ML15037A172
| ML15037A172 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/06/2015 |
| From: | Glenn Dentel Reactor Projects Branch 3 |
| To: | Dean Curtland NextEra Energy Seabrook |
| References | |
| IR 2014005 | |
| Download: ML15037A172 (41) | |
See also: IR 05000443/2014005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100
KING OF PRUSSIA, PA 19406-2713
February 6, 2015
Mr. Dean Curtland
Site Vice President
Seabrook Nuclear Power Plant
NextEra Energy Seabrook, LLC
c/o Mr. Michael Ossing
P.O. Box 300
Seabrook, NH 03874
SUBJECT: SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION
REPORT 05000443/2014005
Dear Mr. Curtland:
On December 31, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an
inspection at Seabrook Station, Unit No. 1. The enclosed inspection report documents the
inspection results, which were discussed on January 29, 2015, with you and other members of
your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents three violations of NRC requirements, which were of very low safety
significance (Green). However, because of the very low safety significance, and because they
are entered into your corrective action program (CAP), the NRC is treating these findings as
non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you
contest the non-cited violations in this report, you should provide a response within 30 days of
the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at
Seabrook Station. In addition, if you disagree with the cross-cutting aspect assigned to any
finding, or a finding not associated with a regulatory requirement in this report, you should
provide a response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at
Seabrook Station.
D. Curtland 2
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules
of Practice, a copy of this letter, its enclosure, and your response (if any) will be available
electronically for public inspection in the NRCs Public Document Room or from the Publicly
Available Records component of the NRCs Agencywide Documents Access 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/
Glenn T. Dentel, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Docket No. 50-443
License No: NPF-86
Enclosure: Inspection Report No. 05000443/2014005
w/ Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DRP RI/DRP RI/DRP
NAME RBarkley/rb PCataldo/pc via email GDentel/gd
DATE 02/6/15 02/5/15 02/6/15
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-443
License No.: NPF-86
Report No.: 05000443/2014005
Licensee: NextEra Energy Seabrook, LLC
Facility: Seabrook Station, Unit No.1
Location: Seabrook, New Hampshire 03874
Dates: October 1, 2014 through December 31, 2014
Inspectors: P. Cataldo, Senior Resident Inspector
C. Newport, Resident Inspector
T. OHara, Reactor Inspector
W. Cook, Senior Reactor Analyst
D. Silk, Senior Operations Engineer
R. Barkley, Senior Project Engineer
B. Dionne, Health Physicist
Approved by: Glenn T. Dentel, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Enclosure
2
TABLE OF CONTENTS
SUMMARY .................................................................................................................................... 3
REPORT DETAILS ....................................................................................................................... 5
1. REACTOR SAFETY .............................................................................................................. 5
1R01 Adverse Weather Protection ...................................................................................... 5
1R04 Equipment Alignment .................................................................................................. 5
1R05 Fire Protection ............................................................................................................. 6
1R11 Licensed Operator Requalification Program ............................................................... 7
1R12 Maintenance Effectiveness ......................................................................................... 8
1R13 Maintenance Risk Assessments and Emergent Work Control ................................ 12
1R15 Operability Determinations and Functionality Assessments .................................... 12
1R18 Plant Modifications .................................................................................................... 13
1R19 Post-Maintenance Testing ....................................................................................... 14
1R22 Surveillance Testing ................................................................................................. 14
2. RADIATION SAFETY .......................................................................................................... 15
2RS3 In-Plant Airborne Radioactivity Control and Mitigation ............................................. 15
2RS4 Occupational Dose Assessment .............................................................................. 16
2RS5 Radiation Monitoring Instrumentation ...................................................................... 16
4. OTHER ACTIVITIES ............................................................................................................ 19
4OA1 Performance Indicator Verification ........................................................................... 19
4OA2 Problem Identification and Resolution ..................................................................... 20
4OA6 Meetings, Including Exit ............................................................................................ 26
ATTACHMENT: SUPPLEMENTARY INFORMATION................................................................ 26
SUPPLEMENTARY INFORMATION ........................................................................................ A-1
KEY POINTS OF CONTACT .................................................................................................... A-1
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1
LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2
LIST OF ACRONYMS ............................................................................................................. A-12
Enclosure
3
SUMMARY
IR 05000443/2014005; 10/01/2014-12/31/2014; Seabrook Station, Unit No. 1; Maintenance
Effectiveness and Radiation Monitoring Instrumentation
This report covered a three-month period of inspection by resident inspectors and announced
inspections performed by regional inspectors. Inspectors identified three findings of very low
safety significance (Green), which were classified as NCVs. The significance of most findings is
indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined
using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated
June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within
Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are
dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Barrier Integrity
- Green. The inspectors identified an NCV of 10 CFR 50 Appendix B Criterion XVI, Corrective
Actions, of very low safety significance because NextEra staff did not promptly identify nine
visual indications of structural problems representing conditions adverse to quality. These
problems were observed by NextEra staff during a maintenance rule (MR) walkdown of the
Fuel Storage Building (FSB) on November 20, 2014, and documented in walkdown notes
as conditions warranting entry into the corrective action program (CAP). However these
problems were not entered into the CAP to identify them as conditions adverse to quality
until questioned by the inspectors. NextEra staff took corrective actions to enter the issues
into their CAP in AR10206192, AR02016238, AR02016225 and AR020168863 and initiated
AR02014116 for not promptly identifying these problems.
This performance deficiency was considered to be more than minor because it is associated
with the Barrier Integrity Cornerstone objective to provide reasonable assurance that
physical design barriers protect the public from radionuclide releases caused by accidents
or events, and affected the attribute of design control - structural integrity. Specifically, the
inspectors determined the finding was more than minor because four of the conditions
exceeded American Concrete Institute (ACI) 349.3R-96 "Tier II structural criteria, which
indicated they require further technical evaluation and analysis to validate the existing
conditions or repair to preserve structural function. This issue was evaluated in accordance
with IMC 0609, Appendix A, The Significance Determination Process for Findings At-
Power, Exhibit 3, Barrier Integrity Screening Questions, and screened as very low safety
significance (Green) because the observed FSB degradation did not adversely impact
structural or radiological barrier functions of the building. This finding is related to the cross-
cutting area of Human Performance - Procedure Adherence because individuals did not
follow CAP process, procedures, and work instructions [H.8]. (Section 1R12)
- Green. The inspectors identified a violation of 10 CFR 50 Appendix B Criterion XVI,
Corrective Actions, of very low safety significance because NextEra did not promptly identify
a condition adverse to quality in December 2013 that involved a deviation from expected
settling assumptions in the Seabrook Station design basis for the FSB. FSB elevation
measurements were received by NextEra staff in December 2010 and in December 2013
indicating that settling at some locations of the FSB was occurring. NextEra staff did not
Enclosure
4
enter this condition, a condition adverse to quality, into their CAP until December 8, 2014, in
response to questions from the inspectors. NextEra initiated AR02011698 to enter this issue
in the CAP and AR02014116 to address their staff not entering this issue previously into the
CAP.
This performance deficiency was considered to be more than minor because it is associated
with the Barrier Integrity Cornerstone objective to provide reasonable assurance that
physical design barriers protect the public from radionuclide releases caused by
accidents or events, and adversely affected the attribute of design control - structural
integrity. Specifically, the inspectors concluded that the structural integrity of the FSB was
potentially adversely affected because measured settling of the structure deviated from
assumed design basis values. Also, this condition exceeded the ACI 349.3R-96 Tier II
structural criteria of the Structures Monitoring Program and requires a structural evaluation.
This issue was evaluated in accordance with IMC 0609, Appendix A, The Significance
Determination Process for Findings At-Power, Exhibit 3, Barrier Integrity Screening
Questions, and screened as very low safety significance (Green) because the observed
degradation does not adversely impact structural or radiological barrier functions for the
FSB. This finding is related to the cross-cutting area of Human Performance - Design
Margins. The organization did not maintain the FSB within design margins and did not
utilize the systematic and rigorous corrective action process. [H.6]. (Section 1R12)
Cornerstone: Occupational Radiation Safety
- Green. The inspectors identified a Green NCV of TS 6.7.1.a, Procedures and Programs,
because NextEra failed to conduct appropriate periodic calibration of neutron survey
instruments. Specifically, since 1996, NextEra assumed that an operability check of certain
neutron survey instruments using an internal alpha check source would provide a calibration
equivalent to that performed to a traceable neutron source of a known neutron flux, contrary
to the periodic calibration frequency requirements specified in the Seabrook Station
Radiation Protection Manual. NextEras immediate corrective actions included capturing
this issue in its CAP (AR 01969397), calibrating all of the neutron survey instruments in
question, and revising the neutron survey instrument operating procedure to require annual
calibrations.
This performance deficiency was determined to be more than minor because it adversely
affected the Occupational Radiation Safety Cornerstone to ensure the adequate protection
of the worker from radiation exposure. Additionally, it was similar to example 6.b in IMC 0612, Appendix E, Examples of Minor Issues, which states that the performance deficiency
is more than minor if a radiation protection instrument was not calibrated properly, and when
recalibrated the as-found condition of the instrument was not within acceptance criteria for
calibration and the accuracy was non-conservative. The issue was evaluated in accordance
with IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination
Process," and determined to be of very low safety significance (Green) since it was not an
as low as is reasonably achievable (ALARA) issue and did not involve an overexposure or
a potential overexposure and it did not affect any significant neutron exposures of plant
personnel. The inspectors determined there was no cross-cutting aspect associated with
this finding since it was not representative of current NextEra performance. Specifically, in
accordance with IMC 0612, the causal factors associated with this finding occurred outside
the nominal three-year period of consideration and were not considered representative of
present performance. (Section 2RS5)
Enclosure
5
REPORT DETAILS
Summary of Plant Status
Seabrook operated at full power for the quarter, with the exception of a down-power to 94
percent, on October 3, 2014, for performance of main turbine control valve testing. Documents
reviewed for each section of this inspection report are listed in the Attachment.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 1 sample)
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of NextEras readiness for the onset of seasonal
cold temperatures. The review focused on the emergency feedwater pump house,
condensate storage tank, turbine building, service water (SW) cooling tower, and
miscellaneous heating systems. The inspectors reviewed the Updated Final Safety
Analysis Report (UFSAR), technical specifications (TSs), the seasonal readiness
memorandum, and the CAP to determine specific temperatures or other seasonal
weather that could challenge these systems, and to ensure NextEra personnel had
adequately prepared for these challenges. The inspectors reviewed station procedures,
including NextEras seasonal weather preparation procedure and applicable operating
procedures. The inspectors performed walkdowns of selected systems to ensure station
personnel identified issues that could challenge the operability of the systems during
cold weather conditions.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns (71111.04Q - 4 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
- B safety injection system return to service on November 4, 2014
- Startup feed pump return to service on November 19, 2014
- B train of control building air handling chilled water system unit 230A, during A train
unit 230B maintenance on December 1, 2014
- A and B SW cooling tower while ocean SW out of service (OOS) for A pump
replacement on December 16, 2014
Enclosure
6
The inspectors selected these systems based on their risk-significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors reviewed
applicable operating procedures, system diagrams, the UFSAR, TSs, work orders
(WOs), condition reports (CRs), and the impact of ongoing work activities on redundant
trains of equipment in order to identify conditions that could have impacted system
performance of their intended safety functions. The inspectors also performed field
walkdowns of accessible portions of the systems to verify system components and
support equipment were aligned correctly and were operable. The inspectors examined
the material condition of the components and observed operating parameters of
equipment to verify that there were no deficiencies. The inspectors also reviewed
whether NextEra staff had properly identified equipment issues and entered them into
the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown (71111.04S - 1 sample)
a. Inspection Scope
During December 11 to 12, 2014, the inspectors performed a complete system
walkdown of accessible portions of the B emergency diesel generator (EDG) system
to verify the existing equipment lineup was correct while the licensee was working on
equipment on the A train. The inspectors reviewed operating procedures, drawings,
equipment line-up check-off lists, and the UFSAR to verify the system was aligned to
perform its required safety functions. The inspectors also reviewed electrical power
availability, component lubrication and equipment cooling, hanger and support
functionality, and the operability of support systems. The inspectors performed field
walkdowns of accessible portions of the systems to verify system components and
support equipment were aligned correctly and operable. The inspectors examined the
material condition of the components and observed operating parameters of equipment
to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample
of related action requests (ARs) and WOs to ensure NextEra appropriately evaluated
and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material
condition and operational status of fire protection features. The inspectors verified that
NextEra controlled combustible materials and ignition sources in accordance with
administrative procedures. The inspectors verified that fire protection and suppression
Enclosure
7
equipment was available for use as specified in the area pre-fire plan, and passive fire
barriers were maintained in good material condition. The inspectors also verified that
station personnel implemented compensatory measures for OOS, degraded or
inoperable fire protection equipment, as applicable, in accordance with procedures.
- Turbine building fire areas/zones (TB-F-1A-Z, TB-F-1B-Z, TB-F-1C-Z, and TB-F-1-0)
on October 17, 2014
- Control building fire areas/zones (CB-F-3A-A, CB-F-3B-A, and CB-F-3C-A) on
October 21, 2014
- Turbine building fire areas/zones (TB-F-3-0 and TB-F-3-Z) on October 27, 2014
- Control building fire areas/zones (CB-F-1D-A, CB-F-1E-A, CB-F-1F-A, and
CB-F-1G-A) on December 4, 2014
- Control building fire area/zone (CB-F-1A-A) on December 20, 2014
1R11 Licensed Operator Requalification Program (71111.11Q and 71111.11A - 3 samples)
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training during the conduct of a
10 CFR 55.59 required requalification examination on December 2, 2014, which
included spurious main steam isolation valve closure and a failure of the reactor to
automatically trip. The inspectors evaluated operator performance during the simulated
event and verified completion of risk significant operator actions, including the use of
abnormal and emergency operating procedures. The inspectors assessed the clarity
and effectiveness of communications, implementation of actions in response to alarms
and degrading plant conditions, and the oversight and direction provided by the control
room supervisor. The inspectors verified the accuracy and timeliness of the emergency
classification made by the shift manager and the TS action statements entered by the
shift technical advisor. Additionally, the inspectors assessed the ability of the crew and
training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed EDG 1B operability surveillance testing on November 1, 2014,
main steam isolation valve testing on November 7, 2014 and SW valve timing testing on
November 25, 2014. The inspectors observed test performance to verify that procedure
use, crew communications, and coordination of activities between work groups similarly
met established expectations and standards.
b. Findings
No findings were identified.
Enclosure
8
.3 Licensed Operator Requalification
a. Inspection Scope
On December 22, 2014, one NRC region-based inspector conducted an in-office
review of results of licensee-administered annual operating tests for 2014, for
Seabrook Station, Unit No.1 operators. (The biennial requalification written examination
was not administered in 2014.) The inspection assessed whether failure rates were
consistent with the guidance of NRC Manual Chapter 0609, Appendix I, and Operator
Requalification Human Performance Significance Determination Process. The review
verified that the failure rate (individual or crew) did not exceed 20%.
- 2 out of 47 operators failed at least one section of the Annual Exam. The overall
individual failure rate was 4.3%
- 0 out of 9 crews failed the simulator test. The crew failure rate was 0.0%
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12 - 3 samples)
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of
maintenance activities on structure, system, and component (SSC) performance and
reliability. The inspectors reviewed system health reports, CAP documents,
maintenance WOs, and MR basis documents to ensure that NextEra was identifying
and properly evaluating performance problems within the scope of the MR. For each
sample selected, the inspectors verified that the SCC was properly scoped into the
MR in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria
established by NextEra staff was reasonable. As applicable, for SCCs classified as
(a)(1), the inspectors assessed the adequacy of the goals and corrective actions to
return these SSCs to (a)(2). Additionally, the inspectors ensured that NextEra staff was
identifying and addressing common cause failures that occurred within and across MR
system boundaries.
- Fuel Storage Building (FSB) structural monitoring results.
b. Findings
.1 Failure to Identify Conditions Adverse to Quality in the Fuel Storage Building Structure
Introduction: The inspectors identified a non-cited violation of 10 CFR 50 Appendix B
Criterion XVI, Corrective Actions, of very low safety significance (Green) because
NextEra staff did not promptly identify nine visual indications of structural problems
representing conditions adverse to quality. These problems were observed by NextEra
staff during a MR walkdown of the FSB on November 20, 2014, and documented in
walkdown notes as conditions warranting entry into the corrective action process (CAP).
Enclosure
9
However these problems were not entered into the corrective action program (CAP)
to identify them as conditions adverse to quality until questioned by the inspectors.
Description: NextEras Engineering Department Procedure 36180, Revision 5,
Structural Monitoring Program, provides guidance to NextEra staff for completing
periodic structural examinations to implement the requirements of 10 CFR 50.65. This
procedure incorporates tiered examination criteria from ACI 349.3R-96, Evaluation of
Existing Nuclear Safety Related Concrete Structures to guide NextEra staff in
identifying visual indications of structural problems that warrant further evaluation.
Procedure 36180, Revision 5, Paragraph 5.2.1 states that measurable discontinuities
exceeding specified ACI Tier II quantitative limits shall be considered unacceptable and
that further evaluation should consider the use of other inspection, testing or analytical
tools to obtain condition and functional information of the structures in question.
On December 18, 2014, in response to a request for the results of the last MR walkdown
of the FSB, the inspectors received and reviewed the walkdown notes prepared by
NextEra staff on November 20, 2014, after completing MR structural walkdowns in eight
rooms within the FSB. The inspectors observed that NextEra staff documented nine
visual conditions which they indicated needed to be entered into the CAP as Action
Reports (ARs) but were not entered at that time. Additionally, NextEra staff indicated
that four of the conditions exceeded the Tier II criteria and warranted further evaluation
and examination to develop corrective actions. These four conditions documented a
crack in a column exceeding 0.04 inches, a diagonal crack in an integral stairwell wall
exceeding 0.04 inches, and multiple indications of cracks in a curb and spalled concrete
supporting the east side of the deck in the New Fuel Storage Area (NFSA). The
inspectors also identified NextEra staff had not issued a work order for this walkdown
activity as per the guidance in their MR procedure.
NextEra staff completed corrective actions to enter the issues into their CAP in
AR10206192, AR020216238, AR020216225 and AR020168863 for further examination
and evaluation. In initial review of these conditions, NextEra staff concluded that each of
these structural elements remained functional. NextEra staff planned to conduct a Root
Cause evaluation of the causes of these conditions in AR 2014325.
Analysis: The inspectors determined that NextEra staff did not promptly identify the
nine visual indications of structural problems as conditions adverse to quality by entering
the issues into their CAP. This was a performance deficiency. It was reasonable to
enter these issues into the CAP because NextEra staff documented in their MR
walkdown notes that these conditions warranted entry into the CAP.
This performance deficiency was considered to be more than minor because it is
associated with the Barrier Integrity Cornerstone objective to provide reasonable
assurance that physical design barriers protect the public from radionuclide releases
caused by accidents or events, and affected the attribute of design control - structural
integrity. Specifically, the inspectors determined the finding was more than minor
because four conditions exceeded Tier II structural criteria, which indicated they
required further investigation and evaluation to determine the causes.
Enclosure
10
The issue was evaluated in accordance with IMC 609, Appendix A, The Significance
Determination Process for Findings At-Power, Exhibit 3, Barrier Integrity Screening
Questions, and screened as very low safety significance (Green) because the observed
FSB degradation did not adversely impact structural or radiological barrier functions of
the building. The finding is related to the cross-cutting area of Human Performance -
Procedure Adherence because individuals did not follow CAP process, procedures, and
work instructions [H.8].
Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions; states, in part,
that measures shall be established to assure that conditions adverse to quality, such
as failures, malfunctions, deficiencies, deviations, defective material and equipment,
and non-conformances are promptly identified and corrected. Contrary to the above
NextEra identified nine structural integrity conditions in FSB structures, but did not
promptly enter the issues into their CAP on November 20, 2014, for structural
evaluations until identified by the inspectors. NextEra staff took corrective actions
to enter the issues into their CAP in AR02016225, AR020168863, AR02016238,
AR10206192 and AR02014116 in January 2015. This violation is being treated as an
NCV, consistent with Section 2.3.2 of the Enforcement Policy. The conditions and the
violation were entered into the licensees corrective action process in the ARs listed.
(NCV 05000443/2014005-01, Failure to Identify Conditions Adverse to Quality in
the Fuel Storage Building Structure)
.2 Fuel Storage Building Measurements
Introduction: The inspectors identified a violation of 10 CFR 50 Appendix B Criterion
XVI, Corrective Actions, of very low safety significance (Green) because NextEra did
not promptly identify a condition adverse to quality in December 2013, that involved a
deviation from design assumptions regarding structure settling in the Seabrook Station
design basis for the FSB. Specifically, FSB elevation measurements were received by
NextEra staff in December 2013, which indicated settling was occurring in some
locations of the FSB. NextEra staff did not enter this condition into their CAP until
December 8, 2014, and did not further investigate the condition.
Description: The Seabrook Station UFSAR Section 3.8.5.7 indicates that for seismic
Category 1 structure foundations such as the FSB, no preoperational or in-service
surveillance is required related to settling because these structures, which are founded
on sound rock, do not have any potential areas of settlement or displacement which
should be monitored. The inspectors reviewed reports received by NextEra staff
providing the results of elevation readings taken from 2010 and 2013. These reports
indicated elevation readings of -0.052 (reference point 15) in December 2010, and
an elevation reading of -.102 (reference point 17) in December of 2013, indicating
settlement. The measurement tolerance on the reported elevations was +/- 0.00012.
Enclosure
11
These measurements were received by NextEra staff in December 2010 and
December 2013, as part of their initiative to monitor the FSB structure. These results
indicated that FSB settlement was occurring in some measured locations, and these
results would deviate from the site design basis as described in the Seabrook UFSAR,
Section 3.8.5.7. In response to the inspectors inquiries regarding design allowances for
building settlement, NextEra staff initiated AR02011698 on December 8, 2014, to identify
this condition and track to completion an overall evaluation of the FSB structure.
The inspectors also noted that NextEra Procedure 36180, Structural Monitoring
Program, Revision 05, paragraph 5.2.1, described conditions which, if exceeded,
required further evaluation. This procedure stated that passive settlements or
deflections greater than the original design limits warranted evaluation. This procedure
further stated that active settlements that are observed in a structure must be treated
carefully as the source of cracking may continue to act or intensify. The inspectors
concluded data indicating FSB settlement was available to NextEra staff, involved a
condition that exceeded their Tier II criteria and warranted evaluation as part of their
periodic MR activities. However this data was not identified in MR or structures system
health report documents reviewed by the inspectors. NextEra initiated AR02011698 on
December 8, 2014, to enter this condition into their CAP and AR AR02014116 to
document not identifying this as a condition adverse to quality. NextEra assessed that
the condition did not adversely impact the structural or radiological barrier functions for
the FSB.
Analysis: The inspectors determined that NextEras staff failure to identify a condition
adverse to quality, involving measured FSB settlement in some locations that involved
a deviation from expected settling assumptions in the Seabrook design basis, as
described in Seabrook Station UFSAR, Section 3.8.5.7, was a performance deficiency
within NextEras ability to foresee and correct.
The performance deficiency was more than minor because it affected the Barrier
Integrity Cornerstone objective to provide reasonable assurance that physical design
barriers protect the public from radionuclide releases caused by accidents or events,
and the condition adversely affected the Cornerstone Attribute of Design Control -
structural integrity because data indicted some locations of the FSB were settling
which would deviate from the design basis as described in the Seabrook UFSAR,
Section 3.8.5.7. This issue was evaluated in accordance with IMC 0609, Appendix A,
The Significance Determination Process for Findings At-Power, Exhibit 3, Barrier
Integrity Screening Questions, and screened as very low safety significance (Green)
because the observed degradation does not adversely impact structural or radiological
barrier functions for the FSB. This finding is related to the cross-cutting area of Human
Performance - Design Margins. Specifically, the organization did not maintain the FSB
within design margins and did not utilize the systematic and rigorous corrective action
process [H.6].
Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions; states, in part,
that measures shall be established to assure that conditions adverse to quality, such
as failures, malfunctions, deficiencies, deviations, defective material and equipment,
and non-conformances, are promptly identified and corrected. Contrary to the above,
NextEra did not promptly identify FSB elevation values, when available in December
2010 and December 2013, as conditions adverse to quality because they represented
deviations from design basis assumptions and did not perform evaluations of the effect
Enclosure
12
of the elevation readings on the FSB. NextEra initiated AR02011698 on December 8,
2014, to enter this condition into their CAP and AR AR02014116 to document not
identifying this as a condition adverse to quality. This violation is being treated as an
NCV, consistent with Section 2.3.2 of the Enforcement Policy. NextEra entered the
condition into their corrective action process in the identified ARs. (NCV 05000443/2014005-02, Failure to Identify and Evaluate FSB Settlement Data
and the Design Basis)
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 4 samples)
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the
maintenance and emergent work activities listed below to verify that NextEra performed
the appropriate risk assessments prior to removing equipment for work. The inspectors
selected these activities based on potential risk significance relative to the reactor safety
cornerstones. As applicable for each activity, the inspectors verified that NextEra
personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the
assessments were accurate and complete. When NextEra performed emergent work,
the inspectors verified that operations personnel promptly assessed and managed plant
risk. The inspectors reviewed the scope of maintenance work and discussed the results
of the assessment with the stations probabilistic risk analyst to verify plant conditions
were consistent with the risk assessment. The inspectors also reviewed the TS
requirements and inspected portions of redundant safety systems, when applicable, to
verify risk analysis assumptions were valid and applicable requirements were met.
- D battery charger cross-tie operations and capacity testing during switchyard
maintenance on October 1, 2014
- A EDG fuel leak repair on October 15, 2014
- Emergent issues on A EDG during offsite power line 394 outage on October 20,
2014
- B EDG digital reference unit and electronic governor replacement on October 30,
2014
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments (71111.15 - 4 samples)
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-
conforming conditions:
- Open B phase heater element for CBA-H-372 on October 1, 2014
- A EDG cumulative deficiencies on October 20, 2014
- B EDG Windrock Engine analyzer report on December 16, 2014
- Degraded mechanical penetration room seals on December 19, 2014
Enclosure
13
The inspectors selected these issues based on the risk significance of the associated
components and systems. The inspectors evaluated the technical adequacy of the
operability determinations to assess whether TS operability was properly justified and
the subject component or system remained available such that no unrecognized.
increase in risk occurred. The inspectors compared the operability and design criteria in
the appropriate sections of the TSs and UFSAR to NextEras evaluations to determine
whether the components or systems were operable. Where compensatory measures
were required to maintain operability, the inspectors determined whether the measures
in place would function as intended and were properly controlled by NextEra. The
inspectors determined, where appropriate, compliance with bounding limitations
associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications (71111.18 - 2 samples)
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether
the modifications affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing
results, and conducted field walkdowns of the modifications to verify that the temporary
modifications did not degrade the design bases, licensing bases, and performance
capability of the affected systems.
- SB-V-9 leak repair temporary modification on December 4, 2014
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
The inspectors evaluated a modification to vital Bus 6 implemented by Engineering
Change 271074, Bus 6 Sync Check Relay Device 25R Replacement. The inspectors
verified that the design bases, licensing bases, and performance capability of the
affected systems were not degraded by the modification. In addition, the inspectors
reviewed modification documents associated with the upgrade and design change,
including associated engineering changes, calculations, communication with the vendor,
and industry operating experience.
b. Findings
No findings were identified.
Enclosure
14
1R19 Post-Maintenance Testing (71111.19 - 7 samples)
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities
listed below to verify that procedures and test activities ensured system operability and
functional capability. The inspectors reviewed the test procedure to verify that the
procedure adequately tested the safety functions that may have been affected by the
maintenance activity, that the acceptance criteria in the procedure was consistent with
the information in the applicable licensing basis and/or design basis documents, and
that the procedure had been properly reviewed and approved. The inspectors also
witnessed the test or reviewed test data to verify that the test results adequately
demonstrated restoration of the affected safety functions.
- Safety injection pump 6A static breaker testing on September 9, 2014
- A EDG fuel leak repair on October 16, 2014
- SW pump P-41D packing maintenance on October 27, 2014
- Reactor coolant pump 62V UV relay on-line setpoint verification on October 28, 2014
- B EDG 24-hour run failure on October 29, 2014 and retest on November 2, 2014
- Control building air conditioning unit 230B testing following maintenance on
December 1, 2014
- B primary component cooling water (PCCW) discharge check valve following
internal inspection on December 10, 2014
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22 - 2 samples)
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of
selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR,
and NextEra procedure requirements. The inspectors verified that test acceptance
criteria were clear, tests demonstrated operational readiness and were consistent with
design documentation, test instrumentation had current calibrations and the range and
accuracy for the application, tests were performed as written, and applicable test
prerequisites were satisfied. Upon test completion, the inspectors considered whether
the test results supported that equipment was capable of performing the required safety
functions. The inspectors reviewed the following surveillance tests:
- Emergency power sequencer operability surveillance on October 2, 2014
- B SW cooling tower pump and discharge valve quarterly test on November 25, 2014
(IST)
b. Findings
No findings were identified.
Enclosure
15
2. RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 sample)
a. Inspection Scope
From December 8 to 11, 2014, inspectors reviewed the control of in-plant airborne
radioactivity and the use of respiratory protection devices. The inspectors used the
requirements in 10 CFR Part 20, the guidance in RG 8.15, RG 8.25, NUREG-0041,
and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the UFSAR, TSs, and emergency planning documents to
identify the location and quantity of respiratory protection devices stored for emergency
use.
Engineering Controls
The inspectors reviewed airborne monitoring protocols associated with four installed
ventilation systems, and associated airborne monitor alarm set-points.
Use of Respiratory Protection Devices
The inspectors reviewed records of air testing for supplied-air devices and self-contained
breathing air (SCBA) bottles; and qualification records for five individuals for use of
respiratory protection devices.
Use of Respiratory Protection Devices
There were no opportunities to observe workers using respiratory protection devices
during the inspection period.
The inspectors reviewed:
- the training curricula for users of respiratory protection devices
- ten respiratory protection devices staged and ready for use in the plant
- records of inspection and maintenance repairs for each type of respiratory protection
device
- training qualifications for onsite personnel assigned to repair respiratory protection
equipment
Enclosure
16
SCBA for Emergency Use
The inspectors reviewed:
- the method used for refilling and transporting SCBA air bottles to and from the
control room and the operations support center
- the past two years of maintenance records for three SCBA units
- the periodic air cylinder hydrostatic testing surveillance documentation
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment (71124.04 - 1 sample)
a. Inspection Scope
The inspectors reviewed the monitoring and assessment of occupational dose by
NextEra. The inspectors used the requirements in 10 CFR Part 20, the guidance
in RG 8.13, RG 8.36, RG 8.40, TSs, and procedures required by TSs as criteria for
determining compliance.
Internal Dosimetry
The inspectors selected three whole body counts (WBCs) and evaluated whether
the counting system was used to ensure appropriate sensitivity for the potential
radionuclides of interest and included a sufficient radionuclide reference library identify
the gamma-emitting radionuclides expected at the site. The inspectors evaluated how
NextEra accounts for non-gamma emitting radionuclides in their internal dose
assessments.
NextEra has not documented any internal dose assessments using WBC results during
the period reviewed.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation (71124.05)
a. Inspection Scope
From December 8 to 11, 2014, inspectors reviewed NextEras performance in assuring
the accuracy and operability of radiation monitoring instruments used for occupational
radiation safety. The inspectors used the requirements in 10 CFR 20; 10 CFR 50,
Appendix I; TSs; offsite dose calculation manual; applicable industry standards; and
procedures required by TSs as criteria for determining compliance.
Enclosure
17
Portable Survey Instruments, Area Radiation Monitors (ARMs), Electronic Dosimetry,
and Air Samplers/Continuous Air Monitors
The inspectors reviewed calibration documentation for at least one of each type of
instrument. For portable survey instruments and ARMs, the inspectors reviewed
detector measurement geometry and calibration methods for each type.
The inspectors selected four portable survey instruments that did not meet acceptance
criteria during calibration or source checks, and reviewed the corrective actions taken for
instruments found out of calibration.
b. Findings
Introduction. The inspectors identified a Green NCV of TS 6.7.1.a, Procedures and
Programs, because NextEra failed to conduct appropriate periodic calibration of neutron
survey instruments. Specifically, since 1996, NextEra assumed that an operability check
of certain neutron survey instruments using an internal alpha check source would
provide a calibration equivalent to that performed to a traceable neutron source of a
known neutron flux, contrary to the periodic calibration frequency requirements specified
in the Seabrook Station Radiation Protection Manual.
Description. At Seabrook Station, the REM 500 neutron survey instrument is used for
conducting neutron radiation surveys to ensure adequate protection of workers. Since
1996, the licensee assumed that an operability check performed prior to each instrument
use, using an internal radioactive source that emitted alpha particles, would provide an
equivalent calibration to that performed using a National Institute of Science and
Technology (NIST) traceable neutron source. As a result, the licensee did not calibrate
the REM-500 neutron survey instruments by comparing the instrument response to a
known acceptable neutron radiation flux. The operability response checks that had been
performed since 1996 did not ensure the instrument performance was within established
calibration acceptance criteria.
During the month of August 2013, REM 500 neutron survey instrument serial number
108 was used for performing five surveys during Independent Spent Fuel Storage
Installation (ISFSI) cask loading, transport and storage work activities. The last
successful operability check on the REM 500 neutron survey instrument, using the built
in alpha check source, was August 6, 2013. This neutron survey instrument was
previously calibrated by the manufacturer using a NIST calibrated neutron source on
August 9, 2002.
In July 2014, NextEra sent this instrument to the manufacturer for calibration due to an
out of tolerance operability check. In August 2014, the manufacturer reported the as-
found condition of this neutron meter to be outside the calibration acceptance criteria
of +20%. The as-found results indicated this survey instrument had a non-conservative
low response of -43%, -17%, -22% and -34% at the 1.04, 12.7, 101.5 and 1,000 mrem/hr
delivered dose rates, respectively. Based on review of all of the neutron survey
instrument calibration results, other REM 500 instruments were also outside of the
calibration acceptance criteria, while successfully passing the operability response
checks, confirming that the previous practice of using an alpha source operability check
was not sufficient to ensure adequate calibration of the REM 500 neutron survey
instruments.
Enclosure
18
NextEra performed an impact evaluation to determine the possible consequences of the
REM 500 Serial number 108 instrument use since the last successful operability check.
The use of this instrument in August 2013 for ISFSI surveys resulted in establishing
inaccurate and non-conservative neutron radiation dose rates for the spent fuel dry cask
loading campaign work activities. The non-conservative neutron radiation dose rates
did not result in any adverse impact on assessing occupational dose associated with
neutrons. After the issue was identified by the inspectors, NextEra entered it into their
corrective action program (AR 01969397), sent all affected REM 500 neutron meters to
the manufacturer for calibration, revised the applicable instrument procedure to include
a requirement to calibrate the instrument to a NIST traceable neutron source annually,
and performed an impact evaluation on the out-of-calibration instruments past use.
Analysis. The inspectors determined that failing to conduct appropriate periodic
calibration of neutron survey instruments was a performance deficiency within NextEras
ability to foresee and correct. Specifically, since 1996, NextEra assumed that an
operability check of certain neutron survey instruments using an internal alpha check
source would provide a calibration equivalent to that performed to a traceable neutron
source of a known neutron flux, contrary to the periodic calibration frequency
requirements specified in the Seabrook Station Radiation Protection Manual. This
performance deficiency was determined to be more than minor because it adversely
affected the Occupational Radiation Safety cornerstone to ensure the adequate
protection of the worker from radiation exposure. Additionally, it was similar to
example 6.b in IMC 0612, Appendix E, Examples of Minor Issues, which states that the
performance deficiency is more than minor if a radiation protection instrument was not
calibrated properly and when recalibrated the as-found condition of the instrument was
not within acceptance criteria for calibration and the accuracy was non-conservative.
The issue was evaluated in accordance with IMC 0609, Appendix C, "Occupational
Radiation Safety Significance Determination Process," and determined to be of very
low safety significance (Green) since it was not an ALARA issue and did not involve an
overexposure or a potential overexposure and it did not affect any significant neutron
exposures of plant personnel. The inspectors determined there was no cross-cutting
aspect associated with this finding since it was not representative of current NextEra
performance. Specifically, in accordance with IMC 0612, the causal factors associated
with this finding occurred outside the nominal three-year period of consideration and
were not considered representative of present performance.
Enforcement. Technical Specification 6.7.1.a, Procedures and Programs, requires
written procedures be established and implemented, including administrative procedures
described in RG 1.33. RG 1.33 requires sites to establish and maintain radiation
protection procedures. Seabrook Radiation Protection Manual, Revision 67, Figure
1-3-1 specifies a semi-annual calibration frequency for portable survey instruments.
Contrary to the above, the inspectors identified that the REM 500 portable neutron
survey instruments were not appropriately calibrated on a semi-annual frequency.
Specifically, the REM 500 portable neutron survey instrument in question had not been
properly calibrated since August 9, 2002. After the issue was identified by the
inspectors, NextEra entered it into their corrective action program (AR 01969397),
sent all affected REM 500 neutron meters to the manufacturer for calibration, revised
the applicable instrument procedure to include a requirement to calibrate the instrument
to a NIST traceable neutron source annually, and performed an impact evaluation on the
out-of-calibration instruments past use, which indicated no significant impact on
Enclosure
19
assessing occupational neutron dose. Because this finding was of very low safety
significance and was documented in the licensees corrective action program, this
violation is being treated as an NCV, consistent with the NRC Enforcement Policy.
(NCV 05000443/2014005-03, Failure to Periodically Calibrate REM-500 Neutron
Survey Instruments)
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1 Mitigating Systems Performance Index (3 samples)
a. Inspection Scope
The inspectors reviewed NextEras submittal of the Mitigating System Performance
Index for the following systems for the period of November 1, 2013 to October 31, 2014:
- Safety System Functional Failures (MS05)
- Residual Heat Removal System (MS09)
- Cooling Water System (MS10)
To determine the accuracy of the performance indicator (PI) data reported during those
periods, the inspectors used definitions and guidance contained in NEI Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors
also reviewed NextEras operator narrative logs, mitigating systems performance index
derivation reports and basis documents, event reports, and NRC integrated inspection
reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
During December 8 to 11, 2014, the inspectors sampled licensee submittals for the
occupational exposure control effectiveness PI for the period from the fourth quarter
2013 through the third quarter 2014. The inspectors used PI definitions and guidance
contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory
Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of
the PI data reported.
The inspectors reviewed condition reports, electronic personal dosimetry dose alarms,
dose reports, and dose assignments for any intakes that occurred during the time period
reviewed to determine if there were potentially unrecognized PI occurrences.
b. Findings
No findings were identified.
Enclosure
20
.3 Radiological Effluent Occurrences (1 sample)
a. Inspection Scope
During December 8 to 11, 2014, the inspectors sampled licensee submittals for
the radiological effluent TS/Offsite Dose Calculation Manual radiological effluent
occurrences PI for the period from the fourth quarter 2013 through the third quarter
2014. The inspectors used PI definitions and guidance contained in the NEI Document
99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to
determine the accuracy of the PI data reported.
The inspectors reviewed NextEras corrective action report database and reviewed
reports generated since this indicator was last reviewed to identify any potential
occurrences such as unmonitored, uncontrolled, or improperly calculated effluent
releases that may have impacted offsite dose. The inspectors also reviewed the
licensees methods for quantifying gaseous and liquid effluents and determining
effluent dose.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution (71152 - 3 samples)
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution,
the inspectors routinely reviewed issues during baseline inspection activities and plant
status reviews to verify that NextEra entered issues into the CAP at an appropriate
threshold, gave adequate attention to timely corrective actions, and identified and
addressed adverse trends. In order to assist with the identification of repetitive
equipment failures and specific human performance issues for follow-up, the inspectors
performed a daily screening of items entered into the CAP and periodically attended
condition report screening meetings.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection
Procedure 71152, Problem Identification and Resolution, to identify trends that might
indicate the existence of more significant safety issues. In this review, the inspectors
included repetitive or closely-related issues that may have been documented by NextEra
outside of the CAP, such as trend reports, performance indicators, major equipment
problem lists, system health reports, MR assessments, and maintenance or CAP
Enclosure
21
backlogs. The inspectors also reviewed NextEras CAP database for the third and fourth
quarters of 2014 to assess action requests/condition reports written in various subject
areas (equipment problems, human performance issues, etc.), as well as individual
issues identified during the NRCs daily condition report review (Section 4OA2.1). The
inspectors reviewed Seabrook Stations Self-Evaluation and Trending Analysis Report
for third quarter of 2014, conducted under PI-AA-207-1000, Station Self-Evaluation and
Trending Analysis, Revision 1, to verify that NextEra personnel were appropriately
evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of departments that are required to provide input into
the quarterly trend reports, which included Operations and Maintenance. This review
included a sample of issues and events that occurred over the course of the past two
quarters to objectively determine whether issues were appropriately considered or ruled
as emerging or adverse trends, and in some cases, verified the appropriate disposition
of resolved trends. The inspectors verified that these issues were addressed within the
scope of the CAP, or through department review and documentation in the quarterly
trend report for overall assessment. For example, while potential adverse trends that
are included in the quarterly trend reports are often identified through the use of
statistical methods to identify statistically significant issues that reach a predetermined
threshold, cognitive trends are often identified by staff or collectively during review by the
Management Review Committee while screening ARs. The inspectors noted that quite
often, cognitive trends are not ultimately documented in the trend report as they are
appropriately assigned trend codes, but do not screen into the report based on the
established thresholds. One such example involved multiple alarms associated with
the loose parts monitoring system (LPMS), which revealed some potential equipment
problems as the source. These LPMS issues were identified in action requests, had
trend codes applied, but were dispositioned within the work control system. Another
example involved several trips of breaker thermal overloads for various loads that were
entered into the CAP and ultimately resolved through the work management system.
While these issues were processed through the CAP and the work management system,
the inspectors noted they were assigned trend codes to ensure they could be identified
as potential trends through the use of statistical tools and enable the staff an opportunity
to properly assess these issues, if applicable, within the trending process. The
inspectors also noted that a multitude of fire protection deficiencies had occurred
throughout the past two quarters, ranging from fire door issues, fire seal delaminations,
and fire alarm circuit problems, and verified that the trend reports had appropriately
identified these fire deficiencies as an adverse trend in the third quarter report. As a
result, the inspectors concluded that NextEras trending process, as well as the CAP
(through the use of trend codes) had the appropriate sensitivity and thresholds to identify
and assess adverse trends.
During review of the trend report, the inspectors assessed the appropriateness of an
adverse trend that was closed out in the third quarter report in the area of work control
supervisor human errors. The inspectors noted that this trend shared common attributes
with fourth quarter human performance issues (see Section 1R22) associated with an
emergency power sequencer (EPS) surveillance, particularly related to personnel not
Enclosure
22
being present during pre-job briefs. However, the inspectors noted extensive and
appropriate corrective actions had resulted in overall improvement in the area of
pre-job briefs and supervisory oversight, notwithstanding anecdotal evidence supplied
by this discrete EPS human performance issue that occurred in the fourth quarter.
Also, the inspector noted corrective actions for this fourth quarter EPS issue included
communication of improved management expectations, which were considered
reasonable and appropriate. Overall, the inspectors verified that individual issues and
trends discussed in this section were evaluated and determined to be of minor safety
significance and, as documented in Section 1R22 of this report, determined that the
human performance issues did not result in the identification of regulatory findings.
.3 Annual Sample: Operability Determinations
a. Inspection Scope
The inspectors performed an in-depth review of NextEras corrective actions for
longstanding weaknesses in the performance of operability determinations, conducted
under NextEra procedure EN-AA-203-1001, Operability Determinations/Functionality
Assessments, Revision 18. While inspectors had previously evaluated issues regarding
operability determinations in the root cause analysis (AR1919736) and associated
corrective actions for the SW leak in August 2013, the inspectors on several occasions,
had identified weaknesses in various attributes of the operability determination (OD)
process. As a result, the inspectors assessed several ODs to ensure consistency with
the applicable procedure. In particular, the inspectors assessed the documented basis
for operability, any supporting information that was considered and/or discounted, as
well as comments provided by the management review committee, and evaluated these
actions to the requirements of NextEras CAP and 10 CFR 50, Appendix B. In addition,
the inspectors interviewed NextEra personnel to assess the effectiveness of the
implemented corrective actions.
b. Findings and Observations
No findings were identified.
The inspectors evaluated several ARs generated since the August 2013 service water
leak operability issue was identified as noted above. This review focused on various
aspects of the operability process to assess the effectiveness and scope of corrective
actions. This included bases and supporting information for immediate operability
evaluations as detailed in the CAP; if applicable, prompt operability evaluations and
associated documentation and bases; and MRCs review of operability statements and
actions to address weaknesses, if identified. Some examples included:
- AR 01953499: MRC identified condition report for Operations to revise operability
screening
- AR 01971462: A Boric acid transfer pump trip
- AR 01987810: B Emergency diesel generator exhaust silencer pipe support
corrosion
- AR 01997819: ARs required rescreening by shift manager
- AR 01997929: Self-assessment regarding timeliness of prompt operability
determinations and functionality assessments
- AR 02000487: A emergency diesel generator loose air intake manifold cap screws
Enclosure
23
The inspectors identified improvements in the functioning of MRC to return operability
determinations that did not contain adequate rigor or provide appropriate bases in
support of operability. In addition, the inspectors verified that the operability screenings
of specific ARs reviewed for this assessment contained appropriate information that
supported operability, and that these determinations were performed in accordance with
applicable procedures.
.4 Annual Sample: Review of Corrective Actions for Alkali-Silica Reaction Affected
Structures
a. Inspection Scope
During the week of October 20, 2014, NRC inspectors from Region I and a structural
engineer from the Division of License Renewal, NRR, witnessed testing conducted at the
Ferguson Structural Engineering Laboratory at the University of Texas - Austin (UT-
Austin) in support of the Seabrook Alkali-Silica Reaction (ASR) Project Corrective Action
Plan. Specifically, the inspectors observed the load testing of reinforcement anchorage
(lap splice) beam No. A3, performed on October 22, 2014. The inspectors verified
compliance with associated testing program procedures and quality assurance/control
requirements; discussed recent testing results and the overall status of the test program,
including projected milestones with the responsible staff; ensured testing results were
appropriately reflected into current open Prompt Operability Determinations (PODs) for
ASR-affected Seabrook structures; and, examined the newly fabricated instrument beam
and associated monitoring devices.
During this inspection period, the inspectors were also on-site to review station activities
related to routine sampling and analysis of groundwater. Groundwater sampling is being
conducted by the licensee to: 1) monitor the movement of tritium contamination
inadvertently released via a spent fuel pool (SFP) cask handling/dewatering area liner
leak that was identified in mid-1999; 2) monitor for potentially aggressive groundwater
that may have an adverse impact on below grade reinforced concrete structures; and, 3)
satisfy commitments to NEI 07-07, Industry Ground Water Protection initiative,
guidance as it pertains to monitoring site hydrology and migration of ground
contaminants. The inspectors reviewed groundwater well sample results and discussed
past, current and future groundwater monitoring activities with the Seabrook Station
Chemistry Manager.
b. Findings
No findings were identified.
Groundwater Monitoring Review Observations
The inspectors observed that the scope of NextEras groundwater monitoring program
has evolved over the past 15 years. An expanded groundwater sampling effort was
initiated following the discovery of a SFP cask handling/dewatering area liner leak in
September 1999. Groundwater radionuclide monitoring (principally tritium) continues to
the present due to this legacy issue. The results of this monitoring program are reported
to the NRC on an annual basis. Currently, a total of 27 monitoring wells located within
the site boundary are sampled annually and the quantification of any measurable
Enclosure
24
radionuclides is reported to the NRC in the Annual Radionuclide Effluent Release
Report. This annual report includes a listing of the groundwater monitoring wells
(by identifier and location) and the associated radionuclide activity concentration
(picocuries/liter) measured for each sample location. The most recent published report
(2013 sample results) is dated April 29, 2014 (ML14121A399). Following resolution of
the SFP leak, NextEra initiated a dewatering campaign in 2004 to contain and mitigate
the tritium plume. This groundwater dewatering effort included removal of groundwater
in-leakage from the containment enclosure area, primary auxiliary building, emergency
feed water pump house, residual heat removal equipment vault, and the B electrical
tunnel. Water removed from these areas has totaled, at times, over 3000 gallons per
day (gpd). Along with the Unit 1 dewatering campaign, approximately 32,000 gpd is
pumped from the Unit 2 containment building area and discharged via the monitored
(for radionuclides) storm water drainage system. Pumping groundwater from Unit 2 has
assisted in the containment of the Unit 1 tritium plume and preventing its migration off
site (reference Seabrook Stations Final Applicants Environment Report- Operating
License Renewal Stage, ML101590092).
In support of license renewal activities and the current Structures Monitoring Program
(SMP), NextEra implemented additional groundwater sampling of five on-site wells
(SW-1, SW-2, SW-3, SD-1 and SD-2). The SMP groundwater sampling and associated
chemical analysis supports NRC guidelines for monitoring for potential aggressive
groundwater conditions consistent with NUREG 1801, Generic Aging Lessons Learned
(GALL) Report,Section XI.S7, and Regulatory Guide 1.127, Inspection of Water-
Control Structures Associated with Nuclear Power Plants. Aggressive groundwater is
identified in the GALL report as having measured pH <5.5, chlorides >500 ppm, or
sulfates >1500 ppm. Aggressive groundwater potentially neutralizes normally high
alkali content concrete and can contribute to the oxidation of carbon steel reinforcing
bars. The initial sampling for aggressive groundwater was conducted in September
2009 and continued into the first quarter of 2011. Based on the indications of chlorides,
Seabrook is sampling for four consecutive quarters every five years in accordance with
NextEras SMP groundwater monitoring program.
The inspectors determined that the NextEra staff planned to conduct their next series of
four quarterly samples beginning in July 2014. The initial SMP groundwater sampling in
September 2009 indicated that wells SW-1, SW-2, and SW-3 contained potentially
aggressive groundwater based on a chloride content range of 2,300 to 2,600 ppm;
however, the sulfate content was only 34 to 92 ppm and the pH 5.8 to 6.7. The
inspector learned from the Chemistry Manager that during the baseline groundwater
monitoring period (early 2010), a buried SW pipe leak occurred in a section buried
between Units 1 and 2, spilling several hundreds of gallons of ocean water into the
surrounding soils before being isolated. The inspectors observed that the groundwater
monitoring data illustrated the affected wells (BD-6, SD-5, SW-1, SW-2 and SW-3) had
chloride content spikes that ranged from 2,600 to 19,000 ppm and are attributable to the
seawater contamination. Typical saltwater (ocean) chloride content is in the 19,000 to
20,000 ppm range. Further inspector review of the sample data and associated site
hydrological studies identified that the below grade concrete structures more likely to be
impacted by the ocean water spill from 2010 were associated with Unit 2 (SW-3, SD-5,
BD-6). The two wells (SW-2 and SD-5) with chloride spikes as high as 19,000 ppm in
the 3rd quarter of 2010 had decreased to 770 ppm and 15,000 ppm by the 1st quarter of
Enclosure
25
2011. The Unit 1 fuel storage building (SW-1) and waste processing building (SW-4)
monitoring wells indicated some continued elevated chloride levels, but was trending
downward due to the ongoing dewatering efforts.
In 2008, NextEra contracted for a hydrological survey, consistent with the guidelines
published in NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance
Document. The results of the initial hydrological study were documented in a
proprietary report. Based upon the commencement of pumping of groundwater from
a site construction dewatering well (designated well emergency feedwater (EFW)) in
October 2013, NextEra plans to update their 2008 hydrological survey, consistent with
NEI 07-07 guidelines, to identify the impact of this recent dewatering effort on ground-
water radiological plume migration. Based upon plant walk-through observations by
the inspectors, the EFW well pumping regime (dewatering at a rate of between 14-15
gallons per minute) has significantly reduced the water infiltration into the adjacent B
Electrical Tunnel. The inspector noted that the water being removed from the EFW well
was being discharged to the site storm water drainage system where it was continuously
monitored prior to release to the environment.
Based upon discussions with NextEra personnel, the monitoring wells SW-1 and SW-3
(located within close proximity to the Unit 1 spent fuel pool) were identified as sentinel
wells (considered the best indicators of the groundwater tritium contamination plume)
and typically had indicated between 2,000 to 5,000 picocuries/liter tritium. The water
being pumped from the EFW construction dewatering well averaged between 1200 to
1600 picocuries/liter tritium. None of the wells on-site were being used for potable
(drinking) water and all of the wells were indicating radioactivity levels significantly
below the US Environmental Protection Agency (EPA) drinking water limit of <20,000
picocuries/liter.
In summary, the inspectors concluded that NextEras various groundwater sampling
and monitoring processes were in conformance with current regulatory requirements,
standards, and station commitments. In addition to the elevation differences (the site
grade is 20 feet above mean sea level), the historic monitoring data and trend results
provided reasonable assurance that the groundwater currently being pumped from
onsite monitoring wells or removed for below grade structures is freshwater infiltrating
from initial construction/excavation exposed aquifers and not saltwater from the
surrounding tidal saltwater marshes.
UT-Austin Testing Program Observations
The inspectors witnessed the performance of load testing of reinforcement anchorage
(e.g. lap splice) beam No. A3. Beam A3 was fabricated on July 9, 2013, and had
undergone controlled accelerated ASR aging per the UT-Austin testing program since
that time. Beam expansion measurements and core sample material property testing
data obtained a few days prior to the October 22 load test by NextEra identified the
following: core compressive strength 3470 psi (compared to the 28-day cylinder
strength of 4500 psi); core Modulus of Elasticity (Ec) 850 ksi (compared to the 28-day
cylinder Ec of 3980 ksi); xy-strain ( xy) 0.06 percent; and, z-strain ( z) 2.02 percent.
Beam A3 was tested in accordance with MPR Project 0326-0063, Procedure 5-7,
Structural Testing of Shear and Anchorage Specimens, Revision 2, dated 5/28/2014.
Beam failure occurred at a load of approximately 271,000 pounds (compared to
Enclosure
26
control beam A7 that failed at 251,000 pounds). No testing anomalies were identified.
Preliminary review of the large specimen load testing results indicated that beam
structural performance (measured by load carrying capacity prior to failure) was
generally inversely proportional to the extracted cores material properties determined
just prior to testing. Specifically, concrete core test results indicated reduced
compressive strength and reduced Modulus of Elasticity, but the overall test specimen
structural performance remained unaffected or slightly improved. ASR-affected
specimens tested, to date, exhibited increased rigidity proportional to the increased
degree of (or time subjected to) ASR aging. Overall, the inspectors observed proper
procedural adherence, appropriate test coordination and proper communications
exhibited by the testing staff, supervisory personnel and quality assurance overseers.
Based upon the large specimen monitoring and testing completed, to date, the NextEra
staff has concluded that it is necessary to modify the test program to address the
apparent plateauing of the x- and y-plane expansion and the associated continuing
expansion in the z-direction (through-wall) of all large test specimens. Deep pin
(cast in-place) expansion measurements in all three planes have been used to compare
the xy-plane combined crack index (CCI) data for validation. Based upon the observed
plateauing of xy-strain (determined by deep pin direct measurement) in all of the large
test specimens, the NextEra staff has preliminarily concluded that the CCI method will
be of minimal value for long-term ASR monitoring. Consequently, an additional large
specimen beam was fabricated in June 2014 and instrumented with three different types
of extensometers to validate future application/installation of extensometers in Seabrook
Station ASR-affected reinforced concrete structures. An extensometer is an instrument
that measures the amount of movement (e.g., expansion or elongation) in a particular
direction. The NextEra staff indicated that the testing programs instrument beam
extensometer outputs will be compared to the installed deep pin expansion measure-
ments to identify the most reliable and accurate device for long term z-strain ASR
monitoring.
Based upon overall testing program progress, to date, NextEra staff projected to have
the large specimen reinforcement anchorage and shear testing completed by the third
quarter of 2015. Following the completion of testing, NextEra currently plans to
summarize the results in a written report, update the current Seabrook Station
ASR-affected reinforced concrete building structural evaluations and PODs, revise
the Seabrook Structures Monitoring Program, and submit a license amendment, if
appropriate, in 2016. The inspectors concluded that the current ASR-affected structures
PODs remained valid and continued to provide reasonable assurance of operability
because none of the testing program results or insights gained, to date, undermined
the engineered margins or assumptions used in the PODs.
4OA6 Meetings, Including Exit
On January 29, 2015, the inspectors presented the inspection results to Mr. Dean
Curtland, Site Vice President, and other members of the Seabrook Station staff. The
inspectors verified that no proprietary information was retained by the inspectors or
documented in this report.
ATTACHMENT: SUPPLEMENTARY INFORMATION
Enclosure
A-1
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
D. Curtland, Site Vice President
R. Dodds, Plant General Manager
P. Allen, Radiation Protection Technician
B. Brown, NextEra Engineering
V. Brown, Senior Licensing Engineer
J. Buyak, Radiation Protection Technician
J. Connolly, Site Engineering Director
K. Douglas, Maintenance Director
P. Dundin, Operations Shift Manager
D. Flahardy, Radiation Protection Manager
D. Hampton, Nuclear Oversight Auditor
J. Klempa, System Engineer
E. Kotkowski, Control room operator
B. McAllister, Nuclear Engineer
L. Michaud, Work Week Manager
M. Nadeau, Radiation Protection Dosimetry Supervisor
M. Ossing, Licensing Manager
E. Pigott, Operations Training Supervisor-Continuing Training
D. Ritter, Operations Director
D. Robinson, Chemistry Manager
T. Smith, Radiation Protection Supervisor
T. Waechter, Nuclear Plant Shift Manager
N. Watts, Senior Reactor Operator
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
05000443/2014005-01 NCV Failure to Identify and Evaluate Class 1 Structural
Conditions Adverse to Quality (Section 1R12)05000443/2014005-02 NCV Failure to Identify and Evaluate FSB Deviation
from Design Basis (Section 1R12)05000443/2014005-03 NCV Failure to Periodically Calibrate REM-500 Neutron
Survey Instruments (Section 2RS5)
Attachment
A-2
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
OP-AA-102-1002, Seasonal Readiness, Revision 5
OS1200.03, Severe Weather Conditions
Condition Reports
01989778 01992418 02000138
Miscellaneous
Seasonal Readiness Memo to Mano Nazar dated 9/24/14
UFSAR Section 8
Section 1R04: Equipment Alignment
Procedures
OS1005.05, Safety Injection System Operation, Revision 26
OS1016.05, Service Water Cooling Tower Operation, Revision 28
OS1026.11, Operating DG 1B Jacket Cooling Water System, Revision 10
OS1023.51, Control Room Ventilation and Air Conditioning System Operation, Revision 22
OX1405.07, Safety Injection Quarterly and 18 Month Pump Flow and Valve Test, Revision 13
OX1436.20, Startup Feed Pump Monthly Valve Operability Surveillance, Revision 2
Condition Reports
01869005 02004748* 02004780* 02013363* 02013369
- NRC identified
Maintenance Orders/Work Orders
40234817 40245048 40111372 40196116 40042857 94109967*
94109969 94072242
Drawings
1-CBA-B20308, Control Building Air Conditioning System Safety Related Chilled Water System
Train B Detail, Revision 7
1-DG-B20463, Diesel Generator Lube oil System Train B Detail, Revision 20
1-DG-B20464, Diesel Generator Fuel Oil System Train B Detail, Revision 17
1-DG-B20465, Diesel Generator Starting Air System Train B Detail, Revision 25
1-DG-B20466, Diesel Generator Cooling Water System Train B Detail, Revision 22
1-DG-B20467, Diesel Generator Intake Exhaust & Crankcase Vacuum System Train B Detail,
Revision 8
Section 1R05: Fire Protection
Miscellaneous
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1A-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1D-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1E-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1F-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-1G-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-3A-A
Attachment
A-3
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-3B-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume I, CB-F-3C-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1A-Z
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1B-A
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1C-Z
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-1-0
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-3-0
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-3-0
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-2-F-Z
Seabrook Station Fire Protection Pre-Fire Strategies, Volume II, TB-F-3-Z
Section 1R11: Licensed Operator Requalification Program
Procedures
ER 1.1, Classification of Emergencies, Revision 52
ER 1.2, Emergency Action Plan Activation, Revision 61
OX1426.23, Emergency Diesel Generator 1B 24 Hour Load Test and Hot Restart Surveillance,
Revision 18
OX1430.02, Main Steam Isolation Valve Quarterly Test, Revision 16
Maintenance Orders/Work Orders
40279900
Miscellaneous
Seabrook Technical Specifications
Section 1R12: Maintenance Effectiveness
Procedures
MA 3.5, Post Maintenance Testing, Revision 14
OS1046.18, 4.16 KV Breaker Racking Operations, Revision 11
OX1456.21, Train A ESFAS Slave Relay K601 Quarterly Go Test, Revision 10
PI-AA-104-1000, Corrective Action, 07/18/14
Technical Procedure 36180, Structural Monitoring Program, Revision 4, 7/29/13
Technical Procedure 36180, Structural Monitoring Program, Revision 5, 10/14/14
Action Requests
02014116* 01831660 00196973
02014120* 01617960 01986980
02011698* 00197551 04-05036
02011698 01992998 02016192*
01921217 01977456 02016238*
01920005 00581434 02016225*
01992998 00396307 02016863*
00196973 00004916
01986980 00197551
- ARs initiated in response to this inspection
Attachment
A-4
Engineering Evaluations, Analyses, Calculations & Standards:
ACI 349.3R-02, Evaluation of Existing Nuclear Safety-Related Concrete Structures,
Reapproved 2012
Apparent Cause Evaluation for AR 196973
Apparent Cause Evaluation Report for AR 1977456
Revised Safety Culture Evaluation for CR1976944, 1977233 and 1977456
Seabrook Station Maintenance Rule (a)(1) Improvement Plan For CE-01, CB-01, CS-01, CT-01,
CST-01, DGB-01, EF-01, EM-01, FB-01, ITS/DTS-01, MF-01, SWB-01, PB-01, RV-01 and
WB-01, Degradation of Concrete, Revision 05, 9/18/2014; AR581434, AR1664399,
AR1636419, AR1687932-(a)(1) Plan, AR1757861, AR1804477, AR1952162
Seabrook Calculation FB-18, Revision 6, Title: Mats & Walls Below Grade, Fuel Storage
Building
Engineering Change Documents:
EC 0000249139 002, Spent Fuel Pool Gate Latch Modification - AR 00396307, 10/4/11
36180, Rev.2, SMP FORM 2, Structural Deficiency Report - Initial Discovery:
CST-SVR-D-001, 11/7/13 CST-SVR-D-002, 11/7/13 CST-SVR-D-003, 11/7/13
CB105-D-001, 11/7/13 CB105-D-002, 11/7/13 CP101-D-001, 10/10/13
CP101-D-002, no date CP101-D-003, 10/10/13 CP101-D-003, no date
PB207-D-001, 6/29/11 PB206-D-001, 6/28/11 MF102-D-001, 9/20/11
36180, Rev.2, SMP FORM 3, Structural Deficiency Report - Engineering Staff Review:
CST-SVR-D-001, 11/7/13 CST-SVR-D-002, 11/7/13 CST-SVR-D-003, 11/7/13
CB105-D-001, 11/7/13 CB105-D-002, 11/7/13 CP101-D-001, 10/21/13
CP101-D-002, 10/21/13 CP101-D-003, 10/21/13 PB207-D-001, 7/20/11
PB206-D-001, 7/20/11 MF102-D-001, 10/18/11
36180, Rev.2, SMP FORM 4, Structural Deficiency Report - Follow-up Inspection:
MF102-D-001, MF102-D-002, MF102-D-003, MF102-D-004
Program Documents:
NextEra Energy Seabrook, Technical Procedure, Structural Monitoring Program, 36180,
Revision 5, 10/14/14
NextEra Energy Seabrook, Technical Procedure, Structural Monitoring Program, 36180,
Revision 4, 7/29/13
Procedures:
NextEra Energy, Nuclear Fleet Administrative Procedure, PI-AA-104-1000,
CORRECTIVE ACTION, 07/18/14
Prompt Operability Determination for AR581434, Revision 000
Prompt Operability Determination for AR581434, Revision 001
Prompt Operability Determination for AR581434, Revision 002
Attachment
A-5
Vendor Inspection Contract:
Contractor Metrology Inspection Services Within the Cooling Pool of the FSB, 12/16/13
Work Orders:
0543784, 7/10/06, 1-BM-INSP-BLDG-INTG-FSB-000 Building Maintenance
Miscellaneous Documents:
Seabrook Station UFSAR, Revision 16, Section 3.8, Page 148 - 153,
Design Of Structures, Components, Equipment AND Systems, Design of Category I
Structures U.S. Nuclear Regulatory Commission, Regulatory Guide 1.13,
Spent Fuel Storage Facility Design Basis, Revision 2, March 2007
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures
OP-AA-102-1003, Guarded Equipment, Revision 5
Miscellaneous
Maintenance Rule (a)(4) Risk Profile for Work Week 1439-05
Maintenance Rule (a)(4) Risk Profile for Work Week 1442-08
Maintenance Rule (a)(4) Risk Profile for Work Week 1443-09
Condition Reports
02000207
Maintenance Orders/Work Orders
40279916
Miscellaneous
PRA-301, MR (a)(4) Process for On-Line Maintenance Group Instruction, Revision 0
WM-AA-100-1000, Work Activity Risk Management, Revision 1
Section 1R15: Operability Determinations and Functionality Assessments
Procedures
EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 19
OX1461.03, SEPS Operational Readiness Status Surveillance, Revision 01
OX1446.01, AC Power Source Weekly Operability Surveillance, Revision 23
Condition Reports
00017982 00018003 01868380 01986793 01995888 01998684
02000487 02000545 02000743 02000743 02003027 02003067
02003427 02013363 02013369 02013417 02013442 02013457
02013458
Maintenance Orders/Work Orders
40191176 40287143 40347648 40347646 40346051
Attachment
A-6
Miscellaneous
Foreign Print FP 22620, Seismic Test Report, Issue No. 6
Plant Engineering Action Plan Register, EDG-B Main Bearings #7 and #8 Vibration Indication
During Engine Analysis Collection
PM Technical Basis - New PM Activity to Replace Heaters on 1-CBA-H-371 and 372
Periodically, Dated 2/27/08
Section 1R18: Plant Modifications
Procedures
MS0526.09, On Stream Leak Repairs, Revision 6
Condition Reports
00394022 01907792 01944267 01944282 02003019 02004186
02004461 02004690 02005370
Maintenance Orders/Work Orders
01383187 40204470
Miscellaneous
Engineering Change 282744, 1-SB-V-9 Temporary Leak Repair, Revision 3
FP100873, 1-SB-V-9 Team Inc. Clamp Design Calculations, Revision 1
Drawings
1-NHY-310102, 4160 Bus 1-E6 RAT Incoming Line, Sheet A72m, Revision 0
1-NHY-310102, 4160 Bus 1-E6 RAT Incoming Line, Sheet A72n, Revision 3
1-NHY-310102, 4160 Bus 1-E6 Potential Xfmrs, Sheet A73j, Revision 1
1-SB-B20626, Steam Generator Blowdown (Blowdown Flash), Revision 18
Section 1R19: Post-Maintenance Testing
Procedures
LS0558.03, 4.16KV Motor - Routine Testing, Inspection and PM, Revision 9
LS0563.23, Type IAC Overcurrent Relay Inspection, Testing and PM, Revision 9
LS0563.186, Trip Relay Checks, Revision 0
LS0564.34, 4160 Volt Static Motor Testing, Revision 8
MS0523.56, Ingersoll-Dresser Ocean Service Water Pump removal and Installation,
Revision 12
MS0539.37, Emergency Diesel Generator Engine Cylinder Head Maintenance, Revision 8
OS1016.04, Service Water Train B Operation, Revision 19
OS1023.51, Control Room Ventilation and Air Conditioning System Operation, Revision 22
OX1405.07, Safety Injection Quarterly and 18 Month Pump Flow and Valve Test, Revision 13
OX1412.02, PCCW Train B Quarterly Operability, 18 month Position Indication, and
Comprehensive Pump Testing, Revision 20
OX1426.26, EDG 1A Semiannual Operability Surveillance, Revision 17
OX1456.26, Train A ESFAS Slave Relay K610 Quarterly Go Test, Revision 7
OX1656.81, Operability Testing of IST Valves, Revision 19
OX1426.23, Emergency Diesel Generator 1B 24 Hour Load Test and Hot Restart Surveillance,
Revision 18
Attachment
A-7
Condition Reports
01969615 01991632 01992923 01998684 01999416 02003706
02003768 02003900 02004037 02004187
Maintenance Orders/Work Orders
01047450 40279688 40279790 40279791 40279792 40279794
40279900 40281987 40325695 40325696 40332384 40337807
40347648 40347769
Miscellaneous
2MSE235-00, Alternate Materials for Check Valve Disc Washer
DRR 92-060, Walworth Disc Washer Material Substitution and Sizing
MS0519.65, Walworth 16-, 18-, 20- and 24-Inch swing check valve maintenance
Seabrook Station UFSAR, Revision 16
Drawings
1-NHY-310882, Reactor Coolant Pump 1-P-1D Three Line Diagram, Sheet A24a, Revision 10
1-NHY-310882, Reactor Coolant Pump 1-P-1D Trip Contacts, Sheet A24c, Revision 5
1-NHY-310882, Reactor Coolant Pump 1-P-1D Protection Schematic, Sheet A24d, Revision 7
1-NHY-310882, Reactor Coolant Pump 1-P-1D Auxiliary Contacts, Sheet A24e, Revision 5
1-NHY-310882, Reactor Coolant Pump 1-P-1D, Sheet A24k, Revision 2
1-NHY-310882, Reactor Coolant Pump 1-P-1D, Sheet A241, Revision 1
Section 1R22: Surveillance Testing
Procedures
OX1412.02, Revision 20, PCCW Train B Quarterly Operability, 18 month Position Indication,
and Comprehensive Pump Testing
OX1416.05, Service Water Cooling Tower Pump Quarterly and 2 Year Comprehensive Test,
Revision 22
OX1416.06, Service Water Discharge Valves Quarterly Test and 18 Month Position Verification,
Revision 11
OX1426.03, Emergency Power Sequencer 18 Month Operability Test, Revision 7
OX1456.81, Operability Testing of IST Valves, Revision 19
OX1456.86, Operability Testing of IST Pumps, Revision 10
Condition Reports
01995518 01995561
Maintenance Orders/Work Orders
40279856 40279857 40292315 40292326
Drawings
FP31418, Emergency Power Sequencer Electrical Schematic, Issue 14
FP31416, Emergency Power Sequencer Electrical Schematic, Issue 13
FP31374, Emergency Power Sequencer Logic Diagram, Issue 08
Miscellaneous
Seabrook Station UFSAR Table 8.3-1, Engineered Safety Features, Revision 14
Attachment
A-8
Section 2RS3: In-Plant Airborne Radioactivity Mitigation and Control
Procedures
CS0917.04, Monitoring Plant Systems for Radioactivity, Revision 1
CS0910.11, Wide Range Gas Monitor Sampling, Revision 1
HD0965.10, Respirator Fit Testing Using the TSI Portacount, Revision 18
HD0965.12, Respiratory Equipment Issue and Use, Revision 39
HD0965.14, Use of PosiChek 3, Revision 10
HD09-01-01, Firehawk M7 and M7 Responder Air Mask Maintenance and Repair, Revision 3
HD0965.08, Breathing Air Certification, Revision 16
JD0999.102, Radiological Guidelines for Use of Containments and Air Handling, Revision 8
Condition Reports
2007480
Miscellaneous
Fit Test Report MSA Ultra Elite 1000 Full Face Negative Pressure Respirator Serial No.
008709147, November 13, 2014
Fit Test Report for Test Subject using MSA Ultra Rubber 1000 using Portacount Pro Serial
No. 803014209, December 10, 2014
HD0965.08 Form A: Grade D In-House Breathing Air Certification for Firefighter Annex Air
Compressor, November 14, 2014
HD0965.14 Form A: SCBA HIP- AIR Regulator Flow Checks Serial No. ML337078,
April 21, 2014
HD0965.14 Form A: SCBA HIP- AIR Regulator Flow Checks Serial No. ANPE186198,
April 23, 2014
HD0965.14 Form B: SCBA Face Piece Test Serial No. FH 80, September 30, 2014
HRE-M01 SCBA Inspection and Inventory, October 17, 2014
HRE-M02 Inspect Routine Use Radiological Ultra-Vue FFAP Respirators, December 8, 2014
HRE-M11 Inventory Routine Use Radiological Ultra-Twin FFAP Respirators, December 8, 2014
MSA Training Certificate Authorized Repair Center, MSA M7 MMR Certified C.A.R.E.
Technician, February 7, 2013
PosiChek 3 USB Test Results for Serial Number ANAD063777 Firehawk M7 Air Mask,
December 10, 2014
Seabrook Updated Final Safety Analysis Report
Seabrook Station Nuclear Training Group OJT/TPE Guide for Firehawk M7 SCBA OJT
- GT1074J, Revision 15
Sentinel Respirator Qualification Expiration Date Report, November 3, 2014
Service History for Instrument Serial Number APAB279682 Firehawk SCBA Regulator,
December 10, 2014
Service History for Instrument Serial Number ANAE186198 Firehawk SCBA Regulator,
December 10, 2014
Service History for Instrument Serial Number FH-86 UltraElite Respirator, December 10, 2014
TRI Air Testing, Inc Laboratory Report-Compressed Air Gas Quality Testing, September 30, 2014
TSI Certificate of Testing for Portacount Pro Serial No. 8030134708, November 12, 2014
Audits, Self-Assessments, and Surveillances
SBK 14-001 Seabrook Nuclear Oversight Report - Radiation Protection and Radwaste
Programs, February 24, 2014
Seabrook Daily Quality Summary Reports January 1, 2014 to December 8, 2014
Attachment
A-9
Section 2RS4: Occupational Dose Assessment
Procedures
HD0961.29, Internal Dosimetry Assessment, Revision 27
RP-AA-101-2001, SENTINEL Software Transactions Associated with Issuance and Control of
Personnel Monitoring Devices, Revision 2
RP-AA-103-2003, SENTINEL Software Miscellaneous Tasks User Guide, Revision 2
Condition Reports
01957032 01957390 01957400 01957403 01957427 01957495
01981002
Miscellaneous
Calibration of the FASTSCAN WBC System at Next Era Seabrook Generating Station,
March 4, 2014
HPSTID 14-007 Calibration of WBC System 2014, March 19, 2014
Seabrook 1 Updated Final Safety Analysis Report
Seabrook 2014-10CFR60 Analysis for Rad Monitor Instrument Response, November 2014
Seabrook Body Count Results for three employees, April 11, 2014
Audits, Self-Assessments, and Surveillances
SBK 14-001 Seabrook Nuclear Oversight Report - Radiation Protection and Radwaste
Programs, February 24, 2014
Section 2RS05: Radiation Monitoring Instrumentation
Procedures
HD0951.11, Documentation of Health Physics Studies and Technical Information, Revision 1
HD0955.50, Far West REM-500 Operation, Revision 6
Condition Reports
01980404
Miscellaneous
ANSI N323AB-2013, Radiation Protection Instrumentation Test and Calibration,
December 16, 2013
CD0900.15 Form A, Chemistry Performance Indicator Report Form, February 18, 2014
CD0900.15 Form A, Chemistry Performance Indicator Report Form, September 14, 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, January 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, February 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, March 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, April 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, May 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, June 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, July 2014
Attachment
A-10
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, August 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, September 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, October 2014
CHL-219 Reactor Coolant Specific Activity and RETS ODCM Radiological Effluent Occurrence
KPIs, November 2014
Far West Technology Operation and Repair Manual for REM-500 Neutron Survey Meter,
September 1998
GEL Laboratories, LLC, Laboratory Certificate of Analysis for Sample Data Group 360401,
Samples received November 3 and December 1, 2014
HPSTID-96-004, Basis for Performing Operability Checks for Use of the Far West Technology
REM-500 Meter, February 10, 1996
JD0999.910 Figure 1: Occupational Exposure Occurrence for October, November and
December 2013
JD0999.910 Figure 1: Occupational Exposure Occurrence for January, February and
March 2014
JD0999.910 Figure 1: Occupational Exposure Occurrence for April, May and June 2014
JD0999.910 Figure 1: Occupational Exposure Occurrence for July, August and September 2014
Maintenance Rule Functional Failure Evaluation for RM-6481-1 Main Stem Line A Rad
Monitor, July 25, 2014
SB UFSAR, Chapter12 Table 12.5-1 Portable Health Physics Instruments, Revision 16
Seabrook 1 Updated Final Safety Analysis Report
Seabrook Station Radiation Protection Manual, Revision 67
Section 4OA1: Performance Indicator Verification
Procedures
CS0917.02, Gaseous Effluent Releases, Revision 14
CX0917.01, Liquid Effluent Releases, Revision 20
HD0958.33, Performance of Radiation Protection Supervisory Plant Walk-downs, Revision 6
JD0999.910, Reporting Key Performance Indicators per NEI 99-02, Revision 6
NAP-206, NRC Performance Indicators, Revision 7
Condition Reports
01856230 01996503
Miscellaneous
Engineering Evaluation EE-11-020, FPL-Seabrook Mitigating System Performance Indicator
Basis Document, Revision 0
LIC-14039, Documentation Supporting the Seabrook Station NRC 3rd Quarter 2014
Performance Indicator Submittal
LIC-14031, Documentation Supporting the Seabrook Station NRC 2nd Quarter 2014
Performance Indicator Submittal
LIC-14018, Documentation Supporting the Seabrook Station NRC 1st Quarter 2014
Performance Indicator Submittal
LIC-14004, Documentation Supporting the Seabrook Station NRC 4th Quarter 2013
Performance Indicator Submittal
NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7
Attachment
A-11
Audits, Self-Assessments, and Surveillances
Quick Hit Assessment Report 1914767, HP Performance Indicator Verification,
November 1, 2013
Section 4OA2: Problem Identification and Resolution
Condition Reports
01904703 01916618 01919736 01930049 01953499 01971447
01997899 02001541 02005503 02007961 02008681 02013888
02014819
Maintenance Orders/Work Orders
40262945
Miscellaneous
Groundwater Monitoring Well SW-1, SW-2, SW-3, SD-1, SD-2 Data, collected on
September 4, 2009
Groundwater Monitoring Well Chemistry Data for 1st QTR 2010 through 1st QTR 2011
Groundwater Monitoring Well Specific Conductivity for BD-6, SD-5, SW-3, collected between
August 2012 and March 2014
MPR Project 0326-0063, Procedure 5-7, Structural Testing of Shear and Anchorage
Specimens, Revision 2
MPR Procedure 0326-0062-46, Procedure for In-process Inspections of FSEL Reinforcement
Anchorage Test Set-up for Seabrook Station, Revision 2
Source Verification Record (SVR) 0326-0062-23-44, Revision 0
Special Test and Inspection Record (STIR) 0326-0062-24-56, Revision 0
STIR 0326-0062-24-57, Revision 0
STIR 0326-0062-24-86, Revision 0
STIR 0326-0062-24-91, Revision 0
STIR 0326-0062-24-92, Revision 0
SVR 0326-0062-23-53, Revision 0
SVR 0326-0062-23-59, Revision 0
SVR 0326-0062-23-61, Revision 0
SVR 0326-0062-23-62, Revision 0
Attachment
A-12
LIST OF ACRONYMS
ACI American Concrete Institute
ADAMS Agencywide Document Access and Management System
ALARA as low as reasonably achievable
AR action request
ARM area radiation monitor
ASR alkali-silica reaction
CAP corrective action program
CCI combined crack index
CFR Code of Federal Regulations
CR condition report
EDG emergency diesel generator
EPS emergency power sequencer
FSB fuel storage building
gpd gallons per day
GALL Generic Aging Lessons Learned
IMC Inspection Manual chapter
ISFSI independent spent fuel storage installation
LPMS loose parts monitoring system
MR maintenance rule
NCV non-cited violation
NEI Nuclear Energy Institute
NFSA New Fuel Storage Area
NIST National Institute of Science and Technology
NRC Nuclear Regulatory Commission
OOS out of service
PCCW primary component cooling water
PARS Publicly Available Records
PI performance indicator
PODs prompt operability determinations
RG Regulatory Guide
SCBA self-contained breathing apparatus
SFP spent fuel pool
SMP structures monitoring program
SSC structure, system, or component
TS technical specification
UFSAR Updated Final Safety Analysis Report
WBC whole body count
WO work order
Attachment