UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100

KING OF PRUSSIA, PA 19406-2713

 August 5, 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 – INTEGRATED INSPECTION REPORT 

05000443/2015002 

Dear Mr. Curtland: 

On June 30, 2015, 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 July 16, 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.

The inspectors documented two findings of very low safety significance (Green) in this report, 

all of which involved violations of NRC requirements. The NRC is treating these violations as 

non-cited violations (NCVs) consistent with Section 2.3.2.a of the 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. 05000443/2015002

 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. 05000443/2015002

 w/ Attachment: Supplemental Information

Distribution: (via e-mail)

DDorman, RA

DLew, DRA 

HNieh, DRP

MScott, DRP 

RLorson, DRS

GSuber, DRS 

GDentel, DRP 

RBarkley, DRP

MDraxton, DRP

CHighley, DRP 

PCataldo, DRP, SRI

CNewport, DRP, RI 

ACass, DRP, Resident AA

KMorganButler, RI, OEDO 

RidsNrrPMSeabrook Resource

RidsNrrDorlLpl1-2 Resource

ROPreports Resource

 DOCUMENT NAME: G:\DRP\BRANCH3\INSPECTION\REPORTS\ISSUED\2015 (ROP 16)\SB IR 2015002 .DOCX

 ADAMS Accession No.: ML15217A256 

 SUNSI Review

 Non-Sensitive

 Sensitive

 Publicly Available

 Non-Publicly Available

OFFICE RI/DRP RI/DRP RI/DRP

NAME PCataldo/ RSB for 

 concurred via phone RBarkley/ RSB GDentel/ GTD

DATE 07/ 30 /15 08/03/15 08/05 /15

OFFICIAL RECORD COPY
1

Enclosure 

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-443

License No.: NPF-86

Report No.: 05000443/2015002

Licensee: NextEra Energy Seabrook, LLC 

Facility: Seabrook Station, Unit No.1

Location: Seabrook, New Hampshire 03874

Dates: April 1, 2015 through June 30, 2015

Inspectors: P. Cataldo, Senior Resident Inspector

C. Newport, Resident Inspector

W. Cook, Senior Reactor Analyst

B. Dionne, Health Physicist

N. Floyd, Reactor Inspector

Approved by: Glenn T. Dentel, Chief

Reactor Projects Branch 3

Division of Reactor Projects
2

TABLE OF CONTENTS

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

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

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

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

1R04 Equipment Alignment ............................................................................................... 6

1R05 Fire Protection.......................................................................................................... 7

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

1R07 Heat Sink Performance ........................................................................................... 8

1R11 Licensed Operator Requalification Program ...........................................................10

1R12 Maintenance Effectiveness .....................................................................................11

1R13 Maintenance Risk Assessments and Emergent Work Control ................................11

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

1R19 Post-Maintenance Testing ......................................................................................12

1R22 Surveillance Testing ...............................................................................................13

1EP6 Drill Evaluation .......................................................................................................13

2. RADIATION SAFETY.........................................................................................................14

2RS5 Radiation Monitoring Instrumentation .....................................................................14

2RS6 Radioactive Gaseous and Liquid Effluent Treatment ...............................................15

4. OTHER ACTIVITIES..........................................................................................................16

4OA1 Performance Indicator Verification ..........................................................................16

4OA2 Problem Identification and Resolution ....................................................................16

4OA3 Follow-Up of Events and Notices of Enforcement Discretion ..................................25

4OA6 Meetings, Including Exit...........................................................................................25

ATTACHMENT: SUPPLEMENTARY INFORMATION...............................................................25

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-1

LIST OF ACRONYMS...........................................................................................................A-11
3

SUMMARY

IR 05000443/2015002; April 1, 2015 - June 30, 2015; Seabrook Station, Unit No. 1; Operability 

Determinations and Functionality Assessments and Problem Identification and Resolution.

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

inspections performed by regional inspectors. Inspectors identified two 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 

April 29, 2015. Cross-cutting aspects are determined using IMC 0310, “Aspects Within the 

Cross-Cutting Areas,” dated December 4, 2014. All violations of NRC requirements are 

dispositioned in accordance with the NRC’s Enforcement Policy dated February 4, 2015. 

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 a Green NCV of 10 CFR, Appendix B, Criterion XVI, 

“Corrective Action,” because NextEra did not ensure that degraded conditions were 

identified and entered into the corrective action process. Specifically, the inspectors 

identified multiple instances of material and equipment degradation resulting from 

deformation of the containment enclosure building (CEB). NextEra entered the condition into 

their corrective action program (CAP) (AR 02014325) and initiated a root cause evaluation 

to evaluate the aggregate cause of the non-conforming condition. Additionally, NextEra 

initiated immediate and prompt operability determinations (PODs), when appropriate, for 

each of the individually identified material and equipment degraded conditions. 

This performance deficiency was considered to be more than minor because, if left 

uncorrected, the performance deficiency had the potential to lead to a more significant 

safety concern if CEB deformation continued to affect plant safety-related structures, 

systems, and components (SSCs) without appropriate identification and evaluation by 

NextEra personnel. The finding was evaluated in accordance with IMC 0609, Appendix A, 

“The Significance Determination Process for Findings At-Power,” and determined to be of 

very low safety significance (Green) since it did not represent an actual open pathway in the 

physical integrity of reactor containment, containment isolation systems, or heat removal 

systems. In addition, the structures and components remained capable of performing their 

safety function. The finding is related to the cross-cutting area of Problem Identification and 

Resolution – Identification, because NextEra did not implement a CAP with a low threshold 

for identifying issues. Specifically, NextEra failed to identify multiple instances of material 

and equipment degradation that would have led to the identification of the CEB nonconforming condition [P.1]. (Section 4OA2.3.1)

 Green. The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, 

“Instructions, Procedures, and Drawings,” because NextEra did not perform an adequate 

POD of a safety-related plant structure. Specifically, NextEra did not appropriately 

categorize the operability of the CEB, a safety-related seismic Category I structure, in 

accordance with EN-AA-203-1001, Operability Determinations/Functionality Assessments, 

Revision 19, after identification of a non-conforming condition affecting the structure. 

NextEra entered the condition into their CAP (AR 02053991), recharacterized the 
4

operability of the CEB as “Operable but Degraded,” and established compensatory 

measures to monitor for additional structural deformation by performing routine seismic seal

gap measurements.

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

design control attribute of the Barrier Integrity cornerstone and its objective to provide 

reasonable assurance that physical design barriers protect the public from radionuclide 

releases caused by accidents or events. Specifically, the inspectors determined that the 

operational capability of the CEB was affected in that compensatory measures were not 

identified and established to monitor for any further degradation of the non-conforming 

condition. The finding was evaluated in accordance with IMC 0609, Appendix A, “The 

Significance Determination Process for Findings At-Power,” and determined to be of very 

low safety significance (Green) since it did not represent an actual open pathway in the 

physical integrity of reactor containment, containment isolation systems, or heat removal 

systems. In addition, the affected structures and components remained capable of 

performing their safety function. The finding is related to the cross-cutting area of Problem 

Identification and Resolution – Evaluation, because NextEra did not thoroughly evaluate an 

issue to ensure that resolutions address causes and extent of condition commensurate with 

their safety significance. Specifically, NextEra did not appropriately characterize the CEB 

non-conforming condition and establish compensatory measures that were commensurate 

with the safety significance of the condition [P.2]. (Section 4OA2.3.2)
5

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 April 17, 2015, 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 – 3 samples)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

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

temperatures. The review focused on the service water cooling tower, switchyard, 

termination yard, control building, and the general site yard. 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 the selected 

systems to ensure station personnel identified issues that could challenge the operability 

of the systems during hot weather conditions.

b. Findings

No findings were identified.

.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation 

and continued availability of the offsite and alternate AC power system to evaluate 

readiness of the systems prior to seasonal high grid loading. The inspectors reviewed 

NextEra’s procedures affecting these areas and the communication protocols between 

the transmission system operator and NextEra. This review focused on changes to the 

established program and material condition of the offsite and alternate AC power 

equipment. The inspectors assessed whether NextEra established and implemented 

appropriate procedures and protocols to monitor and maintain availability and reliability 

of both the offsite AC power system and the onsite alternate AC power system. The 

inspectors evaluated the material condition of the associated equipment by interviewing 

the responsible system manager, reviewing condition reports (CRs) and open work 

orders (WOs), observing NextEra’s inspection activities in the 345 kilovolt (kV) 

termination yard, and walking down portions of the offsite and AC power systems,

including the 345kV termination yard, the 345kV switchyard, and the relay room.
6

b. Findings

No findings were identified.

.3 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed NextEra’s preparations for the onset of solar magnetic 

disturbances (SMDs) that occurred on June 22 to 23, 2015. The inspectors reviewed 

the implementation of applicable procedures to address the impact of SMD on the 

generator step-up unit transformers before the onset of and during this adverse weather 

condition. The inspectors walked down the switchyard and verified that operator actions 

defined in NextEra’s off-normal procedure for SMD events maintained the readiness of 

essential systems. The inspectors discussed readiness and staff availability for SMD 

events with operations, maintenance and work control personnel.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial System Walkdowns (71111.04Q – 4 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

 ‘B’ containment building spray (CBS) return to service on May 31, 2015

 ‘D’ primary component cooling water (PCCW) pump during replacement of the 

‘B’ PCCW pump motor on June 15, 2015

 ‘A’ emergency diesel generator (EDG) return to service on June 16, 2015

 ‘A’ emergency feedwater (EFW) pump return to service on June 24, 2015

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, WOs, 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. 
7

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 

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 out of service, degraded, or 

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

 Intake transition structure (IS-F-1-0) on April 6, 2015

 Discharge transition structure (DS-F-1-0) on April 13, 2015

 Service water pump house (SW-F-1E-Z) on May 1, 2015

 Primary auxiliary building (PAB-F-1C-A, PAB-F-1D-A, PAB-F-1E-A, PAB-F-1F-Z)

on May 5, 2015

 'B' EDG (DG-F-1B-A, DG-F-2B-A, DG-F-3F-A, DG-F-3D-A, DG-F-3B-Z) on May 31, 

2015

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06 – 2 samples)

.1 Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to 

assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP 

to determine if NextEra identified and corrected flooding problems and whether operator 

actions for coping with flooding were adequate. The inspectors focused on the EFW

pump house to verify the adequacy of equipment seals located below the flood line, 

flood and water penetration seals, common drain lines and sumps, sump pumps, level 

alarms, control circuits, and temporary or removable flood barriers.

b. Findings

No findings were identified.

.2 Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope

The inspectors conducted an inspection of underground bunkers/manholes subject to 

flooding that contain cables whose failure could affect risk-significant equipment. The 

inspectors performed walkdowns of risk-significant areas, including manholes W11 and 
8

W05 containing cables for service water pumps, on June 8 and June 19, respectively. 

The inspectors verified water level in the sump and calculations to ensure the cables 

were not submerged. The inspectors verified that the bunkers/manholes were 

dewatered in accordance with station procedures.

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07T – 3 samples)

a. Inspection Scope

The inspectors reviewed program and system health reports, self-assessments, and 

NextEra’s methods (inspection, cleaning, maintenance, and performance monitoring) 

used to ensure heat removal capabilities for the Seabrook Station safety-related heat 

exchangers and compared them to NextEra’s commitments made in response to NRC 

Generic Letter 89-13, “Service Water System Problems Affecting Safety-Related 

Equipment.” The inspectors verified that the methods and acceptance criteria were 

consistent with the accepted industry practices. The inspectors walked down and 

observed conditions of the associated system components, including piping, pumps, 

valves, and heat exchangers with the responsible system engineer.

Based on NextEra’s risk ranking of safety-related components, past triennial heat sink 

inspections, recent operational experience, and resident inspector input, the inspectors 

selected the following heat exchangers for inspection:

 ‘B’ EDG jacket water heat exchanger

 ‘A’ PCCW heat exchanger

 ‘B’ CBS heat exchanger

‘B’ EDG Jacket Water Heat Exchanger

The inspectors reviewed the programs and procedures for maintaining the safety 

functions of the ‘B’ EDG jacket water heat exchanger [1-DG-E-42-B], which is directly 

cooled by service water. The normal service water system source is provided by the 

ocean, and the safety-related back-up source is provided by the cooling tower. The 

Seabrook Station includes two EDG units, each with a jacket water cooling system, 

for supplying back-up electrical power in the event of a loss of normal offsite power. 

The jacket water heat exchanger is monitored by means of performance testing and 

supplemented with periodic eddy current testing and visual inspection.

The inspectors reviewed the results from recent thermal performance tests and 

engineering calculations for the heat transfer capability based on allowable tube 

plugging limits. NextEra monitors the jacket water heat exchanger performance during 

these annual performance tests and trends the data (e.g. fouling factor and maximum 

outlet temperature) to detect long-term degradation. The inspectors verified that the 

acceptance criterion was met and consistent with the design basis values. The 

inspectors also reviewed the most recently completed eddy current testing of the tubes 

to verify structural integrity of the heat exchanger and that the number of plugged tubes 

was within the established limits based on the design heat transfer. The inspectors 
9

discussed with NextEra staff the plans for future replacement of the heat exchanger 

tubes in order to gain increased margin of the tube plugging limits.

‘A’ PCCW Heat Exchanger

The inspectors reviewed the programs and procedures for maintaining the safety 

functions of the ‘A’ PCCW heat exchanger [1-CC-E-17-A], which is directly cooled by 

service water. The PCCW system at Seabrook Station supplies cooling water to safetyrelated components which are required for safe shutdown and/or to mitigate the 

consequences of an accident. The PCCW system consists of two redundant loops, 

each with its own heat exchanger, which also serves as an intermediate fluid barrier 

between the reactor coolant and the service water system. The PCCW heat exchanger 

is monitored by means of temperature ratio trending and supplemented with cleaning 

and visual inspection.

The inspectors reviewed the temperature ratio results from the last three years to verify 

that monitoring was being conducted in accordance with the procedure and that trends 

were being appropriately identified to detect any degradation. NextEra monitors the 

PCCW heat exchanger temperature ratio on a monthly basis, with increased frequency 

based on condenser performance due to the same tube material (i.e. titanium) and 

indication of fouling in the condenser. The inspectors also reviewed the most recently 

completed inspection and cleaning work order to verify that the as-found and as-left 

conditions of the heat exchanger were acceptable and operation was consistent with the 

design and applicable engineering analyses.

‘B’ CBS Heat Exchanger

The inspectors reviewed the programs and procedures for maintaining the safety 

functions of the ‘B’ CBS heat exchanger [1-CBS-E-16-A] which is directly cooled by 

PCCW. The CBS system is intended to be utilized during a postulated design basis 

accident to reduce containment pressure, where the CBS heat exchanger cools the 

reactor coolant prior to being sprayed inside of containment. The heat exchanger is not 

monitored by thermal performance testing or cleaning and inspection because it is part 

of a closed-cycle system (i.e. PCCW).

The inspectors reviewed the results from chemistry monitoring of the PCCW system to 

verify that programs for corrosion control were controlled, tested, and evaluated to 

prevent degradation of components cooled by PCCW. The inspectors verified that the 

normally closed heat exchanger isolation valves were periodically tested as part of inservice testing activities to ensure a flow path upon an accident signal. The inspectors 

also verified that flow was established through the CBS heat exchanger during valve 

testing and surveillance tests.

Review of Intake Structures

Based on the impact to the selected heat exchanger samples, the inspectors performed 

a walkdown of the intake structure, service water pump house, and cooling tower to look 

for indications of piping leakage and/or degradation. The inspectors verified that 

chemistry monitoring and treatments were conducted to prevent clogging and fouling in 

the service water system. The inspectors also reviewed the procedure for NextEra staff 

monitoring and control of cooling tower water temperature during cold weather to 

prevent the formation and impact of ice on this safety-related water source.
10

Problem Identification and Resolution

The inspectors reviewed a sample of Seabrook Station corrective action reports related 

to the heat sink and heat exchangers selected for this inspection. The inspectors 

verified that non-conforming conditions were properly identified, characterized, 

evaluated, and that corrective actions were identified and entered into the CAP for 

resolution.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11Q – 2 samples)

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on May 21, 2015, which 

included exercise of the Extended Loss of AC Power response scenario from Nuclear 

Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies Implementation 

Guide. 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. 

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 infrequently performed test or evolution briefings, pre-shift 

briefings, and reactivity control briefings to verify that these briefings met the criteria 

specified in NextEra’s OP-AA-100-1000, “Conduct of Operations,” Revision 14. In 

particular, the inspectors observed operator response to the loss of CP-295 RDMS, 

i.e., loss of radiation monitoring capability in the control room, on May 28, 2015; shift 

turnover activities and reactivity manipulations (dilution) on June 2, 2015; reactivity 

manipulations (dilution) on June 15, 2015; and a brief for PCCW pump 11B postmaintenance activities, which included plant condition review plus validation of 

prerequisites, on June 15, 2015. In addition to general control room activities on 

June 2, June 25, June 29 and June 30, 2015, inspectors also observed reactor operator 

turnover, multiple video alarm system response, and reviewed the Operations 

Department considerations established for a steam generator pressure analog channel 

test conducted on June 30, 2015. Additionally, 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.
11

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12Q – 2 samples)

a. Inspection Scope

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

maintenance activities on SSC performance and reliability. The inspectors reviewed 

system health reports, CAP documents, maintenance WOs, and maintenance rule (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 SSC 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 were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors 

assessed the adequacy of 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. 

 ‘B’ PCCW pump motor failure on June 13, 2015

 ‘B’ EDG maintenance outage on June 17, 2015

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 – 6 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.

 'B' station battery service test on April 28, 2015

 'B' instrument air maintenance on May 29, 2015

 ‘B’ condensate pump electrical testing on June 2, 2015

 Switchyard activities, Safety Bus 6 electrical testing, and cooling tower basin 

inspections on June 9, 2015

 'B' PCCW motor failure on June 15, 2015

 Reserve auxiliary transformer auto-close relay testing on June 26, 2015
12

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:

 ‘A’ EDG relay IDR2 missing mounting screw, identified on March 10, 2015

 SW-V-16 air leakage on May 4, 2015

 CEB seismic seal degradation on May 15, 2015

 'B' EDG heat exchanger eddy current test results on June 1, 2015

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

One non-cited violation was identified in this area and is described later in the report 

under Section 4OA2.3.2. 

1R19 Post-Maintenance Testing (71111.19 – 6 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.

 ‘B’ EDG woodward governor replacement on April 4, 2015 

 ‘A’ ASDV positioner replacement on April 16, 2015

 ‘B’ charging pump speed increaser lube oil pump refurbishment on April 28, 2015

 EFW building exhaust damper actuator replacement on April 29, 2015
13

 Main steam loop 1 and 4 radiation monitor replacement on June 2, 2015

 ‘B’ PCCW pump motor replacement testing on June 15, 2015

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22 – 7 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:

 ‘A’ engineered safety features actuation system slave relay K615 quarterly test 

on April 13, 2015

 EFW instrument air supply check valve exercise on April 22, 2015

 Protection channel II reactor coolant flow loop operational test on May 4, 2015

 Reactor coolant system (RCS) steady state leak rate calculation on May 5, 2015 

(RCS)

 Primary coolant system sample on May 7, 2015

 'B' CBS pump 125VDC Agastat relay testing on May 26, 2015

 Containment online purge valve testing on June 24, 2015 (IST)

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06 – 2 samples)

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine NextEra emergency drill on June 10, 

2015 to identify any weaknesses and deficiencies in the classification, notification, and 

protective action recommendation development activities. The inspectors observed 

emergency response operations in the simulator and emergency operations facility 

to determine whether the event classification, notifications, and protective action 

recommendations were performed in accordance with procedures. The inspectors also 

attended the applicable drill critiques to compare inspector observations with those 

identified by NextEra staff in order to evaluate NextEra’s critique and to verify whether 

NextEra staff was properly identifying weaknesses and entering them into the CAP.
14

b. Findings

No findings were identified.

.2 Emergency Preparedness Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for Unit 1 licensed operators on 

May 22, 2015, which required emergency plan implementation by an operations crew. 

NextEra planned for this evolution to be evaluated and included in performance indicator 

data regarding drill and exercise performance. The inspectors observed event 

classification and notification activities performed by the crew. The inspectors also 

attended the post-evolution critique for the scenario. The focus of the inspectors’ 

activities was to note any weaknesses and deficiencies in the crew’s performance and 

ensure that NextEra evaluators noted the same issues and entered them into the CAP.

b. Findings

No findings were identified.

2. RADIATION SAFETY

Cornerstone: Public Radiation Safety

2RS5 Radiation Monitoring Instrumentation (71124.05 – 1 sample)

a. Inspection Scope

During the period April 20 to 23, 2015, inspectors reviewed performance in assuring 

the accuracy and operability of radiation monitoring instruments used for effluent 

monitoring and analysis. The inspectors used the requirements in 10 CFR 20, 10 CFR 

50, Appendix I; TSs; Offsite Dose Calculation Manual (ODCM); Regulatory Guides; 

applicable industry standards; and procedures required by TSs as criteria for 

determining compliance. 

Calibration and Testing Program

The inspectors selected five effluent monitor instruments and evaluated whether channel 

calibration and functional tests were performed consistent with NextEra’s TSs/ODCM. 

The inspectors assessed whether: (a) NextEra calibrated its monitors with National 

Institute of Standards and Technology traceable sources; (b) the primary calibrations 

adequately represented the plant radionuclide mix; (c) when using secondary calibration 

sources, primary calibration source comparisons were performed; and (d) NextEra 

channel calibrations encompassed the instrument’s alarm set-point range. The 

inspectors assessed whether the effluent monitor alarm set-points were established as 

provided in the NextEra ODCM and station procedures. For changes to effluent monitor 

set-points, the inspectors evaluated the basis for changes to ensure that an adequate 

justification exists.

b. Findings

No findings were identified.
15

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06 – 1 sample)

a. Inspection Scope

The inspectors reviewed the treatment, monitoring, and control of radioactive gaseous 

and liquid effluents. The inspectors used the requirements in 10 CFR 20, 10 CFR 50, 

Appendix I; TSs; ODCM; applicable industry standards; and procedures required by TSs 

as criteria for determining compliance.

Inspection Planning

The inspectors conducted in-office review of NextEra’s 2013 and 2014 annual 

radioactive effluent and environmental reports, radioactive effluent program documents, 

UFSAR, ODCM, and applicable event reports.

Walk-downs and Observations

The inspectors walked down the gaseous and liquid radioactive effluent monitoring 

systems to assess the material condition and verify proper alignment according to plant 

design. The inspectors also observed potential unmonitored release points and 

reviewed radiation monitoring system surveillance records and the routine processing 

and discharge of gaseous and liquid radioactive wastes.

Sampling and Analyses

The inspectors reviewed: radioactive effluent sampling activities, representative 

sampling requirements; compensatory measures taken during effluent discharges 

with inoperable effluent radiation monitoring instrumentation; the use of compensatory 

radioactive effluent sampling; and the results of the inter-laboratory and intra-laboratory 

comparison program including scaling of hard-to-detect isotopes. 

Effluent Flow Measuring Instruments

The inspectors reviewed the methodology used to determine the radioactive effluent 

stack and vent flow rates to verify that the flow rates were consistent with TS/ODCM and 

UFSAR values. 

Air Cleaning Systems

The inspectors reviewed radioactive effluent discharge system surveillance test results 

based on technical specification acceptance criteria.

Dose Calculations

The inspectors reviewed: changes in reported dose values from the previous annual 

radioactive effluent release reports; several liquid and gaseous radioactive waste 

discharge permits; the scaling method for hard-to-detect radionuclides; ODCM changes; 

land use census changes; public dose calculations (monthly, quarterly, annual); and 

records of abnormal gaseous or liquid radioactive releases. 
16

Groundwater Protection Initiative (GPI) Implementation

The inspectors reviewed: groundwater monitoring results; changes to the GPI program 

since the last inspection; anomalous results or missed groundwater samples; leakage or 

spill events including entries made into the decommissioning files (10 CFR50.75(g)); and 

NextEra’s evaluation of any positive groundwater sample results including appropriate 

stakeholder notifications and effluent reporting requirements.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with the radioactive effluent 

monitoring and control program were identified at an appropriate threshold and properly 

addressed in NextEra’s CAP. Section 4OA2 contains a follow-up evaluation of a 

Problem Identification and Resolution for the GPI.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

RCS Specific Activity and RCS Leak Rate (2 samples)

a. Inspection Scope

The inspectors reviewed NextEra’s submittal for the RCS specific activity and RCS 

leak rate performance indicators for the period of April 1, 2014 to March 31, 2015. To 

determine the accuracy of the performance indicator 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 RCS sample analysis and logs of daily measurements of RCS leakage 

and activity, and compared that information to the data reported by the performance 

indicator.

b. Inspection Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152 – 2 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
17

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 CR

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 

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

second quarters of 2015, to assess CRs written in various subject areas (equipment 

problems, human performance issues, etc.), as well as individual issues identified during 

the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Seabrook 

Station’s Self-Evaluation and Trending Analysis Report for first quarter of 2015, 

conducted under PI-AA-207-1000, Station Self-Evaluation and Trending Analysis, 

Revision 3, 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 the engineering and maintenance

departments. 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, the

inspectors noted that on occasion, potential adverse trends were identified through (1) 

the use of statistical tools available to staff and utilized throughout the quarter to identify 

statistically significant issues that reach a predetermined threshold or (2) cognitive 

trends by staff or collectively during review by the Management Review Committee 

(MRC) while screening ARs.

In general, the inspectors noted that new and existing adverse trends, as well as 

management awareness areas, were consistent with those identified by the NRC 

through daily CR reviews, including those trends identified as cognitive trends during 

MRC reviews. Additionally, the inspectors had identified several issues associated 

with Agastat relays, and noted that AR 02055723 was generated independently by 

Maintenance personnel primarily to evaluate the maintenance work practices and testing 

methodology to discern whether testing was being performed appropriate for the 

circumstances.
18

The inspectors were initially concerned the statistical tool utilized by the responsible 

department corrective action program coordinators was either being under-utilized, or 

more importantly, did not capture this potential trend regarding issues associated with 

Agastat relays. However, further review of this trend regarding Agastat relays revealed 

a station trending process that appropriately identified the cognitive trend during a MRC 

meeting (although not identified as such by the initiating organization) and component 

identification codes associated within the CAP. The inspectors noted that cause/process 

codes or applicable keywords were not utilized consistent with the trending program 

requirements that would have allowed the statistical tool or department cognitive trend 

processes to identify any potential trends specific to the failure, assuming a commonality 

existed among the various styles and types of Agastat relays that exist at NextEra 

Seabrook.

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

Structures

a. Inspection Scope

The purpose of periodic site visits to Seabrook Station over the past few years has been 

to review the adequacy of NextEra’s monitoring of alkali-silica reaction (ASR) on affected 

reinforced concrete structures, per their MR Structures Monitoring Program. In addition, 

periodic visits to the University of Texas – Austin, Ferguson Structural Engineering 

Laboratory (FSEL) are conducted to oversee the progress and implementation of the 

ASR large specimen testing program. The region-based inspectors and Office of 

Nuclear Reactor Regulations (NRR) technical reviewers involved with periodic 

inspections and visits verify NextEra and responsible contractors are appropriately 

implementing station programs and procedures, as well as, adhering to the self-imposed 

10 CFR Part 50 Appendix B, Quality Assurance Program associated with the voluntary 

large-scale testing program. The testing program was developed to better understand 

the impact of ASR on reinforced concrete specimens that were designed to closely 

replicate the ASR-affected structural walls at Seabrook. In addition to region-based 

inspectors’ activities, the resident inspectors conduct routine walkdowns of the site to 

identify any degraded plant conditions and structural impacts attributable to ASR.

b. Observations

During this inspection period, region-based inspectors and NRR reviewers visited 

Seabrook Station the weeks of April 20 and May 11 to examine the preliminary results

of a root cause evaluation being conducted by NextEra to assess observed differential 

movement between the CEB and adjacent structures, a condition that was initially 

identified by the NRC resident inspectors. The inspectors and reviewers toured the 

station with the resident inspectors and NextEra staff to examine the effect of bulk 

ASR expansion on structures and attached components and systems. The NRC staff 

received a presentation by the NextEra engineering staff and contractors regarding the 

ongoing evaluations and associated finite element analysis (FEA) of the CEB and recent 

examination of observed ASR-related wall cracks in the residual heat removal (RHR) 

vault. Field measurements and preliminary FEA results indicate that, where the CEB 

interfaces with the containment ventilation area (CEVA) and West Mechanical 

Penetration structures, CEB deformation of between 1 to 3 inches has occurred due to 

bulk ASR expansion and creep (a dimensional change caused by time-dependent “dead 

weight” loading of reinforced concrete structures). The combination of these two 
19

mechanisms has resulted in degradation of some attached systems and components, 

and needed repairs to building seismic interface joints and fire barrier seals (see NCV 

2015002-01 below).

Based upon the ongoing root cause evaluation and preliminary results, NextEra initiated 

a POD to address the impact of the deformation on the CEB and associated seismic gap 

between the CEB and adjacent safety-related buildings. The NRC staff agreed with the 

NextEra determination that the CEB remains operable based upon sufficient seismic gap 

design margin being maintained, and no current evidence of associated ASR concrete 

degradation that would indicate CEB structural integrity is compromised. However, the 

NRC staff disagreed with the initial NextEra conclusion that the CEB was operable and 

“fully qualified with reduced margin” (see NCV 2015002-02, below). Rather, the NRC 

staff concluded the CEB was operable, but degraded and non-conforming, requiring 

continued monitoring and periodic evaluations to ensure continued operability. Further, 

the NRC concluded that the observed deformation far exceeds any previously 

anticipated creep values for reinforced concrete structures and therefore is nonconforming with the original design and construction code (ACI 318 – 1971). Upon 

completion of NextEra’s CEB root cause evaluation and RHR vault apparent cause 

evaluation, the NRC staff will review the results and NextEra’s planned corrective and/or 

compensatory actions.

The NRC staff considers the identification of bulk ASR expansion and structure 

deformation as an aspect of the non-conforming ASR condition that potentially warrants 

resolution per the 10 CFR 50.59 and 50.90 processes.

c. Findings

.1 Inadequate Identification of Structural Deformation and Impacts on Associated 

Equipment

Introduction. The inspectors identified a Green NCV of 10 CFR, Appendix B, Criterion 

XVI, “Corrective Action,” because NextEra did not ensure that degraded conditions were 

identified and entered into the corrective action process. Specifically, the inspectors 

identified multiple instances of material and equipment degradation resulting from 

deformation of the CEB.

Description. 10CFR 50, Appendix B, Criterion XVI, requires that measures shall be 

established to assure that conditions adverse to quality, such as deficiencies, deviations, 

defective materials, and non-conformances are promptly identified and corrected. While 

performing routine plant walk downs, the inspectors identified degraded seismic and fire 

seals that appeared to have been caused by differential movement between the CEB 

and the adjoining concrete walls that form the boundaries of the CEVA (AR 02004748). 

The CEB is a safety-related seismic Category I structure that completely encloses the 

containment, forming a second barrier to the uncontrolled escape of radioactive nuclides 

in the event of an accident. Walkdowns conducted by NextEra as a result of the 

NRC-identified conditions led to the discovery of additional examples of equipment 

deficiencies that were caused by CEB deformation. These examples include: deformed 

flexible conduit couplings in the Main Steam west pipe chase (ARs 0213417, 2013442, 

2013457, 2013474, 2013502, and 2013521) and interference between the SB-V-9 valve 

operator and CEB wall surface (AR 2014037).
20

As a result of these identified degraded conditions, NextEra initiated a root cause 

evaluation to further evaluate the cause of the differential movement between the 

CEB and adjacent structures (AR 02014325). NextEra’s aggregate evaluation of the 

degraded conditions confirmed that the identified deformation and impacted SSCs can 

be attributed to bulk expansion of the CEB reinforced concrete due to ASR and strain 

associated with “dead weight” creep. The bulk expansion due to ASR results in the 

deformation (circumferential bulging and dimpling) of the free-standing cylindrical CEB

at the interface of the CEVA and West Mechanical Penetration buildings. Based upon

walkdowns and field measurements, no other areas of the CEB appear to be impacted. 

Preliminary engineering review, supported by field measurements and a FEA of the 

CEB, indicates that the deformation of the CEB in these areas is due to the asymmetry 

of the CEB structural design and associated steel reinforcement due to the 

interface/opening communicating between the CEB, CEVA and West Mechanical 

Penetration buildings. The deformation of the CEB in the area of the CEVA and West 

Mechanical Penetration buildings represents a non-conforming condition, in that the 

Seabrook UFSAR, Section 3.8.4.5.c states, in reference to seismic Category I

structures, that ‘...no gross deformations will occur that will cause significant contact

with other structures or pieces of equipment.’

Subsequent to the initiation of the root cause evaluation, the NRC inspectors identified 

additional examples of SSCs affected by the CEB deformation. These degraded 

conditions include:

 Deformed flexible conduit couplings in the EFW pump house (AR 02018292)

 Deformed emergency air handling exhaust pipe expansion joint (AR 02040564)

 Deformed containment air ventilation pipe flexible coupling (AR 02042676)

Additionally, enhanced licensee inspections identified the following:

 Concrete cracking and expansion of the main steam and feedwater stairwell 

south wall (AR 02033147)

 Crimped steam generator blowdown valve instrument air lines (AR 02030590)

 Degraded seismic isolation gaps between structures (AR 02044627)

The inspectors consulted with regional specialists and NRR structural engineers and 

reviewed licensee operability evaluations for each of the identified individual degraded 

conditions, where applicable, and concluded that the affected SSCs remained operable. 

However, additional NRC review is planned to more clearly understand this observed 

ASR effect and the overall impact on the CEB and adjacent buildings’ structural 

performance. Preliminarily, the NRC staff has concluded that this bulk expansion effect 

warrants inclusion into the current Structures Monitoring Program and proposed Aging 

Management Program, under the pending license renewal application. 

Analysis. The inspectors determined that failing to identify this non-conforming condition 

in a timely manner was a performance deficiency within NextEra’s ability to foresee and 

correct. This performance deficiency was considered to be more than minor because, 

if left uncorrected, the performance deficiency had the potential to lead to a more 

significant safety concern if CEB deformation continued to effect plant safety-related 

SSCs without appropriate identification and evaluation by NextEra personnel. The 

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

Determination Process for Findings At-Power,” and determined to be of very low safety 

significance (Green) since it did not represent an actual open pathway in the physical 
21

integrity of reactor containment, containment isolation systems, or heat removal 

systems. In addition, the structures and components remained capable of performing 

their safety function. The finding is related to the cross-cutting area of Problem 

Identification and Resolution – Identification, because NextEra did not implement a CAP 

with a low threshold for identifying issues. Specifically, NextEra failed to identify multiple 

instances of material and equipment degradation that would have led to the identification 

of the CEB non-conforming condition (P.1).

Enforcement. 10 CFR 50, Appendix B, Criterion XVI, requires, in part, that measures 

shall be established to assure that conditions adverse to quality, such as failures, 

malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, prior to 

November 4, 2014, NextEra failed to identify multiple instances of equipment and 

material degraded conditions that would have led to the identification of the CEB nonconforming condition. After the issue was identified by the inspectors, NextEra entered 

the condition into their CAP (AR 02014325) and initiated a root cause evaluation to 

evaluate the aggregate cause of the non-conforming condition. Additionally, NextEra 

initiated immediate and prompt operability determinations, when appropriate, for each 

of the individually identified material and equipment degraded conditions. Because this 

violation is of very low safety significance (Green) and NextEra entered this into their 

CAP (AR 02014325), this violation is being treated as a NCV consistent with the NRC 

Enforcement Policy. (NCV 05000443/2015002-01: Inadequate Identification of 

Structural Deformation and Impacts on Associated Equipment)

.2 Inadequate Characterization of Prompt Operability Determination of the Containment 

Enclosure Building

Introduction. The inspectors identified a Green NCV of 10 CFR 50, Appendix B, 

Criterion V, “Instructions, Procedures, and Drawings,” because NextEra did not perform 

an adequate POD of a safety-related plant structure. Specifically, NextEra did not 

appropriately categorize the operability of the CEB, a safety-related seismic Category I 

structure, in accordance with EN-AA-203-1001, Operability Determinations/Functionality 

Assessments, Revision 19, after identification of a non-conforming condition affecting 

the structure. 

Description. NextEra procedure EN-AA-203-1001, Operability Determinations/ 

Functionality Assessments, provides guidance for the preparation and approval of PODs 

required for establishing the acceptability of continued operation of a safety-related SSC 

that is suspected to be degraded, non-conforming, or in an unanalyzed condition. On 

April 30, 2015, NextEra initiated AR 02044627 identifying a reduction of seismic gap seal 

thickness between the CEB and adjoining safety-related seismic Category I concrete 

structures due to previously-identified deformation of the CEB. The deformation of the 

CEB has been attributed to bulk structural expansion caused by ASR and strain in the 

concrete due to creep. NextEra had initiated a root cause evaluation to further 

understand the causes and effects of the condition. 

On May 5, 2015, in accordance with EN-AA-203-1001, NextEra personnel completed a 

POD that documented NextEra’s evaluation of the condition and confirmed the initial 

characterization of CEB operability. The POD concluded that the CEB was “Operable 

and Fully Qualified with Reduced Design Margin,” which is defined by the procedure as 

“meets all current licensing basis and qualification requirements, but with reduced 

margin below some established design value in a design document.” EN-AA-203-1001 

states that the current licensing basis includes “plant-specific design basis information 
22

defined in 10 CFR 50.2 and documented in the most recent UFSAR.” Seabrook’s 

UFSAR, Section 3.8.4.5.c, Revision 16, in reference to the design of safety related 

seismic Category I structures, states that “since each of the structures was designed 

to be in the small deformation, elastic range, no gross deformations will occur that will 

cause significant contact with other structures or pieces of equipment.” EN-AA-203-

1001 defines “Operable but Degraded” as “does not meet all current licensing basis 

requirements but is capable of performing specified functions/mission times” and directs 

that consideration be given to the establishment of compensatory measures to maintain 

an operable but degraded SSC’s specified safety or current licensing basis functions to 

compensate for the degraded or non-conforming condition. 

After review of the POD and EN-AA-203-1001, the inspectors questioned whether 

NextEra personnel should have characterized the CEB non-conforming condition as 

“Operable but Degraded” due to the observed deformation of the CEB and associated 

equipment impacts exceeding the UFSAR design basis of “no gross deformation will 

occur that will cause significant impact with other structures or pieces of equipment.” 

The inspectors also questioned whether NextEra personnel should have established 

compensatory measures to maintain the safety function of the CEB, given the potentially 

active nature of the non-conforming condition affecting the structure. On June 11, 2015, 

after additional review of the inspector’s comments and applicable procedural 

requirements, NextEra personnel changed the POD characterization of the CEB from 

“Operable and Fully Qualified with Reduced Design Margin” to “Operable but Degraded,”

but did not establish compensatory measures to compensate for the non-conforming 

condition. On June 13, 2015, after additional questioning by the NRC inspectors, 

NextEra initiated AR 02053991 documenting that compensatory measures had not

been established. On July 2, 2015, NextEra further revised their POD to establish

compensatory measures for the non-conforming condition. The compensatory 

measures consist of monitoring for additional structural deformation by performing 

routine seismic seal gap measurements. 

Analysis. The inspectors determined that NextEra’s inadequate characterization of the 

CEB non-conforming condition was a performance deficiency within NextEra’s ability to 

foresee and correct. This performance deficiency was considered to be more than minor 

because it affected the design control attribute of the Barrier Integrity cornerstone and its 

objective to provide reasonable assurance that physical design barriers protect the 

public from radionuclide releases caused by accidents or events. Specifically, the

inspectors determined that the operational capability of the CEB was affected in that 

compensatory measures were not identified and established to monitor for any further 

degradation of the non-conforming condition. The finding was evaluated in accordance 

with IMC 0609, Appendix A, “The Significance Determination Process for Findings AtPower,” and determined to be of very low safety significance (Green) since it did not 

represent an actual open pathway in the physical integrity of reactor containment, 

containment isolation systems, or heat removal systems. In addition, the affected 

structures and components remained capable of performing their safety function. 

The finding is related to the cross-cutting area of Problem Identification and Resolution –

Evaluation, because NextEra did not thoroughly evaluate an issue to ensure that 

resolutions address causes and extent of condition commensurate with their safety 

significance. Specifically, NextEra did not appropriately characterize the CEB nonconforming condition and establish compensatory measures that were commensurate 

with the safety significance of the condition (P.2).
23

Enforcement. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting 

quality shall be prescribed by documented procedures of a type appropriate to the 

circumstances and shall be accomplished in accordance with these procedures. 

Additionally, Criterion V requires that procedures shall include appropriate quantitative

or qualitative acceptance criteria for determining that important activities have been 

satisfactorily accomplished. NextEra procedure EN-AA-203-1001, Operability 

Determinations/Functionality Assessments, Revision 19, provides guidance for the 

preparation and approval of PODs required for establishing the acceptability of 

continued operation of a plant safety-related SSC that is suspected to be degraded, 

non-conforming, or in an analyzed condition. Contrary to the above, on May 5, 2015, 

NextEra failed to properly characterize the operability of the CEB, a safety-related 

seismic Category I structure, during the preparation and approval of the POD addressing 

reduction in seismic gap width due to the deformation of the CEB, a non-conforming 

condition. After the issue was identified by the inspectors, NextEra entered the condition 

into their CAP (AR 02053991), re-characterized the operability of the CEB as “Operable 

but Degraded,” and established compensatory measures to monitor for additional 

structural displacement by performing routine seismic seal gap measurements. 

Because this violation is of very low safety significance (Green) and NextEra entered 

this into their CAP, this violation is being treated as a NCV consistent with the NRC 

Enforcement Policy. (NCV 05000443/2015002-02: Inadequate Characterization of 

Prompt Operability Determination of the Containment Enclosure Building)

.4 Problem Identification and Resolution Follow-up Review: Groundwater Protection 

Initiative (See 2RS6)

a. Inspection Scope

During the period April 20 to April 23, 2015, the inspectors performed a review of the 

effectiveness of NextEra's CAP in response to the past tritium leak into on-site ground 

water through the wall liner of the cask loading pool/transfer canal in the Fuel Storage 

Building. This problem was identified by NextEra in AR 01902166 for Spent Fuel Pool 

Zone 6 Fuel Building Transfer Canal Elevated Tritium and Leakage on September 6, 

2013. Recently, this problem recurred and AR 02038368 was written documenting 

elevated tritium in the EFW french drain and CEVA dewatering well samples on April 6, 

2015. Specifically, the inspectors reviewed CRs concerning the tritium leak to evaluate 

if the issue was completely and accurately identified, the causes were correctly 

identified, and timely corrective actions were performed commensurate with the safety 

significance of the issue.

b. Findings and Observations

No findings were identified. 

In September 1999, elevated tritium concentrations were identified in ground water that 

was seeping into the containment annulus. Subsequently, NextEra determined that the 

cask loading area/transfer canal, adjacent to the Spent Fuel Pool (SFP), was leaking into 

the SFP tell-tale drain collection lines and down into the SFP sump. This water leakage 

contaminated the surrounding concrete, which resulted in leakage of water containing 

tritium into ground water beneath and adjacent to the Fuel Storage Building (FSB). 

To mitigate this leak, the tell-tale drains on the pool walls were flushed. In addition, a 

coating was applied to the cask loading pool and transfer canal surfaces during the 2014 

refueling outage. A previous coating was applied to the cask loading pool and transfer 

canal surfaces during the 2010 refueling outage. While this corrective action reduced 
24

the tritium leakage, a small amount of tritium was identified leaking from the catch basin 

surrounding the skimmer housing for the cask loading pool. 

In addition to the pool and canal liner repair activities, NextEra implemented a building 

dewatering and remediation program by periodically withdrawing ground water in the

areas inside and surrounding the FSB, primary auxiliary building, and containment. 

Tritiated water continues to migrate into the basements of some buildings and 

subsurface regions adjacent to some building foundations. Five dewatering pump 

locations were established in the following area/buildings: 1) containment enclosure 

area, 2) primary auxiliary building, 3) emergency feed water french drain, 4) ‘B’ RHR

equipment vault, and 5) ‘B’ electrical tunnel. Through controlled dewatering at these 

five dewatering/remediation wells, NextEra systematically remediated and monitored 

tritium contaminated ground water. By measuring tritium concentrations and the 

quantities of the water that are discharged to the storm drain system, NextEra 

established a controlled, monitored discharge through the normal liquid effluent 

discharge path. 

A ground water monitoring network of 27 monitoring wells has been established to track 

and trend the concentrations and migration of groundwater. The samples from most 

monitoring wells are collected annually, then analyzed for tritium and gamma emitting 

radionuclides. The three tritium plume indicator wells (SW-1, SD-1 and BD-2) are 

sampled and analyzed quarterly. Tritium is the only radioisotope identified in water 

samples taken from these monitoring wells. Currently, only one well (SW-1) located 

near the FSB is consistently showing a positive concentration slightly above 2000 pCi/l. 

All other wells (except SD-1 and BD-2) are showing less than minimum detectable 

(about 600 pCi/l). Since June 2009, results of two monitoring wells (SD-1 and BD-2) 

intermittently indicated values above the tritium detection limit of 600 pCi/L. These wells 

are southwest of SW-1 up-gradient of the seawall inside the Protected Area (PA) fence. 

Tritium migration to SD-1 and BD-2 is consistent with site hydrology, the site geological 

features and dewatering influence. All monitoring well tritium results were below the 

ODCM reporting level of 30,000 pCi/l and the Environmental Protection Agency’s 

Drinking Water Standard of 20,000 pCi/l. This EPA standard is given for relative 

comparison only as this is not a drinking water source.

Independent hydrologists were retained by NextEra to provide in-depth evaluations 

of site characteristics through expansion of the ground water and dewatering well 

monitoring program and development of a hydrological site conceptual model. Recently, 

a computerized fate and transport model has been developed and calibrated to predict 

tritium groundwater concentrations over space and time. Using this model, no 

detectable tritium has been estimated to migrate offsite. This has been verified by 

groundwater sample results recently obtained from monitoring wells located just outside 

the restricted area. These groundwater sample results have confirmed no detectable 

levels for tritium in the unrestricted area and no safety impact to the public. 

The inspectors determined that NextEra’s overall response to identifying the on-site 

groundwater tritium condition, determining the causes of the condition, and initiating 

corrective actions met the standards of NextEra’s CAP. The prioritization and timing of 

the corrective actions was determined to be commensurate with the safety significance 

of the problem. Currently, the selection and implementation of the most effective option 

for isolating the tritium leak in the skimmer housing for the cask loading pool is awaiting 

management decision.
25

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153 - 1 sample)

Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant 

parameters, reviewed personnel performance, and evaluated performance of mitigating 

systems. The inspectors communicated the plant events to appropriate regional 

personnel, and compared the event details with criteria contained in IMC 0309, “Reactive 

Inspection Decision Basis for Reactors,” for consideration of potential reactive inspection 

activities. As applicable, the inspectors verified that NextEra made appropriate 

emergency classification assessments and properly reported the event in accordance 

with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed NextEra’s follow-up 

actions related to the events to assure that NextEra implemented appropriate corrective 

actions commensurate with their safety significance.

 Steam generator and ‘A’ main condenser sodium and chloride excursions on May 30 

and June 6, 2015

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On July 16, 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 

V. Brown, Senior Licensing Engineer

M. Darois, Hydrologist, Contractor from RSCS

K. Douglas, Maintenance Director

D. Drolette, System Engineer

P. Dullea, Principal Chemist Specialist

D. Flahardy, Radiation Protection Manager

A. Guitas, Chemistry Specialist

K. Harper, Fuel Building System Engineer

S. LaVoie, Maintenance Mechanic

E. Matthews, PCCW/CBS System Engineer

B. McAllister, SW System Engineer

M. Ossing, Licensing Manager

A. Pomeroleais, Chemistry Technician

D. Ritter, Operations Director

D. Robinson, Chemistry Manager

I. Watters, Heat Exchanger Program Owner

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000443/2015002-01 NCV Inadequate Identification of Structural 

Deformation and Impacts on Associated 

Equipment (Section 4OA2.3.1)

05000443/2015002-02 NCV Inadequate Characterization of Prompt 

Operability Determination of the Containment 

Enclosure Building (Section 4OA2.3.2)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

LN0556.35, 1-SY-B-3 Switchyard Quarterly Non-Technical Specification Battery Surveillance, 

Revision 6

ON1090.13, Response to Natural Phenomena Affecting Plant Operations, Revision 5

ON1246.03, GSU Trouble, Revision 7

OP-AA-102-1002, Seasonal Readiness, Revision 7
A-2

Condition Reports

01986003 01986008 01986009 02004595 02045704 02047074

02048771 02052635 02055896

Maintenance Orders/Work Orders

40324583 94102370 94102372 94102373

Miscellaneous

ISO New England Operating Procedure No. 4, Action during a Capacity Deficiency, Revision 12

Master/Local Control center Procedure No. 1, Nuclear Plant Transmission Operations, Revision 13

Master/Local Control center Procedure No. 2, Abnormal Conditions Alert, Revision 17

Seabrook UFSAR, Revision 16

Seasonal Readiness Memo to Peter Sena, dated May 24, 2015

Section 1R04: Equipment Alignment

Procedures

MS0523.26, Horizontal Shaft Alignment, Revision 28

OS1006.04, Operation of the Containment Spray System, Revision 23

OX1426.18, Aligning DG 1A Controls for Auto Start, Revision 5

OX1436.02, Turbine Driven Emergency Feedwater Pump Quarterly and Monthly Valve 

Alignment, Revision 22

Condition Reports

02054284

Maintenance Orders/Work Orders

40333188 40333249 40395367

Drawings

1-CC-B20211, Primary Component Cooling Loop ‘B’ Detail, Revision 21

Section 1R05: Fire Protection

Condition Reports

02030144

Maintenance Orders/Work Orders

40375960

Miscellaneous

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

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, DG-F-2B-A

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

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

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, DG-F-3B-Z

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

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

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

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, PAB-F-1F-Z

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, SW-F-1E-Z
A-3

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

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

Drawings

1-SW-B20794, Service Water System, Revision 36

Section 1R06: Flood Protection Measures

Procedures

MS0599.47, Erection of Scaffolding, Revision 2

SA-AA-100-1006, Confined Space Entry, Revision 4

Condition Reports

00583618 02039955 02042263 02056921

Maintenance Orders/Work Orders

40149135 40209732 40236831 40308818 40328092 94121031

Miscellaneous

Confined Space Entry Permit CSP-15-4369

Drawing 9763-F-310256, Underground Duct Manhole W11 & W12, Revision 7

Preventive Maintenance Activity PMID-15630 (W11), Low Voltage Electrical Manhole and Vault 

Inspections

Preventive Maintenance Activity PMID-54830 (W05), Medium Voltage Electrical Manhole and 

Vault Inspections

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

Seabrook Station UFSAR, Revision 16

Scaffold Tag No. 13-0096

Section 1R07: Heat Sink Performance

Procedures

CP 3.3, Miscellaneous Systems/Closed Cooling Water Systems Chemistry Control Program, 

Revision 28

CP 4.2, Chlorine Management Program, Revision 13

ER1850.017, SW Heat Exchanger Program, Revision 1

ER-AA-123, NRC Generic Letter 89-13 Service Water Program, Revision 1

MS0515.19, PCCW Heat Exchanger Channel Head & Cover and Lower Head 

Removal/Installation, Revision 04

OS1216.01, Degraded Ultimate Heat Sink, Revision 23

OX1412.02, PCCW Train B Quarterly Operability, 18 Month Position Indication, and 

Comprehensive Pump Testing, Revision 20

OX1416.08, Cooling Tower Basin Temperature Weekly Surveillance, Revision 7

PEG-268, Plant Engineering Guidelines Heat Exchanger and NRC GL 89-13 Program, 

Revision 0

Condition Reports

01673445 02037044 02037230 02050993 02051912* 02051914*

02052127*
A-4

Maintenance Orders/Work Orders

40085036 40247852 40294121 40327979 40340663

Miscellaneous

C-S-1-25115, DG Heat Exchanger (DG-E-42A/B) Performance after Tube Plugging, Revision 0

DBD-CC-01, Design Basis Document Primary Component Cooling Water System, Revision 5

DBD-DG-01, Design Basis Document Emergency Diesel Generator, Revision 4

FP 23830, Diesel Generator Vendor Manual

Heat Exchanger Program Health Report, April to June 2015

Heat Exchanger Program Health Report, October to December 2014

NYN-90037, Response to Generic Letter 89-13, dated February 9, 1990

NYN-90176, Supplemental Response to Generic Letter 89-13, dated September 24, 1990

Quick Hit Self-Assessment: 2015 NRC Triennial Heat Sink Inspection, dated April 21, 2015

SBK-L-15073, Enclosure 5, License Renewal Commitment List, dated May 26, 2015

Seabrook Station Updated Final Safety Analysis Report, Revision 11

Thermal Performance Test of 1-DG-E-42B, dated April 5, 2015

Thermal Performance Test of 1-DG-E-42B, dated November 2, 2014

Thermal Performance Test of 1-DG-E-42B, dated November 29, 2012

Thermal Performance Test of CC-E-17-A, dated March 28, 1999

TM-1682, Thermal-Hydraulic Analysis PCCW Heat Exchangers for Seabrook Nuclear Station, 

Revision 1

Drawings

1-NHY-202479, Services & Circ. Water Intake & Discharge Transition Structures Plan - General 

Arrangement, Revision 3

1-NHY-202480, Services & Circ. Water Intake & Discharge Transition Structures Plan - General 

Arrangement, Revision 3

Section 1R11: Licensed Operator Requalification Program

Miscellaneous

Simulator Exercise Guide, Lesson Plan: SBK LOP L3581C, Revision 0

Section 1R12: Maintenance Effectiveness

Procedures

ER-AA-100-2002, Maintenance Rule Program Administration, Revision 2PEG-24, Maintenance 

Rule Goal Setting and Monitoring, Revision 8

PEG-45, Maintenance Rule Program Monitoring Activities, Revision 17

Condition Reports

02039481 02053980

Miscellaneous

‘B’ EDG System Health Report

EE-10-010, Maintenance Rule PRA Basis Document PRA Risk Ranking and Performance

Criteria Based on SSPSS-2009, dated March 2011

Maintenance Rule Functional Failure Evaluation for 1-CC-P-11-B Motor Grounded, dated 

June 22, 2015

NUMARC 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at 

Nuclear Power Plants, Revision 2

PCCW System Health Report, 4/1/15 to 6/30/15
A-5

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

OP-AA-102-1003, Guarded Equipment, Revision 6

OS1012.04, Primary Component Cooling Water Loop B Operation, Revision 26

WM-AA-100-1000, Work Activity Risk Management, Revision 3

Condition Reports

02043905 02050598

Maintenance Orders/Work Orders

40317728 40317729 94119502

Miscellaneous

Maintenance Rule (a)(4) Risk Profile for Work Week 1522

Maintenance Rule (a)(4) Risk Profile for Work Week 1523-02

Maintenance Rule (a)(4) Risk Profile for Work Week 1525-04

Work Activity Risk Plan

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 17

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revisions 19 & 20

OX1456.81, Operability Testing of IST Valves, Revision 22

Condition Reports

01929460 01957744 02004748 02014325 02031118 02031730

02036697 02036700 02037230 02037310 02038232 02038458

02038787 02039190 02039741 02044627 02050993 02052939

02053991 02056483

Maintenance Orders/Work Orders

40200892 40284268 40303901-02 40379153

Miscellaneous

2004 ASME Code for Operation and Maintenance of Nuclear Power Plants

SW-V-16 IST Power Operated Valve Stroke Time Data Sheet

Calculation C-S-1-25115, DG Heat Exchanger (DG-E-42A/B) Performance after Tube Plugging, 

Revision 0

Colt-Pielstick Diesel Engine Vendor Manual

Fairbanks Morse Marketing Information Letter #33

Mistras Preliminary Eddy Current Report dated April 1, 2015

Report ESI-SR-15-063, Customer Specific Seismic Test Report of SG Type Relay, 

Westinghouse (ABB) Model #: 293B254A20, dated 4/23/15

Seabrook Station UFSAR, Revision 16

Drawings

1-NHY-250000, Data Sheets for Motor and Air Operated Valves and Dampers, Revision 80
A-6

Section 1R19: Post-Maintenance Testing

Procedures

IS0609.900, Rebuilding Bettis Nuclear Series Actuators, Revision 5

IS1660.310, RDMS Geiger-Mueller Detector Tube Primary Calibration, Revision 7

IX1660.801, RM-R-6481 or RM-R-6482 Main Steam Line Radiation Monitor Calibration, 

Revision 7

MS0523.29, Inspection and Repair of Lube Oil Pump Coupling (Pacific Charging/Safety 

Injection Pump, Gear Reducers, 1-CS-P-2A & B Skids), Revision 3

MX0539.66, B-EDG Mechanical Governor Venting/Setup and Testing After Replacement, 

Revision 1

OS1026.09, Operation of DG 1B, Revision 25

Condition Reports

02003768 02036004 02039132 02041259 02044073

Maintenance Orders/Work Orders

40236783 40305018 40321878 40321895 40323879 40323908

40323912

Miscellaneous

PM Activity 11214, 1-RM-R-6481-MAN-2, Main Steam Line Loops 1 and 4 Rad Monitor Detector 

Replacement, Revision 0

Specification 9763-006-225-2, Specification for Tornado Check Dampers, Revision 8

Section 1R22: Surveillance Testing

Procedures

CS0910.01, Primary System Sampling at SS-CP-166A, Revision 20

CX0901.02, Determination of Dose Equivalent I-131, Revision 12

EX1803.003, Reactor Containment Type B and C Leakage Rate Tests, Revision 13

IX1662.152, Protection Channel II Reactor Coolant Flow Loops Operational Test, Revision 7

LS0550.09, Timing Relay Acceptance Testing and maintenance Program, Revision 17

LS0563.11, Testing of Agastat 125VDC (7000 Series) TDPU Timing Relays, Revision 9

OX1401.02, RCS Steady State Leak Rate Calculation, Revision 9

OX1423.26, Quarterly Containment Ventilation Valve Testing, Revision 8

OX1436.02, Turbine Driven Emergency Feedwater Pump Quarterly and Monthly Valve

Alignment, Revision 21

OX1456.27, Train A ESFAS Slave Relay K615 Quarterly Go Test, Revision 11

OX1456.81, Operability Testing of IST Valves, Revision 22

Condition Reports

02042496* 02042728 02050327 02050336

Maintenance Orders/Work Orders

40316034 40322927 40324625 40328568
A-7

Section 1EP6: Drill Evaluation

Procedures

EP-AA 101-1000, Nuclear Division Drill and Exercise Procedure, Revision 12

EPDP-03A, EP Cornerstone Reporting and Information Form, Revision 25, dated May 22, 2015

ER 1.1, Classification of Emergencies, Revision 52

ER 1.2, Emergency Action Plan Activation, Revision 61

ER 1.2B, Alert Checklist, Short Term Emergency Director, Revision 59

ER 2.0B, Seabrook Station State Notification Fact Sheet, Revision 31, Alert-HA1, dated 

June 10, 2015

ER 2.0B, Seabrook Station State Notification Fact Sheet, Revision 31, SAE-SS1, dated 

June 10, 2015

ER 2.0B, Seabrook Station State Notification Fact Sheet, Revision 31, Unusual Event-SU5, 

dated May 22, 2015

ER 2.0B, Seabrook Station State Notification Fact Sheet, Revision 31, Alert-FA1, dated 

May 22, 2015

ER 3.1, Technical Support Center Operations, Revision 53

Condition Reports

02054755

Miscellaneous

Simulator Exercise Guide, Lesson Plan: Demonstrative Examination No. 16

Crew and Simulator Examination Forms, Segment 15.3, Week 4, Crew D, dated May 22, 2015

Section 2RS5: Radiation Monitoring Instrumentation

Procedures

CS0908.02, RDMS Setpoints, Revision 10

CX0917.01, Liquid Effluent Release Setpoints, Revision 20

HX0955.32, RDMS Setpoint Determination Rad Monitors, Revision 29

IN1660.992, RM-R-6454 Storm Drain Effluent Monitor Calibration, Revision 5

IX1660.816, RM-R-6509 WLTT Discharge Rad Mont Calibration, Revision 9

IX1660.823, RM-R-6515 6516 Loop A B PCCW Rad Mont Calibration, Revision 6

IX1660.824, RM-R-6519 SGBD Flash Tank Discharge Rad Mont Calibration, Revision 9

IX1660.826, RM-R-6521 Turbine Building Sump Rad Mont Calibration, Revision 6

IX1660.872, RM-R-6516 Loop A PCCW Operation Test, Revision 8

IX1660.873, RM-R-6515 Loop B PCCW Operation Test, Revision 8

IX1660.874, RM-R-6519 SB Flash Tank Discharge Operation Test, Revision 7

IX1660.876, RM-R-6521 Turbine Building Sump Pump Discharge Operation Test, Revision 6

IX1660.816, RM-6509 Waste Liquid Test Tanks Discharge Radiation Monitor Calibration, 

Revision 7

IX1688.110, WL-F-1458-1 Waste Test Tank Discharge Flow Calibration, Revision 4

Audits, Self-Assessments, and Surveillances

SBK 14-013, RETS Chemistry, December 2014

SAQH 2033458, NRC IP 71124.06 Self-Assessment, March 2015

Daily Quality Summary WS SAT Turbine Gland Seal Steam Comp Actions 2015

Daily Quality Summary Chemistry 2012 - 2015 for RETS
A-8

Corrective Actions

01884881 01901568

Miscellaneous

WO 4023552601, R-6509 Waste Liquid Test Tanks Discharge Radiation Monitor Calibration, 

12-10-13

WO 4029393401, WL-F-1458 Waste Test Tank Flow Calibration, 08-08-14

WO 4027990801, R-6519 Flash Tank Discharge Rad Mont Calibration, 09-24-14

WO 4029718101, R-6519 Flash Tank Discharge Rad Mont Operational Test, 12-23-14

WO 4028196601, R-6519 Flash Tank Discharge Rad Mont Operational Test, 09-26-14

WO 4026363701, R-6521 Turbine Building Sump Pump Discharge Rad Monitor Calibration, 

05-20-14

WO 4030015301, R-6521 Turbine Building Sump Pump Discharge Rad Monitor Operability 

Test, 01-05-15

WO 4028451001, R-6521 Turbine Building Sump Pump Discharge Rad Monitor Operability 

Test, 10-08-14

WO 4030883001, F-6577 Plant Vent Stack Flow Trans Op Test, 02-17-15

WO 4030884601, R-6506 Cond Air Evacuator Disc Rad Monitor Calibration, 2-17-15

WO 4029128601, R-6506 Cond Air Evacuator Disc Rad Monitor Operability Test, 11-17-14

WO 4027990701, R-6506 Cond Air Evacuator Disc Rad Monitor Calibration, 09-16-14

Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment 

Procedures

CD 0904.11, Split and Cross Check Analysis, Revision 6

CD 0917.04, Monitoring of Plant Systems for Radioactivity, Revision 3

CDI-015, Sampling of Groundwater Monitoring Wells, Revision 4

CP 3.1, Primary Chemistry Control, Revision 41

CP 3.2, Secondary Chemistry Controls Program, Revision 40

CP 3.3, Miscellaneous System Closed Cooling Water Surveillances, Revision 28

CP 4.1, Effluent Surveillance Program, Revision 29

CP 8.1, Verification of Analytical Systems Performance, Revision 23

CS0908.01, Off-site Dose Assessment, Revision 16

CS0908.02, RDMS Setpoints, Revision 10

CS0910.08, Miscellaneous Primary Side Sampling, Revision 16

CS0911.06, Miscellaneous Secondary System Sampling, Revision 12

CS0917.03, Unmonitored Plant Releases, Revision 10

CS0917.04, Monitoring Plant Systems for Radioactivity, Revision 3

CS0920.07, Tritium Analysis by Liquid Scintillation, Revision 15

CX0917.01, Liquid Effluent Release Setpoints, Revision 20

CX0901.37, Regulatory Guide 1.21 Report, Revision 7

EV-AA-100, Fleet Groundwater Protection Program, Revision 2 

EV-AA-100-1000, Groundwater Protection Program Communications/Notification Plan, 

Revision 5 

EV-AA-100-1001, Fleet Groundwater Protection Program Implementing Guidelines, Revision 2

NARC 3-1.1, Periodic and Special Regulatory Reports, Revision 148

ON1244.01, Spill Response, Revision 30
A-9

Audits, Self-Assessments, and Surveillances

SAQH 2033458 NRC IP 71124.06 Self-Assessment March 2015

SBK 14-013 RETS Chemistry December 2014

Daily Quality Summary WS SAT Turbine Gland Seal Steam Comp Actions 2015

Daily Quality Summary Chemistry 2012 - 2015 for RETS

Corrective Actions

018l85759 01884137 01884906 01891011 01901555 01901561

01902166 01912777 02038368 02038715

Miscellaneous

2013 SB Radioactive Effluent Release Report, April 28, 2014

2014 SB Radioactive Effluent Release Report and addendum issue April 29, 2015

AREVA Submittal SBC-1132: 2014 SB Land Use Census Analysis (AREVA Document No. 

32-9228760-000) Sept 30, 2014

AREVA Submittal SBC-1136: Estimated Public Doses from Seabrook Station Effluents in 2014 

(AREVA Document No.32-9237709-000), April 21, 2015

AREVA Submittal SBC-1136: Seabrook Station Radiological Effluent Impact Assessment for 

2014 (AREVA Document No. 47-9237710-000), April 21, 2015

CP 4.1B GEW Sample Collection Data Permit No. 15-58, ‘A’ Plant Vent, 02-10-15

CS0917.02 Form C: GEW Containment Purge Release Permit, Permit No. 15-01, 01-02-15

CX0917.01 Form C: LEW Release Data Permit No 15-101, ASDA, 02-01-15

CX0917.01 Form C: LEW Release Data Permit No 15-088, Turbine Building Sump, 02-25-15

CX0917.01 Form C: LEW Release Data Permit No 15-076, Waste Test Tank B, 02-25-15

Seabrook Station Updated Final Safety Analysis Report

SB System Health Report: Radiation Monitoring System for 4th Quarter 2014

SB System Health Report: Radiation Monitoring System for 1st Quarter 2015

SB Inter and Intra Laboratory Radiochemistry QC Report 2014

WO 4014773801 18 Month Surveillance on 1-PAH-F-16 including HEPA DOP Test, 

August 27, 2012

WO 40213694 1-EAH-F-9 Charcoal Sampling and Testing, 09-20-13

WO 40220785 1-FAH-F-74 Charcoal Sampling and Testing, 9-30-13

Section 4OA1: Performance Indicator Verification

Procedures

CS0910.01, Primary Systems Sampling at SS-CP-166A, Revision 20

CX0901.02, Determination of Dose Equivalent I-131, Revision 12

NAP-206, NRC Performance Indicators, Revision 6

OX1401.02, RCS Steady State Leak Rate Calculation, Revision 9

Condition Reports

02049206

Miscellaneous

LIC-14031, Documentation Supporting the Seabrook Station NRC 2nd Quarter 2014 

Performance Indicator Submittal

LIC-14039, Documentation Supporting the Seabrook Station NRC 3rd Quarter 2014 

Performance Indicator Submittal

LIC-15004, Documentation Supporting the Seabrook Station NRC 4th Quarter 2014 

Performance Indicator Submittal
A-10

LIC-15015, Documentation Supporting the Seabrook Station NRC 1st Quarter 2015 

Performance Indicator Submittal

Section 4OA2: Problem Identification and Resolution

Procedures

PI-AA-207, Trend Coding and Analysis, Revision 9

PI-AA-207-1003, Control and Application of Trend Codes and Keywords, Revision 4

PI-AA-207-1003-10000, PI Trend Codes and Keywords, Revision 3

Condition Reports

02018619 02028503 02050327 02055086 02055723

Miscellaneous

Seabrook Engineering Self-Evaluation and Trending Analysis Report for 1st Quarter 2015

Seabrook Maintenance Self-Evaluation and Trending Analysis Report for 1st Quarter 2015

Seabrook Station Station Self-Evaluation and Trending Analysis Report for 1st Quarter 2015

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Procedures

CD0905.07, Seawater In-Leakage, Revision 10

OS1234.02, Condenser Tube or Tube Sheet Leak, Revision 17

Condition Reports

02051143 02051889 02056851

*NRC identified
A-11

LIST OF ACRONYMS

AC alternating current

ADAMS Agencywide Document Access and Management System

AR action request

ASR alkali-silica reaction

CAP corrective action program

CBS containment building spray

CEB containment enclosure building

CEVA containment ventilation area

CFR Code of Federal Regulations

CR condition report

DG diesel generator

EDG emergency diesel generator

EFW emergency feedwater

ESFAS engineered safety features actuation system

FEA finite element analysis 

FSB fuel storage building

FSEL Ferguson Structural Engineering Laboratory 

GPI groundwater protection initiative

IMC Inspection Manual chapter

kV kilovolt

MR maintenance rule

MRC Management Review Committee

NCV non-cited violation

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

NRR Office of Nuclear Reactor Regulations

ODCM offsite dose calculation manual

PCCW primary component cooling water

POD prompt operability determination

RHR residual heat removal 

SFP spent fuel pool

SMD solar magnetic disturbance

SSC structure, system, and component

TS technical specification

UFSAR Updated Final Safety Analysis Report

WO work order