UNITED STATES

NUCLEAR REGULATORY COMMISSION 

REGION I 

2100 RENAISSANCE BLVD., SUITE 100 

KING OF PRUSSIA, PA 19406-2713 

August 5, 2016 

Mr. Eric McCartney 

Site Vice President 

Seabrook Nuclear Power Plant 

NextEra Energy Seabrook, LLC 

c/o Mr. Ken Browne 

P.O. Box 300 

Seabrook, NH 03874 

SUBJECT: SEABROOK STATION, UNIT NO. 1 – INTEGRATED INSPECTION REPORT 

05000443/2016002

Dear Mr. McCartney: 

On June 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at 

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

results, which were discussed on July 20, 2016, with you and other members of your staff. 

NRC Inspectors 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. 

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. In addition, if you disagree with the crosscutting 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. 

 
E. McCartney -2- 

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC’s 

“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 and 

Management System (ADAMS). ADAMS is accessible from the NRC website at 

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

Sincerely, 

/RA/ 

Fred L. Bower, Chief 

Reactor Projects Branch 3

Division of Reactor Projects 

Docket No. 50-443 

License No. NPF-86

Enclosure: 

Inspection Report 05000443/2016002 

 w/Attachment: Supplementary Information 

cc w/encl: Distribution via ListServ
E. McCartney -2- 

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC’s 

“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 and 

Management System (ADAMS). ADAMS is accessible from the NRC website at 

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

Sincerely, 

/RA/ 

Fred L. Bower, Chief 

Reactor Projects Branch 3

Division of Reactor Projects 

Docket No. 50-443 

License No. NPF-86

Enclosure: 

Inspection Report 05000443/2016002 

 w/Attachment: Supplementary Information 

cc w/encl: Distribution via ListServ 

DISTIRBUTION w/encl: (via e-mail) 

DDorman, RA 

DLew, DRA 

MScott, DRP 

DPelton, DRP 

RLorson, DRS 

FBower, DRP 

RBarkley, DRP 

MDraxton, DRP 

RVadella, DRP 

PCataldo, DRP, SRI

CNewport, DRP, RI 

ACass, DRP, Resident AA 

JBowen, RI, OEDO 

RidsNrrPMSeabrook Resource 

RidsNrrDorlLpl1-2 Resource 

ROPreports Resource 

DOCUMENT NAME: \\nrc.gov\nrc\R1\Office\DRP\BRANCH3\Inspection Reports\Seabrook\16Q2\SB IR16002 Final.docx 

ADAMS ACCESSION NO: ML16218A455 

 SUNSI Review  Non-Sensitive 

 Sensitive 

 Publicly Available 

 Non-Publicly Available 

OFFICE RI/DRP RI/DRP RI/DRP 

NAME PCataldo RBarkley FBower 

DATE 8/04/16 08/03/14 08/05/16 

OFFICIAL RECORD COPY 
1 

Enclosure 

U.S. NUCLEAR REGULATORY COMMISSION 

REGION I 

Docket No.: 50-443 

License No.: NPF-86 

Report No.: 05000443/2016002 

Licensee: NextEra Energy Seabrook, LLC 

Facility: Seabrook Station, Unit No.1 

Location: Seabrook, New Hampshire 03874 

Dates: April 1, 2016 through June 30, 2016 

Inspectors: P. Cataldo, Senior Resident Inspector 

 C. Newport, Resident Inspector 

J. Vazquez, Resident Inspector (Acting) 

B. Dionne, Health Physicist 

 W. Cook, Senior Reactor Analyst 

Approved by: Fred L. Bower, Chief 

 Reactor Projects Branch 3 

 Division of Reactor Projects 

 
2 

TABLE OF CONTENTS 

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

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

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

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

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

1R06 Flood Protection Measures ......................................................................................... 8

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

1R11 Licensed Operator Requalification Program and Licensed Operator Performance .... 9

1R12 Maintenance Effectiveness ....................................................................................... 10

1R13 Maintenance Risk Assessments and Emergent Work Control ................................. 10

1R15 Operability Determinations and Functionality Assessments ..................................... 11

1R18 Plant Modifications .................................................................................................... 12

1R19 Post-Maintenance Testing ........................................................................................ 13

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

1EP6 Drill Evaluation .......................................................................................................... 14

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

2RS1 Radiological Hazard Assessment and Exposure Controls ........................................ 14

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

4. OTHER ACTIVITIES ............................................................................................................ 17

4OA1 Performance Indicator Verification ............................................................................ 17

4OA2 Problem Identification and Resolution ...................................................................... 17

4OA3 Follow-Up of Events and Notices of Enforcement Discretion.................................... 21

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

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

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

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

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

LIST OF ACRONYMS ............................................................................................................. A-13

 
3 

SUMMARY 

IR 05000443/2016002; 04/01/16-06/30/2016; Seabrook Station, Unit No. 1; Other Activities 

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 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 NUREG1649, “Reactor Oversight Process,” Revision 5. 

Cornerstone: Initiating Events 

 Green. A self-revealing Green NCV of 10 CFR, Appendix B, Criterion V, “Instructions 

Procedures, and Drawings,” was identified, because NextEra did not ensure that activities 

affecting quality were accomplished in accordance with documented instructions. 

Specifically, while implementing a procedure following a plant trip that occurred on March 2, 

2016, NextEra staff performed steps of a procedure in a manner that was prohibited by a 

departmental instruction, leading to an automatic initiation of emergency feedwater (EFW) 

to maintain adequate steam generator (SG) level. NextEra entered this issue into their 

corrective action program (CAP) and subsequently initiated a root cause evaluation to 

determine the factors which contributed to the event. Additionally, NextEra took corrective 

actions (C/As) to provide additional training and guidance for their staff and to resolve 

issues with existing procedures, which were determined to have been contributing factors 

during the event. 

The inspectors determined that this performance deficiency was more than minor because it 

was associated with the Human Performance attribute of the Initiating Events cornerstone, 

and adversely affected the cornerstone objective of limiting the likelihood of events that 

upset plant stability (loss of FW) and challenge critical safety functions during shutdown as 

well as power operations. In accordance with IMC 0609, Attachment 4, “Initial 

Characterization of Findings,” and IMC 0609, Appendix A, “The Significance Determination 

Process for Findings At-Power,” the inspectors determined that this finding was of very low 

safety significance (Green) because the performance deficiency did not cause the loss of 

mitigation equipment relied upon to transition the plant from the onset of a trip to a stable 

shutdown condition. The inspectors determined that this finding had a cross-cutting aspect 

in the area of Human Performance, Challenge the Unknown, because NextEra did not 

ensure that individuals stopped when faced with uncertain conditions. Specifically, the 

individuals involved did not adequately challenge the basis for a decision to disregard a 

department instruction. [H.11] (Section 4OA3) 

 Green. A self-revealing Green NCV of 10 CFR, Appendix B, Criterion V, “Instructions 

Procedures, and Drawings,” was identified because NextEra did not ensure that activities 

affecting quality were prescribed by documented procedures of a type appropriate to the 

circumstances and that these activities were accomplished in accordance with these 

procedures. Specifically, a procedure associated with the testing of safety-related 

containment isolation functions did not contain sufficient instruction to ensure proper control 
4 

of plant configuration; thus implementation of this procedure resulted in an inadvertent 

letdown isolation. Additionally, while attempting to perform this test on a subsequent 

occasion, individuals performed additional steps not prescribed in the associated 

procedure; the execution of these additional steps resulted in an additional inadvertent 

letdown isolation. NextEra entered these issues into their CAP and subsequently 

performed apparent cause evaluations for the two events, made necessary changes to the 

associated procedure, and provided coaching to NextEra staff. 

The inspectors determined that this performance deficiency was more than minor because it 

was associated with the Procedure Quality and Human Performance attributes of the 

Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the 

likelihood of events that upset plant stability (letdown isolation) during power operations. In 

accordance with IMC 0609, Attachment 4, “Initial Characterization of Findings,” and IMC 

0609, Appendix A, “The Significance Determination Process for Findings At-Power,” the 

inspectors determined that this finding was of very low safety significance (Green) because 

the performance deficiency did not cause a reactor trip and the loss of mitigation equipment 

relied upon to transition the plant from the onset of a trip to a stable shutdown condition. 

The inspectors determined that this finding had a cross-cutting aspect in the area of Human 

Performance, Procedural Adherence, because NextEra failed to ensure that individuals 

followed processes and procedures appropriately. [H.8] (Section 4OA3) 

 
5 

REPORT DETAILS 

Summary of Plant Status 

Seabrook operated at full power for the entire assessment period, with the exception of minor 

down powers to perform scheduled turbine 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 reviewed NextEra’s readiness for the onset of seasonal high 

temperatures. The review focused on the EFW building, electrical tunnels, and the 

cooling tower (CT). The inspectors reviewed the Updated Final Safety Analysis Report 

(UFSAR), technical specifications (TSs), control room logs, and the CAP to determine 

what temperatures or other seasonal weather 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, applicable operating procedures, and the summer readiness 

activities tracked through completion in the work management system. 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 reviewed 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 communications 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 

NextEra staff, as applicable, as well as reviewing condition reports (CRs), open work 

orders (WOs), and system health records, and walked down portions of the offsite and 
6 

AC power systems including the termination yard, onsite switchyard, and the high yard 

containing various distribution breakers. 

b. Findings 

No findings were identified. 

.3 Readiness for Impending Adverse Weather Conditions 

a. Inspection Scope 

The inspectors reviewed NextEra’s preparations and actions following a solar magnetic 

disturbance event that occurred between June 8 to 9, 2016, with an associated global 

geomagnetic storm index (Kp index) of 7, which required entry into the abnormal 

operating procedure (AOP) ON1246.03, “GSU Trouble,” Revision 10. The inspectors 

reviewed the implementation of the AOP, as well as other applicable procedures. The 

inspectors walked down the emergency diesel generators (EDGs) and the onsite 

switchyard to ensure system availability, and reviewed the generator stepup (GSU) 

ground induced currents monitored by control room operators. The inspectors verified 

that operator actions defined in NextEra’s procedures maintained the readiness of 

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

weather response with operations and work control personnel. 

b. Findings 

No findings were identified. 

1R04 Equipment Alignment 

.1 Partial System Walkdowns (71111.04 – 4 samples) 

a. Inspection Scope 

The inspectors performed partial walkdowns of the following systems: 

 ‘B’ residual heat removal (RHR) during ‘A’ RHR maintenance on April 12 

 ‘B’ charging pump during ‘A’ charging pump maintenance on June 17 

 ‘B’ vital DC battery distribution during ‘A’ vital battery testing on June 24 

 'A' EDG during 'B' EDG monthly run on June 28 

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 to identify 

conditions that could have impacted the system’s performance of its 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 
7 

issues and entered them into the CAP for resolution with the appropriate significance 

characterization. 

b. Findings 

No findings were identified. 

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

a. Inspection Scope 

During May 2016, the inspectors performed a complete system walkdown of accessible 

portions of the EFW system to verify the existing equipment lineup was correct. The 

inspectors reviewed operating procedures, surveillance tests, system diagrams, 

equipment line-up check-off lists, WOs, work requests, CRs, TSs, and the UFSAR to 

verify the system was aligned to perform its required safety functions. The inspectors 

also reviewed electrical power availability, component lubrication and equipment cooling, 

hanger and support functionality, and operability of support systems. The inspectors 

performed field walkdowns of accessible portions of the systems to verify system 

components and support equipment were aligned correctly and operable. The 

inspectors examined the material condition of the components and observed operating 

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

reviewed whether NextEra staff had appropriately evaluated and resolved any 

equipment issues and other performance deficiencies and entered them into their CAP 

for resolution with the appropriate significance characterization. 

b. Findings 

No findings were identified. 

1R05 Fire Protection 

 Resident Inspector Quarterly Walkdowns (71111.05Q – 5 samples) 

a. Inspection Scope 

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

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

NextEra controlled combustible materials and ignition sources in accordance with 

administrative procedures. The inspectors verified that fire protection and suppression 

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. 

 Non-essential switchgear (NES-F-1A-Z) on May 27 

 Primary auxiliary building (PAB) (PAB-F-1C-A, PAB-F-1D-A, PAB-F-1E-A, PAB-F1F-Z) on June 20 

 Turbine building (TB-F-3-0, TB‐F‐2‐Z) on June 22 
8 

 'B' RHR vault (RHR-F-1A-1C, RHR-F-1A-2A, RHR-F-1A-3A, RHR-F-4A-Z) on June 

27 

 Turbine building (TB-F-1B-A, TB-F-1C-Z) on June 29 

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 

identify internal flooding susceptibilities for the site. The inspectors focused on the RHR 

vaults 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. 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. 

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 W5 and 

W6, on June 17, 2016, which contained safety-related cables for various motor control 

centers and the service water (SW) system. The inspectors verified that the cables were 

not submerged in water, that cables appeared intact, and to observe the condition of 

cable support structures. The inspectors verified that NextEra removed identified water 

following initial opening, and implemented appropriate C/As for issues that were 

identified. 

b. Findings 

No findings were identified. 

1R07 Heat Sink Performance (711111.07A – 1 sample) 

a. Inspection Scope 

The inspectors reviewed the ‘B’ EDG jacket water heat exchanger readiness and 

availability to perform its safety functions. The inspectors reviewed the design basis for 

the component and verified NextEra’s commitments to NRC Generic Letter 89-13, 
9 

“Service Water System Requirements Affecting Safety-Related Equipment.” The 

inspectors observed maintenance activities, which included tube replacement, and 

reviewed the results of previous inspections of this heat exchanger. The inspectors 

discussed the results of the most recent inspection with applicable NextEra staff and 

observed the as-found and as-left conditions. The inspectors verified that NextEra 

initiated appropriate C/As for identified deficiencies. The inspectors also verified that the 

number of tubes plugged within the heat exchanger did not exceed the maximum 

amount allowed. 

b. Findings 

No findings were identified. 

1R11 Licensed Operator Requalification Program and Licensed Operator Performance 

(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 16, 2016, which 

included simulated equipment failures, and other transients resulting in a faulted SG 

event. The inspectors evaluated operator performance during the simulated event and 

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

emergency operating procedures. The inspectors assessed the clarity and effectiveness 

of communications, implementation of actions in response to alarms and degrading plant 

conditions, and the oversight and direction provided by the control room supervisor. The 

inspectors verified the accuracy and timeliness of the emergency classification made by 

the shift manager and identification of the appropriate TS action statements applicable 

for the simulated activities. Additionally, the inspectors assessed the ability of the 

Operations crew to self-identify issues, as well as the 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 licensed operator performance in the main control room during 

SG pressure channel 1 analog channel operability test on April 11, and during ‘B’ EDG 

post maintenance testing on May 2 and 4. Additionally, on April 13, inspectors observed 

dynamic stroke testing and complex troubleshooting of CC-V-145; and operator 

response to a letdown isolation even on June 3. The inspectors observed applicable 

test performance to verify that procedure use, crew communications, and coordination of 

activities between work groups similarly met established expectations and standards. 

b. Findings 

No findings were identified. 
10 

1R12 Maintenance Effectiveness (71111.12Q – 1 sample) 

a. Inspection Scope 

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

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

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

maintenance WOs, and 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 C/As to 

return these SSCs to (a)(2). Where applicable, the inspectors performed a quality 

control review of commercial grade dedications for items that are purchased commercial 

grade, and tested accordingly prior to installation into systems important to safety. 

Additionally, the inspectors ensured that NextEra staff was identifying and addressing 

common cause failures that occurred within and across MR system boundaries. 

 Commercial grade dedication of metal braided hose for CS-P-2A on June 18 (Quality 

Control Sample) 

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. 

 Switchyard breaker No. 52 maintenance and SW maintenance on April 7 

 'A' primary component cooling water to RHR heat exchanger valve maintenance on 

April 12 

 Scaffolding assembly during 'B' EDG maintenance preparations on April 22 

 'B' EDG maintenance and electric power sequencer testing on April 28 

 
11 

 ‘A’ EDG maintenance and guarded equipment verification on May 16 

 ‘A’ station service vital battery cross-tie and service testing on June 14 

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 based on the risk significance of the associated components and 

systems: 

 Gaps beneath missile barrier on SW pumphouse on March 28 

 'A' EDG fuel oil leak on April 14 

 Seismic isolation gaps in containment enclosure building (CEB) annulus on May 3 

 Main steam line loop 1 radiation monitoring failure on June 7 

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. The inspectors confirmed, where appropriate, compliance with 

bounding limitations associated with the evaluations. 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. 

b. Findings and Observations 

No findings were identified. 

The inspectors reviewed CR 2129621, “Seismic Isolation Gap Between Containment 

and CEB is Less Than Specified Value.” The CEB surrounds the containment and 

includes several cantilevered horizontal shield blocks that span the annulus region 

between the CEB and the containment. By design, there is a nominal 3-inch gap 

between the containment and the CEB shields to provide seismic isolation between the 

two structures. NextEra identified during field measurements of the CEB (to refine their 

finite element analysis model) that the gap appeared to have closed in some locations. 

As a result, a prompt operability determination (POD) for the reduced seismic isolation 

gap was completed. The POD addresses the potential impact of a loss of seismic 

isolation on structural integrity and seismic response between the CEB and containment. 

NextEra’s engineering analysis, as documented in the POD, conservatively assumed 

that the gap had closed to zero along the entire length of the one affected horizontal 

shield block. The analysis concluded that (1) the reduced gap would not have an impact 

on the structural integrity of the CEB or the containment; and (2) due to the higher 

stiffness of the containment the reduced gap would have a negligible impact on either 

structures’ seismic response. The POD concluded that the structures have adequate 
12 

margin and capacity to continue to perform their intended function, and that they were 

“Operable, but Degraded.” The POD also analyzed whether systems or components in 

areas adjacent to the affected shield block would be able to perform their functions 

during a seismic event. The POD concluded that all of the equipment that could be 

impacted by a seismic event either does not perform a safety function or would not be 

affected adversely. 

The inspectors reviewed the CEB seismic gap POD and the existing finite element 

analysis associated with the CEB deformation. The inspectors concluded that the 

analysis reasonably demonstrated that the structures have adequate margin to continue 

to perform their intended function, and equipment protected or supported by the affected 

structures would not be compromised due to the seismic gap reduction. The inspectors 

noted that NextEra included compensatory measures to monitor this area for additional 

degradation, and that the effects of this POD are likely linked to other PODs and will be 

included in a final operability determination. Based upon the inspectors’ review, this 

POD provides reasonable assurance of operability of the CEB and containment, while 

awaiting permanent resolution of this non-conforming condition. 

1R18 Plant Modifications (71111.18 – 2 samples) 

 Permanent Modifications 

a. Inspection Scope 

Containment Enclosure Ventilation Area Seal Repair and Modification 

The inspectors evaluated a modification to repair a seismic/ventilation seal located in the 

containment enclosure ventilation area, under engineering change package 285777. 

The inspectors verified that the design bases, licensing bases, and performance 

capability of the affected systems were not degraded by the modification. Moreover, the 

inspectors verified the modification to the seal configuration/location did not impact the 

functional capabilities of the seal for all applicable accident conditions. In addition, the 

inspectors reviewed modification documents associated with the design change, 

including vendor test reports for the replacement seal material to verify the results were 

consistent with the applicable licensing and design bases. 

Seismic Monitoring System Upgrade 

The inspectors evaluated a modification/upgrade to the seismic monitoring system 

implemented by engineering change package 282184. The inspectors verified that the 

design bases, licensing bases, and performance capability of the affected systems were 

not degraded by the modification. In addition, the inspectors reviewed modification 

documents associated with the upgrade and design change, including post-installation 

acceptance testing, replacement of the control room seismic monitor cabinet, and 

replacement of two standalone seismic accelerographs, located in the SW pumphouse 

and the PAB. The inspectors also reviewed revisions to affected control room alarm 

response procedures, and interim emergency plan impacts during system installation 

and testing. 

 
13 

b. Findings 

No findings were identified. 

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

a. Inspection Scope 

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

below to verify that procedures and test activities adequately tested the safety functions 

that may have been affected by the maintenance activity, that the acceptance criteria in 

the procedure were consistent with the information in the applicable licensing basis 

and/or design basis documents, and that the test results were properly reviewed and 

accepted and problems were appropriately documented. The inspectors also walked 

down the affected job site, observed the pre-job brief and post-job critique where 

possible, confirmed work site cleanliness was maintained, and witnessed the test or 

reviewed test data to verify quality control hold point were performed and checked, and 

that results adequately demonstrated restoration of the affected safety functions. 

 Containment building spray pump P-9A agastat inspection on April 11 

 RHR heat exchanger outlet valve troubleshooting on April 13 

 'B' EDG maintenance from April 25 to May 2 

 ‘A’ EDG maintenance outage from May 15 to 22 

 SW CT pump P-110B, discharge valve replacement on May 26 

 Digital rod position indication detector-encoder card replacement on June 1 

 ‘A’ charging system pump, CS-P-2A, lube oil piping replacement on June 18 

b. Findings 

No findings were identified. 

1R22 Surveillance Testing (71111.22 – 6 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: 

 Safety injection isolation valve stroke test on March 23 (IST) 

 SG pressure channel 1 analog channel operability test on April 11 

 'A' EDG operability surveillance 24‐hour run on April 13 

 Nuclear Instrument (NI)‐41 detector saturation curve determination on April 21 

 
14 

 Emergency power sequencer relay inspection on April 28 

 Turbine driven EFW pump quarterly test on June 22 

b. Findings 

No findings were identified.

Cornerstone: Emergency Preparedness 

1EP6 Drill Evaluation (71114.06 – 1 sample) 

 Training Observations 

a. Inspection Scope 

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

May 16, 2016, 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 

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01 – 4 samples) 

a. Inspection Scope 

The inspectors reviewed NextEra’s performance in assessing and controlling radiological 

hazards in the workplace. The inspectors used the requirements contained in 10 CFR 

20, TSs, applicable Regulatory Guides, and the procedures required by TSs as criteria 

for determining compliance. 

Inspection Planning 

The inspectors reviewed the performance indicators for the occupational radiation safety 

cornerstone, radiation protection program audits, and reports of operational occurrences 

in occupational radiation safety since the last inspection. 

Radiological Hazard Assessment 

The inspectors conducted independent radiation measurements during walkdowns of the 

facility and reviewed the radiological survey program, recent plant radiation surveys for 
15 

radiological work activities, and any changes to plant operations since the last inspection 

to verify survey adequacy of any new radiological hazards for onsite workers or 

members of the public. 

Instructions to Workers (1 sample) 

The inspectors reviewed high radiation area work permit controls and use, observed 

containers of radioactive materials and assessed whether the containers were labeled 

and controlled in accordance with requirements. 

The inspectors reviewed several occurrences where a worker’s electronic personal 

dosimeter alarmed. The inspectors reviewed NextEra’s evaluation of the incidents, 

documentation in the CAP, and whether compensatory dose evaluations were 

conducted when appropriate. The inspectors verified follow-up investigations of actual 

radiological conditions for unexpected radiological hazards were performed. 

Contamination and Radioactive Material Control 

The inspectors selected several sealed sources from inventory records and assessed 

whether the sources were accounted for and were tested for loose surface 

contamination. The inspectors evaluated whether any recent transactions involving 

nationally tracked sources were reported in accordance with requirements. 

Radiological Hazards Control and Work Coverage 

The inspectors evaluated in-plant radiological conditions and performed independent 

radiation measurements during facility walkdowns and observation of radiological work 

activities. The inspectors assessed whether posted surveys; radiation work permits; 

worker radiological briefings and radiation protection job coverage; air sampling and 

engineering controls; and dosimetry monitoring were consistent with the present 

conditions. The inspectors examined the control of highly activated or contaminated 

materials stored within the spent fuel pool and the posting and physical controls for 

selected high radiation areas (HRAs), locked high radiation areas and very high radiation 

areas (VHRA) to verify conformance with the occupational performance indicator. 

Risk-Significant HRA and VHRA Controls (1 sample) 

The inspectors reviewed the procedures and controls for HRAs, VHRAs, and radiological 

transient areas in the plant. 

Radiation Worker Performance and Radiation Protection Technician Proficiency 

(1 sample) 

The inspectors evaluated radiation worker performance with respect to radiation 

protection work requirements. The inspectors evaluated radiation protection technicians 

in performance of radiation surveys and in providing radiological job coverage. 

Problem Identification and Resolution (1 sample) 

The inspectors evaluated whether problems associated with radiation monitoring and 

exposure control (including operating experience) were identified at an appropriate 

threshold and properly addressed in the CAP. 
16 

b. Findings 

No findings were identified. 

2RS5 Radiation Monitoring Instrumentation (71124.05 – 3 samples) 

a. Inspection Scope 

The inspectors reviewed performance in assuring the accuracy and operability of 

radiation monitoring instruments used to protect occupational workers. The inspectors 

used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix I; TSs; Offsite 

Dose Calculation Manual (ODCM); Regulatory Guides; applicable industry standards; 

and procedures required by TSs as criteria for determining compliance. 

Inspection Planning 

The inspectors reviewed: Seabrook Station’s 2014 and 2015 annual effluent and 

environmental reports; UFSAR; ODCM; Radiation Protection audits; records of 

in-service survey instrumentation; and procedures for instrument source checks and 

calibrations. 

 Walkdowns and Observations (1 sample) 

The inspectors conducted walkdowns of plant area radiation monitors, continuous air 

monitors and process monitoring systems. The inspectors assessed material condition 

of these systems and that the monitor configurations aligned with the ODCM and the 

UFSAR. The inspectors checked the calibration and source check status of various 

portable radiation survey instruments and contamination detection monitors for 

personnel and equipment. 

Calibration and Testing Program (1 sample) 

The inspectors reviewed the current detector, electronic channel calibration, functional 

testing results and alarm set-points for: portal monitors, personnel contamination 

monitors, small article monitors, portable survey instruments, area radiation monitors, air 

samplers, and continuous air monitors. 

 Instrument Calibrator 

The inspectors reviewed the calibration standards used for portable instrument 

calibrations and response checks to verify that instruments were calibrated by a facility 

that used National Institute of Science and Technology traceable sources. 

 Calibration and Check Sources 

The inspectors reviewed the plant waste stream characterization to assess whether the 

calibration sources used were representative of the radiation encountered in the plant. 

 
17 

 Problem Identification and Resolution (1 sample) 

The inspectors verified that problems associated with radiation monitoring 

instrumentation were identified at an appropriate threshold and properly addressed in 

the CAP. 

b. Findings 

 No findings were identified. 

4. OTHER ACTIVITIES 

4OA1 Performance Indicator Verification (71151) 

 Reactor Coolant System (RCS) Specific Activity and Reactor Coolant System 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 Seabrook Unit 1 for the period of April 1, 2015 through 

March 31, 2016. To determine the accuracy of the performance indicator data reported 

during those periods, the inspectors used definitions and guidance contained in Nuclear 

Energy Institute Document 99-02, “Regulatory Assessment Performance Indicator 

Guideline,” Revision 7. The inspectors also reviewed RCS sample analysis and control 

room logs of daily measurements of RCS leakage, 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 – 1 sample) 

.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 NextEra entered issues into the CAP at an appropriate threshold, 

gave adequate attention to timely C/As, and identified and addressed adverse trends. In 

order to assist with the identification of repetitive equipment failures and specific human 

performance issues for follow-up, the inspectors performed a daily screening of items 

entered into the CAP and periodically attended CR screening meetings. The inspectors 

also confirmed, on a sampling basis, that, as applicable, for identified defects and nonconformances, NextEra performed an evaluation in accordance with 10 CFR Part 21. 

b. Findings 

No findings were identified. 
18 

.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 of CAP 

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

quarters of 2016 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 SelfEvaluation and Trending Analysis Report for first quarter of 2016, conducted under 

PI-AA-207-1000, “Station Self-Evaluation and Trending Analysis,” Revision 5, to verify 

that NextEra personnel were appropriately evaluating and trending adverse conditions in 

accordance with applicable procedures. 

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

the quarterly trend reports, which included the operations 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 determined to be emerging or adverse trends and in some 

cases this review 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. 

b. Findings and Observations 

No Findings were identified. 

In general, with the exceptions discussed below, the inspectors noted that new and 

existing adverse trends – including potential trends, management awareness areas, and 

those trends identified as cognitive trends during Management Review Committee 

reviews – were consistent with those identified by the NRC through daily CR reviews 

and plant status walkdowns. Examples of such trends included control of foreign 

materials exclusion issues during outages (including the April/May EDG outages), an 

open trend associated with component mispositioning events (including two events 

discussed in Section 4OA3 of this report), fire protection door degradation issues, and 

housekeeping issues. 

Inspectors identified a number of instances where due date extensions for C/As were not 

administered in accordance with the applicable revision of NextEra fleet procedure PIAA-104-1000, “Corrective Action.” These instances (summarized in Table 1 and 

Table 2) include six cases where the due dates for C/As or long-term corrective actions 

(LTCAs) were extended on multiple occasions without the required approval by the 

station’s Management Review Committee. These instances also included three cases 

where the required documentation for due date extension approval for C/As or corrective 

actions to prevent recurrence (CAPRs) were not captured in the licensee’s electronic 
19 

document management system as required by the established procedures. A number of 

these instances included C/As associated with the NextEra’s response to ASR-related 

developments. A similar issue, associated with unapproved due date extensions, was 

also documented in NRC Inspection Report 05000443/2016008, related to ASR effects 

on safety-related concrete structures. The issue was associated with a CR (AR 

01977456) that was also associated with one of the C/As (02014325-47) listed in 

Table 2 of this report. These performance deficiencies were considered to be minor in 

nature, in accordance with IMC 0612, Appendix B, “Issue Screening.” NextEra 

addressed these issues in their CAP (AR 2139720 and AR 2139722) and developed 

C/As to coach staff and establish a requirement that due date extensions be reviewed on 

a weekly basis by the responsible department corrective action Program Coordinator in 

order to ensure that the required authorization has been provided. Accordingly, this 

performance deficiency is not subject to further enforcement action, but is being 

documented for performance assessment purposes. 

The inspectors noted that, in February 2016, nuclear oversight staff identified issues 

associated with the multitude of due date extensions being implemented for lowsignificance-level C/As that do not require management approval/oversight for due date 

extensions (AR 2112323). Seabrook management subsequently took the C/A to 

increase management oversight of all C/A due date extensions and track 

improvements. However, in the scope of the February 2016 review of the issue, 

NextEra did not identify the above issues associated with due dates having been 

extended in a manner that was not in accordance with established procedures.

The inspectors also identified a number of instances where plant equipment was not 

adequately guarded in accordance with NextEra fleet procedure OP-AA-102-1003, 

“Guarded Equipment,” Revision 13. In these cases, measures to restrict access to 

certain plant equipment for the purposes of mitigating plant risk, either in accordance 

with established risk-mitigation strategies or in accordance with management direction, 

were not taken. The equipment thus remained in a condition where an individual could 

access/manipulate the equipment without clear and present indication of the 

equipment’s guarded status. However, there were no instances of inadvertent 

interaction with guarded equipment. These performance deficiencies were considered 

to be minor in nature in accordance with IMC 0612, Appendix B, “Issue 

Screening.” NextEra addressed the issue in their CAP (AR 2128093), and inspectors 

thereafter noted improvements in NextEra’s equipment guarding practices, including an 

increased emphasis on the importance of guarding equipment during morning staff 

meetings throughout the April/May EDG maintenance outages. Accordingly, this 

performance deficiency is not subject to further enforcement action, but is being 

documented for performance assessment purposes. 

 
20 

TABLE 1 

Corrective actions with due date extensions that were not approved in accordance with 

licensee procedures 

Assignment 

number CA Type Date CR was 

Initiated 

Number of 

due date 

extensions

Assignment description 

01687932-16 LTCA 02/13/2015 4 

ASR Improvement Plan Action 5.2.13 - 

Action to update the Structures Monitoring 

Plan to include monitoring and acceptance 

criteria for measuring Z-direction expansion 

01687932-15 CA 02/13/2015 3 ASR Improvement Plan Action 5.2.12 - 

Action to install Z-direction extensometers 

02034392-16 CA 06/22/2015 2 

Re-inspection of building seals, affected by 

ASR-related building movement, prior to 

returning them to maintenance rule 

category a(2) status 

01872576-13 LTCA 10/14/2014 1 

Track modification implementation to 

comply with requirements, associated with 

NRC CDBI inspection 

01673900-98 CA 04/25/2012 10 Developments associated with response to 

an industry reactor trip analysis 

01915226-26 CA 08/13/2014 5 

Action associated with industry input 

regarding a LOOP event with a transformer 

fire 

TABLE 2 

Corrective actions with due date extensions for which approval/justification was not 

documented in accordance with licensee procedures 

Assignment 

number CA Type Date CR was Initiated 

Number of 

due date 

extensions

Assignment description 

02014325-33 CAPR 08/19/2015 3 

Provide a case study, associated with 

building movement (e.g. ASR-related) 

issues to station leadership every two years 

02014325-47 CA 08/19/2015 3 

Track completion of corrective action 

1977456-17 to ensure crack gauges and 

invar wire are installed in the RHR vault to 

monitor crack progression 

02014325-75 CA 12/31/2015 1 

Revise analysis in Foreign Print 100985 

(associated with CEB deformation due to 

ASR with refined modeling to better quantify 

and distribute the effects of ASR induced 

strains 

 
21 

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153 – 2 samples) 

.1 (Closed) Licensee Event Report (LER) 05000455/2016-002-00: Emergency Feedwater 

System Actuation on Steam Generator Low-Low Level 

a. Inspection Scope 

On March 2, 2016, at 1:12pm, during a plant cooldown, a valid, but inadvertent, 

actuation of the EFW occurred when ‘B’ SG level reduced to 20%. The lowering level 

was a result of an unanticipated trip of the SUFP on low condensate storage tank (CST) 

level. The SUFP was restarted and feed flow had been restored when the actuation took 

place. Operators subsequently took actions to stabilize the plant and return EFW to its 

standby alignment. 

NextEra personnel completed a root cause evaluation to determine the cause of the 

SUFP trip and subsequent inadvertent EFW actuation. NextEra thereafter took C/As, 

including the development of training to reinforce the associated departmental 

instructions and the revision of associated alarm responses. 

The inspectors reviewed LER 2016-002-00, NextEra’s root cause evaluation, and 

associated C/As. This LER is closed. 

b. Findings 

Introduction. A self-revealing Green NCV of 10 CFR, Appendix B, Criterion V, 

“Instructions Procedures, and Drawings,” was identified, because NextEra did not 

ensure that activities affecting quality were accomplished in accordance with 

documented instructions. Specifically, while implementing a procedure following a plant 

trip that occurred on March 2, 2016, NextEra staff performed steps of a procedure in a 

manner that was prohibited by a departmental instruction, leading to an automatic 

initiation of EFW to maintain adequate SG level. 

Description. On March 2, 2016, Seabrook Unit 1 was in Operational Mode 3 following a 

turbine and reactor trip associated with a perturbation in the turbine control system. The 

operating crew entered into emergency operating procedures and appropriately 

transitioned into ES-0.1, “Reactor Trip Response.” As part of ES-0.1, EFW was secured 

and the SUFP was aligned to the CST to supply water to the SGs. 

Subsequently, the operating crew transitioned to OS1000.11, “Post Trip to Hot Standby,” 

Section 4.1, which contained actions to prepare for a plant cool-down. In parallel, the 

crew also began implementing steps in Section 4.4 of the procedure. The operators’ 

actions were contrary to operations department instruction (ODI)-87, which stated that 

“[m]ajor procedure sections (i.e. 4.1, 4.2, etc.) MUST be completed prior to performing 

steps in the next section.” The operating crew took these steps based on the belief that 

they were only implementing preparatory actions. While work was being performed on 

the two sections, a shift turnover took place, demonstrating that both the off-going and 

incoming operating crews proceeded contrary to the ODI-87 requirement. 

NextEra’s evaluation concluded that performance of steps in Section 4.4, resulted in a 

plant configuration where water was transferred from the CST to the SUFP and the 
22 

condenser hotwells at a rate faster than CST makeup functions were capable of 

maintaining CST inventory. If the operators had completed the steps in Section 4.1 of 

OS1000.11, prior to proceeding to Section 4.4, the condensate cleanup filters would 

have been placed in service and SUFP suction would have been aligned to both the 

CST and the hotwells via the filters, which would have allowed CST inventory to be 

maintained. 

Prior to the event, a CST low level alarm was received in the control room, and the 

operating crew subsequently commenced a plant cooldown in accordance with 

OS1000.04, “Plant Cooldown from Hot Standby to Cold Shutdown,” even though the 

SUFP suction had not yet been aligned to the hotwells due to unsatisfactory results from 

a chemistry analysis of the condensate cleanup filters. These actions resulted in 

decreasing SG levels (temperature shrink) and increasing feedwater flow. The lowering 

CST level and SUFP suction pressure resulted in a trip of the SUFP that caused 

continued lowering of SG water levels. 

Subsequent to the SUFP trip, the shift manager established an administrative setpoint to 

manually start the ‘B’ EFW pump if narrow range SG levels dropped below 24%. The 

crew proceeded to halt the cooldown, and aligned the SUFP suction to the hotwells, to 

restore feedwater flow. When the SUFP was restarted, the resultant introduction of cold 

feedwater led to a further reduction (shrink) in SG level, as expected, and narrow range 

SG levels dropped below the 24% administrative setpoint without operator action to 

manually start EFW to maintain SG inventory, contrary to the administrative guidance 

previously established by the shift manager. As a result, narrow range SG level 

continued to lower until the ‘B’ SG level dropped below 20%, automatically initiating the 

EFW pumps. Operators subsequently took actions to stabilize the plant. 

This event was entered into NextEra’s CAP (AR 2114495), and a root cause evaluation 

(RCE) was initiated. This evaluation determined the root cause of the inadvertent EFW 

actuation to be a failure to adhere to procedural guidance listed in ODI-87. The 

evaluation stated, “All individuals involved were aware of the requirements of ODI-87, 

yet they did not challenge each other or correct the behavior.” The RCE prescribed a 

series of C/As, including the development of training to reinforce the guidance contained 

in ODI-87 and revision of alarm response procedures for CST low level, SUFP trip, and 

SG low level alarms. 

Analysis. The inspectors determined that the failure to adhere to plant operating 

instructions, and ensure adequate control of plant conditions, was a performance 

deficiency within NextEra’s ability to foresee and prevent. The inspectors determined 

that this performance deficiency was more than minor because it was associated with 

the Human Performance attribute of the Initiating Events cornerstone, and adversely 

affected the cornerstone objective of limiting the likelihood of events that upset plant 

stability (loss of FW) and challenge critical safety functions during shutdown as well as 

power operations. Specifically, failure to adhere to the guidance prescribed in ODI-87 

led plant operators to perform a combination of steps that resulted in the inadvertent 

tripping of the SUFP on low suction pressure. The subsequent loss of feedwater flow to 

the SGs impacted SG levels and resulted in an automatic actuation of the EFW 

pumps. In accordance with IMC 0609, Attachment 4, “Initial Characterization of 

Findings,” and IMC 0609, Appendix A, “The Significance Determination Process for 

Findings At-Power,” the inspectors determined that this finding was of very low safety 

significance (Green) because the performance deficiency did not cause the loss of 
23 

mitigation equipment relied upon to transition the plant from the onset of a trip to a stable 

shutdown condition. Specifically, the actuation of the EFW pumps occurred in 

accordance with designed plant response and ensured that adequate feedwater levels 

were maintained in the SGs. 

The inspectors determined that this finding had a cross-cutting aspect in the area of 

Human Performance, Challenge the Unknown, because NextEra did not ensure that 

individuals stopped when faced with uncertain conditions. Specifically, individuals 

involved did not maintain a questioning attitude during a shift turnover meeting, and thus 

did not take the opportunity to adequately challenge the basis for a decision to disregard 

a department instruction. Two separate crews missed the opportunity to challenge this 

decision. Additionally, individuals did not stop work activities when confronted with 

unexpected conditions that delayed aligning the SUFP suction to the hotwells, and the 

operating crew did not resolve these conditions prior to commencing a plant 

cooldown. [H.11] 

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

affecting quality be accomplished in accordance with documented instructions. 

Specifically, instruction in ODI-87 requires that ‘[m]ajor procedure sections (i.e 4.1, 4.2, 

etc.) must be completed prior to performing steps in the next section.” Contrary to the 

above, following a reactor trip on March 2, 2016, while performing procedure OS1000.11 

associated with plant recovery, NextEra staff did not complete a major procedure 

section (4.1) prior to performing steps in another section (4.4) when steps were 

simultaneously performed in these two sections (4.1 and 4.4) of the procedure in a 

manner that was prohibited by ODI-87. The sequence of steps performed introduced 

plant conditions that led to a loss of feedwater flow from the SUFP to the SGs, and an 

automatic initiation of EFW pumps. NextEra entered this issue into their CAP 

(AR 2114495) and subsequently initiated a root cause evaluation to determine the 

factors which contributed to the event. Additionally, NextEra took C/As to provide 

additional training and guidance for their staff and to resolve issues with existing 

procedures, which were determined to have been contributing factors during the 

event. This violation is being treated as an NCV, consistent with Section 2.3.2 of the 

NRC Enforcement Policy. (NCV 05000443/2016002-01, Automatic Initiation of 

Emergency Feedwater Resulting from Performance of Procedural Steps in a 

Manner Prohibited by Documented Instructions)

.2 Inadvertent Letdown Isolations 

a. Inspection Scope 

On two separate occasions, on May 25 and June 3, 2016, while operators were 

performing a test associated with containment isolation functions, an inadvertent 

isolation of letdown occurred when performed actions led to the accidental opening of an 

electrical connection that was intended to be bypassed by an installed electrical 

jumper. Following the loss of letdown, operators entered into the requisite AOP, and 

took actions to restore letdown flow and charging flow, and to restore boration levels 

within the RCS to ensure proper steady-state reactivity levels. NextEra personnel 

completed apparent cause evaluations to determine the cause of both of the letdown 

isolation events and took C/As, including making necessary changes to the associated 

procedure and providing coaching to staff. 
24 

The inspectors reviewed NextEra’s apparent cause evaluation for the two events, along 

with associated C/As, and identified a self-revealing performance deficiency that was 

characterized as more than minor and is documented below. 

b. Findings 

Introduction. A self-revealing Green NCV of 10 CFR, Appendix B, Criterion V, 

“Instructions Procedures, and Drawings,” was identified because NextEra did not ensure 

that activities affecting quality were prescribed by documented procedures of a type 

appropriate to the circumstances and that these activities were accomplished in 

accordance with these procedures. Specifically, a procedure associated with the testing 

of safety-related containment isolation functions did not contain sufficient instruction to 

ensure proper control of plant configuration; thus implementation of this procedure 

resulted in an inadvertent letdown isolation. Additionally, while attempting to perform 

this test on a subsequent occasion, individuals performed additional steps not prescribed 

in the associated procedure; the execution of these additional steps resulted in an 

additional inadvertent letdown isolation. 

Description. On May 25, 2016, NextEra was performing a quarterly slave relay test 

associated with safety-related containment isolation functions. The associated 

procedure, OX1456.83, “Train B ESFAS Slave Relay K624 Quarterly Go Test,” 

Revision 6, contained a step calling for the installation of a jumper to disable operation of 

letdown isolation valve CS-V-150 during performance of the test. Closure of CS-V-150 

during testing would result in a loss of letdown flow, requiring operator action to stabilize 

and restore plant configuration. 

During performance of the procedure, a technician installed the electrical jumper 

associated with CS-V-150 that also contained a switch to allow adjustment to the open 

or closed position. The inspectors noted that the procedure did not contain additional 

instructions, guidance, or verification requirements to ensure that the jumper’s switch 

was in its required configuration to ensure a closed connection prior to performance of 

certain critical steps within theprocedure. During continued performance of the 

procedure, with the electrical jumper’s switch in the open position, a slide link was 

terminated which opened the connection that the jumper was intended to bypass. This 

open circuit resulted in the closure of CS-V-150 and a loss of letdown flow. 

NextEra entered the event into their CAP (AR 0214335) and investigated the associated 

causal factors. NextEra determined that the procedural guidance on the use of the 

jumper switch was inadequate and cited ineffective communication of the status of this 

equipment as a contributing factor. NextEra also established C/As to perform an 

Apparent Cause Evaluation for the event and make necessary changes to the 

associated procedure and other procedures that implemented this type of electrical 

jumper. Procedure changes were incorporated into Revision 7 of OX1456.83, providing 

more detailed instruction regarding the installation of the associated jumper and 

independent verification of its configuration. 

Subsequently, on June 3, 2016, while re-performing the test, technicians properly 

installed the electrical jumper and control room operators proceeded with actuation of 

the test signal for Phase ‘A’ containment isolation. A subsequent procedure step 

required the technicians to verify contact status for the actuated relay device. At this 

point the technicians agreed to perform a test of the multimeter being used to confirm its 
25 

operation and lead integrity, an action which was not explicitly listed in the procedure 

and required the technicians to remove one of the meter’s test leads. Instead, the 

technician performing the action mistakenly disconnected one of the electrical jumper 

leads, which was located adjacent to the meter test lead. Disconnection of the electrical 

jumper terminated the circuit, which satisfied the logic for operation of CS-V-150, and 

resulted in closure of the valve and a loss of letdown flow. 

NextEra entered the event into their CAP (AR 2136006) and investigated the human 

performance aspects associated with the event. NextEra determined that the removal of 

meter test leads was not a step explicitly in the continuous-use procedure. It also 

required the technicians to perform steps to manipulate test equipment that was 

connected to plant equipment without documentation or verification. NextEra 

management acknowledged that these steps, which were considered a “skill-of-worker” 

technique, were inappropriate and unnecessary, given that testing equipment is 

calibrated and tested prior to performing work. Additionally, NextEra’s review of the 

event determined that failure to use human error reduction techniques, such as the 

“STAR” (“Stop, Think, Act, Review”) process, while attempting to remove the multimeter 

test leads was a significant contributing factor. 

On both occasions, following the loss of letdown flow, the inspectors noted that control 

room operators entered into the requisite abnormal operating procedure, OS1202.01, 

“Loss of Letdown,” Revision 13, and took actions to restore letdown flow and charging 

flow, and to restore boration levels within the RCS to ensure proper steady-state 

reactivity levels. Once plant configuration was restored, testing equipment was 

removed, and the testing procedure was exited. 

Analysis. The inspectors determined that the failure to establish and/or adhere to 

adequate testing procedures and thereby ensure control of plant configuration was a 

performance deficiency within NextEra’s ability to foresee and prevent. The inspectors 

determined that this performance deficiency was more than minor because it was 

associated with the Procedure Quality and the Human Performance attributes of the 

Initiating Events cornerstone and adversely affected the cornerstone objective of limiting 

the likelihood of events that upset plant stability during power operations. Specifically, 

for the event that took place on May 25, the procedure did not contain critical steps 

necessary to install test equipment in a manner sufficient to maintain control of plant 

configuration. During the June 3 event, individuals installing testing equipment 

performed steps that were not listed in the associated procedure. As a result, actions 

taken on these two occasions led to an inadvertent isolation of letdown flow, which 

required operators to enter into an abnormal operating procedure to restore control and 

stability of RCS inventory and reactivity levels. In accordance with IMC 0609, 

Attachment 4, “Initial Characterization of Findings,” and IMC 0609, Appendix A, “The 

Significance Determination Process for Findings At-Power,” both dated June 19, 2012, 

the inspectors determined that this finding was of very low safety significance (Green) 

because the performance deficiency did not cause a reactor trip and the loss of 

mitigation equipment relied upon to transition the plant from the onset of a trip to a stable 

shutdown condition. 

The inspectors determined that this finding had a cross-cutting aspect in the area of 

Human Performance, Procedural Adherence, because NextEra did not ensure that 

individuals followed processes and procedures appropriately. Specifically, during the 

event on May 25, individuals involved did not adequately review procedures and 
26 

instructions before performing work to validate that they were appropriate for the scope 

of work, in that, they did not recognize the need for more detailed instructions in order to 

ensure that a jumper cable, necessary to maintain the configuration of a letdown 

isolation valve, was installed correctly. During the event on June 3, individuals involved 

did not ensure that they only manipulated plant equipment when appropriately 

authorized and directed by approved plant procedures or work instructions. Instead, 

these individuals relied upon trained skills/actions when manipulating testing equipment 

in a manner not explicitly prescribed by the procedure. Furthermore, the individuals 

manipulating this testing equipment did not use human error reduction techniques, such 

as the “STAR” (Stop, Think, Act, Review) process. [H.8] 

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

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

circumstances and that these activities be accomplished in accordance with those 

procedures. Contrary to the above, a NextEra procedure implemented on May 25, 2016, 

during the performance of a test associated with a safety-related containment isolation 

function, did not contain sufficient instruction to ensure that critical steps were taken to 

install testing equipment in a manner that would maintain plant configuration and prevent 

an inadvertent letdown isolation. On June 3, 2016, while re-performing the same test, 

NextEra technicians performed steps not prescribed in the associated procedure and 

executed these steps in a manner that led to an inadvertent letdown isolation. NextEra 

entered these issues into their CAP (AR 2134335 and AR 2136006) and subsequently 

performed apparent cause evaluations for the two events, made necessary changes to 

the associated procedure, and provided coaching to NextEra staff. This violation is 

being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement 

Policy. (NCV 05000443/2016002-02, Multiple Letdown Isolations Resulting from an 

Inadequate Procedure and the Performance of Steps Not Prescribed by 

Established Procedures)

4OA6 Meetings, Including Exit 

On July 20, 2016, the inspectors presented the inspection results to Mr. Eric McCartney, 

Site Vice President, and other members of the Seabrook 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 

E. McCartney, Site Vice President 

R. Dodds, Plant General Manager 

K. Boehl, Senior Rad Protection Analyst 

M. Bianco, Radwaste Supervisor 

V. Browne, Senior Licensing Engineer 

K. Douglas, Maintenance Director 

D. Hickey, Radiation Protection Supervisor 

K. Browne, Licensing Manager 

V. Pascucci, Nuclear Oversight Manager 

D. Ritter, Site Operations Director 

D. Robinson, Chemistry Manager 

T. Smith, Radiation Protection Supervisor 

D. Strand, Radiation Protection Manager 

NRC Personnel: 

A. Bufford, Structural Engineer, Office of Nuclear Reactor Regulation (NRR) 

B. Lehman, Structural Engineer, NRR 

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED 

Opened/Closed 

05000443/2016002-01 NCV Automatic Initiation of Emergency Feedwater 

Resulting from Performance of Procedural Steps 

in a Manner Prohibited by Documented 

Instructions (Section 4OA3.1) 

 

05000443/2016002-02 NCV Multiple Letdown Isolations Resulting from an 

Inadequate Procedure and the Performance of 

Steps Not Prescribed by Established Procedures 

(Section 4OA3.2) 

 

Closed 

05000443/2016-002-00 LER Emergency Feedwater System Actuation on 

Steam Generator Low-Low Level (Section 

4OA3.1) 
A-2 

LIST OF DOCUMENTS REVIEWED 

Section 1R01: Adverse Weather Protection 

Procedures 

LN0561.174, 72 Month Mitsubishi Gas Circuit Breaker 52 Preventive Maintenance, Revision 3 

OP-AA-102-1002, Seasonal Readiness, Revision 13 

OS1046.04, 345KV Operations, Revision 41 

OS1246.02, Degraded Vital AC Power (Plant Operating), Revision 16 

Condition Reports 

2123799 2124074 2125531 2130543 2130558 2131134 

2131135 2131392 2133587 2139744 

Maintenance Orders/Work Orders 

40204395 40314055 40327451 40365809 40394927 40405235 

40433687 40443099 40456432 

Miscellaneous 

2016 Seasonal Readiness Certification to NextEra Energy CNO, dated 5/24/2016 

Hood, Patterson and Dewar Job No. 4052.000, Seabrook Station Site Grounding Test Report, 

 dated 10/24/2014 

ISO New England Master/LCC No. 1, “Nuclear Plant Transmission Operations,” Revision 15 

ISO New England Master/LCC No. 1, Attachment D, Revision 18 

SSTR, Technical Requirements Manual, TR 31-3.1, Supplemental Emergency Power System 

 Availability Requirements, Revision 145 

Section 1R04: Equipment Alignment 

Procedures 

OS1002.02, Operation Of Letdown, Charging And Seal Injection, Revision 49 

OS1013.04, Residual Heat Removal Train B Startup and Operation, Revision 28 

OS1026.02, Operating the DG 1A Lube Oil System, Revision 16 

OS1026.03, Operating the DG 1A Jacket Cooling Water System, Revision 11 

OS1026.05, Operating the DG 1A Fuel Oil System, Revision 18 

OS1035.01, Aligning The Emergency Feedwater System For Automatic Initiation, Revision 20 

OS1048.14, Vital Bus 11B Operation, Revision 10 

OX1436.08, StartupFeed Pump Quarterly Surveillance, Revision 13 

Condition Reports 

2091000 2091317 2128648 2136027 

Maintenance Orders/Work Orders 

1205176 

Maintenance Requests/Work Requests 

94139305 

Miscellaneous 

Seabrook Emergency Feedwater System Detailed Systems Text, Revision 10 
A-3 

Drawings 

1-CS-B20725, Chemical & Volume Control Charging System Detail, Revision 32 

1-FW-B20582, Main Steam System Emergency Feedwater Pump Supply Detail, Revision 21 

1-FW-B20684, Feedwater System Overview, Revision 10 

1-FW-B20686, Feedwater System Details, Revision 13 

1-FW-B20688, Emergency Feedwater System Details, Revision 21 

1-MS-B20587, Main Steam System main Steam Drains Detail, Revision 17 

1-NHY-310041, 125vdc and 125vac Instrument Buses Key One Line Diagram, Revision 18 

1-RH-B20663, Residual Heat Removal Sys. Train B Cross-Tie Detail, Revision 21 

Section 1R05: Fire Protection 

Condition Reports 

2040997 2139794 2139795 

Miscellaneous 

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

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, ‘B’ RHR Vault, RHR-F-1A-1C 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, ‘B’ RHR Vault, RHR-F-1A-2A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, ‘B’ RHR Vault, RHR-F-1A-3A 

Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, ‘B’ RHR Vault, RHR-F-4A-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 II, TB-F-3-0 

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

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

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

Seabrook Station Evaluation and Comparison to BTP APCSB 9.5-1, Appendix A, Revision 13A 

Section 1R06: Flood Protection Measures 

Condition Reports 

02138724 02140442 02142036 

Maintenance Orders/Work Orders 

40209732-21 

Miscellaneous 

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

Drawings 

1-CBS-B20233, Containment Spray System, Revision 28 

1-CBS-D20233, Containment Spray System, Revision 25 

9763-F-310248, Underground Duct Plan, Revision 13 

9763-F-101629, Main Steam & Feedwater Pipe Chase (West) Concrete Section, Sheet 3, 

 Revision 2 

9763-F-805150, Radioactive Tunnel Composite Piping Zones 28A & 28B, Revision 16 

9763-F-805582, Containment Penetration Area Sleeves Zone 28A, 28B & 29A Tabulation, 

 Revision 20 
A-4 

Section 1R07: Heat Sink 

Procedures 

ES1807.032, Form B: VT-2 Visual Examination Form, Revision 6 

ES04-01-03, Analog and Digital Eddy Current Inspection of Heat Exchanger Tubes, Revision 4 

Condition Reports 

2128111 2128305 2128343 2128600 2128615 2128711 

Maintenance Orders/Work Orders 

40312389 40433400 

Section 1R11: Licensed Operator Requalification Program 

Procedures 

TR-AA-230-1007, Conduct of Simulator Training and Evaluation, Revision 3 

Miscellaneous 

Simulator Demonstrative Examination #07, Revision 16 

Crew Simulator Evaluation Form 

Individual Simulator Evaluation Form 

Section 1R12: Maintenance Effectiveness 

Condition Reports 

2138627 

Miscellaneous 

Commercial Grade Dedication Evaluation No. 471964/65 

Catalog ID No. 1740636-2, Metal Braided Flex Hose 

Corporate Procurement Engineering & Dedication (CPED) Engineering and Interface Review, 

 NSC Form No. 4032, Revision 1 

Section 1R13: Maintenance Risk Assessments and Emergent Work Control 

Procedures 

MA 4.10, Control of Temporary Equipment, Temporary Power, Job Setup and Plant Storage, 

 Revision 18 

OP-AA-100-1000, Work Activity Risk Management, Revision 5 

OP-AA-102-1003, Guarded Equipment, Revision 13 

Condition Reports 

2123881 2128093 

Maintenance Orders/Work Orders 

40157687 40323884 40327451 40378636 40383557 40394922 

40401167 40401179 40412352 

 
A-5 

Miscellaneous 

Maintenance Rule a(4) Risk Profile for Work Week 1620-12 

Maintenance Rule a(4) Risk Profile for Work Week 1614-07 

Maintenance Rule a(4) Risk Profile for Work Week 1624-03 

Scaffold & Temporary Equipment Engineering Evaluation 16-03 

Section 1R15: Operability Determinations and Functionality Assessments 

Procedures 

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 21 

PI-AA-104-1000, Corrective Action, Revision 6 

PI-AA-104-1000, Corrective Action, Revision 8 

Condition Reports 

2044627 2097743 2120993 2121167 2123509 2123529 

2129621 2132490 2132491 2136405 2136716 2140674 

Maintenance Orders/Work Orders 

622492 40438886 40471327 

Miscellaneous 

Condition Evaluation for AR 2129621 

FP 100911, Tornado Missile Protection Barrier, Service Water Pumphouse, Revision 0 

FP 100912, Robust Missile Protection Barrier, Calculations and Analyses, Revision 4 

FP 100976, Seismic Joint Measurements, Revision 1 

Prompt Operability Determination for AR 2129621, Revision 0 and Revision 1 

Drawings 

9763-F-101453, Containment Enclosure Building Concrete Plan at El. 10’-0”, South, 

Revision 11 

9763-F-101457, Containment Enclosure Building Concrete Sections – Sheet 1, Revision 12 

Section 1R18: Plant Modifications 

Procedures 

EP-AA-105-1000, Form 1, Emergency Equipment Functional Assessment Tool, Revision 0 

ES1802.01, Earthquake Response, Revision 7 

IX1670.920, Seismic Monitoring System Functional Test, Revisions 11 and 12 

IX1670.919, SM-X-6708 Service Water Pumphouse Seismic Monitor Calibration, Revisions 8 

 and 9 

OS1200.04, Seismic Event Response, Revision 4 

Condition Reports 

2073622 2108874 2131025 2131948 2207678 

Maintenance Orders/Work Orders 

40292272 40356697 
A-6 

Miscellaneous 

Calculation C-S-1-61035, Allowable CEVA Penetration Seal Opening Size, Revision 3 

FP 4497R, Penetration Seal Design, Revision 2 

FP 700511, Seismic Qualification of XR-6707, 6708, and 1-SM-CP-58 

FP 72971, Seismic Qualification of XT-6700, XT-6701, and XT-6710 

Regulatory Guide 1.12, Nuclear Power Plant Instrumentation for Earthquakes, Revision 2 

Drawings 

1-NHY-BD-2014, Containment Enclosure Ventilation Area Elev. 21’-6”, Revision 9 

Section 1R19: Post-Maintenance Testing 

Procedures 

ES1850.001, Check Valve Performance Monitoring Program, Revision 10 

ES1807.025, Form B, VT-2 Visual Exam Form, Revision 6 

IS1632.902, Diesel Generator 1B Governor Tuning, Revision 8 

IS1636.904, Woodward Digital Reference Unit, DRU, Bench Calibration, Revision 2 

IS1666.910, Shutdown and Control Rod Position Indication Operational Test, Revision 6 

MS0539.68, EDG Mechanical Overspeed Trip Adjustment and Repair, Revision 0 

MX0539.50, Emergency Diesel generator Engine 24 Month Preventative Maintenance, 

Revision 8 

OX1426.26, DG 1A Semiannual Operability Surveillance, Revision 24 

OX1416.04, Service Water Quarterly Pump and Discharge Valve Test and Comprehensive 

 Pump Test, Revision 20 

OX1406.02, Containment Spray Pump and Valve Quarterly Operability, 18 Month Position 

 Indication and Comprehensive Pump testing, Revision 19 

OX1456.81, Operability Testing of IST Valves, Revision 25 

Condition Reports 

2124957 2127856 2127868 2127873 2129581 2132263 

2132467 2132681 2132832 2133044 2135240 2138627 

Maintenance Orders/Work Orders 

40125689 40157687 40276733 40312389 40323884 40363143 

40383508 40383629 40383673 40396248 40396710 40407945 

40409206 40455824 40463879 40463920 40467381 

Miscellaneous 

FP54946/W120-15, Westinghouse DRPI Technical Manual 

Operability determination 04-07911 

Drawings 

ILD-DG-S09588, Instrument Loop Diagram, DG-1-B, Engine Speed, Revision 0 

1-SW-D20794, Service Water System Nuclear Detail, Revision 38 

Section 1R22: Surveillance Testing 

Procedures 

AD-AA-100-1006, Procedure and Work Instruction Use and Adherence, Revision 9 

IX1640.315, Protection Cabinet 1 Steam Generator Steamline Pressure Operational Test, 

 Revision 10 
A-7 

IX1656.945, NI-N-41 Power Range NI Detector Saturation Curve, Revision 2 

IX1656.945, NI-N-41 Power Range NI Detector Saturation Curve, Revision 3 

LS0563.114, ‘B’ Diesel Generator Emergency Power Sequencer Output Relay PM, Revision 2 

OX1405.11, SI Containment Isolation Valve Quarterly Stroke Tests, Revision 5 

OX1426.22, Emergency Diesel Generator 1A 24 Hour Load Test and Hot Restart Surveillance, 

 Revision 23 

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

 Alignment, Revision 25 

Condition Reports 

2124607 2125280 2125470 2125493 2127157 2134079 

2135119 

Maintenance Orders/Work Orders 

40383557 40395437 40396716 40396724 40401174 40412692 

Miscellaneous 

Calculation C-S-1-E-0161, Fuel Oil Consumption Rate Calculation, Revision 18 

Manuals and Procedures Administration Manual, Appendix C, Operating Procedure Writer’s 

 Guide, Revision 6 

Section 1EP6: Drill Evaluation 

Procedures 

EP-AA-101-1000, Nuclear Division Drill and Exercise Procedure, Revision 15 

ER 1.1, Classification of Emergencies, Revision 55 

ER 1.2, Emergency Plan Activation, Revision 65 

Section 2RS1: Access Control to Radiologically Significant Areas 

Procedures 

RP-AA-101-2004, Method for Monitoring and Assigning Effective Dose Equivalent for High Dose 

 Gradient Work, Revision 4 

RP-AA-102-1000, Alpha Monitoring, Revision 2 

RP-AA-102-1001, Area Radiological Surveys, Revision 1 

RP-AA-103-1001, Posting Requirements for Radiological Hazards, Revision 2 

RP-AA-103-1002, High Radiation Area Controls, Revision 3 

RP-AA-107-1001, Radioactive Material Receipt, Revision 3 

RP-AA-107-1002, Requirement Radioactive Material Stored Outdoors, Revision 2 

RP-AA-107-1003, Unconditional and Conditional Release of Material, Revision 1 

RP-AA-108-1003, Radioactive Material Shipment Surveys, Revision 2 

HD0958.01, Air Sampling, Revision15 

HD0958.17, Performance of Routine Radiological Surveys, Revision 13 

HD0955.50, Far West REM-500 Operation, Revision 6 

HD0958.36, Radioactive Material Storage Control, Revision 15 

HN0958.13, Generation and Control of Radiation Work Permits, Revision 39 

HN0960.10, Radiological Requirements for Entry Beneath Reactor Vessel, Revision 31 

HN0960.16, Radiological Requirements for Spent Process Filter Replacement, Revision 11 

HN0960.17, Radiological Controls for Transfer of Spent Fuel between the Containment and the 

Spent Fuel Pool, Revision 4 

HX0958.23, Radioactive Source Control, Revision 23 
A-8 

OA 13-007 Pre-Planned Posting and Survey Instructions, Revision 0 

WD0598.069, Storage of Radioactive Waste, Revision 8 

Condition Reports 

02092044 02092275 02100839 02102030 02107005 02119191 

02120012 02120839 02122261 02122268 02122278 02122283 

02122286 02123492 

Self-Assessment and Audits Reviewed: 

SBK 16-001 Nuclear Oversight Audit of Radiation Protection and Radwaste, April 7, 2016 

Documents 

Air Sample Results 16-14, SFB SKC Pump, January 7, 2016 

Air Sample Results 16-93, Waste Processing Building-MF105, March 2, 2016 

Air Sample Results 16-107, Containment Building 0 El, March 6, 2016 

Documentation of Health Physics Review for Isotopic Mixture 15-01, April 13, 2016 

Equivalent Weighting Factors for External Exposure, February 28, 2007 

HD0958.19 Form A Dosimetry Abnormality Occurrence Report, ED# 873820, Dose Rate Alarm 

During Coolant Filter Transfer to Cask, March 8, 2016 

HD0958.19 Form A Dosimetry Abnormality Occurrence Report, ED# 865484 Dose Rate Alarm 

in RHR Discharge Line, March 1, 2016 

HD0958.19 Form A Dosimetry Abnormality Occurrence Report, ED# 201750 Dose Rate 

Alarm -16 El RHR, March 6, 2016 

Radiation Protection Department Qualification Guide for Health Physics Technician, LMS 

No. 73545, REM-500, September 5, 2012 

Radiation Protection Department Qualification Guide for Health Physics Technician, SIDs 

No. 28549, REM-500, July 24, 2006 

Seabrook Station and Turkey Point Nuclear Plant Units 3 and 4 – Application to Use Effective 

Survey # M-20160405-5, HSYW-020 PAB-25-PB407, Chemistry Sample Sink and PASS 

sample Cubicles, April 5, 2016 

Survey # M-20160403-1, HSYW-020 PAB-25-PB407, Chemistry Sample Sink and PASS 

sample Cubicles, April 3, 2016 

Survey # M-20151208-4, HSYQ066A FSB-21-FB202, Fuel Storage Building - Quarterly Routine, 

December 8, 2015 

Survey # M-20160127-4, HSYQ066A FSB-21-FB202, Fuel Storage Building - Quarterly Routine, 

January 27, 2016 

Survey # M-20160211-3, HSYQ-001M Dry Fuel Storage Facility, February 11, 2016 

Survey # M-20160406-3, HSYQ-001M Dry Fuel Storage Facility, April 6, 2016 

Survey # M-20160317-4 & M-20160317-5 Non Exempt Source Inventory and Leak Test, 

March 24, 2016 

RP-AA-103-1002-F12, LHRA in Service Key Box Log, November 4, 2015 

RWP-16-0015, High Integrity Container/Liner Shipping, January 2, 2016 

RWP-16-0013, Radwaste Filter Replacement and Preparations for Shipment, January 2, 2016 

e-mail from NSTS Fax Resource to M. Ossing, RE: NSTS Notification 2016 AIR, 

Completed ID 5897, April 4, 2016 

U.S. NRC letter to Florida Power and Light, Co., RE: Duane Arnold Energy Center Dose 

 
A-9 

Section 2RS5: Radiation Monitoring Instrumentation 

Procedures 

HD0955.05, Operation Portable Rad Mont Instruments, Revision 21 

HD0955.19, Use of Sheppard Model 81 Beam Calibrator, Revision 12 

HD0955.42, Operation SAM and Chronos Monitors, Revision 8 

HD0955.47, Operation of the APTEC Model FM-1 Floor Monitor, Revision 6 

HD0955.48, Laboratory Instrument Control Charts, Revision 6 

HD0955.50, Far West REM-500 Operation, Revision 6 

HD0955.53, Use of AMS-4, Revision 4 

HD0955.62, Use Argos 4AB, Revision 3 

HD0955.63, Use Sirius 2 Hand and Foot Counter, Revision 1 

HD0955.64, Use MGP DRM 1 and 2 Area Rad Monitors, Revision 5 

HD0955.69, Use of GEM 5 Gamma Exit Monitor, Revision 2 

HD0961.31, Canberra Whole Body Counting System Operation, Revision 11 

HD0961.32, Canberra WBC Calibration, Revision 1 

HD0961.34, Canberra FASTSCAN WBC Operation, Revision 8 

HD0963.34, Calibration PNR 4 Neutron Rem Counter, Revision 7 

HD0963.38, Calibration of Ludlum 220 Portable Scaler Ratemeter, Revision 5 

HD0963.45, Calibration AMS-4 CAM, Revision 1 

HD0963.47, Tennelec Series 5 XLB Smear Counter Calibration, Revision 1 

HD0963.51, Calibration Argos 4AB, Revision 5 

HD0963.52, DRM 2 Area Rad Mont Calibration, Revision 1 

HD0963.53, Calibration Sirius 2 Hand Foot Counter, Revision 5 

HD0963.58, Calibration SAM 12, Revision 2 

HD0963.60, Calibration Canberra Chronos 4, Revision 2 

HD0963.62, Calibration of Canberra GEM-5 Gamma Exit Monitor, Revision 3 

HN0955.08, Operation RDMS Continuous Air Monitor, Revision 9 

HN0955.67, Alarm Response for Containment Atmosphere Radiation Monitors, Revision 1 

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

IN1660.601, Dual Channel Calibration ARM 6508, 6517, 6536, 6563, Revision 6 

IN1660.604, Single Channel Calibration ARM 6518, 6529, 6540, Revision 6 

IN1660.611, RD 10B RD 12 Calibration ARM 6534, 6537, 6550, Revision 6 

IN1660.622, Non Safety Related Area Rad Monitors Calibration, Revision 7 

IN1660.714, RM 6522, 6531 PAB WPB CAM Calibration, Revision 3 

IN1660.731, RM6495 Plant Vent Mid/Hi Range Rad Monitor Cal, Revision 9 

IN1660.990, RM 6486, 6487, 6488, 6489 Portable Continuous Atmosphere Radiation Monitor 

 Calibration, Revision 6 

IX1660.612, RM-R-6535 A/B Manipulator Crane ARM Calibration, Revision 9 

IX1660.639, RM 6576A, 6576B Cont Hi Range Rad Mont Calibration Revision 11 

IX1660.662, RM-R-6535-A Fuel Manipulator Crane Train A ARM Operation Test, Revision 9 

IX1660.663, RM-R-6535 Fuel Manipulator Crane Train B ARM Operation Test, Revision 9- 

IX1660.689, RM-R-6576-A Containment Hi Range Rad Monitor Operation Test, Revision 9 

IX1660.690, RM-R-6576-B Containment Hi Range Rad Mont Operation Test, Revision 11 

IX1660.710, RM-R-6506 6507 Control Room Air Intake A B Rad Mont Calibration, Revision 9 

IX1660.718, RM 6526 Containment Rad Mont Calibration, Revision 12 

IX1660.719, RM-R-6548 Containment Rad Monitor Calibration, Revision 8 

IX1660.720, RM-R-6527 COP Trains A B Rad Mont Calibration, Revision 9 

IX1660.724, RM-6562 Fuel Storage Bldg Airborne Rad Mont Calibration, Revision 7 

IX1660.730, RM-R-6528 Plant Vent Wide Range Gas Monitor Calibration, Revision 10 

IX1660.760, RM-R-6506-A Control Room East Air Intake Operation Test, Revision 8 
A-10 

IX1660.761, RM-R-6506-B Control Room West Air Intake Operation Test, Revision 8 

IX1660.762, RM-R-6507-A Control Room West Air Intake Operation Test, Revision 8 

IX1660.763, RM-R-6507-B Control Room West Air Intake Operation Test, Revision 8 

IX1660.768, RM-R-6526 Containment Atmosphere Operation Test, Revision 10 

IX1660.769, RM-R-6548 Containment Atmosphere Backup Operation Test, Revision 7 

IX1660.770, RM-R-6527-A Containment On-Line Purge Operation Test, Revision 10 

IX1660.771, RM-R 6527-B Containment On-Line Purge Operation Test, Revision 11 

IX1660.774, RM-R-6562 Fuel Storage Building Ventilation Exhaust Operation Test, Revision 7 

IX1660.780, RM-R-6528 Plant Vent Wide Range Gas Monitor Operation Test, Revision 9 

IX1660.801, RM-R-6481 6482 Main Steam Line Rad Mont Calibration, Revision 8 

IX1660.814, RM-R-6504 Waste Gas Compressor Rad Monitor Calibration, Revision 9 

IX1660.815, RM-R-6505 Condenser Air Ejector Discharge Rad Mont Calibration, Revision 3 

IX1660.823, RM-R-6515 6516 Loop A B PCCW Rad Mont Calibration, Revision 7 

IX1660.824, RM-R-6519 SGBD Flash Tank Discharge Rad Mont Calibration, Revision 10 

IX1660.826, RM-R-6521 Turbine Building Sump Rad Mont Calibration, Revision 8 

IX1660.864, RM-R-6504 WG Compressor Discharge Operation Test, Revision 7 

Audits, Self-Assessments, and Surveillances 

SB Nuclear Oversight Report SBK 16-001, Radiation Protection and Radwaste Programs, 

 April 7, 2016 

SB Quick Hit Assessment 1965305 Annual Assessment of RP Instruments, August 28, 2014 

SB Focused Self-assessment 2028036 Radiation Protection Instrument Program, June 5, 2015 

Condition Reports 

01967570 02069198 02092276 02092497 02101354 02105415 

02107144 02122649 02123522 02124380 

02126327 

Miscellaneous 

Seabrook Station Updated Final Safety Analysis Report 

SB System Health Report for Rad Monitoring, 1st Quarter 2016 

SB System Health Report for Rad Monitoring, 4th Quarter 2015 

Apparent Cause Evaluation Report for AR 02045183 Main Steam Line Loop 2 RM-6482-1 Alert 

 Alarm Level, September 15, 2015 

Apparent Cause Evaluation Report for AR 09039945 WRGM Pump RM-P-391 Stopped 

 Rotating, June 15, 2015 

Apparent Cause Evaluation Report for AR 02048328 Channel 2 West Air Intake to Control 

 Room Spiked to Alert, June 18, 2015 

HPSTID 16-005, Calibration of the Chair Whole Body Counter, May 12, 2016 

HPSTID 16-004, Calibration of the FastScan Whole Body Counter, May 2, 2016 

Spectrum Techniques LLC, Certificate of Calibration Multi Gamma Ray Standard Co 60 and 

 Cs 137, September 18, 2012 

HPSTID 11-002 Additional Information on Containment Atmosphere Radiation Monitor Setpoint 

 Basis, March 9, 2011 

AEA Technology, Source Certificate CO 44727-KE 452 Wide Area Beta Source: Tc-99 Activity 

 917 Bq on October 22, 2001 

The Source Inc., Certificate of Calibration S-TC-SP Beta Source: Tc-99 Activity 8,366 Bq on 

 March 20, 1997 

Eberline Services Certificate of Calibration Electroplate Beta Standard DNS-12: Tc-99 293 Bq 

 Activity on August 18, 2008 

 
A-11 

Analytics Inc. Certificate of Calibration 21132-127 Eu-152 15cc Solid in Plastic Liquid 

 Scintillation Vial Eu-152 Activity 33,640 Bq on August 14, 1986 

Amersham International Certificate of Calibration 505025/12785-3 UE Anodized Alpha Disc 

 Source: Am-241 Activity 631 Bq on April 19, 1984 

The Source Inc., Certificate of Calibration 91TCSP00178 Beta Source: Activity Tc-99 103 Bq on 

 January 30, 1991 

HPSTID 15-007 Verification/Calibration on the Sheppard Model 81-12 (Serial No. 7015): Cs-137 

 Irradiator, November 1, 2015 

HD0955.48 Form A: Daily Instrument Check - Ludlum M2200 Alpha Scintillation Counter Serial 

 No. 38798 using Am-241 Source NE-97-21 from May 1 – 17, 2016 

HD0955.48 Form C: Canberra S5-APC-GM Daily Instrument Check – Gamma GeLi Detector 

 Serial No. 0717789 using Eu-152 15cc Solid in Plastic Liquid Scintillation Vial NE-86-60 

 from May 1 – 17, 2016 

HD0955.48 Form B: Tennelec XLB Daily Instrument Check – Alpha Beta Proportional Counter 

 Serial No. 43431 using Am-241/Cl-36 Source NE-01-10 and from May 1 – 17, 2016 

HD0955.48 Form A: Daily Instrument Check - Ludlum M2200 Alpha Scintillation Counter Serial 

 No. 38798 using Am-241 Source NE-97-21 from May 1 – 17, 2016 

HPSTID 09-004, Increased Trend Assessment of RM 6526 Particulate Channel from 

3/9/2009 – 4/14/2009, April 15, 2009 

HPSTID 09-006, Reactor Coolant Pressure Boundary Leakage Radiation Monitor Sensitivity to 

 Power Related Nuclides, May 12, 2009 

Work Orders 

40111868 40200988 40200992 40235509 40235518 40310958 

40310959 40323879 40337277 40410443 40410443 

Section 4OA1: Performance Indicator Verification 

Miscellaneous 

Surveillance Frequency Control Program Manual, Appendix A, Revision 3 

Open CDM database results, Dose Equivalent Iodine, April 2015 through June 2016 

Memorandum LIC-16006, dated April 20, 2016 

Section 4OA2: Problem Identification and Resolution 

Procedures 

OP-AA-102-1003, Guarded Equipment, Revision 13 

PI-AA-104-1000, Corrective Action, Revision 6 

PI-AA-104-1000, Corrective Action, Revision 8 

PI-AA-104-1000, Condition Reporting, Revision 9 

PI-AA-104-1000, Condition Reporting, Revision 10 

PI-AA-207-1000, Station Self-Evaluation and Trending Analysis, Revision 5 

Condition Reports 

2112323 2128093 2139720 2139722 

Miscellaneous 

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

 2016 

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

 2016 
A-12 

Seabrook Station Operations Department, Station Self-Evaluation and Trending Analysis Report 

 for 1st Quarter 2016 

Seabrook Station Security, Self-Evaluation and Trending Analysis Report for 1st Quarter 2016 

Seabrook Station, Station Self-Evaluation and Trending Analysis Report for 1st Quarter 2016 

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

Procedures 

OS1000.11, Post Trip to Hot Standby, Revision 19 

OS1000.04, Plant Cooldown from Hot Standby to Cold Shutdown, Revision 53 

OS1202.01, Loss of Letdown, Revision 13 

OX1456.83, Train B ESFAS Slave Relay K624 Quarterly Go Test, Revision 6 

OX1456.83, Train B ESFAS Slave Relay K624 Quarterly Go Test, Revision 7 

Condition Reports 

2114495 2134335 2136006 

Miscellaneous 

LER 2016-002-00 

Station Clock Reset, Letdown Isolation during Slave Relay Testing 

Operations Department Instruction 87 

 
A-13 

LIST OF ACRONYMS 

AC alternating current 

ADAMS Agencywide Document Access and Management System 

AOP abnormal operating procedure 

C/A corrective action 

CAPR corrective action to prevent recurrence 

CAP corrective action program 

CEB containment enclosure building 

CFR Code of Federal Regulations

CR condition report 

CST condensate storage tank 

CT cooling tower 

EDG emergency diesel generator 

EFW emergency feedwater 

GSU generator stepup 

HRA high radiation area 

IMC Inspection Manual Chapter 

kV kilovolt 

LER licensee event report 

LTCA long term corrective action 

MR maintenance rule 

NCV non-cited violation 

NRC Nuclear Regulatory Commission 

NRR Nuclear Reactor Regulation 

ODCM offsite dose calculation manual 

ODI operations department instruction 

PAB primary auxiliary building 

POD prompt operability determination 

RCS reactor coolant system 

RCE root cause evaluation 

RHR residual heat removal 

SG steam generator 

SSC structure, system, and component 

SUFP startup feed pump 

SW service water 

TS technical specification 

UFSAR Updated Final Safety Analysis Report

VHRA very high radiation area

WO work order