ML20198R787

SALP Rept 50-443/86-99 for Jan 1985 - Mar 1986

ML20198R787
Person / Time
Site:	Seabrook
Issue date:	06/05/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198R772	List: ML20198R771 ML20198R787
References
50-443-86-99, NUDOCS 8606100210
Download: ML20198R787 (42)

See also: IR 05000443/1986099

Text

O

u

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-443/86-99

PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE

SEABROOK STATION, UNIT 1

ASSESSMENT PERIOD: JANUARY 1,1985 - MARCH 31, 1986

BOARD MEETING DATE:

MAY 14, 1986

8606100210 860605 3

ADOCK 0500

gDR

t

.

O

i

l

TABLE OF CONTENTS

1

PAGE

I. INTRODUCTION...................... ......... ........................ 1

A. Purpose and Overview....... ........... ........................ 1

B. SALP Board Members............. .. ............................. 1

. C. Background........................... ....... .. ..... ......... 2

i

II. CRITERIA......... ..................... .. . ........................ 6

III. SUMMARY OF RESULTS. ................................................. 8

A. Ove ra l l Faci l i ty Eva l ua ti on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

B. Facility Performance....... ............. ...................... 9

IV. PERFORMANCE ANALYSIS...... .. . ..................................... 10

A. Construction........................ ........................... 10

B. Preoperational Testing....... ....... . ....................... 13

C. Fire Protection and Housekeeping..... .......................... 16

D. Operational Readiness........................................... 18

E. Emergency Preparedness................................ ......... 25

F. Assurance of Quality. ............ ............................. 27

G. Licensing.................... .................................. 31

V. SUPPORTING DATA AND SUMMARIES........................................ 33

A. Construction Deficiency Reports................................. 33

B. Investigations and Allegations Review.................. . . . . . . . . 33

C. Escalated Enforcement Actions................ .................. 34

D. Management Conferences................. ...... ................. 34

E. Licensing Activities............................................ 34

TABLES

TABLE 1 - CONSTRUCTION DEFICIENCY REPORTS

TABLE 2 - INSPECTION HOURS SUMMARY

TABLE 3 - ENFORCEMENT DATA

i

.

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

o

l

l

l

I. INTRODUCTION

1

A. Purpose and Overview l

l

The Systematic Assessment of Licensee Performance (SALP) is an integrated

NRC staff effort to collect the available observations and data on a

periodic basis and to evaluate licensee performance based upon this in-

formation. SALP is supplemental to normal regulatory processes used to

ensure compliance to NRC rules and regulations. SALP is intended to be

sufficiently diagnostic to provide a rational basis for allocating NRC

resources and to provide meaningful guidance to the licensee's management

to promote quality and safety of plant construction and operation.

An NRC SALP Board, composed of the staff members listed below, met on

May 14, 1986 to review the collection of performance observations and

data and to assess the licensee performance in accordance with the guid-

ance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Per-

formance". A summary of the guidance and evaluation criteria is provided

in Section II of this report.

This report is the SALP Board's assessment of the licensee's performance

at the Seabrook Station for the period January 1, 1985 through March 31,

1986. This SALP differs significantly from previous Seabrook Station

assessments. For the entire assessment period, Unit 2 has been in an

" indeterminate" status with licensee work confined to preventive main-

tenance, preservation and protection activities and the construction

completion required to support Unit 1 operation. Therefore, licensee

performance related to Seabrook Unit 2 has not been assessed, although

some inspection (See fiote in Table 2) has been performed of licensee

efforts with regard to Unit 2. Also, construction related activities

have been combined into one functional area with emphasis not so much

on the individual disciplines, but more upon constuction completion and

readiness for operation. New functional areas were added to address

other plant operations and readiness aspects of licensee performance.

B. SALP Board:

Chairman:

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

Board Members

T. Martin, Director, Division of Radiation Safety and Safeguards (DRSS)

S. Ebneter, Director, Division of Reactor Safety (DRS)

E. Wenzinger, Chief, Projects Branch No. 3. DRP

T. Elsasser, Chief, Reactor Projects Section 3C, DRP

V. Nerses, Project Manager, PWR Project Directorate 5, NRR

A. Cerne, Senior Resident Inspector

.

o

2

Other Attendees

W. V. Johnston, Deputy Director, DRS

J. R. Johnson, Chief, Operational Programs Branch, DRS

W. J. Lazarus, Senior EP Specialist, DRSS

J. R. McFadden, Radiation Specialist, DRSS

D. Ruscitto, Resident Inspector

M. M. Shanbaky, Chief, Facilities Radiation Protection Section, DRSS

R. W. Starostecki, Director, ORP (Part Time)

C. Background

Public Service Company of New Hampshire (PSNH) applied for a license to

construct and operate the Seabrook Station (DNs 50-443 and 50-444) on

July 9,1973, and was issued Construction Permits (CPPR-135 and CPPR-136)

on July 7,1976. Each reactor is a Westinghouse four-loop, PWR rated

at 1198 MWe and is housed in a reinforced concrete containment structure.

The units are arranged using a " slide-along" concept with certain struc-

tures common to both units. PSNH has contracted with the Yankee Atomic

Electric Company (YAEC) for services which include project administra-

tion, facility design control, construction coordination, quality assur-

ance, and licensing. For the purpose of this report, these YAEC services

are considered synonymous with PSNH activities.

On June 23, 1984 the New Hampshire Yankee Division (NHY) of PSNH was

created with the primary responsibility for construction of Seabrook

Station. While some of the organizational interfaces and responsibili-

ties between PSNH and YAEC have been restructured to accommodate the

formation of NHY, at this time, PSNH continues to retain overall re-

sponsibility for all activities related to Seabrook, as is specified in

the Construction Permits. Proposed organizational changes seeking to

name the New Hampshire Yankee Electric Corporation (i.e., NHY incorporated

and separated from PSNH) as the new managing agent for Seabrook Station

have not yet been effected. Thus, use of the generic term (" licensee")

in this SALP currently constitutes recognition of not only the ultimate

responsibility of PSNH, but also the specific dutie's of both NHY and

vAEC.

a. Licensee Activities

At the beginning of this SALP assessment period, the licensee pro-

jected Unit 1 construction to be 83'. complete. The site work force,

still building up from the 1984 work suspension, numbered about 2500

personnel, 1400 of whom were craft. As construction continued,

priorities were directed to the support of preoperational testing

and the completion of major milestone activities. In this regard,

major testing progressed through the period with the conduct of the

Reactor Coolant System Hydrostatic Test in April, 1985; Hot Func-

tional testing during November, 1985; and Engineered Safety Features

.

a

3

testing, Loss of Offsite Power testing and the Containment Struc-

tural Integrity and Integrated Leak Rate testing in early 1986.

Additionally, six plant buildings were completed and turned over

to the control of the plant staff.

By the end of the assessment period, only 3% of the plant systems

remained in a construction status awaiting turnover to the startup

test staff. The remaining construction work, not yet substantially

complete, includes insulation and fire sealant installation, paint-

ing, activities in support of the remaining preoperational testing,

building turnover, and design modification rework. Preservice in-

spection, ASME Code stamping, and piping and pipe support stress

reconciliation programs are also continuing. The construction work

force, as of March 31, 1986 was approximately 3500 personnel, about

2200 of whom were craft. The licensee estimates Unit 1 to be 98%

complete.

Other licensee activities during this SALP period included continued

operator licensing, emergency preparedness, and operational readiness

planning and program reviews. New fuel was initially received on

site in February, 1986 and an Emergency Orill, exercising NRC, the

State of New Hampshire and licensee response, was also conducted

in February, 1986. As of March 31, 1986, a station staff in excess

of 500 personnel, in addition to a New Hampshire Yankee corporate

staff, were in residence at the Seabrook site.

The licensee projects a Fuel Load Date (FLD) of June 30, 1986 for

Seabrook Unit 1.

b. Inspection Activities

Two NRC resident inspectors were assigned throughout the assessment

period with a third inspector assigned on site since May, 1985.

A total of 53 inspections were performed with 7912 hours0.0916 days <br />2.198 hours <br />0.0131 weeks <br />0.00301 months <br /> dedicated

to the inspection of Unit 1 activities. This corresponds to 6330

hours on an annualized basis. An additional twelve hours were

utilized to confirm licensee preventive maintenance, preservation

and protection efforts on Unit 2. NRC inspections conducted during

this SALP period are functionally categorized below, with the five

types of team inspections listed separately by their unique scope.

Region

e !_ Specialist __ Inspections Number

Construction 8

Preoperational Testing 15

Fire Protection 2

Operational Readiness 4

Radiological Controls 3

Security 3

Emergent.y Preparedness (EP) 1

.

O

4

Operator Licensing 2

Resident Inspections 9

Team Inspections

Management Reorganization 1

NDE Independent Measurements 1

EP Appraisal 2

Safe Shutdown (Appendix R) 1

As-Built Plant 1

The nine resident inspections noted above represent continuous on-

site coverage of licensee activities throughout this assessment

period. A distribution of inspection hours, by functional area is

shown in Table 2. Enforcement data, resulting from these inspection

activities, are summari:ed in Table 3.

This report also discusses the " Assurance of Quality" as a separate

functional area. Although this topic is assessed in the other func-

tional areas as one of the evaluation criteria, discussion of this

ar 1 separately provides a synopsis. For example, quality assurance

effectiveness has been assessed on a day-to-day basis by resident

inspectors and as an integral aspect of specialist inspections.

Although quality work is the responsibility of every employee, one

of the management tools to measure this effectiveness is reliance

on quality assurance inspections and audits. These and other major

factors that influence quality, such as involvement of first-line

supervision, safety committees and worker attitudes, are discussed

in each area,

c. Other Activities

An NRC Caseload Forecast Panel visit to Seabrook was conducted on

September 4-5, 1985 to assess the status of Unit 1 construction.

Their review found the June 30, 1986 fuel load date (FLD) to be

reasonable, but recognized that funding and schedular uncertainties,

known to exist at that time, made the achievement of fuel load dur-

ing the third quarter of CY 1986 more likely.

It is noted that subsequent to the Caseload Forecast Panel visit

to Seabrook, the joint owners of Seabrook Station voted to authorize

full-construction funding and proceed with all scheduled construc-

tion activities, effective October 1, 1985.

The EPA permit, granting final approval for use of the ocean cooling

tunnels, became effective August 25,1985. Testing of the circulat-

Ing water system commenced that same day.

s

5

.

The NRC Special Nuclear Materials License No. SNM-1963 (Docket No.

70-3027), authorizing the receipt, possession, inspection and stor-

age of fuel assemblies and other radioactive materials for eventual

use at Seabrook Unit 1, was issued on December 19, 1986. Initial

fuel receipt and storage on site, in accordance with the provisions

of the 10CFR70 license, commenced in Febraury,1986.

A Prehearing Conference for the EP phase of the ASLB hearings was

conducted in Portsmouth, New Hampshire on March 25-26,1986. In

accordance with the ASLB Memorandum and Order, dated January 17,

1936, the hearings for New Hampshire Offsite Emergency Planning

Contentions are scheduled to commence on July 21, 1986.

The " Proof & Review" edition of the Seabrook Technical Specifica-

tions (TS) was issued for comment in late March,1986. The licen-

see, Region I and the Office of NRR are currently involved in re-

view activities for TS conformance to FSAR commitments, plant-

specific as-built conditions, and operational safety considerations.

.

.

6

II. CRITERIA

Licensee performance is assessed in selected functional areas, depending on

whether the facility is in the construction, preoperational, or operating

phase. Each functional area normally represents areas significant to nuclear

safety and the environment, and are normal programmatic areas. Special areas

may be added to highlight significant observations.

The following evaluation criteria, where appropriate, were used to assess each

functional 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 effe:tiveness.

Based upon the SALP Board assessment each functional area evaluated is clas-

sified into one of three performance categories. Tne definitions of these

performance categories are:

Category 1. Reduced NRC attention may be appropriate. 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 is being achieved.

Category 2. NRC attention should be maintained at normal levels. Licensee

management attention and involvement are evident and are concerned with nuclear

safety; licensee resources are adequate and reasonably effective so that

satisfactory performance with respect to operational safety is being achieved.

Category 3. Both NRC and licensee attention should be increased. Licensee

management attention or involvement is acceptable and considers nuclear safety,

but weaknesses are evident; licensee resources appear to be strained or not

effectively used so that minimally satisfactory performance with respect to

operational safety is being achieved.

The SALP Board also assessed each functional area to compare the licensee's

performance during the last quarter of the assessment period to that during

the entire period in order to determine the recent trend for each functional

area. The trend categories t. sed by the SALP Board are as follows:

.

.

7

Improving: Licensee performance has generally improved over the last quarter

of the current SALP assessment period.

Consistent: Licensse performance has remained essentially constant over the

last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last quarter

of the current SALP assessment period.

Notwithstanding the allowance permitted by a Category 1 rating to reduce NRC

attention, NRC oversight at Seabrook Station will be maintained at a high

level if a low power license is issued. Due to the nature and scope of acti-

vities conducted during low power testing and power ascension, it is NRC

policy that close scrutiny be provided for- the first two years of operation.

Subsequent SALP evaluation will therefore be done on a 12 month frequency ir-

respective of the good performance noted in this report.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _

. . . - _ . -. - - - - -- - . . . -. . _ -

..

.

8

,

,

III. SUMMARY OF RESULTS

,

A. Overall Facility Evaluatri_on

e

During this assessment period, the licensee's overall performance re-

flected not only a commitment to safety and quality construction, but

also evidence of effective planning and conduct of activities directed

>

,'

toward fuel load and safe operations thereafter. The inspection effort

!

during this period was far in excess of that of previous SALP periods.

An evaluaticn of a broad spectrum of licensee activities was necessary

because of the nature of ongoing construction completion, preoperational

'

testing, and operational preparedness activities. Hardware quality has

been found to be in conformance with design requirements and system in-

stallation has met licensing commitments. The preoperational test pro-

gram has confirmed the existence of quality construction'with generally

, outstanding test r3sults and minimal number of test exceptions. In al-

a

most all! cases, a high level of performance was achieved with evidence

of effective planning for those areas where program implementation could

not yet be fully assessed. Management attention continued to be focused

on improving those areas identified in the previous SALP period as poten-

tial problems. As a result, only minor problems were observed during

i the period.

' '

Regsrding operational preparedness, thorough planning and a high level

of management attention to the readiness of plant hardware, programs,

a'nd procedures are very' much in evidence. Licensed operator training

and the preparation and receipt of new fuel are noteworthy examples of

the effectiveness of the licensee's programs. Also, the licensee's de-

velopment of the security program represents effective management plan-

ning to integrate ekperienced staff supervisors with a trained contract

i security force. In summary,'where operational programs have been imple-

mented, the quality exhibited during construction appears to have carried

oser during the transition pro ~ cess from construction into operations.

While licinsee responsiveness to op'erational issues has been appropri-

ately directed, it should be noted that these programs are still under

development. Future inspection and assessment of the full program im-

plementation will provide an ongoing mea'sure of their effectiveness.

At Seabrook Unit I now enters a new phase of program development, im-

plementation, and work priorities, this oVerall facility evaluation

should be considered both a positive reflection of past licensee per-

, formance, as well as an indicator of licensee potential for continued

performance at a high level during the operational phase.

3

eY

I

s

,

.

- ,, ,, -

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

.

i

.

9

B. Facility Performanco

CATEGORY CATEGORY

LAST THIS

PERIOD PERIOD

(7/1/83- (1/1/85- RECENT

FUNCTIONAL AREA 12/31/84) 3/31/86) TREND *

Construction 2 1 Consistent

Preoperational Testing 1 1 Consistent

Fire Protection and Housekeeping N/A 1 Consistent

Operational Readiness N/A 1 Consistent

Emergency Preparedness N/A 2 Improving

Assurance of Quality 1 1 Consistent

(See Trend

at the end

of Section

IV.F)

Licensing 2 1 Consistent

• Trend during the last quarter of the current assessment period.

l

- - -_- - _ - _ - _ - -

.

.

10

t

IV. PERFORMANCE ANALYSIS

A. Construction (3788 hours0.0438 days <br />1.052 hours <br />0.00626 weeks <br />0.00144 months <br />, 48%)

1. Analysis

During the previous SALP assessment period, the following functional

construction areas were evaluated and rated separately: Containment,

.

Safety-Related Structures & Major Steel Supports (Category 1);

- Piping Systems & Supports (Category 2); Safety-Related Components-

Mechanical (Category 2); Auxiliary Systems (Category 1); Electrical

Equipment and Cables (Category 3); and Instrumentation (Category

2). The summary of these SALP results noted a significant improve-

4

ment in the piping systems & supports area, but declining trends

in the electrical and instrumentation areas because of apparent

programmatic problems. Management attention to routine problems

I (e.g., housekeeping) was solicited to: (1) correct deficiencies,

,

and (2) provide direction to an improvement in the trend in this

"

area. During the previous SALP period it was also noted that posi-

4

tive steps had been taken in the way of a project restructuring and

organizational realignment to eliminate some of the interface and

control difficulties which had been identified as the root cause  :

of several problem areas.

'

During this current assessment period all construction disciplines

have been combined under one functional area. In recognition of

both the management reorganization, which started during the pre-

vious SALP period, and the problems raised by the previous SALP,

i a Construction Team Inspection (CTI) was conducted in June, 1985

to assess the effectiveness of the resumption of construction acti-

l vities under the new site organization. Particular inspection

'

emphasis was placed upon the electrical and instrumentation areas,

as well as engineering interface controls, where problems had pre-

!.

viously been' identified. The results of this CTI (three violations,

three weaknesses, and three strengths) provided no indication of

programmatic deficiencies. In fact, the s!te management organiza-

1

'

tion (i.e., the area directed by the CTI trape to be the focal point

of inspection effort) was identified as a 1.,.!nsee program strength.

, The CTI findings, when analyzed in conjunction with the enforcement

!

data and negative observations from other construction inspections,

appear to share one common attribute -- while process control,

documentation, and identification failures were identified, these

'

, problems / errors did not appear to lead to an adverse impact on the

hardware itself. It is noted that of the seven enforcement items

! grouped in this construction functional area, only one violation

i

was found to result from deficient construction.

, This theme of hardware installation and construction in compliance

s

with design requirements and licensing commitments appears to be

i corroborated also by another more recent CTI. In March, 1986, an

.

- -

--~-..--- ,, p-m, -----, y - - .-r e , ,-

. - - - _- . - - = _ ._ _ - - - - _ . - .

.

.

11

1

'

As-Built Construction Team Inspection was conducted with a primary ,

inspection focus on hardware. While two severity level V violations

.

were identified, the summary conclusion of this inspection was that

.

Seabrook Unit I was constructed in substantial agreement with the

FSAR. Additionally, an NRC independent measurements inspection of

68 weldments, utilizing the Region I Mobile Nondestructive Examina-

tion (NDE) laboratory, in conjunction with a review of licensee ,

radiographs for over 150 welds, identified no weld deficiencies or '

i

hardware problems.

The NDE van inspection in July, 1985 did document some concerns re-

i

garding the conduct of the Preservice Inspection (PSI) program at

Seabrook Unit 1. An unresolved item was written to track several

i

PSI questions involving data keeping, calibration, weld surface

i preparation and plans for ultrasonic (UT) examination of the loop

cast stainless steel (SS) elbows. Subsequent NRC inspections noted

adequate licensee resolution to most of these questions. A recent,

joint NRR/ Region I inspection of a demonstration of the UT technique

planned for the loop cast SS elbows revealed not only technical

acceptability, but responsiveness on the part of the licensee. The

basic concerns regarding the PSI program, as raised by the NDE van

inspection, have since been closed, although NRC follow-up of two

specific items remains.

j As in the case of the PSI issue, other NRC inspections in this func-

, tional area have raised questions more of a program and process

i

control nature, than of the identification of' improper construction.

Such issues include the improper usage of selected revisions of ASME

Code Cases, failure to implement commitments to Regulatory Guide

i (RG) 1.97, and the questionable adequacy of criteria for final

building verification and cable tray testing qualification. For

all of these items, licensee action to address the concerns has been

j complete and responsive.

For example, when problems were identified with the licensee adop-

!

tion and documentation of certain ASME Code Cases, not only was a

'

project position on ASME Code Case adoption and usage announced and

disseminated, but also a complete review of all past and present

,

Code Case usage was initiated. Both design and procurement speci-

fications were checked. Such comprehensive corrective action was

followed through by the licensee even though no evidence of material

or construction defects existed as a result of the identified im-

proper Code Case usage. In fact, licensee completion of their in-

vestigation, with subsequent NRC review, revealed the lack of any

adverse hardware impact. "

The status of construction during the current assessment period

,

'

provided sufficient opportunity for the inspection of electrical

and instrumentation activities, not only because by nature such work

4

I

- , ,. --

-. .. -- . - -

. - _ - . -.

..

.

12

I

is prevalent during the later stages of construction, but also be-

cause the previous SALP had raised some concerns in these areas.

Thirteen NRC inspections examined either in process or as-built work

in these disciplines. Additionally, NRC team inspections reviewed

such activities in conjunction with the scope of the CTI objectives.

While some violations were identified, the overall findings of the

NRC inspection effort into the electrical and instrumentation dis-

ciplines confirmed the general effectiveness of licensee corrective

measures initiated during the latter part of the previous SALP

period. Analysis of all the inspection items, not just enforcement

,

'

data, indicates a consistent theme of concerns with process and

design control issues with no evidence that the questioned controls

had resulted in incorrect construction. While some of these issues

but remain open, licensee actions to address the questions appear

to be pointed in the proper direction.

Similarly, an analysis of the CDRs (See Table 1) reported during

this assessment period reveals no real trend of programmatic defi-

ciencies in this construction functional area. NRC review of in-

1 terim and final 10CFR50.55(e) reports, as applicable, and involve-

1 ment in the in process troubleshooting of several of these defi-

j

ciencies has confirmed adequate liaison with the vendors and working

'

interfaces among engineering, construction, and test personnel to

expeditiously solve the known problem as well as investigate any

generic impact.

Thus, in summary of the assessment of construction activities, sig-

nificant NRC inspection effort has identified few hardware defi-

ciencies and the licensee appears to have adequate control over

their self-identified construction problems. While some concerns

over process controls were noted, they appear to have received ade-

quate licensee attention. One CTI near the beginning of the as-

sessment period evaluated construction management and programs,

while another CTI at the end of the period examined the as-built

plant hardware. These team inspections, in concert with resident

i. and specialist inspections over the course of the entire SALP period,

.

!

verified implementation of a generally effective construction man-

agement program with resultant evidence of quality hardware, mate-

,

rial, components and systems.

!

2. Conclusion

Rating: Category 1.

Trend: Consistent

3. Board Recommendation

None.

,

l _ _ _ _ _ _ _ . , , _ , _ . - . - - -

._ .-_ -_- .-.- --_ _ - -------

- - - - - -- - - - - - - - - -. ~

, -- _- .-.

.

e

,

13

B. Preoperational Testing (2451 hours0.0284 days <br />0.681 hours <br />0.00405 weeks <br />9.326055e-4 months <br /> 31%)

1. Analysis

During the last assessment period, preoperational test activities

were just commencing. NRC review of the preoperational test pro-

gram verified adequate controls and program direction. One specific

problem area was noted in that unauthorized work activities on com-

ponents under the jurisdiction of the Startup Test Department (STD)

were identified. The licensee responded with programmatic correc-

tive action. A high level of performance was maintained in this

area during the previous SALP period; however, this assessment was

based upon a limited NRC inspection effort.

, Over the course of the current assessment period, the bulk of pre-

operational testing for Seabrook Unit I was accomplished. NRC in-

spections devoted effort to the witnessing of tests in progress and

the review of approved test procedures and test results. Signifi-

cant tests conducted and witnessed by the NRC during this time period

included the Reactor Coolant System (RCS) Hydrostatic test, the

Reactor Protection System test, the integrated system 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 is noteworthy

that all of these tests, also being major schedular milestones, were

provided significant management oversight to ensure conduct in con-

cert with schedular presssures and other construction priorities.

Despite a situation where the pressure for progress might be per-

ceived to be contrary to the quality objectives of the test program,

the subject tests were performed, witnessed and reviewed with

generally outstanding results.

While the month-long HFT did result in some significant test excep-

tions requiring system redesign, the SIT /CILRT resulted in no test

exceptions being noted and the RCS hydro identified only one RCS

boundary leak (other than the expected flanged joints) in an in-

strument tube. NRC questions on ESF testing have been raised with

regard to valve interlocks and safety-injection "S" signal reset

design, but in each case the conduct of the test was found to agree

with the system design, as stated in the FSAR. Thus, the NRC con-

cerns related to design, not testing, issues. Similarly, for other

<

testing activities (e.g., diesel generator operation), the problems

that have arisen provided validation of the test objective itself.

STD troubleshooting of some diesel generator air start problems

'

(identified during Phase 1 testing in 1984) ultimately led to the

discovery of an undersized diesel starting air vent line (reported

a* a 10CFR50.55(e) design deficiency in 1986 (see Table 1). This

issue currently remains an open NRC inspection item. Another NRC

inspection item on the diesel generators was a concern regarding

the sequence of LOCA/ LOP testing with respect to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endur-

'

_ _ _ _ _ _ _ _ - _ __ . _ _ _ - - _ _ _. _ _ _ . . _ - - __ _. _

.

.

14

ance runs of the diesels, as per Regulatory Guide 1.108. This issue

was satisfactorily resolved when the licensee agreed to duplicate

stable diesel generator temperature conditions (as determined by

the 24-hour run test) as an initial condition to the performance

of the hot LOCA/ LOP sequencing load test.

The most significant system problems identified, to date, during

precperational testing were noted during HFT. In particular, with

respect to the Emergency Feedwater (EFW) system, a water hammer was

experienced in the steam lines to the Terry Turbine and EFW recir-

culation and flow to the steam generator problems were noted; ex-

tensive system redesign was required. As was the case with other

HFT problems (i.e. , feedwater recirculation vibration, main steam

bypass, steam dump, and steam generator blowdown exceptions), the

system / component rework will be functionally retested during the

startup hot functional testing, after core load, but prior to in-

itial criticality. The licensee's coordination between its engi-

neering, construction, and test staffs to effect the correct system

redesign on the above items has been comprehensive. NRC personnel

,

have been briefed and kept informed of all significant developments

and NRC inspection relative not only to the above items, but all

HFT activities resulted in no significant adverse findings.

While the HFT identified certain major items requiring retest, the

remainder of the preoperational test program (i.e., Phase 2 & 3

tests) to date, represents a verification of system readiness for

operations with relatively few problems. At any given time during

this SALP period, as preoperational testing was conducted in accord-

ance with the more than one hundred each preoperational and accept-

ance test procedures, the number of open test exceptions remained

below 100 in number. Preoperational testing has, in general, met

its objectives with respect to Unit I components and systems and

in fact has identified several of the construction deficiencies,

reported under 10 CFR 50.55(e), listed in Table 3. The trend for

the number of remaining work items, as tracked on the licensee In-

complete Items List (IIL), is downward as the total items currently

number less than 4000 for the first time since pre-HFT in mid-1985.

NRC inspection in this functional area has identified only one

violation, although it was a repetitive item from the last SALP

period involving an unauthorized work activity. Licensee corrective

action has not yet been reviewed by the NRC, however, the STD record

in the resolution of problem; encountered to date in testing has

been both comprehensive and complete. A high level of performance

was found to exist in this functional area during the prior SALP

period based upon limited data. During this SALP period, that high

level of performance has been maintained over the course of the

majority of preoperational test activities.

.

.

15

This evaluation corroborates the finding of a minimal number of

actual hardware problems identified in the construction area. Lic-

ensee performance in this area reflects aggressive management in-

volvement and serves as an impetus for and the STD to sustain such

a level of testing performance as construction is completed and

operations and the startup testing phase commences.

2. Conclusion

Rating: Category 1.

Trend: Consistent

3. Board Recommendation

None.

_

.

.

16

C. Fire Protection and Housekeeping (296 hours0.00343 days <br />0.0822 hours <br />4.89418e-4 weeks <br />1.12628e-4 months <br />, 4%)

1. Analysis

This area was not evaluated during the previous SALP period, al-

though some housekeeping concerns were raised as they impacted the

acceptability of safety-related components.

During this assessment period, a Region I team inspection was per-

formed to evaluate the licensee's efforts to comply with the re-

quirements of 10CFR50, Appendix R, concerning fire protection fea-

tures necessary tc ensure the ability to achieve and maintain safe

shutdown in the event of a fire. Two Region I specialist inspec-

tions into the Fire Main Loop installation and the readiness of the.

Fire Protection Program, particularly as it related to fuel receipt

onsite, were also conducted. Additionally, routine resident in-

spections have examined fireproof coating material applications,

fire sealant installation, and cable separation and routing activi-

ties. Housekeeping, as appropriate to the status of the Unit 1

plant conditions during construction, testing and building turnover

to the plant staff, were observed during random plant inspection-

tours.

Electrical separation concerns have been raised during both this

and previous SALP periods. Where nonconforming conditions have been

identified (e.g., less than six inch wire spacing internal to

panels), the licensee had committed to corrective rework to retrain

and separate the cables / wires or install barriers, as required by

the applicable IEEE Standards. However, a recent licensee submittal

to NRR of an " Analysis of Electrical Separation Criteria for Sea-

brook Station" establishes the basis for the adoption of certain

new separation criteria at Seabrook, as determined by analysis and

testing. Thus, previous long-standing commitments for the correc-

tion of electrical separation deviations need not be implemented

if NRR approves the licensee proposal to relax the separation cri-

teria, based upon site-specific testing. Similarly, the Region I

team inspection identified two Appendix R exemptions in the areas

of emergency lighting and the reactor coolant pump oil collection

system. Each of these exemptions requires further NRR review to

determine the acceptability of the plant design and to resolve the

open inspection items.

Generally, with respect to the Appendix R team inspection at Sea-

brook, both the corporate and site management were found to be ag-

gressively pursuing fire protection issues to their proper resolu-

tion. The licensee's fire hazard analysis was thorough and detailed.

The licensee has made several modifications to achieve compliance

with Appendix R,Section III.G separation requirements. The licen-

see also had many redundant means of achieving a plant safe shutdown

in the event of a fire, including two redundant Remote Shutdown

_ ___ _

_ - _-- .

< .

.

17

, Panels whose adequacy was demonstrated through walkdowns of selected

'

portions of the procedures to safely shut down the plant. Walkdowns

have further demonstrated that procedures were well planned and

adequate procedural training was given to the operators.

The inspections team's conclusion was that the licensee's fire pro-

tection program, when fully completed and implemented, will be ade-

quate for its intended purpose. A major contributing factor is the

rapport maintained by the fire protection staff and management and

the increased awareness of the plant's personnel of fire protection

concerns. Other NRC inspections of fire protection at Seabrook have

confirmed this conclusion, even though one apparent deviation from

FSAR commitments was identified. The installed Fire Loop hydrant

isolation valves had not been procured as U.L. listed components,

as was committed. The licensee, however, provided a comparison of

the installed valves with similar U.L.-listed valves and demon-

strated that the existing valves are acceptable for their intended

service. Another inspection item identified a discrepancy between

the SER and actual plant design with respect to the inability to

start the fire pumps from the control room. This issue is being

pursued by the licensee with the Office of NRR.

With respect to housekeeping at Seabrook Unit 1, both NRC CTIs

(discussed in Section IV.A of this report) noted acceptable levels

of site cleanliness. Resident inspections have noted that the ac-

ceptability of site housekeeping appears to be dependent upon the

status of plant activities; construction areas require continual

attention, buildings turned-over to the plant staff appear to be

maintained in good order, and other plant areas appear to improve

as the preoperational testing and turnover process progress.

l

The housekeeping problems raised during the past SALP appear to have

.

been adequately addressed by plant management. Continued attention

to this area, as well as to the resolution of the noted fire pro-

tection licensing issues with NRR, is necessary to provide a con-

sistency to the licensee's approach to fire protection as the plant

,

enters operations.

2. Conclusion

Rating: Category 1.

Trend: Consistent.

4

3. Board Recommendation

None.

.. _ -

.- --

. - . _ __

- .

.

.

18

, D. Operational Readiness (743 hours0.0086 days <br />0.206 hours <br />0.00123 weeks <br />2.827115e-4 months <br />, 9%)

1. Analysis

5 This functional area was evaluated in the previous assessment period

only from the perspective of Operator Licensing. In that area, a

Category I rating was assessed based upon evidence of a highly com-

petent, technical training program and the resulting high pass rate

.

of SR0/R0 candidates in their initial licensing examinations. Dur-

i

ing the current SALP period, the-functional area of Operational

Readiness has been expanded to include consideration of procedures

and staffing, radiological controls, and security, in addition to

operator licensing. Analysis of each of these areas is discussed

separately below.

.

a. Procedures and Staffing

i During the current SALP period four separate Region I inspec- i

^

tions were conducted in such areas as plant maintenance and

surveillance procedures, design change and modification con-

trols, and operational QA/QC program administration and con-

trols. Resident inspections have examined the plant readiness

for fuel receipt and storage, and licensee plans / implementation

of their commitments to meet the TMI Action Plan requirements

specified by NUREG-0737. Also, several IE Bulletins and Cir-

culars, of an operational nature, sent to Seabrook Station for

information only, were reviewed in conjunction with licensee

measures to address the concerns raised by these generic docu-

ments.

No enforcement findings or unresolved safety issues have been

identified as a result of these operational preparedness in-

l spections, to date. Licensee attentiveness to an FSAR commit-

'

ment to have the Fuel Building and the appropriate fuel hand-

ling and storage systems completed and tested prior to new fuel

receipt onsite was noted. Scheduled fuel receipt was first

delayed to allow time to meet such a commitment and subse-

,

quently, removal of the new fuel from the storage casks was

'

further delayed to provide for additional testing of the fuel

building ventilation systems. NRC inspection of the new fuel

arrival, movement and storage revealed adequate security meas-

ures in place, the utilization of approved new fuel handling

and inspection procedures, knowledgeable operations personnel,

and general compliance with the provisions of the Special Nuc-

lear Materials license issued by the NRC Office of NMSS.

NRC inspections of licensee plans for controlling specific

operations programs for Measuring and Test Equipment (M & TE),

calibration, inservice testing, material storage, records

storage, procurement, safety review committees, and admini-

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

.

.-

19

strative procedures all resulted in a finding of adequate pro-

gress and proper direction by the licensee operations staff

in addressing proper quality controls and generic industry in-

itiatives. The status of operating and emergency procedures

was not amenable to inspection during this assessment period,

since most procedures were still in draft form. However, it

was noted that the operating personnel had utilized these pro-

cedures, where appropriate, during the conduct of preopera-

tional testing, to troubleshoot procedural problem areas.

While the development of operating procedures is dependent

upon Technical Specification approval, management attention

to their program for operating procedure issuance is warranted

to provide not only a generic site perspective on the way

regulatory guidance (e.g., NUREG-0737) is to be handled, but

also assurance that these procedures can be reviewed and edited

in a timely manner relative to the licensee fuel load date.

In the same vein, licensee actions to demonstrate compliance

with NUREG-0737 commitments have not been timely, as sufficient

progress on certain TMI Action Plan requirements had not been

made by the end of this assessment period. Licensee management

attention was directed to this area, and since the end of the

assessment period, greater progress appears evident. Continued

management responsiveness to all remaining operational pre-

paredness areas and items is necessary to assure Seabrook Unit

1 plant readiness for fuel load and operation.

NRC inspection effort has also been devoted to the licensee's

nonlicensed training program, and other training conducted to

correct or prevent problems which have arisen in the construc-

tion and preoperational test areas. One NRC concern in the

area of nonlicensed training was raised in that no matrix and

comprehensive schedule of such training was yet available to

demonstrate that all personnel training needs would be ful-

filled. Since the identification of that item, NRC reinspec-

tion has found the licensee responsive to this concern and has

taken adequate action to allow closure of the open item.

l b. Operator Licensing

4

, During the current assessment period, two operator license ex-

aminations were administered during the weeks of March 18, 1985

and September 30, 1985. Of the 17 senior reactor operator

(SRO) and 3 reactor operator candidates examined in March, only

one SRO candidate was denied a license. All 5 senior reactor

operator candidates participating in the September examination

were issued licenses. This included the candidate previously

denied a license during the March exam.

. -- . _ ._. -. - - _- - __ = _.. - - - _ .. -.

.

.

20

.

I

The licensee began its first replacement operator training

class in mid-February, 1985. The class of 15 reactor operator

and 5 senior reactor operator candidates is presently scheduled

for a July 1987 operator license examination.

1

In addition to operator training, the licensee has demonstrated

a strong commitment to the enhancement of the simulator's

.'

operational capabilities. A new modern high speed computer

is being installed to improve system response time and fidelity

and to provide a larger storage capacity.

Tne simulator malfunction list provided for the March 1985 ex-

'

,

amination contained several malfunctions with only a cursory

description. The licensee was informed of this weakness at

I the March 1985 operator license examination exit meeting. This

'

4 same weakness was again identified during the September 1985

examination. It continued to make the development of quality

simulatoi scenarios difficult for operator license examination

purposes.

The first group of cold license candidates was examined in

September, 1984. These operators and those that closely fol-

lowed will be scheduled for renewal near the proposed time of

! fuel load and the follow-on startup test program. Based on

this and the. fact that none of the operators will have been

able to make " active use" of their licenses during the previous

,

two years, the NRC staff has begun selective monitoring of the

l licensed operator requalification training program. This pro-

gram was implemented immediately after the last cold license ,

training class ended. To date, the licensee has demonstrated '

a strong commitment to quality requalification training that

l not only addresses the operator's need for skill and knowledge

i

reinforcement, but also identifies unique areas of specialized

training that are required in preparation for the upcoming

l' startup test program. The licensed operator-requalification

training program at Seabrook is considered an additional

strength in the already strong operator licensing training

program.

, With respect to licensed operator training and qualification

at Seabrook, the licensee continues to devote substantial re-

~

sources to the training program. The licensee training staff

appears to be both technically competent and professional.

.

Responsiveness on the part of the licensee to suggestions to

2

improve training has been evident.

c. Security

. Three preoperational security program reviews were performed

i

during the assessment period by region-based inspectors. Rou-

tine resident inspections continued throughout the assessment

period.

4

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

. . _ _ - . . _ . - . - - . .- -_ . _ _ _ ._ .. - - - _ _ - .. .- .

,

1 s

.

21

i

The effectiveness of the licensee's planning for the security

program was evident from the first preoperational review. De-

I velopment of the security program was on schedule and station

administrative procedures pertaining to plant security and

security program implementing procedures had been prepared and

approved for use. Management attention was evident from the

selection of personnel and the organization of key staff post-

tions. The station security organization is directed by an

experienced Security Program Manager, assisted by a Site

Security Supervisor. Four experienced functional supervisors

, are assigned to provide guidance and coordination in developing

and implementing the program.

'

Early establishment of these

+

program features enabled the regional inspectors to conduct

an in-depth analysis of the Physical Security Plan, Training

and Qualification Plan and Security Contingency Plan even be-

fore the receipt of new fuel on site. It also enabled the

NRC's Office of Nuclear Material Safety and Safeguards to com-

plete its plan reviews and an onsite program review expedi-

tiously and with a minimum of effort. The experience and pro-

fessional attitude of the licensee security management and

staff were evident.

i

NRC representatives found that the licensee had established

, a professional management team to select, train and manage the

contract security force. The licensee has aggressively re-

'

sponded to all NRC initiatives and is currently prepared to

implement a fully developed security program.

'

'

With the receipt of fuel on site in February 1986, the resident

inspectors routinely checked security controls for the fuel

building where the new fuel assemblies are being stored. Also,

while not part of the Seabrook physical security program to

be implemented during operation, security controls of various

areas of the plant where preoperational testing activities were

in progress were inspected to confirm compliance with proce-

, dural requirements and preoperational test assurance controls.

These NRC inspections revealed that the appropriate program-

j matic security controls were being properly implemented.

.

l Licensee management and security supervisors have provided a L

l workable system for allowing NRC inspectors "immediate unfet- '

tered" access to Seabrook Station for inspection purposes and

'

, are developing plans for badging and access provisions for NRC

personnel to facilitate future NRC inspections when the Sea-

.

brook Physical Security Plan !: implemanted. While NRC in-

l spection effort during this SALP period cannot provide a com-

i plete assessment of the licensee's security controls, both the 1

lack of significant problem areas anc management responsiveness

to security issues provide evidence of properly directed lic-

l ensee efforts in this area. Since the Physical Security Plan

!

!

- _

.

.

22

will be implemented for Seabrook Unit 1 in sufficient time

prior to planned fuel load for the licensee to identify problem

areas, management attention to security controls should be

focused in such a way as to address corrective measures, where

required,

d. Radiological Controls

During the latter part of this assessment period, three in-

spections were conducted by region-based radiation specialists

into the following areas: readiness for preoperational inspec-

tiens in radiation protection, radioactive waste management,

transportation, and effluent control and monitoring; prepara-

tion for initial fuel receipt; initial fuel receipt; and,

radiation protection.

During this assessment period, the radiological controls de-

partment was involved in the management control system via the

station operation review committee (50RC), radiation safety

committee (RSC-ALARA), and frequent routine management meetings.

All interfaces between the health physics (HP), radioactive

waste, chemi stry, instrumentation and control, and training

had not been fully defined and documented. Corporate responsi-

bility for appraisal of the radiation protection prcgram was

not clearly stated with regard to scope and frequency. Plan-

ning and scheduling appeared adequate in that licensee provided

readiness dates for preoperational inspections generally re-

mained unchanged during the inspection period.

General employee and radiation worker training programs were

in progress. While supplemental health physics training for

self-monitoring had not yet been fully defined, active planning

in this area was apparent from discussions with the licensee.

The Quality Assurance organization has initiated their sur-

veillance program and plans to audit tre radiatico protection

program on an annual basis, which exceeds standard requirements

for audit frequency. The external personnel dosimetry system

received NAVLAP certification during this inspection period.

Acceptable quantitative ALARA goals have been established.

While procedural deficiencies in ALARA procedures were identi-

fied, the HP staff committed to resolve them by fuel load.

Satisfactory changes to the ALARA proccdures were initiated.

One revision has completed the licensee's review and approval

process while the other is currently going through this step.

The fact that considerable responsibility for implementing

ALARA principles had been placed with job supervisors was ex-

pressed as an NRC concern. However, a need for additional

ALARA training for job supervisors and upper level management

had already been recognized by the licensee.

. .. -. _ - .- , _ _ _ _ _ = - _ - . - . - .-- _ - _ _ _ .

i .

.

23

i

Adequate management control systems are in place in the area

of HP. There is an adequate number of supervisory and profes-

sional staff possessing acceptable educational and experience

credentials. A simulated fuel receipt was conducted prior to

the initial fuel receipt in February 1986. Approximately fifty

i percent of the radiation protection technicians are on hand;

'

the majority of the technicians present are fully qualified

,

by experience; the site-specific training and qualification

manual process is being implemented.

Dosimetry procedures were found to be adequate, but not com-

prehensive. However, this was compensated by a strong training

program in the dosimetry area. One deficiency in the radiation ,

i work permit procedures was noted, and the licensee has imple-

} mented an approved revision which corrected the deficiency.

j Procedures for fuel receipt and the posting and controlling

4 of a radiologically-controlled area (RCA) were found to have

i been effectively used. Recordkeeping was adequate, but docu-

j- mentation of the dose assessment methodology was found to re-

! quire additional licensee attention. Subsequently, the licen-

'

'

ses remedied this NRC concern about dose assessment methodology

documentation. Additional data is required to support the beta

dosimetry methodology and is presently being developed by the

,

licensee.

> A whole-body-counting program is available and in use. A real-

time computer-based personnel training and dosimetry record-

j keeping system is being utilized. During this inspection

l period, additional portable survey meters, respirators, and

!

air samplers have been added to the licensee's equipment stores,

j while even more equipment is on order. However, testing and

! turnover of certain systems to the station staff is not yet

j complete.

i

! While the radioactive waste (RW) management, transportation,

I and effluent control and monitoring areas did not receive de-

j

'

tailed inspections during this assessment period, NRC inspec-

tors did review the organizational reporting lines and responsi-

bilities and did interview responsible supervisors in these

disciplines. The laboratory facilities were observed to be

i spacious, well kept, and well equipped. Emphasis on multiple

'

levels of quality control was apparent from discussions with

chemistry personnel . It was noted that RW supervisory and

i

'

technician staffing is almost complete and that health physics

training to be provided to radioactive waste handling personnel

is being developed.

l

t

4

1

, . - , ,,m--- - - - - - - - - - - - - . - , , . , - - - - - - - - - - - - - - - - - - , - ,,--- - -

. . . - - . - - _ _ _ _ . -- _ - - _ - . - _ _ _ _ _ _. _ .

i

j

i

!

24

1

Several new fuel shipments have been received, and adequate

radiological controls and attention to DOT regulations were

observed. Work controls were demonstrated to be effective for

fuel receipt and for controlling and posting of RCAs. The

planned operational survey and monitoring program is acceptable.

The operational readiness of the four radiological controls

i

areas (radiation protection, waste management, transportation

i and effluent control and monitoring) in regard to organization

j and management controls, staffing and training, work controls

and procedures, and facilities and equipment exceeds what would

l be routinely found at a plant like Seabrook Station Unit I at

i this preoperational stage. Since radiological controls func-

t tions have not yet been adequately challenged by operational

j requirements, a full assessment cannot be made at this time.

l

'

However, based upon supervisory awareness of the problem areas

and what still needs to be accomplished, the Radiological Con-

trols Program appears to be heading on a proper course. This

i positive trend should continue, provided that the management

commitment, the degree of preplanning and preparation, and the

'

! attention to detail remain at the same level that has been

l de,onstrated up to this point.

i 2. Conclusion

1

,

Rating: Category 1.

.

Trend: Consistent.

3. Board Recommendation ,

)

A normal level of inspection activity on part of the NRC shall be

i maintained during the next SALP assessment period due to the pre-

operational nature of the findings in this area.

t

4

!

!

i

..

!

4

I

!

,

f

I

i

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

.

.

25

E. Emergency Preparedness (634 hours0.00734 days <br />0.176 hours <br />0.00105 weeks <br />2.41237e-4 months <br />, 8%)

1. Analysis

This functional area was not evaluated during the previous SALP.

During this assessment interval, New Hampshire Yankee (NHY) has

placed considerable emphasis on the area of emergency preparedness

as they have approached their projected fuel load date. Two NRC

team inspections were conducted to perform the NT0L Emergency Pre-

paredness Implementation Appraisal (EPIA), and a third inspection

was conducted to evaluate licensee performance during a full parti-

cipation exercise.

The emergency preparedness function is controlled by a corporate

staff that is located at the site. This staff maintains a close

liaison with the site organization. The organization and staffing

is ample, principally consisting of a Director of Emergency Planning,

a Radiological Assessment Manager, an Emergency Preparedness Super-

visor, and two Senior Emergency Planners. The position of Director

of Emergency Planning is temporarily filled by a contract consultant.

Installation of equipment and training of personnel to fulfill their

emergency response organization functions is ongoing but has been

substantially completed based on observations made during the two

appraisal inspections and the exercise. The EPIA was begun during

December,1985, based on the applicant's firm judgement that they _

had reached a condition in which the emergency preparedness program

could be adequately evaluated. However, the appraisal had to be

terminated prior to completion because equipment, training, and

procedures had not been sufficiently completed to assess the EP

program. This appeared to be indicative of inadequate planning on

the part of the licensee. Sufficient progress had been made by

February,1986 so that the first full-scale exercise was conducted

on February 26 and the appraisal was completed on March 28, 1986.

The principal concerns identified during the appraisal are a lack

of sufficient numbers of qualified individuals to fill the key

energency response organization positions during an emergency on

a twenty-four hour basis (presently only a primary and one alternate

are qualified) and lack of on-shift dose assessment capability.

NHY has committed to have at least three people qualified for each

key EP position prior to issuance of a full power license and to

provide shift personnel with a programmed calculator to meet the

requirement to perform dose assessment at two, five, and ten miles,

prior to the arrival of the augmentation emergency response staff.

The exercise on February 26, 1986 involved the utility and the state

of New Hampshire, as the Commonwealth of Massachusetts Emergency

Plans had not yet been submitted for review by FEMA. No major on-

site deficiencies in the implementation of an adequate emergency

response were identified during the exercise. In general, personnel

.

26

involved in the exercise demonstrated a high level of training and

knowledge of their response functions. Assessment of plant condi-

tions and recommendations of protective actions for the public were

timely and conservative. The EOF is of adequate size and functioneJ

effectively with both the state of New Hampshire and a response team

from NRC Region I participating in the exercise. Several deficien-

cies were identified by FEMA with offsite response by New Hampshire.

These areas will be reassessed in a subsequent exercise prior to

consideration of a full power license. That exercise is also ex-

pected to include participation by Massachusetts.

There has been excellent cooperation on the part of NHY with the

NRC on the resolution of issues concerning the Emergency Plan and

procedures.

2. Conclusion

Rating: Category 2.

Trend: Improving.

3. Board Recommencation

Continued licensee attention to EP issues and to the resolution of

the open items resulting from both the EPIA and the emergency exer-

cise is warranted.

-

1

.-

l

l

= l

27

F. Assurance of Quality

1. Analysis

During the previous SALP period, " Quality Programs" was assessed

a Category I rating based primarily upon the strong and stabilizing

influence that the QA program at Seabrook has had upon project and

construction controls. During this period, quality program effec-

tiveness has been assessed by both resident and specialist inspec-

tors. Various aspects of this functional area have been considered

and discussed, as appropriate, as integral evaluation criteria in

other functional areas and the respective inspection hours are in-

cluded in each one. It is noted that management involvement in as-

suring quality is one attribute that is considered in the assessment

of licensee performance for all areas. Consequently, this area is

a synopsis of these discussions relating to the quality of work,

and management's role in assuring it.

An NRC team inspection (the first CTI discussed in Section IV. A of

this report) dedicated significant inspection resources to licensee

management programs and quality assurance. Two of the licensee

strengths documented in that inspection were attributed to Site

Management and Quality Assurance. New Hampshire Yankee (NHY) man-

agement was recognized for both its positive management support of

quality and the establishement of new programs and directives (e.g.,

the Independent Review Team, the Employee Allegation Resolution

program, the Piping and Pipe Support Closecut Task Team, and the

reorganization of site engineering under one director) The site

QA function was cited as a strength because of the implementation

of effective audit and trending programs and for its responsiveness

in initiating comprehensive corrective actions.

A review of the enforcement data in Table 3, reveals that of the

four violations attributed to this functional area, two involved

improper handling of Nonconformance Report (NCR) dispositions and

two involved incomplete follow-up of corrective action on Construc-

tion Deficiency Reports. Thus, in all four cases, the site QA pro-

gram was instrumental in finding the subject problems, but licensee

measures were not sufficiently complete to assure proper correc-

tion / repair of the identified problems. These examples represent

somewhat of a continuing negative theme from the last SALP where

licensee correspondence to the NRC on CDRs and enforcement actions

was found at times to be incomplete and corrective repair / rework

was not always timely.

As was discussed in the CTI as a strength, the initiation of cor-

rective action at Seabrook appears to be well directed. However,

the total assurance of quality depends upon every licensee employee,

and particularly upon supervisory level responsiveness to the prob-

lems. If corrective measures are not followed through in the same

!,

. _ . _ - - - - _ _ _

e

.

28

i

comprehensive vein as the inspection program that first identified

the items, the results are continuing problems and, as was noted

2

in the preoperational test area (Section IV.8), recurrent enforce-

ment findings. Management attention to this concern is warranted

as new operational programs are developed and different technical

areas come under inspectior.

Despite the examples of corrective action problems, noted above,

NRC inspections have generally identified a minimal number of prob-

lems, particularly in the hardware area. This was substantiated

'

by the as-built team inspection (CTI) conducted at the end of this

! assessment period (March, 1986). Management reinforcement of qual-

) ity objectives is evident not only in the support of the QA program,

l but also in first-line craft and supervisor training and in project

policy statements routinely issued by the construction manager to

prevent individual problems from becoming generic issues.

A "Startup Quality Assurance Interface Agreement" between the con-

struction and operations QA program staffs, and with the concurrence

of the station manager and the startup test department manager, has

'

been implemented. This Seabrook QA policy defines various organi-

zational responsibilities and scopes the role of the Operational

QA Program from the time of Conditional Acceptance Turnover (CAT)

of components, structures or systems to the initial fuel load of

Seabrook Unit 1. The planning and coordination that has served as

the basis for such a QA policy appears to be well thought out and

should provide the necessary direction for the further implementa-

tion of QA controls as the transition into operations continues.

'

NRC specialist inspections into the operational preparedness phase

of the Seabrook QA program have identified no substantive weaknesses.

Licensee QA interface controls for design changes, maintenance,

procurement, and testing activities appear to be working as addi-

tional components and systems achieve CAT status. Licensee attempts

I to achieve some measure of practice in the implementation of such

!

'

controls, by initiating the program first for nonsafety-related

equipment, have successfully identified some problem areas requiring

program revision.

As discussed in other functional areas in this SALP, licensee man-

{ agement's approach and priorities toward the achievement of pro-

l grammatic controls that assure quality appear well directed. The

licensee's initiation of an FSAR Consistency Review has provided

programmatic response to previous NRC concerns regarding errors in

.

the FSAR and has established a better basis for the continued de-

l velopment of test criteria and operational procdures. Other man-

1 agement initiatives, like the establishment of a site licensing

! office and a site organizational restructuring, have provided a

j better framework for responding to NRC concerns and other quality

j items requiring action. As has been recognized by previous SALPs,

i

i

l

t

s - - - - - -m,.-1.-- y w-. ,..r_ --y__..~,,___w- -

- . - _- . . . - - - -

--

.

.

29

an effective QA program has been and is in place at Seabrook Station

and continued management support continues to provide the necessary

assurance of quality.

2. Conclusion

Rating: Category 1.

Trend: Consistent. Such a consistent trend recognizes continued

management attention to quality programs during the

transitior, phases of the Seabrook project from construc-

tion to preoperational testing and on to operational

readiness.

3. Board Recommendation

None.

_ . - ..- . - . _ - _ __- -_ _ . _ _ - . - - - _ - - - . . - .. _- - _ _

. .

,

n a

j 30

!

i

t

'

G. Licensing

1. Analysis

j

'

During the last assessment period, the licensee's overall perform-

<

ance in the plant licensing area was considered satisfactory and

improving with evidence of licensee management attention and in-

.

I

volvement.

f During this current SALP period, the basis for this analysis was

the licensee's performance in support of the following licensing

actions, which were either completed or active during the current

assessment period:

--

l fire protection

'

'

--

vibration of diesel generator instrumentation

--

containment systems

--

materials engineering

--

emergency preparedness

--

instrumentation and controls

,

--

detailed control room design review

j --

electric power systems

environmental qualification of electric equipment

'

--

!

--

seismic and dynamic qualification of mechanical & electrical

equipment

,

--

licensed operator requalification

> --

safety parameter display system

--

technical specifications

During the latter half of calendar year 1985, licensing actions on

-

the part of the licensee began to pick up considerably. This clearly

l was necessary because a number of SER outstanding issues needed re-

solution. During this SALP reporting period licensee's management

involvement in licensing actions improved significantly. The lic-

i

ensee's management has been accessible and available to assure that

necessary corporate decisions are arrived at to bring about resolu-

r

tion of NRC concerns. Of particular note is the licensee's manage-

, nent involvement in the Seabrook proposed Technical Specification

! (TS) improvement program. The staff has determined that many of

'

the objectives in the licensee's TS improvement program coincide

with those of the NRC program to improve TS. The licensee's effort

in this area has been sizable and represents a commendable reflec-

tion of licensee management's involvement and commitment to this

program. ,

,

It is noted that the licensee has dedicated substanital resources

!

i

to the development of appropriate Technical Specifications (TS) for

Seabrook Unit 1. With the issuance of the " Proof and Review" edi-

tion of TS in March 1936, the licensee has initiated a substantive

I review process to correlate the TS to FSAR commitments and current

]

<

J

.

. . -- _

--- - - . _ . - --

. . --. _ _ - - - . - - - - _ .-- - -_ _ _ - _ . __ - _ . .

[.

f

.

31

i

'

design precautions, limits, and setpoint data. This demonstrates

l good initiative on the part of the licensee to determine and provide

objective evidence that the plant can be safely operated as licensed.

As noted in the previous SALP report, the licensee's management has

'

established an office in Bethesda, Maryland to provide ready atten-

tion to NRC concerns. This has continued during the current evalu-

ation period.

.

The licensee generally demonstrated an understanding of issues dur-

ing meetings and discussions with the NRC staff and in its submit-

tals to the staff. The licensee generally exhibits conservatism

where the potential for safety significance exists. The approach

to resolution of technical issues is viable and generally sound and

l

'

thorough. The licensee was willing to perform additional studies

as necessary to resolve technical issues. Generally, when the NRC

i and the licensee held differing technical positions, the licensee

'

provided a sound basis for his position. Some exceptions occurred

in the containment systems, control room design portion and safety

l parameter display system portion of the safety review. In these

!

cases, the licensee was slow in demonstrating a clear understanding

of the issues. However, once the licensee began to understand the

problems, the staff received acceptable responses.

Positions within the licensee's organization are identified and

authorities and responsibilities are defined. The licensee's lic-

ensing and engineering groups appear to be adequately staffed as

indicated by representatives who have attended numerous review

j

'

meetings. Generally, sufficient technical staff are participating

in review meetings to effect resolution of open items. The licen-

see's licensing staff has demonstrated a much needed cooperativeness

i in resolving difficult issues. Staffing at the Seabrook Unit 1

j plant appears adequate for the status of the plant as it prepares

for operation.

The licensee is responsive to a majority of NRC concerns and has

i

taken the initiative to resolve issues by requesting conference

.

calls and meetings and has then followed up with responsive submit-

l tals. In general, responses have been technically sound and ad-

!

dressed NRC concerns in a professional manner. The licensee pro-

! vided effective licensing liaisons between their technical staff

2 and NRR. Except for certain of the technical issues noted above,

licensee responses have been timely.

h

l

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

-

O

e

32

2. Conclusion

Rating: Category 1.

Trend: Consistent

3. Board Recommendations

None.

- - - + --___- - - _ J

s

e

33

V. SUPPORTING DATA AND SUMMARIES

A. Construction Deficiency Reports (CDRs)

Twenty-four CDRs were reported by the licensee during the assessment

period. Of this total, five potential deficiencies were subsequently

withdrawn by the licensee with NRC inspection confirming the validity

of the licensee analysis and resultant cancellation. All reported de-

ficiencies are listed in Table 1 and were evaluated and discussed, as

appropriate, in the affected functional area.

While analysis of the listed CDRs for causal linkage has identified no

unacceptable chains per statistical acceptance criteria, it was noted

that seven of the ten deficiencies analyzed as vendor problems were re-

lated to the electrical discipline. This appears to be consistent not

only with CDR data from the previous SALP period where eight of.a total

22 CDRs were caused by vendor problems in electrical components, but also

with other NT0L plant data where electrical component deficiencies are

more numerous than those reported in other disciplines. Both the status

of construction progress and the nature of preoperational testing acti-

vities as the plant approaches operations, tend to identify and accentu-

ate electrical problems. However, this is not perceived to be a pro-

grammatic problem with electrical CDRs and no additional corrective

measu es, other than those taken to correct the individual deficiencies,

are believed necessary since no generic electrical problem appears to

exist.

.B. Investigations and Allegations Review

During this assessment period five allegations were received, only one

of which is open with an investigation by the NRC Office of Investiga-

tions currently in progress. The other four allegations were inspected

and closed with no substantive negative findings resulting from the NRC

follow-up of the stated concerns.

Additionally, the investigation / inspection of five allegations reported

during previous SALP periods were completed during this assessment period.

Four of these allegations were unsubstantiated, while NRC follow-up of

the fith revealed that the licensee had identified the problem and re-

ported it under the provisions of 10 CFR 50.55(e). NRC inspection of

the resulting CDR confirmed adequate licensee corrective action and meas-

ures taken to prevent recurrence of the problem.

Early in this assessment period, the licensee established the Employee

Allegation Resolution (EAR) program at Seabrook Station to investigate,

track and respond to allegations / concerns brought to their attention.

NRC interface with the EAR program has provided both an independent

verification of programmatic actions taken by the licensee to address

quality concerns, and an effective means of utilizing the licensee in-

spection resources without compromising the conduct or results of the

s

e-

34

NRC investigation. In three specific cases, the EAR program was called

upon to investigate and respond to allegations received by the NRC. All

three allegations have been closed with no substantive findings and with

independent NRC inspection corroborating both the EAR investigation re-

3 sults, and the implementation of corrective measures to avoid similar

problematic situations in the future.

C. Escalated Enforcement Action

None.

D. Management Conferences

1. March 21,1985 - a special, announced management meeting at NRC re-

quest to discuss the results of the Region I SALP board convened

-to evaluate licensee performance from July 1,1983 to December 31,

1984.

2. May 15,1985 - a special, announced management meeting upon mutual

NRC/ Licensee agreement to discuss the Seabrook project status and

schedule and to review licensee initiatives in the areas of the

Employee Allegation Resolution (EAR) program, an FSAR consistency

review, and establishment of a site licensing office.

3. October 2,1985 - a special, announced management meeting upon mutual

NRC/ Licensee agreement to discuss the Seabrook Staion cable tray

design and seismic tray testing in progress, intended to qualify

extensive bracing redesign.

4. October 16,1985 - a special, announced management meeting upon mutual

NRC/ Licensee agreement to discuss the p'roject construction, licens-

ing and state regulatory hearing status and emergency planning

schedules.

E. Licensing Activities

1. NRR Site Visits, Audits and Management Meetings

The following listing represents those subject areas where the NRR

personnel have visited Seabrook Station for the purpose of conduct-

ing activities related to Unit I licensing. A significant number

of meetings'were also conducted between the applicant and NRR per-

sonnel with meeting notices and summaries documenting the discussion

topics, as applicable.

--

Cable Tray Support Qualification

--

Caseload Forecast Panel

--

Emergency Preparedness

--

Environmental Qualification of Equipment

--

Fire Protection / Safe Shutdown

-

o

,

a

35

--

Power Systems Review

--

Pump and Valve Operability Review Team

--

Security

--

Seismic Qualification Review Team

--

Technical Specification Review

Also, on September 27, 1985, the Director of the Office of NRR met

with applicant representatives at Seabrook Station to discuss the

project status and tour the plant to observe Unit I construction

progress.

2. Licensino Documents

The following listing represents the documents issued, to date, by

NRR as part of the Operating License review for Seabrook Unit 1.

--

Final Environmental Statement (FES) - December,1982

--

Safety Evaluation Report (SER) - March,1983

--

SER (Supplement 1) - April, 1983

--

SER (Supplement 2) - June,1983

--

SER (Supplement 3) - July,1985

--

Technical Specifications (" Proof and Review" edition) - March,

1986

1

--

g ,

o

4

.

.

TABLE 1

CONSTRUCTION DEFICIENCY REPORTS

(1/1/85 - 3/31/86). '

SEABROOK STATION

CDR NUMBER DEFICIENCY CAUSE CODE

85-00-01 Failure of Gould molded case circuit breakers to B

pass trip test

85-00-02* Missing cation bed demineralizer radiography A

85-00-03* Reduced discharge head for the service water C

pumps

85-00-04 Lining problem in tne Airflex instrument air

'

D

.

hoses -

85-00-05* " Questionable integrity of limit switch brackets

'

D

on SI valves

85-0G-06 Brown-Boveri circuit breaker switch wiring damage B

'

85-00-07 Questionable HVAC heat load desig~n calculations E

85-00-08* Incompatible grease in fan motor bearings .A

85-00-09 Inadeouate spacing between battery cells and rack B

85-00-10 Logic deficiency in the ' f% high flow isolation E

signal

85-00-11 Incorrect '.u... delay links in circuit breaker over- B

currer- t ir evices

~

85-00-12* Georg , Teu - RUDL computer program error.

"

E

85-00-13 Detachment of lining in the service water piping C

and valves

85-00-14 Excessive leakage in nitrogen gas supply contain- B

, ment isolation valves ,

85-00-15 Salt water spill from the service water system in A

the water system in the auxiliary building

85-00-16 Seizure of linkage in HVAC dampers B

1

.

o

.

O

T-1-2

CDR NUMBER DEFICIENCY CAUSE CODE

85-00-17 Binding of contacts in Gould motor control B

starters

85-00-18 Disc malfunctions in Dresser valves used in gas B

systems

85-00-19 Misapplication of Type MDR relays in the solid B

state protection system

85-00-20 Failure of HVAC air dampers to close under certain C

air flow conditions

85-00-21 Improper terminal boards used in the uninterruptible B

power supply inverters

86-00-01 Design deficiency in undersizing the diesel genera- E

tor air vent line

86-00-02 Pressurizer pressure transmitter drift in excess of C

design basis

86-00-03 Impact of a P-10 permissive malfunction on protec- E

tive system functions

Cause Codes

A - Personnel / Procedure Error D - Construction Error

B - Vendor Problem E - Design Error

C - Component Failure

• Reported by the licensee as a potential CDR and subsequently cancelled. Basis

for nonreportability was reviewed by NRC and item is considered closed.

O

s

0

TABLE 2

INSPECTION HOURS SUMMARY

(1/1/85 - 3/31/86)

SEABROOK STATION

FUNCTIONAL AREA HOURS  ?; 0F TIME

A. Construction 3788 48

B. Preoperational Testing 2451 31

C. Fire Protection and housekeeping 296 4

D. Operational Readiness 743 9

E. Emergency Preparedness 634 8

F. Assurance of Quality -* --

G. Licensing -* --

TOTALS 7912 100

• Hours expended in these activities are either included in other functional areas

or considered not to be direct inspe: tion effort.

NOTE: Additionally, a total of 12 inspection hours were expended during this as-

sessment period in the review of preservation, protection and preventitive

maintenance activities, for Seabrook Unit 2 (a plant still in an indeter-

minate status).

,

e

O

s

0

TABLE 3

ENFORCEMENT DATA

(1/1/85 - 3/31/86)

SEABROOK STATION

A. Number and Severity Level of Violations

Severity Level I - 0

Severity Level II - 0

Severity Level III - 0

Severity Level IV - 9

Severity Level V - 2

Deviation - 2

TOTAL T3~

B. Violations vs. Functional Area

IV V DEV.

A. Construction 4 2 1

B. Preoperational Testing 1

- -

C. Fire Protection and Housekeeping 1

-

1

D. Operational Readiness - - -

E. Emergency Preparedness - - -

F. Assurance of Quality 4 - -

G. Licensing - - -

TOTALS * 10 2 2

• NOTE: The total number of Severity Level IV violations listed vs. functional area

is one greater than the total issued (ie: Section A above). This occurred

because of the issuance in the 86-14 inspection report of a single violation

containing multiple findings, each in a different functional area.

i

l

L

O

o

T-3-2

C. Listing of Violations

SEVERITY FUNCTIONAL

REPORT SUBJECT LEVEL AREA

85-01 Failure to translate flow restrictor IV A

sizing tolerances into the design

details

85-01 Failure to document and track noncon- IV F

forming conditions for all affected

components

85-03 Failure to attach required nameplates V A

to safety-related equipment

85-06 Failure to install UL approved valves in DEV. C

the fire protection water supply system

85-15 Failure to control design / construction IV A

interfaces with regard to pipe support

installation

85-15 Failure to detail installation criteria IV A

for instrument tubing crossing siesmic

boundaries

85-15 Incorrect dispositioning of nonconform- IV F

ance reports on instrument tubing

85-20 Failure to implement complete corrective IV F

action on identified component pedestal

cracking problems

85-20 Failure to control a design change and IV F

implement adequate corrective action on

valve bracket rework

85-25 Failure to comply with commitments to DEV. A

to NRC Regulatory Guide 1.97

86-12 Failure to translate an enclosure build- IV A

ing ventilation design requirement into

the construction details

86-14 Failure to follow procedures in fire IV B/C

sealant and preoperational testing

activities

86-14 Failue to adequately control component V A

identification