ML20196G637

Responds to & Investigative Rept on Drug & Alcohol Abuse at Plant.Commission Believes That Existing fitness-for-duty Programs Are as Effective as Those Which Would Have Been Established by Earlier Proposal.Rept Encl

ML20196G637
Person / Time
Site:	Seabrook
Issue date:	03/02/1988
From:	Zech L NRC COMMISSION (OCM)
To:	Markey E HOUSE OF REP.
Shared Package
ML20147J287	List: ML20147J278 ML20196G637 ML20196G722
References
NUDOCS 8803090286
Download: ML20196G637 (10)

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Docket File l--NRC-PDR EDO 3458

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TRehm DMossburg WRussell, RI CHAIRMAN March 2, 1988 BHaye's, 01 JMurray, GC

'fo g TMurley/JSniezek FMiraglia The Honorable Edward J. Markey 9'f FGillespie SVarga United States House of Representatives EReis, 0GC Washington, D. C.

20515 WKane, RI JPartlow

Dear Congressman Markey:

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

reviewed your report and advises us that no new issues have been raised to support the contention that the safe operation of the is in question due to construction deficiencies Seabrook plant More detailed comments caused by drug or alcohol abuse.addres sing the six recommendations in.

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 constructionThe staff is manner that would indicate that it can be safely operate management.

performance to date indicates that utility management would operate the plant in a responsible manner should they be granted a, the most recent NRC Systematic licerse to do so.

issued Assessment of Licensee Performance (SALP) Report February 2, 1988, provides a detailed summary of the NRC staff's views regarding the adequacy of construction and preoperationalThe C testing activities at Seabrook.

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 develop rulemaking options for our consideration and l

Although the proposed rule deals i

publication for public comment.

primarily with drug use at operating reactors, in conjunction with I

this rulemaking process we expect to consider the extent to which fitness for duty requirements can be made applicable to reactor As described further in Enclosure 1, construction activities.

this action is consistent with the Commission's origina 1986 policy statement on gained under the Commission's August fitiieis f or duty.

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-~W "J The Commission fully agrees that the goal of achieving a workplace 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 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 Ref:

CR-88-43 Originating Office:

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RESPONSE TO RECOMMENDATIONS Recomendation 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.

The 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 cw review, we conclude that no new technical issues 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 she "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 m et 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 cod completed construction activities, a quality as w ance 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.

l l

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

l An integrated startup test program that demonstrates that the plant will respond to a specified set of I

transients for which it has been designed.

ENCLOSURE 1 1

Response to Recommendations 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 redundancy and diversity are designed and constructed into all safety systems so that safe operation of the plant does not rely on a single level of protection.

The NRC inspection effort at Seabrook has been and continues to be extensive, with more than 26,000 inspection-hours expended to date. The progran, which consists of routine resident inspections, construction team inspections, and special team inspections, has examineo both progrannatic and functional aspects of the construction activities, as noted below:

Routine Inspections A Senior Construction Resident Inspector and Con-struction Resident Inspector--by direct observation, 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 the site and at the engineering offices, quality performance in the areas of soils and fcundations, containment ard other safety-related structures, support activities and systens, 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 Region I Construction Assessment team inspection (June /

July 1982) - This inspection evaluated the licensee's project management effectiveness by performing detailed examinations of quality assurance, construction control _,

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

Response _to Recommendations 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 Team inspectior.

(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) -

The purpose of this inspection 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 I 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 inspection 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.

i,

,h Region I Technical Specification Inspection (May 1986) - The purpose of this inspection was to detennine 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 by the Employee's Legal Project (ELP) and others.

These response efforts 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.

Response to Recomendations 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.

Recomendation 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 disposal of seized drugs and paraphernalia, a potential "cover-up" of certain drug-related episodes in particular in areas housing executive offices, and potential false statements to a Congressional comittee. The areas requested to be investigated are of a serious nature and nust be addressed by other State or Federal agencies, such as the State Police, the FBI, and others, as appropriate.

Recomendation 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 clcohol at the site.

Response 3.

The Comission fully agrees that the goal of achieving a workplace that is free of the effects of drugs and alcohol requires dedicated efforts and cooperation by both manage-ment ud employee 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 Comission policy statement. A copy of the appropriate section from the EEI guide concerning union relationships is attached.

It includes provisions for the use of outside experts in working with employee representatives.

Recomendation 4.

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

L

Response to Recommendations Response 4.

Concerning NRC's policy on fitness for duty regulations, the investigative report asserts that the Comission 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 Congressman Markey, dated December 9, 1986 and January 20, 1987 (as well as in an August 14, 1987 letter to Congressman Gejdenson, included as a reference in the investigative report), the Comission explained the rationale supporting our decisions and policy regarding fitness for duty.

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

In December 1987, the Comission was briefed by the Nuclear Utility Management and Resources Council (NUMARC) and the NRC staff on their evaluations of the effectiveness of the industry initiative. The staff reported that, while continued improvements are needed in some areas, the 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 discussions with the staff and with industry representa-tives did, however, result in identification of the need to make a regulatory decision, at the Federal government level, on the need for random, unannounced drug testing of nuclear power plant personnel. Accordingly, the staff has been instructed to develop for the Comission's consideration proposed rulemaking that includes various options for random testing. We expect to ecmplete this process and issue a proposed regulation for public ccment 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 comitment has been met.

In fact, 22 of the 54 nuclear utilities have implemerted random testing programs, an element of testing that goes beyond the general industry comitment. Other utilities have attempted to establish random testing, but

Response to Recomendations 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 instituting additional testing.

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

In sumary, notwithstanding the investigt.tive report, the Comission continues to believe that its decisions on this matter have been responsible ones. We believe that fitness for duty programs in place today are at least as effective and comprehensive as those that would have been established by now under the earlier, proposed rule. Significant improvements have been made and the experience gained provides the basis for responsibly building further improvements.

Recomendation 5.

The NRC should audit other utilities to detennine whether the kinds of alcohol and drug related terminations which occurred at Seabrook also occurred at other pit;t 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 Comission's policy staterent on fitness for duty, the Headquarters staff corducted nine special inspections, eight at operat-ing plants and one at a plant nearing readiness for licens-ing. Several of these inspections included reviews at tho i

corporate offices of utilities that are responsible for both operating plants and construction sites. Ourobjec-tive during these inspections was not to gather statistics on past alcohol and drug-related terminations. 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 prcept 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.

I

Response to Recomendations NRC regulations that took effect in October 1987 require that licensees report cases of dreg involvement by persons with unescorted access to operating nuclear power plants.

Recomendation 6.

Appropriate rate setting authorities should undertake prudence reviews.

Response 6.

The Comission has no authority to set rates and therefore has no coment on this recomendation.

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6. Union Briefing safety hazards of drugs and alcohol and the Most utilities have collective bargaining effects that off thejob use can have on on-agreements with unions governing wages, the job performancc, The briefing should hours and working conditions. The company, stress that the company intends to administer however, has the right to establish policies this policy in a uniform manner, and that all and rules for the safe and effective operation supervisors will be given thorough training on of its plants and equipment. Company rules fitness for duty standards and their responsi-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 discriminat d should be welcomed policy will be applieel to management as well by unions and management alike.

as bargaining unit personnel, and that it has When implementing a new or revised com.

been reviewed from a legal, labor relations, pany drug and alcohol / fitness for duty policy, security, operational and safety standpoint, briefing of union leadership (where a collec.

The senior company official present nr an 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 leadership and, to viduals 18 to 25 years of age uses an illicit be most effective, should take place prior to drug at least once a month; industry alone has communication of the company's drug and a productivity loss in excess of $50 billion alcohollfitness for duty policy to employees from drug and alcohol abuse; and in 18 U.S.

and supervisors.

railroad incidents In which alcohol and drug The union briefing should focus nn estab-use was involved,25 railroad 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 were injured, for an effective health and safety program that and an entire town of 3,000 people had to be affects their membership. During the briefing.

evacuated because railroad employees 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 tecting the safety and jobs of the non-drug 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 emphasized that drug and program and the company's willingness to alcohol impairment may cause accidents, help its employees overcome substance reduce productivity, damage or destroy plant abuse and other problems affecting job per-and equipment, increase costs, and reduce formance should be emphasized to the union the level of confidence in the company on the representatives. However, it should also be part of the public, regulators, media, and pointed out that access to the EAP is not necessarily a substitute for disciplinary consumers, measures.

The briefing team might include an outside medical or other health professional to pro-vide a perspective to the union on current steps other companies are taking with respect to drug and alcohol abuse and fitness for duty, and providing an insight into the health and l

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FEB 021988 m

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

Subject:

Systematic Assessment of Licensee Performance (SALP) Report Number 50-443/86-99 This refers to the SALP for the Seabrook Station, conducted by this office on September 17 ana October 2,1987, and discussed with your staff at a meeting on December 9, 1987.

The list of meeting participants is attached 'as.

The NRC Region I SALP Report, covering th> neriod April 1,1986 through July 31,1987, is provided as Enclosure 2.

This report was not amended as a result of our meeting with your staff and remains, in it: 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

• i 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 period is that your performance 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 r 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 fact, as well as a willingness to implement new programmatic initiatives where necessary.

No reply to this letter is required. We believe that our meeting with you and t

the resulting interchange of information were beneficial and improved the mutual understanding of your activities and our regulatory program.

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OFFICIAL RECORO COPY SALP LTR SEABROOK 86 0001.0.0 \\',

01/26/88 ENCLOSURE 2

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Public. Service Company ~of

-2 FEB 021988 New Hampshire Your cooperation is appreciated.

Sincerely,

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ORl gin.i.L SiGED BY:

JAMB M. ALLN1 g William T. Russeil Regional Administrator

Enclosures:

1.

December 9, 1987 SALP Management Meeting Attendees 2.

USNRC Region I SALP Report 50-443/86-99 3.

'USNRC Region.I Letter, W. T. Russell to R. J. Harrison, October 26, 1987 4

PSNH letter, NYN-38002 (Response to SALP Report), January 6,1988 p

cc w/ennis:

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

G. S. Thomas, Vice President - Nuclear Production, NHY T. C. Feigenbaum, Vice President of Engineering and Quality Programs, NHY

'0 J. Hall, Regulatory Services Manager, NHY 0, ti. Moody, Station Manager, NHY P. W. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Employee's Legal Project Public Document Room (POR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC) lNRC Resident Inspector State of New Hampshire f.'

Commonwealth of Massachusetts (2)

Seabrook Hearing Service List i

Chairman Zech Commissioner Roberts r

Commissioner Bernthal Commissioner Carr

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Commissioner Rogers INPO (Record Center, INPO)

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bec w/encis:

J. Taylor, DE30' T. Murley, 0/NRR B. Boger, AD/RI, NRR V. Nerses, PM, NRR

'E. Trottier, NRR W. Russell, RA J. Allan, ORA

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Kane, ORP J. Wiggins, ORP

0. Haverkamp, DRP A. Cerne, SRI Seabrook 7

0. Ruscitto, RI'- Seabrook W. Johnston, DRS T. Martin, DRSS R. Bores, DRSS l

Region I Docket Room (with concurrences)

Management Assistant, ORMA (w/o encis)

~0. Holody, EC ORP WISHLIST Coordinators (2)

K. Abraham, PA0 (20)

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...i Seabrook 1 Service Hearing List i

Thomas Dignan, Esq E. Tupper Kinger, Esq.

John.A. Ritscher,' Esq.

Assistant Attorney General Ropes and Gray Office of Attorney General 225 Franklin Street 203 State House Annex

. Boston, Massachusetts 02110 Concord, New Hampshire 03301 Mr. Bruce Beckley, Project Manager Resident Inspector New Hampshire Yankee Seabrook Nuclear Power Station P.O. Box 330 c/o U.S. Nuclear Regulatory Comm.

I Manchester, New Hampshire 03105 P. O. Box 1149 Seabrook, New Hampshire 03874 Or. Murray Tye, President Mr. John C. DeVincentis, Director Sunn Valley Association Engineering and Licensing

.209 Summer Street Yankee Atomic Electric Company Haverhill, Massachusetts C3139 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 o

State House Station # 6 20001 S. Street, N.W.

Augusta, Maine 04333 Suite 430 Washington, D.C.

20009 Jo Ann Shotwell, Esq.

O. 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 i

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

T 2

Mr.-Calvin A. Canney, City Manager Senator Gordon J. Humphrey

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City Hall AT1N:

Tom Burack 126 Daniel' Street U.S. Senate Portsmouth, New Hampshire 03810 Washington 0.C.

20510 Ms. Letty Hett Mr. Owen B. Durgin, Chairman Town of-Brentwood Ourham Board of Selectmen RF0 Dalton Road Town of Durham Exeter, New Hampshire 03833 Durham, hew Hampshire 03824 Ms. Roberta C. Pevear Charles Cross, Esq.

Town of Hampton Falls Shatnes, Mardrigan, 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 Hall c/o Rye Town Hall South Hampton, New.H&mpshire 03827 10 Central Road Rye, New Hampshire 03870 Mr. Angie Machiros, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Comm.

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

. 25 High Road Room 8105 Nawbury, Massachusetts 01950 Washington, 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 Honorablo 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, Massachusetts 01950 Me. Warren J. Hall Mr. William B. Derrickson Puolic 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

.s 3

Administrative Judge Administrative Judge Alan S. Rosenthal, Chairman Bary J. Edles Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Administrative Judge Howard A. Wilber Helen F. Ibyt, Chairman Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 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 I

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 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. Thom n Carol S. Sneider, Esq.

Federal Emergency Management Agency Assistant Attorney General 442 J. W. McCormack (P0CH)

Office of the Attorney General Boston, Massachusetts 02109 One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Paul McEachern, Esq.

Richard A. Haaps, Esq Shaines and McEachern Haaps and McNicholas 25 Maplewook Avenue 35 Pleasant Street Portsmouth, N!w Harpshire 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 Streat Kensington, New Hampshire 03827 Exeter, New Hampshire 03833

[

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, Mass'achusetts 01913 Michael ~$antosuosso, 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 Se';ctmen 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 03842 Hampton, New Hampshire 03842 Jane Doughty Seacoast Anti-Pollution League 5 Market Street Portsmouth, New Hampshire 03801

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ENCLOSURE 1 December 9, 1987 SAlp Management Me,eting Attendees I

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

0. E. Moody, Station Manager, NHY 2.

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

J. T. Wiggins, Chief, Reactor Projects Branch No. 3, ORP R. Haverkamp, Chief, Reactor Projects Section No. SC, ORP 0.,Nerses, Licensing Project Manager, Project Directorate I-3, NRR V.

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 COMMISSION REGION I SYSTEMATIC ASSESSMENT.0F LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 86-99 PUBLI'C SERVICE COMPANY OF NEW HAMPSHIRE SEABROCK STATION, UNIT 1 ASSESSMENT PERIOD: APRIL 1, 1986 - JULY 31, 1987 BOARD MEETING DATE:

SEPTEMBER 17 AND OCTOBER 2, 1987 d

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t TABLE OF CONTENTS PAGE I.

INTR 00VCTION...............................................

1 II.

CRITERIA...................................................

2 III.

SUMMARY

OF RESULTS.........................................

3 1

l A.

Overall Facility Evaluation...........................

3 l

B.

Background............................................

4 C.

Facili ty Performance Analysi s Summary.................

7 IV.

PERFORMANCE ANALYSIS.......................................

8 A.

Construction Completion...............................

8 C.

Startup Testing.......................................

10 C.

Plant Gperations......................................

13 0.

9adiological Controls.................................

19 E.

En.o rg e n cy P re p a red n e s s................................

23 F.

S e c u.-i ty a n d S a f e g u a rd s...............................

25 G.

En g i ne e ri n g S up po r t...................................

28 H.

Licensing Activities..................................

31

'I.

Training and Qualification Effectiveness..............

33 J.

Assurance of Quality..................................

36 V.

SUPPORTING DATA AND SUMMARIES..............................

40 A.

Investigation and Allegation Review...................

40 B.

Escalated Enforcement Action..........................

40 C.

Management Conferences................................

40 D.

Review of Licensee Event Reports (LERs)...............

40 E.

Summary of Licensing Activities.......................

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

Table 2 - Inspection Hour Summary................................

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

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

s.

1.

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 conpliance with NRC regulations.

It is intended to be sufficiently diagnestic 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 ar.cordance with NRC Manual Chapter 0516 "Systematic Assessment 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'e 16-month period from April 1.,1986 through July 31, 1987.

The SALP Board was compose') of the following:

Chairman:

W. F. Kane, Director, Oivision of Reactor Projects (DRP)

Members:

T.

T.

Martin, Director, Division of Radiation Safety and Safeguards, (DRSS) (Part-Time)

J. P. Ourr, Actirg Deputy Director, Division of Reactor Safety (CRS)

J. T. Wiggins, f hief 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. Cerne, Senior Resident Inspector, Seabrook Other Attendees: (Non-Voting)

R. J. Bailey, Physical Security Inspector (DRSS) (Part-Time)

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 J. A. Schumacher, Senior Emergency Preparedness Specialist, DRSS (Part-Time)

M.

M.

Shanbaky, Chief, Facilities Radiation Protection Section, CRSS (Part-Time)

R. M. Gallo, Chief, Operations Branch, DRS (Part-Time)

W.

J.

Lazarus, Chief. Emergency Preparedness Section, CRSS (Part-Time)

C. A. Carpenter, Reactor Engineer, DRP (Part-Time)

~

2 II.

CRITERIA Licensee performance is assessed in selected functional areas.

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

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).

7.

Training and qualification effectiveness.

Based upon the SALP Board assessment, each function'ai area evaluated is classified into one of three performance categories.

Inese are:

Category 1.

Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety 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-tion should be maintained at normal levels.

Catego ry 3.

Licensee management attention or involvement is acceptable and considers nuclear safety, but weauesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisf actory perfomance with respect to operational safety and construc-tion quality is being achieved.

Both NRC and licensee attention should be increased.

The SALP Board may determine to include an appraisai of the performance trend of a functional area. Normally, this performance trend is only used where both a definite trend of performance is discernable to the Board and the Board believes that continuation of the trend may result in a change of performance level. Improving (declining) trend is defined as: Licensee performance was determined to et improving (declining) near the close of the assessment period.

i

3 III.

SUMMARY

OF RESULTS A.

Overall Summary During this assessment period, a mak transition occurred as con-struction and preoperational testing were completed, and startup testing and operations under the technical specifications (TS) and license conditions commenced.

Throughout this transitional period, the licensee'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 licensee demonstrated the ability to conduct limited operations along with a state 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 cperations 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 TS 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 c^aditions.

The shutdown plant conditions and lack of radiological activity did not provide the realistic bases for such notifications.

As an example, durir.g 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, the 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 trinitt:en from construction to operations has pro-coeded in a relatively smoos5 manner, the latter part of this current assessment period provided soms 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 result, 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 subcategori6s of the appro-priate functional areas in this SALP, will become even more important for equipment preservation during prolonged periods of shutdown conditions.

In the past, licensea responsiveness to problematic issues and NRC initiatives has been appropriately directed.

In the future, even more aggressive and innovative corporate management involvement 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-stallation 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.

On October 17, 1986, a Facility Operating License was issued for Seabrook Station Unit 1.

Specific license conditions limited activ-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 lead was conducted during the period October 22 to 29, 1986.

Plant heat-up for the conduct of tho precritical phase of hot func-tional testing (HFT) commenced on February 9,1987. Over the follow-ing six weeks startup testing activities were in progress with the plant achieving normal operating temperature and pressure conditions and with the conduct of operations in accordance with Technical Specifications.and special license conditions. Most noticeable among

o 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 steam generator safety valve actuation on February 26, 1987, as a result of emergency feedwater (EFW) system testing. The conduct of specific tests on the steam-driven EFW pump itself was one of the more significant areas of tasting 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 component cooling water heat exchanger; and the inspection, lining configuration redesign, and lining repair and testing on several servicc water valves. As of the end of this assessment period, these repair activities were continuing with additional heat exchangers yet to be inspected and additional valves yet to'be relined.

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 preparedness (EP) activities.

In addi-tion to working with New Hampshire to improve the stat emergency response plan, which is the subject of ASLB hearings sc 3duled to commence in October, 1987, the licensee is formulating a utility plan with the stated capability to compensate for Massachusetts emergency response functions.

Submission of this plan to the NRC in September has received priority attention along with the conduct of other licensee EP activities required to meet the criteria provided by CLI-87-03 for issuance of a Icw power operating license.

Inspection Activities Two NRC resident inspectors were assigned to the site during the assessment period. The NRC inspections 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 f acility Technical Specifications (May,1986); in re-sponse to the Unusual Event (February, 1987); and in three follow-up inspections of allegations raised regarding construction quality and the as-built conditions of the plant (October,1986; Novemoer,1986;

6 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 violation 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 areas 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'es "Training and Qualification Effectiveness" c

and "Assurance of Quality" as separate functional areas.

Although these topics, in themselves, are assessed in the other functional areas through their use as criterit, the two areas provide a synop-sis.

For example, quality assurance effectiveness has been assessed on a day-to-day basis by resident inspectors 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.

O 7

C.

Facility Performance Analysis Summary 1936 1987 FUNCTIONAL AREA CATEGORY CATEGORY TREND 1.

Construction Completion 1

1 2.

Startup Testing 1

1 l

3.

Plant Operations la 2

1 4.

Radiological Controls 5.

Emergency Preparedness 2

1 6.

Security and Safeguards 1

7.

Engineering Support 2

i

8. - LiceasingActivities 1

1

[

1 i

9.

Training and Qualification Effectiveness l

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.

"During the previous SALP period, Engineering Support was not evaluated as a separate Functional Area.

i i

f i

l r

i i

8 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'.')

1.

Analysis During the previous SALP assessment period, all of the construc-tion disciplines' were combined under one functional area.

Significant NRC inspection effort, including two team inspec-tions and an additional NDE Van inspection, revealed adequate control over construction processes by licensee management and few hardware deficiencies.

As construction was nearing com-pletion, as-built inspections by both the resident inspectors and regional specialists confirmed a high degree of plant conformance to the design bases and technical details provided by the FSAR. A Category I rating was determined, based upon an effective construction management program with resultant evidence of quality hardware, material, components and systems.

During this current SALP period, an assessment of construction completion was conducted to not only evaluate the plant's as-built quality, but also to provide an independent review of the results of inspection effort into allegations involving the plant 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 to investigate the validity of several allegations raised re-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 readi-ness of Seabrook Unit 1 for issuance of an operating license.

This review revealed both an aggressive construction management approach to the implementation of corrective measures, where necessary, and a responsiveness to NRC initiatives.

Routine inspection results also provided evidence that the licensee's internal as-built verification programs (e.g., the pipe support closeout task team, PAPSCOTT; and the cable tray and support qualification activities) had been implemented 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 noted.

A strong QA involve-ment in the conclusion of construction activities and in the assurance of quality records storage and retrievability con-tinued from the previous assessment period into this SALP.

$A 9

r P

An independent verificatier, of plant quality also arose from NRC followup _ of a number of allegations regarding the construction processes. Because of the nature of several of the stated con-cerns and the fact that they were raised after construction was essentially complete, the quality of hardware and ability of the as-constructed system to function as designed became the focus of a'multidisciplinary NRC-inspection effort. The effectiveness of licensee programs, which had been -inspected in progress over the course of construction, was revisited - and the qualification of personnel _ to perform safety-related activities reviewed.

Systems were opened and inspected; independent measurements were taken; tests in progress were witnessed; and both design and as-built construction records were reviewed.

.This collective NRC inspection effort to investigate the tech -

nical validity of several allegations did not identify new prob-lems, but instead confirmed the effectiveness of licensee cor-rective action in response to known problem areas and provided additional assurance of the measure of quality that construction completion has received.

2.

Conclusion Category 1 3.

Board Recommendation None

r.

10 8.

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

1.

Analysis 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 maintained l

during the entire SALP period and for the majority of the pre-operational test activities. Accordingly, this functional area 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 leading and post-core load testing, including another HFT. The completion of the preoperational test prograr and final closure of the remaining test exceptions proceedtd smoothly with the transition into the startup test prograa.

NRC inspection coverage of initial fuel loading, as a startur 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 NSSS 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 testing activities were delib-erate 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 exceptions were few and dispositioned in a technically appro-priate and thorough manner.

r

-st O

11 One significant testing issue regarding the emergency feedwater (EFW) system carried over fror, the original HFT, as difficulties had been encountered in the conduct of the turbine driven EN pump preoperational test.

The steam supply system to the Terry turbint 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 (5T-53) was formulated to verify system modification and design 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 generator 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 EFW 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-fled.

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 ue warranted, given that operating license conditions and technical specifications were in effect.

Tne licensee has attempted to address all NRC questions on this issue and has planned conduct of a special test (STp-101) to verify adequacy of the normal 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 problem areas, effect corrective measures, and retest as necessary.

Overall, the NHY startup testing program planning and implemen-tation have continued to provide the same level of technically competent confirmation of system and component adequacy, as was provided by the preoperational test program.

Licensee manage-ment and startup personnel continue to demonstrate not only a responsiveness to NRC concerns, but also a technical determina-tion to objectively verify EFW system operability.

1

\\

12 2.

Conclusion Category 1 3.

Board Recomendation None

n 13 C.

Plant Operations (2667 hours0.0309 days <br />0.741 hours <br />0.00441 weeks <br />0.00101 months <br />, 38.2*4) 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 level 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 surveillance 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 teen 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 assessment 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 procru was determined to contain certain weaknasses which 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 the 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.

1a l

14 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 in 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 problem areas, once identified by the NRC, has been thorough. Particularly in the areas of independent verification and the procedure j

consistency review,-quality products have resulted once the licensee dedicated sufficient resources to the corrective

measures, b)

Conduct of Operations Since Seabrook is not a fully operational plant, the basis for assessment in this sub-area is necessarily limited.

Notwithstanding the limited scope of licensee activities e

in this area, significant NRC inspection was conducted into i

routine operations, response to events / transients and TS interpretation / reporting.

f 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 ccmpetency 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.

l Their judgement is routinely conservative and demonstrates a safety censcious attitude.

Individual control room operators and shift supervisors are vigilant and knowledge-able and have taken a significant initiative in providing l

quality on-the-job training to licensed operator candidates on shift. As evidenced by a review of the LERs in Table 4 of this SALP, 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 (SI) while a F

t n

-4

'15 second SI was generated due to tagging procecural error.

On another occasion, a switch misoperation resulted in a diesel generator start.

In two separate events, substan-tial volumes of RWST water were inadvertently transferred, once to the containment and once to the refueling cavity.

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, daily operations.

Additional cperational 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-1ents and events, however, several minor occurrences war-rant discussion.

In addition to the events related to operator errors, discussed above, several other ESF actua-tions occurred. 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 were two inadvertent safety injection actuations caused by malfunctioning 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 as the event progressed.

This disagreement, relating to event classification and notification requirements, contri-buted to the delay in reporting and therefore resulted in the issuance of a violation.

Additional training and specific delegation of responsibility within the operations department were necessary to clarify operational duty roles within the Emergency Response Organization.

Some difficulties were initially experienced in the inter-pretation of Technical Specification (TS) limiting cendt-tions for operation (LCO) and the reportability of events under 10 CFR 50.72.

The most significant example was the handling of equipment and procedural problems associated with the control building air handling (CBA) system where

= :n i

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 ~1nterpreting these. requirements have

. improved, in the wake of the initial difficulties.

In another administrative

area, however, the paperwork /

nonoperational workload-of the Unit Shif t. Supervisor (USS) 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--

i cussion of the concern and merits further station manage-ment attention.

t With the exception of the potential problem related to the USS 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.

Certain problems attributable to inattention to detail have been experienced, but appear to have been appropriately disposi-tiened by station management.

The real effectiveness of i

licensee corrective actions in this area can only be measured during future hot testing and operations.

c)

Surveillance Ouring this period the licensee implemented the Westing-hcuse computerized TS Appraisal Program and began cor.duc-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-I quirements, thus enhancing the procedures and establishing baseline data.

Additionally, surveillance and operating procedures were utilized as much as possible during the test program to allow additional trial usage. While a few surveillance errors have occurred, the overall surveillance program has been effective. The licensee also established measures to strengthen this program with new initiatives involving TS log reviews and the surveillance procedure 1

consistency review program referred to in paragraph a) above.

l The NHY Program Support Department Staff which is respon-i sible for certain surveillance testit,g (e.g., ASME Section XI and 10 CFR 50, Appendix J) is highly competent and I

professional.

One notable example of this was the dis-covery by surveillance test engineers of the common mode

- 2

!?

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 surveillance 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.

Although the plant has not conducted sustained power oper-ations, challenging the capabilities of the surveillance programs, inspection to date which has sampled higher mode operations indicates that licensee efforts in this area are effective and. the programs are appropriately staffed.

d)

Maintenance The licensee has reorganized the maintenance support organ-ization, establishing separate Maintenance and Technical Support Departments. Electrical, mechanical, and I&C func-tions are performed by the maintenance department while system support is provided by individual system engineers who have been delegated responsibility for the separate systems. This organizational concept has provided consis-tency and accountability in the maintenance chain.

As a result, the Maintenance / Technical Support capability has been significantly strengthened.

The most visible example of this was the primary component cooling water neat ex-changer repairs where follow-up to this maintenance activ-ity led to identification of the service water valve lining problems, discussed in Section IV.G.

These two jobs re-quired considerable expenditure of maintenance resources, extensive hardware disassembly and complex special process controls. There has been extensive involvement by Station Technical Support Engineers in the maintenance area.

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) cantinues to demonstrate excellent maintenance tech-niques in the area of pre-staging, cleanliness, temporary support and storage and procedural adherence.

t 18 E

An additional licensee strength lies in the area of plan-c ning. and scheduling.: Daily ' plan of the day" meetings are effective in the coordf nation of. the diverse requirements of the many station deputments. The computerized planning schedule:is kept currtnt 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-

't established for each system on a rotating weekly basis.

Station maintenance has been conducted in a highly effec -

tive manner with no maintenance-related failure or events identified.

Future plant operations will provide more significant challenges, but the maintenance and repair l

activities conducted to date indicate well controlled efforts capable of supporting more complex operations.

Plant operations at Sabrook have been cenducted professionally, safely and conservatively.

Initial weaknesses in.the develop-ment of procedures and programs have, for the most part, -been cor ected.

Licensee efforts in strengthening the tagging pro-gram and the consistency review of operating procedures are ongraing.

The skills and knowledge of the licend operating l

staff remains a strength and initial problems with ina O ntion to detail have been overcome.

The maintenance and technica support organizations remain a significant asset.

2.

Conclusion Category 2 3.

Board Recommendation Licensee: Station management should emphasize attention to co-tail in the conduct of routine operations, assess the effectiveness and control of operational programs and

[

evaluate methods to reduce operational errors.

j NRC:

None l

I l

i

b:

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.

Analysh A Category 1 rating, as partsof the Operational-Readiness area, was provided for this area in the last assessment period based upon the observation that the licensee's operational readiness in the four radiological control areas (radiation protection, waste management, transportation and effluent control and men-itoring) exceeded that routinely found at similar plants at the same preoperational stage.

This fact was attributed to a high level of management commitment, the degree of preplanning and preparation, and the level of attention to detail.

This current assessment is based upon both an observation of ongoing plant activities and an evaluation of the programs which have been established.

Since radiological conditions at the plant were limited, the scope of this assessment necessarily emphasized programmatic and operational readiness

reviews, rather than demonstrated implementation of radiological con-trols.

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 review of the limited activities (e.g., fuel load) and the con-trols in evidence during their conduct.

Program areas include In-Plant Radiation Protection, Radioactive Waste Management, Ef fluent Controls, Nonradiological Water Chemistry, and Enyf ron-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 staff and management commitment to the program were evidenced by an increase ir; staffing level airned 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 action items. Formal and timely evaluation packages on previously identified NRC inspector concerns demonstrated licensee responsiveness and attention to these items.

As a further licensee initta-tive, a supplemental HP training program was developed and implemented.

During this period, the heen:ee's principal

T 20 -

.=

(corporate) health physicist and. the licensee QA'organiza-tion performed evaluations of the health physics (HP) pro-gram. The corporate review resulted in several recommenda-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 appraisal period, primary startup sources were installed in fuel assemblies in the fuel storage butiding.

The fuel assemblies were moved into containment and loaded into the reactor vessel.

Also, calibration of area and process radiation monitors and of other radiation detection instrumentation was conducted. The licensee reported mini-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 ccnducted during this assessment period.

In summary, the licensee has developed an aggressive radia-tion protection program in preparation for commercial oper-ation. Considering the nature of the activities conducted to date, effective radiological controls have been imple-mented. When areas for improvement have been ider.tified by either the licensee or NRC, site 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 chemistry management, involvement.

The radiological environmental monitoring program (REMP) is implemented through a clearly designated program which interfaces the site and corporate groups.

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

I

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

Although not required, the direct radiation monitoring environmental TLD program was found to include efforts to 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-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 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 opere ting reactor. Also, the inadequate calibration of instru-ments was noted. Follow-up inspection in these areas fouid considerable improvements in the sample analysis and quality control in the lab was upgraded. Again the lican-see management demonstrated involvement in the program land responsiveness to inspection rec 0mmendations.

Review of the water chemistry control program indicated a clearly defined policy, competent organization, effee:ive administrative procedures and adequate resources for imple-mentation. Based in part upon a study cone by the station chemistry department, the licensee continues to exolore additional enhancement options to the present p rog rare of all-volatile treatment (AVT) for secondary side water treatment.

22 t

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

?

a plant ready for operation.

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 i

performance during this period indicates that the site radio-logical, effluent control and chemistry programs. have been established with the capability to effectively sur9ert plant operations.

j 2.

Conclusion Category 1 3.

Board Recemmendations l

None f

L i.

t s

I r

e c

1

$.-)?

23 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 Term Operating License (NTOL) Emergency Preparedness Implementation Appraisal (EPIA) and the first full-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 off-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 management 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 includec 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.

Ltconsee management aggressively addressed NRC concerns resulting in the closure of twenty-two open items.

The remaining two open items are required to be corrected prior to issuance of a full power license.

A routine EP safety inspection, conducted in March, 1987, relate

• to inspection of the training program, operational status of the emergency pre-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 l

surrounding the classification of an Unusual Event on l

February 11, 1987 and the required notification process.

This special safety inspection identified a violation of the licen-l 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 l

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-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.1.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 swipment 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 personnel to fill the Key emergency response organization positions on a twenty-four hour basis are currently involved in qualification activities.

The lack of on-shift dose assessment capability hr.s been corrected and the addition of iodine deter-mination 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 c: operation provided by NHY on the resolu-tion of NRC issues concerning the emergency pian and procedures.

Additionally, significant effort has been expended by licensee management toward the resolution of of f site concerns. Although weaknesses in the training of supervisory personnel were uncov-ered during an Unusual Event, this incident was quickly and comprehensively addressed by licensee management.

Overall, the commitment and performance by the licensee in emergency preparedness remains high.

2.

Conclusion Category 1 3.

Board Recommendation None

25 F.

Security and Safeguards (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 equipment 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 suf ficient number of technical and support personnel resulted in sound designs, good planning, and timely procurement and installation. Such oversight underscores senior New Hampshire Yankee management's support for an effective security program.

Throughout the preoperational

phase, the licensee was responsive 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 developed feedback mechanisms to resolve security program issues.

This has resulted in security program enhancements being implemented at the Seabrook site.

Effective communications exist between the security organization 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 0 ganization and with other nuclear industry groups engaged in the development of security program standards and innovative approaches to security issues.

1 i

j 26 Twenty-four ' event reports were submitted in accordance with 10 CFR 73.71 during this period.

Twenty-two of tnese reports resulted from minor-problems-typical to those encountered during the startup and continued testing and maintenance of new secur-ity equipment and systems, including the security computer and its associated sof tware.

While the licensee's event reporting program was found to be acceptable, NRC evaluation revealed that several reports required further clarification from the licensee 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-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 both the contractor and proprietary staffs is encouraged by licensee management and reviewed in a timely manner. Special emphasis is currently being focused on the performance of security systems and equipment, and their reliability. This effort is intended to enhance the effectiveness of both short-term reactive and long-term 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 continuously 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

27 performance obiectives.

Security personnel involved in plan maintenance are knowledgeable of NRC requirements.

Addition-ally, the licensee's program and procedures to control and account _for special ~ nuclear material were reviewed and found to be adequate, as was the licensee's plan for the protection of special nuclear material of low strategic significance (new fuel).

In summary, the_ licensee has established an effective Physical Security Program.

Efforts to improve the operation and reli-ability of systems and equipment and personnel qualification have centinued.

The security program is actively supported by other plant functional groups, as evidenced by the lack of problems in the maintenance of security equipment, response to events and other areas where effective interfaces were nece s sa ry.

Both corporate and station management support of security programs and initiatives is evident.

2.

Conclusion Category 1 3.

Board Recommendation None

h 28 G,

Engineering Support (579 Hours, 8.3%)

1.

Analysis This area was not evaluated as a separate Functional Area during 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 assessed based upon the engineering services provided to the plant maintenance and modification processes, the analyses performed to address NRC concerns and self-identi-fied 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 engineering organization was established with a smaller in-house review capability than existed during the period of full con-struction and architect / engineer presence.

However, well de-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-

• 2in problems have arisen during this SALP period which high-iight 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.

29

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 equipment hatch airflock 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 valv'e 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 corrective action for a 10 CFR 50.55(e) report issued in 1985.

At that time, the original vain rubber-like linings were replaced by a "Belzona D&A" elastome.

However, it appears that both the replacement design and the construction bonding process were defective, resulting in the current problems.

The licensee's current approach to both the engineering and pro:ess controls required to repair these valves, however, appears to be thorough and well directed.

i In response to concerns raised by the NRC with respect to the engineering department interfaces with.the station staff, the licensee has implemented new initiatives to foster mutual co-operation and reliance on technical expertise to address prob-lems.

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 weaknesses are perceived.

.p 30 As was discussed in Section IV. A with respect to construction.

completion, engineering support activities related to the design reconciliation of the as-built plant (e.g., PAPSCOTT) were ef-fectively implemented to assure compliance with the design bases and FSAR commitments.

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 problems (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 sections of. this SALP report does, however, highlight the need for additional licensee attention to adequate control of the corractive work processes.

In summary, engineering services to the station construction 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-house engineeri.1g 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 p

31 H.

Licensing 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.

i t.e licensee has continued to demonstrate strengths in their 4

approach to problems from a safety standpoint, in the qualifi-cations and level of staffing and in.the active involvement of 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-answer any outstanding NRC questions.

Thus, on technical-i matters, effective communications between the licensee and the NRC staff have been beneficial in processing licensing actions.

The licensee facilitated timely resolution of the majority-of outstanding licensing issues.

In most cases, acceptable pro-posals were submitted with the initial licensee response.

The overall responsiveness to NRC initiatives was generally satis-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 licensing activities during this evaluation period. On several occasions, licensee management has demon-strated not only involvement in licensing, but also prompt, l

l

32

. appropriate corrective action to situations where the respon-siveness to NRC 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 resolve problems.

NHY licensing and engineering groups have been adequately staffed, as indicated by the qualified representatives attending numerous meetings with the NRC. Competent technical staff have 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-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.

2.

Conclusion Category 1 3.

Board Recommendation None i

t

r 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 also being considered as a separate area and as such, represents a synopsis of the assessments in the other areas. Training effec-tiveness is measured by observation of licensee personnel per-formance 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 training and qualification criteria, this assessment provides an overall evaluation of the effectiveness of control and conduct of licensee work activities.

In the last SALP period, this functional area was not evaluated separately, but. Operator Licensing was assessad a Category I 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 ir, the areas of simulator enhancement and efforts directed toward licensed operator training program accreditation by the Institute of Nuclear Power Operations

-(INPO).

4 The first group of operator licenses at Seabrook became due for renewal during this period.

Two year license renewals were issued for these individuals.

A requalification program eval-uation was also initiated to provide a basis for the license renewal.

To date, this evaluation 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 existing NHY requalification program. Training Depart-ment actions to address NRC identified generic weaknesses and strengthen the overall program have been initiated and appear well directed. As had been evident in previous, less formal 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 commit additional resources to upgrade identified areas of weakness.

e -

.}

34 It should be noted that another initial operator licensing examination was administered in August, 1987.

Although this examination was conducted shortly af ter 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 Seacrook Station.

A review of the LERs and enforcement actions issued during this SALP period identified certain problems related to training 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-plete 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, t

An evaluation of the LERs issued during this assessment-period identified no specific causal linkage between performance-

_i 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 areas 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 rec;ualification 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-nical programs have been effectively utilized. Region I special team inspections into allegations regarding Seabrook construc-tion hardware and programs revealed no specific disciplinary i

training deficiencies and no generic problems with the licensee program of education and handling of substance abuse policies.

r

?

^~

~

35

• ~

Thus, a review of licensee performance across the range of different 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 example 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 provided guidance to the technical staff for performance improvements.

In summary, in those areas where NRC and licensee evaluation have identified training related weaknesses, 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.

onclusion Category 1 3.

Board Recommendation s

None E-

36 J.

Assurance of Quality 1.

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

This appraisal of the assurance of quality is a synopsis of the applicable aspects of other areas, including worker and supervisor performance, management oversight, and safety review committee activities.

During the last SALP period, this functional area was assessed a Category 1 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 construc-tion processes to maintenance and modification activities. The interdependence of NHY QA policy and procedures with the Yankee Atomic Electric Company (YAEC) program was eliminated and key personnel responsibilities shifted accordingly.

It is note-worthy that the licensee retained sufficient experienced per-sonnel from contractor organizations (e.g.,

YAEC, VE&C, 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 action process has diminished.

This may be the result of and a normal consequence to the establishment of a strong station staff with particularly qualified and technically competent operations, maintenance and technical support groups.

However, one negative aspect of this has persisted throughout the current SALP period and relates to the feeling that the station staff can disposition their own problems without the need for QA involvement and that the QA staff mission relates more to pro-grammatic and procedural overview than it does to the effective-ness of controls.

y

37 NRC inspection issues which have highlighted this concern inclurie questions into tagging controls, station operating and surveillance procedures, the use of unauthorized operator aids, 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 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 rot 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 pr.:t, ras, is the effective use of quality control inspections and noicoints to confirm the proper conduct of special processes. The implementation of such QC measures has strengthened an already strong maintenance pro-gram in the area of independent checks and assurances of the adequacy of controls in the various disciplines. Another pro-grammatic strength is the individual expertise 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 wnich 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 tne successful functioning of the 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 evaluation;, and the analyses of component failures and human factor problems which have led 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 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 groups where necessary, have provided a measure of the licensee's ability to self-criticize and thus learn and improve with the corrective action process.

1

~

38 Another licensee internal review group, the Station Operation Review Committee- (SORC), has also been active during this assessment period in reviewing program and procedural revisions.

Some administrative problems in 50RC effectiveness were iden -

tified by the NRC with respect to the application of. safety review criteria to "nonintent" procedural changes.

Also, the 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 i

database which fails to track the valuable trending information available in documents other than nonconformance reports.

Licensee QA management was apprised of these concerns and has instituted program reviews intended to upgrade the defined cor-rective action prneess.

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.

l Overali, 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 emphasis on quality performance, to include 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

~the major noted to sustain the Assurance of Quality during transition from construction to operations.

A strong quality I

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 Category 2 h

A I-

39 3.

Board Recommendation Licensa+: New Hr pshire Yankee management shnuld reassess the role ci the QA organization in the analysis of opera-tionti-problems.

The licensee should consider expan-ding '.he scope of quality assurance functions to more effe w.ively utilize QA as n~ management tool to recog-niz, :he generic-impact of certain problems, and thus alb corrective action to be directed to related areas of programmatic weakness.

NRC:

None a

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40 V.

SUPPORTING DATA AND SUMMARIES A.

Investigation 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 inspection treated these allega-tions rigorously as technical issues to determine if some deficiency could be linked to safety-related activities. No linkage 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 hardwaye problems have been identified and thos2 that had existed have been adequately corrected.

B.

Escalated Enforcement Action None C.

Management Conferences 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 performance from January 1, 1985 to March 31, 1986.

D.

Review of Licensee Event Reports (LERs) 1.

Tabular Listing Refer to SALP Table 4 for Listing of LERs by Functional Area i

.y.

41

2., Causal Analysis Analysis of the LERs listed in Table 4 has identified no unac-ceptable chains per statistical acceptance criteria.

An AE00 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 licensee 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 Operational Readiness of Seabrook Unit 1

a. June 26, 1986 Seabrook Station Risk Management and

b. August 6, 1986 imergency Planning (RMEP) Study and Emergeacy Planning Sensitivity (EPS)

Study

c. September 4, 1986 -

Seabrook Fire Hazards Analysis

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

e. September 23, 1986 - RMEP & EPS Studies Seabrook Unit 1 Licensing Issues

f. March 18, 1987 BNL Report on RMEP & EPS Studies

g. March 25, 1987 Seabrook Unit 1 Licensing Issues

h. May 7, 1987 Utility Compensatory E-Plan for

1. July 30, 1987 Massachusetts 2.

Commission & ASLB/ASLAB Decisions

a. October 17, 1986 -

Issuance of Facility Operating License (NPF-56) for Zero Power Testing

b. November 20, 1986 -

ASLAB Denial of Zero Power License Appeal (ALAB-853) by Massachusetts Commission Review of ALAB-853 Stays

c. January 9, 1987 Issuance of Low Power License

P 42' ASLB Issuance of Partial Initial

d. March. 25, 1987 Decision on Low' Power License Commission Order (CLI-87-02). Retains

e. April 9, 1987 in Effect License stay Full Power ASLB Denial of Licensee

f. April 22, 1987-Petition to Reduce EPZ Commission Order (CLI-87-03)

Denies

g. June 11, 1987 Licensee Motion' to Lift License Stay 9

4 1

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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 itams 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

Table 1 2

Report No.

Inspection Hours _

Area (s) Inspected 86-30 113 Routine Inspection to Follow up Emergency Plan Implementation Appraisal and Previous Items 86-31 32 Routine Inspection of Startup Test Program and Procedures 86-32 27 Routine Inspection of Fire Protection Program 86-33 37 Routine Inspection of Abnormal and Emergency Operating Procedures and Previous Items 86-34 333 Routine Inspection of Construction Completion, System Design, TMI Action Plan and Previour Items 86-35 110 Routiae Inspection of Chemistry, Effluant Controls and Radwaste Programs 86-36 91 Routine Inspection of Operational Readiness and Previous Items 86-37 88 RouryneInspectionof Preoperational Test Program 86-38 32 Routine Iaspection of Radiological Environmental Monitoring Program 86-39 79 Routine Inspection of Occupational Radiological Controls Program 86-40 47 Routine Inspection of Preoperational Test Program 86-41 44 Routine Inspection of Security Plan and Procedures Inspection Number Not Used 86-42

Table 1 3

Foport No._

Inspection Hours Area (s) Insoected 86-43 115 Routine Inspection of Seismic Piping Systems, Pre-Service Inspection Program and As-Built Plant 86-44 68 Routine Inspection of Effluents Control and Radwaste Programs 86-45 36 Routine Inspection of Electrical and I&C Procedures and Previous Items 86-46 358 Routine Inspection of Construction Completion Activities, Design Changes, As-Builts, TMI Action Plan, Previous Items 86-47 428 Routine Inspection of Testing, License issuance, Core Loading, Maintenance, Surveillance, Operations and Previous Items 86-48 48 -

Routine Inspection of Startup Test Program and Procedures; Review of Containment Sit Report 86-49 39 Routine Inspection of Pre-Service Inspection Program and Records and Previous Items 86-50 131 Routine Inspection of Initial Fuel Loading Activities 86-51 97 Special Team Inspection To Review Allegation of As-Built Orawing Discrepancies 86-52 478 Special Team Inspection to Review Allegations by ELP Inspection Number Not Used 86-53 36-54 187 Routine Inspection of Operations, Maintenance, Surveillance, Startup Testing and Previous Items

Table'l 4.

Report No.

Inspection Hours Area (s) Insoected 86-55 40 Routine Inspection of Occupational Radiological 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 87-02 432 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 Rout $ne Inspection of Radwaste Program and Pre 0perational Tesc Results Evaluation 87-05 69 Routine Inspection of Startup Test Program, Post-Core Leading Hot Functional Testing and Test Results Evaluation Inspection Number Not Used 87-06 i

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 e

. Table 1 5

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 87-11 32 Routine Inspection of Startup Test Program, Post-Core Loading Hot 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 Raciological Controls Program 87-15 33 Routine Inspection of Non-Radiological Chemistry Vrogram Operator Licensing Examination 87-17**

87-18 35 Special Inspection of Service Water Valve Repairs Operator Licensing Examination 87-19 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 next SALP period.

TABLE 2 INSPECTION HOUR

SUMMARY

HOURS FUNCTIONAL AREA Actual Annualized Percent 1.

Construction Completion 1349 1012 19.4 2.

Startup Testing 1244 932 17.8 3.

Plant Operations 2667 2000 38.2 4.

Radiological Controls 739 554 10.6 5.

Emergency Preparedness 219 164 3.2 6.

Security and Safeguards 175 130 2.5 f

7.

Engineering Support 579 434 8.3 8.

Licensing Activities 9.

Training and Qualification Effectiveness

10. Assurance of Quality TOTAL 6972 5226 100.0

u TABLE 3 ENFORCEMENT ACTIVITY f

A.

Violations Versus Functional Area By Severity Level-t No. of Violations in Each Severity Level Functional Area V

IV III II I

Total i

1.

Construction Completion 0

2.

Startup Testing 0

3.

Plant Operations 1

4 5

4.

Radiologica'l Controls 0

5.

Emergency Preparedness 1

1 l

6.

Security and Safeguards 0

7.

Engineering Support 0

8.

Licer, sing Activities -

0 9.

Training and Qualification 0

4

10. Assurance of Quality 0

TOTAL I

5

~5

~D 0

6 t

i i

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Table 3 2

B.

Summary Inspection Severity Functional Brief Number Requirement level Area Description 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 87-02 10 CFR 50, 4

Operations CBA System Not APP.B Operated In Accordance With Design Requirements 87-08 T.S.6.7.1 4

Emerg. Prep.

Failure To Report 8)nusual Event 87-13 10 CFR 50.59 4

Operattons SW/SCW Temporary Modification 87-20 10 CFR 50, 5

Operations Tagging Program ADP. B Deficiencies s

o i

~

s TABLE 4 LICENSEE EVENT REPORTS A.

LER By Functional Area Number By Cause Code

• Functional Area A

B C

D E

X

' 1 '.

Plant Operations 8

2

- 4 3

2. cRadiological Controls 3.

Emergency Preparedness 4.

Security'and 3afeguards 5.

Starcup Testing 6.

Licensing Activities 7.

Construction Completion 8.

Engineering Support 9.

Training Qualification and Effectiveness

10. ~ Assurance of Quality TOTAL 8

2 0

4 3

0

• Cause Codes A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - Externei Cause 0 - Defective Procedures E - Component Failure X - Other Cause Codes in this table are based on inspector evaluations and may differ from those specified in the LER.

f, Table 4 2

8.

LER Synoosts LER Number Summary Cause 86-001 Normally Locked Closed Valve Found A

Mispositioned 86-002 Inadvertent Safety Injection A

86-003 ESF Actuation - Control Room A

Ventilation Isolation 87-001 ESF Actuation - Control Room E

Ventilation Isolation 87-002 ESF Actuation - Loss of Offsite Power A

To Essential Swit.chgear Bus

^

47-003 Source Range Analog Channel Operational A

Tests Not Staggered 87-004 Containment Equipment Hatch Air Lock B

Equalizing Valves Inoperable 87-005 Main Control Board Indicators Not B

Properly Mounted 87-006 ESF 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

Table 4 3

87-013 Area Temperature Monitoring In B

Battery Rooms87-014 ESF Actuation - Start of EDG "B" 0

O

/

UNITED STATES NUCLEAR REGULATORY COMMISSION a

REGION 1 l-631 PARK AVENut 0

k.... g,a KING oP PRUS$1A, PENNSYLVANIA 19400 OCT 261987 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 Number 50-443/86-99 An NRC Region I SALP Scard 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 commitment 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 existed throughout this assessment period, however, the station and its personnel may not have been significantly challenged in many of the areas that were evaluated.

Thas, management awareness and support of the station's readiness to respond to the future challenges and sustain a high level of performance in these areas should be rnaintained.

A meeting in the vicinity of the Seabrook Site has been scheduled to discuss the Unit 1 assessment on November 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 our assessments and your plans to enhance the program effectiveness in those areas which warrant additional attention. Additionally, you may provide written comments 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, pM I h u dk William T. Russell Regional Administrator Ad g,, n,, n e.

w,6 v F /L/l.2 U '

<* C ' t ' 8 1 ma

7_ _

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Public Service Company of New 2

Hampshire 00T 261987

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 Safety, Commonwealth of Massachusetts Employee's Legal Project Public Document Room (POR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachus'etts (2)

State of New Hampshire Chairman Zech Commissioner Roberts Commissioner Bernthal Commissioner Carr Commissioner Rogers l

.. ~...

i

tou. vaunt e h

George S.Thomes wee heucem Nucw hoevenon Public SeMee of New Hampshire New Hampsnire Yankee Division i

I NYN-88002 January 6, 1988 United States Nuclear Regulatory Coc:nission Washington, DC 20555 Attention:

Document Control Desk

References:

(a)

Facility Operating License No. NPF-56, Docket No. 50-443 (b) USNR0 Letter, Dated October 26, 1987, ' Systematic Assessment of Licensee Performance (SALP)', Report Not,50-443/86-99

Subject:

Response to SALP Report

. Gentlemen:

Pursuant to the SALP Management Meeting on December 9, 1987, New Hampshire Yankee (NHY) offers the following additional information regarding the functional areas of Plant operations Engineering Support, and Assurance of f<uality as described in Reference (b).

Plant 0:erations. Functional Area #3 In order to alleviate the burden of the paperwork /nonoperational workload placed on the Unit Shift Supervisor (USS), the work control process vill be reviewed to determine areas where the workload can be transferred from the USS to the equipment control group.

The equipment control group will be co= prised of operators which will be responsible for reviewing work requests.

Another area of concern was the inattention to detail in routine daily operations.

To resolve this :.oncern, either the Operations Manager or the Assistant Operations Manager is currently attending all requalification simulator exams to observe shift crews in an operating environment.

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

V t

C wMtxjKcL.fW4rmk, NH 03874. Telephone (603) 474 9574 w.

l O

United States Nuclear Regulatory Cormission January 6, 1988 Attention:

Document. Control Desk Page 2 Inaineerina Succort. Functional Area #7 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 Jud will make further adjustments to engineering programs, as necessary, to f acilitate a strong tea =vork approach.

Assurance of Quality, Functional Area #10 A formal review is being conducted of the manner in which operational problem areas are identified and analyzed, and the role of Quality Assurance (QA) in the corrective action process.

Initiatives have been and will continue to be taken to assure that implementation of internal programs used to identify and correct material and progron deficiencies are both effective and performance oriented.

{

Initiatives already in place include,the following:

1.

Integrating the conttruction QA personnel into the operations 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 i

identified operational problem areas.

3.

Relocating all QA personnel, including the Nuclear Quality Group (NQG) Kanager, to the Operations Support Building in order to i= prove 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.

t 5.

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

[

6.

Upgrading and expanding the operational QA trending program through

[

the use of a computerized data base to categorize problem areas and focus audit and inspection activities and management attention where they will be most effective.

I i

o

.~

United States Nuclear Regulatory Consnission January 6, 1988 Attention:

Document Control Desk Page 3 Management will continually assess quality program effectiveness, and it is expected that additional initiatives

~'t be taken, as necessary, to enhance the overall program.

Should you have any questions cos.-,.ing our response.please contact Mr. William J. Temple at (603) 474-9574, extension 3781.

Very truly yours, 9f c

George S. Tho=ss cci Document onte Desk Unite tat Nucles gulatory Co:nmission Wa s - ngte, DC 29355 Mr. Victor Nersas,, Project Manager Project Directorate I-3 Division of Reactor Projects United States Nuclear Regulatory Conmisr, ion Washington, DC 20555 Mr. A. C. Cerne NRC Senior Resident Inspector Seabrook Station Seabrook, NH 03874 (l{likB6)

Mr. William T. Russell Regional Administrator United States Nuclear Regulatory Co= mission Region 1, 631 Park Avenue King of Prussia, PA 19406 I

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UNITED $TATES NUCLEAR REGULATORY COMMISSION c

fp g

'i l

wAssiwaTow. o, c. mes T.,,,,/

MbI JU EDO PRINCIPAL CORRESPDNDFNCF CONTROL

'FROM:

DilF o?/10/8R EDri 870NTROL : OMASS DOC DT: 31/;'8/83 REP.' EDWARD J.

MARKEY g@

FINA) RFPLY:-

gh TO:

b 77 CHAIRMAN 7ECH

)

[

FOR SIGNATilRF OF

• • PRIORITY **

SECY NO: 89-58 CHAIRMAN DESC:

ROUTING:

URGES NRC TO AtITHORI7t'. AN INDEPENDENT BLUF RIBRON STELLO-COMMISSION TO CONr?tCT A SAFETY REVIEW OF THE TAYLOR CEABROOK NtlCLEAR POWFR Pl. ANT REHM RUSSELL DATE: 02/01/88' HAYES ASSIGNED TO: NRR CONTACTt M(IRt.EY MllRRAY SPECIAL INSTRUCTION 5 OR RFMARKS:

C RI PROVIDE INPUT TO NRR.

NRR RECEIVED: FEBRUARY 2, 1988 CIRpt:Z L-a -w:,VARGA ACTION:

ma,_, ;

-NRR ROUTING:

MURLEY/SNIEZEK MIRAGLIA GILLESPIE ADT MOSSBURG Notat 2 copies of the rpt rec'd in NRR:

1 copy to DRPR - 1 copy to Murley/Sniezek t

r m

0FFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER:

CRC 0058 LOGGING DATE: I/28/88 ACTA' CTFICE:

E00 AUTHOR:

E J Markey AFFILIATION:

U.S. House of Representatives LETTER DATE:

1/28/88 FILE CODE:

SUIL7ECT:

Urges the Com to authorize an independent blue ribbon comission to conduct a safety review of the Seabrook nuclear power plant ACTION:

Prepare Response for Signature of Chairman DIFTRIBUTION:

RF, OCA to Ack, Docket SPECIAL HANDLING: None NOTES:

Feb 12 DATE DUE:

SIGNATURE:

DATE SIGNED:

AFFILIATION:

re'd Off. EDON'O Date l'. 3. o k Time E DO 003456

---