ML20151W628

Ack Receipt of in Response to Congressional 880128 Rept on Allegations of Drug & Alcohol Abuse During Const of Facility.Urges Commission to Investigate Matters Thoroughly & Provide Complete Rept

ML20151W628
Person / Time
Site:	Seabrook
Issue date:	03/03/1988
From:	Markey E HOUSE OF REP.
To:	Zech L NRC COMMISSION (OCM)
Shared Package
ML20151W564	List: ML20151W561 ML20151W568 ML20151W628 ML20154C940
References
NUDOCS 8805030443
Download: ML20151W628 (5)

Text

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March 3, 1988 Honorable Lando W. zech, Jr.

Chairman U.S. Nuclear Regulatory Comninsion 1717 H Street N.W.

Washington, D.C. 20555

Dear chairman Zech:

I have received your letter of March 2, 1988 in response to the report I released on January 28, 1988 regarding allegations of drug and alcohol abuse during the construction of the seabrook nuclear power plant.

I was deeply troubled by the lack of any specific reference whatsoever in your letter to the details of that report.

Moreover, the Commission's and staff's apparent ignorance about the report's contents was undurscored during your appearance today before the House Interior and Insular Affairs Committee, subcommittee on Energy and thu Environment. Neither you nor the NRC's Director of Nuclear Reactor Regulation demonstrated any awareness of important allege,tions contained in that report --

for example, that the company reportedly responsible for. testing the concrete at seabrook was dismissed because of the number of times drugs and alcohol were found at their on-site facilities.

(See the affidavit of Mr. Peter McKinnon, appended as an attachment to the report.)

I include ao att attachnsnt to this letter a sworn affidavit I obtained from the former Assintant Director of construction at Seabrook which supports Mr. McKinnon's allegation that the concrete testing company was dismissed for reasons related to drugs and alcohol. In addition, this new affidavit indicates that even though the Assistant Director of Construction br;11 eves he ordinarily would have been informed obout drug and alcohol discoveries on-site, he had been told nothing about the discovery of $10,000 worth of cocaine inside the protected area in a three-day period in June 1906. I fail to understand why I should be able to obtain such informatien so easily while the NRC remains in the dark, particularly after the commission and its huge staff have had more than a month to examine my report of January 26th.

EDO 3/4..To 466 to Prepare Response for Signature of Chairman...

Date due: March 18...Cpys to: RF, EDO, OCA to Ack. 88-0174

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03/06/88 09:43 N.R.C. H ET HC.001 003

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e The Honorable Lando W. Zech, Jr.

Page 2 March 3, 1988

, The Commission's bland assurances which say essentially that "Seabrook is safe, no matter what" reflect little awareness of the detailed allegations that have been made about drug and alcohol use during construction, and indicate no effort on the part of the commission' staff to determine whether such incidents may have compromised the safety of the plant. For instance, your assertions that "no new technical issues concerning the construction of the Seabrook plant have been identified" and that "the adequacy of the plant physical construction has been verified through...the licensee's approved and detailed construction and testing program" (emphasis added) ring particularly hollow in light of the NRC's ignorance of the allegations regarding the  ;

concrete testing company. If the concrete testing program at Seabrook was compromised by drugs and alcohol, how can the NRC be certain that essential systems and components are indeed safe?

In addition, I cannot understand why the Commission has not investigated the issue of whether the licensee failed to comply with Part 21 of the Commissien's regulations in not reporting either the alleged problem with the concrete testing company or  ;

the discovery of roughly 100 grams of cocaine on-site in June 1986. It also appears to ne that the dismissal of the concrete testing company should raise the most serious questions about the .

adequacy of the Quality Assurance and Quality Control programs. I Moreover, if you add to.this list the other allegations in the report, the company's attempt to withhold information from '

Congress, and the failure te inform the NRC about at least 561 drug and alcohol incidents during 1982-1987 and almost 300 terminations in the same peried, I cannot comprehend why the WRC has not raised the issue of management competence and integrity.

Is this really the kind of "performance to date [which) indicates that utility management would operate the plant in a responsible manner should they be granted a license to do so"?

I hope the commission will investigate these matters thoroughly and provide me with a complete report on the outcome of ,

those investigations. And I continue to believe that only an '

independent, comprehensive, and thorough investigation will answer the question of whether or not the plant's construction has been compromised.

Sincerely, Edward J. Markey Member of Congress l \

03/06/88 J9:44 N.R.C. H ST NC.001 004

/

The Honorable Lando W. zech, Jr.

Page 3 March 3, 1988 cc The Honorable Morris K. Udall, Chairman Committee on Interior and Insular Affairs The Honorable Philip R. Sharp, Chairman subcommittee on Energy and Power i

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03/06/88 09:44 N.R.C. H ST ' NC.001 005 e ,, .

AFFIDAVXT I, JoRM F0WELL, being first duly sworn, depose and say the ic11owing:

1. My name is John Powell.

2. I served as Assistant Construction Director for the seabrook nuclear power plant from March 1984 to September 1986

3. If a substantial amount of a controlled substance er alcohol were found on the site, I ordinarily would have been centacted and would have been informed.

4. on rebruary 25, 1988 Iwastoldfortheikrettimethat approximately 100 grams of cocaine, with an estimated street value of $10,000, had been found inside the protected area at Seabrook ,

within a three-day period in June, 1936. I was never informed of these cocaine discoveries during the time I served at the site.

5. In December, 1985, Peter Mel:innon and I found marijuana at the on-site facilities of Pittsburgh Testing Labocatories, the i co;pany charged with inspection and quality assurance testing of i the concrete poured at seabrook. I ves aware that Peter McKinnon had previously found evidence of drug and alcohol use at their facilities, even though I had not personally been involved in

03/06/88 09:44 N.R.C. H ST NC.001 006 CO)' 36$ 9tn,C1 as 2-those discoveries.

6. As a consequence of the December 1985 nacijuana discovery, I recommended to the Director of Construction that ,

Pittsburgh Testing Laboratories be discharged, and within a few days the company was dismissed f rcm further work at, the site.  !

7. I had assumed that the Nuclear Regulatory Commission l

(NAC) would be informed of this action. However, I na not aware whether the NRC was ever informed of the fact that Pittsburgh

• Testing Laboratories had been dischirged from the site because of I

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the discovery of marijuana at their facilities.

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1988, JONN POW Lt,, who acknowledged the anove and foregoing facts ,

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{ .j NUCLEAR REGULATORY COMMISSION memworow, o. c.soses h i

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f i commu March 2, 1988 The Honorable Edward J. Markey .

United States House of Representatives Washington, D. C. 20515 ,

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Dear Congressman Markey:

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This responds to your letter of January 28, 1988, which enclosed your investigative report on drug and alcohol abuse at the Seabrook Nuclear Power Station. The NRC staff has carefully  ;

reviewed your report and advises us that no new issues have been )

raised to support the contention that the safe operation of the Seabrook plant is in question due to construction deficiencies l caused by drug or alcohol abuse. More detailed comments addressing Enclosure 1. the six recommendations in the report are set forth in -

t d Since the start of construction at Seabrook, the staff has conducted extensive routine and special inspections which have consistently shown that Seabrook Unit 1 is a well constructed plant, with good quality control and strong construction management.

The staff is satisfied that the Seabrook plant has been constructed and tested through the preoperational phase in a manner that would indicate that it can be safely operated, and performance to date indicates that utility management would operate license tothedoplant so. in a responsible manner should they be granted a Enclosure 2, the most recent NRC Systematic Assessment of Licensee Performance (SALP) Report issued February 2, 1988, provides a detailed summary of the NRC staff's views testingregarding activitiesthe at adequacy Seabrook.of construction and preoperational The Commission has concluded that in light of the extensive safety reviews of the Seabrook plant, an independent review by a blue ribbon commission is not warranted.

Concerning fitness for duty, the Commission has recently requested the staff to for publication develop publicrulemaking comment. options for our consideration and Although the proposed rule deals primarily with drug use at operating reactors, in conjunction with this rulemaking process we expect to consider the extent to which fitness for duty requirements can be made applicable to reactor construction activities. As described further in Enclosure 1.

this ' action is consistent with the Commission's original plan to l I

revisit this important issue following an evaluation of experience gained under fitness the Commission's August 1986 policy statement on for duty.

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The Commission fully agrees that the goal of achieving a workplace I free of the effects of drugs and alcohol requires dedicated efforts and cooperation by both management and employee '

representatives. However, the Commission believes that the fitness-for-duty programs in place today are at least as effective .

and comprehensive as those which would have been established I by now under the earlier proposed rule.

We hope that the efforts described above and in the enclosures will help resolve the concerns you raised.

1 Sincerely, 44 t/c b. A Lando W. Z , Jr l

Enclosures:

1. Response to Recommendations l

2. Systematic Assessment of Licensee Performance Report, dtd 2/9/88 l

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l l RESPONSE TO RECODMENDATIONS Reconnendation 1. An independent audit of both alcohol and drug use and safety-related issues at Seabrook should be conducted before the plant is licensed for operation.

Response 1. Tha NRC staff has been aware of drug and alcohol abuse concerns at the Seabrook site (see our response of January 20, 1987 toCongressmanMarkey). The NRC staff has reviewed these previous allegations as to their impact on alleged construction deficiencies as well as allegations included in the present Congressional Investigative Report.

Based on our review, we conclude that no new technical 1ssues concerning the construction of the Seabrook Plant have been identified. The adequacy of the plant physical construction has been verified through the NRC inspection program and previous special inspection efforts, as well as through the licensee's approved and detailed construction and testing program. These programs ensure the implementation of the "defense-in-depth" concept at Seabrook. This "defense-in-depth" philosophy is incorporated in the design and construction of nuclear power plants to assure that the final "as-built" configuration will aset the original design intent without reliance on any single element of the program. The follow-ing key elements demonstrate the "defense-in-depth" program at Seabrook:

A multi-layered construction quality program which included quality control inspection of in-process and completed construction activities, a quality assurance surveillance program, a quality assurance audit program, and extensive assessments of the Seabrook project by independent management concerns.

An intense routine and special NRC inspection program that evaluated by a sampling verification process all aspects of the Seabrook program from design to "as-built" construction.

A post-construction preoperational test program that consisted of physical testing of completed plant systems to ensure that they would perfom in accord-ance with design requirements.

An integrated startup test program that demonstrates that the plant will respond to a specified set of transients for which it has been designed.

ENCLOSURE 1

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Response t1 Recomendations

• Post-construction NRC routine and special inspections which have served to further verify that.the Seabrook facility is designed in accordance with design speci-fications.

A plant design that is such that =edundancy and diversity are designed and constructed into all safety systems so that safe opera'; ion of the plant does not rely on a single level of protection.

The NRC inspection effort at St.abrook has been and continues to be extensive, with more than 26,000 inspection hours expended to date. The program, which consists of routine resident inspections, construction team

'} inspections, and special tear. inspections, has examiined both programatic and functional aspects of the construction activities, as noted below:

Routine Inspections A Senior Construction Resident Inspector and Con-struction Resident Inspe; tor--by direct observation, t independent verification, daily presence, and both routine and reactive inspection--have provided an  !

additional independent measure of assurance that the quality of construction and testing has been achieved and maintained.

During the construction of Seabrook, Region I inspec-tors verified, both on tho site and at the engineering offices, quality performance in the areas of soils and foundations, containment and other safety-related structures, support activities and Systems, electrical power supply and distribution, instrumentation and control systems, quality assurance, management controls, design and design change control, and the effectiveness ,

of corrective actions.

Team Inspections

• l RegionIConstructionAssessmentteaminspection(June / '

July 1982) - This inspection evaluated the licensee's project management effectiveness b examinations of quality assurance,yconstructinn perfoming detailed control.,

project control, and decign control. Additionally, the Region I Mobile Nondestructive Examination (NDE) laboratory was used to' perform independent examination of welds.

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1 Response to Recosunendations

• Headquarters Integrated Design Inspection (November /

December 1983) - This inspection assessed the cuality of the design activities as well as the as-built configuration.

Headquarters Construction Appraisal Tote inspection (April /May 1984) - This inspection evaluated the adequacy of construction through a review of the con-struction program and selected portions of the Quality Assurance (QA) program, with emphasis on installed

_ hardware.

Region I Construction Team Inspection (June 1985) -

1 The purpose of this inepection was to assess the effectiveness of the resumption of construction activities (after the 1984 work suspension) under the new New Hampshire Yankee (NHY) site organization.

A multi-disciplinary review of selected portions of key safety-related systems was conducted.

Region ! Independent Measurements Inspection (July 1985) - The purpose of this inspection was to verify the adequacy of the licensee's welding and nondestruc-tive examination (NDE) quality control programs utilizing the NRC mobile NDE laboratory.

Region I As-Built Team Inspection (March 1986) - The

' purpose of this !.:spection was to determine if the systems, structures, and components selected for review were constructed in accordance with the descriptions provided in the Final Safety Analysis Report and the NRC's Safety Evaluation Report. The inspection also included a comparison of the physical installation with engineering design documents.

Region I Technical Specification Inspection (May 1986) - The purpose of this inspection was to detenmine whether the draft Technical Specifications and the Final Safety Analysis Report are compatible with the as-built plant configuration and operating characteristics.

Special Team Inspections The NRC Region I has responded to numerous allegations raised b others. y These the Employee's responseLegal effortsProject (ELP) and have resulted in two separate special team inspections and the expenditure of more than 1000 direct inspection hours. Following the completion of these reviews, the NRC concluded that no safety-related hardware problems were identi-fied.

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Response to Recoseendations ,

Conclusion On the basis of the inspection effort described above, the NRC concludes that no new issues have been raised to support the contention that the safety of the Seabrook plant is in question because of drug-related construction deficiencies and that no further special safety reviews are required or warranted.

Recospendation 2.

Possible violations of law should be investigated by appropriate authorities.

Response 2.

The principal thrust of this recommendation is an allega-tion of potential 111egal activities relating to j disposal of seized drugs and paraphernalia, a potential "cover-up" of certain drug-related episodes in particular in kreas housing executive offices, and potential false statements to a Congressional committee. The areas reqJested to be investigated are of a serious nature and must be addressed by other State or Federal agencies, such as the State Police, the FBI, and others, as appropriate.

Recoemendation 3. Seabrook management and unions should work together with experts from successful drug and alcohol awareness programs to develop and implement a comprehensive program for dealing with problems related to drug and alcohol use in the workplace, with a goal of no drugs or alcohol at the site. ,

Response 3.

The Connission fully agrees that the goal of achieving a j workplace that is free of the effects of drugs and alcohol i requires dedicated efforts and cooperation by both manage-ment and empicyee representatives. The need for coordina-tion with unions is one of the basic elements of the Fitness for Duty Program contained in the Edison Electric Institute (EEI) Guide to Effective Drug and Alcohol / Fitness for Duty Policy Development, which was endorsed by the Commission policy statement. A copy of the appropriate section from the EE! guide concerning union relationships is attached. It includes provisions for the use of outside experts in working with employee representatives.

Recoseendation 4. The NRC should adopt Fitness for Duty regulations and strengthen them to include individuals involved in construction as well as operation.

Response to Recommendations Response 4.

Concerning NRC's policy on fitness for duty regulations, I the investigative report asserts that the Connission has abdicated its regulatory responsibilities and has capitu-lated to industry pressure to refrain from rulemaking. .

However, the Congressional report is silent concerning the Comission's responses in this area.

In our letters to I

Congressman Markey, dated December 9,1986 and January 20, 1987 (as well as in an August 14, 1987 1etter to Congressman Ge.idenson, included as a reference in the investigative report), the Commission explained the rationale fitness for supporting duty. our decisions and policy regarding 1 i

In conjunction with the issuance of the policy statement on fitness for duty in August 1986, the Comnission indicated that we would (1) evaluate the performance of industry in meeting its commitment to establish and implement fitness 3 for duty programs and (2), following this evaluation, i reconsider the matter to detennine the most responsible long-ters course of action. We are keeping to that plan.  !

i In December 1987 i Utility Managemen,t and Resources Council (NUMARC the indu::try the NRC staff on theirThe initiative. evaluations staff reported tha cf the effectiveness of continued improvements are needed in some areas,t, thewhile  !

industry has generally met its comitment and significant progress has been made over the past several years in  !

establishing an environment in which nuclear power plant operations are free of the effects of drugs and alcohol.

Our tivesdiscussions did however, with the staff and with industry representa-result in identification of the need to make a reg,ulatory decision, at the Federal government lev on the need for random, unannounced drug testing of nuclear power plant personnel. Accordingly, the staff has been instructed to develop for the Connission's consideration proposed rulemaking that includes various options for random testing. We expect to cceplete this process and issue a proposed regulation for public ccament within the next several months.

The Comission wishes to emphasize that the decision to develop Federal regulations does not reflect dissatis-

. faction with the responsiveness of the nuclear industry to this important issue. For example, the industry comitted to implement comprehensive fitness for duty programs, which include provisions for drug testing. That cosnitment has been met.

In fact 22 of the 54 nuclear utilities have that goes beyond the ceneral industry comitment. im Other utilities have attempted to establish random testing, but

' Response to Recountendstions have been thwarted by various legal challenges. Subject to final approval by the Comission, rulemaking that includes provisions for random testing will provide even greater assurance of the fitness of nuclear power plant personnel and will provide all nuclear utilities with the basis for j instituting additional testing. '

Although the Comission's policy statent on fitness for duty is oriented toward personnel in. wived in operating nuclear power plants, the basic elements of fitness for duty programs, as described in the industry standard i developed by the Edison Electric Institute, have been l established at reactor construction sites as well. The Coenission will consider the need for regulations applicable to construction activities during the forthcoming rulemaking process.

i In sumary, notwithstanding the investigative report, the Commission matter have baencontinues responsible to believe ones. that its decisions on this

! We believe that fitness  !

for duty programs in place today are at least as effective and comprehensive as those that would have been established l

' by now under the earlier, proposed rule. Significant j

improvements have been made and the experience gained t provides improvements.

the basis for responsibly building further i Recomendation 5.

The NRC should audit other utilities to detemine whether the kinds of alcohol and drug related teminations which occurred at Seabrook also occurred at other plant sites.

Response 5.

The historical audits recomended in the investigative report would not provide data which would significantly contribute to the NRC mission. In conjunction with the evaluation of industry responsiveness to the Comnission's policy statement on fitness for duty, the Headquarters staff ing conducted nine special inspections eight at operat-ing. plants and one at a plant nearing rea,diness for licens-Several of these inspections included reviews at the corporate offices of utilities that are responsible for both operating plants and construction sites. Our objec-4 tive during these inspections was not to gather statistics on past alcohol and drug-related teminations. During these inspections, as well as during our Regional office

- follow-up to reports of alcohol or drug abuse, our focus has been more on ensuring that programs are in place to deter and detect abuse, that the utility has taken proept action to remove involved individuals from nuclear duties, and that steps have been taken to review the quality of any safety-sensitive work that may have been accomplished by the individual without supervision or inspection.

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e Response to Recomunendations NRC regulations that took effect in October 198.7 require that licensees report cases of drug involvement 'by persons with unescorted access to operating nuclear power plants, )

i Recossendation 6. Appropriate rate setting authorities should undertake  ;

prudence reviews, l

Response 6. The Consissiori has no authority to set rates and therefore has no cooment on this reconvendation.

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6. Union Brie 8ng safety hazards of drugs and alcohol and the Most utilities have collective bargaining effects that offeth+)ob use can have on on-agreements with unions goveming wages, mejob performance. The briefing should hours and working conditions. The company, stress that the company intends to administer however, has the right to establish policles this policy in a uniform manner, and that all and rules for the safe and effective operation supefvisors will be given thosough training on of its plants and equipment. Company rules fitness for duty standards and their responsl.

and regulations that promote safety and effi. bility to be fair in the administration of the ciency and that are administered fairly and program. The company should stress that the without discrimination should be welcomed policy will be applied to management as well by unions and management slike, as bargaining unit personnel, and that it has When implementing a new or revised com. been reviewnd from a legal, labor relations, pany drug and alcohol / fitness for duty policy, security, operational and safety standpoint.

l briefing of union leadership (where a collec. The senior company official present or an j tive bargaining relationship exists)is recom- outside resource may wish to cite relevant, mended Such a briefing should involve the current national statistics, which, for ex.

senior company labor relations official gen- ample, might point out that; one out of 3 indi-erally in contact with union leadersNp and, to v6 duals 18 to 25 years of age uses are lilicit be most effective, should take place prior to drug at least once a month; industry alone has o communication of the company's drug and a prod;ctivity Ices in excess of $50 billion alcohol / fitness for duty policy to employees from drug and alcohol abuse; and in 18 U.S. I and supervisors, railroad incidents in which alcohol and drug

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The union briefing should focus on estab. use was involved,25 rallroad employees were lishing a spirit of cooperation and enlisting killed, over $25 million of property damage oc.

the interest and support of union leadership curred, dozens of employees - Injured, for an effective health and safety program that and an entire town of 3,000 pec to be affects their membership. During the briefing, evacuated because railroad em, were the company should stress its concern for all intoxicated. Statistical data will also show .

employees and their mutual interest in pro. that throughout plants in the United States  :

txting the safety and jobs of the non4 rug millions of dollars in equipment has been and non-alcohol abusers-the vast majority of destroyed and billions of dollars of costs employees-whose positions and personal incurred due to alcohol and drug abuse by

. well being could be jeopardized by the actions employees.

of alcohol. and drug-Impaired individuals it The benefits of the employee assistance should also be emphastzed that drug and program and the company's willingness to l alcohol impairment may cause accidents, help its employees overcome substance l reduce productivity, damage or destroy plant abuse and other problems affecting job per. l and equipment, increase costs, and reduce formance should be emphasized to the union the level of confidence in the company on the representatives. Howerar, it should also be part of the pubi;c, regulators, media, and pointed out that access to the EAP is not consumers, necessarily a substitute for disciplinary i

measures.

The briefing team might levde an outside rnedical or other health professional to pro-vide a perspective to the union on current steps other companies are taking with respect ,

i to drug and alcohol abuse and fitness for duty, j and providing an insight into the health and 1

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FEB 021988 Docket No. 50-443 Public Service Company of New Hampshire ATTN: Mr. Robert J. Harrison President and Chief Executive Officer Post Office Box 330 Manchester, New Hampshire 03105 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP) Report Numb,r 50-443/86-99 i

This refers to the SALP for the Seabrook Station, conducted by this office on

' September on December17 9, and 1987. October 2,1987, and discussed with your staff at a meeting The list of meeting participants is attached as Enclosure 1. The NRC Region I SALP Report, c.overing the period April 1,1986 through July 31, 1987, is provided as Enclosure 2.

This report was not amended 3

as a result of our meeting with your staff and remains, in its entirety, the same report transmitted for your review with our letter of October 26, 1987 (Enclosure 3). Your response, dated January 6, 1988 is provided as Enclosure 4.

While that response offered additional information on your corrective measures *

- in progress in certain functional areas, we note that it provided no indication

of any disagreement with the original SALP report findings or your discovery of any factual errors.

Therefore, no amendments / errata to the October 26, 1987 SALP report have been deemed necessary.

Our overall assessment of activities at Seabrook Unit 1 during the assessment j

period is that your pirrformance reflected a continued commitment to quality as construction was completed and the transition into operations progressed. While strong management involvement in the evaluated areas was noted, challenges of a more significant nature in several of these functional areas would await Seabrook Station and its personnel if power operations are subsequently authorized. Your response to the enclosed SALP report appears to recognize this where necessary.

fact, as well as a willingness to implement new programmatic initiatives

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No reply to this letter is required. We believe that our meeting with you and the resulting interchange of information were beneficial and improved the mutual understanding of your activities and our regulatory program.

i R 4 43

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t OFFICIAL RECORD COPY SALP LTR SEABROOK 86 0001.0.0 d

01/26/88 ,

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.FEB 021988 New Hampshire i

Your cooperation is appreciated.

Sincerely, OREN.i.L SiGED Bh Ml:8 M. ALLVI

. William T. Russell .

Regional Administrator ]

. I

Enclosures:

1. December 9, 1987 SALP Management Meeting Attendees 4

2. USNRC Region I SALP Report 50-443/86-99 )

3. USNRC Aegion I Letter, W. T. Russell to R. J. Harrison, October 26, 1987 j

4. PSNH Letter, NYN-88002 (Response to SALP Report), January 6,1988 ,

(

cc w/encls:

E. A. Brown, President, New Hampshire Yarkee (NHY)

G. S. Thomas, Vice President - Nuclear Production, NHY <

T. C. Feigenbaum, Vice President of Engineering and Quality Programs, NHY  !

W. J. Hall, Regulatory Services Manager, NHY l D. E. Moody, Station Manager, NHY l P. W. Agnes, Assistant Secretary of Public Safety, Comonwealth of  !

i Massachusetts

• Employee's Legal Project l Public Document Room (PDR) l Local Public Document Room (LPOR) ,

Nuclear Safety Information Center (NSIC) l NRC Resident Inspector State of New Hampshire Commonwealth of Massachusetts (2)

Seabrook Hearing Service List Chairman Zech Commissioner Roberts Commissioner Bernthal Commissioner Carr Commissioner Rogers INPO (Record Center, INPO) j l

4 0FFICIAL RECORD COPY SALP LTR SEABROOK 86 0002.0.0 01/26/88

' . ' . ' fublic Service Company of

• 3 New Hampshire ((Q Q 2 $88 -

bec w/encls:

J. Taylor, DEDO T. Murley, D/NRR ,

8. Boger, AD/RI, NRR V. Nerses, PM, NRR E. Trottier, NRR '

W. Russell, RA J. Allan, DRA W. Kane, DRP J. Wiggins, DRo D. Haverkamp, DRP A. Corne, SRI - Seabrook D. Ruscitto, RI - Seabrook W. Johnston, DRS T. Martin, DRSS R. Bores, DRSS Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encis)

D. Holody, EC DRPWISHLISTCoordinators(2)

K. Abraham, PA0 (20) e RI:DRP RI:DRP RI:DRP I RI:l g mjd mp iggins RP lins (p 1/S7/88 1/M /88 1/Il88 1M/88 1/d/88 W "

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)/f/88 h $88 0FFICIAL RECORD CDPY SALP LTR SEABROOK 86 0003.0.0 01/27/88

. . 1 Seabrook 1 Service Hearino List I j

Thomas Dignan, Esq E. Tupper Kinger, Esq. l John A. Ritscher,' Esq. Assistant Attorney General  :

Ropes and Gray Office of Attorney General -

225 Franklin Street 208 State House Annex Boston, Massachusetts 02110 Concord, New Hampshire 03301 Mr. Bruce Beckley, Project Manager Resident Inspector New Hampshire Yankee Seabrook Nuclear Power Station l P.O. Box 330 c/o U.S. Nuclear Regulatory Com:n.

Manchester, New Hampshire 03105 P. O. Box 1149 Seabrook, New Hampshire 03874 Dr. Murray Tye, President Mr. John C. DeVincentis, Director Sunn Valley Association Engineering and Licensing 209 Summer Street Yankee Atomic Electric Company l Haverhill, Massachusetts 08139 1671 Worcester Road Framingham, Massachusetts 01701  !

Robert A. Backus, Esq. George D. Bisbee, Esq.

O'Neill, Backus, and Spielman Assistant Attorney General 116 Lowell Street Office of the Attorney General ,

Manchester, New Hampshire 03105 25 Capitol Street Concord, New Hampshire 03301 Mr. Phillip Ahrens, Esq. William S. Jordan, III Assistant Attorney General  !

Diane Curran Office of the Attorney General Harmon, Weiss, and Jordan I State House Station # 6 20001 S. Street, N.W.

Augusta, Maine 04333 Suite 430 Washington, D.C. 20009 Jo Ann Shotwell, Esq. D. Pierre G. Cameron, Jr., Esq  !

Office of the Assistant Attorney General Counsel General Public Service Company of Environmental Protection Division New Hampshire One Asburton Place P. O. Box 330 Manchester, New Hampshire 03105 Boston, Massachusetts 02108 Ms. Diana P. Randall Regional Administrator, Region I 70 Collins Street U.S. Nuclear Regulatory Commission Seabrook, New Hampshire 03874 631 Park Avenue King of Prussia, Pennsylvania 19406 Richard Hampe, Esq. Mr. Alfred V. Sargent New Hampshire Civil Defense Agency Chairman 107 Pleasant Street Board of Selectmen Concord, New Hampshire 03874 Town of Salisbury, MA 01950 I

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1 Mr. Calvin A. Canney, City Manager Senator Gordon J. Humphrey j City Hall ATTN: Tom Burack l 126 Daniel Street U.S. Senate .

Portsmouth, New Hampshire 03810 Washington, D.C. 20510 '

Ms. Letty Hett Mr. Owen B. Durgin, Chairman I Town of Brentwood Durham Board of Selectmen RF0 Dalton Road Town of Durham Exeter, New Hampshire 03833 Ourham, New Hampshire 03824 Ms. Roberta C. Pevear Charles Cross, Esq.

Town of Hampton Falls Shatnes, Hardrigan, and McEaschern Drinkwater Road 25 Maplewood Avenue Hampton Falls, New Hampshire 03844 P. O. Box 366 Portsmouth, New Hampshire 03801 Ms. Anne Verga Mr. Guy Chichester, Chairman Chairman, Board of Selectmen Rye Nuclear Intervention Committee Town itall c/o Rye Town Hall '

South Hampton, New Hampshire 03827 10 Central Road l Rye, New Hampshire 03870 Mr. Angie Machiros, Chairsan Jane Spector Board of Selectmen Federal Energy Regulatory Comm. ,

for the Town of Newbury 825 North Capitol Street, N.E. i

. 25 High Road Roce 8105 Newbury, Massachusetts 01950 Washir gton, D.C. 20426 Ms. Rosemary Cashman, Chairman Mr. R. Sweeney Board of Selectmen New Hampshire Yankee Division Town of Amesbury Public Service Company of Town Hall New Hampshire Amesbury, Massachusetts 01913 7910 Woodmont Avenue ,

Bethesda, Maryland 20814 Honorable Peter J. Matthews Mr. Donald E. Chick, Town Manager Mayor, City of Newburyport Town of Exeter Office of the Mayor 10 Front Street City Hall Exeter, New Hampshire 03823 Newburyport, Massa:husetts 01950 Mr. Warren J. Hall Mr. William B. Derrickson '

Public Service Company of Senior Vice President New Hampshire Public Service Company of P. O. Box 300 New Hampshire Seabrook, New Hampshire 03874 P.O. Box 700, Route 1 Seabrook, New Hampshire 03874 l

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Administrative Judge Administrative Judge '

Alan S. Rosenthal, Chairman Bary J. Edles -

l Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal j Board Board i U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission l Washington, D.C. 20555 Washington, D.C. 20555  !

h 1 Administrative Judge Administrative Judge Howard A. Wilber Helen F. Hoyt, Chairman l Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 ,

Administrative Judge Administrative Judge  !

Emmeth A. Lusbke Jerry Harbour Atomic Safety and Licensing Board Atomic Safety and Licensing Board  :

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. j 20555 Washington, D.C. 20555  ;

1 Edwin J. Reis. Esq. H. Joseph Flynn, Esq.  !

Office of the Executive Legal Assistant General Counsel '

Director Federal Emergency Management Agency U.S. Nuclear Regulatory Commission 500 C. Street, S.W.

, Washington, D.C. 20555 Washington, D.C. 20472 Edward A. Thomas Carol S. Sneider, Esq.

Federal Emergency Management Agency Assistant Attorney General 442 J. W. McCormack (POCH) Office of the Attorney General Boston, Massachusetts 02109 One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Paul McEachern Esq. Richard A. Haaps, Esq Shatnes and McEachern Haaps and McNicholas 25 Maplewook Avenue 35 Pleasant Street Portsmouth, New Hampshire 03801 Concord, New Hampshire 03301 J. P. Nadeau Allen Lampert Board of Selectmen Civil Defense Director 10 Central Street Town of Brentwood Rye, New Hampshire 03870 20 Franklin Street Exeter, New Hampshire 03833 William Armstrong Sandra Gavutis, Chairman

! Civil Defense Director Board of Selectmen

, Town'of Exeter RF0 #1, Box 1154 10 Front Street Kensington, New Hampshire 03827 Exeter, New Hampshire 03833 I

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. 4 Anne Goodman, Chairman William S. Lord Board of Selectmen Board of Selectmen 13-15 Newmarket Road Town Hall - Friend Street Durham, New Hampshire 03824 Amesbury, Massachusetts 01913 Michael Santosuosso, Chairman Jerard A. Croteau, Constable Board of Selectmen 82 Beach Road South Hampton, New Hampshire 03827 P. O. Box 5501 Salisbury, Massachusetts 01950 Stanley W. Knowles, Chairman Judith H. Mitzner Board of Selectmen Silverglate, Bernter, Baker, Fine, P. O. Box 710 Good, and Mitzner North Hampton, New Hampshire 03862 88 Broad Street Boston, Massachusetts 02110 Norman C. Katner Bary W. Holmes, Esq.

Superintendent of Schools Holmes and Ells School Administrative Unit No. 21 47 Winnacunnet Road Aluani Drive

• Hampton, New Hampshire Hampton, New Hampshire 03842 03842 Jane Doughty Seacoast Anti-Pollution League 5 Market Street

• portsmouth, New Hampshire 03801 T

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ENCLOSURE 1 December 9.1987 SALP Management Meeting Attendees .

1. Licensee E. A. Brown, President, New Hampshire Yankee (NHY)

W. B. Derrickson, Senior Vice President, NHY G. S. Thomas, Vice President - Nuclear Production, NHY T. C. Feigenbaum, Vice President of Engineering and Quality Programs, NHY D. E. Moody, Station Manager, NHY

2. USNRC \

W. F. Kane, Director, Division of Reactor Projects (DRP), Region I B. A. Boger, Assistant Director for RI, Division of Reactor Projects I/II, Office of Nuclear Reactor Regulation (NRR)

J. T. Wiggins, Chief, Reactor Projects Branch .o. 3 , DRP D. R. Haverkamp, Chief, Reactor Projects Section No. SC, DRP V.'Nerses, Licensing Project Manager, Project Directorate I-3, NRR t A. C. Corne, Senior Resident Inspector - Seabrook D. G. Ruscitto, Resident Inspector - Seabrook E. H. Trottier, Licensing Engineer, NRR

3. Other members of the public, press and licensee staff attended, but did not participate in the meeting.

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COPNISSION REGION I SYSTEMATIC ASSESSMENT.0F LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 86-99 PUBLfC SERVICE COMPANY OF NEW HAMPSHIRE SEABROOK STATION, UNIT 1 ASSESSMENT PERIOD: APRIL 1, 1985 - JULI 31, 1987 BOARD MEETING DA72: SEPTEMBER 17 AND OCTOBER 2, 1987 I

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0 TABLE OF CONTENTS EdGS I.

I NT.". DDU C T I ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1,. . . . . . . . . . .

II.

CRITERIA................................................... 2 III.

SUMMARY

OF RESULTS......................................... 3 A. Overall Facility Evaluation

8. Background................. ..........................

3 C. 4 Facility Pe rformance Analysis Summa ry. . . . . . . . ......... ........

7 IV. PERFORMANCE ANALYSIS....................................... 8 A. Construction Completion.......

' 8. Startup Testing............... ....................... 8 C. Plant Operations......................................

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D. Radiological Controls............ .................... .

13 E.

F.

Emergency Preparedness............. .................. 19 Security and Safeguards.............. ................

• 23 G. Engineering Support................ ................ 25 H.

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Licensing Activities............... .................. .................. 28 Training and Qualification Effectiveness 31 J. A s s u ra n c e o f Qua 11 ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

............. 36 V. SUPPORTING DATA AND SUMMARIES.............................. 40 A. Investigation and Allegation 8.

Escalated Enforcement Action.

Review................... 40 C. Management Conferences....... ........................

40 D. 40 Review of Licensee Event Reports (LERs E. Summa ry of Lice:# sing Activ i ti e s . . . . . . . .) . . . . . . . . . . . ...40 .

............... 41 TABLES Table 1 - Inspection Report Activities...

Tabl e 2 - In s pec t ion Ho u r S umma ry. . . . . . . . .......... ......................

Table 3 - Enforcement Activity..................... ........ ....

Table 4 - Licensee Event Reports.................... ............

i I. INTRODUCTION ,

The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect information periodically and evaluate licensee performance. The SALP program supplements the normal regulatory processes that ensure compliance with NRC regulations. It is intended to be sufficiently diagnostic to. provide a rational basis for allocating NRC resources and meaningful guidance to licensee management to promote the quality and safety of plant operation.

An NRC SALP Board met on September 17 and October 2,1987 to assess licensee performance in accordance with NRC Manual Chapter 0516, "Systematic Assesssent of Licensee Performance". A summary of the SALP guidance and evaluation criteria is provided in Section II of this report.

This report assesses performance at Seabrook Station, Unit 1, during th's 16-month period from April 1,1986 through July 31, 1987.

The SALP Board was composed of the following:

Chairman:

W. F. Kane, Director, Division of Reactor Projects (DRP) 1 Members:

)

T. T. Martin, Director, Division of Radiation Safety and Safeguards, I J

(DRSS)(Part-Time)

J. P. Durr, Acting Deputy Director, Division of Reactor Safety (DRS)

J. T. Wiggins, Chief, Projects Branch No. 3, DRP T. C. Elsasser, Chief, Reactor Projects Section 3C, DRP R. J. Bores, Technical Assistant, DRSS B. A. Boger, Assistant Director for Region I, Division of Reactor Projects I/II, Office of Nuclear Reactor Regulation (NRR) (Part-Time)

V. Nerses. Acting Director, Project Directorate I-3, NRR A. C. Corne, Senior Resident Inspector, Seabrook Other Attendees: (P.on-Voting)

R. J. Bailey, Physical Security Inspector (DRSS) (Part-Time) i D. R. Haverkamp, Project Engineer, DRP (Part-Time)

W. J. Pasciak, Chief. Effluents Radiation Protection Section, DRSS (Part-Time)

) D. G. Ruscitto, Resident Inspector Seabrook l J. A. Schumacher, Senior Emergency, Preparedness Specialist, DR$$

(Part-Time)

M. M. Shanbaky, Chief, Facilities Radiation Protection Section, DRSS (Part-Time) l R. M. Gallo, Chief, Operations Branch, DRS (Part-Time) j i W. J. Lazarus, Chief. Emergency Preparedness Section, DRSS (Part-Time)  ;

C. A. C6rpenter, Roactor Engineer, DRP (Part-Time) 4 j

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II. CRITERIA .

i Licensee performance is assessed in selected functional areas. These  !

areas are significant to nuclear safety and the 2nvironment, and are l normal programmatic areas. The following criteria were used as appropri- i ate to assess each area. i i

1. Management involvement and control in assuring quality.

2. Approach to resolution of technical issues from a safety standpoint.

3. Responsiveness to NRC initiatives.

4. Enforcement history.

5. Reporting and analysis of. reportable events.

6. Staffing (including management).

I 7. Training and qualification effectiveness.

Based upon the SALP Board assessment, nach function'al area evaluated is

/ classified into one of three performance categories. These are:

Category 1. Licensee manag'ement attention and involvement are aggressive l and oriented toward nuclear safety; licensee resources are ample and i effectively used so that a high level of performance with respect to operational stfety and construction quality is being achieved. Reduced NRC attention may be appropriate.

Category 2. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to

, operational safety and construction quality is being achieved. NRC atten- i tion should be maintained at normal levels. )

(

Category 3 Licensee management attention or involvement is acceptable l and considers nuclear safety, but weaknesses are evident; Itcensee resources appear to be strained or not effectively used so that minimally  ;

satisf actory performance with respect to operational safety and construc- l

tion quality is being achieved. Both NRC and licensee attention should be increased.

4 The SALP Board may determine to include an appraisal of the performance trend of a functional area. No-mally, this 9erformance trend is only used )

where both a definite trend of performance is discernable to the Board and i i the Board believes that continuation of the trend may result in a change i of performance level. Improving (declining) trend is defined as: Licensee performance was determined to be improving (declining) near the close of l

) .the assessment period.  !

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3 III.

SUMMARY

OF RESULTS A. Overall Summary During this assessment period, a major transition occurred as con-struction and preoperational testing were completed, and startup testing and operations under the technical specifications (TS) and Itcense conditions consenced. Throughout this transitional period, the Itcensee's commitment to quality, along with its safety-conscious attitude and management support of quality assurance (QA) initia-tives, has been maintained. It is noted that some of the functional areas are being evaluated for the first time. In certain of these areas, the station and its personnel may not have been significantly challenged due to plant conditions and license limitations. In all cases, assessments are made based upon program adequacy and observed performance. However in those areas where activities were limited, such performance may ,not be truly indicative of station response to future, more challenging events and situations. During this assess-me'nt period, the Itcensee demonstrated the ability to conduct limited operations along with a stata of readiness for future, more expansive operational activities. ,

Some transitional problems have been experienced during this assess-ment period. Both the programmatic and organizational interfaces between the Seabrook Station staff and the New Hampshire Yankee engineering and quality assurance groups required clarification. The operations QA program, while implemented properly from a compliance standpoint, did not evidence total effectiveness with respect to causal analysis of identified operational problems or the evaluation of related generic weaknesses. Also, plant operations and startup testing activities were somewhat negatively impacted by divergent requirements to conduct system testing and to troubleshoot problems, while at the time adhering to the T5 and special conditions pre-scribed by the zero-power license. Likewise, new reporting require-ments (e.g., licensee event reports) were exercised based primarily on legal interpretations, rather than normal operating conditions.

The shutdown plant conditions and lack of radiological activity did not provide the realistic bases for such notifications. As an example, during the one emergency event classified during this SALP period, there were interpretation problems as to whether the plant's nonradiological status warranted declaration of an unusual Event with its attendant notifications.

Notwithstanding these difficulties, the licensee's establishment of a new program of controls, which is operationally based, has been effective. Construction completion has resulted in quality hardware, which is being maintained at the same level. Similarly, 'tne licensee's approach to component problems and testing anomalies reflects the same comprehensive attitude toward corrective action that was evident during construction. Management attention to plant readiness and independent, internal review of plant performance remains high.

4 While the overall transition from construction to operations has pro-ceeded in a relatively smooth manner, the latter part of this current I assessment period provided some evidence of the future' problems which might be encountered. The PCCW heat exchanger problems, discussed in Section IV.G of this report, represent an example of the component degradation which may reruit, in part, from lack of system operation.

This type of concern could become even more troublesome if Mode 5 operations continue for a long period of time. Licensee preplanning in the areas of water chemistry control, surveillance and maintenance activities, which have been evaluated as subcategories of the appro- l priate functional areas in this SALP, will become even more important for equipment preservation during prolonged periods of shutdown conditions. In the past, licensee responsiveness to problematic issues and HRC initiatives has been appropriately directed. In the future, even more aggressive and innovative corporate management I involveinent may be necessary to sustain the same high level of performance.

B. Background Licensee Activities .

Over the course of this SALP period, major changes in both the scope and organization of plant activities occurred as construction was completed and operations commenced. On April 1, 1986 a construction work force of approximately 3500 personnel was still on site as pre-operational testing, building turnover and final support system in-sta11ation activities were ongoing. In the ensuing months, construc-tion was effectively completed and the licensee filed a motion pur-suant to 10 CFR 50.57(c) before the ASLB on August 22, 1986, seeking authorization to load fuel and conduct precriticality testing.

1 On October 17, 1986, a Facility Operating License was issued for l Seabrook Station Unit 1. Specific license conditions limited activ- 1

' ities to "Zero power" operation and precriticality testing, but did allow the licensee to load fuel and conduct hot operations in Mode 3 in accordance with the Technical Specifications. Initial fuel load l was conducted during the period October 22 to 29, 1986. l mnt heat-up for the conduct of the precritical phase ~of het func- i tional testing (HFT) commenced on February 9,1987. Over the follow- l ing six weeks, startup testing activities were in progress with the  !

plant achieving normal operating temperature and pressure conditions anc with the conduct of operations in accordance with Technical Specifications ,and special license conditions. Most noticeable among I J

i

5 the routine operational activities and events which occurred during this period were the declaration of an Unusual Event on February 11, 1987 based upon commencement of a plant cool-down from Mode 4 to com-ply with a Technical Specification related to containment air lock operability; and a st m generator safety valve actuation on February 26, 1987, as a result of emergency feedwater (EN) system testing. The conduct of specific tests on the steam-driven EN pump itself was one of the more significant areas of testing during HFT, because major design modifications had been implemented for this system since the previous HFT in December, 1985. Plant cool-down from hot operations was initiated on March 19, 1987 and the plant has remained in Mode 5 through the remainder of this SALP period.

Since the completion of HFT activities, the licensee has initiated some extensive maintenance activities. These include the inspection, baffle repair, and tube plugging and sleeving operations on a primary 4

component cooling configuration redesiwaterand heat exchanger; and the inspection, lining service water valves.gn, itning repair and testing on several As of the end of this assessment period, these repair activities were continuing with additjonal heat exchangers yet to be inspected and additional valves yet to be relined.

I Completion of this maintenance, along with the associated, routine operational surveillance activities, are scheduled for a November, 1987 time frame to support heat-up, initial criticality and further testing, if a low power license is issued to Seabrook, Unit 1. In anticipation of license issuance and in response to the Commission's Memorandum and Order (CLI-87-03 the licensee has committed resources to several emergency prepa)r,edness(EP) activities.

In addt-tion to workin response plan, g with New Hampshire to improve the state emergency which is the subject of ASLB hearings scheduled to commence in October, 1987, the licensee is formulating a utility plan with the stated capability to compensate for Massachusetts emergency s

response functions. Submission of this plan to the NRC in September  ;

has received priority attention along with the conduct of other i licensee EP activities required to meet the criteria provided by CLI-87-03 for issuance of a low power operating license. 3 l

Inspection Activities l Two NRC resident inspectors were rasigned to the site during the assessment period. The NRC irspections are summarized in Table 1 and represent an inspection effort of 6972 hours0.0807 days <br />1.937 hours <br />0.0115 weeks <br />0.00265 months <br /> (5226 hours0.0605 days <br />1.452 hours <br />0.00864 weeks <br />0.00199 months <br /> calculated on an annual basis) with the total inspection hours distributed in the various functional areas, as shown in Table 2.

Special inspections were conducted of the compatability between the plant and the facility Technical Specifications (May,1986); in re-i sponse to the Unusual Event (February,1987); and in three follow-up j inspections of allegations raised regarding construction quality and the as-built conditions of the plant (October,1986; November,1986; i

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and April-May, 1987). An Emergency Plan Implementation Appraisal follow up inspection was also conducted in June, 1986. Seven en-forcement actions, including a Severity Level IV violition resulting from follow-up inspection of the Unusual Event, were issued. The violations issued during this SALP period are tabulated in Table 3.

It is noted that construction was completed during this SALP, period and NRC inspections of the various technical disciplines were con-

, ducted, as necessary, to examine final construction activities. Al-legations regarding construction quality were also received during this assessment period after construction of the plant was essen-tially complete. In order to objectively address these allegations, over 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> of additional inspection were expended to investigate the stated concerns.Section V.A of this report generally discusses the Investigation and Allegation Review conducted during this SALP.

The expenditure of this large inspection effort into the several con-struction disciplines and sreas of as-built quality has resulted in a reaffirmation of the NRC position that Seabrook Unit I was construc-ted in accordance with its design bases and regulatory requirements.

. This report also discuss'ds "Training and Qualification Effectiveness" and "Assurance of Quality" as separate functional areas. Although these topics, in themselves, are assessed in the other functional areas through their use as criteri:, the two areas prcvide a synop-sis. For example, quality assurance effectiveness has been assessed on a day-to-day basis by resident inspec. tors and as an integral as-pect of specialist inspections. Although quality work is the respon-sibility of every employee, one of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. Other major factors that influence quality, such as involve-

ment of first-line supervision, safety committees, and work atti-tudes, are discussed in each area.

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C. Facility performance Analysis Summary I 1986 1987 FUNCTIONAL AREA CATEGORY CATEGORY TREND

1. Construction Completion 1 1 I

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2. Startup Testing 1 1

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3. Plant Operations la 2 l i

4. Radiological Controls

• 1

5. Emergency Preparedness 2 1 l 1

6. Security and Safeguards

• 1 j

7. Engineering Support

• 2

8. Liceasing Activities 1 1

9. Training and Qualification

• 1 Effectiveness

10. Assurance of Quality 1 2

• During the previous SALP period, "plant operations" was evaluated in terms of "operational readiness", which included "radiological controls",

"security and safeguards", and "training / qualification" assessments in one general functional area. i

• • During the previous SALP period, Engineering Support was not evaluatec as a separate Functional Area. <

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IV. PERFORMANCE ANALYSIS

. A. Construction Completion (1349 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.132945e-4 months <br />, 19.4%)

4

1. Analysis During the previous SALP assessment period, all of the construc- l tioa disciplines' were combined under one functional area. I significant NRC inspection effort, including two team inspec-tions and an additional NDE Van inspection, revealed adequate control over construction processes by if censee management and few hardware deficiencies. As constru: tion was nearing com-plation, as-built inspections by both the resident inspectors 2

and regional specialists confirmed a high degree of plant conformance to the design bases and technical details provided by the FSAR. A Category 1 rating was determined, based upon an effective construction management program with resultant evidence of quality hardware, material, components and systems.

M During this current SALP period, an &ssessment of construction i

, completion was conducted to not only evaluate the plant's as- l

- built quality, but also to provide an independent review of the results of inspection effort into allegations involving the pitnt hardware. Several NRC inspections were conducted to re-  !

view licensee corrective action on previous construction find-  !

ings (e.g., open items and construction deficiency reports) and  !

l to investigate the validity of several allegations raised re- l

garding construction quality. The results of these inspections essentially confirmed previous assessments that Seabrook Unit I was constructed in accordance with regulatory requirements and licensing commitments.

As construction was being completed, an NRC inspection review of all unresolved items and licensee corrective action on pre-vious inspection findings was conducted to determine the readt-ness of Seabrook Unit 1 for issuance of an operating license.

' This review revaaled both an aggressive construction management approach to the implementation of corrective seasures, where neces sary, and a responsiveness to NRC initiatives. Routine

' inspection results also provided evidence that the licensee's i

internal as-built verification programs (e.g., the pipe support closecut task team, PAP 5COTT; and the c6ble tray and support qualification activities) had been implementec in.a technically competent manner. Effective licensee controls of both construc-tion completion and the process of reconciling the as-built plant with the design details were roted. A strong QA involve-ment in the conclusion of construction activities and in the assurance of quality records storage and retrievabiltty con-tinued from tne previous assessment period into this SALP.

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An independent verification of plant quality also arose from NRC  !

followup of a number of allegations ragarding the, construction  ;

processes. Because of the nature of several of the' stated con- l cerns and the fact that they were raised after construction was ,

essentially complete, the quality of hardware and ability of the l as-constructed system to function as designed became the focus I of a saltidisciplinary NRC inspection effort. The effectiveness 1 of licensee programs, which had been inspected in progress over the enurse of construction, was revisited and the qualification of personnel to perform safety-related activities reviewed.  !

Systems were opened and inspected; independent measurements were l taken; tests in progress were witnessed; and both design and  !

as-built construction records were reviewed. .

I This collective NRC inspection effort to investigate the tech-nical validity of several allegations did not identify new prob-less, but instead confirmed the effectiveness of licensee cor-rective action in response to known problem areas and provided additional assurance of the sensure of quality that construction completion has received.

2. Conclusion -

d Category 1

3. Board Recommendation None I

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.: ,. ', 10 B. Startuo Testing (1244 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.73342e-4 months <br />, 17.8%)

1. Analysis '

l During the last assessment period, nearly 2500 hours0.0289 days <br />0.694 hours <br />0.00413 weeks <br />9.5125e-4 months <br /> were ex-pended in the inspection of the preoperational test program of

• Seabrook Unit 1. Over that course of time, major testing was  ;

completed including the pre-core load Hot Functional Test (HFT), '

the Engineered Safety Features (ESF) and Loss of Offsite Power (LOP) tests, and the combined Structural Integrity Test (SIT) and Containment Integrated Leak Rate Test (CILRT). It was de-termined that a high level of performance had been saintained during the entire SALP period and for the majority of the pre- .

operational test activities. Accordingly, this functional area i was given a Category I rating.

The current assessment period provided the opportunity to assess not only the completion of preoperational testing, but also the conduct of fuel loading and post-core load testing, including another HFT. The completion of the preoperational test program and final closure of the remaining test exceptions proceeded smoothly with the transition into the startup test program. l NRC inspection coverage of initial fuel loading, as a startupa testing activity, identified a mispositioned valve in violation of operating license conditions. The programmatic deficiencies associated with this problem are described in the Plant Opera-tions section of this report.

Licensee preparation of the startup testing procedures was excellent. All 56 startup test procedures were finalized in a timely manner. They were well written and received adequate review and approval. Industry experience and NS$$ vendor review comments were properly incorporated into the procedures. Major test evolutions were verified and transient test responses were evaluated on the Seabrook site-specific simulator with the eval-uation results incorporated into the test procedures.

Fuel load and post-core load HFT tasting activities were delib-erste and well coordinated. Adherence to procedural controls was well in evidence. The conduct of startup testing was noted to be performed by qualified personnel, who interfaced well with their operations counterparts, and with management involvement in the prompt resolution of equipment problems and test defici-encies. Test records were well prepared and maintained. Test j

exceptions were few and dispositioned in a technically appro-priate and thorough manner.

" '?

11 One significant testing issue regarding the emergency feedwater (EN) system carried over from the original HFT, se difficulties had been encountered in the conduct of the turbine driven EN pump preoperational test. The steam supply system te the Terry turbine was redesigned after the identification of the original HFT water hammer problems. An NRC zero power license condition mandated successful completion of the subject EN testing prior to initial criticality. A specific startup test (ST-53) was formulated to verify system modification and desigr. adequacy.

During the conduct of this testing, weeping valves were observed to affect test conditions which necessitated the continuation of testing with an abnormal valve lineup. This unusual lineup contributed to an unexpected steam gene ator safety valve actu-ation in February, 1987. It also resulted in a testing issue which remains open, since the completion of the post-core load HFT and cooldown in March, 1987 has not yet provided complete evidence that the EN system functions as designed. The post-core load HFT had to be extended over an approximate six week period to troubleshoot the testing problems which were identi-fied. During this time, the licensee employed a trial-and-adjustment iterative technique to problem solving which is more characteristic of a "preoperational" rather than "startup" pro-gram. Review of the test results with a more systematic and analytical approach to resolution of the problems appeared to be warranted, given that operating license conditions and technical specifications were in effect. The licensee has attempted to address all NRC questions on this issue and has planned conduct i of a special test (STP-101) to verify adequacy of the normal I start and operation of the EN turbine driven pump. Thus, in ,

general the EN problems and how they have been handled by the  !

licensee validate the position that the startup testing process is functioning as intended, to identify probles areas, effect corrective seasures, and retest as necessary.

Overall, the NHY startup testing program planning and implemen-tetion have continued to provide the same level of technically coroetent confirmation of system and component adequacy, as was provided by the preoperational test program. Licensee manage-ment end startup personnel continue to demonstrate not only a responsiveness to NRC concerns, but also a technical determina-tion to objectively verify EN system operability.

4 I

4 a I

- 12 1 1

2. Conclusion ,,

l Category 1

3. Board Recomendation None 4

. 13 C. Plant Operations, (2667 hours0.0309 days <br />0.741 hours <br />0.00441 weeks <br />0.00101 months <br />, 38.2%) ",

1. Analysis The operational readiness functional area was evaluated in the previous assessment period in the areas of procedures and staff-ing, operator licensing, security and radiological controls. An overall Category 1 rating was assessed in this area based upon thorough licensee planning and a high leval of management atten-tion to the development of procedures and programs in the indi-vidual areas and in the preparation for a receipt of new fuel.

During this assessment period, security and radiological con-trols will each be evaluated as a separate functional area. -

Maintenance and surveillt.nce activities have been added to the Plant Operations functional area for this SALP evaluation.

During the current assessment period, core loading, pre-critical hot functional testing (HFT), and operational controls under the Technical Specifications provided the bases for evaluating the effectiveness of the station programs and procedures, which had been under development in the previous period. Analysis of each area contributing to an overall assessment of plant operations is discussed separately below, a) Procedures and Programs The evaluation of procedural and programmatic controls weighed heavily in the 63sessment of plant operations since the "zero power" license conditions limited the scope of operational activities. As initially inspected by the NRC, the implementation of the independent verification program was determined to contain certain weaknesses w,'.*-5 included vague selection criteria and inconsistent application among various station departments. Other programmatic areas where NRC inspection identified areas of concern included the equipment tagging, valve lineup and temporary modifica-tion programs. These problems were tne subject of enforce-ment action on two occasions. Additionally, during startup testing, a violation of the "zero power" license condition concerning locked valves was identified. This violation related directly to a deficiency in the operational con-trols for identifying the position of locked valves. The identified program development and implementation problems

.. have required concentrated licensee effort to upgrade the affected programs.

" 14

i 1

In the area of procedure development, weaknesses in format, content and consistency were first noted by the NRC in the operations surveillance procedures and later ift plant oper-ating procedures. NHY task teams of experienced operators and test engineers were formed and a procedure consistency review process was initiated. NRC review of these licensee efforts revealed a significant improvement in the quality and accuracy of these procedures.

Licensee initiatives and corrective measures in the above two areas have been responsive to both internally and externally generated programmatic reviews. While the time-liness of response to certain procedural concerns has been questioned, management attention to the probles areas, once identified by the NRC, has been thorough. Particularly in the areas of independent verification and the procedure consistency review, quality products have resulted once the licensee dedicated sufficient resources to the corrective measures, b) Conduct of Ooerations Since Seabrook is not a fully operational plant, the basis for assessment in this sub-area is necessarily limited.

Notwithstanding ths limited scope of licensee activities in this area, significant NRC inspection was conducted into routine operations, response to events / transients and TS interpretation / reporting.

Routine daily operation of the plant both in Mode 5, cold shutdown, and in Modes 3 and 4 during HFT was excellent.

A high degree of professionalism and competency of the con-trol room operators was in evidence throughout the period.

Control room logs and records showed continuous improvement over the period. The shift superintendents (SS) are tasked with 'a high level of responsibility for station operations.

Their judgement is routinely conservative and demonstrates a safety consclous attitude. Individual control room operators and shift supervisors are vigilant and knowledge-able and have taken s significant initiative in providing quality on-the-job training to licensed operator candidates on shift. As evidenced by a review of the LERs in Table 4 of this $ ALP, operator error has been identified as the cause of several inadvertent engineered safety features (ESF) actuations. In one case, improper switch operation resulted in an inadvertent safety injection ($1) while a ,

m i 15 second SI was generated due to tagging procedural error.

On another occasion, a switch misoperation resulted in a diesel generator start. In two separate events, substan-tial volum2s of RWST water were inadvertently transferred, once to the containnent and once to the refueling cavity.

1 While NRC review of each of these incidents has revealed timely corrective action on the part of the operations department, the number of problems experienced warrants increased management attention to detail in routine, Aily operations. Additional operational experience and famil-iarization with a zero power license environment reduced the number and frequency of such events during the latter part of this SALP period.

During this assessment period, the operators were not severely challenged to respond to significant plant trans-ients and events, however, several minor occurrences war-rant discussion. In addition to the events related to i operator errors, discussed above, several other ESF actua-tions c,ccurred. NRC evaluation of operator response in the control room verified effective use of procedures and appropriate operator judgement in restoring the unit to a normal configuration. Most notable of the above incidents wwe two inadvertent safety injection actuations caused by sa1 functioning control switches.

The station response to the declaration of an Unusual Event is summarily assessed in the Emergency Preparedness section of this report. No specific technical problems related to the conduct of operations were identified as a result of this event. However, it was noted that an internal dis-agreement between members of the operations staff developed J

as the event progressed. This disagreement, relating to event classification and notification requirements, contri-buted to the delay in reporting and therefore resulted in l the issuance of a violation. Additional training and specific delegation of responsibility within the operations department were neesssary to clarify cperational duty roles within the Emergency Response Organization.

Some difficulties were initially experienced in the inter-pretation of Technical Specification (TS) limiting condi-I tions for operation (LCO) and the reportability of events

] . under 10 CFR 50.72. The most significant example was the J handling of equipment and procedural problees associated with the control building air handling (CBA) system where i

I 1

4

, - _ _ _ _ , , - - - - , , _ _ . _ . , _ . - . _ _ - - - - - ._e-. _- .,,,, _ . _ - . .,

' 16 eventually, a definition of CBA single train

• operation had to be disseminated for generic interpretation by the sta-tion staff. Presently, licensee awareness of reporting requirements and the training provided to those individuals responsible for interpreting these requirements have improved in the wake d the initial difficulties. In another administrative area, however, the paperwork /

nonoperational workload of the Unit Shift Supervisor (US$)

continues to represent a potential problem, since it diverts his attention from shift operations. This situa-tion has not improved significantly since initial NRC dis-cussion of the concern and merits further station manage-ment attention. .

With the exception of the potential problem related to the US$ administrative burden, operations during this SAlp period have been conducted safely by qualified personnel, utilizing adequate procedures and controls in accordance with the Technical Specifications. Cartain problems attributable to inattention to detail have been experienced, but appear to have been appropriatelf dispost-tiened by station management. The real effectiveness of licensee corrective actions in this area etn only be measured during future hot testing and coerattoas.

c) Surveillance During this period the licensee implemented the Westing-house computerized TS Appraisal program and began conduc-ting surveillances. The licensee instituted this program on an accelerated schedule in order that surveillances were performed in advance of the actual required operability re-quirements, thus enhancing the procedures and establishing baseline data. Additionally, surveillance and operating procedures were utilized as much as possible during the l test program to allow additional trial usage. While a few  :

surveillance errors have occurred, the overall surveillance l program has been effective. The licensee also established I measures to strengthen this program with new initiatives involving T5 log reviews and the survet11ance procedure consistency review program referred to in paragraph a) above.

Th6 NHY Program Support Department Staff which is respon-sible for certain surveillance testing (e.g., ASME Section l XI and 10 CFR 50, AppendixJ) is highly competent and professional. One notable example of this was the dis- l covery by surveillance test engineers of the coarien mode l

1

l

/ , 17 valve failure on the equipment hatch air lock doors (dis-cussed in section IV.G of this report). Performance of the surveillance on the hatch doors at that time 'was in paral-lel to, but not directly responsible for identification of the problem. It was the alertness of 'the surveillince engineer himself that identified the malfunction and eventually led to the declaration of an Unusual Event. The technical support staff has also been extremely responsive to NRC questions and concerns. i Although the plant has not conducted sustained power oper- I ations, challenging the capabilities of the surveillance programs, inspsetion to date which has sampled higher mode operations indicates that licensee efforts in this area are '

sffective and. the programs are appropriately staffed. l i

d) Maintenance -

l The licensee has reorganized the maintenance support organ-ization, establishing separate Maintenance and Technical Support Departments. Electcical, mechanical, and I&C func-tions are performed by the c.aintenance department while system support is provided by individual systes engineers who have been delegated responsibility for the separate systems. This organizational concept has provided consis-tency and accountability in the maintenance chain. /,s a result, the Maintenance / Technical Support capability has I been signtficantly strengthened. The most visible example of this was the primary component cooling water heat ex-changer repairs where follow-up to this paintenance activ-ity led to identification of the service water valve lining problems, discussed in Section IV.G. Thesa two jobs re-quired considerable expenditure of maintenance resources, extensive hardware disassembly and complex special process controls. Th9re has been extensive involvement t;y Station Technical Support Engineers in the maintenance araa. The competence of these system engineers and their supervisors is a licensee strength. Liaison between technical support and maintenance has been an effective part of the work con-trol process. The NHY maintenance organization (including I&C) continues to demonstra6e excellent maintenance tech-niques in the area of pre-staging, cleanliness, tamporary support and storage and procedural adherence.

l

. 18 An additional licensee strength lies in the . area of plan-ning and scheduling. Daily "plan of the day" meetings are effective in the coordination of the diverse requirements of the many station departments. The computerized planning schedule is kept currbnt so that future planning is based on accurate data. A high degree of management attention has been directed to the coordination of the support activ-ities of various departments to meet the established sta-tion work schedules. A recent positive initiative involved the establishment of a new maintenance concept whereby preventive and corrective maintenance periods are pre- )

established for each system on a rotating weekly basis, i

Station maintenaue has been conducted in a highly effec- '

l tive manner with no maintenance-related f ailure or events i identified. Future plant operations will provide more significant challenges, but the maintenance and repair activities conducted to date indicate well controlled efforts capable of supporting more complex operations.

Diant operations at Seabrook have been cenducted professionally, I safely and conservatively. Initial weaknesses in the develop- i sent of procedures and programs have, for the most part, been i corrected. Licensee efforts in strengthening the tagging pro- I gram anc the consistency review of operating procedures are ongoing. The skills and knowledge of the licensed operating staff remains a strength and initial problems with inattention to detail have been overcome. The maintenance and technic:.1  !

support organizations remain a significant asset.

2. Conclusion l Category ?,

3. Board Recommendation l Licensee: Station management should emphasize attention to de-tr.11 in the conduct of routine operations, assess the effectiveness and control of operational programs and evaluate methods to reduce operational errors.

l NRC: None O

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l

• l '.' .

19 D. Radiological Controls (739 hours0.00855 days <br />0.205 hours <br />0.00122 weeks <br />2.811895e-4 months <br />, 10.6%) -

1. Analysis l

A Category I rating, as part of the Operational. Readiness area, l was provided for this area in the last assessment period based upon the observation that the licensee's operational readiness l in the four radiological control areas (radiation protection, l waste management, transportation and effluent control and non- l itoring) exceeded that routinely found at similar plar.ts at the i same preoperational stage. This fact was attriouted to a high l level of management commitment, the degree of preplanning and j preparation, and the level of attention to detail. l This current assessment is based upon both a'n observation of ongoing plant activities and an evaluation of the programs which ,

have been established. Since radiological conditions at the l plant were limited, the scope of this assessment necessarily l emphasized programmatic and operational readiness reviews, rather than demonstrated implementation of radiological con-trol s. It was noted that while the licensee was not greatly challenged in this functional area during this assessment period, a meaningful evaluation is still possible based upon i review of the limited activities (e.g., fuel load) and the con- I trols in evidence during their conduct. Program areas include In-plant Radiation Protection, Radioactive Waste Management, i Effluent Controls, Nonradiological Water Chemistry, and Environ- i

. mental Monitoring,

a. Radiation Protection

. During this assessment period, the licensee continued to make significant progress towards operational readiness in the areas of staffing, training procedures, and equipment and instrumentation. The continued presence of a motivated and professional sta"f and management commitment to the program were evidence) by an increase in staffing level aimed at commercial operation. The Radiation Safety Committee met at the required frequency and was tracking  ;

and evaluating program development, implementation, main- '

tenance, results, and outstanding accion items. Formal and timely evaluation packages on prr.viously identified NRC inspector concerns demonstrated it ensee responsiveness and attention to these items. As a further licensee initia-tive, a supplemental HP training program was developed and implemented. During this period, the licensee's principal

- , - , - - _ . , , .. ,- -c-- v,, -,c--w <g-.,v.w.,ev-yw--,-~.,-,.,,,y--

20 l

(corporate) health physicist and the licensee QA organiza- I tion performed evaluations of the health physics (HP) pro-  !

gram. The corporate review resulted in severi.1 recommenda- I tions being evaluated as program enhancements while the QA audit addressed good practices in addition to the regula-tory requirements. Both evaluations were timely and encompassed the full scope of HP activities.

During this appraical period, primary startup sources were  !

installed in fuel assemblies in the fuel storage building. i The fuel assemblies were moved into containment and loaded into the reactor vessel. Also, calibration of area and 1 process radiation monitors and of other radiation detection instrumentation was conducted. The licensee reported nint-mal person-rem exposures (less than 1 man-rem for 1986 and for the first quarter of 1987), indicating that appropriate radiological controls had been exercised over the limited activities which were conducted during this assessment period. ,

In summary the licensee has developed an aggressive radia-tion protection program in preparation for commercial oper-atton. Considering the nature of the activities conducted to date, effective radiological controls have been imple-mented. When areas for improveihent have been identified by either the licensee or NRC, sita and corporate HP manage-ment has initiated timely and appropriate corrective action,

b. Radwaste Management / Effluent Controls The licensee demonstrated aggressive oversight of the radiochemistry program in preparing for fuel load and ,

responded to NRC identified concerns in a timely manner.  !

Regarding radioanalytical standards submitted to the  ;

licensee for analysis, disagreements in two samples were  ;

resolved promptly, indicating a high level of radiological i chemistry management involvement. The radiological environmental monttoring program (REMP) is implamented through a clearly designated program which interfaces the ,

site and corporate groups. The scope and method of over-view audit functions were clearly stated.

y Several aspects of the REMP program implementation during the preoperational phase exceeded regulatory requirements.

Although not required, the direct radiation monitoring ,

environmentri TLD program was found to include efforts to , i meet. criteria for quality control found in USNRC Regulatory Guide 4.13 and ANSI N545. The licensee also participates in the International Environmental Dosimeter Intercompar- l ison project. These licensee initiatives indicate a high level of corporate management awareness, commitment of  !

resources and sensitivity to the needs of this program.

Procedures for effluent measurement and control are coupled i to an administrative procedure for surveillance for comply- .

ing with the requirements of the Technical Specifications.

The program for preoperational and acceptance testing of radwaste systems was found to be effective. Test excep-tions and identified weaknesses were addressed in a timely manner.

c. Non-Radiological Water Chemistry During the assessment period, the licensee made progress in nonradiological water chemistry for monitoring para-meters of primary and secondary water and preoperational and acceptance test programs. Procedures were found to be technically sound and adequate to meet TS requirements.

However, an initial inspection of this area identified certain weaknesses. The licensee was unable to analyze samples in the concentrations normally found in an opera-ting reactor. Also, tha inadequue calibration of instru-ments was noted. Follow-up inspection in these areas found considerable improvements in the sample analysis and quality control in the lab was upgraded. Again the lican-see management demonstrated involvement in the program and responsiveness to inspection recommendations.

Review of the water chemistry control program indicated a l clearly defined policy, competent organization, effective )

administrative procedures and adequate resources for imple- '

mentation. Based in part upon a study done by the station l chemistry department, the licensee continues to explore l additional enhancement options to the present program of I all-volatile treatment (AVT) for secondary side water  ;

treatment.

l

22

'a = ,

Although the functional area was not severely challenged during this assessment period, the licensee demonstrated levels of i preplanning, preparation and program development consistent with  :

a plant ready for operat'on. In those activities where the  !

radiological controls were tested, good results were achieved.

The licensee organization is staffed with qualified personnel, from the station HP and chemistry management down. The overall l performance during this period indicates that the site radio-logical, effluent control and chemistry programs have been established with the capability to effectively support plant j operations.

2. Conclusion Category 1 l

3. Board Recommendations None .

8 1

l 1

l l

23 j

~

E. Emergency Preparedness (219 hours0.00253 days <br />0.0608 hours <br />3.621032e-4 weeks <br />8.33295e-5 months <br />, 3.2%) .

1. Analysis .

During the previous assessment period licensee performance in this area was rated as Category 2 (improving), based upon per-formance during the Near Tern Operating License (NTOL) Emergency Preparedness Implementation Appraisal (EPIA) and the first full- 1 participation emergency preparedness (EP) exercise. During the current assessment period, one NTOL appraisal follow-up inspec-tion, one routine safety inspection, and one special safety inspection were conducted. Additionally, changes to the Emerg-ency Plan and Emergency Plan Implementing Procedures were re-viewed. Although not specifically addressed as part of their assessment, it should be noted that licensee initiatives for eff-site planning have been implemented and preparations by the site staff to support such initiatives are in progress. Licen-see efforts towards obtaining a workable off-site emergency plan reflect a strong commitment by licensee manageme. n t towards a complete emergency preparedness program.

Two NTOL Appraisal followup inspections were performed in March and June,1986, specifically to follow up on twenty-four open items resulting from the appraisal. While the first of these two inspections concluded on March 28, which was during the last SALP period, it has been included in this assessment because it represented the conclusion of the EPIA inspection process at Seabrook and the report results were not available until well

. into this period. Licensee management aggressively addressed NRC concerns resulting in the closure of twenty-two open items.

The remaining two open items are requirad to be corrected prior 1 to i ssuance of a full power license. A routine EP safety  !

inspection, conducted in March,1987, related to inspection of 1 the training program, operational status of the emergency pre- i paredness program, and security / emergency preparedness program interfaces. Inspection results indicate a comprehensive onsite emergency preparedness program is in place.

The special safety inspection conducted in February,1987, re-lated to follow-up of the sequence of events and circumstances surrounding the classification of an Unusual Event on February 11, 1987 and the required notification process. This special safety inspection identified a violation of the lic6n-see's internal procedures. The licensee failed to follow the requirements of emergency procedure ER 1.0, "Classification and Notification of Emergencies at Zero Power", which requires

i 24 notification of both Massachusetts and New Hampshire within fifteen minutes of classifying any emergency condition (as de-fined in procedure ER 1.1). The causes of the violation, spec-4

/

ifically the failure to notify Massachusetts within fifteen minutes, were related to weaknesses in the training of the operations management and supervisory staff and are discussed in more detail in Section C.I.b of this report.

The emergency preparedness planning function continues to be controlled by the NHY corporate staff located at the plant site and close liaison exists within the site organization. During this assessment period, the position of Director of Emergency Preparedness and additional corporate planner positions were filled by permanent NHY employees.

The installation of equipe.ent and training of personnel to ful-fill their emergency response organization functions, while on-going, has been substantially completed. First aid capability and nursing coverage have been added to the staff. Also, addi-

- tional personnul to fill the Key emerency response organization positions on a twenty-four hour basis are currently involved in qualification activities. The lack of on-shift dose assessment capability has been corrected and the addition of todine deter-aination for off-site dose estimation has been completed.

The licensee has been responsive to NRC initiatives. This is in evidence not only by the addition and training of personnel to fill key functions within the emergency response organiza-tion, but also by the cooperation provided by NHY on the resolu-tion of NRC issues concerning the emergency plan and procedures.

Additionally, significant effort has been expended by licensee management toward the resolution of offsite concerns. Although  :

weaknesses in the training of supervisory personnel were uncov- l ered during an Unusual Event, this incident was quickly and l comprehensively addressed by licensee management. Overall, the connitment and performance by the licensee in emergency preparedness remains high.

2. Conclusion Category 1

3. Board Recoamendation

- None

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l

. . 1 25 F. Security and Safeauards (175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br />, 2.5%) .

1. Analysis During the previous SALP period, the licensee was assigned a Category 1 rating, as part of the Operational Readiness evalua-tion, for preoperational activities involving security personnel training and the installation and testing of new systems and equ'pment for the Unit 1 Physical Security Program. In the cur-rent assessment period two preoperational security program reviews, one routine physical security inspection and one pre-operational nuclear material control and accounting review were conducted, along with physical security inspector participation .

in a Region I team inspection. No violations were identified.

The NRC completed its evaluations and approved the Seabrook Station's Physical Security, Training and - Qualification, and

' Safeguards Contingency Plans on July 23, 1986.

Over the course of this assessment period, the licensee's staff has been involved in monitoring the performance of new security systems and equipment, evaluating the effectiveness of training and procedures and assessing the need for changes based on pro-gram experience and feedback. Both corporate and station management involvement in and support for the security program were evident and resulted in the initial implementation of the Unit 1 Physical Security Program with few identified problems.

The allocation of a sufficient number of technical and support personnel resulted in sound designs, good planning, and timely procurement and installation. Such oversight underscores senior I New Hampsnire Yankee management's support for an effective '

security program. Throughout the preoperational phase, the licensea'was respensive to the resolution of weaknesses / concerns identified during NRC inspections and in NRC Bulletins, Circu-lars and Information Notices. The licensee also initiated

' liaison with other Region I licensees, visited other sites, and i developed feedback mechanisms to resolve security program l issues. This has resulted in security program enhancements l

being implemented at the Seabrook site.

Effective communications exist between the security organizatioa and the other station departments, as evidenced by the station response to security events. Program support and cooperation is also evident from local law enforcement agencies. The licen-

- see's security organization is actively involved in the Region I

- Nuclear Security Organization and with other nuclear industry groups engaged in the development of security program standards and innovative approaches to security issues.

. . _ _ _ _ _ _ _ . . _ _ . ~ . _ _ _ _ _ _ _ . . _ _ _ . . , _ _ _ . _ _ _ _ , _ , _ . _ . , _ _ _ _ _ _ _ , . , _ . - _ . .

. 26 Twenty-four event reports were submitted in accordance with 1 10 CFR 72.71 during this period. Twenty-two of these reports resulted from minor problams typical to those encountered during the startup and continued testing and maintena'.:e . .of new secur-I ity equipment and systems, including the security computer and its associated software. While the licensee's event reporting program was found to be acceptable, NRC evaluation revealed that (

several reports required further clarification from the licensee l with regard to the analysis of causes and planned corrective actions. During the latter portion of this assessment period,  !

both an improvement in the quality of event reports and a reduc-tion in the number of security event reports were noted.

Staffing of both the proprietary oversight and contract security organizations was timely and effective. Management and super-visory personnel appear to be well qualified, experienced and motivated. Clear and concise security procedures were devel- l oped, approved and implemented to ensure program cohesiveness.

Modification of these procedures is continuing in response. to feedback and experience gained through use. The self-identif t-cation of program weaknesses and needed improvements by Doth the contractor and proprietary staffs is encouraged by licensee management and reviewed in a timely manner. Special emphasis is currently being focused on tt.2 performance of security systems and equipment, and their reliability. This effort is intended to enhance the effectiveness of both short-term reactive and long-ters preventive maintenance for the systems and equipment.

The level of staffing for security equipment maintenance program further reflects the licensee's commitment to a high quality program.

The security organization's training and qualification program has been well established with full-time experienced instruc-tors, lesson plans, state of the art instructional aids and adequate facilities. Entry level training and annual requalif-ication training of security force members are administered in conformance with NRC approved criteria. Oversight by the pro-prietary staff ensures that the program is ctmtinuously updated to include feedback from operating experience. Members of the security organization were observed to perform their duties in a professional manner.

During the assessment period, the licensee submitted two revisions to the Security Training and Qualification Plan and a revision to the Safeguards Contingency Plan under the provisions of 10 CFR 50.54(p) and provided its response to the recent mis-cellaneous amendments to 10 CFR 73.55. The revisions were of high quality and indicative of the station management's continu-ing oversight of the program to ensure it is consistent with NRC I

.-- - _ , . _ - - . . , _ - - - . - , _ . _ _ _ _ - . _ _ _ _ _ , _ , _ _ . , , _ . _ ._, , __.,._ ,,_ _ ,__,_g_ ...__,,._.,,,_,_,,__c . , _ _ _ . , . _ , , _ , . , _ _ _ ,

l

'i 27 performance objectives. Security personnel invb,1ved , in plan maintenance are knowledgeable of HRC requirements. Addition-ally, the licensee's program and procedures to control and account for special nuclear material were reviewed and found to j be adequate, as was the licensee's plan for the protection of 1 special nuclear material of low strategic significance (new fuel).

In sumary, the licensee has established an effective Physical I Security Program. Efforts to improve the operation and reli-ability of systems and equipment and personnel qualification have continued. The security program is actively supported by other plant functional groups, as evidenced by the lack of l l

problems 'r the maintenance of security equipment, response to events and sther areas where effective interfaces were necessary. Bo.h corporate and station management support of security prograas and initiatives is evident. l

2. Conclusion Category 1

3. Board Recomendation None l 4

_ _ _ _ . . , , , , , - , , . - , , , , ~ , - _ _ , . , . . . _ _ , . _ , _ _ , , - _ - - . _ _ , _ , , _ - . _ , . _ . _ . . _ _ - _ . - -

gg G. Engineering Support (57g Hours, 8.3%) ,

1. Analysis This area was not evaluated as a separate Functional Area during  !

l the previous SALP period, although the engineering services provided to support construction activities were considered in the overall assessment of the construction area.

During this current SALP period, engineering support to the station staff is asse.* sed based upon the engineering services provided to the plant maintenance and modification processes, the analyses perforned to address NRC concerns and self-identi-fled design problems and the licensee's overall technical ability to support construction completion and ongoing opera-tions from an engineering standpoint. It is noted that during this period, a reorganization of both the corporate engineering and technical support staffs occurred. A New Hampshire Yankee l

engineering organization was established with a smaller in-house review r,apability than existed during the period of full con- l struct:en and architect / engineer presence. However, well de- l fined agreements with both UE&C and YAEC were established to provide additional engineering services on an as-required basis.

The station staff also restructured their technical support capability to align with a system / discipline service orientation.

While this licensee reorganization has tailored the engineering staff more directly in support of operational activities, cer-tain problems have arisen during this SALP period which high-light the need for more timely and complete engineering analysis of deficiencies particularly by the corporate engineering staff.

Examples of such problem areas included NRC identification of a Control Building Air (CBA) system which deviated from system design commitments provided in the FSAR and also of a Contain-ment Building Spray (CBS) piping design which required upgrade and implementation of a design modification to meet the intent of the pertinent ASME Boiler and Pressure Vessel Code. In each case, licensee events or observations had identified evidence of the problem areas (control room ventilation isolation events in the case of CBA and leaking check valves in the case of CBS),

but were not sufficiently developed by engineering review to effect timely corrective action. Ultimately, in both cases, system modifications were effected and NRR review and approval

- of the CBA and CBS designs were required.

-...,..,,,-----,..-.,n- ,,_..n, , . , , _,___.,.__,_.,,e ,,.n_,_m., ,,_,,.m,-y.. -,,,_--__,.wn,,m.y., .,w,

a gg Other noteworthy problem areas included the identification by the licensee of' tube erosion and pitting problems in.the primary component cooling water (PCCW) heat exchangers, evidence of valve lining detachment and degradation in the Service Water (SW) system, and a common mode failure of equalizing valves' ,in the containment er,Jipment hatch air lock doors. The latter two issues represent items which were reported by the licensee under the provisions of 10 CFR 21. Unlike the handling of the CBA and CBS problems, however, licensee reaction by the station tech-nical support staff to these major problems was thorough, methodical and well scheduled. Eddy current testing of the PCCW heat exchangers was implemented, resulting in the conduct of tube plugging and sleeving operations. The SW valve lining .

configurations were redesigned and a comprehensive test program was implemented to verify adequacy. The equipment hatch air lock equalizing valve linkage was also redesigned to preclude recurrence of a similar failure. .

The only negative aspect to the licensee responsiveness to these problem areas was the fact that the SW lining problems repre-sented, in effect, a weakness in the licensee's cor'rective action for a 10 CFR 50.55(e) report issued in 1985. At that time, the original valve rubber-like linings were replaced by a "Belzona D&A" elastomer. However, it appears that both the replacement design and the construction bonding process were defective, resulting in the current problems. The licensee's currant approach to both the engineering and process controls required to repair these valves, however, appears to be thorough and well directed.

In response to concerns raised by the NRC with respect to the engineering department interfaces with the station staff, the licensre has implemented new initiatives to foster mutual co-operation and reliance on technical expertise to address prob-less. This cooperation has evidenced itself in corporate engi-neering management attendance at "plan of the day" meetings, the more timely involvement of the corporate engineering staff in operation decisions related to the FSAR and design basis analysis, and plans to relocate corporate engineering personnel from the general office building to offices closer to the plant itself. Both the Independent Review Team (IRT) and Independent Safety Engineering Group (ISEG) appear to be functioning in an atmosphere which provides valuable overview to not only site specific engineering problems, but also generic issues affecting the industry. Current New Hampshire Yankee Engineering Evalua-tions from the corporate staff provide a documented, well defined approach to technical questions. Thus, the licensee'has demonstrated a willingness to implement programmatic improve-ments not only where deficiencies are identified, but also where weakness,es are perceived.

..-,_.--,,,m,.,7-____---.--y,, , -y.y ,m-,,,,..,,,m.y-,-, _ - . , .

. 30 As wcs discussed in Section IV. A with respect to construction completion, engineering support activities related.to the design raconciliation of the as-built plant (e.g., PAPSCOTT) were ef-factively implemented to assure compliance with the design bases and FSAR coasnitments. Licensee corporate management has demon-strated a willingness to implement design modifications where justified by internal engineering evaluations or independent staff reviews. This licensee responsiveness to determine and effect the proper engineering solution to identified proolems (e.g., EFW Terry-turbine testing; service water valve lining repairs) continues to represent a licensee strength. The recur-rent nature of some of the problems described here~ and in other I sections of this SALP report does, however, highlight the need for additional licensee attention to adequate control of the corrective work processes.

In summary, engineering services to the station construction l completion, maintenance and modification efforts has evidenced '

some transitional problems from reliance on a large staff, heavily dependent on architect / engineer (UE&C) support, to a smaller New Hampshire Yankee in-heuse engineering program. The licensee has recognized these problems and appears not only to understand the.need for improvement in support of future opera-tions, but also to have initiated corrective measures to proceed in the proper direction.

2. Conclusion Category 2

3. Board Recommendation None e

---

~.- --e - - - . - ,,,,-,-e

- - - - , - -- - - - . _y._,.---,.-___---_,-,__-,,,,,,,-,,,_,..c._,,,,----.%-,-

I

• 3 * -

31 H. Licensino Activities -

1. Analysis This area was rated as Category 1 during the previous assessment period based upon the required preparations, responses to open items, and overall readiness with respect to the issuance of an operating license. The previous assessment concluded that management involvement was evident and effective, that a high degree of responsiveness was apparent, and that corporate staf-fing levels were sufficient to support licensing actions. Since the previous assessment period, a license has been issued to permit fuel load and the conduct of precritical tests. A .

license to operate up to five-percent power has been requested.

The current assessment is based principally on NHY performance in support of those actions which were required to obtain a fuel load license and which were taken in connection with its request for issuance of the five-percent license.

The licensee has continued to demonstrate strengths in their approach to problems from a safety standpoint, in the qualifi-cations and level of staffing and in the active involvement of j corporate management. The licensee has provided the needed tech-nical capability in the engineering and scientific disciplines to resolve items of concern to the NRC. Resolutions to tech-nical issues have been consistent and thorough. The licensee has been willing to perform additional studies, as necessary, to j answer any outstanding NRC questions. Thus, on technical -

matters, effective communications between the licensee and the NRC staff have been beeficial in processing licensing actions.

The licensee facilitated timely resolution of the majority of l outstanding licensing issues. In most cases, acceptable pro-posals were submitted with the initial licensee response. The overall respor.stveness to NRC initiatives was generally satts-factory, except for certain issues, where in the first part of the current SALP period, additional NRC requests were needed to gather complete information. For these cases, NHY corporate management involvement and timely action were effective in promoting satisfactory resolutions to the specific problems.

NHY management has actively participated in licensing actions and generally has maintained awareness and knowledge of current and anticipated licensiag activities during this evaluation period. On several occasions, licensee management has demon-strated not only involvement in licensing, but also prompt, t

4

- . . - , ~ , . . - _ . - _ _ _ -- . _ - , . _ _ , - . _ _ _ . _ _ _ , . __

s -

- 32 appropriate corrective action to situations wherp the respon-siveness to WRC initiatives was deemed unacceptable or not timely. NHY has also demonstrated a willingness to meet with the NRC Licensing Project Manager to discuss , licensing action status on an as-needed basis and with a cooperative attitude to I

resolve problems.

I NHY licensing and engineering groups have been adequately i staffed, as indicated by the qualified representatives attending numerous meetings with 'the NRC. Competent technical staff have l participated in scheduled reviews and effected satisfactory resolution of open items. The NHY Bethesda Licensing office has remained active throughout this SALP period as a significant licensee initiative which continues to provide priority atten- l tion to NRC concerns. In general, the licensing group has effectively coordinated the effort of providing input from the different functions within the NHY organization.

l

2. Conclusion Category 1

3. Board Recommendation Non: .

e e

e l

l 1

l i

l

a 33 -

I. Training and Qualification Effectiveness '.

1. Analysis Training and Qualification ' Effectiveness is an evaluation cri-terion for each Functional Area. In this appraisal, it is a.lso being considered as a separate area and as such, represents a synopsb of the assessments in the other areas. Training effec-tiveness is measured by observation of licensee personnel per-forniance and through reviews of licensee programs.

The limited scope of operations during this assessment period has not allowed for an appraisal of the effectiveness of train-ing over the full range of operational activities which will be implemented in the future. However, in those areas where the measures of licensee performance can be related to tnsining and qualification criteria, this assessment provides an overall evaluation of 'he effectiveness of control and conduct of licensee work activities.

. In the last SALP period, this fun:tional area was not evaluated separately, but Operator Licensing was assessed a Category 1 rating as part of the overall operational readiness appraisal.

During the previous assessment period, the licensee had demon-strated a commitment to quality training. This commitment has remained evident through the

• current SAlp period based upon licensee initiatives in the areas of simulator enhancement and efforts directed toward licensed operator training program accreditation by the Institute of Nuclear Power Operations (INPO).

The first group of operator licenses at Seabrook became due for renewal during this period. Two year license renewals wire issued for these individuals. A requalification program eval-untion .was also initiated to provide a basis for the license renewal. To date, this evalu.1 tion has consisted of an NRC review of the requalification program and an NRC requalification examination administered to eight licensed operators. Three operators failed one or more portions of the NRC administered requalification examination and are being upgraded in accordance with the axisting NHY requalification program. Training Depart-ment actions to address NRC identified generic weaknesses and strengthen the overall program have been initiated and appear 1 -

well directed. As had been evident in previous, less forwal NRC appraisals of operator training with respect to requalification, the licensee has demonstrated a willingness to devote adequate resources to the training goals and to cosuit additional resources to upgrade identified areas of weakness.

, _ . - _ - - . - , - . , , - , , , - , , . , - . - ,,_,,,,---.._,m_,,y , _ , _ _ . ._,,-.m.,,,r,,_., ..,y_m.,,,,,,..m._,._.y..g ...,,-.~e,m...,...,rr_m,,, ,,g___, ,e

- -- - - -- - - - ~ - - - ~ ' - - - - - - - - -

~ ~ -

_.---6 '

34 It should be noted that another initial operator licensing examination was administered in August, 1987. Although this examination was conducted shortly after the end of this current SALP assessment period, the results indicate a high initial examination pass rate which is consistent 'with the previous initial license examinations at Seaorook Station.

A review of the LERs and enforcement actions issued during this SALP period identified certain problems related to training J

effectiveness. As discussed in other Functional Areas, viola-tions resulting from the failure to maintain a valve locked-closed in accordance with license conditions and the failure to .

follow procedures in notification during the Unusual Event, were caused in part by training deficiencies. Additionally, incom-plate operator understanding of the design bases of the CBA system design, as noted in Section IV.G, led to a violation, after a deviation from FSAR commitments had already been issued on the same subject. The problems, however, appear to have been isolated examples, as the overall training provided the opera-tions staff ts of high quality with no major generic weaknesses.

An evaluation of the LERs issued during this assessment period identified no specific causal linkage between performance-related problems and the adequacy of training.

In the area of general and specialty training, a reorganization has consolidated all training functions under the Training Center Manager who previously was responsible only for licensed operator training. This change should enhance the overall training effort while reducing the administrative responsibil-ities of the Station Manager.

NRC inspectors monitored various licensee training sessions both for the purpose of on-site program familiarity and to assess the effectiveness of licensee training in a<reas such as general employee training, radiological controls and fitness for, duty.

Also, NRC inspections of other functional areas have evaluated the conduct of training (e.g., Technical Specification revision training for operators, entry level and annual requalification for the security force, supplemental HP training, and general Ep training provided the licensee Emergency Response Organization. ,

This inspection effort has confirmed that the training and qual-  !

ification criteria inherent in the implementation of other tech- l nical programs have been effectively utilized. Region I special l team inspections into allegations regarding Seabrook construc-tion hardware and programs revealed no specific disciplinary training deficiencies and no generic problems with the licensee program of education and handling of substance abuse policies.

- 35 Thus, a review of licensee performance across the range of dif ferent. disciplines, as highlighted in the different func-tional areas, reveals that the conduct of adequate training and qualification programs have contributed to the successful imple-mentation of overall station objectives. An additional exainple of licensee philosophy in this regard was the wide dissemination of technical information, either industry initiated or NRC originated, throughout the station staff. This information flow has effectively increased the station's awareness to problem areas in the industry and has cravided guidance to the technical staff for performance improvements.

In summary, in those areas where NRC and licensee evaluction have identified training related weakriassas, prompt and effec-tive corrective measures, including the retraining of personnel, have been implemented. With respect to the overall control of training functions and performance by station personnel, NRC inspections over the course of this SALP period have found the licensee programs and staff to be effective.

2. Conclusion Category 1

2. Board Recommendation None e--, ,,.-, .-., . - - - -.,-. - . - - - . , , , , . . - - - - - , , , , - _ .

.,,.,,-,.,,_,,.n, . .n._.,, _,,-___.,_,..,.,,,---...-ne.- _-,,-,---,--..n.

.36 i

J. Assurance of Quality i

1. Analysis Management involvement in assuring quality is an evaluation i criterion for each functional area. Quality assurance (QA) also I is an integral part of each functional area. This appraisal of (

the assurance of quality is a synopsis of the applicable aspects  !

l of other areas, including worker and supervisor performance, sanagement oversight, and safety review committee activities.

During the last SALP period, this functional area was assessed a 1 Category I rating based upon an effective QA program, which assured construction quality, and the continued management support of QA initiatives.

During the current assessment, an entirely new QA program, that of operational quality assurance, was subject to evaluation along with a new

• organizational structure, revised interfaces, different work controls, and the necessary shift from construca tion processes to maintenance and modification activities. The I interdependence of NHY QA policy and procedures with the Yankee Atomic Electric Company (YAEC) program was eliminated and key ,

personnel responsibilities shif ted accordingly. It is note- )

worthy that the licensee retained sufficient experienced p6r-sonnel from contractor organizations (e.g., YAEC, UU Westinghouse) to effect a smooth transition into the operational system of controls.

However, certain transitional problems have been experienced in the restructuring of the QA organization to fit its operational responsibilities. While management support of an effective QA program remains strong, the relative strength of the QA organi-zation as an independent force and prime mover in the corrective a.ction process has diminished. This may be the result of and a normal consequence to the establishment of a stroy station l staff with particulcrly qualified and technically competent operations, maintenance and technical support groups. However, one negative aspect of this has persisted throughout the current SALP pariod and relates to the feeling that the station staff can disposition their own problems without the need for QA involvemtat and that the QA staff mission relates more to pro-grasunatic and procedural overview than it does to the effective- ,

ness of controls. l

-.--,,..n,, ~ . . ~ . . . _ _ . , , _ , , _ , . , , _ _ , _ _ _ _ _ _ _ _ _ _ , _ _ _ _

37 NRC inspection issues which have highlighted '.this concern include questions into tagging controls, station operating and i surveillance procedures, the use of unauthorized operator aids, l general housekeeping and corrective action processes, and utilization of Station Incident Reports as an information source for root cause problem analysis. In several of these cases, )

where a specific NRC recommendation for QA follow-up of the i identified deficiencies was made, audits were conducted. These audits proved to be extensive and thorough and generally con-firmed a need for corrective action. However, the fact that such QA reaction to the problems was not routine, but evident only upon NRC interest is a matter that warrants further manage-ment evaluation of their QA program of controls.

One strongpoint of the present QA program is tha effective use of quality control inspections and holdpoints to confirm the proper conduct of special processes. The implemantation of such QC measures has strengthened an already strong main *,enance pro-gram in the area of independent checks and assurantes of the adequacy of controls in the various disciplines. Another pro-grammatic strength is the individual expertite provided by the technical support staff. The NHY system engineers, while not QA

- personnel, provide a definite measure of effectiveness to the overall station assurance of quality, based upon their knowledge and technical interfacing with other personnel on the station staff and with the QA and engineering organizations. This strength relates to an overall NHY organizational structure which appears to be effectively working, while still providing a system of independent checks and balances.

Examples of independent groups within NHY which provide quality services which have supported the successful functioning of the j overall organization include the Independent Review Team (IRT),

the Employee Allegation Resolution (EAR) program and the Independent Safety Engineering Group (ISEG). Both the IRT and ISEG have been involved in design evaluations, and the analyses 1 of component failures and human factor problems which have led I to reportable events. In the same way with respect to allega-tions, the EAR program has provided a "third party" review of concerns which has not only proved beneficial to the investi-gative process for worker concerns, but also has provided a measure of independence to the normal management review of problems. The IRT and the EAR were also both noteworthy as i licensee initiatives which were established and maintained, not because of regulatory requirements, but because of the benefits the licensee knew would accrue from independent self-evaluations.

Programmatically, these independent groups, along with the Nuclear Safety Audit and Review Committee (NSARC) and the use of special review proups where necessary, have provided a measure of the licensee s ability to self-criticize and thus learn and improve with the corrective action process.

38 Another licensee internal review group, the Stati'on Operation Review Committee (50RC), has also been active during this assessment period in reviewing program and proc.drP mvicions.

Some administrative problems in 50RC effectiveness were iden-tified by the NRC with respect to the application of safety Also, the review criteria to "nonintent" procedural changes.

practice of conducting such reviews outside the scope of the SORC meeting was questioned. On both these matters, the licen-see recognized the advisability of instituting improvements to the 50RC and safety review processes and implemented additional systematic review measures to address the NRC concerns.

Another program where NRC inspection revealed the need for further development was the licensee's implementation of a Quality Trending System. Weaknesses identified in this area related to the lack of corporate and QA management attention to the availability of problem trending mechanisms and also to a database which fails to track the valuable trending information available in documents other than nonconformance repo rts.

ycensee QA management was apprised of these concerns and has instituted program reviews intended to upgrade the defined cor-rective action process. Continued attention to the controls which integrate plant activities and problems (e.g., Station Incident Reports) into a QA trending system, thus providing insights into the lessons learned, is warranted.

Overall, in evaluating this functional area in the context of quality criteria affecting other rated areas, a high level of performance was noted. Effective work controls, strong first line supervision, timely QC inspection and a continued emphas.c on quality performance, to includa management support of QA goals, have resulted in evidence that the plant is being oper-ated and maintained safely. While some areas requiring improve- .

ment were identified, positive licensee initiatives were also noted to sustain the Assurance of Quality during 'the major transition from construction to operations. A strong quality conscious attitude is evident throughout all levels of the plant

- organization. The increased involvement of the QA organization into operational activities and problem analysis should further enhance the overall effectiveness of the quality program.

2. Conclusion Categen 2

4' 4

• 39

3. Board Recommendation ,

Liernsu: New Hampshire Yankee management should reassess the

~

role of the QA organization in the analysis of opera- l tional problems. The licensee should consider expan- l ding the scope of quality assurance functions to mere effectively utilize QA as a management tool to recog-nize the generic impact of certain problems, and thus allow corrective action to be directed to related areas of programmatic weakness.

NRC: None l

l l

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D 9 e

, - . - . , - - _-,,,,,,,,,.,,.-,..,.,_.---n+_-..,n . - - - - , - , . - - - - - , --

. a l

- 40

~

V. SUPPORTING DATA AND SUMMARIES A. Investtention and Allegation Review During this assessment period, a total of four separate and gener-ically categorized allegations were received by the NRC. One of these generic sets of concerns was multifarious and involved concerns of a broad and general nature. To date, over 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of direct NRC inspection effort have been expended to determine whether quality construction or safe operation had been or could be ' adversely impacted by this set of stated allegations. In this case, as with the other three allegations, no violations were identified. <

It is noteworthy that while several of the stated concerns involved nonsafety-related components, NRC inspa.ction treated these allega-tions rigorously as technical issues to determine if some deficiency could be linked to safety-related activities. No linkige was identi-fied, and, to date, no hardware problems (either safety or nonsafety) have been in evidence. While evaluation of several new concerns is in progress, the findings so far corroborate the quality of con-struction. These results also confirm previous NRC assessments that over the course of construction completion, few hardware problems have been identified and those that had existed have been adequately corrected.

B. Escalated Enforcement Action None C. Management Conferences 1

No conferences with the licensee dealing with enforcement were held during the appraisal period. On June 10, 1986, a management meeting at NRC request was conducted at Seabrook Station to discuss the  ;

results of the Region I SALP board convened to evaluate licensee l performance from January 1, 1985 to March 31, 1986.

D. Review of Licensee Event Reports (LERs)

1. Tabular Listina Refer to SALP Table 4 for Listing of LERs by Functional Area 6

---.--,-,,.---.,._e,

, , - , , , , ,,..___.~-.._c.-_.-.,

- 41 l 2. , Causal Analysis Analysis of the LERs listed in Table 4 has identified no unac-ceptable chains per statistical acceptance criteria. An nE0D evaluation of Seabrook's LERs indicated that the reports were of generally above-average quality. Additionally, one other non-reportable event was identified which was linked to a reportable event. While the Itcensee had not recognized this linkage in subsequent reporting, this had no effect on the causal analysis or the results.

E. Summary of Licensing Activities

1. Significant NRR/ Licensee Meetings

a. June 26, 1986 -

Operational Readiness of Seabrook Unit 1

b. August 6, 1986 - Seabrook Station Risk Management and Emergency Planning (RMEP) Study and Emergency Planning Sensitivity (EPS)

Study .

c. September 4, 1986 - Seabrook Fire Hazards Analysis  !

d. September 8-9, 1986- NRR &' Brookhaven National Laboratory (BNL) Site Tour for RMEP & EPS Studies ,

e. September 23, 1986 - RMEP & EPS Studies

f. March 18, 1987 - Seabrook Unit i Licensing Issues

g. March 25, 1987 - BNL Report on RMEP & EPS Studies

h. May 7, 1987 -

Seabrook Unit 1 Licensing Issues

1. July 30, 1987 - Utility Compensatory E-Plan for Massachusetts

2. Commission & ASLB/ASLAB Decisions

a. October 17, 1986 - Issuance of Facility Operating License (NPF-56) for Zero Power Testing l

b. November 20, 1986 - ASt.AB Denial of Zero Power License I Appeal (ALAB-853) by Massachusetts I

c. January 9, 1987 - Commission Review of ALAB-853 Stays Issuance of Low Power License l l

l l

l

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- 42

d. March 25, 1987 -

ASLB Issuance of Partial Initial Decision on Low Power Licehse

e. April 9, 1987 -

Comi ssion Order (CLI-87-02) Retains '

in Effect License Stay

f. April 22, 1987 -

Full Power ASLB Dental of Licensee Petition to Reduce EPZ

g. June 11, 1987 -

Comi ssion Order (CLI-87-03) Denies Licensee Motion to Lift License Stay t

+

1 4

8 J .

o+

TABLE 1 .

INSPECTION REPORT ACTIVITIES Report No. Inspection Hours Area (s) Inspected

• 86-09 74 Routine Inspection of General and System Operating Procedures 86-19 86 Routine Inspection of Preoperational Test Program 86-20 439 Routine Inspection of .

Construction Completion, Preoperational Testing, Training, TMI Action Plan and Previous Items 86-21 43 Routine Inspection of Previous Items

~

86-22 160 Routine Inspection of Chemistry, Effluent Controls and Radioactive

- Waste Programs 86-23 122 Routine Inspection of QA' Program and Previous items 86-24 37 Routine Inspection of Records Related to Reactor Vessel and Internals and Previous Items 86-25 123 Routine Inspection of Occupational Radiological Protection Program 86-26 33 Routine Inspection of Nuclear Material Control and Accounting 86-27 240 Special Team Inspection Comparing Technical Specifications to As-Built Plant 86-28 135 Routine Inspection of Operational Readiness and Previous Items 86-29 74 Routine Inspection of Security' Plan and Implementing Procedures 8

---

,,--_nn y-- , - - , - ,n, , _. ,, , , , - - . , , - - - . , ,,_,--,__---.,-,--.-n-., , _ - - - w---- . -c, mee,,,,-v- - - - - , -

l

. l l

2 [

Taole 1 Inspection Hour; -Ares (s) Inspected Report No.

I Routine Inspection to Follow up 86-30 -

113 Emergency Plan Implementation Appraisal and Previous Itecs 32 Routine Inspection of Startup 86-31 Test Program ud Procedures Routine Inspection of Fire f 86-32 27 j Protection Program 37 Routine Inspection of Abnormal 86-33 and Emergency Operating Procedures and Previous Items 333 Routine Inspection of 86-34 - Construction Completion, System Design, TMI Action Plan and Previous Items  ;

110 Routine Inspection of Chemistry, 86-35 Effluent Controls and Rndwaste Programs 91 Routine Inspection of Operational 86-36 l Readiness and Previous Items 88 Routinit Inspection of 86-37 Preoperational Test Program  !

32 Routine Inspection of 86-38 Radiological Environmental Monitoring Program 79 Routine Inspection of 86-39 Occupational Radiological Controls Program 47 Routine Inspection of 86-40 Preoperational Test Program 44 Routine Inspection of Security 86-41 Plan and Procedures

- Inspection Number Not Used 86-42

l l

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. j 3 .

Table 1 I l

Report No. Inspection Hours ire; Jnspeeted 115 Routine Inspection of Seismic 86-43 Piping Systems, Pre-Service Inspection Program and As-Built Plant 68 Routine Inspection of Effluents 86-44 Control and Radwaste Programs 36 Routine Inspection of Electrical 86-45 and I&C Procedures and Previous Items  ;

I 350 Routine Inspection of 86-46 Construction Completion Activities, Design Changes, As-Builts. TMI Action Plan, Previous Items 428 Routine Inspection of Testing, 86-47 License Issuance, Core Loading, Maintenance, Surveillance, Operations and Previous Items 48 - Routine Inspection of Startup 86-48 Test Program and Procedures; Review of Containment Sit Report i 39 Rautine Inspection o# Pre-Service 86-49 Inspection Fregram and Records and Previous Items i

131 Aoutine Inspection of Initial 4 86-50 Fuel Letding Activities l l

C7 Special Team Inspection To Review 86-51 Allegation of As-Built Drawin?

Discrepancies 478 Special Team Inspectio* i: *eview ,

86-52 l

' Allegations by ELP l

- Inspection Number Not Used d4 -5'3 187 Routine Inspection of Operations,

%-54 Maintenance, Survaillance.

l Startup Testing and Previous Items l

i

l

- Table *1 4.

Report No. Inspection Hours Area (s)InsSected 86-55 40 Routine Inspection of Occupational Radiologica!

Controls Program and Previous Items 86-56 24 Routine Inspection of Physical Security Program and Previous Items 86-57

- Inspection Number Not Used 86-58 118 Special Team Inspection To Review Licensee Action on GL 83-28, ATWS 87-01 128 Routine Inspection of Preoperational Test Program, Test Procedure Review, Test Witnessing and Test Results Evaluation 87-0? 432 Routine Inspection of Post-Core Loading Heat-Up and HFT, Maintenance, Surveillance,

- Operations and Previous Items 87.-03 56 Routine Inspection of I&C Surveillance Test Program 87-04 30 Routine Inspection of Radwaste Program and Pre 0perational Test Results Evaluation 87-05 69 R;.utine Inspection of Startup Test Program, Pott-Core Leading Hot Functional Testing and Test Rasults Evaluation 87-06

- Inspection Number Not Used 87-07 583 Special Team Inspection of Allegations Raised by Elp 87-08 26 Special Inspection to Follow-up Unusual Event of 02/11/87 87-09 34 Routine Inspection of Post-Core Loading Hot Functional Testing i

e

_ . _ _ . _ _ ,_____.. _ _ . . _ _ _c _ _ _ _ , _.w_.y-y,.. .-.w_,_- . _ _ . . - , . . -. _ - _ , _ _ , , . . . , , . . , _ _ _ _ . , . . , _ , , - , . . . . , , , , _ - ,

, a Table 1 .

5 I

Report No. Inspection Hours Area (s) Inspected 87-10 346 Routine Inspection of Post-Core Loading Heat Up and HFT and Cooldown, Maintenance, Training, Operations and Previous Items 1 87-11 32 Routine Inspection of Startup Test Program, Post-Core Loading H,t Functional Test Witnessing and Test Results Evaluation 87-12 54 Routine Inspection of EP Program, Organization and Management Control, Training and Previous Items 87-13 268 Routine Inspection of Design Control Program, Testing, Maintenance, Surveillance and Previous Items 87-14 34 Routine Inspection of Occupational Radiological Controls Progra.a 87-15 33 Routine Inspection of Non-Radiological Chemistry Program 87-17 " - Operator Licensing Examination l I

87-18 35 Special Inspection of Service '

Water Valve Repairs 87-19 - Operator Licensing Examination 87-20 34 Routine Inspection of Equipment Tagging and Temporary Modification Programs

• First inspection conducted during this SALP period was IR 86-19, 86-09 was subsequently conducted out of sequence.

"87-16 report will be included in cext SALP period.

s, 'l - .

TABLE 2 INSPECTION HOUR

SUMMARY

HOURS FUNCTIONAL AREA Actual Annualized Percent Construction Completion 1349 1012 19.4 1.

Startup Testing 1244 932 17.8 2.

Plant Operations 2C67 2000 38.2 3.

Radiological Controls 739 554 10.6 4.

5. Emergency Preparedness 219 164 3.2 Security and Safeguards 175 130 2.5

6. ,

Engineering Support 579 434 8.3 7.

8. Licensing Activities -

9. Training and Qualification -

Effectiveness

10. Assurance of Quality -

TOTAL 6972 5226 100.0 4

e 4 2

TABLE 3 ENFORCENENT ACTIVITY A. Violations Versus Functional Area By Severity Level No. of Violations in Each Severity Level Functional Area V IV III II I Total Construction Completion 0 1.

Startup Testing 0 2.

Plant Operations 4 5 i

3. 1

4. Radiological Controls 0 1

5. Emergency Preparedness 1

6. Security and Safeguards ,

0

7. Engineering Support 0 Licensing Activities 0 8.

Training and Qualification 0

9. l

10. Assurance of Quality 0 TOTAL 7 7 7 7 7 f i 1

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Table 3 I 1

B. Summary Inspection Severity Functional Brief Requirement Level Area Description Number 86-46 10 CFR 50, 4 Operations seismic 2 Over 1 APP. B Controls For Temporary Equipment 86-47 10 CFR 50, 4 Operations Locked Valve APP. B Controls .

10 CFR 50, 4 Operations CBA System Not ,

87-02 APP.B Operated in /

Accordance With Design

. Requirements T.S.6.7.1 4 Emerg. Prep. Failure To Report 87 08 Unusual Event 10 CFR 50.59 4 Operations SW/SCW Temporary 87-13 Modification i

f B7-20 10 CFR 50, 5 Operations Tagging Program APP. B Deficiencies 1

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TABLE 4 l LICENSEE EVENT REPORTS A. LER By Functional Area l Number By Cause Code

• l 1

Functional Area A B C D E X l

1. Plant Operations B 2 4 3

2. Radiological Controls

3. Emergency Preparedness l

4. Security and S&feguards

5. Startup Testing ,

6. Licensing Activities

7. Construction Completion j

8. Engineering Support

9. Training Qualification and Effectiveness

10. Assurance of Qus11ty TOTAL 8 2 0 4 3 0 l

• Cause Codes  !

l A - Personnel crror '

B - Design, Manufacturing, Consttuction, or Installation Error l

C - External Cause D - Defective Procedures E - Component f ailure X - Other Cause Codes in this table are based on inspector evaluations and may differ from those specified in the LER.

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Table 4 2 .

l B. LER Synensit )

Summary Cause LER Number 86-001 Norn411y Locked Closed Valve Found A l Mispositioned 96-002 Inadvertent Safety Injection A I

ESF Actuation - Control Room A 86-003 Ventilation Isolation 87-001 ESF Actuation - Control Room E Venti 1& tion Isolation ESF Actuation - Loss of Offsite Power A 87-002 To Essential Switchgear Bus

.87-003 Source Range Analog Channel Operatio'nal A Tests Not Staggered 87-004 Containment Equipment Hatch Air Lock B Equalizing Valves Inoperable j 87-005 Main Control Board Indicators Not B l Properly Mounted 87-006 CSF Actuation - Loss of Power To Vital E Instrument Panel 87-007 Solid State Protection System Auto A Shunt Trip Test 87-008 Technical Specifications Daily Log A 87-009 ESF Actuation - Improper Tagout Of A MSIV Actuation 87-010 ESF Actuation - Main Feedwater 0 Isolation 87-011 ESF Actuation - Loss of Power To a 0 Vital Bus87-012 ESF Actuation - Failure of SI Reset E Switch .

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Table 4 . 3 l l

87-013 Area Temperature Monitoring In B Battery Rooms '

ESF Actuation - Start of EDG "B" 0 87-014 1

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"# ENCLOSURE 3 i

%'g UIHTED STATES  !

. 8 e NUCLEAR REGULATORY COMMISSION

{ ]j - ItSGION 1 get PAAm Avenue 1

\*...*/ mmo or PuusstA. etwasvLvAntA teeos 00T 261987 I

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Docket No. 50-443 Public Service Company of New Hampshire i ATTN: Mr. Robert J. Harrison President and Chief Executive Officer Post Office Box 330 Manchester, New Hampshire 03105 Gentlemen 1

Subject:

Systematic Assessment of Licensee Performance (SALP) Report .

Number 50-443/86-99 An NRC Region I SALP Board assessed the performance of Seabrook Station, Unit 1 for the period from April 1,1986 through July 31, 1987. The SALP Board found generally acceptable performance and evidence of continued cemitment to quality during the transition period from construction completion through preoperational testing to operations in accordance with the current license.

. Due to plant conditions and license limitations that exist.ed throughout this assessment period, h vever, the station and its personnel may not have been significantly challenged in many of the areas that were evaluated. Thus, management awareness and suppurt of the station's readiness to respond to the future challenges and sustain a high level of performance in these areas should be maintained. ,

A reeting in the vicinity of the Seabrook Site has been scheduled to discuss the Unit 1 assessment on Neverber 12, 1987. This meeting is intended to provide a forum for candid discussions of the performance evaluation. At the meeting, you should be prepared to discuss out assessments and your plans to enhance the program effectiveness in those areas which warrant additional attention. Additionally, you may provide written coments within 30 days after the meeting.

Following our meeting and receipt of your response, the SALP report and your response will be placed in the NRC Public Document Room.

Your cooperation is appreciated.

Sincerely,

.pN T h n'Jk Willian T. Russell Regional Administrator gnadamr

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Public Service Company of New 2 w ihire 00T.2 6 M'/

Enclosure:

NRC Region I SALP Report 50-443.86-99 cc w/ enc 1:

Seabrook Hearing Service List Ted. C. Feigenbaum, Vice President of Engineering and Quality Programs William B. Derrickson, Senior Vice President Warren J. Hall, Regulatory Services Manager Donald E. Moody, Station Manager Peter W. Agnes, Assistant Secretary of Public Sa'ety, Commonwealth of Massachusetts Employee's Legal Project Public Document Room (POR)

Local Public Document Room (LPDR) .

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachus'etts (2)

State of New Hampshire

. Chairman Zech Commissioner Roberts Commissioner Bernthal

Commissioner Chrr .

Commissioner Rogers I

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y~~.n fubac seMee of New HampeNro New HampaNre Yankee DMslon NYN- 88002 January 6, 1988 United States Nuclear Regulatory Commission Washington, DC 20535 Attention Document Control Desk

References:

(a). Facility Operating License No. NPF-56 Docket No. 50-443 (b) USNRC Letter. Dated October 26, 1987, ' Systematic Assessment of Licensee Performance (SALP)', Report Nog,50-443/86-99

Subject:

Response to SALP Rep'crt

. Gentlemen:

Pursuant to the SALP Management Meeting on December 9, 1987, New Ha=pshire Yankee (NFt) offers the following additional information regarding the functional areas of Plsnt Operations. Engineering Support, and Assurance of Quality as described in Reference (b).

Plant Coerations. Functi7nal Ares {},

In order to alleviate the burden of the paperwork /nonoperational workload placed on the Unit Shift Supervisor (USS), the work control process will be reviewed to determine areas where the workload can be transf erred f rom the USS to the equipment control group. The equipment control group will be comprised of operators which will be responsible for reviewing work requests.

Another area of concern vra the inattention to detail in routine daily operations. To resolve this concern, either the operations Manager or the Assistant Operations Manager is currently attending all requalification simulator er.ams to observe shift crews in an operating environment.

Additionally, a course is being developed which emphasizes the need to keep in mind the overall operational objectives, as well as details, while conducting an evolution guided by Station procedures. This course will be provided as part of the Annual Operator Regualification Program.

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United States Nuclear terulatory Cosmicsion January 6, 1948 Page 2 l Attention: Document. Control Desk

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l Innineerina Suncert. Functional Area #7 1 Engineering is now placing greater emphasis on interf acing with and responding to the needs of the Station staff as well as implementing the initiatives as discussed in the SALP report. Management will closely monitor ,

progress in these areas and will make further adjustments to engineering programs, as necessary, to f acilitate a strong teamwork approach.

Assurance of Quality. Functional Area #10 A formal review is being conducted of the manner in which operational problem areas are identified and analysed, and the role of Quality Assurance (QA) in the corrective action process. Initiatives have been and will j continue to be taken to assure that implementation of internal programs used to identify and correct material and progras deficiencies are both effective l and performance oriented. l i

'0!tiatives already in place include,the following:

1. Integrating the construction QA personnel into the operatione QA staff. This has resulted in a combined group with a greater range of )

technical expertise to identify and review problems.

2. Establishing a QA surveillance section to perform both preplanned and i programmatic surveillances, increasing interface with the NRC resident inspectors and initiating early independent reviews of l identified operational problem areas.

3. Relocating all QA personnel, including the Nuclear Quality Group (NQG) Manager, to the Opers.tions support Building in order to improve the timely support of Quality Control (QC) and early involvement by QA in the resolution of operational problems.

4. Establishing a quality Control Department Supervisor position to ,

provide more oversight of QC activities and to ensure that proper management attention is focused on resolution of problems.

5. Providing for more timely review and evaluation of Station Information Reports to identify generic prograrnatic weaknesses.

6. Upgrading and expanding the operational QA trending program through the use of a computerized data base to categorise prchlem areas and focus audit and inspection activities and management attention where l they will be most effective. .

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l January 6, 3988 United States Wuclear Regulatory Commission Page 5 Attention: Doctament Control Desh Management will continually assess quality program effectiveness, and it i is expected that additional initiatives will be takru, as necessary, to  !

enhance the overall program.

Should you hav6 say questions concerning our response, J 1ease contact )

Mr. Villiam J. Temple at (403) 474-9574, extension 5781.

Very truly yours, i George S. Thomas l 1

Desk l cc Document onte Unite tat Nucleaf[tegulatoryCoenission  ;

l Vas ngte . DC 2CE85 Mr. Victor Norsets, Project Manager Project Directorate I-5 Division of Reactor Projects United States Nuclear Regulatory Cossaissica Washington, DC 20555 Mr. A. C. Corne NRC Senior Resident Inspector Seabrook Station Seabrook, NB 03874 l

(l(OkSS) Mr. William T. Russell Regional Administrator United States Nuclear Regulatory Commission Region 1, 631 Park Avenue King of Prussia. PA 19406 (

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The Commission fully agrees that the goal of achieving a workplace' free of the effects of drugs and alcohol requires d6dicated efforts and cooperation by both management and employee representatives. However, the Commission believen that the fitness-for-duty programs in place today are at least as effective and comprehensive as those which would have betn established by now under the earlier proposed rule.

We hope that the efforts described above and in the enclosures will help resolve the concerns you raised.

Sincerely, Lando W. Zech, Jr.

Enclosures:

1. Response to Recommendations

2. Systematic Assessment of Licensee Performance Report, dtd 2/9/88 i

Reft CR-88-43 Originating Office: EDO/NRR OCA ......OCH .................

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• y,2,0,5 'l rDe!AMo yMARKEY

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' " " ' ' " " * ' Congress of ttje hittb 6tates -5.in m :=T:!Er) m,p ge4%

=i house of Representatibfg ,

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January 28, 1988 ,

l The Honorable Lando W. Zech, Jr. '

Chairman U.S. Nuclear Regulatory Commission 1717 H Street, N.W. I Washington, D.C. 20555 i

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Dear Mr. Chairman:

on October 28, 1986, I initiated an investigation into allegations of widespread drug and alcohol use at theconsiderable As you know, seabrook nuclear power plant. Enclosed is the result of that correspondence ensued.

investigation.

In the report, you will see that I an highly of critical of an unquestionable neglect on the part of the NRC to adequately address the problem of drug and alcohol use at the Seabrook plant in particular and also its failure to adopt meaningful and enforceable ritness for Duty regulations which would cover the critical period of a reactor's construction.

i Finally the evidence presented in this toport leads to one overriding conclusions it is essential that a thorough and independent safety review of seabrook be cor. ducted before ,

the plant is licensed for operation.

7herefore, I urge you to authorize an independent blue .

ribbon commission to conduct a safety review of the seabrook f acility. My staf f is available to discuss any aspect of this report at your convenience.

Sincerely, EdwardJ.Markfy j Member of Congress setspf 4  ;

d  %, UNITE 9 8TATES

! o NUCLEAR REGULATORY COMMISSION y

l WA&e4tNGTON, D. C. NES6

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EDO PRINCIPAL CORRESPONDENCE CONTROL FROMa~ DUE: 03/16/88 EDO CONTROL: 003546 DOC DT: 03/03/88 REP. EDWARD J. MARKEY FINAL REPLY:

TO:

CHAIRMAN ZECH FOR SIGNATURE OF ** PRIORITY ** SECY NO: 88-174 CHAIRMAN DESC: ROUTING:

ALLEGATIONS OF DRUG AND ALCOHOL ABUSE DURING THE STELLO I CONSTRUCTION OF SEABROOK TAYLDR I REHM 1 DATE: 03/05/88 RUSSELL ]

ASSIGNED TO: NRR CONTACT: MURLEY HAYES '

MURRAY l I

CPECIAL INSTRUCTIONS OR REMARKS:

REF. EDO 3458 l

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9 OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-88-0174 LOGGING DATE: Mar 3 88 ACTION OFFICE: EDO t

AUTHOR: E.J. Markey ,

AFFILIATION: U.S. HOUSE OF REPRESENTATIVES '

LETTER DATE: Mar 3 88 FILE CODE: ID&R-5 Seabrook

SUBJECT:

Allegations of drug and alcohol abuse during the construction of the Seabrook nuc power plant <

ACTION: Signature of Chairman DISTRIBUTION: OCA to Ack, RF SPECIAL HANDLING: None NOTES:

i DATE DUE: Mar 18 88 i SIGNATURE: . DATE SIGNED:

AFFILIATION:

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• • • eV#nA"*iuOi March 3, 1988 Honorable Lando W. Zech, Jr.

Chairman U.S. Nuclear Regulatory Commission 1717 H Street N.W.

Washington, D.C. 20555

Dear Chairman Zech:

I have received your letter of March 2, 1988 in response to the report I released on January 28, 1988 regarding allegations of drug and alcohol abuse during the construction of the Seabrook nuclear power plant.

I was deeply troubled by the lack of any specific reference whatsoever in your letter to the details of that report.

Moreover, the Commission's and staff's apparent ignorance about the report's contents was underscored during your appearance today before the House Interior and Insular Affairs Committee, Subcommittee on Energy and the Environment. Neither you nor the NRC's Director of Nuclear Reactor Regulation demonstrated any awareness of important allegations contained in that report --

for example, that the company reportedly responsible for testing the concrete at Seabrook was dismissed because of the number of times drugs and alcohol were found at their on-site facilities. 1 (See the affidavit of Mr. Peter McKinnon, appended as an attachment to the report.)

I include as an attachment to thir letter a sworn affidavit I obtained from the former Assistant Director of Construction at Seabrook which supports Mr. McKinnon's allegation that the concrete testing company was dismissed for reasons related to d:ugs and alcohol. In addition, this new affidavit indicates that l 1

even though the Assistant Director of Construction believes he l ordinarily would have been informed about drug and alcohol l

discoveries on-site, he had been told nothing about the discovery ,

of $10,000 worth of cocaine inside the protected area in a I three-day period in June 1986. I fail to understand why I should be able to obtain such information so easily while the NRC remains in the dark, particularly after the Commission and its huge staff have had more than a month to examine my report of January 28th.

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The Honorable Lando W. Zech, Jr.

Page 2 March 3, 1988 The Commission's bland assurances which say essentially that "Seabrook is safe, no matter what" reflect little awareness of the detailed allegations that have been made about drug and alcohol use during construction, and indicate no effort on the part of the Commission staff to determine whether such incidents may have compromised the safety of the plant. For instance, your assertions that "no new technical issues concerning the construction of the Seabrook plant have been identified" and that "the adequacy of the plant physical construction has been verified through...the licensee's approved and detailed construction and testing program" (emphasis added) ring particularly hollow in light of the NRC's ignorance of the allegations regarding the concrete testing company. If the concrete testing program at Seabrook was compromised by drugs and alcohol, how can the NRC be certain that essential systems and components are indeed safe? ,

In addition, I cannot understand why the Commission has not investigated the issue of whether the licensee failed to comply with Part 21 of the Commission's regulations in not reporting either the alleged problem with the concrete testing company or the discovery of roughly 100 grams of cocaine on-site in June 1986. It also appears to me that the dismissal of the concrete testing company should raise the most serious questions about the adequacy of the Quality Assurance and Quality Control programs.

Moreover, if you add to this list the other allegations in the report, the company's attempt to withhold information from '

Congress, and the failure to inform the NRC about at least 561 drug and alcohol incidents during 1982-1987 and almost 300 terminations in the same period, I cannot comprehend why the NRC has not raised the issue of management competence and integrity.

Is this really the kind of "performance to date (which] indicates that utility management would operate the plant in a responsi'ble manner should they be granted a license to do so"? ,

I hope the Commission will investigate these matters thoroughly and provide me with a complete report on the outcome of those investigations. And I continue to believe that only an independent, comprehensive, and thorough investigation will answer the question of whether or not the plant's construction has been compromised.

Sincerely, Edward J. Markey

Member of Congress

n . 1 i

i The Honorable Lando W. zech, Jr.

Page 3 t March 3, 1988  ;

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cc: The Honorable Morris K. Udall, Chairman -

Committee on Interior and Insular Affairs j i

The Honorable Philip R. Sharp, Chairman*

, Subcommittee on Energy and Power ,

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i AFFIDAVIT F

I, JOHN POWELL, being first duly sworn, depose and say the following:

1. My name is John Powell.

2. I served as Assistant Construction Director for the Seabrook nuclear power plant from March 1984 to September 1986.

3. If a substantial amount of a controlled substance or i

alcohol were found on the site, I ordinarily would have been contacted and would have been informed.

4. On February 25, 1988 I was told for the first time that i

approximately 100 grams of cocaine, with an estim6ted street value of $10,000, had been found inside the protected area at Seabrook within a three-day period in June, 1986. I was never informed of these cocaine discoveries during the time I served at the site.

5. In December, 1985, Peter McKinnon and I found marijuana ,

at the on-site facilities of Pittsburgh Testing Laboratories, the 4

i company charged with inspection and quality assurance testing of the concrete poured at Seabrook. I was aware that Peter McKinnon had previously found evidence of drug and alcohol use at their facilities, even though I had not personally been involved in i l

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l those discoveries.

6. As a consequence of the December 1985 marijuana discovery, I recommended to the Director of Construction that Pittsburgh Testing Laboratories be discharged, and within a few days the company was dismissed from further work at the site.

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7. I had assumed that the Nuclear Regulatory Commission (NRC) would be informed of this action. However, I am not aware whether the NRC was ever informed of the fact that Pittsburgh Testing Laboratories had been discharged from the site because of the discovery of marijuana at their facilities.

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JOHN POWELL Datedt fAA. SS, N Personally appeared before me this J d, day of L.h . ,

1988, JOHN POWELL, who acknowledged the above and foregoing facts and statement to be true and correct to the best of his belief and knowledge.

,hbf kA LC' No o~ry Public/ Justice of the Pdece My Commission Expires: l Rtuy h!'> !Te tf F;;"h at brze.

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