ML20206J645
| ML20206J645 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/20/1986 |
| From: | Sherwin Turk, Turks S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Harbour J, Luebke E, Wolfe S Atomic Safety and Licensing Board Panel |
| References | |
| CON-#286-730 OL, NUDOCS 8606270231 | |
| Download: ML20206J645 (1) | |
See also: IR 05000443/1986099
Text
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UNITED STATES
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E ' }, NUCLEAR REGULATORY COMMISSION / W % ,
p WASHINGTON, D. C. 20555 /j
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JUN 2 01986 O ~UW"
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Sheldon J. Wolfe, Esq. , Chairman Dr. Jerry Harbour
Administrative Judge Administrative Judge
Atomic Safety and Licensing Atomic Safety and Licensing
Board Panel Board Panel
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
Washington , D.C. 20555 Washington, D.C. 20555
Dr. Emmeth A. Luebke
Administrative Judge
Atomic Safety and Licensing
Board Panel
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
In the Matter of
PUBLIC SERVICE COMPANY OF NEW IIAMPSIIIRE, et al. --
(Seabrook Station, Units 1 and 2)
Docket Nos. 50-443 OL and 50-444 OL
Dear Administrative Judges:
Enclosed for your information is a June 5, 1986 letter from Thomas E.
Murley, Regional Administrator, NRC Region I, to Robert J. Harrison ,
President and CEO, Public Service of New llampshire, enclosing the NRC
Region I Systematic Assessment of Licensee Performance (SAPL) Report No.
50-443/86-99 for Seabrook Station, Unit 1. You may wish to note that the
Applicants' off-site emergency preparedness is among the items evaluated
(at pp. 25-26) .
Sincerely,
( /Q
Sherwin E. Turk
Deputy Assistant Chief
flearing Counsel
ec: With Enclosure-Service list
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1 JUN 0 51986 -
Docket No. 50-443
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Public Service of New Hampshire
ATTN: Mr. Robert J. Harrison
President and Chief Executive Officer
P. O. Box 330
- Manchester, New Hampshire 03105
- Gentlemen
- Subject
- Systematic Assessment of Licensee Performance (SALP) Report No.
50-443/86-99
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On May 14, 1986, the NRC Region I SALP Board reviewed and evaluated the performance
of activities associated with the Seabrook Station, Unit 1. This assessment is
j documented in the enclosed SALP Board report. A meeting has been scheduled for
June 10, 1986 at 10:00 a.m. at the site to discuss this assessment. That meeting
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is intended to provide a forum for candid discussions relating to the performance
- evaluation.
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At the meeting, you should be prepared to discuss our assessment and your plans
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to ensure continued emphasis upon those activities which would have a positive ef-
i fect upon your performance through Seatrook's transition into the operations phase.
l Any comments you may have regarding our report may be discussed. Additionally,
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you may provide written comments within 30 days after the meeting.
Following our meeting and receipt of your response, the enclosed report, your writ-
ten response (if deemed necessary), and a summary of our findings and planned ac-
tions will be placed in the NRC Public Document Room.
1
I Your cooperation is appreciated.
! Sincerely,
i
OrigYnal Maned tiy
! thomas I. Murlev
Thomas E. MurTey
i Regional Administrator
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! Enclosure: NRC Region I SALP Report No. 50-443/86-99
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f cc w/ encl:
l John DeVincentis, Director, Engineering and Licensing
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William B. Derrickson, Senior Vice President
i Warren Hall, Operational Services Supervisor
! Donald E. Moody, Station Manager - Seabrook Station
Gerald F. Mcdonald, Construction QA Manager
i Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
! State of New Hampshire
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Public Service Company of New Hampshire 2
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bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
DRP Section Chief
J. Allan, RI
H. Thompson, NRR
S. Ebneter, RI
T. Martin, RI
J. Partlow, IE
T. Murley, RI
J. Taylor, IE
K. Abraham, RI (2 copies)
SALP Board Members
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Schumacher/m 1sasser We tircer {I4rscki
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5/21/86 & p g g Qg , .g
0FFICIAL RECORD COPY
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U.S. NL' CLEAR REGULATORY COMMISSION .
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT 50-443/86-99
- PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE
SEABROOK STATION, UNIT l'
. ASSESSMENT PERIOD: JANUARY 1,1985 - MARCH 31, 1986
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BOARD MEETING DATE:
MAY 14, 1986
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TABLE OF CONTENTS
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I. INTRODUCTION......................................................... 1
- A. Purpose and 0verview............................................ 1
B.
C.
SALP Board Members.............................................. I
Background...................................................... 2
j II. CRITERIA............................................................. 6
I I I . SUMMARY O F RES U LTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
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A. Overall Facility Evaluation..................................... 8
B. Facility Performance............................................ 9
IV. PERFORMANCE ANALYSIS................................................. 10
A.
B.
Construction....................................................
Preoperational
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Testing.......................................... 13
C. Fire Protection and Housekeeping................................ 16
D. Operational Readiness........................................... 18
E. Emergency Preparedness.......................................... 25
- F. Assurance of Qua11ty............................................ 27
j G. Licensing....................................................... 31
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V. SUPPORTING DATA AND SUMMARIES........................................ 33
A. Construction Deficiency Reports................................. 33
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B. Investigations and Allegations Review........................... 33
C. Escalated Enforcement Actions................................ 34
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D. Management Conferences.......................................... ... 34
E. Licensing Activities............................................ 34
TABLES
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TABLE 1 - CONSTRUCTION DEFICIENCY REPORTS
TABLE 2 - INSPECTION HOURS SUMMARY
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TABLE 3 - ENFORCEMENT DATA
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I. INTRODUCTION
A. Purpose and Overview
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 j
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 licensea 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-
3 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 Note 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
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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, DRP (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)
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on July 7, 1976. Each reactor is a Westinghouse four-loop, PWR rated
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at.1198 MWe and is housed in a reinforced concrete containment structure.
l 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
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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-
spensibility for all activities related to Seabrook, as is specified in
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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
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responsibility of PSNH, but also the specific duties of both NHY and
! YAEC.
a. Licensee Activities
At the beginning of this SALP assessment period, the licensee pro-
jected Unit I 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
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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
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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 I to be 98%
complete.
' Other licensee activities during this SALP period included continued
operator licensing, emergency preparedness, and operational readiness ;
i planning and program reviews. New fuel was initially received on *
site in February, 1986 and an Emergency Drill, exercising NRC, the
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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.
l 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 witt a third inspector assigned on site since May, 1985.
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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
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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 I Specialist Inspections Number
Construction 8
Preoperational Testing 15
Fire Protection 2
Operational Readiness 4
Radiological Controls
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! Security 3 i
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Operator Licensing 2
Resident Inspections 9
Team Inspections
Management Reorgarization 1
NDE Independent Maasurements 1
EP Appraisal 2
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Safe Shutdown (Appendix R) 1
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As-Built Plant 1
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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 summarized in Table 3.
i.
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
area 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 tvery 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, 1936 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.
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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- '
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ing water system commenced that same day.
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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
19, 1986. for eventual
Initial i
use at Seabrook Unit 1, was issued on December
fuel receipt and storage on site, in accordance with the provisions
of the 10CFR70 license, commenced in Febraury, 1986.
A Prehearing Conferer.ce for the EP phase of the ASLB hearings was
25-26,1986. In
conducted in Portsmouth, New Hampshire on March
accordance with the ASLB Memorandum and Order, dated January 17,
1986, the hearings for New Hampshire Offsite Emergency
21, 1986.Planning
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Contentions are scheduled to commence on July
The " Proof & Review" edition of the Seabrook Technical Specifica-
The licen-
tions (TS) was issued for comment in late March,1986.
see, Region I and the Office of NRR are currently involved in re-
view activities for TS conformance te FSAR commitments, plant-
specific as-built conditions, and operational safety considerations.
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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.
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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.
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6. Staffing (includingmanagement).
l 7. Training and qualification effe:tiveness.
l Based upon the SALP Board assessment each functional area evaluated is clas-
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sified into one of three performance categories. The definitions of these
performance categories are:
1 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
j management attention and involvement are evident and are concerned with nuclear
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safety; licensee resources are adequate and reasonably effective so that
l 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 's acceptable and considers nuclear safety,
' but weaknesses are evident; licensee resources appear to be strained or not
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effectively used so that minimally satisfactory performance with respect to
a operational safety is being achieved.
The SALP Board also assessed each functional area to compare the licensee's
i performance during the last quarter ot* the assessment period to that during
- the entire period in order to determine the recent trend for each functional
area. The trend categories used by the SALP Board are as follows:
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Improving: Licensee performance has generally improved over the last quarter
of the current SALP assessment period.
Consistent: Licensee 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.
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j III. SUMMARY OF RESULTS
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! A. Overall Facility Evaluation
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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
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during this period was far in excess of that of previous SALP periods.
An evaluation of a broad spectrum of ifcensee 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-
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stallation has met licensing commitments. The preoperational test pro-
1 gram has confirmed the existence of quality construction with generally
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outstanding test results and minimal number of test exceptions. In al-
- most all cases, a high level of performance was achieved with evidence
i of effective planning for those areas where program implementation could
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not yet be fully assessed. Management attention continued to be focused
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on improving those areas identified in the previous SALP period as poten- -
l tial problems. As a result, only minor problems were observed during
! the period.
Regarding operational preparedness, thorough planning and a high level
- of management attention to the readiness of plant hardware, programs, -
l and procedures are very much in evidence. Licensed operator training
i and the preparation and receipt of new fuel are noteworthy examples of
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the effectiveness of the licensee's programs. Also, the licensee's de-
velopment of the security program represents effective management plan-
ning to integrate experienced staff supervisors with a trained contract-
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security force. In summary, where operational programs have been imple-
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mented, the quality exhibited during construction appears to have carried
1 over during the transition process from construction into operations.
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While licensee responsiveness to operational issues has been appropri-
! ately directed, it should be noted that these programs are still under
l development. Future inspection and assessment of the full prcgram im-
i plementation will provide an ongoing measure of their effectiveness.
As 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.
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B. Facility Performance
CATEGORY CATEGORY
LAST THIS
PERIOD PERIOD
(7/1/83- (1/1/85- RECENT
I 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 l' Consistent
- Trend during the last quarter of the current assessment period.
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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
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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-
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
(e.g., housekeeping) was solicited to: (1) correct deficiencies,
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and (2) provide direction to an improvement in the trend in this
area. During the previous SALP period it was also noted that posi-
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,
a Construction Team Inspection (CTI) was conducted in June, 1985
to asses. the effectiveness of the resumption of construction acti-
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-
viousiy been identified. The results of this CTI (three violations,
three weaknesses, and three strengths) provided no indication of
programmatic deficiencies. In fact, the site management organiza-
tion (i.e., the area directed by the CTI scope to be the focal point
of inspection effort) was identified as a licensee 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
was found to result from deficient construction.
, This theme of hardware installation and construction in compliance
with design requirements and licensing commitments appears to be
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corroborated also by another more recent CTI. In March, 1986, an
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As-Built Construction Team Inspection was conducted with a primary
inspection focus on hardware. Vhile 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
hardware problems.
The NDE van inspection in July, 1985 did document some concerns re-
garding the conduct of the Preservice Inspection (PSI) program at .
Seabrook Unit 1. An unresolved item was written to track several
PSI questions involving data keeping, calibration, weld surface
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
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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.
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
control nature, than of the identification of ~1mproper construction.
Such issues include the improper usage of selected revisions of ASME
Code Cases, failure to implement commitments to Regulatory Guide
(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
complete and responsive.
For example, when problems were identified with the licensee adop-
tien and documentation of certain ASME Code Cases, not only was a 1
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 assessme'nt period
provided sufficient opportunity for the inspection of electrical
and instrumentation activities, not only because by nature such work l
l
l
1
- _ _ - , . . _
- . - - _ ,__ _ .- .___ , . - - . ~. . . _ . . -
_ _ .
.
12
9
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 j
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-
terim and final 10CFR50.55(e) reports, as applicable, and involve-
ment in the in process troubleshooting of several of these defi-
ciencies has confirmed adequate liaison with the vendors and working
interfaces among engineering, constru-tion, 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 deft-
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
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.
i
1
_ _ .
_- - -
- . - . . - ._ _ - - .- - _.- -. -.-
, .,
1
.
- 13
- .
I
i 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)
lI 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
j based upon a limited NRC inspection effort.
l
l 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
i included the Reactor Coolant System (RCS) Hydrostatic test, the
- Reactor Protection System test, the integrated system Hot Functional
l 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-
I
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.
STO troubleshooting of some diesel generator air start problems
4 (identified during Phase 1 testing in 1984) ultimately led to the
I discovery of an undersized diesel starting air vent line (reported
- as 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-
)
i
.
l
,,--,r.--.-m, - . , , .,,w. ,-----g , - - -er,--- -~ , - - - -,. - ,-~ - -en... .- r-,, . - - - > - - -
.
.* .
!
.-
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
preoperational 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 hunored 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 problems 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.
1
I
. __ _
.:
, 3
'
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.
.
i
8
l
4
__ , , . . _ _ . _ _ _ . . _ _ . ,_ _ - _ , .
. .
. .
..
..
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 to 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 relt,ted 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 ha:ard 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
. . _ _ . . _ - _ - __ _ _ _ _ _ . _ _ . . - _ - _ _ - _ . -
E -
.
-
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.
l The inspections team's conclusion was that the licensee's fire pro-
taction 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 '
1
l 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
1 the installed valves with similar U.L.-listed valves and demon-
l 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
i status of plant activities; construction areas require continual :
j attention, buildings turned-over to the plant staff appear to be
j maintained in good order, and other plant areas appear to improve
i
i
as the preoperational testing and turnover process progress.
The housekeeping problems raised during the past SALP appear to have
4
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
j enters operations.
2. Conclusion
i
Rating: Category 1.
l Trend: Consistent.
! 3. Board Recommendation
\
None.
l
!
l
l l
'
,
i
., - , _ , - . - - . -
, _ , - , - - - - . , . - , , . . --------------.-----------.,---,,,----m-- -
,me--.-. *-----,-------e=r-v--w+---+-=w' - - "
- . _ - _ - _ . .- ___ -. .. . ~ . - .- .
,
." .
.
"
18
-
i
4
D. Operational Readiness (743 hours0.0086 days <br />0.206 hours <br />0.00123 weeks <br />2.827115e-4 months <br />, 9*4)
i
1. Analysis
J
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-
t
petent, technical training program and the resulting high pass rate
of SRO/R0 candidates in their initial licensing examinations. Dur-
ing the current SALP period, the functional area of Operational
,
Readiness has been expanded to include consideration of procedures
j and staffing, radiological controls, and security, in addition to'
operator licensing. Analysis of each of these areas is discussed
.
! '
separately below.
t
a. Procedures and Staffino
During the current SALP period four separate Region I inspec-
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
i
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
I
identified as a result of these operational preparedness in-
- spections, to date. Licensee attentiveness to an FSAR commit-
ment to have the Fuel Building and the appropriate fuel hand-
l ling and storage systems completed and tested prior to new fuel
i
i
receipt ensite was noted. Scheduled fuel receipt was first
delayed to allow time to meet such a commitment and subse-
j
quently, removal of the new fuel from the storage casks was
j
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),
i
calibration, inservice testing, material storage, records
storage, procurement, safety review committees, and admini-
!
l
l
i
_ _ ._ __
..
. .
-
I .
'
19
.
!
.
'
strative procedures all resulted in a finding of adequate pro-
gress and proper direction by the licensee operations staff
i
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
4 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
J
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,
i
NRC inspection effort.has also been devoted to the licensee's
i
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 noniteensed training was raised in that nb matrix and
,
' comprehensive schedule of such training was yet available to
demonstrate that all personnel training needs would be ful-
i 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. ;
b. Operator Licensine
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
i 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.
<
!
_ _ _ - ______
.- .- -- . -. -.- ---- -- -----
l
'
- .- l
1 <
j !
j -
,
-
j 20 !
i l
j 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 !
l for a July 1987 operator license examination.
i
j 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.
4
The 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
- the March 1985 operator license examination exit meeting. This
i same weakness was again identified during the September 1985
i examination. It continued to make the development of quality
i simulator scenarios difficult for operator license examination
j purposes.
l The first group of cold license candidates was examined in
- September, 1984. These operators and those that closely fol-
1 lowed will be scheduled for renewal near the proposed time of
j 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
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
, not only addresses the operator's need for skill and knowledge
i reinforcement, but also identifies unique areas of specialized l
training that are required in preparation for the upcoming '
startup test program. The licensed operator requalification
j training program at Seabrook is considered an additional
j
'
strength in the already strong operator licensing training !
program.
{
r
With respect to licensed operator training and qualification !
at Seabrook, the licensee continues to devote substantial re- l
1 sources _to the training program. The licensee training staff i
l appears to be both technically competent and professional, i
i
Responsiveness on the part of the licensee to suggestions to I
improve training has been evident. i
t
c. Security
l
Three preoperational security program reviews were performed I
during the assessment period by region-based inspectors. Rou-
i tine resident inspections continued throughout the assessment i
l period.
I
l
l 1
(
l .
, ,
.
21
.
l The effectiveness of the licensee's planning for the security
l program was evident from the first preoperational review. De-
I velopment of the security program was on schedule and station
!
'
administrative proceJures pertaining to plant security and
security program irplementing 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 featuras 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.
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-
matic security controls were being properly implemented.
Licensee management and security supervisors have provided a
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 is implemented. While NRC in-
spection effort during this SALP period cannot provide a com- i
plete assessment of the licensee's security controls, both the
, lack of significant problem areas and management responsiveness l
to security issues provide evidence of properly directed lic-
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-
tions 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 (SORC), radiation safety
committee (RSC-ALARA), and frequent routine management meetings.
All interfaces between the health physics (HP), radioactive
waste, chemistry, 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 the radiation 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 procedures 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-
i
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.
!
'
__ ~ _. . _ - .
_ _ . _ . _ _ __
__ . . _ _____ __
- .
23
F
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
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
work permit procedures was noted, and the licensee has imple-
mented an approved revision which corrected the deficiency.
Procedures for fuel receipt and the posting and controlling
of a radiologically-controlled area (RCA) were found to have
been effectively used. Recordkeeping was adequate, but docu-
mentation of the dose assessment methodology was found to re-
quire additional licensee attention. Subsequently, the licen-
see 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-
i
'
keeping system is being utilized. During this inspecticn
period, additional portable survey mete s, respirators, and
air samplers have been added to the licensee's equipment stores,
while even more equipment is on order. However, testing and
turnover of certain systems to the station staff is not yet
complete.
While the radioactive waste (RW) management, transportation,
and effluent control and monitoring areas did not receive de-
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
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
technician staffing is almost complete and that health physics
training to be provided to radioactive waste handling personnel
is being developed.
._
. _ - . - . . - _ - - - -_
.
,'
. 24
.
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
areas (radiation protection, waste management, transportation
and effluent control and monitoring) in regard to organization
and management controls, staffing and training, work controls
and procedures, and facilities and equipment exceeds what would
be routinely found at a plant like Seabrook Station Unit 1 at
this preoperational stage. Since radiological controls func-
tions have not yet been adequately challenged by operational
requirements, a full assessment cannot be made at this time.
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
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
demonstrated up to this point.
2. Conclusion
Rating: Category 1.
Trend: Consistent.
3. Board Recommendation
A normal level of inspection activity on part of the NRC shall be
maintained during the next SALp assessment period due to the pre-
operational nature of the findings in this area.
l
t
,
. - - .
.
'. .
-
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 NTOL 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 ta completion because equipment, training, and
procedures had no. )een 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 individuo's to fill the key
emergency 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
i
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-
l site deficiencies in the implementation of an adequate emergency
l response were identified during the exercise. In general, personnel )
l
)
l
l
1
. _ _ _ _ _ _ . . _ _ _ _ ___
_..
..
.
'
26
F
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 functioned
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.
.
_ , . . - . . - - .
- .
.~
-
27
9
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 upcn 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
i 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.
l
As was discussed in the CTI as a strength, the initiation of cor-
l
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
- _ _ . _ _ - . _
_ . - - . ._ _ _ _ _ _ _ . . _ _ __
_ _ _. - _ . _ _ . -_ _ -. _ _ _ _ _ _ _ _
,"
.
-
28
,
'
comprehensive vein as the inspection program that first identified
the items, the results are continuing problems and, as was noted
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 inspection.
Despite the examples of corrective action problems, noted above,
i
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,
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 defir.es 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
j should provide the necessary direction for the further implementa-
t
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
! to achieve some measure of practice in the implementation of such
l controls, by initiating the program first for nonsafety-related
,
equipment, have successfully identified some problem areas requiring
,
program revision.
i
l As discussed in other functional areas in this SALP, licensee man-
} agement's approach and priorities toward the achievement of pro-
i
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-
velopment of test criteria and operational proedures. Other man- .
agement initiatives, like the establishment of a site licensing !
office and a site organizational restructuring, have provided a
better framework for responding to NRC concerns and other quality
l
items requiring action. As has been recognized by previous SALPs,
l
l
. - _. _ -. - -.. _- - -- - - - - - ---
. .
,
'
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
transition phases of the Seabrook project from construc-
tion to preoperational testing and on to operational '
readiness.
3. Board Recommendation
None.
.
- - - , -
,,,- - : ~
,...n_,_, . , ,,, ,- e
_ _ _ - - _ _ _ _ _ _ _ _ .
. .
.
'
30
.
G. Licensing
1. Analysis
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-
volvement.
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:
--
fire protection
--
vibration of diesel generator instrumentation
--
containment systems
--
materials engineering
--
--
instrumentation and controls
--
detailed control room design review
--
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
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-
entee's management has been accessibla and available to assure that
necessary corporate decisions are arrived at to bring about resolu-
tion of NRC concerns. Of particular note is the licensee's manage- l
ment 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 t
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
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 1986, the licensee has initiated a substantive ,
!
review process to correlate the TS to FSAR commitments and current
l
l
l
l
_ __ ._ _
f
-
.
i
.
' *
31
-
.
design precautions, limits, and setpoint data. This demonstrates
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-
tais to the staff. The licensee generally exhibits conservatism
where the potential for cafety significance exists. The approach
to resolution of technical issues is viable and generally sound and
thorough. The licensee was willing to perform additional studies
as necessary to resolve technical issues. Generally, when the NRC
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
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
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
in resolving difficult issues. Staffing at the Seabrook Unit 1
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
taken the initiative to resolve issues by requesti'ng conference
calls and meetings and has then followed up with responsive submit-
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
and NRR. Except for certain of the technical issues noted above,
licensee responses have been timely.
_ __- _. _ _ _ _ - _ . _
- _ .- . .-. -_ ._ _.
- .
.
32
9
2. Conclusion
Rating: Category 1.
Trend: Consistent
3. Board Recommendations
None.
.
. - - . - .- . -. - .- . _ - - . . _- . . - -
..
,
.
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
j exist.
1
,B. Investications and Allegations Review
,
During this assessment period five allegations were received, only one
i
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 sLbstantive negative findings resulting from the NRC
follow-up of the stated concerns.
i Additionally, the investigation / inspection of five allegations reported
during previo0s 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
i the resulting CDR confirmed adequate licensee corrective action and meas-
! ures taken to prevent recurrence of the problem. ,
j
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
t
-_ _ _ _ _ . _ _ _ _ _ _ _ . . ~ _ _ _ _ _ _ _ _ . . . _ _ _ . _ _ . - _ _ _ _ _ , _ . . _ . , - . , _ _ , _ . _ . - - . . _ - . _ - _ _ _ , -
- ._ - . - . - . _. . . -. . _
- -- .- - - -
- .
4
.
-
34
-
i
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- i
sults, and the implementation of corrective measures to avoid similar '
problematic situations in the future. ,
!
C. Escalated Enforcement Action
None.
3
D. Management Conferences j
March 21,1985 - a special, announced management meeting at NRC re- !
1.
i quest to discuss the results of the Region I SALP board convened
- to evaluate licensee performance from July 1,1983 to December 31, j
1984.
'
- 2. May 15,1985 - a special, announced management meeting upon mutual
! NRC/ Licensee agreement to discuss the Seabrook project status and
i schedule and to review licensee initiatives in the areas of the
, Employee Allegation Resolution (EAR) program, an FSAR consistency
j review, and establishment of a site licensing office,
i '
3. October 2,1985 - a special, announced management meeting upon mutual ,
'
1 NRC/ Licensee agreement to discuss the Seabrook Staion cable tray
J
design and seismic tray testing in progress, intended to qualify
l extensive bracing redesign.
I
4. October 16,1985 - a special, announced management meeting upon mutual
NRC/ Licensee agreement to discuss the project construction, licens-
j ing and state regulatory hearing status and emergency planning
'
schedules.
I i
E. Licensing Activities
i
l 1. NRR Site Visits, Audits and Management Meetings
4
, 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. ;
i --
Cable Tray Support Qualification i
- --
Caseload Forecast Panel 1
! --
--
Envirenmental Qualification of Equipment
--
Fire Protection / Safe Shutdown
)
,
, - - n--. .-.--,---v-,,.n. -m . - ~ . - , -.-- --- - ,,-- ,,,.,,,,_.,-,--,-n,- ,n ,- , ,., - - _ - - ,.m, .,- . . . , - - . .
. - - - - - . . - - .v,
. . -- .. . .. - _- _ _-
.' .
r 35
,
--
Power Systems Review
--
Pump and Valve Operability Review Team
--
Security
--
Seismic Qualification Review Team
--
Tecnnical 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. Licensing Documents .
'
The following listing represents the documents issued, to date, by
NRR as part of the Operating License review for Seabrook Unit 1.
4
--
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
)
!
!
l
,
-
1
1
.
I
'!
i
i
.
4
_ _ _ _ _ _ . __ - . _ _ _ _ _ _ _ _ _ _ . _ , _ - , _ . _ _ - _ , - - _ _ _ _ .
- _ . _ _. ___ __ __. _ _ _ _ . _ . - _
._. -
_ _ , _ _
.* ,
"
.
.
'
TABLE 1
CONSTRUCTION DEFICIENCY REPORTS
(1/1/85 - 3/31/86)
SEABROCK 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 the Airflex' instrument air 0
hoses
,
85-00-05* Questionable integrity of limit switch brackets D
"
on SI valves
85-00-06 Brown-Boveri circuit breaker switch wiring damage B
j 85-00-07 Questionable HVAC heat load design calculations E
85-00-08* Incompatible grease in fan motor bearings A
85-00-09 Inadequate spacing between battery cells and rack B
<
85-00-10 Logic deficiency in the EFW high flow isolation E
signal
85-00-11 Incorrect time delay links in circuit breaker over- B
current trip devices
,
85-00-12* Georgia Tech STRUDL 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
i
85-00-16 Seizure of linkage in HVAC dampers 'B
l
)
!
!
I
__ __. _ . _ _ _ . _ . . _
_ . _ . _ _ _.,. __._ _ _ _ . . . . _ - _ _ . _ . . _ . _ . . - -
_ - _ _ _ _ _ _ _
.. .
6
'
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
ter 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-Personne)/ProcedureError 0 - Construction Error
8 - 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.
. _ . . __ ._
. . _ .
,r , ,
"
.
.
TABLE 2
INSPECTION HOURS SUMMARY
(1/1/85 - 3/31/86)
SEABROOK STATION
FUNCTIONAL AREA HOURS % OF 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 IUD
- Hours expended in these activities are either included in other functional areas
or considered not to be direct inspection effort.
NOTE: Additionally, a total of 12 inspection hours were expended during this as-
sessment period in the review of preservation, protection and prevent 1tive
maintenance activities, for Seabrook Unit 2 (a plant still in an indeter-
minate status).
.
_.__ _ __. _ m - -- __
.- ,
.
.
.
7
TABLE 3 -
ENFORCEMENT DATA
(1/1/85 - 3/31/86)
SEABROOK STATION
A. Number and Severity Level of Violations
0
0
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.
- . - - - - - - + - ,
_
." ,
. *
T-3-2
,
C. Listing of Violations
SEVERITY FUNCTIONAL
rep 0RT SUBJECT LEVEL AREA
Failure to translate flow restrictor IV A
85-01
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
. _ . .