Inspectors identified a non-cited violation of
10 CFR 50.65(bX2) because NextEra did not include certain Seabrook buildings as in-scope structures under the
MR program. Specifically, NextEra did not classify the intake transition structure (lTS) and the discharge transition structure (DTS) as in-scope structures in the
MR database, and as a result did not include them in the periodic inspections completed under the structures monitoring program per PEG04 from 1995 to 2009. NextEra initiated a
MR scoping screening worksheet per procedure NAP 415 and upon consideration of the design basis information concluded both transition structures should be in-scope per
10 CFR 50.65(aX1). The NAP 415 scoping results were accepted by the
MR Expert Panel on March 15,2011. NextEra initiated CR 1629504 to enter the issue into the Corrective Action Program (
CAP) and determine the extent of condition. The performance deficiency is more than minor because if left uncorrected, given the indications of
ASR identified in these concrete structures, not monitoring the
ITS and DTS structures for degradation could result in the loss of function of structures supporting systems used to mitigate design basis events, used in the emergency operating procedures, or whose loss could result in a
reactor trip. The inspectors performed a Phase 1
Significance Determination Process (
SDP) screening, in accordance with NRC Inspection Manual Chapter (lMC) 0609, Attachment 4, and determined the issue was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, was not a loss of barrier function, and was not potentially risk significant for external events. This finding did not have a cross cutting aspect because the most significant contributor to the performance deficiency was not reflective of current licensee performance.