test, 

Revision 22 

OX1416.06, Service Water Discharge Valves Quarterly Test and 18 Month Position Verification, 

Revision 11 

OX1426.03, Emergency Power Sequencer 18 Month Operability Test, Revision 7 

OX1456.81, Operability Testing of IST Valves, Revision 19 

OX1456.86, Operability Testing of IST Pumps, Revision 10 

Condition Reports

01995518 01995561 

Maintenance Orders/Work Orders

40279856 40279857 40292315 40292326 

Drawings

FP31418, Emergency Power Sequencer Electrical Schematic, Issue 14 

FP31416, Emergency Power Sequencer Electrical Schematic, Issue 13 

FP31374, Emergency Power Sequencer Logic Diagram, Issue 08 

Miscellaneous

Seabrook Station UFSAR Table 8.3-1, Engineered Safety Features, Revision 14 

 
A-8 

Attachment 

Section 2RS3: In-Plant Airborne Radioactivity Mitigation and Control 

Procedures

CS0917.04, Monitoring Plant Systems for Radioactivity, Revision 1 

CS0910.11, Wide Range Gas Monitor Sampling, Revision 1 

HD0965.10, Respirator Fit Testing Using the TSI Portacount, Revision 18 

HD0965.12, Respiratory Equipment Issue and Use, Revision 39 

HD0965.14, Use of PosiChek 3, Revision 10 

HD09-01-01, Firehawk M7 and M7 Responder Air Mask Maintenance and Repair, Revision 3 

HD0965.08, Breathing Air Certification, Revision 16 

JD0999.102, Radiological Guidelines for Use of Containments and Air Handling, Revision 8 

Condition Reports

2007480 

Miscellaneous

Fit Test Report MSA Ultra Elite 1000 Full Face Negative Pressure Respirator Serial No. 

 008709147, November 13, 2014 

Fit Test Report for Test Subject using MSA Ultra Rubber 1000 using Portacount Pro Serial 

No. 803014209, December 10, 2014 

HD0965.08 Form A: Grade D In-House Breathing Air Certification for Firefighter Annex Air 

 Compressor, November 14, 2014 

HD0965.14 Form A: SCBA HIP- AIR Regulator Flow Checks Serial No. ML337078, 

April 21, 2014 

HD0965.14 Form A: SCBA HIP- AIR Regulator Flow Checks Serial No. ANPE186198, 

April 23, 2014 

HD0965.14 Form B: SCBA Face Piece Test Serial No. FH 80, September 30, 2014 

HRE-M01 SCBA Inspection and Inventory, October 17, 2014 

HRE-M02 Inspect Routine Use Radiological Ultra-Vue FFAP Respirators, December 8, 2014 

HRE-M11 Inventory Routine Use Radiological Ultra-Twin FFAP Respirators, December 8, 2014 

MSA Training Certificate Authorized Repair Center, MSA M7 MMR Certified C.A.R.E. 

 Technician, February 7, 2013 

PosiChek 3 USB Test Results for Serial Number ANAD063777 Firehawk M7 Air Mask, 

 December 10, 2014 

Seabrook Updated Final Safety Analysis Report 

Seabrook Station Nuclear Training Group OJT/TPE Guide for Firehawk M7 SCBA OJT 

 #GT1074J, Revision 15 

Sentinel Respirator Qualification Expiration Date Report, November 3, 2014 

Service History for Instrument Serial Number APAB279682 Firehawk SCBA Regulator, 

 December 10, 2014 

Service History for Instrument Serial Number ANAE186198 Firehawk SCBA Regulator, 

 December 10, 2014 

Service History for Instrument Serial Number FH-86 UltraElite Respirator, December 10, 2014 

TRI Air Testing, Inc Laboratory Report-Compressed Air Gas Quality Testing, September 30, 2014 

TSI Certificate of Testing for Portacount Pro Serial No. 8030134708, November 12, 2014 

Audits, Self-Assessments, and Surveillances 

SBK 14-001 Seabrook Nuclear Oversight Report - Radiation Protection and Radwaste 

Programs, February 24, 2014 

Seabrook Daily Quality Summary Reports January 1, 2014 to December 8, 2014 
A-9 

Attachment 

Section 2RS4: Occupational Dose Assessment

Procedures

HD0961.29, Internal Dosimetry Assessment, Revision 27 

RP-AA-101-2001, SENTINEL Software Transactions Associated with Issuance and Control of 

 Personnel Monitoring Devices, Revision 2 

RP-AA-103-2003, SENTINEL Software Miscellaneous Tasks User Guide, Revision 2 

Condition Reports

01957032 01957390 01957400 01957403 01957427 01957495 

01981002 

Miscellaneous

Calibration of the FASTSCAN WBC System at Next Era Seabrook Generating Station, 

March 4, 2014 

HPSTID 14-007 Calibration of WBC System 2014, March 19, 2014 

Seabrook 1 Updated Final Safety Analysis Report 

Seabrook 2014-10CFR60 Analysis for Rad Monitor Instrument Response, November 2014 

Seabrook Body Count Results for three employees, April 11, 2014 

Audits, Self-Assessments, and Surveillances 

SBK 14-001 Seabrook Nuclear Oversight Report - Radiation Protection and Radwaste 

 Programs, February 24, 2014 

Section 2RS05: Radiation Monitoring Instrumentation

Procedures

HD0951.11, Documentation of Health Physics Studies and Technical Information, Revision 1 

HD0955.50, Far West REM-500 Operation, Revision 6 

Condition Reports

01980404 

Miscellaneous

ANSI N323AB-2013, Radiation Protection Instrumentation Test and Calibration, 

December 16, 2013 

CD0900.15 Form A, Chemistry Performance Indicator Report Form, February 18, 2014 

CD0900.15 Form A, Chemistry Performance Indicator Report Form, September 14, 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, January 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, February 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, March 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, April 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, May 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, June 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, July 2014 
A-10 

Attachment 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, August 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, September 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, October 2014 

CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence 

 KPIs, November 2014 

Far West Technology Operation and Repair Manual for REM-500 Neutron Survey Meter, 

 September 1998 

GEL Laboratories, LLC, Laboratory Certificate of Analysis for Sample Data Group 360401, 

 Samples received November 3 and December 1, 2014 

HPSTID-96-004, Basis for Performing Operability Checks for Use of the Far West Technology 

 REM-500 Meter, February 10, 1996 

JD0999.910 Figure 1: Occupational Exposure Occurrence for October, November and 

 December 2013 

JD0999.910 Figure 1: Occupational Exposure Occurrence for January, February and 

March 2014 

JD0999.910 Figure 1: Occupational Exposure Occurrence for April, May and June 2014 

JD0999.910 Figure 1: Occupational Exposure Occurrence for July, August and September 2014

Maintenance Rule Functional Failure Evaluation for RM-6481-1 Main Stem Line “A” Rad 

Monitor, July 25, 2014 

SB UFSAR, Chapter12 Table 12.5-1 Portable Health Physics Instruments, Revision 16 

Seabrook 1 Updated Final Safety Analysis Report 

Seabrook Station Radiation Protection Manual, Revision 67 

Section 4OA1: Performance Indicator Verification

Procedures

CS0917.02, Gaseous Effluent Releases, Revision 14 

CX0917.01, Liquid Effluent Releases, Revision 20 

HD0958.33, Performance of Radiation Protection Supervisory Plant Walk-downs, Revision 6 

JD0999.910, Reporting Key Performance Indicators per NEI 99-02, Revision 6 

NAP-206, NRC Performance Indicators, Revision 7 

Condition Reports

01856230 01996503 

Miscellaneous

Engineering Evaluation EE-11-020, FPL-Seabrook Mitigating System Performance Indicator 

 Basis Document, Revision 0 

LIC-14039, Documentation Supporting the Seabrook Station NRC 3rd Quarter 2014 

 Performance Indicator Submittal 

LIC-14031, Documentation Supporting the Seabrook Station NRC 2nd Quarter 2014 

 Performance Indicator Submittal 

LIC-14018, Documentation Supporting the Seabrook Station NRC 1st Quarter 2014 

 Performance Indicator Submittal 

LIC-14004, Documentation Supporting the Seabrook Station NRC 4th Quarter 2013 

 Performance Indicator Submittal 

NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7 
A-11 

Attachment 

Audits, Self-Assessments, and Surveillances 

Quick Hit Assessment Report 1914767, HP Performance Indicator Verification, 

November 1, 2013 

Section 4OA2: Problem Identification and Resolution

Condition Reports

01904703 01916618 01919736 01930049 01953499 01971447 

01997899 02001541 02005503 02007961 02008681 02013888 

02014819 

Maintenance Orders/Work Orders

40262945 

Miscellaneous

Groundwater Monitoring Well SW-1, SW-2, SW-3, SD-1, SD-2 Data, collected on 

September 4, 2009 

Groundwater Monitoring Well Chemistry Data for 1st QTR 2010 through 1st QTR 2011 

Groundwater Monitoring Well Specific Conductivity for BD-6, SD-5, SW-3, collected between 

 August 2012 and March 2014 

MPR Project 0326-0063, Procedure 5-7, Structural Testing of Shear and Anchorage 

 Specimens, Revision 2 

MPR Procedure 0326-0062-46, Procedure for In-process Inspections of FSEL Reinforcement 

 Anchorage Test Set-up for Seabrook Station, Revision 2 

Source Verification Record (SVR) 0326-0062-23-44, Revision 0 

Special Test and Inspection Record (STIR) 0326-0062-24-56, Revision 0 

STIR 0326-0062-24-57, Revision 0 

STIR 0326-0062-24-86, Revision 0 

STIR 0326-0062-24-91, Revision 0 

STIR 0326-0062-24-92, Revision 0 

SVR 0326-0062-23-53, Revision 0 

SVR 0326-0062-23-59, Revision 0 

SVR 0326-0062-23-61, Revision 0 

SVR 0326-0062-23-62, Revision 0 

 
A-12 

Attachment 

LIST OF ACRONYMS 

ACI American Concrete Institute 

ADAMS Agencywide Document Access and Management System 

ALARA as low as reasonably achievable 

AR action request 

ARM area radiation monitor 

ASR alkali-silica reaction 

CAP corrective action program 

CCI combined crack index 

CFR Code of Federal Regulations

CR condition report 

EDG emergency diesel generator 

EFW emergency feedwater 

EPS emergency power sequencer 

FSB fuel storage building 

gpd gallons per day 

GALL Generic Aging Lessons Learned 

IMC Inspection Manual chapter 

ISFSI independent spent fuel storage installation 

LPMS loose parts monitoring system 

MR maintenance rule 

NCV non-cited violation 

NEI Nuclear Energy Institute 

NFSA New Fuel Storage Area 

NIST National Institute of Science and Technology 

NRC Nuclear Regulatory Commission 

OOS out of service 

OD operability determination 

PCCW primary component cooling water 

PARS Publicly Available Records 

PI performance indicator 

PODs prompt operability determinations 

RG Regulatory Guide 

SCBA self-contained breathing apparatus 

SFP spent fuel pool 

SMP structures monitoring program 

SSC structure, system, or component 

SW service water 

TS technical specification 

UFSAR Updated Final Safety Analysis Report 

WBC whole body count 

WO work order