ML20246B976
| ML20246B976 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/16/1989 |
| From: | Eselgroth P, Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20246B943 | List: |
| References | |
| CAL-89-11, OL, NUDOCS 8908240136 | |
| Download: ML20246B976 (171) | |
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- UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1
l In the Matter of ) ; i
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l l PUBLIC SERVICE COMPANY OF ) Docket No. 50-443 OL l NEW HAMPSHIRE, gt; gl. )- l
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l (Sotbrook Station, Units 1 and 2) ) i. ~ AFFIDAVIT OF THOMAS T. MARTIN AND PETER W. ESELGROTH~ l Thomas T. Martin and Peter W. Eselgroth, being first duly sworn, hereby cffirm that the responses to the-questions set forth herein,. designated by. l our initials after.the response,1 are true and correct' to the best of our i kr.*wledge and belief: Q1: Please state your full name, employer, and occupation. kR G
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Als . My name is Thomas T. Martin. I am the Deputy Regional Administrator for Region :I of the U. S. Nuclear Regulatory Commission. I am a Registered Professional Engineer of the State of New Jersey. (T.T.M.) My name is Peter W. Eselgroth. I am the Chief, Pressurized Water Reactor Section, for Region I of the U.S. Nuclear Regulatory Commission. (P.W.E.) Q2: Gentlemen, have you prepared a statement of your professional qualification? . l l A2: Yes, statements of our professional qualifications are attached to this affidavit as Attachment.1 for Thomas T. Martin'and Attachment 2 I for Peter W. Eselgroth. (T.T.M. and P.W.E.) l Q3: Gentlemen, what is the purpose of this affidavit? A3: This affidavit sets forth: the observations of NkC personnel in the I Seabrook control room during the conduct of a natural circulation test on June 22, 1989; the findings of the NRC Augmented Inspection' Team - that reviewed the circumstances surrounding. that event; the significance of that event relative to the adequacy of the licensee's low power testing program, and; the effect, if any, that event has on the earlier Regional recommendations. (T.T.M. and P.W.E.) W n. asih A*.Ad _% i, _hk 's=.0 N. _% war 2L "Ah i
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Q4 Gentlemen, interveners' contention and motion to reopen is based upon the results' of an event occurring on June 22, 1989 during low power ; testing of the Seabrook Station. Which of you observed that event? A4: I did (Thomas T. Martin), along 'with Noel Dudley, Acting Senior Resident Inspector, -Seabrook Station, and James 'Trapp, Reactor Engineer, Special Test Programs Section, Region I. (T.T.M.) QS: Did any of the- NRC persons observing the June 22, 1989 event have cause to document those observations? A5: Yes, in a memorandum dated- June 26, 1989, I coordinated the documentation of the observations of the three NRC personnel in the control room at the time of the event. That document is attached i I hereto as Attachment 3, and incorporated herein as if fully set forth. l
~I (T.T.M.)
l Q6: What, if anything, did the NRC do in response to this event? A6: The initial NRC review concluded that additional licensee and NRC actions were needed to assure a thorough analysis of, and appropriate ; response to, identified concerns. Actions were committed to by the licensee and documented in an-NRC Confirmatory Action Letter (CAL 89-11). The CAL is attached hereto' as Attachment 4 and incorporated herein as if fully set forth. .It confirmed the plans of 2
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I the licensee to conduct a post-trip review of the June 22, 1989, event which occurred during the natural circulation startup test; to 3 establish short-term corrective actions to be completed prior to plant restart; to determine longer term corrective actions and schedules for those actions; to review the post-trip review and corrective actions with the NRC; and, to obtain the agreement of the NRC Region I Administrator prior to restart. Additional NRC review was initiated through designation of an Augmented Inspection Team (AIT) to analyze the event. The AIT charter is fully described in Appendix G to the AIT report which is attached 1 hereto as Attachment 5 and incorporated herein as if fully set forth.. ; The principle requirement of the AIT charter was NRC's performance of l a thorough review of the causes, safety implications, and associated licensee actions which led to and followed the reactor trip which i occurred during the Seabrook Station conduct of a natural circulation test on June 22, 1989. (T.T.M. & P.W.E.) l Q7: Who was the leader and what were the activities and principle findings of the AIT? l A7: I was the leader (Peter W. Eselgroth). The AIT implemented 'its 1 charter through a fact finding and causal . determination inspection which consisted of interviews with personnel, direct observations and examinations of plant equipment; selective examinations of procedures,
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I representative records, and design documents; and documentation of the inspection effort and findings of fact and significance in the AIT report, which is attached hereto as Attachment 5. Principle findings of the AIT were that:
+ The actual plant dynamic response was reviewed and compared to i the post trip review pradicted response. The plant responded as predicted in the June 22nd natural circulation testing including the very mild overcooling event which resulted from steam dump .,
valve MS-PV-3011's failure to properly modulate.
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- Plant equipment was not ready to support the June 22nd test.
Prior to commencing the test, a test prerequisite to confirm the l l l availability of the steam dump system was signed off. However, j i there was an open work order for post maintenance stroke testing of steam dump valve MS-PV-3011. j l
. The interviews of the Unit Shift Supervisor (USS), Senior Control Room Operator (SCRO) and Control Room Operators (CRO) found them to be highly competent individuals, clearly aware of their !
assignments for safe operation of the plant. In particular, the I l USS communicated that he had no doubts about being the one . responsible for conduct of the test in a safe and controlled manner. 6 m 51. . .2. t ...E- .m. 1 ' <_ _ m.II n %M t t # 9 m 7. + n p' bd :t' . t'm % s - 4 '*a* r 4 i th _..a_M .r_A_'.1.'.
- Trainingrrelative to the conduct of.the' natural circulation test which covered details of the expected plant response had been accomplished about a year prior to the test. The AIT found no evidence that 'such training had been repeated or refresher training given since that time.
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* .A review of the pre-test briefing that - was conducted for the operators by the Test Director determined that it was inadequate with respect to covering the details of the testing to be
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performed and thoroughly reviewing the reactor trip criteria.
- The operating crew was observert to be conducting plant operations in a controlled, unfrenzied n;nner prior to, during the test and following the reactor trip when the applicable emergency operating procedures were entered and carried out appropriately.
- During the Low Power Testing program prior to the June 22nd event, as well as during this event, there was no evidence of pressure applied by management or anyone else to complete testing at the expense of controlled, safe operation of the plant. In fact, the NRC has been aware of personnel assigned to shift operating and test responsibilities having received direction from management to proceed with testing in a controlled manner and specifically to not permit themselves to feel rushed into L
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- The USS; did not trip the reactor at the 17% pressurizer level, as required by the test procedure (1-ST-22). He stated his reason was that the decreasing pressurizer level was under control and turning around. The AIT concluded that a cause of this event was the lack of importance and/or sense of ownership placed on test procedure requirements by the USS as compared to-his other operating requirements such as those contained in Technical Specifications and plant operating procedures. Two other operators interviewed also indicated the perception of a hierarchy of importance for procedural requirements between test procedures and plant operating procedures. These misunder-standings on the part of the operators demonstrated an absence of recognition of test procedure criteria as controlling l
requirements for operation under testing conditions. I 1 i
- The Shift Superintendent (SS) did not provide effective supervisory involvement in the conduct of this test.
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- Operating crew personnel 'n o w recognize and understand that the i
proper action was to have tripped the reactor before the 1-ST-22 .) i trip criterion on pressurizer level was exceeded. l 1
+ The startup test group had responsibility to interrupt or terminate the test in the event that required plant conditions )
were not maintained. However, no such recommendation was made to j i 1 i' l Gn Aa. .,~.u ~w, _ w ..a m ,s ,,- _ a. s arm.~ - . x. A > a n_ .G .* .- . .a . . . , . ii
the shift operating crew by the test group even though the Startup Manager was made ' aware of. the NRC's concern . about the plant being below a manual trip criterion. The overall direction given by the test organization during the performance of this. test'was inadequate.
- ' From the interviews of startup group personnel it-~has been-concluded that these personnel now recognize and : understand that the proper action was to have terminated the test- and ~ recommend to the operating crew that'the. reactor'be tripped before the 1-ST-22 trip criterion on pressurizer level was exceeded.
- During the conduct of 1'-ST-22 and at the time when plant conditions had reached the reactor trip criterion associated with
. pressurizer level, there were several plant management observers -+
in the control room with the authority to direct shift super-vision to terminate testing and/or plant operations when condi-tions adverse to safety are observed. The managers either did not know the reactor trip limits were exceeded or did not inform shift supervision or otherwise act to correct the failure to trip the reactor when required.
- The initial management thrust following this event appeared to be to resolve any equipment problems necessary to resume. testing.
An in-depth review of the cause or causes leading to the improper W Y A . d - s we,nn u k ik Monh w th e%.*l 1. lam $t?% 1.mA 1 s20 LP 15 *Ym.M a l 3 '. c. 'sh t. s ce. s . ...sA + AY.~ " + h e \ m " s.Y :? , N as
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conduct of the 1-ST-22 natural circulation test apparently did not take place prior to an initial management decision to resume testing. A thorough review of this event was not completed by ) the licensee until after the NRC raised this issue with licensee management. l
- The plant transient which resulted from the steam dump valve equipment problem and failure to follow the test procedure reactor trip criterion did not significantly challenge the plant margin of safety. However, the failure of the operating crew to trip the reactor when required by the test' procedure'during the June 22nd test; the failure of test group personnel to recommend tripping of the reactor at that point; the failure of management 3 present in the control room to exercise their responsibilities in this situation, despite the fact the plant was being-operated under a Technical Specification Special Test Exception; and, the
. apparent willingness of management to proceed with testing ;
following the June 22nd occurrence without first completing a j thorough' review and casual factor assessment was unacceptable. Test programs are designed to uncover equipment, personnel and I procedure problems that need to be. fixed. The error in judgement by > 1 certain operating crew members of perceiving a hierarchy of I requirements between various procedures and the absence of a-stronger sense of ownership of test procedure criteria as operating 6 Ni _9.A M S
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i t requirements was unacceptable and not condoned. The failure of certain managers to recognize their responsibility to recommend a i reactor trip when they became aware of the procedural non-compliance j 4 was also unacceptable and not condoned. These problems became known for the first time as errors in practice during the natural circulation test. These problems remain important only so long as they remain undetected. (T.T.M. and P.W.E.) { Q8: Have you reviewed the intervenor's motion and attached affidavit of Gregory C. Minor and Steven C. Sholly? l 1 A8: Yes, we have. (T.T.M. & P.W.E.) 1 1 Q9: Do you agree with the- intervenor's conclusion that " ... Plant l operators deliberately disregarded test procedures. . ."? - l A9: No. Although the plant operators knew they had exceeded a test procedure criterion for tripping the reactor, the operators incorrectly believed the trip criterion could be treated as guidance. 1 The operators understood why the pressurizer level had dropped in response to the open steam bypass valve, were in the final stages of recovery from the transient, recognized the plant was not in danger and made an incorrect decision that the trip was not required. (T.T.M. and P.W.E.) Q10: Do you agree with the intervenor's conclusion that " ... Senior management personnel, including the Vice President - Nuclear 23-: -- . 2_ . . ~ x. .x . . . w. w:. . - w.: ~ , _ a.. . a .n . .w - , ~: c.z,
Production, unit. shift supervisor, assistant operations manager, and the operations manager, knew that continued operation violated test Procedures..."? l' A10: No. Of the named individuals, only the Unit Shift Supervisor was aware at the ' time the criterion was exceeded that the.' criterion ~was exceeded,- and as stated above, he regarded' that' criterion to ' be guidance only. The Assistant Operations Manager was informed that the criterion was exceeded during- a conversation with an NRC representative late in the event. He then confirmed the observation by. questioning the Test Director and then . walked over to - the Unit-Shift Supervisor and Plant Manager, arriving shortly before the time-the Unit Shift Supervisor directed the reactor . tripped. The Vice President - Nuclear Production and' Operations Manager did not' learn of the failure to trip the reactor in accordance with-the test procedure criterfa until after the reactor was tripped. (T.T.M. and P.W.E.) Q11: Do you agree with the intervenor's conclusion that " ...Even when repeatedli advised of the violation by NRC inspectors, these plant l personnel continued to willfully violate test procedures, ignored NRC notifications, and initially refused to shutdown the reactor..."? 1 I All: No. Of the named managers, only the. Assistant Operations Manager was' advised by the URC -during the event that the test criterion was l l exceeded. He was only advised once late in the event, not' repeatedly, -l did not ignore the notification, confirmed the information and-4 6 Ero Mr r$$ bah ._ el 2 k - d..n d A E Mh / b E'.aba > .' 2.5 U'.e . 2 'A.% b t. 4 ~ u _. M ['5 . ro bi ' $ :i 2. ; s 1. . UCI C ' "_Tib.C *
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i proceeded to the vicinity of the Unit Shif t Supervisor just prior to the trip of the reactor. No one that the NRC informed during the event refused to shutdown the reactor. The NRC also informed the Startup Manager and the Test Director that the test criterion was exceeded in sufficient time for them to recommend to shift supervision the tripping of the reactor. The failure of the Startup Manager to communicate NRC concerns to the shift crew and his failure to recommend termination of the test upon learning that the test criterion was exceeded, as was his ! responsibility, is of concern. The Test Director did inform shift supervision of NRC's concerns, but his failure to recommend test termination as was his responsibility is also of concern. (T.T.M. and P.W.E.) ~ l l Q12: Do you agree with the intervenor's conclusion that "... senior management personnel provided inaccurate and incomplete information to NRC on the shutdown..."? A12: No. Notwithstanding the licensee's post-trip report which documented , l their conclusion to the contrary, we have concluded that the quality,
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i completeness and perspective of the information provided to NRC, both ! initially and in subsequent updates, as both the licensee and NRC gained knowledge of the event, was acceptable and consistent with our
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l l J expectations of and experience with communications during and immediately following any reportable event. (T.T.M. and P.W.E.) Q13: Do you agree with the intervenor's conclusion that ... senior management personnel refused to acknowledge the seriousness of their I procedural non-compliance, and even suggested restarting the reactor without resolution of these issues..."? A13: No. However, we do agree that the Vice President-Nuclear Production failed to recognize the seriousness of their procedural non-compli-ance, and even suggested restarting the reactor without adequate prior l review or resolution of this issue. The Plant Manager recognized the ) significance of the procedural non-compliance, but did not effectively , communicate the matter to the Vice President before the Vice President
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indicated to the NRC plans for unit restart. The Vice President was subsequently relieved of his responsibilities for nuclear matters by the licensee. This action was not prompted by the NRC. (T.T.M. and P.W.E.) Q14: Do you agree with the intervenor's conclusion that " ...NRC suspended
- Applicants' low power operating license..."?
A14: No. Based on discussions with the licensee, the NRC documented in a Confirmatory Action Letter (CAL 89-11) our understanding of the ) s . A . h s t a n:%* . w. d.
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licensee's:-voluntary er reement to take certain specified actions described in . the CAL prior to startup of the plant. The CAL had neither the intent nor the effect of suspending the Applicant's low power operating license. (T.T.M. and P.W.E.) Q15: Do you agree with the intervenor's conclusion that " ... Low power testing at Seabrook has demonstrated that operators and management personnel are not adequately trained or supervised. . . " and " ...some improvement in the training program is essential if similar violations are to be prevented in the future..."? A15: Yes, some improvements in staff training are necessary. The performance of'the licensee's operating and startup testing staff and supervision during and immediately following the natural circulation test demonstrates the need for remedial action. The details of those necessary actions will be developed in the normal course of NRC's enforcement deliberations. At this time, however, the licensee's training program inadequacies are not so great as to materially change the Region's recommendation relative to the issuance of a low power license. It should be noted that low power testing was evaluated by two teams of NRC inspectors between May 27 - June 1 and June 12 - June 24, 1989. A total of approximately twelve inspectors observed plant operations on a continuous basis, twenty-four hours a day, for approximately . = .a. w w . x w. u w .:a ~. c.2. . . . = ~ - :. - . .- - .-
4 thirteen days. The conclusions reached by these teams are documented in NRC Inspection Report Nos. 50-443/89-80, and 50-443/89-81. Those reports indicate that operators and management were adequately trained and that operators were adequately supervised. (T.T.M. and P.W.E.) Q16: Do you agree with the intervenor's conclusion that " ... Prior procedural non-compliance problems mean the procedural non-compliance is not an isolated event, but is part of a pattern of procedural non-compliance. . . and ". . .the procedural noncompliance which occurred during the Natural Circulation Test on 22 June 1989 may not be an isolated event. There is at least some evidence of other possibly related procedural noncompliance problems. Inspection Report 89-3 (February 28, 1989 - April 24, 1989) states: Four incidents highlighted a potential reduction in attention to detail in the conduct of routine plant operations. Two involved failures to properly position and lock a valve to prevent potential boron dilution of the reactor coolant system. Another concerned the generation of a reactor trip signal when steam generator levels were allowed to drop to the trip setpoint while in wet layup. A fourth event involved the inadvertent opening of a pressurizer power operated relief valve ; i during I&C testing. While none of these incidents had significant i 1 safety impact, they may indicate a potential weakness in what has been to date, an excellent operating record..."? u w - w _2.ex:a m. w u a c_ n -a 2x a u :m .. 2 1_z
A16: No. The NRC Low Power Startup Test Team provided continuous observation of test activities from reactor criticality through the natural circulation test. The low power startup team inspection was conducted to assure compliance of the licensee's test program with I regulatory requirements, and to assess the conduct of the licensee's j i startup and operations personnel. I i The NRC found the Low Power Test Program was conducted in accordance ! i with approved test procedures and fulfilled regulatory requirements except for the June 22nd failure to trip the reactor, per the test I procedure. At no time, other than during the natural circulation test, did the inspectors observe licensee personnel fail to follow operating or startup test procedures. In fact, the operating staff's adherence to procedures was identified as a strength in Inspection Rdport 50-443/89-81. The operators were observed to follow procedures and were cognizant of details regarding test activities. The NRC inspectors observed throughout the low power testing progran that the
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licensed control room operators were made cognizant of test activities by briefings held by the startup staff. Professionalism and attention to detail by both the licensed control room operators and the startup staff were observed to be strong throughout the startup program. The ; procedure adherence problems identified during the natural circulation test were the only violations observed by the inspectors in approximately two weeks of continuous low power test witnessing. l l
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4 A repetition of,the weakness involving procedure compliance described -
.3 in the Notice of Violation provided in NRC inspection report 50-443/89-03, was not observed by the NRC inspection team during low power testing prior to-the June 22, 1989 event. Poor communications and inattention to detail, which were then determined to be contributing factors to the violation, were not witnessed during the low power test team inspection. In fact, communications and attention to detail were both determined by the NRC inspectors to be strengths during the low power test program. The NRC observed that operator i
performance, strong management involvement and constant QA/QC coverage during low power testing had adequately addressed these procedure compliance issues. (T.T.M. and P.W.E.) Q17: Do you, agree with the intervenor's conclusion that "...The operations Command and Control Policy is not adequate, and did not function an intended..."? l A17: It is clear in this instance that the implementation of proper command 1 and control functions was inadequate. Further, this was essentially i the conclusion of the licensee in their report on the event. (T.T.M. and'P.W.E.) i Q18: Do you agree with the intervenor's conclusion that " ... Management l procedures for oversight of plant operation are not adequate, and lines of authority and responsibility for management personnel are vague and confusing..."? { i l I R. ?m MI hu ha . .h't JA ! Mk > ei d #\ . AA b A._am_1m_w.
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e A18: No. The administrative and operating procedures committed to be written by the applicant are described in section 13.5 of the Final Safety Analysis Report (FSAR). The FSAR commitments were reviewed and approved by the NRC. The managers and operators involved in the natural circulation test were interviewed by six inspectors. The conclusions of the inspection team are documented in NRC Inspection Report No. 50-443/89-82. The report concludes that the managers and operators clearly understood the lines of authority and that the unit shift supervisor was always in charge of conducting the natural circulation test procedure. The report did not identify any inade- ; quacies in the management procedures. (T.T.M. and P.W.E.)
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Q19: Do you agree with the inte.rvenor's conclusion that "...The Station and operati,ons Management policy on procedure adherence is unclear and i confusing. Clarification is necessary to clearly delineate when deviation from procedures is acceptable and when conformity to procedures is mandatory..."? l A19: The NRC found that the operators did not clearly understand the ! I requirements for test procedure compliance. During the natural ] circulation test, the operators evidenced a belief in a hierarchical approach to procedural compliance and used the limits of normal and emergency operating procedures instead of the limits of the test i l j a-, = u _ . u s. . = a x. ~ . ~ - = . -~ .
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-l procedure. This hierarchical' approach to procedural compliance is improper and-is not endorsed by the licensee's written administrative !
i policies nor' by the documented operator licensing and continuing training programs. The NRC has not determined how operators came to this improper understanding of test procedure . requirements. The l l licensee has revised procedures and is conducting training to correct the operators' misunderstanding. (T.T.M. and P.W.E.) 1 Q20: Do you agree with the intervenor's conclusion that " ...Present l management training programs are not adequate. This was demonstrated when management failed to exercise authority to order a reactor shutdown, or direct operators to take this action. In addition, training must be provided with respect to all procedures identified for revision..."? l A20: We agree that some additional training is needed, but disagree that l the basic training programs are inadequate. NRC's previous assessments of management training and performance has been generally i positive as indicated in response to questions 15 and 16. Obviously, we will expect the licensee to appropriately train affected management staff regarding any procedures which are revised. (T.T.M. and P.W.E.) l
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.: i Q21: Do you agree. with the . interven'or's conclusion that " ...The existing i
NHY Post Trip. Review Process is not adequate. . This was demonstrated when -senior management provided wholly inaccurate .and incomplete information on the circumstances. surrounding the shutdown and violated j l l reporting requirements'in 10 C.F.R. 50.72..."? j l A21: Although we agree that the Post . Trip Review Process was not-adequately implemented with respect to review of human performance, as previously discussed in answer to question 12, we have not found a significant problem with the licensee's initial report to ' the NRC regarding the event. (T.T.M. and P.W.E.) Q22: Do you agree with the intervenor's conclusion that " ... Procedures necessary to assure operating proficiency and regulatory compliance are not adequate..."? A22: No. Operating, emergency, and test. procedures have been found acceptable, and operators have been found capable of safely using the i a plant and emergency procedures incident to achieving their NRC l operator licenses. Plant operating procedures were specifically inspected and found ; acceptable by the NRC. For example, General and System Operating i l' l Procedures were reviewed in inspection 50-443/86-09. Inspection 50-4'43/86-27 examined the procedures which implement technical l i j
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. -1 specification requirements. Inspection 50-443/80-33 reviewed the Abnormal and ' Emergency Operating Procedures. NRC questions on the above noted procedures were acceptably resolved during follow-up inspections documented in reports 50-443/86-28 and 50-443/86-36.
Startup test procedures were subsequently reviewed, and were found acceptable as documented in report 50-443/88-13. Implementation of the Startup Procedures was found acceptable as documented in report 50-443/89-81. Further, maintenance and surveillance procedures were ; i reviewed during inspection 50-443/89-05; operating surveillance, and radiological controls procedures were also reviewed during inspection 50-443/89-80, and routine resident inspector review of plant operations also has found the plant's procedures to be acceptable. (T.T.M. and P.W.E.)
. j Q23: Do you agree with the intervenor's conclusion that "... prior to t h e test, the operating crew read the entire test procedure, and the Test Director briefed these personnel and made individual copies of the manual reactor trip criteria for these personnel..."?
l l l A23: No. As stated in the AIT report, not everyone received a copy and l read the test procedures. Further, not everyone received the I l l individual briefings by the Test Director, which were considered of marginal quality. (T.T.M. and P.W.E.)
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e A Q24: Gentlemen,. has the Region ever taken a position on the readiness of the licensee to conduct activities authorized by a low-power license? A24: Yes. Prior to NRC's issuance of the Applicant's low power operating license, the Region documented its low power license recommendations in three memoranda (Attachments 6, 7, and 8) to the Office of Nuclear Reactor Regulation. (T.T.M. and P.W.E.)- 4 Q25: Based upon the' staff 's review of the circumstances surrounding the June 22, 1989 event, would your earlier recommendation change in any material respect? I l A25: No. Based on our current knowledge of the event, we are not aware of any condition that would. require a material change in the Region's earlier recommendation. The identified potential violations of license conditions and NRC requirements are cause for requiring corrective actions; however, the licensee staff's failure to implement their procedure and program requirements does not necessarily imply those requirements and our recommendations must be changed. Corrective actions by the licensee will likely involve an appropriate I combination of procedure enhancements, staff selections, training and i assessments of success. The NRC will assure that the licensee has i adequately reviewed the event and identified lessons learned, l developed appropriate plans and schedules for corrective actions to l I l
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q prevent recurrence, and is adequately implementing those activities. However, based upon the limited safety significance of the actual l transient, the prior good performance of the licensee's staff and i i management and the isolated nature of this instance of failure to I l comply with test procedures, the Region has concluded that its prior ' l recommendations are not materially affected. (T.T.M. and P.W.E) Q26: Gentlemen, does this complete your affadavit? A26: Yes, it does. (T.T.M. and P.W.E.) m . _ Thomas T. Martin
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Peter W. Ese roth Sworn to and subscribed before me this /6AIC day of August 1989
$* f% W-NOTARIAL SEAL MICHAEL A. PERKINS, Notary Public My coi uW!!stfeflP ImpiYWit?en Co., PA Vy Commission Expres March 20,'1993 l
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ATTACHMENT 1 THOMAS T. MARTIN ; Organization: U.S. Nuclear Regulatory' Commission, Region I
Title:
Deputy Regional Administrator
. Education: B.E.E., Georgia Institute of Technology, 1963 U.S. Navy Submarine School, 1964' U.S. Navy Nuclear Power School, 1964 U.S. Navy Nuclear Power Prototype,'S1W, 1965
. Westinghouse Nuclear Plant Design' Familiarization, 1972 U.S.N.R.C. BWR Training Series, 1975 Additional graduate courses in Business Administration (10), Computer Science (5)~, General Engineering (2), Electrical Engineering (2) and Nuclear Engineering (1)
Qualifications: Licensed Professional Engineer,-State of.New Jersey Licensed Gold Seal Stationary Steam Plant Engineer, j State of New Jersey I I U.S. Navy Nuclear Ship's Engineer U.S. Navy Engineering Officer of'the Watch, S1W, S5W, DIG U.S. Navy Submarine Officer
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U.S.D.O.E. Certified Accident / Incident Investigator ] U.S.N.R.C. Reactor Inspector' ! Experience: 1 1989-Present Denuty Recional Administrator. RI ~ - Responsible ~ to the Regional Administrator for ths - direction, support and implementation of regionalized ' programs for licensing, inspection, and; enforcement- for' reactors, fuel cycle facilities and material 1 licensees. (NRC) 1988-1989 Director. Division of Reactor Safety. RI - Responsible to the I Regional Administrator for the management of regionalized programs for reactor operator licensing and the programs-for inspection and enforcement at reactor, fuel cycle and nuclear material- facilities involving the disciplines of engineering. (NRC) i 4 l l 1 1
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' 1988-1988 Actina Associate Director for Inspections and' Technical j I
Assessment. NRR - Responsible to the Office Director, Nuclear Reactor Regulation, for the direction and implementation of headquarter's programs for reactor operator licensing, license reviews, event evaluation,_ generic communications, human factors, quality assurance, performance assessment, emergency preparedness,- security, engineering, health physics and inspections. (NRC) 1984-1988 Director. Division of Radiation Safety and Safeauards. RI - Responsible to the Regional Administrator for the direction-and implementation'-of regionalized programs - for licensing, l inspection and enforcement at reactors,. fuel facilities'and material licensees _ involving the technical disciplines of-health physics, chemistry, security and. emergency i preparedness. (NRC) l l 1981-1984 Director. Division of Enaineerinu and Technical Proarama. RI - Responsible to the Regional Administrator for the management. of the region-based licensing, inspection, investigation and enforcement programs for reactor, fuel cycle and . material licensees involving the disciplines of engineering, health physics, . material control and accounting, and safeguards. (NRC) 1981-1981 Chipf. Encineerina Insoection Branch. DETI. RI-OIE - Responsible for the management of region-based inspection programs involving various engineering disciplines applicable to reactors, fuel facilities and major materials facilities
- under construction, testing, operation or ' decommissioning.
Supervised four (4) Section Chiefs. -(NRC) . 1979-1981 Chief. Reactor Proiects Section No. 3. RO&NS Branch. RI-OIE - Responsible to the Branch Chief for the management of the inspection and enforcement program at four power reactor sites, including the supervision of assigned Senior Resident and Resident Inspectors. (NRC) 1978-1979 Insoection Soecialist. Performance ADDraisal Branch. RCI-OIE - Responsible to the Branch Chief for (1) evaluation of the performance of NRC licensees from a national perspective;-(2) evaluation of the effectiveness of NRC programs; and, (3) confirmation of the objectivity of NRC inspectors. (NRC)~ 1977-1978 Proiect Insnector. Reactor Proiects Section No. 2. RO&NS Branch. RI-OIE -- Responsible to_ the Section Chief for the conduct of inspections and for coordination : and review ._ of specialist inspections of two BWRs and one Research Reactor. (NRC) 2 k l _1
y a p 4 1974-1977 Lead Insoector. Nuclear Succort Section No. 1. RO&NS Branch. RI-OIE - Responsible to the Section Chief for the schedule and conduct of refueling, containment testing and major surveillance inspections at 15 PWRs and 8 BWRs. (AEC/NRC) 1974-1974 Operations Encineer - Salen Nuclear Generatina Station - Responsible to the Chief Engineer for preoperational testing of a nuclear power plant and administration and supervision of the operations staff. (PSEEG Co. of New Jersey) 1972-1974 Performance Suoervisor (Trainina Coordinator) - Salem Nuclear Generating Station - Responsible to the Chief Engineer for training, administration and supervision of the initial group of Reactor Operators. (PSE&G Co.) l 1970-1972 Various Positions - Mercer Generating Station - Staff and supervisory assignments involving increasing responsibilities in the areas of planning, operation, maintenance and testing at a coal fired electric generating station. (PSEEG Co) 1963-1970 Naval Of ficer - Supervised operations, testing and maintenance of naval nuclear power plants and supporting auxiliaries. Trained officer and enlisted personnel onboard ship and at DIG Naval Nuclear Prototype. Developed, established and supervised Naval Submarine School's course for prospective Naval Nuclear Engineering Officers. (USN) Honors and Associations: l Tau Beta Pi Engineering Honorary Society Eta Kappa Nu Electrical Engineering Honorary Society Scabbard and Blade Military Honorary Society 1 l J l l 3 l l i 4_ _ . _
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, ATTACHMENT 2 4
y . STATEMENT OF ~~ PROFESSIONAL QUALIFICATIONS ; BY PETER W. ESELGROTH I am the Chief of the PWR Section, Operations Branch, in the ! Division of Reactor Safety, Region I, of the United States Nuclear Regulatory Commission. I have over twenty years of experience in the area of overall nuclear reactor plant operations. This experience has encompassed reactor plant testing, plant operations, operating procedure development, personnel training and the evaluation of operating- !' crews and individuals with respect to safety. I received a Bachelor of Science. Degree in Mechanical Engineering from Cal Poly University la 1965 and a Master.of Science Degree in Mechanical Engineering (with nuclear plant thermal-hydraulics-emphasis) from the Massachusetts-Institute of Technology in 1967. ,
-1 Work Experience Summary:
U.S. Nuclear Regulatory Commission 1988 - 1989 Supervision of reactor operator examiners and reac-l tor operation inspectors whose jobs are to examine PWR reactor-operator. candidates for an NRC License and to inspect PWR reactor operations with respect to public health and safety. 1985 - 1987 Supervision of reactor inspectors for implementation of routine and reactive inspection! programs ap-plicable to BWR and PWR reactors in pre-operational-and start-up testing programs. 1983 - 1984 Conduct of routine and reactive inspections, as a.- senior resident inspector, for safety and . licensee compliance with regulatory requirements. This'as-signment also included systematic assessments 'of licensee performance.
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- United Nuclear Corporation, Nuclear Industries 1979 - 1983 Program management responsibilities with respect to reactor plant operations including crew evaluations, operator training and individual operator examina-tions at the Department of Energy, Hanford N-Reactor.
U.S. Naval Nuclear Propulr; ion Program 1976 - 1979 Management of field office at Idaho Naval Reactors Facility with responsibility for overseeing the operational and training objectives of that site. 1973 - 1975 Supervision of various submarine technical programs l including reactor plant testing. Served as a member of oral exam boards for prospective commanding of-ficers and served as an audit team member for crew reactor safety examinations. 1968 - 1972 Performed reactor engineer assignments for review of various aspects of submarine nuclear propulsion plant design and construction. Worked on reactor operator exam development and grading. a
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, 'g, s, y 475 ALLENDALE AoAD KINO oF PRUS$1A PENNSYLVANIA 19406 ATTACHMENT 3 June 26, 1989 MEMORANDUM FOR: William T. Russell, Regional Administrator FROM: Thomas T. Martin, Deputy Regional Administrator
SUBJECT:
NRC OBSERVATIONS REGARDING SEABROOK NATURAL CIRCULATION TEST As requested, please find enclosed a composite narrative of NRC observations regarding the licensee's preparation for and conduct of the Seabrook Natural Circulation Test. The narrative was developed as a joint effort of Noel Dudley, Senior Resident Inspector, Jim Trapp, Reactor Engineer and myself. 6 Thomas T. Martin
. MW Deputy Regioiaal Administrator
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Enc 1osure: As Stated ) cc: J. Taylor, DEDO T. Murley, NRR J. Wiggins, RI ! D. Haverkamp, RI N. Dudley, RI J. Trapp, RI I
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, ENCL 4SURE NRC OBSERVATIONS REGARDING SEABROOK NATURAL CIRCULATION TEST
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Tim Martin, Deputy Regional Administrator, Noel Dudley, Senior Resident Inspector (SRI), and Jim Trapp, Reactor Engineer, representing the NRC, were present in the Seabrook Control Room on June 22, 1989, to observe the preparations for and conduct of the licensee's natural circulation test. All three NRC participants had reviewed and discussed the test procedure. The chift operating crew in the Control Room consisted of a Shift Superintendent, Unit ) i Shift Superintendent, Senior Control Room Operator and three Control Room Operators. With the exception of the licensee's {
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operating crew, several operations department managers and several test engineers, all personnel (approximately 40 total) were outside the immediate area of the controls and approximately 25 j feet from the control panels. The observers maintained a minimum , noise Icvel throughout the test preparations and conduct. In preparation for the test, the Lead Test Engineer (LTE) presented a very general discussion of the test to be conducted. The LTE stated he would review separately with the operating crew the conditions requiring a reactor trip. (The SRI believes he subsequently observed this briefing taking place. ) In recognition l of the assembled observers' inability to read panel indications, the SRI requested a description of plant parameters presented on large CRT's that were observable from outside the operating area. The operating crew identified the parameters displayed on each CRT to enable the observers to follow the transient. Preparations for the test and conduct of the operating crew appeared to be conservative, cautious, and thorough. The initial operating conditions, needed to initiate this test, required time { i to establish. Key operating parameter oscillations required i dampening while e m blishing the initial test conditions. These ! oscillations were normal and occurred because many controllers were ' required by the test procedure, to be placed in manual control. At this point, there was no basis for any concern in the minds of , i the NRC observers. . When the plant was finally stabilized at - 3% power, the Unit Shift Supervisor (USS) announced the test was starting. Two individuals were utilized to trip the four reactor coolant pumps nearly simultaneously. The transient was predicted to last 10-50 minutes and the operators appeared to conscientiously monitoring their controls. Neutron flux level was noted to decrease, initiating quiet discussion between Mr. Martin and Mr. Dudley, given the stated test prerequisite to reach a zero moderator temperature coefficient. W &o v.k'_." ...-.~~~w. s .-~.i. . O Eu o oi n - a$ 2 6. - n r.1. M o.E L, . . N L . . ~. . .w., s ~. - n. a
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Jim panel Trapp, was the first NRC observer to detect a problem, noting j indications of an automatic de-energization of the pressurizer heaters and isolation of letdown. From previous ! experiences as a licensed individual at another facility, he ; recalled this occurred at about 18% pressurizer level, just slightly above the 17% level that the test procedure instructed ! operators to manually trip the reactor. Mr. Trapp asked a Senior Reactor Operator (SRO), who was also an observer and not part of the current shift operating crew, what their isolation setpoint was. He learned it was 174, the condition under the current test ! procedure requiring the operators to manually trip the reactor. I Although the plant was not currently in danger, Mr. Trap immediately went to the Startup Manager at the Test Engineer'ps l table. Mr. Trapp advised the manager, who had authority to stop the test, that the heaters trip and letdown isolates at 17% pressurizer level and that they were now operating below the criteria for manually tripping the reactor. The manager continued to watch the in-progress test, appeared to take no action, and gave no oral response; but did appear to hear Mr. Trapp's concern. Mr. ,Trapp then went to Mr. Dudley and Mr. Martin, informing them of his concern that the licensee had met conditions requiring a manual trip, for about two minutes, and the lack of response to that information by the Startup Manager. This discussion took about thirty seconds. Pressurizer level, as shown on the CRT, was now offscale low and the Senior Control Room Operator (SCRO) appeared to be initiating additional makeup with a corresponding increase in indicated pressure, showing that pressurizer level was , being restored. Mr. Trapp then went over to talk to the Lead Test Director (LTD) who had his back to the control console and was reviewing data from a printer. Mr. Trapp informed the LTD, an individual who could recommend halting the test, that they were operating below the level requiring a manual trip of the reactor. The LTD examilted his l printout, said something to the effect that he would get back to ' him, and turned, wtalked over to the Unit Shift Supervisor (USS) and communicated to that individual. The USS, an SRO with authority to order a reactor trip, was directing the activities of the operating crew. The SR , noting that Mr. Trapp was not getting a satisfactory response, immediately went over to the Assistant Operations Manager (AOM), an SRO with authority to stop the test, and advised that the pressurizer level was below 17%, requiring a manual reactor trip. During this period, the LTD returned to the printer, and the AOM I asked was it true they should have tripped the reactor. When told yes, the AOM went to the Operations Manager, another SRO with I m _
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, 3 authority to direct tripping the reactor, and the USS, and appeared to communicate with both individuals.
Subsequently, and without a clear impression of whether the response was or was not prompted by the expressed NRC concern, with pressurizer pressure and level now rapidly increasing and again on the CRT scale, the USS directed a Control Room Operator (CRO) to trip the reactor. The SCRO, an individual who could independently trip the reactor, indicat de he was about to re-establish control and requested a delay. The USS told him no and the CRO then tripped the reactor. The NRC observers then watched the apparent smooth performance of the required Emergency Operating Procedures, discussed their perception of why the operators initially failed and subsequently decided to trip the reactor, and discussed the safety significance of what had been observed. The role of the Shif t Superintendent during the event was not apparent to the NRC observers. Mr. Martin informed the Vice President (VP) of operations, while still in the Control Room, that the NRC staff was concerned that the operators did not follow their procedures and manually trip the reactor when pressurizer level fell below 174. The VP acknowledged the concern, indicated'they would review the event and offared no explanation for the operators' actions. The NRC observers remained in the Control Room until the reactor coo.lant pumps were restarted and the plant was again stable. At no time during the event did NRC personnel grab a licensed-individual, raise their voices or manipulate the controls. The NRC observers' concern during the entire event was that their was no safety reason for not following the procedure; therefore, it should have been followed. - NRC actions were predicated on their concern, the fact that we were not authorized to order licensed activities and that, in this instance, the reactor was never in danger. Subsequently, Mr. Trapp and Mr. Dudley were directed by Mr. Martin to observe the post trip reviews to assess licensee performance, but not to participate in the licensee's deliberations. i Y e N f.A. Wi$mi3 Ph'.bt MEtW wd b I" *I* #' #" '*# ^
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KING OF PRUSSIA, PENNSYLVANIA 194o6 Dockets No.: 50-443 CAL No.: 89-11 Public Service of New Hampshire (PSNH) ATIN: Mr. Edward A. Brown, President and Chief Executive Officer New Hampshire Yankee Division Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:
Subject:
CONFIRMATORY ACTION LETTER (CAL) 89-11 This letter confirms our understanding of those actions you intend to take in response to the reactor manual trip which occurred on June 22, 1989 during the performance of the natural circulation startup test. Those actions were discussed during a June 23, 1989 phone conversation between yourself and Mr. Thomas T. Martin, Deputy Regional Administrator, NRC Region 1. Specifically, we understand that, prior to startup of the unit, PSNH will: (1) Complete and document the results of the post-trip review process associated with the June 22, 1989 event; l (2) Establish those short-term corrective actions to be completed prior to resta-t of the unit to address the specific deficiencies identified during your post-trip review; (3) Determine those longer term corrective actions and their respective schedules, to address any potentially broader implications associated with the specific deficiencies identified as a result of your review; and, (4) Review the results of items (1), (2) and (3), above, with the NRC staff. We further understand that the agreement of the Regional Administrator, Region 1, would be obtained prior to restart of the unit. j 1 i
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E JUN 231989 s Public Service of New Hampshire 2 If your understanding differs from that set forth above, please call me immediately. Sincerely,
/ :^: .
William T. Russell
' Regional Administrator s I
cc-
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J. C. Duffett, President and Chief Executive Officer, PSNH T. C. Feigenbaum, Vice President, Engineering, Licensing & Quality Program, NHY J. M. PescFel, Regulatory Services Manager, NHY-D. E. Moody, Station Manager, NHY j P. W. Agnes, Jr., Assistant Secretary of Public Safety, i Commonwealth of Massachusetts i Public Document Room (PDR) Local Public Document Room (LPDR) ) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of New Hampshire Commonwealth of Massachusetts Seabrook Hearing Service List l l ~ _ , _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ .
ATTACHMENT 5
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***** August 17, 1989 Docket No. 50-443 License No. NPF-67 1 EA No. 89-158, Public Service Company of New Hampshire
' ATTN:. Mr. Edward A. Brown, President and Chief Executive Officer i New Hampshire Yankee Division Post Office Box 300 !
Seabrook, New Hampshire 03874
)
i Gentlemen: 1
Subject:
NRCRegionIAugmentedInspectionTeam(AIT) Inspection (50-443/89-82) of the Natural Circulation Test at Seabrook Station, Unit No.1 , This letter refers to the June 28-30, 1989 AIT review of the June 22, 1989 natu-ral circulation test at Seabrook Station, Unit No.1. The AIT inspection, led by P. W. Eseigroth of this office, was a fact finding and causal factor deter-mination effort. At the conclusion of the inspection, an exit interview was held with you and members of your staff to discuss the inspection findings. The AIT report is attached as Enclosure 1. Confirmatory Action Letter (CAL) 89-11 stated your agreement to review correc-tive actions and post-trip review results with the NRC staff and to obtain the agreement of the Regional Administrator prior to restart of the unit. You I should be prepared to discuss the findings and conclusions of this inspection report and your response to CAL 89-11 at a public meeting planned for Septem-ber 6,1989 at the New England Center at the University of New Hampshire in Durham, New Hampshire. Following this meeting, elected officials and inter-ested members of the public will be offered an opportunity to provide coments to the NRC staff on the results of the AIT inspection and on the adequacy of . your corrective actions. If, after review of the enclosed report, you. identify additional corrective actions not discussed in your July 12,1989 response to CAL 89-11, please provide those in writing no later than. August 25, 1989. The expression of concern in Section 5.3.3 of the. report for the failure of certain managers observing the natural circulation test to assure adherence to ' test procedure requirements should not be viewed as establishing new expecta-tions of performance. NRC encourages licensee managers to tour their ; facilities and observe significant activities and to be alert to conditions - that could adversely affect safety. In general managers, not on watch, should not direct activities of licensed operators but rather should make their concerns known to shift supervision. However, we remain concerned with the lack of action by managers in the control room on June 22, 1989,'during the five minutes a test criterion was exceeded, particularly sinco this condition was identified to licensee management by an NRC representative. - - _ - - . - - _ _ . _ - - _ - - - _ - - - - _ - - - - _ . - _ - - _ _ _ - - . . _ _ . ._ b --
r siL r i Public Service of New Hampshire, Inc. 2 August 17, 1989 l The failure to trip the reactor when required and the failure to promptly re- l view and resolve any associated personnel performance implications associated with the failure to trip are potential violations of NRC requirements. To dis-cuss these and other. matters identified in Enclosure 2 to this letter, we have scheduled an enforcement conference in the NRC Region I office at 1:00 p.m. on September 7, 1989. At that conference, for each item, please be prepared to present your assessment of safety significance, root cause(s), and your interim and final corrective actions. You will be informed in writing of the NRC deci- i sion on enforcement action when that decision is reached after the conference. { l In accordance with 10 CFR 2 Appendix C, the enforcement conference will not be l open for public observation. Your cooperation with us is appreciated. l Sincerely, Q,7 h&!f William T. Russell Regional Administrator I
Enclosures:
- 1. NRC Region I Augmented Inspection Team Report No. 50-443/89-82 l
- 2. Enforcement Conference Issues and Related Regulatory Requirements cc w/encls:
J. C. Duffett, President and Chief Executive Officer, PSNH T. C. Feigenbaum, Senior Vice President and Chief Operating Officer, NHY J. M. Peschel, Operational Programs Manager, NHY D. E. Moody, Station Manager, NHY P. W. Agnes, Jr., Assistant Secretary of Public Safety, Commonwealth of Massachusetts PublicDocumentRoom(PDR) LocalPublicDocumentRoom(LPDR) Nuclear Safety Infonnation Center (NSIC) NRC Resident Inspector State of New Hampshire Connonwealth of Massachusetts Seabrook Hearing Service List i 0
A ENCLOSURE 2 Enforcement Conference Issues and Related Regulatory Requirements
- 1. The following activities appear to be contrary to: 10 CFR 50, Appendix B, Criterion V, requiring adherence to appropriate procedures;-to 10 CFR 50, Appendix B, Criterion XI requiring adherence to test procedures; to Final Safety Analysis Report (FSAR) Section 14.2 specifying that 1) the. initial startup program be administered in accordance with an approved startup procedure, and 2) that Startup Test Direction personnel will perform startup test coordination and direction functions; and to Natural Circu-lation Startup Test Procedure 1-ST-22. ,
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- a. During the performance of Startup Test Procedure 1-ST-22 on June 22, 1989, pressurizer level reached the 17% criterion requiring a ructor trip in accordance with Attachment 9.3 to the procedure, and the reactor was not tripped by the operating shif t as required (ReportDetails 5.1.4,5.1.5).
- b. Startup Test 1-ST-22 prerequisite 3.6.7 confirming the availability of main steam dump valve MS-0V-3011 was-signed off despite the valve not being properly ready to support- the test because work order WR87W005592, requiring a stroke test at normal operating temperature and pressure, was still open (Report Detail 4.3.3). The failure of MS-PV-3011 during performance of 1-ST-22 initiated the June 22, 1989, test transient. i
- c. Startup Test 1-ST-22 pre-test briefings were not conducted as required, in that the Test Step 3.2 provisions for personnel involved with pro-cedure performance to be briefed on procedure aonduct and' test per- i formance was r.ot accomplished for one of the two control board oper-atorsassignedtoassisttheshiftcrew(ReportDetail5.2.4). Fur-ther, the briefings which were conducted were not appropriate because they were conducted for individuals in a fragmented and abbreviated l manner and not for the operators as a group sReport Details 5.2.4, ;
5.2.6), because the shift supervisor's awareness and knowledge was ; not commensurate with the significance and complexity of the test ) (Report Detail 5.1.5), and because the operators accepted violation i ofatestproceduretriprequirement(ReportDetail5.1.5). These ' conditions were evaluated as contributors to the June 22, 1989 fail-ure to trip the plant as required by Startup Test 1-ST-22. , In addition, inasmuch as simulator training on the startup test program I was conducted in April and May of 1986 and classroom training on low power testing was last conducted in September and October of 1988 (ReportDetails 5.1.2,5.1.5), a lack of recent training was a potential additional contributor to the June 22, 1989 failure to trip the plant as required. _______m . . _ _ _ _ _ . __ _ _ . - m
i i \ Enclosure 2 2
- d. During performance of Startup. Test 1-ST-22 on June 22, 1989, the Startup Manager, Shif t Test Director, and Test Director were present in the control room. No interruption or termination action was in-itiated by the Startup Organization when the 17% pressurizer level reactor trip criterion of Startup Test 1-ST-22 was reached nor was the operating staff counselled by the Startup Organization that a reactor. trip was required under the existing conditions (Report De-tails 5.2.5,5.2.6)
- 2. The following appear to be contrary to: 10 CFR.50, Appendix B, Criterion XVI which requires that measures be established to assure that conditions adverse to quality be promptly identified and corrected, and to assure that the cause for each significant condition adverse to quality and the corrective action taken be reported to appropriate levels of management, ,
and to the FSAR Chapter 13.1.2.2 operating shift management provisions; j and to the assignment of responsibilities for implementation of those pro- i visions in accordance with the Operations Management Manual.
- a. Subsequent to the June 22, 1989 failure to effect a plant trip during conduct of Startup Test 1-ST-22, licensee management failed to promptly resolve associated personnel performance failures (Report Detail 5.3.3).
- b. During performance of Startup Test 1-ST-22 on June 22, 1989, managers present in the control room included the Operations Manager, who is responsible for the operation of the unit's equipment in accordance with approved station procedures, and the Assistant Operations Manager, who directs the activities of the shift superintendents. Both of these managers have the authority to order a reactor shutdown and were observing Startup Test 1-ST-22 performance.in the control board area (ReportDetail5.3.2). Neither of these managers effectively !
implemented his oversight responsibility during the test. I l i I _ _______________.m_. _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ . . ._ _ _ _ . .
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...f October 9, 1986 Docket No. 50-443 MEMORANDUM FOR: Harold R. Denton, Director, Office of Nuclear Reactor Regulation FROM: Thomas E. Murley, Regional Administrator, Region I
SUBJECT:
SEABROOK STATION, UNIT 1 LOW POWER LICENSE RECOMMENDATION This memorandum provides the Region I assessment and recommendation for issuance of a low Power Operating License for Seabrook Station, Unit 1. This recommendation includes issuance of a license pursuant to the provisions of 10 CFR 50.57(c) and is based upon the Region I evaluation documented in the attached Initial Operating License Review Report, with special note of the following:
- 1. The construction and preoperational testing inspection programs have verified that the Seabrook Unit I plant tjas been constructed substantially in conform-ante to the construction permit and the application, as amended, the provi-sions of the Act, and the rules and regulations of the Commission, as required by 10 CFR 50.57(a)(1) and (2).
- 2. We have concluded that New Hampshire Yankee, currently a division of Public Service Company of New Hampshire, is capable of operating the plant safely at low power. Seabrook Unit 1 is essentially ready for fuel loading, While a few systems remain to be final tested, successful completion of these acti-vities is controlled by Technical Specifications in such a way that systems required to be operable for a particular mode of operation (including Mode
- 6) must be declared operable'before that mode can be entered.
- 3. Region I has worked closely with NRR in reviewing New Hampshire Yankee's ap-plication for a subtritical license pursuant to 10 CFR 50.57(c). This has included a review of selected licensee special procedures developed to ensure subcriticality is maintained. The proposed licensee program provides reason-able assurance that the reactor will remain subtritical following fuel load permitted by license issuance.
- 4. Each Region I professional employee was requested by memorandum, dated April 21, 1986, to identify any unaddressed safety concerns which he or she might have concerning Seabrook Unit 1. No concerns were identified.
Other significant elements of this recommendation include: , l
- 1. The evaluation is based upon over 20,000 NRC field inspection hours to date.
- 2. As ouilt inspections have found substantial conformance between the facility and the FSAR, SER, and Technical Specifications.
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1 2 Memorandum for Harold R. Denton 2 g c $M i. ?
- 3. An'IE Integrated Design Inspection (IDI) and a Construction Appraisal Team (CAT) inspection were conducted at Seabrook Unit 1. In general, there was consistency between the plant, regulatory requirements, and licensing commit-ments. All inspection findings opened by these two inspections were subse-quently resolved and closed.
- 4. Region I independent NDE examinations were conducted in 1982 and 1985 and confirmed acceptable weld quality, welding and material controls, and imple-mentation of the Seabrook Unit 1 NDE program in accordance with ASME Code commitments.
- 5. NRC investigation and inspection of allegations raised to Region I with re-spect to Seabrook Unit I construction have identified no significant hardware impact and no unresolved safety issues. A number of new allegations have come to our attention in recent weeks. We will evaluate these allegations in accordance with our regional procedures. Our. preliminary evaluation of these recent allegations'is that they do not raise signifi. cant hardware or safety issues that would preclude a fuel load license.
The following is planned to evaluate the licensee's performance during initial operations:
- 1. As part of routine inspection, plant and staff conformance to license condi-tions and Technical Specifications, including operability requirements for the various operational modes, will be reviewed upon license issuance and frequently thereafter.
- 2. If a license is issued pursuant to 10 CFR 50.57(c), routine inspections will be conducted to evaluate the effectiveness of the special procedures imple-mented by the licensee to maintain the reactor suberitical. This would in-clude both a review of the administrative control over valves which could cause boron dilution as well as other procedures implemented to maintain boron concentration.
In conclusion, I find that Seabrook Unit 1 has been constructed substantially in accordance with Construction Permit CPPR-135, the Seabrook Station FSAR, and NRC regulatory requirements. I also find that, subject to the license conditions recommended by Region I in Attachment I to NPF-56, the licensee is capable of operating the plant safely at low power. Thomas E. Murley Regional Administrator l
Attachment:
Initial Operating License Review Report l l ______-_____-_____-_A
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i . Memorandum for Harold R. Denton 3 OCT 0 9 085 cc w/ attachment. V. Stello, EDO J. Taylor, IE J. Davis, NM55 H. Thompson, NRR T. Novak, NRR V. Noonan, NRR V. Nerses, NRR W. Kane, RI S. Ebneter, RI T.. Martin, RI E. Wenzinger, RI T. Elsasser, RI A. Cerne, RI b i l e G
5, , . , 3 4 6. ATTACHMENT INITIAL OPERATING LICENSE i REVIEW REPORT I l FOR _ I SEABROOK STATION UNIT 1 DOCKET NO. 50-443 l PREPARED BY UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I i
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, o TABLE OF CONTENTS Pace 1.0 Introduction.................................................... 1 2.0 Overview-of Plant Status. ............. ....... .......... .... 2 3.0 Facility Construction........................................... 3 3.1 Overview and Status........................................ 3 3.2 Inspection Program Hi story and Findi ngs. . . . . . . . . . . . . . . . . . . . 3 3.2.1 Routine Region I Inspection Program................. 3 3.2.2 NRC Special Inspections............................. 6 3.2.3 Review of Construction Deficiencies................. 11 3.2.4 Third Party Audits and Evaluations.................. 11
- 3. 3 Quality Assurance for Construction......................... 12 2.4 Facility Construction Summary and Conclusion............... 13 4.0 Facility Preoperational Testing................................. 14 4.1 Overview and Status........................................ 14 4.2 Inspection Program History and Findings. . . . . . . . . . . . . . . . . . . . 14 4.3 Facility Preoperational Testing Summary and Conclusions.... 15
- 5. 0 Fa:ility Preparations for Operations.............................' 15 l
l 5.1 Overview and Status........................................ 15 l 5. 2 Inspection Program Hi story and Findi ngs. . . . . . . . . . . . . . . . . . . . . 15 1
- 5. 2.1 Facility Operations - Staffing and Programs......... 15 l 5.2.2 Quality Assurance for Operations.................... 17 5.2.3 Emergency Preparedness Facilities and Program....... 17 5.2.4 Radiological Controls and Fuel Receipt................ 18 .
5.2.5 Security Facilities and Programs.................... 19 5.2.6 Fire Protection Facilities and Programs............. 19 5.2.7 Technical Specifications............................ 20
- 5. 2. 8 . Thi rd Party Audits and Evaluations. . . . . . . . . . . . . . . . . . 20
- 5. 3 Startup Test Program....................................... 21 ,
6.0 E n f o rc eme n t H i s to ry. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21' 7.0 Systematic Assessment of Licensee Performance (SALP). . . . . . . . . . . . 22 1 7.1 Overview and Status......................................... 22 l 7.2 First SALP................................................. 22 l l 7.3 Second SALP................................................ 23 7.4 Third SALP................................................. 23 7.5 Fourth SALP................................................ 23 7.6. Fifth SALP................................................. 24 7.7. Sixth SALP.................................................. 24
- 7. 8 Seventh SALP............................................... 25 i
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l 8.0 Allegations........ ... . ...................................... 25
- 8.1 Overview and Status. ............ .... .................... 25 8.2 Facility Allegation Resolution and Summary....... ..... . . 26 8.3 Licensee Employee Allegation Resolution Program. .......... 26
- 9. 0 10 CFR 50.57(c) Motion.......................................... 27 j 1
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10.0 Future Region I Actions........... ....... ..................... 28 l J, 11.0 Justification for Interim Operation............................. 29 i 12.0 Summary and Conclusions.. ...................................... 29 f LIST OF ENCLOSURES Enclosure Title 1 Special Assessment of the Quality of Construction of Seabrook Station Unit 1 2 Summary of SALP Evaluations 3 Inspection Program Annual Breakdown (Hours) 4 Inspection Summary i l
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.1.0 Introduction Public Service Company of .New Hampshire (PSNH) applied f or a . license .to con-struct and operate Seabrook Unit 1 (DN 50-443) on July 9,1973, and was issued a Construction Permit (CPPR-135) on July 7,1976. Unit 1 is a Westinghouse-four-loop PWR, rated at 1198 MWe and housed in a reinforced concrete contain-ment structure It is located in the town of Seabrook, Rockingham County,-
New Hampshire, along with Unit 2, a similarly designed reactor, currently 24% complete with construction halted and in an " indeterminate status". .The units are arranged using a " slide-along" concept with certain structures common to both units. United Engineers and Constructors (UE&C) served as the architect / engineer and construction manager. PSNH has contracted with the Yankee Atomic Electric Company (YAEC) for specific services,'to include project engineering, licens-ing, fuel supply and the establishment and implementation of the Quality As-surance Program for design and construction. YAEC will also provide engineer-ing services necessary to support the operation of Seabrook Unit 1. On June 23, 1984 an organizational change was made to create the New Hampshire Yankee (NHY) Division of PSNH with the primary responsibility for construction, startup and operation of Seabrook. This followed a temporary suspension of construction activities, initiated on April 18,-1984 due to financial pres-sures on PSNH. Other organizational changes which released several contrac-tors from the Seabrook project, replacing.them with UE&C as.the " direct em-ployment" constructor. Other major construction work stoppages occurred in February,1977 and July,1978 when the NRC suspended the construction permit because of questions regarding the circulating water tunnels and the lack of EPA approval for this cooling system. NRC Region I began performing inspections at Seabrook in 1973 and has com-pleted over 200 inspections totalling over 20,000 hours. These inspections involved observation of work in progress, examination of completed work, re- ! view of work control documents, independent measurements and calculations, and the examination of quality records. This report describes the process used by the licensee to monitor'and control the quality of construction and preoperational testing, discusses the results of independent evaluations of the licensee's performance, and addresses both ! the inspection program and the Systematic Assessment of Licensee Performance I (SALP) program conducted by NRC Region I. The report also discusses facility' < preparations for' operation. This report presents the basis for the Region I conclusion that.(1) Seabrook I Unit I has been constructed substantially in accordance with Construction ! Permit CPPR-135, the-Final Safety Analysis Report (FSAR), and NRC regulations; and (2) New Hampshire Yankee, as a division of PSNH, is ready to safely operate the facility. l l l
g, . .- ~w- -- - . , x ymmg ny,. .. , pg ;wmm _ y _ p i 7* l 2.0 Overview of Plant Status Construction of!Seabrook Unit 1 is. essentially complete. All buildings, sys .
-tems, and equipment'have been turned over to.the station-staff. Some con-struction completion activities'such:as painting remain-to be finished. Ad-
'ditionally, some minor-construction activities in the turbine building remain.
Preoperational testing activities are nearly complete. Some tests remain to 'l be' completed and some test exceptions in the; areas of heating,- ventilation,
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and air conditioning (HVAC), solid waste transfer, Land the station computer remain to'be closed out. Where system tests are not complete or rework is ongoing (i.e. , resolution of construction deficiencies identified per 10 CFR . 50.55(e)), the Technical Specifications will govern the: operability of systems and equipment in the mode ~ for which they are needed. During the' course of NRC inspection and investigation activities at Seabrook' Unit I since 1973,-over 1,000 inspection items requiring tracking and follow-up have been opened. .These items include enforcement actions and allegation followup activities as documented in other sections of this report, routine bulletins, circulars, construction deficiency reports, unresolved issues, and program weaknesses identified by-special team inspections. Approximately 50 of these NRC inspection items currently remain open,-the.other items have been closed in NRC inspection or-investigation reports as appropriate. The status . of outstanding items is continually being assessed and' updated as Region I inspection activities continue. At this time, no open. inspection item, cur-rently outstanding, is deemed of such significance as to affect the Region I recommendation'for issuance of a low power license. Testing exceptions noted during the conduct'of Hot Functional Testing required l partial system design modifications and appropriate retesting. Systems af-fected are: emergency feedwater (recirculation system and Terry turbine cold starts); steam generator blowdown; feedwater recirculation; main steam isola-tion bypass and steam valve operability system functions. Successful comple-- tion'of additional hot testing during the licensee's planned post-fuel load, hot functional tests to close the-open test exceptions is required prior to initial criticality. In terms of readiness for operation,-no major impediments to the low power license issuance have been identified. Procedural preparation and validation continue and it is anticipated that all procedures required for a particular mode of operation will be approved and issued prior to the plant entering that mode. Prior to 1984, the licensee demonstrated adequate management of Seabhok~ con-struction and testing activities, primarily through the use of YAEC QA, lic-ensing, engineering and project management services. The establishment of-this management structure provided independence and resulted in the construc-tion of a generally quality product. However, some recurrent' programmatic problems did arise, as in the area of piping and pipe support construction, discussed later in this report. ~With the reorganization under New Hampshire 1
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l 3 l- Yankee in 1984, not only were .YAEC and UE&C services and functions combined under dire.ct senior licensee management overview, but also the responsibility for the quality completion of work, given schedular goals, was delegated with the associated accountability. The impact of such a change in management direction not only improve,d schedular and budgetary performance, but also
.provided effective corrective action to some of the persistent problems in the piping and pipe support area. -The New Hampshire Yankee reorganization is also viewed as having been beneficial to the preparedness of the operations staff by providing the same management concept and direction to all parts of the Seabrook team.
In summary, Seabrook Unit 1 is deemed: ready for safe low power operations and testing, subject to the license conditions. 3.0 Facility Construction i l 3.1 Overview and Status. l The construction of Seabrook Unit 1 is essentially complete. Region I ! inspections of construction activities at Seabrook have been conducted i in accordance with the program established by the Office of Inspection and Enforcement. The objective of these safety. inspections is to obtain sufficient information through direct observation in the field, personnel interviews, and review of procedures and records to determine whether construction and installation of safety-related components, structures, ; cnd systems meet applicable requirements. A significant portion of the~ ! inspection effort is directed toward inspection of the applicant's Qual- l ity Assurance Program and its implementation in both the Preliminary and Final Safety Analysis Reports. This program has been reviewed by the NRC and accepted as documented in the appropriate Safety Evaluation Re- , ports. ! l 3.2 Inspection Program History and Findings l 3.2.1 Routine Region I Inspection Program A Senior Construction Resident Inspector was assigned to Sea-brook in May,1980. Additional resident inspection resources were dedicated to Seabrook with the assignment of a' resident inspector in September,1982 and a resident entry level engi-neer was assigned in April, 1985. Currently, there are two operations resident inspectors on site, who have a combined total of seven. years of Seabrook resident experience and who ! both inspected the conduct of most of the preoperational test program, including the month-long series of tests integrated into the Hot Functional Testing of Seabrook systems. By direct observation, independent verification, daily presence, and both routine and reactive inspection, the resident inspectors have provided an additional measure of assurance that the quality of construction and testing has been achieved and maintained. e
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Initial NRC inspection activities commenced at Seabrook in 1973. Announced and unannounced Region I inspections have been con-ducted since that time at a frequency consistent with the pace of construction activities as work at the Seabrook site pro-gressed. With the inception of the resident inspection program at Seabrook, NRC on-site coverage of construction work has been ' provided and supplemented by additional inspections by Region I specialist inspectors. In general, Region I inspection reff urces were directed to the verification of quality performance in the areas of soils and foundations, containment and other safety-related structures, , piping systems and supports, safety related components, support ! activities and systems, electrical power supply and distribu-tion, instrumentation.and control systems, quality assurance, management controls, design and design change control, and corrective action effectiveness. Enclosure 4 identifies the inspections performed, the areas inspected, and significant inspection findings. To date, over 200 inspections have been performed for Seabrook Unit 1. A comparison of Seabrook in-spection hours with those expended at two recently licensed Region I facilities (taken.at 90% construction completion as
.a reference point for comparison purposes) is illustrated below:
1 Seabrook Unit 1 Millstone Unit 3 Hope Creek 15600 hours 9100 hours 7600 hours The NRC routine inspection program at Seabrook has confirmed ; the overall quality of construction and hardware installed in ; Unit 1, as well as identified those areas of programmatic con- ! cern where licensee management attention and corrective action were necessary. Historically, NRC concerns have been raised in the areas of QA program implementation, design and design change controls, piping and pipe support construction, and electrical installation. The problems with QA, identified during the early phases of Unit 1 construction, were related to the large number of contractors on site, each with their own separate QA program. It is noteworthy that the continuity and overview of YAEC, in the area of QA, were able to not only make the QA program effective, but eventually make it one of the strengths of management controls at Seabrook. One key step in this progress occurred in early 1984 when the reporting lines for each contractor site QA organization were redirected from the contractor corporate staff offsite to the onsite YAEC Construction QA manager. This management change provided the licensee a more direct control of the QA function and the ability to implement effective corrective action, when re-quired. h____.____.________________________._________. _ _ _ . _ _ . _ _ _ _ _ . . _ _ . _ _ _ _ _ .__ _ . _ _ . . _ . _ _ _ _ _ _ . . _ . _ _ _ _ _ _ _ _ . _ . _ _ _ _ . . _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ . _ _
5. Similarly, in the area. of design and design change controls, increased YAEC involvement in the engineering overview of UE&C activities provided the necessary direction for improvement. in this area of NRC concern. Liaison between Region I and the IE Vendor Inspection Branch (VIB) resulted ir, the. conduct of VIB inspections on site in'conjun~ction with planned audits of the UE&C office in' Philadelphia. A subsequent management meet - ing with the licensee and both Region I and the VIB reinforced I the NRC position.that' additional corrective measures.were war-ranted in the design. change area. With the increased YAEC
' overview, and with the establishment of the NHY Director of i
l, Engineering and his. staff to further manage design activities, the programmatic problems identified.in this area were' satis-factorily addressed. The piping and pipe support discipline historically has repre-sented the area of greatest concern at Seabrook~ Unit 1. A Region I-Immediate Action Letter confirming a licensee stop . work order to halt all weld repairs performed by the piping contractor.(Pullman-Higgins) was issued in late-1980. While corrective action'on this: issue was. implemented by the licensee in a timely manner, subsequent routine NRC inspection continued
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to identify concerns with weld procedures qualifi, cation', weld NDE, pipe support-installation, and particularly with generic interface problems between'UE&C and Pullman-Higgins. With Jegard.to hardware impact, it was noted that significant rework. was required in the piping and pipe supports area to assure quality installation in line.with design criteria. All of these NRC concerns culminated in Region I convening a special Systematic Assessment of Licensee Performance (SALP) Board in February,1984 to evaluate licensee performance and corrective l-action'in the " Piping Systems and Support'E area alone. Licensee response-to the special SALP finding was integrated.. into the'overall change in management direction, which occurredJ in 1984. At that time, as noted.above,-the shift in reporting responsibility for contractor QA organizations-(in this case, Pullman-Higgins) was implemented and the establishment of New-Hampshire Yankee took place. Construction management control-of the piping discipline was thereby more firmly placed under ! direct NHY management supervision. These management actions,- l- in congruence with the specific corrective measures-for the identified' technical- problems, proved effective in improving the subsequent' performance in the piping and pipe supports area. NRC: inspections of this discipline since the implementation'- of,all'the corrective actions have~ confirmed their effective-nes{. l
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With regard to the last identified NRC construction concern
'e nvolving electrical installation deficiencies, it is noted that interface problems between the installation contractor and the-A/E-construction manager, here also, proved to be the root-cause basis for the programmatic concern. With the re-placement of the electrical contractor with a UE&C direct labor force and with additional NHY supervision, effective controls
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were implemented in this area at the time when the electrical discipline workload was at its most critical period with con-trol and power circuits and systems being tested. NRC follow-up inspection of electrical construction, along with routine inspection of all the construction disciplines, con-firmed quality hardware and installation and acceptable licen-see process controls related to this area. 3.2.2 NRC Special Inspections Several special team inspections of Seabrook Unit I have been conducted to supplement the routine inspection program and to provide additional assurance of quality. These in n ctions
. are listed below with a description of the inspeci.oa scope and conclusions. .
- a. Region I Construction Assessment Team (CAT) inspection -
. June / July,1982:
The purpose of this CAT inspection was to evaluate the licensee's project management effectiveness by performing detailed examinations of quality assurance, construction control, project management and design control. Also, the Region I Mobile Nondestructive Examination (NDE) laboratory was used, along with a contractor-supplied radiographic source and technicians, to perform indepen-dent examination of welds /weldments using Radiography, Magnetic Particle, Liquid Penetrant, Thickness Measure-ment, Ferrite Measurement, Hardness Measurement, and Visual Examination. The CAT inspection found that the overall project was adequately managed. Design control and the effectiveness of corrective action were two areas identified as requir-ing additional management attention. Also, one radio-graphically examined weld was found to contain a reject-able linear indication for which repair was required. Corrective action on these issues was effected by the licensee and all open NRC inspection items have been closed. I 1-l
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- b. IE Integrated Design Inspection (IDI) - November / December, 1983: .
The IDI at Seabrook was based upon an NRC initiative to develop a program to assess the quality of design.activi-
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ties for a nuclear facility, to include the examination of the as-built configuration, resulting from such design. A comprehensive examination of the design development and implementation was conducted for the Unit 1 containment
-building spray (CBS) system. The inspection was-an in-teroffice NRC effort, conducted with contractor assistance, which evaluated the CBS system design with respect to five major engineering disciplines - mechanical systems, me-chanical components, civil and structural, instrumentation and controls,.and electric power.
While a large number of findings and observations were generated in the IDI Report, the summary conclusion indi-cated that the problems found in the Seabrook design ap-peared to be confined to specific issues that did not seem to cross discipline boundaries. Each individual issue and finding was addressed by the licensee in response to the IDI report. A follow-up inspection was. conducted at the UE&C offices in Philadelphia, PA in November,1984. Most open inspection items were closed by the NRC Office of IE with certain specific issues being transferred to Region I or the Office of NRR for closure. In June 1986, all IDI items were closed.
- c. IE Construction Appraisal Team.(CAT) inspection - April /
May, 1984: i The objective of this CAT inspection was to evaluate the adequacy of construction at Seabrook Unit I through review of the construction program and selected portions of the QA program, with emphasis upon the installed hardware. , Sample inspections were conducted by both NRC personnel I . and contractors in the following construction areas: electrical and instrumentation mechanical civil and structural. welding and NDE material traceability and controls design change control corrective action systems l
4 8 l i The overall conclusion reached by the CAT inspection was that hardware and documentation for the various construc-tion areas reviewed were generally found to be in accord-ance with requirements and commitments. Certain program weaknesses were identified, particularly with regard to the design change control process, A/E interface with the i contractors, and pipe support construction. Subsequent ; NRC inspection of all of these areas has identified ac- i ceptable corrective action on the part of the licensee and has closed all CAT inspection findings.
- d. Region I Construction Team Inspection (CTI) - June, 1985:
The purpose of this inspection was to assess the effec-tiveness of the resumption of construction activities 1 (after the 1984 work suspension) under the new NHY site organization. A multidisciplinary review of selected j portions of key safety-related systems for Seabrook Unit ' I was conducted. The systems reviewed and inspected in-cluded the safety injection, residual heat removal, HVAC, ! and diesel generator jacket water cooling systems. While the inspection results revealed certai.n weaknesses in the I&C, design change and welder qualification records areas, overall program strengths were found to reside with licensee site management, QA effectiveness, and UE&C welding engineering. In summary, the CTI noted a high level of management involvement in the quality and control of site construction activities. All of the CTI inspec-tion findings have been closed.
- e. Region I Independent Measurements Inspection - July,1985:
The purpose of.this inspection was to verify the adequacy I of the licensee's welding and NDE quality control programs. Utilizing the NRC Mobile Nondestructive Examination (NDE) Laboratory, Region I engineers and NDE technicians, as-sisted by contractor personnel with a radioactive NDE I source, conducted examinations of welds and weldsents required of the licensee by code in order to check the licensee evaluation of the original examinations. Also, other confirmatory measurements were taken to indepen-dently determine the quality of selected inspection items. The following represents a summary of all items examined: Radiography - 37 welds Socket Weld Gap Measurement - 24 welds i Liquid Penetrant - 32 welds Visual Examination - 68 weldments
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Magnetic Particle - 23 welds 1 Ultrasonic Examination - 6 welds Hardness Measurement - 11 welds
' Thickness Measurement - 44 weldments Ferrite Measurement - 24 weldments Alloy Analysis - 5 welds .
. Anchor Bolt Length Measurement .56 bolts Visual Examination of Steam Generator "J" Tubes -
8 welds. I Containment' Liner. Coating Thickness Measurement'- 10 readings each at 3 different locations The inspection results revealed no unacceptable conditions and confirmed the validity of the original licensee NDE, along with the acceptability of the sample hardware.
- f. Region I As-Built Team Inspection - March,1986:
The purpose of this team inspection'was to determine j whether.the systems,' structures, and components selected for review were constructed substantially.in accordance with the descriptions provided in the Final Safety Analysis-Report (FSAR) and NRC's Safety Evaluation Report (SER). ' The. inspection also included a' comparison of the physical installation with engineering design documents (including piping.and instrumentation drawings (P& ids) and the ap-plicant's plans:for controlling plant configuration and operations during the startup and operational. phases. System walkdowns were performed during which independent dimensional measurements were made. The "Seabrook Station Probabilistic. Safety Assessment" ' (SSPSA), PLG-0300 by Pickard, Lowe'and Garrick, Inc. was reviewed!to obtain the potential accident sequences that were significant contributors to core melt frequency and offsite risk. This information was used to select the systems and components for' inspection. The final selec-tion included Emergency Diesel 18 Emergency-Diesel 1B Room Ventilation, Service Water Train B,- and Primary Com-ponent Cooling Water Train B. . Limiting the inspection to the "B" train of. the selected systems allowed the in-spection to cover a greater depth. Other systems in- -) spected included the cooling tower and the reactor coolant pump thermal. barrier. cooling ~ system. In summary, all of.the systems selected for review were found to have been built and operated in. substantial ; agreement with the Seabrook FSAR description and the~ pro - 1 ject design documents. The two inspection findings which were identified related to material traceability and work 1 i j i
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10 process control issues, and did not affect the accept-ability of the overall system design and construction. All of the open inspection items from this as-built team-inspection have been closed, except one-which is currently under review by the Region I staff.
- g. Region I Technical Specification (TS) Inspection - May, 1986:
NRC contractor personnel, with the direction of Region I inspectors, conducted an inspection of Seabrook Unit 1 to determine whether the draft Technical Specifications and the FSAR'are compatible with the as-built plant con-figuration and operating characteristics and whether the draft TS are definitively measurable. The inspection was concentrated on plant systems, structures and components identified as having particular significance with respect to minimizing the severity of potential accidents and ac-cident consequences. The. systems evaluated included: containment and related support systems, containment spray systems, emergency core cooling systems (ECCS), soluble poison reactivity control (boration) systems, electrical power systems, and selected secondary plant systems and components. At the time of the inspection, the draft TS consisted of the " Proof and Review" edition with final TS still under development by the licensee in conjunction with the NRC Office of NRR. Selected observations and findings, re-sulting from this team inspection, were a direct result of the " draft" nature of TS used in the inspection. The team concluded that information which is still under de-velopment for incorporation into the final TS and imple-menting procedures appears subjected to sufficient man-agement control to assure adequate completion of the in-corporation / revision process. One overall conclusion of this inspection was that the TS and implementing procedures reviewed appeared to be compatible with the as-built plant configuration. How-ever, the inspection identified several TS inconsistencies. The licensee has been working on resolving these incon-sistencies and correcting any procedural errors that may have resulted. Also, Region I has provided NRR, under separate correspondence, a list of those items determined to be TS inconsistencies as a result of this inspection. Region I plans . follow-up inspection activities to close each identified issue. i
11 3.2.3 Review of Construction Deficiencies j To date at Seabrook, the iicensee has submitted 103 Construc-tion Deficiency Reports.(CDR). Of these, subsequent licensee _. evaluation determined that 17 items were not reportable and the applicable.CDR's were withdrawn. l The significant deficiencies reported cover a' wide range of topics. Licensee sensitivity to reporting and their. evaluation ]j to the 10 CFR 50.55(e) criteria have been appropriately applied. In mid-1983, some problems were encountered when final con- 1 struction deficiency reports were issued to the NRC. For.in - ; stance, when corrective' actions outlined in the deficiencyH -l reports were reviewed by NRC. inspectors, they found that some l had not been implemented. In response to this' problem, the licensee published _new guidance on CDR evaluation, tracking, verification and formal report issuance to the NRC. One sig-nificant attribute of the licensee's new CDR policy involved the requirement for verification of corrective action by.the QA organization prior to issuance of a final report-to.the NRC. Since the initiation of this policy, corrective action on CDRs has proceeded well. Analysis of the CDR's for causal linkage, as is done routinely in conjunction with the NRC Systematic Assessment of Licensee Performance (SALP) reviews, revealed linkage of 21 items be-cause of A/E design errors. This.CDR. linkage was; indicative ] of. problems in the design and design change c'ontrol area, as < discussed in section 3.1.1 of this report. Region I management meetings with the licensee, in conjunction with Vendor Inspec-tion Branch meetings _and inspections of.UE&C, emphasized NRC concern:in this area. As was discussed earlier,-the establish- ) ment of a NHY Director of Engineering-has since. strengthened- l the design function. Also, the IDI-team inspection identified-no major weaknesses-in'the overall design program which would render the Seabrook design process suspect. In' fact, the.lic - ensee's: reporting of design deficiencies has illustrated their program can identify- and correct- mistakes. With regard to all-of the reported CDRs,' licensee corrective action has generally been timely. As_of August 28, 1986, eight CDR's were outstanding, pending completion'of licensee corrective action'and NRC review. All of the outstanding CDRs are expected to be closed or disposition will be reviewed by ; Region I prior to the initial _ criticality of Unit 1. : 3.2.4 Third Party Audits and Evaluations Three INPO-sponsored evaluations of the construction of Seabrook . Unit I have been conducted. The first was a Self-Initiated i Construction Project Evaluation (October / November, 1982) util-l
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12 izing an independent team of Northeast Utilities and Stone & Webster engineers with the Performance Objectives and Criteria of. Construction Project Evaluations developed by the Institute of Nuclear Power Operations (INPO) used as the basis for the evaluation. The following two evaluations (October, 1983 and December, 1984) were conducted by INPO personnel at the Seabrook site.and the UE&C. design offices in Philadelphia, PA. The INPO evaluation
-teams formed at those times examined the areas of, organization and administration, design control, construction control,' pro-ject support, training, quality, test control, maintenance.,
technical support, and industry operations experience at the Seabrook project. A summary determination by INPO during the last construction evaluation indicated that the systems in place _ to control the quality of design and construction are being implemented ef-fectively. The Region I staff has been briefed on the INPO findings, including licensee responses and corrective action on the individual findings, and has discussed with licensee l personnel whether certain findings met the reportatrility cri- ' teria of 10 CFR 50.55(e). . 3.3 Quality Assurance for Construction The QA program for Seabrook Unit I construction is described in the Sea-L brook Station PSAR and FSAR and has been implemented through the program l and procedural controls dictated by the Seabrook Station Quality Assur-l ance Manual. While PSNH has retained the overall responsibility for QA at Seabrook, it has delegated to the Yankee Atomic Electric. Company (YAEC) the responsibility for the development, execution, and administration ; of the quality assurance program. This delineation of responsibility j was not affected by the formation of the NHY division of PSNH in June, i 1984. l l Three levels of QA verification have always been a part of the QA program { controls. The first le'el of quality control is provided by inspection j by the contractors of their work and preventive maintenance and receipt ; inspection by the construction manager (UE&C). The second level of sur- ) veillance activities is provided by either the YAEC Field Quality Assur-ante Group on site or, in the case of civil / structural activities, by the UE&C Field QA Department. The third level of QA is provided by , audits of the site programs conducted by independent YAEC auditors from ! the YAEC offices in Framingham, MA or by full time YAEC auditors sta- l tioned on site. UE&C and Westinghouse (the N555 supplier) also conduct i audits of site organizations and are responsible for the vendor inspec- I tion program of their suppliers. Each contractor is also periodically j I
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y l 13 audited by their respective corporate QA staffs. PSNH periodically con-ducts external audits of the YAEC QA program and participates in the conduct of YAEC internal audits of the same program. Region I has monitored the licensee's construction QA program through a the implementation of the routine and special inspections discussed earlier in this report. The weaknesses discussed in section 3.1.1 were identified early in construction and the licensee took prompt and effec-tive corrective action. The steady improvement of the QA controls being j implemented at Seabrook Unit 1 is, tracked by the SALP process where the 1984 assessment noted that a " strong and stabilizing QA program exerted { 1 a positive influence upon project and construction controls at Seabrook i Station". Likewise, the most recent SALP evaluation in May,1986 recog-nized that "an effective QA program has been and is in place at Seabrook l Station and continued management support continues to provide the neces-sary assurance of quality".
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Enclosure 1 presents a Special Assessment of the Quality of Construction j of Seabrook Station Unit 1, as p % ided by the licensee's QA organization. l The data provided have not been verified by the NRC, but indicate QA ac-1
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i tivities and actions over the course of Unit I construction and testing. 3.4 Facility Construction Summary and Conclusion . At 90% construction completion, over 15,000 inspection-hours had been expended evaluating the quality of construction at Seabrook Unit 1. The IE Inspection Program (Manual Chapter 2512) for the construction phase is essentially complete with only the Preservice/Intervice Inspection i and Spent Fuel Storage Rack Inspection modules deferred for later in- i spection after license issuance. Numerous team inspections have been ' conducted at Seabrook with both IE CAT and IDI inspections supplementing the Region I routine and team inspection effort. ! Based upon the large amount of inspection hours, the enforcement history (Section 6.0) for facility construction has indicated no major hardware problems. The highest severity level violation issued at Seabrook was a severity Level IV, while the most significant escalated enforcement action was the issuance of an Immediate Action Letter to confirm a lic-ensee stop work on pipe welding. Corrective actions by the licensee on other problems with the piping contractor have been confirmed to have been effective, as were corrective measures taken for early QA and design control problems. Recent NRC team inspections of the plant and Technical Specification l conformance to the plant have found that Seabrook Unit 1:has been con-structed in substantial accord witty the FSAR and NRC requirements. NRC l inspection over the' course of construction, to include reviews and evaluation of the licensee QA program, has confirmed quality hardware and acceptable standards of construction. l
14 l
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'4.0 Facility Preoperational Testing 4' .1 Overview and Status The preoperational test (PT) inspection program began in September, 1983 and is essentially complete._ The program was conducted by both resident and region-based specialist inspectors. Inspections of test procedures, performance, and results were accomplished, along with an overview of management controls to verify proper implementation of the test program and the requisite involvement of the QA organization.
4.2 Inspection Procram' History.and Findings The NRC preoperational testing inspection program (Appendix A to IE l Manual Chapter 2513) is essentially complete with all mandatory tests witnessed and results reviewed, while the primal tests have received over three times the inspection effort required by MC 2513. LParticular atten-tion was devoted to certain major integrated tests (hot functional test-ing, reactor coolant system hydrostatic test, the containment structural integrity.and integrated leak. rate tests). During conduct of these in-tegrated tests, region-based inspection teams, in conjunction with the resident inspectors,.provided twenty-four hour sample coverage'of'the .. test while in progress. 'In total, over 3,000 hours have been expended in the Region I implementation of the preoperatirmal testin~g program at Seabrook Unit 1. - This total includes conduct of portions of the As-Built' and Technical Specification team inspections, which were accomplished to compare the as-built plant tr the FSAR description, NRC review of selected test procedures indicated an acceptable level of technical Edequacy. Witness'of the tests confirmed that an adequately staffed and. qualified startup test group was in control of test conduct and that the QA staff was involved in test surveillance'and QC activities. I Not more than 100 test exceptions were open at any given time during i preoperational testing of Seabrook Unit 1. Some integrated tests (SIT i
& ILRT) were successfully completed without a single test. exception ;
documented. Region I inspection of the PT test results has verified j adequate action on the part of the licensee to close all test exceptions. j i During the conduct of the month-long Hot _ Functional Test (HFT), some i significant test exceptions were noted. A water hammer was experienced in the steam lines to the EFW Terry Turbine and other emergency feedwater'- ; (EFW) problems with' recirculation and flow to the steam generator were - ' experienced. ' As with the othu test exceptions (e.g. , main steam bypass 1 and steam dump' problems) which require the plant to be hot, system re- , design and reanalysis was necessary. Six specific startup tests (ST) have been written by the licensee'to validate system functionality for the HFT test exceptions, with these'ST's to be conducted during the post-core load HFT prior to initial criticality. e
15 NRC review of the licensee's preoperational testing progress has con-firmed an adequately m'anaged program with quality. test objectives being met and generally acceptable test results being achieved. 4.3 Facility Preoperational Testino Summary and Conclusions As discussed earlier in this report, a minimal number. of actual hardware problems'were identified in the construction of Seabrook Unit 1. The-good test results attained by the preoperational test program provide additional. assurance of the adequacy of Unit I construction. Only two violations were issued against the preoperational area since the initi-ation of the reoperation inspection program in 1983.- This is further corroborated by the two successive Category 1 SALP ratings (Section 7.0)
. assessed in the Preoperational Testing area by the last two SALP boards.
'Overall a high level ~of performance was fou nd to exist in the=1icensee's implementation of the testing program at Seabrook Unit 1. Where system redesign was necessary and further. testing is required, further. Region I follow-up inspection is planned during the Startup Testing phase.
- 5. 0 Facility Preparations for Operations 5.1 Overview and Status -
)
i Procedural preparations and validation continue and it is anticipated l that all procedures required for a particular mode of operation will be j approved and issued prior to'the plant achieving the applicable mode. i Activities in preparation for initial fuel load were closely monitored .i by Region I. Facility staffing, personnel qualifications, training and ! procedure. development, and implementation and establishment of operational l organization interfaces have been reviewed. TheseLreviews indicate that the licensee has an effective program-in place to support the operational . phase. ' l 5.2 Inspection Program History and Findinos ! 5.2.1 Facility Operations - Staffino and Programs New Hampshire Yankee (NHY) will operate Seabrook Station. The : Vice President-of Nuclear Production located in the NHY'Cor- i porate Offices onsite, is responsible for. corporate management of the station staff, nuclear training center, nuclear-services, ; regulatory services, production services"(startup), and emer-gency preparedness. At the station ~ staff. level, the Operations Manager, under the Station Manager, is responsible for managing, and controlling the operations department and assuring safe and efficient plant operatjon. a -m___ _ _ - _ - _ _ _ ___.___ _ _ _ -_________._______._m-._________m___ - ___-___m__.
16 The licensee plans to operate Seabrook Unit 1 with six shift crews. Each shift will be under the direction of a Shift Superin'tendent (55). Reporting to the SS will be a Unit Shift Supervisor (USS) who will be in the control room. Either the 55 or the USS will fulfill the shift technical advisor (STA) function. Additionally, several senior control room operators (SCR0s) and control room operators (CR0s) qualified as STAS. Both the SS and USS hold SRO licenses. Also, in the control room on each shift will be a SCR0 and a CRO. While both of these operators are required to hold reactor operator (RO) licenses, most of the SCRO's will hold SRO licenses. Of the 38 licensed operators at Seabrook, 32 operators hold SRO lic-enses.
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A summary of the Seabrook operator license examinations is presented below. Of particular note is the high success rate (93%) of the Seabrook candidates who passed the examination on their first attempt. Exam Week Results September 17, 1984 11 SRO Candidates - 10 passed 2 R0 Candidates ,1 passed December 3, 1984 4 SRO Candidates - 4 passed 3 R0 Candidates - 3 passed March 18, 1985 17 SRO Candidates - 16 passed (includes one SRO retake) 3 R0 Candidates - 3 passed (includes one RO retake) September 30, 1985 5 SRO Candidates - 5 passed (includes one SRO retake) These results reflect the use of a site-specific Limulator, located onsite at the nuclear training center which was com-missioned in November,1980, and a generally effective licensed operator training program. The licensee will have at least one SRO per shift with the required six months hot experience or an approved hot experience equivalency. Also, a requalifi-cation program for licensed operators at Seabrook is underway and is currently being maintained. In summary, the staffing and training program for Seabrook Unit 1 indicates the readiness of the staff to safely operate the plant. Positive aspects which support this conclusion are: l the availability of the p1&nt-specific simulator, the perform-ance of licensed operators, both from an examination standpoint I I u_____________
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. 17 I
and from their performance in the control room during testing in progress, and the program planned for six-shift rotation, and continued training and qualification. 5.2.2 Quality Assurance for Operations The quality assurance for operations is described in Section 17.2 of the Seabrook Station FSAR. Based upon the staff review and as documented in the SER, the Seabrook QA program was de-termined to describe requirements, procedures and controls that, when properly implemented, comply with the requirements of 10 CFR 50, Appendix B. Also, the organizations and persons performing QA functions appear to have the required indepen-l dence and authority to effectively carry out the QA program. Commencing in January,1986, Region I initiated several opera-tional readiness inspections at Seabrook Unit I to review, in part, the Operational QA Program structure and implementation in such diverse areas as administration, audits, procurement control, receipt & storage, records, document control, main-I tenance, design changes & modifications, test & measurement equipment, and surveillance testing. The inspection modules associated with these QA program activities are essentially complete. No areas of concern were identified. , Also, a "Startup Quality Assurance Interface Agreement" between l the licensee construction and operations program staffs has been implemented at Seabrook. This QA policy defines various organizational responsibilities and scopes the role of the , Operational QA Program from the time of Conditional Acceptance l Turnover of components, systems or structures to the initial fuel load of Seabrook Unit 1. The planning and coordination upon which this QA policy is based appears to have provided I the necessary direction for QA controls during the transition from construction into operations. Overall, Region 1 inspec-tions into the operational preparedness phase of the Seabrook QA program have identified no substantive weaknesses. 5.2.3 Emeroency Preparedness Facilities and Program The Seabrook Station Emergency Plan and Emergency Planning in general were evaluated by the staff during licensing reviews, j documented in the Seabrook SER (March,1983) and Supplements 1 (April, 1983) and 4 (May, 1986). l l Region I has conducted two Emergency Preparedness Implementa- ! tion Appraisals (EPIA) at the Seabrook site, has witnessed the full-scale exercise, graded by FEMA, in February, 1986, and has conducted several EP follow-up inspections. The first . EPIA, initiated in December,1985, had to be terminated prior ! 1
18 to completion because licensee equipment, training and proce-dures had not been sufficiently completed to allow full.as- ! sessment of the EP program. Since that time and with the. con-duct of'the exercise, in which Region I management also parti- 4 cipated, the licensee had made sufficient progress, such that the appraisal was completed in March, 1986. All but a few of-the EP open inspection items have been closed by subsequent Region I review. The remaining open items must be completed prior to the issuance of a full power license, but are not required for the low power license. , The exercise on February 26, 1986 involved the utility and the state of New Hampshire. No major onsite deficiencies in the implementation of an adequate emergency response were identi- ! fied during the exercise. In general, personnel . involved in the exercise demonstrated a high level of training and knowl- l' edge 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 deficiencies were identified by FEMA with offsite response by New Hampshire. These areas will be re-assessed in a' subsequent exercise prior to consideration of i full power license.
As documented in Supplement 4 to the Seabrook SER, prior to authorizing operation above 5% of rated power, the staff must l provide an overall conclusion on offsite EP, in addition to l onsite preparedness.. For this determination, the findings made by FEMA on state and local emergency response plans must.be l considered. However, Region I concurs with the overall staff l position that the emergency plan is adequate and can be ade-quately implemented for operation up to 5% power. 5.2.4. Radiological Controls and' Fuel Receipt Region-based inspections have evaluated the licensee's chemis-try, environmental monitoring, health physics, radiation' moni-toring and radioactive waste management programs and facilities.: Although not all. testing of solid radwaste and HVAC. systems is complete, completion of this work is not expected to impact fuel load or the commencement of low power testing. In general, the Region.I inspections of the above. areas af-fecting radiological controls have revealed'that adequate management control systems have been established. The inspec-tion items, opened to date, are being followed-up as appropriate
2- s m y 19 ! I i f-to the operational milestone affected by their completion.
' Systems necessary for the safe conduct of fuel load activities a will be complete prior to Mode 6 in line with licensee commit- !
ments. New fuel was received onsite during the period of February to May., 1986. Region I inspections routinely checked licensee fuel receipt'and storage. activities during that period ir M ne I with the Special. Nuclear Materials License (SNM-1963) and with- 'l regard to radiological controls, DOT regulations, and.the ade-quacy of operational, procedures and operator training for fuel movement. Overall licensee controls in this area were demon-strated to'be effective. 5.2.5 Security Facilities and' Programs The staff has reviewed'.the Seabrook. Physical Security. Plan and-regional-based security inspectors have conducted'several site , ll inspections, including two after the security' plan was imple- ! mented for Unit 1 in May, 1986. . Major portions;of the plan 1 were implemented then to allow the station personnel, particu-larly the security staff, to; exercise the program' prior to plant operations. The resident inspectors have a_1so_ verified . g on a sampling basis,--implementation of.the plan with respect-l to new fuel receipt, movement and storage. 'No major problems L were identified during the security inspections- . The licensee has retained the services of an experienced con- l tract security force (Green Mountain Security Services, Inc.).
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This contractor is also employed at Yankee Rowe and Vermont Yankee. A NHY security supervisor is provi'ded on each shift. ~i Station administrative procedures pertaining to plant security .l and specific implementation procedures _have been approved and ' issued and were reviewed by regional inspection personnel. Protected area controls, to-include the erection of. barriers with respect to Unit 2 access points into Unit I, have been .i implemented and were verified during Region I _ inspections. , The NRR/NMSS 10 CFR 73.55 confirmatory security site. visit was . conducted in February, 1986. The licensee has. implemented i actions to address open items resulting from that visit, as , well as those resulting from Region I. security inspections. i No open items in the area of security controls or their.. imple--
- mentation currently exist to preclude issuance of low power ,
license to PSNH.
-l 5.2.6 Fire' Protection Facilities and Programs In January, 1986 an audit team of Region I, NRR and contractor personnel conducted an inspection onsite at Seabrook Unit 1 of the licensee's~ efforts to comply with the requirements of 1
L
20 a 10 CFR 50, Appendix R, concerning fire protection features to_ 'l ensure the ability to achieve and maintain safe shutdown in the event of a fire. Only two unresolved . items resulted from this_ audit, both of which were noted to be exemption requests by the licensee to the Office of NRR. These two items have been since closed with NRR concurrence. As discussed.in a memorandum from W. F. Kane, Director, DRP/RI, to T. M. Novak, Director, PAD 0/NRR,_ dated August 27, 1986, certain fire protection construction activities (e.g., fire doors, sealant, conduit wrap, cable tray' cover installation, and-fire damper. testing) had not been completed at Seabrook i Unit 1. Except for fire doors, this work has been completed. ] While work on fire doors is progressing, it_is not anticipate'd I that this item will necessarily be finished at.the time of license issuance. The licensee has indicated their intention to station fire watches to compensate for uncompleted activi-ties. We understand that NRR is considering removing fire pro-l tection requirements from the improved technical specifications. l Therefore, as stated in the' August 27, 1986 memorandum, Region I recommends that Section 2.F (formerly 2.C.4) of the draft license be evaluated to determine the completeness and enforce-- ability of all fire protection requirements. . ! 5.2.7- Technical Specifications The " proof and review" copy of the Seabrook Technical ~Specifi-cations was issued for comment in March, 1986. A general re-view of these TS, in conjunction with licensee suggestions for TS improvements, was conducted by Region I with camments sub- ; mitted to NRR on May 29, 1986. 'AsLis discussed in section ~j 3.1.2g of this report, a TS team inspection, utilizing con- l tractor personnel under the direction of Region I personnel, was conducted in May,1986 to determine whether the TS are compatible with the FSAR and as-built plant. The results of that inspection indicate that adequate licensee controls exist tt assure that final plant implementing procedures will reflect final TS requirements. 5.2.8 Third Party Audits and Evaluations During the weeks of January 20 and 27, 1986,'INPD conducted an assistance visit to Seabrook Station to review site activi-ties and assist in the Unit 1 preparation for operation. Areas-reviewed included' station organization and administration, operations, maintenance, technical support, training and quali-- fication, radiological protection, chemistry, emergency pre-paredness, and operating experience reviews. A follow-up cor-porate assistance visit to New Hampshire Yankee was conducted i at the NHY corporate offices onsite the week of February 10, a
21
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t 1986. At an exit meeting on February 14, 1986, specific re-commendations, resulting from these INPO assistance visits, were presented to NHY management. 1 While Region I has not followed-up the INPO recommendations, j the licensee has indicated to Region I that they have evaluated q and addressed each one. 1 5.3 Startup Test Program The licensee's Startup Test (ST) Program was first developed with the initiation of the preoperational testing program (Phase 1-3) and con-tinues with the ST Phases 4-6, which encompasses initial fuel loading, initial criticality and low power tests. and power ascension. All 50 Startup Test (ST) Procedures scoped by 9.he Start 0p Test ALstracts in Chapter 14 of the Seabrook Ststion FSAR have been prepared, approved by l the Station Operations Revie~w Committee, and issued. An additional six ; ST's, written to govern further testing to close certain preoperational test program exceptions during post-fuel load hot functional testing are-in varying . levels of development and approval. Region I has conducted initial inspections of the Startup Test Program and has found the overall program status, procedures, organization and staffing to be adequate. Controls appear to be in place for initial fuel loading (Phase 4) and initial criticality and low power testing'(Phase
- 5) to support licensee activities under the low power license. -j 6.0 Enforcement History )
The NRC inspection program uses enforcement measures to promote adherence to regulatory requirements, reduce repeated nonconformances, and encourage self-identification and correction of nonconformances. NRC enforcement measures,< that is, Notices of Violations, have been issued when necessary. The appli- I cant has been required to respond to these Notices of Violation and provide ' the proposed actions to correct the nonconforming conditions and to take ac-tions to prevent recurrence of similar violations. NRC inspectors and management have reviewed and evaluated these responses for acceptability. The inspection staff confirms, during subsequent inspections. ; that corrective actions are properly completed. .The following table gives a comparison of Seabrook Unit I enforcement statistics with those of two other -- plants at a similar point in construction. Early enforcement actions were classified as " violations", " infractions", and " deficiencies" (in descending ! order of severity) while the more recent reports contain violations categor-i2ed into severity levels ranging from 1 to VI (again, in descending order).
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e e
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1 I i Below is an enforcement comparison through 90% construction completion: 1 FACILITY CPFR VIOL INF DEF I II III IV V VI -TOTAL INSP HRS l Seabrook 1 7/7/76 0 24 9 0 0 0- 44 23 0 100 15,600 Hope Creek 11/4/74 0 19 5 0 0 0 19- 13 2 58 7,600 l Millstone 3 8/9/74 0 2 2 0 0 0 24 25 1 54 9,100 In evaluating the NRC inspection enforcement history for Seabrook Unit 1, the total of 100 enforcement items is substantially higher than Hope Creek and Millstone 3. However, Seabrook Unit I had 15,600 inspection hours at 90% com-plete compared to less than half of that for Hope Creek. Thus, if comparison were done on the basis of enforcement actions per inspection hours, all three l plants would be in the same range of ratios with Seabrook I in the middle. I From the standpoint of overall enforcement history, Seabrook I is considered i an average plant in Region I. !
)
What is more significant is the licensee's overall corrective action effec-tiveness in adcressing problems in the areas of QA, design change control, piping and pipe supports and electrical installation, as discussed in Section 3.1.1 of this report. Particularly in the piping area, where an Immediate Action Letter was issued to confirm a licensee stop work order for contractor pipe repairs, the licensee has demonstrated adequate corrective. measure im-plementation. This coupled with the determination tha,t numerous NRC inspec-tions have identified relatively few hardware problems, is indicative of an : overall high quality construction effort at Seabrook Unit 1. l 7.0 Systematic Assessment of Licensee Performance (SAlp) l 7.1 Overview and Status 1 Since the initiation of the SALP process by the NRC, licensee performance at Seabrook Unit I has been assessed seven times. Each assessment is ) summarized below:
]
- 7. 2 First SALP I Assessment Period: January 1 - December 31, 1980; SALP Board Date: Febru-ary 13, 1981; Licensee Meeting Date: March 12, 1984 i
Of the thirteen areas assessed, performance in the area of liner erection was found to be above average with nine other construction areas assessed
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average ratings and the areas of QA, safety-related structures and piping
& hangers rated below average. Of most significance in this first SALP were the identification of numerous QA problems related to the diverse nature of the numerous contractor programs and particularly with respect to the subpar performance of the piping and pipe support contractor. ,
Licensee corrective measures to improve the QA program were effective ; primarily because of the implementation of tighter YAEC controls. How- , ever, as discussed in later SALPs, the piping contractor problems were i
- not fully resolved.
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- 7. 3 Second SALP Assessment Period: July 1,1980 - June 30, 1981; SALP Board Date: Septem-ber 28,1981; Licensee Meeting Date: October 15, 1981 i Eleven construction areas were assessed with all but the foundations and training areas. (Category 1) and the design and design change area (Cate-gory 3) receiving Category 2 ratings. Significant improvement was noted in the QA areas from the previous SALP and apparent improvement was also noted in the piping area. The major problem in this SALP was found in the ares of design controls, where interfaces between the A/E and dif-l
' ferent contractors were not being sufficiently monitored to properly translate all design criteria into specific contractor procedural re-quirements. The licensee initiated corrective action in this area to have YAEC engineering personnel become more involved in the engineering and design change evaluations. 7.4 Third SALP Assessment Period: August 1, 1981 - July 31, 1982; SALP Board Date: Sep-tember 13, 1982; Licensee Meeting Date: September. 29, 1982 , A Category I evaluation was assessed in three construction areas - foun-i dations, support systems and I&C systems. All six other construction f areas, except piping, was assessed a Category 2 rating. In the area of t piping systems & supports assessed as Category 3, the piping contractor (Pullman-Higgins) was found to be openly utilizing construction practices in conflict with UE&C specifications. This indicated a direct interface prchlem between UE&C and Pullman-Higgins for which the licensee initiated an audit of all contractor procedures. Organizational changes in the Pullman-Higgins site management organization were effected, Pullman cor-porate QA auditors were assigned to the site, and YAEC second and third level QA activities were increased. At this point, program effectiveness in this area was of concern to the NRC; however, major problems with hardware were not identified. 7.5 Fourth SALP Assessment Period: July 1, 1982 - June 30, 1983; SALP Board Date: August 8, 1983; Licensee Meeting Date: August 22, 1983 In this SALP, the three areas evaluated as Category 1 during the last assessment were again rated Category 1, with the additional area of con-tainment & safety-related structures also rated in-this highest category. Four additional construction areas were rated Category 2, with the piping area again rated Category 3. During this SALP period, the licensee had merged the piping activities under a joint UE&C/ Pullman-Higgins organi-zation and " learning curve" problems *under the resultant system of con-trols were experienced. Additionally,.a Region I-Construction Assessment
- m. Team inspection had identified significant program weaknesses in this l
1 l
24 area and the INPO sponsored Self-Initiated Construct Project Evaluation. noted the piping contractor's activities as the most significant area I of weakness. 1 The licensee formed a Supervisory Support Group dedicated to continuously monitor and evaluate the performance of the piping contractor. Also, the licensee issued stop work orders in specific work areas involving design change implementation by the piping contractor and containment piping penetration installation. To check the effectiveness of these ; generic, and other specific, corrective measures, the NRC SALP Board 1 directed that another SALP Board be convened in six months to further i evaluate the performance in the piping area. 7.6~ Fifth SALP l 1 Assessment Period: July 2 - December 31, 1983; SALP Board Date: February l 14, 1984; Licensee Meeting Date: March 9, 1984 j 1 A special SALP Board was convened to assess licensee performance in the { piping and pipe supports area alone over the previous six-month period, j because of continuing problems identified in that area. While a Category -] 3 rating was again assessed, improvements were noted over the course of j the six-month assessment period. Construction quality was ,better; better ' engineering and erection controls were in evidence; and NRC identified, hardware problems were minimal. In fact, some of the problems contri-buting to the Category 3 rating, resulted from the licensee's self-iden-tification of the concerns due to a more rigorous surveillance and audit i program. Thus, while improvement was noted, additional licensee manage-I ment attention was solicited to continue the improved trend. Also, an increased level of NRC activity was recommended to measure the total ef-festiveness of the licensee's corrective action in the piping and pipe supports area. 7.7 Sixth SALP Assessment Period: July 1, 1983 - December 31, 1984; SALP Board Date: February 19, 1985; Licensee Meeting Date: March 21, 1985 1 l Seven construction areas were evaluated during this-SALP, in addition I l to assessments of Preoperational testing, operator licensing and plant I licensing. Category I ratings were given in the areas of containment )
& safety-related structures, auxiliary systems, ' quality programs & man-agement controls, preoperational testing and operator licensing. Three ]
! other construction areas and plant licensing were assessed as Category i 2, while the electrical equipment & cables area was rated as a Category
- 3. In the piping systems & supports area (Category 2), licensee correc-tive measures implemented since the last SALP were evaluated and found 1 to have produced positive results. Particularly after the reporting line ;
from the piping contractor site QA manager was restructured more directly to the site Construction QA Manager and after New Hampshire Yankee was i l
25 - f formed and became more involved in piping activities did the trend indi-cate marked improvement of construction controls in this area. Upper , management appeared both attentive and responsive to past NRC concerns : in this area and had taken the appropriate corrective measures, which ' were effective. In the area of electrical equipment & cables, the Category 3 rating re-flected increased construction activity in this area along with apparent , communications problems between the' construction manager and the elec- ! trical contractor. It was noted that most of the identified problem in this area surfaced early in the assessment period, prior to the estab- l l lishment of the NHY organization. Management plans for corrective meas-l ure implementation and the needed retrofit activities on hardware rework were already formulated and in progress. Increased NRC inspection re-sources was directed to confirm the effectiveness of the licensee actions. i
- 7. 8 Seventh SALP ~
i Assessment Period: January 1, 1985 - March 31, 1986; SALP Board Date: J May 14,1986; Licensee Meeting Date: June 10, 1986 l During this SALP, all the separate construction activities were evaluated ! in one area, while the other assessed areas included preoperational testing, fire protection and housekeeping, operational readiness, emer-gency preparedness, the assurance of quality and licensing. All areas were rated Category 1 except emergency preparedness which was assessed as Category 2. This evaluation reflected not only continued improvement ] in the piping area, but effective corrective actions in the electrical area. Overall preoperational testing results were outstanding and the l operational readiness area provided an indicator of licensee potential for continued performance at a high level during the operational phase. 1 8.0 Allegations 8.1 Overview and S".atus Over the course of construction and testing activities for Seabrook Unit , 1, a total of 47-allegations were raised. Four allegations currently remain open,'sith two of these involved'with the electrical records and ; QC controls t.nd the third relating to painting of the polar crane inside ~ containment. A fourth allegation, opened on September 22, 1986, involves a series of concerns raised by the Employees Legal Project of Amesbury,- Massachusetts. These concerns were included in a letter from the Legal Project to Governor Dukakis requesting that he investigate these issues. Many of the issues are general in nature, with several a repetition of previous allegations or events already resolved by the licensee and/or !- the NRC. Initial review of the open allegations has revealed no apparent impact upon the quality of plant hardware. 6 . e C________.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _- __ _ - - -
+ .
4 - 2s- .
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8.2 Facility A11ecation Resolution and Summary NRC inspection'and investigation of the allegations that are closed re-
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vealed no significant hardware impact for the-cases that were substanti-ated. Followup of two allegations did result in the' issuance'of severity level IV and V violations respectively, but this enforcement action re-lated to findings of improper process control and inadequate corrective action, rather than confirmation of any acts of willful wrongdoing. -) The follow-up of two additional allegations are noteworthy in the amount of inspection effort expended not only by the NRC, but also by the lic- j ensee in support of the investigation and in implementation of. corrective j action, as required. The first item, also reported by the licensee as l a construction deficiency under 10 CFR 50.55(e) in 1983, involved the falsification of NDE records at Seabrook. Upon confirmation of the sus- , pect nature of certain NDE, examination performed by one technician, all 2,399 suspect items, both safety-related and nonsafety, were' evaluated i by the licensee. Over 1,300 NDE re-examinations were conducted. Inde-pendently, the NRC followed-up the licensee corrective action.and' con-ducted two separate NDE Independent Measurement inspections, utilizing the Region I Mobile Nondestructive Examination Laboratory, on samples of the suspect. welds. . Additionally, the'NRC Office of Investigations conducted an investigation into this allegation with the conclusion that NDE record falsification was substantiated, but that this falsification was an individual, isolated incident.of wrongdoing by the subject tech- , nician. ' The other. noteworthy allegation involved a diverse set of multiple alle- l gati'ns o anonymously communicated to Commissioner J. Asselstine. In order 1 to follow-up.the stated concerns, a special, unannounced inspection by 1 a region-based team of inspectors, and led by a Region I Branch Chief, i was conducted over a two-week period in 1984. .This inspection involved l 349 hours on site and identified no violations related to the allegation. ) In two specific areas the allegation was substantiated, but Region I 1 inspection found that corrective action by the licensee had already been implemented. ' In summary, extensive inspection and investigative effort on both of the ! above allegations, while substantiating certain of the stated concerns, also confirmed comprehensive and complete corrective measures on the part of the licensee. 1' 8.3 Licensee Employee Alleoation Resolution ProcramL In February, 1985, 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 inter-face with the EAR program has provided both an. independent verification of programmatic actions. taken by the licensee to address quality concerns, l
.m __._._ _ _ _ . . _ __.__.______ -______
]u 27 i i
and an effective means of_ utilizing the licensee inspection resources 1 without compromising the conduct or results of the 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 I inspection corroborating both the EAR investigation results, and the.im-plementation of corrective measures to avoid similar problematic situ-ations in the future. 9.0 10 CFP 50.57(c) Motion g The licensee filed a motion pursuant to 10 CFR 50.57(c) before the ASLB on August 22, 1986, seeking authorization to load fuel and conduct precriticality testing with respect to Seabrook Station, Unit 1. 'In this motion the licensee l indicated that special procedures would be in place to assure that the boron concentration does not go below 2000 ppm. Such procedures would consist of periodic. sampling of the water in the reactor and makeup supply, sampling of i the contents of makeup water to verify the concentration whenever water is )' added, and locking all valves which when opened could permit the entry of non-borated water into the reactor coolant system. In a meeting with NRR on September 3, 1986 regarding this 50.57(c) request, J Region I representatives discussed the need for licensee'conditjons'to be im- 3 posed. It was agreed that the verification of licensee implementation of their procedural controls to assure proper boron concentration'in accordance q with the license conditions would be a Region I inspection function. .. In preparation for the required implementation inspections, the Region I resident inspectors initiated a review of the existing licensee special pro-cedures and drawings, marked up with a listing of the designated " locked valves." This initial review identified certain areas-where the adequacy of ! the proposed licensee controls was questioned. It was noted that additional ' ; potential flow paths for diluted water would have to be analyzed, the Techni- l cal Specification conditions less limiting than the. license conditions would ] have to be addressed, and that additional administrative controls on the. identified " locked valves" which could be opened during test conduct would have to be formulated. One concern common to these questions of procedural ! adequacy was the lack of understanding and delineation of~the criteria used l by the licensee in evaluating potential flow paths, locked valves, and affected l routine procedural or test operations. i At a meeting between the licensee and the NRC staff on September 11, 1986, ; these questions and concerns were discussed and the licensee committed to conduct. additional reviews of the affected systems, operations and procedures to predefine criteria, judged to adequately assure maintenance of the RCS L boron concentration above 2000 ppm. 1These' criteria, along with a modified unborated water source " locked valve" list: and any other pertinent conditions, would then be transmitted by-New Hampshire Yankee memorandum to the NRC Office i of NRR. . l 1-
,6 I
At the conclusion of the licensee review, a telephone conference was held on j September 16, 1986 in which the licensee review criteria and results were pre- J sented to NRR. Subsequent discussions.by the resident inspectors with the ; licensee have confirmed that eight valves have been added to the " locked valve" i list (note: one valve was also removed because of unnecessary redundancy). , The. resident inspectors also discussed with the licensee the evaluation cri- ' teria, the frequency of the required surveillance, and impact on existing procedures and those which must still be revised, and the need for further administrative controls of conditions where the Technical Specifications are , not conservative with respect to the 50.57(c) license conditions. Further discussions between Region I and the licensee, based upon continuing inspection by the resident inspectors, are in progress. As of September 19, 1 1986, a sample inspection of the system drawings used by the licensee in their l review, accomplished to criteria presented by the licensee to the Office of ! NRR, revealed no deficiencies or errors. Since special procedure issuance l and/or revision has not been completed, the adequacy of such procedures will be the subject of continuing resident inspection. However, the resident in-spectors have discussed with the licensee a description of the process by which all affected procedures will be controlled. No programmatic problems have been identified in this process. Based upon the foregoing and the inspection process to date, Region I has reasonable assurance that the licensee has provided adequate controls, given I the assumptions and criteria presented to NRR, to preclude. boron dilution be-I low 2000 ppm. Given the proper implementation of these controls,'the timing of surveillance activities, and the margin of conservatism between the criti-c61 boron concentration and the one required by the 50.57(c) license condi-tions, Region I believes that adequate assurances are or will be in place to preclude inadvertent criticality. Inspections of the special affected procedures, as they are revised and become available, will continue in line with the routine regional and resident in-spection programs. Special inspections of those licensee controls intended to meet the proposed 50.57(c) license conditions will be conducted on a sample basis once the license is issued and operational activities conducted under this license commence. l 10.0 Future Recion I Actions Region I resident and specialist inspections will continue throughout the startup test program. Results evaluation will be closely monitored. In the event a license is issued pursuant to the provisions of 10 CFR 50.57(c), certain specific actions are anticipated. The licensee will implement special l procedures to insure boron concentration remains greater than 2000 ppm to en-l sure subcriticality is maintained. Region I residents, and specialists if needed, will evaluate implementation of these special procedures by: reviewing the status of locked and procedurally control valves, observing periodic samp-ling for boron concentration, and evaluating any other actions which have the potential to impact on altering boron concentration. l . l
29 l A Readiness Assessment Team inspection is currently planned for near the end of the Power Ascension . Test Program and prior to commercial _ operation. Such an assessment will be particularly significant because of the projected delay in issuance of a Full Power License. If such a delay should occur, resident and specialist inspections will continue to monitor licensed activities and j the Readiness Assessment will verify that the Seabrook management,. program, i hardware and personnel are not adversely impacted by any periods of relative inactivity. I 11.0 Justification for Interim Ooeration Generally, the licensee has prepared for submission to both Region I~and NRR a list of incomplete construction and testing work, which could be categorized as items requiring justification for interim operation (i.e. , "JIOs"). On l this list, the scheduled completion milestone is delineated and is generally l associated with a certain mode of operation, in which the affected equipment is required to be operable. Region I has evaluated the licensee review pro-cess which generated this JIO list and which links modal milestones to the incomplete work activities. While the basic concept as implemented by the licensee appears sound, any differences regarding which specific work must be completed prior to operating in a given mode will be resolved between Region I and the licensee on a case basis. With respect to licensing activi- l ties, it is assumed that the submission cf the JIO list by the ljcensee to ' NRR will satisfy the licensing need to determine which construction and test-ing activities are not fully completed and the licensee's justification where required. 12.0 Summary and Conclusions The NRC has expended over 20,000 inspection-hours, to date, at Seabrook Unit I to determine if the plant has been built in accordance with FSAR commitments and regulatory requirements and whether management direction was focused on quality. Over the course of the ten years of construction, the licensee has demonstrated not only a commitment to quality, but a real responsiveness to NRC concerns as they were identified. YAEC, as the agent for the licensee, has been a very strong and steadying force on the project during this time, particularly in the area of QA program implementation. The establishment of the New Hampshire Yankee organization has reinforced the quality goals and provided a management structure which has retained re-sponsibility and accountability for getting work completed correctly the first time it's done. NRC team inspections over the last year in the areas of NDE independent veri-fication, an as-built check of the plant, and a Technical Specification review confirmed that Unit I is a well-built plant, in accord with the design speci-l fications. The overall theme of the most recent SALP is construction quality, with few identified hardware problems, and preoperational test results which verify these findings. .
~.
O
30 - Wnere problems were identified by Region I, early in construction in the case of both QA and Design Change Control, corrective action by the licensee was i
. effectively implemented, both with a strong measure of YAEC involvement.
While-the piping problems were of a continued Concern for a 10nger period of time, the impact of such problems on installed hardware was closely monitored , ar.d licensee management changes were able to reverse the negative performance ] trend. In not- only the piping area, but also the electrical area where prob- ;
-lems were later identified, New Hampshire Yankee and its organizational ap- 1 proach to the issues from a generic standpoint demonstrated both a commitment
~
i to' address NRC concerns and a capability to complete the construction of a ' quality nuclear plant. Region I concludes that Seabrook Station, Unit I, has been constructed sub-stantially in accordance with Construction Permit CPPR-135, the Seabrook Sta- l tion FSAR and NRC requirements. Certain construction and testing activities ' are still in progress and therefore Region I has recommended the appropriate license conditions. Considering the recommended license conditions, the overall Region I conclusion is that the licensee has taken all necessary ac-tions to permit issuance of a low power license. *
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1 l i j I i 5
----__.m_____-__- _ _ _ _ _ _ _ _ _ _ _ _
4 4 ENCLOSURE 1 SPECIAL ASSESSMENT OF THE QUALITY OF i
)
i CONSTRUCTION OE SEABROOK STATION UNIT 1 l 1 (Note: The data in this enclosure has been compiled by the licensee's QA staff. The writeup and information provided is essentially a licensee analysis and as-sessment. No effort was made by Region I to verify the data or information.) I The quality of Construction of Seabrook Station Unit I is predicated upon the fol- ) lowing:
- 1. Public Service Company of New Hampshire (PSNH) thru its New Hampshire Yankee Division and delegation to Yankee Atomic Electric Company (YAEC) Huclear Ser-vices Division has and continues to employ a group of management, engineering,.
operations and support personnel Who have valuable knowledge and experience in the design, construction, and operation of nuclear power plants. The ex- , pertise and experience gained by these personnel have been utilized to the I maximum extent in the design and construction of Seabrook Station. PSNH ; delegated to YAEC the responsibility for the development, execution, and ad- ] ministration of the Quality Assurance Program. The QA . Program has been very effective throughout all phases of design, procurement, construction, startup, and preoperational testing.
- 2. Seabrook Station has received relatively few allegations which is indicative j of a positive attitude toward quality. Management involvement and support of quality as well as an effective QA program contribute to this attitude. !
NRC investigations into concerns have not required actions beyond those taken l by the licensee in the normal course of business.
- 3. Region I headquarters personnel have expended considerable manhours of in-spection, evaluation, and independent verification time at the Seabrook Sta-tion. Inspections have been indepth, extensive in scope, have included special inspections, mobile laboratory involvement, and many other techniques.
The number of NRC inspections is summarized in Enclosure 3.
- 4. Special inspections / evaluations conducted at Seabrook Station are:
- a. Regional Construction Assessment Team Safety Inspection (CAT); June 21 - July 2,1982.
No major areas of noncompliance or program weaknesses in design or construction.
- b. Integrated Design Inspection . November 1 . December 21, 1983.
Overall design appeared to be adequately controlled. l n O
Enclosure 1 2-i
- c. 1 NRC Construction Appraisal Team Inspection (CAT); April 23 - May 4, May 14-25, 1984.
Minor technical deficiencies and program weaknesses resolvable with increased management communication'and attention.
- d. Construction Team Inspection; June 3-14, 1985.
Three noncompliance, three program strengths, three weaknesses.
- e. Independent Measurements Inspection; July 15-26, 1985 (NRC Mobile Non-Destructive Examination (NDE) Laboratory.
Verification of the adequacy of welding,.non-destructive examination < and material analysis quality control program - no violations noted. I
- f. As-Built Team Inspection; March 10-21, 1986.
Plant construction found to be in accordance with design and FSAR commitments, team commented additionally on the high quality of the installation work. Seabrook Station did not receive any violations' classified as Severity Level III or above and no civil penalties were assessed.
- 5. The Quality Assurance / Quality Control organization for the Seabrook Station has exercised effective systems of control and assured quality of work at the site location and corporate offices. Inspections performed by the NRC, the Applicant's Quality Organization or other agencies have not identified condi-tions which have required total reinspection or reverification programs.
Seabrook Station's Construction Quality Assurance Program is predicated on j the philosophy of prevention, planning, early detections, organizational co- ! operation, and team work. Senior management support of QA has always been I a project strong point. The effective control of quality.has been demon-strated by the Seabrook Construction Quality Assurance Organization's approval authority for all safety related QA/QC and work procedures. These QA reviews and approvals contributed-to programmatic controls and practices which assure that work is performed correctly the first time.. The Construction QA organi- I zation at Seabrook has identified problems early in the fabrication and in-sta11ation processes and has achieved timely and positive corrective action.
- 6. The Seabrook Station Quality Assurance Program is reviewed by YAEC QAD at least annually to assure that it is kept current. YAEC performs audits on WRD and UE&C to assure that their programs are kept up to date and effective.
The YAEC program for quality assurance normally involves three control levels: Level 1 - Quality Control by vendors, constructors,:and UE&C on.the. activities they perform, by YAEC on startup activities. This includes reviews, inspec-tions, and tests. 8 -5 I ____m_ _ _ _ .__.__._.. _ . _ _ _ __ .__ . _ _ . _ _ - .
Enclosure 1 3 4 Level 2 - Surveillance of design, fabrication, and construction activities, including Level 1 Quality Control. Contractors provide this level for the design and procurement phases. UE&C and YNSD provide additional surveillance on site construction activities. Level 3 - Audits by YAEC QA Department of activities performed by Level 1 and 2 organizations.
- 7. The Construction QA Program at Seabrook is also subject to review and verifi-cation of independent organizations,
- a. The American Society of Mechanical Engineers (ASME)
- b. National Board of Boiler and Pressure Vessel Inspectors
- c. Lumbermens Mutual Casualty Company
- d. Institute of Nuclear Power Operation (INPO)
- e. Public Service Company of New Hampshire Management Audits
- 1. American Nuclear Insurers
- 8. The Construction QA organization at Seabrook has the authority to stop work independent of the construction and engineering organizations. This stop work authority was invoked 33 times during the course of construction. The fol-lowing summarizes stop work actions initiated by the Seabrook Construction QA organization.
Year Description Remarks 1986 None. ' 1985 Hanger installations performed to Hanger drawings withdrawn and drawings without required Engi- submitted for required approval. l neering approval. 1984 Safety related and associated All safety related and associated cables pulled in trays containing cable pulling sinpped. Cable debris. trays cleaned of debris and in- = stalled cables reinspected. Site- ! l wide directives issued on tray cleanliness. 1984 Work proceded on an item without Work stopped until NCR disposi-an approved disposition to an NCR. tioned and approved. ! l
Enclosure 1 4 Year Description Remarks 1984 Adequate interface lacking be- Cable pulling stopped. Trays tween UE&C and site contractors cleaned and debris removed. All
~
for. maintaining tray cleanliness. contractors were reminded of their responsibility for cleaning up their materials.
. 1984 Required procedures not issued and QA' procedures issued for safety QA staff not adequate. related activities. Staff in-creased to provide adequate QA coverage.
1983 Hilti bolt installations not per All work on Hilti bolts stopped.,- procedure. and involved personnel reindoc-trinated. 1983 Installation / fabrication packages I/F packages placed on hold until for metal bellows flex hose lack- insertion of appropriate criteria ing criteria. in the packages, i 1983 Plastice mixing operations for Engineering evaluation of plastice safety related areas not properly mixing indicated that the opera-controlled. tion was not safety related. 1983 Material storage areas and mate- Movement i'n and out of storage rial status indicators, areas restricted. A SWO was issued allowing only withdrawal ) of properly identified material from storage. SWO was closed based on QA evaluation of storage areas. 1983 Wrong welding procedure specifi- Specific lists of piping ISO's cation referenced on certain pip- required review and correction l ing ISO's. to the proper weld procedure j specification. 1983 Installation of non-safety related Procedure revised to require QC associated cables in nuclear inspections of associated cables. island not QC inspected. 1983 Sodium hydroxide, PVC solvent Use of sodium hydroxide, PVC
-- cement, and epoxy white enamel solvent cement, and epoxy white with expired shelf life. enamel stopped. Inventory of all items with shelf- life expira- l tion dates required to be per-formed on monthly basis by QC.
._-_-_____a
. . Enclosure 1 5 Year Description Remarks 1983 Non safety detail use for safety Engineering approved detail for related installations, safety related installations.
Training conducted for Engineer-ing, Construction Supervision, and Quality Control Personnel. 1983 QC inspection deficiencies of low QC inspector retrained. All af-I chloride fireproofing. fected application areas placed on hold. ' 1983 Affected documents not listed on Site engineering personnel re-On-The-Spot ECAs. trained. An evaluation of pre-viously issued OTS ECAs performed to evaluate affected documents. 1983 Listing of ECAs on controlled stop work on all safety related drawings not per procedure. (piping and supports) work. Ex-isting drawings updated. Indoc- { trinated and trained personnel to procedural requirements. 1982 Reinspection and retrofit program Revised procedures"to include proceeding without approved pro- scope of work and provide in-cedures and inspection documenta- spection forms. tion forms. 1982 Implementation program failed to Procedures revised to address address limited access welding. site position on limited access welding 1982 Anchor bolt installation without i coreboring procedure. Procedure revised to include ' coreboring criteria and inspec-tions. 1981 Welding electrode portable ovens Welding procedures updated and not plugged in. welding personnel retrained.
}
1981 Plug welding of frames without Containment interior plug repairs use of Weld Data Cards, weld mapped. Field welds as*- built. Weld data cards made up. for new welds. 1981 T5 bolt tensioning / installation. Construction personnel retrained in bolting procedures. 1981 Cadweld tensile test results below Cadweld operator's records re-minimum. viewed and additional testing performed. { i I I I 1 E___________._.__ _ _ _ _ _ _ . _ _ _ _ . _ ._ ___ _ _ _ _ _ _ _ _ _ . _ _ _j
. . Enclosure 1 6
-l J
Year Description Remarks
]
4 1981 Safety related installation of 'ECA issued to more s'trictly con- 1 Hilti-Kwik bolts. trol installation and provide { margins of safety in torque ] values. Contractors to retorque j all installed Hilti-Kwik bolts. 1 1981 Tray splice bolts not certified. Bolt certification for NI and
.MP 5 bolts received from supplier and found acceptable.
1981 Project specification require- Procedure revised to include ments not incorporated into pro-requirements of Project speci- ' cedure for weld material control. fication. 1981 Weld repair cycles not' controlled Procedures revised to include in accordance with Project speci- requirements of. Project speci-fication. fication. 1980 Tightening of high strength bolts. All structural iron workers were retrained in bolting procedures. 1980 Weld joints for attachment of Engineering revised detail to support channels to anchor bolts provide backing plate to conform not in conformance with prequali- with prequalified joint detail. field weld joint detail. 1980 Cadweld splices accepted with Affected cadweld splices visually packing material remaining. reinspected. Additional splices removed and tested. 1980 P-H repair welding of ASME Sec- Welding procedure revised. Weld-tion III and safety related work. ing personnel retrained. 1979 Mechanical equipment erection Procedures developed'and approved 1 without approved procedures. to include these activities. 1978 Rebar installation continued in Work stopped until affected NCRs area that was on hold. were closed. Construction com-mitted to' follow QA program. 4 1977 None. 1976 None. 1975 None. 1974 None. , 4 l e __ _ _ _ - _ _ _ _-
Enclosure 1 7
- 9. The YAEC Construction Quality Assurance organization has conducted audits of th'e design and procurement activities performed by Westinghouse (NSSS) and United Engineers and Constructc,rs (AE) as well as audits of YAEC's design, procurement, and review activities. Technical specialists from.various dis-ciplines were assigned to the audit teams, where warranted, to assure techni-cal aspects of the audit process were reviewed in depth. A summary of the' results of these audits is as follows:
UE&C H.O. 'No. of Audits No. of items 1973 2 5 1974 15 67 1975 10 29 1976 6 41 1977 2 17 1978 2 24 1979 2 14 1980 3 74 1981 5 33 1982 5 23 1983 4 39 1984 4 37 1985 5 31'
~
1986 5 5
, TOTALS 70 439 Westinghouse No. of Audits No. of-Items 1973 2 1 l 1974 6 38 l 1975 4 24 l 1976 9 25 1977 6 8 1978 5 11 1979 10 11 1980 .15 11 1981 8 3 1982 2 0 1983 5 10 1984 5 2 l 1985 3 6 I 1986 1 2 TOTALS 81 152-4 I
.___.___.m_________________-___m___ m.___.
.. . ., Enclosure 1. 8 :
l
)
i Internal No. of~ Audits- ~No. of' Items ! 1974 - 10 31
'1975 8 1 1976 10 8
'1977 15 -
24 1978 15 22 , 1979 15 24 ; 1980 12 21 1981 15 41 1982 13 34' .J 1983 13 61. 1 1984 14 .32 1985 8 28 ; 1986 4 -28 l TOTALS 152 355
- 10. The VAEC Construction QA organization has an onsite staff of Quality Assurance I Engineers which conducted routine onsite audits and surveillance of construc-tion and engineering activities. A summary of the results.. of these audits and surveillance is as follows:
Year .No. of-Surveillance No.~- of Items 1976 6 29 1977 36 52 1978 102 16 1979 183 87 1980 326 86 1981 831 361 1 1982 2210 1066 I , 1983 2543 1452 1984 1486 '881 : 1985 2726 628 1986 1229 248 TOTALS 11,678 4906 .i l i l~ l l
. - Enclosure-1 9 t
Year -
- o. of Audits ~ No. of Items 1973 -4: .
O. 1974 13 14
'1975 5 4 1976 34- 7-1977 -46 36
'1978 71 .71 -{
1979 68- 159 1980 121 95 1981 102 142 1982 85' 228 1983 94 338 1984 73 326
'1985 92 337: ,
1986 33'- 94 ' TOTALS 841 .1851
.q l
l I e 6 e 1 l 4 0 4
ENCLOSURE 2 l
SUMMARY
OF SALP EVALUATIONS I Ratino (for period ending) Functional Area 12/80 6/81 7/82 6/83 12/83 12/84 3/86
- 1. Substructure / Soils and Foundations Avg. I 1 1 --
1 --
- 2. Piping Systems and Supports Below 2 3 3 3** 2
~
Avg.
- 3. Safety Relat.ed Components Avg. 2 2 2 --
2 --
- 4. Support / Auxiliary Systems (Including HVAC & Fire j Protection) -- --
1 1 -- 1 --
- 5. Electrical Power Supply and Distribution Avg. 2 2 2 --
3 --
- 6. Electrical (tray and wire) Avg. -- -- -- -- -- --
- 7. Instrument and Controls -- --
1 1 -- 2 --
- 8. Licensing Activities -- --
2 2 -- 2 1
- 9. Containment Liner /
Structures. Avg. 2 2 1 -- 1 --
- 10. Safety Related Structures Avg. 2 * * -- * --
- 11. Project Management Effec- !
tiveness -- -- 2 -- -- -- --
- 12. Properational Testing -- -- -- -- --
1 1
- 13. Quality Assurance / Control Below 2 -- -- -- -- --
Avg, 14 Quality Programs and Management Controls -- -- -- -- -- 1 -- l 15. Operational Readiness l . (Operator Licensing) -- -- -- -- -- 1 --
- 16. Reporting / Corrective !
l-l Actions Avg. 2 -- 2 -- -- --
^
l 17. Design and Design Changes -- 3 -- -- -- -- --
- 18. Procurement --
2 -- -- -- -- --
- 19. Training Avg. 1 -- -- -- -- --
- 20. Environmental Avg. -- -- -- -- -- --
- 21. Management Avg. -- -- -- -- -- --
- 22. Concrete l Avg. -- -- -- -- -- --
i
- 23. Construction -- -- -- -- -- --
1*** .
- 24. Fire Protection and I Housekeeping Avg. -- -- -- -- --
1 ;
- 25. Operational Readiness -- -- -- -- -- --
1 l
- 26. Emergency Preparedness -- -- -- -- -- --
2
- 27. Assurance of Quality -- -- -- -- -- --
1 l Notes: Functional area not evaluated or no basis for assessment. , Functional area 10 combined with functional area 9 for evaluation purposes. I y _ Special assessment of only functional area 2. Functional area 23 is a combination of areas previously reported separately. 1 m _ - _ - - - - _ _ _ _ _ - _ _ _ _ _ _ _ _ . - - _ _ _ . _ _ -
{ ENCLOSURE 3- f INSPECTION PROGRAM , ANNUAL BREAKDOWN (HOURS) I Year Reports Construction Preops. Startup Operations Total - i 1973 1 3 -- -- a 3 1974 5 100 -- -- a 100 1975 2 11 -- -- -- 8 11 1976 6 54 -- -- -- 54 1977 10 101 -- -- -- 101 j i 1978 16 523 -- -- -- 523 i ll 1979 10 281 -- -- -- 281 1980 13 621 -- -- -- 621 I 1981 14 859 10 -- -- 869 l 1982 16 1560 3 -- -- 1563 D b / 1983 13 4049 47 -- -- 4096 1984 c c 20 4471 123 -- -- 4594 d d 1985 34 2879 1829' 12 22 4742 I 1986 41 1182 4090 100 280 56529 TOTALS 201 16694 6102 112 302 23210 Notes: a Estimated hours - no record of actual hours. 1 b Includes an estimated 2400 hours for integrated design inspection. c Includes an estimated 2500 hours for construction appraisal team inspection. d Includes 567 hours for construction team inspection and 654 hours for inde-pendent measurements inspection.
- 1 Includes an estimated 340. hours for emergency preparedness implementation appraisal. i 1
I Through June 30, 1986. 9 Includes an estimated 230 hours for Appendix R inspection, 637 hours for as- ; built team inspection,.and 240 hours for Technical Specifications inspection. 1 1 i
l ENCLOSURE 4 l INSPECTION
SUMMARY
I l Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions l l 73-01 3/6/73 Initial management meeting. None. 1 i 74-01 1/7-8/74 Contractor (UE&C) QA program None, but several major 1/10/74 planning and . implementation. deficiencies with 10 4 CFR 50, Appendix B requirements. 74-02 2/26-27/74, QA program implementation. None, but several 10 2 CFR 50, Appendix B deficiencies. 74-03 4/29-5/2/74 QA program implementation. None, but consolidated 2 10 CFR 50, Appendix B deficiencies. 74-04 7/10-12/74 QA program implementation. None. I 74-05 10/30-31/74 QA program implementation. None. 11/6/74 - 3 75-01 3/4-5/75 Management audit and QA pro- None. I gram implementation. 75-02 9/11/75 QA program implementation. None. 1 76-01 5/4/76 Management meeting and on- None. I site activities. 76-02 7/14-15/76 Site clearing activities, None. 1 QA/QC staff, construction drawings and specifications, management audits. i 76-03 8/2-4/76 QA/QC implementing proce- None. 2 dures for site preparation and foundation / structural concrete work. 76-04 9/15-16/76 Environmental protection None. 1 program for construction. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ J
1 Enclosure 4 2 Inspection Dates / Number . Inspection Enforcement Number c+ Inspectors Areas Actions l 76-05 10/27-28/76 Impact of construction acti- One deficiency: failure 2 vities on environment. to control turbidity of dewatering effluents. 76-06 12/13-15/76 Contractor QA plans, work None. I procedures for concrete and - reinforcing steel work. 77-01 2/15/77 Containment area evacuation None. 3 I status, storage facilities, { and storage material. ! 77-02 4/13-14/77 Environmental protection One deficiency: failure I program implementation to perform turbidity (construction phase), measurements of site effluent. 77-03 7/6-8/77 QA procedures and records None. 1 for storage and storage maintenance of safety re- - lated components, plant ! tour / inspection. ! 77-04 7/26-27/77 QA procedures for receiving None. 2 and storage of reactor pres-sure vessel, preparations to unload vessel, and vessel post-hydro test verification. 1 77-05 8/2/77 Reactor vessel receiving and None. ! I transportation to interim / long-term storage. l 77-06 8/26/77 Site preparation and place- None. 1 ment of fill concrete in floor of service water. trench. 77-07 10/3-4/77 Placement of fill concrete None. 2 at reactor containment area, site dewatering and runoff water control, stcrage of reactor vessel. 77-08 10/31/77 Site excavation work activi- None. I ties and construction water effluent turbidity control. l l
. - . - ___m_____._____.__
Enclosure 4 3 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 77-09 12/1-2/77 Environmental protection One deficiency: failure 1 programs (construction), to control effluent turbidity. 77-10 12/5-9/77 Preparatory activities and None. 12/14/77 QA/QC procedures for concrete 2 and rebar, observations of concrete batch plants, con-crete ingredients storage facilities, laboratory test facilities, and rebar lay-down areas. 78-01 1/16-18/78 Construction work in pro- One infraction: failure 2 gress, containment liner and to properly control access penetrations proce- master drawing rack dures, field welding on ser- stick files. vice ' water piping, cadweld-ing and offsite equipment storage. 78-02 2/14-17/78 Foundation preparation and None. 2 rebar installation; geologic mapping and approval of rock, records of concrete mixing, l fill concrete' placement, in- J spection personnel qualifica-tions, audit reports on con-crete activities. 78-03 2/21-24/78 Sand-cement mix procedures, None. 4 quality assurance programs and procedures for subcon-contractors on testing, structural steel, contain- 1 ment liner and penetrations. j 78-04 3/6/78 Surveillance and nondestruc- None. f I tive examination records on i underground piping. 78-05 3/20-24/78 Containment concrete base mat One deficiency: failure 1 placement, safety related to comply with 10 CFR l components storage and hand- Part 21 posting re- i ling procedures, site prepar quirements. ation blasting records, and posting of 10 CFR Part 21.
Enclosure 4 4 Inspection Dates / Number Inspection Enforcement Number of Inspectors _ Areas Actions 78-06 4/~.9-21/78 Environmental protection Two deficiencies: 1 programs (construction). Failure to control runoff water turbidity.' Failure to maintain acceptable drainage patterns at the hemlock l ravine vegetation area. l 78-07 4/24-28/78 Site preparation records and None. 2 work in progress, foundation ' records, and containment liner fabrication. 76-08 5/22-25/78 Work activities on contain- None. I ment liner fabrication and installation, concrete place-ment, and licensee action on Bulletins and Circulars. t 78-09 6/26-28/78 Concrete placements, con- None. 2 tainment steel fabrication activities, electrode con-trol, and welder and proce-dure qualification. 78-10 7/10-14/78 Preparations, QC and con- None. ; I crete placement activities ' for the reactor pit struc- ' ture walls, and rebar instal-lation and cadwelding for the reactor base mat. 78-11 7/21-27/78 Compliance with NRC 6/30/78 None. 1 Order to suspend the con- ; struction permit effective 7/21/78. i 78-12 7/26-8/11/78 Investigation of complaints None. 4 2 concerning blasting and other' unauthorized work after construction permit ; suspended. ! 78-13 9/5-8/78 Piping contractor's QA pro- None. i 1 gram, installation of con-tainment reinforcing steel. l
Enclosure 4 5 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 76 10/2-6/78 Piping contractor's QA pro- None. 3 gram and work procedures, welding of containment liner plate. 78-15 11/6-9/78 Procedures and work activi- None. 4 ties for safety related piping and components, con-tainment concrete placement activities. 78-16 12/12-15/78 Work in construction area One infraction: failure 2 and material storage area; to control material implementing procedures for storage. safety related structures and supports. i 79-01 1/15-18/79 Work in construction area, None. 4 l 3 reactor pressure vessel un- ) loading and handling proce- , dures, concrete placement records. 79-02 1/24-25/79 Investigation of allegation None. I that frozen water present on previously placed concrete ' prior to subsequent concrete placement. 79-03 2/12-15/79 Reactpr pressure vessel None. 2 handling load test, elec-trical QA program and pro- ! cedures. ; 79-04 3/12-13/79 Construction activities in- None. 2 ciuding piping alignment, rebar installation, cadweld-ing, liner plate welding, concrete curing and finish-t ing. I G
. . Enclosure 4 6 i
1 l Inspection Dates / Number Inspection Enforcement , Number of Inspectors Areat Actions 79-05 4/3-4/79 Construction activities in- One infraction: failure 2 ciuding stripping forms in to electrically con- i
, equipment vault, dewatering nect stored equipment containment for liner plate supplied with space installation, weld prepara- heaters.
tion on containment liner, and concrete compression strength testing, mainten-ance of material stored offsite. ! 79-06 5/21-25/79 Work activities and records Three infractions: l 2 for concrete, containment, Failure to follow ] and safety related piping; welding procedures. 1 and document control. Failure to control , access to warehouses.
' Failure to follow ]
document control pro- j cedures.' l 79-07 8/13-16/79 Construction activities in- Four infractions: 2 ciuding containment building Failure to reject un-liner offstand welding and acceptable void in inplace welding of erected cadweld splice. rings, vacuum testing of liner welds, liner stud Failure to provide de-welding, rebar installation tails in Perini pro- i and cadwelding for exterior cedure for major re- ! wall and interior columns, pairs in concrete. soil backfill compaction and testing, laboratory testing Failure to provide ' of concrete cylinders and criteria in procedure qualification testing of the for storage of con-new iron workers in cadweld tainment equipment. splicing; and review of QA surveillance reports. Failure to issue a deficiency report for deficient items un-l covered during sur-l veillance. i
Enclosure 4 7 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas ~ Actions 79-08 9/4-7/79 QA program for various or- Two infractions: 4 ganizations involved with' Failure to provide
~Seabrook Station. details in YAEC pro-cedure for reaudit of open items.
Failure to provide details in UE&C sur-veillance QA procedure for when to verify that prompt corrective ac-tion was taken. 79-09 11/13-16/79 Work activities, record re- One infraction: failure 2 views, welding and nonde- to prescribe corrective structive tests on primary actions by Perini and containment; nonconformance UE&C to preclude place-and disposition reports in ment of concrete until concrete and rebar for all reinforcing steel. safety related structures; identified in design and concrete curing. and detall- drawing has been installed. 79-10 12/11-13/79 Rebar installation and con- None. 3 tainment liner welding acti-vities, field drawing con-i
' trol, condition of erected structural steel and stain-less steel pipe stored on flatbed trailer, and elec-trical specifications and procedures. J 80-01 1/22-25/80 Cadwelding splicing, con- None. ;
2 crete replacement and cur- ) ing activities, equipment : maintenance and storage, ! weld rod control, and in- > quiry regarding drug indict-ments of Seabrook construc- ' tion workers. l 80-02 2/6/80 Management meeting to dis- None. I 1 cuss establishment of onsite ; office for full-time NRC in- l spector. l
1 Enclosure 4 -8 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 80-03 2/26-28/80 Construction activities in- Two infractions: 1 ciuding terrporary storage of Failure to conduct material supplies within a required stud weld-containment, stainless steel ing inspection. welding and weld rod con-trols, and stud welding pro- Failure to control cedures and controls. changes to assure re-vision of affected contractor procedures. 80-04 4/14-17/80 Pipe welding controls, cad- One infraction: failure 3 weld reinspection program to provide sequence and corrective action, and for examination of pipe construction activities in- weld repairs to assure ciuding containment interior code compliance. shield walls and exterior building walls reinforcing steel installation and cad-weld splicing, preparations for concrete placement of PAB . walls, cold weather protec-tion and curing of control building walls and cadweld splice reinspection. 80-05 5/5-7/80 Environmental protection One infraction: Inade-1 programs (construction quate environmental phase). control program. Two deficiencies: Failure to control dewatering water turbidity. l Exceeding construction permit turbidity dis-charge limit. 80-06 5/19-6/27/80 Containment concrete place- One infraction: failure 2 ment, pipe and pipe support to provide appropriate welding, installation of criteria for inspection electrical embedded items of equipment grouting. and raceway supports and safety related component installation.
Enclosure 4 9 I Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 80-07 6/30-8/1/80 Containment and safety re- One infraction: failure lated concrete; safety re- to initiate noncon-lated pipe welding, NDE and formance report and support installation; RPV review and disposition internals storage; and stud weld nonconforming safety related steel tension conditions per proce-set bolting and embed in- dural requirements. sta11ation. 80-08 7/3/80 Management meeting to dis- None. I cuss Seabrook construction
, status, resident inspection program, NRC programs for SALP and independent meas-urements, 50.55(e) report-ing, current NRC enforcement policy, and Seabrook QA pro-gram and implementation.
80-09 S/4-9/5/80 Piping erection, pipe and None. I pipe support welding, struc- . tural steel erection, compon-ent support welding, and com-ponent storage. 80-10 9/8-10/10/80 Pipe and pipe support erec- Two infractions: I 1 tion and welding, structural Failure to install pipe ) steel erecti.on and welding, support welds in ac- 1 and purchased material cordance with draw-status and records. ings. Failure to assure that purchased structural steel conforms to'the code requirements specified in procure-ment documents. 80-11 9/16-19/80 Containment liner welding, Two infractions: 2 safety related pipe welding, Missing inspection . and storage of components, sequences on field I weld repair process sheets. l Failure to comply with requirements when mak- ; ing a weld repair of I piping.
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- - Enclosure 4 30 l
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Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 80-11 One deficiency:-failure (CONTINUED) to comply with proce-dures when welding on paint. 80-12 10/13-11/21/80 Pipe and pipe support erec- One infraction: failure ; 3 tion and welding, electrical to perform pipe base .j duct bank construction and metal repair welding 'l cable tray erection, concrete and final NDE in ac- { batch plant operation.and cordance with ASME ! records, anchor bolt instal- and specification re- 1 lation, and investigation quirements. -l into concerns.about improper site testing practices. 80-13 11/24-12/31/80 Containment internal con- One violation: failure 1 crete placement and liner to control and document wind girder removal, polar engineering review and crane rail installation and approval nf A field NDE, piping operations and initiated design change NDE, Kwik-bolt installation (Level r, Supplement and system design considera- II). ] tions for electrical work, audit of licensee evaluation program for 10 CFR 50.55(e)- deportability. -3 81-01 1/2-30/81 Safety'related components Two violations: 3 work activities, RPV inter- Failure to include ' nals, structural steel and appropriate weld ac-polar crane rail welding and ceptance criteria in rail repair and pipe support the field hanger draw- I welding. ing change (Level IV, Supplement II). < Failure to follow pro- I cedure in acceptance i of undersized fillet ; weld (Level V, Supple- -i ment II). 81-02 2/2-27/81 Pipe welding and support 2 One violation: failure erection, embed installation to perfom magnetic j and structural steel erec- particle examination j tion, and component mainten- on threaded anchor ; ance and installation. bolts as required by ' specification (Level V, Supplement II). 5
Enclosure 4 11
't Insoection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 81-03 3/2-4/81 Pipe welding and support Two violations:
1 erection, structural steel Failure to control welding and erection, NSSS structural bolting support installation, equip- and welding to code ment storage and maintenance, and procedural re-and component conformance quirements (Level IV, and seismic qualification. IV, Supplement II). Failure to provide weld length criteria for pipe support in-stallation prior to welding (Level V, Sup-plement II). 81-04 3/12/81 Management meeting to dis- N/A. cuss SALP board results of licensee's performance of 1/1/80-12/31/80. 81-05 4/6-5/8/81 Structrual steel erection Two violations: I and welding, pipe welding Failure to consider and support erection, equip- specification and code . ment support installation requirements for weld j l and component installation. ISI in the approval < of a pipe support in-sta11ation (Level V, Supplement II). I I Failure to utilize a properly qualified weld procedure for welding a flued head to a con-tainment penetration ; sleeve (Level IV, Sup- ' plement II). I i 81-06 5/11-15/81 Weld metal repairs and non- None. I destructive examinations by pipe fabricator, storage of material and moving of No. 3 steam generator. j 81-07 5/26-6/26/81 Pipe and pipe support weld- One violation: failure ing, pipe storage, electrical to install properly supports and components, and supported electrical Part 21 diesel generator boxes within contain-problems. ment (Level V. Supple-ment II). I
Enclosure 4 12 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 81-08 6/29-8/21/81 Pipe and pipe support weld- None. 2 ing; RPV and other NSSS com-
,ponents, design considera-tions for pipe and electrical cable routing, and miscellane-ous structural connections and QA.
81-09 8/24-10/2/81 Pipe and pipe support instal- Two violations: 1 lation, NSSS supports, con- Failure to install
. tainment structural connec- adequate structural tions, electrical raceway support welds (Level support inspection and tray IV, Supplement II).
qualification, and contain-l ment liner dome lift. Failure to preclude I i installation of NSSS supports with noncon-forming, undersized welds (Level IV, Sup-plement II). 81-10 9/28-30/81 Proposed physical security None, 1 plan. 81-11 10/15/81 Management meeting to dis- N/A. cuss SALP board results of licensee's performance from 7/1/80-6/30/81. 81-12 10/5-11/16/81 Piping QA program, pipe in- One violation: failure 4 sta11ation,. welding and sup- to erect instruments-ports; concrete placement tion supports in ac-preparation,-cadweld splic- cordance with the con-ing, site civil testing, and trolling design docu-containment liner'and con- ment (Level IV, Sup-crete interfacing; component plement II). installation, instrumentation supports; and structural con-nections to include design control over the structural impact of combined loadings. 81-13 11/3-6/81 Machine orbiting, gas tungs- None. 2 ten arc (GTA) butt welding process used to weld Class 1 reactor coolant system pipe and components. e, u_____ _ _ _ . _
. . Enclosure 4 13 f
Inspection Dates / Number Inspection Enforcement 1 Number j of Inspectors Areas Actions j l 81-14 11/17/81- Field fabrication of rein- One violation: failure l 1/8/82 forcing steel; pipe instal- to assure applicable 1 lation, welding and supports; design considerations
~ electrical component storage, (i.e., thermal pipe supports and welding; blast growth) were correctly monitoring for safety related translated into pipe j effects; and design verifica- support modification
{ tion controls, details (Level V, Sup-plement II). 82-01 1/11-2/12/82 Pipe installation, welding One violation: failure 1 and supports; structural to. clearly establish steel connections; electri- and assign responsi-cal raceway supports and con- bility for modification j tainment penetration. welding; (i.e., stiffening) of l and cadweld testing program. structural beams ! necessitated by certain j electrical raceway ' support installations (Level V, Supplement l II). 82-02 2/16-3/22/82 Pipe installation and pipe Two violations: I whip restraint erection; con- Failure to adequately tainment penetration and iso- control a containment lation valve installation; penetration welding structural connections; and process (Level IV, electrical cable termina- Supplement II). tions. Design failure in ! specifying undersized fillet welds for pipe whip restraints. (Level IV, Supplement II). ; 82-03 3/23-5/3/82 Electrical component pro :ure- Two violations: 4 ment, installation and in- Failure to establish spection; reactor coolant an inspection program pipe welding; rebar cadweld- for installed cable ing; corrective action on tray (Level V, Supple-ground water leakage, support ment II). erection to include the Kwik- : bolt installation program; Failure of QC pipe and and followup of 50.55(e)/Part electrical support in-21 item. spections to identify nonconforming condi-tions (Level IV, Sup-plement II).
Enclosure 4 14 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 82-04 5/4-14/82 Control battery' installation One violation: failure 6/1-18/82 and inspection; followup of to follow procedures I concern regarding concrete and manufacturer's repair sand usage and con- specifications in con-trol; and follouwp. to IE Bul- trol battery installa-letins and Circulars. tion and inspection (Level IV, Supplement II). 82-05 5/6/82 Meeting to discuss Opera- N/A. tional Quality Assurance Pro-gram for Seabrook Station. l 82-06 6/21-7/2/82 Construction Assessment Team Nine violations: 5 inspection of project manage- Failure to follow pro-ment, quality assurance, de- cedures for qualifica-sign control, construction tion of auditors (Level control and nondestructive V, Supplement II). testing. Inadequate water stop specification (Level V, Supplement II). - Failure to properly process ECA's (design change documents) (Level IV, Supplement II). Failure to properly review NCR design changes (Level IV, Supplement II). Failure to distribute design documents in i ' the area of use (Level IV, Supplement II). Failure to provide
. proper directions to pipe welders (Level IV, Supplement II).
Failure to reaudit deficient areas (Level IV, Supplement II).
j Enclosure 4 15 i 1
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i f Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 82-06 Failure to provide ade-i (CONTINUED) quate protection for equipment in storage (Level IV, Supplement < II). I i Failure of welds to ; meet ASME III Code acceptance criteria (Level IV, Supplement II). Also, 5 significant { program weaknesses. ( 82-07 6/14-17/82 Concrete construction of None. 1 primary concrete building i exterior wall and dome, l control of ground water i seepage, and structural fill placement, compaction- - l and testing for service l water lines. { 82-08 7/12-8/23/82 AWS welding, structural steel None. 3 erection, reactor coolant j pressure boundary and safety { related piping runs and weld- J ing, RPV internals condition and stroage, and design / con- ) { struction interface issues. J 82-09 8/24-27/82 Concrete construction of None. 1 reactor containment building dome, structural welding within containment building, QA surveillance of structural steel erection, and welding Category I buildings. 82-10 8/24-9/30/82 Pipe penetrations; pipe weld- Two violations: 1 ing, supports, and whip re- Failure to assure that straints; design issues; and pipe whip restraint corrective action. design documents specify appropriate material requirements and quality standards, i re: design intent for ! i
i Enclosure 4 16 .
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i Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions , i 82-10 high-strength bolting 1 (CONTINUED) applications (Level V, Supplement II). Failure to implement prompt and effective l { corrective action in 1 resolution of issue ! re: questionable pipe
. erecti on c learances (Level IV, Supplement
{ II). 1 82-11 9/20-24/82 Installation and inspection None. 1 of electrical and instrumen-tation components. 82-12 9/28-10/1/82 Reactor vessel internals and One violation: failure I containment bo'undary electri- to distribute a safety cal, mechanical and access related-design change penetrations. (Level IV, Supplement II). l 82-13 10/1-11/5/82 Safety related structural One violation: failure 2 steel erection, reactor cool- to conduct and document { ant pressure boundary piping an inspection of pipe installation; safety related support Kwik-bolting pipe supports, and design activities per proce-issues. { dure hold point re-quirements (Level V, Supplement II). 82-14 11/2-5/82 Refueling water storage tank None. I and structural support instal- 3 lation and erection for reac- 1 tor coolant pumps. 82-15 11/8-12/20/82 Diesel generator coolant sys- One violation: failure 4 tem piping and supports, to adequately control electrical cable routing and status of design separation, including fire changes to a pipe sup-protection, and technical re port installation, re- ! sponses to design questions. sulting in undersized welds and QA acceptance l of same (Level IV, Supplement II).
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Enclosure 4 17
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Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 82-16 12/21/82- Safety related piping and One violation: failure l 1/17/83 support erection issues, and to assure installation ' 2 Class IE cable installation. of Class IE cable in a qualified (i.e., seismic) raceway system (Level IV, Supplement II). i i 83-01 1/17-21/83 Pipe support installation None. I and allegations concerning ) { welding aspects of. hanger l (supports) fabrication, in- l cluding return end (boxing) ! welding and welding on radius between web and flanges for l NF Class 2 hanger welds. j 83-02 1/18-2/28/83 Component-installation, pro- Three violations: 2 cess controls, containment Failure to control in-piping penetrations, and sta11ation and inspec-engineering controls. tion protess on weld end preparation and component installation J (Level IV, Supplement II). Failure to document and control cable tray support nonconformances to the FSAR and drawing-details (Level IV, Sup-plement II). Failure to maintain records, as evidenced by. identification of an uncontrolled and erroneous reconstructed installation record (Level V, Supplement II). 83-03 2/22-25/83 Installation, routing and None. s 1 termination of electrical cables. e
Enclosure 4 18 Inspection I Dates / Number Inspection Enforcement Number of Inspectors Areas Actions , 83-04 2/28-3/4/83 Design changes associated None. 3/17/83 with large bore pipe and HVAC 2 . support installation, UE&C 4 i onsite organizational struc- i ture and design responsibili-ties including site /home of- ' fice interface, implementa-tion and audits of UE&C pro-cedure AP-15 controlling the design process, and upgrade of control room supply air duct work. 83-05 3/1-4/8/83 System and component instal- None. 3 lation, structural steel erection, electrical cable and instrument tubing instal-lation; and control of field 4 drawings for piping supports. I 83-06 4/11-5/23/83 Pipe, pipe support and elec- None. - I' 2 trical raceway installation. 83-07 5/23-27/83 Reactor vessel internals, 2 Three violations: containment structural steel, Failure to perform containment dome concrete reactor internals work placement, steel structures per procedures (Level and supports in emergency IV, Supplement II). feedwater pumphouse and fuel storage building. Failure to issue a Process Control Sheet with a procedure change (Level V, Supplement II). Failure to maintain proper storage of reactor internals (Level IV, Supplement II). 83-08 5/24-26/83 Electrical system including Two violations: 1 procedures, training, race- Failure to maintain way installation, cable in- motor operator valves' sta11ation and cable termi- limit switch compart-nations. ments clean and sealed (Level V, Supplement II). O d
Enclosure 4 19 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 83-08 Failure to maintain (CONTINUED) safety related cables and raceways clean and free of debris, tools, etc. , during the con-struction phase (Level V, Supplement II). 83-09 5/24-7/1/83 Piping and pipe support in- One violation: failure 2 sta11ation, actions on CDR's, to implement adequate and licensee investigation of corrective action to incident reported to NRC. preclude recurrence of deviant and noncon-forming conditions (Level IV, Supplement II). 83-10 6/7/83 Management meeting to dis- N/A. i 2 cuss licensee actions in re-sponse to general NRC con- . cerns, re: performance of site piping contractor (Pullman-Higgins), and to specific construction de-ficiency, re: questionable conduct of surface NDE by one Pullman-Higgins tech-nician. 83-11 7/5-8/83 Installation of instruments- None. I tion components and systems. 83-12 8/8-12/83 Corrective action program, One violation: ultra-3 reactor vessel internals, in- sonic examination for strument tube installation, acceptance of safety and safety related pipe and related components pipe support welding. (fillet welds) without a qualified ultrasonic test procedure (Level IV, Supplement II). 83-13 7/11-8/26/83 RCP B" weld repairs, NDE, 'One violation: failure 3 and instrument tubing checks; to follow procedures design change controls; com- in the control and im-ponent testing; and construc plementation of a de-tion, gauge cal _ibration pro- sign change (Level V, gram. '- Supplement II).
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Enclosure 4 20 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 83-14 8/15-19/83 Installation, routing, and One violation: failure 1 termination of instruments- to properly inspect tion and control cables. terminations of small gauge conductors (Level j V, Supplement II). l, 83-15 9/12-10/14/83 Electrical cable and compon- One violation: failure 2 ent installation and QA, to review design changes licensee field QA surveil- for adequacy of welding lance program, miscellaneous process controls (Level structural issues, and CDR IV, Supplement II). followup. 83-1.6 9/27-30/83 Preoperational test program, None. 1 preoperational test proce-dure review, and preliminary test results review. 83-17 10/17-12/5/83 Containment leak chase sys- Three deviations: 3 tem, containment penetra- DG SKV bus duct needs tions, design change con- collar Yor vibration trol, licensee Self-initiated dampening. Construction Project Evalu-ation and in process instal- Certain penetration lation of piping, pipe sup- leak chases not con-ports and whip restraints. nected to test piping system. Recirculation piping encapsulation tank welds do not meet ASME design requirements. 83-18 11/14-18/83 NDE of piping and pipe sup- None. t 4 port weldments for re verifi- l i cation of previous NDE results. 83-19 11/28-12/1/83 Reactor vessel safe end None. ; 1 radiographs. 83-20 12/19-22/83 Installation, inspection and One violation: failure l 1 testing of electrical and in- to properly install ; strumentation equipment. equipment per drawing ) requirements (Level IV, Supplement II) ;
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Enclosure 4 21 i
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o l
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Inspection Dates / Number Inspection Enforcement' ! Number- of Inspectors Areas Actions 1 83-21 12/19-22/83 Preoperational and acceptance None. l 1 test procedure review. 22 12/6/83- Small bore piping and compon- Two violations: 1/20/84 ent installation, electrical Recurrent' electrical 2 cable inside containment - construction violation routing and component erec- regarding misinterpret-tion, rework activities - tation of design re-construction and preopera- quirements (Level IV, tional testing, certification Supplement II). of NDE personnel, HVAC proce- ) dures, licensee Supervisory L,rk request directions Support Group piping surveil- and authority were ex-- lance / audits. ceeded, resulting in !
. partially assembled J l
, equipment'with an im-proper status.(Level !
IV, Supplement II). I 8?-23 and 11/1-12/21/83 Integrated Design Inspection None; however, exten-Supplement 1 11/7-9/84 focused on containment build- sive findings regarding 17 Inspectors ing spray system. errors, procedural and Contrac- violations, and incon-tors sistencies identified in report. 84-01 1/23-3/12/84 Piping and pipe support in- None. 5 sta11ation, welder qualifi-cation, electrical cable and terminations, diesel genera-tors, and equipment turnover to startup test group. 84-02 2/28-3/2/84 Preoperational and acceptar.ce None. 1 test procedure review, special test procedure re-view, and system turnover review. 84-03 3/12-16/84 Installation, inspection and None. 2 testing of electrical equip-ment. 84-04 3/13-5/7/84 Diesel generator testing, One violation: inade-4 main control board modifica- quate design and in-tion controls, refueling spection of diesel .; 1 .
Enclosure 4 22 i Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 84-04 water storage tank erection generator exhaust , (CONTINUED) records, pressurizer relief silencer installation I valve and associated piping resulted in damage to and pipe support erection, the component support new UE&C. instrumentation and pedestals during in-control procedures, general process testing (Level housekeeping and storage of IV, Supplement II). i equipment and material. I 84-05 4/17-20/84 Vendor diesel' generator test None. I witnessing and preoperational test procedure review. 84-06 4/30-5/4/84 Preservice inspection activi- None. 1 ties including program re-view, observations of work in progress,-review of NDE procedures, and review of ! PSI data. ! 84-07 4/23-5/4/84 NRC Construction Appraisal Five violations: 5/14-25/84 Team (CAT) inspection to Failure ~of QA program 9 Inspectors evaluate adequacy of con- to effectively provide 7 Consultants struction at Seabrook Station control over activities including electrical and in- involving seismic cable 1 strumentation construction, tray support installa-mechanical construction, .tions (Level IV, Sup-civil and structural con- plement II). struction, welding and non- , i destructive examination, Failure to maintain i material traceability and adequate design control controls, design change con- (Level IV, Supplement trol and corrective action II). ; systems. ! Failure to effectively perform instructional and procedural activi- , ties (Level V, Supple- ' ment II). Failure to effectively implement program for inspection of activi-ties affecting quality (Level IV, Supplement II). . e______.-__-_-_ - _ - - - - --- - - - - - - - - - ' ' - '- ~~
- r. y Entiosure 4 23 ;
i Inspection Dates / Number Inspection Enforcement { Number of InsDettors Areas Actions ! 84-07 Failure to assure that (CONTINUED) nonconforming condi-tions have been pro-perly identified, re- i viewed, resolved, and i evaluated for correc- ' J tive action (Level IV,. Supplement II). Three program weak-nesses: hardware being installed and inspected while design changes continue. Communication problem . between applicant's i various management, engineering and con-structio,n groups i (utility, engineering, i contractors, and QA/QC personnel). Weaknesses involving piping support instal-latf or.s have been pre- i viously identified by -i NRC Region I. 84-08 5/29-6/25/84 Electrical, terminations, RHR One violation:~ inade-2 line flushing, IE Bulletin quate storage and pre-actions, tank farm chase servation of NSSS com-buildings, CRDM cooling ponents (Level IV, Sup-shroud, steam generator tube plement II). plugging, and I&C procedures. 84-09 6/12-15/84 Preoperational test procedure None. I review and verification, and QA interface with preopera-tional testing. 84-10 6/26-8/24/84 Reactor vessel fabrication None. 2 reactor. vessel flange seal ring groove repairs, welder decertification, records of ! reactor vessel nozzle repairs, . radwaste piping, and steam i generator nozzle repairs. I O
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Enclosure 4 24 L Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 84-11 8/21-24/84 Preoperational test proce- None. 2 dure review and verification,
.QA interface with preopera-tional testing, and system turnover program.
84-12 8/13-17/84 Special inspection of con- One violation: failure 8/27-31/84 struction activities regard- to implement adequate 4 ing concrete walls, steam corrective action to generators, welding, piping, preclude recurrence valves, storage and NCR con- of a forged signature trol, as a result of allega- at an inspection hold tion statement submitted by point (Level IV, Sup- I an anonymous alleger. piement II). 84-13 8/27-10/26/84 Instrument cable termina- One violation: inade- l 2 tions, cable pulling, piping quate records for steam ' and support welding, steam generator lateral sup-generator lateral support ports installation structures, field QA manual, (Level V, Supplement design changes, ASME Code II). Case commitments and 10 CFR 50.55(e) program. 84-14 9/17-21/84 Operator licensing examina- N/A. l 1 Examiner tions of eleven SRO and two i 4 Contractors R0 candidates. 84-15 10/15-19/84 HVAC systems final as-built None. I conditions and preparation of as-built records. 1 84-16 10/29-11/2/84 Repair of reactor pressure None. 2 l vessel nozzle to safe end welds, welding procedures, ! and welder performance quali-fication. 84-17 10/29-12/17/84 Weld repairs to RPV nozzle One deviation: un-2 safe ends, ECCS piping system authorized use of a walkdown and procedure re- superseded ASME Code view, reactor coolant piping Case in a design heat treatment records, de- change. sign and procurement of ori- " fice plates and penetration sealants, nonconformance.re- , ports, and system turnover activities.
. Enclosure 4 25 Inspection Dates / Number Inspection- Enforcement
. Number of Inspectors Areas Actions 84-18 12/3-7/84 Installation of electrical / One violation: accumu-3 instrument components and lation of trash and-
. systems and review of QA ' debris detrimental to records, quality and safety (Level V, Supplement II).
84-19 12/4-7/84 Operator licensing examina- N/A. 3 Examiners- tions of.'four SRO and three 2 Contractors R0 candidates. 84-20 12/18/84- Instrumentation and control None. 2/8/85 activities, electrical train 4 separation,~ safety related piping system walkdown, reac-l tor coolant loop piping heat l treatment, and vendor audit / surveillance program. 85-01 2/12-4/5/85 I&C installation, valve'in- Two vio1_ations: 3 terlock logic and limit Failure of design con-switch installation, RPV.in- trol and interfacing
-ternals records, flow re- between design organi-strictor design and field zations in not'trans-
' installation, and conduct of lating the significance system and component hydro- of maximum flow re-static tests. strictor orifice sizing into drawing details and field instructions (Level IV, Supplement-II). Inadequate nonconform-ing item control as evidenced by condition cf two valves (Level 1 IV, Supplement II). 85-02 1/28-2/1/85 Preoperational test procedure None. I review and verification, test witnessing (Phase I), and QA interface with preoperational testing. 85-03 2/11-15/85 Installation, inspection and One violation: failure 1 testing of electrical equip- to have identifying ment. nameplates attached to electric equipment (Level V, Supplement o II). l~
- 1 .
w-____-_______-- _ - - - _ - - - -
Enclosure 4 26 Inspection Dates / Number Inspection Enforcement-hmber of Inspectors Areas Actions 85-04 3/18-22/85 Operator licensing examina- N/A. 1 Examiner tions of seventeen SR0 and 4 Contractors three R0 candidates. 85-05 2/26-3/1/85 Preoperational test procedure None. I review and verification, test witnessing (Phase I), QA in-terface with preoperational testing and code hydrostatic test preparations. 85-06 2/25-3/1/85 Fire main loop installation. One deviation: failure l to install UL listed hydrant isolation valves. 85-07 3/11-15/85 Work performance and'inspec- None. I tion of HVAC systems as af-fected by 1984 reorganiza-tion and assignment of work to UE&C. - 85-08 4/2-5/85 Reactor coolant system hydro- None. 2 static test including test witnessing and independent measurements of metal sur- [ q face temperatures. l 85-09 4/8-5/24/85 Instrumentation and control None. 4 activities, system piping i ' component walkdowns, and in-office review of A/E metal-lurgical evaluation contained in a component failure analy-sis report. 85-10 4/15-19/85 Containment structural steel None. I weld quality, radiography, preservice inspection acti-vity including ultrasonic ; examination of welds and- ' preparation for eddy current examination of steam genera-tor tubes, and observation of pipe hanger / support instal-lation.
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_ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ M
'Enulosure 4 27 Inspection Dates / Number' ' Inspection Enforcement Number of Inspectors Areas Actions 85 4/29-5/3/85 Installation of electrical None.
I safety related equipment. 85-12 4/29-5'/3/85 ' Acceptance test procedure re- None. 1 view and verification, pre-operational test witnessing, preoperational and accept-ance test results evalu- ' ation', steam generator eddy current testing, emergency diesel generator preopera-tional test scope, and QA interface with preopera-tional tesing. 85-13 5/6-10/85 Turnover portion of QA pro- None. ) 3 gram for preoperatienal ) testing, including QA/QC overview and interface activities. ! 85-14 5/13-17/85 Preservice inspection (PSI) None. 1 activities including work in progress, NDE procedures, and PSI data. I 85-15 6/3-14/85 Construction Team Inspection Three violations: j 7 of construction site manage- Seismic installation j ment, quality assurance, de- criteria for instrument j sign change program, electric tubes crossing a seis- i systems, instrumentation and mic boundary were not l control, mechanical and translated into instal-structural systems, and weld- lation specifications j ing and metallurgy. (Level IV, Supplement ' II). Two NCRs which docu- J mented installation I nonconformance of two i seirmic Category I l instrument installa- ' tions were not sub- ' mitted to engineering for processing (Level IV, Supplement II).
i i
*
- i Enclosure'4 28 I i
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Inspection- Dates / Number Inspection Enforcement Number of Inspectors Areas Actions l 85-15 Inadequate control of (CONTINUED) pipe support design and insta11ation'acti-vities (Level IV, sup- j plement II). '
~
Three licensee weak- I nesses: ! Instrumentation tubing program design. Design change program. Welder qualification records. Three licensee strengths: Site management. Site QA function. UE&C welding engineer-ing efforts. 85-16 5/28-31/85 Preoperational test witness- None. 1 ing, preoperational and ac- . ceptance test results evi.lu- , ation review, and QA inter- l tace. 85-17 5/27-7/5/85 Containment piping penetra- None. 2 tion. certifications, review and walkdown of EFW HVAC sys-
- tem, review of licensee docu-mentation concerning cold pull l
of piping in response to an l allegation. 85-18 6/10-14/85 Preoperational security pro- None. 2 gram review including secur-ity program audit, security plan and implementing proce-dures, reanagement effective-ness, and physical barriers (protected area). I i
Enelosure 4 29-Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas , Actions 85-19 7/1-26/85 Independent measurements in- None. 3 spection, using NRC mobile NDE laboratory, of safety re-lated piping, structural and support weldments fabricated to ASME Code, Section III, Classes 1, 2, and 3, and AWS Code D1.1 requirements. 85-20 7/8-8/27/85 I&C installation, piping and Two violations: 6 component. supports, fuel Inadequate design change building ventilation systems control and corrective and spent fuel rack erection, action on limit switch preoperational testing acti- bracket rework (Level vities, and operational IV, Supplemer.t II). readiness and testing activi-ties. Corrective action failure on DG pedestal cracking (Level IV, Supplement II). 85-21 7/8-12/85 Preoperational test witness- None. l ' I ing, preoperational test pro-cedure review and verifica-tion, preoperational test re-suits evaluation review, QA/ QC interface with preopera-tional test program and inde-pendent calculations /verifica-tions. 85-22 7/22-26/85 Testing of safety related None. I electrical equipment and IE Information Notice followup. l 85-23 8/5-8/85 Preoperational test witness- None. ) 3 ing, preoperational and ac-ceptance test results evalu-ation review, preoperational test program implementation. QA interface and independent calculations. 85-24 10/1-4/85 Operator licensing examina- N/A. 3 Examiners tions of five SRO candidates.
m
' Enclosure 4 30 Inspection Dates /hurber Inspection Enforcement
' Number of Inspectors Areas Actions 85-25 8/28-10/18/85- Pipe snubber and strut erec- One deviation: QA pro-4 tion, reactor vessel level gram requirements for indication system (RVLIS) in- tubing installation sta11ation, pressurizer power of RVLIS and RCS wide operated relief valve field range pressure trans-modification, installation of mitters were not com-spent fuel storage racks, mensurate with Reg.
boron concentration and-radi- Guide 1.97-requirements.- ation monitoring systems, preoperational test witness-l ing, hot functional testing procedures review, and diesel generator brush holder assem-bly supports. 85-26 9/23-27/85 .Preoperational test witness- None. 2 ing, preoperational test pro-cedure review and verifica-tion, preeperational and ac-ceptance test results evalu-ation review,. independent - verification, and QA inter-face. 85-27 10/15-18/85 Preoperational security pro- None. 2 gram review including secur-ity plan and implementing procedures, management ef-festiveness, security or-ganization, security program audit, physical' barriers (protected and vital areas), security system power supply,. ; i l access control (personnel),- 1 and training qualification plan. 85-28 10/15-17/85 Preoperational inspection of None. I radiation safety program in-cluding organization and I status of health physics, radioactive waste, chemistry and I&C departments. e
1 Enclosure 4 31 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas , Actions 85-29 11/4-8/85 Licensee programs for quali- None. I fication of electrical race- ~
. ways by testing and stress reconciliation of RCS piping (ASME Class 1).
85-30 10/28-11/27/85 Hot functional preoperational None. I 5 test witnessing and test pro-cedure review and verifica-tion, preoperational and ac-ceptance test results evalu-ation review, QA interface and independent verification. 85-31 10/21-12/6/85 Conduct of testing relative None. 7 to preoperational test pro-gram and hot functional tests. 85-32 12/9-13/85 Emergency prepareriness imple- None. , 7 mentation appraisal of emer-gency preparedness program
, including organization, ad-ministration, procedures, training, and facilities and equipment.
85-33 12/11-13/85 Fire protection program None. I readiness to receive fuel, including procedures, fire brigade and plant personnel training, and observations of work. 85-34 N/A. Inspection cancelled. N/A. 85-35 12/9/85- Work activities and testing None 1/31/86 relative to emergency and 3 startup feedwater systems redesign / rework,' fuel hand-ling and storage equipment /
' facilities and readiness for fuel receipt, fire protection,-
piping and isometric drawing controls, and followup of i event involving loss of shielding for boron concen-tration monitor.
- 4 Enclosure 4 32 i
^
Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 86-01 1/6-10/86 Preoperational test proce- None. 3 dures, preoperational test results evaluation review, test program review, indepen-dent verification, and QA/QC interface. 86-02 1/13-24/86 Preoperational test program None. 4 including procedures in areas of receipt, storage and hand-ling, records, document con-trol, surveillance testing and calibration, and test and measurement equipment. 86-03 1/27-31/86 Compliance with 10 CFR 50, None. 1 Inspector Appendix R, Sections III.G, 4 Others J, and 0 concerning fire pro-tection features to ensure ability to achieve and main-tain safe shutdown in event - of fire. 86-04 1/13-16/86 Implementing procedures for None. I 2 receipt of special nuclear material of low strategic significance and reoperation security program review in-ciuding physical security plan and implementing proce-dures, management effective-ness, and physical barriers (protected / vital areas). 86-05 1/27-2/7/86 Preoperational quality con- None. 2 trol, maintenance and testing program, preoperational test-procedures, maintenance and calibration results, Seabrook QA/QC inspections, safety re-view committees, and procure-ment control program. 86-06 2/10-28/86 Design changes and modifica- None. 3 tions, QA/QC interfaces, inde-pendent measurements, surveil-lance testing procedures and l maintenance work request pro- ' cedures. I
. . Enclosure 4 33 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 86-07 3/10-14/86 Quality assurance of the None 2 startup test program, main-
- tenance program, and test and
- experiments program.
86-08 2/5-6/85 Radiological protection pro- None. I gram's preparation for ini-tial fuel receipt. I 86-09 4/7-11/86 Preoperational review of None. 2 general and system operating procedures and QA interfaces. 86-10 2/24-28/86 Emergency preparedness in- None. 7 spection to observe the lic-ensee's first full scale emergency exercise performed on 2/26/86. 86-11 2/10-14/86 Preservice inspection activi- None. 2 ties including program and -- procedure reviews and obser-vation of field activities. 86-12 2/3-3/31/86 Containment enclosure venti- One violation: failure 4 lation system and solid rad- to provide sufficient waste system design and con- design for inclusion struction, preoperational of specific area of testing activities and test containment enclosure results evaluation, new fuel as part_of air space receipt inspection, and TMI ventilated by contain-Action Plan items. ment enclosure air handling system (Level IV, Supplement II). 86-13 1/20-24/86 Preoperational test proce- None. 1/25-31/86 dures, test witnessing, evalu-2/1-21/86 ation of test results of com-2/24-28/86 pleted tests, independent 2 verification and QA/QC inter-face for POT program. 86-14 3/10-21/86 As-built team inspection in Two violations: 6 areas of piping and pipe sup- Traceability was not ports, instrumentation and maintained for a ser-controls, components (valves, vice water valve and pumps, motors, heat exchan- diesel generator ven-h m_ _ . _ _ _ _ _ _ _ _ ___mm_____________m..__--__m.._-____-___-.__._ -_____.u_m .__ ___._ _ ___m - ,- ._ ._..-,_
i Enclosure 4 34 l Inspection Dates / Number Inspection Enforcement Number- of Inspectors Areas Actions , , 86-14 gers) and electrical power tilation fan motors (CONTINUED) supplies and distribution identification (Level systems. V, Supplement II). Work expanded beyond authorized scope of work request and fire penetration in diesel generator room not sealed properly (Level IV, Supplement II). 86-15 3/4-19/86 Procedure review, test wit- None. ( 3 nessing and preliminary re-sults evaluation of preopera-tional containment integrated leak rate test and structural integrity test. 86-16 3/17-21/86 Preoperational inspection of None. , 3 radiation protection program including organization and management controls, train-ing and qualifications, ex-ternal occupational exposure controls and personnel dosi-metry, internal exposure con-trol and assessment, control , of radioactive materials and contamination, surveys, moni-toring and maintaining occupa-tional exposures ALARA. 86-17 3/3-14/86 Preoperational test program None. ! 3 including test witnessing of preoperational tests, evalu-ation of test results of com-pleted tests, independent verification of test measure-ments, and QA/QC interfaces; and startup. test program ad-ministrative controls. 1 86-18 3/24-28/86 Emergency preparedness imple- None,but several pro-2 Inspectors mentation appaisal to evalu- gram areas identified
- - 3 Contractors ate adequacy and effective- which were incomplete ness of emergency prepared- or required corrective
~
. i I
Enclosure 4 35 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas . Actions 86-18 ness program for Seabrook I actions. (CONTINUED) including organization, ad-ministration, procedures,
' training, and facilities and equipment.
86 3/24-28/86 Preoperational test program None. 4/28-5/2/86 including test witnessing, 1 Inspector evaluation of test results, 1 Consultant independent verification of test measurements, and QA/ i QC interface. l 86-20 4/1-5/23/86 Work activities related to None. 6 waste process building and Lystems; primary auxiliary building, control building and RHR vaults turnover pre-paration; design and , con-struction; preoperational testing activities; train- -
, ing programs and TMI Action Plan items; previous find-ings; and techniques pro-posed for NDE examination of reactor coolant piping welds.
86-21 3/31-4/4/86 Resolution of previous in- None. 1 spection findings, including electrical and I&C construc-tion ceficiency reports fol-lowp actions. 86-22 5/5-30/86 Preoperational inspection of None. 5 chemistry, effluent controls and radioactive waste pro-grams including organization and management, training, i procedural development, facilities and equipment, liquid and gaseous radio-active waste systems; con- l i firmatory measurements, and ' non-radiological chemistry control. l i i l i
----_- ---_- _ _ l
'I,
' Enclosure 4 36 'I 4
i Inspection Dates / Number Inspection Enforcement Number of Inspectors ! Areas' Actions j j 86-23 4/14-18/86 Readiness.of QA program and None. 3 staff to. support plant opera- ' .tions including QA/QC organi-zation, QA/QC surveillance, j onsite operating and support staff, and non-licensed train-ing. 86-24 4/14-18/86 Licensee records re. lated to None. I reactor vessel and. internals I and licensee's activities re-lated to previous inspection findings. 85-25 5/5-9/86 Preoperational inspection of None.
- 3. ]
occupational radiation pro- .! tection program including i previous. findings, organi-zation and management con- ' trols, training and quali-fications, external expo- ~ sure control and personnel dosimetry, internal expo-sure control and assessment, control'of radioactive mate-rials and contamination, sur-veys and monitoring, facili-ties and equipment, and main-taining exposure ALARA. J 86-26 5/6-8/86 Initial inspection of nuclear None. I material control and account-ing including organization and operation, shipping and receiving, storage and in- , ternal control, inventory, l records and reports, and : management of material I control system. 86-27 5/5-16/86 Draft Technical Specifica- None, but several areas ! 2 Inspectors tions review to determine identified where clari-- , 3 Contractors whether draft TS and FSAR are fication of licensee { compatible with as-built position.or specifica- ; plant configuration and oper- tion correction re- ' ating characteristics and qui red.- whether draft TS are defi-nitely measurable. l
i
- J Edlosure 4 37 i I
l Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions j 86-28 5/12-22/86 Previous findings, CDRs, IE None. Some deficiencies 3 Circular, operating programs noted in procedures. - and procedures, licensee con-trol of NRC action items, 1 commitments and TS changes, and reactor engineering pro- ; cedures. ^ 86-29 5/12-15/86 Preoperational security pro- None. I gram review of previous find-
, ings.
86-30 6/E-13/66 Emergency preparedness imple- None. 3 mentation appraisal followup review. 86-31 6/2-6/86 Startup program and startup None. I test procedures. 86-32 5/20-22/86 Fire protection / prevention None. 1 program readiness to load - fuel including organization, control of combustible and ignition sources, equipment maintenance and test program, fire brigade training and QA audits. 86-33 6/2-6/86 Abnormal and emergency oper- None 2 ating procedures. 86-34 5/23-6/30/86 Licensee action on previous Report not issued. 8 findings and CORs, building turnover preparations and general design and construc-tion activities. 86-35 6/9-13/86 Chemistry, effluent controls None. 3 and radioactive waste pro-grams including water chemis-try control program, effluent measurement and control, pro-cess and effluent radiation monitor calibration, chemis-try program and preopera-tional and acceptance test-ing.
n
+ - ..
Enclosure 4 38 Inspection Dates / Number Inspection Enforcement f er.;.er of Insoectors Areas Actions 86-36 6/16-23/86 Previous findings, CDRs, IE None. 3 Circulars and Bulletins. 86-37 6/9-13/86 Preoperational test program None. 1 Inspector including test witnessing, 1 Consultant test procedures review, test results evaluation, test measurements independent verification, and test excep-I tions. 86-38 6/23-27/86 Preoperational inspection of None. 2 radiological environmental monitoring program including air, soil, and water environ-mental sampling and meteoro-logical monitoring program. 86-39 6/23-27/86 Preoperational radiation pro- None. 2 tection program review of previous findings. . 86-40 6/23-27/86 Preoperational test program None. I test exceptions and previous findings. 86-41 6/23-27/86 Preoperational security pro- None. I gram review of previous find-ings. 4 86-42 Inspection Cancelled. 86-43 7/7-11/86 Previous findings, CDRs, None. 3 IEBs, cable tray seismic qualifications, PSI program. 86-44 7/7-11/86 Previous findings of pre- None. 2 operational radiation protec-tion program. ~ 86-45 8/18-22/86 CDRs, electrical procedures, Report not issued. I design changes.
\.
I h_ ___m______________ _ _ _ _ _ _ ____.______.._m.__.-_ _ _ _ _ _ _..
i ATTACHMENT 7
# UNITE 3 STATES
=, g/ c- < a- \g NUCLEAR RE'2ULATORY COMMISSION CET.lON I [E g ; I
.]
u a 475 ALLEN 0 ALE ROAD 1
.f ximo or enues A.etwasvLvAw A senos
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NOV 2 21988 ) f MEMORANDUM FOR: Thomas E. Murley, Director Office of Nuclear Reactor Regulation FROM: William T. Russell, Regional Administrator j Region I SEABROOK STATION, UNIT 1 LOW POWER LICENSE RECOMMENDATION,
SUBJECT:
SUPPLEMENT 1 ! and l This memorandum provides an update -to the original Region I assessment i recommendation for issuance of a Low Power Operating License for Seabrook Sta-tion, Unit 1. That document was forwarded by memorandum from Region I to NRR l on October 9,1986. Subsequent to that recommendation a "zero power" license ! was issued to Seabrook Station, Unit 1 in accordance with 10 CFR 50.57(c) on October 17, 1986. The attached Initial Operating License Review Report Supple-i ment I addresses only those areas which required updated information. In the l absence of any updates, the original submittal should be considered to reflect . l I information that remains accurate as of this date. l l Region I continues to recommend that a Low Power License be issued for Seabrook Station Unit I with special note of the following- l
- 1. New Hampshire Yankee successfully loaded fuel and completed post core load hot functional testing with a minimum of difficulty.
- 2. Licensee operations pursuant to their "zero power" license have been con-ducted safely and without incident.
- 3. Regional staff review of the proposed Technical Specifications in conjunc-tion with your staff has revealed no significant issues requiring resolu-tion that are not being appropriately dispositioned.
- 4. Each Region 1 professional employee was requested by memorandum dated October 14, 1988, to identify any unaddressed safety concerns which he or she might have regarding Seabrook Unit 1. No concerns were identified.
- 5. This evaluation is based upon over 6,000 NRC field inspection hours since the last recommendation.
- 6. NRC investigation and inspection of recent allegations have identified no
- significant hardware impact and no unresolved safety issues.
- 7. NRC evaluation of the licensee Phase I Self Assessment which covered readiness to conduct heatup and low power testing, revealed no impediments to issuance of a low power license.
1 l
o NOV 221988 k Merorandum for Thomas E. Murley 2 O i 1
- 8. A review of outstanding inspection open items ' including NRC Bulletins indicates no technical issue which would preclude safe low power opera-tions. Licensee review of a recent problem at another nuclear facility ;
( involving Agastat 7000 series relays is ongoing. Should this issue reveal ' that safety impact is involved, additionc1 written updates will be pro-vided. In conclusion I find that Seabrook Unit I remains ready to conduct initial criticality and low power operations. O 1 William T. Russell l Regional Administrator l
\
Attachment:
Initial Operating License Review Report, Supplement I cc w/ attachment: V. Stell.o, EDO M. Johnson, EDO D. Crutchfield, NRR S. Varga, NRR - B. Beger, NRR R. Wessmari, NRR V. Nefses, NRR W. Kane, RI S. Collins, RI S. Ebneter, RI T. Martin, RI J. Wiggins, RI D. Haverkamp, RI J. Lyash, RI D. Ruscitto, SRI - Seabrook i' ( L
1
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.g i
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A'TTACHMENT INITIAL OPERATING LICENSE ~ REVIEW REPORT
' SUPPLEMENT 1 FOR SEABROOK STATION UNIT.1 DOCKET NO. 53-443 PREPARED BY UNITED STATES NUCLEAR REGULATORY COMMISSION;
. REGION I i
__._-_=____-__-___.--__ _ _ - - _ . 1- _
~.
s TABLE OF CONTENTS g I 1.0 Introduction.................................................... 2 2.0 Plant Status.................................................... 2 2.1 0verview................................................... 3 2.2 Chronology of Major Plant Milestones....................... Testing...................... 4 2.3 Post-Fuel Load Hot Functional 4 2.4 Cold Shutdown Activities................................... !- 4 l 3.0 Facility Construction........................................... 4 3.1 Overview and Status........................................ 5 3.2 Design Changes............................................. 5 3.2.1 Control Building Air Handling System. . . . . . . . . . . . Containment Building Spray System................ .5 , 3.2.2 Post Accident Sampling Systems................... 5
- 3.2.3 6
3.3 Construction Deficiency Reports and 10 CFR 21 Reports...... 6 1 3.3.1 Service Water Va1ves.............................. 6 3.3.2 Emergency Feedwater System....................... . 1 Containment Equipment Hatch Personnel Airlock.... 6 i 3.3.3 7 3.3.4 Gould Type J-10 Re1ays........................... 7 3.4 Allegation Status.......................................... Employee's Legal Project...........-.............. -7 3.4.1 As-Built Piping Di screpancies . . . . . . . . . . . . . . . . . . . . 9 3.4.2 Alcohol and Drug 9 3.4.3 Concerns.......................... 10 3.5 NRC Bu11etins.............................................. 10 3.6 Conclusions................................................ 1 L_____---_-_--._,_______- . _- _ - _ _ - . _ - _h--...-.._.L_._ - _. - - , . - - _ _ . _ _ ._._a-._-_ - - - _ . . _ - - - - . _ _ _ . _ _
t-5
- Table of Contents (Continued) 9
.P. aJL' 10 4.0 Facility Testing................................................
10 4.1 Summary and 0verview....................................... 11 4.2 Startup Testing............................................ 11 4.3 Conclusions................................................ 11 5.0 Operational Readiness........................................... 11 5.1 Summary and 0verview....................................... 12 5.2 Plant
~
0perations........................................... 12 5.2.1 Conduct of Operation.............................. 12 5.2.2 Organization and Staffing........................ 5.3 Operator Licensing Examinations and Licensed 13 Operator Training........................................ 13 5.4 Maintenance and Surveillance............................... 14 5.5 Radiological Controls and Chemistry........................ 14 5.6 Emergency Preparedness..................................... 14 5.7 Security........................,........................... 14 5.8 Engineering and Technical Support.......................... 15 5.9 Quality Assurance.......................................... 15 5.10 Conclusions................................................ 15 6.0 NRC Inspection Program Hi story and Findings. . . . . . . . . . . . . . . . . . . . . 15 6.1 Routine Inspection Activities.............................. Inspecti on Program Status. . . . . . . . . . . . . . . . . . . . . . . . 15 6.1.1 15 6.1.1.1 MC 2512 Program........................ 16 6.1.1.2 MC 2513 Program........................ 16 6.1.1.3 MC 2514 Program........................ 17 6.1.1.4 MC 2515 Program........................ 11 l ___.,_____n_ ..m____ _ _ . _ _ . _ _ _ _ _
i k 6
. Table of Contents (Continued)
P,.agt 17 6.1.2 Team Inspections................................. 6.1.2.1 Allegation Team - November,1986. . . . . . . 18 ATWS Team - December, 1986............. 18 6.1.2.2 Allegation Team - April /May, 1987...... 18 6.1.2.3 i t 19 1 6.1.2.4 EP Exercise Team - December,1987. . . . . . EP Exercise Team - June, 1988. . . . . . . . . . 19 6.1.2.5 6.1.2.6 SAT Evaluation Team - October / November, 1988....................... 19 f 20 6.2 Enforcement History........................................ 20 7.0 NRC Evaluation of Licensee Self Asses sment. . . . . . . . . . . . . . . .. . . . . . . 20 8.0 Financial Qualifications........................................ 20 8.1 Background................................................. L
*************** 21 '
{. 8.2 Conclusions..................... - 21 l 9.0 Future NRC Region I Actions..................................... 21 10.0 Overall Conclusion.............................................. l ENCLO'SURES Enclosure 1 - Inspection Summary
- Enclosure 2 - Enforcement History Enclosure 3 - NRC Bulletin Summary Enclosure 4 - Summary of SALP Evaluations Enclosure 5 - Review of New Hampshire Yankee Operational Readiness Self-Assessment 1
1 iii
- _ _ _ _ _ . _ _ _ _ _ . . _ . _ _ . _ x. - - - - - _ _S__.._. .___-_w._ _ - - - - _ a_--.h-_._________a
1.0 Introduction Public Service Company of New Hampshire (PSNH) applied for. a license to construct.and operate Seabrook Unit 1 (DN 50-443) on July 9,1973, and was issued a Construction Permit (CPPR-135) on July 7,1976. Unit 1 is a Westinghouse four-loop pressurized water reactor, rated at 1198 MWe which
'is housed in a reinforced concrete containment structure. It is located in the town of Seabrook, Rockingham County, New Hampshire, along with Unit 2,. a similarly designed reactor, currently 25% complete with constru'ction halted. The construction permit.for Unit 2 expired on October 31, 1988.and
.the Joint Owners have indicated that they have no intention of completing the project. The units are arranged using a " slide-along" concept with certain structures common to both units.
United Engineers and Constructors served as the architect / engineer - and construction manager. PSNH.has contracted with the Yankee Atomic Electric Company for specific services, including project . engineering, licensing, fuel supply and the establishment and implementation of the Quality Assur-ance Program for design and construction. YAEC will also provide engi-neering services necessary to support the operation of Seabrook Unit 1. On June 23, 1984, an organizational change was made to create the New Hampshire Yankee (NHY) Division of PSNH with the primary responsibility for construction, startup and operation . of Seabrook. This followed a temporary suspension of construction activities, initiated on April 18, 1984 due to financial pressures on PSNH. Other organizational changes , released several contractors from the Seabrook project, replacing them with UE&C as the " direct employment" constructor. Other major construc-tion work stoppages occurred in February,1977 and July,1978 when the NRC-suspended the construction permit because of questions regarding the cir-l culating water tunnels and the' lack of EPA approval for this cooling sys- ! tem. PSNH once again faced financial difficulties in 1987 and filed for 4 protection with the U.S. Bankruptcy Court in Manchester, N.H. on Janu-ary 28,1988. The Massachusetts Municipal Wholesale ' Electric Company (MMWEC), an eleven percent owner, stopped paying its project share in June,1988 and negotiations are presently underway to provide' alternative , financing. During this time period, project funding has continued at l 1evels equal to that available prior to bankruptcy. ! NRC Region I began performing inspections at Seabrook in 1973 and has completed over 250 inspections totalling over 26,000 hours. These inspec-tions involved observation of work in progress, examination of completed ! work, review of work control documents, independent measurements 'and ,
, calculations and the examination of quality records, as well as review of I operations, maintenance, surveillance, security, emergency preparedness and health physics activities.
l _ _ _ _ - _ _ _ _ _ _ - _ _ = _ .
O 2
. TbIsireport describes the process used by the' licensee to monitor 'an'd con'-
trol the quaHty of construction, testipg apd operations. Also4&scus ,ed ' . ., are the restr1Q"of the licensee's Self Assessment,' and the Systematic Assessment of Licensee Performance (SALP) program conducted 'by NRC Region I. - - During heatup and approach to criticality, Region I will conduct.a Readt-ness Assessment Team Inspection to evaluate licensee performance and con-formance to license conditions and Technical Specifications. This assess- , ment will focus on activities in the areas of operations, maintenance, ! surveillance, engineering and technical support, radiation protecti on', I radwaste, environmental monitoring, chemistry, management effectiveness I and quality assurance. l 1 This report supplements the previous report which presented the basis for the Region I conclusion that (1) Seabrook Unit I has been constructed sub- l stantially in accordance with Construction Permit CPPR-135, the Final ! Safety Analysis Report and NRC regulations; and (2) New Hampshire Yankee, as a division of PSNH, is ready to safely operate the' facility. 2.0 Plant Status 2.1 Overview Construction of Seabrook Unit 1 is essentially complete. All build-ings, systems, and equipment have been turned over to the station '! staff. Some construction completion activities such as painting and yard paving remain to be finished. Preoperational testing activities l
- are complete. The majority of zero power startup testing has been completed with the major exception of the emergency feedwater system.
During the course of NRC inspection and investigation activities at Seabrook Unit I since 1973, over 1,000 inspection items requiring tracking and follow-up have been opened. These _ items include en-forcement actions and ellegation follow-up activities, as documented-in other sections of this report; NRC Bulletins, Circulars, Infor-mation Notices, and Generic Letters; temporary instructions; 10 CFR 21 reports, licensee event reports and construction deficiency re-ports; TMI action plan items; and, unresolved issues and program weaknesses identified by special team inspections. Approximately 50 of these NRC inspection items currently remain open,- the other items have been closed in NRC inspection or investigation reports, as appropriate. The status of outstanding items is continually being assessed and updated as Region I inspection activities continue. At this time, no open inspection item, currently outstanding, is deemed to be of such significance as to affect the Region I recommendation for issuance of a low power license. An item currently under evalua-tion by the licensee involves the seismic qualification of Agastat e
3 7000 series time delay relays. This problem was identified at an-other facility. Licensee staff has placed a high priority on re-solving this issue. A written followup to this report will be pro-vided if this issue is not resolved prior to low power license issuance. In terms of readiness for operation, no major impediments to the low l power license issuance have been identified. Procedural preparation l - and validation and consistency review continue and it is anticipated that all procedures required for a particular mode of operation will be approved and issued prior to the plant entering that mode. l During the period covered by this supplement, a major transition occurred as construction and preoperational testing was completed and startup testing and operations under the technical specifications-(TS) and license conditions commenced. 2.2 Chronology of Major plant Milestones October 17, 1986 Facility Operating License NPF-56 issued for Sea-brook Station, Unit I authorizing fuel loading and precriticality testing. October 22, 1986 Mode 6 entered as fuel loading commenced. October 29, 1986 Fuel loading completed.
'- November 5,1986 Mode 5 entered as reactor vessel head tensioned.
February 10, 1987 Heatup commenced and Mode 4 entered as plant tem-perature reached 200 degrees F. February 11, 1987 Unusual Event declared due to containment equip-ment hatch airlock malfunction and immediately terminated.
- February 15, 1987 Mode 3 entered as plant temperature reached 350 -
degrees F. l February 16, 1987 Plant achieves normal operating temperature and pressure. Post-core load hot functional testing l begins. February 26, 1987 Two steam generator safety valves lift during testing of the emergency feedwater system as a l_ result of a pressure transient. 1 a- .---____2_ ___x-
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4 - March 20, 1987 Post-core load hot functional te' sting completed. Cooldown commenced and Mode 4 entered as plant temperature fasis below 350 degrees F. Cold
. shutdown is achieved as plant temperature falls below 200 degrees F. - -
, . . 6 2.3 post-Fuel Lead Hot Functional Testing On October 17, 1986, a Facility Operating License was issued for Seabrook Station Unit 1. Specific license conditions limited activ-ities to "zero power" operation and precriticality testing but did allow the licensee to load fuel and conduct hot operations in Mode 3 in accordance with the Technical Specifications. Initial fuel load was conducted during the period October 22-29, 1986.
plant heat-up for the conduct of the precritical phase of hot func-tional_ testing (HFT) commenced on February 9, 1987. This testing included those pre-operational tests for which additional startup testing was required. The most notable of these was testing on the steam-driven EFW pump because major design modifications had been implemented for this system since the previous HFT in December,1985 (refer to paragraph 3.3.2). Plant cool-down from hot operations was initiated on March 19, 1987. 2.4 Cold Shutdown Activities , l The plant has remained in Mode 5, cold shutdown since the March, 1987 cooldown. Plant temperature has been maintained between 110 degrees l F and 140 degrees F with the primary system depressurized. Major maintenance and/or modification activities were conducted on both primary and secondary systems. The plant also conducted reactor coolant system mid-loop testing related to Generic Letter 87-12. Other significant testing activ-ities involved fastener testing per NRC Bulletin 87-02 and hardness testing of flanges and fittings per NRC Bulletin 88-05. No major safety significant events occurred while operating in Mode 5 although an Unusual Event was declared during heatup when equaliz-ing valves malfunctioned on the containment equipment hatch personnel airlock (refer to paragraph 3.3.3). 3.0 Facility Construction 3.1 Overview and Status The construction of Seabrook Unit 1 is essentially complete. Paint- , ing in the turbine building and paving of the yard inside the pro- j tected area fence remain to be completed. Minor construction items remain and are identified on the construction " punch list." None of i L___ A? h ax'a--
- ? - - - - . _ . - .
e 5 the above items has impact 'on ' low power operations. Several design changes are in progress in the plant. These changes are routine for a plant in an outage condition and none are considered to be low power limiting. .The status of several significant design changes, 10 CFR 21 and 10 CFR 50.55(e) reports, and NRC Bulletins is described below. The status of the most significant construction related alle-gations is also summarized below. , 3.2 Design Changes Several significant safety-related system design changes arc in progress or awaiting plant milestones for implementation. 3.2.1 Control Building Air (CBA) Handling System The control building air handling system was redesigned following NRC identification that the system 'was suscep-tible to a single electrical train failure. Licensee an-alysis of plant operation with the current configuration was reviewed in Seabrook Safety Evaluation Report, Supple-ment No. 7 (SSER-7). It was determined that the present design. was adequate for 1cw power operation. The system must be modified prior to issuance of a full power license. The current status of the design change' is .that the . new filter unit and fan are mounted on their foundation. The cross-tie piping to the other existing filter unit is com- , plete up to the connection point. No other work is to be completed until after low power testing because such work would make the system inoperable. 3.2.2 Containment Building Spray (CBS) System ' It was determined that the CBS system suction piping was i not designed to withstand system pressures under all an-l alyzed conditions. The licensee subsequently committed to modify the design. In the interim, a thermocouple moni-toring system was installed to alert operators of check valve leakage which could eventually cause overpressuriza-tion. This issue was reviewed in SSER-7. As long-term action, the licensee intends to add four motor operated valves to the subject piping prior to the first refueling outage. 3.2.3 post Accident Sampling System (PASS) The PASS has undergone design modifications to allow improved sample temperature control. Since there is not yet any coolant activity level, the PASS has not been demonstrated, however dilution factor testing will be
6 .
. . . conducted on heatup using boron concentration as a moni-tored parameter. The PASS is not required for low power operations.
3.3 Construction Deficiency and 10 CFR 21 Reports To date at Seabrook, the licensee has submitted 106 Construction Deficiency Reports (CDR). Of these, subsequent licensee evaluation - determined that 17 items were not reportable and the applicable CDR's were withdrawn. Only one CDR remains open concerning the emergency i feedwater system and it" will be addressed during the heatup prior to initial criticality (refer to paragraph 3.3.2). l 3.3.1 Service Water Valves This 10 CFR 21 report, submitted in July,1987 described ) problems with the liners of Fischer Controls butterfly valves. Licensee corrective action included modifying the seats of the valves installed in cr.itical locations. Final NRC closure of this item was reported in NRC:RI Inspection Report 50-443/88-10. 3.3.2 Emergency Feedwater System (EFW) This 10 CFR 50.55(e) final report was made in May, 1986 and , concerned the inability of the EFW system to provide the design flow rate due to the configuration of the recircu-
. lation lines. The lines were subsequently modified. Dur-ing post-core load hot functional testing in February, 1987 the EFW turbine driven pump continued to experience prob-l 1 ems in starting and achieving rated flow in the required time period. Licensee modifications allowed completion of startup test ST-53; however, full functionality of the EFW ,
system was never demonstrated. The system redesign was 1 evaluated in SSER-4. During .heatup prior to initial crit- I icality, a new test procedure (STP-101) will be performed. This test will include five cold starts of the system which were not previously demonstrated due to leaking steam sup-ply valves. Other system performance criteria will also be ! evaluated. 3.3.3 Containment Equipment Hatch Personnel Airlock l
. On February 11, 1987, an Unusual Event was declared and promptly terminated because of a condition requiring plant -i shutdown. This condition involved the Technical Specifica- -
tion for containment integrity which could not be met due i I to a failure of the equalizing valves in the linkages for the personnel airlock in the containment equipment hatch. In April, 1987 NHY reported this linkage failure as a 10
- i e
4 ___.______m___ m.m___
a i 7 CFR 21 report, described the redesign of the faulty link-ages and indicated completion of all modifications. To date, the. linkages have performed satisfactorily. 3.3.4 Gould Type J-10 Relays Telemecanique (formerly Gould), the manufacturer of the type J-10 relays, reported a defect in accordance with
'10 CFR 21 in October,1987. The defect involved overheat-ing of a special magnet coil used in_ the Seabrook design..
NHY replaced the 57 relays installed in safety-related applications. This item was closed in NRC:RI Inspection Report 50-443/88-10. 3.4 A11ecation Status 3.4.1 Employee's Lecal Project The NRC Region I Office contacted the Employee's Legal Project (ELP), a nonprofit organization, on August 4,1986, regarding allegations of questionable construction prac-tices at New England nuclear power plants. The NRC became aware in the May-July,1986 time frame of the ELP and their efforts to gather previous nuclear power plant employee concerns. Subsequently, the NRC acquired an unsigned let- - ter to the Governor of the Commonwealth 'of Massachusetts ' from the ELP, dated September 12, 1986, containing two anonymous affidavits and thirty-five allegations related to plant construction and management controls at the Seabrook facility. Further contact with the ELP resulted in ten additional allegations. The several allegation sources were consolidated by the NRC and each allegation was re- ' viewed separately, although it may have resulted in dup- i licate allegations. This was done to preclude any issues f rom being overlooked. This resulted in sixty-one separate allegations. The allegations were grouped into seven j categories as follows: concrete, piping and welding, i painting, pr,ocedures and training, security and drugs, l electrical and management. 1 An interdisciplinary inspection team ' was established to ! investigate the allegations. The inspection was' conducted ! in November,-1986. Plant hardware was inspected and inde- I pendent tests performed where possible to evaluate each ! allegation. In some cases' the previous record of inspec- i tion.had documented the allegation _ and in these cases the ! record was reviewed and corrective actions verified. Inter-views were conducted of allegers and plant staff to aid in i the inspection. The bases for any conclusions are derived L l
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from anWaspection of the actual item or area if known and accessible, previous NRC inspections of the issue, estab-lished engineering knowledge and quality assurance records. The inspection, in many instances, disclosed that previous knowledge of the,,, alleged condition was identified by the NRC or the licensee and documented in - quahty assurance records, NRC inspection reports or formal correspondence between the licensee and the NRC. Thirteen of the allega-tions were ' substantiated in that the statement made by the a11eger was accurate; however, eleven of these allegations were previously. identified by the NRC or the licensee and were appropriately dispositioned. The remainder of the allegations could not be substantiated, but in all cases, even if the event had occurred, there would have been no nuclear safety significance. The results of this first inspection are contained in NRC:RI Inspection Report 50-443/86-52. Subsequently, the ELP reviewed and commented on the 86-52 report, raised technical questions and comments concerning the contents of the report and, in some cases, provided new information regarding the original allegations. The in-spection team was reconstituted and additional inspections were performed onsite during April and May, 1987. The NRC staff met with the ELP and some of the allegers on April 20, 1987, to gather additional detailed information concerning - l the technical issues. During the interview, the ELP pre-sented a document to the inspection team containing new allegations. Based on the new information, the team was able to more accurately identify the specific areas of concern relative to the original allegations. The team determined that the allegations that were previously in-spected remained as originally characterized and did not represent a safety concern. The remaining allegations could not be substantiated. The new allegations also could not be sub'stantiated' as valid technical issues of which the licensee was not previously aware and addressing. The second report published in August, 1987 (50-443/87-07) contains two unresolved items that will receive further attention. One item deals with the long-term effects of ground water on the reinforcing steel and the licensee's l program to monitor the condition of the structures affec-ted. The second issue is an in-depth review of the con-crete cracks in structures such as the waste process build-ing and the cooling towers. Neither of these items pre-sents an immediate concern to the operation of the facility. 1 I c= .__ ___ . - - . -_ - _. - - _ _ _ _ _ - _
I
. 9 3.4.2 As-Built piping Discrepancies
)
The Region I Office was notified by Region III of an alle-gation involving as-built drawings of safety-related piping systems at the Seabrook Station. The Region III staff was 2 j informed of the allegation while conducting an interview j with personnel from Computerized Interference Elimination ' (CIE), a former contractor to New Hampshire Yankee (NHY), ; regarding alleged discrepancies in as-built drawings of ; piping systems in Units 1 & 2 of Byron Station. Two Region I engineers traveled to Redmond, Washington on October 21, 1986, to interview the two principal allegers from CIE. The allegers identified certain concerns regard-ing the existence of discrepancies in as-built drawings of safety-related piping systems designed by Westinghouse and United Engineers and Constructors at the Seabrook Station. The allegation primarily dealt with concerns over the ac-curacy of the measurements provided on the drawings and the impact on the adequacy of the licensee pipe stress recon-ciliation efforts. It also referenced other design activ-ities which would potentially be affected as a result of using input data from as-built drawings containing dis-crepancies. An inspection was conducted in November,1986 to evaluate the alleged discrepancies. Based 'on independent measure-ments of selected piping system dimensions and evaluation of the pipe stress reconciliation, building beam verifica-tion, ' seismic II/I and failure mode and effects analysis programs, the allegation was found to be unsubstantiated. ' 3.4.3 Alcohol and Drug Concerns i l In response to a letter dated January 28, 1988, to Chair-man Zech from Congressman Edward J. Markey, regarding an investigation that he initiated on October 28, 1986, into allegations of widespread drug and alcohol abuse at Sea-brook, the NRC staff conducted an independent multidis-q ciplinary review of the Congressman's concerns. The review j team included Region I and NRR personnel, and an independ- j l l ent but related effort was conducted by the NRC Office of I Investigation (01) and 01:RI personnel. The review team f concluded that the Congressman's investigative efforts and the licensee's responses to the alleged drug and alcohol ( concerns identified no deficiencies or safety concerns that would impact or alter the NRC staff's previous conclusions regarding the adequacy of construction of Seabrook Station Unit 1.
4
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10 3.5 NRC Bulletins A review of NRC Bulletins was conducted to ensure that no issues which remain outstanding could adversely impact low power operations. A summary of bulletin status is listed in Enclosure 3. Six bulletins-remain open. Licensee responses have been made to four of- these. Responses to the other two are not yet due. Licensee action on each Bulletin is well directed and none of the open issues affect plant startup. i 3.6 Conclusions Regarding design changes, the licensee has submitted and the NRC approved actions to address concerns with the CBA and CBS systems. Both systems are considered adequate as presently designed and installed to-fulfill all requirements up to 5% power. The PASS will be tested to the extent possible prior to the existence of coolant activity and is not required at low power. With respect to construction deficiency reports, reports of defects per 10 CFR 21 and NRC Bulletins, Region I has determined that no technical issues exist which would preclude issuance of a low power license. The emergency feedwater system, while not completely proven, has demonstrated the ability to operate under normal condi-tions. Special test procedure STP-101 will ensure that the system is fully operable prior to initial criticality. , With respect to allegations at Seabrook involving both technical and Fitness for Duty concerns, no issues remain open which would indicate . any adverse impact on issuance of a low power license. Region I concludes that facility construction is essentially com-plete, is essentially in accordance with the Final Safety Analysis Report. The plant is ready to undergo initial criticality and low power testing. 4.0 Facility Testing 4.1 Summary and Overview The preoperational test program began in September,1983 and is com-plete. The startup test program is partially completed. Following fuel loading in October, 1986, the plant heatup commenced on February 10, 1987. During this post-core load hot functional testing (HFT) period, all required startup tests were completed. Plant cool-down was commenced on March 19, 1987. O
-.i_-_--__-n
c. 11 i 4.2 Startup Testing T_he first two phases of startup testing, initial fuel loading and pre-critical testing .were accomplished in late 1986 and early 1987. Significant ' testing completed to date includes fuel loading and source installation, reactor coolant system flow, leakage and thermal expansion tests, instrumentation testing, rod control and nuclear instrumentation testing and retesting of those preoperational tests which were not completed - during the previous HFT. Two notable exceptions remain unresolved. The startup testing for the emergency feedwater system (ST-53) experienced additional problems. The start-up test was completed; however, further testing to prove operability and system functionality will be performed on the next heatup (refer to paragraph 3.3.2). The steam generator blowdown test (ST-54) was also completed; however,_ the blowdown flow instrumentation experi-enced accuracy fluctuations and will also be retested on the next f heatup. This testing will involve data taking to determine what q additional changes, if any, are necessary. The system is presently capable of providing blowdown of the steam generators. During the extended layup period, seconcary systems were chemically treated, drained and maintained in a de-humidified atmosphere. Licen-see preparations for heatup are underway and secondary systems are 1 being made ready to support startup testing. 4.3 Conclusions l preoperational testing . is complete, startup testing has been com-l pleted satisfactorily up to the point of initial criticality. All items requiring retest on heatup are properly documented, tracked and ; l scheduled for completion. The startup test program is ready to be ! continued with initial criticality and low power testing. 5.0 Operational Readir.ess 5.1 Summary and Overview I With the exception of the six week post-core load hot functional testing period in early 1987, the plant has been operated in Mode 5, l - Cold Shutdown, with primary temperatures between 110 degrees F and j 140 degrees F. The pressurizer has been vented and one residual heat removal (RHR) pump is normally operating to maintain boron concen-tration mixing. The zero power license. issued under 10 CFR 50.57(c) i includes license conditions which ensure that the 2100 ppm boron ! concentration in the reactor coolant system (RCS) cannot be diluted. Operation is in accordance with Technical Specifications which in Mode 5 provide substantial flexibility to allow major maintenance and ; modification work to be performed. J l l
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{ 12-Fuel loading was conducted professionally, safely and without inci-dent. The declaration of an Unusual' Event based upon. leaking con-tainment equipment hatch personne1~' airlock valves resulted from a communications problem but had minimal safety impact. The affected vaTve linkages have been redesigned (refer to paragraph 3.3.3). The eighth Seabrook Systematic Assessment of Licensee Performance (SALP) report covered '.the - period between April 1, 1986 and July 31, 1987. The findings of that report are summarized in . each l functional' area below along with a current status. The eighth SALP report is generally. favorable describing : a licensee-with strong man-agement focus and effective programs. : A comparison of the seventh ! l and eighth .SALP report ratings is included in Enclosure 4. The l transition from construction to operation has" been effective, although the long shutdown period has provided few operational challenges. a' 5.2 plant Operations 5.2.1 Conduct of Operations I Routine plant operations continue to be conducted in ac- J cordance with the highest standards of professionalism. ! In spite of a two year cold shutdown mode of operation, the j vigilance of the operators- has never lessened. The opera- i tors are knowledgeable in their duties and conservative in ' their interpretation of Technical Specifications and License Conditions'. Occasional: errors, partly attributable to procedural weakness have occurred. The RHR/RCS mid loop test was performed without incident. Several reporting errors including the failure ,to notify the Commonwealth of ' Massachusetts of the Unusual Event, diesel failures and IE/non-1E problems have occurred , but are not considered pro,.rammatic. The department has re-duced the number of. inadvertent ESF actuations. ' Program-matic areas of. weakness previously identified such as tag-ging, independent verification, temporary modifications and locked valves have been' adequately addressed. 5.2.2 Organization'and Staffino l New personnel promoted to positions of responsibility with' - in the department are responsive to NRC concerns. Recent organizational changes have added a work control organiza-
- tion consisting of an additional Unit Shift Supervisor (referred to as the Work Control Supervisor), senior con-trol room operator and. auxiliary , operator to the control room. This small team will coordinate tagging and work
, control on day shifts. In addition, a Day Shift Superin-tendent position was created and staffed with a senior
13 shift superintendent who reports to th.e Assistant Opera-tions Manager and coordinates planning and scheduling of plant activities with other departments. These dedicated staff positions are expected to enhance the work control function as well as free the on-shift operators of a pre-viously burdensome administrative work load. 5.3 Operator Licensino Examinations and Licensed Operator Trainino A summary of operator licensing examinations administered since the last recommendation for license issuance is given belov. It may be noted that the station continues to achieve a high pass rate, indi-cative of a high quality training program which incorporates trainin, on the site-specific simulator. The Seabrook requalification program has been fully implemented and integrated into the six shift rotation. Thirty-eight individuals hold senior reactor operator (SRO) licenses, twenty-three of whom are involved in plant operations. Nine individuals hold reactor operator (RO) licenses, eight of whom are involved in plant operations. Fi f-teen of the SR0s are qualified as shift technical advisors. Examination Date No. of Candidates Results August, 1987 13 SRO Candidates 13 Passed 7 R0 Candidates 6 Passed , January, 1988 1 R0 Retake 1 Passed
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5.4 Maintenance and Surveillance The plant operational configuration has allowed for major maintenance - activities to be accomplished when necessary.~ Major corrective main-tenance was conducted on the RHR pumps, emergency diesel generators, circulating water pumps, service water valves and piping and the pri-mary and secondary component cooling water hett exchangers. Major component repairs were conducted on Elgar inverters, Veritrak/Tobar transmitters, Gamma-Metrics nuclear instrument cables, Gould J-10 relays and Westinghouse D5-416 reactor trip broders. Significant NRC Bulletin responses were made related to substandard flanges and fasteners. Integrattd planning and scheduling activities remain a strength and to date no significant maintenance related failures have occurred. The surveillance program, fully implemented with issuance of the Technical Significations, has been relatively trouble free with only minor errors resulting in missed or overdue surveillance. The licensee's failure to report diesel failures, previously identified -_____-________-___2_ . -_
14 as symptomatic of a programmatic weakness, has been corrected. Sur-veillance activities in preparation for plant heatup - continue and Mode 2 surveillance'is on track. 5.5 Radiological controls and Chemistry The radiological controlled area at Seabrook was recently re-estab-11shed for training and familiarization purposes. During the fuel loading evolution, the radiological protection staff. demonstrated an aggressive program geared toward commercial operation. No incidents of. significance occurred during source installation and. fuel _ loading. The health physics _ department appears ready for low power testing. The chemistry laboratory has been in operation during the zero power i l licensa period. The department is aggressive in ensuring compliance with appropriate standards. 5.6 Emergency Preparedness Onsite emergency preparedness (EP) readiness is ~ considered to be adequate with respect to' 5% operation, however, Region I is aware of certain hearing board activities related to 1988 EP Annual Exercise weaknesses which were closed for inspection purposes in NRC:RI In-spection Report 50-443/88-10. This exercise was conducted in June, 1988 and no deficiencies were noted. . It is expected that' FEMA will. provide NRC with a consolidated finding on offsite. plans _in the near ' future.
- 5. 7- Security i
The NHY Physical Security Plan has been fully implemented for about two years. The result is a program with substantially greater maturity than most at the low power licensing stage. 5.8 Engineering and Technical Support 1 I Since the previous recommendation,: this area has undergone signifi-cant evolution. The NHY. corporate engineering staff .is located on-site and reports to the Vice-President, Engineering, Licensing and Quality Programs. The technical support staff is a station depart-ment and reports to the Vice-President, Nuclear Production via the Station Manager. As evidenced by a Category 2. rating, in the eighth SALP report, the corporate engineering program demonstrated / weak-nesses in several areas.' A concerted effort.to zimprove has been noted and liaison between corporate engineering and technical support engineers has improved as. has the quality, timeliness and offec-tiveness of the overall engineering product. Licensee technical support engineering remains a strength utilizing the system engineer
. 1
15 concept. This overall engineering organization will be able to meet station needs provided staffing by experienced personnel remains adequate. 5.9 Quality Assurance The eighth SALP report rated quality assurance (QA) as Category 2. Little has changed since that time. Although the QA organization has made efforts to become more pro-active in their role, they are still program oriented. In this respect, they effectively schedule, per-form and track inspections, audits and surveillance. They appear somewhat reluctant to expand upon station or NRC identified areas of potential weakness. Detailed QA involvement in the startup program was not in evidence until NRC concerns were raised. Presently, QA involvement in the startup program is under evaluation. 5.10 Conclusion An analysis of recent licensee performance by functional area reveals generally mature programs with strong management involvement with the exception of quality assurance (QA). Areas of weakness have been aggressively addressed and corrected. In the QA area the level of performance is acceptable but not equivalent to the high licensee standards found in all other programs. The station staff and support organizations are ready to receive and utilize a low power license. - 6.0 NRC Inspection Program History and Findings Since the original submittal of this recommendation in October, 1986, forty-nine inspections totalling 6059 hours have been conducted. Enclosure 1 summarizes these inspections. 6.1 Routine Inspection Activities Routine inspection activities are coordinated by the resident in-spectors. The inspection programs require both resident and regional specialist inspection. Additionally, team inspections are conducted to provide reactive or pr2 planned focus on one or several specific issues. 6.1.1 Inspection Program Status 1 The status and overall findings of the sequential NRC In-spection hanual Chapter (MC) 2500 series inspection pro-grams are given in the following paragraphs. 6.1.1.1 MC 2512 procram: Region I inspections of con-struction activities at Seabrook have, in the past, been conducted in accordance with the pro-gram established by the Office of Inspection
,______,.____._w._._ . _ . - - - - - - ^' "
26 and Enforcement. The objective of these safety inspections was to obtain sufficient information through direct observation in the field, per-sonnel interviews, and review of procedures and records to determine whether construction and installation of safety-related components, structures and systems met applicable require-ments. The Construction Inspection Program at Seabrook has been completed. 6.1.1.2 MC 2513 Program: During the pre-operational testing period, two resident inspectors were assigned to the site with a third entry level inspector / trainee assigned until July, 1986. Region I specialist inspectors provided signif-icant coverage including test procedure reviews, test witnessing and test results evaluation. Operational readiness was inspected by regional and resident personnel. Staffing, programs and procedures were evaluated. The Pre-operational Phase Inspection Program per MC 2513 was com-pleted in early 1987. 6.1.1.3 MC 2514 Program: Two resident inspectors were assigned to the site during the fuel loading and precritical testing time frame. Currently, one - Senior Resident Inspector with over three years experience at Seabrook is assigned to the site. Additional resident office coverage has been maintained with periodic assignments of regional inspectors to the site for periods of from one to six weeks. The Startup Inspection Program is up to date with respect to current plant status. Inspection of initial fuel loading and precriti-cal (post core load) tests is complete. Proced-ure reviews required for initial criticality and low power tests are also complete. By memorandum dated April 20,1987 (Kane to Murley), the Sea-brook Startup Test Program Category I tests to be witnessed were identified. The selection of Group A and selected Group B tests was supported by the PRA recommendations of the Region I/EG&G study completed in March,1986. NRC resident and specialist inspector coverage of the startup activities completed to date reveal only two anomalies. The EFW system test, ST-53 has been satisfactorily completed, however, certain NRC and licensee concerns remain. These issues are to be addressed by accomplishment of special test
27 procedure STP-101 which is scheduled to be con-ducted during heatup prior to initial critical-ity. The steam generator blowdown system test ST-54 is also completed, however, erratic flow indication at low flow rates will require addi-tional analysis of data obtained during the next heatup. The 11cansee preparation of the startup testing procedures -was excellent. All 56 startup test procedures were finalized in a timely manner. They were well written and received adequate review and approval. Fuel load and post-core load HFT activities were deliberate and well coordinated. Adherence to ' procedural controls was well in evidence. Start-up testing was performed by qualified personnel who interfaced well with their operations coun-terpar.ts and with management in the prompt reso-lution of equipment problems and test deficien-cies. Test records were well prepared and main-tained. Test exceptions were few and disposit-ioned in manner. a technically ap.propriate and thorough Overall, a high level of performance has been found to exist in the licensee's implementation of. the startup testing program at Seabrook Unit 1. Where system redesign was necessary and ad-ditional testing is required, further Region I follow-up inspection is planned- during the low power testing phase. 6.1.1.4 MC 2515 program: The Operations Inspection Pro-gram has been implemented at the core level with selected reactive inspection module accomplish-ment on a case basis. Implementation of this pro-gram to date inspection has been principally a resident function. Upon completion of low power testing it is expected that additional regional resou,rces will be allocated in antici-pation of full power license issuance. 6.1.2 Team Inspections Saveral been special team inspections of Seabrook Unit I have-conducted since the original piement the routine inspection program. recommendation to sup-These inspections are conclusions. and listed below with a description of the inspection scope
.m a m .-
18 6.1.2.1 Region I Allegation Team Inspection - November, 1986 The purpose of this team inspection was to in-vestigate sixty-one allegations made by the Employee's Legal Project related to construction quality as well as several other technical and non-technical concerns. The interdisciplinary team consisted of specialists in the electrical, mechanical, civil and metallurgical engineering fields. Plant hardware was inspected and independent tests were performed where possible to evaluate , the allegation. Previous NRC inspection records
'were reviewed and allegers and plant staff were interviewed. Further details of this inspection may be found in paragraph 3.4.1. .Within the scope of this- inspection, no nuclear safety.
significant issues or violations were identified. 6.1.2.2 Region I_ATWS Team Inspection - December, 1986 The purpose of the ATWS Team Inspection .was to address licensee activities taken in response to Generic Letter 83-28 concerning - the Salem ATWS. The team was composed of three inspectors from the NRC:RI Quality Assurance Section. Licensee actions in the area of equipment class- ! ification, vendor interface, post maintenance j testing, plant surveillance and QA/QC interface ! were reviewed. No violations were identified. One unresolved item was opened with respect to spare parts and was subsequently closed in NRC:RI i Inspection Report 50-443/87-26. 6.1.2.3 Region I Allegation Team Inspection - April /May ! 1987 The allegation team which performed the November, ! 1986 team inspection was reconstituted following l a meeting with the Employee's Legal Project (ELP) l
. in April, 1987. During this meeting additional allegations were presented which were inspected on site during the weeks of April 6, April 20 and May 4, 1987.
l l L_z______.____ _ _ _ _ _ _. _ _ _ .2 __
19 While no' significant. findings occurred' from this inspection, two' unresolved items . concerning . con-- crete cracking and, groundwater effects on rein-forcing steel'were identified and referred to NRR-for technical analysis. Brookhaven . National Laboratory was contracted to perform independent-analyses .of' these issues. While resolution of' these _ issues is still pending -a . responsef to
. Region I from NRR,- neither are bel ieved to be-low l- power issues. Further: details of this' inspection may be found in paragraph 3.4.1. No violations- -l were. identified.
1 .. 6.1.2.4 Annual Emergency Preparedness Exercise Team Inspection - December, 1987 The 1987 annual Seabrook emergency drill :was observed by. a ' team of three emergency. prepared-ness (EP) specialists from Region I and' NRR. . i This-._was a partial participation exercise with limited participation by- the New Hampshire (NH) Civil Defense Agency. The Commonwealth of Massachusetts and several NH communities did not participate. Six . exercise' strengths and two exercise weaknesses were identified and nine open items from previous EP inspections were closed. No violations were identified. - 6.1.2.5 Annual Emergency Preparedness Exercise Team Inspection - June,1988 The 1988 Seabrook annual EP exercise was observed . by a team of seven inspectors from Region I, NRR and Pccific Northwest Laboratories. .This was a full partic-ipation- exercise and included the states of Maine and NH as well as the NHY Offsite
' Response Organization (ORO). The ORO i s . the .
organization- which compensates forl a lack. of participation on the part of the Commonwealth'of Massachusetts. Five exercise strengths and' four exercise weaknesses were noted. The four weak-l nesses were subsequently ' closed in NRC:RI In-l' spection Report 50-443/88-10. 6.1.2.6 Region I Self Assessment Team Inspection -
.0ctober/ November, 1988 The purpose of this_ NRC inspection was. to evaluate the licensee's Phase I self assessment activities. The team reviewed the NHY self i
I a l .. _ _. _ 1 - m . _ _ ' _. . :m.1 _. _ _ _ _ ~.
- i
20 assessment program and results as well as con-ducted independent inspection to corroborate licensee conclusions. No violations were iden-tified and it was determined that NHY is ready to heat up and conduct low power testing (refer to paragraph 7.0). 6.2 Enforcement History There have been ten Notices of Violation issued since the last recommendation. They are summarized in Enclosure.2. It may be noted that while two violations involve the control building air handling (CBA) system,. no recurring problem areas are identified. The CBA concerns have been adequately addressed in a major design change which is presently in progress.and will be completed before exceeding 5% power (refer to paragraph 3.2.1). No escalated enforcement action has been initiated at Seabrook and the relatively low safety signif-icance of all the violations indicates that no major areas of pro-grammatic weakness exist. 7.0 NRC Evaluation of Licensee Self Assessment A team inspection was conducted on October 31 - November 4,1988, at Sea-brook to review the NHY Phase I Self Assessment of readiness to conduct initial criticality and low power testing. The inspection included dis-cussions with licensee personnel, selected observations of self assessment , activities and review of licensee self assessment findings. The team noted that the licensee has considerable experience in self assessment, having a perraanent group which, since 1984, has conducted approximately 200 self assessments of various areas. The overall conclusion of the team was that the licensee self assessment was a strong effort involving considerable resources and utilf zing highly qualified individuals. The assessment was formal, well structured and self critical. Findings were found to have been reviewed by management ' and assigned appropriate priorities for resolution. This inspection served to confirm the licensee's overall readiness to conduct low power opera-tions. The team findings and conclusions are discussed further in a memorandum from J. E. Beall for J. T. Wiggins dated November 17, 1988,
Rev i ew of New Hampshire Yankee Operational Readiness Self-Assessment,"
(Enclosure 5). 8.0 Financial Qualifications !
8.1 Background
The NHY Division of PSNH manages the Seabrook project for the twelve Joint Owners. PSNH is the majority holder with 35.6% share. The Massachusetts Municipal Wholesale Electric Company (MMWEC) is a minority holder with 11.6% share. On August 20, 1987 the Atomic l
.h."h.____ _a__m__A._a _ . _ _ . - - _
- 21 Safety and Licensing Board (ASLB) denied a petition' by interveners to waive the financial qualification rule because of the financial status of PSNH at that time. On January 29, 1988 the ASLAB in hear-ing an appeal of- the above ruling took up investigation of the issue based upon the PSNH bankruptcy. filing' of the previous day. On April.13, 1988, the ASLAB declined to rule on this issue and refused
- to re-open the record based on a lack of information. On July 5,1988, the ASLAB certified the above appeal to the Commission for further consideration based upon the MMWEC decision to halt pro-ject payments. . On August 11, 1988, NRR requested that NHY provide clarification of its financial coverage for its cost of operations, any permanent shutdown of the plant and post-low power test program
- maintenance. NHY has responded and continues to periodically update '
NRR on its status, most recently with respect to the agreennt to provide alternative funding of the MMWEC shares. 8.2 Conclusions Region I was tasked with providing periodic updates to NRR concerning onsite observation of any potential impact on plant operations of the station's financial difficulties. To date, there is no indication that the PSNH bankruptcy or the MMWEC withdrawal have had any adverse impact on safety-related activities at Seabrook. This evaluation was based upon resident inspector review of overtime, staffing, training schedules, maintenance backlog, design changes, surveillance status ' and housekeeping. 9.0 Future NRC Reoion I Actions l- During the heatup to, normal operating temperature Region I will conduct a Readiness Assessment Team Inspection (RATI). The inspection team will evaluate licensee performance in the areas of operations, maintenance, surveillance, technical support, radiation protection, chemistry, en-vironmental monitoring, startup testing, management effectiveness and quality verification. This heatup period will provide windows 'of oppor-tunity to operations. evaluate facility operation during heatup, mode changes and hot Routine surveillance- testing, special startup testing and normal maintenance activities will be conducted and subject to NRC in-spection.. The results of this inspection will serve to validate the licensee's readiness for initial criticality and provide an opportunity to ensure necessary corrective actions are taken if necessary prior to that milestone. 10.0 Overall Conclusion The licensee has established programs and procedures to track readiness relatec issues. Both licensee and NRC evaluation of these mechanisms reveal a facility that is ready to startup. These conclusions are sup-ported not only by recent evaluation but by over 26,000 inspection hours over the life of the project. Management attention to organizational
&__- .,s._-.-- x- - - - - -
22 goals remains high and independent reviews play an integral part in man-agement decision making. Self criticism has been encouraged since the establishment of the NHY Division of PSNH. The licensee and facility level of operational readiness appears to be excellent. This has been substantiated by the licensee self assessment and verified by NRC evaluation of that activity. Continued NRC inspection plans will provide real time feedback.to agency managers to ensure that the Seabrook startup, when conducted, is conducted safely and in accord-ance with all applicable regulations and ' requirements. Region I concludes that the plant has been constructed and tested in accordance with the FSAR and NRC requirements. Programs, procedures and organization are in place to permit . issuance of a low power license,
. Therefore, Region I supports issuance of a low power operating license.
I e l 1 1 h__ h_._m____m ___ u _ mm.w_, _A
1 l, . l ENCLOSURE 1 Inspection Sumgacy l Inspection Inspection Inspection Number Areas Hours 86-45 Routine Inspection of 36 CDRs, Procedures and Design Changes. . 86-46 Routine Inspection of 358 I Construction Design I ' Changes, TMI Action Plan, Previous Items. 86-47 Routine Inspection of Testing, 428 License Issuance, Core Loading, Maintenance, Surveillance, Operations and Previous Items. 86-48 Routine Inspection of Startup 48 Test Program and Procedures; Review of Containment Test Report. . 86-49 Routine Inspection of Pre-Service 39 .
. Inspection Program and Records and Previous Items.
86-50 Routine Inspection of Initial 131 Fuel Loading Activities. 86-51 Special Inspection To Review 97 Allegation of As-Built Drawing Discrepancies. 86-52 Special Team Inspection to Review 478 Allegations by ELP. 86-53 Inspection Number Not Used. -
\
86-54
]
Routine Inspection of Operations, 187 Maintenance, Surveillance, Startup Testing and Previous Items. ' 86-55 Routine Inspection of Occupational 40 Radiological Controls Program and . Previous Items. I i
- - _______ - A
Enclosure 1 2 i Inspection Inspection Inspection i Number Areas Hours .i i 86-56 Routine Inspectio'n of Physical 24 ; Security Program and Previous ' Items. 86-57 Inspection Number Not Used. - 86-58 Special Team Inspection.To 118 Review-Licensee Action on GL 83-28, ATWS. I 87-01 Routine Inspection of 128
- Preoperational Testing 87-02 Routine Inspection of 432 Preoperational Testing, Maintenance, Surveillance, Operations and Previous Items.
87-03 Routine Inspection of 56 Surveillance Test Program. 87-04 Routine Inspection of Radwaste 30 . , Program and Preoperational l - Testing.
~
87-05 Routine Inspection of Startup 69 l i and Preoperational Testing, 87-06 Inspection Number Not Used. - 87-07 Special Teani Inspection of 583 -4 Allegations Raised by ELP. 87-08 Special Inspection to Follow-up 26 Unusual Event of 02/11/87. 87-09 Routine Inspection of 34 Preoperational Testing. 87-10 Routine Inspection of 346 Preoperational Testing, " Maintenance, Training, Operations and Previous Items, i j 4 1 e L M. .._._r_..C__ - . _ .m. .n -- - - -" ' ~~ - ~
~
b Enclosure 1 3-Inspection Inspection Inspection Number Areas Hours 87-11 Routir.e Inspection of Startup 32 and Preoperational Test Programs. 87-12 Routine Inspection of EP Program 54 and Previous Items. 87-13 Routine Inspection of Design l 268 Control Program, Testing, Maintenance, Surveillance and Previous Items. 87-14 Routine Inspection of 34 Occupational Radiological Controls Program. 87-15 Routine Inspection of 33 Non-Radiological Chemistry Program. 87-16 Routine Inspection of Operations, 270
- Maintenance, Surveillance, Design .
Changes, Training and Previous Items.
~
87-17 Operator Licensing Examination. -
)
87-18 Special Inspection of Service 35 ' Water Valve Repairs. 87-19 Operator Licensing Examination. - 87-20 Routine Inspection of i 34 i Maintenance Programs. " t 87-21 Routine Inspection of Physical 68 Security Program. 87-22 Routine Inspection To Follow-Up 32 Corrective Actions Concerning Unusual Event and Emergency Siren Status. 87-23 Routine Inspection of Operations, IIS 'i Maintenance, Surveillance, ; Security, Licensee Reports and, - Previous Items. ' l l -_Z 2- __ - -. c .s. - _e.
Enclosure 1 4 Inspection Inspection Number Inspection . Areas Hours 87-24 Routine Inspection of 208 Operational Safety, Maintenance, Surveillance, Licensee Reports and Previous Items. 87-25 Special Team Inspection of Annual 54 Emergency Plan Exercise. 87-26 Routine Inspection of 98 Operational Safety, Design Changes, Allegations and Previous Items. 88-01 Operator Licensing Examination. - 88-02 Routine Inspection of 176 Operational Safety, Maintenance, Security and Previous Items. 88-03 Routine Inspection of Emergency 24 Preparedness Program. 88-04 Routine Inspection of the 34 Startup Testing and Follow-Up to General Letter 83-28. 88-05 Routine Inspection of Physical 42 Security Program. 88-06 Routine Inspection of Mid Loop Test, 210 Operations, Maintenance, Security Previous Items. 88-08 Special Inspection of Vehicular 30 Alert and Notification System. 88-09 Special Inspection of 176 of Annual EP Exercise. 88-10 Routine Inspection of Operational 224 Safety, Licensee Reports, ' Maintenance, Surveillance, Design Changes, Allegations and Training. 88-11 Routine Inspection of 75 Engineering and Technical Support. m. i_____. m_m__- * -- -
Enclosure 1 5
'O I Inspection Inspection Number:
Inspection ; Areas- Hours i 88-12 Routine-Inspection _of 39 Startup Testing.
' 88-13 }
Routine Inspection of. _ 226 ' Operational Safety. Previous- 1 Items, Licensee Reports, j Maintenance, Surveillance Design Changes and Previous
. Items.
88-14 Routine Inspection of '38 physical Security Program. 9 l l 3 i S e I'
- h_'_ . _ _ _ _ . a__n --_$. _ _ _ _ . . _I_AI h.. m k .=aA-. _2m._ a_a__ .hl m2 ________m ___@ ___.m.A __u__-_m__ _ ...a.m. __ ..
ENCLOSURE 2 Enforcement History
'l Inspection Requirement i Severity Brief Number Level Description 86-46 10 CFR 50, 4 Seismic 2 Over 1 APP. B Controls For Temporary Equipment 86-47 10 CFR 50, 4 Locked Valve APP. B Controls 87-02 10 CFR 50, 4 CBA System Not APP.B Operated In Accordance With Design Requirements 87-08 TS 6.7.1 4 Failure To Report l Unusual Event 87-13 10 CFR 50.59 4 SW/SCW Temporary ,;
Modification 87-16 - 10 CFR 50, 4 CBA System APP. B Inoperable 87-20 10 CFR 50, 5 Tagging Program Deficiencies
,88-10 TS 4.8.1.1.3 5 Failure To Report Diesel Generator Failures 88-13 TS 3.8.4.2 5 Non Class IE Devices Connected to IE Sources 88-14 Physical Security 4 Vehicle Search Plan Deficiencies 4
ENCLOSURE 3 NRC Bulletin Summary Bulletin No. Subject Status 85-03 Motor-Operated Valve Common Open - Updated Mode Failures During Plant in IR 88-13 by Transients Due to Improper NRC:NRR:0GC8 Switch Settings. 86-01 Minimum Flow Logic Problems N/A That Could Disable RHR Pumps. 86-02 Static "0" Ring Differential Closed in 7/18/86 Pressure Switches. IR 86-47 1 86-03 Potential Failure of Multiple Closed in ECCS Pumps'Due to Single IR 86-54 > Failure of Air-Operated Valve in Minimum Flow Recirculation Line. 86-04 Defective Teletherapy Timer. N/A That May Not Terminate Dose. ' 87-01 - Thinning of Pipe Walls in Closed in Nuclear Power Plants. IR 87-16 87-02 Fastener Testing to Closed in Determine Conformance With IR 88-10 Applicable Material Specifications. 88-01 Defects in Westinghouse Closed in { Circuit Breakers. IR 88-06
]
88-02 Rapidly Propagating Fatigue Closed in l Cracks in Steam Generator IR 88-02
- Tubes.
88-03 Inadequate Latch Engagement Open - Relays in HFA Type Latching Relays replaced 10/88 ' Manufactured by General Licensee response
. Electric (GE) Company. due j i
88-04 Potential Safety-Related Open - Licensee Pump Loss. response 2/88 indicates additional information due ! 12/31/88
)
a__.-= -- -- e - - - - o- - i
Enclosure 3 2 Bulletin No. Subject Status d 88-05 Nonconforming Materials - Open - Licensee Supplied by Piping Supplies, response 8/88 Inc. at Folsom, New Jersey . NRR requested and West Jersey Manufacturing ' chemical testing Company at Williamstown, of all heats, New Jersey. resulted in two flanges replaced 11/88. Final response due. 88-06 Actions to be Taken For N/A
- the Transportation of Model No. Spec 2-T Radiographic Exposure Device.
88-07 Power Oscillations in . N/A Boiling Water Reacturs. 88-08' Thermal Stresses in Piping Open - Temporary Connected to Reactor Coolant modification Systems. installed to monitor for ' leakage. Licensee responded 9/88. 88-09 Thimble. Tube Thinning. Open - Inspection required at first refueling outage. i l i 1 4 h
- n
\
ENCLOSURE 4 Summary of SALP Evaluations Report Number: 50-443/86-99 Evaluation Period: April 1,1986 - July 31,1987 Management Meeting Date: November 12, 1987 Management Meeting Location: Seabrook, New Hampshire PREVIOUS RATING CURRENT RATING FUNCTIONAL AREA (Seventh SALP) (Eight SALP)
- 1. Construction Completion 1 1
- 2. Startup Testing 1 1
- 3. Plant Operations 1* 2 4 Radiological Controls
- 1
- 5. Emergency Preparedness 2 1 -
- 6. Security and Safeguards
- 1
- 7. Engineering Support **
2
- 8. Licensing Activities 1 1
- 9. Training and Qualification
- 1 Ef f ect '. ve n es s
- 10. Assurance of Quality 1 2
*During the previous SALP period, " plant operations" was evaluated in terms of
" operational readiness", which included " radiological controls", " security and safeguards", and " training / qualification" assessments in one general functional area.
**During the previous SALP period, Engineering Support was not evaluated as a separate Functional Area. .
9 ___u_ - LA -
4 NOV 171988
, ENCLOSURE 5 MEMORANDUM FOR: James T. Wiggins, Chief Reactor Projects Branch No. 3 Division of Reactor Projects FROM: James E. Beall, Senior Resident Inspector Beaver Valley Power Station
SUBJECT:
REVIEW OF NEW HAMPSHIRE YANKEE OPERATIONAL READINESS SELF-ASSESSMENT A team inspection was conducted at the Seabrook facility to review the licensee's self assessment (Phase I) of readiness to achieve initial criti-cality and complete low power testing. The inspection included discussions with licensee personnel, selected observations of self-assessment activities, and review. of licensee self-assessment findings. Additionally, the team con-ducted an independent review of licensee readiness in the following selected key areas: training for low power operations, status of health physics pro-grams, control of mode change criteria, and effectiveness of management sys-tems. The inspection was performed by James E. Beall (Team Leader), SRI, Beaver Valley; Stephen M. Pindale, RI, Beaver Valley; Anthony A. Weadock, Radi-ation Specialist, Region I; Edward Yachimiak, Operations Engineer, Region I during the period of November 2-4, 1988. Subsequent to the inspection, the team leader reviewed the final licensee self-assessment (Phase 1) report. The overall conclusion of the team was that the licensee's self assessment was i ' a strong effort involving considerable resources (over 2000 man-hours) and - utilizing highly qualified individuals. The assessment was formal, well struc-tured and self critical. Findings were found to have been reviewed by manage-ment and assigned appropriate priorities for resolution. For example, the area of root cause analysis had been originally selected by the team for review but was found to have been self-identified by the licensee as an area needing improvement. The inspectors reviewed the licensee's recommendations for improvement and identified no weaknesses. The team noted that the licensee has considerable experience in self assessment, having a permanent group (since 1984) which has conducted approximately 200 self assessments of various areas. The existence of this group and the long-term dedication of resources to self-assessment was considered a strength. In the area of operator training, the licensee was found _to meet all required criteria of 10 CFR 55.59. Substantial additional _ classroom training was also provided in the area of initial low power operations and planned startup tests. The team noted, however, that the site specific simulator was not used to demonstrate either the planned approach to initial criticality or possible transient scenarios originating from within the planned operating region. There was no evidence in the licensee's self assessment that use of the simulator was considered. The scope of planned low power operations was found to be adequately covered in classroom training, but the team noted to the licensee that simulator use has been found by other licensees to be a valuable training enhancement, especially during power ascension testing. 1 l' . _ - - _ _ _ _ _ _ _ _ _ . _ _ -
=
Memorandum for James T. Wiggins 2 NOV 171988 R In the area of health physics readiness, the licensee's report contained more program status presentation than assessment. The team noted that the assessor was also the individual responsible for the health physics program. The licen-see's analysis in this area could have benefited from a more independent assessor. The team conducted an independent review and found the licensee's preparations to be adequate with sufficient 1 to implement the radiation protection program. qualified personnel and equipment i l The team previously Seabrook also reviewed the licensee's measures to control mode change criteria. ascended to Mode 3 (Hot Standby) under the fuel load license which provides the licensee with mode change experience not usually possessed tions. Theby licensees licensee makespreparing good useforof initial criticality and low power opera-ascension. mode change checklists during mode I The licensee employs two different computer databases in scheduling testing and calibration of systems Specifications and components in dif ferent modes. required to be operable by the Technical One database is used for scheduling sys-tems/ equipment surveillance tests, whereas the other database is used for scheduling testing of prmanent plant indicators. No deficiency was identified in the licensee's approach, but the team noted that system surveillance tests did not contain confirmation of the calibration status of permanent plant in-dicators used to measure system performance. relies and meter upon perfect performance of the other computer program calibration. to assur The team identified this potential programmatic weak- l ness end of 1988. to the licensee who committed to complete the review of this item by the , The team reviewed the licensee's use of the Station Operations Review Committee (SORC)-and icant the conduct of safety evaluations required by 10 CFR 50.59. strengths were noted in these aspects of management effectiveness.Signif- The 50RC makes good use of subcommittees and there are excellent guidelines on pro viding preparation time to SORC members prior to decision: making meetings. The reviews and training requirements for evaluators. safety evaluation p sampled areas appeared to be comprehensive and mature,The licensee programs in the In s umma quality. ry , the team found the licensee's self assessment to be of good Independent i weaknesses. This assessments in selected areas identified no significant I inspection served to confirm the licensee's conclusions contained in its sel f-a s ses sment Phase 1) report regarding the facility's I overall readiness to conduct low pow (er operation. l
! d%44F w James E. Beall, Senior esident Inspector Beaver Valley Power Station
_ _ _ _ _ _ _ _ _ - _ _ _ _ - . - - - - - - i
Memorandum for James T.~ Wiggins ' 3 NOV 17 M
, J. .
e cc: W. Kane, DRP-S. Collins, DRP -... T. Martin, DRS *
- 5. Ebneter; DRSS.
D. Haverkamp, DRP L. Tripp, DRP D. Ruscitto, SRI Seabrook 1 e 1 I
-1 i
i I j mi i I
ATTACHMENT 8 A p* f'g .meag UNITED STATES %Tg [ [Y >**% S, NUCLEAR REGULATORY COMMISSION I ( g ' %.
/
J REoioN I 475 ALLENDALE ROAD
***** KING OF PRUSSIA. PENNSYLVANIA 194o8 I
MAY 031989 MEMORANDUM FOR: Thomas E. Murley, Director Office of Nuclear Reactor Regulation 1 FROM: William T. Russell, Regional Administrator Region I
SUBJECT:
SEABROOK STATION, UNIT 1 LOW POWER LICENSE RECOMMENDATION, SUPPLEMENT 1 l This memorandum provides an update to my November 22, 1988, low power license recommendation. This update reports the closure of the technical issue asso-ciated with Agastat 7000 series relays and provides the status of two NRC 1 Bulletins issued since my initial recommendation. It also discusses a recent l series. of events which have occurred. Regarding the Agastat 7000 series relays, licensee action involved replacement of five relays and is complete. Region I inspection of this activity has been ! satisfactorily completed and this issue is considered closed. , NRC Bulletin 88-10 concerning nonconforming molded case circuit breakers was l issued on November 22, 1988. Based upon licensee actions taken in response to s NRC Information Notice 88-46 and the action plan developed by New Hampshire I Yankee (NHY) to comply with Bulletin 88-10, Region I believes that this issue I is being- appropriately dispositioned by the licensee. j NRC Bulletin 88-11 concerning pressurizer surge line thermal stratification was j issued on December 20, 1988. An ongoing dialogue has occurred between NHY and NRR on the low power implications of this Bulletin. No additional inspection 1 is needed on this Bulletin to support low power licensing. Recently, several minor events and problems have occurred at the site which raise NRC concern over the attention to detail in operations displayed by the plant staff. The most significant of these involve two violations of the special zero-power license conditions associated with locked valves. While none of the individual events or problems had an impact on safety, taken together they indicated a possible declining trend in facility performance. The licensee has taken corrective action for the individual instances and has developed and implemented an approach to improve attention to detail throughout the organization which involves observations and reviews through the self-assessment process. Region I will monitor the effectiveness of these licensee activities through heatup and initial low power operations. i
N Memorandum for Thomas E. Murley 2 MAY 031989
' Enclosures 1 and 3 of my November 22, 1988 memorandum are also updated for information. .
In conclusion, I continue to find that Seabrook Unit I remains ready to conduct initial criticality and low power testing operations. 0 William T. Russell Regional Administrator
Attachment:
'.ipdated Enclosures I and 3 to Region I's November 22, 1988 Memorandum cc w/ attachment:
V. Stello, EDO J. Taylor, EDO B. Clayton, EDO J. Partlow, NRR S. Varga, NRR B. Boger, NRR R. Wessman, NRR V. Nerses, NRR W. Kane, RI ' S. Collins, RI M. Knapp, RI T. Martin, RI J. Wiggins, RI D. Haverkamp, RI , L. Doerflein, RI D. Ruscitto, SRI - Seabrook 4 4
k.y l ENCLOSURE I l Inspection Summary l Inspection Inspection Inspection l Number Areas Hours 1 88-15 Routine Inspection of 434 Operational Safety, Maintenance Security, Radiation Protection, Licensee Self Assessment, Reportable Events and Previous Inspection Findings. 88-16 Inspection Number Not Used - 88-17 Routine Inspection of Operational 97 Safety, Reportable Events, Maintenance, NRC Bulletins and
- Information Notices and Previous Inspection Findings.
89-01 Routine Inspection of Operational 130 Safety, Licensee Reports, Design , Changes, Maintenance, Training and Previous Inspection Findings. 89-02 Routine Inspection of the 39 Emergency Preparedness Program and Previous Inspection Findings. 89-03 Routine Inspection of Operational 150(Est)*' i Safety, Maintenance, Reportable l Events and Previous Inspection l Findings 1 89-04 Routine Inspection cf Electrical 64(Est)* Maintenance, Licensee Action on the Information Notice on Raychem Splices. Licensee Program for Controlling Quality of Emergency l Oiesel Generator Fuel Oil and l Previous Inspection Findings l l
- Report Not Yet Issued.
2_-_----.---..
F . I%
- r. :
ENCLOSURE 3 NRC Bulletin Summary
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Bulletin No. Subject Status 88-03 Inadequate Latch Engagement Closed - Relays Replaced in HFA Type Latching Relays 10/88. Licensee response Manufactured by General 12/88. NRC inspection 1/89. Electric (GE) Company. 88-04 Potential Safety-Related Open - Licensee response Pump Loss. 8/88. Licensee Engineering Evaluation completed. Follow-up response 12/88. Licensee response appears satisfac-to ry. No additional inspec-tion needed to support licen-sing. 88-05 Nonconforming Materials Closed - Licensee responses l Supplied by Piping Supplies, 8/88 and 10/88. Closecut SER Inc. at Folsom, New Jersey issued 12/88. j and West Jersey Manufacturing Company at Williamstown, New Jersey. 1 , 88-08 Thermal Stresses in Piping Open - Temporary modification Connected to Reactor Coolant installed to monitor for Systems. leakage. Licensee responded l 9/88. Additional licensee response to NRR RAI 12/88. No further inspection needed for licensing. 88-09 Thimble Tube Thinning. Open - Licensee inspection required at first refueling outage. 88-10 Nonconforming Molded Case Open - Licensee action plan Circuit Breakers, in place and response re-ceived 4/89. Response ap-pears acceptable. 88-11 Pressurizer Surge Line Open - Licensee responses to Thermal Stratification conference call with NRR 12/88 describes action plan. Westinghouse report submitted 3/89 and updated 4/89. No further inspection needed for
. . licensing.
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. PAPER:
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2 ed'. spell cut lcng term corrections ' and review those issues with the j NRC..Brcwn said be was teld by -
.NRC cfncials that they also will I,c
. , .4 held a p.iblic treeting to discuss f ess m actmgm emw e.' o '.' e- 7- .. ? -
Tar. , ,. NRC spckesmen said such sus .
. e pensions .in lew-pcwer tests e.re
. On ~ a V ve " cited ". r '-
- - " .aRep. 2 ..Edward m .. Markey (D 3t
- n. .
iy Larry'Tye I trol room.'ttie plant's cperators . Me.ssA a lengti=c entie of Sea ; breck, last ri!ght effered an ana1 Globe Staff ! elosed the valve and centinued to egy for recent events at the pis.n,7 3 The' Nuclear Regulatery Com. mmiter the system. Minutes later. . they decided to shut down the re- r *'SCADTC0h CPCTRI0T8 *'I rnissien last night tock the unueu. to pass their dN.E test t al step of suspending Icw power actor manually. having taken de wrW.en na,, . tests at the Seabrock nuclear "We did not strictly sdhere to When they tock the car mM e , plant until its owners explain our test procedures during these . changes in system conditiens," first time. the NRC fcf.d it nec s ;. , what went wrcng during Thurs. i Brown t, aid in a statement. "The sary to reach in an. pu m day's unplanned shutdowr of the brake ta shut the plant ocwn e ., NRC said'we waited several min. reacter. utes too long.before actually per. cause Seahrock geta_WD,y - Eefere the tests can resume, ' knew what they were doing ,
- they u have te ccme down here . .v
.' forming the shntdewn...At no t'ce'ws:s "I thinkthe7e it's ve y afMghtening risk 17 to ,
and hge a canagement meeting think what wecid tave happened. y ' y with us, explain what they've . plant;sy' stems cr.to' the generaj done, r6nd convfnee us it's the !! this public." the peabrock executive' aem .? 70' to phnt he.d been 60 ercent cperating at f, of power,ah.,8' right thing." said Karl Abraham, 3 ~
, k there had n no NRC pecp.e id ~ifflefin Peidisy!drifal~~p-a spokesman a ' NRC inspckesman the NRCAbre.htm re lenalEr.id ! the cent-cl rocm." Markey adM3.,.12s c
Seabrook operators "did not do I . . . ., .. ? f,8e I ,
- Seabrock offietals last night Ehs.nnen said he wi!! use this og aafd they have no idea how long , things the procedures cated fer."' .
The shutdown they were under- week s events to argue before s.n; cr. the delay willlast. Edward Brown. takin , the NRC cfficial r.dded. .NRC apperds beard the.t low-pow- fif president of New Hampshire Yan. 'er tes's be stc~ed until all sa.fety u kee, whfeh runs the plant in Sea. has n required of ever7 plant
$1nce there was a Three Alle 18- !ssues requireNor full-pewer cper . '
brook, N.H. mid the NRC s actien -
; land." referring to a near melt- atten he.ve been reviewed. -1g,.,
was prompted by the fact that i dcwn at the Pennsylve.nfa plant .g ,
"we waited r.everrl minutes too ,,,
g be or ac,tually permitting' , in 1976. : ping at 3 percent of its pcwer po % . Winiam Russell. head of the l tential when it wts: shut. Sefere p it - But Massachusetts Attorney ca.n get a fun pewer licen c, General James Shannon said the . NRC regionaloffice,sent aletterto : officials aiso must satisfy troubles at Seabrock run mneh the plant s cwrers last night set- i that they could safe evacun e. .e g. . deeper:"It is a questien of wheth- tingfour condit!cns for the tests to nearby ec== unities ter an acef .:; i er eperators know how tpfespend. resume: Seabrock must finish do- den.. . 0. . . ni 1 sypropriately in the event of an "' cumenting Thursday's events, de-termine what quick (txes are need- .
", * *" ,l d ! accident ... the NRC pointed to * - a " '
these same problems a year ago after a mock evacuation exercise
.took place." . . ,
Sentrock ste.rted its low-power , tests June 13. and they were
, scheduled to.run about a week.
On Thursday, however, a i steam valve in the, nennuclear alde cf the plant remained open ' longer than intended and too
- .'much steam was sent to a cen- '
' denser, causing changes in pres- ' sure and temperature. In the con - . - _ - _ _ _ _ _ m.___ h
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'By NICK TATE ;
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' Dut reactor critics, Tehb'7)' a news what the risk wou'Id '
~ B8Y EI"I* 3.ttorney ~ General James Shannen, said the glitch 3 GS,:.,r.oS
..have been for thegeople living Ance.rby).f x w ,. . ,,
and ' operator errers peint up se- . Seatrock cffidtals acknowl. ; ME NUCLEAR Regulatory Commiss!cn ~
' rious flaws la equ!pment, emer-edfed operaters fa!!ed to ad- ]
rdered Seabrook Station. yesterday te ~ here to NRC regulations in de >; .
~
kort low pewer tests until operatcrs ex- gency. preparedness plans .and ernployee training. laying the plant a thutdown, sain why werkers Ignored safety regula. "Inevltably, !! you shcrtcut but denied c. aims the incident ons and failed to shut the plant a.fter a safety procedures you're going highlights flaws in p!t.nt proce-malfunction. Handing Seabrook a serious setback yh,tine're h l ' see! ere/ se k no time we.s there a risk s stammering first steps toward full to plant systems er to the ten-Sht.n.nen, who' has led the eral public " sa!d Edward peration, the NRC indefinitely euspend- ,1g s oppesitien to the p!,.nt; Bravm, president cf Seabreck . 6 teactor cperatiens and faulted centrol. , ...The NRC has been doing oom werkers fer w:alting " severe.1 min J cperater New Hampetire Yan ' whatever it could to make it kee. "Centrol room cperators at ates too leng" to turn off the ieacter after ' easy fer these guys," he added.,
"and the ' result .laimistakes ; e.Il t!=en maintained s f aultyia'lve failed Thursday afternoon. atien ef_the reactor., safe cper-have been made and the plant .
Rep. Edward J. Markey (D Mass.), n ' icabrook, opponent, e aid tcp NRC cfficials {s rjt,, ready for e en lyw, power ]a ke{ spo esman Rcrj old him an NRC off!cial in the centrol .- Shannen and cther plant cr!.J just after necn.while.the $$ til . l >oom crdered workers to thut the plant tics said the NRC decisten ' licip1Et'wss rfining at 3 per ' lown when the prob!c,m a'rcse, but noth- cchces concerns ra! sed last cent power, the peak ef.the low-
.g was donc until he grabbed one, em- summer during a mcck emer l pcwer testing prccess.A velve en th
? CY - - - - ! gency r.t' Beabrock/.which
. side 'cf the plant designed to
"% hat we have 'here is a situation turned up " weakness" in re- '
where the Seabrook reacter ~ operators sponse e!!cris that raised ques ! ' direct steam from fcur genera-were net able to felicw their own procc . tiens atcut workers' ability to ters " stayed cpen too leng." gres._and e.n NRC official in,the.CQntrol handle e.n unexpected event. - The malfunction caused But the NRC last fall denied mere steam to be eenverted to room, first having given a verbal instruc- Shanncn's bid to initiate full- water than is preper, which lion, had to physically Erab one cf the ecale hearings en these wee.k- would eccl the nuc ee.r ccre too 3eatrock operaters to ensure that proce-Sures would be followed to shut the plant' e'd E ar er" yeeterday said .the fown immediately. Af arkey said. [*an'elcar e problem wr. n't eeneidered se-Seabrook spokesman Rob Williams l appeal of that. denial teveral days ago. ricus enough to warrt.nt notift- $1sputed Ma.rkey a account, caying."That "I don't want to say,'l told catien to the NRC er state eff1-Aldn't happen." Plant efficials said it was you so! but I did in this case," cials. act NRC monitors but Seabrock staff that he raid. vcwing to rneunt new But NRC mentters inside Elfst noticed the glitch, c!!crts to open hearings. the centre! reem chserved a NThev..also.eaid there was no " moving" Markey said the incident vicMtion in regulattens when
, cf control rocrNeper- tacks cpponents' cla!=s the.t - Beatrcok cperators waited ,
aters er test supervisors by the reacter es.nnot be ss.fely "three to feur minutes" after { NRC rnentters during the ~ 7perated arid ~ fnadeqstte 'evaE the malfunction to shut down a
;- ,, event, t.nd maintained the inc!- cuatics plans for net.rty rest. ' the plant.
, dent would not prove t. Ir.ajcr - dents will leave thousands t.t ' Eher said t. report en the setback. risk. . - i event will te comp!cted next
'g ' ,
weck. JThe NRC. which last menth - "I think the lessen that has t to be learned is regardless of Lew. power testing at the t 4 . author!:cd Sentrock to tegin 1.150 megawatt plant, the first
, the 1ests, said the actlen did nct all the assurances Seabock offi-constitute a revccaten cf the . cials are givirg thet no acci- phase in Ecabrock's cperatten. .
Icw power license, but opera. dent will hcypen. We ete that was approved last month by t!cne will remain on hold until lhuman beings make mistakes," I the NRC. But to move to full-he st.!d. I power creratiens. Seabrook
, Seabrook c!!!cials previde an ' "This event cecurred 'at 8 ! cdsf first win NRC apprcval
. accounting cf the shutdown and - fer.'a!x Bay State icwns ,near take long. and shcrt_ term. ac. percent power with NEC men!- I j.
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. 0 e But the test director then e ray talked to the shift superviser, a higher ranking official, who said e 1.Lvi tkt pressure was dropping en its b{@l{ gdQ@
- i olb and that there was no need ' to l it3 cff the plant.
k '
- Dud!cy stepped in at that I
. point. approaching a still higher i Ey Larry Tye SEbroox official, the
- assistant op-entions ' manager. The assistant ,
f Globe Staff rgpager consulted the operations Nuclear Regulatory Commission inspectors ad- '
) vised .
three officials at the Seabrook nuelcar plant to -
! mana j inUr=ger ation"who acknowledged and deferred to the the b turn the reactor off last week, but that advice was j ignored, NRC officials said yesterday. l ,
- d_@sion of the shift supervisar to i 1
11 w s not until steam pressure began rising that . continue to operate." Herwitz Seabrook officials finally fotlowed their own proce- . said. i durcl requirernents and closed the plant, said Noel j , Z.They
= were making a cen-Dudley, the center NRC inspector at the plant in i l Seabrook. N.H. If pressure had continued rising and l !
' scious de !sion to attempt to re-cther safety systems had not responded. pipes even- 4 gain pressure control,
- Dudley tually could have cracked or other problems devel- ]i .
said in an interview yesterday. cped Dudley added. ' ' But he added that it was a wrong Th:1 delay in shutting the reactor lasted only 5 d sj n g i 1 . ts
, minutes. Dudley said. But NRC cfficials felt it re. Y 4 flected n serious enot'gh disregard for plant proce- ;
,dures . . . It was a concern to us.u dures - and apparently for the advice of federal .
Seabrook spokesman Ronald l safety inspectors - that on Friday they tock the - S t th,e epcratcr t highly unusual step of suspending low-power tests. - sajd ,y go,e o een-More than a dozen Seabrook of- tinue to monitor plant cenditions C.! :s are working this weekend lI .
- because they were returning to to sort out what went wrong last the test condition . . . Several min <
~ wnk and to come pp with short- utes later the eperator recegnized ; I Q - a,nd long-range plans to ccrrect ~'"d that the plant condition was not j l the problems. While they hope to . within the parameters of the test l l
"' procedure, and then he shut the '
t those plans to the NRC '
' week, observers say it will , plant down." .
]ge a lot longer,to repair the 5
Plant officials maintain that f tnrised public image of the con- there was never a threat to safety. ' IEersial $6 b!11!cn plant. . Rep. Edward Markey (D , . T.'lThe first hurdle is to retrace Mass. a longtime Seabrook foe. ullllpt happened during the un- ,
'said h)e, was told by NRC chairman ;
pgnned shutdown Thursday. Lando Zech Jr. and other commis-
= he reactor wr s in its 10th day sten offletals that after federal in-Ow pcwcr tests ' aimed at deter- spectors were ignored, they actu-giing how vital systems perform ally grabbed Seabrook eye-ators der actual operating condi- to get them to respond. Dudley de-
- s. Shortly after noon, a valve nied that, saying."It was only ver-23he nennuclear side of the plant bal ecmmunication."
Clll pained open longer than in- Wh!!e a five-minute delay may seem inconsequential industry Wed and too much steam went specialists say fatlure to follow
>= condenser, causing pressure lllllSse. i procedures in turning a plant off P'Weaure hit 17 percent could create safety problems.
Even more important, they said, Obudley and an NRC spokes. the Three Mile Island and Cherno-Sn. Steve Morwitz, said that an , byl accidents show how vital it is i NR,C inspector then approached for cperators to be well-trained thp startup manager who oversees and to follow procedures. low-power tests, reminding him W!! ham Russell, head cf the th~rd pressure had hit 17 percent. NRC regional office. was sufff-(!;e* point at which the plant is to ciently cencerned that he set four be shut manually, When the man. conditions for Seabrook to resume aps did not respend. the NRC in. low-power testing: Plant effic!als spbeter t.pptcached the test direc, tor. who was closer to the scene in ; thecontrol room, and the director agreed the plant shculd be shut. 06-?J .
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'It's very frightening to think what would have happened if this plant had '
been operating at 70 to 80 percent of power and there had been no NRC peo-ple in the control room.'
- - Rep. Edward Markey... ,
- a longtime Seabrook opponent
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with no new plants being built. must f!ntsh documenting Thurs- worry that the federalgovernment commission stsffers have more , day a events. determine what has given their many crittes new time to police existing reactors. quick fixes are needed. epell out ammunition. "There are pecple long-term corrections and review who are op osed to nut! car power. Others maid it evidences a new - toughness by the NEC. those issue.s with the NRC. and they a ways try to ('encralize But Peter Aj[nes Jr.. Dukakis, NRC launches own probe from a specific mistake said an tcp nuclear moviser. was skepd-executive at a nuclear plant that cal: "The NRC may want to dem-Meanwhile. the NRC 'has launched its own investfration of has faced similar er:ticism from .
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1 the incident, and Dudley ad that the NRC. onstrate to a very wary publi will take longer than the week ..Very frightening to think" that it is very vigilant and caus l Seabrook estimates for its review- Massachusetts Attorney Gen. some people to relax a bit abou Neither NRC nor Seabrook cff!- eral James Shannon one of the future events en !! censing .. . Ye cials would speculate on when mest persistent crities, already while it shows extrerne attent!c4 low-power testing may c:ntinue, has vowed to use the NEC suspen. to very minor technical deta!!s, it While issues falsed by the sion'to raise larger questions continues to disregard larger safe-shutdown probably will be re- about whether Seabrook opera. ty questions. l 6olved soon, observera say it will tors are quahfied. Markey said, take far longer fer Seabrook to re- "It's very frightening to think
.- store its image, what would have happened if this Mfgh-level NRC officials have plant had been operating at 70 to lav'.shed praise on the New Hamp- 60 percent of power and there had shire plant in recent years,in con- been no NRC pecplein the control trast to their frequent criticism of room "
the Pilgrim plant in Plymouth, ghtle Seabrcok's pub!!c stand-Mrr.s. Seabrook officials regularly ing probably suffered a setback asserted that the reacter is the sa- from last week's episode, the fest in the country. NRC*a may have been bolstered. Now. those same officials may The agency has never turned down alicense for a completed nu-clear plant.,almost always lets closed ones reopen, and substan. tially amended its ru!cs to ease l Seabrock's path to teensing. Mar ' key says the agency has beceme a lap dog, rather than the watchdog it was intended to be. Given that history, the dect , alon to suspend testing surprised and delighted some NRC cr: tics. One industry source said it rray simply r Dect the fact that i j l
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