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#REDIRECT [[IR 05000443/1986052]]
{{Adams
| number = ML20212B923
| issue date = 12/17/1986
| title = Insp Rept 50-443/86-52 on 861103-14 & 18-21.Major Areas Inspected:Allegations Re Const Activities & Mgt Controls. Insp results:13 of 47 Allegations Substantiated,Although 11 Previously Identified by NRC or Licensee
| author name = Bailey R, Chaudhary S, Durr J, Ebneter S, Gray H, Koltay P, Paolino R, Winters R
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =
| addressee affiliation =
| docket = 05000443
| license number =
| contact person =
| document report number = 50-443-86-52, NUDOCS 8612290345
| package number = ML20212B805
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 133
}}
See also: [[see also::IR 05000443/1986052]]
 
=Text=
{{#Wiki_filter:g.
                              U.S. NUCLEAR REGULATORY COMMISSION
                                              REGION I
^
    Report No. 86-52
    Docket No.  50-443
    License No. NPF-56              Priority                        Category        C
    Licensee: New Hampshire Yankee
    Facility Name:      Seabrook Unit 1
    Inspection At:      Seabrook, New Hampshire
    Inspecti,on Conducted:    Nov. 3 - 14, and Nov. 18 - 21, 1986
    InspectoMs:    N calt h W                                                            iz /17 / 8 6
                  S. K. CMT(Tdhary,/ Lead Reactor Engineer, 08, DRS                            ' date
                              CLM          f                                              />/ti/tc.
                  R. J(/Paolino, Lead ' Reactor Engineer, EB, DRS                                date
"
                          y        ag                                                  /2 ////d?C
                  H. Gray, Lead p Zctor Engineer, EB, DRS                                        date
                    ''~
                                      S                                                    //l/ 7l8C.
                  P. S. Koltay, Sr. Resipent Inspector, IP#3                                  ' da t'e
                        dhtu            n_s+      n-                                    /n//'//TC-
                  R/ J. Aailey, Physical Secgrity Inspector, DRSS                            ' d a t'e
                                                                                            17.,fi 1      Bb
                  R. W. Winters, Reictor Engineer, QAS, DRS                                      date
    Team Leader:        mc /              o#rs                                        /a//v/E
                                                                                              ' dath
                                                                                                        ~
                  Macq6'e P. Durr, Chie,f, Engineering Branch, DRS
    Approved by:  .
                            -
                                  Y              c                                      / ?-// 7 [Y
                    ~5tewart D. Ebneter, Director, Division of                              ' date
                          Reacter Safety
        8612290345 861219
        PDR    ADOCK 05000443
        G                    PDR
                                                                                                            ___ - . _ , _
          _            _                    _
                                                    _ - . _ - . _ - -        , _ _ , _            . - _ _
 
                                                          . -
                                  TABLE OF CONTENTS
EXECUTIVE SUMMARY
1.0 INTRODUCTION
      1.1 PERSONS CONTACTED
      1.2 BACKGROUND
      1.3 REPORT ORGANIZATION
      1.4 QUALITY ASSURANCE HISTORY
      '1.5  NRC INSPECTION PROGRAM
2.0 ALLEGATIONS
        No.          Subject                Page No.        'S
          1.          Concrete                  15
        2.            Concrete                  17
        3.            Concrete                  20
        4. & 17.      Concrete                  22
        5.            Concrete                  24      .
        6. 49. & 50. Fire System                25
        7.            Concrete Lining          28    ,
        8.            Service Water Flood      31
        9.            Paint                    33
        10. & 35.      Training                  35
        11.            Training                  37
        12. & 27.      Weld Training            38
        13. & 21.      Drugs                    42
        14.30.31.&60. Work Hours                46
        15.            Painting                  47
        16.            Harassment                49
        18.            Debris in Motor          50
        19.            Fire in Conduit          51
        20.            Startup Checklists        53
        22.            Security                  55
        23.            Security _                56
        24.            Procedures                58
        25.            Frocedures                60
        26.            Procedures                61
        28.            Electrical Training      62
        29.            Training                  63
        32. & 57.      Track Blueprints          64
        33.34.47.59&60 Contractor                66
        36.            QA                        69
 
                                                                                    '
          -63
                        ~
          m..w
e'd-
      ,
                  Table of Contents                            2                                                  ,
it:
                              No.          Subject-              Page No.
                            37.            Literacy Test            70
                            38.            Elect. Paint Thinner      71
; ~
  ''
                            39.            Electrical Fire          73
            .
                            40. & 46.      Pipe Alignment            74
          0-              141.            Security                  76
                            42.            Concrete                  78
                            43.            Housekeeping              80
                            44.            Improper Welds
                      ~
                                                                    81
                            4 5 .-        Welding Argon            83
s
                            48.            Feedwater System          85
  '
          cr
          "
                            51.    s      CBA HVAC                  86
                            5 2 .'        EFW                      87
      4      ;fT          53.            Control Room Sprinkler    88
                            54.            CBA Drawings              90
i                          55.            Turbine Bldg. Equipment 91
                            56.            Records Storage          94
                            58.            Training                  95
gr                          61.            Wet Wires.                96
                  3.0 SUMMARY AND CONCLUSIONS
                  APPENDICES
                  A.    STAFF RESUMES
                  B.    REFERENCE DOCUMENTS
        '
                  C.    PuBLIC SERVICE OF NEW HAMPSHIRE
      '
                        SUBSTANCE ABUSE PROGRAM
.
J
                                      , ,  y  . , , -                . . - . __  . . _ , , m -- _ _ , .-. ,,..
 
                                  EXECUTIVE SUMKARY
BACKGROUND
Tne Nuclear Regulatory Commission (NRC), Region I Office, contacted the
Employees Legal Project (ELP), a nonprofit organization, on August 4,1986,
regarding allegations of questionable construction practices 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 letter to Governor Dukakis
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.
Throughout the contacts with ELP, the NRC requested to be put into direct
contact with the allegers without success. However, two of the allegers made
public statements to the press and issued signed affidavits containing their
concerns. The NRC attended the press conference and acquired the allegers
names and addresses for future contact. These affidavits were not from the
san.e sources as those provided in the Governor Dukakis letter.
The several allegation sources were reviewed by the NRC and each allegation was
listed separately, although it may have resulted in duplicate allegations.
This was done to preclude any issues from being overlooked. This resulted in
sixty-one separate allegations. The allegations were grouped into seven
categories as follows: concrete, piping and welding, painting, procedures and
training, security and drugs, electrical, and management. Where similar or
duplicate allegations have been 'centified, they are grouped and addressed
together in the report.
INSPECTION TEAM
An interdisciplinary inspection team was established to investigate the
allegations. Engineering disciplines of the team members correlated directly
with the technical concern identified in the allegations. Each engineering
inspector had extensive experience in at least one technical discipline and was
thoroughly familiar with the NRC program of inspection. Disciplines represented
on the team were electrical, mechanical, metallurgical, and civil engineering.
These technical disciolines were supplemented by members experienced in fire
protection, security, quality assurance, and plant operations. The team leader
was a middle manager, Engineering Branch Chief, with extensive nuclear
plant construction experience. The team members were authorized to expend
whatever resources were required to resolve the issues. The inspection team
arrived at the Seabrook plant on November 3, 1986.
 
Executive Summary                          2
INSPECTION METHOD
The inspection method was to review the allegation, determine the alleger's
basic concern, and restate the allegation where more detail was needed to focus
on the technical issue perceived by the NRC. Based on the specificity of
information supplied by the alleger, the alleged condition was related to
specific plant areas.    In those cases where specifics were lacking, i.e. the
allegation was in general, broad terms, the team interviewed ELP and allegers
to obtain more details. In most cases, the alleger did not provide further
details.
Plant hardware was inspected and independent tests performed where possible to
evaluate the allegation.      In some cases the previous record of inspection had
documented the allegation and in these cases the record was reviewed and
corrective actions verified.      Interviews were conducted of allegers and plant
staff t'o aid in the inspection.      The bases for any conclusions are derived
from an inspection of the actual item or area if known and accessible, previous
NRC inspections of the issue, established engineering knowledge and quality
assurance records.
SUMMARY AND CONCLUSION
The total number of allegations identified was sixty-one; this was reduced to
forty-seven when duplicates were combined. The inspection, in many instances,
disclosed that previous knowledge of the alleged condition was identified by
the NRC or the licensee and documented in quality assurance records, NRC
inspection reports or formal correspondence between the licensee and the NRC.
Thirteen of the allegations were substantiated in that the statement made by
the alleger was accurate; however, eleven of these allegations were previously
identified by the NRC or the licensee and were appropriately dispositioned by
engineering. 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. Within the scope of this inspection, no nuclear safety
significant issues or violations were identified.
 
1. INTRODUCTION
  1.1 PERSONS CONTACTED
        New Hampshire Yankee
        R. Cyr, Maintenance Manager
        W. Daley, Licensing Manager
        W. Derrickson, Senior Vice President
        W. DiProfio, Assistant Station Manager
        R. Ferrell, Licensing Coordinator
        I. Fugenbaum, Executive Assistant to Sr. V.P.
        W. Johnson, Vice President, Quality Programs
        D. McLain, Production Services Manager
        D. Moody, Station Manager
        T. Murphy, I&C Supervisor
        D. Perkins, Licensing Engineer
        T. Pucko, Senior Licensing Engineer, Regulatory Services
        C. Roberts, Security and Computer Services Manager
        J. Tefft, Project Engineer, Regulatory Services
        W. Temple, Licensing Coordinator
        C. Vincent, QC Supervi:;or
        L. Walsh, Operations Manager
        N. Wiggins, Training Manager
        Yankee Atomic Electric Co.
        G. F. Mcdonald, QA Manager
        S. B. Sadosky, EAR Program Manager
        Employee Allegation Resolution Program
        A. Fasano, Investigator
        W. Gagnon, Investigatcr
        U. S. Nuclear Regulatory Commission
        A. C. Cerne, Senior Resident Inspector
        D. Ruscitto, Resident Inspector
        The above listed personnel attended one or both exit interviews
        conducted on November 7 and 14, 1986. Other licensee personnel were
        contacted as the inspection interfaced with their area.
 
                                      2
1.2 BACKGROUND
      During the May - July 1986 time period, the NRC became aware of The
      Employee's Legal Project (ELP), a nonprofit organization, which is
      designed to receive safety concerns of current and former employees
      of New England nuclear power plants. On August 4, 1986, the NRC
      formally contacted the Employee's Legal Project and solicited any
      safety allegations concerning nuclear power plants under the NRC's
      jurisdiction.
      The NRC came into possession of an unsigned letter, dated
      September 12, 1986, from the Employee's Legal Project to Governor
      Dukakis of the Commonwealth of Massachusetts, containing two
      unidentified affidavits and 35 allegations of wrongdoing at the
      Seabrook Nuclear Power Station. The NRC responded to the Governor
      Dukakis letter with a telephone call on September 23, 1986 and a
      letter, dated September 24,1986 to The Empicyee's Legal Project
      requesting any additional information.    In these contacts, the NRC
      requested Employee's Legal Project assistance in making direct
      contact with the allegers.The Employee's Legal Project responded by
      letter, dated September 25, 1986. In this response, it was stated
      that all allegers refused to meet with the NRC directly. Further, the
      ELP transmitted 10 additional allegations also relating to the
      Seabrook Nuclear Power Plant.
    The NRC transmitted the forty-five allegations to Public Service of-
    New Hampshire, the licensee of the facility, and requested that they
    perform an investigation. Independently, the NRC formulated plans to
    assemble an inspection team to address the allegations. Subsequent to the
      foregoing ELP contacts, two of the allegers provided affidavits and
    media interviews which raised the number of allegations to sixty.
    Some of these additional allegations were duplicates of the previous
    forty-five but originated from a different source and were treated
    as separate issues to insure that all allegations were addressed.
    During the course of the inspection, the NRC contacted the ELP and
    the identified allegers and conducted formal interviews in order to
    gather as much detailed information as possible. The interview
    results increased the number of allegations to sixty-one. Subsequent
    to the inspection on-site, the ELP sent a letter to the NRC inspection
    team leader, dated November 10, 1986, containing clarifications to
    allegations 1, 2, 3, 18, 19 and 22.    These clarifications were
    evaluated, inspected, as appropriate, and factored into the inspection
    findings.
                                                      . _ -
 
                                      3
-1.3  REPORT ORGANIZATION
      The sixty-one allegations generally were categorized into seven
      areas: concrete, piping and welding, painting, procedures and
      training, security and drugs, elsctrical, and management. The NRC
      formed a team consisting of a team leader and six specialist inspectors
      with qualifications in electrical, metallurgical, quality assurance,
      security, civil and operations engineering to address the allegations.
      The team arrived onsite at the Seabrook Nuclear Power Plant on
      November 3, 1986.
      The inspection focused on any general or specific actions that the
      licensee had previously taken to address these allegations;
      any previous actions by the NRC during the course of its normal
      inspection program; and any direct inspection or examinations that
      could be performed after the fact by the inspection team. It is
      important to note at the time of the inspection the major systems,
      structures and components of the facility were completed, and most
      major contractors have demobilized and left the site. The only major
      contractor remainino on-site is United Engineers and Constructors,
      the architect engineer, which has significantly reduced its staff
      size. This means that most of the people that had first hand
      knowledge of the events discussed in this report are no longer
      readily available at the site. The inspection team's charter
      was to address the allegations resulting from the ELP letters, the
      affidavits, and any allegations resulting from interviews directly
      connected with the inspection.
      Further, the licensee has announced the cancellation of Unit No. 2;
      thus, the inspection focused on Unit No. 1 and the implications
      resulting from Unit No. 2 allegations as they might relate to
      Unit No. 1.
      The allegations are numbered one through sixty-one and are sequenced
      in the order in which they were recieved. Where there are duplicate
      or similar allegation;, they are grouped together. The report is
      structured such that the allegation is presented as it was received
      from the alleger, the allegation is restated, as necessary, to better
    define or clarify the problem or concern as it is understood by the
      NRC; details resulting from the inspection are provided and then a
      conclusion based on the facts is stated. The allegation conclusions
      are presented according to whether they are substantiated, true, as
      stated, or unsubstantiated, any part or all of the allegation is not
      borne out by the facts. Those that are substantiated are then
      evaluated for any significant impact on nuclear safety.                    !
                                                                                1
1.4 QUALITY ASSURANCE HISTORY                                                    !
                                                                                !
    As a prelude to the resolution of the allegations, it appears to be        I
    appropriate to describe the Quality Assurance Program that has been        l
      in place since the beginning of constrt.ction at the Seabrook Nuclear      '
    Station. Many of the allegations appear to have been made without the      1
      knowledge of the comprehensive procedures for assuming quality that        !
    have been in place during construction and are continuing today.
                                                                    ___ _    -
 
                                      4
        Public Service of New Hampshire was required to have a quality assurance
      program outlined, approved and in place before construction began.
      This approval was granted by the Nuclear Regulatory Commission only
      after a thorough review. The program was presented in the Preliminary
      Safety Analysis Report which wo submitted with the application for a
      permit to construct the plant.
      The program outlined and implementoa was a three tier system in which
      first level quality control inspections were provided by the organi-
      zation performing the work. The organizational structure was required
      to be such that the quality control group was independent of the
      group doing the work. The second and third levels were performed by
      the Yankee Atomic Electric Company in the form of surveillances and
      audits. These surveillances and audits were and are performed on
      suppliers, fabricators and constructors of safety related equipment
      and structures.
1.5 NRC INSPECTION PROGRAM
      Overlaid on this system is the Nuclear Regulatory Commission's
      inspection program wherein resident inspectors and regional based
      technical specialists perform inspections and audits of all licensee
      safety related activities. To date, the NRC has expended over 20,000
      inspection hours at the Seabrook site verifying that the construction
      meets established requirements. Further, there are other organizatons
      that provide inspection and audits during the construction and startup
      phases such as the American Society of Mechanical Engineers' Authorized
      Nuclear Inspector for the piping systems and the containment to insure
      that the plant meets the national codes.
      The inspection programs do not end with the construction phate. During
      the preoperational and actual plant startup phases, additional tests
      are performed to assure that the equipment functions as designed.
      Each system is tested to demonstrate that it meets performance
      specifications. These tests are run on individual systems and, in
      some cases, as integrated systems where they must function together.
    After the preoperational tests are performed, the startup testing
    program demonstrates that the plant will respond to a known set of
      transients for which it has been designed. All of these tests have
    established acceptance criteria which must be met. These tests are
      reviewed and monitored by the NRC to assure the program is working as
      required.
    Throughout the construction and the preoperational phase, the NRC
    performeo special inspections designed to focus on known critical
    aspects of the project. These inspections included a Region I
    Construction Assessment Team, June 1982; an Inspection and Enforce-
    ment Integrated Design Inspection, November 1983; an Inspection and
 
                                                5
                                              %
    Enforcement Construction Appraisal Team, April 1984; a Region I
    Construction Team Inspection, June 1985; a Region I Independent          j
    Measurements Inspection, July 1985; a Region I As-Built Team Inspec-    l
    tion, March 1986; and a Region I Technical Specification Inspection,
    May 1986. These inspections were designed to examine the programmatic
    aspects as well as the actual installation of equipment.
    Fundamental to all of this is the NRC inspection program which
    examines all aspects of the licensee's construction organization and
    practices. Examples of the NRC's efforts in this area are discussed
    below as they relate to the allegations.
    Several of the allegation conclusions are supported by the fact that
    NRC inspectors interface directly with licensee's staff, the contractors
l
    and subcontractor personnel. This includes the craftsmen performing
    the work. During these interfaces, the inspector discusses the
    technical aspects of the ongoing task including any concerns the
    craftsman may nave with the construction practices. The NRC has been
    informed of allegations by craftsmen on several occasions at this and
    other nuclear power plants. Interviews are an integral part of the
l
!
    inspection process and occur in almost every inspection. Inspection
    reports that provide examples of interviews are presented in Table 1.
    The NRC performed in excess of twenty-six inspections directed toward
    the welding process application, including training and qualification,
    in the nuclear piping and structural welding areas. See Table 2 for
    a listing of sample reports. Welding inspections have also been
    performed on the Heating, Ventilation and Air Conditioning, pipe
    supports, electrical cable trays and non-nuclear components. These
    inspections have included evaluation of the nondestructive examina-
!  tion (NDE) methods used, appearance of welds by visual examination
l
i
    and documentation of weld acceptance. Confirmation of the effective-
    ness of contractor NDE has been verified by independent NRC examina-
    tions using the Mobile Nondestructive Examination Van employing
    radiography, magnetic particle, ultrasonic and other examination
    methods.
    In general, welding god NDE activities were found to be conducted in
    accordance with applI,able codes and specifications. Where problems
    have been identified by the NRC, these have been tracked until completion
    of the corrective actions. A review of a sample of the NRC inspection
    reports indicates that thousands of individual field observations
    have been made over the life of the construction.
    During the construction of the Seabrook facility, the NRC has con-
    sistently been concerned with the training and qualification of
    personnel performing safety related work. The nuclear standards and
  .
    regulations provide for the training and qualification of welders to
    the American Society of Mechanical Engineers, Section IX, nondestructive
    examination inspectors to the Society of Nondestructive Testing
    practice SNT-TC-1A and other inspectors to the American National
          _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
 
                                    6
Standards Institute N45.2.6.      Other training is performed that assures
the technical aspects of construction are satisfied, although it is
not specifically prescribed by codes; examples of this are the cable
splicing and termination and concrete expansion anchor installation
instructions given. The NRC inspects these training and qualification
programs and examples af inspection reports that reflect this are
presented in Table 6.
The electrical inspection program reviewed the procedures, design
specifications, personnel qualifications, and installation and
inspection criteria.      In conjunction with this, the installation of
equipment was observed to assure that the established procedures
were being implemented. The observation phase of the program
included the witnessing of terminations, cable splices, cable
pulling operations and proper routing. The routing inspections also
included the verification of the cable support system. Examples of
these inspection are presented in Table 3.
In the area of civil / structural work, the NRC has performed in-excess
of forty (40) inspection starting in 1976 with geotechnical/ foundation
work to concrete and other structural work. These inspections focused
on the clarity, technical adequacy, and quality assurance aspects of
the controlling specification and procedure of the work to include
witnessing on going work, inspection of completed work, and review
and examination of records generated by quality control to document
conformance to the requirements. Most of these inspections were
unannounced, that is the licensee and/or contractor personr.el did not
know of the impending inspection by the NRC until the arrival of NRC
inspectors on site.      Examples of inspection reports showing areas of
inspection and their focus are presented in Table 4.
As the plant is built, the NRC continuously monitors the progress
and selects completed portions for as-built verification.        This
includes co:nparison of the as-built system with the Final Safety
Analysis Report, drawings and other requirements and commitments to
assure accuracy. Several inspections were made of the as-built
condition of systems, one of which was a team effort devoted to this
alone. Table 5 contains a listing of inspection reports that
address as-built inspections.
All of this inspection is designed to assure that any single error
in design or installation will not prevent the design safety features
from performing as intended. Incorporated into the design features of
the plant are concepts of defense-in-depth and redundancy.
                                                                            l
 
                                            7
,                                      TABLE 1
                              EXAMPLES OF NRC INTERVIEWS
                                AT SEABROOK F0WER STATI0rj
  INSPECTION          DATE                      REMARKS
4
  REPORT NO.
  80-03                2/26-28/80                Electrical
  84-10                6/26 - 8/24/84            Containment, Reactor Vessel
  84-13                8/27 - 10/26/84          Welding
  85-01                2/11 - 4/5/85            Piping and Electrical
  85-07                3/11-15/85                Heating and Ventilation
  85-09                4/8-24/85                Preoperational Testing
  85-10                4/15-19/85                Welding
  86-15                3/14-19/86                Containment Leak Rate Testing
  86-21                3/31 - 4/4/86            Electrical
  86-23                4/14-18/86                Training
  86-34                6/24 - 7/7/86            Bolting, Health Physics
  86-45                8/18-22/86                Electrical
  86-46                7/8 - 9/15/86            Startup Testing, Fireproofing
j
i
    . - - - , - - . - -
 
                                      8
                                                                                      4
                                TABLE 2
                    WELDING AND NDE INSPECTIONS ON
                    NUCLEAR AND STRUCTURAL WELDING
INSPECTION INSPECTION          REMARKS
  REPORT      DATE
                                                                                      :
78-07      4/24 - 4/28/78-      Containment Liner Welding and NDE
78-08      5/22 - 5/25/78      Containment Liner Welding and NDE
78-09      6/26 - 6/28/78      Containment Steel, Welding, NDE, Qualifications
80-03      2/26 - 2/28/80      Stainless Steel Welding, Stud Welding -
                                  One Violation
80-04      4/14 - 4/17/80      Pipe Welding Controls, Overcheck of Shop Welds
80-11      9/16 - 9/19/80      Three Violations - Resolved
81-08      6/29 - 7/24/81      Pipe and Pipe Supports Including NSSS,
                                  RPV Safe Ends                .
81-12      10/5 - 11/16/81      Pipe Installation, Programmatic QA Inspection
81-13      11/3 - 11/6/81      Machine Welding (GTAW)
81-14      11/17/81 - 1/8/82    Pipe Installation, QC and NDE, Interviews
82-03      3/23 - 5/3/86        Reactor Coolant Pipe Welding, NDE, Pipe
                                  Weld Repair Program
82-06      6/21 - 7/2/82        Two Violations Resolved (NRC-NDE Van Insp)
82-10      8/24 - 9/30/82      Pipe and Pipe Support Welding, Interviews, NDE
83-01      1/17 - 1/21/8        End Return Welds (Boxing), Pipe Support Welding
83-06      4/11 - 5/23/83      Pipe, Pipe Support and Electrical Raceway
                                  Installation
83-07      5/23 - 5/27/83      Vessel Internals - Violations - Resolved
                                  Struct Steel
83-09      5/24 - 7/1/83        Piping and Pipe Supports, QC Inspector
                                  Harassment Interviews
83-12      8/8 - 8/12/83        Violation - UT Procedural Problem - Resolved
83-13      7/11 - 8/26/83      RCPB Installation, Instrument Tubing,
                                  Pipe Supports
83-17      10/17 - 12/5/83      Containment - Penetrations and Leak Chase,
                                  Piping and Supports
83-22      12/6/83 - 1/20/84    Small Bore Piping, NDE Qualifications
84-07      4/23/ - 5/25/84      Hardware and Documentation is per Requirements
84-12      8/13 - 8/31/84      Allegation Inspection - Welding, Piping,
                                  Valves, NCR Control
84-17      10/29 - 12/17/84    Interviews of Crafts, RPV, Piping Walkdown
84-16      10/29 - 11/2/84      RPV Nozzle Repair, Pipe and Pipe Support Welding
85-15      6/3 - 6/14/85        Special Construction Inspection, Management,
                                  Welding and QA
85-19      7/15-7/26/85        No Violations (NRC-NDE Van Insp)
                                                      _ _ _ .  -
                                                                  _      _ _ _ . -
                                                                                    _
 
                                                          9
                                                    TABLE 3
                                            ELECTRICAL INSPECTIONS
      . INSPECTION
        REPORT NO.                  DATE                                        REMARKS
        50-443/79-10        December 11-13, 1979        Installation procedures require safety
                                                        related cables installed in raceways.
        50-443/82-03        March 23 - May 3, 1982      Discusses the qualification and flame
                                                        retardant characteristics of Class IE
                                                        cables.
      50-443/82-11        September 20-24, 1982        Verified by inspection that safety-related
                                                        cables are installed in raceways.
      50-443/83-03        February 22-25, 1983        Reviewed the cable pulling program (CASP)
;                                                        and verified that safety-related
                                                        cables were in the specified raceways
                                                        as required by the CASP. Also
                                                        verified cable terminations were made
                                                        per specification requirements.
      50-143/83-05        March 2 - April 8, 1983 Verified that Class IE cables were in
                                                        seismically installed raceways and
                                                        that cable pulls were per procedures.
      50-443/86-36        June 16-20, 1986            Allegation 18 - A review of the HVAC
                                                        re-work was verified by the inspector
                                                        and the operational. testing of the
                                                        system reviewed.
      50-443/86-37        May 10-17 & June 9-13,86 Preoperational testing of the HVAC
                                                        system was verified by NRC witnessing.
      50-443/86-46        July 8 - September 15,86 As built verification of the enclosure
                                                        air handling and PAB air handling
                                                        system.
  .--          - - _ _ . _    -
                                      -  _ - -  _
                                                        _ _ _ - - , .    . . .        _, -
 
                                                                                                              _
                                                    10
                                                TABLE 4
                                            EXAMPLES OF NRC
                                  CIVIL / STRUCTURAL INSPECTIONS
          INSPECTION  DATE                    REMARKS
          REPORT NO.
        76-02        7/14-15/76              QA plan for Construction
        76-03        8/2-4/76                Concrete Quality Control, Qualification
                                              of Concrete Test Lab.
    .
        76-06        12/13-15/76            Interview craft personnel, Cadweld
                                              procedure.
        77-03        7/6-8/77                Qualification of concrete lab, control
                                              of concrete.
'i
        77-06        8/26/77                Craft interview, concrete fill, test
1                                              lab inspection, groundwater control.
        77-07        10/3-4/77              Control of concrete, test lab.
        77-10        12/5-9/77              QA/QC for concrete, rebar, batch plant,
                                              test lab. Sampling of rebar.
        78-02        2/14-17/78            Concrete test lab inspection, observation
                                              of rebar installation inside containment
                                              in reactor cavity. Fill concrete.
                                              Qualification of cadweld splicing process
,
                                              - equipment and crews. Qualification of
                                              concrete testing and inspection personnel.
                                              Waterproofing of containment foundation.
        78-05        3/20-24/78            Observation of Unit I containment basement
                                              placement.            (Placement #1-CPS-3A; 4000 psi
                                              Mix)
        78-07        4/24-28/78            Record review for foundation concrete.
        78-08        5/22-25/78            Observation of concrete placements.
.
                                              (placement #1TB-41B; ITB-27B; CN-E7d;
;                                            ITB-41)
        78-10        7/10-14/78            Observation of containment concrete
                                              (1300 cy of 4000 psi concrete in reactor
i                                            pit structure); Installation of Rebars
;
                                              and cadwelds in containment basement.
,
                                              Resolution of concrete lab conformance
1
                                              to ASTM E-329 (78-02-04)
,
!
'
    .~ ,    _ __. -  _
                        _. -.    .____ _              _ _ _ _ _ _ . _ _ _ . - _ _ _ . _ . . _ _ . _ - _ _ _ . . _ _ _ . . _ _ _ _ _ _
 
                                      11
                              TABLE 4 (Cont)
INSPECTION DATE                REMARKS
REPOPT NO.
78-13      9/5-8/78            Concrete aggregate tests, interview
                                craft personnel.
78-15      11/6-9/78          Observation of containment structural
                                concrete - QA/QC, preplacement, placement,
                                post placement inspection and curing of
                                previously placed concrete (placement
                                #1-CM-7A; 4000 psi mix)
79-01      1/15-18/79          Containment Concrete placement observation
                                records. (Placement #1-CI-1)
79-02      1/24-25/79          Investigation of frozen c.oncrete joint.
79-03      2/12-15/79          Training of site personnel.    (Professionally
                                produced film)
79-07      8/13-16/79          NOV - Void area in excess of maximum
                                      allowed. (79-07-02)
                                NOV - Lack of approved repair procedure
                                        for concrete (major repairs).
                                      (79-07-03)
79-09-      11/13-16/79        NOV - Failure to prescribe corrective
                                action for rebar installation before
                                concrete placement.    (79-09-01)
80-01      1/22-25/80          (Drug Indictments) Observation of cadweld
                                splicing of rebars in Containment Building
                                exterior walls; Observations of placement
                                preparation circulating water pump house
                                walls; observations of cold weather
                                curing of concrete.
80-04      4/14-17/80          Review of cadweld significant deficiency
                                50.55(e)
80-06      5/19/80 - 6/27/80  Observation of concrete base mat placement
                                for Unit 2 containment.
80-12      10/13/80 - 11/21/80 Allegation Investigation of Site Concrete
                                Lab for conformance to ASTM and ANSI
                                standards. Concrete Batch Plant inspection.
80-13-      11/24/60 - 12/31/80 Containment concrete placement (cutting of
                                1000 rebars at Elv. +25.0)
 
                                      12
                            TABLE 4 (Cont.)
INSPECTION DATE                REMARKS
REPORT NO.
81-04      3/12/81            SALP    no change in concrete inspection
                                program.
81-12      10/5/81 - 11/16/81 Concrete placement preparation, cadweld
                                splicing, containment liner and concrete
                                interfacing.
82-03      3/23/82 - 5/3/82    Cadwelding of rebars, corrective action
                                on groundwater leakage.
82-04      5/4-14/82          Concerns regarding concrete repair
            6/1-18/82          (allegation on concrete sand)
82-07      6/14-17/82          Observations of concrete construction of
                                containment review of corrective actions
                                plan for control of groundwater seepage
                                through concrete cracks.
82-09      8/24-27/82          Review of procedures and observation of
                                work in containment concrete preparation,
                                placements, and curing.
83-07      5/23-27/83          Review of documentation of containment
                                dome concrete.
84-07      4/23/84 - 5/4/84    Construction Appraisal Team Inspection
            5/14-25/85          Concrete Activity (Report Section IV)
84-12      8/13-17/84          Team Inspection to resolve allegations.
            8/27-31/84          Cracks in concrete wall; interviews with
                                craft personnel.
86-43
 
                  -    . _        . . . _                . _ _ _ _                                                . _ _ _ _ _ . . . .    _    _  _
                                                                            13
                                                                        TABLE 5
                                                    EXAMPLES OF NRC AS-BUILT INSPECTIONS
                    INSPECTION                              DATE                                      REMARKS
                    85-09                                    4/8 - 5/24/85                            RHR, EFW, Steam Generator
                    85-15                                    6/3-14/85                                Safety injection, RHR, HVAC
                    86-43                                    7/7-11/86                                Cable trays and supports
                    86-46                                    7/8 - 9/15/86                            RHR, CVS, RCS and others
,
!
                                                                                                                                                            .
1
I
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!
!
I
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i
  . _ - - - . . -          . - - -        - , - .                ...-  -    . . . . _ - , - . . - - _ _ _ _ - - .                    - -  . .  . .-
 
      '
,
                              14
                          TABLE 6
              NRC INSPECTIONS OF TRAINING
  INSPECTION
  REPORT      DATE                REMARKS
  79-08      9/4 - 7/79          Quality Assurance
  79-09      11/13 - 16/79        Concrete Placement
  79-10      12/11 - 13/79        Quality Assurance, Welding
  82-06      6/19/82            Nondestructive Examination
  83-12      8/8 - 12/83        Instrumentation, Mechanical,
                                  Nondestructive Examination
  84-07      4/23 - 5/4/84      Electrical, Mechanical
  84-16      10/29 - 11/2/84      Mechanical, Welding
  85-07      3/11 - 15/85        Mechanical
  85-11      4/29 - 5/3/85      Electrical
  85-19      7/15-26/85          Nondestructive Examination
  86-15      3/4-19/86          Startup Mechanical
  86-23      4/14-18/86          Non Licensed - I&C, Electrical,
                                  Mechanical
                                                                  ,
 
                      .
                                                  15
          2.0 ALLEGATIONS
          1. " Cement was poured in below freezing temperature (contrary to product
          recommendation designed to produce proper solidification and strength)."
          NRC UNDERSTANDING OF THE ALLEGATIONS
          NRCs understanding of this allegation is that during cold weather, one place-
        ment of concrete in the containment wall was done where the construction joint,
          top surface from a previous placement, was frozen due to inadequate heating of
          the enclosure provided for cold weather construction protection. Additional
          information provided by the alleger to the NRC, indicated that it happened on
          the night shift in the containment building. Also, the allegation was regarding
          frozen concrete on which fresh concrete was deposited rather than freezing
        weather conditions.
        DETAILS
        The NRC inspector interviewed the Site Quality Assurance Manager and Supervisors
        to determine their knowledge and understanding of site QA procedures during
!
        concrete construction; examined the construction schedule and associated QC
        documentation for the construction of Unit-1 containment structure; and reviewed
        prior NRC-Inspection Reports and other correspondence to determine the history
        of containment concrete and its quality. Because the allegation did not provide
        a specific year or period, the NRC reviewed the chronological construction
        schedule for the Unit I containment structure beginning on 9-1-77 through 4-14-83.
        The concrete placements carried out in cold weather months were selected for
        detailed record review. Out of a total of seventy-seven (77) major and minor
        concrete placements (pours) during this period, sixteen placements were identified
        to have been performed during the months of November through March of 1980 -
        1983.    It was determined by these records that none of the sixteen placements
        were started on the second shift; moreover, only four of the placements were
        started when the ambient temperature was below freezing. The previously placed
        concrete temperature in every case was above freezing levels. These temperatures
;        were recorded by quality control inspectors using calibrated thermometers;
        calibration of which was traceable to National Bureau Standard (NBS). More
        importantly, in addition to temperature measurements, construction joints are
,
        inspected for surface preparation, water and ice, and general cleanliness and
        preparation.
        The inspector determined by review of NRC Inspection Report (IR-50-443/79-02)
        that a similar allegation had been brought to the NRCs attention by a telephone
        call on January 23, 1979. The NRC investigated the concern, and concluded that
        the concern was not sub:tantiated. This conclusion was based on the following:
  - - .      - -      . _ - - -      --      -      -- - -      - _ - . ..    --    . - - -
 
                                            16
      "The inspector examined batch plant, quality control and placement records
      and examined all concrete placements that had been performed at the site
      on January 23, 1979. The placement were:
      Unit No. 1 Administration Building Stack Foundation, Placement A3B,
      Elevation 21 ft., 61 cubic yards, started 12:40 PM, completed 2:30 PM.
      Unit No.1 Condenser Pads, C Bay North, Placement ITPM-80, 5 cubic yards,
      started 2:30 PM, completed 3:30 PM.
      The inspector also interviewed construction supervision, quality control
      and quality assurance personnel involved in the January 23, 1979 placements.
      Each of these persons was found to be fully familiar with the details of
      their placements, including the steps taken to remove the small patches of
      ice that had formed over the previously placed concrete, the use of space
      heaters in the placement areas prior to placement, the use of portable
      propane torches to dry surface water remaining on the previously placed
      concrete, and the measurement by quality control personnel of the concrete
      surfaces prior to placement, to assure that minimum placement temperatures
      were exceeded."
Starting from 1976 through 1984, the NRC has performed 35 inspections /investi-
gations in the area of containment concrete and penetrations to verify the
licensee's conformance to specifications, codes, and standards. Observation of
on going work was an integral part of these inspections, the NRC monitored and
witnessed many of the safety related concrete placements.      (See Table 4.0).
Furthermore, the overall functional capability and the safety of the contain-
ment structure is tested by the NRC required Structural Integrity Test (SIT).
The NRC has witnessed the test, and has evaluated the results. If there was a
deficiency in a construction joint, it is expected that the deficiency would
show-up during the SIT. The expansion of containment due to pressurization
induces cracks in the concrete which are mapped and documented. Any deficient
joint is the most likely place for crack development. No such indications were
noted during the SIT.
The inspector visually examined some construction joints in this inspection,
and did not find any spalling of surface concrete, any cracks visible to
the unaided eye, voids, or any evidence of foreign material embedded in the
joint to indicate unacceptable joint preparation.
CONCLUSION
Based on the summation of NRC inspections, the relatively small number of cold
weather concrete placements, a review of quality records, and the successful
completion of the structural integrity test, it is determined the containment
is struturally sound and there is no evidence of inadequate construction joints.
This allegation was not substantiated.
                                                                                    l
                                                                                    l
                                                                                    l
 
                                            17                                        l
                                                                                    l
2.2 ALLEGATION
" Cement which was tested and rejected as an improper mixture by a safety inspector
was subsequently poured."
NRC UNDERSTANDING OF .THE ALLEGATIONS
                                                                                    l
Based on further amplification from the alleger, it is understood that this          i
occurrence was alleged to have happened on the third shift during a concrete        l
placement in the containment structure.                                              '
In the November 10, 1986 letter to the NRC, ELP provided additional information
as follows:                                                                          1
" Allegation #2: Concrete rejected by an inspector was poured anyway.
When: November - December 1977 or January - Febrmry 108.
Where: Containment of Unit II; could not be ::. ore specific.
Why concrete was rejected:    It did not meet specifications. A woman in white
hard hat had a sample can, put something like a probe in it, rejected it, then
left."
DETAILS
The containment structure is built with a 4000 psi nominal strength concrete
mix. A total of approximately 11500 cubic yards of concrete have been used in
the base mat, the shell, and the dome of the structure. One batch of concrete
which is nominally 10 cubic yards, is a very insignificant part of the structure
(approximately 0.00087 of the total). Also, if the process of placement of
concrete by pumping is taken into consideration, this batch is placed over a
wide area and mixed with previous and subsequent batches by thorough internal
vibration. The primary purpose of all the process controls and field testing
of concrete is to insure production of generally uniform' concrete of desired
characteristics. However, concrete being a hardened mass of hetrogeneous
material is subject to th2 influence of numerous variables. Consistent
concrete of acceptable quality is produced and placed, if proper control is
maintained, test results are properly interpreted, and limitations are con-
sidered.
To evaluate an isolated instance of a batch of concrete which does not meet the
strict acceptance criterion, the following statement in the American Concrete
Institute standard, ACI 214-65, must be considered:
      " Proper control is achieved by the use of satisfactory materials,
      properly mixing these materials....., and good practices in transporting,
      placing, curing, and protecting the fresh concrete."
 
                                            18
        "Whenever practicable, conclusions on strength of concrete should be
        derived from a pattern of tests from which the characteristics and
        uniformity of the concrete can be more accurately estimated. To place
        too much reliance on too few tests may result in erroneous conclusions."
        (emphasis added)
  The quality of structural concrete in the Unit I containment structure has been
  inspected, and the test records of the concrete have been reviewed by the NRC
  periodically throughout the construction phase. These inspections have been
  documented in 14 NRC Inspection Reports (78-01; 78-05; 78-10; 78-15, 79-02;
  79-09; 80-01; 81-12; 82-03; 82-07; 82-09; 82-13; 84-12; and 85-07)
  There are several checks of concrete quality; one at the batch plant, one at
  the point of placement and a final strength test (compressive test cylinders).
  The cylinders are stored to properly cure the concrete for a specified period
  of time and then loaded in compression and the failure strength measured by an
  independent contractor. The strength of the cylinder test is a direct correlation
  to the quality of the concrete and produces an independent check.
  The NRC inspector reviewed the compression test records for containment
  concrete during this inspection.    These records were generated and submitted to
  the licensee by Pittsburg Testing Laboratory, an independent testing contractor.
  The records indicated an average strength of approximately 5000 psi, which is
  25*4 higher than the nominal design strength. Also, there is a latitude in the
  acceptance standards for fresh concrete with regard to air content, slump, and
  temperature.    Isolated minor deviations in these properties do not affect the
  serviceability of concrete. A wide range of tolerance in the acceptance value
  for these properties is allowed in concrete specifications.
  The NRC was unable to determine the significance of the action by the woman in
  the white hard hat. Normally, concrete acceptance requires a set of tests
  specified by project specifications and the Division 2 of the ASME code.    The
  tests include slump, air content, and temperature for every 50 CFT, and in
  addition a minimum of two sets (two 6" X 12" cylinders each set) of compression
  test specimens for every 100 CFT of concrete placed. The inspector / technician
  is also required to record the rejection on the batch ticket and/or acceptance
  form. All acceptance, rejection, or other disposition of the concrete must be
  recorded on the batch ticket that accompanies the batch of concrete. The batch
  ticket is the primary vehicle to account for the production, use, and rejection
  of concrete. Therefore, if the concrete was truly tested by the " woman in
  white hard hat", and she was a QC inspector, she must perform the full set of
  tests, i.e. air-content, slump and temperature; and if the batch is rejected it
  must be recorded on the batch ticket, and the ticket returned to the batch
  plant. The batch plant inspector must review and account for all concrete
  produced and its disposition through the use of batch tickets.
,
  The inspector reviewed concrete batch tickets in conjunction with the cold
  weather concrete placement record review. No instance of rejected concrete
  being placed was identified. The NRC has reviewed batch tickets for many
  placement in safety related structures during prior inspections (see table 4.0).
 
                                                                                                                                                    l
                                                                                  19
                    CONCLUSION
                    This allegation can not be substantiated. It is unlikely that an occurrence of
                    this nature can happen because of the multiple inspection and audits. In
                    addition, actual test samples of concrete by an independent lab verified that
                    the age hardened concrete exceeds design strength by an average of approximately
                    25%.
,
,
e
a
  . . ~ . w-- -- -
                  w ,y 9-+--wwe-9 ,,w,- ,y-w,e-pwen-----7ywwm  mquS+'NehMWWW"MMYW  9--*-
                                                                                                                                              "
                                                              .
                                                                                          CN' - * * *^*" *~ " " " " ^ ' ^ ' " " ' ^ - ' ^ ^ ~ ~ # '
 
                                                                                  s
                                            20
  3.  ALLEGATION
  " Empty beer cans and bottles were discarded in the wet cement by workers drink-
  ing on the job, potentially creating air pockets and affecting the integrity of
  the containment."
NRC UNDERSTANDING OF THE ALLEGATION
The allegation as understood by the NRC is that empty containers (cans and
bottles) were discarded into the fresh concrete during concrete placement.
DETAILS
The NRC reviewed the licensee's alcohol detection / prevention program and other
related documentation. The licensee instituted controls to prevent the use of
alcohol on the Seabrook site. Futhermore, NRC has monitored / witnessed many of
the safety-related concrete placement directly in containment and other
structures. These inspections did not disclose any instance of discarding of
cans / bottles in concrete. The NRC has also periodically reviewed the concrete
placement inspection records generated by the site QA/QC organization. These
records also did not indicate any instance of foreign materials in concrete.
The licensee concrete placement QA program required more than one placement QC
inspector to monitor the placement. On larger placements, six to eight QC
inspectors monitored the placement.    It seems likely that if containers were
being discarded into the concrete, the QC inspectors would notice this problem.
Additionally, engineers and construction supervisors were also present to
monitor and direct the placement operations. None of these technical and
supervisory personnel reported any such incident.
In spite of the unlikely event that large numbers of containers were
being thrown into the concrete, it is possible that some isolated instance
of this act could have happened. To determine the safety significance of such
an occurrence, the NRC evaluated the response of the containment during the
Structural Integrity Test (SIT) under 115*; design pressure. No unusual response
and/or cracks were noticed; the crack patterns developed on the wall were mapped
and compared with the predicted crack growth. It was consistent; indicating no
unusual concentration of voids or imperfections within the wall of the
containment shell and dome.
The NRC also evaluated the likelihood of any void created by these containers,
and its effect on the integrity of the containment. Any metallic container on
the surface of concrete or dropping with the stream of fresh concrete would not
survive the impact of concrete placement drop (5 f t); because the density (unit
weight) of concrete in the containment structure is approximately 145 pounds
per cubic foot; therefore, a can is likely to be flattened leaving no measurable
void. The glass bottles, wnich are more likely to survive the impact, may
remain intact creating the possibility of a void. However, any one bottle can
only create approximately a 12 fluid ounce void at one place (approximately
0.00125 CFT). Assuming 500 containers embedded in the shell, and 40*;
 
                                          21
of these (200 bottles) to be glass bottles, a total void of approximately 2.5
CFT is create.d  The volume of this void approximately equals the volume of one
pipe penetration of 12" diameter pipe through the containment wall. The
conservativeness of design, properties of the concrete-mix used, and the
response of the structure in the SIT provide additional confidence in the
safety of containment.
The inspector further noted that no foreign materials had been observed
embedded in concrete in the containment wall or dome after form removal. The
inspector, therefore, determined that the integrity of the Unit I containment
structure is unimpaired.
CONCLUSION
This allegation can not be substantiated. The probability of a large void
in the containment structure due to any adverse conditions, including cans or
bottles, is very low due to quality control and supervisory activities during
placement. A small void has been shown to be insignificant. The integrity of
the structure and the lack of significant voids, are demonstrated by the
successful structural integrity test.
 
.
                                            22
    4. and 17. ALLEGATION
    4. Superficial patches were applied to major cracks in the containment
    (resulting from improperly cured cement ).
    17. There were cracks in the cement of the equipment vault which were leaking
  water and cracks in the inside containment dome between the inside and outside
  domes which were just patched over. It is my understanding that patching on
  hardened cement does not last very long.
  NRC UNDERSTANDING OF THE ALLEGATIONS
  4. The NRCs understanding of this allegation was that due to inadequate curing
  of concrete placed in the containment structure, cracks developed in the
  concrete and these cracks were only superficially patched. The repairs,
  therefore, were inadequate.
  17. This allegation refers to two related conditions: 1) there are cracks in
  concrete in the equipment vault and containment dome; and 2) water seeps
  through the cracks in the equipment vault.
  DETAILS
  The NRC has been aware of concrete cracks in structures at the Seabrook Station
  through its routine inspections and, in some cases, by allegations brought to
  NRCs attention by individuals. These cracks have been examined and evaluated
  by the NRC from the very early stages of construction. The licensee's actions
  to evaluate and repair cracks in concrete have also been reviewed and found
  adequate by the NRC.
  Cracks in concrete are a common phenomenon recognized and addressed by all
  concrete codes, standards, and specification. The mo;t common cause for
  surface cracks in concrete is due to shrinkage. The exaosed surface of any
  concrete structural member is not considered as part of the structural design
  basis of the member. The structural portions of a slab, beam or wall extends
  from the center of the main rebar on one face to the center of the main rebar
  at the opposite face. The additional thickness of the concrete is provided as
  a cover on all exposed faces of the member to provide corrosion protection to
  the reinforcing bars. Furthermore, in the design of concrete structures,
  concrete is not assumed to resist any tensile stress; it is only designed for
  compressive loads. Cracks, by definition, are separations of material caused
  by tensile stress (pulling apart). The tensile stress is resisted by the
  reinforcing bars in the member; therefore, superficial surface cracks in
  concrete are not a structural concern.
  Pursuant to the current allegation, the licensee again reviewed / investigated
  this concern through his Employee Allegation Resolution (EAR) program office.
  The EAR program investigation similarly concluded that concrete repairs on the
  project were performed properly and were verified to meet engineering
  requirements. No inadequacy in either the repair procedures or their
  implementation was identified.
 
                                                                                    <[                            x
                                                                                                                    s
                                                                                          (
                                                                                                    %
                                            23
                                                                                                      ,                  l
    Cracks in concrete and seepage of water through them have been identified,
    examined and evaluated by the NRC at this project in several structures. The
    results of these inspections are documented in NRC Inspection Reports (50-4,43/82-03,
    82-07, 84-12 and 86-43). The NRC Inspection Report number 82-03 documents'        "
'
.
    leakage of water through concrete cracks in the diesel generator building;
    report number 82-07 documents water leakage in the RHR equipment vault; and
    report 84-12 documents extensive inspection and evaluation of concrete cracks
    and repairs in the waste processing building.
                                                                                                    ,
                                                                              t  s
                                                                                  *
  During this inspection, the inspector visually examined some concrete repairs
  performed to repair cracks in the containment wall and equipment vault for
  evidence of unacceptable workmanship or any degradation, i.e. excessive              3
    surface moisture, mineral deposits, joint cracks / shrinkage, and/or a hollow '                        -
  sound indicating separation of patches from sound concrete. The examined '                              ss
  repairs did not indicate any of these conditions. The inspector, therefore,                          *
                                                                                                              (
  concluded that the concrete repair procedure and repairs were acceptable.
  (Photo nos. 1 & 2)                                                    i
  TherepairofconcreteisdescribedintheAmericanConcreteInstitu[e's
  specification ACI 301-72, " Specification for Structural Concrete for Buildirgs",
  Section 9.0. The inspector reviewed pertinent documents and determited t    that,
  the repairs to ccncrete were acceptable. It met the requirements of the                                            '
                                                                                              '
  Architect-Engineer's (AE's) specification and the governing design and                                                -
  construction codes, i.e. ACI, and ASME, Section III, Division 2.
                                                                                                                    \
  CONCLUSION
                                                                                    s
  The allegation regarding cracks and water leakage was substantiated. Cracks
  in concrete are expected to occur and are permissible if they do not affect the                    -
  integ-ity of tne structure. The inspector concluded that the wall had hairlino '
  cracks, and some of them leaked groundwater through them. However, the repairs                              s
  effected were in accordance with applicable codes, accepted industry practice,                            '
  and approved construction techniques.
                                                                                                                [
  The allegation that repairs to cracks were " superficial" was not substantiated.                            *
                                                                                                                      '
  The effected repairs were technically adequate, and met the requirements of                                    ^
                                                                                                                      1;
  national codes and standards,
                                                                                                                i
1
!
                                                        .    _____  _      _              . , __ -
 
                                                                  . _ . _ ,
                                                                            23a
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                                                                                    '
                                                                                                      ,
                                                                      *                                    .
            ,
          \
                                                                            '
.
              .
                                                                                                    .
!
                          ..
                -; .-
                                                                                        .
                                                                                              - -,.
;                                                                            ,
                                                                                                      .
                                -
                                                .
                                                                                              , .
                              '
    .,
                                        ,                                                  .
                                                                                .,
        _o                                                                                .
                1-    ,
                                                                                  ~
    f,f9,, -                                .
                                              .        .
                                      a                                                            b,L,.?'--l
-
    . e&aaaaaaa                                          asawsw ASA3c iaal& &in                          a-
  <
                        PHOTO NO.1, CONCRETE REPAIRS IN THE EQUIPMENT
                        VAULT ELEVATION (-25')(REF. ALLEGATION NO. 4)
                                                                                                              l
                                                                                                              l
                            .vwsen          xv.w g m
                                                    ->
                                                          ..
                                                                                                              1
                                            .a <
        :                          b                      .'
    t.                                            :...st, . . ' 4'?
    }._;                                      :l
    f_                            0'
    hl'
    t
    D
                                                                                                              l
                                                                                                              l
                                                    :&
                                                              -
                                                                                      ed
                        PHOTO NO. 2, CONCRETE REPAIRS IN CONTAINMENT
                        ELEVATION O'(REF. ALLEGATION NO. 4)
 
  . _ _ . .          _                ._.            .              __. _                              _                _ ._ _.                                                  - __                  __
                                                                                                  23a
            n                          ,;~~wyy , .
                                                                                                            . .
                                                                                                                                                                                                ,
                                                                                                                                                                                                          .k,"i -.
                                                                                                                                                                                                                            l
            J_                                  -/f          3
            t:        .
                                            . p v/e                                                                                                                                                      . <
                                              bp " .                                            ~                                                                                                          .-
            f,x . .';m
                                .
                                    e.q                              s                                                                                                                                          ,
            v ; ..
                            ..
                                  ..
                                                        .
                                                          .
                                                                                                                                                            ,. .                                          ,. -
                                                                                                                                                                                                              -t
            p              .
            1 . . . . .-                        , .                        ..                .
                                                                                                                                                              g.
                                                                        *
            tj.: ? 9:.
            . . ~
                                                                                        .-
                                                                                                                                                                                          :
            L; 91,.:.: ;.
                                                                                                                  '
                                                            ?                  .
                                                                                                                                                                                . , ,
                                                                                                                                                                                            _
                                                                                                                                                                                                      .,
                        ;~ '                  ' g.lg .
                                              '
                                                          T                                                                                                          s.
                                                    1 .pl. 3 , ,'                  ,
                                                                                                                                                                5
                                                    4.._..
                                                      ~ ay. .                                                                                      .
                                                                                                                                                                            .
                                                                                                                                                                                                  .e
                ..                                        , fi', , ..        -
                                                                                                .;:.                                                                    ;$.'.    .
            t.:t, -,                                      ,x,..e                                                                                                                                                a
                                                              hs.i                          .'              '- *                            ~
                                                                                                                                                                                                          g
            o [#
                                            '                                                                        -
l
                            <
                                              q                                                                                      s. -        . . .
                                                su .                                  ..              .
                                                                                                            , . ,                        _
                                                                                                                                                .                .
                                                                                                                                                                                                                .,          .
                                    ./              #r    .                                    y.,                                                        ;y-                            ',.
                                                                                                                                                                                              ,.
                                                                                  44 g,[~)['l, . -[h;$[['k .
                  .
                                                                                                                                                                      ,
                                          *
            -
                                  .
                                                        e7.j,.                                                          ..  .Y .
                                                                                                                                                    g.
                        .m                                          y'.
                                                                    '
                                                                                                                ,
                                                                                                                      ,
                                                                                                                                          -
                                                                                                                                                  v3%g  ^q;:,g...g
                                                                                                                                                                        .;; ,> yht        -      ,..g                      l
l                                                                                                                                                                          s
                                                                                                                                                                                v.op,                          m
!                                                                                          .
                                                                                                                                  ;, ''
l                                                                                      l:                                          's
                                                                                                                                                        .
                                                                                                                                                                        .
                                                                                                                                                                              e                            ,s,. ,'k.
                                                                                                                                                                                                            ..
                                                                                                                                                                                                            :
                r                                                                                              4 + +
                                                                                                                                                        . :, \...              .;k'.,;    s    s:.,qjn'$;l.:.l$k          l
                                                                                                                                                                                                                            l
                                    PHOTO NO.1, CONCRETE REPAIRS IN THE EQUIPMENT
                                    VAULT ELEVATION (-25') (REF. ALLEGATION NO. 4)
l
,
                                                            -
                                                                              wm.  *
                                                                                                  3.+...
                                                                                . .. A
                                                                                  n)
                                                                                  n
                                                                  s
                                                                '
            7.,_
                                    _ LY,l:      .
                                                                _
            AL
            x            .
            g.          -
            w,    .
                                                                    a:a '''                                                    k'
                                                                                '
                                                                                            . . . . . .                                  '' . . .                ..
                                    PHOTO NO. 2, CONCRETE REPAIRS IN CONTAINMENT
                                    ELEVATION O'(REF. ALLEGATION NO. 4)
                                                                                                                                                                                                                      ._. -
 
                                              24
    5.  ALLEGATION
  " Steel rods designed to support the containment walls were improperly severed
  at the second story level of the reactor to simplify the construction process."
  NRC UNDERSTANDING OF THE ALLEGATION
  As understood by NRC, the allegation pertains to the containment structure
  reinforcing bars (rebars) that were cut at 2' above the final slab elevation of
  25'-0". These dowels represented the vertical rebar for the seven foot shield
  wall around the pressurizer and four steam generator openings.
  DETAILS
  The rebars in question were reinforcement for the shield wall around the steam
  generators and the pressurizer inside the containment. These walls are not
  structural members nor do they contribute to the safety function of containment
  structures. The walls are designed and constructed to provide radiation shielding
  to personnel inside the containment during outages and maintenance operations.
                                                                                      .
  The NRC was aware of rebar cutting to facilitate the setup of the concrete
  system during construction inside the containment. The licensee cut approxi-
  mately 1000 rebars at about 2' above the final slab elevation (25'). The
  approval of this cutting operation included the engineering decision to install
  cadweld splices at the cut dowels to extend the rebar curtain again at a later
  date. The NRC inspection report 80-13 documented this particular cutting of
  rebars described in the allegation. The above concerns were reviewed and evaluated
  by the
  NRC. The original design of the shield wall provided for lap splicing of rebar.
  The Architech-Engineer's Engineering Change Authorization (ECA 01/06198) replaced
  the lap splices with cadweld splices. The NRC examined the technical adequacy
  of this design change, and determined that the design change was acceptable,
  because cadweld splicing would return the cut dowels to a condition equal to
  the original design. "Cadweld" splices are stronger than the rebar itself.
  The NRC concluded that this design change does not affect the safety of
  containment.
  CONCLUSION
  The statement that the rebars were cut is substantiated. However, the cut
  dowels were spliced by the "cadneld" process which is an acceptable way of
  joining rebar.
2
          _ , , _ _ _ _ _ _ _ . _ _ _ . . _ _  _      _ _ .      _
 
                                              25
  6. 49. and 50. ALLEGATION
  6. "The volume of the water from the fire sprinkler system is not adequate because-
  the pipes are partially clogged from sitting for several years with water in
  them. When the fire sprinkler system was tested, it was only checked for
  pressure not for volume."
  49.  " Pipes in the fire protecticn system were dangerously clogged because
  they sat for years with water in them.
  The pipes are so clogged that they could not carry enough water to put out the
  fire."
  50. "While performing preventive maintenance on the batteries to the emergency
  diesel pump, testing was being done on the system at the fire pump house. The
  testing was for sediment in the pipe.
  The testing involved tapping of the main pipe for the sprinkler system. The
  test ran for 24 hours a day.
  After the ground thawed out, the workers began to remove and replace the pipes
  coming out of the fire pump house.
  ...A  pipefitter showed me one of the elbows that had been removed. The elbow
  was approximately 12" and it contained sediment which was clogging the sprinkler
  system. This pipe was so clogged with hardened sediment that there remained a
  hole of only about 4 inches in diameter or 3/4 clogged."
  DETAILS
  The NRC inspector reviewed these three allegations which question the ability
  of the Fire Protection System to carry an adequate supply of water to the plant
  sprinkler systems.
  The inspector reviewed NRC inspection reports 50-443/85-06 and 50-443/86-32
  that are directed toward Fire Main Loop Installations and the Fire Protection /
  Prevention Program and noted that conditions that prevent delivery of water at
  sprinkler locations were not identified. During inspection 86-32, the insoector
  verified a surveillance and testi.y program for fire protection equipment was
  established. Procedures for traintenar.ce, inspection and testing of fire
  protection equipment were reviewed and found to be adequate.
  To establish the present cor.dition of the Fire Protection (FP) System, the inspector
  observed Fire Hydrant Testing, Sprinkler System Testing and examined screens as
  removed from two locations in the fire protection piping. Further, documentation of
  detailed cleaning packages for eleven Fire Protection Systems and the General
  Test Procedure GT-C-01, Revision 11 for flushing, and the YAEC-SQC
.
'
  Inspection Report Q-02-03-01 for QC inspection of disassembly, cleaning and
  reassembly of fire pump house piping (Work Requests FP 841 and IIL #FP-1037)
  was reviewed. These reviews verified that quality control inspections and
  operational tests were established and performed.
                _
 
  _          .
!
l                                              26
    The NRC inspector interviewed the Insurance Representative to confirm that 100%
!  of the Fire Protection System is as-built inspected and functionally tested for
'
    insurance purposes in addition to previous plant startup, cleaning and
    surveillance testing. The functional testing of each fire sprinkler system and    I
    fire hydrant test is witnessed by the American Nuclear Insurers representative,
    the Director of Technical Review. The American Nuclear Insurers memorandum,
!  dated October 22, 1986, as reviewed by the NRC, documents the preparation and
i
    execution of test procedures for Fire Protection Systems M, U, V, W, WA and WB.
    On November 4, 1986, the NRC observed the Insurance Tests for systems
    "P" and "I"; the Electrical Transformer 2" Drain Tests for UAT-1X-2B, GSU-1X-1B,
    RAT-1X-3A, UAT-1X-2A, UAT-1X-1C and GSU-IX-2A; and the Hydrant #1 (1-FP-V-0316)
    Flow Test. The expected pressure and water volume flow characteristics were      .
    achieved with no evidence of line blockage noted. The water flow that was        l
,  visible during the inspector's test at the far end of sprinkler loops was
!  slightly discolored but not indicative of significant sediment or pipe clogging.
    Water flow from the Hydrant Test was measured to be a total of 1753 gallons per
    minute from two nozzles at 147 psi. The stream through a 1 3/4" nozzle reached
    beyond 200' from the nozzle. All water flowing from the hydrant was clear. An
    examination of the Fire Pump House two diesel engine driven pumps and one
    electric driven pump was made by the NRC inspector. The Fire Pump House is
    kept locked when not attended, critical valves are chained and locked in the
    required (open or closed) position.
!  Chlorination of the Fire System Water which was initiated in October 1983 was
    noted to be in progress. This chlorination was initiated as a measure to
    prevent microbiological induced corrosion (MIC) in the unlined portions of the
    FP system piping. In conjunction with the FP system chlorination, piping in
    the Fire Pump House was disassembled to remove MIC deposits and reassembled.
    Evidence of the success of the chlorination and pipe cleaning work was noted
    during observation of system test water clarity and the clean condition of
    system strainers at the input to the containment building FP system and at the
    most remote portion of the FP system piping, the Service Water Chlorination
    Building. The present water source for the Fire Protection System is the
    Seabrook area public water supply (potable water).
    The NRC inspector reviewed the following drawings and compared them to documen-
    tation of testing and flushing of the Fire Protection System.
          9763-F-604058 - Fire Pump House Piping Plan
          9763-F-604068 - Yard Fire Protection Piping Diagram
          9763-F-604146 - Fire Protection System Standpipe Diagrams
    In summary, the inspector found that some MIC had occurred in Fire Pump House
    piping, but corrosion products had been removed with further growth prevented
    by chlorination. As-built FP piping reviews and testing have confirmed sufficient
    flow volume and pressure capability to be present in the Fire Protection Piping
    Systems.
 
        [
                                        27
CONCLUSION
Field observation of system testing and examination of a sample of system
strainers by the inspector did not show a significant problem with sedi.sentation
in Fire Protection (FP) piping system. Prior FP piping system problems (Fire
Pamp House Microbiological Induced Corrosion (MIC)) have beer; identified and
corrected by the licensee. Allegations number 6, 49 and 50 were not found to
have plant safety-related significance. The FP piping outside the fire pump
house is concrete lined piping and could give the impression of being partially
clogged with hardened sediment.    The allegations are not substar.tiated.
                                    ,-                                    .-
 
                                  _ _ _ _ _ _ _ _ _ _ - _ _ _ _    _ _ _ - _ _ __
l
                                                                28
  7.    ALLEGATION
f
  "When the service water lines were tested, some of the inside cement coating
  broke off. This system cools essential parts of the plant and must be
  debris-free. The only parts of the lines replaced were the elbows where the
  greatest friction occurs."
  NRC UNDERSTANDING 0F THE ALLEGATION
  During interviews with the alleger and the Employees' Legal Project (ELP), no
  additional details were provided about the service water (SW) cement lined
  piping concerns. To establish the likelihood of a safety-related problem with
  SW piping, the typical SW cement lined piping installation and inspection
  sequence and the resolution of SW line coating deficiencies were reviewed.
  DETAILS
  The NRC has received allegations related to this subject in the past. The NRC
  performed a detailed inspection of the service water pipe concrete as detailed
  in Inspection Report No. 50-443/84-12. The following quotations from the NRC
  inspection outline the scope and findings relative to cement lined SW piping:
        "For cement-lined service water (SW) pipe, the staff reviewed records                        {
        and drawings, interviewed engineering and supervisory personnel and
        observed concrete lining inside piping. The staff entered the 42" pipe
        and visually inspected approximately 40 linear feet. The SW pipe is
        classified as safety-related ASME Class 3, Seismic.
        The inspection was conducted to determine the conditions and controls
        applicable to pipe cold springing, to establish if the lining cracked
        during pipe fitup or welding, and how cracking woulc be identified such
        that repair could be initiated. Interviews and records review were
        concentrated toward service water piping in the area between the diesel
        generator building and the waste processing building. The staff visually
        inspected accessible interior and exterior portions of the SW pipe in
        several areas...
      The staff found that it is unlikely that the cement lining would have
      been subjected to sufficient forces to cause significant cracking by cold
        springing the pipe during installation.                    Should cracking by this mechanism
        have occurred, it would have been identified during work operations
        including QC inspections conducted in the pipe after welding and those
      cracks exceeding the 1/32" criteria would be repaired.
      The inspector entered the 42 inch diameter line 2-SW-1825 thru the opening
        for SW valve V-46 and observed the cement lining and junctions at weld
        seams for approximately 40 feet. The lining did contain hairline cracks
      although these were of a width much less than the 1/32" acceptance criteria
        in paragraph 3.4.3.10.6 of Specification 248-2. The lining at weld joints
      was noted to be smooth and merged with the pipe lining."
                        _ _ _ _
 
                                            29
The NRC inspector, during this current inspection (443/86-52), to resolve
allegation number 7, reviewed the following documentation regarding the service
water piping lining problems, corrective actions and continuing inspection
programs.
      --CDR 85-00-13 dated 8/20/85 - SW polyurethane insert detachment
      -- PSNH Letter SBN-1198, dated September 18,1986 " Service Water System
          Lining Inspection"
      -- PSNH Letter SBN-1001, dated April 10,1986 " Final 10CFR50.55(e) Report:
          Service Water System Spool Linings, Pipe Inserts and Valve Liner / Seats
          (COR 85-00-13)"
      -- PSNH Letter SBN-874, dated September 18, 1985, " Interim
          10CFR50.55(e) Report: Service Water System Spool Linings,
          Pipe Inserts and Valve Liner / Seats", J. DeVincentis to
          R. W. Starostecki
      -- PSNH Letter SBN-923, dated January 13, 1986, " Interim
          10CFR50.55(e) Report: Service Water System Spool Linings,
          Pipe Inserts and Valve Liner / Seats", J. DeVincentis to
          R. W. Starostecki
      -- PSNH Memorandum dated 3/27/85 " Summary of Service Water Cement
          Lined Piping Concerns and IRT Recommendations"
      -- NCR 7035-4481
The NRC inspector reviewed the licensee memorandum, dated 3/27/85, which states
that the STD operation of the Service Water System to date has included a
pre-fill inspection, filling, flushing and 200 as well as 700 hr. teardowns for
internal visual inspections.      Upon initial operation, pre-heat-exchanger
strainer debris contained considerable grouting compound fragments as well as
other miscellaneous material. Recent debris still contains grouting compound
fragments but in negligible amounts.
NRC inspection was also directed toward the lined service water pipe system
during observations and reviews made during resolution of CDR 85-00-13. This
CDR is closed in NRC inspection report 50-443/86-47. The NRC inspector reviewed
licensee status reports on the implementation of corrective action in progress
and periodically checked field rework activities including grit blasting, pipe
and valve relining, and QC inspection of Belzona lining thicknesses by
spark-testing techniques. YAEC QA surveillance inspection reports of the SW
modifications were reviewed to confirm compliance to UE&C procedure FPP-13,
" Application of Belzona Coatings to Interior Surfaces". The inspector also
reviewed an Employee Allegation Resolution (EAR) file which addressed a concern
regarding Belzona material curing times and the minimum purge time between
metal washings after grit blasting.
 
                                            30
  Additionally, an inspector witnessed reinspections in March and September, 1986
  of the Belzona liner material after operation of the SW system. At both times,
  the piping in the proximity of service water valve SW-V-15 was checked because
  of the heavy cavitation expected downstream of that valve due to the design
  flow condition during periods of SW dump to the cooling tower basin. This
  particular operation is needed for basin deicing in the winter months. The
  inspector noted no evidence of Belzona lining deterioration, even where lining
  pits had been repaired during earlier rework activities.
  In letters to Region I dated September 18 and October 15, 1986, the licensee
  addressed the recent SW lining reinspection and its results and committed to
  another internal inspection after the first refueling outage. The inspector
  evaluated all licensee rework, analyses, and reinspections and verified the
  conduct of appropriate corrective action with adequate QA/QC coverage.
  The NRC inspector by review of the existing NRC inspection reports and licensee
  documentation established that the primary corrective action for service water
  piping internal coating problems was to repair or replace the coating. The
  above documentation indicates that while problems were identified with portions
  of the concrete and polyurethane lining of SW piping, these problems were
  evaluated and corrective actions implemented.
  CONCLUSION
  The portion of the allegation that some concrete coating was found detached
  from the SW piping during testing was substantiated. This condition and
  related SW pipe lining problems have been previously identified and resolved by
  the licensee anc reviewed by the NRC. The presence of safety related plant
  problems as implied by the balance of the allegation was not substantiated.
                                                                                    l
                                                                                    1
,          , . _ _ _ _ _ _ _ _ . -    ,                                  -      -
 
                                          31
                                                                                  :
                                                                                  l
8. ALLEGATION
"When the Service Water System was turned on for testing a valve was accidently_
left closed. A geyser of 750,000 gallons of salt water flooded the equipment
vault building."
NRC UNDERSTANDING OF THE ALLEGATIONS
What was the source, magnitude and effect of the service water (SW) discharge
on the contents of the equipment vault building and were steps taken to
examine affected components, remove salt water deposits and to prevent
recurrence.                                                                      ;
DETAILS
The station Incit.ent Report (SIR) 0009, dated 6/27/86, states "On 5-27-86
service watar was discharged from the SW overflow line, flooding the outside
area between the PAB Building and D/G Building. Some of the seawater was
washed ov r into the North Vault stairwell wetting all piping, instrumentation,  !
electrical equipment, conduit, insulation, etc. with saltwater. Reference        '
attached sheets for incident report, affected areas and corrective actions
taken."
The SIR 0009 time log indicates the SW overflow alarm initiated at 0932 hours
and both service water pumps were shut down at 0936 hours for an overflow
duration pump time of four minutes. The licensee, under Work Request 86-002088
provided for investigation and identification of all items wetted by seawater
in the North Vault Building. Corrective actions included washdown with
demineralized water and verification of effectiveness by chemical analysis.
Electrical components and instrumentation were included in the post cleanup
inspection.    Refer to photograph number 3 showing the SW overflow outside the
PAB.
The above incident was caused by the outematic alignment of Service Water (SW)
during an abnormal operational alignment. As a result of this and a previous
incident, a logic change was made to the valve control circuit to prevent
recurrence. During this incident, seawater entered the North equipment vault.
All wetted insulation was removed from equipment and piping, the effected
equipment and piping was washed with demineralized water and a chloride swipe
test was performed. All wetted insulation was either washed and swiped, as
stated at ce, or replaced. All electrical equipment was dried and tested to
ensure proper operation.
The NRC inspector evaluated the event duration, pump capability, overflow
location and area drains to establish the magnitude of water flow into the
equipment vault.
                              ..    . .                                  _  _
 
                                          32
The SW overflow event of 5/27/86 with two 10,500 gpm SW pumps operating in the
overflow mode for four minutes is estimated to be 84,000 gallons of discharge.
The SW overflow is located outside of the Primary Auxiliary Building and away
from the equipment vault building entrance. A 32" x 50" rectangular drain is
located between the SW overflow and the doors leading to the equipment vault
door. Due to the distance from the SW overflow to the equipment vault door,
the unimpeded flow route away from ground drains and elevation differences the
inspector concluded that only a small portion of the SW overflow water would
have entered the equipment vault.
                                                                                .
The inspector reviewed documentation of the SW overflow event including Work
Order 86-W-002088 verifying that cleanup activities and subsequent inspections
had been performed. The NRC inspector examined components including,
piping and wiring in the Equipment Vault Building for evidence of salt deposits
and corrosion effects from residual saltwater. No concerns were identified.
One trace of white substance that appeared to be leachate from concrete at
elevation minus 61 was submitted for chemical analysis. This substance was
confirmed to be boric acid. The chloride salt content of this material was
less than 0.01%, and is considered to not be an indication of seawater presence
in the building.
In summary, while the Service Water System overflow line was shown to have
flooded the area outside the equipment vault, only a minor amount of saltwater
compared to the stated volume of 750,000 gallons entered the equipment vault.
Corrective action including washdown, examination and testing of components was
controlled by work order and involved engineering, operations and maintenance.
CONCLUSION
The portion of the allegation indicating that the service water overflow did
release saltwater during testing on 5-27-86 was substantiated. However, the
quantity of water passing through the overflow was estimated by the NRC
inspector to be significantly less than 750,000 gallons. The NRC inspection
of the affected area did not reveal any evidence of water damage or degraded
equipment.
 
  ._ _ -__                                . .. - .          _                        _                _ _ _ _                    . _ _ .    . _ _ _ _ _ _ _ _ _ _ _ _ _ _
                                                                                        32a
                                                                                                                -        -
                                                                                                7
                                                                                          ,
                                                                                              -
                                                                                                                          K
i
                                                                .
                                                                                                                                N
                                                            -
                                                                              a
!                                                                                    +
                                                                                '
l
                                                                  .            .    ,
                                                    ,            um
)                                                        --
                                                                  ._
                                                                            _
                                                                                                    ..
                                                                                                                                                                              l
                                                                    . . ,,                                                                                                  )
                                                                                                                  ~~
                                                        '
                                                                        .
                                                                                                                        :
                                                                                                                                              .
                                                                                                                                            .
                                                                      .
                                                      *'    '
                                                                                  ' ,          ...A . 47          W -.
                                                                                                                    .
                                                                                                                            ' * ',_
                                                                                                                              -
'
                                                        PHOTO NO. 3, VIEW OF SERVICE WATER
'
                                                        OVERFLOW DISCHARGE PIPE AND SUR-
                                                        ROUNDING AREA (REG. ALLEGATION NO.
                                                        ROUNDING AREA (REF. ALLEGATION NO. 8)
  . . - .  . . . - _ . _ - . . _ _ _ - - -                                        _        ..
 
                                              33
  9. ALLEGATION
  " Paint is crucial to the plants safe operation in keeping dust down and so
  radiation can be easily washed away. The paint on the floor of the containment
  is peeling".
  NRC UNDERSTANDING OF THE ALLEGATION
  As understood by NRC, this allegation was a concern with bubbling and peeling
  of paint on the containment building floor.
  DETAILS
  The NRC inspector examined all floor paint from elevation - 25' to +25', and
  did not find any bubbling or peeling of paint anywhere on the containment
  floor. The inspector, however, observed that in some areas of the floor on
  elevation +25' original paint had been reworked. (Photo No. 4)
  Paint peeling can be caused either by surface moisture or lack of adhesion; the
  most common cause of paint bubbling is moisture on the substrate. The lack of
  adhesion may stem from many causes, e.g. chemical incompatibility, insufficiently
  cleaned surfaces and/or poor paint application practices. However, any of these
  problems are very quick to appear on the painted surface during the first few
  months after the application. The inspector also determined that there were
  some problems with paint adhesion on the containment floor which were identified,
  evaluated and dispositioned by engineering. This process is documented on
  Nonconformance Reports (NCR) 59/5463A and 59/5463B. A test program of the
  "Elcometer Adhesion Test" for the suspect area was implemented, and a repair
  procedure on the basis of the test results was developed. The procedure included
  removal of questionable coated surfaces, rotopeening the exposed concrete and
  reapplication of new sealer, and then coat the area with approved paint.
! The NRC inspector visually examined the repaired areas to determine any
  evidence of coating failure, i.e. peeling, flaking and/or bubbling of paint in
  these areas. There was no visual evidence of coating failure in either the
  repaired areas or the areas with original coatings. The original coating
  application and the repaired areas appeared adequate.    No other problem of
  bubbling or peeling of paint inside the containment has been reported after the
  repairs were effected in the summer of 1986.
  The NRC inspector reviewed quality control records, test data, and nonconfor-
  mance reports related to coating inspections. During this review, the inspector
  noted that approximately 4% of the total coatings inside containment deviated
  from one or more of the acceptance criteria:
        -
              Surface preparation could not meet the standards of class 1
              preparation due to inaccessibility of the area.
        -
              Small equipment supplied by other vendors that came with
              coatings /pa'nts applied from the suppliers.
        -
              Installed piping in component cooling water system.
                                                                                    i
                                                                                    l
                                                                                    l
                                                                                    1
                                                                                    I
                                      ..                      _
                                                                  _
                                                                                    l
 
                                                                                            !
,
                                            34
  Any area determined to fall within the above categories was identified and
  inventoried on a log maintained by QC titled as "The Unqualified Coatings Log".
  The licensee is currently evaluating the effect of these deviations from the
  coating criteria. The resolution will be reviewed by the NRC.
  The inspector also reviewed NRC independent examination and measurements of
  coatings inside the containment performed in August, 1984. This confirmatory
  inspection was performed with a Zormco 2002 paint thickness gauge, and dry film
  thickness (DFT) was ineasured in addition to a general visual examination for
  workmanship. This examination indicated that, on the average, the DFT was in
  the 15 to 25 MILS range, and the workmanship was adequate (IR 50-443/84-12).
  Furthermore, the painting and coating inside the containment is not safety
  related to the extent that it does not contribute to the safe operation or safe
  shutdown of the reactor. The only safety implication of the paint is that
  peeling and flaking paint, if extensive, could clog the sump grating, thereby
  affecting the suction of the containment spray recirculation. The main purpose
  of the paint is to make decontamination easier in case of any radioactive
  spill.
  CONCLUSION
  The allegation is not substantiated. No bubbling and/or peeling of floor paint
  in the reactor building is evident at the present time.            Some paint peeling had
  occurred in the past, but adequate repairs have been accomplished.
                                                          _ _ _ _ _                      _
 
    - - .- - - __ . -        -. -,. .-                            -.  - - - -.
,
l
'
                                                                                  i
                                        34a                                      )
f
                                            -
l
[                                                                                ,
                                                                  s              I
                                                                                  l
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                                                                      ,
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                                                        .                        \
                        -                                                        }
                                  -
                                              .
                                                            .
                                                                                  \
                                                                                  l
                                                                                  <
                                      .  .,                  .
                                                                  .
                                        sgQ f.        ' ,_ .
                                            -
                                              4
                                            %. , s - .  ..
                                          .s.
                                                                                  l
                      PHOTO NO.4, EXAMPLEOF PAINTTOUCH-
                      UP ( REF. ALLEGATION NO. 9)
t
                                                                                  I
                                                                                  i
                                                                                  l
  !
:
.
                                                                                  l
.
 
                                                          __
  _ . .        ._    -..          _
                                                                          l
                                                        24a
                                                                          l
                                                                          l
                                                                          ,
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                                                                          .
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                                                                          l
                                                    - < ~            ,
                                                    .
                                                  :.
                                                    ,              ,,
                                    PHOTO NO.4, EXAMPLE OF PAINTTOUCH-
                                    UP ( REF. ALLEGATION NO. 9)
,                                                                        i
l
                                                                          l
                                                                          I
                                                                          l
                                                                          l
        - - . .    _ -    __ . _ _      _ _ _              _-_-      -
 
                                            35
10. AND 35. ALLEGATIONS
10. No training records exist before April, 1985, preventing assessment or
verification of training and orientation process.
35. People being trained, retrained and left untrained because of inadequate
tracking systems.
NRC UNDERSTANDING OF THE ALLEGATIONS
10. No training records exist prior to April 1985, preventing assessment a'
verification of training and orientation processes.
35. Some employees were trained, some were given the same training more than once
and some employees did not have any training.
DETAILS
The NRC inspector selected and reviewed training records generated by Pullman
Power Corporation, Fischbach-Boulos-Manzi-NH, and Perini Power Constructors,
Inc. covering the period from February 1979 through November 1982. These
records were generated by the respective companies and the records reviewed
covered such topics as Superintendents Indoctrination, Quality Assurance Manual
Review, Project Rules, Hilti Installation, Inspector Indoctrination and Receiving
Inspection.    The inspector determined that for the balance of plant the
contractors were not required to retain training records for their employees.
Contracts which included installation of balance of plant equipment were the
turbine generator by General Electric, the intake and discharge tunnels by
Morrison-Knudsen, and the main condenser by Union Boiler. In the case of these
contractors, if qualifications and training were required to perform certain
operations, e.g. welding or nondestructive examinations, such qualifications
were established and documented and records are available.
Yankee Nuclear Services Division conducted eleven audits that included training
on seven contractors during the period from May 1978 to December 1981. In
addition United Engineers and Constructors (UE&C), Reliability and Quality
Assurance Department conducted ten internal audits on UE&C training activities
during the period from July 1974 to October 1985. No significant oeficiencies
were found during these audits.
The NRC inspected training and qualification programs as a routine part of the
inspection program during tne construction phase.    Typical reports that discuss
inspection of training are 50-443/79-10, 79-03, 82-06 and 84-16; other reports
are listed in Table 6. The inspection of training programs was supplemented by
direct interviews of craftsmen, engineers and quality assurance personnel to
determine their knowledge and understanding of the technical requirements.
The quality of the training programs was ultimately reflected in the quality
of the equipment installations. The quality of equipment installation was
extensively examined by the NRC.
        _            _    __
 
                                                    .
                                            36
The Construction Site Training Group was established in April 1984 to coordinate
site training previously performed by each contractor. This Group was subsequently
transferred to the General and Speciality Training Department in April 1985.
Records generated by the contractors have been stored in the document control
center.    In the existing system, tracking is initiated either when an employee
is hired or when the individual receives General Employee Training (GET) required
for access to the protected area. In addition, all station staff employees are
requested to verify their training record annually. The inspector determined
that some employees records are not maintained in this system. These employees
are those that were working at the site prior to establishment of the present
systems of. record tracking and have not received GET.
CONCLUSION
The allegation that training records did not exist before April 1985 was not
substantiated. A review of existing files confirmed that training racords do
exist for the period before April 1985.      In those cases where an Omployee's
position requires admission to the protected area or qualificscion to specific
requirements, the records are stored in the licensee's document control system.
The adequacy of the tracking system for control of training and qualification
for safety related activities was inspected throughout construction by the NRC
as exemplified in the details of allegations 12 and 27. The inspector determined
that training and qualification records exist for personnel who worked on
safety related contracts prior to April 1985.
                                                                                    i
                          _
                              --
 
                                            37                                    ,
                                                                                  !
                                                                                  !
11. ALLEGATION
" Extensive written procedures and instructions were used as a primary training
tool, although some workers were illiterate and many foreign engineers were not
fluent in English."
NRC UNDERSTANDING OF THE ALLEGATION
1.    Those individuals who have difficulty in reading and comprehension were
      unable to absorb the training when written material was used as a training
      aid.
2.    Foreign engineers not fluent in English had difficulty with training when
      written procedures were used as training aids.
DETAILS
The inspector discussed the hiring practices for United Engineers and
Constructors with the site personnel manager who had been at the construction
site since 1976. The personnel manager described the system used to screen
professional engineers which included interviews with the personnel department,
departmental and supervisory staff; completion of application forms, and
verification of education. The personnel manager confirmed that foreign born
professionals were employed but believed the employment process would have
screened out persons with significant fluency problems. Further, the employer
utilizes an employee performance appraisal system which would also identify
unacceptable performance. During construction, employees committing repetitive
errors are soon singled out and some form of corrective action applied. If the
communication problem was severe, it would be reflected in unacceptable work
and be detected by the multiple checks and counterchecks.
Nonprofessional employees were required to complete an application and interview
with supervision to assure their acceptability.
NRC inspectors interviewed both professional and craft personnel during the
routine course of inspections including foreign nationals. The interviews were
focused on the individuals understanding and knowledge of the technical content
of the procedures, specifications and drawings utilized for construction.
Thirteen examples of NRC inspection reports that discuss interviews of engineer
and crafts personnel are listed in Table 1 of section 1. No instances of
fluency or literacy problems were identified.
CONCLUSION
This allegation was not substantiated.
                          _ __  .
 
                                          38
12. and 27. ALLEGATION
12. " Workers with no previous experience were trained "on the spot" in
delicate techniques to perform critical welding (and other reports allege that
although all welds should be tested, many are inaccessible)."
27.  " Improperly trained welders welding on the job site."
NRC UNDERSTANDING OF TS ALLEGATIONS
1.  Welders with minimum or no experience were hired to perform welding on
    safety-related systems.
2.  Subsequent to the welding operation but prior to testing, the location of
    the joint may become inaccessible due to the installation of other equipment.
DETAILS
The NRC inspector reviewed the Pullman Power Products Procedure II-8 for Welder
Performance Qualification and the General Welding Standard GWS-III to confirm
that Welder Qualifications are required to be done per the ASME Code Section
IX for piping and pipe supports and that limited access welds are required to
be evaluated to determine if special methods are required to perform the weld.
The inspector determined that a training program was established by the
licensee in cooperation with Local 131 of the United Association of Plumbers
and Steamfitters Union. This training was carried out off site. Upon
completion of the training, individuals were brought to the site for
familiarization and qualification testing. During this qualification and
testing period, the worker was given time to become familiar with the specific
equipment to be used for the qualification test and then required to weld the
test coupon. This test coupon welding included requirements for the materials
used, electrodes used, position of the coupon and other variables required by
the codes and specifications. In cases where the individual would be required
to make joints with limited access, a test with limited access was performed.
Also, when a weld would become inaccessible due to subsequent installation of
other equipment, inspections were scheduled and performed prior to the joint
becoming inaccessible.
The welder training and qualification activity at Seabrook has been reviewed
numerous times during construction. The stringent nature of the qualification
process is indicated by a Qualification Test fail rate of approximately 70's.
As an example, inspection results as reported in NRC IR 50-443/82-06 in the
area of Welder Training and Qualification are quoted below:
                                -        .-. .
 
                                                                                    l
                                          39
"6.3.1 aW lder Training and Performance Qualification
      The NRC Inspector reviewed the welder performance procedures used by P-H
      for welders qualified on sit.e and off-site to insure that welding is
      accomplished by qualified personnel. A detailed analysis was made of the
      controls exercised in the maintenance of identification during welding
      and evaluation of the test assemblies. The NRC Inspector attended a
      typical indoctrination course where a recently qualified welder is
      instructed to understand those portions of the Field Weld Process Sheet
      and the Weld Rod Stores Requisition applicable to the welder. The welder
      is instructed in the Pullman Power Products PH001, dated 12/15/81,
      " Instructions for Welders."
      A review was made of the P-H 6/21/82 Qualified Welder List which
      indicated that 95 of the current 364 welders were qualified by welding
      test assemblies off-site under P-H QC Supervision. All, except 3, welded
      P-H Standard Welding Test SWT #1. Welders qualified off-site were
      trained and tested at UA Welding Schools at Seabrook, N.H.; Cleveland,
      Ohio; Terre Haute, Indiana; or Pasco, Washington.
      All of the Seabrook, N.H., test assemblies were radiographed by P-H at
      the Seabrook Site. The disposition sheets for the RT are maintained with
      the ASME PQR document.
      Currently (since 6/82), welders qualified off site are photographed by
      the P-H QC Welding Inspector supervising the welding and the photographs
      are referred to at time of employment at the Seabroo. .~1te."
Welders are given indoctrination on the site's General Welding Specifications
as well as Welding Procedure Specifications. The WPS is the procedure to which
the welder will test. Each welder testing signs an affidavit that he has read
and understands the GWS and WPS. These affidavits are maintained in each welder's
qualification record.
When in the field, each time a welder draws weld rod, he is issued a rod can.
On the can is a copy of the heat sheet which tells him the rod size, heat
settings and other specific information pertinent to the proper welding technique.
Other information or questions a welder may have are directed to the foreman and
welding supervisor in the area.
In excess of twenty six NRC inspections have included attention toward welding
process application in the nuclear and structural welding areas. A practice of
"on the spot" training of inexperienced workers to perform critical welding was
not identified. These NRC inspections include 78-07, 78-08, 78-09, 80-03,
80-04, 80-08, 80-11, 81-08, 81-12, 81-13, 82-03, 82-06, 82-10, 83-01, 83-02,
83-06, 83-07, 83-09, 83-13, 83-17, 83-22, 84-07, 84-12, 84-16, 84-17 and 85-19.
                                                                            . _ _ _
 
                                                                                          _        _
                                                                  40
  The NRC Nondestructive Testing (NDE) Van has performed over 592 independent
  examinations of welds at Seabrook on several occasions including inspections
  82-06, 84-12 and 85-19. Approximately 145 pipe welds were selected by the NRC
  and examined by radiographic (RT), ultrasonic (UT), magnetic particle (MT) or
  liquid penetrant testing (PT) methods. During these inspections and the
  construction assessment team inspection (84-07), numerous welds were selected
  for visual examination. Also, radiographs taken by the licensee were reviewed
  and compared to NRC radiographs.                        Interviews have been performed with craft
  welders and fitters in the field and at welder qualification stations during
  many NRC inspections relating to piping and welding. Those workmen and foremen
  interviewed expressed an understanding of the requirements for proper component                      I
  fitup, welding, use of work related document, and recordkeeping as necessary                        l
  for completion of the work task in progress.                                                        l
  The quality level of welding ext.nined and testing by the NRC during field
  inspections indicates the selection and use of properly trained and qualified
  welders. Except where prevented by design constraints and properly documented,
  welds picked for independent NRC examination have been found accessible.
  In the area of limited access welds, the inspector reviewed the UE&C
,
  memorandum (SB-LD-F-4643) dated September 29, 1986.                        This memorandum
  summarizes the welder selection process and welder training guidelines where
  conditions require special training of supplemental nondestructive examination
  of a weld.
  On the topic of having welds made inaccessible prior to testing, the same
  memorandum provides the result of the UE&C evaluation regarding testing of
  inaccessible welds. This evaluation found that ASME Section III pipe welds
  have all been inspected and documented in accordance witn the requirements of
  the code. However, the memorandum states:
        "In the conventional portion of the plant there have been rare instances
        where embedded or buried piping lacked a welding program's documented
        evidence of a visual weld inspection but was deemed acceptable due to the
        test programs' Hydrostatic Test Report. The Hydrostatic Test Report
        documented the pressure test for these welds during which each weld is
        visually examined. The Hydrostatic Test Report is the only documentation
f      required by the Code which governs fabrication and construction."
i
  The American Society of Mechanical Engineers Code (ASME) Section III is a
  required national design, fabrication and erection code for pressure vessels
  and piping used in nuclear power plants. Part of the requirements that must
  be met by the licensee is the inspection and testing of welds. This activity
  is monitored by a third party, independent inspector who must sign off the
  nuclear power systems before they have the code stamp affixed. Each weld
  within a piping system must have all required 2xaminations and tests before the
  code stamp is applied. Therefore, welds which are made inaccessible due the
  advance of construction are closely tracked to assure they meet the code
  program. The NRC reviewed this program, an example is presented in Inspection
  Report 50-443/85-29, and found it acceptable.
<
                _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
 
                                            41
    Further, the ASME Code, Section XI, for in-service inspection, also required
    by the NRC, specifies that, where possible, welds be made accessible for in
    service examinations.
,
    In summary, the present and past NRC inspections have established the presence
    of adequate welder training and qualification programs at the Seabrook site and
    the effectiveness of welds qualification is evidenced by the quality and
    acceptability of the welds.
    CONCLUSION
    The allegation was not substantiated.
                                                                                                                        .
4
,
v
  ~                              __ -_ , _    , _ , _ . . . , _ , _ , , _ _ _ . _ _ _ _ . _ _.___._________,.m .,, , ,
 
                                              42
  13. and 21. ALLEGATIONS
  13. On-the job drug and alcohol abuse of epidemic proportions was reported by
contact after contact.      Cocaine was cited as the drug of choice.
21. Any kind of drug there is was available there.            People did cocaine on the
cable trays.
ALLEGATION AS UNDERST0OD BY THE NRC
Professional and nonprofessional workers extensively used drugs at the plant
site.
DETAILS
The inspectors interviewed Seabrook managers, reviewed records related to
personnel actions / complaints and inspected plant areas to verify drug / alcohol
program commitments were met. The Seabrook Station contractor has had a policy
since early 1976 that prohibited the use of drugs and alcohol on the site. This
policy was documented in job rules and promulgated to the construction forces
in diverse and multiple means to assure the forces were aware of the prohibition.
New employees received orientation in the site job rules which included
the drug / alcohol policy. The policy was posted at the " brass alley" entry ways
to site areas, and notices of drug / alcohol policy were distributed in pay checks.
The right of Seabrook to search for alcohol, drugs, and firearms was visibly painted
in large letters on billboards at the site boundary roadways.              These
were observed during NRC inspections.
Early preventive measures by Seabrook to detect the use of alcohol and drugs on site
included supervisory controls and quality assurance audits. These were
supplemented later by undercover surveillance in cooperation with the New Hampshire
State Police and the Rockingham County Sheriff's Department in 1979. Although
lunch box searches (openings) of construction personnel were made at the brass
alley routinely, these were intensified in the form of personnel and
vehicle searches beginning in 1980.
To provide an anonymous, harrassment-free environment to encourage construction /
plant staff to report drug / alcohol abuse and other safety concerns the licensee
established the Employee Allegations Resolution (EAR) program in 1985. This
was an independent contractor run program with confidentiality for all parti-
cipants. All allegations were independently investigated and resolved;
protection of the individual's identity was preserved.
The licensee's programs did ioentify some drug activities on site, one of which
resulted in 12 laborers and other non-nuclear craftsmen being indicted for drug
sale, use and possesion in 1980. Another example of the effectiveness of the
substance abuse program was the use of trained dogs to detect drugs.              The use
of dogs to sniff out drugs was introduced in 1981. The patrol " sniffer" dogs
did identify a car with drug remains (marijuana butts) in it parked in the
construction parking lot in December 1982. The employee was discharged.
                  ____    __        .__ - _.    .      . _ _ _ _ _ _ _ _ .
 
                                            43
The NRC has over the years observed work habits on the construction site which
included worker performance. In addition to observation of work activities,
NRC inspectors interviewed craft workers during onsite inspection and observed
their condition in addition to checking their knowledge of procedures and work
activities. The NRC, when it becomes avtare of undesirable practices such as
drug / alcohol, notified the industry via an Information Notice. In 1982, the
NRC issued IE Information Notice 82-05: Increasing Frequency of Drug-Related
Incidents. This notice was sent to all construction permit holders and
licensees including Seabrook, and provided early notification of NRC ccncern
about drug use. Additionally, in 1982, the NRC published NUREG-0903 titled
Survey of Indu:try and Government Programs To Combat Drug and Alcohol Abuse.
This documents the results of an NRC initiative to assess industry and govern-
ment programs related to drug and alcohol abuse. It also discusses the early
NRC approach (1982) to establishment of an NRC fitness for duty rule. The
publication of NUREG/CR-3196, titled Drug and Alcohol Abuse: The Bases for
Employee Assistance Programs in the Nuclear Utility Industry, in 1983 further
documents the NRC concern about drug / alcohol abuse and provides data useful for
regulatory planning and rule making. More recently, the NRC has promoted a
vigorous industry wide fitness-for-duty program which is being implemented by
the nuclear utilities.
The NRC has interviewed craft and q-c inspectors in the field environment at
Seabrook extensively during the Construction of the plant. These interviews
were conducted on all shifts at various times to assure a cross section of
workers were represented. These interviews provided the opportunity for NRC
inspectors to observe worker behavior first hand and identify any aberrant
actions such as that induced by alcoholic or drug substances. NRC inspections
are unannounced and performed in a random manner throughout the plant which
further assures the probability of detecting unauthorized substance use. Many
recorded examples of these interviews are documented in Table 1 of this report.
Continued use of unauthorized substances which impair an individuals ability
to perform would result in unsatisfactory and rejected work. Repetitive
nonconformances are documented in the quality assurance nonconformance
reporting system (QA NCR). The NRC inspection program reviews the NCR and QA
programs specifically for this aspect to detect repetitive NCRs and trends of
poor workmanship and requires licensee corrective action which could be
retraining of the individual or discharge / removal from the job.
The NRC has periodically reviewed Seabrook actions in relation to their
drug / alcohol program.  This included an inspection of the Seabrook undercover
drug surveillance and is reported in NRC Inspection Report 50-443/80-01, a
portion of which is reproduced below:
                                                        _            _-  _      _ _ _
 
                                            44
      " Preliminary Inquiry - Seabrook Drug Indictments
      During this inspectior., the inspector conducted inquiries into any impact
      the recent arrests of construction workers on drug charges may have had
      on safety-related construction at Seabrook. He interviewed management
      personnel and the foremen of twelve of the indicted individuals and
      examined Project Rule 7, the violation of which led to the discharge of
      these individuals.
      Nine of these twelve workers were employed as laborers whose work function
      could be categorized as that of a " tender", performing various tasks under
      the direction of or meeting the supply needs of other craftsmen (e.g. -
      carpenters or masons). The other three workers were carpenters involved
      in the fabrication and erection of concrete formwork. In either case, all
      of the work performed by these individuals had been checked both in
      process and at subsequent construction stages by supervisory and related
      craft personnel (e.g. - surveyors), and any safety-related work had
      additionally received quality assurance inspection. The interviews with
      the foremen disclosed no specific problems regarding the work performance
      of any of these twelve individuals.
      The inspector also verified that employment at Seabrook Station for the
      subjeJ. personnel had been terminated as of either January 10 or 11,1980
      and that records indicate the only work performed for their employer,
      Perini Power Constructors, at Seabrook was correctly represented by their
      stated occupations. Various licensee and contractor management personnel
      were interviewed concerning the events surrounding these indictments and
      the impact upon construction activities.
      No items of noncompliance or concerns about the quality of construction,
      as related to this drug inquiry, were identified. This finding was
      substantiated by separate, but complementary inquiry conducted by an NRC
      investigation specialist, the results of which are detailed below..."
As a result of the NRC report described previously (NUREG-0903) and in
conjunction with IN 82-05, the NRC conducted an on-site survey of the Seabrook
drug and alcohol abuse programs.en March 9, 1983 at the site.
In 1984 a private organization titled Nuclear Safety Hotline (NSH) distributed
a flyer in the local Seabrook area requesting that any Seabrook employee who
had a concern about safety, or ary issues that could affect safety, at Seabrook
should contact them. They would assure that the issue was presented to the
proper authorities and that the individual's identity would be protected. The
NRC promptly notified the NSH by letter, dated July 5,1984, that the NRC had a
responsibility in the resolution of issues and specifically requested that all
safety related issues be forwarded to NRC for evaluation for their safety
significance.    No reply was received from this 1984 request.
 
                                          45
The NRC inspectors during this inspection interviewed the manager and staff of
the independent-contractor run EAR program and reviewed records and files EAR
Drug Investigation. The program appears to be functioning adequately and
investigations are sufficiently in depth to assure resolution of issues.
Selected personnel files, representing examples of persons accused of
substance abuse, were reviewed by the NRC inspector to determine the nature of
investigations performed by the licensee. Discussions were held with manage-
ment-supervisory staff regarding the decision process used to determine the
impact on inspection, equipment installation or design and the need for rework
or reinspection.    The basic policy was that if the accused person's work was
independently reviewed, inspected or reinspected then no further actions were
warranted. If, however, the accused person's work was not independently
reviewed or inspected during the normal work process, then reinspection / review
would be directed.
Efforts to gather more specific information from the allegers regarding any
safety impact on the construction of the facility were unsuccessful. Because
of the quality assurance program, NRC inspections and outside agency audits
and inspections, there is a high degree of assurance that safety significant
equipment deficiencies do not exist at the Seabrook Station.
CONCLUSION
This allegation, as understood by the NRC, was not substantiated to the degree
stated by alleger. However, there was some indication of substance abuse, and
the licensee enhanced his basic drug and alcohol abuse control program to identify
and mir.imize the effects of substance abuse. There are no identified equipment
deficiencies resulting from this allegation.
The licensee took appropriate correction actions where instances of drug or
alcohol abuse were identified. Both the licensee and the NRC recognized the
potential threat cause by employees involved in substance abuse and took steps
to alert management, contractors and individuals.
                                                                                  l
                                                                                  l
                                                                                  1
                                                                                  l
 
                                          46
14. 30. 31. and 60. ALLEGATIONS
14.  Engineers and tradespeople routinely worked 18 to 20 hour shifts.
30. Have worked 18 to 20 hour shifts.
31. Have seen engineers, technicians, and craftspeople working 18 to 20 hour
      shifts.
60. Work on site was chronically behind schedule, resulting in management
      depending on extensive overtime to meet deadlines.
NRC UNDERSTANDING OF THE ALLEGATIONS
All of the foregoing allegations imply that the routine use of overtime was
not conducive to quality work. The allegers could not give any names, places
er dates to which this overtime work referred. More importantly, they could
not provide any instances were this practice resulted in improper work or
adverse equipment or safety conditions.
DETAILS
All of the major subcontractors have demobilized and left the site. It
appears that the allegations were made for the construction forces and not the
current operating staff. Attempts to establish the amounts of overtime for
individual contractors were unsuccessful, but a review of the overtime records
for the current startup engineering group confirms that they have employed
significant use of overtime for some people. However, the extensive use of
overtime, in itself, does not mean that improper work was performed.
Interviews with the allegers did not reveal any situations where specific
equipment or processes were identified as suffering from this practice.
The overtime for the plant operating staff is limited by the facility
Technical Specification, paragraph 6.2.2.e which invokes Generic Letter No.
82-12. The Generic Letter prescribes the amount of overtime that an operator
can incur in any 24, 48 and 72 hour period.
CONCLUSION
The allegation was substantiated from the fact that existing records for
certain activities do indicate the use of extensive overtime. However,
it could not be establishec that this resulted in any improper work or degraded
equipment.
 
                                                        47
      15. ALLEGATION
      "The company has been having some painters do quality control checks on other
      painters' work.    By federal law, those who do quality control must be organiza-
      tionally independent; members of the same union checking each others work does
      not meet this criteria."
      NRC UNDERSTANDING OF THE ALLEGATION
      As understood by the NRC, the alleger is concerned about the independence of
      painting monitors, painters who reviewed and examined other painters work after
      repair / touch-up painting on steel components and supports.
      DETAILS
      The NRC inspector reviewed the licensee's quality assurance program as applied to the
      painting / coating activities. The inspector determined that sufficient controls
    existed to assure conformance to the technical requirement specified in the
      coating specification and procedures. In section 6.0 of procedures IP-103,
    Structural Steel Coating, and IP-104, for concrete coatings detailed inspection
    and surveillance requirements were established. The inspector found that the
      requirements were clearly stated, and were adequate to assure painting / coating
    quality commensurate with its safety significance. Criterion II of 10 CFR 50,
    Appendix B requires:      "The quality assurance program shall provide control over
    activities affecting the quality of the identified structures, systems, and
    components, to an extent consistent with their importance to safety."
    (emphasis added) Moreover, to enhance the efficiency of coating application,
    and reduce the instances of rework due to quality control inspection, the
    licensee implemented a program of " Paint Monitors" in which experienced
    craftsmen reviewed the work of other craftsmen before final QC inspection and
    acceptance. This review and examination was in addition to the Quality Control
    inspection and did not replace it.
    The inspector reviewed the painting / coating, procedure to determine the
    inspection requirements, acceptance criteria, and the procedures conformance
    to applicable national standards (American National Standards Institute ANSI
    N101.1 and N101.4). The inspector determined that subsection 6.1.1 of IP-104,
    and subsection 6.1 of IP-103 specifically and clearly established QC " Hold-Points"
    which murt be inspected and released by quality control before further work
    could proceed. These hold points had been designated by engineers to meet the
    intent of engineering requirements of the coating design.
    The inspector verified in this inspection that designated forms to document
    these QC inspections had been completed by QA personnel before the work was
    accepted.    Section 7.0 of the coating procedures (IP-103, & 104) clearly
    instructs QC personnel of the requirement of documentation and filing of
    the required report form; " Daily Inspection Report - Level I Coating".
!
    Paragraph 7.3 of IP-103 requires the QC Engineer to do a surveillance of the
    areas being worked for repairs. The surveillance includes atmospheric condi-
    tions, surface preparations, applications and curing. Surveillances were
    normally done two times per shift.
l
l
  ,                      _        _ _ _ _ _ ___, , ~    _. , _
 
                                                48
      Quality of coatings is also dependent on environmental conditions during appli-
      cation, such as temperature and relative humidity. As an additional control to
      assure quality coatings, '' Weather Stations" had been established inside
  y containment on the -26', O' and 25' levels. These stations were clock driven,
      7 day recorders of wet and dry bulb temperatures. They had been placed in
p; areas where the coldest temperatures were expected-(near stair wells). 7The
      stations were calibrated every 6 months. From the the recorded information, QC
      and the foreman calculated dew point and relative humidity. Metal temperature
    was obtained by a hand-held thermometer. Training had been conducted for the
      foremen, and they were provided with dew point and relative humidity tables.
    The requirement of independence of inspection organization and inspectors
    pertains to the final verification of the work to meet the technical require-
    ments and the attendant acceptance criteria.    It is not intended to replace the
    responsibility and/or normal in process verification of the quality of work of
    the craftsmen. These reviews and examination functions are variously performed
    by experienced craftsmen, foremen, general foremen, superintendents, and
    construction engineers. The very intent of these actions is to assure pro-
    duction of " quality" work which will be inspected and accepted by an independent
    inspection organization. The verification and acceptance inspection does not
    substitute, and/or relieve the construction organization of its responsibility
    w verify the quality of its work before final inspection and acceptance,
    although it is carried out in an informal manner.
    At icebrook, this self-verification and in processes control was up graded and
    to.se e extent formalized by construction to minimize unacceptable work, and
    exercise better control over the painting / coating operations. It did not
    substitute or in any way degrade the formal inspection and/or final acceptance
    of work by Quality Control inspectors.
    CONCLUSION
    Paint monitor painters did review and examine other painters works, but the
    implication that they were engaged in formal quality control is not substan-
    t1ated.
    By review of specifications, construction procedures, inspection records, and a
    visual examination of the completed work, the inspector determined that the
    paints / coatings applied and accepted, met the acceptance criteria and national
    code. It appears that the pai7t monitor program did enhance the quality of
    coating operations, because the incidence of rejection by QC was minimized and
    the paint repairs in the summer of 1986 were expedited.
                                                                                        l
                                                                                        l
                                                        .-
 
                                          49
  16. ALLEGATION
" Workers report personal harassment subsequent to causing safety complaints."
                                                                  .    -
NRC UNDERSTANDING OF THE ALLEGATIONS
                                                                '
                                                                        R tjl,
Workers that identify safety concerns at the plant and report them were
routinely harassed.
DETAILS
The Code of Federal Regulations,10 CFR 50.7 very clearly provides protection
to employees who identify violations of the Act and report them to the NRC.
The provisions of 10 CFR 50.7 must be posted in prominent areas throughout the
facility so that all workers are aware of its provisions and can avail them-
selves of it. The existence of this protection is often incorporated into the
General Employee Training.
The NRC regulations and initiatives make it easy for site personnel to report
harassment to the NRC. The regulation is required to be posted in conspicuous
places at Seabrook station so all employees can see it. The posting contains
the Region I telephone number and states collect calls will be accepted. The
NRC also posts the Resident Inspector phone number and photograph at the site
to further assure easy identification of him and make NRC access easier. The
NRC also makes itself available to the plant workers through interviews which
are performed in the field in conjunction with the inspection. Examples of
these interviews are discussed in allegation No. 11 and Table No. 1.
The alleger did not give any further details than stated above. However, a
review of licensee and NRC records shows that on several occasions reports of
harassment and intimidation were made by the Seabrook construction staff. In
all of the cases that were reported, only one resulted in harassment and intimi-
dation being confirmed. This was identified and investigated by the licensee.
The investigations appeared to be thorough and involved interviews of the
affected parties and their co workers.
Allegations of harassment and intimidation also were made to the NRC and
formally investigated. (Reference Investigation Report No. 50-443/1-83-001 and
50-444/1-83-007; Inspection Report 50-443/83-09 and 50-444/83-08 and other
internal memoranda) None of these were ever confirmed. Generally, the issues
that were involved dealt with the supervisor and subordinate relationship where-
in the confrontation situation was not skillfully dealt with by the supervisor.
An inexperienced supervisor may crossover the fine line between directing a
subordinate and intimidation or the employee may perceive the encounter to be
intimidation. There is no evidence to indicate that any of the documented reports
of harassment or intimidation have resulted in equipment deficiencies.
CONCLUSION
This allegatien as understood by NRC was not substantiated. However, one
case of harassment was confirmed.
                                                                                  - - - .
          _
              .                                          .
                                                                                .
 
                                              50
                                                                                    .
                                                                                          !
    18. ALLEGATIONS                          SE * "        ^        '
                                                                          ['~        ~
                                                                                          l
    "Rebar, wire, pieces of steel and other debris was thrown into an, electric- .      !
  s generator..on the second floor;of the-north 44deref-thegipamWhA-
D/!NRCfuNDERSTANDING OF THE-ALLEGATIONS EdsLY W Mip MEihM5&EO4                          -
    The alleger states that rebar, wire, pieces of steel and other debris were
    thrown into an electric generator on the second floor of the north side of the
    equipment vault.
    DETAILS
                                                                          -
    The NRC inspector examined the equipment vault noting that there is no electrical
    generator installed. P.owever, the NRC inspector did see equipment which could
    have been mistaken for an electrical generator. There is an air handling unit
    (photo no. 5) on the upper level of the equipment vault and a safety injection
    pump motor housing (photo no. 6) on the second floor of the equipment vault
  which approximates the size and configuration provided by the alleger.
  Both Units were in operation, having successfully gone through the preoperational
    testing program. Phase 1 of this program requires confirmation of the correct
    installation, verification of control wiring and determination of functional
  capability of the equipment. In addition, the equipment has been placed on the
  licensee's preventative maintenance program to ensure operability.
  The NRC inspector examined the above equipment and all areas of the equipment
  vault, noting that all areas and equipment are clean and free of any debris.
  The inspector noted that access to the equipment vault is limited to authorized
  personnel only and that control is by card key and surveillance by security
  personnel.
  CONCLUSION
                                                                                          \
  There is no evidence or presence of dirt or debris in the equipment vault area
  or equipment, the allegation was not substantiated.                                    I
 
                                            . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
                                                                                                                              ,
                            50a
                                v,;  .;
  .
                    _.__ _
                                                                                                                              l
                                                                                                                              l
                                        :
        PHOTO NO. 5, AIR HANDLING UNIT (REF. ALLEGATION
        NO.18)
                                                                                                                . -        e.
                                                                                                                    /      '
                                                                                                                      , [* 1'
  s.. c
  h
        PHOTO NO. 6, SAFETY INJECTION PUMP MOTOR
        HOUSING (REF. ALLEGATION NO.18)
_
 
                                                                                                                                                                .s
,
                                                                                          52a
                                                                                g
            ~
                                                                            ..
                                                                                                                                                                        a
                                                                                                              m'
                                                                      ..
                              ..
                                          [
          -
                      .
                                                          4
        ,
              g                  .                                                                      y.
                      ~*w                  ,,,m                                                      f-.
                                                                                                      t
        -
                                                            ig f.                                    f
                                          ,                                      .
                                                                                                      .
                                                                                                                .
              ~
                                                              ,
                                                                                                    !        . , .
                              PilOTO NO. 7, CONDU!TS AND J-BOX AT ELEVATION 7'-O"
                              IN THE PRIMARY AUXILI ARY BUILDING (REF. ALLEGA-
                              TION 19)
!
                                      ^}}                                                                                                        "Nf?qj
                                        j                          .                              8
                                                                                                                                                  s    0@{{
                                              ,
                                                                                    *
                                                                                            g 7.    _ ,
                                                                                                                            '
                                                                                                                                            .Z                  . . ,
                                      ;l. ~        .
                                                                ,;
                                                                                                ; v. ' l          u-
                                                                                                                        g                          .
                                                                                                                                                      *
                                                                                                                                                              \
                              ', d[; a_
                                                .
                                                      ..
                                                                    *
                                                                                    i            k,,
                                                                                                t                  .
                                                                                                                        .
                                                                                                                                                    .            ,
                        w                              ,          ;              ,
                                                                                                - - -
                                                                                                          ,                                  _ _ .
                              w                                ..                      la d* -                                                                        *
                                                                                                                                                                      :4
                                  g                  '
                                                                                      .1.                                                              ', ;g
                                      ^
                                            .
                                                                              '
                                                                                      , l l'
                                                                                                            '
                                                                                                                                {.                _.all
                              w                                                                                                              _ .
                              k''*                                                                                                                g ' :J, j
                              ff                            t *                                                      'N                      $,g
                              M      '
                                                            ,            .
                                                                                                    .
                                                                                                        t
                                                                                                                                    % 's                              '
                                                                  .
                                                                                                                  ,                                          ,
                          - ji
                            .
                                                                                                                            ,                      ' -
                                    .          .
                                                                <                      i
                                                                                                              #_
                              PHOTO NO. 8, PRIMARY AUXILIARY BUILDING ELEVATION
                              25'- O'(REF. ALLEGATION NO.19)
  . _ -        _ _--.. - --.                                                        _ _ _ _ _ _ _                        __- __-__ . _ _ - - _ - - - - _ - - - - - _ .
 
                          _            ___
                                                                __ -_      _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
                                                                                                                            ..
!
f                                                                    53
;
  ,
    20. ALLEGATION
    People doing cheds for startup did their. checkoffs very carelessly.
    NRC UNDERSTANDIhG OF THE ALLEGATION
    Verification of system component identification was performed in a manner that
    could lead to erroneous information. Clarifying information obtained during
    an interview indicated that individuals assigned to verify tagging of compo-
    nents in a system requested assistance in reading tag numbers for components in
    hard to reach places when another individual was in the immediate vicinity of
    the tagged component.
    DETAILS
    The objective of the tagging verification prior to start up testing was to
    verify that the components in the syster.: were ready for testing. After the tag                                          -
    identification was established the information was checked oy entering the                                                [
    equipment numbers into the computer tracking system to determine if there were                                              ~
    outstanding Nonconformance Reports (NCR) or Engineering Change Authorizations                                              .
    (ECA) that must be cleared before the test.                          If erroneous information was
    gathered from the field verification of the tagging, this information would be
    identified when the computer failed to locate the component in the data bank.
    In such cases, another field verification of the component number would be
    required. The objective of the start up tests is to assure systems will
    operate as designed prior to plant operations.
  The NRC has been closely following the preoperational and startup test programs
    as they are performed at Seabrook. From October 1985 through March 1986 pre-
    operational testing has been the subject of approximately 38 inspections.
    Documentation of some of these inspections may be found in Inspection Reports
    50-443/85-30, 85-31, 85-13, 86-37, 85-08.
  NRC inspectors have witnessed numerous walkdowns of safety and nonsafety
    related systems during the system turnover and preoperational testing phase of
    the project. A few of these systems include CL-M-1, Chlorination System /
  Mechanical, nonsafety related; SWA-H-1, Service Water Pumphouse Ventilation /
  Mechanical, safety related; CL-I-1 Chlorination System / Instrumentation,
    nonsafety related; Component Cooling Water System, safety related; and the CVCS
  Thermal Regeneration Demineralizer, nonsafety related. NRC inspectors used as
    built drawings in their walkdowns which were verified to be the latest revision.
    Findings resulting from these walkdowns were documented and correctoc.
    NRC inspectors witnessed many tests such as the cold hydrostatic test of the
    Reactor Coolant System including the reactor coolant piping, the reactor
    coolant pump housings, the primary side of the steam generators, the pressurizer
    and associated instrumentatior tubing. Typically during the witnessing of
                              _ _ _ - - _ _ _ - _ _ _ _ _ _ _ _                                                                  I
 
  - -
                                                              54
      these tests the inspector verifies the test will meet the established require-
      ments, reviews the test procedures, verifies the system line ups, and assures
      the test is performed as planned and the test results valid. This test was
      also witnessed by the Authorized Nuclear Inspector (insurer) and at the
      conclusion the results were accepted by both the NRC and the Authorized Nuclear
      Inspector.
      During the inspections performed for preoperational and startup testing, there
;
'
      was not an excessive number of exceptions taken to the various tests indicating
      the precedures used for system verification, test planning and test performance
      were adequate.
      CONCLUSION
      This allegation could not be substantiated. Based on the large number of
      inspections performed by the NRC during preoperational and start up testing of
      the plant, the inspector determined that the objective of the tests is being
      achieved i.e. assurance that the plant will operate as designed. Due to the
      structure of the system, if erroneous information was gathered, it would have
      been detected and corrected.
                                                                                                                                .
                    --        ,      t-- - - , ,- -> s%----    ,,m+ . , , , - - - y-- ,c ,
                                                                                            -+w-4-----w-w--- w y.- -,--v- ----
 
                                              55
:
    22. - ALLEGATION
  '" Security there was very slack. To see if the security system worked, someone
    put gunpowder in their pocket and mixed up a paste and rubbed it on their pants,
    then stood right against the machine which detects those things. It did not go
    off."
    NRC UNDERSTANDING OF CONCERN
    The alleger states the explosive detector will not detect gunpowder.
    DETAILS
    The inspector evaluated the Ion Track Instruments (ITI) explosive detector,
    used by the licensee for access controls through interviews with licensee
    representatives and the manufacturer. Further discussion on th'e capabilities
    and effectiveness of this model explosive detector and its use at Seabrook are
    considered Safeguards Information as defined in 10CFR73.21, and will not be
    discussed in detail.
    The licensee developed a security program that was approved by the NRC and the
    use of an explosive detector represents one facet of personnel access control
    that is part of that program. Other facets of personnel access control include
    the use of the initial employment application, background investigation,
    psychological testing, metal detection, trained guard observation and the badge
    issue procedure. Each of these facets are satisfied prior to the issuance of
    unescorted access to the designated protected and vital areas. There are other
    facets which are employed to further aid in the detection and prevention of
    harmful devices.
    The inspector verified that as of this inspection, personnel access control is
    developed as described above.    In addition, the licensee strictly controls the
    right and need for personnel to have unescorted access to designated protected
'
,  and vital areas. Supervisors are also trained to detect and report aberrant
  behavior.
  The NRC approved the Seabrook Nuclear Generating Station Physical Security Plan
    for fuel implementation on October 17,1986. Portions of that plan contain the
  procedures for providing positive access control to protected and vital areas.
  CONCLllSION
  Due to safeguard implications, NRC cannot comment on the validity of this
  allegation. However, the inspector determined that the licensee was in
  compliance with the NRC approved Physical Security Plan and its procedures.
                      -
                            __  ._                    .-        _ _ -  __      -__ _,_ _ __
 
        .                    __
_ . . _.    -
                                                    56
        23. ALLEGATIGN
        Guards would smoke in the doorway of the area where the fuel is held with both
        the doors open. Much of the time, the back door of that area was held open
        with a block of wood.
        NRC UNDERSTANDING OF CONCERN
        Security guards were smoking in the doorway of the new fuel storage area. The
        doors to this area were blocked open.
        DETAILS                -
        The inspector determined through direct interviews with security supervision
        that guards were authorized to smoke while assigned access control and sur-
        veillance duties at the~ fuel storage building (FSB). They were instructed to
        smoke in the doorway of hallway leading to the front access control point to
        the FSB if they wanted to smoke. The doors to the FSB were to remain closed
        unless authorization ^or~ opening"was granted by designated plant officials.  -
        The inspector reviewed the Security Activities Log for the period May through
        October 1986. A random sample of entries in those logs indicated that.the
        opening of doors to the FSB was. controlled.as required (See excerpted entries
        from log, below). In addition, these logs reflected comments concerning when
        the area surrounding the FSB was patrolled. This patrol was in addition to the
        surveillance provided by the assigned security guard at the FSB.
                                          SHIFT COMMANDER
                                      SECURITY ACTIVITIES LOG
              TIME                          AUTHORIZING
        OPENED    CLOSED        DATE      OFFICIAL            REASON
        12:45PM    13:31PM        5-6-86    Merrill/Rx Eng      Fuel truck entry
        11:01AM    11:01AM        5-10/P6    Gurney /Rx Eng      Run welding leads
                                                                  into the FSB
        09:21AM    09:21AM        5-12-86    Gurney /Rx Eng      Run welding leads
                                                                  into the FSB
        16:09PM    16:12PM        6-2-86    Couture /Fng Supv  Delivery of fuel
                                                                  rods by truck
        11:09PM      -
                                  6-17-86    Messina/Sec Supy    Doors opened for
                                                                  maintenance
        11:31PM      -
                                  9-5-86      St Pierre /Opr    Auxiliary operator
                                              Supervisor        entry
 
  -          .
                                                      57
          10:53AM      -
                                      9-8-86    Kline/Eng Mgr          One door opened for
                                                                        entry of an electri-
                                                                        cian
          18:25PM      -
                                      9-9-86    Sukeforth/ Con-        Roll up door opened
                                                trol room              for maintenance
          09:51AM    10:00AM          9-10-86  Couture /Eng Supy      Replace ceiling
                                                                        light bulbs
          08:05AM    08-43AM          9-11-86  Couture /Eng Supy      Replace ceiling
                                                                        light bulbs
          10:19AM      -
                                      10-2-86  Clark / Control RM    Bring scafolding
                                                                        through the door
          13:31PM      -
                                      10-10-86 Couture /Eng Supv      Equipment entry
          10:15AM      -
                                      10-17-86 Couture /Eng Supy      Removing equipment
          The inspector determined from a review of records and personal interviews, that'
          the doors to the FSB were opened at times, however, the openings were authorized
        'by plant officials who were so designated. This practice was in accordance
,
          with established procedures. The inspector could not determine whether the
          doors to the FSB were blocked open, but for some of the reasons cited above,
          doors could have been blocked open to allow the entry of welding leads, etc.
          The inspector found no indication of violations of the NRC approved Physical
          Security Plan for the Protection of New Fuel.
          CONCLUSION
          The allegation was substantiated. Guards were permitted to smoke outstue of
          the doorway to the new fuel storage area. This posed no hazard to the new
          fuel. Operational needs in the new fuel storage area may have required the
          back door to be open at times, however, surveillance of the new fuel was a
          responsibility of the posted security guards who were on post 24 hours per day.
;
    -- .                  ,.    - - .        .                  ., -_        __        -  -_.,__ .-.
 
m
                                              58
  24. ALLEGATION
  " Implementation of the TP10 procedure. This procedure enables Nonconformance
  Reports to be written without the NRC's knowledge saving valuable steps of
  inspection (saving the company money)."
  NRC UNDERSTANDING OF THE ALLEGATION
  Nonconfermance Reports that were written as a result of positioning deficiencies
  encountered during installation of attachments to embedded plates were
  dispositioned without Nuclear Regulatory Commission approval.
  DETAILS
  The purpose of the procedure TP-10 " Technical Procedure for Location of
  Attachments to Embedded Plates" is to define the location requirements for
  attachment of structural members welded to embedded plates. Procedure TP-10
  specifies the tolerances for the location of a member to be attached to an
  embedded plate e.g. a pipe support. Installation drawings specify the location
  tolerances for the support on the pipe. When both sets of tolerances could not
  be met, an Engineering Change Authorization (ECA) was generated to resolve the
  condition. If the support was installed and either tolerance requirement not
  met, a Nonconformance Report (NCR).was generated-and . processed in .accordance
  with established procedures. During verification of the as-built conditions,
  the actual location of the attachment on bot'        is was determined and recorded.
  Using the as-built dimensions, the stress ca        . ;tions were verified.  If, as a
  result of this verification, an attachment had to be moved, an NCR was generated
  to authorize the movement.
  The NRC has performed at least twelve inspections to verify the as built
  conditions of the plant. These include 50-443/84-07, 84-20, 85-09, 85-20,
  85-31, 86-41, and 86-43. During these inspections minor problems were found
  and have been corrected.      Except as required by 10 CFR 50.55e, nonconforming
  conditions are not required to be reported to the NRC. The rule provides for
  NRC's notification for significant construction deficiencies that, if uncorrected,
  could affect the operation of the plant.      Reportable significant deficiencies
  include a breakdown in the quality assurance program; deficient final design; a
  deficiency in construction that requires extensive evaluation and rework; and
  deviations from the performance specification for equipment and structures.
  Control of ncnconformances is part of the Quality Assurance Program. NCRs are
  required to be written and processed -in accordance with this program, evaluated
  and corrective action taken if necessary.      The NRC has performed numerous
  inspections of the licensee's Quality Assurance program since the inception of
  the project including one specifically evaluating the nonconformance program
 
          _ .
1
                                                                          59
                for design changes (50-443/85-15). In this report both the ECA and the NCR
                programs were evaluated. Deficiencies were identified and were subsequently
*
'
                corrected. However, it was determined that there was no significant effect on
                the plant safety as a result of these findings. In addition, nonconformances
                are tracked to determine if there are trends indicating generic problems. This
                trer. ding enables the licensee to determine root causes of recurring problems.
                CONCLUSION
'
                The allegation was not substantiated. The NRC has performed inspections as
                described above and no procedures permitting deviations from reporting
                requirements were identified. Further, nonconforming conditions are not
                required to be reported to the NRC excepted as provided for by 10 CFR 50.55e.
                                                                                                                                                      "
i
$
  '
i
i
I
    - _.
              .        .    _ . . _ . . _ . - _ - . ..-- . _ _ , __._. -    - _ _ _ . . . - - - _ . . . . _ - . . _ - - _ . . . - - _ -. - . - - . .
 
                                              60
    25. ALLEGATION
    " Safety related construction procedures written in ambiguous, hard to interpret
    language in order to make conformance to them up to the reader and his or her
    interpretation."
    NRC UNDERSTANDING OF THE CONCERN:
    In many cases construction procedures were written that contained specific
-
    technical language that was difficult for non-technically trained individuals
    to interpret.
    DETAILS
    Nuclear safety related procedures are mandated by the Code of Federal
    Regulations, 10 CFR 50, Appendix B, for all structures, systems and components
    important to safety. The NRC devotes significant amounts of inspection time to
    procedure review to assure compli nce with national codes, standards and
    regulations. Reviews of procedures are a normal part of NRC inspections, some
    reports containing these reviews are 50-443/76-02, 77-10, 79-06, 81-07, 83-02,
    83-09, 85-11, and 86-11. The NRC formal inspection program requires that these
    reviews be made by the NRC inspectors.
    As discussed in allegation No. 11, the NRC has interviewed a large number of
    crafts, engineers and quality control personnel to determine their knowledge
    and understanaing of procedures.
    Procedures are written in precise technical language for the discipline
    involved to assure all areas are covered, to assist in uniformity by a large
    work force and to avoid misinterpretation. All procedures used for safety
    related construction and installation were reviewed by the engineering and
    quality organizations prior to implementation or after revision. Further,
    experienced supervisory and engineering personnel were available in the work
    place and a formal process existed for clarification of procedures or inter-
    pretation of technical requirements.
    CONCLUSION
    Based on the number of NRC inspections in which procedures were reviewed by
    NRC inspectors, this allegation could not be substantiated.
  -
 
                                              61
  26. ALLEGATION
  " Procedures written to allow conditions to exist that are unsafe, but since a
  procedure has been written to cover the given condition that makes it
  acceptable."
  NRC UNDERSTANDING OF THE ALLEGATION
  Equipment was installed incorrectly relative to the procedure, but once it was
  installed the procedure was rewritten to reflect the installation. This
  clarification was obtained from the ELP during an interview on November 4,1986.
  DETAILS
  If procedures were not followed this resulted in a deviation or nonconforming
  condition. Such conditions were evaluated in accordance with the requirements
  of the Quality Assurance Program and, if required, the initial procedure revised,
  an Engineering Change Authorization written, or disposition made by an NCR. In
  any of these cases, an engineering evaluation of the situation was made to
  assure the installation, as actually performed, met code, regulatory and design
  requirements.
  Procedures must meet code, regulatory and design requirements. They may be
  appropriately revised to provide clarification or additional technical require-
  ments or for other reasons when the procedure as written is not viable.
  Procedures are reviewed and approved by quality assurance, engineering, and
  construction to assure they meet these commitments. When esses of unanticipated
  interferences prevent installation of equipment as originally planned, drawings
  were revised to provide alternate methods of installation.        These alternate
  drawings are reviewed by the same organizations that reviewed the original
  drawings prior to use to assure compliance to requirements and to assure the
  alternate installation will provide satisfactory performance.
l
  The NRC reviews procedures, drawings and revisions to these documents as a part
'
  of their inspections. These reviews include the technical content of the
  documents as well as the applicability of the appropriate codes, standards and
  regulations and the qualifications of the individuals preparing, reviewing and
  approving the documents. A few of the inspections where this was done include
  50-443/76-02, 77-10, 78-01, 79-06, 80-01, 82-03, 83-14, 85-15, 85-06, 85-14,
  and 86-11.
  CONCLUSION
  Based on the on going effort by the NRC in reviewing procedures and inspecting
  the work done in using these procedures, and the rigorously controlled systems
  provided by the licensee to control procedural changes, this allegation could
  not be substantiated.
              -,- ,.-.  . .    -,.  _  .  - - . _ - - _
                                                              - , - _ _ . - - - -  - _ - .
 
                                                                          s. e,~..
                                            62
  28. ALLEGATION
  Improperly trained electricians.
  NRC UNDERSTANDING OF THE ALLEGATIONS
  The alleger states that electricians are not properly trained.
  DETAILS
  NRC inspector discussions with electrical craftsmen indicate that electricians,
  welders, pipe fitters, carpenters and other tradesmen are hired through a Union
  Hall. To become a member of a Union Hall, one must apply and be accepted in
  the apprentice training program. Individuals meeting the minimum educational
  requirements must then successfully complete the 2-4 year apprenticeship and
  pass the written examinations to qualify for the journeymans card. This card
  signifies qualificaiton in the selected trade and availability for work assign-
  ments through the Union Hall. The Union Hall also supplies apprentices who
  perform non-technical tasks such as clean-up, tenders for qualified journeymen
  and other laborous tasks for.which the use of fully qualified electrical
  journeyman would underutilize his technical skills. The NRC inspector verified
  that individuals are given site specific indoctrination and assigned to perform
  work to the level of expertise required by the job assignment. Qualification
  is documented by training records filed for each individual.
  CONCLUSION
  The allegation was not substantiated. All safety related work requiring
  skilled craftsmen is performed by qualified electrical journeymen. Quality
  control performs in process and final inspection to ensure quality workmanship
  and compliance with NRC requirements and licensee commitments through drawings,
  instructions and procedures.
A
            n  . - - -    - - a    n -        - . - _ _ - _ - . .- ----          ,-n - , _ _ ,
 
                                            63
29. ALLEGATION
" Trainers / engineers give classes inadequately to groups within their
organizations."
NRC UNDERSTANDING OF THE ALLEGATION
Training sessions within organizations are informal and do not include all of
the functions of that organization.
DETAILS
The NRC inspector examined the licensee's training practices to determine the
possible basis for the allegation. Training sessions presented by individual
organizations are, in addition to the formal sessions presented by the General
and Specialty Training Department, typically in the form of tool box meetings,
some on-the-job and that given by supervisors. These sessions are given by
supervisory or staff personnel who do not possess sophisticated training skills.
In addition, this supplemental informal training is done without the benefit of
lesson plans and usually in small groups. The purpose of these sessions is
generally to identify minor changes in procedures or job rules or to strengthen
group knowledge in a specific area.
There are special cases where an experienced person was hired who was fully
qualified.    In these cases, the individuals training and work experience were
documented during the hiring process, but the individual had to demonstrate his
qualification.    Exarpples of these are welders and nondestructive examiners.
Training of welders was done off site, and qualification testing done on site.
During qualification testing, time was allowed the individual to set up their
equipment and practice.    This was not intended as a training program.
Nondestructive examination personnel were tested to assure their qualifications
met the code and standard requirements, the individual's experience record was
verified to assure adherence to the requirements. Again this was not intended
to be training because qualification was based on prior experience, education
and training as required by the specifications.
The NRC examined the formal training programs to assure that code, standard and
regulatory requirements were met. Examples of these kinds of inspections are
documented in NRC Inspection Reports Nos. 50-443/85-07, 85-11, 85-15, 85-19,
86-15 and 86-23.
CONCLUSION
The NRC has reviewed records of individual training and qualification throughout
the construction of the plant including training programs provided by the licensee
and contractors. Formal training and qualifications were found acceptable.
This allegation could not be substantiated.
 
                                                              64
    32. and 57. ALLEGATION
  32. " Tracking of blueprints an impossibility."
  57. " Drawing revision control was ineffective."
  NRC UNDERSTANDING OF THE ALLEGATION
  The alleger was doing as-built inspection on the fire protection system in the
  turbine building when he saw a workman using the same drawing as the one he was
  working to and noticed that the workman's drawing was Revision F and his was
  Revision J.
  The alleger was also concerned that changes in the fire protection system were
  not reflected in the General Arrangement drawings.
  . Tracking of drawing revisions was difficult and revision control was
  ineffective.
,
  DETAILS
  The NRC has performed several inspections on the drawing and revision control
  system during the construction of the plant. Some of the NRC inspections where
  drawing and document control were addressed include 50-443/83-02, 84-07, 85-15,
  and 85-29.    In these inspections, one violation was found, corrected by the
  licensee, and the correction reinspected and accepted. Further, the NRC has
  made many formal and informal as-built verification inspections of piping and
  equipment installations. These inspections verify the accuracy of the latest
  approved revision of the drawing with the actual installation.
  During construction each contractor was responsible for the initiation,
  revision, and distribution of their drawings. As a result, there were several
  systems of drawing control in use on the site. All of the systems used for
  safety related document control were audited by both the licensee and the prime
  contraccor, United Engineers and Constructors Incorporated.
  Most revisions made to drawings do not affect the entire drawing, so the
  revision the workman had could have been correct for the portion of the drawing
  being used. The purpose of the as-built inspection is to verify that the
  system was installed as designed and to provide accurate drawings of the system
  as it exists. As contractors cceplete their projects, drawings are turned over
  to the licensee, audited, changes required noted, and placed under the licensee's
  document control system to be updated later, if necessary.
4
                                                            -
                    - - . . - - _ - - . _ . - _ _ _ . . - .      _
                                                                    , . , - - , . - - . . - . - ,-
 
                                                                                  1
                                            65
  Duri:  +his inspection, the NRC inspectors selected drawings for equipment and
  pipin.  iich were compared to the installations such as those described in
  allegacions Nos. 6, 48, 51, 52, 54 and 55. In addition, the NRC has performed
  many inspections which verified as-built conditions.  This is discussed in the
  Details of allegation No. 24 and Table 5 of this report.
  CONCLUSION
  These allegations could not be substantiated. The NRC has reviewed drawings
  and documents as a routine part of inspections since the project was started.
  Isolated cases of outdated drawings were found during these inspections and in
  each case the situation was corrected. The inspectors did not identify any
  nonconforming conditions relative to plant drawings during this inspection.
,
 
                                            66
  33. 34. 47.    59. and 60. ALLEGATIONS
  33. " Battling and sabotage between different contractors."
  34. " Contractors engineering and constructing jobs improperly in order to
  prolong the job."
  47. " Write nonconformances in such a way as to put as little blame on
  Pullman-Higgins as possible. I was specifically directed to try to avoid
  listing craft error or poor workmanship as cause of nonconformance of a pipe."
  59. "The relationship between Pullman-Higgins and United Engineers and
  Constructors frequently appeared to be adversarial rather than cooperative.
  Disagreement between some P-H and UE&C personnel over procedures and
  responsibilities was in my opinion detrimental to job performance on both
  sides, as much effort appeared to be oriented by both toward defending
  themselves from possible criticism. While working for P-H, I was told by my
  supervisor to write nonconformance reports in such a way as to put as little
  blame on P-H as possible. I was specifically directed to try to avoid listing
  craft error or poor workmanship as a cause of nonconformance, as this would    -
  tend to indicate poor performance by P-H."
  "This conflict was also manifested in partisan graffiti throughout the
  plant, and satirical documents circulated among the engineering staff."
  60. "UE&C was commonly belieted to be using the Seabrook project to provide
  work for engineering staff idled from other projects. At various times I met
  one person from the Cherry Hill , N.J. office; one from a nuclear project in
  North carolina; at least two from the WPPS project in Washington State; and a
, number of people from the Badger Division of Raytheon, UE&C's parent company.
;
  All were there because they had no other work available within the company.
I
  The UE&C staff grew so large that an office building had to be leased off-site
l to accomodate some of them."
  "The perception that UE&C intended to take over the job responsibilities from
  P-H in order to keep their own employees busy was a further source of friction
  between UE&C and P-H staff. After I left P-H, UE&C did in fact take over
  as-built inspection, document control, and drafting responsibilities from P-H
  and I was told later took over all instrumentation and control systems work
  from Johnson Control. I would estimate that the UE&C staff at the site
  increased by up to 30% when the WPPS project war shut down."
  NRC UNDERSTANDING OF THE ALLEGATIONS
  33. Based on an interview with the Employees Legal Project, the allegation does
  not mean sabotage in the sense of causing equipment damage but impugning of the
  the contractor's reputations. The allegation is directed specifically to the
  United Engineers and Constructors and Pullman-Higgins relationship.
        .-
 
                                                                            '
                                                  67
  34. The statement essentially alleges that work was done intentionally wrong
  to extend the contract time.
  47.and 59. The source of allegaton number 47. was the Newburyport Daily News
  article of October 20,1986, which was later restated in more detail in an
  affidavit supplied to the NRC by the alleger.
  The allegation deals with an adversarial relationship between the construction
  manager, United Engineers and Constructors, and the piping contractor,
  Pullman-Higgins. As a result of this relationship, instructions were given to
  inspectors to write nonconformance reports in a manner that would obscure the
  root causes of deficiencies.
  60. The allegation again deals with the adversarial relationship between the
  construction manager, UE&C, and the piping contractor, Pullman-Higgins as
  previously described in allegations 33,47, and 59. Additional causes of this
  adversarial relationship are the replacement of Pullamn-Higgins personnel
  with UE&C personnel from other constructions sites that were no longer in the
  construction phase.
  DETAILS
  The construction organization for the Seabrook project was based on a
  construction manager concept. United Engineers and Constructors (UE&C) was
  contracted as the construction manager. As the constructon manager, UE&C
  subcontracted the various tasks such as electrical, piping, and structural
  work. Pullman-Higgins (P-H) was awarded the piping subcontract.
  In the early 1980s, significant concerns with P-H's job performance were
  identified by the NRC. These concerns were primarily with design control and
  the use of construction practices which were in conflict with UE&C
  specifications. These NRC concerns and licensee corrective actions are
  documented in the Systematic Assessment of Licensee Performance Reports,
  inspection reports and licensee /NRC management meetings for the period
  1982-1984.
  These NRC concerns were translated into corrective actions by the licensee
  through the UE&C and P-H interface. The corrective actions took the form of
  organizational and procedural changes which ultimately led to increased
  licensec and UE&C control of P-H activities. The UE&C and P-H interactions
  resulting from these changes apparently gave the impression , if not in fact,
  of an adversarial relationship. This could not be substantiated due to the
  fact that Pullaman-Higgins has demobilized and is no longer on site.
  However, the job performance problem and the quality of work resulting from
  these changes were monitored very closely by the NRC.
.        -
                                        _ . _ _ ,    _.
 
                                              .
                                                    . -_
                                            68
  In an interview with one of the allegers, it was disclosed that the P-H and
  UE&C relationship did not result in equipment deficiencies but made the work
  environment mentally more difficult. This was futher reflected in his
  allegation regarding the writing of nonconformances and not citing craft error
  and workmanship as the cause of the deficiency. The alleger stated that this
  was to make Pullman - Higgins "look better." He was unable to cite any
  instances where this compromised equipment operability.
F
  The allegation regarding the contractors engineering and constructing the work
  in order to prolong the contract was discussed with the alleger; the concern
i expressed was that it caused the cost of the project to increase. There was
I no specific information that would indicate that equipment had been adversely
  affected by these actions. Plant cost is beyond the scope of this inspection.
(
  CONCLUSION
  The foregoing allegations could not be fully substantiated. However, no safety
  related equipment deficiencies could be identified as a result of these
  allegations.
        ..    .
                              ..                        _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ . _ . _
 
                                          69
36. ALLEGATION
" Quality Assurance and Quality Control slipped the last few years; there was no
QA or QC on third shift, and none for cement on second shift."
NRC UNDERSTANDING 0F THE ALLEGATION
Quality Assurance and Quality Control have not been as conspicuous on second
and third shifts as construction neared completion.
DETAILS
The NRC very closely monitored the licensee's Quality Assurance Program throughout
the construction of the plant. The NRC has maintained a full time resident
inspector on the site since May,1980 and a second resident inspector was assigned
in 1982. These resident inspectors are in addition to the specialist inspectors
that visit the plant on periodic scheduled, but unannounced, inspections. The
licensee's quality assurance program is also submitted to the NRC annually for
review if any revisions have been made in the previous year. During this review
any reductions in commitments are carefully evaluated to determine if they meet
the requirements of 10 CFR 50, Appendix B, and other codes and specifications
committed to by the licensee. Some NRC inspections of the liicensee's QA
program include 50-443/74-01, 78-03, 81-12, 84-07, 84-13, and 85-15.
The Quality Assurance and Quality Control inspection force is directly related
to the number of craft workers at the plant and the amount of safety related
work in progress. As the construction was nearing completion, the number of
craft employees and the degree of safety related work, particularly in concrete,
was very small. Therefore, there was no need for a large number of QA/QC
inspectors in that area.
The inspector reviewed logs of concrete and grout placement during the two year
period ending in August, 1986. From this log, it was noted that in less than
ten cases did placement of concrete or grout require second shift work to
complete the placement. Surveillance of completed concrete and grouting for
temperature and humidity conditions has been performed as required by manu-
factures recommenda ions, or procedures. In many cases, this surveillance was
performed by using recording temperature indicators and daily observation of
the humidity conditions of the curing material where no individual was required
to be present during the second and third shifts. If conditions were noted
that were not as required, a Nonconformance Report was written and disposition
made in accordance with established procedures.
CONCLUSION
Based on the continuing inspections of the licensee's quality assurance
program this :llegation could not be substantiated.
                                                      -.        .  -
 
                                              70
  37. ALLEGATION
  "There was cheating on literacy tests, others took literacy tests for people who
  were illiterate. Literacy tests were given toward the end of construction as
  an excuse to lay people off."
  NRC UNDERSTANDING OF THE ALLEGATION
  This is a three part allegation interpreted as follows:
  1.  General Employee Training (GET) and the required examinations associated
        with this training have been interpreted by the alleger as a literacy test
        used as an excuse to lay people off.
  2.    There was cheating on the examination given as part of the General Employee
        Training (GET) program required for access to the protected area.
  3.    One individual took GET for another.
  DETAILS
  The inspector discussed literacy testing with the training manager and was
  informed the licensee has never given literacy tests. Near the end of
  construction prior to establishing the protected area, GET with written
  examinations was given as a requirement of the NRC license to operate the
  plant. Initiation of the training was delayed until immediately prior to
  establishment of the protected area to allow more convenient access to the
  plant during final construction by personnel performing the finishing work on
  the plant in this area.
  GET is always culminated with an examination to verify the employees under-
  standing of the topical areas and to provide feedback to training. As part of
  this examination, the class is monitored by a proctor. In an isolated case,
  one employee had been given a GET examination paper by another employee. This
  employee was using the previous examination when he took the test. The test
  proctor observed this cheating and as a result both the employee caught cheating
  and the employee who gave him the test were laid off.
  Since inception, measures that require positive identification of individuals
  receiving GET training have bcen employed.      These measures include the use of
  photo identification prior to receiving the training, personal interviews, and
  background checks. The inspector was satisfied that identification require-
  ments for employees receiving GET were satisfactory.
  CONCLUSION
  Based on the examinations made by the inspector, this allegation could not
  substantiated on a general basis.
<
                  . . - . - . . - - -
                                          ,-..c--          -n          - - - - . . - - , --
 
                                                                                                  i
                                            71
38. ALLEGATION
Paint thinner was accidentally spilled on electrical cables.
NRC UNDERSTANDING OF THE ALLEGATIONS                                                      .
The alleger stated that paint thinner was accidentally spilled on electrical
cables, and is concerned the thinner could be detrimental to the cable
insulation. No specific area or system was identified.
DETAILS
Because of painting activities throughout the plant, paint, containing paint
thinners, was inadvertently being spilled on electric cables. Site engineering
was aware of and had evaluated instances of paint splatters or spills onto
plant cables during the April-November 1985 time period.          In each of these
cases, it was established either by inspection of the affected cables, or by a
test program conducted by Franklin Institute that the cable jackets or insula-
tion were not damaged, and the cables were not adversely affected. The spills
in the plant which have been evaluated have included paint which contains
thinners of the types used on-site, and which would have been involved in any
thinner spills that occurred.
A Deficiency Report (85-48D) has been identified, dated 7/18/86 regarding a
phosphoric acid spill involving cables going to electrical per.etration nodes
H02, H41, HIS, H20 & H55. Additional items affected are cables in tray Nos.
93VILB, 92 MIKV and the tray themselves. Disposition involved cleaning of the
Tri-Sodium Phosphate residue from the cables with an approved cleaner,
chlorothene, also a paint thinner and visual inspection of cable for signs of
deterioration. The trays and other affected metal components were cleaned and
retouched with galvanox coating. Engineering visually inspected the repairs
and determined that they were acceptable.
The NRC inspector conducted additional tests on November 3-4, 1986. Sample
cables of the type used in safety related systems were exposed to applications
of several types of paint thinners used on site as a test. The following
thinners were used to wet the cable outer protective jacket:
        a) Keeler & Long #4093 (Epoxy thinner)
        b) Keeler & Long #3100 (Kolorane thinner)
        c) Keeler & Long #1638 (thinner)
        d) Keeler & Long #3700 (Kolor-Poxy thinner)
        e) Wisconsin Protective coating #71 (thinner)
        f) Gates Engineering #N-450-1 (Neoprene thinner cleaner)
Samples of safety-related cables used on site were wetted with each of the
above noted cleaners. All thinners evaporated immediately following applica-
tion. Following evaporation, the glossy surface of all cables became dull.
The NRC inspector examined the cables for surface deterioration; no damage was
evident. The thinners did not penetrate the cable outer protective jacket.
      _    _.
                  .  __        ___ ._.    _
                                                    _ _ _ _ _ _ _          . _ _ _ _ . _ _
                                                                              --
                                                                                              __.
 
                                                                _ _ _ _ _ _ _ _ _ _ _ _ _ - -
                                                                                                .. ..              ..
  !'
                                                  72
h                          -
t
        CONCLUSION
        This allegation was substantiated.
        The NRC test results indicate that paint thinners used on site have no detrimental                              I
        affect when spilled on electrical cable jackets. Site engineering was aware of
        spills that occurred during the period April to November 1985, confirming the
        allegation of paint thinner spills on cables. However, based on the above
        results and the test program conducted by the Franklin Institute Laboratory,
    '; spilling of the paint thinners has no adverse affect on the cable.
      W
,
                                                                                                                        l
                                                                                                                        l
                                                                                              _      _ _ _ - _ _ .
 
                                              _ _ _ _ _ _ _    _ _
                                                                    _ _ _ _ _ - _ _ _ _ _ _ _ _ -
                                                            73
      39. ALLEGATION
      " Electrical cables along the outer walls of the centainment gave off sparks
      starting little fires. An electrician said this was because the cables had
      been there too long with people walking on them, wearing them down."
      NRC UNDERSTANDING 0F THE ALLEGATIONS,
t
      The alleger stated that cables along the oater containment wall and lying on
      floor gave off sparks causing minor fires.
      DETAILS
      The NRC inspector determined that normal construction practice is to run
      temporary cables to provide power to operate tools and welding equipment used
      in construction / fabrication activities. These wires or cables are hung on the                          l
      wall, across trays and some times are laid on the floor. This practice is                                !
      still in effect as evidenced in photos nos. 9 & 10 taken on November 20, 1986.
      Discussions by the NRC inspecto: with licensee personnel confirmed that fires
      have resulted in temporary cable when tha insulation is worn through or stepped
      on to expose a current carrying conductor. Craftsmen are continually reninded
      of the hazards imposed by improper Tractices and care in handling temporary
      cable. The subject was discussed frequently at the Weekly Tool Box meetings.
      The hazard is that fires from these sources could damage safety related equipn'ent.
      Usual construction practices to lessen the threat of fires is to employ training
      and awareness, flame rett.rdant lumber, and fire extinguishers.
      The above practice rele.tes to temporary cable installation which as the name
      implies will be removed after construction or test. Permanent plant cables,
      both safety related and non safety related, are routed in permanent raceways.
      The site electrical installation procedure no. 9763-006-48-2 requires that all
      safety-related cablas be routed in cable trays or conduits. Quality Control
      inspectors are present to inspect the cleanliness and to insure that the trays /
      conduits are free of debris before each cable pull. All safety-related cables
      are in protective enclosures such as tray / conduit. Cables are checked electrically
      and given a walkdown visual inspection for surface damage during construction
      and at turnover. Finally, preoperational testing is performed to verify functional
      operability of each system.
      Quality Control is involved in all aspects of cable installation, termination
      and functional testing of safety-related cable.
      CONCLUSI0PJ
      The alle.gation is substantiated for temporary cable; however, tnere is no
      evidence to indicate that these instances involved safety related cables.
  .
    .          .
                                                      .
                                                                                                  - _ _ _ _ _ .
 
                                                                              ___ _-_
                                  73a
.
        ,
                                    C
                                                        =;-
          .;
                                      $ '.
                                                            .
                                        4
                                            r. -
                                            f
                                              My.
                                          ..
      PHOTO NO. 9, WELDING AND TEMPORARY
      POWER CABLES ON THE FLOOR ( REF.
      ALLEGATION NO. 39)
                                                                                              s
                                                                              !nt            :
                                                                            I            i    .
                                                                            fd          fi ,
                                                                            j      . \ !' =
                                                                            !.        >
                                                                            ja;
                                                                          -
                                                                              '!b
                                                                          4> 'ly
                                                                                      9s
                                                                                            ..i
              -  . . . . . . . . . . . . . , , . . . . , .    $l  n-. u+              -
                                                                                          s'
  PHOTO NO.10, TEMPORARY WELDING AND POWER
  CABLES ON THE FLOOR (REF. ALLEGATION NO. 39)
                              _ _ _ _ . . .                      _                              ...
 
                                              74
  40. & 46. ALLEGATION
  40. "One of the main pipes from the reactor to the turbine building did not fit so
  workers had to use a comealong to make the connection."
  46. ALLEGATION
                                                                                      i
  " Cold pulling to align pipes."
  NRC UNDERSTANDING OF ALLEGATION
  The alleger restates a well documented licensee identified cold pull incident.
  A comealong was used in the fitup operation for a main steam line final closure
  weld. Allegation No. 46 while general in nature, is addressed by the licensee's
  -corrective actions to No. 40. Cold pulling of pipe is also discussed in
  allegations number 7 and 55.
  SUPPORTING DETAILS
  Piping and pipe supports are a significant portion of the plant installation
  work and have been inspected by the NRC on a continuing basis throughout
  construction. The NRC inspections 443/84-12, 84-13 and 85-25 discuss NRC
  observations, reviews and findings in the area of cold pulling of pipes.
  There are two major piping systems connecting the turbine generator building
  with the containment (reactor) building; four feed water lines and four main
  steam lines. The inspector determined that the subject incident was identified
  by a licensee contractor and documented in Nonconformance Report (NCR) No.
  80749, dated August 10, 1982.
  The licensee found that a misalignment greater than permitted by the piping
  erection specification existed prior to the fitup of the Main Steam Piping
  (Line MS-4007-01-B1-30) field welds F0105 ' A' and F0106 'B' . Subsequently, the
  licensee determined that the contractor was not fully cognizant of the details
  of Specification No.    9763-006-248-51 which required that no mechanical means
  could be used to move pipe more than 1/8 inch off its centerline position. A
  Final Report (SBN 869) dated September 10, 1985 for Construction Deficiency
  Report, CDR-82-00-13, submitted to the NRC which described the deficiency and
  detailed the corrective actions, including:
  1.    An evaluation of 70 ASME, Section III, Class 2 and 3 piping systems
        verified that the supports /restaints were installed after the final
        closure weld thus assuring that the effects of cold pull that may have
        been introduced were minimal.
  2.    The cold pull identified on the conconformance report was corrected by
        refitting the line.
.
 
                                                                                      75
                        3.      Applicable welding installation and inspection procedures were revised to
                                preclude recurrence.
,                      The above corrective actions were in place by January 1983. Subsequent
                        inspections in this area by the licensee and NRC inspectors did not identify
                      any additional discrepancies. NRC inspection 85-25 completed a final review
                      and concluded that the licensee's corrective actions were effective.
                      CONCLUSION
                      The allegation was substantiated. The subject allegation addressed a single
                        instance of cold pull of piping. The incident, originally identified by
                      supervision, is well documented and resulted in a comprehensive evaluation of
                      systems installed prior to the event to assure that previously installed piping
                      was not adversely affected.
1
i
,
,
  - - - , . . . . - - - . - - -    m. ---.,,.,--,-.. -----. ,,---m., _,, , ,.--_v-----    _ - - - -- . . , - -
 
                                          76
41. ALLEGATION
" Security was poor. Unauthorized people regularly had access to restricted
areas."
NRC UNDERSTANDING 0F CONCERN
The alleger stated that unauthor.ized. people. regularly had access to restricted
areas. Restricted areas, meaning those areas of the plant where construction
had been completed and were prepared for turnover for start-up testing.
Unauthorized people were those who could not immediately produce a valid work
request to a responding security guard.
DETAILS
The inspector reviewed the incident and event reports submitted by security
personnel for the period May 1 through October 30,1986. The results of this
review are as follows:
        MONTH                      COMMENTS
    May 1986                      There were 12 events in which security
                                    patrols observed unsecured doors; locking
                                    mechanism taped to prevent locking or
                                    doors blocked open with wooden wedges.
    June 1986                      There were 14 events during the month of
                                    June. On 3 events, security received an
                                    intrusion alarm and a patrol responded
                                    and discovered unsecured doors. On 11
                                    events, security patrols observed
                                    unsecured doors, locking mechanized taped
                                    to prevent locking or defective locks.
    July 1986                      There were 8 events during the month of
                                    July 1986. On 2 events, security received
                                    an alarm and a patrol responded and
                                    discovered an unsecured door. On 6 events,
                                    security patrols observed unsecured doors,
                                    defective locks or doors blocked open for
                                    wires and pipes.
    August 1986                    There were 5 events in which security
                                    patrols discovered unsecured doors or
                                    doors being blocked open.
                                                                                  :
                                                                                  1
                                                                                  1
 
                                            4
                                            77
        September 1986                  There were 5 events in September
                                        1986. On 3 events, security received
                                        an alarm and a patrol responded
                                        and discovered unsecured doors. On
                                        2 events, security patrols observed
                                        unsecured doors.
        October 1986                    There were 4 events in October 1986.
                                        On 3 events security received an alarm
                                        and a patrol responded and discovered
                                        an employee had created the alarm On
                                        1 event, an unalarmed door was found
                                        unsecured.
  The licensee stated that during the construction phase of the plant, the access
'
  controls that were implemented throughout the plant were imposed as a result of
  safety or construction concerns. Access control as defined in the approved
  physical security plan was not required during the construction of the plant.
  The inspector verified that the licensee had implemented the NRC approved
  physical security plan as of October 17, 1986. At that time, unescorted access
  to protected and vital areas was positively controlled. During this inspection,
  the inspector observed that the security force is providing positive access
  control to protected and vital areas. All personnel granted unescorted access
  have received a background investigation, a psychological test and general site
  education.
  The NRC approved the Seabrook Nuclear Generating Station Physical Security Plan
  for full implementation on October 17,1986. Portions of that plan contain
  procedures for providing positive access control to protected and vital areas.
  The inspector determined that the licensee was in compliance with the NRC
  approved physical security plan and its procedures.
  CONCLUSION
  The allegation was substantiated. Based on an interview with the alleger, the
  period of concern is the spring of 1985 to the spring of 1986. The physical
  security plan, however, the official security plan for regulatory compliance,
  was not implemented until October 17,1986.
 
      -
                                            78
42. ALLEGATION                                                      ,
Three thousand pound cement was used at Seabrook whereas at other nuclear
plants 5000 pound cement was used because 3000 pound was not thought to be
  strong enough.
NRC UNDERSTANDING OF THE ALLEGATIONS
The allegation as understood by the NRC is that the reference is made to
concrete rather that cement; and 3000 pound and 5000 pound refers to the
nominal strength of the mix-design of concrete which is measured in the units
of pound per square inch (psi). Furthermore, because the alleger is concerned
about the safety of the nuclear plant, his concern is related to concrete
design in safety-related structures.
DETAILS
The 10 CFR 50, Appendix A, " General Design Criteria" (GDC-50) establishes
. requirements for containment design. Every licensee must satisfy these design
requirements'for a nuclear power plant. The Preliminary and -Final Safety                -
Analysis Reports (PSAR and FSAR) have been reviewed by the NRC, and Safety
Evaluation Reports (SERs) have been issued.
The inspector reviewed the FSAR for the Seabrook Station, and noted that the
containment design has been reviewed by the NRC and that the licensee was
committed to design the containment in accordance with the ASME Code. Section
III, Division 2, Subsection CC, Article CC-3000 of the Code establishes methods
for containment design. The inspector also noted that a nominal 4000 psi
mix-design concrete was the basis of the containment analysis in the FSARs and
the NRC SER.
By review of specifications, placement records and construction drawings the
NRC inspector determined that the concrete used in containment and other
safety-related structures was a 4000 psi mix-design minimum. The mix was
designed in accordance with American Concrete Institute (ACI) standard ACI
211.1-7A. The concrete as mixed in the on-site batch plant and delivered to
placements was sampled at the point of delivery and tested for strength (see
allegation 2) The results indicate that the average actual strength of the
minimum 4000 psi mix-design was in excess of 5000 psi.        The test cylinders of
the concrete used in containment structures indicated a strength distribution
range from approximately 4400 psi to 6000 psi for twenty eight day tests.
The NRC has also independently performed nondestructive tests (impact hammer;
windsor probe) of the concrete used in safety-related structures. These tests
indicate an average value of approximately 7200 psi. (IR 50-443/84-12)
                                                                                                I
                                            - - _      - - - - - -.              . . - _ _ - -
 
                                                                                              l
  '
                                                          79
        The nominal strength of a concrete mix-design whether 3000, 4000, 5000 or even
        6000 psi does not inherently make a structure " strong enough" or weak. The
        minimum nominal strength is used in designing (sizing) a structural member of
        an optimum size to withstand the design loads. With proper design and adequate
        size of any structure, a 3000 psi mix concrete is as serviceable as 6000 psi
        mix concrete. However, other considerations such as pump placement, durability,
        forming and ease of placement, and radiation shielding may dictate the choice
        of a mix-design rather than just strength. In a given structural size, however,
        a higher strength mix will provide a higher strength structural member. The
        Seabrook design is for 4000 psi, and tests show that actual average strength to
        be approximately 5000 psi.
        CONCLUSION
j        This allegation is not substantiated. The concrete mix used for safety-related
        structures, especially containment is of a nominal 4000 psi design. The safety
        margin is more than adequate. The independent neasurements by NRC show that
        actual average strength to be considerably higher than 4000 psi.
I
  i
  !
                                                                                            r
  <
4
4
  I
4?
:
  i
                                                                                            Y
i
1
-
    _.    - ._
      -
                  - _ - -          . - . - - - - - _ _ .                  -.-      _ _ .-
 
                                                                                _ _ _ . . _ _
                                          80            g
43. ALLEGATION
"The reactor was filthy compared to other nuclear plants under construction
where a dust free environment was maintained. At Seabrook there were wooden
ladders and debris in the reactor. Compared to other nuclear plants, general
practices at Seabrook were slovenly, shoddy.
NRC UNDERSTANDING OF THE ALLEGATION
In comparison to other nuclear power plants under construction, housekeeping
practices at Seabrook in and around the installed reactor vessel were poor.
OETAILS
During the construction of the facility, the NRC identified housekeeping
deficiencies which were characterized as an area of concern but "not to a
severe degree". This was reported in the Systematic Assessment of Licensee
Performance Reports for the periods of July 1983 through January 1984 and
January 1985 through March 1986. NRC Inspection report 50-443/84-18 formed a
basis for this conclusion wherein it cited " empty spray cans, loose hardware,
stripped cable insulation and other debris." The NRC resident inspectors were
aware of this problem and monitored the licensee's activities in this area.
The inspector toured the plant during this inspection noting plant cleanliness
at this point in time. The areas are painted and debris free; no construction
dirt is evident. In areas where post construction activities are in progress,
the areas are maintained and clean.
During various phases of construction prior to 1985, equipment required to
facilitate work on the reactor coolant system, specifically wooden ladders,
were placed in the reactor vessel; this practice is not uncommon. During the
first quarter of 1985, the reactor coolant system piping and the reactor vessel
were cleaned in accordance with Flushing Procedures 1-RC-F-4 and 1-RC-F-5.
Upon completion of the cleaning program in March 1985, with the exception for
periods of related testing and inspections, the reactor vessel remained sealed
with a fire resistant polycover.
Final cleaning of the reactor vessel consisting of manual cleaning per procedure
GT-C-02 to a final surface cleanliness level of Grade 'B' was accomplished on
July 19, 1986. procedure GT-C-01 Revision 11, includes system cleanliness
classifications with Grade 'B' identified as the most stringent level, specified
for the reactor vessel.
CONCLUSION
This allegation was substantiated.
During certain phases of the construction period, equipment and possible debris
may have been found in the reactor vessel. However, flushing operations and
manual wipe down of the vessel and visual examination indicated that the
required levels of cleanliness were achieved and subsequently maintained
throughout the period leading up to fueling activities.
 
                                            81
44. ALLEGATION
" Improper welds were performed by untrained welders.      Wrap-around welds were
used when return welds were called for; return welds prevent the " keyhole"
from breaking under stress."
NRC UNDERSTANDING OF THE ALLEGATIONS
The first portion of this allegation relates to the use of untrained welders
and is addressed in the finding for allegation Number 12. The second portion
of the allegation questions the difference between a wrap-around weld and a
return weld on AWS structures and ASME Code, Section III, NF pipe support
welding.
DETAILS
The American Welding Society (AWS) standard for welding terms and definitions
defines an "end return" to be a non-standard term for " boxing" which is "the
continuation of a fillet weld around a corner of a member as an extension of
the principa] weld". The term " wrap-around weld" is not defined in the AWS
standard for weld terms. Therefore, the NRC inspector determined the Seabrook
site requirements for end return (or boxed) welds. This includes the AWS
definition; the ASME Code Section III, interpre+ation III-1-86-10 end return
requirement of NF components; the UE&C drawing 5/63-M-805943S, Sheet 2C, Note
6 requiring return welds where practical, and ECA 25-03728.      The basic require-
ment is that fillet welds shall be end returned for 1/2" minimum or 2 times the
fillet size where geometry permits.
The NRC inspector examined a sample of approximately 100 welds in each of the
containment and PAB areas to establish the presence of end return welds where
required. All welds examined were properly "end returned".
A similar allegation was investigated by the NRC in 1983 and is quoted below
from the inspection Report 50-443/83-01, Part 4e.
      "e.  The NRC inspector reviewed the return end (or boxing) requirements of
            ASME Section III, NF and AWS D1.1 and discussed the technical intent
            of these requirements with the NRR-ASME Section III, NF representative
            and the AWS Staff expert on D1.1. The function of the return end
            welds is to prevent premature tearing of the ends of fillet welds
            under ultimate failure conditions (as discussed in paragraph 8.8.6 of
            the Commentary Section of the 1980 01.1 document.) The loading
            conditions may negate the technical requirements for many return end
            welds. The 2X minimum length requirement is secondary in technical
            importance to the existence of the weld end corner closure.    UE&C did
            not initially recognize the return end weld requirement in their
            specifications and Engineering Change Authorization (ECA) 250372A was
            written on February 27,1981 to address this question based on a
            Request for Information (RFI) initiated by YAEC. The ECA required
            that inspection be made of all P-H field welds and shop welds and
            additional weld be added if required. All future field welds are to
 
                                            82
            be made with return welds (where applicable). The licensee indicated
            that consideration may be given to an engineering evaluation calling
            for return end repair welds on an "as required" basis based on loading
            conditions (directions) rather than 100% of all fillet welds on supports
            identified by the subject ECA. This could minimize additional quality
            problems associated with repair welding.
      The technical significance of the above areas of concern of hanger fabrication
      has been addressed in this inspection report by inspections conducted
    without direct or indirect reference to the existence c.,f the allegation.
      The inspection indicated that some of these areas were under review prior
      to the time of the allegation. As a result of ECA 250372A (dated February
    27,1981) resulting from an RFI initiated by the licensee, all support
      fillet welds are required to be reinsepcted for return end welds."
The AWS term " keyhole" refers to a welding procedure where a through hole at
the leading edge of the molten metal is developed and fills in behind the hole
as the weld arc progresses. Keyhole welding is associated with gas tungsten
arc and plasma arc welding but is not applicable to shielded metal arc fillet
welding.
CONCLUSION
The allegation was not substantiated.
                                                                                      1
                                                                                      I
 
                                          83
45. ALLEGATION
" Bottles of Argon used for we1 Jing were contaminated with moisture but were
used anyway."
NRC UNDERSTANDING OF THE ALLEGATIONS
How is the moisture content of Argon gas for weld shielding controlled? If
Argon contaminated with moisture was used would a welder see any resulting
problems?
DETAILS
All Argon purchased for welding use at Seabrook Station is certified to be
99.995% pure Argon. Argon has beer purchased in bottle and bulk form and, is
used as a shielding and purging medium for the Gas Tungsten Arc Welding (GTAW)
process. There never has been a problem with the bottled gas but there have
been instances where problems occurred with the bulk system. The welder (s)
would recognize the problem due to the change in welding characteristics, stop
work and notify a welding supervisor. The affected portion (s) of-the bulk
supply system would be taken out of service until the problem was found and
corrected. The welder (s) would remove the affected weld, switch over to
bottled gas, and complete the welding assignment. Most of the problems found
were aspirating hose connections.
The NRC inspector was avare that if moisture contaminated Argon gas is used in
the gas shielded Tungsten Arc Welding (GTAW) of stainless steel and carbon or
low alloy steels, weld metal porosity may occur. The NRC inspector reviewed
the purchase order and Argon gas analysis reports to determine if the maximum
moisture level of Argon gas was specified and controlled. The effects of
moisture on the GTAW Tungsten electrode, visibility of resulting porosity, weld
technique of verifying weld integrity by looking at GTAW root passs welds and
involvement of supervision and weld engineering in resolving weld porosity
problems were considered.
The inspector reviewed the statement of analysis for Argon Welding Grade Gas
dated November 29, 1977 which specifies a minimum purity of 99.996% Argon with
a maximum dew point of -76 F, and a typical analysis of 99.9989% purity with a
dew point of -90 F. Test results of welding grade shielding gases were
reviewed, confirming a combination of high purity and low dew point. The
inspector concluded that the weld gas supplier (also a supplier of medical gas)
did control and check weld gas purity and moisture content to levels consistent
with quality GTAW, porosity free welding.
Field procedure FWP-18 part 5.2.5.1, C and the P-H General Weld Standard GS-111
Part 4.2 require the use of oxygen analyzers to check the adequacy of Argon gas
backing purge for GTAW root pass welding. While this analyzer does not measure
moisture content, it does provide another field check on Argon gas purity
besides observations made by welders during welding and observations of completed
weld lay 9rs by welders, QC inspectors, supervision and NDE technicians.
                                                                                  I
 
                                          84
Previous NRC weld inspections of both welder qualification and production
welding have not identified GTAW Argon gas, moisture induced porosity as a
significant contributor to weld metal defects. Where a problem with GTAW
shielding gas has been observed, the problem is usually found in the delivery
system such as a bad gas lens, loose gas line fitting or damaged gas hose. The
resulting weld process problerr.s in these cases are generally immediately
obvious.
In addition, the NRC performed independent weld examinations using the
Nondestructive Examination Van on three occasions (6/82, 8/84 and 7/85). The
inspections employed radiography, magnetic particle, liquid penetrant and
visual examinations of welds. Any widespread porosity problems would have
been identified using these techniques.
CONCLUSION
This allegation was not substantiated.
 
                                            85
48. ALLEGATION
"
  ...in a number of locations throughout the plant, the primary and backup
feedwater systems were supported by a single structure."
"
  ...it appears the plant is vulnerable to total failure of feedwater and
emergency feedwater systems ir, some accident situations."
NRC UNDERSTANDING OF THE ALLEGATIONS
The alleger is concerned that a single failure of an Emergency Feed Water (EFW)
component will result in the loss of the EFW system. Also, the failure of a
main steam line or main feedwater line in the area of the EFW pump house and
Condensate Storage Tank (CST) can also result in the loss of the EFW system.
DETAILS
The inspector reviewed the requirements of the Standard Review Plan 10.4.9,
Auxiliary Feedwater System, Final Safety Assessment Report (FSAR) Section 3.5,
Missile Protection, and section 6.8 Emergency Feedwater System, and NUREG-0896,
Safety Evaluation Report for Seabrook Station, Section 6.8.
The inspector verified that the NRC has completed an in depth review of all
design and operational aspects of the EFW system. The review determined that
all components and associated piping are housed in seismic Category I
structures, with the exception of suction piping that is routed underground
between the CST and the pump house. Within the seismic Category I structures,
equipment and piping are supported by seismic Category I restraints.
High energy lines of the main steam and feedwater systems are also supported
by seismic Category I structures, preventing adverse impact upon the EFW
system.
The seismic Categoy I concrete structure surrounding the CST, will contain
adequate water to cool down the plant should the steel tank fail. Redundant
emergency feedwater pumps are locatea in a seismic Categoy I pump house. There
are no barriers between the pumps; however, an analysis conducted in response
to an NRC request for additional information, RAI 410.8, was completed by the
licensee in August 1982 and included in Section 3.5 of the FSAR. The analysis
concludes that a missile generated by the turbine driven pump is not a credible
event, allowing the two pumps to be located in the same area.
CONCLUSION
This allegation could not be substantiated. Although it is true that the
emergency feedwater system is supported by a single structure in a number of
location, these structures are designed to withstand natural occurring events
and pose no threat to the piping system.
 
                                                                                                ..
                                                          86
                51. ALLEGATION
                " Control building air conditioning system refrigerant lines (CBA) lack
                separation; no physical barrier between them."
                NRC UNDERSTANDING 0F THE ALLEGATION
                Redundant trains of the control room air conditioning rystem are located in
                the same room and are, therefore, subject to common mode failure.
                DETAILS
                Air conditioning (cooling) in the control butiding is limited to the control
                room complex and it is comprised of two independent systems.
                      a) control room - safety-related
                      b) computer room - non-safety-related
                The inspector reviewed the system drawings and examined the installed piping and
                equipment. The control room air conditioning system consists of two redundant
                trains of 100*4 capacity each. Power supply to each train is an independent
                emergency source.  Electrical cable seperation criteria meet the requirements
                of Regulatory Guide 1.75.
                All equipment associated with the control room air conditioning system is
                housed in seismic Category I structures designed to withstand safe shutdown
                earthquake and postulated tornado missiles. Cooling system components
                including fan dampers and associated equipment duct work are ANSI Safety Class
                3, Seismic Category I. This system has been evaluated by the NRC staff in
                accordance with Section 9.4.1 of the Standard Review Plan (SRP). The staff
                determined that the system is in conformance with applicable General Design
                Criteria.
                No specific criteria exist for the segregation of refrigerant lines of the
                redundant air conditioning systems. However, all piping is seismically
                supported to assure system reliability during and after seismic events.
                Independent verifications of the as-built conditions of the subject system has              ,
                been conducted by the licensee's contractor and the NRC, as documented in NRC
                                                                                                            '
                report No.86-12.
                The computer room air conditioning system consists of a self-contained single
                unit housed in its entirety inside the computer room.    This unit is not
                safety-related.
                CONCLUSION
l
l              This allegation is substantiated. kowever, there are no requirements to meet
                specific separation criteria for refrigerant lines. The existing system design
i
                has been reviewed by the NRC and does not degrade plant safety.
  . . - - - . -                  -      -  --  --                    --
                                                                            _ _ - - . _ _ _ - . _ . . . -.
 
_  -
                                                    87                                  .
        52. ALLEGATION
      -The emergency feedwater system is supplied from a single tank, which also
        serves as condensate storage for the main steam feedwater system.
      NRC UNDERSTANDING OF THE ALLEGATIONS
      Additional clarifications by.the alleger: On Nov. 5,1986, during a personal
        interview, the alleger clarified his concern as it appeared in the October
      21,1986 affidavit.
        It.is the inspector's understanding of the alleger's concerns that an adequate
      source of water supply to the emergency feedwater system cannot be assured for
      two reasons:
              a) condensate water storage tank level is not controlled
              b) other . systems taking suction from the Condensate Storage Tank (CST) can
                  drain the tank leaving an inadequate supply to the Emergency Feedwater    l
                  Pump (EFP) during an emergency.                                          !
      DETAILS
      The licensee's Technical Specification (T.S.) which is part of the operating
      license, Section 3.7.13, requires that a minimum of 212,000 gallons of water be
      contained in the CST; and the concrete CST enclosure is capable of retaining
      212,000 gallons of water. This minimum water volume is sufficient to cool the
      reactor coolant system to less than 350*F, when the residual heat removal (RHR)
      system can be placed into operation. At this point, the emergency feedwater
      system is no longer required. The condensate storage tank level is continuously
      monitored in the contrpi room and a low tank level alarm, at 240,000 gallon
      alerts the operators to take corrective action.        If the above requirements
      cannot be met, for a period of 4 hours , the plant must be in hot shutdown
      within the following 12 hours.
      The inspector reviewed Section 9.2.63 of the FSAR, Condensate Storage Facility
      Safety Evaluation, in conjunction with Figure No 10.4-4, Sheet 1. The lowest
      elevation of non-nuclear safety pipe is at 44' - 4 3/8"; the EFP suction pipes
      are at 23' 11", assuring a 20' 5" reserve of this 42 ft. diameter tank for
      emergency feedwater of 212,000 gallons. There are six (6) nozzle penetrations
      into the CST within the elevation reserved for EFP. Five are associated with
      EFW pump and condensate pump recirculation, and tank level instrumentation.
      One suction line at elevation 25'-3" is associated with the Startup Feedwater
      pump.      This line is isolated by valve No. CO-142, which is normally locked
      shut. The above connections and all associated piping are nuclear grade
      seismic Category I, and are protected by missile shields.
      CONCLUSION
      This allegation is not substantiated. The system design and administrative
      controls insure a reliable water supply during emergencies.
  .
 
                                                                .
i
                                                88
      53. ALLEGATION
      " Control room is protected by an automatic water sprinkler system, thus
      exposing the electronics to disruption by water."
      Fire protection systems throughout the plant consists of an automatic water
      sprinkler system, water fire hoses and hand-held fire extinguishers. This is
      the only fire protection equipment installed in the control room, thus
i      exposing electronically operated control systems to the threat of disruption
      due to water infiltration when sprinklers are activated. Computerized
;    equipment is not customarily sealed against liquids due to the need for
      ventilation to maintain a constant temperature.
      NRC UNDERSTANDING OF THE ALLEGATIONS
      The alleger states that the control room is protected only by an automatic
j
'
      water suppression system. Use of this system to put a fire out in the control
      room can cause disruption of electrical equipment exposed to the water spray.
      DETAILS
      The control room cabinets and consoles are subject to damage from two distinct
      fire hazards.
            a) Fire originating within a cabinet or console
                                                                                      '
            b) Exposure fire involving combustibles in the general room area
i
                                                                                      1
l    The NRC inspector examined the fire detection in the control room complex and
I    verified it is protected by ionization detectors. Manual hose stations are
      located outside the control room near the stairwells. Halon and dry chemical
      hand-held extinguishers are located in the control room. Control room equip-
      rient is not provided with pedestals and floor drains are not provided. However,
      these features are not required as the hose stations and standpipes are located
      outside the control room and up to 4 inches of flooding can be tolerated without
      damage to any safety-related equipment. Drainage is maintained through the
      open door to the turbine building or the stairwells to tne outdoors. Nozzles
      for the manual hose station are chosen to minimize physical damage to the
      electrical equipment and satisfy electrical safety.
      The NRC has imposed extensive requirements for fire protection through 10 CFR
      50.48 and Appendix R. The licensee's fire protection program was reviewed by
      the NRC and is documented in a Safety Evaluation Report dated March 1983.
      Further, a team inspection verified the implementation of the safe shutdown
      aspects of this fire protection program. This is documented in Inspection
      Report 50-443/86-03.
      In addition the control room is manned on a 24 hour basis so that any fire in
      the area would be immediately detected and extinguished.                        !
                                                                                      1
l                                                                                      I
l                                                                                      1
  _ .
 
                        ___ - __- _ -_ _ _
                                            89
  The plant computer does not perform any safety function and the failure of the
  computer will not prevent the safe and orderly shutdown of the plant. The
  plant computer room is a portion of the control room complex but is separated
  from the main control room by three hour rated fire walls. Automatic fire
l detectors with a fixed Halon 1301 system is provided in the computer room.
l Portable fire extinguishers are not provided.
  CONCLUSION
l The control room does not have an automatic water suppression system. The
  primary fire protection consists of portable Class "C", appropriate for
  fighting electrici fires, fire extinguishers with the standpipe and hose
  station as the back-up system.
  This allegation was not susbstantiated.                                        l
!
 
                                            90
  54. ALLEGATION
  " Parts of CBA system were constructed without design drawings."
  NRC UNDERSTANDING OF THE ALLEGATIONS
  The installation of'the air conditioning system lines was completed without
  the use of drawings. The original installation consisted of 2 and 3 inch
  diameter steel piping which was subsequently replaced with 3/4 inch diameter
  copper tubing.
  Additional clarification by the alleger: On Nov. 1,1986 during a personal
  interview the alleger clarified his concern as it appeared in the
  October 21, 1986 affidavit. The alleger stated that his concerns address the
  air conditioning system of the Control Building Air Handling (CBA) equipment.
  DETAILS
  The allegation was inspected inconjunction with allegation No. 51 wherein the
  inspector reviewed tha drawings and installation of the system.
  The inspector determined that detailed drawings of the subject system have
  been issued and are designated as United Engineers & Constructor (UE&C)
  drawings 4019600 through 4019618. System modification dates and applicable
  construction details appear on each drawing. As-built walkdowns of the system
  have been completed using the subject drawings.
  Licensee's specification No.9763-006-248-1, Shop Fabrication of Pipe requires
  that refrigeration piping be installed in accordance with ANSI B31.5, Field
  Supplied Refrigeration Piping. In accordance with the code, all piping
  associated with the system is rigid copper piping. Steel piping is not used
, in any part of the system.
,
  CONCLUSION
  This allegation could not be substantiated.
i
l
1
1
 
  , .        .        -      .    --        -      . -    -    -    -.      ._  _ - .
                                                  '91~
t
!      55. ALLEGATION
      The allegations about turbine building _ equipment and piping are summarized
      below:
            a.  Condensate traps in horizontal pipe runs
l            b.  Uneven support loading under heat exchangers
            c.  Prohibited work practices used thoughout the system
            d.  Weld identification procedures not carried out                              !
            e.  B 31.1 as-built inspection program was canceiled because                    l
                it was too costly and unnecessary                                          l
            f.  Cold pulling pipe                                                          !
l
      The allegation stated:
      " Turbine exhaust piping was installed with several reverse slopes, and runs
      out of plumb and skewed.      Some misalignments at pipe welds were evident.  I
      believe this to be due in large part to inaccurate fabrication of the                  :
      condenser shells in which the piping was installed. Some of the heat                  l
      exchangers in the condensers were also installed out of level.                        !
      On one occasion I saw a crew attempting to force a pipe spool into location by
      use of a chainfall. This practice, known as cold pulling or cold springing,
      is normally prohibited by the construction specifications. The presence in            .
      other locations of blocking similar to what was used by this crew, and                *
      apparent fitup problems throughout the piping suggest that this may have been
l
      done in other places in the system. In my work with documentation for the              i
!
      exhaust piping I found no reference to any authorization for piping to be
      cold pulled into alignment.
      All field welds were required to be stenciled by the welder with his
      identification symbol and the field weld number.      In numerous instances I
      found unmarked welds, and in some cases, incorrectly identified welds. Many            -
      of these had substantial surface rust, indicating that the work had been done
      some time ago. Identification marks were inscribed on these welds after I              '
      brought them to the craft supervisor's attention."
      I was told by a co-worker that the original contractor for the condensers and
      associated piping had been dropped when the system was partially completed,            l
      and the job reassigned to Pullman-Higgins.
      In my judgement these potential problem areas exist in the turbine exhaust            ,
      system and condenser piping:
      * Condenser traps in horizontal pipe runs.
      * Uneven support loading under heat exhangers.    In operation they are to be
      approximately half filled with water.      Those that are out of level will not        .
      match the weight distribution for which the supports were designed.                    i
      * Prohibited work practices may have been used to an unknown degree throughout        l
      the system.                                                                            l
      * Identification procedures created to insure weld quality do not appear to
      have been correctly carried out.
                                                                                            ,
l                                                                                            [
                                                                                            ,
;
 
                                                          ..  - - _          -. _      . -.  --  - - _ -  . ._- __  _-_  - _ .    - -, ,
t
                                                                                                                                                  '
.
4
                                                                                                92
                                                                                                                                                  i
i                                                    I wrote up a large number of nonconformance reports on piping in this system.
*
                                                      I do not know how they were dispositioned. This was the last system I worked                l
L                                                    on under Pullman-Higgins. When I returned to the site in July 1983, I was
,                                                    told that the as-built inspection program for ANSI B31.1 piping had been
{                                                    cancelled at that time because it was both too costly and unnecessary."
;
,                                                  ALLEGATIONS AS UNDERSTOOD BY THE NRC
j                                                    No clarification of the allegations was necessary.
                                                    DETAILS
:                                                                                                                                                1
                                                    The systems described in the allegation are not nuclear safety-related and are
.
'
                                                    not governed by regulations. However, the NRC is concerned about the general
                                                    quality of all plant systems to avoid equipment failures and challenges to
  '
                                                      safety systems. The inspector examined the installed condition of various                  '
                                                      feedwater beaters including FW-E-268 by column 10 and runs of horizontal piping.
l                                                  Horizontal runs of steam piping of significant length were noted to be sloped
4
                                                    toward drain piping taps. Feedwater heaters were found to be installed level
;                                                    in accordance with the high pressure and low pressure feedwater heater
j
                                                      installation instructions (IL 1370-1388 and 1370-1386) (Photos Nos.11 & 12).                f
i                                                    Tht; feedwater heater supports are as shown on drawings 4618039 and 4618038.                  !
l                                                    The turbine exhaust lines from both steam driven turbine feedwater (FWP) pumps
;                                                    were observed to be installed with a slope toward the condenser in accordance
i                                                    with drawir.g 97C3-F-2024. The nearby steam extraction lines (which exit the
i'                                                  condenser near the turbine FWP exhaust ifne entrance to the condenser) were                  [
                                                    observed to slope down from the condenser in accordance with Drawing 1-EX-4125-01.            t
{                                                    This condition of two lines penetrating the condenser with opposite slope would              [
i
                                                    present the appearance of reverse slopes, however system design requires the as
                                                                                                                                                  '
                                                    installed slope conditions.
,                                                  Cold pulling of pipe is discussed in allegations #7, #40 and #46, however one
;                                                    cold pulling incident did occur on Field Weld F0105 Spool E2937-1982 in the                  !
i                                                    turbine building as reported in the NCR 7035-80749, dated 8/10/82. The NCR                    t
i                                                    disposition provided for removal of the Comealong to establish the amount of
j                                                  cold pulling and provided for refitup of the weld without cold pull. The
                                                    disposition was verified as complete on 6/20/83. This NCR tilustrated that
                                                    excess cold pull of pipe was prohibited, workers were aware of the requirement
;                                                    and the need to implement the requirement.
l
l                                                    Weld identification is a means of providing traceability from the actual pipe
2
                                                    weld to drawings, procurement documents and quality records. It can be
!                                                    accomplished if the as butit pipe correlates with the drawings and construction              ;
I                                                    records. In the area of weld identification to ANSI B31.1, the inspector noted
                                                    the requirement for weld joint and welder identifications to be recorded on the              ;
                                                    appropriate weld procsss sheets, which are traceable to the applicable weld.                  :
                                                    For turbine building piping, the stenciling of pipe welds with the weld and
;                                                    welder symbols is supplementary information but not a regulatory requirement,                  ,
;                                                    and has no safety significance.                                                                l
l                                                                                                                                                l
l                                                                                                                                                  [
!                                                                                                                                                  !
!
!                                                                                                                                                  !
4                                                                                                                                                  ,
l  _ _ _ _ _ _ _ _ _ _ _ ____ _ _ _ _ _ _ _ _ _ _ _                _                                                                        .-_
 
  -
                                              93
    The as-built inspection program for ANSI B31.1 piping is not an NRC requirement
    for non-safety-related piping. The information generated by a detailed
    as-built B31.1 non-safety-related piping program would be entirely for the
    benefit of the licensee. The cancellation of the as-built B31.1 program in
    view of existing drawings, NCRs and installation records is justifiable. This
    decision has no effect on safety-related equipment integrity.
    For the main steam (MS) and feedwater lines (FW) an as-built inspection was
    performed including those sections of these lines in the turbine building.
    This inspection was conducted by the licensee under the Piping and Pipe
    Support Close Out Task Team (PAPSCOTT) reconciliation program. As of
    September 16,1986, the MS and FW lines including lines 4600 and 4601 were
    shown to be installed per the applicable design drawings. The licensee's
    investigation results, dated October 24,1986, concerning the as-buil6 inspection
    of MS and FW lines reported in File E-86-102-3(15) was reviewed by the
    inspector.
    CONCLUSION
    This allegation was not substantiated. During investigation of the              i
                                                                                    '
    allegation, all items inspected by the NRC were found to be installed in
    accordance with design drawings and equipment manuals. While it is true that    !
    the B31.1 as-built program was cancelled, the 831.1 code conformance was met by
    installation practices and procedures. No safety-related equipment deficiencies
    could be identified as a result of these allegations,
                                                                                    t
                                                                                    i
                                                                                    ,
                                                                                      !
                                                                                      !
                                                                                      r
                                                                                      l
                                                                                      !
                                                                                      i
-
 
    _. _ _ _ . _            _ _ . _ . . _ _ _ _                      . _ . _ _ _ _ _ _ _                              ._.
                                                                                                    93a
;                                                  ,  _            ;
                                                                                                              w c a.,
!                                                                                                        .
                                                                                                  '
                                                        ri. --                              . .
l                                                  Q] ta r ' K:
                                                  .i >
                                                                          [            s.
                                                                                                1.
                                                                                                4
                                                                                                                                        4
                                                                                                                          4
!                                              t
                                                                                                                                        .
I                                                                                                                                                  l
                                                  : ,; c'                                            4;y3;+ln
l
                                                                                                                -
                                                                                                                                        .        i
l
                                                t                                                                                        ,
                                                                                                                                        '
                                                                                                                                                  l
.l                                              ?                                                                                                  l
I                                                                                                                                                  l
:                                                                                                                                                  l
                                                                                                                                                  t
j                                                        PHOTO NO.11, FEEDWATER HEATER BEING CHECKED                                              l
I
4
                                                          FOR LEVEL INSTALLATION (REF. ALLEGATION NO. 55)                                          [
                                                                                                                                                  i
!                                                                                                                                                  l
!
I,                                                                                                                                                c
I
i
I                                                                                                                                                  !
1
i
                                                                                                                                                  i
l
s
:                                                                                                                                      4
                                                                    ~
                                                            .
                                                                .
                                                          w  -
                                                                                                                                . .
                                                                                                                                                  l
                                                                                                                                                  (
                                                                                                                                                  I
!
i                                                                                                                                                  i
                                                                                                                                                  !
                                                                                                                                                  I
I                                                                                                                                                I
I                                                                                                                                                l
:                                                                                                                                                !
)
!                                                          PHOTO NO.12, FEEDWATER HEATER DEING CHECKED
,                                                          FOR LEVEL INSTALLATION (REF. ALLEGATION NO. 55)                                        f
                                                                                                                                                  ,
k                                                                                                                                                ,
i                                                                                                                                                l
i
  -              _. _ . . . . _ _ . . . . _ _ . . . .                      _                              .. .            .. _    .    .. . .
 
    __ _ __.___ . . _ _ . _ _ _ . _ _ _ .                _ _ _ _ _ . _ . . _              ._                _ _ _ _ .            ..
  I
                                                                                                                                                              l
'
                                                                                          93a
1
l
l                                                                    k
i                                                              [N              f! i,.            ,
                                                                                                                                  >
                                                                                                                                        t
                                                                                                                                          a
l                                        ces          .
                                                                    . , .
                                                                                  ''
j
                                          i        dr!. ,4% a                ; j].
                                                !                                                                        " **
i
                                          j
                                            '
                                                                                                                                    % ,,,4
                                  e
!
l
                                                                                                    .
                                                                                                                                                    'l
                                                                                  ,
;                                x.          -                                        ,.  -r-sp
                                  % $: , ^ , -                                      ,                .
                                                                                                          -- 8
                                                                                                                                            .      ^: ;
                                                    '.                                        .,
                                                                                                        -
                                                                                                                              ~r                .
                                                                                                                                                      j
!
                                                                                                                                                      4
i
i
                                                  PHOTO NO.11, FEEDWATER HEATER BEING CHECKED
                                                  FOR LEVEL INSTALLATION (REF. ALLEGATION NO. 55)
l
1
1
l
                                                                                                                                                                '
i
i
                                                                                                                                                                '
(
                                                                                                                                        -
                                                                                                                                                  -
                                                                                                                                ..
                                                                                                                                                                l
                                                                                                          -
                                                                    .
                                                                                                                                                                ;
                                                    .g s
                                                                  .-
                                                                                                                                                                i
                                                                                                                                                                  l
                                                                                                                                                    q          l
                                                  PHOTO NO,12, FEEDWATER HEATER BEING CHECKED                                                                    i
                                                                                                                                                                I
                                                  FOR LEVEL INSTALLATION (REF. ALLEGATION NO. 55)                                                              .
                                                                                                                                                                \
                                                                                                                                                              ,
                                                                                                                                              .
                                                                                                                                                        . . .
                                                                                                                              .
 
                                                                                        1
!
!
                                            94
  56. ALLEGATION
  " Original drawings are required to be kept in fire proof storage. This
  requirement was frequently violated. A fire in the Johnson Controls tre.iler
  resulted in the loss of several drawings."
l
  NRC UNDERSTANDING OF THE ALLEGATION
  The requirement for fireproof storage of records was violated on site,
  specifically by Johnson Controls International; thereby, destroying important
  quality records and drawings.
  DETAILS
  The fire in the Johnson Controls trailer occurred in December 1982 as they were
  moving into a new trailer complex. Both the licensee fire brigade and the
  Seabrook Fire Department made efforts to prevent the loss of records. Partially    as
  a result of these efforts, no records were burned; however, some received smoke
l
  damage.
  The requirements for records storage include provision for duplicate and
  separate storage facilities as a means of protecting records.from fire and
  other loss. Johnson Controls maintained a duplicate storage for " original / copies"
  of drawings at a second location on the site at the time of the fire. When the
  records and drawings required for the work performed by Johnson Controls were
  turned over at the completion of the contract, the audit of those records did
  not disclose missing drawings or illegible records caused by fire damage.
  The inspector reviewed a representative sample of the records turned over by
  Johnson Controls and determined that these records were legible after
  microfilming.
  CONCLUSION
  This allegation as understood by NRC was not substantiated. Although, there
  was fire damage to the JCI facility, no permanent loss of records was sustained.
i
              9
 
-.
                                                                95
        58. ALLEGATION
        " Training of new hires was of uneven quality."
        " Training provided to new hires was of uneven quality. That provided by
        Pullman-Higgins was implicitly acknowledged by staff and students to be
        oriented toward passing everybody. Students were permitted to sleep through
        classes. Instruction at times consisted of being told what questions would be
        asked, and what the answers were. Testing was minimal and usually done with
        open books. I do not recall that any testing was done by Pullman-Higgins a
        the area of construction standards and practices. I failed to learn that sid
        springing of pipe in the turbine exhaust system which I observed was a prohibited
        practice; consequently I did not report it."
        NRC UNDERSTANDING OF THE ALLEGATION
        Orientation of newly hired employees was inadequate for specific positions and
        designed to assure all employees were accepted. The alleger was formally
        interviewed on November 5, 1986, the obtain additional clarification of his
        Concerns.
        DETAILS
        The inspector determined through interviews with the training supervisor that
        Construction Orientation was to provide newly hired employees with the basic
        requirements for working on the site. It included such things as safety rules
        so the employee would not become a hazard to themselves or others, actions that
        could result in disciplinary action, locations of restricted areas and other
        information. It should be recognized that training did vary with the type of
        job assignment and from contractor to contractor depending on the technical
        levels involved.
        The course of instruction was administrative in context and was not a measure
        of technical skill. As discussed in allegation nos. 10, 11, 12, 28 and 29 the
        NRC extensively inspected formal training related to engineer, inspector and
        craft qualification to perform job related tasks.
        During a formal interview with the NRC, it was acknowledged by the alleger that
        he received the appropriate specification to which he would be working, given
        time in the office to read and understand its contents, and a period of
        on-the-job training under supervision before he was allowed to independently
        inspect work.
        CONCLUSION
        This allegation could not be substantiated. Construction orientation was
        performed by various contractors prior to initiation of the General and
        Specialty Training Department. Each contractor presented the information they
        believed was necessary for thir employees to know. Due to the various
        projects on site this inform tion varied both from content and presentation.
        However, the training was administrative in nature and not related to job
        skills which were verified by employment checks, union halls, and
        qualification tests.
. _ _ .        - _ _ _ _ - _ _ _ _ - _ _ _ - _ _ - - _ - _ - -    - _.                    _ _ _ _ _ _ _
 
                                                  - _ _ _ - _ _ _
                                          96
61. ALLEGATION
" Fire Protection system was triggered in the control building and wires in the
trenches in the floor got wet.                                      ,
NRC UNDERSTANDING OF THE ALLEGATIONS
                                                                                  i
                                                                                  '
The alleger stated that cables were wetted when the fire protection system
was set off in the control building.
DETAILS
The NRC inspector reviewed FSAR layout drawings of the control building and
determined that the control building houses the control room, computer room,
north / south mechanical equipment roo,n and the cable spreading room. The cable
spreading room is the only area in the control building that is provided with a
zoned deluge valve fire protection system.    This automatic sprinkler system
provides fire protection for cable trays except for solid bottom trays with
covers in the cable spreading room, cable chases, electrical tunnels, penetra-
tions outside of containment and elevation 25'-0" of the primary auxiliary
building.
The NRC inspector reviewed APCSB 9.5-1, Appendix A, which evaluated the fire
protection systems and the automatic water suppression system in the cable
spreading room. No other area of the control building is provided with auto-
matic water suppression. Since the alleger has not identified any specific
area, referencing only the control building, it is assumed the alleger is
referring to the cable spreading room water suppression system. The NRC
inspector interviewed the fire protection coordinator who indicated that there
have been no reports or indications that the automatic water suppression system
in the cable spreading room had been tripped.
                                                                                ,
Assuming that there was a trip and the cable had been exposed to water,
material qualification documents for all safety-related cable used at Seabrook
indicate the cable is qualified for service in a harsh environment, including
submergence in water.
CONCLUSION
The allegation was not substantiated.
                                                                  .
                                                                                    .
 
                                                                      _ _ _ _ _ _
                                                    97
I
t
    ( M.ARY AND CONCLUSIONS
  The inspection team identified sixty-one allegations which were ultimately
  combined into forty-seven different issues. None of the allegations were
  determined to present a nuclear safety concern. Most of the substantiated
    issues were previously identified and do not represent equipment deficiencies.
I  Of the forty-seven issues that were inspected, thirteen were substantiatad in
  that the statement made by the alleger was accurate. However, eleven of the
  thirteen were previously identified either by the NRC or the licensee and were
  documented in licensee quality assurance records, NRC inspection reports, or
  formal correspondence between the licensee and the NRC, and received the
  appropriate engineering review and disposition.
  The two issues that have been classified as substantiated and not previously
  identified are one dealing with contractor adversarial relationships and the
  'other-dealing with cleanliness in the reactor. The contractor adversarial          l
  relationship was, to some extent, known by the NRC due the corrective actions      .
  that were applied to the subcontractor to rectify the inadequate performance      l
  problems. This was conservatively classified as not previously known becaure
  of the manner in which the NRC perceived the problem, not as one involving an
  adversarial relationship but one of iaadequate performance. The relationship
  aspect of the issue resulted from the identification of the performance reroblem.
  The second issue, dealing with cleanliness in the reactor, although confirmed
  to be true, was a conscious decision approved by the licensee's engineering staff. l
  The practice of providing a lower standard of cleanliness during heavy
  construction in the reactor, and then performing a final cleaning to
  acceptable standards may be different from other nuclear power plaats, but it
  was an acceptable method.
  The allegations that were substantiated were valid observations that "something
  was wrong" at that time in the plant construction when they we.re made. This is
  supported by the fact that thirteen of the allegations were substantiated and
  that the record indicates that substantial effort was expenr;ed to correct the
  condition. However, the allegers were unable to acquire a'l of the facts
  surrounding the issue and could not be expected to have knowledge of the
  corrective actions that subsequently took place.
                              -        _ - _ _ _ _
 
                                                      . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .      .. .. . . .
    e
  ,
!
                                      APPENDIX A
!
I
                                        RESUMES
l'
      Suresh K. Chaudhary, P.E.
      Organization:  U.S. Nuclear Regulatory Commission
                      Region I, Operational Programs Section, Operations Branch                                        i
(.    Title:          Lead Reactor Engineer
      Education:      Bachelor of Science in CE, University of Missouri, Rolla, Mo.
i
                      Master of Science in CE, University of Missouri, Rolla, Mo.
                      BWR Technology, USNRC
                      -PWR Technology, USNRC
l                      Welding Technology & Nuclear Code, USNRC
                      NDE Technology & Nuclear Code, USNRC                                                              !
                      Electrical Technology & Nuclear Code, USNRC                                                      I
                      Concrete Technical & Nuclear Code, Portland Cement Assoc.                                        i
                                                                        Chicago, IL/USNRC                                l
f                      Registered Professional Engineer
      Experience:
      USNRC          Member of technical staff engaged in inspection, analysis,
      1985  present and evaluation of nuclear plant operating systems and
l                      maintenance specialist in nuclear structures, supports,
l
,
                      and fluid systems.
      1982-1985      Senior Resident Inspector for construction at a two uait
                      BWR.  Responsible for resident inspection in construction
                      and preoperational tests.
      1978-1982      Member of regional technical staff engaged in inspection,
                      analysis,'and evaluation of nuclear power plant systems
                      under construction, especially, concrete and steel
J                      construction; modification of operating plant systems,
                      and plant maintenance.
      1976-1978      Duration and Management of Quality Assurance program at a
                      1000 MW PWR plant under construction.
      1963-1976      Various assignments in structural design of concrete
                      structures and pavements; technical and site feasibility
                      studies; geotechnical engineering, concrete and structural
                      quality control; and project cost and scheduling controls
                      at project and/or staff engineer level.
      Over 18 years of Design, Construction, and Inspection experience in
      nuclear industry.
                                                                                          _ _ _ _ _ _ _____
 
Appendix A                                    2
Name:          Edwin H. Gray
Organization:  U.S. Nuclear Regulatory Commission
                Region I, Materials and Processes Section
                Engineering Branch
Title:          Lead Reactor Engineer
Education:      B.S. Metallurgical Engineering - Drexel University,1963
Experience:    (Nuclear Industry - 20 years)
1982-Present    Member of NRC technical staff responsible for performing
                periodic inspections and related investigation of power,
                test and research reactor facilities during construction,
                testing, startup and operational phases.
1980-1982      Leighton Industries - Quality Assurance Director - Responsible
                for QA, QC Program, welding and metallurgy activities. ASME
                and Section I, IV, VIII, PP.
1978-1980      Foster Wheeler - Manager Dansville Welding Laboratory (NY)
                Manage Lab Functions of procedure qualification, services to
                manufacturing plant in areas of welding and materials ASME
                Section I, VIII, IX, MIL Specs
1970-1978      Foster Wheeler - Weld Applications Engineer - Oversee welding
                applications at Mountaintop Plant (PA) Products - FFTF & CRBRP
                IHX, Valves, Etc. and ASME Section I, VIII boilers and heat
                exchangers.
1963-1970      Chicago Bridge, Welding / Materials Engineer - Lab / Production
              coverage on ASME Section III vessels, Hydorcrackers, misc.
              other welded products.
Special Qualifications: Registered Professional Engineer - Penna.
                          Certified Welding Inspector - AWS
                          ASNT TC - la Level III - RT
                                                                                                  .
        .-          -          .      ,,- . .  .,      - __        __
                                                                            - - - - - . _ _ _ - .
 
,                                                                                            . .
  Appendix A                              3
  Name:        Peter S. Koltay
  Organization: U. S. Nuclear Regulatory Commission
                Region I, Division of Reactor Projects
!                                                                                                I
I
  Title:        Senior Resident Inspector                                                        '
  Education:    B.S. Engineering Sciences
                Registered Professional Engineer
                Member of Society of Fire Protection Engineers
  Experience:  12 years of nuclear industry experience.
  1981-Present  NRC Resident Inspector and Senior Resident Inspector.
                Responsible for accomplishing the NRC Light Water Inspector
                Program at an operating pressurized water reactor facility.
                Conduct aetailed inspections of such areas as system                              l
                surveillance, maintenance, major system modifications,
                inservice inspections, fire protection refueling and outage
                activities, radiation protection and quality assurance.
  1978-1981    Reactor . Inspector, performed inspections of . fire protection
                plan at nuclear power plants; evaluated the adequacy of fire
                protection system design.
  1975-1978    Senior Engineer, responsible for incorporating fire protection
                requirements of 10 CFR 50, App. A, Criterion 3, and those of
                Branch Technical Position 9.5-1, into the design and
                construction of nuclear generating stations, including
                Waterford 3, Lucy Unit 2, WPPSS Units 3/5, and Shearon Harris
                Units 1 through 4. Provided pertinent input on the interior
                design of safety-related structures, layout of safety-related
                equipment, routing of Class IE electrical cables and separation
                of redundant protection channels.
                                                                                _ _ _ _ _ _ .
 
Appendix A                              4
    Ralph J. Paolino
    Organization:  U. S. Nuclear Regulatory Commission
                  Region I, Plant Systems Section, Engineering Branch
    Title:        Lead Reactor Engineer
    Education:    University of Pittsburgh
                  Electrical Engineering - 3 years
                  Nuclear Engineering - 1 year
    Experience:    (Nuclear Industry - 22 years):
    1975-Present  Member of technical staff responsible for performing
                  periodic inspections and related investigation of power,
                  test and research reactor facilities during construction,
                  testing, startup and operational phases, to:    ascertain
                  conformity with design and other criteria; observe as to
                  the adequacy of licensee's controls and provisions for
                  overall operational safety; evaluate management, organization
                  control, procedures and practices of licensees and the
                  effect on, or their relations to, the safety of operations;
                  and observe as to the status of compliance of licensees
                  with license provisions, rules, orders and regulations of
                  the commission; and verify compliance with construction
                  industry codes and standards.
    1972-1975      Corporate Staff I&C Consultant / Senior Staff Engineer for
                  Architech Engineer. Responsible for the direction / develop-
                  ment and resolution of generic /specfic issues, establishing
                  corporate policy regarding specific design, standards and
                  specifications applicable to I&C systems and safety related
                  processes for nuclear generating plants.
    1964-1972      Special Products Manager - Medical Electronics firm.
                  Responsible for the direction, development and fabrication
                  of process control equipment utilizing radiation
                  monitoring techniques including effluent and process
                  radiation monitors for nuclear generating facilities.
                                                                                l
 
Appendix A                                  5
                                    RESUME
    Robert W. Winters
    Organization:  U. S. Nuclear Regulatory Commission
                  Region I, Quality Assurance Section, Operations Branch
    Title:        Reactor Engineer
    Education:    Bachelor Metallurgical Engineering
                  Rensselaer Polytechnic Institute
    Experience:    (Nuclear Industry - 13 Years)
    1985-Present  Member of the NRC technical staff responsible for
                  performing periodic inspections and related investigation
                  of power generating facilities during construction, testing,
                  startup and operational phases, to ascertain conformity
                  with design and other criteria; evaluate licensee manage-
                  ment controls procedures and practices as applied quality
                  assurance.
    1973-1985      Quality Assurance Specialist / Supervisor for nuclear
                  equipment manufacturer and installer. Responsible for
                  quality assurance programs, auditing performance,avelding
                  procedures and performance, vendor evaluation, and overall
                  quality performance during installations. Provided tech-
                  nical guidance to installation projects in processes and
                  welding. Interfaced with licensees, regulatory bodies and
                  industry standards groups.
    1951-1973      Various positions in aerospace, steel manufacturing,
                  non ferrous materials manufacturing, materials fabrication
                  and testing, and quality assurance.
                              ._    . - - ~  --.  ._. _ -            .-
 
                    APPENDIX B
                DOCUMENTS REVIEWED
UE&C Letter #SBU-98678, dated March 31, 1986, to
R. J. DeLoach, YNSD Project Manager
Nonconformance Report:
Nos. 59-5463; 57-5068;
In-Process Inspection Report
IR # P-106
Station Operating Procedure IP-104, " Level I Coating of
Concrete Surfaces", Rev. I through 4
Pittsburg Testing Laboratory, " Statistical Analysis-
Concrete Compression Test Data"    1977-1986
American Concrete Institute Standards:
ACI-211; ACI-214; ACI-301; ACI-318
Containment Concrete Placement Records:
Placement Number                    Date
1-CS-1E-1                            11/19/80
1-CS-1F-1                            11/25/80
1-CS-1K-3                            11/20/81
1-CS-1K-3A                          12/15/81
1-CS-I LM-3                          12/18/81
1-CS-1NO-3                          01/06/82
1-CS-1PQ-3                          01/28/82
1-CS-1RS-3                          02/10/82
1-CS-1TV-3                          02/24/82
1-CS-IV-3                            03/04/82
1-CS-1W-3                            03/10/82
1-CS-1FTC-1                          02/25/83
1-CS-1 FTC-2                        03/02/83
1-CS-1FTC-3                          03/04/83
1-CS-1FTC-4                          03/08/83
1-CS-1FTC-5                          03/10/83
 
.r-                                              ,
                                                                                    1
    Appendix B                                2
    Qualification of Flame Retardant Cable
    - - -
          Anaconda Certified Test Report No. 81-338-2-1
    --
          Cable Specification No. 9763-006-113-18                                  l
    --
          Franklin Institute Research Laboratory Report No. F-C4836-2 dated
          January 1,1978 and No. F-C4969 dated July 1978 with attachment No. 80282
    --
          Okonite Cable Code No. 13136H
          Receipt Inspection Report (RIR) No. 13199
          Reel NO. 24, 2/C #2
    --
          Anoconda Cable Code No. ABGM
          RIR No. 11272
          Reel No. 44, 2/C AWG 19/22
          Purchase Order No. 113-17
    --
          Okonite Cable Code No. CCGD
          RIR No. 3731,
          Reel No. 6, 3/C 250 MCM
          Purchase Order No. 113-3
    --
          Flame Test per IPCEA Publication S-66-524
          Part 6, Paragraph 6-12b
    --
          IEEE std 336-1871 requirement for inspection of cables and raceways.
 
  Appendix B                                3
  NRC INSPECTION REPORTS
        50-443/82-08
        50-443/82-12
        50-443/82-16
        50-443/83-04
        50-443/83-13
        50-443/83-17
        50-443/83-22
        50-443/85-05
      50-443/85-12
      50-443/85-15
      50-443/85-20
      50-443/85-30
      50-443/86-15
      50-443/86-19
      Systematic Assessment of Licensee Performance - February 19, 1985
      Systematic Assessment of Licensee Performance - May 14, 1986
  PROCEDURES
      FGCP-1    Development and Preparation of ASME Field Construction
                  Procedures.
      TP-10      Technical Procedure for Location of Attachments to Embedded
                  Plates
      ASP-3      Nanconformances
      QA-15      Nonconforming Materials, Parts, or Components
                  Fire Protection Plan (10 CFR 50 Appendix R)
  CORRESPONDENCE
      Letter Public Service Company of New Hampshire to US Nuclear
      Regulatory Commission dated December 2, 1982, referencing Inspection
      50-443/82-12
      Fire Department report of the Johnson Controls Incorporated fire on
      December 22, 1982.
  RECORDS
      QA Record Document Review Checklist - Johnson Controls Incorporated    i
      10/13/82                                                              i
      QA Record Document Review Checklist - Johnson Controls Incorporated    ,
4
      11/30/83                                                              l
      Training Record - Classroom Lecture and Hands On Workshop, Raychem
      High Voltage Kits, 8,3,84
  -      __  _
                                                        .
 
                                _ _                        -                                              ..                                              .                          . _ _. .__
,
          Appendix B                                                                                        4
          RECORDS (Continued)
              Training Records - Pullman Power Corporation, individual records
              August 1982.
              Training Records - Fischbach-Boulos-Manzi-NH - Individual records -
              February,1979 to January,1983
              Training Records - Perini Power Constructors, Inc. - November, 1981
'i
,
5
i
                                                                                                                                                                                                I
                                                                                                                                                                                                l
i
,
                                                                                                                                                                                                I
  - - - ,      - - - - - , - ,    -- . , . - . - - - - - - - , . . . - - . .. - - , _ - - - - - - . , - . - . - - - - _ - - - - - - . - , , . , - . , _ . - . . - - , , . , - , , , -
 
  .                                                                                                                                                                                .
                          APPENDIX C:                  PUBLIC SERVICE Of HEW HAMPSHIRE SUBSTANCE ABUSE PROGRAM
                                                                                                                                                                                        I
                                                                                                                                                                                        i
                                              BRIEF EXPLANATION OF SEABROOK DRUG AND ALCOHOL PROGRAM
                                                                                                                                                                                    i
                    NOTE:
                                                                                                                                                                                    1
                    The following is being provided in response to your request for additional
                    information regarding the Seabrook Anti-Drug and Alcohol Abuse Program. It
                    should be noted that some of the information being provided herein is based on
                    our investigations to date and has not been finalized. This may be updated as
                    additional information is reviewed in connection with NHY's response to a
                    request for information by Representative Edward J. Markey.
                    Discussion                                                                                                                                                      ,
                                                                                                                                                                                    1
                    Seabrook Station's policy regarding alcohol and drug abuse was not established
                    because of any perceived problem at Seabrook but rather because NHY recognized
                    at the inception of construction (i.e. July, 1976) that drug and alcohol abuse
                    are problems of national proportion and that the potential for those types of
                    activities might exist within the Seabrook Station workforce. To that end,
                    throughout the construction of the plant at Seabrook, NHY had in ef fect
                    measures designed to deter the use of controlled substances and to detect
                    their presence on site. However, given the magnitude of a project such as
                    Seabrook, where in excess of 20,000 workers of varying trades labored for over
                    eleven years, notwithstanding vigorous ef forts to bar these substances, there
                    were incidents involving alcohol and controlled substances, such as marij uana.
                    As such incidents occurred, management escalated the measures to detect and
                    deter usage of drugs and alcohol. A chronological outline of the measures
                    taken is provided in Attachment A. It should be noted that measures were, of
                    course, supplemented by a f ull scale quality assurance program to ensure the
                    integrity of plant safety, so that any work by any employee involving plant
                    safety has been and will continue to be su 'tect to multi-layered review.
                    The existing drug and alcohol program consists of several major features that
                    include, but are not limited to, the following:                                              search of personnel and
                    vehicles entering and leaving the site (begun in 1980), use of dogs to search
                    vehicles, buildings and site-related areas (begun in 1981), and drug screening
l                  of site personnel (begun in 1986). These steps are clarified in the security
                    procedures designed to prevent the entry of drugs or alcohol into the
,                  protected area and to identify drug and alcohol abusers. NRY feels the drug
                    prevention program has been effective and is one of the best in the industry.
                    Where our security program has uncovered instances of drug and alcohol
                    possession and has identified users, appropriate measures have been taken to
                    strengthen the program and deal with the individuals in question.
                                                                                                                                                                                      !
                                                            .                                                                                                            +
    _ _ . - - - - _      __ _ _ _ _ _ _ . - ,          .__  _ _ . _ . . . , , _ - . ,_____ _ _ --__._. ,______              - . _ _ . . . . . , , , _ . . ,- - --_x--.  . - ---
 
                                                                                      .
                                                                                    <
  The NHY " Fitness for Duty Policy" (Directive 10.0), "Use of Cont rolled Drugs"
  (Directive 10.l), and "Use of Alcoholic Beverages" (Directive 10.2) clearly          l
  state the corporate policy that drugs and alcohol have no place at the work
  site and will not be tolerated by NHY (part of Attachment B). This ef fort has
  been ongoing and will continue to improve since Seabrook Station is committed
  to implementing the Industry Sponsored Fitness For Duty Standards and has
  worked and will continue to work with INPO, EEI, and NUMARC on the issues.
  The length to which NHY has gore to stop drug abuse at Seabrook is evidenced
  in the April-December 1979 NHY initiated undercover operation that was
  performed with the full cooperation of the New Hampshire State Police and the
  Rockingham's County Sherif f's Department . As a result of this, 12 people were
  indicted for drug sale, use, and possession on January 10, 1980 (Reference NRC
  Combined Inspection Report 40-443/80-01; 50-444/80-01)
  In regard to your question regarding details of NHY's drug / alcohol
  rehabilitation program, we of fer the following. As indicated in Attachment A,
  shortly af ter July, 1976 a voluntary program was started to of fer workers
  assistance through personal counseling. In the spring of 1979, that voluntary
  Employee Assistance Program was recognized by Seabrook Station Management for
  site employees (manual and non-manual). In 1983, NHY also implemented an EAP
  for NHY employees. These EAP programs were established to ensure anyone who
  wanted help would receive it. EAP and Station Management handle each case
  independently, but when personnel seek help, they receive it through these
  programs. Under the NHY EAP, NHY personnel are removed f rom duty and not
  allowed to ret urn to duty until they have successf ully passed chemical
  screening testing. This program is clarified in New Hampshire Yankee
  Directives 10.3 and 10.4 provided as Attachment B.
  Finally, regarding your request for more details regarding the identified
  incidents of drug / alcohol usage we of fer the following. As you requested,
  provided in Attachments C and D are the " drug / alcohol use" summaries of NHY
  investigations by record type. In Attachments C and D, we have also atterapted
  to identify the source of our information as well as the breakdowns by craft
  or trade.
  The number of documented cases of workers in non-manual positions or
  " sensitive" positions being involved or terminated are very few (the breakdown
  by craft can be seen in Attachment C). An isolated example is the QA
  Inspector working for NHY for a period of 2 months until he was detected by
  chemical screening. In this case, the OA manager ordered a reinspection of
  the individual's work by qualified QA inspectors. Since Seabrook Station has
  an extensive system of checks and balances in place to ensure that all work on
  the Project is independently checked and verified several times, the work of
  any one individual cannot compromise the Ouality Assurance System or the
  quality of construction.    In this regard it should be noted that to date no
  personnel directly employed by NHY (Operators, Maintenance Services,
  Engineering Services, etc.) have failed the chemical screening testing.
,
                                                                                    li
                                                                                    ,
                                      --      _  -                  _. . _ - - -
 
                                                                              1
                                                                              !
Conclusion
In conclusion, it can be seen that an aggressive Security program has been and
continues to be in place to detect and prevent drug and alcohol abuse to the
greatest extent practical. Individuals who seek help get it and those who
violate the Seabrook Station drug and alcohol policy, including the Fitness
For Duty Policy are terminated. This pelicy is not new and Project rules are
in place and well-known.  Furthermore, when one takes into consideration the
number of workmen at Seabrook from 1976 to present (i.e. over 20,000
personnel), NHY does not believe that the figures represented in Attachment C
substantiate the allegations set forth by ELP nor do they reflect a compromise
in the quality of construction.
                                        _
 
                                                                    _ _ _ _ _ _ _ - _ _ _ _ _ -
                                                                                                  i
f
                                        ATTACMMENT A
            BRIEF CHRONOLOGICAL LOG OF SEABROOK DRUG / ALCOHOL ACTIVITIES
  July 14th, 1976      Project Rule #7 issued which prohibited the use of drugs
i
                      and alcohol at Seabrook Station. A volunteer program                        I
                      based on Alcoholics Anonymous principles started shortly
                      af terward.
!
l Spring of  1979    Employee Assistance Program (EAP) recognized by Seabrook
                      Station management for helping employees with
                      drug / alcohol problems
              1980    Vehicle / personnel search program implemented for anyone
                      entering Seabrook Station
  May,        1981    Training of Supervision on EAP (including foremen)                          l
                                                                                                    l
  September, 1981      Construction Management began putting greater emphasis on
                      the EAP program for use by employees
  December,  1981    Implemented use of dogs to perform random drug searches
                      at the Station
              1983    NHY Employee Assistance Program established specifically
                      for NHY personnel
  January,    1985    Employee Allegations Resolution Of fice established
  March,      1986    Fitness For Duty Policy established which included
                      chemical screening, observation and training
                                                                                                k
                                    _ _ _ _ _ _
 
                                                                    ^=o=""
                    FOR INFORNIMION Om                                                                a
                                                                                                        I
            4                        DIRECTIVE # 1000
                              FITNESS FOR DUTY POLICT                EFFECTIVE
      ONO                                                          03/03/86
PURPOSE:      To provide the NNY Fitness for Duty Policy. The NNY Fitness for
              Duty Program is contained in the Station Security Manual.
SCOPE:        This Directive applies to all NNY personnel, contractors, or visitors
              (e.g., inspection agencies) who are on the property that is control-
              led by NNY and known as Seabrook Station.
POLICY        NHY is committed to providing a safe work environment that protects
SUNMARY:      the health and safety of employees and the public.        The operation of
              a nuclear plant requires that employees be trustworthy and meet
              strict job performance standards.    Public and regulatory agency
              confidence in NHY's ability to fulfill its responsibilities also
              depends on meeting such standards. Personnel performing functions
              related to the construction and operation of facilities at Seabrook
              Station must be physically and sentally fit to safely and efficiently
              perform their assigned functions.
---------------------------------- REQUIREMENTS ---------------------------------
                                                                                    .
GENERAL      1.  All personnel at Seabrook Station shall adhere to the NHY
INFORMATION:      Fitness for Duty Policy.
              2.  Violation of the Policy will result in denial of access to the
                  Protected Area, and may result in disciplinary action up to
                  and including termination of employment or denial of access to
                  Seabrook Station.
              3.  All personnel entering Seabrook Station shall be subject to
                  personal searches, vehicle searches and chemical screening.
USE OF            Personnel entering Seabrook Station shall comply with
DRUCS:            Directive #10.1, Use of Controlled Drugs.
USE OF            Personnel entering Seabrook Station shall comply with                                  ,
                                                                                                          '
ALCOHOL:          Directive #10.2, Use of Alcohol.
                                                                                                          i
                                                                                                          l
CONTINUAL        NHY supervisory personnel shall receive initial and continutng                          '
BEHAVIOR          training in Behavior Observation in order to determine the
OBSERVATION:      continual reliability of personnel who are authorized unescorted
                  access to the Protected Area.                                                          )
EMPLOYEE          NHY vill provide confidential assistance to NHY personnel in
ASSISTANCE:      dealing with drug and alcohol problems that may adversely affect
                  job performance, in accordance with Directive #10.4, Employee
                  Assistance Program.
                  Participation in the Employee Assistance Prograo does not
                  preclude administrative action as a result of violating the                            ,
                  Fitness for Duty Policy.                                                              q
                                        .  ,,
                                                                    - ,                  - _ - . - - -
 
-
                                                                                      .
                                        DIRECTIVE 810.0                                l
                                  FITNESS FOR DUTT POLICY              EFFECTIVE
y        g                                                                03/03/86
  ADMINISTRATIVE  The appropriate Vice President or Director is responsible for
  ACTION:        taking administrative action, in accordance with Directive
                  #10.3, against personnel who violate the Fitness for Duty
                  Policy.
  ACCESS TO      1.  The Station Manager shall determine who is allowed access
    THE              to the Protected Area.
  PROTECTED
    AREA:        2.  Ef fective May 1,1986, all personnel, prior to being
                      authorized unescorted access to the Protected Area, shall
                      successfully complete a chemical screenina in accordance
                      with the NHY Fitness for Duty Program.
  PROGRAM            The Vice President - Nuclear Production is responsible for:
  RESPONSIBILITY:
                      e    implementation of the Fitness for Duty Program, and
                      e  ensuring that all NHY supervisory personnel receive
                            initial and continuing training in Behavior Observation.
                                                                                        l
                                                                                        l
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                                                                                        1
                                                                                        !
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                                                                                        l
                        *"
                                                                      2l2S/8d
                            E. A. Brown, President and CEO                  Date    -
                                          2 of 2
          .                  __          ___  -        -    ._.
 
                                                                                        i
                                                    I          I
                                                  J
                                'f
          "    #'                      DIRECTIVE #10.1
                                    USE OF CONTROLLED DRUCS                  EFFECTIVE
          lIO!                                                              03/03/86
  PURPOSE:      To provide the NNY policy regarding the use, possession, or sale of
                controlled drugs.
  SCO?E:        This Directive applies to all NNY personnel, contractors or visitors
                who are on the property that is controlled by NNY and known as
                Seabrook Station.
  POLICY:        The ille3al sale, use or possession of any controlled drug by an
                NHY employee, contractor or visitor while either at Seabrook
                Station or in an NHY vehicle or while assigned to NNY duty shall be
                cause for termination of employment or denial of access to Seabrook
                Station.
                The sale of any controlled drug by an NHY employee or contractor
                while off-duty shall be cause for suspension or termination of
                employment or denial of access to Seabrook Station.
                                                                                          1
                The illegal use of a controlled drug by an NNY employee or contractor
                while off-duty (other than any drug legally prescribed for use by the
                individual) may be cause for suspension or termination of employment
                or denial of access to Seabrook Station if such use could reasonably
                be expected to adversely af fect:
                      1.  the individual's job performance, or
                      2.  public or regulatory confidence in NHY to effectively
                          carry out its public service responsibilities.
DEFINITION:      The following shall be considered to be controlled drugs:
                      1. Amphetamines
                      2. Hallucinogenic / psychotropic drugs
                      3. Heroin and morphine-based drugs
                      4. Barbiturates
                      5. Cannabis-based drugs (e.g., marijuana, hashish, THC)
,
                      6. Cocaine
                      7. Other controlled stimulants or depressants
                      8. Prescription drugs
                      9. Any drug for which the use, possession or sale is
                          considered to be a violation of criminal law.
                                            1 3# 1
                                    -                    - _ _  . . . _ _ ~
 
                                                                                      D
                                                                                          i
    Hornpshire                    01RzCT8vt #10.t
        g
                                                                                        ,
                                USE OF CONTROLLED ORUCS            EFFECTIVE
                                                                                      '
                                                                                            l
                                                                    03/03/86              rl
                                                                                            l
PRESCRIBRD    An employee using a drug that has been prescribed by a licensed
DRUCS:        physician for personal use shall report the use of that drug to his
              inusediate supervisor if such a drug might reasonably be expected to
              impair that employee's ability to perfore any duties of the job to
              which assigned.
SEARCH AND    All personnel entering Seabrook Station may be subject to personal
SCREENING    search, vehicle search and chemical screening. The refusal to par-
              ticipate in such search and screening shall be grounds for denying
              access and for suspension or tertaination of employment.
              Personnel who require unescorted access to the Protected Area shall
              successfully complete a chemical screening prior to bsing
              authorized such access,
              1aw enforcement of ficials will be notified whenever illegal drugs are
              found at Seabrook Station.
                                                                                .
EMPLOYEE      NHY will provide confidential assistance to NMY personnel in dealing
ASSISTANCE:  with drug problems that may adversely affect job pe rformance , in
              accordance with Dtrective #10.4, Employee Assistance Program.
OTHER CON-    Supervisors are responsible for enfor:ing this policy and for
SIDERATIONS: reporting to other appropriate levels of supervision any activities
              that are prohibited herein.
                            MA-
                          E. A. Brown, President and CEO
                                                                      @c/uDate      t
                                        2 of 2
 
                                  1
    HQttpthG                      DIRECTIVE #10.2                                i
        g                    USE OF ALColiOLIC BEVERACES          EFFECTIVE          ,
                                                                  03/03/86            l
                                                                                      l
                                                                                      i
PURPOSE:    To provide the NNY Policy regarding the use, possession, or sale of      f
            alcoholic beverages.                                                      l
SCOPE:      This Directive applies to all NNY personnel, contractors, or visitors
            who are on the property that is controlled by NHY and known as            I
            Seabrook Station.                                                        I
POLICY:    The sale, use, or possession of an alcoholic beverage by an NHY
            employee, contractor or visitor while either at Seabrook Station
            or  in an NHY vehicle or while assigned to NHY duty at Seabrook
            Station shall be cause for suspension or terisination of employment,
            or denial of access to Seabrook Station.
            The use of an alcoholic beverage by an NHY employee or contractor
            while of f-duty may be cause for suspension or termination of
            employment or denial of access to Seabrook Station if such use could
            reasonably be expected to adversely affect:
                                                                              .
                    1. the individual's job performance, or
                    2. public or regulatory confidence in NHY to ef fectively
                  *
                      carry out its public service responsibilities.
DEFINITION: The following shall be considered alcoholic beverages:
                    1. Distilled and rectified spirits
                  2.  Wines
                  3.  Fermented and malt liquors and ciders
                  4  Beer, lager beer, ale, porter, stout
                  5.  Any other liquid containing one percent or more of
                      alcohol by volume and not more than six percent of
                      alcohol by volume at 60* Fahrenheit.
EMPLOYEE    NHY will provide confidential assistance to NHY personnel in dealing
ASSISTANCE: with alcohol problems that may adversely af fect job performance in
            accordance with Directive #10.4, Employee Assistance Program.
SEARCH      All personnel entering Seabrook Station shall be subject to
AND        personal search, vehicle search and chemical screening. The
SCREENING:  refusal to participate in such search and screening shall be
            grounds for denying access and for suspension or termination
            of employment.
            Personnel who request unescorted access to the Protected Area
            shall successfully complete a chemical screening prior'to being
            authorized such access.
                                                                                    l
                                                                                    t
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                                      ._
 
                                                                                                      ;
                                                                                                    ?,
                                                                                                    i
                                                                                                    l
r
                      Hampshire                  oIazCTIvt #10.2                                    j'
                        g                  USE OF ALCOBOLIC BEYERActs          EFFECTIV            1
                                                                                03/03/86
,
              OTHER CON-      Supervisors are responsible for enforcing this policy and for
              SIDERATIONS: reporting to other appropriate levels of supervision any activities
                              that are prohibited herein.
                                                                                            .
I
                                                        W                            Wlpg          ,
                                                                                                  i'
                                        E. A. Brown, President and CEO                Date        i
                                                    9 ,a 9
  . . _ _ . . , , . _                                              .                  _      _
 
                                                              l
            mpshire                              DIRECTIVE #10.3
            g                  FITNESS FOR DUTY: ADMIN!STRATIVE ACTION          EFFECTIVE
                                                                                  03/03/86
                                                                                                l
PURPOSE:            To provide the NNY Policy concerning the Administrative Actions that
                    will be taken when an individual violates the Fitness for Duty              i
                    Policy.
SCOPE:              This Directive applies to all NHY personnel, contractors or visitors
                    who are on the property that is controlled by NHY and known as
                    Seabrook Station.
TESTINC:            Drug testing shall be performed during all pre-employment and annual
                    physicals and prior to the .g ' anting of unescorted access to the
                    Protected Area.
                    Drug testing may be performed randomly on any individual at
                    Seabrook Station in accordance with the Fitness for Duty Program.
                    Drug or alcohol testing may be performed for cause anytime an
                    individual is suspected of being under the influence of alcohol.or
                                                                                          *
                    involved with illegal drugs.
                    Individuals have the right to re fuse to submit to drug or alcohol
                    testing.      Refusal to take either a drug or alcohol test shall result
                    in the same Administrative Action as a test failure.
                          e    Drug Testing - A positive drug confirmation requires that
                                both an Enzyme Multiplied Immunoassay Technique (EMIT) test
                                and a Cas Chromotography/ Mass Spectroscopy (CS/MS) test
                                confirm a value that exceeds the Fitness for Duty Program
                                limits provided in the Station Security Manual,
                          e    Alcohol Testing - A positive alcohol confirmation requires
                                that a blood analysis confirms a value that exceeds the
                                Fitness for Duty Program limits provided in the Station
                                Security Manual.
ACTION:            1.    Sale, Use or Possession of Alcohol or Drugs
                                          at Seabrook Station
                    Visitors who sell, use or possess alcohol or drugs shall be immediate-
                    ly escorted from Seabrook Station.
                    When a NHY or contractor employee sells, uses or possesses alcohol or
                    drugs at Seabrook Station, the appropriate Vice President / Director
                    shall immediately:
                          e suspend a NHY employee without pay, or
                          e    inform the senior contractor personnel on site to
                                remove the contractor employee from Seabrook Station.
                                                    1 of 2
    ___ -__            _    _
                                      _ -.        _    __.      ..
                                                                  .      - . - .            __
 
                                                                                                !
                                                                                                tl ,
        pahire                                DIRECTIVE #10.3
                                                                                                {l
        g                        FITNESS FCE DUTY: ADMINISTRATIVE ACTION          gFFECTIVE
                                                                                                !l
                                                                                  03/03/86
                                                                                                '
                                                                                                    1
ACTION:        2.  Pre-Esployment Testina
                Any individual showing positive on a drug or alcohol test shall not
                be hired by NNY or by contractors.                                                  I
                                                                                                  i
                3.  Initial, Periodie, Randos or "For Cause" Drun or Alcohol Testing
                                                                                                  1
                (These actions are illustrated in Figure 1)                                        J
                                                                                                  ,
                When any individual fails a drug or alcohol test, the appropriate
                Vice President / Director shall immediately:
                      e suspend a NHY employee without pay, or
                      e inform the senior contractor personnel on site to remove
                              the contractor employee from to Seabrook Station.
                4.  NHY Employees
                NHY employees violating the NHY Use of Alcohol Policy shall be referred
                to the Employee Assistance Program and may be returned to duty at the
                discretion of the appropriate Vice President / Director.
                NHY employees who fail the drug testing shall be referred to the Es-
                ployee Assistance Program and shall undergo retesting within 7 days
                of the suspension and, if necessary, at 14 and 21 days. An individual
                passing the tests at one of these intervals may return to work at the
                discretion of the appropriate Vice President / Director with the know-
                ledge that a 3 year randos drug testing program will be imposed. Failure
                of the tests at the 7, 14, and 21 day intervals shall be cause for ter-
                aination of employment at the discretion of the appropriate Vice
                President or Director.
                A second violation of the Fitness for Duty Policy shall result in
                tarmination of employment.
                5.  Contractor Employees
                A contractor employee who violates the NHY Use of Alcohol Policy may
                return to work at the discretion of the appropriate Vice President /
                Director after a 30 day suspension.
                A contractor employee who violates the NHY Use of Controlled Drugs
                Policy may return to work at the discretion of the appropriate Vice
                President / Director af ter a 30 day suspension and satisfactory completion
                of the drug testing.        Such individuals will be subject to a 3 year ran-
                dom drug testing program.
                A second violation of the Fitness for Duty Policy will result in the
                individual being denied access to Seabrook Station.
                                                                                A      V/ .5'd
                                  E. A. Brown, President and CEO                    Date    f
- _ _ _  _ _ .          __.      . .              .    . _ _ _ _ _ _
 
                                                                                                                                                                        .
                                                                                                                                                                      t
                                                        DIRECTIVE #1003
              .
                                    FITNESS FOR 00TY: ADMINISTRATIVE ACTION                                                                              EFFICTIVE
              IM                                                                                                                                                      h
                                                                                                                                                        03/03/86      i
.
                                                                          re.es.,
                                                                          e..,    ...
                                                                              ,,
                                                                      ,., p . i . e.e e , -
                                                                                                                      ate ***t          ru rea
                                                                                                                                    [. .. ree
                                                                            .,,f,                                                  a n net
                                                                    e ..
                                                                              9
                                                        *                        '
        .
        -
                                                                        e.... .
                                                                                s .'                                                            y
                                                                                                                                          t.              .
                                                                        m-                                                              Rose
                                                                                                                                      e.ei le                  i
                                                                                                                                      eu
      -                                                a                  wm
      '                                                                    fee                                                                                .
                                                                      e    ..s.,                                                                            8
                                                                                                                                                              .
                                                                                                                                              1
                                                                        as-
                                                                                                                              =          .,
                                                                              ,                                                      e iw '                      *
                                                                %..,..              .. .
                                                                    e  e.e...      e .
                                                                ,,. t .e i n u.e                                                      .                        !
                                                                                                                                                              .
                ==...
                        .......            D c.. . . .e . .                .,
                                                                                                                                                .
                                                                                                                                                ,
                'd'**                      T                                                                                                  ,              .
    '                          '
                " , , ' , ' " j" , , , -
                                      '
                                                                    t=*""'"
                                                                          ' "" " e                                              ei e. n.. .ee ..
                                                                                                                                                              '
                                                                                                                                                              i
                        9,,
                                                                                                                                3 6, = .. .... .
                                                                                                                                                              t
                    se .          I
                                                                                                                                see cettee to be
                                                                                  et                                          t      ' "a '              '    l
            l      Statta.      I
    '                        *
                                                                              ,
                                                                                                                                              .              ;
                                                                O f espees the 8
                                                                                                                                                  m
                            I                                    l                                                                                '
    '
                        :4 Set      I                                68en.tdeel.
                                                                    ei  t teet ma
            I
                SflPTB9 t N
                                                                          '-est                              fts
                                                                          ? eat
                                                                        Passee *
                            t
                            .
                                                                          .6 tet                            75 8  '
                                                                          ?a e t
                                                                        Poseee '
  s
                                                                        e
                                                                                                                  ,
                                        j
          '
              ftse Pteenoset et          -            ED / 11feet          Set                                  !
              9tteeter seter.a.ee t '                                  Psesse I
              the acesse te be        f
                                                                                                                                            ,
                                                                      fl0 1                                                                ,
                                                                              Y                                                            -
                          l                                e. n res.no se                                                                                                1
                          I                                      re est e 8-F.e#                                                                                      I\
                          i                                ..,. usee-  seeeense                                                                                      ,
                          i                                                                                                                                            t,
                          9                                              y_ -                                                                                              ,
                                                                                                                                                                    ;
                                                                                                                                                                    i
                                                                            sus
                - __ -                      ..                                      . _ - . _ - - . __ ,. _.                          . - - _ - . . -
 
                                                                    ,    i
                                          p
                                                          DIRECTIVE #1004
                      pahire                        EMPLOYEE ASSISTANCE PROC W                              gTFECTIVE
                                                                                                              03/03/86
  PURPOSE:                            To establish the NWY Employee Assistance Progree and infora
                                      employees of the help that it can provide in resolving personal
                                      problems.
  SCOPE:                              The Employee Assistance Progree is committed to helping any
                                      employee of NHY or a member of an NNY employee's immediate
                                      family who desires help in dealing with:
                                            e emotional or mental distress,
                                            e alcohol or drug problems,
                                            e marital or family dif ficulties , and
                                            e    financial or other personal problems.
  PARTICIPATION:                      Participation in the Employee Assistance Program is voluntary.
                                      All requests and referrals are held in strict confidence.                                          An
                                      employee's job security and opportunities for promotion are not
                                      jeopardized by these requests and referrals.
                                      Employees who are having difficulties coping with a persona'l
                                      problem or troubled situation are encouraged to use this
                                      program.
                                      The Employee Assistance Program provides initial probles
                                      assessment end subsequent referral to appropriate counseling
                                      and professional services. Locations and time of appointments
'
                                      will be made in accordance with the employee's schedule and
                                      needs.
                                      When the employee health care program does not cover the
                                      service, employees will be referred, whenever possible, to
                                      services that can be paid for on a sliding fee scale.
                                      NHY employees may make an appointment with the Employee
                                      Assistance Program Administrator by calling 83-2565 or
                                      622-3842.      The latter phone number can accomodate a confiden-
                                      tial message 24 hours a day.
  RESPONSIBILITY:                    The Director of '4anagemment Control is responsible for ensuring
                                      that all NHY employees are made aware of the Employee Assistance
                                      Program and to periodically evaluate the Program to ensure that
                                      tt is responstve to employee needs.
                                                                                                                                            !
                                                WW
                                                                                                                                            f
                                                E. A. Brown, President and CEO
                                                                                                            a/.w/x                  Date
                                                                                                                                            l
                                                                                                                                            '
                                                                      i , , .
      . _ _ . . _ _ _      _ _ _ . -          _
                                                            _ _ . .        _ _ _ _ _ . _ _ _ __ . _ _ _ ___  _ _ _ _ _ - . _ _ . _ _ .    -
 
                                      ATTACHMENT C
                                                                                      '
                          Types Of P7rs'n*71 And Medien! Rec"rds                        l-
                                                                                        I
                        Reviewed And Statistics Associated Thereof
                                                                                        l.
                                                                  Records That Contain
                                                  Total Records      References To
                                                      Reviewed      Drums Or Alcohol    <
1. UE&C files on manual employees (crafts-
  men) that were determined ineligible for
  rehire covering the period 1978 thru
  1983. Although only UE&C subcontractors
  hired craftsmen during this period, the
  files encompass the total population of
  craf tsmen determined ineligible for
  rehire based on circumstances of termi-                                          *
  nation through end of 1983.                          716              117
2. UE&C files on terminated manual employees
  covering the period 1984 to present. At
  the start of this time period, all sub-
  contractors to UE&C were eliminated and
  UEEC assumed the hiring, payroll and
  records responsibilities                            6800                26
                                                  (includes
                                                  "rampdowns" in
                                                  site craftsmen)
  NOTE:    Record types 1 and 2 above include all manual labor used on the
            site from 1978 to present with the exception of lump sum contracts
            labor, which although small in terms of overall numbers, could not
            be estimated in the time available.
3. 1986 chemical screening process failures
  which resulted in denial of access to
  Unit I protected areas                              $300              136
4. UE&C non-manual files (supervisors, QA/QC
  personnel, engineers, etc.) covering the
  period since onset of site work (7/14/76)
  thru present.    These files do not include
  non-manuals associated with UE&C subcon-
  tractors for the 1976 through 1983 time
  periad. Those records are the property
  of tt.e various subcontractors and are not
  available to NHY.                                  3400                10
                                                  (includes        (1 rehabilitated
                                                  "rampdowns" in  and rehired)
                                                                                        I
                                                  site workforce)
 
                                                  2
                            Types Of Personnel And Medical Records
                          Reviewed And Statistics Associated Thereof
                                                                      Records That Contain
                                                      Total Records    References To
                                                        Reviewed      Druas Or Alcohol
50 Medical records associated with
    Workman's Compensation Claim files
    covering the time period of 1976 thru
    present. This review encompassed all
    individuals that reported to the site
    (UE&C) first-sid station and were
    referred to any off-site medical
    practice or facility. UE&C handled
    all non-PSNH Workman's Compensation
    related insurance carrier claims
    throughout this period.                              10,607              44
NOTE:    Further broken down the 44 Workman's Compensation case files, that
        involved mention of drugs or alcohol, many of which are unsubstan-
        tiated by objective medical testing, appear as follows:
  a.) Exeter Area Hospital Emergency
          Room Reporte                                                        8
            (Note: These are the 8 instances referred to by
                      Mr. E. A. Brown on 11/7/86 and represent
                      the full extent of NHY investigation as
                      of that date.)
  b.) Notes, by various attending physicians
          in Workman's Compensation Follow-Up
          Reports                                                              5
  c.) Exeter Clinic progress reports same
          day as site-related injury                                          3
  d.)    Exeter Clinic progress reports one
          or more days after the site-related
          injury                                                              4
  e.) Notes in UE&C investigation reports
          (UE&C conducted a backup investigation
          for all 10,607 Workman's Compensation
          Claims)                                                              7
  f.)    Individuals terminated due to events
          unassociated with the on-going and
          incomplete Workman's Compensation
          Claim (all for violation of Project
          Rule #7)                                                            3
  3.) Records of testimony:        New Hampshire
          Department Of Labor Decisions                                        3          j ;
 
                                                                                                        3
                                                            Types Of Personnel And Medical Records
                                                          Reviewed And Statistics Associated Thereof
                                                                                                                            Records That Contain
                                                                                                              Total Records    References To      i
                                                                                                                  Reviewed    Drugs Or Alcohol
        h.) Notes made by attending physicians
            that made reference to the injured
            employee's previous medical history
            which, although not directly related
            to the injury, established historical
            reference                                                                                                              11
                                                        Total Workman's Compensation                                            -
                                                        Files That Involved Mention Of
                                                        Drug Or Alcohol                                                            44
                                                                                                                                                    I
        The 44 case files conservatively represent less than 0.25% of the
        total on-site workforce (greater than 20,000 individuals) over the
        1976 to present time frame.
                      .                                                    .
                                                        44    x 100 = 0.22%
                                        20,000
                      _                                                    ..
                                                                                                                                                  $
                                                                                                                                                  $
                                                                                                                                                  1
                                                                                                                                                  l
                                                                                                                                                  n
                                                                                                                                                  J
                    -                                                                                                                            \
- _ _ _                  _- - - - - _ _ - - - _ - - - -                        -- _ -- - -- -------- - - --- -
 
  -    __ __-_            _ _ _ _ - _ _ - -
                                                                                i
                                                                                I
                                                    ATTACHMENT D
    Craft / Trade Breakdown                                                      b
    h Inettatble for Rehire files
                                                                                4
              Painters                          1                              el  i
              Carpenters                      22                              .
[              Laborers                        32                              l'
>              Iron Workers                    32
              Pipe fitters                    15                                  l
              Electricians                      9
              Machine Operators                4
              Truck Drivers                    2
                                                                                l-
                                        Total 117
                                                                                    'I
    E UE&C Manual Workers Termination                                          ,
              Painters                          4
              Carpenters                        4
              Laborers                          5
              Ircn Workers                      2
              Pipe fitters                      5
              Insulators                        3
              Electricians                      1
              Welders                          I
                                                                                      l
              Surveyors                        1
                                      Total    26                              ,
                                                                                't
                                                                                  I
    $ UE&C Non-Manual Terminations
              Clerical                          3                                l
              Safety                            1                                ,
              Drafter                          1                                !
              QA Engineer                      2
              Craft Supv.                      1
              Engineer *                        2
                                                                                i
                                      Total    10
              *  I of fice Engineer underwent rehabilitation and was rehired.
}}

Latest revision as of 16:49, 5 May 2021

Insp Rept 50-443/86-52 on 861103-14 & 18-21.Major Areas Inspected:Allegations Re Const Activities & Mgt Controls. Insp results:13 of 47 Allegations Substantiated,Although 11 Previously Identified by NRC or Licensee
ML20212B923
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 12/17/1986
From: Bailey R, Chaudhary S, Durr J, Ebneter S, Gray H, Koltay P, Paolino R, Winters R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212B805 List:
References
50-443-86-52, NUDOCS 8612290345
Download: ML20212B923 (133)
v • d • e


See also: IR 05000443/1986052

Text

{{#Wiki_filter:g. 

                              U.S. NUCLEAR REGULATORY COMMISSION
                                             REGION I

^ 

    Report No. 86-52
    Docket No.   50-443
    License No. NPF-56              Priority                         Category         C
    Licensee: New Hampshire Yankee
    Facility Name:       Seabrook Unit 1
    Inspection At:       Seabrook, New Hampshire
    Inspecti,on Conducted:     Nov. 3 - 14, and Nov. 18 - 21, 1986
    InspectoMs:    N calt h W                                                             iz /17 / 8 6
                  S. K. CMT(Tdhary,/ Lead Reactor Engineer, 08, DRS                            ' date
                             CLM          f                                              />/ti/tc.
                  R. J(/Paolino, Lead ' Reactor Engineer, EB, DRS                                date

" 

                          y        ag                                                   /2 ////d?C
                  H. Gray, Lead p Zctor Engineer, EB, DRS                                        date
                   ~
                                     S                                                     //l/ 7l8C.
                  P. S. Koltay, Sr. Resipent Inspector, IP#3                                  ' da t'e
                        dhtu            n_s+       n-                                    /n//'//TC-
                  R/ J. Aailey, Physical Secgrity Inspector, DRSS                            ' d a t'e
                                                                                            17.,fi 1      Bb
                  R. W. Winters, Reictor Engineer, QAS, DRS                                      date
    Team Leader:         mc /               o#rs                                        /a//v/E
                                                                                             ' dath
                                                                                                        ~
                  Macq6'e P. Durr, Chie,f, Engineering Branch, DRS
    Approved by:   .
                           -
                                  Y              c                                      / ?-// 7 [Y
                   ~5tewart D. Ebneter, Director, Division of                               ' date
                         Reacter Safety
       8612290345 861219
       PDR    ADOCK 05000443
       G                     PDR
                                                                                                           ___ - . _ , _
         _             _                     _
                                                   _ - . _ - . _ - -        , _ _ , _            . - _ _

                                                          . -
                                  TABLE OF CONTENTS

EXECUTIVE SUMMARY 1.0 INTRODUCTION 

      1.1 PERSONS CONTACTED
      1.2 BACKGROUND
      1.3 REPORT ORGANIZATION
      1.4 QUALITY ASSURANCE HISTORY
     '1.5   NRC INSPECTION PROGRAM

2.0 ALLEGATIONS 

        No.           Subject                Page No.         'S
         1.           Concrete                  15
        2.            Concrete                  17
        3.            Concrete                  20
        4. & 17.      Concrete                  22
        5.            Concrete                  24      .
        6. 49. & 50. Fire System                25
        7.            Concrete Lining           28    ,
        8.            Service Water Flood       31
        9.            Paint                     33
       10. & 35.      Training                  35
       11.            Training                  37
       12. & 27.      Weld Training             38
       13. & 21.      Drugs                     42
       14.30.31.&60. Work Hours                 46
       15.            Painting                  47
       16.            Harassment                49
       18.            Debris in Motor           50
       19.            Fire in Conduit           51
       20.            Startup Checklists        53
       22.            Security                  55
       23.            Security _                56
       24.            Procedures                58
       25.            Frocedures                60
       26.            Procedures                61
       28.            Electrical Training       62
       29.            Training                  63
       32. & 57.      Track Blueprints          64
       33.34.47.59&60 Contractor                66
       36.            QA                        69

                                                                                   '
         -63
                        ~
         m..w

e'd- 

     ,
                  Table of Contents                            2                                                   ,
it:
                             No.          Subject-               Page No.
                           37.            Literacy Test             70
                           38.            Elect. Paint Thinner      71
~
  
                           39.            Electrical Fire           73
            .
                           40. & 46.      Pipe Alignment            74
         0-               141.            Security                  76
                           42.            Concrete                  78
                           43.            Housekeeping              80
                           44.            Improper Welds
                     ~
                                                                    81
                           4 5 .-         Welding Argon             83

s 

                           48.            Feedwater System          85
  '
          cr
          "
                           51.    s       CBA HVAC                  86
                           5 2 .'         EFW                       87
      4       ;fT          53.            Control Room Sprinkler    88
                           54.            CBA Drawings              90
i                          55.            Turbine Bldg. Equipment 91
                           56.            Records Storage           94
                           58.            Training                  95

gr 61. Wet Wires. 96 

                  3.0 SUMMARY AND CONCLUSIONS
                  APPENDICES
                  A.    STAFF RESUMES
                  B.    REFERENCE DOCUMENTS
       '
                  C.    PuBLIC SERVICE OF NEW HAMPSHIRE
      '
                        SUBSTANCE ABUSE PROGRAM

. J 

                                      , ,   y   . , , -                 . . - . __   . . _ , , m -- _ _ , .-. ,,..

                                 EXECUTIVE SUMKARY

BACKGROUND Tne Nuclear Regulatory Commission (NRC), Region I Office, contacted the Employees Legal Project (ELP), a nonprofit organization, on August 4,1986, regarding allegations of questionable construction practices 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 letter to Governor Dukakis 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. Throughout the contacts with ELP, the NRC requested to be put into direct contact with the allegers without success. However, two of the allegers made public statements to the press and issued signed affidavits containing their concerns. The NRC attended the press conference and acquired the allegers names and addresses for future contact. These affidavits were not from the san.e sources as those provided in the Governor Dukakis letter. The several allegation sources were reviewed by the NRC and each allegation was listed separately, although it may have resulted in duplicate allegations. This was done to preclude any issues from being overlooked. This resulted in sixty-one separate allegations. The allegations were grouped into seven categories as follows: concrete, piping and welding, painting, procedures and training, security and drugs, electrical, and management. Where similar or duplicate allegations have been 'centified, they are grouped and addressed together in the report. INSPECTION TEAM An interdisciplinary inspection team was established to investigate the allegations. Engineering disciplines of the team members correlated directly with the technical concern identified in the allegations. Each engineering inspector had extensive experience in at least one technical discipline and was thoroughly familiar with the NRC program of inspection. Disciplines represented on the team were electrical, mechanical, metallurgical, and civil engineering. These technical disciolines were supplemented by members experienced in fire protection, security, quality assurance, and plant operations. The team leader was a middle manager, Engineering Branch Chief, with extensive nuclear plant construction experience. The team members were authorized to expend whatever resources were required to resolve the issues. The inspection team arrived at the Seabrook plant on November 3, 1986. 

Executive Summary                          2
INSPECTION METHOD
The inspection method was to review the allegation, determine the alleger's

basic concern, and restate the allegation where more detail was needed to focus on the technical issue perceived by the NRC. Based on the specificity of 

information supplied by the alleger, the alleged condition was related to
specific plant areas.    In those cases where specifics were lacking, i.e. the

allegation was in general, broad terms, the team interviewed ELP and allegers 

to obtain more details. In most cases, the alleger did not provide further

details. Plant hardware was inspected and independent tests performed where possible to evaluate the allegation. In some cases the previous record of inspection had documented the allegation and in these cases the record was reviewed and corrective actions verified. Interviews were conducted of allegers and plant staff t'o aid in the inspection. The bases for any conclusions are derived from an inspection of the actual item or area if known and accessible, previous NRC inspections of the issue, established engineering knowledge and quality assurance records. SUMMARY AND CONCLUSION The total number of allegations identified was sixty-one; this was reduced to forty-seven when duplicates were combined. The inspection, in many instances, disclosed that previous knowledge of the alleged condition was identified by the NRC or the licensee and documented in quality assurance records, NRC inspection reports or formal correspondence between the licensee and the NRC. Thirteen of the allegations were substantiated in that the statement made by the alleger was accurate; however, eleven of these allegations were previously identified by the NRC or the licensee and were appropriately dispositioned by engineering. 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. Within the scope of this inspection, no nuclear safety significant issues or violations were identified.

1. INTRODUCTION 

  1.1 PERSONS CONTACTED
        New Hampshire Yankee
        R. Cyr, Maintenance Manager
        W. Daley, Licensing Manager
        W. Derrickson, Senior Vice President
        W. DiProfio, Assistant Station Manager
        R. Ferrell, Licensing Coordinator
        I. Fugenbaum, Executive Assistant to Sr. V.P.
        W. Johnson, Vice President, Quality Programs
        D. McLain, Production Services Manager
        D. Moody, Station Manager
        T. Murphy, I&C Supervisor
        D. Perkins, Licensing Engineer
        T. Pucko, Senior Licensing Engineer, Regulatory Services
        C. Roberts, Security and Computer Services Manager
       J. Tefft, Project Engineer, Regulatory Services
       W. Temple, Licensing Coordinator
        C. Vincent, QC Supervi:;or
        L. Walsh, Operations Manager
        N. Wiggins, Training Manager
        Yankee Atomic Electric Co.
       G. F. Mcdonald, QA Manager
       S. B. Sadosky, EAR Program Manager
       Employee Allegation Resolution Program
       A. Fasano, Investigator
       W. Gagnon, Investigatcr
       U. S. Nuclear Regulatory Commission
       A. C. Cerne, Senior Resident Inspector
       D. Ruscitto, Resident Inspector
       The above listed personnel attended one or both exit interviews
       conducted on November 7 and 14, 1986. Other licensee personnel were
       contacted as the inspection interfaced with their area.

                                     2

1.2 BACKGROUND 

      During the May - July 1986 time period, the NRC became aware of The
     Employee's Legal Project (ELP), a nonprofit organization, which is
     designed to receive safety concerns of current and former employees
     of New England nuclear power plants. On August 4, 1986, the NRC
      formally contacted the Employee's Legal Project and solicited any
      safety allegations concerning nuclear power plants under the NRC's
     jurisdiction.
     The NRC came into possession of an unsigned letter, dated
     September 12, 1986, from the Employee's Legal Project to Governor
     Dukakis of the Commonwealth of Massachusetts, containing two
     unidentified affidavits and 35 allegations of wrongdoing at the
     Seabrook Nuclear Power Station. The NRC responded to the Governor
     Dukakis letter with a telephone call on September 23, 1986 and a
     letter, dated September 24,1986 to The Empicyee's Legal Project
     requesting any additional information.     In these contacts, the NRC
     requested Employee's Legal Project assistance in making direct
     contact with the allegers.The Employee's Legal Project responded by
     letter, dated September 25, 1986. In this response, it was stated
     that all allegers refused to meet with the NRC directly. Further, the
     ELP transmitted 10 additional allegations also relating to the
     Seabrook Nuclear Power Plant.
    The NRC transmitted the forty-five allegations to Public Service of-
    New Hampshire, the licensee of the facility, and requested that they
    perform an investigation. Independently, the NRC formulated plans to
    assemble an inspection team to address the allegations. Subsequent to the
     foregoing ELP contacts, two of the allegers provided affidavits and
    media interviews which raised the number of allegations to sixty.
    Some of these additional allegations were duplicates of the previous
    forty-five but originated from a different source and were treated
    as separate issues to insure that all allegations were addressed.
    During the course of the inspection, the NRC contacted the ELP and
    the identified allegers and conducted formal interviews in order to
    gather as much detailed information as possible. The interview
    results increased the number of allegations to sixty-one. Subsequent
    to the inspection on-site, the ELP sent a letter to the NRC inspection
    team leader, dated November 10, 1986, containing clarifications to
    allegations 1, 2, 3, 18, 19 and 22.     These clarifications were
    evaluated, inspected, as appropriate, and factored into the inspection
    findings.
                                                     . _ -

                                      3

-1.3 REPORT ORGANIZATION 

      The sixty-one allegations generally were categorized into seven
      areas: concrete, piping and welding, painting, procedures and
      training, security and drugs, elsctrical, and management. The NRC
      formed a team consisting of a team leader and six specialist inspectors
      with qualifications in electrical, metallurgical, quality assurance,
      security, civil and operations engineering to address the allegations.
      The team arrived onsite at the Seabrook Nuclear Power Plant on
      November 3, 1986.
     The inspection focused on any general or specific actions that the
      licensee had previously taken to address these allegations;
      any previous actions by the NRC during the course of its normal
      inspection program; and any direct inspection or examinations that
     could be performed after the fact by the inspection team. It is
      important to note at the time of the inspection the major systems,
      structures and components of the facility were completed, and most
     major contractors have demobilized and left the site. The only major
     contractor remainino on-site is United Engineers and Constructors,
     the architect engineer, which has significantly reduced its staff
     size. This means that most of the people that had first hand
     knowledge of the events discussed in this report are no longer
     readily available at the site. The inspection team's charter
     was to address the allegations resulting from the ELP letters, the
     affidavits, and any allegations resulting from interviews directly
     connected with the inspection.
     Further, the licensee has announced the cancellation of Unit No. 2;
     thus, the inspection focused on Unit No. 1 and the implications
     resulting from Unit No. 2 allegations as they might relate to
     Unit No. 1.
     The allegations are numbered one through sixty-one and are sequenced
     in the order in which they were recieved. Where there are duplicate
     or similar allegation;, they are grouped together. The report is
     structured such that the allegation is presented as it was received
     from the alleger, the allegation is restated, as necessary, to better
    define or clarify the problem or concern as it is understood by the
     NRC; details resulting from the inspection are provided and then a
     conclusion based on the facts is stated. The allegation conclusions
     are presented according to whether they are substantiated, true, as
     stated, or unsubstantiated, any part or all of the allegation is not
     borne out by the facts. Those that are substantiated are then
     evaluated for any significant impact on nuclear safety.                    !
                                                                                1

1.4 QUALITY ASSURANCE HISTORY  ! 

                                                                                !
    As a prelude to the resolution of the allegations, it appears to be         I
    appropriate to describe the Quality Assurance Program that has been         l
     in place since the beginning of constrt.ction at the Seabrook Nuclear      '
    Station. Many of the allegations appear to have been made without the       1
     knowledge of the comprehensive procedures for assuming quality that        !
    have been in place during construction and are continuing today.
                                                                    ___ _     -

                                      4
       Public Service of New Hampshire was required to have a quality assurance
      program outlined, approved and in place before construction began.
      This approval was granted by the Nuclear Regulatory Commission only
      after a thorough review. The program was presented in the Preliminary
      Safety Analysis Report which wo submitted with the application for a
      permit to construct the plant.
      The program outlined and implementoa was a three tier system in which
      first level quality control inspections were provided by the organi-
      zation performing the work. The organizational structure was required
      to be such that the quality control group was independent of the
      group doing the work. The second and third levels were performed by
      the Yankee Atomic Electric Company in the form of surveillances and
      audits. These surveillances and audits were and are performed on
      suppliers, fabricators and constructors of safety related equipment
     and structures.

1.5 NRC INSPECTION PROGRAM 

     Overlaid on this system is the Nuclear Regulatory Commission's
      inspection program wherein resident inspectors and regional based
     technical specialists perform inspections and audits of all licensee
     safety related activities. To date, the NRC has expended over 20,000
     inspection hours at the Seabrook site verifying that the construction
     meets established requirements. Further, there are other organizatons
     that provide inspection and audits during the construction and startup
     phases such as the American Society of Mechanical Engineers' Authorized
     Nuclear Inspector for the piping systems and the containment to insure
     that the plant meets the national codes.
     The inspection programs do not end with the construction phate. During
     the preoperational and actual plant startup phases, additional tests
     are performed to assure that the equipment functions as designed.
     Each system is tested to demonstrate that it meets performance
     specifications. These tests are run on individual systems and, in
     some cases, as integrated systems where they must function together.
    After the preoperational tests are performed, the startup testing
    program demonstrates that the plant will respond to a known set of
     transients for which it has been designed. All of these tests have
    established acceptance criteria which must be met. These tests are
     reviewed and monitored by the NRC to assure the program is working as
     required.
    Throughout the construction and the preoperational phase, the NRC
    performeo special inspections designed to focus on known critical
    aspects of the project. These inspections included a Region I
    Construction Assessment Team, June 1982; an Inspection and Enforce-
    ment Integrated Design Inspection, November 1983; an Inspection and

                                                5
                                              %
    Enforcement Construction Appraisal Team, April 1984; a Region I
    Construction Team Inspection, June 1985; a Region I Independent          j
    Measurements Inspection, July 1985; a Region I As-Built Team Inspec-     l
    tion, March 1986; and a Region I Technical Specification Inspection,
    May 1986. These inspections were designed to examine the programmatic
    aspects as well as the actual installation of equipment.
    Fundamental to all of this is the NRC inspection program which
    examines all aspects of the licensee's construction organization and
    practices. Examples of the NRC's efforts in this area are discussed
    below as they relate to the allegations.
    Several of the allegation conclusions are supported by the fact that
   NRC inspectors interface directly with licensee's staff, the contractors

l 

   and subcontractor personnel. This includes the craftsmen performing
    the work. During these interfaces, the inspector discusses the
   technical aspects of the ongoing task including any concerns the
   craftsman may nave with the construction practices. The NRC has been
    informed of allegations by craftsmen on several occasions at this and
   other nuclear power plants. Interviews are an integral part of the

l ! 

    inspection process and occur in almost every inspection. Inspection
   reports that provide examples of interviews are presented in Table 1.
   The NRC performed in excess of twenty-six inspections directed toward
   the welding process application, including training and qualification,
    in the nuclear piping and structural welding areas. See Table 2 for
   a listing of sample reports. Welding inspections have also been
   performed on the Heating, Ventilation and Air Conditioning, pipe
   supports, electrical cable trays and non-nuclear components. These
   inspections have included evaluation of the nondestructive examina-

! tion (NDE) methods used, appearance of welds by visual examination l i 

   and documentation of weld acceptance. Confirmation of the effective-
   ness of contractor NDE has been verified by independent NRC examina-
   tions using the Mobile Nondestructive Examination Van employing
   radiography, magnetic particle, ultrasonic and other examination
   methods.
   In general, welding god NDE activities were found to be conducted in
   accordance with applI,able codes and specifications. Where problems
   have been identified by the NRC, these have been tracked until completion
   of the corrective actions. A review of a sample of the NRC inspection
   reports indicates that thousands of individual field observations
   have been made over the life of the construction.
   During the construction of the Seabrook facility, the NRC has con-
   sistently been concerned with the training and qualification of
   personnel performing safety related work. The nuclear standards and
 .
   regulations provide for the training and qualification of welders to
   the American Society of Mechanical Engineers, Section IX, nondestructive
   examination inspectors to the Society of Nondestructive Testing
   practice SNT-TC-1A and other inspectors to the American National
          _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

                                   6
Standards Institute N45.2.6.       Other training is performed that assures
the technical aspects of construction are satisfied, although it is
not specifically prescribed by codes; examples of this are the cable
splicing and termination and concrete expansion anchor installation
instructions given. The NRC inspects these training and qualification
programs and examples af inspection reports that reflect this are
presented in Table 6.
The electrical inspection program reviewed the procedures, design
specifications, personnel qualifications, and installation and
inspection criteria.      In conjunction with this, the installation of
equipment was observed to assure that the established procedures

were being implemented. The observation phase of the program 

included the witnessing of terminations, cable splices, cable
pulling operations and proper routing. The routing inspections also
included the verification of the cable support system. Examples of
these inspection are presented in Table 3.
In the area of civil / structural work, the NRC has performed in-excess

of forty (40) inspection starting in 1976 with geotechnical/ foundation work to concrete and other structural work. These inspections focused on the clarity, technical adequacy, and quality assurance aspects of the controlling specification and procedure of the work to include witnessing on going work, inspection of completed work, and review and examination of records generated by quality control to document conformance to the requirements. Most of these inspections were unannounced, that is the licensee and/or contractor personr.el did not know of the impending inspection by the NRC until the arrival of NRC inspectors on site. Examples of inspection reports showing areas of inspection and their focus are presented in Table 4. As the plant is built, the NRC continuously monitors the progress and selects completed portions for as-built verification. This includes co:nparison of the as-built system with the Final Safety Analysis Report, drawings and other requirements and commitments to assure accuracy. Several inspections were made of the as-built condition of systems, one of which was a team effort devoted to this alone. Table 5 contains a listing of inspection reports that address as-built inspections. All of this inspection is designed to assure that any single error in design or installation will not prevent the design safety features from performing as intended. Incorporated into the design features of the plant are concepts of defense-in-depth and redundancy. 

                                                                            l

                                            7
,                                       TABLE 1
                              EXAMPLES OF NRC INTERVIEWS
                               AT SEABROOK F0WER STATI0rj
  INSPECTION           DATE                       REMARKS

4 

  REPORT NO.
  80-03                2/26-28/80                Electrical
  84-10                6/26 - 8/24/84            Containment, Reactor Vessel
  84-13                8/27 - 10/26/84           Welding
  85-01                2/11 - 4/5/85             Piping and Electrical
  85-07                3/11-15/85                Heating and Ventilation
  85-09                4/8-24/85                 Preoperational Testing
  85-10                4/15-19/85                Welding
  86-15                3/14-19/86                Containment Leak Rate Testing
  86-21                3/31 - 4/4/86             Electrical
  86-23                4/14-18/86                Training
  86-34                6/24 - 7/7/86             Bolting, Health Physics
  86-45                8/18-22/86                Electrical
  86-46                7/8 - 9/15/86             Startup Testing, Fireproofing
j

i 

   . - - - , - - . - -

                                     8
                                                                                      4
                                TABLE 2
                    WELDING AND NDE INSPECTIONS ON
                    NUCLEAR AND STRUCTURAL WELDING

INSPECTION INSPECTION REMARKS 

 REPORT      DATE
                                                                                      :

78-07 4/24 - 4/28/78- Containment Liner Welding and NDE 78-08 5/22 - 5/25/78 Containment Liner Welding and NDE 78-09 6/26 - 6/28/78 Containment Steel, Welding, NDE, Qualifications 80-03 2/26 - 2/28/80 Stainless Steel Welding, Stud Welding - 

                                 One Violation

80-04 4/14 - 4/17/80 Pipe Welding Controls, Overcheck of Shop Welds 80-11 9/16 - 9/19/80 Three Violations - Resolved 81-08 6/29 - 7/24/81 Pipe and Pipe Supports Including NSSS, 

                                 RPV Safe Ends                .

81-12 10/5 - 11/16/81 Pipe Installation, Programmatic QA Inspection 81-13 11/3 - 11/6/81 Machine Welding (GTAW) 81-14 11/17/81 - 1/8/82 Pipe Installation, QC and NDE, Interviews 82-03 3/23 - 5/3/86 Reactor Coolant Pipe Welding, NDE, Pipe 

                                 Weld Repair Program

82-06 6/21 - 7/2/82 Two Violations Resolved (NRC-NDE Van Insp) 82-10 8/24 - 9/30/82 Pipe and Pipe Support Welding, Interviews, NDE 83-01 1/17 - 1/21/8 End Return Welds (Boxing), Pipe Support Welding 83-06 4/11 - 5/23/83 Pipe, Pipe Support and Electrical Raceway 

                                 Installation

83-07 5/23 - 5/27/83 Vessel Internals - Violations - Resolved 

                                 Struct Steel

83-09 5/24 - 7/1/83 Piping and Pipe Supports, QC Inspector 

                                 Harassment Interviews

83-12 8/8 - 8/12/83 Violation - UT Procedural Problem - Resolved 83-13 7/11 - 8/26/83 RCPB Installation, Instrument Tubing, 

                                 Pipe Supports

83-17 10/17 - 12/5/83 Containment - Penetrations and Leak Chase, 

                                 Piping and Supports

83-22 12/6/83 - 1/20/84 Small Bore Piping, NDE Qualifications 84-07 4/23/ - 5/25/84 Hardware and Documentation is per Requirements 84-12 8/13 - 8/31/84 Allegation Inspection - Welding, Piping, 

                                 Valves, NCR Control

84-17 10/29 - 12/17/84 Interviews of Crafts, RPV, Piping Walkdown 84-16 10/29 - 11/2/84 RPV Nozzle Repair, Pipe and Pipe Support Welding 85-15 6/3 - 6/14/85 Special Construction Inspection, Management, 

                                 Welding and QA

85-19 7/15-7/26/85 No Violations (NRC-NDE Van Insp) 

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

                                                         9
                                                   TABLE 3
                                           ELECTRICAL INSPECTIONS
     . INSPECTION
       REPORT NO.                   DATE                                        REMARKS
       50-443/79-10        December 11-13, 1979         Installation procedures require safety
                                                        related cables installed in raceways.
       50-443/82-03        March 23 - May 3, 1982       Discusses the qualification and flame
                                                        retardant characteristics of Class IE
                                                        cables.
      50-443/82-11         September 20-24, 1982        Verified by inspection that safety-related
                                                        cables are installed in raceways.
      50-443/83-03         February 22-25, 1983         Reviewed the cable pulling program (CASP)
and verified that safety-related
                                                        cables were in the specified raceways
                                                        as required by the CASP. Also
                                                        verified cable terminations were made
                                                        per specification requirements.
      50-143/83-05         March 2 - April 8, 1983 Verified that Class IE cables were in
                                                        seismically installed raceways and
                                                        that cable pulls were per procedures.
      50-443/86-36         June 16-20, 1986            Allegation 18 - A review of the HVAC
                                                        re-work was verified by the inspector
                                                       and the operational. testing of the
                                                        system reviewed.
      50-443/86-37         May 10-17 & June 9-13,86 Preoperational testing of the HVAC
                                                        system was verified by NRC witnessing.
      50-443/86-46         July 8 - September 15,86 As built verification of the enclosure
                                                       air handling and PAB air handling
                                                        system.
 .--           - - _ _ . _     -
                                     -   _ - -  _
                                                        _ _ _ - - , .     . . .         _, -

                                                                                                              _
                                                    10
                                                TABLE 4
                                           EXAMPLES OF NRC
                                 CIVIL / STRUCTURAL INSPECTIONS
         INSPECTION   DATE                    REMARKS
         REPORT NO.
        76-02         7/14-15/76              QA plan for Construction
        76-03         8/2-4/76                Concrete Quality Control, Qualification
                                              of Concrete Test Lab.
    .
        76-06         12/13-15/76             Interview craft personnel, Cadweld
                                              procedure.
        77-03         7/6-8/77                Qualification of concrete lab, control
                                              of concrete.
'i
        77-06         8/26/77                 Craft interview, concrete fill, test

1 lab inspection, groundwater control. 

        77-07         10/3-4/77               Control of concrete, test lab.
        77-10         12/5-9/77              QA/QC for concrete, rebar, batch plant,
                                              test lab. Sampling of rebar.
        78-02         2/14-17/78             Concrete test lab inspection, observation
                                             of rebar installation inside containment
                                              in reactor cavity. Fill concrete.
                                             Qualification of cadweld splicing process

, 

                                             - equipment and crews. Qualification of
                                             concrete testing and inspection personnel.
                                             Waterproofing of containment foundation.
        78-05         3/20-24/78             Observation of Unit I containment basement
                                             placement.            (Placement #1-CPS-3A; 4000 psi
                                             Mix)
        78-07         4/24-28/78             Record review for foundation concrete.
        78-08         5/22-25/78             Observation of concrete placements.

. 

                                             (placement #1TB-41B; ITB-27B; CN-E7d;
ITB-41)
        78-10         7/10-14/78             Observation of containment concrete
                                             (1300 cy of 4000 psi concrete in reactor

i pit structure); Installation of Rebars 

;
                                             and cadwelds in containment basement.

, 

                                             Resolution of concrete lab conformance

1 

                                             to ASTM E-329 (78-02-04)

, ! ' 

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

                                      11
                             TABLE 4 (Cont)
INSPECTION DATE                 REMARKS
REPOPT NO.
78-13      9/5-8/78             Concrete aggregate tests, interview
                                craft personnel.
78-15      11/6-9/78           Observation of containment structural
                               concrete - QA/QC, preplacement, placement,
                               post placement inspection and curing of
                               previously placed concrete (placement
                               #1-CM-7A; 4000 psi mix)

79-01 1/15-18/79 Containment Concrete placement observation 

                               records. (Placement #1-CI-1)

79-02 1/24-25/79 Investigation of frozen c.oncrete joint. 79-03 2/12-15/79 Training of site personnel. (Professionally 

                               produced film)

79-07 8/13-16/79 NOV - Void area in excess of maximum 

                                      allowed. (79-07-02)
                               NOV - Lack of approved repair procedure
                                       for concrete (major repairs).
                                      (79-07-03)

79-09- 11/13-16/79 NOV - Failure to prescribe corrective 

                               action for rebar installation before
                               concrete placement.    (79-09-01)

80-01 1/22-25/80 (Drug Indictments) Observation of cadweld 

                               splicing of rebars in Containment Building
                               exterior walls; Observations of placement
                               preparation circulating water pump house
                               walls; observations of cold weather
                               curing of concrete.

80-04 4/14-17/80 Review of cadweld significant deficiency 

                               50.55(e)

80-06 5/19/80 - 6/27/80 Observation of concrete base mat placement 

                               for Unit 2 containment.

80-12 10/13/80 - 11/21/80 Allegation Investigation of Site Concrete 

                               Lab for conformance to ASTM and ANSI
                               standards. Concrete Batch Plant inspection.

80-13- 11/24/60 - 12/31/80 Containment concrete placement (cutting of 

                               1000 rebars at Elv. +25.0)

                                     12
                            TABLE 4 (Cont.)
INSPECTION DATE                REMARKS

REPORT NO. 81-04 3/12/81 SALP no change in concrete inspection 

                               program.

81-12 10/5/81 - 11/16/81 Concrete placement preparation, cadweld 

                               splicing, containment liner and concrete
                               interfacing.

82-03 3/23/82 - 5/3/82 Cadwelding of rebars, corrective action 

                               on groundwater leakage.

82-04 5/4-14/82 Concerns regarding concrete repair 

           6/1-18/82           (allegation on concrete sand)

82-07 6/14-17/82 Observations of concrete construction of 

                               containment review of corrective actions
                               plan for control of groundwater seepage
                               through concrete cracks.

82-09 8/24-27/82 Review of procedures and observation of 

                               work in containment concrete preparation,
                               placements, and curing.

83-07 5/23-27/83 Review of documentation of containment 

                               dome concrete.

84-07 4/23/84 - 5/4/84 Construction Appraisal Team Inspection 

           5/14-25/85          Concrete Activity (Report Section IV)

84-12 8/13-17/84 Team Inspection to resolve allegations. 

           8/27-31/84          Cracks in concrete wall; interviews with
                               craft personnel.

86-43 

                  -     . _         . . . _                 . _ _ _ _                                                 . _ _ _ _ _ . . . .     _     _   _
                                                                            13
                                                                        TABLE 5
                                                    EXAMPLES OF NRC AS-BUILT INSPECTIONS
                    INSPECTION                               DATE                                       REMARKS
                    85-09                                    4/8 - 5/24/85                             RHR, EFW, Steam Generator
                    85-15                                    6/3-14/85                                 Safety injection, RHR, HVAC
                    86-43                                    7/7-11/86                                 Cable trays and supports
                    86-46                                    7/8 - 9/15/86                             RHR, CVS, RCS and others
,
!
                                                                                                                                                           .

1 I l ! ! I i i 

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

     '

, 

                             14
                         TABLE 6
              NRC INSPECTIONS OF TRAINING
 INSPECTION
 REPORT      DATE                REMARKS
 79-08       9/4 - 7/79          Quality Assurance
 79-09      11/13 - 16/79        Concrete Placement
 79-10      12/11 - 13/79        Quality Assurance, Welding
 82-06       6/19/82             Nondestructive Examination
 83-12       8/8 - 12/83         Instrumentation, Mechanical,
                                  Nondestructive Examination
 84-07       4/23 - 5/4/84       Electrical, Mechanical
 84-16      10/29 - 11/2/84      Mechanical, Welding
 85-07       3/11 - 15/85        Mechanical
 85-11       4/29 - 5/3/85       Electrical
 85-19       7/15-26/85          Nondestructive Examination
 86-15       3/4-19/86           Startup Mechanical
 86-23       4/14-18/86          Non Licensed - I&C, Electrical,
                                  Mechanical
                                                                 ,

                     .
                                                  15
         2.0 ALLEGATIONS
         1. " Cement was poured in below freezing temperature (contrary to product
         recommendation designed to produce proper solidification and strength)."
         NRC UNDERSTANDING OF THE ALLEGATIONS
         NRCs understanding of this allegation is that during cold weather, one place-
        ment of concrete in the containment wall was done where the construction joint,
         top surface from a previous placement, was frozen due to inadequate heating of
         the enclosure provided for cold weather construction protection. Additional
         information provided by the alleger to the NRC, indicated that it happened on
         the night shift in the containment building. Also, the allegation was regarding
         frozen concrete on which fresh concrete was deposited rather than freezing
        weather conditions.
        DETAILS
        The NRC inspector interviewed the Site Quality Assurance Manager and Supervisors
        to determine their knowledge and understanding of site QA procedures during
!
        concrete construction; examined the construction schedule and associated QC
        documentation for the construction of Unit-1 containment structure; and reviewed
        prior NRC-Inspection Reports and other correspondence to determine the history
        of containment concrete and its quality. Because the allegation did not provide
        a specific year or period, the NRC reviewed the chronological construction
        schedule for the Unit I containment structure beginning on 9-1-77 through 4-14-83.
        The concrete placements carried out in cold weather months were selected for
        detailed record review. Out of a total of seventy-seven (77) major and minor
        concrete placements (pours) during this period, sixteen placements were identified
        to have been performed during the months of November through March of 1980 -
        1983.     It was determined by these records that none of the sixteen placements
        were started on the second shift; moreover, only four of the placements were
        started when the ambient temperature was below freezing. The previously placed
        concrete temperature in every case was above freezing levels. These temperatures
were recorded by quality control inspectors using calibrated thermometers;
        calibration of which was traceable to National Bureau Standard (NBS). More
        importantly, in addition to temperature measurements, construction joints are

, 

        inspected for surface preparation, water and ice, and general cleanliness and
        preparation.
        The inspector determined by review of NRC Inspection Report (IR-50-443/79-02)
        that a similar allegation had been brought to the NRCs attention by a telephone
        call on January 23, 1979. The NRC investigated the concern, and concluded that
        the concern was not sub:tantiated. This conclusion was based on the following:
  - - .       - -      . _ - - -      --       -      -- - -       - _ - . ..    --     . - - -

                                            16
      "The inspector examined batch plant, quality control and placement records
      and examined all concrete placements that had been performed at the site
      on January 23, 1979. The placement were:
      Unit No. 1 Administration Building Stack Foundation, Placement A3B,
      Elevation 21 ft., 61 cubic yards, started 12:40 PM, completed 2:30 PM.
      Unit No.1 Condenser Pads, C Bay North, Placement ITPM-80, 5 cubic yards,
      started 2:30 PM, completed 3:30 PM.
      The inspector also interviewed construction supervision, quality control
      and quality assurance personnel involved in the January 23, 1979 placements.
      Each of these persons was found to be fully familiar with the details of
      their placements, including the steps taken to remove the small patches of
      ice that had formed over the previously placed concrete, the use of space
      heaters in the placement areas prior to placement, the use of portable
      propane torches to dry surface water remaining on the previously placed
      concrete, and the measurement by quality control personnel of the concrete
      surfaces prior to placement, to assure that minimum placement temperatures
      were exceeded."
Starting from 1976 through 1984, the NRC has performed 35 inspections /investi-

gations in the area of containment concrete and penetrations to verify the 

licensee's conformance to specifications, codes, and standards. Observation of

on going work was an integral part of these inspections, the NRC monitored and witnessed many of the safety related concrete placements. (See Table 4.0). Furthermore, the overall functional capability and the safety of the contain- ment structure is tested by the NRC required Structural Integrity Test (SIT). The NRC has witnessed the test, and has evaluated the results. If there was a deficiency in a construction joint, it is expected that the deficiency would show-up during the SIT. The expansion of containment due to pressurization induces cracks in the concrete which are mapped and documented. Any deficient joint is the most likely place for crack development. No such indications were noted during the SIT. The inspector visually examined some construction joints in this inspection, and did not find any spalling of surface concrete, any cracks visible to the unaided eye, voids, or any evidence of foreign material embedded in the joint to indicate unacceptable joint preparation. CONCLUSION Based on the summation of NRC inspections, the relatively small number of cold weather concrete placements, a review of quality records, and the successful completion of the structural integrity test, it is determined the containment is struturally sound and there is no evidence of inadequate construction joints. This allegation was not substantiated. 

                                                                                   l
                                                                                   l
                                                                                   l

                                           17                                        l
                                                                                    l
2.2 ALLEGATION
" Cement which was tested and rejected as an improper mixture by a safety inspector

was subsequently poured." 

NRC UNDERSTANDING OF .THE ALLEGATIONS
                                                                                    l

Based on further amplification from the alleger, it is understood that this i occurrence was alleged to have happened on the third shift during a concrete l placement in the containment structure. ' 

In the November 10, 1986 letter to the NRC, ELP provided additional information

as follows: 1 " Allegation #2: Concrete rejected by an inspector was poured anyway. When: November - December 1977 or January - Febrmry 108. Where: Containment of Unit II; could not be ::. ore specific. Why concrete was rejected: It did not meet specifications. A woman in white hard hat had a sample can, put something like a probe in it, rejected it, then left." DETAILS The containment structure is built with a 4000 psi nominal strength concrete mix. A total of approximately 11500 cubic yards of concrete have been used in the base mat, the shell, and the dome of the structure. One batch of concrete which is nominally 10 cubic yards, is a very insignificant part of the structure (approximately 0.00087 of the total). Also, if the process of placement of concrete by pumping is taken into consideration, this batch is placed over a wide area and mixed with previous and subsequent batches by thorough internal vibration. The primary purpose of all the process controls and field testing of concrete is to insure production of generally uniform' concrete of desired characteristics. However, concrete being a hardened mass of hetrogeneous material is subject to th2 influence of numerous variables. Consistent concrete of acceptable quality is produced and placed, if proper control is maintained, test results are properly interpreted, and limitations are con- sidered. To evaluate an isolated instance of a batch of concrete which does not meet the strict acceptance criterion, the following statement in the American Concrete Institute standard, ACI 214-65, must be considered: 

     " Proper control is achieved by the use of satisfactory materials,
     properly mixing these materials....., and good practices in transporting,
     placing, curing, and protecting the fresh concrete."

                                            18
       "Whenever practicable, conclusions on strength of concrete should be
       derived from a pattern of tests from which the characteristics and
       uniformity of the concrete can be more accurately estimated. To place
       too much reliance on too few tests may result in erroneous conclusions."
       (emphasis added)
 The quality of structural concrete in the Unit I containment structure has been
  inspected, and the test records of the concrete have been reviewed by the NRC
 periodically throughout the construction phase. These inspections have been
 documented in 14 NRC Inspection Reports (78-01; 78-05; 78-10; 78-15, 79-02;
 79-09; 80-01; 81-12; 82-03; 82-07; 82-09; 82-13; 84-12; and 85-07)
 There are several checks of concrete quality; one at the batch plant, one at
 the point of placement and a final strength test (compressive test cylinders).
 The cylinders are stored to properly cure the concrete for a specified period
 of time and then loaded in compression and the failure strength measured by an
 independent contractor. The strength of the cylinder test is a direct correlation
 to the quality of the concrete and produces an independent check.
 The NRC inspector reviewed the compression test records for containment
 concrete during this inspection.     These records were generated and submitted to
 the licensee by Pittsburg Testing Laboratory, an independent testing contractor.
 The records indicated an average strength of approximately 5000 psi, which is
 25*4 higher than the nominal design strength. Also, there is a latitude in the
 acceptance standards for fresh concrete with regard to air content, slump, and
 temperature.    Isolated minor deviations in these properties do not affect the
 serviceability of concrete. A wide range of tolerance in the acceptance value
 for these properties is allowed in concrete specifications.
 The NRC was unable to determine the significance of the action by the woman in
 the white hard hat. Normally, concrete acceptance requires a set of tests
 specified by project specifications and the Division 2 of the ASME code.     The
 tests include slump, air content, and temperature for every 50 CFT, and in
 addition a minimum of two sets (two 6" X 12" cylinders each set) of compression
 test specimens for every 100 CFT of concrete placed. The inspector / technician
 is also required to record the rejection on the batch ticket and/or acceptance
 form. All acceptance, rejection, or other disposition of the concrete must be
 recorded on the batch ticket that accompanies the batch of concrete. The batch
 ticket is the primary vehicle to account for the production, use, and rejection
 of concrete. Therefore, if the concrete was truly tested by the " woman in
 white hard hat", and she was a QC inspector, she must perform the full set of
 tests, i.e. air-content, slump and temperature; and if the batch is rejected it
 must be recorded on the batch ticket, and the ticket returned to the batch
 plant. The batch plant inspector must review and account for all concrete
 produced and its disposition through the use of batch tickets.

, 

 The inspector reviewed concrete batch tickets in conjunction with the cold
 weather concrete placement record review. No instance of rejected concrete
 being placed was identified. The NRC has reviewed batch tickets for many
 placement in safety related structures during prior inspections (see table 4.0).

                                                                                                                                                    l
                                                                                 19
                    CONCLUSION
                    This allegation can not be substantiated. It is unlikely that an occurrence of
                    this nature can happen because of the multiple inspection and audits. In
                    addition, actual test samples of concrete by an independent lab verified that
                    the age hardened concrete exceeds design strength by an average of approximately
                    25%.

, , e a 

 . . ~ . w-- -- -
                  w ,y 9-+--wwe-9 ,,w,- ,y-w,e-pwen-----7ywwm   mquS+'NehMWWW"MMYW  9--*-
                                                                                                                                             "
                                                              .
                                                                                          CN' - * * *^*" *~ " " " " ^ ' ^ ' " " ' ^ - ' ^ ^ ~ ~ # '

                                                                                  s
                                           20
 3.   ALLEGATION
 " Empty beer cans and bottles were discarded in the wet cement by workers drink-
 ing on the job, potentially creating air pockets and affecting the integrity of
 the containment."
NRC UNDERSTANDING OF THE ALLEGATION
The allegation as understood by the NRC is that empty containers (cans and
bottles) were discarded into the fresh concrete during concrete placement.
DETAILS
The NRC reviewed the licensee's alcohol detection / prevention program and other
related documentation. The licensee instituted controls to prevent the use of
alcohol on the Seabrook site. Futhermore, NRC has monitored / witnessed many of
the safety-related concrete placement directly in containment and other
structures. These inspections did not disclose any instance of discarding of

cans / bottles in concrete. The NRC has also periodically reviewed the concrete placement inspection records generated by the site QA/QC organization. These 

records also did not indicate any instance of foreign materials in concrete.

The licensee concrete placement QA program required more than one placement QC 

inspector to monitor the placement. On larger placements, six to eight QC
inspectors monitored the placement.    It seems likely that if containers were

being discarded into the concrete, the QC inspectors would notice this problem. Additionally, engineers and construction supervisors were also present to monitor and direct the placement operations. None of these technical and supervisory personnel reported any such incident. In spite of the unlikely event that large numbers of containers were being thrown into the concrete, it is possible that some isolated instance of this act could have happened. To determine the safety significance of such an occurrence, the NRC evaluated the response of the containment during the Structural Integrity Test (SIT) under 115*; design pressure. No unusual response and/or cracks were noticed; the crack patterns developed on the wall were mapped and compared with the predicted crack growth. It was consistent; indicating no unusual concentration of voids or imperfections within the wall of the containment shell and dome. The NRC also evaluated the likelihood of any void created by these containers, and its effect on the integrity of the containment. Any metallic container on the surface of concrete or dropping with the stream of fresh concrete would not survive the impact of concrete placement drop (5 f t); because the density (unit weight) of concrete in the containment structure is approximately 145 pounds per cubic foot; therefore, a can is likely to be flattened leaving no measurable void. The glass bottles, wnich are more likely to survive the impact, may remain intact creating the possibility of a void. However, any one bottle can only create approximately a 12 fluid ounce void at one place (approximately 0.00125 CFT). Assuming 500 containers embedded in the shell, and 40*; 

                                         21

of these (200 bottles) to be glass bottles, a total void of approximately 2.5 CFT is create.d The volume of this void approximately equals the volume of one pipe penetration of 12" diameter pipe through the containment wall. The conservativeness of design, properties of the concrete-mix used, and the response of the structure in the SIT provide additional confidence in the safety of containment. The inspector further noted that no foreign materials had been observed embedded in concrete in the containment wall or dome after form removal. The inspector, therefore, determined that the integrity of the Unit I containment structure is unimpaired. CONCLUSION This allegation can not be substantiated. The probability of a large void in the containment structure due to any adverse conditions, including cans or bottles, is very low due to quality control and supervisory activities during placement. A small void has been shown to be insignificant. The integrity of the structure and the lack of significant voids, are demonstrated by the successful structural integrity test.

. 

                                            22
   4. and 17. ALLEGATION
   4. Superficial patches were applied to major cracks in the containment
   (resulting from improperly cured cement ).
   17. There were cracks in the cement of the equipment vault which were leaking
  water and cracks in the inside containment dome between the inside and outside
  domes which were just patched over. It is my understanding that patching on
  hardened cement does not last very long.
  NRC UNDERSTANDING OF THE ALLEGATIONS
  4. The NRCs understanding of this allegation was that due to inadequate curing
  of concrete placed in the containment structure, cracks developed in the
  concrete and these cracks were only superficially patched. The repairs,
  therefore, were inadequate.
  17. This allegation refers to two related conditions: 1) there are cracks in
  concrete in the equipment vault and containment dome; and 2) water seeps
  through the cracks in the equipment vault.
 DETAILS
 The NRC has been aware of concrete cracks in structures at the Seabrook Station
  through its routine inspections and, in some cases, by allegations brought to
 NRCs attention by individuals. These cracks have been examined and evaluated
 by the NRC from the very early stages of construction. The licensee's actions
 to evaluate and repair cracks in concrete have also been reviewed and found
 adequate by the NRC.
 Cracks in concrete are a common phenomenon recognized and addressed by all
 concrete codes, standards, and specification. The mo;t common cause for
 surface cracks in concrete is due to shrinkage. The exaosed surface of any
 concrete structural member is not considered as part of the structural design
 basis of the member. The structural portions of a slab, beam or wall extends
 from the center of the main rebar on one face to the center of the main rebar
 at the opposite face. The additional thickness of the concrete is provided as
 a cover on all exposed faces of the member to provide corrosion protection to
 the reinforcing bars. Furthermore, in the design of concrete structures,
 concrete is not assumed to resist any tensile stress; it is only designed for
 compressive loads. Cracks, by definition, are separations of material caused
 by tensile stress (pulling apart). The tensile stress is resisted by the
 reinforcing bars in the member; therefore, superficial surface cracks in
 concrete are not a structural concern.
 Pursuant to the current allegation, the licensee again reviewed / investigated
 this concern through his Employee Allegation Resolution (EAR) program office.
 The EAR program investigation similarly concluded that concrete repairs on the
 project were performed properly and were verified to meet engineering
 requirements. No inadequacy in either the repair procedures or their
 implementation was identified.

                                                                                    <[                            x
                                                                                                                    s
                                                                                         (
                                                                                                    %
                                            23
                                                                                                      ,                   l
   Cracks in concrete and seepage of water through them have been identified,
   examined and evaluated by the NRC at this project in several structures. The
   results of these inspections are documented in NRC Inspection Reports (50-4,43/82-03,
   82-07, 84-12 and 86-43). The NRC Inspection Report number 82-03 documents'         "

' 

.
   leakage of water through concrete cracks in the diesel generator building;
   report number 82-07 documents water leakage in the RHR equipment vault; and
   report 84-12 documents extensive inspection and evaluation of concrete cracks
   and repairs in the waste processing building.
                                                                                                    ,
                                                                             t  s
                                                                                  *
  During this inspection, the inspector visually examined some concrete repairs
  performed to repair cracks in the containment wall and equipment vault for
  evidence of unacceptable workmanship or any degradation, i.e. excessive              3
   surface moisture, mineral deposits, joint cracks / shrinkage, and/or a hollow '                         -
  sound indicating separation of patches from sound concrete. The examined '                              ss
  repairs did not indicate any of these conditions. The inspector, therefore,                           *
                                                                                                             (
  concluded that the concrete repair procedure and repairs were acceptable.
  (Photo nos. 1 & 2)                                                     i
  TherepairofconcreteisdescribedintheAmericanConcreteInstitu[e's
  specification ACI 301-72, " Specification for Structural Concrete for Buildirgs",
  Section 9.0. The inspector reviewed pertinent documents and determited t     that,
  the repairs to ccncrete were acceptable. It met the requirements of the                                             '
                                                                                              '
  Architect-Engineer's (AE's) specification and the governing design and                                                -
  construction codes, i.e. ACI, and ASME, Section III, Division 2.
                                                                                                                    \
  CONCLUSION
                                                                                    s
  The allegation regarding cracks and water leakage was substantiated. Cracks
  in concrete are expected to occur and are permissible if they do not affect the                     -
  integ-ity of tne structure. The inspector concluded that the wall had hairlino '
  cracks, and some of them leaked groundwater through them. However, the repairs                               s
  effected were in accordance with applicable codes, accepted industry practice,                             '
  and approved construction techniques.
                                                                                                                [
  The allegation that repairs to cracks were " superficial" was not substantiated.                             *
                                                                                                                      '
  The effected repairs were technically adequate, and met the requirements of                                     ^
                                                                                                                      1;
  national codes and standards,
                                                                                                                i

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                       PHOTO NO.1, CONCRETE REPAIRS IN THE EQUIPMENT
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                                                                                                                                                                                                                     ._. -

                                             24
   5.   ALLEGATION
  " Steel rods designed to support the containment walls were improperly severed
  at the second story level of the reactor to simplify the construction process."
  NRC UNDERSTANDING OF THE ALLEGATION
  As understood by NRC, the allegation pertains to the containment structure
  reinforcing bars (rebars) that were cut at 2' above the final slab elevation of
  25'-0". These dowels represented the vertical rebar for the seven foot shield
  wall around the pressurizer and four steam generator openings.
  DETAILS
  The rebars in question were reinforcement for the shield wall around the steam
  generators and the pressurizer inside the containment. These walls are not
  structural members nor do they contribute to the safety function of containment
  structures. The walls are designed and constructed to provide radiation shielding
  to personnel inside the containment during outages and maintenance operations.
                                                                                     .
  The NRC was aware of rebar cutting to facilitate the setup of the concrete
  system during construction inside the containment. The licensee cut approxi-
  mately 1000 rebars at about 2' above the final slab elevation (25'). The
  approval of this cutting operation included the engineering decision to install
  cadweld splices at the cut dowels to extend the rebar curtain again at a later
 date. The NRC inspection report 80-13 documented this particular cutting of
  rebars described in the allegation. The above concerns were reviewed and evaluated
 by the
 NRC. The original design of the shield wall provided for lap splicing of rebar.
 The Architech-Engineer's Engineering Change Authorization (ECA 01/06198) replaced
 the lap splices with cadweld splices. The NRC examined the technical adequacy
 of this design change, and determined that the design change was acceptable,
 because cadweld splicing would return the cut dowels to a condition equal to
 the original design. "Cadweld" splices are stronger than the rebar itself.
 The NRC concluded that this design change does not affect the safety of
 containment.
 CONCLUSION
 The statement that the rebars were cut is substantiated. However, the cut
 dowels were spliced by the "cadneld" process which is an acceptable way of
 joining rebar.

2 

         _ , , _ _ _ _ _ _ _ . _ _ _ . . _ _  _       _ _ .       _

                                             25
 6. 49. and 50. ALLEGATION
 6. "The volume of the water from the fire sprinkler system is not adequate because-
 the pipes are partially clogged from sitting for several years with water in
 them. When the fire sprinkler system was tested, it was only checked for
 pressure not for volume."
 49.   " Pipes in the fire protecticn system were dangerously clogged because
 they sat for years with water in them.
 The pipes are so clogged that they could not carry enough water to put out the
 fire."
 50. "While performing preventive maintenance on the batteries to the emergency
 diesel pump, testing was being done on the system at the fire pump house. The
 testing was for sediment in the pipe.
 The testing involved tapping of the main pipe for the sprinkler system. The
 test ran for 24 hours a day.
 After the ground thawed out, the workers began to remove and replace the pipes
 coming out of the fire pump house.
 ...A  pipefitter showed me one of the elbows that had been removed. The elbow
 was approximately 12" and it contained sediment which was clogging the sprinkler
 system. This pipe was so clogged with hardened sediment that there remained a
 hole of only about 4 inches in diameter or 3/4 clogged."
 DETAILS
 The NRC inspector reviewed these three allegations which question the ability
 of the Fire Protection System to carry an adequate supply of water to the plant
 sprinkler systems.
 The inspector reviewed NRC inspection reports 50-443/85-06 and 50-443/86-32
 that are directed toward Fire Main Loop Installations and the Fire Protection /
 Prevention Program and noted that conditions that prevent delivery of water at
 sprinkler locations were not identified. During inspection 86-32, the insoector
 verified a surveillance and testi.y program for fire protection equipment was
 established. Procedures for traintenar.ce, inspection and testing of fire
 protection equipment were reviewed and found to be adequate.
 To establish the present cor.dition of the Fire Protection (FP) System, the inspector
 observed Fire Hydrant Testing, Sprinkler System Testing and examined screens as
 removed from two locations in the fire protection piping. Further, documentation of
 detailed cleaning packages for eleven Fire Protection Systems and the General
 Test Procedure GT-C-01, Revision 11 for flushing, and the YAEC-SQC

. ' 

 Inspection Report Q-02-03-01 for QC inspection of disassembly, cleaning and
 reassembly of fire pump house piping (Work Requests FP 841 and IIL #FP-1037)
 was reviewed. These reviews verified that quality control inspections and
 operational tests were established and performed.
               _

 _          .

! l 26 

   The NRC inspector interviewed the Insurance Representative to confirm that 100%

! of the Fire Protection System is as-built inspected and functionally tested for ' 

    insurance purposes in addition to previous plant startup, cleaning and
   surveillance testing. The functional testing of each fire sprinkler system and    I
   fire hydrant test is witnessed by the American Nuclear Insurers representative,
   the Director of Technical Review. The American Nuclear Insurers memorandum,

! dated October 22, 1986, as reviewed by the NRC, documents the preparation and i 

   execution of test procedures for Fire Protection Systems M, U, V, W, WA and WB.
   On November 4, 1986, the NRC observed the Insurance Tests for systems
   "P" and "I"; the Electrical Transformer 2" Drain Tests for UAT-1X-2B, GSU-1X-1B,
   RAT-1X-3A, UAT-1X-2A, UAT-1X-1C and GSU-IX-2A; and the Hydrant #1 (1-FP-V-0316)
   Flow Test. The expected pressure and water volume flow characteristics were       .
   achieved with no evidence of line blockage noted. The water flow that was         l

, visible during the inspector's test at the far end of sprinkler loops was ! slightly discolored but not indicative of significant sediment or pipe clogging. 

   Water flow from the Hydrant Test was measured to be a total of 1753 gallons per
   minute from two nozzles at 147 psi. The stream through a 1 3/4" nozzle reached
   beyond 200' from the nozzle. All water flowing from the hydrant was clear. An
   examination of the Fire Pump House two diesel engine driven pumps and one
   electric driven pump was made by the NRC inspector. The Fire Pump House is
   kept locked when not attended, critical valves are chained and locked in the
   required (open or closed) position.

! Chlorination of the Fire System Water which was initiated in October 1983 was 

   noted to be in progress. This chlorination was initiated as a measure to
   prevent microbiological induced corrosion (MIC) in the unlined portions of the
   FP system piping. In conjunction with the FP system chlorination, piping in
   the Fire Pump House was disassembled to remove MIC deposits and reassembled.
   Evidence of the success of the chlorination and pipe cleaning work was noted
   during observation of system test water clarity and the clean condition of
   system strainers at the input to the containment building FP system and at the
   most remote portion of the FP system piping, the Service Water Chlorination
   Building. The present water source for the Fire Protection System is the
   Seabrook area public water supply (potable water).
   The NRC inspector reviewed the following drawings and compared them to documen-
   tation of testing and flushing of the Fire Protection System.
         9763-F-604058 - Fire Pump House Piping Plan
         9763-F-604068 - Yard Fire Protection Piping Diagram
         9763-F-604146 - Fire Protection System Standpipe Diagrams
   In summary, the inspector found that some MIC had occurred in Fire Pump House
   piping, but corrosion products had been removed with further growth prevented
   by chlorination. As-built FP piping reviews and testing have confirmed sufficient
   flow volume and pressure capability to be present in the Fire Protection Piping
   Systems.

       [
                                        27

CONCLUSION Field observation of system testing and examination of a sample of system strainers by the inspector did not show a significant problem with sedi.sentation in Fire Protection (FP) piping system. Prior FP piping system problems (Fire Pamp House Microbiological Induced Corrosion (MIC)) have beer; identified and corrected by the licensee. Allegations number 6, 49 and 50 were not found to have plant safety-related significance. The FP piping outside the fire pump house is concrete lined piping and could give the impression of being partially clogged with hardened sediment. The allegations are not substar.tiated. 

                                    ,-                                     .-

                                  _ _ _ _ _ _ _ _ _ _ - _ _ _ _     _ _ _ - _ _ __

l 

                                                                28
 7.    ALLEGATION

f 

 "When the service water lines were tested, some of the inside cement coating
 broke off. This system cools essential parts of the plant and must be
 debris-free. The only parts of the lines replaced were the elbows where the
 greatest friction occurs."
 NRC UNDERSTANDING 0F THE ALLEGATION
 During interviews with the alleger and the Employees' Legal Project (ELP), no
 additional details were provided about the service water (SW) cement lined
 piping concerns. To establish the likelihood of a safety-related problem with
 SW piping, the typical SW cement lined piping installation and inspection
 sequence and the resolution of SW line coating deficiencies were reviewed.
 DETAILS
 The NRC has received allegations related to this subject in the past. The NRC
 performed a detailed inspection of the service water pipe concrete as detailed
 in Inspection Report No. 50-443/84-12. The following quotations from the NRC
 inspection outline the scope and findings relative to cement lined SW piping:
       "For cement-lined service water (SW) pipe, the staff reviewed records                         {
       and drawings, interviewed engineering and supervisory personnel and
       observed concrete lining inside piping. The staff entered the 42" pipe
       and visually inspected approximately 40 linear feet. The SW pipe is
       classified as safety-related ASME Class 3, Seismic.
       The inspection was conducted to determine the conditions and controls
       applicable to pipe cold springing, to establish if the lining cracked
       during pipe fitup or welding, and how cracking woulc be identified such
       that repair could be initiated. Interviews and records review were
       concentrated toward service water piping in the area between the diesel
       generator building and the waste processing building. The staff visually
       inspected accessible interior and exterior portions of the SW pipe in
       several areas...
      The staff found that it is unlikely that the cement lining would have
      been subjected to sufficient forces to cause significant cracking by cold
       springing the pipe during installation.                     Should cracking by this mechanism
       have occurred, it would have been identified during work operations
       including QC inspections conducted in the pipe after welding and those
      cracks exceeding the 1/32" criteria would be repaired.
      The inspector entered the 42 inch diameter line 2-SW-1825 thru the opening
       for SW valve V-46 and observed the cement lining and junctions at weld
       seams for approximately 40 feet. The lining did contain hairline cracks
      although these were of a width much less than the 1/32" acceptance criteria
       in paragraph 3.4.3.10.6 of Specification 248-2. The lining at weld joints
      was noted to be smooth and merged with the pipe lining."
                       _ _ _ _

                                            29
The NRC inspector, during this current inspection (443/86-52), to resolve
allegation number 7, reviewed the following documentation regarding the service
water piping lining problems, corrective actions and continuing inspection
programs.
      --CDR 85-00-13 dated 8/20/85 - SW polyurethane insert detachment
      -- PSNH Letter SBN-1198, dated September 18,1986 " Service Water System
          Lining Inspection"
     -- PSNH Letter SBN-1001, dated April 10,1986 " Final 10CFR50.55(e) Report:
          Service Water System Spool Linings, Pipe Inserts and Valve Liner / Seats
          (COR 85-00-13)"
     -- PSNH Letter SBN-874, dated September 18, 1985, " Interim
          10CFR50.55(e) Report: Service Water System Spool Linings,
          Pipe Inserts and Valve Liner / Seats", J. DeVincentis to
          R. W. Starostecki
     -- PSNH Letter SBN-923, dated January 13, 1986, " Interim
          10CFR50.55(e) Report: Service Water System Spool Linings,
          Pipe Inserts and Valve Liner / Seats", J. DeVincentis to
          R. W. Starostecki
     -- PSNH Memorandum dated 3/27/85 " Summary of Service Water Cement
          Lined Piping Concerns and IRT Recommendations"
     -- NCR 7035-4481

The NRC inspector reviewed the licensee memorandum, dated 3/27/85, which states that the STD operation of the Service Water System to date has included a pre-fill inspection, filling, flushing and 200 as well as 700 hr. teardowns for internal visual inspections. Upon initial operation, pre-heat-exchanger strainer debris contained considerable grouting compound fragments as well as other miscellaneous material. Recent debris still contains grouting compound fragments but in negligible amounts. NRC inspection was also directed toward the lined service water pipe system during observations and reviews made during resolution of CDR 85-00-13. This CDR is closed in NRC inspection report 50-443/86-47. The NRC inspector reviewed licensee status reports on the implementation of corrective action in progress and periodically checked field rework activities including grit blasting, pipe and valve relining, and QC inspection of Belzona lining thicknesses by spark-testing techniques. YAEC QA surveillance inspection reports of the SW modifications were reviewed to confirm compliance to UE&C procedure FPP-13, " Application of Belzona Coatings to Interior Surfaces". The inspector also reviewed an Employee Allegation Resolution (EAR) file which addressed a concern regarding Belzona material curing times and the minimum purge time between metal washings after grit blasting. 

                                            30
 Additionally, an inspector witnessed reinspections in March and September, 1986
 of the Belzona liner material after operation of the SW system. At both times,
 the piping in the proximity of service water valve SW-V-15 was checked because
 of the heavy cavitation expected downstream of that valve due to the design
  flow condition during periods of SW dump to the cooling tower basin. This
 particular operation is needed for basin deicing in the winter months. The
  inspector noted no evidence of Belzona lining deterioration, even where lining
 pits had been repaired during earlier rework activities.
 In letters to Region I dated September 18 and October 15, 1986, the licensee
 addressed the recent SW lining reinspection and its results and committed to
 another internal inspection after the first refueling outage. The inspector
 evaluated all licensee rework, analyses, and reinspections and verified the
 conduct of appropriate corrective action with adequate QA/QC coverage.
 The NRC inspector by review of the existing NRC inspection reports and licensee
 documentation established that the primary corrective action for service water
 piping internal coating problems was to repair or replace the coating. The
 above documentation indicates that while problems were identified with portions
 of the concrete and polyurethane lining of SW piping, these problems were
 evaluated and corrective actions implemented.
 CONCLUSION
 The portion of the allegation that some concrete coating was found detached
 from the SW piping during testing was substantiated. This condition and
 related SW pipe lining problems have been previously identified and resolved by
 the licensee anc reviewed by the NRC. The presence of safety related plant
 problems as implied by the balance of the allegation was not substantiated.
                                                                                   l
                                                                                   1

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

                                          31
                                                                                 :
                                                                                 l
8. ALLEGATION
"When the Service Water System was turned on for testing a valve was accidently_
left closed. A geyser of 750,000 gallons of salt water flooded the equipment
vault building."
NRC UNDERSTANDING OF THE ALLEGATIONS
What was the source, magnitude and effect of the service water (SW) discharge
on the contents of the equipment vault building and were steps taken to
examine affected components, remove salt water deposits and to prevent
recurrence.                                                                      ;
DETAILS

The station Incit.ent Report (SIR) 0009, dated 6/27/86, states "On 5-27-86 

service watar was discharged from the SW overflow line, flooding the outside
area between the PAB Building and D/G Building. Some of the seawater was

washed ov r into the North Vault stairwell wetting all piping, instrumentation,  ! electrical equipment, conduit, insulation, etc. with saltwater. Reference ' 

attached sheets for incident report, affected areas and corrective actions

taken." The SIR 0009 time log indicates the SW overflow alarm initiated at 0932 hours and both service water pumps were shut down at 0936 hours for an overflow duration pump time of four minutes. The licensee, under Work Request 86-002088 provided for investigation and identification of all items wetted by seawater in the North Vault Building. Corrective actions included washdown with demineralized water and verification of effectiveness by chemical analysis. Electrical components and instrumentation were included in the post cleanup inspection. Refer to photograph number 3 showing the SW overflow outside the PAB. The above incident was caused by the outematic alignment of Service Water (SW) during an abnormal operational alignment. As a result of this and a previous incident, a logic change was made to the valve control circuit to prevent recurrence. During this incident, seawater entered the North equipment vault. All wetted insulation was removed from equipment and piping, the effected equipment and piping was washed with demineralized water and a chloride swipe test was performed. All wetted insulation was either washed and swiped, as stated at ce, or replaced. All electrical equipment was dried and tested to ensure proper operation. The NRC inspector evaluated the event duration, pump capability, overflow location and area drains to establish the magnitude of water flow into the equipment vault. 

                              ..    . .                                  _  _

                                          32
The SW overflow event of 5/27/86 with two 10,500 gpm SW pumps operating in the
overflow mode for four minutes is estimated to be 84,000 gallons of discharge.

The SW overflow is located outside of the Primary Auxiliary Building and away 

from the equipment vault building entrance. A 32" x 50" rectangular drain is
located between the SW overflow and the doors leading to the equipment vault

door. Due to the distance from the SW overflow to the equipment vault door, the unimpeded flow route away from ground drains and elevation differences the 

inspector concluded that only a small portion of the SW overflow water would

have entered the equipment vault. 

                                                                               .

The inspector reviewed documentation of the SW overflow event including Work Order 86-W-002088 verifying that cleanup activities and subsequent inspections had been performed. The NRC inspector examined components including, piping and wiring in the Equipment Vault Building for evidence of salt deposits and corrosion effects from residual saltwater. No concerns were identified. One trace of white substance that appeared to be leachate from concrete at elevation minus 61 was submitted for chemical analysis. This substance was confirmed to be boric acid. The chloride salt content of this material was less than 0.01%, and is considered to not be an indication of seawater presence in the building. In summary, while the Service Water System overflow line was shown to have flooded the area outside the equipment vault, only a minor amount of saltwater compared to the stated volume of 750,000 gallons entered the equipment vault. Corrective action including washdown, examination and testing of components was controlled by work order and involved engineering, operations and maintenance. CONCLUSION The portion of the allegation indicating that the service water overflow did release saltwater during testing on 5-27-86 was substantiated. However, the quantity of water passing through the overflow was estimated by the NRC inspector to be significantly less than 750,000 gallons. The NRC inspection of the affected area did not reveal any evidence of water damage or degraded equipment. 

  ._ _ -__                                 . .. - .           _                        _                _ _ _ _                    . _ _ .     . _ _ _ _ _ _ _ _ _ _ _ _ _ _
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                                                       PHOTO NO. 3, VIEW OF SERVICE WATER

' 

                                                       OVERFLOW DISCHARGE PIPE AND SUR-
                                                       ROUNDING AREA (REG. ALLEGATION NO.
                                                       ROUNDING AREA (REF. ALLEGATION NO. 8)
  . . - .  . . . - _ . _ - . . _ _ _ - - -                                        _        ..

                                             33
  9. ALLEGATION
  " Paint is crucial to the plants safe operation in keeping dust down and so
  radiation can be easily washed away. The paint on the floor of the containment
  is peeling".
  NRC UNDERSTANDING OF THE ALLEGATION
 As understood by NRC, this allegation was a concern with bubbling and peeling
  of paint on the containment building floor.
 DETAILS
 The NRC inspector examined all floor paint from elevation - 25' to +25', and
 did not find any bubbling or peeling of paint anywhere on the containment
  floor. The inspector, however, observed that in some areas of the floor on
 elevation +25' original paint had been reworked. (Photo No. 4)
 Paint peeling can be caused either by surface moisture or lack of adhesion; the
 most common cause of paint bubbling is moisture on the substrate. The lack of
 adhesion may stem from many causes, e.g. chemical incompatibility, insufficiently
 cleaned surfaces and/or poor paint application practices. However, any of these
 problems are very quick to appear on the painted surface during the first few
 months after the application. The inspector also determined that there were
 some problems with paint adhesion on the containment floor which were identified,
 evaluated and dispositioned by engineering. This process is documented on
 Nonconformance Reports (NCR) 59/5463A and 59/5463B. A test program of the
 "Elcometer Adhesion Test" for the suspect area was implemented, and a repair
 procedure on the basis of the test results was developed. The procedure included
 removal of questionable coated surfaces, rotopeening the exposed concrete and
 reapplication of new sealer, and then coat the area with approved paint.

! The NRC inspector visually examined the repaired areas to determine any 

 evidence of coating failure, i.e. peeling, flaking and/or bubbling of paint in
 these areas. There was no visual evidence of coating failure in either the
 repaired areas or the areas with original coatings. The original coating
 application and the repaired areas appeared adequate.     No other problem of
 bubbling or peeling of paint inside the containment has been reported after the
 repairs were effected in the summer of 1986.
 The NRC inspector reviewed quality control records, test data, and nonconfor-
 mance reports related to coating inspections. During this review, the inspector
 noted that approximately 4% of the total coatings inside containment deviated
 from one or more of the acceptance criteria:
       -
             Surface preparation could not meet the standards of class 1
             preparation due to inaccessibility of the area.
       -
             Small equipment supplied by other vendors that came with
             coatings /pa'nts applied from the suppliers.
       -
             Installed piping in component cooling water system.
                                                                                   i
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                                                                                   1
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                                                                  _
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                                                                                           !

, 

                                            34
 Any area determined to fall within the above categories was identified and
  inventoried on a log maintained by QC titled as "The Unqualified Coatings Log".
 The licensee is currently evaluating the effect of these deviations from the
 coating criteria. The resolution will be reviewed by the NRC.
 The inspector also reviewed NRC independent examination and measurements of
 coatings inside the containment performed in August, 1984. This confirmatory
 inspection was performed with a Zormco 2002 paint thickness gauge, and dry film
 thickness (DFT) was ineasured in addition to a general visual examination for
 workmanship. This examination indicated that, on the average, the DFT was in
 the 15 to 25 MILS range, and the workmanship was adequate (IR 50-443/84-12).
 Furthermore, the painting and coating inside the containment is not safety
 related to the extent that it does not contribute to the safe operation or safe
 shutdown of the reactor. The only safety implication of the paint is that
 peeling and flaking paint, if extensive, could clog the sump grating, thereby
 affecting the suction of the containment spray recirculation. The main purpose
 of the paint is to make decontamination easier in case of any radioactive
 spill.
 CONCLUSION
 The allegation is not substantiated. No bubbling and/or peeling of floor paint
 in the reactor building is evident at the present time.            Some paint peeling had
 occurred in the past, but adequate repairs have been accomplished.
                                                          _ _ _ _ _                      _

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                     PHOTO NO.4, EXAMPLEOF PAINTTOUCH-
                     UP ( REF. ALLEGATION NO. 9)

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                                   PHOTO NO.4, EXAMPLE OF PAINTTOUCH-
                                   UP ( REF. ALLEGATION NO. 9)

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

                                           35

10. AND 35. ALLEGATIONS 10. No training records exist before April, 1985, preventing assessment or verification of training and orientation process. 35. People being trained, retrained and left untrained because of inadequate tracking systems. NRC UNDERSTANDING OF THE ALLEGATIONS 10. No training records exist prior to April 1985, preventing assessment a' verification of training and orientation processes. 35. Some employees were trained, some were given the same training more than once and some employees did not have any training. DETAILS The NRC inspector selected and reviewed training records generated by Pullman Power Corporation, Fischbach-Boulos-Manzi-NH, and Perini Power Constructors, Inc. covering the period from February 1979 through November 1982. These records were generated by the respective companies and the records reviewed covered such topics as Superintendents Indoctrination, Quality Assurance Manual Review, Project Rules, Hilti Installation, Inspector Indoctrination and Receiving Inspection. The inspector determined that for the balance of plant the contractors were not required to retain training records for their employees. Contracts which included installation of balance of plant equipment were the turbine generator by General Electric, the intake and discharge tunnels by Morrison-Knudsen, and the main condenser by Union Boiler. In the case of these contractors, if qualifications and training were required to perform certain operations, e.g. welding or nondestructive examinations, such qualifications were established and documented and records are available. Yankee Nuclear Services Division conducted eleven audits that included training on seven contractors during the period from May 1978 to December 1981. In addition United Engineers and Constructors (UE&C), Reliability and Quality Assurance Department conducted ten internal audits on UE&C training activities during the period from July 1974 to October 1985. No significant oeficiencies were found during these audits. The NRC inspected training and qualification programs as a routine part of the inspection program during tne construction phase. Typical reports that discuss inspection of training are 50-443/79-10, 79-03, 82-06 and 84-16; other reports are listed in Table 6. The inspection of training programs was supplemented by direct interviews of craftsmen, engineers and quality assurance personnel to determine their knowledge and understanding of the technical requirements. The quality of the training programs was ultimately reflected in the quality of the equipment installations. The quality of equipment installation was extensively examined by the NRC. 

        _            _    __

                                                   .
                                           36

The Construction Site Training Group was established in April 1984 to coordinate 

site training previously performed by each contractor. This Group was subsequently

transferred to the General and Speciality Training Department in April 1985. Records generated by the contractors have been stored in the document control center. In the existing system, tracking is initiated either when an employee is hired or when the individual receives General Employee Training (GET) required for access to the protected area. In addition, all station staff employees are requested to verify their training record annually. The inspector determined that some employees records are not maintained in this system. These employees are those that were working at the site prior to establishment of the present systems of. record tracking and have not received GET. CONCLUSION The allegation that training records did not exist before April 1985 was not substantiated. A review of existing files confirmed that training racords do exist for the period before April 1985. In those cases where an Omployee's position requires admission to the protected area or qualificscion to specific requirements, the records are stored in the licensee's document control system. The adequacy of the tracking system for control of training and qualification for safety related activities was inspected throughout construction by the NRC as exemplified in the details of allegations 12 and 27. The inspector determined that training and qualification records exist for personnel who worked on safety related contracts prior to April 1985. 

                                                                                   i
                         _
                             --

                                           37                                    ,
                                                                                 !
                                                                                 !
11. ALLEGATION

" Extensive written procedures and instructions were used as a primary training tool, although some workers were illiterate and many foreign engineers were not 

fluent in English."

NRC UNDERSTANDING OF THE ALLEGATION 1. Those individuals who have difficulty in reading and comprehension were 

      unable to absorb the training when written material was used as a training
      aid.

2. Foreign engineers not fluent in English had difficulty with training when 

     written procedures were used as training aids.

DETAILS The inspector discussed the hiring practices for United Engineers and Constructors with the site personnel manager who had been at the construction site since 1976. The personnel manager described the system used to screen professional engineers which included interviews with the personnel department, departmental and supervisory staff; completion of application forms, and verification of education. The personnel manager confirmed that foreign born professionals were employed but believed the employment process would have screened out persons with significant fluency problems. Further, the employer utilizes an employee performance appraisal system which would also identify unacceptable performance. During construction, employees committing repetitive errors are soon singled out and some form of corrective action applied. If the communication problem was severe, it would be reflected in unacceptable work and be detected by the multiple checks and counterchecks. Nonprofessional employees were required to complete an application and interview with supervision to assure their acceptability. NRC inspectors interviewed both professional and craft personnel during the routine course of inspections including foreign nationals. The interviews were focused on the individuals understanding and knowledge of the technical content of the procedures, specifications and drawings utilized for construction. Thirteen examples of NRC inspection reports that discuss interviews of engineer and crafts personnel are listed in Table 1 of section 1. No instances of fluency or literacy problems were identified. CONCLUSION This allegation was not substantiated. 

                          _ __   .

                                          38
12. and 27. ALLEGATION
12. " Workers with no previous experience were trained "on the spot" in
delicate techniques to perform critical welding (and other reports allege that
although all welds should be tested, many are inaccessible)."
27.  " Improperly trained welders welding on the job site."
NRC UNDERSTANDING OF TS ALLEGATIONS
1.  Welders with minimum or no experience were hired to perform welding on
    safety-related systems.

2. Subsequent to the welding operation but prior to testing, the location of 

    the joint may become inaccessible due to the installation of other equipment.

DETAILS The NRC inspector reviewed the Pullman Power Products Procedure II-8 for Welder Performance Qualification and the General Welding Standard GWS-III to confirm that Welder Qualifications are required to be done per the ASME Code Section IX for piping and pipe supports and that limited access welds are required to be evaluated to determine if special methods are required to perform the weld. The inspector determined that a training program was established by the licensee in cooperation with Local 131 of the United Association of Plumbers and Steamfitters Union. This training was carried out off site. Upon completion of the training, individuals were brought to the site for familiarization and qualification testing. During this qualification and testing period, the worker was given time to become familiar with the specific equipment to be used for the qualification test and then required to weld the test coupon. This test coupon welding included requirements for the materials used, electrodes used, position of the coupon and other variables required by the codes and specifications. In cases where the individual would be required to make joints with limited access, a test with limited access was performed. Also, when a weld would become inaccessible due to subsequent installation of other equipment, inspections were scheduled and performed prior to the joint becoming inaccessible. The welder training and qualification activity at Seabrook has been reviewed numerous times during construction. The stringent nature of the qualification process is indicated by a Qualification Test fail rate of approximately 70's. As an example, inspection results as reported in NRC IR 50-443/82-06 in the area of Welder Training and Qualification are quoted below: 

                                -         .-. .

                                                                                   l
                                          39
"6.3.1 aW lder Training and Performance Qualification
     The NRC Inspector reviewed the welder performance procedures used by P-H
      for welders qualified on sit.e and off-site to insure that welding is
     accomplished by qualified personnel. A detailed analysis was made of the
     controls exercised in the maintenance of identification during welding
     and evaluation of the test assemblies. The NRC Inspector attended a
     typical indoctrination course where a recently qualified welder is
      instructed to understand those portions of the Field Weld Process Sheet
     and the Weld Rod Stores Requisition applicable to the welder. The welder
     is instructed in the Pullman Power Products PH001, dated 12/15/81,
     " Instructions for Welders."
     A review was made of the P-H 6/21/82 Qualified Welder List which
      indicated that 95 of the current 364 welders were qualified by welding
     test assemblies off-site under P-H QC Supervision. All, except 3, welded
     P-H Standard Welding Test SWT #1. Welders qualified off-site were
     trained and tested at UA Welding Schools at Seabrook, N.H.; Cleveland,
     Ohio; Terre Haute, Indiana; or Pasco, Washington.
     All of the Seabrook, N.H., test assemblies were radiographed by P-H at
     the Seabrook Site. The disposition sheets for the RT are maintained with
     the ASME PQR document.
     Currently (since 6/82), welders qualified off site are photographed by
     the P-H QC Welding Inspector supervising the welding and the photographs
     are referred to at time of employment at the Seabroo. .~1te."

Welders are given indoctrination on the site's General Welding Specifications as well as Welding Procedure Specifications. The WPS is the procedure to which the welder will test. Each welder testing signs an affidavit that he has read and understands the GWS and WPS. These affidavits are maintained in each welder's qualification record. When in the field, each time a welder draws weld rod, he is issued a rod can. On the can is a copy of the heat sheet which tells him the rod size, heat settings and other specific information pertinent to the proper welding technique. Other information or questions a welder may have are directed to the foreman and welding supervisor in the area. In excess of twenty six NRC inspections have included attention toward welding process application in the nuclear and structural welding areas. A practice of "on the spot" training of inexperienced workers to perform critical welding was not identified. These NRC inspections include 78-07, 78-08, 78-09, 80-03, 80-04, 80-08, 80-11, 81-08, 81-12, 81-13, 82-03, 82-06, 82-10, 83-01, 83-02, 83-06, 83-07, 83-09, 83-13, 83-17, 83-22, 84-07, 84-12, 84-16, 84-17 and 85-19. 

                                                                           . _ _ _

                                                                                          _         _
                                                                 40
 The NRC Nondestructive Testing (NDE) Van has performed over 592 independent
 examinations of welds at Seabrook on several occasions including inspections
 82-06, 84-12 and 85-19. Approximately 145 pipe welds were selected by the NRC
 and examined by radiographic (RT), ultrasonic (UT), magnetic particle (MT) or
 liquid penetrant testing (PT) methods. During these inspections and the
 construction assessment team inspection (84-07), numerous welds were selected
 for visual examination. Also, radiographs taken by the licensee were reviewed
 and compared to NRC radiographs.                         Interviews have been performed with craft
 welders and fitters in the field and at welder qualification stations during
 many NRC inspections relating to piping and welding. Those workmen and foremen
 interviewed expressed an understanding of the requirements for proper component                      I
 fitup, welding, use of work related document, and recordkeeping as necessary                         l
 for completion of the work task in progress.                                                         l
 The quality level of welding ext.nined and testing by the NRC during field
 inspections indicates the selection and use of properly trained and qualified
 welders. Except where prevented by design constraints and properly documented,
 welds picked for independent NRC examination have been found accessible.
 In the area of limited access welds, the inspector reviewed the UE&C

, 

 memorandum (SB-LD-F-4643) dated September 29, 1986.                        This memorandum
 summarizes the welder selection process and welder training guidelines where
 conditions require special training of supplemental nondestructive examination
 of a weld.
 On the topic of having welds made inaccessible prior to testing, the same
 memorandum provides the result of the UE&C evaluation regarding testing of
 inaccessible welds. This evaluation found that ASME Section III pipe welds
 have all been inspected and documented in accordance witn the requirements of
 the code. However, the memorandum states:
       "In the conventional portion of the plant there have been rare instances
       where embedded or buried piping lacked a welding program's documented
       evidence of a visual weld inspection but was deemed acceptable due to the
       test programs' Hydrostatic Test Report. The Hydrostatic Test Report
       documented the pressure test for these welds during which each weld is
       visually examined. The Hydrostatic Test Report is the only documentation

f required by the Code which governs fabrication and construction." i 

 The American Society of Mechanical Engineers Code (ASME) Section III is a
 required national design, fabrication and erection code for pressure vessels
 and piping used in nuclear power plants. Part of the requirements that must
 be met by the licensee is the inspection and testing of welds. This activity
 is monitored by a third party, independent inspector who must sign off the
 nuclear power systems before they have the code stamp affixed. Each weld
 within a piping system must have all required 2xaminations and tests before the
 code stamp is applied. Therefore, welds which are made inaccessible due the
 advance of construction are closely tracked to assure they meet the code
 program. The NRC reviewed this program, an example is presented in Inspection
 Report 50-443/85-29, and found it acceptable.

< 

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

                                            41
   Further, the ASME Code, Section XI, for in-service inspection, also required
   by the NRC, specifies that, where possible, welds be made accessible for in
   service examinations.

, 

   In summary, the present and past NRC inspections have established the presence
   of adequate welder training and qualification programs at the Seabrook site and
   the effectiveness of welds qualification is evidenced by the quality and
   acceptability of the welds.
   CONCLUSION
   The allegation was not substantiated.
                                                                                                                        .

4 , v 

 ~                               __ -_ , _     , _ , _ . . . , _ , _ , , _ _ _ . _ _ _ _ . _ _.___._________,.m .,, , ,

                                             42
 13. and 21. ALLEGATIONS
 13. On-the job drug and alcohol abuse of epidemic proportions was reported by
contact after contact.       Cocaine was cited as the drug of choice.
21. Any kind of drug there is was available there.             People did cocaine on the
cable trays.
ALLEGATION AS UNDERST0OD BY THE NRC
Professional and nonprofessional workers extensively used drugs at the plant
site.

DETAILS The inspectors interviewed Seabrook managers, reviewed records related to personnel actions / complaints and inspected plant areas to verify drug / alcohol program commitments were met. The Seabrook Station contractor has had a policy 

since early 1976 that prohibited the use of drugs and alcohol on the site. This

policy was documented in job rules and promulgated to the construction forces 

in diverse and multiple means to assure the forces were aware of the prohibition.

New employees received orientation in the site job rules which included the drug / alcohol policy. The policy was posted at the " brass alley" entry ways to site areas, and notices of drug / alcohol policy were distributed in pay checks. The right of Seabrook to search for alcohol, drugs, and firearms was visibly painted in large letters on billboards at the site boundary roadways. These were observed during NRC inspections. Early preventive measures by Seabrook to detect the use of alcohol and drugs on site included supervisory controls and quality assurance audits. These were supplemented later by undercover surveillance in cooperation with the New Hampshire State Police and the Rockingham County Sheriff's Department in 1979. Although lunch box searches (openings) of construction personnel were made at the brass alley routinely, these were intensified in the form of personnel and vehicle searches beginning in 1980. To provide an anonymous, harrassment-free environment to encourage construction / plant staff to report drug / alcohol abuse and other safety concerns the licensee established the Employee Allegations Resolution (EAR) program in 1985. This was an independent contractor run program with confidentiality for all parti- cipants. All allegations were independently investigated and resolved; protection of the individual's identity was preserved. The licensee's programs did ioentify some drug activities on site, one of which resulted in 12 laborers and other non-nuclear craftsmen being indicted for drug sale, use and possesion in 1980. Another example of the effectiveness of the substance abuse program was the use of trained dogs to detect drugs. The use of dogs to sniff out drugs was introduced in 1981. The patrol " sniffer" dogs did identify a car with drug remains (marijuana butts) in it parked in the construction parking lot in December 1982. The employee was discharged. 

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

                                           43
The NRC has over the years observed work habits on the construction site which
included worker performance. In addition to observation of work activities,
NRC inspectors interviewed craft workers during onsite inspection and observed
their condition in addition to checking their knowledge of procedures and work
activities. The NRC, when it becomes avtare of undesirable practices such as
drug / alcohol, notified the industry via an Information Notice. In 1982, the
NRC issued IE Information Notice 82-05: Increasing Frequency of Drug-Related
Incidents. This notice was sent to all construction permit holders and
licensees including Seabrook, and provided early notification of NRC ccncern
about drug use. Additionally, in 1982, the NRC published NUREG-0903 titled
Survey of Indu:try and Government Programs To Combat Drug and Alcohol Abuse.

This documents the results of an NRC initiative to assess industry and govern- ment programs related to drug and alcohol abuse. It also discusses the early NRC approach (1982) to establishment of an NRC fitness for duty rule. The publication of NUREG/CR-3196, titled Drug and Alcohol Abuse: The Bases for Employee Assistance Programs in the Nuclear Utility Industry, in 1983 further documents the NRC concern about drug / alcohol abuse and provides data useful for regulatory planning and rule making. More recently, the NRC has promoted a vigorous industry wide fitness-for-duty program which is being implemented by the nuclear utilities. The NRC has interviewed craft and q-c inspectors in the field environment at Seabrook extensively during the Construction of the plant. These interviews were conducted on all shifts at various times to assure a cross section of workers were represented. These interviews provided the opportunity for NRC inspectors to observe worker behavior first hand and identify any aberrant actions such as that induced by alcoholic or drug substances. NRC inspections are unannounced and performed in a random manner throughout the plant which further assures the probability of detecting unauthorized substance use. Many recorded examples of these interviews are documented in Table 1 of this report. Continued use of unauthorized substances which impair an individuals ability to perform would result in unsatisfactory and rejected work. Repetitive nonconformances are documented in the quality assurance nonconformance reporting system (QA NCR). The NRC inspection program reviews the NCR and QA programs specifically for this aspect to detect repetitive NCRs and trends of poor workmanship and requires licensee corrective action which could be retraining of the individual or discharge / removal from the job. The NRC has periodically reviewed Seabrook actions in relation to their drug / alcohol program. This included an inspection of the Seabrook undercover drug surveillance and is reported in NRC Inspection Report 50-443/80-01, a portion of which is reproduced below: 

                                                       _            _-   _       _ _ _

                                           44
      " Preliminary Inquiry - Seabrook Drug Indictments
      During this inspectior., the inspector conducted inquiries into any impact
      the recent arrests of construction workers on drug charges may have had
      on safety-related construction at Seabrook. He interviewed management
      personnel and the foremen of twelve of the indicted individuals and
      examined Project Rule 7, the violation of which led to the discharge of
      these individuals.
      Nine of these twelve workers were employed as laborers whose work function
      could be categorized as that of a " tender", performing various tasks under
      the direction of or meeting the supply needs of other craftsmen (e.g. -
      carpenters or masons). The other three workers were carpenters involved
      in the fabrication and erection of concrete formwork. In either case, all
      of the work performed by these individuals had been checked both in
      process and at subsequent construction stages by supervisory and related
     craft personnel (e.g. - surveyors), and any safety-related work had
     additionally received quality assurance inspection. The interviews with
      the foremen disclosed no specific problems regarding the work performance
     of any of these twelve individuals.
     The inspector also verified that employment at Seabrook Station for the
      subjeJ. personnel had been terminated as of either January 10 or 11,1980
     and that records indicate the only work performed for their employer,
     Perini Power Constructors, at Seabrook was correctly represented by their
     stated occupations. Various licensee and contractor management personnel
     were interviewed concerning the events surrounding these indictments and
     the impact upon construction activities.
     No items of noncompliance or concerns about the quality of construction,
     as related to this drug inquiry, were identified. This finding was
     substantiated by separate, but complementary inquiry conducted by an NRC
     investigation specialist, the results of which are detailed below..."

As a result of the NRC report described previously (NUREG-0903) and in conjunction with IN 82-05, the NRC conducted an on-site survey of the Seabrook drug and alcohol abuse programs.en March 9, 1983 at the site. In 1984 a private organization titled Nuclear Safety Hotline (NSH) distributed a flyer in the local Seabrook area requesting that any Seabrook employee who had a concern about safety, or ary issues that could affect safety, at Seabrook should contact them. They would assure that the issue was presented to the proper authorities and that the individual's identity would be protected. The NRC promptly notified the NSH by letter, dated July 5,1984, that the NRC had a responsibility in the resolution of issues and specifically requested that all safety related issues be forwarded to NRC for evaluation for their safety significance. No reply was received from this 1984 request. 

                                          45

The NRC inspectors during this inspection interviewed the manager and staff of 

the independent-contractor run EAR program and reviewed records and files EAR

Drug Investigation. The program appears to be functioning adequately and 

investigations are sufficiently in depth to assure resolution of issues.

Selected personnel files, representing examples of persons accused of 

substance abuse, were reviewed by the NRC inspector to determine the nature of
investigations performed by the licensee. Discussions were held with manage-

ment-supervisory staff regarding the decision process used to determine the impact on inspection, equipment installation or design and the need for rework or reinspection. The basic policy was that if the accused person's work was independently reviewed, inspected or reinspected then no further actions were warranted. If, however, the accused person's work was not independently reviewed or inspected during the normal work process, then reinspection / review would be directed. Efforts to gather more specific information from the allegers regarding any safety impact on the construction of the facility were unsuccessful. Because of the quality assurance program, NRC inspections and outside agency audits and inspections, there is a high degree of assurance that safety significant equipment deficiencies do not exist at the Seabrook Station. CONCLUSION This allegation, as understood by the NRC, was not substantiated to the degree stated by alleger. However, there was some indication of substance abuse, and the licensee enhanced his basic drug and alcohol abuse control program to identify and mir.imize the effects of substance abuse. There are no identified equipment deficiencies resulting from this allegation. The licensee took appropriate correction actions where instances of drug or alcohol abuse were identified. Both the licensee and the NRC recognized the potential threat cause by employees involved in substance abuse and took steps to alert management, contractors and individuals. 

                                                                                  l
                                                                                  l
                                                                                  1
                                                                                  l

                                          46
14. 30. 31. and 60. ALLEGATIONS
14.   Engineers and tradespeople routinely worked 18 to 20 hour shifts.
30. Have worked 18 to 20 hour shifts.
31. Have seen engineers, technicians, and craftspeople working 18 to 20 hour
      shifts.
60. Work on site was chronically behind schedule, resulting in management
     depending on extensive overtime to meet deadlines.

NRC UNDERSTANDING OF THE ALLEGATIONS All of the foregoing allegations imply that the routine use of overtime was not conducive to quality work. The allegers could not give any names, places er dates to which this overtime work referred. More importantly, they could not provide any instances were this practice resulted in improper work or adverse equipment or safety conditions. DETAILS All of the major subcontractors have demobilized and left the site. It appears that the allegations were made for the construction forces and not the current operating staff. Attempts to establish the amounts of overtime for individual contractors were unsuccessful, but a review of the overtime records for the current startup engineering group confirms that they have employed significant use of overtime for some people. However, the extensive use of overtime, in itself, does not mean that improper work was performed. Interviews with the allegers did not reveal any situations where specific equipment or processes were identified as suffering from this practice. The overtime for the plant operating staff is limited by the facility Technical Specification, paragraph 6.2.2.e which invokes Generic Letter No. 82-12. The Generic Letter prescribes the amount of overtime that an operator can incur in any 24, 48 and 72 hour period. CONCLUSION The allegation was substantiated from the fact that existing records for certain activities do indicate the use of extensive overtime. However, it could not be establishec that this resulted in any improper work or degraded equipment. 

                                                       47
     15. ALLEGATION
     "The company has been having some painters do quality control checks on other
     painters' work.    By federal law, those who do quality control must be organiza-
     tionally independent; members of the same union checking each others work does
     not meet this criteria."
     NRC UNDERSTANDING OF THE ALLEGATION
     As understood by the NRC, the alleger is concerned about the independence of
     painting monitors, painters who reviewed and examined other painters work after
     repair / touch-up painting on steel components and supports.
     DETAILS
     The NRC inspector reviewed the licensee's quality assurance program as applied to the
     painting / coating activities. The inspector determined that sufficient controls
    existed to assure conformance to the technical requirement specified in the
     coating specification and procedures. In section 6.0 of procedures IP-103,
    Structural Steel Coating, and IP-104, for concrete coatings detailed inspection
    and surveillance requirements were established. The inspector found that the
     requirements were clearly stated, and were adequate to assure painting / coating
    quality commensurate with its safety significance. Criterion II of 10 CFR 50,
    Appendix B requires:      "The quality assurance program shall provide control over
    activities affecting the quality of the identified structures, systems, and
    components, to an extent consistent with their importance to safety."
    (emphasis added) Moreover, to enhance the efficiency of coating application,
    and reduce the instances of rework due to quality control inspection, the
    licensee implemented a program of " Paint Monitors" in which experienced
    craftsmen reviewed the work of other craftsmen before final QC inspection and
    acceptance. This review and examination was in addition to the Quality Control
    inspection and did not replace it.
    The inspector reviewed the painting / coating, procedure to determine the
    inspection requirements, acceptance criteria, and the procedures conformance
    to applicable national standards (American National Standards Institute ANSI
    N101.1 and N101.4). The inspector determined that subsection 6.1.1 of IP-104,
    and subsection 6.1 of IP-103 specifically and clearly established QC " Hold-Points"
    which murt be inspected and released by quality control before further work
    could proceed. These hold points had been designated by engineers to meet the
    intent of engineering requirements of the coating design.
    The inspector verified in this inspection that designated forms to document
    these QC inspections had been completed by QA personnel before the work was
    accepted.    Section 7.0 of the coating procedures (IP-103, & 104) clearly
    instructs QC personnel of the requirement of documentation and filing of
    the required report form; " Daily Inspection Report - Level I Coating".
!
    Paragraph 7.3 of IP-103 requires the QC Engineer to do a surveillance of the
    areas being worked for repairs. The surveillance includes atmospheric condi-
    tions, surface preparations, applications and curing. Surveillances were
    normally done two times per shift.

l l 

  ,                       _         _ _ _ _ _ ___, , ~    _. , _

                                                48
     Quality of coatings is also dependent on environmental conditions during appli-
     cation, such as temperature and relative humidity. As an additional control to
     assure quality coatings,  Weather Stations" had been established inside
 y containment on the -26', O' and 25' levels. These stations were clock driven,
     7 day recorders of wet and dry bulb temperatures. They had been placed in

p; areas where the coldest temperatures were expected-(near stair wells). 7The 

     stations were calibrated every 6 months. From the the recorded information, QC
     and the foreman calculated dew point and relative humidity. Metal temperature
    was obtained by a hand-held thermometer. Training had been conducted for the
     foremen, and they were provided with dew point and relative humidity tables.
    The requirement of independence of inspection organization and inspectors
    pertains to the final verification of the work to meet the technical require-
    ments and the attendant acceptance criteria.     It is not intended to replace the
    responsibility and/or normal in process verification of the quality of work of
    the craftsmen. These reviews and examination functions are variously performed
    by experienced craftsmen, foremen, general foremen, superintendents, and
    construction engineers. The very intent of these actions is to assure pro-
    duction of " quality" work which will be inspected and accepted by an independent
    inspection organization. The verification and acceptance inspection does not
    substitute, and/or relieve the construction organization of its responsibility
    w verify the quality of its work before final inspection and acceptance,
    although it is carried out in an informal manner.
   At icebrook, this self-verification and in processes control was up graded and
    to.se e extent formalized by construction to minimize unacceptable work, and
    exercise better control over the painting / coating operations. It did not
    substitute or in any way degrade the formal inspection and/or final acceptance
   of work by Quality Control inspectors.
   CONCLUSION
   Paint monitor painters did review and examine other painters works, but the
    implication that they were engaged in formal quality control is not substan-
   t1ated.
   By review of specifications, construction procedures, inspection records, and a
   visual examination of the completed work, the inspector determined that the
   paints / coatings applied and accepted, met the acceptance criteria and national
   code. It appears that the pai7t monitor program did enhance the quality of
   coating operations, because the incidence of rejection by QC was minimized and
   the paint repairs in the summer of 1986 were expedited.
                                                                                       l
                                                                                       l
                                                       .-

                                          49
 16. ALLEGATION
" Workers report personal harassment subsequent to causing safety complaints."
                                                                  .     -
NRC UNDERSTANDING OF THE ALLEGATIONS
                                                                '
                                                                       R tjl,
Workers that identify safety concerns at the plant and report them were
routinely harassed.
DETAILS
The Code of Federal Regulations,10 CFR 50.7 very clearly provides protection
to employees who identify violations of the Act and report them to the NRC.

The provisions of 10 CFR 50.7 must be posted in prominent areas throughout the 

facility so that all workers are aware of its provisions and can avail them-
selves of it. The existence of this protection is often incorporated into the

General Employee Training. The NRC regulations and initiatives make it easy for site personnel to report harassment to the NRC. The regulation is required to be posted in conspicuous places at Seabrook station so all employees can see it. The posting contains the Region I telephone number and states collect calls will be accepted. The NRC also posts the Resident Inspector phone number and photograph at the site to further assure easy identification of him and make NRC access easier. The NRC also makes itself available to the plant workers through interviews which are performed in the field in conjunction with the inspection. Examples of these interviews are discussed in allegation No. 11 and Table No. 1. The alleger did not give any further details than stated above. However, a review of licensee and NRC records shows that on several occasions reports of harassment and intimidation were made by the Seabrook construction staff. In all of the cases that were reported, only one resulted in harassment and intimi- dation being confirmed. This was identified and investigated by the licensee. The investigations appeared to be thorough and involved interviews of the affected parties and their co workers. Allegations of harassment and intimidation also were made to the NRC and formally investigated. (Reference Investigation Report No. 50-443/1-83-001 and 50-444/1-83-007; Inspection Report 50-443/83-09 and 50-444/83-08 and other internal memoranda) None of these were ever confirmed. Generally, the issues that were involved dealt with the supervisor and subordinate relationship where- in the confrontation situation was not skillfully dealt with by the supervisor. An inexperienced supervisor may crossover the fine line between directing a subordinate and intimidation or the employee may perceive the encounter to be intimidation. There is no evidence to indicate that any of the documented reports of harassment or intimidation have resulted in equipment deficiencies. CONCLUSION This allegatien as understood by NRC was not substantiated. However, one case of harassment was confirmed. 

                                                                                 - - - .
         _
              .                                          .
                                                                               .

                                              50
                                                                                   .
                                                                                         !
    18. ALLEGATIONS                           SE * "        ^        '
                                                                          ['~        ~
                                                                                         l
    "Rebar, wire, pieces of steel and other debris was thrown into an, electric- .       !
 s generator..on the second floor;of the-north 44deref-thegipamWhA-

D/!NRCfuNDERSTANDING OF THE-ALLEGATIONS EdsLY W Mip MEihM5&EO4 - 

   The alleger states that rebar, wire, pieces of steel and other debris were
   thrown into an electric generator on the second floor of the north side of the
   equipment vault.
   DETAILS
                                                                         -
   The NRC inspector examined the equipment vault noting that there is no electrical
   generator installed. P.owever, the NRC inspector did see equipment which could
   have been mistaken for an electrical generator. There is an air handling unit
   (photo no. 5) on the upper level of the equipment vault and a safety injection
   pump motor housing (photo no. 6) on the second floor of the equipment vault
  which approximates the size and configuration provided by the alleger.
  Both Units were in operation, having successfully gone through the preoperational
   testing program. Phase 1 of this program requires confirmation of the correct
   installation, verification of control wiring and determination of functional
  capability of the equipment. In addition, the equipment has been placed on the
  licensee's preventative maintenance program to ensure operability.
  The NRC inspector examined the above equipment and all areas of the equipment
  vault, noting that all areas and equipment are clean and free of any debris.
  The inspector noted that access to the equipment vault is limited to authorized
  personnel only and that control is by card key and surveillance by security
  personnel.
  CONCLUSION
                                                                                         \
  There is no evidence or presence of dirt or debris in the equipment vault area
  or equipment, the allegation was not substantiated.                                    I

                                           . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
                                                                                                                             ,
                           50a
                                v,;   .;
 .
                   _.__ _
                                                                                                                             l
                                                                                                                             l
                                       :
        PHOTO NO. 5, AIR HANDLING UNIT (REF. ALLEGATION
        NO.18)
                                                                                                               . -        e.
                                                                                                                   /       '
                                                                                                                     , [* 1'
  s.. c
  h
        PHOTO NO. 6, SAFETY INJECTION PUMP MOTOR
        HOUSING (REF. ALLEGATION NO.18)

_ 

                                                                                                                                                               .s

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                                                                                         52a
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                                                                                                    !         . , .
                             PilOTO NO. 7, CONDU!TS AND J-BOX AT ELEVATION 7'-O"
                             IN THE PRIMARY AUXILI ARY BUILDING (REF. ALLEGA-
                             TION 19)

! 

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                             PHOTO NO. 8, PRIMARY AUXILIARY BUILDING ELEVATION
                             25'- O'(REF. ALLEGATION NO.19)
 . _ -         _ _--.. - --.                                                         _ _ _ _ _ _ _                        __- __-__ . _ _ - - _ - - - - _ - - - - - _ .

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

! f 53 

;
  ,
    20. ALLEGATION
    People doing cheds for startup did their. checkoffs very carelessly.
    NRC UNDERSTANDIhG OF THE ALLEGATION
    Verification of system component identification was performed in a manner that
    could lead to erroneous information. Clarifying information obtained during
    an interview indicated that individuals assigned to verify tagging of compo-
    nents in a system requested assistance in reading tag numbers for components in
    hard to reach places when another individual was in the immediate vicinity of
    the tagged component.
   DETAILS
   The objective of the tagging verification prior to start up testing was to
   verify that the components in the syster.: were ready for testing. After the tag                                           -
    identification was established the information was checked oy entering the                                                [
   equipment numbers into the computer tracking system to determine if there were                                              ~
   outstanding Nonconformance Reports (NCR) or Engineering Change Authorizations                                              .
   (ECA) that must be cleared before the test.                          If erroneous information was
   gathered from the field verification of the tagging, this information would be
    identified when the computer failed to locate the component in the data bank.
    In such cases, another field verification of the component number would be
    required. The objective of the start up tests is to assure systems will
   operate as designed prior to plant operations.
  The NRC has been closely following the preoperational and startup test programs
   as they are performed at Seabrook. From October 1985 through March 1986 pre-
   operational testing has been the subject of approximately 38 inspections.
   Documentation of some of these inspections may be found in Inspection Reports
   50-443/85-30, 85-31, 85-13, 86-37, 85-08.
  NRC inspectors have witnessed numerous walkdowns of safety and nonsafety
   related systems during the system turnover and preoperational testing phase of
   the project. A few of these systems include CL-M-1, Chlorination System /
  Mechanical, nonsafety related; SWA-H-1, Service Water Pumphouse Ventilation /
  Mechanical, safety related; CL-I-1 Chlorination System / Instrumentation,
   nonsafety related; Component Cooling Water System, safety related; and the CVCS
  Thermal Regeneration Demineralizer, nonsafety related. NRC inspectors used as
   built drawings in their walkdowns which were verified to be the latest revision.
   Findings resulting from these walkdowns were documented and correctoc.
   NRC inspectors witnessed many tests such as the cold hydrostatic test of the
   Reactor Coolant System including the reactor coolant piping, the reactor
   coolant pump housings, the primary side of the steam generators, the pressurizer
   and associated instrumentatior tubing. Typically during the witnessing of
                             _ _ _ - - _ _ _ - _ _ _ _ _ _ _ _                                                                  I

 - -
                                                             54
     these tests the inspector verifies the test will meet the established require-
     ments, reviews the test procedures, verifies the system line ups, and assures
     the test is performed as planned and the test results valid. This test was
     also witnessed by the Authorized Nuclear Inspector (insurer) and at the
     conclusion the results were accepted by both the NRC and the Authorized Nuclear
     Inspector.
     During the inspections performed for preoperational and startup testing, there

' 

     was not an excessive number of exceptions taken to the various tests indicating
     the precedures used for system verification, test planning and test performance
     were adequate.
     CONCLUSION
     This allegation could not be substantiated. Based on the large number of
     inspections performed by the NRC during preoperational and start up testing of
     the plant, the inspector determined that the objective of the tests is being
     achieved i.e. assurance that the plant will operate as designed. Due to the
     structure of the system, if erroneous information was gathered, it would have
     been detected and corrected.
                                                                                                                               .
                   --         ,       t-- - - , ,- -> s%----    ,,m+ . , , , - - - y-- ,c ,
                                                                                            -+w-4-----w-w--- w y.- -,--v- ----

                                             55
:
    22. - ALLEGATION
  '" Security there was very slack. To see if the security system worked, someone
    put gunpowder in their pocket and mixed up a paste and rubbed it on their pants,
    then stood right against the machine which detects those things. It did not go
   off."
   NRC UNDERSTANDING OF CONCERN
   The alleger states the explosive detector will not detect gunpowder.
   DETAILS
   The inspector evaluated the Ion Track Instruments (ITI) explosive detector,
   used by the licensee for access controls through interviews with licensee
   representatives and the manufacturer. Further discussion on th'e capabilities
   and effectiveness of this model explosive detector and its use at Seabrook are
   considered Safeguards Information as defined in 10CFR73.21, and will not be
   discussed in detail.
   The licensee developed a security program that was approved by the NRC and the
   use of an explosive detector represents one facet of personnel access control
   that is part of that program. Other facets of personnel access control include
   the use of the initial employment application, background investigation,
   psychological testing, metal detection, trained guard observation and the badge
   issue procedure. Each of these facets are satisfied prior to the issuance of
   unescorted access to the designated protected and vital areas. There are other
   facets which are employed to further aid in the detection and prevention of
   harmful devices.
   The inspector verified that as of this inspection, personnel access control is
   developed as described above.    In addition, the licensee strictly controls the
   right and need for personnel to have unescorted access to designated protected

' 

,  and vital areas. Supervisors are also trained to detect and report aberrant
  behavior.
  The NRC approved the Seabrook Nuclear Generating Station Physical Security Plan
   for fuel implementation on October 17,1986. Portions of that plan contain the
  procedures for providing positive access control to protected and vital areas.
  CONCLllSION
  Due to safeguard implications, NRC cannot comment on the validity of this
  allegation. However, the inspector determined that the licensee was in
  compliance with the NRC approved Physical Security Plan and its procedures.
                      -
                           __  ._                    .-         _ _ -   __       -__ _,_ _ __

        .                    __

_ . . _. - 

                                                    56
        23. ALLEGATIGN
        Guards would smoke in the doorway of the area where the fuel is held with both
        the doors open. Much of the time, the back door of that area was held open
        with a block of wood.
        NRC UNDERSTANDING OF CONCERN
        Security guards were smoking in the doorway of the new fuel storage area. The
        doors to this area were blocked open.
        DETAILS                 -
        The inspector determined through direct interviews with security supervision
        that guards were authorized to smoke while assigned access control and sur-
        veillance duties at the~ fuel storage building (FSB). They were instructed to
        smoke in the doorway of hallway leading to the front access control point to
        the FSB if they wanted to smoke. The doors to the FSB were to remain closed
        unless authorization ^or~ opening"was granted by designated plant officials.   -
        The inspector reviewed the Security Activities Log for the period May through
        October 1986. A random sample of entries in those logs indicated that.the
        opening of doors to the FSB was. controlled.as required (See excerpted entries
        from log, below). In addition, these logs reflected comments concerning when
        the area surrounding the FSB was patrolled. This patrol was in addition to the
        surveillance provided by the assigned security guard at the FSB.
                                          SHIFT COMMANDER
                                     SECURITY ACTIVITIES LOG
              TIME                           AUTHORIZING
        OPENED     CLOSED         DATE       OFFICIAL            REASON
        12:45PM    13:31PM        5-6-86     Merrill/Rx Eng      Fuel truck entry
        11:01AM    11:01AM        5-10/P6    Gurney /Rx Eng      Run welding leads
                                                                 into the FSB
        09:21AM    09:21AM        5-12-86    Gurney /Rx Eng      Run welding leads
                                                                 into the FSB
        16:09PM    16:12PM        6-2-86     Couture /Fng Supv   Delivery of fuel
                                                                 rods by truck
        11:09PM      -
                                  6-17-86    Messina/Sec Supy    Doors opened for
                                                                 maintenance
        11:31PM      -
                                  9-5-86      St Pierre /Opr     Auxiliary operator
                                              Supervisor         entry

 -          .
                                                      57
          10:53AM       -
                                      9-8-86    Kline/Eng Mgr          One door opened for
                                                                       entry of an electri-
                                                                       cian
          18:25PM      -
                                      9-9-86    Sukeforth/ Con-        Roll up door opened
                                                trol room              for maintenance
         09:51AM    10:00AM           9-10-86   Couture /Eng Supy      Replace ceiling
                                                                       light bulbs
         08:05AM    08-43AM           9-11-86   Couture /Eng Supy      Replace ceiling
                                                                       light bulbs
         10:19AM       -
                                      10-2-86   Clark / Control RM     Bring scafolding
                                                                       through the door
         13:31PM       -
                                      10-10-86 Couture /Eng Supv       Equipment entry
         10:15AM       -
                                      10-17-86 Couture /Eng Supy       Removing equipment
         The inspector determined from a review of records and personal interviews, that'
         the doors to the FSB were opened at times, however, the openings were authorized
        'by plant officials who were so designated. This practice was in accordance

, 

         with established procedures. The inspector could not determine whether the
         doors to the FSB were blocked open, but for some of the reasons cited above,
         doors could have been blocked open to allow the entry of welding leads, etc.
         The inspector found no indication of violations of the NRC approved Physical
         Security Plan for the Protection of New Fuel.
         CONCLUSION
         The allegation was substantiated. Guards were permitted to smoke outstue of
         the doorway to the new fuel storage area. This posed no hazard to the new
         fuel. Operational needs in the new fuel storage area may have required the
         back door to be open at times, however, surveillance of the new fuel was a
         responsibility of the posted security guards who were on post 24 hours per day.

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

m 

                                              58
  24. ALLEGATION
  " Implementation of the TP10 procedure. This procedure enables Nonconformance
  Reports to be written without the NRC's knowledge saving valuable steps of
  inspection (saving the company money)."
 NRC UNDERSTANDING OF THE ALLEGATION
 Nonconfermance Reports that were written as a result of positioning deficiencies
 encountered during installation of attachments to embedded plates were
 dispositioned without Nuclear Regulatory Commission approval.
 DETAILS
 The purpose of the procedure TP-10 " Technical Procedure for Location of
 Attachments to Embedded Plates" is to define the location requirements for
 attachment of structural members welded to embedded plates. Procedure TP-10
 specifies the tolerances for the location of a member to be attached to an
 embedded plate e.g. a pipe support. Installation drawings specify the location
 tolerances for the support on the pipe. When both sets of tolerances could not
 be met, an Engineering Change Authorization (ECA) was generated to resolve the
 condition. If the support was installed and either tolerance requirement not
 met, a Nonconformance Report (NCR).was generated-and . processed in .accordance
 with established procedures. During verification of the as-built conditions,
 the actual location of the attachment on bot'         is was determined and recorded.
 Using the as-built dimensions, the stress ca        . ;tions were verified.   If, as a
 result of this verification, an attachment had to be moved, an NCR was generated
 to authorize the movement.
 The NRC has performed at least twelve inspections to verify the as built
 conditions of the plant. These include 50-443/84-07, 84-20, 85-09, 85-20,
 85-31, 86-41, and 86-43. During these inspections minor problems were found
 and have been corrected.      Except as required by 10 CFR 50.55e, nonconforming
 conditions are not required to be reported to the NRC. The rule provides for
 NRC's notification for significant construction deficiencies that, if uncorrected,
 could affect the operation of the plant.       Reportable significant deficiencies
 include a breakdown in the quality assurance program; deficient final design; a
 deficiency in construction that requires extensive evaluation and rework; and
 deviations from the performance specification for equipment and structures.
 Control of ncnconformances is part of the Quality Assurance Program. NCRs are
 required to be written and processed -in accordance with this program, evaluated
 and corrective action taken if necessary.       The NRC has performed numerous
 inspections of the licensee's Quality Assurance program since the inception of
 the project including one specifically evaluating the nonconformance program

         _ .

1 

                                                                         59
               for design changes (50-443/85-15). In this report both the ECA and the NCR
               programs were evaluated. Deficiencies were identified and were subsequently

' 

               corrected. However, it was determined that there was no significant effect on
               the plant safety as a result of these findings. In addition, nonconformances
               are tracked to determine if there are trends indicating generic problems. This
               trer. ding enables the licensee to determine root causes of recurring problems.
               CONCLUSION
'
               The allegation was not substantiated. The NRC has performed inspections as
               described above and no procedures permitting deviations from reporting
               requirements were identified. Further, nonconforming conditions are not
               required to be reported to the NRC excepted as provided for by 10 CFR 50.55e.
                                                                                                                                                     "

i $ 

  '

i 

i
I
    - _.
             .        .     _ . . _ . . _ . - _ - . ..-- . _ _ , __._. -    - _ _ _ . . . - - - _ . . . . _ - . . _ - - _ . . . - - _ -. - . - - . .

                                             60
    25. ALLEGATION
    " Safety related construction procedures written in ambiguous, hard to interpret
    language in order to make conformance to them up to the reader and his or her
    interpretation."
   NRC UNDERSTANDING OF THE CONCERN:
    In many cases construction procedures were written that contained specific

- 

   technical language that was difficult for non-technically trained individuals
   to interpret.
   DETAILS
   Nuclear safety related procedures are mandated by the Code of Federal
   Regulations, 10 CFR 50, Appendix B, for all structures, systems and components
   important to safety. The NRC devotes significant amounts of inspection time to
   procedure review to assure compli nce with national codes, standards and
   regulations. Reviews of procedures are a normal part of NRC inspections, some
   reports containing these reviews are 50-443/76-02, 77-10, 79-06, 81-07, 83-02,
   83-09, 85-11, and 86-11. The NRC formal inspection program requires that these
   reviews be made by the NRC inspectors.
   As discussed in allegation No. 11, the NRC has interviewed a large number of
   crafts, engineers and quality control personnel to determine their knowledge
   and understanaing of procedures.
   Procedures are written in precise technical language for the discipline
   involved to assure all areas are covered, to assist in uniformity by a large
   work force and to avoid misinterpretation. All procedures used for safety
   related construction and installation were reviewed by the engineering and
   quality organizations prior to implementation or after revision. Further,
   experienced supervisory and engineering personnel were available in the work
   place and a formal process existed for clarification of procedures or inter-
   pretation of technical requirements.
   CONCLUSION
   Based on the number of NRC inspections in which procedures were reviewed by
   NRC inspectors, this allegation could not be substantiated.
 -

                                              61
  26. ALLEGATION
  " Procedures written to allow conditions to exist that are unsafe, but since a
  procedure has been written to cover the given condition that makes it
  acceptable."
  NRC UNDERSTANDING OF THE ALLEGATION
  Equipment was installed incorrectly relative to the procedure, but once it was
  installed the procedure was rewritten to reflect the installation. This
  clarification was obtained from the ELP during an interview on November 4,1986.
 DETAILS
  If procedures were not followed this resulted in a deviation or nonconforming
 condition. Such conditions were evaluated in accordance with the requirements
 of the Quality Assurance Program and, if required, the initial procedure revised,
 an Engineering Change Authorization written, or disposition made by an NCR. In
 any of these cases, an engineering evaluation of the situation was made to
 assure the installation, as actually performed, met code, regulatory and design
 requirements.
 Procedures must meet code, regulatory and design requirements. They may be
 appropriately revised to provide clarification or additional technical require-
 ments or for other reasons when the procedure as written is not viable.
 Procedures are reviewed and approved by quality assurance, engineering, and
 construction to assure they meet these commitments. When esses of unanticipated
 interferences prevent installation of equipment as originally planned, drawings
 were revised to provide alternate methods of installation.         These alternate
 drawings are reviewed by the same organizations that reviewed the original
 drawings prior to use to assure compliance to requirements and to assure the
 alternate installation will provide satisfactory performance.

l 

 The NRC reviews procedures, drawings and revisions to these documents as a part

' 

 of their inspections. These reviews include the technical content of the
 documents as well as the applicability of the appropriate codes, standards and
 regulations and the qualifications of the individuals preparing, reviewing and
 approving the documents. A few of the inspections where this was done include
 50-443/76-02, 77-10, 78-01, 79-06, 80-01, 82-03, 83-14, 85-15, 85-06, 85-14,
 and 86-11.
 CONCLUSION
 Based on the on going effort by the NRC in reviewing procedures and inspecting
 the work done in using these procedures, and the rigorously controlled systems
 provided by the licensee to control procedural changes, this allegation could
 not be substantiated.
             -,- ,.-.   . .    -,.   _  .  - - . _ - - _
                                                              - , - _ _ . - - - -   - _ - .

                                                                         s. e,~..
                                            62
  28. ALLEGATION
  Improperly trained electricians.
  NRC UNDERSTANDING OF THE ALLEGATIONS
 The alleger states that electricians are not properly trained.
 DETAILS
 NRC inspector discussions with electrical craftsmen indicate that electricians,
 welders, pipe fitters, carpenters and other tradesmen are hired through a Union
 Hall. To become a member of a Union Hall, one must apply and be accepted in
 the apprentice training program. Individuals meeting the minimum educational
 requirements must then successfully complete the 2-4 year apprenticeship and
 pass the written examinations to qualify for the journeymans card. This card
 signifies qualificaiton in the selected trade and availability for work assign-
 ments through the Union Hall. The Union Hall also supplies apprentices who
 perform non-technical tasks such as clean-up, tenders for qualified journeymen
 and other laborous tasks for.which the use of fully qualified electrical
 journeyman would underutilize his technical skills. The NRC inspector verified
 that individuals are given site specific indoctrination and assigned to perform
 work to the level of expertise required by the job assignment. Qualification
 is documented by training records filed for each individual.
 CONCLUSION
 The allegation was not substantiated. All safety related work requiring
 skilled craftsmen is performed by qualified electrical journeymen. Quality
 control performs in process and final inspection to ensure quality workmanship
 and compliance with NRC requirements and licensee commitments through drawings,
 instructions and procedures.

A 

            n  . - - -    - - a    n -         - . - _ _ - _ - . .- ----          ,-n - , _ _ ,

                                           63
29. ALLEGATION
" Trainers / engineers give classes inadequately to groups within their
organizations."
NRC UNDERSTANDING OF THE ALLEGATION
Training sessions within organizations are informal and do not include all of
the functions of that organization.

DETAILS The NRC inspector examined the licensee's training practices to determine the possible basis for the allegation. Training sessions presented by individual organizations are, in addition to the formal sessions presented by the General and Specialty Training Department, typically in the form of tool box meetings, some on-the-job and that given by supervisors. These sessions are given by 

supervisory or staff personnel who do not possess sophisticated training skills.
In addition, this supplemental informal training is done without the benefit of

lesson plans and usually in small groups. The purpose of these sessions is generally to identify minor changes in procedures or job rules or to strengthen group knowledge in a specific area. There are special cases where an experienced person was hired who was fully qualified. In these cases, the individuals training and work experience were documented during the hiring process, but the individual had to demonstrate his qualification. Exarpples of these are welders and nondestructive examiners. Training of welders was done off site, and qualification testing done on site. During qualification testing, time was allowed the individual to set up their equipment and practice. This was not intended as a training program. Nondestructive examination personnel were tested to assure their qualifications met the code and standard requirements, the individual's experience record was verified to assure adherence to the requirements. Again this was not intended to be training because qualification was based on prior experience, education and training as required by the specifications. The NRC examined the formal training programs to assure that code, standard and regulatory requirements were met. Examples of these kinds of inspections are documented in NRC Inspection Reports Nos. 50-443/85-07, 85-11, 85-15, 85-19, 86-15 and 86-23. CONCLUSION The NRC has reviewed records of individual training and qualification throughout the construction of the plant including training programs provided by the licensee and contractors. Formal training and qualifications were found acceptable. This allegation could not be substantiated. 

                                                              64
   32. and 57. ALLEGATION
  32. " Tracking of blueprints an impossibility."
  57. " Drawing revision control was ineffective."
  NRC UNDERSTANDING OF THE ALLEGATION
  The alleger was doing as-built inspection on the fire protection system in the
  turbine building when he saw a workman using the same drawing as the one he was
  working to and noticed that the workman's drawing was Revision F and his was
  Revision J.
  The alleger was also concerned that changes in the fire protection system were
  not reflected in the General Arrangement drawings.
 . Tracking of drawing revisions was difficult and revision control was
  ineffective.

, 

  DETAILS
  The NRC has performed several inspections on the drawing and revision control
  system during the construction of the plant. Some of the NRC inspections where
  drawing and document control were addressed include 50-443/83-02, 84-07, 85-15,
  and 85-29.    In these inspections, one violation was found, corrected by the
  licensee, and the correction reinspected and accepted. Further, the NRC has
 made many formal and informal as-built verification inspections of piping and
  equipment installations. These inspections verify the accuracy of the latest
  approved revision of the drawing with the actual installation.
 During construction each contractor was responsible for the initiation,
  revision, and distribution of their drawings. As a result, there were several
  systems of drawing control in use on the site. All of the systems used for
  safety related document control were audited by both the licensee and the prime
 contraccor, United Engineers and Constructors Incorporated.
 Most revisions made to drawings do not affect the entire drawing, so the
  revision the workman had could have been correct for the portion of the drawing
 being used. The purpose of the as-built inspection is to verify that the
  system was installed as designed and to provide accurate drawings of the system
 as it exists. As contractors cceplete their projects, drawings are turned over
 to the licensee, audited, changes required noted, and placed under the licensee's
 document control system to be updated later, if necessary.

4 

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

                                                                                 1
                                           65
 Duri:  +his inspection, the NRC inspectors selected drawings for equipment and
 pipin.   iich were compared to the installations such as those described in
 allegacions Nos. 6, 48, 51, 52, 54 and 55. In addition, the NRC has performed
 many inspections which verified as-built conditions.   This is discussed in the
 Details of allegation No. 24 and Table 5 of this report.
 CONCLUSION
 These allegations could not be substantiated. The NRC has reviewed drawings
 and documents as a routine part of inspections since the project was started.
 Isolated cases of outdated drawings were found during these inspections and in
 each case the situation was corrected. The inspectors did not identify any
 nonconforming conditions relative to plant drawings during this inspection.

, 

                                            66
  33. 34. 47.     59. and 60. ALLEGATIONS
  33. " Battling and sabotage between different contractors."
  34. " Contractors engineering and constructing jobs improperly in order to
  prolong the job."
  47. " Write nonconformances in such a way as to put as little blame on
  Pullman-Higgins as possible. I was specifically directed to try to avoid
  listing craft error or poor workmanship as cause of nonconformance of a pipe."
 59. "The relationship between Pullman-Higgins and United Engineers and
 Constructors frequently appeared to be adversarial rather than cooperative.
 Disagreement between some P-H and UE&C personnel over procedures and
 responsibilities was in my opinion detrimental to job performance on both
  sides, as much effort appeared to be oriented by both toward defending
 themselves from possible criticism. While working for P-H, I was told by my
  supervisor to write nonconformance reports in such a way as to put as little
 blame on P-H as possible. I was specifically directed to try to avoid listing
 craft error or poor workmanship as a cause of nonconformance, as this would     -
 tend to indicate poor performance by P-H."
 "This conflict was also manifested in partisan graffiti throughout the
 plant, and satirical documents circulated among the engineering staff."
 60. "UE&C was commonly belieted to be using the Seabrook project to provide
 work for engineering staff idled from other projects. At various times I met
 one person from the Cherry Hill , N.J. office; one from a nuclear project in
 North carolina; at least two from the WPPS project in Washington State; and a

, number of people from the Badger Division of Raytheon, UE&C's parent company. 

 All were there because they had no other work available within the company.

I 

 The UE&C staff grew so large that an office building had to be leased off-site

l to accomodate some of them." 

 "The perception that UE&C intended to take over the job responsibilities from
 P-H in order to keep their own employees busy was a further source of friction
 between UE&C and P-H staff. After I left P-H, UE&C did in fact take over
 as-built inspection, document control, and drafting responsibilities from P-H
 and I was told later took over all instrumentation and control systems work
 from Johnson Control. I would estimate that the UE&C staff at the site
 increased by up to 30% when the WPPS project war shut down."
 NRC UNDERSTANDING OF THE ALLEGATIONS
 33. Based on an interview with the Employees Legal Project, the allegation does
 not mean sabotage in the sense of causing equipment damage but impugning of the
 the contractor's reputations. The allegation is directed specifically to the
 United Engineers and Constructors and Pullman-Higgins relationship.
       .-

                                                                           '
                                                  67
  34. The statement essentially alleges that work was done intentionally wrong
  to extend the contract time.
  47.and 59. The source of allegaton number 47. was the Newburyport Daily News
  article of October 20,1986, which was later restated in more detail in an
  affidavit supplied to the NRC by the alleger.
  The allegation deals with an adversarial relationship between the construction
 manager, United Engineers and Constructors, and the piping contractor,
  Pullman-Higgins. As a result of this relationship, instructions were given to
  inspectors to write nonconformance reports in a manner that would obscure the
  root causes of deficiencies.
 60. The allegation again deals with the adversarial relationship between the
 construction manager, UE&C, and the piping contractor, Pullman-Higgins as
 previously described in allegations 33,47, and 59. Additional causes of this
 adversarial relationship are the replacement of Pullamn-Higgins personnel
 with UE&C personnel from other constructions sites that were no longer in the
 construction phase.
 DETAILS
 The construction organization for the Seabrook project was based on a
 construction manager concept. United Engineers and Constructors (UE&C) was
 contracted as the construction manager. As the constructon manager, UE&C
 subcontracted the various tasks such as electrical, piping, and structural
 work. Pullman-Higgins (P-H) was awarded the piping subcontract.
 In the early 1980s, significant concerns with P-H's job performance were
 identified by the NRC. These concerns were primarily with design control and
 the use of construction practices which were in conflict with UE&C
 specifications. These NRC concerns and licensee corrective actions are
 documented in the Systematic Assessment of Licensee Performance Reports,
 inspection reports and licensee /NRC management meetings for the period
 1982-1984.
 These NRC concerns were translated into corrective actions by the licensee
 through the UE&C and P-H interface. The corrective actions took the form of
 organizational and procedural changes which ultimately led to increased
 licensec and UE&C control of P-H activities. The UE&C and P-H interactions
 resulting from these changes apparently gave the impression , if not in fact,
 of an adversarial relationship. This could not be substantiated due to the
 fact that Pullaman-Higgins has demobilized and is no longer on site.
 However, the job performance problem and the quality of work resulting from
 these changes were monitored very closely by the NRC.

. - 

                                        _ . _ _ ,     _.

                                              .
                                                   . -_
                                           68
 In an interview with one of the allegers, it was disclosed that the P-H and
 UE&C relationship did not result in equipment deficiencies but made the work
 environment mentally more difficult. This was futher reflected in his
 allegation regarding the writing of nonconformances and not citing craft error
 and workmanship as the cause of the deficiency. The alleger stated that this
 was to make Pullman - Higgins "look better." He was unable to cite any
 instances where this compromised equipment operability.

F 

 The allegation regarding the contractors engineering and constructing the work
 in order to prolong the contract was discussed with the alleger; the concern

i expressed was that it caused the cost of the project to increase. There was I no specific information that would indicate that equipment had been adversely 

 affected by these actions. Plant cost is beyond the scope of this inspection.

( 

 CONCLUSION
 The foregoing allegations could not be fully substantiated. However, no safety
 related equipment deficiencies could be identified as a result of these
 allegations.
        ..    .
                              ..                         _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ . _ . _

                                         69
36. ALLEGATION
" Quality Assurance and Quality Control slipped the last few years; there was no

QA or QC on third shift, and none for cement on second shift." NRC UNDERSTANDING 0F THE ALLEGATION Quality Assurance and Quality Control have not been as conspicuous on second and third shifts as construction neared completion. DETAILS The NRC very closely monitored the licensee's Quality Assurance Program throughout the construction of the plant. The NRC has maintained a full time resident 

inspector on the site since May,1980 and a second resident inspector was assigned

in 1982. These resident inspectors are in addition to the specialist inspectors that visit the plant on periodic scheduled, but unannounced, inspections. The licensee's quality assurance program is also submitted to the NRC annually for review if any revisions have been made in the previous year. During this review any reductions in commitments are carefully evaluated to determine if they meet the requirements of 10 CFR 50, Appendix B, and other codes and specifications committed to by the licensee. Some NRC inspections of the liicensee's QA program include 50-443/74-01, 78-03, 81-12, 84-07, 84-13, and 85-15. The Quality Assurance and Quality Control inspection force is directly related to the number of craft workers at the plant and the amount of safety related work in progress. As the construction was nearing completion, the number of craft employees and the degree of safety related work, particularly in concrete, was very small. Therefore, there was no need for a large number of QA/QC inspectors in that area. The inspector reviewed logs of concrete and grout placement during the two year period ending in August, 1986. From this log, it was noted that in less than ten cases did placement of concrete or grout require second shift work to complete the placement. Surveillance of completed concrete and grouting for temperature and humidity conditions has been performed as required by manu- factures recommenda ions, or procedures. In many cases, this surveillance was performed by using recording temperature indicators and daily observation of the humidity conditions of the curing material where no individual was required to be present during the second and third shifts. If conditions were noted that were not as required, a Nonconformance Report was written and disposition made in accordance with established procedures. CONCLUSION Based on the continuing inspections of the licensee's quality assurance program this :llegation could not be substantiated. 

                                                      -.         .   -

                                              70
  37. ALLEGATION
  "There was cheating on literacy tests, others took literacy tests for people who
 were illiterate. Literacy tests were given toward the end of construction as
  an excuse to lay people off."
  NRC UNDERSTANDING OF THE ALLEGATION
 This is a three part allegation interpreted as follows:
  1.   General Employee Training (GET) and the required examinations associated
       with this training have been interpreted by the alleger as a literacy test
       used as an excuse to lay people off.
 2.    There was cheating on the examination given as part of the General Employee
       Training (GET) program required for access to the protected area.
 3.    One individual took GET for another.
 DETAILS
 The inspector discussed literacy testing with the training manager and was
 informed the licensee has never given literacy tests. Near the end of
 construction prior to establishing the protected area, GET with written
 examinations was given as a requirement of the NRC license to operate the
 plant. Initiation of the training was delayed until immediately prior to
 establishment of the protected area to allow more convenient access to the
 plant during final construction by personnel performing the finishing work on
 the plant in this area.
 GET is always culminated with an examination to verify the employees under-
 standing of the topical areas and to provide feedback to training. As part of
 this examination, the class is monitored by a proctor. In an isolated case,
 one employee had been given a GET examination paper by another employee. This
 employee was using the previous examination when he took the test. The test
 proctor observed this cheating and as a result both the employee caught cheating
 and the employee who gave him the test were laid off.
 Since inception, measures that require positive identification of individuals
 receiving GET training have bcen employed.       These measures include the use of
 photo identification prior to receiving the training, personal interviews, and
 background checks. The inspector was satisfied that identification require-
 ments for employees receiving GET were satisfactory.
 CONCLUSION
 Based on the examinations made by the inspector, this allegation could not
 substantiated on a general basis.

< 

                  . . - . - . . - - -
                                          ,-..c--          -n          - - - - . . - - , --

                                                                                                 i
                                           71
38. ALLEGATION
Paint thinner was accidentally spilled on electrical cables.
NRC UNDERSTANDING OF THE ALLEGATIONS                                                       .
The alleger stated that paint thinner was accidentally spilled on electrical
cables, and is concerned the thinner could be detrimental to the cable
insulation. No specific area or system was identified.

DETAILS Because of painting activities throughout the plant, paint, containing paint 

thinners, was inadvertently being spilled on electric cables. Site engineering

was aware of and had evaluated instances of paint splatters or spills onto plant cables during the April-November 1985 time period. In each of these cases, it was established either by inspection of the affected cables, or by a test program conducted by Franklin Institute that the cable jackets or insula- tion were not damaged, and the cables were not adversely affected. The spills 

in the plant which have been evaluated have included paint which contains

thinners of the types used on-site, and which would have been involved in any thinner spills that occurred. A Deficiency Report (85-48D) has been identified, dated 7/18/86 regarding a phosphoric acid spill involving cables going to electrical per.etration nodes H02, H41, HIS, H20 & H55. Additional items affected are cables in tray Nos. 93VILB, 92 MIKV and the tray themselves. Disposition involved cleaning of the Tri-Sodium Phosphate residue from the cables with an approved cleaner, chlorothene, also a paint thinner and visual inspection of cable for signs of deterioration. The trays and other affected metal components were cleaned and retouched with galvanox coating. Engineering visually inspected the repairs and determined that they were acceptable. The NRC inspector conducted additional tests on November 3-4, 1986. Sample cables of the type used in safety related systems were exposed to applications of several types of paint thinners used on site as a test. The following thinners were used to wet the cable outer protective jacket: 

       a) Keeler & Long #4093 (Epoxy thinner)
       b) Keeler & Long #3100 (Kolorane thinner)
       c) Keeler & Long #1638 (thinner)
       d) Keeler & Long #3700 (Kolor-Poxy thinner)
       e) Wisconsin Protective coating #71 (thinner)
       f) Gates Engineering #N-450-1 (Neoprene thinner cleaner)

Samples of safety-related cables used on site were wetted with each of the above noted cleaners. All thinners evaporated immediately following applica- tion. Following evaporation, the glossy surface of all cables became dull. The NRC inspector examined the cables for surface deterioration; no damage was evident. The thinners did not penetrate the cable outer protective jacket. 

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

                                                                _ _ _ _ _ _ _ _ _ _ _ _ _ - -
                                                                                                .. ..               ..
 !'
                                                 72

h - t 

       CONCLUSION
       This allegation was substantiated.
       The NRC test results indicate that paint thinners used on site have no detrimental                              I
       affect when spilled on electrical cable jackets. Site engineering was aware of
       spills that occurred during the period April to November 1985, confirming the
       allegation of paint thinner spills on cables. However, based on the above
       results and the test program conducted by the Franklin Institute Laboratory,
    '; spilling of the paint thinners has no adverse affect on the cable.
     W

, 

                                                                                                                       l
                                                                                                                       l
                                                                                              _       _ _ _ - _ _ .

                                              _ _ _ _ _ _ _    _ _
                                                                   _ _ _ _ _ - _ _ _ _ _ _ _ _ -
                                                            73
     39. ALLEGATION
     " Electrical cables along the outer walls of the centainment gave off sparks
      starting little fires. An electrician said this was because the cables had
     been there too long with people walking on them, wearing them down."
     NRC UNDERSTANDING 0F THE ALLEGATIONS,

t 

     The alleger stated that cables along the oater containment wall and lying on
     floor gave off sparks causing minor fires.
     DETAILS
     The NRC inspector determined that normal construction practice is to run
     temporary cables to provide power to operate tools and welding equipment used
     in construction / fabrication activities. These wires or cables are hung on the                           l
     wall, across trays and some times are laid on the floor. This practice is                                 !
     still in effect as evidenced in photos nos. 9 & 10 taken on November 20, 1986.
     Discussions by the NRC inspecto: with licensee personnel confirmed that fires
     have resulted in temporary cable when tha insulation is worn through or stepped
     on to expose a current carrying conductor. Craftsmen are continually reninded
     of the hazards imposed by improper Tractices and care in handling temporary
     cable. The subject was discussed frequently at the Weekly Tool Box meetings.
     The hazard is that fires from these sources could damage safety related equipn'ent.
     Usual construction practices to lessen the threat of fires is to employ training
     and awareness, flame rett.rdant lumber, and fire extinguishers.
     The above practice rele.tes to temporary cable installation which as the name
     implies will be removed after construction or test. Permanent plant cables,
     both safety related and non safety related, are routed in permanent raceways.
     The site electrical installation procedure no. 9763-006-48-2 requires that all
     safety-related cablas be routed in cable trays or conduits. Quality Control
     inspectors are present to inspect the cleanliness and to insure that the trays /
     conduits are free of debris before each cable pull. All safety-related cables
     are in protective enclosures such as tray / conduit. Cables are checked electrically
     and given a walkdown visual inspection for surface damage during construction
     and at turnover. Finally, preoperational testing is performed to verify functional
     operability of each system.
     Quality Control is involved in all aspects of cable installation, termination
     and functional testing of safety-related cable.
     CONCLUSI0PJ
     The alle.gation is substantiated for temporary cable; however, tnere is no
     evidence to indicate that these instances involved safety related cables.
 .
   .           .
                                                      .
                                                                                                 - _ _ _ _ _ .

                                                                              ___ _-_
                                  73a

. 

       ,
                                    C
                                                       =;-
         .;
                                      $ '.
                                                           .
                                       4
                                            r. -
                                           f
                                             My.
                                          ..
      PHOTO NO. 9, WELDING AND TEMPORARY
      POWER CABLES ON THE FLOOR ( REF.
      ALLEGATION NO. 39)
                                                                                             s
                                                                             !nt            :
                                                                            I            i    .
                                                                            fd          fi ,
                                                                           j       . \ !' =
                                                                           !.         >
                                                                           ja;
                                                                         -
                                                                              '!b
                                                                         4> 'ly
                                                                                      9s
                                                                                            ..i
             -  . . . . . . . . . . . . . , , . . . . , .    $l   n-. u+              -
                                                                                         s'
 PHOTO NO.10, TEMPORARY WELDING AND POWER
 CABLES ON THE FLOOR (REF. ALLEGATION NO. 39)
                             _ _ _ _ . . .                      _                               ...

                                             74
  40. & 46. ALLEGATION
  40. "One of the main pipes from the reactor to the turbine building did not fit so
  workers had to use a comealong to make the connection."
  46. ALLEGATION
                                                                                     i
  " Cold pulling to align pipes."
  NRC UNDERSTANDING OF ALLEGATION
  The alleger restates a well documented licensee identified cold pull incident.
  A comealong was used in the fitup operation for a main steam line final closure
  weld. Allegation No. 46 while general in nature, is addressed by the licensee's
 -corrective actions to No. 40. Cold pulling of pipe is also discussed in
  allegations number 7 and 55.
  SUPPORTING DETAILS
  Piping and pipe supports are a significant portion of the plant installation
  work and have been inspected by the NRC on a continuing basis throughout
  construction. The NRC inspections 443/84-12, 84-13 and 85-25 discuss NRC
  observations, reviews and findings in the area of cold pulling of pipes.
  There are two major piping systems connecting the turbine generator building
  with the containment (reactor) building; four feed water lines and four main
  steam lines. The inspector determined that the subject incident was identified
  by a licensee contractor and documented in Nonconformance Report (NCR) No.
  80749, dated August 10, 1982.
  The licensee found that a misalignment greater than permitted by the piping
  erection specification existed prior to the fitup of the Main Steam Piping
  (Line MS-4007-01-B1-30) field welds F0105 ' A' and F0106 'B' . Subsequently, the
  licensee determined that the contractor was not fully cognizant of the details
  of Specification No.    9763-006-248-51 which required that no mechanical means
  could be used to move pipe more than 1/8 inch off its centerline position. A
  Final Report (SBN 869) dated September 10, 1985 for Construction Deficiency
  Report, CDR-82-00-13, submitted to the NRC which described the deficiency and
  detailed the corrective actions, including:
  1.    An evaluation of 70 ASME, Section III, Class 2 and 3 piping systems
        verified that the supports /restaints were installed after the final
        closure weld thus assuring that the effects of cold pull that may have
        been introduced were minimal.
  2.    The cold pull identified on the conconformance report was corrected by
        refitting the line.

. 

                                                                                      75
                       3.      Applicable welding installation and inspection procedures were revised to
                               preclude recurrence.

, The above corrective actions were in place by January 1983. Subsequent 

                       inspections in this area by the licensee and NRC inspectors did not identify
                      any additional discrepancies. NRC inspection 85-25 completed a final review
                      and concluded that the licensee's corrective actions were effective.
                      CONCLUSION
                      The allegation was substantiated. The subject allegation addressed a single
                       instance of cold pull of piping. The incident, originally identified by
                      supervision, is well documented and resulted in a comprehensive evaluation of
                      systems installed prior to the event to assure that previously installed piping
                     was not adversely affected.

1 i , , 

 - - - , . . . . - - - . - - -    m. ---.,,.,--,-.. -----. ,,---m., _,, , ,.--_v-----    _ - - - -- . . , - -

                                         76

41. ALLEGATION " Security was poor. Unauthorized people regularly had access to restricted areas." NRC UNDERSTANDING 0F CONCERN The alleger stated that unauthor.ized. people. regularly had access to restricted areas. Restricted areas, meaning those areas of the plant where construction had been completed and were prepared for turnover for start-up testing. Unauthorized people were those who could not immediately produce a valid work request to a responding security guard. DETAILS The inspector reviewed the incident and event reports submitted by security personnel for the period May 1 through October 30,1986. The results of this review are as follows: 

        MONTH                      COMMENTS
    May 1986                       There were 12 events in which security
                                   patrols observed unsecured doors; locking
                                   mechanism taped to prevent locking or
                                   doors blocked open with wooden wedges.
    June 1986                      There were 14 events during the month of
                                   June. On 3 events, security received an
                                   intrusion alarm and a patrol responded
                                   and discovered unsecured doors. On 11
                                   events, security patrols observed
                                   unsecured doors, locking mechanized taped
                                   to prevent locking or defective locks.
    July 1986                      There were 8 events during the month of
                                   July 1986. On 2 events, security received
                                   an alarm and a patrol responded and
                                   discovered an unsecured door. On 6 events,
                                   security patrols observed unsecured doors,
                                   defective locks or doors blocked open for
                                   wires and pipes.
    August 1986                    There were 5 events in which security
                                   patrols discovered unsecured doors or
                                   doors being blocked open.
                                                                                 :
                                                                                 1
                                                                                 1

                                            4
                                            77
       September 1986                  There were 5 events in September
                                        1986. On 3 events, security received
                                       an alarm and a patrol responded
                                       and discovered unsecured doors. On
                                       2 events, security patrols observed
                                       unsecured doors.
       October 1986                    There were 4 events in October 1986.
                                       On 3 events security received an alarm
                                       and a patrol responded and discovered
                                       an employee had created the alarm On
                                       1 event, an unalarmed door was found
                                       unsecured.
 The licensee stated that during the construction phase of the plant, the access

' 

 controls that were implemented throughout the plant were imposed as a result of
 safety or construction concerns. Access control as defined in the approved
 physical security plan was not required during the construction of the plant.
 The inspector verified that the licensee had implemented the NRC approved
 physical security plan as of October 17, 1986. At that time, unescorted access
 to protected and vital areas was positively controlled. During this inspection,
 the inspector observed that the security force is providing positive access
 control to protected and vital areas. All personnel granted unescorted access
 have received a background investigation, a psychological test and general site
 education.
 The NRC approved the Seabrook Nuclear Generating Station Physical Security Plan
 for full implementation on October 17,1986. Portions of that plan contain
 procedures for providing positive access control to protected and vital areas.
 The inspector determined that the licensee was in compliance with the NRC
 approved physical security plan and its procedures.
 CONCLUSION
 The allegation was substantiated. Based on an interview with the alleger, the
 period of concern is the spring of 1985 to the spring of 1986. The physical
 security plan, however, the official security plan for regulatory compliance,
 was not implemented until October 17,1986.

      -
                                           78
42. ALLEGATION                                                      ,
Three thousand pound cement was used at Seabrook whereas at other nuclear
plants 5000 pound cement was used because 3000 pound was not thought to be
 strong enough.
NRC UNDERSTANDING OF THE ALLEGATIONS
The allegation as understood by the NRC is that the reference is made to
concrete rather that cement; and 3000 pound and 5000 pound refers to the
nominal strength of the mix-design of concrete which is measured in the units
of pound per square inch (psi). Furthermore, because the alleger is concerned
about the safety of the nuclear plant, his concern is related to concrete
design in safety-related structures.
DETAILS
The 10 CFR 50, Appendix A, " General Design Criteria" (GDC-50) establishes

. requirements for containment design. Every licensee must satisfy these design 

requirements'for a nuclear power plant. The Preliminary and -Final Safety                -

Analysis Reports (PSAR and FSAR) have been reviewed by the NRC, and Safety 

Evaluation Reports (SERs) have been issued.

The inspector reviewed the FSAR for the Seabrook Station, and noted that the containment design has been reviewed by the NRC and that the licensee was committed to design the containment in accordance with the ASME Code. Section 

III, Division 2, Subsection CC, Article CC-3000 of the Code establishes methods
for containment design. The inspector also noted that a nominal 4000 psi

mix-design concrete was the basis of the containment analysis in the FSARs and the NRC SER. By review of specifications, placement records and construction drawings the NRC inspector determined that the concrete used in containment and other safety-related structures was a 4000 psi mix-design minimum. The mix was designed in accordance with American Concrete Institute (ACI) standard ACI 211.1-7A. The concrete as mixed in the on-site batch plant and delivered to placements was sampled at the point of delivery and tested for strength (see allegation 2) The results indicate that the average actual strength of the minimum 4000 psi mix-design was in excess of 5000 psi. The test cylinders of the concrete used in containment structures indicated a strength distribution range from approximately 4400 psi to 6000 psi for twenty eight day tests. The NRC has also independently performed nondestructive tests (impact hammer; windsor probe) of the concrete used in safety-related structures. These tests indicate an average value of approximately 7200 psi. (IR 50-443/84-12) 

                                                                                                I
                                            - - _      - - - - - -.               . . - _ _ - -

                                                                                             l
 '
                                                         79
        The nominal strength of a concrete mix-design whether 3000, 4000, 5000 or even
        6000 psi does not inherently make a structure " strong enough" or weak. The
        minimum nominal strength is used in designing (sizing) a structural member of
        an optimum size to withstand the design loads. With proper design and adequate
        size of any structure, a 3000 psi mix concrete is as serviceable as 6000 psi
        mix concrete. However, other considerations such as pump placement, durability,
        forming and ease of placement, and radiation shielding may dictate the choice
        of a mix-design rather than just strength. In a given structural size, however,
        a higher strength mix will provide a higher strength structural member. The
        Seabrook design is for 4000 psi, and tests show that actual average strength to
        be approximately 5000 psi.
        CONCLUSION

j This allegation is not substantiated. The concrete mix used for safety-related 

        structures, especially containment is of a nominal 4000 psi design. The safety
        margin is more than adequate. The independent neasurements by NRC show that
        actual average strength to be considerably higher than 4000 psi.
I
 i
 !
                                                                                            r
 <

4 4 

 I

4? 

:
 i
                                                                                            Y
i

1 - 

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

                                                                                _ _ _ . . _ _
                                          80             g
43. ALLEGATION
"The reactor was filthy compared to other nuclear plants under construction

where a dust free environment was maintained. At Seabrook there were wooden 

ladders and debris in the reactor. Compared to other nuclear plants, general
practices at Seabrook were slovenly, shoddy.

NRC UNDERSTANDING OF THE ALLEGATION 

In comparison to other nuclear power plants under construction, housekeeping

practices at Seabrook in and around the installed reactor vessel were poor. OETAILS During the construction of the facility, the NRC identified housekeeping deficiencies which were characterized as an area of concern but "not to a 

severe degree". This was reported in the Systematic Assessment of Licensee

Performance Reports for the periods of July 1983 through January 1984 and January 1985 through March 1986. NRC Inspection report 50-443/84-18 formed a basis for this conclusion wherein it cited " empty spray cans, loose hardware, stripped cable insulation and other debris." The NRC resident inspectors were aware of this problem and monitored the licensee's activities in this area. The inspector toured the plant during this inspection noting plant cleanliness at this point in time. The areas are painted and debris free; no construction dirt is evident. In areas where post construction activities are in progress, the areas are maintained and clean. During various phases of construction prior to 1985, equipment required to facilitate work on the reactor coolant system, specifically wooden ladders, were placed in the reactor vessel; this practice is not uncommon. During the first quarter of 1985, the reactor coolant system piping and the reactor vessel were cleaned in accordance with Flushing Procedures 1-RC-F-4 and 1-RC-F-5. Upon completion of the cleaning program in March 1985, with the exception for periods of related testing and inspections, the reactor vessel remained sealed with a fire resistant polycover. Final cleaning of the reactor vessel consisting of manual cleaning per procedure GT-C-02 to a final surface cleanliness level of Grade 'B' was accomplished on July 19, 1986. procedure GT-C-01 Revision 11, includes system cleanliness classifications with Grade 'B' identified as the most stringent level, specified for the reactor vessel. CONCLUSION This allegation was substantiated. During certain phases of the construction period, equipment and possible debris may have been found in the reactor vessel. However, flushing operations and manual wipe down of the vessel and visual examination indicated that the required levels of cleanliness were achieved and subsequently maintained throughout the period leading up to fueling activities. 

                                            81

44. ALLEGATION " Improper welds were performed by untrained welders. Wrap-around welds were used when return welds were called for; return welds prevent the " keyhole" from breaking under stress." NRC UNDERSTANDING OF THE ALLEGATIONS The first portion of this allegation relates to the use of untrained welders and is addressed in the finding for allegation Number 12. The second portion of the allegation questions the difference between a wrap-around weld and a return weld on AWS structures and ASME Code, Section III, NF pipe support welding. DETAILS The American Welding Society (AWS) standard for welding terms and definitions defines an "end return" to be a non-standard term for " boxing" which is "the continuation of a fillet weld around a corner of a member as an extension of the principa] weld". The term " wrap-around weld" is not defined in the AWS standard for weld terms. Therefore, the NRC inspector determined the Seabrook site requirements for end return (or boxed) welds. This includes the AWS definition; the ASME Code Section III, interpre+ation III-1-86-10 end return requirement of NF components; the UE&C drawing 5/63-M-805943S, Sheet 2C, Note 6 requiring return welds where practical, and ECA 25-03728. The basic require- ment is that fillet welds shall be end returned for 1/2" minimum or 2 times the fillet size where geometry permits. The NRC inspector examined a sample of approximately 100 welds in each of the containment and PAB areas to establish the presence of end return welds where required. All welds examined were properly "end returned". A similar allegation was investigated by the NRC in 1983 and is quoted below from the inspection Report 50-443/83-01, Part 4e. 

      "e.  The NRC inspector reviewed the return end (or boxing) requirements of
           ASME Section III, NF and AWS D1.1 and discussed the technical intent
           of these requirements with the NRR-ASME Section III, NF representative
           and the AWS Staff expert on D1.1. The function of the return end
           welds is to prevent premature tearing of the ends of fillet welds
           under ultimate failure conditions (as discussed in paragraph 8.8.6 of
           the Commentary Section of the 1980 01.1 document.) The loading
           conditions may negate the technical requirements for many return end
           welds. The 2X minimum length requirement is secondary in technical
           importance to the existence of the weld end corner closure.    UE&C did
           not initially recognize the return end weld requirement in their
           specifications and Engineering Change Authorization (ECA) 250372A was
           written on February 27,1981 to address this question based on a
           Request for Information (RFI) initiated by YAEC. The ECA required
           that inspection be made of all P-H field welds and shop welds and
           additional weld be added if required. All future field welds are to

                                           82
            be made with return welds (where applicable). The licensee indicated
            that consideration may be given to an engineering evaluation calling
            for return end repair welds on an "as required" basis based on loading
            conditions (directions) rather than 100% of all fillet welds on supports
            identified by the subject ECA. This could minimize additional quality
            problems associated with repair welding.
     The technical significance of the above areas of concern of hanger fabrication
     has been addressed in this inspection report by inspections conducted
    without direct or indirect reference to the existence c.,f the allegation.
     The inspection indicated that some of these areas were under review prior
     to the time of the allegation. As a result of ECA 250372A (dated February
    27,1981) resulting from an RFI initiated by the licensee, all support
     fillet welds are required to be reinsepcted for return end welds."

The AWS term " keyhole" refers to a welding procedure where a through hole at the leading edge of the molten metal is developed and fills in behind the hole as the weld arc progresses. Keyhole welding is associated with gas tungsten arc and plasma arc welding but is not applicable to shielded metal arc fillet welding. CONCLUSION The allegation was not substantiated. 

                                                                                     1
                                                                                     I

                                          83
45. ALLEGATION
" Bottles of Argon used for we1 Jing were contaminated with moisture but were
used anyway."

NRC UNDERSTANDING OF THE ALLEGATIONS How is the moisture content of Argon gas for weld shielding controlled? If Argon contaminated with moisture was used would a welder see any resulting problems? DETAILS All Argon purchased for welding use at Seabrook Station is certified to be 99.995% pure Argon. Argon has beer purchased in bottle and bulk form and, is used as a shielding and purging medium for the Gas Tungsten Arc Welding (GTAW) process. There never has been a problem with the bottled gas but there have been instances where problems occurred with the bulk system. The welder (s) would recognize the problem due to the change in welding characteristics, stop work and notify a welding supervisor. The affected portion (s) of-the bulk supply system would be taken out of service until the problem was found and corrected. The welder (s) would remove the affected weld, switch over to bottled gas, and complete the welding assignment. Most of the problems found were aspirating hose connections. The NRC inspector was avare that if moisture contaminated Argon gas is used in the gas shielded Tungsten Arc Welding (GTAW) of stainless steel and carbon or low alloy steels, weld metal porosity may occur. The NRC inspector reviewed the purchase order and Argon gas analysis reports to determine if the maximum moisture level of Argon gas was specified and controlled. The effects of moisture on the GTAW Tungsten electrode, visibility of resulting porosity, weld technique of verifying weld integrity by looking at GTAW root passs welds and involvement of supervision and weld engineering in resolving weld porosity problems were considered. The inspector reviewed the statement of analysis for Argon Welding Grade Gas dated November 29, 1977 which specifies a minimum purity of 99.996% Argon with a maximum dew point of -76 F, and a typical analysis of 99.9989% purity with a dew point of -90 F. Test results of welding grade shielding gases were reviewed, confirming a combination of high purity and low dew point. The inspector concluded that the weld gas supplier (also a supplier of medical gas) did control and check weld gas purity and moisture content to levels consistent with quality GTAW, porosity free welding. Field procedure FWP-18 part 5.2.5.1, C and the P-H General Weld Standard GS-111 Part 4.2 require the use of oxygen analyzers to check the adequacy of Argon gas backing purge for GTAW root pass welding. While this analyzer does not measure moisture content, it does provide another field check on Argon gas purity besides observations made by welders during welding and observations of completed weld lay 9rs by welders, QC inspectors, supervision and NDE technicians. 

                                                                                 I

                                          84

Previous NRC weld inspections of both welder qualification and production welding have not identified GTAW Argon gas, moisture induced porosity as a significant contributor to weld metal defects. Where a problem with GTAW shielding gas has been observed, the problem is usually found in the delivery system such as a bad gas lens, loose gas line fitting or damaged gas hose. The resulting weld process problerr.s in these cases are generally immediately obvious. In addition, the NRC performed independent weld examinations using the Nondestructive Examination Van on three occasions (6/82, 8/84 and 7/85). The inspections employed radiography, magnetic particle, liquid penetrant and visual examinations of welds. Any widespread porosity problems would have been identified using these techniques. CONCLUSION This allegation was not substantiated. 

                                           85
48. ALLEGATION
"
  ...in a number of locations throughout the plant, the primary and backup
feedwater systems were supported by a single structure."
"
  ...it appears the plant is vulnerable to total failure of feedwater and
emergency feedwater systems ir, some accident situations."
NRC UNDERSTANDING OF THE ALLEGATIONS
The alleger is concerned that a single failure of an Emergency Feed Water (EFW)
component will result in the loss of the EFW system. Also, the failure of a
main steam line or main feedwater line in the area of the EFW pump house and
Condensate Storage Tank (CST) can also result in the loss of the EFW system.
DETAILS

The inspector reviewed the requirements of the Standard Review Plan 10.4.9, Auxiliary Feedwater System, Final Safety Assessment Report (FSAR) Section 3.5, Missile Protection, and section 6.8 Emergency Feedwater System, and NUREG-0896, Safety Evaluation Report for Seabrook Station, Section 6.8. The inspector verified that the NRC has completed an in depth review of all design and operational aspects of the EFW system. The review determined that all components and associated piping are housed in seismic Category I structures, with the exception of suction piping that is routed underground between the CST and the pump house. Within the seismic Category I structures, equipment and piping are supported by seismic Category I restraints. High energy lines of the main steam and feedwater systems are also supported by seismic Category I structures, preventing adverse impact upon the EFW system. The seismic Categoy I concrete structure surrounding the CST, will contain adequate water to cool down the plant should the steel tank fail. Redundant emergency feedwater pumps are locatea in a seismic Categoy I pump house. There are no barriers between the pumps; however, an analysis conducted in response to an NRC request for additional information, RAI 410.8, was completed by the licensee in August 1982 and included in Section 3.5 of the FSAR. The analysis concludes that a missile generated by the turbine driven pump is not a credible event, allowing the two pumps to be located in the same area. CONCLUSION This allegation could not be substantiated. Although it is true that the emergency feedwater system is supported by a single structure in a number of location, these structures are designed to withstand natural occurring events and pose no threat to the piping system. 

                                                                                               ..
                                                         86
               51. ALLEGATION
               " Control building air conditioning system refrigerant lines (CBA) lack
                separation; no physical barrier between them."
               NRC UNDERSTANDING 0F THE ALLEGATION
               Redundant trains of the control room air conditioning rystem are located in
               the same room and are, therefore, subject to common mode failure.
               DETAILS
               Air conditioning (cooling) in the control butiding is limited to the control
               room complex and it is comprised of two independent systems.
                     a) control room - safety-related
                     b) computer room - non-safety-related
               The inspector reviewed the system drawings and examined the installed piping and
               equipment. The control room air conditioning system consists of two redundant
               trains of 100*4 capacity each. Power supply to each train is an independent
               emergency source.   Electrical cable seperation criteria meet the requirements
               of Regulatory Guide 1.75.
               All equipment associated with the control room air conditioning system is
               housed in seismic Category I structures designed to withstand safe shutdown
               earthquake and postulated tornado missiles. Cooling system components
               including fan dampers and associated equipment duct work are ANSI Safety Class
               3, Seismic Category I. This system has been evaluated by the NRC staff in
               accordance with Section 9.4.1 of the Standard Review Plan (SRP). The staff
               determined that the system is in conformance with applicable General Design
               Criteria.
               No specific criteria exist for the segregation of refrigerant lines of the
               redundant air conditioning systems. However, all piping is seismically
               supported to assure system reliability during and after seismic events.
               Independent verifications of the as-built conditions of the subject system has              ,
               been conducted by the licensee's contractor and the NRC, as documented in NRC
                                                                                                           '
               report No.86-12.
               The computer room air conditioning system consists of a self-contained single
               unit housed in its entirety inside the computer room.     This unit is not
               safety-related.
               CONCLUSION

l l This allegation is substantiated. kowever, there are no requirements to meet 

               specific separation criteria for refrigerant lines. The existing system design

i 

               has been reviewed by the NRC and does not degrade plant safety.
 . . - - - . -                  -      -   --   --                    --
                                                                            _ _ - - . _ _ _ - . _ . . . -.

_ - 

                                                    87                                  .
       52. ALLEGATION
     -The emergency feedwater system is supplied from a single tank, which also
       serves as condensate storage for the main steam feedwater system.
      NRC UNDERSTANDING OF THE ALLEGATIONS
      Additional clarifications by.the alleger: On Nov. 5,1986, during a personal
       interview, the alleger clarified his concern as it appeared in the October
      21,1986 affidavit.
       It.is the inspector's understanding of the alleger's concerns that an adequate
      source of water supply to the emergency feedwater system cannot be assured for
      two reasons:
              a) condensate water storage tank level is not controlled
              b) other . systems taking suction from the Condensate Storage Tank (CST) can
                 drain the tank leaving an inadequate supply to the Emergency Feedwater    l
                 Pump (EFP) during an emergency.                                           !
      DETAILS
      The licensee's Technical Specification (T.S.) which is part of the operating
      license, Section 3.7.13, requires that a minimum of 212,000 gallons of water be
      contained in the CST; and the concrete CST enclosure is capable of retaining
      212,000 gallons of water. This minimum water volume is sufficient to cool the
      reactor coolant system to less than 350*F, when the residual heat removal (RHR)
      system can be placed into operation. At this point, the emergency feedwater
      system is no longer required. The condensate storage tank level is continuously
     monitored in the contrpi room and a low tank level alarm, at 240,000 gallon
     alerts the operators to take corrective action.         If the above requirements
     cannot be met, for a period of 4 hours , the plant must be in hot shutdown
     within the following 12 hours.
     The inspector reviewed Section 9.2.63 of the FSAR, Condensate Storage Facility
     Safety Evaluation, in conjunction with Figure No 10.4-4, Sheet 1. The lowest
     elevation of non-nuclear safety pipe is at 44' - 4 3/8"; the EFP suction pipes
     are at 23' 11", assuring a 20' 5" reserve of this 42 ft. diameter tank for
     emergency feedwater of 212,000 gallons. There are six (6) nozzle penetrations
      into the CST within the elevation reserved for EFP. Five are associated with
     EFW pump and condensate pump recirculation, and tank level instrumentation.
     One suction line at elevation 25'-3" is associated with the Startup Feedwater
     pump.      This line is isolated by valve No. CO-142, which is normally locked
      shut. The above connections and all associated piping are nuclear grade
     seismic Category I, and are protected by missile shields.
     CONCLUSION
     This allegation is not substantiated. The system design and administrative
     controls insure a reliable water supply during emergencies.
 .

                                                                .

i 

                                                88
      53. ALLEGATION
      " Control room is protected by an automatic water sprinkler system, thus
      exposing the electronics to disruption by water."
      Fire protection systems throughout the plant consists of an automatic water
      sprinkler system, water fire hoses and hand-held fire extinguishers. This is
      the only fire protection equipment installed in the control room, thus

i exposing electronically operated control systems to the threat of disruption 

     due to water infiltration when sprinklers are activated. Computerized
equipment is not customarily sealed against liquids due to the need for
     ventilation to maintain a constant temperature.
     NRC UNDERSTANDING OF THE ALLEGATIONS
     The alleger states that the control room is protected only by an automatic

j ' 

     water suppression system. Use of this system to put a fire out in the control
     room can cause disruption of electrical equipment exposed to the water spray.
     DETAILS
     The control room cabinets and consoles are subject to damage from two distinct
     fire hazards.
           a) Fire originating within a cabinet or console
                                                                                      '
           b) Exposure fire involving combustibles in the general room area

i 

                                                                                      1

l The NRC inspector examined the fire detection in the control room complex and I verified it is protected by ionization detectors. Manual hose stations are 

     located outside the control room near the stairwells. Halon and dry chemical
     hand-held extinguishers are located in the control room. Control room equip-
     rient is not provided with pedestals and floor drains are not provided. However,
     these features are not required as the hose stations and standpipes are located
     outside the control room and up to 4 inches of flooding can be tolerated without
     damage to any safety-related equipment. Drainage is maintained through the
     open door to the turbine building or the stairwells to tne outdoors. Nozzles
     for the manual hose station are chosen to minimize physical damage to the
     electrical equipment and satisfy electrical safety.
     The NRC has imposed extensive requirements for fire protection through 10 CFR
     50.48 and Appendix R. The licensee's fire protection program was reviewed by
     the NRC and is documented in a Safety Evaluation Report dated March 1983.
     Further, a team inspection verified the implementation of the safe shutdown
     aspects of this fire protection program. This is documented in Inspection
     Report 50-443/86-03.
     In addition the control room is manned on a 24 hour basis so that any fire in
     the area would be immediately detected and extinguished.                         !
                                                                                      1

l I l 1 

 _ .

                        ___ - __- _ -_ _ _
                                            89
 The plant computer does not perform any safety function and the failure of the
 computer will not prevent the safe and orderly shutdown of the plant. The
 plant computer room is a portion of the control room complex but is separated
 from the main control room by three hour rated fire walls. Automatic fire

l detectors with a fixed Halon 1301 system is provided in the computer room. l Portable fire extinguishers are not provided. 

 CONCLUSION

l The control room does not have an automatic water suppression system. The 

 primary fire protection consists of portable Class "C", appropriate for
 fighting electrici fires, fire extinguishers with the standpipe and hose
 station as the back-up system.
 This allegation was not susbstantiated.                                        l

! 

                                            90
  54. ALLEGATION
  " Parts of CBA system were constructed without design drawings."
 NRC UNDERSTANDING OF THE ALLEGATIONS
 The installation of'the air conditioning system lines was completed without
 the use of drawings. The original installation consisted of 2 and 3 inch
 diameter steel piping which was subsequently replaced with 3/4 inch diameter
 copper tubing.
 Additional clarification by the alleger: On Nov. 1,1986 during a personal
 interview the alleger clarified his concern as it appeared in the
 October 21, 1986 affidavit. The alleger stated that his concerns address the
 air conditioning system of the Control Building Air Handling (CBA) equipment.
 DETAILS
 The allegation was inspected inconjunction with allegation No. 51 wherein the
 inspector reviewed tha drawings and installation of the system.
 The inspector determined that detailed drawings of the subject system have
 been issued and are designated as United Engineers & Constructor (UE&C)
 drawings 4019600 through 4019618. System modification dates and applicable
 construction details appear on each drawing. As-built walkdowns of the system
 have been completed using the subject drawings.
 Licensee's specification No.9763-006-248-1, Shop Fabrication of Pipe requires
 that refrigeration piping be installed in accordance with ANSI B31.5, Field
 Supplied Refrigeration Piping. In accordance with the code, all piping
 associated with the system is rigid copper piping. Steel piping is not used

, in any part of the system. , 

 CONCLUSION
 This allegation could not be substantiated.

i l 1 1 

 , .        .        -       .     --         -       . -     -    -     -.      ._   _ - .
                                                 '91~

t ! 55. ALLEGATION 

      The allegations about turbine building _ equipment and piping are summarized
      below:
            a.  Condensate traps in horizontal pipe runs

l b. Uneven support loading under heat exchangers 

            c.  Prohibited work practices used thoughout the system
            d.  Weld identification procedures not carried out                              !
            e.  B 31.1 as-built inspection program was canceiled because                    l
                it was too costly and unnecessary                                           l
            f.  Cold pulling pipe                                                           !

l 

     The allegation stated:
     " Turbine exhaust piping was installed with several reverse slopes, and runs
     out of plumb and skewed.      Some misalignments at pipe welds were evident.   I
     believe this to be due in large part to inaccurate fabrication of the                  :
     condenser shells in which the piping was installed. Some of the heat                   l
     exchangers in the condensers were also installed out of level.                         !
     On one occasion I saw a crew attempting to force a pipe spool into location by
     use of a chainfall. This practice, known as cold pulling or cold springing,
     is normally prohibited by the construction specifications. The presence in             .
     other locations of blocking similar to what was used by this crew, and                 *
     apparent fitup problems throughout the piping suggest that this may have been

l 

     done in other places in the system. In my work with documentation for the              i

! 

     exhaust piping I found no reference to any authorization for piping to be
     cold pulled into alignment.
     All field welds were required to be stenciled by the welder with his
     identification symbol and the field weld number.      In numerous instances I
     found unmarked welds, and in some cases, incorrectly identified welds. Many            -
     of these had substantial surface rust, indicating that the work had been done
     some time ago. Identification marks were inscribed on these welds after I              '
     brought them to the craft supervisor's attention."
     I was told by a co-worker that the original contractor for the condensers and
     associated piping had been dropped when the system was partially completed,            l
     and the job reassigned to Pullman-Higgins.
     In my judgement these potential problem areas exist in the turbine exhaust             ,
     system and condenser piping:
     * Condenser traps in horizontal pipe runs.
     * Uneven support loading under heat exhangers.     In operation they are to be
     approximately half filled with water.      Those that are out of level will not        .
     match the weight distribution for which the supports were designed.                    i
     * Prohibited work practices may have been used to an unknown degree throughout         l
     the system.                                                                            l
     * Identification procedures created to insure weld quality do not appear to
     have been correctly carried out.
                                                                                            ,

l [ 

                                                                                            ,

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t
                                                                                                                                                  '
.
4
                                                                                                92
                                                                                                                                                  i
i                                                     I wrote up a large number of nonconformance reports on piping in this system.
*
                                                     I do not know how they were dispositioned. This was the last system I worked                 l
L                                                    on under Pullman-Higgins. When I returned to the site in July 1983, I was
,                                                    told that the as-built inspection program for ANSI B31.1 piping had been

{ cancelled at that time because it was both too costly and unnecessary." 

,                                                   ALLEGATIONS AS UNDERSTOOD BY THE NRC

j No clarification of the allegations was necessary. 

                                                    DETAILS
:                                                                                                                                                 1
                                                    The systems described in the allegation are not nuclear safety-related and are
.
'
                                                    not governed by regulations. However, the NRC is concerned about the general
                                                    quality of all plant systems to avoid equipment failures and challenges to
 '
                                                     safety systems. The inspector examined the installed condition of various                   '
                                                     feedwater beaters including FW-E-268 by column 10 and runs of horizontal piping.
l                                                   Horizontal runs of steam piping of significant length were noted to be sloped

4 

                                                    toward drain piping taps. Feedwater heaters were found to be installed level
;                                                    in accordance with the high pressure and low pressure feedwater heater

j 

                                                     installation instructions (IL 1370-1388 and 1370-1386) (Photos Nos.11 & 12).                 f

i Tht; feedwater heater supports are as shown on drawings 4618039 and 4618038.  ! l The turbine exhaust lines from both steam driven turbine feedwater (FWP) pumps

were observed to be installed with a slope toward the condenser in accordance

i with drawir.g 97C3-F-2024. The nearby steam extraction lines (which exit the i' condenser near the turbine FWP exhaust ifne entrance to the condenser) were [ 

                                                    observed to slope down from the condenser in accordance with Drawing 1-EX-4125-01.            t

{ This condition of two lines penetrating the condenser with opposite slope would [ 

i
                                                    present the appearance of reverse slopes, however system design requires the as
                                                                                                                                                  '
                                                    installed slope conditions.
,                                                   Cold pulling of pipe is discussed in allegations #7, #40 and #46, however one
cold pulling incident did occur on Field Weld F0105 Spool E2937-1982 in the  !

i turbine building as reported in the NCR 7035-80749, dated 8/10/82. The NCR t i disposition provided for removal of the Comealong to establish the amount of 

j                                                   cold pulling and provided for refitup of the weld without cold pull. The
                                                    disposition was verified as complete on 6/20/83. This NCR tilustrated that
                                                    excess cold pull of pipe was prohibited, workers were aware of the requirement
and the need to implement the requirement.
l

l Weld identification is a means of providing traceability from the actual pipe 2 

                                                    weld to drawings, procurement documents and quality records. It can be

! accomplished if the as butit pipe correlates with the drawings and construction  ; I records. In the area of weld identification to ANSI B31.1, the inspector noted 

                                                    the requirement for weld joint and welder identifications to be recorded on the               ;
                                                    appropriate weld procsss sheets, which are traceable to the applicable weld.                   :
                                                    For turbine building piping, the stenciling of pipe welds with the weld and
welder symbols is supplementary information but not a regulatory requirement, ,
and has no safety significance. l

l l l [ !  ! ! !  ! 4 , 

l  _ _ _ _ _ _ _ _ _ _ _ ____ _ _ _ _ _ _ _ _ _ _ _                 _                                                                        .-_

 -
                                             93
   The as-built inspection program for ANSI B31.1 piping is not an NRC requirement
    for non-safety-related piping. The information generated by a detailed
   as-built B31.1 non-safety-related piping program would be entirely for the
   benefit of the licensee. The cancellation of the as-built B31.1 program in
   view of existing drawings, NCRs and installation records is justifiable. This
   decision has no effect on safety-related equipment integrity.
   For the main steam (MS) and feedwater lines (FW) an as-built inspection was
   performed including those sections of these lines in the turbine building.
   This inspection was conducted by the licensee under the Piping and Pipe
   Support Close Out Task Team (PAPSCOTT) reconciliation program. As of
   September 16,1986, the MS and FW lines including lines 4600 and 4601 were
   shown to be installed per the applicable design drawings. The licensee's
   investigation results, dated October 24,1986, concerning the as-buil6 inspection
   of MS and FW lines reported in File E-86-102-3(15) was reviewed by the
   inspector.
   CONCLUSION
   This allegation was not substantiated. During investigation of the               i
                                                                                    '
   allegation, all items inspected by the NRC were found to be installed in
   accordance with design drawings and equipment manuals. While it is true that     !
   the B31.1 as-built program was cancelled, the 831.1 code conformance was met by
   installation practices and procedures. No safety-related equipment deficiencies
   could be identified as a result of these allegations,
                                                                                    t
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j PHOTO NO.11, FEEDWATER HEATER BEING CHECKED l I 4 

                                                         FOR LEVEL INSTALLATION (REF. ALLEGATION NO. 55)                                          [
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                                                 PHOTO NO.11, FEEDWATER HEATER BEING CHECKED
                                                 FOR LEVEL INSTALLATION (REF. ALLEGATION NO. 55)

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                                                 PHOTO NO,12, FEEDWATER HEATER BEING CHECKED                                                                    i
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                                                 FOR LEVEL INSTALLATION (REF. ALLEGATION NO. 55)                                                              .
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                                                                                       1

! ! 

                                            94
  56. ALLEGATION
 " Original drawings are required to be kept in fire proof storage. This
  requirement was frequently violated. A fire in the Johnson Controls tre.iler
 resulted in the loss of several drawings."

l 

 NRC UNDERSTANDING OF THE ALLEGATION
 The requirement for fireproof storage of records was violated on site,
 specifically by Johnson Controls International; thereby, destroying important
 quality records and drawings.
 DETAILS
 The fire in the Johnson Controls trailer occurred in December 1982 as they were
 moving into a new trailer complex. Both the licensee fire brigade and the
 Seabrook Fire Department made efforts to prevent the loss of records. Partially    as
 a result of these efforts, no records were burned; however, some received smoke

l 

 damage.
 The requirements for records storage include provision for duplicate and
 separate storage facilities as a means of protecting records.from fire and
 other loss. Johnson Controls maintained a duplicate storage for " original / copies"
 of drawings at a second location on the site at the time of the fire. When the
 records and drawings required for the work performed by Johnson Controls were
 turned over at the completion of the contract, the audit of those records did
 not disclose missing drawings or illegible records caused by fire damage.
 The inspector reviewed a representative sample of the records turned over by
 Johnson Controls and determined that these records were legible after
 microfilming.
 CONCLUSION
 This allegation as understood by NRC was not substantiated. Although, there
 was fire damage to the JCI facility, no permanent loss of records was sustained.

i 

              9

-. 

                                                               95
        58. ALLEGATION
        " Training of new hires was of uneven quality."
        " Training provided to new hires was of uneven quality. That provided by
        Pullman-Higgins was implicitly acknowledged by staff and students to be
        oriented toward passing everybody. Students were permitted to sleep through
        classes. Instruction at times consisted of being told what questions would be
        asked, and what the answers were. Testing was minimal and usually done with
        open books. I do not recall that any testing was done by Pullman-Higgins a
        the area of construction standards and practices. I failed to learn that sid
        springing of pipe in the turbine exhaust system which I observed was a prohibited
        practice; consequently I did not report it."
       NRC UNDERSTANDING OF THE ALLEGATION
       Orientation of newly hired employees was inadequate for specific positions and
       designed to assure all employees were accepted. The alleger was formally
        interviewed on November 5, 1986, the obtain additional clarification of his
       Concerns.
       DETAILS
       The inspector determined through interviews with the training supervisor that
       Construction Orientation was to provide newly hired employees with the basic
       requirements for working on the site. It included such things as safety rules
       so the employee would not become a hazard to themselves or others, actions that
       could result in disciplinary action, locations of restricted areas and other
       information. It should be recognized that training did vary with the type of
       job assignment and from contractor to contractor depending on the technical
       levels involved.
       The course of instruction was administrative in context and was not a measure
       of technical skill. As discussed in allegation nos. 10, 11, 12, 28 and 29 the
       NRC extensively inspected formal training related to engineer, inspector and
       craft qualification to perform job related tasks.
       During a formal interview with the NRC, it was acknowledged by the alleger that
       he received the appropriate specification to which he would be working, given
       time in the office to read and understand its contents, and a period of
       on-the-job training under supervision before he was allowed to independently
       inspect work.
       CONCLUSION
       This allegation could not be substantiated. Construction orientation was
       performed by various contractors prior to initiation of the General and
       Specialty Training Department. Each contractor presented the information they
       believed was necessary for thir employees to know. Due to the various
       projects on site this inform tion varied both from content and presentation.
       However, the training was administrative in nature and not related to job
       skills which were verified by employment checks, union halls, and
       qualification tests.

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

                                                 - _ _ _ - _ _ _
                                         96

61. ALLEGATION " Fire Protection system was triggered in the control building and wires in the trenches in the floor got wet. , NRC UNDERSTANDING OF THE ALLEGATIONS 

                                                                                  i
                                                                                  '

The alleger stated that cables were wetted when the fire protection system was set off in the control building. DETAILS The NRC inspector reviewed FSAR layout drawings of the control building and determined that the control building houses the control room, computer room, north / south mechanical equipment roo,n and the cable spreading room. The cable spreading room is the only area in the control building that is provided with a zoned deluge valve fire protection system. This automatic sprinkler system provides fire protection for cable trays except for solid bottom trays with covers in the cable spreading room, cable chases, electrical tunnels, penetra- tions outside of containment and elevation 25'-0" of the primary auxiliary building. The NRC inspector reviewed APCSB 9.5-1, Appendix A, which evaluated the fire protection systems and the automatic water suppression system in the cable spreading room. No other area of the control building is provided with auto- matic water suppression. Since the alleger has not identified any specific area, referencing only the control building, it is assumed the alleger is referring to the cable spreading room water suppression system. The NRC inspector interviewed the fire protection coordinator who indicated that there have been no reports or indications that the automatic water suppression system in the cable spreading room had been tripped. 

                                                                                ,

Assuming that there was a trip and the cable had been exposed to water, material qualification documents for all safety-related cable used at Seabrook indicate the cable is qualified for service in a harsh environment, including submergence in water. CONCLUSION The allegation was not substantiated. 

                                                                 .
                                                                                    .

                                                                     _ _ _ _ _ _
                                                    97

I t 

   ( M.ARY AND CONCLUSIONS
  The inspection team identified sixty-one allegations which were ultimately
  combined into forty-seven different issues. None of the allegations were
  determined to present a nuclear safety concern. Most of the substantiated
   issues were previously identified and do not represent equipment deficiencies.

I Of the forty-seven issues that were inspected, thirteen were substantiatad in 

  that the statement made by the alleger was accurate. However, eleven of the
  thirteen were previously identified either by the NRC or the licensee and were
  documented in licensee quality assurance records, NRC inspection reports, or
  formal correspondence between the licensee and the NRC, and received the
  appropriate engineering review and disposition.
  The two issues that have been classified as substantiated and not previously
  identified are one dealing with contractor adversarial relationships and the
 'other-dealing with cleanliness in the reactor. The contractor adversarial          l
  relationship was, to some extent, known by the NRC due the corrective actions      .
  that were applied to the subcontractor to rectify the inadequate performance       l
  problems. This was conservatively classified as not previously known becaure
  of the manner in which the NRC perceived the problem, not as one involving an
  adversarial relationship but one of iaadequate performance. The relationship
  aspect of the issue resulted from the identification of the performance reroblem.
  The second issue, dealing with cleanliness in the reactor, although confirmed
  to be true, was a conscious decision approved by the licensee's engineering staff. l
  The practice of providing a lower standard of cleanliness during heavy
  construction in the reactor, and then performing a final cleaning to
  acceptable standards may be different from other nuclear power plaats, but it
  was an acceptable method.
  The allegations that were substantiated were valid observations that "something
  was wrong" at that time in the plant construction when they we.re made. This is
  supported by the fact that thirteen of the allegations were substantiated and
  that the record indicates that substantial effort was expenr;ed to correct the
  condition. However, the allegers were unable to acquire a'l of the facts
  surrounding the issue and could not be expected to have knowledge of the
  corrective actions that subsequently took place.
                              -         _ - _ _ _ _

                                                      . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .       .. .. . . .
    e
  ,

! 

                                      APPENDIX A

! I 

                                        RESUMES

l' 

      Suresh K. Chaudhary, P.E.
      Organization:   U.S. Nuclear Regulatory Commission
                      Region I, Operational Programs Section, Operations Branch                                         i

(. Title: Lead Reactor Engineer 

      Education:      Bachelor of Science in CE, University of Missouri, Rolla, Mo.

i 

                      Master of Science in CE, University of Missouri, Rolla, Mo.
                      BWR Technology, USNRC
                     -PWR Technology, USNRC

l Welding Technology & Nuclear Code, USNRC 

                      NDE Technology & Nuclear Code, USNRC                                                              !
                      Electrical Technology & Nuclear Code, USNRC                                                       I
                      Concrete Technical & Nuclear Code, Portland Cement Assoc.                                         i
                                                                       Chicago, IL/USNRC                                l

f Registered Professional Engineer 

      Experience:
      USNRC           Member of technical staff engaged in inspection, analysis,
      1985   present and evaluation of nuclear plant operating systems and

l maintenance specialist in nuclear structures, supports, l , 

                      and fluid systems.
      1982-1985       Senior Resident Inspector for construction at a two uait
                      BWR.   Responsible for resident inspection in construction
                      and preoperational tests.
      1978-1982       Member of regional technical staff engaged in inspection,
                      analysis,'and evaluation of nuclear power plant systems
                      under construction, especially, concrete and steel

J construction; modification of operating plant systems, 

                      and plant maintenance.
      1976-1978       Duration and Management of Quality Assurance program at a
                      1000 MW PWR plant under construction.
      1963-1976       Various assignments in structural design of concrete
                      structures and pavements; technical and site feasibility
                      studies; geotechnical engineering, concrete and structural
                      quality control; and project cost and scheduling controls
                      at project and/or staff engineer level.
      Over 18 years of Design, Construction, and Inspection experience in
      nuclear industry.
                                                                                          _ _ _ _ _ _ _____

Appendix A 2 Name: Edwin H. Gray Organization: U.S. Nuclear Regulatory Commission 

               Region I, Materials and Processes Section
               Engineering Branch

Title: Lead Reactor Engineer Education: B.S. Metallurgical Engineering - Drexel University,1963 Experience: (Nuclear Industry - 20 years) 1982-Present Member of NRC technical staff responsible for performing 

               periodic inspections and related investigation of power,
               test and research reactor facilities during construction,
               testing, startup and operational phases.

1980-1982 Leighton Industries - Quality Assurance Director - Responsible 

               for QA, QC Program, welding and metallurgy activities. ASME
               and Section I, IV, VIII, PP.

1978-1980 Foster Wheeler - Manager Dansville Welding Laboratory (NY) 

               Manage Lab Functions of procedure qualification, services to
               manufacturing plant in areas of welding and materials ASME
               Section I, VIII, IX, MIL Specs

1970-1978 Foster Wheeler - Weld Applications Engineer - Oversee welding 

               applications at Mountaintop Plant (PA) Products - FFTF & CRBRP
               IHX, Valves, Etc. and ASME Section I, VIII boilers and heat
               exchangers.

1963-1970 Chicago Bridge, Welding / Materials Engineer - Lab / Production 

              coverage on ASME Section III vessels, Hydorcrackers, misc.
              other welded products.

Special Qualifications: Registered Professional Engineer - Penna. 

                          Certified Welding Inspector - AWS
                          ASNT TC - la Level III - RT
                                                                                                  .
       .-          -          .       ,,- . .   .,       - __        __
                                                                            - - - - - . _ _ _ - .

, . . 

 Appendix A                               3
 Name:         Peter S. Koltay
 Organization: U. S. Nuclear Regulatory Commission
               Region I, Division of Reactor Projects

! I I 

 Title:        Senior Resident Inspector                                                         '
 Education:    B.S. Engineering Sciences
               Registered Professional Engineer
               Member of Society of Fire Protection Engineers
 Experience:   12 years of nuclear industry experience.
 1981-Present  NRC Resident Inspector and Senior Resident Inspector.
               Responsible for accomplishing the NRC Light Water Inspector
               Program at an operating pressurized water reactor facility.
               Conduct aetailed inspections of such areas as system                              l
               surveillance, maintenance, major system modifications,
               inservice inspections, fire protection refueling and outage
               activities, radiation protection and quality assurance.
 1978-1981     Reactor . Inspector, performed inspections of . fire protection
               plan at nuclear power plants; evaluated the adequacy of fire
               protection system design.
 1975-1978     Senior Engineer, responsible for incorporating fire protection
               requirements of 10 CFR 50, App. A, Criterion 3, and those of
               Branch Technical Position 9.5-1, into the design and
               construction of nuclear generating stations, including
               Waterford 3, Lucy Unit 2, WPPSS Units 3/5, and Shearon Harris
               Units 1 through 4. Provided pertinent input on the interior
               design of safety-related structures, layout of safety-related
               equipment, routing of Class IE electrical cables and separation
               of redundant protection channels.
                                                                               _ _ _ _ _ _ .

Appendix A 4 

   Ralph J. Paolino
   Organization:  U. S. Nuclear Regulatory Commission
                  Region I, Plant Systems Section, Engineering Branch
   Title:         Lead Reactor Engineer
   Education:     University of Pittsburgh
                  Electrical Engineering - 3 years
                  Nuclear Engineering - 1 year
   Experience:    (Nuclear Industry - 22 years):
   1975-Present   Member of technical staff responsible for performing
                  periodic inspections and related investigation of power,
                  test and research reactor facilities during construction,
                  testing, startup and operational phases, to:    ascertain
                  conformity with design and other criteria; observe as to
                  the adequacy of licensee's controls and provisions for
                  overall operational safety; evaluate management, organization
                  control, procedures and practices of licensees and the
                  effect on, or their relations to, the safety of operations;
                  and observe as to the status of compliance of licensees
                  with license provisions, rules, orders and regulations of
                  the commission; and verify compliance with construction
                  industry codes and standards.
   1972-1975      Corporate Staff I&C Consultant / Senior Staff Engineer for
                  Architech Engineer. Responsible for the direction / develop-
                  ment and resolution of generic /specfic issues, establishing
                  corporate policy regarding specific design, standards and
                  specifications applicable to I&C systems and safety related
                  processes for nuclear generating plants.
   1964-1972      Special Products Manager - Medical Electronics firm.
                  Responsible for the direction, development and fabrication
                  of process control equipment utilizing radiation
                  monitoring techniques including effluent and process
                  radiation monitors for nuclear generating facilities.
                                                                                l

Appendix A 5 

                                   RESUME
   Robert W. Winters
   Organization:  U. S. Nuclear Regulatory Commission
                  Region I, Quality Assurance Section, Operations Branch
   Title:         Reactor Engineer
   Education:     Bachelor Metallurgical Engineering
                  Rensselaer Polytechnic Institute
   Experience:    (Nuclear Industry - 13 Years)
   1985-Present   Member of the NRC technical staff responsible for
                  performing periodic inspections and related investigation
                  of power generating facilities during construction, testing,
                  startup and operational phases, to ascertain conformity
                  with design and other criteria; evaluate licensee manage-
                  ment controls procedures and practices as applied quality
                  assurance.
   1973-1985      Quality Assurance Specialist / Supervisor for nuclear
                  equipment manufacturer and installer. Responsible for
                  quality assurance programs, auditing performance,avelding
                  procedures and performance, vendor evaluation, and overall
                  quality performance during installations. Provided tech-
                  nical guidance to installation projects in processes and
                  welding. Interfaced with licensees, regulatory bodies and
                  industry standards groups.
   1951-1973      Various positions in aerospace, steel manufacturing,
                  non ferrous materials manufacturing, materials fabrication
                  and testing, and quality assurance.
                              ._    . - - ~   --.  ._. _ -            .-

                   APPENDIX B
               DOCUMENTS REVIEWED

UE&C Letter #SBU-98678, dated March 31, 1986, to R. J. DeLoach, YNSD Project Manager Nonconformance Report: Nos. 59-5463; 57-5068; In-Process Inspection Report IR # P-106 Station Operating Procedure IP-104, " Level I Coating of Concrete Surfaces", Rev. I through 4 Pittsburg Testing Laboratory, " Statistical Analysis- Concrete Compression Test Data" 1977-1986 American Concrete Institute Standards: ACI-211; ACI-214; ACI-301; ACI-318 Containment Concrete Placement Records: Placement Number Date 1-CS-1E-1 11/19/80 1-CS-1F-1 11/25/80 1-CS-1K-3 11/20/81 1-CS-1K-3A 12/15/81 1-CS-I LM-3 12/18/81 1-CS-1NO-3 01/06/82 1-CS-1PQ-3 01/28/82 1-CS-1RS-3 02/10/82 1-CS-1TV-3 02/24/82 1-CS-IV-3 03/04/82 1-CS-1W-3 03/10/82 1-CS-1FTC-1 02/25/83 1-CS-1 FTC-2 03/02/83 1-CS-1FTC-3 03/04/83 1-CS-1FTC-4 03/08/83 1-CS-1FTC-5 03/10/83

.r- , 

                                                                                   1
    Appendix B                                2
    Qualification of Flame Retardant Cable
    - - -
          Anaconda Certified Test Report No. 81-338-2-1
    --
          Cable Specification No. 9763-006-113-18                                  l
    --
          Franklin Institute Research Laboratory Report No. F-C4836-2 dated
          January 1,1978 and No. F-C4969 dated July 1978 with attachment No. 80282
    --
          Okonite Cable Code No. 13136H
          Receipt Inspection Report (RIR) No. 13199
          Reel NO. 24, 2/C #2
   --
          Anoconda Cable Code No. ABGM
          RIR No. 11272
          Reel No. 44, 2/C AWG 19/22
          Purchase Order No. 113-17
   --
          Okonite Cable Code No. CCGD
          RIR No. 3731,
          Reel No. 6, 3/C 250 MCM
          Purchase Order No. 113-3
   --
          Flame Test per IPCEA Publication S-66-524
          Part 6, Paragraph 6-12b
   --
          IEEE std 336-1871 requirement for inspection of cables and raceways.

 Appendix B                                 3
 NRC INSPECTION REPORTS
       50-443/82-08
       50-443/82-12
       50-443/82-16
       50-443/83-04
       50-443/83-13
       50-443/83-17
       50-443/83-22
       50-443/85-05
      50-443/85-12
      50-443/85-15
      50-443/85-20
      50-443/85-30
      50-443/86-15
      50-443/86-19
      Systematic Assessment of Licensee Performance - February 19, 1985
      Systematic Assessment of Licensee Performance - May 14, 1986
 PROCEDURES
      FGCP-1     Development and Preparation of ASME Field Construction
                 Procedures.
      TP-10      Technical Procedure for Location of Attachments to Embedded
                 Plates
      ASP-3      Nanconformances
      QA-15      Nonconforming Materials, Parts, or Components
                 Fire Protection Plan (10 CFR 50 Appendix R)
 CORRESPONDENCE
      Letter Public Service Company of New Hampshire to US Nuclear
      Regulatory Commission dated December 2, 1982, referencing Inspection
      50-443/82-12
      Fire Department report of the Johnson Controls Incorporated fire on
      December 22, 1982.
 RECORDS
      QA Record Document Review Checklist - Johnson Controls Incorporated    i
      10/13/82                                                               i
      QA Record Document Review Checklist - Johnson Controls Incorporated    ,

4 

      11/30/83                                                               l
      Training Record - Classroom Lecture and Hands On Workshop, Raychem
      High Voltage Kits, 8,3,84
  -       __   _
                                                       .

                               _ _                        -                                               ..                                              .                          . _ _. .__
,
          Appendix B                                                                                         4
          RECORDS (Continued)
              Training Records - Pullman Power Corporation, individual records
              August 1982.
              Training Records - Fischbach-Boulos-Manzi-NH - Individual records -
              February,1979 to January,1983
              Training Records - Perini Power Constructors, Inc. - November, 1981

'i , 5 i 

                                                                                                                                                                                                I
                                                                                                                                                                                                l
i
,
                                                                                                                                                                                                I
  - - - ,      - - - - - , - ,     -- . , . - . - - - - - - - , . . . - - . .. - - , _ - - - - - - . , - . - . - - - - _ - - - - - - . - , , . , - . , _ . - . . - - , , . , - , , , -

 .                                                                                                                                                                                 .
                         APPENDIX C:                  PUBLIC SERVICE Of HEW HAMPSHIRE SUBSTANCE ABUSE PROGRAM
                                                                                                                                                                                       I
                                                                                                                                                                                       i
                                              BRIEF EXPLANATION OF SEABROOK DRUG AND ALCOHOL PROGRAM
                                                                                                                                                                                    i
                   NOTE:
                                                                                                                                                                                    1
                   The following is being provided in response to your request for additional
                   information regarding the Seabrook Anti-Drug and Alcohol Abuse Program. It
                   should be noted that some of the information being provided herein is based on
                   our investigations to date and has not been finalized. This may be updated as
                   additional information is reviewed in connection with NHY's response to a
                   request for information by Representative Edward J. Markey.
                   Discussion                                                                                                                                                       ,
                                                                                                                                                                                    1
                   Seabrook Station's policy regarding alcohol and drug abuse was not established
                   because of any perceived problem at Seabrook but rather because NHY recognized
                   at the inception of construction (i.e. July, 1976) that drug and alcohol abuse
                   are problems of national proportion and that the potential for those types of
                   activities might exist within the Seabrook Station workforce. To that end,
                   throughout the construction of the plant at Seabrook, NHY had in ef fect
                   measures designed to deter the use of controlled substances and to detect
                   their presence on site. However, given the magnitude of a project such as
                   Seabrook, where in excess of 20,000 workers of varying trades labored for over
                   eleven years, notwithstanding vigorous ef forts to bar these substances, there
                   were incidents involving alcohol and controlled substances, such as marij uana.
                   As such incidents occurred, management escalated the measures to detect and
                   deter usage of drugs and alcohol. A chronological outline of the measures
                   taken is provided in Attachment A. It should be noted that measures were, of
                   course, supplemented by a f ull scale quality assurance program to ensure the
                   integrity of plant safety, so that any work by any employee involving plant
                   safety has been and will continue to be su 'tect to multi-layered review.
                   The existing drug and alcohol program consists of several major features that
                   include, but are not limited to, the following:                                               search of personnel and
                   vehicles entering and leaving the site (begun in 1980), use of dogs to search
                   vehicles, buildings and site-related areas (begun in 1981), and drug screening

l of site personnel (begun in 1986). These steps are clarified in the security 

                   procedures designed to prevent the entry of drugs or alcohol into the

, protected area and to identify drug and alcohol abusers. NRY feels the drug 

                   prevention program has been effective and is one of the best in the industry.
                   Where our security program has uncovered instances of drug and alcohol
                   possession and has identified users, appropriate measures have been taken to
                   strengthen the program and deal with the individuals in question.
                                                                                                                                                                                      !
                                                            .                                                                                                            +
   _ _ . - - - - _       __ _ _ _ _ _ _ . - ,           .__   _ _ . _ . . . , , _ - . ,_____ _ _ --__._. ,______              - . _ _ . . . . . , , , _ . . ,- - --_x--.   . - ---

                                                                                     .
                                                                                    <
 The NHY " Fitness for Duty Policy" (Directive 10.0), "Use of Cont rolled Drugs"
 (Directive 10.l), and "Use of Alcoholic Beverages" (Directive 10.2) clearly           l
 state the corporate policy that drugs and alcohol have no place at the work
 site and will not be tolerated by NHY (part of Attachment B). This ef fort has
 been ongoing and will continue to improve since Seabrook Station is committed
 to implementing the Industry Sponsored Fitness For Duty Standards and has
 worked and will continue to work with INPO, EEI, and NUMARC on the issues.
 The length to which NHY has gore to stop drug abuse at Seabrook is evidenced
 in the April-December 1979 NHY initiated undercover operation that was
 performed with the full cooperation of the New Hampshire State Police and the
 Rockingham's County Sherif f's Department . As a result of this, 12 people were
 indicted for drug sale, use, and possession on January 10, 1980 (Reference NRC
 Combined Inspection Report 40-443/80-01; 50-444/80-01)
 In regard to your question regarding details of NHY's drug / alcohol
 rehabilitation program, we of fer the following. As indicated in Attachment A,
 shortly af ter July, 1976 a voluntary program was started to of fer workers
 assistance through personal counseling. In the spring of 1979, that voluntary
 Employee Assistance Program was recognized by Seabrook Station Management for
 site employees (manual and non-manual). In 1983, NHY also implemented an EAP
 for NHY employees. These EAP programs were established to ensure anyone who
 wanted help would receive it. EAP and Station Management handle each case
 independently, but when personnel seek help, they receive it through these
 programs. Under the NHY EAP, NHY personnel are removed f rom duty and not
 allowed to ret urn to duty until they have successf ully passed chemical
 screening testing. This program is clarified in New Hampshire Yankee
 Directives 10.3 and 10.4 provided as Attachment B.
 Finally, regarding your request for more details regarding the identified
 incidents of drug / alcohol usage we of fer the following. As you requested,
 provided in Attachments C and D are the " drug / alcohol use" summaries of NHY
 investigations by record type. In Attachments C and D, we have also atterapted
 to identify the source of our information as well as the breakdowns by craft
 or trade.
 The number of documented cases of workers in non-manual positions or
 " sensitive" positions being involved or terminated are very few (the breakdown
 by craft can be seen in Attachment C). An isolated example is the QA
 Inspector working for NHY for a period of 2 months until he was detected by
 chemical screening. In this case, the OA manager ordered a reinspection of
 the individual's work by qualified QA inspectors. Since Seabrook Station has
 an extensive system of checks and balances in place to ensure that all work on
 the Project is independently checked and verified several times, the work of
 any one individual cannot compromise the Ouality Assurance System or the
 quality of construction.     In this regard it should be noted that to date no
 personnel directly employed by NHY (Operators, Maintenance Services,
 Engineering Services, etc.) have failed the chemical screening testing.

, 

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

                                                                              1
                                                                              !

Conclusion In conclusion, it can be seen that an aggressive Security program has been and continues to be in place to detect and prevent drug and alcohol abuse to the greatest extent practical. Individuals who seek help get it and those who violate the Seabrook Station drug and alcohol policy, including the Fitness For Duty Policy are terminated. This pelicy is not new and Project rules are in place and well-known. Furthermore, when one takes into consideration the number of workmen at Seabrook from 1976 to present (i.e. over 20,000 personnel), NHY does not believe that the figures represented in Attachment C substantiate the allegations set forth by ELP nor do they reflect a compromise in the quality of construction. 

                                       _

                                                                    _ _ _ _ _ _ _ - _ _ _ _ _ -
                                                                                                  i

f 

                                       ATTACMMENT A
           BRIEF CHRONOLOGICAL LOG OF SEABROOK DRUG / ALCOHOL ACTIVITIES
 July 14th, 1976      Project Rule #7 issued which prohibited the use of drugs

i 

                      and alcohol at Seabrook Station. A volunteer program                        I
                      based on Alcoholics Anonymous principles started shortly
                      af terward.

! l Spring of 1979 Employee Assistance Program (EAP) recognized by Seabrook 

                      Station management for helping employees with
                      drug / alcohol problems
             1980     Vehicle / personnel search program implemented for anyone
                      entering Seabrook Station
 May,        1981     Training of Supervision on EAP (including foremen)                          l
                                                                                                   l
 September, 1981      Construction Management began putting greater emphasis on
                      the EAP program for use by employees
 December,   1981     Implemented use of dogs to perform random drug searches
                      at the Station
             1983     NHY Employee Assistance Program established specifically
                      for NHY personnel
 January,    1985     Employee Allegations Resolution Of fice established
 March,      1986     Fitness For Duty Policy established which included
                      chemical screening, observation and training
                                                                                                k
                                    _ _ _ _ _ _

                                                                    ^=o=""
                    FOR INFORNIMION Om                                                                 a
                                                                                                        I
           4                        DIRECTIVE # 1000
                             FITNESS FOR DUTY POLICT                EFFECTIVE
      ONO                                                          03/03/86

PURPOSE: To provide the NNY Fitness for Duty Policy. The NNY Fitness for 

             Duty Program is contained in the Station Security Manual.

SCOPE: This Directive applies to all NNY personnel, contractors, or visitors 

             (e.g., inspection agencies) who are on the property that is control-
             led by NNY and known as Seabrook Station.

POLICY NHY is committed to providing a safe work environment that protects SUNMARY: the health and safety of employees and the public. The operation of 

             a nuclear plant requires that employees be trustworthy and meet
             strict job performance standards.     Public and regulatory agency
             confidence in NHY's ability to fulfill its responsibilities also
             depends on meeting such standards. Personnel performing functions
             related to the construction and operation of facilities at Seabrook
             Station must be physically and sentally fit to safely and efficiently
             perform their assigned functions.

REQUIREMENTS --------------------------------- 

                                                                                    .

GENERAL 1. All personnel at Seabrook Station shall adhere to the NHY INFORMATION: Fitness for Duty Policy. 

             2.  Violation of the Policy will result in denial of access to the
                  Protected Area, and may result in disciplinary action up to
                 and including termination of employment or denial of access to
                  Seabrook Station.
             3.  All personnel entering Seabrook Station shall be subject to
                  personal searches, vehicle searches and chemical screening.

USE OF Personnel entering Seabrook Station shall comply with DRUCS: Directive #10.1, Use of Controlled Drugs. USE OF Personnel entering Seabrook Station shall comply with , 

                                                                                                          '

ALCOHOL: Directive #10.2, Use of Alcohol. 

                                                                                                          i
                                                                                                          l

CONTINUAL NHY supervisory personnel shall receive initial and continutng ' BEHAVIOR training in Behavior Observation in order to determine the OBSERVATION: continual reliability of personnel who are authorized unescorted 

                  access to the Protected Area.                                                           )

EMPLOYEE NHY vill provide confidential assistance to NHY personnel in ASSISTANCE: dealing with drug and alcohol problems that may adversely affect 

                  job performance, in accordance with Directive #10.4, Employee
                 Assistance Program.
                 Participation in the Employee Assistance Prograo does not
                 preclude administrative action as a result of violating the                            ,
                 Fitness for Duty Policy.                                                              q
                                        .  ,,
                                                                    - ,                  - _ - . - - -

-
                                                                                      .
                                       DIRECTIVE 810.0                                l
                                  FITNESS FOR DUTT POLICY               EFFECTIVE

y g 03/03/86 

  ADMINISTRATIVE  The appropriate Vice President or Director is responsible for
  ACTION:         taking administrative action, in accordance with Directive
                  #10.3, against personnel who violate the Fitness for Duty
                  Policy.
  ACCESS TO       1.  The Station Manager shall determine who is allowed access
    THE               to the Protected Area.
  PROTECTED
    AREA:         2.  Ef fective May 1,1986, all personnel, prior to being
                      authorized unescorted access to the Protected Area, shall
                      successfully complete a chemical screenina in accordance
                      with the NHY Fitness for Duty Program.
  PROGRAM             The Vice President - Nuclear Production is responsible for:
  RESPONSIBILITY:
                      e    implementation of the Fitness for Duty Program, and
                      e   ensuring that all NHY supervisory personnel receive
                           initial and continuing training in Behavior Observation.
                                                                                        l
                                                                                        l
                                                                                        l
                                                                                        l
                                                                                        1
                                                                                        !
                                                                                        l
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                        *"
                                                                      2l2S/8d
                           E. A. Brown, President and CEO                  Date     -
                                         2 of 2
          .                   __          ___   -        -    ._.

                                                                                       i
                                                    I          I
                                                  J
                                'f
         "     #'                      DIRECTIVE #10.1
                                   USE OF CONTROLLED DRUCS                   EFFECTIVE
          lIO!                                                               03/03/86
 PURPOSE:       To provide the NNY policy regarding the use, possession, or sale of
                controlled drugs.
 SCO?E:         This Directive applies to all NNY personnel, contractors or visitors
                who are on the property that is controlled by NNY and known as
                Seabrook Station.
 POLICY:        The ille3al sale, use or possession of any controlled drug by an
                NHY employee, contractor or visitor while either at Seabrook
                Station or in an NHY vehicle or while assigned to NNY duty shall be
                cause for termination of employment or denial of access to Seabrook
                Station.
                The sale of any controlled drug by an NHY employee or contractor
                while off-duty shall be cause for suspension or termination of
                employment or denial of access to Seabrook Station.
                                                                                         1
                The illegal use of a controlled drug by an NNY employee or contractor
                while off-duty (other than any drug legally prescribed for use by the
                individual) may be cause for suspension or termination of employment
                or denial of access to Seabrook Station if such use could reasonably
                be expected to adversely af fect:
                      1.  the individual's job performance, or
                      2.  public or regulatory confidence in NHY to effectively
                          carry out its public service responsibilities.

DEFINITION: The following shall be considered to be controlled drugs: 

                      1. Amphetamines
                      2. Hallucinogenic / psychotropic drugs
                     3. Heroin and morphine-based drugs
                     4. Barbiturates
                     5. Cannabis-based drugs (e.g., marijuana, hashish, THC)

, 

                     6. Cocaine
                     7. Other controlled stimulants or depressants
                     8. Prescription drugs
                     9. Any drug for which the use, possession or sale is
                         considered to be a violation of criminal law.
                                           1 3# 1
                                    -                    - _ _   . . . _ _ ~

                                                                                     D
                                                                                         i
    Hornpshire                     01RzCT8vt #10.t
       g
                                                                                       ,
                               USE OF CONTROLLED ORUCS             EFFECTIVE
                                                                                      '
                                                                                           l
                                                                   03/03/86              rl
                                                                                           l

PRESCRIBRD An employee using a drug that has been prescribed by a licensed DRUCS: physician for personal use shall report the use of that drug to his 

             inusediate supervisor if such a drug might reasonably be expected to
             impair that employee's ability to perfore any duties of the job to
             which assigned.

SEARCH AND All personnel entering Seabrook Station may be subject to personal SCREENING search, vehicle search and chemical screening. The refusal to par- 

             ticipate in such search and screening shall be grounds for denying
             access and for suspension or tertaination of employment.
             Personnel who require unescorted access to the Protected Area shall
             successfully complete a chemical screening prior to bsing
             authorized such access,
             1aw enforcement of ficials will be notified whenever illegal drugs are
             found at Seabrook Station.
                                                                                .

EMPLOYEE NHY will provide confidential assistance to NMY personnel in dealing ASSISTANCE: with drug problems that may adversely affect job pe rformance , in 

             accordance with Dtrective #10.4, Employee Assistance Program.

OTHER CON- Supervisors are responsible for enfor:ing this policy and for SIDERATIONS: reporting to other appropriate levels of supervision any activities 

             that are prohibited herein.
                            MA-
                          E. A. Brown, President and CEO
                                                                     @c/uDate       t
                                       2 of 2

                                  1
   HQttpthG                       DIRECTIVE #10.2                                 i
        g                    USE OF ALColiOLIC BEVERACES          EFFECTIVE           ,
                                                                  03/03/86            l
                                                                                      l
                                                                                      i
PURPOSE:    To provide the NNY Policy regarding the use, possession, or sale of       f
            alcoholic beverages.                                                      l
SCOPE:      This Directive applies to all NNY personnel, contractors, or visitors
            who are on the property that is controlled by NHY and known as            I
            Seabrook Station.                                                         I
POLICY:     The sale, use, or possession of an alcoholic beverage by an NHY
            employee, contractor or visitor while either at Seabrook Station
            or  in an NHY vehicle or while assigned to NHY duty at Seabrook
            Station shall be cause for suspension or terisination of employment,
            or denial of access to Seabrook Station.
           The use of an alcoholic beverage by an NHY employee or contractor
           while of f-duty may be cause for suspension or termination of
            employment or denial of access to Seabrook Station if such use could
            reasonably be expected to adversely affect:
                                                                             .
                   1. the individual's job performance, or
                   2. public or regulatory confidence in NHY to ef fectively
                  *
                      carry out its public service responsibilities.

DEFINITION: The following shall be considered alcoholic beverages: 

                   1. Distilled and rectified spirits
                  2.  Wines
                  3.  Fermented and malt liquors and ciders
                  4   Beer, lager beer, ale, porter, stout
                  5.  Any other liquid containing one percent or more of
                      alcohol by volume and not more than six percent of
                      alcohol by volume at 60* Fahrenheit.

EMPLOYEE NHY will provide confidential assistance to NHY personnel in dealing ASSISTANCE: with alcohol problems that may adversely af fect job performance in 

           accordance with Directive #10.4, Employee Assistance Program.

SEARCH All personnel entering Seabrook Station shall be subject to AND personal search, vehicle search and chemical screening. The SCREENING: refusal to participate in such search and screening shall be 

           grounds for denying access and for suspension or termination
           of employment.
           Personnel who request unescorted access to the Protected Area
           shall successfully complete a chemical screening prior'to being
           authorized such access.
                                                                                    l
                                                                                    t
                                                                                    l
                                     ._

                                                                                                     ;
                                                                                                   ?,
                                                                                                    i
                                                                                                    l

r 

                     Hampshire                   oIazCTIvt #10.2                                    j'
                       g                   USE OF ALCOBOLIC BEYERActs           EFFECTIV             1
                                                                                03/03/86

, 

             OTHER CON-      Supervisors are responsible for enforcing this policy and for
              SIDERATIONS: reporting to other appropriate levels of supervision any activities
                             that are prohibited herein.
                                                                                            .

I 

                                                       W                             Wlpg           ,
                                                                                                 i'
                                        E. A. Brown, President and CEO                 Date         i
                                                    9 ,a 9
 . . _ _ . . , , . _                                               .                   _       _

                                                             l
            mpshire                              DIRECTIVE #10.3
            g                   FITNESS FOR DUTY: ADMIN!STRATIVE ACTION           EFFECTIVE
                                                                                  03/03/86
                                                                                               l

PURPOSE: To provide the NNY Policy concerning the Administrative Actions that 

                   will be taken when an individual violates the Fitness for Duty              i
                    Policy.

SCOPE: This Directive applies to all NHY personnel, contractors or visitors 

                   who are on the property that is controlled by NHY and known as
                    Seabrook Station.

TESTINC: Drug testing shall be performed during all pre-employment and annual 

                    physicals and prior to the .g ' anting of unescorted access to the
                   Protected Area.
                   Drug testing may be performed randomly on any individual at
                   Seabrook Station in accordance with the Fitness for Duty Program.
                   Drug or alcohol testing may be performed for cause anytime an
                    individual is suspected of being under the influence of alcohol.or
                                                                                         *
                    involved with illegal drugs.
                   Individuals have the right to re fuse to submit to drug or alcohol
                   testing.       Refusal to take either a drug or alcohol test shall result
                    in the same Administrative Action as a test failure.
                          e    Drug Testing - A positive drug confirmation requires that
                               both an Enzyme Multiplied Immunoassay Technique (EMIT) test
                               and a Cas Chromotography/ Mass Spectroscopy (CS/MS) test
                               confirm a value that exceeds the Fitness for Duty Program
                               limits provided in the Station Security Manual,
                          e    Alcohol Testing - A positive alcohol confirmation requires
                               that a blood analysis confirms a value that exceeds the
                               Fitness for Duty Program limits provided in the Station
                               Security Manual.

ACTION: 1. Sale, Use or Possession of Alcohol or Drugs 

                                          at Seabrook Station
                   Visitors who sell, use or possess alcohol or drugs shall be immediate-
                   ly escorted from Seabrook Station.
                   When a NHY or contractor employee sells, uses or possesses alcohol or
                   drugs at Seabrook Station, the appropriate Vice President / Director
                   shall immediately:
                          e suspend a NHY employee without pay, or
                          e    inform the senior contractor personnel on site to
                               remove the contractor employee from Seabrook Station.
                                                    1 of 2
    ___ -__             _    _
                                     _ -.        _    __.      ..
                                                                  .      - . - .            __

                                                                                                !
                                                                                                tl ,
        pahire                                DIRECTIVE #10.3
                                                                                               {l
       g                        FITNESS FCE DUTY: ADMINISTRATIVE ACTION           gFFECTIVE
                                                                                                !l
                                                                                 03/03/86
                                                                                                '
                                                                                                   1

ACTION: 2. Pre-Esployment Testina 

               Any individual showing positive on a drug or alcohol test shall not
               be hired by NNY or by contractors.                                                  I
                                                                                                  i
               3.   Initial, Periodie, Randos or "For Cause" Drun or Alcohol Testing
                                                                                                  1
               (These actions are illustrated in Figure 1)                                        J
                                                                                                  ,
               When any individual fails a drug or alcohol test, the appropriate
               Vice President / Director shall immediately:
                     e suspend a NHY employee without pay, or
                     e inform the senior contractor personnel on site to remove
                             the contractor employee from to Seabrook Station.
               4.   NHY Employees
               NHY employees violating the NHY Use of Alcohol Policy shall be referred
               to the Employee Assistance Program and may be returned to duty at the
               discretion of the appropriate Vice President / Director.
               NHY employees who fail the drug testing shall be referred to the Es-
               ployee Assistance Program and shall undergo retesting within 7 days
               of the suspension and, if necessary, at 14 and 21 days. An individual
               passing the tests at one of these intervals may return to work at the
               discretion of the appropriate Vice President / Director with the know-
               ledge that a 3 year randos drug testing program will be imposed. Failure
               of the tests at the 7, 14, and 21 day intervals shall be cause for ter-
               aination of employment at the discretion of the appropriate Vice
               President or Director.
               A second violation of the Fitness for Duty Policy shall result in
               tarmination of employment.
               5.   Contractor Employees
               A contractor employee who violates the NHY Use of Alcohol Policy may
               return to work at the discretion of the appropriate Vice President /
               Director after a 30 day suspension.
               A contractor employee who violates the NHY Use of Controlled Drugs
               Policy may return to work at the discretion of the appropriate Vice
               President / Director af ter a 30 day suspension and satisfactory completion
               of the drug testing.        Such individuals will be subject to a 3 year ran-
               dom drug testing program.
               A second violation of the Fitness for Duty Policy will result in the
               individual being denied access to Seabrook Station.
                                                                               A      V/ .5'd
                                  E. A. Brown, President and CEO                     Date     f

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

                                                                                                                                                                        .
                                                                                                                                                                      t
                                                        DIRECTIVE #1003
              .
                                   FITNESS FOR 00TY: ADMINISTRATIVE ACTION                                                                              EFFICTIVE
              IM                                                                                                                                                      h
                                                                                                                                                        03/03/86      i

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                                                                   ,     i
                                          p
                                                          DIRECTIVE #1004
                     pahire                        EMPLOYEE ASSISTANCE PROC W                               gTFECTIVE
                                                                                                             03/03/86
 PURPOSE:                            To establish the NWY Employee Assistance Progree and infora
                                      employees of the help that it can provide in resolving personal
                                      problems.
 SCOPE:                              The Employee Assistance Progree is committed to helping any
                                      employee of NHY or a member of an NNY employee's immediate
                                      family who desires help in dealing with:
                                            e emotional or mental distress,
                                            e alcohol or drug problems,
                                            e marital or family dif ficulties , and
                                            e    financial or other personal problems.
 PARTICIPATION:                      Participation in the Employee Assistance Program is voluntary.
                                     All requests and referrals are held in strict confidence.                                          An
                                     employee's job security and opportunities for promotion are not
                                     jeopardized by these requests and referrals.
                                     Employees who are having difficulties coping with a persona'l
                                     problem or troubled situation are encouraged to use this
                                     program.
                                     The Employee Assistance Program provides initial probles
                                     assessment end subsequent referral to appropriate counseling
                                     and professional services. Locations and time of appointments

' 

                                     will be made in accordance with the employee's schedule and
                                     needs.
                                     When the employee health care program does not cover the
                                     service, employees will be referred, whenever possible, to
                                     services that can be paid for on a sliding fee scale.
                                     NHY employees may make an appointment with the Employee
                                     Assistance Program Administrator by calling 83-2565 or
                                     622-3842.      The latter phone number can accomodate a confiden-
                                     tial message 24 hours a day.
 RESPONSIBILITY:                     The Director of '4anagemment Control is responsible for ensuring
                                     that all NHY employees are made aware of the Employee Assistance
                                     Program and to periodically evaluate the Program to ensure that
                                     tt is responstve to employee needs.
                                                                                                                                           !
                                                WW
                                                                                                                                           f
                                                E. A. Brown, President and CEO
                                                                                                            a/.w/x                  Date
                                                                                                                                           l
                                                                                                                                           '
                                                                     i , , .
     . _ _ . . _ _ _       _ _ _ . -          _
                                                           _ _ . .         _ _ _ _ _ . _ _ _ __ . _ _ _ ___   _ _ _ _ _ - . _ _ . _ _ .    -

                                      ATTACHMENT C
                                                                                     '
                         Types Of P7rs'n*71 And Medien! Rec"rds                         l-
                                                                                        I
                       Reviewed And Statistics Associated Thereof
                                                                                        l.
                                                                  Records That Contain
                                                 Total Records       References To
                                                     Reviewed       Drums Or Alcohol    <

1. UE&C files on manual employees (crafts- 

  men) that were determined ineligible for
  rehire covering the period 1978 thru
  1983. Although only UE&C subcontractors
  hired craftsmen during this period, the
  files encompass the total population of
  craf tsmen determined ineligible for
  rehire based on circumstances of termi-                                          *
  nation through end of 1983.                          716               117

2. UE&C files on terminated manual employees 

  covering the period 1984 to present. At
  the start of this time period, all sub-
  contractors to UE&C were eliminated and
  UEEC assumed the hiring, payroll and
  records responsibilities                            6800                26
                                                 (includes
                                                 "rampdowns" in
                                                 site craftsmen)
  NOTE:    Record types 1 and 2 above include all manual labor used on the
           site from 1978 to present with the exception of lump sum contracts
           labor, which although small in terms of overall numbers, could not
           be estimated in the time available.

3. 1986 chemical screening process failures 

  which resulted in denial of access to
  Unit I protected areas                               $300               136

4. UE&C non-manual files (supervisors, QA/QC 

  personnel, engineers, etc.) covering the
  period since onset of site work (7/14/76)
  thru present.    These files do not include
  non-manuals associated with UE&C subcon-
  tractors for the 1976 through 1983 time
  periad. Those records are the property
  of tt.e various subcontractors and are not
  available to NHY.                                   3400                 10
                                                 (includes        (1 rehabilitated
                                                 "rampdowns" in   and rehired)
                                                                                       I
                                                 site workforce)

                                                 2
                            Types Of Personnel And Medical Records
                          Reviewed And Statistics Associated Thereof
                                                                     Records That Contain
                                                     Total Records     References To
                                                        Reviewed      Druas Or Alcohol

50 Medical records associated with 

   Workman's Compensation Claim files
   covering the time period of 1976 thru
   present. This review encompassed all
   individuals that reported to the site
   (UE&C) first-sid station and were
   referred to any off-site medical
   practice or facility. UE&C handled
   all non-PSNH Workman's Compensation
   related insurance carrier claims
   throughout this period.                               10,607              44

NOTE: Further broken down the 44 Workman's Compensation case files, that 

        involved mention of drugs or alcohol, many of which are unsubstan-
        tiated by objective medical testing, appear as follows:
  a.) Exeter Area Hospital Emergency
         Room Reporte                                                         8
            (Note: These are the 8 instances referred to by
                     Mr. E. A. Brown on 11/7/86 and represent
                     the full extent of NHY investigation as
                     of that date.)
  b.) Notes, by various attending physicians
         in Workman's Compensation Follow-Up
         Reports                                                              5
  c.) Exeter Clinic progress reports same
         day as site-related injury                                           3
  d.)    Exeter Clinic progress reports one
         or more days after the site-related
         injury                                                               4
  e.) Notes in UE&C investigation reports
         (UE&C conducted a backup investigation
         for all 10,607 Workman's Compensation
         Claims)                                                              7
  f.)    Individuals terminated due to events
         unassociated with the on-going and
         incomplete Workman's Compensation
         Claim (all for violation of Project
         Rule #7)                                                             3
  3.) Records of testimony:        New Hampshire
         Department Of Labor Decisions                                        3           j ;

                                                                                                       3
                                                            Types Of Personnel And Medical Records
                                                          Reviewed And Statistics Associated Thereof
                                                                                                                            Records That Contain
                                                                                                              Total Records    References To       i
                                                                                                                 Reviewed     Drugs Or Alcohol
       h.) Notes made by attending physicians
            that made reference to the injured
            employee's previous medical history
            which, although not directly related
            to the injury, established historical
            reference                                                                                                               11
                                                        Total Workman's Compensation                                            -
                                                        Files That Involved Mention Of
                                                        Drug Or Alcohol                                                             44
                                                                                                                                                   I
        The 44 case files conservatively represent less than 0.25% of the
        total on-site workforce (greater than 20,000 individuals) over the
        1976 to present time frame.
                      .                                                    .
                                                       44    x 100 = 0.22%
                                       20,000
                      _                                                    ..
                                                                                                                                                  $
                                                                                                                                                  $
                                                                                                                                                  1
                                                                                                                                                  l
                                                                                                                                                 n
                                                                                                                                                 J
                    -                                                                                                                             \

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

 -    __ __-_             _ _ _ _ - _ _ - -
                                                                                i
                                                                                I
                                                   ATTACHMENT D
   Craft / Trade Breakdown                                                      b
   h Inettatble for Rehire files
                                                                                4
              Painters                           1                              el   i
              Carpenters                       22                               .

[ Laborers 32 l' > Iron Workers 32 

              Pipe fitters                     15                                  l
              Electricians                      9
              Machine Operators                 4
              Truck Drivers                     2
                                                                                l-
                                        Total 117
                                                                                   'I
   E UE&C Manual Workers Termination                                           ,
              Painters                          4
              Carpenters                        4
              Laborers                          5
              Ircn Workers                      2
              Pipe fitters                      5
              Insulators                        3
              Electricians                      1
              Welders                           I
                                                                                     l
              Surveyors                         1
                                      Total    26                              ,
                                                                               't
                                                                                  I
   $ UE&C Non-Manual Terminations
              Clerical                          3                                 l
              Safety                            1                                 ,
              Drafter                           1                                 !
              QA Engineer                       2
              Craft Supv.                       1
              Engineer *                        2
                                                                               i
                                     Total     10
              *   I of fice Engineer underwent rehabilitation and was rehired.

}}

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