IR 05000443/1986099: Difference between revisions

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{{Adams
{{Adams
| number = ML20198R787
| number = ML20236E375
| issue date = 06/05/1986
| issue date = 10/26/1987
| title = SALP Rept 50-443/86-99 for Jan 1985 - Mar 1986
| title = SALP Rept 50-443/86-99 for Apr 1986 - Jul 1987
| author name =  
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
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| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-443-86-99, NUDOCS 8606100210
| document report number = 50-443-86-99-01, 50-443-86-99-1, NUDOCS 8710290195
| package number = ML20198R772
| package number = ML20236E244
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 42
| page count = 55
}}
}}


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U.S. NUCLEAR REGULATORY COMMISSION
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U.S,; NUCLEAR REGULATORY COMMISSION.
 
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==REGION I==
==REGION I==
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-443/86-99 PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE SEABROOK STATION, UNIT 1 ASSESSMENT PERIOD: JANUARY 1,1985 - MARCH 31, 1986 BOARD MEETING DATE:
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MAY 14, 1986 8606100210 860605 3 ADOCK 0500 gDR t
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SYSTEMATIC ASSESSMENT OF LICENSEE' PERFORMANCE INSPECTION REPORT NUMBER 86-99 J
PUBLIC SERVICE COMPANY 0F NEW HAMPSHIRE g
SEABROOK STATION, UNIT 1 -!
ASSESSMENT PERIOD: . APRIL 1,'1986 - JULY 31, 1987
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BOARD. MEETING DATE: SEPTEMBER 17 AND.0CTOBER 2, 1987  i
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l SUMMARY TABLE 3 - ENFORCEMENT DATA i
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l l INTRODUCTION 1 Purpose and Overview   l l
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The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this in-formation. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operatio An NRC SALP Board, composed of the staff members listed below, met on May 14, 1986 to review the collection of performance observations and data and to assess the licensee performance in accordance with the guid-ance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Per-formance". A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's performance at the Seabrook Station for the period January 1, 1985 through March 31, 1986. This SALP differs significantly from previous Seabrook Station assessments. For the entire assessment period, Unit 2 has been in an
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  " indeterminate" status with licensee work confined to preventive main-tenance, preservation and protection activities and the construction completion required to support Unit 1 operatio Therefore, licensee performance related to Seabrook Unit 2 has not been assessed, although some inspection (See fiote in Table 2) has been performed of licensee efforts with regard to Unit Also, construction related activities have been combined into one functional area with emphasis not so much on the individual disciplines, but more upon constuction completion and readiness for operation. New functional areas were added to address other plant operations and readiness aspects of licensee performanc SALP Board:
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Chairman:
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W. F. Kane, Deputy Director, Division of Reactor Projects (DRP)
PDR ADOCK 05000443 G PDR
Board Members T. Martin, Director, Division of Radiation Safety and Safeguards (DRSS)
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S. Ebneter, Director, Division of Reactor Safety (DRS)
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E. Wenzinger, Chief, Projects Branch No. 3. DRP T. Elsasser, Chief, Reactor Projects Section 3C, DRP V. Nerses, Project Manager, PWR Project Directorate 5, NRR A. Cerne, Senior Resident Inspector


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Other Attendees W. V. Johnston, Deputy Director, DRS J. R. Johnson, Chief, Operational Programs Branch, DRS W. J. Lazarus, Senior EP Specialist, DRSS J. R. McFadden, Radiation Specialist, DRSS D. Ruscitto, Resident Inspector M. M. Shanbaky, Chief, Facilities Radiation Protection Section, DRSS R. W. Starostecki, Director, ORP (Part Time)
4 SUMMARY OF RESULTS    I .0verall Summary:
C. Background Public Service Company of New Hampshire (PSNH) applied for a license to construct and operate the Seabrook Station (DNs 50-443 and 50-444) on July 9,1973, and was issued Construction Permits (CPPR-135 and CPPR-136)
During this assessment period, a major transition occurred as con-struction' and preoperational testing were completed, Land startup .
on July 7,1976. Each reactor is a Westinghouse four-loop, PWR rated at 1198 MWe and is housed in a reinforced concrete containment structur The units are arranged using a " slide-along" concept with certain struc-tures common to both units. PSNH has contracted with the Yankee Atomic Electric Company (YAEC) for services which include project administra-tion, facility design control, construction coordination, quality assur-ance, and licensin For the purpose of this report, these YAEC services are considered synonymous with PSNH activitie On June 23, 1984 the New Hampshire Yankee Division (NHY) of PSNH was created with the primary responsibility for construction of Seabrook Station. While some of the organizational interfaces and responsibili-ties between PSNH and YAEC have been restructured to accommodate the formation of NHY, at this time, PSNH continues to retain overall re-sponsibility for all activities related to Seabrook, as is specified in the Construction Permits. Proposed organizational changes seeking to name the New Hampshire Yankee Electric Corporation (i.e., NHY incorporated and separated from PSNH) as the new managing agent for Seabrook Station have not yet been effected. Thus, use of the generic term (" licensee")
testing and ~ operations under the technical specifications (TS)' and: '
in this SALP currently constitutes recognition of not only the ultimate responsibility of PSNH, but also the specific dutie's of both NHY and vAE Licensee Activities At the beginning of this SALP assessment period, the licensee pro-jected Unit 1 construction to be 83'. complete. The site work force, still building up from the 1984 work suspension, numbered about 2500 personnel, 1400 of whom were craft. As construction continued, priorities were directed to the support of preoperational testing and the completion of major milestone activitie In this regard, major testing progressed through the period with the conduct of the Reactor Coolant System Hydrostatic Test in April, 1985; Hot Func-tional testing during November, 1985; and Engineered Safety Features
license conditions- commenced. Throughout this transitional period,
  .the licensee's commitment.to quality, along with its safety-conscious
  ' attitude: 'and - management support of quality ' assurance '(QA) initia- !
  -tives, has been maintained. It is noted that . some .of the functional- '
areas are being evaluated for the first time. In- certain of 'these '
areas, the station ~and its personnel may not have- been significantly i challenged due to plant conditions and license limitations. In all a, cases, assessments are made based upon program adequacy and . observed i
  ' performance. .However, in those areas where activities were limited,
  .such performance may not be truly indicative of station response .to future, more challenging events and situations. During this assess-ment period, t.he licensee demonstrated the ability to conduct limited operations along with a state of readiness for future, more expansive
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operational activitie .
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Some transitional problems' nave been experienced during this assess- ;
merit period. Both .the programmatic and organizational interfaces :
between the Seabrook Station staff and the New Hampshire JYankee  !
engineering and quality assurance ' groups required clarification. The operations QA program, while implemented properly from a compliance standpoint, did - not ' evidence. total E effectiveness with respect to causal analysis of identified operational problems or the evaluation of related generic weaknesses. Also, plant cperations and startup testing activities were somewhat negatively impacted by divergent requirements to conduct system testing and to . troubleshoot problems, while. at the time adhering to the TS and 'special conditions pre-scribed by 'the zero power license. Likewise, new reporting require-ments (e.g., licensee event reports) were exercised based primarily on legal interpretations, rather than normal operating condition The shutdown plant conditions and lack of radiological activity -did not provide the realistic bases for such notification As an example, during the one emergency event classified during this SALP period, there were interpretation problems as to whether the plant's nonradiological status warranted declaration of an Unusual Event with its attendant notifications.


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Notwithstanding these difficulties, the licensee's establishment of a new program of controls, which is operationally based, has been effective. Construction completion has resulted in quality hardware, which is being, maintained at the same leve Similarly, the licensee's approach to component problems and testing anomalies reflects the same comprehensive attitude toward corrective action that was evident during construction. Management attention to plant readiness and independent, internal review of plant performance
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testing, Loss of Offsite Power testing and the Containment Struc-tural Integrity and Integrated Leak Rate testing in early 198 Additionally, six plant buildings were completed and turned over to the control of the plant staf By the end of the assessment period, only 3% of the plant systems remained in a construction status awaiting turnover to the startup test staf The remaining construction work, not yet substantially complete, includes insulation and fire sealant installation, paint-ing, activities in support of the remaining preoperational testing, building turnover, and design modification rewor Preservice in-spection, ASME Code stamping, and piping and pipe support stress reconciliation programs are also continuing. The construction work force, as of March 31, 1986 was approximately 3500 personnel, about 2200 of whom were craft. The licensee estimates Unit 1 to be 98%
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complet Other licensee activities during this SALP period included continued operator licensing, emergency preparedness, and operational readiness planning and program reviews. New fuel was initially received on site in February, 1986 and an Emergency Orill, exercising NRC, the State of New Hampshire and licensee response, was also conducted in February, 1986. As of March 31, 1986, a station staff in excess of 500 personnel, in addition to a New Hampshire Yankee corporate staff, were in residence at the Seabrook sit The licensee projects a Fuel Load Date (FLD) of June 30, 1986 for Seabrook Unit b. Inspection Activities Two NRC resident inspectors were assigned throughout the assessment period with a third inspector assigned on site since May, 198 A total of 53 inspections were performed with 7912 hours dedicated to the inspection of Unit 1 activities. This corresponds to 6330 hours on an annualized basis. An additional twelve hours were utilized to confirm licensee preventive maintenance, preservation and protection efforts on Unit NRC inspections conducted during this SALP period are functionally categorized below, with the five types of team inspections listed separately by their unique scop Region e !_ Specialist __ Inspections Number Construction  8 Preoperational Testing  15 Fire Protection  2 Operational Readiness  4 Radiological Controls  3 Security  3 Emergent.y Preparedness (EP)  1
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While the'overall. transition from construction to. operations.has pro-ceeded in a relatively smooth manner,;the latter part of this curren assessment period pr_ovided some evidence ~of the future. problems which might be encountered. The PCCW heat exchanger problems.. discussed
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  'in Section:IV.G of this report,. represent an example of the. componen degradation which may result, in part, from lack of . system; operatio This type' of concern could become even more troublesome if: Mode.- 5-
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operations -continue for a long period of time. Licensee preplanning in the areas of water chemistry control, surveillance and maintenance '
activities, which have been evaluated as ' subcategories of- the appro-priate functional areas in this SALP, will .become even more important for . equipment preservation during prolonged periods o shutdown conditions. In the past, licensee responsiveness to problematic d issues and~ NRC initiatives has been appropriately di'rected. In ~ the j future, even more aggressive and innovative corporate management b
  : involvement may be necessary to sustain the same high ' level' of j performance,    j B_ackground Licensee Activities Over the course of this SALP period, major changes in both the scope-and organization of plant activities occurred -- as con'struction was completed and operations commenced. On April 1, 1986.a construction work ' force. of approximately 3500 personnel was still on .' site as pre-operational testing, building turnover and . final support system in-stallation activ ties were ongoing. In the ensuing months, construc--


Operator Licensing  2 Resident Inspections  9 Team Inspections Management Reorganization  1 NDE Independent Measurements  1 EP Appraisal  2 Safe Shutdown (Appendix R) 1 As-Built Plant  1 The nine resident inspections noted above represent continuous on-site coverage of licensee activities throughout this assessment period. A distribution of inspection hours, by functional area is shown in Table Enforcement data, resulting from these inspection activities, are summari:ed in Table This report also discusses the " Assurance of Quality" as a separate functional area. Although this topic is assessed in the other func-tional areas as one of the evaluation criteria, discussion of this ar 1 separately provides a synopsis. For example, quality assurance effectiveness has been assessed on a day-to-day basis by resident inspectors and as an integral aspect of specialist inspection Although quality work is the responsibility of every employee, one of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. These and other major factors that influence quality, such as involvement of first-line supervision, safety committees and worker attitudes, are discussed in each area, c. Other Activities An NRC Caseload Forecast Panel visit to Seabrook was conducted on September 4-5, 1985 to assess the status of Unit 1 constructio Their review found the June 30, 1986 fuel load date (FLD) to be reasonable, but recognized that funding and schedular uncertainties, known to exist at that time, made the achievement of fuel load dur-ing the third quarter of CY 1986 more likel It is noted that subsequent to the Caseload Forecast Panel visit to Seabrook, the joint owners of Seabrook Station voted to authorize full-construction funding and proceed with all scheduled construc-tion activities, effective October 1, 198 The EPA permit, granting final approval for use of the ocean cooling tunnels, became effective August 25,198 Testing of the circulat-Ing water system commenced that same da s
tion was effectively completed and the licensee filed a motion pur-suant to 10 CFR 50.57(c) before. the ASLB on August 22, 1986, seeking authorization to load fuel and conduct precriticality testin On October 17, 1986, a1 Facility Operating License was issued for Seabrook Station Unit Specific license conditions limited activ-ities to "zero power" operation and preci aicality testing, but did allow the licensee to load fuel and conduct hot operations in Mode 3 in accordance with the Technical Specifications. Initial fuel load was conducted during the period October 22 to 29, 1986, i
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Plant heat-up for the conduct of the precritical phase of hot func-tional testing (HFT) commenced on February 9,1987. Over the follow-ing six weeks, startup testing activities were in progress with the
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plant achieving normal operating temperature and pressure conditions L  and with the conduct of operations in accordance with Technical o
Specifications and special license conditions. Post noticeable among


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The NRC Special Nuclear Materials License No. SNM-1963 (Docket N ), authorizing the receipt, possession, inspection and stor-age of fuel assemblies and other radioactive materials for eventual use at Seabrook Unit 1, was issued on December 19, 198 Initial fuel receipt and storage on site, in accordance with the provisions of the 10CFR70 license, commenced in Febraury,198 A Prehearing Conference for the EP phase of the ASLB hearings was conducted in Portsmouth, New Hampshire on March 25-26,1986. In accordance with the ASLB Memorandum and Order, dated January 17, 1936, the hearings for New Hampshire Offsite Emergency Planning Contentions are scheduled to commence on July 21, 198 The " Proof & Review" edition of the Seabrook Technical Specifica-tions (TS) was issued for comment in late March,1986. The licen-see, Region I and the Office of NRR are currently involved in re-view activities for TS conformance to FSAR commitments, plant-specific as-built conditions, and operational safety consideration .
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II. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in the construction, preoperational, or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic area Special areas may be added to highlight significant observation The following evaluation criteria, where appropriate, were used to assess each functional are . Management involvement and control in assuring qualit . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Reporting and analysis of reportable event . Staffing (including management). Training and qualification effe:tivenes Based upon the SALP Board assessment each functional area evaluated is clas-sified into one of three performance categorie Tne definitions of these performance categories are:
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Category Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety is being achieve Category 2. NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety is being achieve Category Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety is being achieve The SALP Board also assessed each functional area to compare the licensee's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend for each functional area. The trend categories t. sed by the SALP Board are as follows:
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Improving: Licensee performance has generally improved over the last quarter of the current SALP assessment perio Consistent: Licensse performance has remained essentially constant over the last quarter of the current SALP assessment perio Declining: Licensee performance has generally declined over the last quarter of the current SALP assessment perio Notwithstanding the allowance permitted by a Category 1 rating to reduce NRC attention, NRC oversight at Seabrook Station will be maintained at a high level if a low power license is issue Due to the nature and scope of acti-vities conducted during low power testing and power ascension, it is NRC policy that close scrutiny be provided for- the first two years of operatio Subsequent SALP evaluation will therefore be done on a 12 month frequency ir-respective of the good performance noted in this repor _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _
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the routine operational activities and events which occurred during i this period. were the declaration of an Unusual Event on February 11, '
1987 based upon commencement of a plant cool-down from Mode 4 to com-ply with a Technical Specification related to containment air lock !
operability; and a steam generator safety valve actuation on February 26,1987, ' as a result of emergency feedwater (EFW) system testing. The conduct of specific tests on the steam-driven EFW pump itself was one of the more significant areas of testing during HFT, because major design modifications had been implemented for this system since the previous HFT in December, 1985. Plant cool-down-from hot operations was initiated on March 19, 1987 and the plant has remained in Mode 5 through the remainder of this SALP perio Since the completion of HFT activities, the licensee has initiated )
some extensive maintenance activities. These include the inspection, .l baffle repair, and tube plugging and sleeving operations on a primary l component cooling water heat exchanger; and the inspection, l i r.i ng j configuration redesign, and - lining repair and testing on several  i service water valves. As of the end of this assessment period, these repair activities were continuing with additional heat exchangers yet '{g to be inspected and additional valves yet to be reline i Completion of this maintenance, along with the associated, routine  '
operational surveillance activities,- are scheduled for a November, 1987 time frame to support heat-up, initial criticality and further testing, if a low power license is issued to Seabrook, Unit 1. In anticipation of license issuance and in response to the Commission's Memorandum and Order (CLI-87-03), the licensee has committed resources to several emergency preparedness (EP) activities. In addi-tion to working with New Hampshire to improve the state emergency response plan, which is the subject of ASLB hearings scheduled to commence in October, 1987,'the licensee is formulating a utility plan with the stated capability to compensate for Massachusetts emergency ]
response functions. Submission of this plan to the NRC in September i has received priority attention along with the conduct of other  j licensee EP activities required to meet the criteria provided by  ;
CLI-87-03 for issuance of a low power operating licens l Inspection Activities Two NRC resident inspectors were assigned to the site during the  j assessment period. The NRC inspections are summarized in Table 1 and  i represent an inspection effort of 6972 hours (5226 hours calculated
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on an annual basis) with the total inspection hours distributed in the various functional areas, as shown in Table I Special inspections were conducted of the compatibility between the plant and the facility Technical Specifications (May, 1986); in re-sponse to the Unusual Event (February, 1987); and in three follow-up inspections of allegations raised regarding construction quality and the as-built conditions of the plant (October,1986; November, 1986;
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III. SUMMARY OF RESULTS
, Overall Facility Evaluatri_on e
During this assessment period, the licensee's overall performance re-flected not only a commitment to safety and quality construction, but also evidence of effective planning and conduct of activities directed
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toward fuel load and safe operations thereafter. The inspection effort
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during this period was far in excess of that of previous SALP period An evaluaticn of a broad spectrum of licensee activities was necessary because of the nature of ongoing construction completion, preoperational
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testing, and operational preparedness activities. Hardware quality has been found to be in conformance with design requirements and system in-stallation has met licensing commitments. The preoperational test pro-gram has confirmed the existence of quality construction'with generally
,  outstanding test r3sults and minimal number of test exceptions. In al-a most all! cases, a high level of performance was achieved with evidence of effective planning for those areas where program implementation could not yet be fully assessed. Management attention continued to be focused
;  on improving those areas identified in the previous SALP period as poten-tial problems. As a result, only minor problems were observed during i  the period.
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Regsrding operational preparedness, thorough planning and a high level of management attention to the readiness of plant hardware, programs, a'nd procedures are very' much in evidence. Licensed operator training and the preparation and receipt of new fuel are noteworthy examples of the effectiveness of the licensee's programs. Also, the licensee's de-velopment of the security program represents effective management plan-ning to integrate ekperienced staff supervisors with a trained contract i  security forc In summary,'where operational programs have been imple-mented, the quality exhibited during construction appears to have carried oser during the transition pro ~ cess from construction into operation While licinsee responsiveness to op'erational issues has been appropri-ately directed, it should be noted that these programs are still under developmen Future inspection and assessment of the full program im-plementation will provide an ongoing mea'sure of their effectivenes At Seabrook Unit I now enters a new phase of program development, im-
;  plementation, and work priorities, this oVerall facility evaluation should be considered both a positive reflection of past licensee per-
,  formance, as well as an indicator of licensee potential for continued performance at a high level during the operational phas eY I
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   ' and April-May, :1987). An Emergency Plan Implementation -l Apprais'al . '
 
follow-up kinspection was also conducted in June, 1986. Seven en-forcementoa6tions, including a Severity Level IV violation ,resulting from -. follow-up. inspection of. the Unusual Event, were issued. The violations iss'ued during this' SALP period are tabulated in. Table o It is = noted. that construction was L completed during this SALP. period-and ~ NRC inspections of the various ' technical disciplines were con--
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ducted, as necessary, to examine' final- construction activities; Al-legations 'regarding construction quality were also received .during i this assessment period af ter construction of the plant- was .essen-
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tial.ly~ complete.- In order to objectively. ' address 'these allegations,'
9 Facility Performanco CATEGORY CATEGORY LAST THIS PERIOD PERIOD (7/1/83- (1/1/85- RECENT FUNCTIONAL AREA  12/31/84) 3/31/86) TREND *
over.1100 hours of additional inspection were expended to investigat the stated concerns. -Section V. A of this report' generally discusses -
Construction  2 1 Consistent Preoperational Testing  1 1 Consistent Fire Protection and Housekeeping N/A 1 Consistent Operational Readiness N/A 1 Consistent Emergency Preparedness N/A 2 Improving Assurance of Quality 1 1 Consistent (See Trend at the end of Section IV.F)
the Investigation and Allegation Review conducted during this SAL ,
Licensing  2 1 Consistent
The: expenditure of this large inspection effort into the several con-struction disciplines and areas of as-built quality has resulted in a i reaffirmation 'of the NRC position that Seabrook Unit 1 was construc- '
* Trend during the last quarter of the current assessment period.
ted in accordance .with its design-bases and regulatory requirement This report also discusses " Training and Qualification Effectiveness" and " Assurance i of Quality" as . separate functional areas. Although these topics, in themselves,' are assessed in the other functional- , i areas through their use as criteria, the two areas provide a synop-sis. For example, quality assurance effectiveness 'has been assessed
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on' a day-to-day basis by resident inspectors and as an integral as-pect. of specialist inspections. Although quality work is the respon-sibility of. every employee, one' of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. Other major factors that' influence quality,.such as involve-ment' of first-line supervision, safety committees, 'and work atti-tudes,' are discussed. in. each are ..
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7 Facility Performance Analysis Summary 1986 1987 FUNCTIONAL AREA  CATEGORY CATEGORY TREND Construction Completion  1 1 Startup Testing 1 1 Plant Operations 1* 2 Radiological Controls *


t IV. PERFORMANCE ANALYSIS Construction (3788 hours, 48%) Analysis During the previous SALP assessment period, the following functional construction areas were evaluated and rated separately: Containment,
l Emergency Preparedness  2 1  ;
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1 Security and Safeguards  *
Safety-Related Structures & Major Steel Supports (Category 1);
1 Engineering Support  **
  - Piping Systems & Supports (Category 2); Safety-Related Components-Mechanical (Category 2); Auxiliary Systems (Category 1); Electrical Equipment and Cables (Category 3); and Instrumentation (Category 2). The summary of these SALP results noted a significant improve-
2 Licensing Activities  1 1 Training and Qualification *
1  l Effectiveness 10. Assurance of Quality  1 2
*During the previous SALP period, " plant operations" was evaluated in terms of " operational readiness", which included " radiological controls",
  " security and safeguards", and " training / qualification" assessments in one general functional are **During the previous SALP period, Engineering Support was not evaluated as a separate Functional Are .


ment in the piping systems & supports area, but declining trends in the electrical and instrumentation areas because of apparent programmatic problems. Management attention to routine problems I (e.g., housekeeping) was solicited to: (1) correct deficiencies,
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and (2) provide direction to an improvement in the trend in this
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area. During the previous SALP period it was also noted that posi-


tive steps had been taken in the way of a project restructuring and organizational realignment to eliminate some of the interface and control difficulties which had been identified as the root cause  :
IV. PERFORMANCE ANALYSIS- Construction Completion (1349 hours, 19.4%) Analysis During the previous SALP assessment period, all of the construc-tion disciplines were combined under one functional a re a .
of several problem area '
Significant NRC inspection effort, including two team inspec-
During this current assessment period all construction disciplines have been combined under one functional area. In recognition of both the management reorganization, which started during the pre-vious SALP period, and the problems raised by the previous SALP, i  a Construction Team Inspection (CTI) was conducted in June, 1985
:  to assess the effectiveness of the resumption of construction acti-l  vities under the new site organizatio Particular inspection
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emphasis was placed upon the electrical and instrumentation areas, as well as engineering interface controls, where problems had pre-
tions and an additional NDE Van inspection, revealed adequate control over construction processes by licensee management and few hardware deficiencies. As construction was nearing com-pletion, as-built inspections by both the resident inspectors and regional specialists confirmed a high degree of plant conformance to the design bases and technical details provided by the . FSAR. A Category I rating was determined, based upon an effective construction management program with resultant evidence of quality hardware, material, components and system During this current SALP period, an assessment of construction l  completion was conducted to not only evaluate the plant's as-built. quality, but also. to provide an independent review of the results of inspection effort into allegations involving the plant hardwar Several NRC inspections were conducted to re-view licensee corrective action on previous construction find-ings (e.g., open items and construction deficiency reports) and to investigate the validity of several allegations raised re-garding construction qualit The results of these inspections essentially confirmed previous assessments that Seabrook Unit 1 was constructed in accordance with regulatory requirements and licensing commitment As construction was being completed, an NRC inspection review of all unresolved items and licensee corrective action on pre-vious inspection findings was conducted to determine the readi-ness of Seabrook Unit 1 for issuance of an operating licens This review revealed both an aggressive construction management approach to the implementation of corrective measures, where necessary, and a responsiveness to NRC initiative Routine inspection results also provided evidence that the licensee's internal as-built verification programs (e.g. , the pipe support closecut task team, PAPSCOTT; and the cable tray and support qualification activities) had been implemented in a technically competent manner. Effective licensee controls of both construc-tion completion and the process of reconciling the as-built plant with the design details were noted. A strong QA involve-ment in the conclusion of construction activities and in the assurance of quality records storage and retrievability con-tinued from the previous assessment period into this SALP,
!.
_ _ _ _ _ _ _ _ _ _ _ .
viously been' identified. The results of this CTI (three violations, three weaknesses, and three strengths) provided no indication of programmatic deficiencies. In fact, the s!te management organiza-


'
,
tion (i.e., the area directed by the CTI trape to be the focal point of inspection effort) was identified as a 1.,.!nsee program strength.
' .
i>
    -
      ,


, The CTI findings, when analyzed in conjunction with the enforcement
  .x An independent verification of plant quality also arose from NRC:
!
      - !
data and negative observations from other construction inspections, appear to share one common attribute -- while process control, documentation, and identification failures were identified, these
followup of a number of allegations regarding the construction processes'. Because of the nature of several of. the stated -con '
'
' terns and the fact that .they were raised afterfconstruction wa essentially complete, the' quality of hardware and ability of the:
,  problems / errors did not appear to lead to an adverse impact on the hardware itself. It is noted that of the seven enforcement items
as-constructed system to function as . designed became the focus-of a multidisciplinary NRC inspection effort. 'The effectiveness of licenseeL programs, which had .been inspected in ' progress over the course aof construction,:was Previsited and the' qualification; 4 of. ' personnel - to ' perform safety-related~ activities . reviewe Systems.were opened and inspected;-independent measurements were l, taken;. tests 11n progress were witnessed; . and both design ? and !
! grouped in this construction functional area, only one violation i
-as-built construction records were reviewe This collective NRC inspection effort to investigate the tech'-
was found to result from deficient construction.
nical validity. of several allegations' did not identify. new prob-lems,r but instead confirmed .the effectiveness ~ of licensee cor- ,
rective action in response to known problem areas and provided k-additional assurance of the measure of quality that construction completi(n has receive . Conclusion-Category 1 3. -Board Recommendation None l
      )
i
      !
      . . .
I i
i
      !
      !
      .Ib


,  This theme of hardware installation and construction in compliance s
      !
with design requirements and licensing commitments appears to be i  corroborated also by another more recent CT In March, 1986, an
l
.
- -
    --~-..--- ,, p-m, -----, y - - .-r e , ,-


. - - - _- . - - = _ ._ _ - - - - _ . - .
    - - - - - -
  .
  .
  .
  . .
;  11


B. Startup Testing (1244 hours, 17.8%)
, Analysis l
During the last assessment period, nearly 2500 hours were ex-pended in the inspection of the preoperational test program of Seabrook Unit 1. Over that course of time, major testing was completed including the pre-core load Hot Functional Test (HFT),
the Engineered Safety Features (ESF) and Loss of Offsite Power (LOP) tests, and the combined Structural Integrity Test (SIT)
and Containment Integrated Leak Rate Test (CILRT). It was de-termined that a high level of performance had been maintained during the entire SALP period and for the majority of the pre-operational test activities. Accordingly, this functional area was given a Category 1 ratin The current assessment period provided the opportunity to assess
'
'
As-Built Construction Team Inspection was conducted with a primary ,
not only the completion of preoperational testing, but also the conduct of fuel loading and post-core load testing, including another HFT. The completion of the preoperational test program and final closure of the remaining test exceptions proceeded smoothly with the transition into the startup test progra NRC inspection coverage of initial fuel loading, as a startup testing activity, identified a mispositioned valve in violation of operating license conditions. The programmatic deficiencies associated with this problem are described in the Plant Opera-tions section of this repor Licensee preparation of the startup testing procedures was excellont. All 56 startup test procedures were finalized in a timely manner. They were well written and received adequate reviaw and approva Industry experience and NSSS vendor review comments were properly incorporated into the procedures. Major test evolutions were verified and transient test responses were evaluated on the Seabrook site-specific simulator with the eval-uation results incorporated into the test procedure Fuel load and post-core load HFT testing activities were delib-erate and well coordinated. Adherence to procedural controls was well in evidence. The conduct of startup testing was noted to be performed by qualified personnel, who interfaced well with their operations counterparts, and with management involvement in the prompt resolution of equipment problems and test defici-encies. Test records were well prepared and maintained. Test exceptions were few and dispositioned in a technically appro-priate and thorough manne .
inspection focus on hardware. While two severity level V violations
__ _ _ _ . _ - - _ . _ . _ _ _ - _-
.
_ _ . - - - - - - - - - - _ - _ - - - - - - - - - - - -
were identified, the summary conclusion of this inspection was that
      ._  --- - - - --- -- - - - - - - - - - - ' - - ~ - ' - ~ ~
.
Seabrook Unit I was constructed in substantial agreement with the FSAR. Additionally, an NRC independent measurements inspection of 68 weldments, utilizing the Region I Mobile Nondestructive Examina-
: tion (NDE) laboratory, in conjunction with a review of licensee ,
; radiographs for over 150 welds, identified no weld deficiencies or '
i hardware problem The NDE van inspection in July, 1985 did document some concerns re-i garding the conduct of the Preservice Inspection (PSI) program at Seabrook Unit 1. An unresolved item was written to track several i
PSI questions involving data keeping, calibration, weld surface i preparation and plans for ultrasonic (UT) examination of the loop cast stainless steel (SS) elbows. Subsequent NRC inspections noted
; adequate licensee resolution to most of these questions. A recent, joint NRR/ Region I inspection of a demonstration of the UT technique planned for the loop cast SS elbows revealed not only technical acceptability, but responsiveness on the part of the licensee. The basic concerns regarding the PSI program, as raised by the NDE van inspection, have since been closed, although NRC follow-up of two specific items remains.


j As in the case of the PSI issue, other NRC inspections in this func-
_
  , tional area have raised questions more of a program and process i
      ,
control nature, than of the identification of' improper constructio Such issues include the improper usage of selected revisions of ASME Code Cases, failure to implement commitments to Regulatory Guide i (RG) 1.97, and the questionable adequacy of criteria for final building verification and cable tray testing qualification. For all of these items, licensee action to address the concerns has been j complete and responsiv For example, when problems were identified with the licensee adop-
  , .
!
l
tion and documentation of certain ASME Code Cases, not only was a
      !
'
l 11  .l
project position on ASME Code Case adoption and usage announced and disseminated, but also a complete review of all past and present
)
,
One significant testing issue regarding the emergency feedwater !
Code Case usage was initiated. Both design and procurement speci-fications were checked. Such comprehensive corrective action was followed through by the licensee even though no evidence of material or construction defects existed as a result of the identified im-proper Code Case usag In fact, licensee completion of their in-vestigation, with subsequent NRC review, revealed the lack of any adverse hardware impac "
(EFW) system carried over from the original HFT, as difficulties had been encountered in the conduct of the turbine driven EFW pump preoperational test. _ The steam supply system to the Terry ;
The status of construction during the current assessment period
turbine was redesigned after the identification of the original '
,
HFT water hammer problems. An NRC zero power license condition mandated successful completion of the subject EFW testing prior to initial criticalit A specific. startup test (ST-53) was formulated te verify system modification and design adequac i During the conduct of this testing, weeping valves were observed !
'
to affect test conditions which necessitated the continuation of ~
provided sufficient opportunity for the inspection of electrical and instrumentation activities, not only because by nature such work
testing with an abnormal valve lineup. .This unusual lineup contributed to an unexpected steam generator' safety valve actu- j ation in February, 198 It also resulted in a testing issue which remains open, since the completion of the post-core load ;
HFT and cooldown in March, 1987 has not yet provided complete !
. evidence that the EFW system functions as designed. The post-core load HFT had to be extended over an approximate six week 3 period to troubleshoot the testing problems which were identi- 1 fied. During this . time, the licensee employed a ' trial-and-adjustment iterative technique to problem solving which is more l
      ;
characteristic of a "preoperational" rather than "startup" pro- :
gra Review of the test results with a more systematic and !
analytical approach to resolution of the' problems appeared to be warranted, given that operating license conditions and technical l specifications were in effec The licensee has attempted to !
address all NRC questions on this issue and has planned conduct !
of a special test (STP-101) to verify adequacy of the normal start and operation of the EFW turbine driven pump. Thus, in general the EFW problems and how they have been handled by the l licensee validate the position that the startup testing process is functioning as intended, to identify problem areas, ef fect corrective measures, and retest as necessar I Overall, the NHY startup testing program planning and implemen- s tation have continued to provide the same level of technically competent confirmation of system and component adequacy, as was provided by the preoperational test program. Licensee manage-ment and startup personnel continue to demonstrate not only a responsiveness to NRC concerns, but also a technical determina-tion to objectively verify EFW system operabilit n


I
  . . _  _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -_ - __________ _ _ -________
  - ,    ,. --
 
-. ..  -- . - -
      . - _ - . -.
..
  .
  .
          '
. .
12 Conclusion Category 1 l Board Recommendation None
. .
          ~,
            .I
,
            .
O
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _


I is prevalent during the later stages of construction, but also be-cause the previous SALP had raised some concerns in these area Thirteen NRC inspections examined either in process or as-built work in these disciplines. Additionally, NRC team inspections reviewed such activities in conjunction with the scope of the CTI objective While some violations were identified, the overall findings of the NRC inspection effort into the electrical and instrumentation dis-ciplines confirmed the general effectiveness of licensee corrective measures initiated during the latter part of the previous SALP period. Analysis of all the inspection items, not just enforcement
_ _-
,
  '
  '
data, indicates a consistent theme of concerns with process and design control issues with no evidence that the questioned controls had resulted in incorrect construction. While some of these issues but remain open, licensee actions to address the questions appear to be pointed in the proper directio Similarly, an analysis of the CDRs (See Table 1) reported during
*
this assessment period reveals no real trend of programmatic defi-ciencies in this construction functional area. NRC review of in-1  terim and final 10CFR50.55(e) reports, as applicable, and involve-1  ment in the in process troubleshooting of several of these defi-j ciencies has confirmed adequate liaison with the vendors and working
;
  '
  '
interfaces among engineering, construction, and test personnel to expeditiously solve the known problem as well as investigate any generic impac Thus, in summary of the assessment of construction activities, sig-nificant NRC inspection effort has identified few hardware defi-ciencies and the licensee appears to have adequate control over their self-identified construction problems. While some concerns over process controls were noted, they appear to have received ade-quate licensee attention. One CTI near the beginning of the as-sessment period evaluated construction management and programs, while another CTI at the end of the period examined the as-built plant hardware. These team inspections, in concert with resident and specialist inspections over the course of the entire SALP period,
.. .~  n    .
.
        -
!
'      '
verified implementation of a generally effective construction man-agement program with resultant evidence of quality hardware, mate-
        /
,
,         i
  *
        < 'l
rial, components and system !
        .
2. Conclusion Rating: Category Trend: Consistent 3. Board Recommendation Non ,
j iC.. Plant' Operations (2667 hours, 38.2%)    l l'. . Analysis l
l _ _ _ _ _ _ _ . , , _ ,  _ . - . - - -
 
    ._ .-_ -_- .-.- --_ _ - -------
The operational readiness functional area was evaluated in the previousLassessment period in the areas of procedures and staff-  i ing,-operator licensing, security and radiological controls. An a overall Category 1 -rating was assessed in this area based upon  ,
      -  - - - - -- - - - - - - - - -. ~
thorough licensee planning and a high level of management atten-
    - tion to the development of . procedures and' programs in- the indi-vidual areas and in the' preparation ~for a receipt of new fue .'
During this assessment period, security and radiological con-  ;
trols will each be evaluated as a separate functional are Maintenance and surveillance activities have been added to the !!
Plant Operations functional area for this 'SALP evaluatio ,i During the current assessment period, core loading, pre-critical-hot functional testing (HFT), and operational controls under the t Technical Specifications provided the bases for evaluating the .;
effectiveness of the station programs and procedures,.which.had"  '
been ' under development in the previous period. . Analysis of each {
area contributing to an overall assessment of plant operations  '
is discussed separately belo y a) Procedures and Programs    3 The evaluation of procedural and programmatic controls weighed heavily in the assessment of plant operations since  i the "zero power" license conditions limited the scope of j
    . ope ra tional ' activitie s . As initially inspected by the NRC, 1 the implementation of' the independent verification program  !
was determined to contain certain weaknesses which include j vague selection criteria and inconsistent application among j various station department Other programmatic- areas '
where NRC inspection identified areas of concern included 1 the equipment tagging, valve lineup and temporary modifica-tion programs. These problems were the subject of enforce-ment action on two occasions. Additionally, during startup 'l testing, a violation of the "zero power" license condition  1 concerning locked valves was identifie This violation I related directly to a deficiency in the operational con-  l trols for identifying the position of locked valve The l identified program development and implementation problems  '
;    have required concentrated licensee effort to upgrade the affected program .
l
_ _ _ _ _ _ _ _ _ _ _ _ _ . .__
 
,    -   ..


  ,   -- _- .-.
   -
.
  .
e
w  .
,
  ,
:.
    '


B. Preoperational Testing (2451 hours 31%) Analysis During the last assessment period, preoperational test activities were just commencin NRC review of the preoperational test pro-gram verified adequate controls and program direction. One specific problem area was noted in that unauthorized work activities on com-ponents under the jurisdiction of the Startup Test Department (STD)
1
were identified. The licensee responded with programmatic correc-tive action. A high level of performance was maintained in this area during the previous SALP period; however, this assessment was based upon a limited NRC inspection effort.


, Over the course of the current assessment period, the bulk of pre-operational testing for Seabrook Unit I was accomplished. NRC in-spections devoted effort to the witnessing of tests in progress and the review of approved test procedures and test results. Signifi-cant tests conducted and witnessed by the NRC during this time period
In the area of procedure ' development, weaknesses in format,
;
    . content-and. consistency were- first notedL by: the NRC in the operations surveillance procedures and later in plant oper-ating procedures. NHY' task- teams of experienced; operators-
included the Reactor Coolant System (RCS) Hydrostatic test, the Reactor Protection System test, the integrated system Hot Functional
    'and _ test engineers were . formed. and a procedure consistency review process was initiated. NRC review of the'se licensee
.
    . efforts revealed a significant improvement in the quality .j and accuracy of these procedure a
Test- (HFT), the Engineered Safety Features (ESF) and Loss of Offsite Power (LOP) tests, and the combined Structural Integrity Test (SIT)
    ' Licensee initiatives and corrective measures in the above two- areas have been. responsive to both internally and i externally generated programmatic. reviews. While the time- -
and Containment Integrated Leak Rate Test (CILRT). It is noteworthy that all of these tests, also being major schedular milestones, were provided significant management oversight to ensure conduct in con-cert with schedular presssures and other construction prioritie Despite a situation where the pressure for progress might be per-ceived to be contrary to the quality objectives of the test program, the subject tests were performed, witnessed and reviewed with generally outstanding results.
,
liness of response to certain' procedural concerns has been ,
questioned, management attention to the problem areas, once .i identified by' the NRC, has . been - thorough. Particularly in l the areas of independent verification and .the procedure
    - consistency review, quality products have resulted once the !
    ~ licensee dedicated. sufficient resources to the corrective measures, b) Conduct of Operations    !
Since Seabrook is not a fully operational plant, the basis '
for assessment in this sub-area is nec'essarily limite Notwithstanding the limited . scope of licensee. activities in this area, significant NRC inspection was conducted into i routine operations, response to events / transients and TS i interpretation / reportin Routine daily operation of the plant both in Mode 5, cold I shutdown, and in Modes 3 'and 4 during HFT was excellen A high degree of professionalism and competency of the con-trol room operators was in evidence throughout the perio Control room logs and records showed continuous improvement over.the period. The shift superintendents (SS) are tasked with a high level of responsibility for station operation Their judgement is routinely conservative and demonstrates a safety conscious attitud Individual control room ,
operators and shif t supervisors are vigilant and knowledge- j able and have taken a significant initiative in providing  >
quality on-the-job training to licensed operator. candidates on shift. As evidenced by a review of the LERs in Table 4 of this SALP, operator error has been identified as the cause of several inadvertent engineered safety features (ESF) actuations. In one case, improper switch operation resulted in an inadvertent safety injection (SI) while a


;
_ _ _ _ _ _ _ _ _ _ _ - - - -
While the month-long HFT did result in some significant test excep-tions requiring system redesign, the SIT /CILRT resulted in no test
;
exceptions being noted and the RCS hydro identified only one RCS boundary leak (other than the expected flanged joints) in an in-strument tub NRC questions on ESF testing have been raised with regard to valve interlocks and safety-injection "S"  signal reset design, but in each case the conduct of the test was found to agree with the system design, as stated in the FSAR. Thus, the NRC con-cerns related to design, not testing, issues. Similarly, for other
<
testing activities (e.g., diesel generator operation), the problems that have arisen provided validation of the test objective itsel STD troubleshooting of some diesel generator air start problems
'
(identified during Phase 1 testing in 1984) ultimately led to the discovery of an undersized diesel starting air vent line (reported a* a 10CFR50.55(e) design deficiency in 1986 (see Table 1). This issue currently remains an open NRC inspection item. Another NRC
; inspection item on the diesel generators was a concern regarding the sequence of LOCA/ LOP testing with respect to the 24 hour endur-
'
_ _ _ _ _ _ _ _ - _ __ . _ _ _ - - _ _  _. _ _ _ . . _ - - __ _. _


  .
- _ _ _ _ _ - _ _ _ _
  .
  .. .


ance runs of the diesels, as per Regulatory Guide 1.108. This issue was satisfactorily resolved when the licensee agreed to duplicate stable diesel generator temperature conditions (as determined by the 24-hour run test) as an initial condition to the performance of the hot LOCA/ LOP sequencing load tes The most significant system problems identified, to date, during precperational testing were noted during HFT. In particular, with respect to the Emergency Feedwater (EFW) system, a water hammer was experienced in the steam lines to the Terry Turbine and EFW recir-culation and flow to the steam generator problems were noted; ex-tensive system redesign was required. As was the case with other HFT problems (i.e. , feedwater recirculation vibration, main steam bypass, steam dump, and steam generator blowdown exceptions), the system / component rework will be functionally retested during the startup hot functional testing, after core load, but prior to in-itial criticality. The licensee's coordination between its engi-neering, construction, and test staffs to effect the correct system redesign on the above items has been comprehensiv NRC personnel
second SI was generated due to tagging procedural- erro ''
On another occasion, a switch misoperation resulted in a
,
,
have been briefed and kept informed of all significant developments and NRC inspection relative not only to the above items, but all HFT activities resulted in no significant adverse finding While the HFT identified certain major items requiring retest, the remainder of the preoperational test program (i.e., Phase 2 & 3 tests) to date, represents a verification of system readiness for operations with relatively few problems. At any given time during this SALP period, as preoperational testing was conducted in accord-ance with the more than one hundred each preoperational and accept-ance test procedures, the number of open test exceptions remained below 100 in number. Preoperational testing has, in general, met its objectives with respect to Unit I components and systems and in fact has identified several of the construction deficiencies, reported under 10 CFR 50.55(e), listed in Table The trend for the number of remaining work items, as tracked on the licensee In-complete Items List (IIL), is downward as the total items currently number less than 4000 for the first time since pre-HFT in mid-198 NRC inspection in this functional area has identified only one violation, although it was a repetitive item from the last SALP period involving an unauthorized work activity. Licensee corrective action has not yet been reviewed by the NRC, however, the STD record in the resolution of problem; encountered to date in testing has been both comprehensive and complete. A high level of performance was found to exist in this functional area during the prior SALP period based upon limited dat During this SALP period, that high level of performance has been maintained over the course of the majority of preoperational test activitie .
diesel generator star In two separate events, substan- .
.
l  tial volumes of RWST water were inadvertently transferred, l
once to the containment and once to the refueling cavit While NRC review of each of these incidents has revealed
      )
      "
timely corrective action on the part of the operations department, the number- of problems experienced warrants increased management attention to detail in routine, daily operations. Additional operational experience and famil-iarization with a zero power license environment reduced l


This evaluation corroborates the finding of a minimal number of actual hardware problems identified in the construction area. Lic-ensee performance in this area reflects aggressive management in-volvement and serves as an impetus for and the STD to sustain such a level of testing performance as construction is completed and operations and the startup testing phase commence . Conclusion Rating: Category Trend: Consistent 3. Board Recommendation Non _
the number and frequency of such events during the latter l
part of this SALP perio During this assessment period, the operators were not severely challenged to respond to significant plant trans-ients and events, however, several minor occurrences war-rant discussio In addition to the events related to operator errors, discussed above, several other ESF actua-tions occurred. NRC evaluation of operator response in the
      [
control room verified effective use of procedures and
,  appropriate operator judgement in restoring the unit to a
!  normal configuratio Most notable of the above incidents
!  were two inadvertent safety injection actuations caused by malfunctioning control switche The station response to the declaration of an Unusual Event is summarily assessed in the Emergency Preparedness section of this repor No specific technical problems related to the conduct of operations were identified as a result of this event. However, it was noted that an internal dis-agreement between members of the operations staff developed as the event progresse This disagreement, relating to event classification and notification requirements, contri-buted to the delay in reporting and therefore resulted in the issuance of a violatio Additional training and specific delegation of responsibility within the operations department were necessary to clarify operational duty roles within the Emergency Response Organizatio Some dif ficulties were initially experienced in the inter-pretation of Technical Specification (TS) limiting condi-tions for operation (LCO) and the deportability of events under 10 CFR 50.72. The most significant example was the handling of equipment and procedural problems associated with the control building air handling (CBA) system where


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


C. Fire Protection and Housekeeping (296 hours, 4%) Analysis This area was not evaluated during the previous SALP period, al-though some housekeeping concerns were raised as they impacted the acceptability of safety-related component During this assessment period, a Region I team inspection was per-formed to evaluate the licensee's efforts to comply with the re-quirements of 10CFR50, Appendix R, concerning fire protection fea-tures necessary tc ensure the ability to achieve and maintain safe shutdown in the event of a fir Two Region I specialist inspec-tions into the Fire Main Loop installation and the readiness of th Fire Protection Program, particularly as it related to fuel receipt onsite, were also conducted. Additionally, routine resident in-spections have examined fireproof coating material applications, fire sealant installation, and cable separation and routing activi-ties. Housekeeping, as appropriate to the status of the Unit 1 plant conditions during construction, testing and building turnover to the plant staff, were observed during random plant inspection-tour Electrical separation concerns have been raised during both this and previous SALP periods. Where nonconforming conditions have been identified (e.g., less than six inch wire spacing internal to panels), the licensee had committed to corrective rework to retrain and separate the cables / wires or install barriers, as required by the applicable IEEE Standard However, a recent licensee submittal to NRR of an " Analysis of Electrical Separation Criteria for Sea-brook Station" establishes the basis for the adoption of certain new separation criteria at Seabrook, as determined by analysis and testin Thus, previous long-standing commitments for the correc-tion of electrical separation deviations need not be implemented if NRR approves the licensee proposal to relax the separation cri-teria, based upon site-specific testing. Similarly, the Region I team inspection identified two Appendix R exemptions in the areas of emergency lighting and the reactor coolant pump oil collection syste Each of these exemptions requires further NRR review to determine the acceptability of the plant design and to resolve the open inspection item Generally, with respect to the Appendix R team inspection at Sea-brook, both the corporate and site management were found to be ag-gressively pursuing fire protection issues to their proper resolu-tio The licensee's fire hazard analysis was thorough and detaile The licensee has made several modifications to achieve compliance with Appendix R, Section III.G separation requirements. The licen-see also had many redundant means of achieving a plant safe shutdown in the event of a fire, including two redundant Remote Shutdown
eventually, a definition of C8A single train operation had to - be disseminated for generic interpretation by the sta-tion staf Presently, licensee awareness of reporting requirements and the training provided to those individuals responsible for interpreting these requirements have imprnved in the wake of the initial difficultie In another administrative area, however, the paperwork /
nonoperational workload of the Unit Shift Supervisor (USS)
continues to represent a potential problem, since .it diverts his attention from shift operations. This situa-tion has not improved significantly since initial NRC dis-cussion of the concern and merits further station manage-ment attentio With' the exception. of the potential problem related to the USS administrative burden, operations during this SALP period have been conducted safely by qualified personnel, utilizing adequate procedures and controls in accordance with the Technical  Specification Certain problems attributable  to inattention to detail have been experienced, but appear to have been appropriately disposi-tioned by station management. The real effectiveness of licensee corrective actions in this area can only be measured during future hot testing and operation c) Surveillance During this period the licensee implemented the Westing-house computerized TS Appraisal Program and began conduc-ting surveillanc The licensee instituted this program on an accelerated schedule in order that surveillance were performed in advance of the actual required operability re-quirements, thus enhancing the procedures and establishing baseline data. Additionally, surveillance and operating procedures were utilized as much as possible during the test program to allow additional trial usage. While a few surveillance errors have occurred, the overall surveillance program has been effectiv The licensee also established measures to strengthen this program with new initiatives involving TS log reviews and the surveillance procedure consistency review program referred' to in paragraph a)
abov The NHY Program Support Department Staff which is respon-sible for certain surveillance testing (e.g., ASME Section XI and 10 CFR 50, Appendix J) is highly competent and professional. One notable example of this was the dis-covery by surveillance test engineers of the common mode
            .
__--_-_ _ . _ - _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - . ' - ' - - - - - ' ' ' ' '


_ ___ _
_ -
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      ,
.
a
  : 17 -
valve' failure on the equipment. hatch a'ir lock doors (dis- !
cussed in section IV.G-of this report). Performance of thel 1 surveillance' on the-hatch doors at that- time was in ' paral- l 1el: to, . but not directly' responsible for identification 'of:
the problem. It was '.the alertness of the surveillance J q
engineer himself that' identified the. malfunction and i eventually. led to the declaration of an Unusual Event. The "
technical support staff has also been extremely responsive to NRC questions and concerns, p
Although the plant has not conducted sustained power oper-ations, .- challenging the capabilities of the surveillance .
programs, inspection to date.which has sampled higher mode 4 operations indicates that licensee efforts in this area are effective and the programs are appropriately staffe d) Maintenance    y The licensee.has reorganized the maintenance support' organ-- H
  'ization, establishing separate Maintenance and. Technical Support Departments. Electrical, mechanical, and I&C func-tions 'are performed by the mai nter.ance department while !
system support is' provided by individual' system engineers who have been delegated responsibility ' for, the -separate' l systems. This organizational concept hcs provided consis-
      '
  'tency and accountability in the maintenance chai As a- ;
result, the Maintenance / Technical Suppor t capability has ;
been significantly. strengthened. The mos . visible example '
of this was the primary component coolir gL water heat ex-changer repairs where follow-up to this m.tintenance activ-ity led,to identification of the service water valve. lining !
problems, discussed in' Section IV.G. These two jobs re-quired considerable expenditure of maintenance resources, extensive hardware disassembly and complex special process controls. There has been extensive involvement by Station Technical Support Engineers in the maintenance area. The competence of these system engineers and their supervisors is a licensee strength. Liaison between technical support and maintenance has been an effective part of the work con-trol process. The NHY maintenance organization (including I&C) continues to' demonstrate excellent maintenance tech-niques in the area of pre-staging, cleanliness, temporary support and storage and procedural adherenc .


, Panels whose adequacy was demonstrated through walkdowns of selected
_ _
'
r .    -
portions of the procedures to safely shut down the plant. Walkdowns have further demonstrated that procedures were well planned and adequate procedural training was given to the operator The inspections team's conclusion was that the licensee's fire pro-tection program, when fully completed and implemented, will be ade-quate for its intended purpose. A major contributing factor is the rapport maintained by the fire protection staff and management and the increased awareness of the plant's personnel of fire protection concerns. Other NRC inspections of fire protection at Seabrook have confirmed this conclusion, even though one apparent deviation from FSAR commitments was identified. The installed Fire Loop hydrant isolation valves had not been procured as U.L. listed components, as was committe The licensee, however, provided a comparison of the installed valves with similar U.L.-listed valves and demon-strated that the existing valves are acceptable for their intended service. Another inspection item identified a discrepancy between the SER and actual plant design with respect to the inability to
J-      j
;
:
start the fire pumps from the control room. This issue is being pursued by the licensee with the Office of NR With respect to housekeeping at Seabrook Unit 1, both NRC CTIs (discussed in Section IV.A of this report) noted acceptable levels of site cleanliness. Resident inspections have noted that the ac-ceptability of site housekeeping appears to be dependent upon the status of plant activities; construction areas require continual attention, buildings turned-over to the plant staff appear to be
  ~ An additional licensee' strength lies in the area -o'f plan-ning and scheduling. Daily' " plan of the day" meetings are effective in the coordination of the diverse requirements of'the many station departments. The computerized planning schedule is kept current so that future planning is based on accurate data. A high degree .of management attention has been directed to the coordinationLof the support activ-ities- of various departments to meet the established'sta-~ '
;
tion work schedules. A recent positive initiative. involved the establishment of a new - maintenance concept whereby -
maintained in good order, and other plant areas appear to improve as the preoperational testing and turnover process progress.
preventive and corrective maintenance periods are pre-established for each system on : a . rotating weekly basis, Station maintenance has been conducted in a highly effec -
tive manner with no maintenance-related failure or events identifie Future . plant operations will provide more significant challenges, but- the maintenance and ' repair activities conducted to date indicate well controlled efforts capable of supporting ' more complex operations.' H


l The housekeeping problems raised during the past SALP appear to have
Plant operations at Seabrook-have been conducted professionally, safely and conservatively. Initial weaknesses in the develop-ment of procedures and programs .have, for the most part, been-corrected. Licensee efforts in strengthening the tagging pro- 1 gram and the consistency review- of operating procedures are l ongoing. The skills and knowledge of the licensed operating j staff remains a strength and initial problems with_ inattention
.
    ~
been adequately addressed by plant management. Continued attention to this area, as well as to the resolution of the noted fire pro-tection licensing issues with NRR, is necessary to provide a con-sistency to the licensee's approach to fire protection as the plant
l to. detail have been overcome. The maintenance and technical !
,
support organizations remain a significant asset.
enters operation . Conclusion Rating: Category Trend: Consistent.


4 Board Recommendation Non .. _ -
<      -l 2. Conclusion    i Category 2 3. Board Recommendation
  .- --
      :
   . - . _ __
Licensee: Station management 'should emphasize attention to de- {
tail in the conduct of routine operations, assess the .i ef festiveness and control of operational programs and !
evaluate methods to reduce operational error E: None   i i
i


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i
.
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, D. Operational Readiness (743 hours, 9%) Analysis 5 This functional area was evaluated in the previous assessment period only from the perspective of Operator Licensing. In that area, a
l l
: Category I rating was assessed based upon evidence of a highly com-petent, technical training program and the resulting high pass rate
t
.
___
of SR0/R0 candidates in their initial licensing examinations. Dur-i ing the current SALP period, the-functional area of Operational Readiness has been expanded to include consideration of procedures and staffing, radiological controls, and security, in addition to operator licensing. Analysis of each of these areas is discussed separately belo . Procedures and Staffing i  During the current SALP period four separate Region I inspec-  i
^
tions were conducted in such areas as plant maintenance and surveillance procedures, design change and modification con-trols, and operational QA/QC program administration and con-trol Resident inspections have examined the plant readiness for fuel receipt and storage, and licensee plans / implementation of their commitments to meet the TMI Action Plan requirements specified by NUREG-0737. Also, several IE Bulletins and Cir-culars, of an operational nature, sent to Seabrook Station for information only, were reviewed in conjunction with licensee measures to address the concerns raised by these generic docu-ment No enforcement findings or unresolved safety issues have been identified as a result of these operational preparedness in-l spections, to dat Licensee attentiveness to an FSAR commit-
;
'
ment to have the Fuel Building and the appropriate fuel hand-ling and storage systems completed and tested prior to new fuel receipt onsite was noted. Scheduled fuel receipt was first delayed to allow time to meet such a commitment and subse-
,
quently, removal of the new fuel from the storage casks was
'
further delayed to provide for additional testing of the fuel building ventilation system NRC inspection of the new fuel arrival, movement and storage revealed adequate security meas-ures in place, the utilization of approved new fuel handling and inspection procedures, knowledgeable operations personnel, and general compliance with the provisions of the Special Nuc-lear Materials license issued by the NRC Office of NMS NRC inspections of licensee plans for controlling specific operations programs for Measuring and Test Equipment (M & TE),
calibration, inservice testing, material storage, records storage, procurement, safety review committees, and admini-
, _ . - - - -    _ . - - - _ . _ -


m    "}j';,4t    }
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a;
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.-


strative procedures all resulted in a finding of adequate pro-gress and proper direction by the licensee operations staff in addressing proper quality controls and generic industry in-itiatives. The status of operating and emergency procedures was not amenable to inspection during this assessment period, since most procedures were still in draft form. However, it was noted that the operating personnel had utilized these pro-cedures, where appropriate, during the conduct of preopera-tional testing, to troubleshoot procedural problem area While the development of operating procedures is dependent upon Technical Specification approval, management attention to their program for operating procedure issuance is warranted to provide not only a generic site perspective on the way regulatory guidance (e.g., NUREG-0737) is to be handled, but also assurance that these procedures can be reviewed and edited in a timely manner relative to the licensee fuel load dat In the same vein, licensee actions to demonstrate compliance with NUREG-0737 commitments have not been timely, as sufficient progress on certain TMI Action Plan requirements had not been made by the end of this assessment period. Licensee management attention was directed to this area, and since the end of the assessment period, greater progress appears evident. Continued management responsiveness to all remaining operational pre-paredness areas and items is necessary to assure Seabrook Unit 1 plant readiness for fuel load and operatio NRC inspection effort has also been devoted to the licensee's nonlicensed training program, and other training conducted to correct or prevent problems which have arisen in the construc-tion and preoperational test area One NRC concern in the area of nonlicensed training was raised in that no matrix and comprehensive schedule of such training was yet available to demonstrate that all personnel training needs would be ful-fille Since the identification of that item, NRC reinspec-tion has found the licensee responsive to this concern and has taken adequate action to allow closure of the open item.
T fy  ,
Atht
      }' yJ  l u
19 I    i ti '- y
    \  >  >
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D. Radiological Controls (739 hours, 10.6%)  e A,
      ;  .i % Analysis ,    1'
        (  !
A Cate' gory I rating, as part of the Operational Readintss area,  ' g'
was. provided for this area in the last assessmpt .per.f Ad based upon the observation that the licensee's operattoriab readiness in the four radiological control arets (radiation protection, q waste management,,: transportation and effluent control and ' mon-itoring) axereded that ' routinely found at similar plants at the [i same preoperational stage. This fact was attributed to a high  h level of management commitment, the degree of prepla'nning and  i
        '
preparation, and the level of attention to detai This current assessment is based upon both an observation of ongoing plant activities and an evaluation of the programs which  ^
have been established. Since radiological conditions at the
        '
        -j
        '
plant were limited, the scope of this assessment necessarily  J emphasized programmatic and operational readiness . reviews, '
rather than demonstrated implementation of radiological con-trol It was noted that while the licensee was not greatly i  ,
challenged in this functional area during this assessment period, a meaningful evaluation is still pr.ssible based upon review of the limited activities (e.g., fuel road) and the con-trols in evidence during their conduct. ' Pragram areas inciqde In-Plant Radiacion Protection, Radioactive Waste Management, Ef fluent Controls,, Nonradiological Water Chemistry, and Environ-mental Monitoring, Radiation Protection During this assessment period, the licensee continued to make significant progress towards operational readiness in  4 the areas of staffing, training procedures, and equipment and instrumentation. The continued posehce of a motivated  ;
and professional staff and managemeht commitment to the program were evidented by an increase in staffing level  (
aimed at commercial operation. .Ine. Radiation Safety  l Committee met at the required frecuency and was tracking  , I and evaluating program development; implementation, main- /' I tenance, results, and outstanding action items. Formal and l timely evaluation packages on previnusly identified NRC inspector concerns demonstrated licerste responsiveness and attention to these item As a further licensee initia-tive, a supplemental HP training progre.n we developed and implemented. During this period, the 1!cer.see's principal
        ,
___n____ -_ _ _ _ _ _ _ _ _ _ . -


l b. Operator Licensing
y  , 7m
  ,
    .N).


, During the current assessment period, two operator license ex-aminations were administered during the weeks of March 18, 1985 and September 30, 1985. Of the 17 senior reactor operator (SRO) and 3 reactor operator candidates examined in March, only one SRO candidate was denied a license. All 5 senior reactor operator candidates participating in the September examination were issued licenses. This included the candidate previously denied a license during the March exa . -- . _  . . - - _- - __ = _.. - - - _ ..    -.
..
.
  .
  .
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  .
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l M'  N; (corporate) health physicist and the ' licensee QA organiza-tien performed evaluations of the . health physick (HP) pro- ,
gram. The corporate review resulted in several recommenda- l
  %''  i< tidns being evaluated as program enhancements while the QA
    '
ahdit < addressed good practices in addition to the regula-
  't tpy! t requirements. Both evaluations were timely- and encompassed the full scope of HP activitie f During this appraisal period, primary startup sources were l
  .'  installed in fuel assemblies in the fuel storage buildin ri !
  .
  .
I The licensee began its first replacement operator training class in mid-February, 1985. The class of 15 reactor operator and 5 senior reactor operator candidates is presently scheduled for a July 1987 operator license examinatio In addition to operator training, the licensee has demonstrated a strong commitment to the enhancement of the simulator's
.'
operational capabilities. A new modern high speed computer is being installed to improve system response time and fidelity and to provide a larger storage capacit Tne simulator malfunction list provided for the March 1985 ex-
'
,
amination contained several malfunctions with only a cursory descriptio The licensee was informed of this weakness at I  the March 1985 operator license examination exit meeting. This
'
4  same weakness was again identified during the September 1985 examination. It continued to make the development of quality simulatoi scenarios difficult for operator license examination purpose The first group of cold license candidates was examined in September, 1984. These operators and those that closely fol-lowed will be scheduled for renewal near the proposed time of
!  fuel load and the follow-on startup test program. Based on this and the. fact that none of the operators will have been able to make " active use" of their licenses during the previous
,
two years, the NRC staff has begun selective monitoring of the l  licensed operator requalification training program. This pro-gram was implemented immediately after the last cold license    ,
training class ended. To date, the licensee has demonstrated    '
a strong commitment to quality requalification training that l  not only addresses the operator's need for skill and knowledge i
reinforcement, but also identifies unique areas of specialized training that are required in preparation for the upcoming l'  startup test program. The licensed operator-requalification training program at Seabrook is considered an additional strength in the already strong operator licensing training progra :
,  With respect to licensed operator training and qualification at Seabrook, the licensee continues to devote substantial re-
~
sources to the training program. The licensee training staff appears to be both technically competent and professiona .
Responsiveness on the part of the licensee to suggestions to


improve training has been eviden Security
The fuel assemblies were moved into containment hnd loaded into t.>e reactor vessel. Also, calibration of area and '
. Three preoperational security program reviews were performed i
process radiation monitors and of other radiation detection i instrumentation was conducted. The licensee reported mini- l mal person-rem exposures (less than 1 man-rem for 1986 and i
during the assessment period by region-based inspectors. Rou-tine resident inspections continued throughout the assessment
for the first quarter of 1987), indicating that appropriate I';
  ;  perio , _ _ . _ . , -, . _ . . - _ _ , - . , . _ . , - - _ . - - , _ _ . - _ - - _ - - _ . , , _ - - _ , - - _ . _ . -
radiological controls had been exercised over the limited activities which were conducted during this assessment gj    perio I In summary, the licensee has developed an aggressive radia- !
tion protection program in preparation for commercial oper-ation. Considering the nature of the activities conducted ( to date, effective radiolo'g1 cal controls have been imple-mented. When areas for improvement have been identified by l 9 '
j  either the licensee or NRC, site and corporate HP manage- q 1,   ment has initiated timely and appropriate corrective ;
  %.. o ' r' >
' '
  ) t  actio y, '
        .,
        " l
        < Radwaste Management / Effluent Controls
        !
The licensee demonstrated aggressive oversight of the  i radiochemi stry program in preparing for fuel load and  j responded to NRC identified concerns in a timely manne '
        ;
Regarding radioanalytical standards submitted to the !
licensee for analysis, disagreements in two samples were  2 resolved promptly, indicating a high level of radiological j chemistry s nagement involvemen The radiological j environmental monitoring program (REMP) is implemented
  !. through a clearly designated program which interfaces the site and corporate groups. The scope and method of over-view audit functions were clearly state ;
    .
f i
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    'Ae
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. . _ _ - . . _ . - . - - . .- -_ . _ _ _ ._ .. - - - _ _ - .. .- .
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  ,
  ,
1 s
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  .
  .
, ,' f-21 U ,
Several aspects of the' REMP program implementation 'd'ur.ing
    .
the preoperational, phase exceeded . regulatory requirement Although not required, the direct radiation monitoring .
environmental TLD program was found to include efforts ' to-meet. criteria for. quality' control found in USNRC' Regulatory
  ~ Guide 4.13 and ANSI N545. The lic'ensee also,' participates in the International -Environmental . Dosimeter Intercompar-L
  .ison project. These licensee initiatives indicate a high level 'of corporate management' awareness,.- commitment ' of
      '
i resources and- sensitivity to the needs of this-. progra . Procedures for effluent measurement and' control'are coupled  1 to an ' administrative procedure for surveillance for' comply-ing with- the requirements of the Technical Specification The program -for preoperational and acceptance testing: of radwaste systems was found to be effectiv Test 1excep-tions and identified weaknesses were addressed in a _ timely manne c, .Non-Radiological Water Chemistry During the assessment period, the licensee made . progress .
  , in nonradiological water chemistry for monitoring para-meters' of . primary and secondary water and preoperational and acceptance test programs. . Prccedures were found to be technically sound and adequate to meet TS requirement However, an initial inspection of this area identified certain weaknesses. The licensee was unable to analyze samples' in the concentrations normally found in an opera-
"
ting reactor. Also, the inadequate calibration of instru-ments was noted. Follow-up inspection in these areas found considerable improv" ants in the sample analysis and
'
quality control in ins leh was upgraded. Again the~11cen-see management demonstrated ti volver snt in the program and responsiveness to inspection recommendation Review of the water chemistry control program indicated a clearly defined policy, competent organization, effective-administrative procedures and adequate resources for imple-mentatio Based in part upo a study done by the station "
chemistry department, the licensee continues to explore additional enhancement options to the present program pf all-volatile treatment (AVT) for secondary side water treatmen I
    . - _ _ . - _ - - _-__--_-_____--______-_____________-A
-  . - - - _ . .
      .
        ..
..
N ..: .,.v-


i The effectiveness of the licensee's planning for the security program was evident from the first preoperational review. De-I   velopment of the security program was on schedule and station administrative procedures pertaining to plant security and
i r
;
-
security program implementing procedures had been prepared and approved for use. Management attention was evident from the selection of personnel and the organization of key staff post-
i22      i
  ;  tions. The station security organization is directed by an
      .o
;
, ' '
experienced Security Program Manager, assisted by a Site Security Supervisor. Four experienced functional supervisors
  - Although the~ fun'ctional ' area was 'not~ severely challenged durin .this assessment period, the . licensee demonstrated levels .:of-  s l
,   are assigned to provide guidance and coordination in developing and implementing the program.
  , preplanning, preparation and program development co_nsistent with
  : a; plant- ready - for - operation. In: those' activities - where the'
        .
R
  : radiological controls. were: tested,' good results were achieved.'  '
The ~ licensee organization 'is staffed with qualified-: personnel, 4 from the station .HP, and chemistry management.down.. The overall:
      -
  . performance during this period ' indicates that the site radio-  ?!
logical, effluent control and chemistry ' programs- have been establis.hed with the capability ' to1 effectively support plant:
operation ~  .- !
l 2. Conclusion Category 1
        ]
3. Board Recommendations None:
i
,t


'
i<
Early establishment of these
+
program features enabled the regional inspectors to conduct
:  an in-depth analysis of the Physical Security Plan, Training and Qualification Plan and Security Contingency Plan even be-
;  fore the receipt of new fuel on site. It also enabled the NRC's Office of Nuclear Material Safety and Safeguards to com-plete its plan reviews and an onsite program review expedi-tiously and with a minimum of effor The experience and pro-fessional attitude of the licensee security management and staff were evident.


i
____._____________________---____--_---J
;  NRC representatives found that the licensee had established
,  a professional management team to select, train and manage the contract security force. The licensee has aggressively re-
'
sponded to all NRC initiatives and is currently prepared to implement a fully developed security program.


'
m .
'
z
With the receipt of fuel on site in February 1986, the resident inspectors routinely checked security controls for the fuel
.- .. l 7  )
;  building where the new fuel assemblies are being stored. Also, while not part of the Seabrook physical security program to
I
*
be implemented during operation, security controls of various areas of the plant where preoperational testing activities were in progress were inspected to confirm compliance with proce-
,  dural requirements and preoperational test assurance control These NRC inspections revealed that the appropriate program-j  matic security controls were being properly implemented.


.
E. Emergency Preparedness (219 hours, 3.2%) ' Analysis
l  Licensee management and security supervisors have provided a  L l  workable system for allowing NRC inspectors "immediate unfet- '
      )
tered" access to Seabrook Station for inspection purposes and
During the previous assessment period licensee performance in this area was rated as Category 2 (improving), based upon per-formance during the Near Term Operating License (NT0L) Emergency Preparedness Implementation Appraisal (EPIA) and the first full-participation emergency preparedness (EP) exercise. During the current assessment period, one NT0L appraisal follow-up inspec-tion, one routine safety insp6ction, and one special safety inspection were conducted. Additionally, changes to the Emerg-ency Plan and Emergency Plan Implementing Procedures were re-viewe Although not specifically addressed as part of their f assessment, it should be noted that licensee initiatives for off-site planning have been implemented and preparations by the site staff to support such initiatives are in progress. Licen-see efforts towards obtaining a workable off-site emergency plan reflect a strong commitment by licensee management towards a complete emergency preparedness prcgra Two NT0L Appraisal followup in:;pections were performed in March and June, 1986, specifically to follow up on twenty-four open items resulting from the appraisa While the first of these two inspections concluded on March 28, which was during the last-SALP period, it has been included in this assessment because it represented the conclusion of the EPIA inspection process at Seabrook and the report results were not available until well into this perio Licensee management aggressively addressed i NRC concerns resulting in the closure of twenty-two open iten The remaining two open items are required to be corrected prior i to issuance of a full power licens A routine EP safety l inspection, conducted in March,1987, related to inspection of l the training program, operational status of the emergency pre-paredness program, and security / emergency preparedness program interface Inspection results indicate a comprehensive onsite emergency preparedness program is in plac The special safety inspection conducttd in February, 1987, re-lated to follow-up of the sequence of events and circumstances ;
'
surrounding the classification of an Unusual Event on l February 11, 1987 and the required notification process. This
,   are developing plans for badging and access provisions for NRC personnel to facilitate future NRC inspections when the Sea-
      '
.
special safety 11 pection identified a violation of the licen-see's internal procedures. The licensee failed to follow the requirements of emergency procedure ER 1.0, " Classification and Notification of Emergencies at Zero Power", which requires i
brook Physical Security Plan !: implemanted. While NRC in-l  spection effort during this SALP period cannot provide a com-i   plete assessment of the licensee's security controls, both the 1
- _ _ _ _ -
:
*
lack of significant problem areas anc management responsiveness to security issues provide evidence of properly directed lic-l  ensee efforts in this area. Since the Physical Security Plan
!
!
        - _


.
mn p 7 ,
.
j. - *
  '
24'
,
j d.


will be implemented for Seabrook Unit 1 in sufficient time prior to planned fuel load for the licensee to identify problem areas, management attention to security controls should be focused in such a way as to address corrective measures, where required, Radiological Controls During the latter part of this assessment period, three in-spections were conducted by region-based radiation specialists into the following areas: readiness for preoperational inspec-tiens in radiation protection, radioactive waste management, transportation, and effluent control and monitoring; prepara-tion for initial fuel receipt; initial fuel receipt; and, radiation protectio During this assessment period, the radiological controls de-partment was involved in the management control system via the station operation review committee (50RC), radiation safety committee (RSC-ALARA), and frequent routine management meeting All interfaces between the health physics (HP), radioactive waste, chemi stry, instrumentation and control, and training had not been fully defined and documente Corporate responsi-bility for appraisal of the radiation protection prcgram was not clearly stated with regard to scope and frequency. Plan-ning and scheduling appeared adequate in that licensee provided readiness dates for preoperational inspections generally re-mained unchanged during the inspection perio General employee and radiation worker training programs were in progres While supplemental health physics training for self-monitoring had not yet been fully defined, active planning in this area was apparent from discussions with the license The Quality Assurance organization has initiated their sur-veillance program and plans to audit tre radiatico protection program on an annual basis, which exceeds standard requirements for audit frequenc The external personnel dosimetry system received NAVLAP certification during this inspection perio Acceptable quantitative ALARA goals have been establishe While procedural deficiencies in ALARA procedures were identi-fied, the HP staff committed to resolve them by fuel loa Satisfactory changes to the ALARA proccdures were initiate One revision has completed the licensee's review and approval process while the other is currently going through this ste The fact that considerable responsibility for implementing ALARA principles had been placed with job supervisors was ex-pressed as an NRC concer However, a need for additional ALARA training for job supervisors and upper level management had already been recognized by the license . .. -. _ -  .- , _ _ _ _ _ = - _ - . - . -  .-- _ - _ _ _ .
''
i .
notification of both Massachusetts and New Hampshire within !
fifteen minutes of ~ classifying, any emergency condition (as de-' i fined .in procedure ER 1.1). The causes of the violation, spec-ifically the failure to' notify . Massachusetts "within fifteen minutes, were - related to weaknesses Ein ther training of the operations. management and supervisory staff and are discussed in more detail in Section C.I.b of this repor The- emergency preparedness planning function continues to be
  .
  .
'''  controlled by the NHY corporate staff located 'at the plant site and close liaison exists.within the site organization. .09 ring this. assessment period, the position 'of ' Director of Emergency preparedness and additional corporate planner positions were filled by permanent NHY employee The. installation of. equipment and training of personnel to ful-fill their emergency response organization functions, while on-going, .has been substantially completed. First aid capability and nursing coverage have been addeo to-the. staff. Also,.addi-tional personnel to fill the key' emergency response organization )
positions on a twenty-four hour basis are currently involved in
"
qualification activities. The lack of on-shift dose assessment capability has been corrected and the addition of iodine deter-mination for off-site dose estimation-has been complete The licensee has been responsive to NRC initiatives. -This is in evidence not only by the addition and training of personnel to fill key functions within the emergency response organiza-tion, but also by the cooperation provided by NHY on the resolu-tion of NRC issues concerning the emergency plan and procedure Additionally, significant effort has been expo.9ded b/ licensee management toward the resolution of of fsite concerns. Although weaknesses 'in the training of supervisory personnel were uncov-ered during an Unusual Event, this incident was quickly and comprehensively addressed by licensee management. Overall, the commitment and performance by the licensee in emergency preparedness remains hig l 2. Conclusion Category 1 3. Board Recommendation None I
- _ - _ .      1


i
      - - - - _
:
_ ,
Adequate management control systems are in place in the area of HP. There is an adequate number of supervisory and profes-sional staff possessing acceptable educational and experience credentials. A simulated fuel receipt was conducted prior to
. .
;    the initial fuel receipt in February 1986. Approximately fifty i     percent of the radiation protection technicians are on hand;
25-    j F. Security and Safeguards (175 hours, 2.5%) Analysis i
'
l During the previous SALP period, the licensee was assigned a  '
the majority of the technicians present are fully qualified
Category I rating, as part of the Operational Readiness evalua-tion, for preoperational activities involving security personnel i training and the installation and testing of new systems and equipment for the Unit 1 Physical Security Program. In the cur-rent assessment period two preoperational security program reviews, one routine physical security inspection and one pre-operational nuclear material control and accounting review were conducted, along with physical security inspector participation in a Region I team inspection. No violations were identifie The NRC completed its evaluations and approved the Seabrook Station's Physical Security, Training and Qualification, and  i Safeguards Contingency Plans on July 23, 198 i Over the course of this assessment period, the licensee's staff has been involved in monitoring the performance of new security systems and equipment, evaluating the effectiveness of training and procedures and assessing the need for changes based on pro-  t gram experience and feedbac Both corporate and station management involvement in and support for the security program were evident and restited in the initial implementation of the Unit 1 Physical Security Program with few identified problem The allocation of sufficient number of technical and support personnel resultea in sound designs, good planning, and timely procurement and installation. Such oversight underscores senior New Hampshire Yankee management's support for an effective security progra Throughout the preoperational phase, the licensee was responsive to the resolution of weaknesses / concerns identified during NRC inspections and in NRC Bulletins, Circu-
,
      ,
by experience; the site-specific training and qualification manual process is being implemente Dosimetry procedures were found to be adequate, but not com-
lars and Information Notices. The licensee also initiated liaison with other Region I licensees, visited other sites, and developed feedback mechanisms to resolve security program .
:    prehensive. However, this was compensated by a strong training program in the dosimetry area. One deficiency in the radiation  ,
I issues. This has resulted in security program enhancements being implemented at the Seabrook sit Effective communic.ations exist between the security organization and the other station departments, as evidenced by the station response to security events. Program support and cooperation is also evident from local law enforcement agencies. The licen-see's security organization is actively involved in the Region I Nuclear Security Organization and with other nuclear industry groups engaged in the development of security program standards  m and innovative approaches to security issue ,
i    work permit procedures was noted, and the licensee has imple-
C
}    mented an approved revision which corrected the deficiency.
 
,
. .


j    Procedures for fuel receipt and the posting and controlling 4    of a radiologically-controlled area (RCA) were found to have i     been effectively use Recordkeeping was adequate, but docu-j-    mentation of the dose assessment methodology was found to re-
Twenty-four event reports were submitted in accordance with 10 CFR 73.71 during this period. Twenty-two of these reports resulted from minor problems typical to those encountered during the startup and continued testing and maintenance of new secur-ity equipment and systems, including the security computer and its associated software. While the licensee's event reporting program was found to be acceptable, NRC evaluation revealed that several reports required further clarification from the licensee l with regard to the analysis of causes and planned corrective i
!    quire additional licensee attention. Subsequently, the licen-
actions. During the latter portion of this assessment period, both an improvement in the quality of event reports and a reduc-l tion in the number of security event reports were note Staffing of both the proprietary oversight and contract security organizations was timely and effective. Management and super-visory personnel appear to be well qualified, experienced and motivated. Clear and concise security procedures were devel-oped, approved and implemented to ensure program cohesivenes Modification of these procedures is continuing in response to feedback and experience gained through use. The self-identifi-cation of program weaknesses and needed improvements by both the
'
'
ses remedied this NRC concern about dose assessment methodology documentation. Additional data is required to support the beta dosimetry methodology and is presently being developed by the
,
,
licensee.
contractor and proprietary staffs is encouraged by licensee l management and reviewed in a timely manner. Special emphasis is l currently being focused on the performance of security systems l and equipment, and their reliability. This ef fort is intended to enhance the ef festiveness of both short-term reactive and long-term . preventive maintenance for the systems and equipmen The level of staffing for security equipment maintenance program further reflects the licensee's commitment to a high quality progra The security organization's training and qualification program has been well established with full-time experienced instruc-tors, lesson plans, state of the art instructional aids and adequate facilitie Entry level training and annual requalif-ication training of security force members are administered in conformance with NRC approved criteria. Oversight by the pro-prietary staff ensures that the program is continuously updated to include feedback from operating experience. Members of the security organization were observed to perform their duties in a professional manne During the assessment period, the licensee submitted two revisions to the Security Training and Qualification Plan and a revision to the Safeguards Contingency Plan under the provisions of 10 CFR 50.54(p) and provided its response to the recent mis-cellaneous amendments to 10 CFR 73.55. The revisions were of high quality and indicative of the station management's continu-ing oversight of the program to ensure it is consistent with NRC


>    A whole-body-counting program is available and in use. A real-time computer-based personnel training and dosimetry record-j    keeping system is being utilized. During this inspection l    period, additional portable survey meters, respirators, and
- - . . -
!
_ _ _ _ - _
air samplers have been added to the licensee's equipment stores, j    while even more equipment is on orde However, testing and
.
!    turnover of certain systems to the station staff is not yet j    complete.
..
. .
4 performance objectives, Secur_ity personnel ' involved .in plan 3 maintenance are knowledge'able of NRC _ requirement Addition- ;
ally,.'the licensee's program - and procedures to control and !
account- for special nuclear material were' reviewed and found to- 1 be adequate, as _was the licensee's' plan for the protection of special nuclear material- of low . strategic significance .(new
;
r fuel).


i
In - summary, the licensee has established an l effective Physical Security Program. Efforts to improve the' operation and reli-ability of systems and equipment ' and personnel qualif.ication have - continued. The security program is actively supported by.- .
!    While the radioactive waste (RW) management, transportation, I    and effluent control and monitoring areas did not receive de-j
      )
'
other plant functional groups,: as evidenced by the lack''of problems _ in _ the maintenance of security equipment,_ response 'to 1 events and other areas where effective ~ interfaces- were necessa r Both corporate and station management ~ support of security programs and initiatives is evident, l Conclusion Category 1-
tailed inspections during this assessment period, NRC inspec-tors did review the organizational reporting lines and responsi-bilities and did interview responsible supervisors in these
;    disciplines. The laboratory facilities were observed to be i    spacious, well kept, and well equipped. Emphasis on multiple
'
levels of quality control was apparent from discussions with chemistry personnel . It was noted that RW supervisory and i
'
technician staffing is almost complete and that health physics training to be provided to radioactive waste handling personnel is being develope l t


1
  - 3. Board Recommendation    1 i
, . - , ,,m--- - - - - - - - - - - - - . - , , . , - - - - - - - - - - - - - - - - - - , - ,,--- - -
Non .       .


. . . - - . - - _ _ _ _ . -- _ - -    _ - . - _ _ _ _ _ _ .
j i
i j
i
*
!


1 Several new fuel shipments have been received, and adequate radiological controls and attention to DOT regulations were observed. Work controls were demonstrated to be effective for fuel receipt and for controlling and posting of RCAs. The
- _ _ _ . _ _ _  _ . _ . _
;    planned operational survey and monitoring program is acceptabl The operational readiness of the four radiological controls i
l t I i
areas (radiation protection, waste management, transportation i    and effluent control and monitoring) in regard to organization j    and management controls, staffing and training, work controls and procedures, and facilities and equipment exceeds what would l    be routinely found at a plant like Seabrook Station Unit I at i    this preoperational stag Since radiological controls func-t    tions have not yet been adequately challenged by operational j    requirements, a full assessment cannot be made at this time.
I 28  ! Engineering Support (579 Hours, 8.3%)  -{
1 Analysis This area was not evaluated as a separate Functional Area during the previous :SALP period, although the engineering services
  .provided to support construction activities were considered in the overall assessment of the' construction are During this current SALP period, engineering support to . the station staff is assessed based upon the engineering services provided to ~ the plant maintenance -and modification processes, the analyses performed to address NRC concerns 'and self-identi-fied design problems and the: licen_see's overall. technical ability to . support construction completion and ongoing opera-tions fromL an engineering . standpoint. It is noted that _ during this, period, a reorganization of both the corporate engineering and technical support staffs occurred. . A New Hampshire: Yankee . i engineering organization was established with a smaller in-house review capability than existed during the period of full con-struction .and architect / engineer presence. However, well de-fined agreements with . both UE&C and YAEC were established to provide additional engineering services on an as-required basi The station staff also restructured their technical support capability to align with a system / discipline service orientatio While this licensee reorganization has tailored the engineering staff more directly in support of operational activities, cer-tain problems have arisen during this SALP period which high-light the need for more timely and complete engineering analysis of deficiencies particularly by the corporate engineering staf Examples of such problem areas included NRC identification of a Control Building Air (CBA) system which deviated from system-design commitments provided in the FSAR and also of a Contain-ment Building Spray (CBS) piping design which required upgrade and implementation of a design modification to meet the intent of the pertinent ASME Boiler and Pressure Vessel Code. In each case, licensee events or observations had identified evidence of the problem areas (control room ventilation isolation events in the case of CBA and leaking check valves in the case of CBS),
but were not sufficiently developed by engineering review to effect timely corrective actio Ultimately, in both cases, system modifications were effected and NRR review and approval of the CBA and CBS designs were require .
_--._l----__------___


l
l
'
.
However, based upon supervisory awareness of the problem areas and what still needs to be accomplished, the Radiological Con-
,1 4
;   trols Program appears to be heading on a proper course. This i    positive trend should continue, provided that the management commitment, the degree of preplanning and preparation, and the
 
            '
S      q
;
,
!    attention to detail remain at the same level that has been l    de,onstrated up to this point.
Other noteworthy problem areas included the' identification b "
      .
the licensee of. tube erosion and pitting problems in the primary i component cooling water (PCCW) heat excha ngers ,- evidence of valve lining detachment and ' degradation. in the Service Water (SW) system, and a common mode failure of equalizing valves in the containment equipment hatch' air lock doors. The latter two 3'
issues represent items which were reported by the licensee unde the provisions of 10 CFR 21. Unlike the handling of the CBA and
: CBS problems, however, licensee > reaction by the station . tech-
    .
i nical support' staff to these. major problems . was_~ thorough,- j methodical and.well scheduled. Eddy current testing lof the. PCCW - !
heat . exchangers ; was implemented, . resulting in the conduct of i tube plugging and sleeving operation The SW valve ' lining- I configurations were redesigned' and .a comprehensive test program j was implemented to verify adequacy. The equipment hatch air  j lock equalizing valve ' linkage was also redesigned to preclude l recurrence of a similar failur i i
The only negative aspect to the . licensee responsiveness to these problem areas. was the fact that the SW lining problems repre- -
sented, in - ef fect, a weakness in the licensee's corrective  l action. for a 10 CFR 50.55(e) report issued in 1985. At that time, the original valve rubber-like linings were replaced by "Belzona D&A" elastomer. However, it appears that both the replacement design and the construction bonding process . were defective, resulting in the current problem The licensee's j current approach to both the engineering and process. controls required to repair these valves, however, appears to be thorough i and well directe _l In response to concerns raised by the NRC with respect to the  !
engineering department interfaces with the station staff, the licensee has implemented new initiatives to foster mutual co-operation and reliance on technical expertise to address prob-lems. This cooperation has- evidenced itself in corporate engi-neering management attendance at " plan of the day" meetings, the more timely involvement of the corporate engineering staff in operation decisions related to the FSAR and design basis  1 analysis, and plans to relocate corporate engineering personnel !
from the general office building to offices closer to the plant !
itself. Both the Independent Review Team (IRT) and Independent l Safety Engineering Group (ISEG) appear to be functioning in an !
atmosphere which provides valuable overview to not only site  i specific engineering problems, but also generic issues affecting :
the industr Current New Hampshire Yankee Engineering Evalua- I
      '
tions from the corporate staff provide a documented, well defined approach to technical questions. Thus, the licensee has demonstrated a willingness to implement programmatic improve-ments not only where deficiencies are identified, but also where weaknesses are perceive ii
__b


;
--- _ _ - _ - _ - _ _        _ _ _ _ _
i Conclusion
.  .
(          30 As was discussed in Section IV. A with respect to construction completion, engineering support activities related to the design reconciliation of the as-built plant (e.g. , PAPSCOTT) were ef-fectively implemented to assure compliance with the design bases and FSAR commitment Licensee corporate management has demon-strated a willingness to implement design modifications where justified by internal engineering evaluations or independent staff reviews. This -licensee responsiveness to determine and effect the proper engineering solution to identified problems (e.g. , EFW Terry-turbine testing; service water valve lining repairs) continues to represent a licensee strength. The recur-rent nature of some of the problems described here and in other sections of this SALP report does, however, highlight the need for additional licensee attention to adequate control of the corrective work processe In summary, engineering services to the station construction completion, maintenance and modification efforts has evidenced some transitional problems from reliance on a large staff, heavily dependent on architect / engineer (UE&C) support, to a smaller New Hampshire Yankee in-house engineering program. The licensee has recognized these problems and appears not only to understand the need for improvement in support of future opera-tions, but also to have initiated corrective measures to proceed in the proper directio . Conclusion Category 2 l Board Recommendation None
          .
__ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - ~ ~ ' - " - - - - - ' - ' " - - - - - - -  '-- - - ~ ' '


,
_ _ _ _ - - _
Rating: Category .
  .. .
Trend:  Consistent.


; Board Recommendation      ,
H .- Licensing Activities I Analysis This area was rated as Category 1 during the previous assessment-period based upon the required preparations, responses to open items, and.overall readiness with respect to the issuance of an !
)
operating . licens The previous assessment. concluded 'that .I
A normal level of inspection activity on part of the NRC shall be i  maintained during the next SALP assessment period due to the pre-operational nature of the findings in this area.
,
  ' management involvement was evident and effective, that a high'  {
degree of responsiveness was apparent, and that corporate staf- !
fing levels were sufficient to support licensing . actions. Since the previous assessment period, a license has _ been is' sued to permit fuel load and the conduct of' precritical test A license to. operate.up to five percent power has been requeste The current assessment is based principally on NHY performance  !
in support of those. actions which were required to obtain a fuel l
  . load license and which were taken in connection with its request I for issuance of the five percent licens The licensee . has continued' to demonstrate - strengths in their approach to problems from a safety standpoint, in the qualifi-  !
cations and level of staffing and in the active involvement of-corporate management. The licensee has provided 'the needed tech-
  .nical capability in the engineering and scientific disciplines to' resolve items of concern to the NRC. Resolutions to tech-nical issues have been consistent and thorough. The licensee has been willing to perform additional studies, as necessary, to answer any outstanding NRC question . Thu s ,- on technical matters, ef fective communications between -the licensee and the NRC staff have been beneficial in processing licensing action The licensee. f acilitated timely resolution of the majority of outstanding licensing issues. . In .most cases, acceptable pro-posals were submitted with the initial licensee response. The overall responsiveness to NRC initiatives was generally satis-factory, except for certain issues, where in the first part of the current SALP period, additional NRC requests were needed to gather ' complete information. For these cases, NHY corporate management involvement and timely action were effective in promoting satisfactory resolutions to the specific problem NHY management has actively participated in licensing actions and generally has maintained awareness and knowledge of current and anticipated licensing activities .during this evaluation period. On several occasions, licensee management has demon-strated not only involvement in licensing, but also p romp t ,


t
l -


!
__ - - - _ -  -
!
~.
i
4h-
  ..
  ;; !. . -
!


I
      -
!
  .
,
,
f I
appropriate corrective ' action to situations where . the respon-siveness to NRC initiatives was deemed unacceptable or not timely. --NHY has also demonstrated a willingness to ' meet with the .NRC Licensing Project Manager to; discuss licensing action status on an as-needed' basis and with a cooperative attitude to resolve problem NHY. licensing and engineering groups have b'een adequately-staffed, as' indicated by the qualified representatives attending-numerous meetings with the NRC, . Competent technical staff have
  -
participated' in scheduled reviews and . effected satisfactory
      . resolution of open items. The NHY Bethesda Licensing. office has
      . remained active throughout this SALP period as a significant licensee -initiative which continues to provide priority atten-
          -
tion toL NRC concerns. In ' general, - the licensing group has ef fectively coordinated the effort of providing input from 'the -
,
      .differeht functions within the NHY organizatio ' Conclusion
  ,
Catego'y r 1 3 '. Bosed Recommendation None
        >  ,
:
      %
i
i
  ~ . , - -n. .._,  . . - - _ - _ _ . . _ , . _ , _ _ . - . , - , - - - - . - - - .
  .
_ _ _ _ _ _ _ . _ _ _ _ _ _ _ - - - _ - - --'


.
__ _ _
.
  .
-
.: ... ,
J i
l 33  'j
        )
  ' Training and Qualification Effectiveness
  '
i Analysis Training and Qualification Effectiveness is an evaluation cri-
  .terion for each Functional Area. 'In .this appraisal, it is!also being considered as a separate area and as such, represents c a synopsis of the assessments .in the other areas. Training effec-tiveness is measured by observation of licensee personnel per-formance and through reviews of licensee. programs,  _
The limited scope of operations during this assessment period has not allowed for an appraisal - of the - effectiveness. of train-
        .
        {
ing over the full . range of operational activities:which will be I implemented in the future. However, in those. areas where the measures of licensee performance can be related. to ' training and - !
qualification criteria, this assessment provides an overall i evaluation of the effectiveness of control and conduct of' i licensee work activitie !
In the last SALP period, this functional area was not evaluated !
separately, but Operator Licensing was assessed a Category 1 rating as part of the overall operational readiness appraisa !
During the previous assessment period, the licensee had demon- ;
strated a commitment to quality training. This commitment has remained evident through the current SALP period based upon licensee initiatives in the areas of simulator enhancement and efforts directed toward licensed operator training program accreditation by the Institute of Nuclear Power Operations  3 (INPO).


E. Emergency Preparedness (634 hours, 8%) Analysis This functional area was not evaluated during the previous SAL During this assessment interval, New Hampshire Yankee (NHY) has placed considerable emphasis on the area of emergency preparedness as they have approached their projected fuel load date. Two NRC team inspections were conducted to perform the NT0L Emergency Pre-paredness Implementation Appraisal (EPIA), and a third inspection was conducted to evaluate licensee performance during a full parti-cipation exercis The emergency preparedness function is controlled by a corporate staff that is located at the site. This staff maintains a close liaison with the site organization. The organization and staffing is ample, principally consisting of a Director of Emergency Planning, a Radiological Assessment Manager, an Emergency Preparedness Super-visor, and two Senior Emergency Planners. The position of Director of Emergency Planning is temporarily filled by a contract consultan Installation of equipment and training of personnel to fulfill their emergency response organization functions is ongoing but has been substantially completed based on observations made during the two appraisal inspections and the exercise. The EPIA was begun during December,1985, based on the applicant's firm judgement that they _
The first group of operator licenses at Seabrook became due for renewal during this period. Two year license renewals were issued for these individuals. A requalification program eval- q uation was also iritiated to provide a basis for the license >
had reached a condition in which the emergency preparedness program could be adequately evaluated. However, the appraisal had to be terminated prior to completion because equipment, training, and procedures had not been sufficiently completed to assess the EP program. This appeared to be indicative of inadequate planning on the part of the license Sufficient progress had been made by February,1986 so that the first full-scale exercise was conducted on February 26 and the appraisal was completed on March 28, 198 The principal concerns identified during the appraisal are a lack of sufficient numbers of qualified individuals to fill the key energency response organization positions during an emergency on a twenty-four hour basis (presently only a primary and one alternate are qualified) and lack of on-shift dose assessment capabilit NHY has committed to have at least three people qualified for each key EP position prior to issuance of a full power license and to provide shift personnel with a programmed calculator to meet the requirement to perform dose assessment at two, five, and ten miles, prior to the arrival of the augmentation emergency response staf The exercise on February 26, 1986 involved the utility and the state of New Hampshire, as the Commonwealth of Massachusetts Emergency Plans had not yet been submitted for review by FEMA. No major on-site deficiencies in the implementation of an adequate emergency response were identified during the exercis In general, personnel
renewal. To date, this evaluation has consisted of an NRC review of the requalification program and an NRC requalification examination administered to eight licensed operators. Three operators failed one or more portions of the NRC administered !
requalification examination and are being upgraded in accordance +
with the existing NHY requalification program. Training Depart- l ment actions to address NRC identified generic weaknesses and j strengthen the overall program have been initiated and appear i well directed. As had been evident in previous, less formal NRC appraisals of operator training with respect to requalification, the licensee has demonstrated a willingness to devote adequate l resources to the training goals and to commit additional  )
resources to upgrade identified areas of weaknes I l
- _ _ _ _ - _ - _ - _ _


_ _ _ . _
M
.,; .
3      .>
    ,
    .34
>      1 It..should be::noted 'that' another initial operator licensing
    -
?  -
examination .was administered in August,= 1987. . Although this '
examination'was conducted shortly aftere the end of this current SALP assessment period, the results Lindicate ; a high initial >!
  . examination pass - rate which is consistent with the previous  ~
initial. license' examinations:at Seabrook Station, A review of the LERs and enforcement actions issued during this SALP ' period identified certain problems 'related to training effectiveness. ~As discussed in other Functional Areas, viola-tions resulting from the failure ~ to ' maintain a.. valve': locked-- ,
closed in accordance with license conditions and the failu're to-
        '
follow' procedures in notification during_ the Unusual Event, were caused .in part by training deficiencies. Additionally, . incom- i plete operator understanding of - the design bases of . the CBA system design, as noted in Section IV.G, led to a violation, af ter a deviation from FSAR commitments had already been issued l-on the same subject. The problems, however, appear to have been "
isolated examples,, as the' overall training provided the opera- 1 tions staf f.is of high quality with no major generic weaknesse An.eva'luation of the LERs issued during this assessment period identified no specific causal linkage between performance-related problems and the adequacy of trainin In the area of general and specialty training, a reorganization-has consolidated all training functions under the-Training Center Manager who previously was responsible only for licensed operator trainin This change should enhance the overall training effort while reducing the administrative resp'onsibil-ities'of the Station Manage NRC inspectors monitored various licensee training sessions both for the purpose of on-site program familiarity and to assess the '
effectiveness of licensee training in areas such as general employee training, radiological controls and fitness for dut Also, NRC inspections of other functional areas have evaluated the conduct of training (e.g., Technical Specification revision training for operators, entry level and annual requalification for the security force, supplemental HP training, and general EP training provided the licensee Emergency Response Organizatio This inspection effort has confirmed that the training and qual-ification criteria inherent in the implementation of other tech-nical programs have been effectively utilized. Region I special team inspections into allegations regarding Seabrook construc-tion hardware and programs revealed no specific disciplinary  ,
training deficiencies and no generic problems with the licensee program of education and handling of substance abuse policie .
.
.
*
__ _ - _ . _      l


involved in the exercise demonstrated a high level of training and knowledge of their response functions. Assessment of plant condi-tions and recommendations of protective actions for the public were timely and conservative. The EOF is of adequate size and functioneJ effectively with both the state of New Hampshire and a response team from NRC Region I participating in the exercise. Several deficien-cies were identified by FEMA with offsite response by New Hampshir These areas will be reassessed in a subsequent exercise prior to consideration of a full power licens That exercise is also ex-pected to include participation by Massachusett There has been excellent cooperation on the part of NHY with the NRC on the resolution of issues concerning the Emergency Plan and procedure . Conclusion Rating: Category Trend: Improvin . Board Recommencation Continued licensee attention to EP issues and to the resolution of the open items resulting from both the EPIA and the emergency exer-cise is warrante .-
.
l l
  . -
=     l
        ,
    '
,, -
y,. or
  .j..' i 13 -
        =


F. Assurance of Quality Analysis During the previous SALP period, " Quality Programs" was assessed a Category I rating based primarily upon the strong and stabilizing influence that the QA program at Seabrook has had upon project and construction controls. During this period, quality program effec-tiveness has been assessed by both resident and specialist inspec-tor Various aspects of this functional area have been considered and discussed, as appropriate, as integral evaluation criteria in other functional areas and the respective inspection hours are in-cluded in each one. It is noted that management involvement in as-suring quality is one attribute that is considered in the assessment of licensee performance for all areas. Consequently, this area is a synopsis of these discussions relating to the quality of work, and management's role in assuring i An NRC team inspection (the first CTI discussed in Section IV. A of this report) dedicated significant inspection resources to licensee management programs and quality assurance. Two of the licensee strengths documented in that inspection were attributed to Site Management and Quality Assuranc New Hampshire Yankee (NHY) man-agement was recognized for both its positive management support of quality and the establishement of new programs and directives (e.g.,
      .
the Independent Review Team, the Employee Allegation Resolution program, the Piping and Pipe Support Closecut Task Team, and the reorganization of site engineering under one director) The site QA function was cited as a strength because of the implementation of effective audit and trending programs and for its responsiveness in initiating comprehensive corrective action A review of the enforcement data in Table 3, reveals that of the four violations attributed to this functional area, two involved improper handling of Nonconformance Report (NCR) dispositions and two involved incomplete follow-up of corrective action on Construc-tion Deficiency Reports. Thus, in all four cases, the site QA pro-gram was instrumental in finding the subject problems, but licensee measures were not sufficiently complete to assure proper correc-tion / repair of the identified problems. These examples represent somewhat of a continuing negative theme from the last SALP where licensee correspondence to the NRC on CDRs and enforcement actions was found at times to be incomplete and corrective repair / rework was not always timel As was discussed in the CTI as a strength, the initiation of cor-rective action at Seabrook appears to be well directe However, the total assurance of quality depends upon every licensee employee, and particularly upon supervisory level responsiveness to the prob-lems. If corrective measures are not followed through in the same
l-
!,
      .
        .-l Thus, 'a review of flicensee1 performance across Lthe. range, of
        .
        "
  'different disciplines,- as .' highlighted 'in .theidifferent' func -
  -
tional areas, reveals that- the. conduct of. adequateLtraining and


. _ . _ - - -  - _ _ _
qualification programs have contributed to the successful'imple- ;
e
cmentation JoF overall station objectives. An additional example {
.
  'of licensee; philosophy in this regardLwas the wide disseminatio l of technical''information, either industry initiated oraNRC' I
  ! originated, throughout'the station staff. This information flow has effectively increased the; station's awareness to problem areas-in the industry and.has provided guidance.to the technical
  ' staff for' performance improvement N  ' In summ'ary, in those 1 areas 'where : NRC and licensee- evaluation I have identified ;trai.ning related weaknesses, prompt. and ef fec-
  .
tive , corrective ' measures, including the retraining of ~ personnel, have'been implemented. With respect.t'o the overall: control' of j training ' functions and ~ performance by statio_n personnel, NRC l inspections over' the course of. this SALP period have found the
    -
i licensee programs and_ staff.to be effective, i Conclusion-
    .
i,
  .. Category 1 - Board Recommendation    ;
'
None i-1
  ,
j


i comprehensive vein as the inspection program that first identified the items, the results are continuing problems and, as was noted
I
- _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ _  - _ _ _ _ -  - --
. .


in the preoperational test area (Section IV.8), recurrent enforce-ment findings. Management attention to this concern is warranted as new operational programs are developed and different technical
J. Assurance of Quality Analysis Management involvement in assuring quality is an evaluation criterion for each functional area. Quality assurance (QA) also l
:  areas come under inspectio Despite the examples of corrective action problems, noted above, NRC inspections have generally identified a minimal number of prob-lems, particularly in the hardware area. This was substantiated
'
'
by the as-built team inspection (CTI) conducted at the end of this
is an integral part of each functional are This appraisal of the assurance of quality is a synopsis of the applicable aspects s of other areas, including worker and supervisor performance, management oversight, and safety review committee activitie During the last SALP period, this functional area was assessed a Category 1 rating based upon an ef fective QA program, which assured construction quality, and the continued management support of QA initiative;.
!  assessment period (March, 1986). Management reinforcement of qual-
During the current assessment, an entirely new QA program, that of operational quality assurance, was subject to evaluation along with a new organizational structure, revised interfaces, different work controls, and the necessary shif t from construc-tion processes to maintenance and modification activities. The interdependence of NHY QA policy and procedures with the Yankee AtonHc Electric Company (YAEC) program was eliminated and key personnel responsibilities shifted accordingly. It is note-worthy that the licensee retained sufficient experienced per-sonnel from contractor organizations (e.g., YAEC, UE&C, Westinghouse) to effect a smooth transition into the operational system of control However, certain transitional problems have been experienced in the restructuring of the QA organization to fit its operational responsibilities. While management support of an effective QA program remains strong, the relative strength of the QA organi-zation as an independent force and prime mover in the corrective action process has diminished. This may be the result of and a normal consequence to the establishment of a strong station staff with particularly qualified and technically competent operations, maintenance and technical support groups. However, one negative aspect of this has persisted throughout the current SALP period and relates to the feeling that the station staff can disposition their own problems without the need for QA involvement and that the QA staff mission relates more to pro-grammatic and procedural overview than it does to the effective-ness of control . - - _ _ _ _ _ - _ _ _ _ - - _ - _ _ _ _ _ _ -  _ __ _ _
)  ity objectives is evident not only in the support of the QA program, l  but also in first-line craft and supervisor training and in project policy statements routinely issued by the construction manager to prevent individual problems from becoming generic issue A "Startup Quality Assurance Interface Agreement" between the con-struction and operations QA program staffs, and with the concurrence of the station manager and the startup test department manager, has
. .
'
. .
been implemented. This Seabrook QA policy defines various organi-zational responsibilities and scopes the role of the Operational QA Program from the time of Conditional Acceptance Turnover (CAT)
of components, structures or systems to the initial fuel load of Seabrook Unit The planning and coordination that has served as the basis for such a QA policy appears to be well thought out and should provide the necessary direction for the further implementa-tion of QA controls as the transition into operations continues.


NRC inspection issues which have highlighted this concern include questions into tagging controls, station operating and surveillance procedures, the use of unauthorized operator aids, general housekeeping and corrective action processes, and utilization of Station Incident Reports as an information source for root cause problem analysis. In several of these cases, where a specific NRC recommendation for QA follow up of the identified deficiencies was made, audits were conducted. These q audits proved to be extensive and thorough and generally con" firmed a need for corrective actio However, the fact that such QA reaction to the problems was not routine, but evident only upon NRC interest is a matter that warrants further manage-ment evaluation of their QA program of controls, t
One strongpoint of the present QA program is the effective use
'
'
NRC specialist inspections into the operational preparedness phase of the Seabrook QA program have identified no substantive weaknesse Licensee QA interface controls for design changes, maintenance, procurement, and testing activities appear to be working as addi-tional components and systems achieve CAT status. Licensee attempts I  to achieve some measure of practice in the implementation of such
of quality control inspections and holdpoints to confirm the 5 proper conduct of special processes. The implementation of such l    QC measures has strengthened an already strong maintenance pro-gram in the area of independent checks and assurances of the adequacy of controls in the various discipline Another pro-g rammatic strength is the individual expertise provided by the i
!
technical support staff. The NHY system engineers, while not QA l
'
'
controls, by initiating the program first for nonsafety-related equipment, have successfully identified some problem areas requiring program revisio As discussed in other functional areas in this SALP, licensee man-
personnel, provide a definite measure of effectiveness to the overall station assurance of quality, based upon their knowledge and technical interfacing with other personnel on the station l    P.aff and with the QA and engineering organization This strength relates to an overall NHY organizational structure which appears to be effectively working, while still providing a system of independent checks and balance Examples of independent groups within NHY which provide quality services which have supported the successful functioning of the overall organization include the Independent Review Team (IRT),
{  agement's approach and priorities toward the achievement of pro-l  grammatic controls that assure quality appear well directed. The licensee's initiation of an FSAR Consistency Review has provided programmatic response to previous NRC concerns regarding errors in
the Employee Allegation Resolution (EAR) program and the Independent Safety Engineering Group (ISEG). Both the IRT and ISEG have been involved in design evaluations, and the analyses of component failures and human factor problems which have led to reportable events. In the same way with respect to allega-tions, the EAR program has provided a " third party" review of concerns which has not only proved beneficial to the investi-gative process f o'r worker concerns, but also has provided a measure of independence to the normal management review of problems. The IRT and the EAR were also both noteworthy as licensee initiatives which were established and maintained, not because of regulatory requirements, but because of the benefits the licensee knew would accrue from independent self-evaluation Programmatically, these independent groups, along with the Nuclear Safety Audit and Review Committee (NSARC) and the use of special review groups where necessary, have provided a measure of the licensee's ability to self-criticize and thus learn and improve with the corrective action proces __
.
      - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
the FSAR and has established a better basis for the continued de-l velopment of test criteria and operational procdures. Other man-1 agement initiatives, like the establishment of a site licensing
L. .  ...      .;
!  office and a site organizational restructuring, have provided a j better framework for responding to NRC concerns and other quality j  items requiring action. As has been recognized by previous SALPs, i
 
i l
1
t s - - - - - -m,.-1.-- y w-. ,..r_ --y__..~,,___w- -
    , . 38'
      - . - _- . . . - - - -
          {
      --
Another licensee internal review group, the Station Operation Review Committee (SORC), has also ' been . active during this assessment period in reviewing program and procedural revision Some ' administrative problems in SORC. effectiveness were iden-  i tified by the NRC with respect to the application of safety  j review criteria to "nonintent" procedural changes, _ Also, the  "
practice of conducting such reviews outside the. scope of the SORC rneeting was questioned, On both these matters, the licen-  i
          .
see' recognized the . advisability of . instituting . improvements to  ,
the SORC and safety . review processes and implemented additional !
systematic review measures to address.the NRC concern ,
 
Another program where - NRC ' inspection revealed the need for  i further development was the licensee's implementation of a Quality Trending System. Weaknesses . identified ' in .this area -
related to the lack of corporate and QA management attention to  i the availability of problem trending mechanisms and ' also to a  I database which fails to track the valuable. trending information available in documents other than nonconformance reports,   j Licensee . QA management was apprised of these concerns and 'has  ,
instituted. program reviews intended to upgrade ,the defined cor- i rective action proces Continued attention to the controls  l which integrate plant activities and ' problems (e.g., Station Incident Reports) into a QA trending system,- thus providing insights into the lessons learned, is warrante Overall, in evaluating this _ functional area, in the context of  ''
quality criteria affecting other rated areas, a high level of performance was note Effective work controls, strong first  i line supervision, timely QC inspection and a continued emphasis on quality performance, to include management support of QA  ,
goals, have resulted in evidence that the plant is being oper-   i
  ^  ated and maintained safely. While some areas requiring improve-ment were identified,. positive licensee initiatives were also noted to sustain the Assurance of Quality during the major transition from construction to operations. A strong quality conscious attitude is evident throughout all levels of the plant  i organization. The increased involvement of the QA organization into operational activities and problem analysis should further enhance the overall effectiveness of the quality progra . Conclusion Category 2


.
0
.
    '
- _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ . _ . . .


an effective QA program has been and is in place at Seabrook Station and continued management support continues to provide the necessary assurance of qualit . Conclusion Rating: Category Trend: Consistent. Such a consistent trend recognizes continued management attention to quality programs during the transitior, phases of the Seabrook project from construc-tion to preoperational testing and on to operational readines . Board Recommendation Non _ .  - ..- . - . _ - _ __- -_ _ . _ _ - . - - - _ - - - . . - .. _- - _ _
- ____ __  _ _ _ _ _ - _ _ _ - - _ _ - _ _ _ - _ _ _ - _ - - - - - - - _ - - - _ - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
  . .
  . .
,
39 Board Recommendation Licensee: New Hampshire Yankee management should reassess the role of the QA organization in the analysis of opera-tional problems. The licensee should consider expan-I
n a j      30
!
i t
' Licensing Analysis j
'
'
During the last assessment period, the licensee's overall perform-
ding the scope of quality assurance functions to more effectively utilize QA as a management tool to recog-nize the generic impact of certain problems, and thus allow corrective action to be directed to related areas of programmatic weaknes NRC:  None
<
- _ _ - - _ _ _ _ - _ _ _ - _ _ _ - _ _- -
ance in the plant licensing area was considered satisfactory and improving with evidence of licensee management attention and in-
 
.
  't
I volvement.


f   During this current SALP period, the basis for this analysis was the licensee's performance in support of the following licensing actions, which were either completed or active during the current assessment period:
   . ...
   --
..
l    fire protection
40 ; SUPPORTING DATA AND SUMMARIES
'
        .. . Investigation and-Allegation Revie ]
'
    :During .this assessment period, a total of four separate and gener- }
  --
          ;
vibration of diesel generator instrumentation
ically categorized allegations were received by . the NRC. One '' of
  --
''
containment systems
these. generic sets of concerns was-multifarious and' involved concerns of. a broad and general. nature. To date, over 1000 hours of direct NRC j i-   inspection effort have been expended to determine whether quality construction ori. safe operation had been 'o r could be adversely l j
  --
l    impacted by this ' set of stated allegations. In. this case, as ..with : j the other' three. allegations, no violations were identifie ~l It is'' noteworthy that while several of the stated concerns involved nonsafety-related components, NRC inspection treated - these allega- ,
materials engineering
tions rigorously as technical issues to determine if s' ome deficiency '
  --
could be linked to safety-related activities. No linkage was-identi-i   fied, and, to date, no hardware problems (either safety or'nonsafety)
emergency preparedness
   --
instrumentation and controls
,
  --
detailed control room design review j  --
electric power systems environmental qualification of electric equipment
'
  --
!
!
  --
have been-in evidence. While evaluation of several new concerns ' is in~ progress, the findings 'so far corroborate the quality of con-struction. These results also confirm previous NRC . assessments that-
seismic and dynamic qualification of mechanical & electrical equipment
    -over the. course of construction -completion, few hardware . problems have been identified and those that had existed have been adequa'tely-correcte Escalated Enforcement Action None L Management Conferences No conferences with the licensee dealing with enforcement were held during the appraisal period. On June 10, 1986, a management meeting at NRC request was conducted at Seabrook Station to discuss the results of the Region I SALP board convened to evaluate licensee performance from January 1, 1985 to March 31, 198 Review of Licensee Event Reports (LERs) Tabular Listing Refer to SALP Table 4 for Listing of LERs by Functional Area s
,
e
  --
_ . , _ _ . _ _ _ _ . _ _ _ _ _ _ .
licensed operator requalification
 
>  --
  '
safety parameter display system
g4
  --
   -
technical specifications During the latter half of calendar year 1985, licensing actions on
  -
-
  ..
the part of the licensee began to pick up considerably. This clearly l  was necessary because a number of SER outstanding issues needed re-
    ,
;
,. s.-
solution. During this SALP reporting period licensee's management
t
;   involvement in licensing actions improved significantly. The lic-i ensee's management has been accessible and available to assure that necessary corporate decisions are arrived at to bring about resolu-r tion of NRC concerns. Of particular note is the licensee's manage-
,   nent involvement in the Seabrook proposed Technical Specification
!  (TS) improvement program. The staff has determined that many of
  '
  '
the objectives in the licensee's TS improvement program coincide with those of the NRC program to improve TS. The licensee's effort in this area has been sizable and represents a commendable reflec-tion of licensee management's involvement and commitment to this progra ,
41'    <
,
_ Causal Analysis 7  Analysis of the LERs listed in: Table 4' has identified no unac--
It is noted that the licensee has dedicated substanital resources
ceptable. chains per statistical acceptance criteria.' . An AEOD evaluation of-Seabrook!s LERs indicated that the reports were of
!
  . generally above-averageL quality. . ' Additionally, one ' other non -
i to the development of appropriate Technical Specifications (TS) for Seabrook Unit 1. With the issuance of the " Proof and Review" edi-
''  . reportable event was' identified which Was lin ed to.a reportable
;  tion of TS in March 1936, the licensee has initiated a substantive I  review process to correlate the TS to FSAR commitments and current
. ,
]
event. While the licensee ' had notn recognized this. linkage 'in subsequent reporting, this had no effect on the causal analysis-
<
  .or the'result . Summary of Licensing Activities Significant-NRR/ Licensee Meetings-a. June 26, 1986 --
J
Operational Readiness of.Seabrook Unit 1 b. August 6, 1986 --
.
Seabrook : Station. Risk' Management and Emergency Planning,.(RMEP)'. Study. and-Emergency'' Planning Sensitivity (EPS)
  . . -- _
Study c. September 4, 1986--
  --- - - . _ . - --
  . Seabrook Fire. Hazards Analysis  j u
d. September 8-9, 1986- NRR '& Brookhaven National Laboratory (BNL) Site Tour for RMEP & EPS Studies e. September 23, 1986 - RMEP & EPS' Studies
  'f.' March 18, 1987 -
Seabrook Unit 1 Licensing Issues g ' March'25, 1987 --
BNL Report on RMEP & EPS Studies i
  ". h. May 7, 1937 -
Seabrook Unit 1 Licensing Issues 1. July 30, 1987 -
Utility Compensatory  E-Plan for Massachusetts Commission & ASLB/ASLAB Decisions a. October 17, 1986 - Issuance of Facility Operating License (NPF-56) for Zero Power Testing b. November 20, 1986 - ASLAB Denial of Zero Power License Appeal (ALAB-853)  by Massachusetts c. January 9,1987 -
Commission Review of ALAB-853 Stays Issuance of Low Power License l
_ _ _ _ _ _ __________ ____--_ __ -_ - E


   . . --. _ _ - - - . - - - - _ .-- - -_ _ _ - _ . __ - _ . .
   ._ . _
[.
    . _ - _ _ _ . .
f
        - ,
.
  . .


i
l
'
        .
design precautions, limits, and setpoint data. This demonstrates l  good initiative on the part of the licensee to determine and provide
        ''
;
d. March 25, 1987 -
objective evidence that the plant can be safely operated as licensed.
ASLB Issuance of Partial Initial Decision on Low Power License e. April 9, 1987- -
Commission' Order (CLI-87-02) Retains
  ,
in Effect License Stay f. April 22, 1987 -
Full Power ASLB Denial of Licensee Petition to Reduce EPZ g. June 11, 1987 -
Commission Order (CLI-87-03) Denies !
Licensee Motion to Lift License Stay
_ _ _ _ _ _ _ - _ .


;  As noted in the previous SALP report, the licensee's management has
  - .
'
I, TABLE 1 INSPECTION REPORT ACTTVITIES Report No. Inspection Hours  Area (s) Inspected
established an office in Bethesda, Maryland to provide ready atten-tion to NRC concerns. This has continued during the current evalu-ation perio .
  *86-09 74  Routine Inspection of General and System Operating Procedures l
The licensee generally demonstrated an understanding of issues dur-ing meetings and discussions with the NRC staff and in its submit-tals to the staf The licensee generally exhibits conservatism where the potential for safety significance exists. The approach to resolution of technical issues is viable and generally sound and l
86-19 86  Routine Inspection of Preoperational Test Program 86-20 439  Routine Inspection of Construction Completion, Preoperational Testing, Training, TMI Action Plan and Previous ;
'
Items 86-21 43 Routine Inspection of Previous Items
thorough. The licensee was willing to perform additional studies as necessary to resolve technical issues. Generally, when the NRC i  and the licensee held differing technical positions, the licensee
      !
;
86-22 160  Routine Inspection of Chemistry, Effluent Controls and Radioactive Waste Programs 86'23- 122 Routine Inspection of QA Program and Previous items 86-24 37 Routine Inspection of Records Related to reactor Yessel and Internals and Previous Items 86-25 123  Routine Inspection of Occupational Radiological Protection Program 86-26 33 Routine Inspection of Nuclear Material Control and Accounting 86-27 240  Special Team Inspection Comparing Technical Specifications to As-Built Plant 86-28 135 Routine Inspection of Operational Readiness and Previous Items
'
provided a sound basis for his positio Some exceptions occurred in the containment systems, control room design portion and safety l parameter display system portion of the safety revie In these
!
cases, the licensee was slow in demonstrating a clear understanding of the issues. However, once the licensee began to understand the problems, the staff received acceptable response Positions within the licensee's organization are identified and authorities and responsibilities are define The licensee's lic-ensing and engineering groups appear to be adequately staffed as
; indicated by representatives who have attended numerous review j
'
meetings. Generally, sufficient technical staff are participating in review meetings to effect resolution of open items. The licen-see's licensing staff has demonstrated a much needed cooperativeness i in resolving difficult issues. Staffing at the Seabrook Unit 1 j  plant appears adequate for the status of the plant as it prepares for operatio The licensee is responsive to a majority of NRC concerns and has i
taken the initiative to resolve issues by requesting conference
.
calls and meetings and has then followed up with responsive submit-l tal In general, responses have been technically sound and ad-
!
dressed NRC concerns in a professional manner. The licensee pro-
!  vided effective licensing liaisons between their technical staff 2 and NRR. Except for certain of the technical issues noted above,
;
licensee responses have been timely.


h l
86-29 74  Routine Inspection of Security l Plan and Implementing Procedures '
- _ _ _ _ _ . .~ _ ._ .- _ _ _ . _ _ . _ - - _
l
    -
_ _ = _ - _ _ - _    l . .
  '
Table 1  2 Report No. Inspection Hours Area (s) Inspected 86-30 113 Routine Inspection to Follow up Emergency Plan Implementation Appraisal and Previous Items 86-31 32 Routine Inspection of Startup Test Program and Procedures 86-32 27 Routine Inspection of Fire Protection Program 86-33 37 Routine Inspection of Abnormal and Emergency Operating Procedures and Previous Items 86-34 333 Routine Inspection of Construction Completion, System Design, TMI Action Plan and Previous Items 86-35 110 Routine Inspection of Chemistry, Effluent Controls and Radwaste Programs 86-36  91 Routine Inspection of Operational Readiness and Previous Items
, 86-37  88 Routine Inspection of l
Preoperational Test Program l
86-38  32 Routine Inspection of Radiological Environmental Monitoring Program 86-39  79 Routine Inspection of Occupational Radiological Controls Program 86-40 47 Routine Inspection of Preeperational Test Program 86-41 44 Routine Inspection of Security Plan and Procedures 86-42 -
Inspection Number Not Used
  - _ . _ _ _ - _ . - - - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -


O e
.
_
  - ,
.
'ht ' g 3 o L "
  ' Table m s      i Report N Inspection Hours  Area (s) Inspected 86-43 115 ' Routine Inspection of Seismic'
    ~ Piping Systems, Pre-Service Inspection ~ Program and As-Built 1
    :P1 ant-86-44 '68- Routine Inspection of Effluents JI Control and Radwaste Programs
  ~86-45 36 Routine Inspection of Electrical and I&C Procedures and Previous Items 86-46 358 ,
Routine Inspection o Construction Completion Activities, Design Changes, :
    ~As-Builts, TMI Action Plan,- >
Previous Items 86-47 '428 Routine Inspection of Testing, License Issuance, Cor'e Loading, Maintenance, Surveillance, ;
Operations and Previous Items 86-48 48 Routine Inspection of Startup Test Program and Procedures; Review of Containment Sit Report 86-49 39 Routine Inspection of Pre-Service Inspection Program and Records and Previous Items
      '{
86-50 131 Routine Inspection of Initial Fuel Loading Activities 86-51 97 Special Team Inspection To Review Allegation of As-Built Drawing Discrepancies 86-52 478 Special Team Inspection to Review Allegations by ELP 86-5'3- -
Inspection Number Not Used 86-54 187 Routine Inspection of Operations, - .
Maintenance, Surveillance, 1 Startup Testing and Previous j Items  '
___


2. Conclusion Rating: Category Trend: Consistent 3. Board Recommendations Non + --___- - - _ J
_-_-
;
.r  .
t Table l    4 Report N Inspection Hours  Area (s) Inspected 86-5 . Routine Inspection of Occupational Radiological ..
        '
        ' Controls Drogram and. Previous Items
          !
86-56  24 Routine Inspection of Physical Security Program and. Previous Items-86-57    -
Inspection Number Not'Used
  .86-58  118 Special' Team. Inspection To Review. Licensee ~ Action on GL 83-28, ATWS 87-01  128 Routine _ Inspection of'
Preoperational Test Program, Test Procedure Review, Test. Witnessing ~j and Test Results Evaluation'
87-02  432 Routine Inspection of .. 4
          .
Post-Core' Loading Heat-Up and i HFT, Maintenance, Surveillance, -l Operations and Previous Items i 87-03  '56 Routine Inspection of I&C Surveillance Test Progra '30 Routine, Inspection of Radwaste Program and Pre 0perational Test Results Evaluation 87-05  69 Routine Inspection of Startup Test-Program, Post-Core Loading Hot Functional Testing and Test Results Evaluation 87-06'  -
Inspection Number Not Used
  . 87-07    583 Special Team Inspection of -j Allegations Raised by ELP 87-08  26 Special Inspection to Follow-up Unusual Event of 02/11/87 87-09    34 Routine Inspection of Post-Core Loading Hot Functional Testing
,


s e
_ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
33 SUPPORTING DATA AND SUMMARIES Construction Deficiency Reports (CDRs)
Twenty-four CDRs were reported by the licensee during the assessment period. Of this total, five potential deficiencies were subsequently withdrawn by the licensee with NRC inspection confirming the validity of the licensee analysis and resultant cancellation. All reported de-ficiencies are listed in Table 1 and were evaluated and discussed, as appropriate, in the affected functional are While analysis of the listed CDRs for causal linkage has identified no unacceptable chains per statistical acceptance criteria, it was noted that seven of the ten deficiencies analyzed as vendor problems were re-lated to the electrical disciplin This appears to be consistent not only with CDR data from the previous SALP period where eight of.a total 22 CDRs were caused by vendor problems in electrical components, but also with other NT0L plant data where electrical component deficiencies are more numerous than those reported in other disciplines. Both the status of construction progress and the nature of preoperational testing acti-vities as the plant approaches operations, tend to identify and accentu-ate electrical problems. However, this is not perceived to be a pro-grammatic problem with electrical CDRs and no additional corrective measu es, other than those taken to correct the individual deficiencies, are believed necessary since no generic electrical problem appears to exis . Investigations and Allegations Review During this assessment period five allegations were received, only one of which is open with an investigation by the NRC Office of Investiga-tions currently in progress. The other four allegations were inspected and closed with no substantive negative findings resulting from the NRC follow-up of the stated concern Additionally, the investigation / inspection of five allegations reported during previous SALP periods were completed during this assessment perio Four of these allegations were unsubstantiated, while NRC follow-up of the fith revealed that the licensee had identified the problem and re-ported it under the provisions of 10 CFR 50.55(e). NRC inspection of the resulting CDR confirmed adequate licensee corrective action and meas-ures taken to prevent recurrence of the proble Early in this assessment period, the licensee established the Employee Allegation Resolution (EAR) program at Seabrook Station to investigate, track and respond to allegations / concerns brought to their attentio NRC interface with the EAR program has provided both an independent verification of programmatic actions taken by the licensee to address quality concerns, and an effective means of utilizing the licensee in-spection resources without compromising the conduct or results of the


s e-
_ _ _ _ _ _ -
l *.    }-
1; 2 1 N <
        .1
  ..
      ,.
        ' J' m Table 1  ,
5  l
      , -
o, ,
Report N Inspection Hour's  Area (s) Inspected
  ~87-10  346' . Routine Inspection of Post-Core  '
Loading Heat Up and HFT and-  j
    ~Cooldown,-Maintenance, Training, Operations and Previous Items 87-11-  32  Routine Inspection of Startup Test Program, Post-Core Loadin Hot Functional: Test Witnessing-and Test Results' Evaluation.


NRC investigatio In three specific cases, the EAR program was called upon to investigate and respond to allegations received by the NRC. All three allegations have been closed with no substantive findings and with independent NRC inspection corroborating both the EAR investigation re-3 sults, and the implementation of corrective measures to avoid similar problematic situations in the futur C. Escalated Enforcement Action Non D. Management Conferences March 21,1985 - a special, announced management meeting at NRC re-quest to discuss the results of the Region I SALP board convened-to evaluate licensee performance from July 1,1983 to December 31, 198 . May 15,1985 - a special, announced management meeting upon mutual NRC/ Licensee agreement to discuss the Seabrook project status and schedule and to review licensee initiatives in the areas of the Employee Allegation Resolution (EAR) program, an FSAR consistency review, and establishment of a site licensing offic . October 2,1985 - a special, announced management meeting upon mutual NRC/ Licensee agreement to discuss the Seabrook Staion cable tray design and seismic tray testing in progress, intended to qualify extensive bracing redesig . October 16,1985 - a special, announced management meeting upon mutual NRC/ Licensee agreement to discuss the p'roject construction, licens-ing and state regulatory hearing status and emergency planning schedule E. Licensing Activities NRR Site Visits, Audits and Management Meetings The following listing represents those subject areas where the NRR personnel have visited Seabrook Station for the purpose of conduct-ing activities related to Unit I licensing. A significant number of meetings'were also conducted between the applicant and NRR per-sonnel with meeting notices and summaries documenting the discussion topics, as applicabl Cable Tray Support Qualification
'-
  --
87-12  -54'  Routine Inspection.of EP Progra'm~,- ,
Caseload Forecast Panel
Organization and Managemen l
  --
    . Control, Training and Previous  '
Emergency Preparedness
Items  ,. ;
--
87-13  268  Routine Inspection of Design  ,
Environmental Qualification of Equipment
l
--
.
Fire Protection / Safe Shutdown
Control Program, Testing,- .
    -
        !
Maintenance, Surveillance and 1 Previous Items 87-14  34  Routine Inspection of Occupational Radiological Controls Program 87-15  33  Routine Inspection of   !
Non-Radiological Chemistry Program 87-17**  -
Operator Licensing Examination 87-18  35 Special Inspection of Service Vater Valve Repairs 87-19  -
Operator Licensing Examination 87-20  34 Routine Inspection of Eoutpment Tagging and Temporary Modification Programs-sirst inspection conducted during this SALP period was IR 86-19. 86-09 was subsequently conducted out of sequenc **87-16 report will be included in next SALP perio {
l p
i I
Y _ -_ -_ - -_


o
2. :.
  ,
Y't '''
a
.,
        -
        -
          ,c - -
          ';y -
,
(
          ( '-
            .
            ---- ( - - r- ----
        , ,
_p.


  --
9;; . .
Power Systems Review
  > ... ,, =    , .
  --
        ,
Pump and Valve Operability Review Team
        ,
  --
          - '
Security
          .:  .., , .
  --
            .,
Seismic Qualification Review Team
  '. '
  --
  -
Technical Specification Review Also, on September 27, 1985, the Director of the Office of NRR met with applicant representatives at Seabrook Station to discuss the project status and tour the plant to observe Unit I construction progres . Licensino Documents The following listing represents the documents issued, to date, by NRR as part of the Operating License review for Seabrook Unit Final Environmental Statement (FES) - December,1982
    . '-        '. , ,
  --
.h  .
Safety Evaluation Report (SER) - March,1983
            .
  --
t al fW f;,
SER (Supplement 1) - April, 1983
            '
  --
            -
SER (Supplement 2) - June,1983
TABLE '
--
      ,
SER (Supplement 3) - July,1985
              '
  --
9- . INSPECTION HOUR SUMMARYJ    .
Technical Specifications (" Proof and Review" edition) - March, 1986
. ,
    . . .
HOURS'
FUNCTIONAL AREA 5 Actual ' Annualized- . Percent
        '
IL : Construction' Completion'    1349-  1012 :1 . Startup' Testing.'    :1244  932- 17. 8 ': '
    #  ,
a- .o
    ' '
p    Plant Operation '
2667  2000 '3 .'4'-. Radiological Controls    739  554- 1 J
,   : 5.' - Em'ergency Preparednes .
219- 16 .2l 3 U
L 6.:-- Security.'and Safeguards    175  '130- n        ,
  .
    ; 7,.-- Engineering.. Suppor . . Licensing Activities    -  -  -
9.- Training and Qualification    -
          '
          - -
    . Effectiveness-
            -
      ~
10. -Assurance'of Qualit .-
            -
        ._____  _____ _____
TOTAL .- '6972  -5226  100.0
.,
f v


--
I t A,,.,,__,_ ____2..mm_,. _._m.w_ ____-m-w--.a..-
g ,


o
-7  ,..
  ,  -  ~'
      .',
  @,
    ,
    '
t
      -
>
  '
  :' 8 '' ; d  }, N'.
L ! :'
    .$I 1r . y
! 2    . c~
    -
., ,
w - '-  .    ..
TABLE 3:
a4 g', '- '
>>
      . ENFORCEMENT ACTIVITY
+
    ~
  'A,- Violatio'ns Versus Functional Area By Severity Level'
. ;; -
    ,  t No. of Violations in Each Sevarity. Level ic  Fun'ctional Area  V I V,' III' II 'I ' Total '
  .. . 1. -Construction Completion-  -
O sy Startup Testing    'O Plant Operations-  1E 4  5 Radiological Controls .
<
  <
5. . Emergency Preparedness  1  .1
* Security-and Safeguards ~    0
    ~ Engineering' Support-    0
  < 8. , Licensing, Activities
  -
0 . Training and Qualification    0
  .1 Assurance of Quality'. 0 TOTAL 1 5- ~0 0 0 6 i


.
  .
.
a 1'a'.
TABLE 1 CONSTRUCTION DEFICIENCY REPORTS (1/1/85 - 3/31/86). '
  ,.          !
SEABROOK STATION CDR NUMBER DEFICIENCY    CAUSE CODE 85-00-01 Failure of Gould molded case circuit breakers to B pass trip test 85-00-02* Missing cation bed demineralizer radiography A 85-00-03* Reduced discharge head for the service water  C pumps 85-00-04 Lining problem in tne Airflex instrument air
          :
  '
D
   .
   .
hoses -
          )
85-00-05* " Questionable integrity of limit switch brackets
p T
      '
l*
D on SI valves 85-0G-06 Brown-Boveri circuit breaker switch wiring damage B
,,
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, . . ,        ,
 
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    ' '    \
  -Table 3
    '
L2l
' '
q ; Summary
  ,
  . Inspection . Severity Functional Brief-1 Numbe .. Requiremen Leve : Area . Description-
-
86-46 110 CFR 50, 4 Operation Seismic 2 Over ,
        '
c APP.'B~  Controls'For-Temporary Equi pment'"
        '
i- ~  86-47~ .10 CFR 50,. 4 Operation . Locked Valve ,f APP. Controls  "
  .87,-02 '10 CFR-50, 4' Operation CBA Sys;em Noti Ao Operated;I Accordance With Design Requirements
  '
  '
85-00-07 Questionable HVAC heat load desig~n calculations E 85-00-08* Incompatible grease in fan motor bearings  .A 85-00-09 Inadeouate spacing between battery cells and rack B 85-00-10 Logic deficiency in the ' f%'' high flow isolation E signal 85-00-11 Incorrect '.u... delay links in circuit breaker over- B currer- t ir evices
87-08' T..S.6.7.1' 4 Emerg. Pre . Failure To Report:
Unusual Event'
  .87-13 10 CFR 50.59 4 Operations SW/SCW Temporary
      . Modification 87-20 10 CFR 50,  Op'erations
        ~
5  Tagging Program APP. B  Deficiencies
        ;
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Q
  ~
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85-00-12* Georg , Teu - RUDL computer program erro "
1 . .
E 85-00-13 Detachment of lining in the service water piping C and valves 85-00-14 Excessive leakage in nitrogen gas supply contain- B
  .? .'., .
, ment isolation valves ,
85-00-15 Salt water spill from the service water system in A the water system in the auxiliary building 85-00-16 Seizure of linkage in HVAC dampers  B


      .
-
o
, 77-- -- .- .
.
O T-1-2 CDR NUMBER DEFICIENCY  CAUSE CODE 85-00-17 Binding of contacts in Gould motor control B starters 85-00-18 Disc malfunctions in Dresser valves used in gas B systems 85-00-19 Misapplication of Type MDR relays in the solid B state protection system 85-00-20 Failure of HVAC air dampers to close under certain C air flow conditions 85-00-21 Improper terminal boards used in the uninterruptible B power supply inverters 86-00-01 Design deficiency in undersizing the diesel genera- E tor air vent line 86-00-02 Pressurizer pressure transmitter drift in excess of C design basis 86-00-03 Impact of a P-10 permissive malfunction on protec- E tive system functions Cause Codes A - Personnel / Procedure Error D - Construction Error B - Vendor Problem  E - Design Error C - Component Failure
* Reported by the licensee as a potential CDR and subsequently cancelled. Basis for nonreportability was reviewed by NRC and item is considered close O s


TABLE 2 INSPECTION HOURS SUMMARY (1/1/85 - 3/31/86)
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SEABROOK STATION FUNCTIONAL AREA  HOURS ?; 0F TIME A. Construction   3788 48 B. Preoperational Testing 2451 31 C. Fire Protection and housekeeping 296 4 D. Operational Readiness 743  9 E. Emergency Preparedness  634  8 F. Assurance of Quality   -*  --
s
G. Licensing   -* --
    ' '. , '.
TOTALS 7912  100
?W gif   '
* Hours expended in these activities are either included in other functional areas or considered not to be direct inspe: tion effor NOTE: Additionally, a total of 12 inspection hours were expended during this as-sessment period in the review of preservation, protection and preventitive maintenance activities, for Seabrook Unit 2 (a plant still in an indeter-minate status).
  '
  .   ,
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  ,
TABLE 4 a LICENSEEEVENTEEPORTS
    .
LA . LER By Functional ' Area-    .
      ' Number By Cause Code *'
'
  ' Functional Area-  A! 8 -C- D- E 'X l'.' Plant' Operations 8 2 4 3
  ?2.LRadiologicalControl '
e ' Emergency. Preparedness Security and Safeguards- Startup. Testing
  .,
   ,
Licensing-Activities
' ' -
  . 6 .'
.. Construction Completion  - ! l
  . Engineering Support-   '
        ,j
  . ~ .Trainin'g. Qualification:and
    : Effectiveness-
  @
10. Assurance cf Quality
      .___ ___ ___. ___ ___ ___
8'
        .
'
TOTAL 2 0 4 3 0
  *Cause Codes'
        !
1  A Personnel Error i
B . Design,' Manufacturing, Construction, or Installation Error 9  C - External Cause D - Defective Procedures E - Component Failure X - Other
  ''
Cause Codes in this table are based on in:pector evaluations and may differ from those specified in the LE .,
i
  :
  -
I
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  <
      . '
  -
  %,-
'- --
  .. . _ . _ _    .I


,
_ _ _ - .  - - -
e
#
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    ' .: + '
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      .(
*
  , Table 4  2  s-
_
t 'LER Synopsis l
  <
LER Number Summary  Cause 86-001 Normally Locked Closed Valve Found Mispositioned A . l '
86-002 ' Inadvertent Safety Injection . :ESF Actuation-- Control Room A-Ventilation Isolation 287-001 ESF Actuation - Control Room E l
Ventilation Isolation  -i 87-002 ESF Actuation - Loss of Offsite Power A-
        '
    'To Essential Switchgear Bus 87-003 Source Range Analog Channel Operational ~ A' -
Tests.Not Staggered 87-004 Containment Equipment Hatch Air Lock B 1 Equalizing' Valves Inoperable
  '87-005 Main Control Board Indicators Not B Properly Mounted
._f'
!
87-006' ESF Actuation - Loss of-Power To Vita E Instrument Panel 87-007 Solid State Protection System-Auto A Shunt Trip Test  i
  .,. 87-008 Technical Specifications Daily Log A 87-009 ESF Actuation - Improper Tagout Of A MSIV Actuation  3 87-010 ESF Actuation - Main Feedwater D !
Isolation    '
87-021 ESF Actuation - Loss of Power To a 0
        '
>
Vital Bus
'
87-012 ESF Actuation - Failure of SI Reset E Switch o
        .
____  _ _ _


O s
,  . . .. ._ _ _ _ . _ .
Y e
  .e *
      ,


TABLE 3 ENFORCEMENT DATA (1/1/85 - 3/31/86)
      .
SEABROOK STATION Number and Severity Level of Violations Severity Level I - 0 Severity Level II - 0 Severity Level III - 0 Severity Level IV - 9 Severity Level V - 2 Deviation - 2 TOTAL T3~ Violations vs. Functional Area IV V DE A. Construction  4 2 1 B. Preoperational Testing 1
  . Table 4  3
    - -
      .
C. Fire Protection and Housekeeping  1
      <
    -
87-013 Area Temperature Monitoring In
 
      '
D. Operational Readiness  - - -
B Batter / Rooms 87-014 ESF Actuation.- Start of EDG "B" 0 i
E. Emergency Preparedness  - - -
i
F. Assurance of Quality  4 - -
_ _ _ _ _ _ _ _ _ _ _  _.
G. Licensing  - - -
TOTALS * 10 2 2
* NOTE: The total number of Severity Level IV violations listed vs. functional area is one greater than the total issued (ie: Section A above). This occurred because of the issuance in the 86-14 inspection report of a single violation containing multiple findings, each in a different functional are i l
L
 
O
:
o T-3-2 Listing of Violations SEVERITY FUNCTIONAL REPORT SUBJECT  LEVEL AREA 85-01 Failure to translate flow restrictor IV A sizing tolerances into the design details 85-01 Failure to document and track noncon- IV F forming conditions for all affected components 85-03 Failure to attach required nameplates V A to safety-related equipment 85-06 Failure to install UL approved valves in DE C the fire protection water supply system 85-15 Failure to control design / construction IV A interfaces with regard to pipe support installation 85-15 Failure to detail installation criteria IV A for instrument tubing crossing siesmic boundaries 85-15 Incorrect dispositioning of nonconform- IV F ance reports on instrument tubing 85-20 Failure to implement complete corrective IV F action on identified component pedestal cracking problems 85-20 Failure to control a design change and IV F implement adequate corrective action on valve bracket rework 85-25 Failure to comply with commitments to DE A to NRC Regulatory Guide 1.97 86-12 Failure to translate an enclosure build- IV A ing ventilation design requirement into the construction details 86-14 Failure to follow procedures in fire IV B/C sealant and preoperational testing activities 86-14 Failue to adequately control component V A identification
}}
}}

Latest revision as of 14:47, 17 December 2021

SALP Rept 50-443/86-99 for Apr 1986 - Jul 1987
ML20236E375
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 10/26/1987
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236E244 List:
References
50-443-86-99-01, 50-443-86-99-1, NUDOCS 8710290195
Download: ML20236E375 (55)
v • d • e


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U.S,; NUCLEAR REGULATORY COMMISSION.

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REGION I

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SYSTEMATIC ASSESSMENT OF LICENSEE' PERFORMANCE INSPECTION REPORT NUMBER 86-99 J

PUBLIC SERVICE COMPANY 0F NEW HAMPSHIRE g

SEABROOK STATION, UNIT 1 -!

ASSESSMENT PERIOD: . APRIL 1,'1986 - JULY 31, 1987

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BOARD. MEETING DATE: SEPTEMBER 17 AND.0CTOBER 2, 1987 i

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4 SUMMARY OF RESULTS I .0verall Summary:

During this assessment period, a major transition occurred as con-struction' and preoperational testing were completed, Land startup .

testing and ~ operations under the technical specifications (TS)' and: '

license conditions- commenced. Throughout this transitional period,

.the licensee's commitment.to quality, along with its safety-conscious

' attitude: 'and - management support of quality ' assurance '(QA) initia- !

-tives, has been maintained. It is noted that . some .of the functional- '

areas are being evaluated for the first time. In- certain of 'these '

areas, the station ~and its personnel may not have- been significantly i challenged due to plant conditions and license limitations. In all a, cases, assessments are made based upon program adequacy and . observed i

' performance. .However, in those areas where activities were limited,

.such performance may not be truly indicative of station response .to future, more challenging events and situations. During this assess-ment period, t.he licensee demonstrated the ability to conduct limited operations along with a state of readiness for future, more expansive

,.

operational activitie .

'

Some transitional problems' nave been experienced during this assess- ;

merit period. Both .the programmatic and organizational interfaces :

between the Seabrook Station staff and the New Hampshire JYankee  !

engineering and quality assurance ' groups required clarification. The operations QA program, while implemented properly from a compliance standpoint, did - not ' evidence. total E effectiveness with respect to causal analysis of identified operational problems or the evaluation of related generic weaknesses. Also, plant cperations and startup testing activities were somewhat negatively impacted by divergent requirements to conduct system testing and to . troubleshoot problems, while. at the time adhering to the TS and 'special conditions pre-scribed by 'the zero power license. Likewise, new reporting require-ments (e.g., licensee event reports) were exercised based primarily on legal interpretations, rather than normal operating condition The shutdown plant conditions and lack of radiological activity -did not provide the realistic bases for such notification As an example, during the one emergency event classified during this SALP period, there were interpretation problems as to whether the plant's nonradiological status warranted declaration of an Unusual Event with its attendant notifications.

t

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Notwithstanding these difficulties, the licensee's establishment of a new program of controls, which is operationally based, has been effective. Construction completion has resulted in quality hardware, which is being, maintained at the same leve Similarly, the licensee's approach to component problems and testing anomalies reflects the same comprehensive attitude toward corrective action that was evident during construction. Management attention to plant readiness and independent, internal review of plant performance

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remains hig l

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While the'overall. transition from construction to. operations.has pro-ceeded in a relatively smooth manner,;the latter part of this curren assessment period pr_ovided some evidence ~of the future. problems which might be encountered. The PCCW heat exchanger problems.. discussed

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>

'in Section:IV.G of this report,. represent an example of the. componen degradation which may result, in part, from lack of . system; operatio This type' of concern could become even more troublesome if: Mode.- 5-

.

operations -continue for a long period of time. Licensee preplanning in the areas of water chemistry control, surveillance and maintenance '

activities, which have been evaluated as ' subcategories of- the appro-priate functional areas in this SALP, will .become even more important for . equipment preservation during prolonged periods o shutdown conditions. In the past, licensee responsiveness to problematic d issues and~ NRC initiatives has been appropriately di'rected. In ~ the j future, even more aggressive and innovative corporate management b

involvement may be necessary to sustain the same high ' level' of j performance, j B_ackground Licensee Activities Over the course of this SALP period, major changes in both the scope-and organization of plant activities occurred -- as con'struction was completed and operations commenced. On April 1, 1986.a construction work ' force. of approximately 3500 personnel was still on .' site as pre-operational testing, building turnover and . final support system in-stallation activ ties were ongoing. In the ensuing months, construc--

tion was effectively completed and the licensee filed a motion pur-suant to 10 CFR 50.57(c) before. the ASLB on August 22, 1986, seeking authorization to load fuel and conduct precriticality testin On October 17, 1986, a1 Facility Operating License was issued for Seabrook Station Unit Specific license conditions limited activ-ities to "zero power" operation and preci aicality testing, but did allow the licensee to load fuel and conduct hot operations in Mode 3 in accordance with the Technical Specifications. Initial fuel load was conducted during the period October 22 to 29, 1986, i

Plant heat-up for the conduct of the precritical phase of hot func-tional testing (HFT) commenced on February 9,1987. Over the follow-ing six weeks, startup testing activities were in progress with the

! -

plant achieving normal operating temperature and pressure conditions L and with the conduct of operations in accordance with Technical o

Specifications and special license conditions. Post noticeable among

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w__________.__._____.______ _ _ _ . _ _ _

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the routine operational activities and events which occurred during i this period. were the declaration of an Unusual Event on February 11, '

1987 based upon commencement of a plant cool-down from Mode 4 to com-ply with a Technical Specification related to containment air lock !

operability; and a steam generator safety valve actuation on February 26,1987, ' as a result of emergency feedwater (EFW) system testing. The conduct of specific tests on the steam-driven EFW pump itself was one of the more significant areas of testing during HFT, because major design modifications had been implemented for this system since the previous HFT in December, 1985. Plant cool-down-from hot operations was initiated on March 19, 1987 and the plant has remained in Mode 5 through the remainder of this SALP perio Since the completion of HFT activities, the licensee has initiated )

some extensive maintenance activities. These include the inspection, .l baffle repair, and tube plugging and sleeving operations on a primary l component cooling water heat exchanger; and the inspection, l i r.i ng j configuration redesign, and - lining repair and testing on several i service water valves. As of the end of this assessment period, these repair activities were continuing with additional heat exchangers yet '{g to be inspected and additional valves yet to be reline i Completion of this maintenance, along with the associated, routine '

operational surveillance activities,- are scheduled for a November, 1987 time frame to support heat-up, initial criticality and further testing, if a low power license is issued to Seabrook, Unit 1. In anticipation of license issuance and in response to the Commission's Memorandum and Order (CLI-87-03), the licensee has committed resources to several emergency preparedness (EP) activities. In addi-tion to working with New Hampshire to improve the state emergency response plan, which is the subject of ASLB hearings scheduled to commence in October, 1987,'the licensee is formulating a utility plan with the stated capability to compensate for Massachusetts emergency ]

response functions. Submission of this plan to the NRC in September i has received priority attention along with the conduct of other j licensee EP activities required to meet the criteria provided by  ;

CLI-87-03 for issuance of a low power operating licens l Inspection Activities Two NRC resident inspectors were assigned to the site during the j assessment period. The NRC inspections are summarized in Table 1 and i represent an inspection effort of 6972 hours0.0807 days <br />1.937 hours <br />0.0115 weeks <br />0.00265 months <br /> (5226 hours0.0605 days <br />1.452 hours <br />0.00864 weeks <br />0.00199 months <br /> calculated

'

on an annual basis) with the total inspection hours distributed in the various functional areas, as shown in Table I Special inspections were conducted of the compatibility between the plant and the facility Technical Specifications (May, 1986); in re-sponse to the Unusual Event (February, 1987); and in three follow-up inspections of allegations raised regarding construction quality and the as-built conditions of the plant (October,1986; November, 1986;

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' and April-May, :1987). An Emergency Plan Implementation -l Apprais'al . '

follow-up kinspection was also conducted in June, 1986. Seven en-forcementoa6tions, including a Severity Level IV violation ,resulting from -. follow-up. inspection of. the Unusual Event, were issued. The violations iss'ued during this' SALP period are tabulated in. Table o It is = noted. that construction was L completed during this SALP. period-and ~ NRC inspections of the various ' technical disciplines were con--

ducted, as necessary, to examine' final- construction activities; Al-legations 'regarding construction quality were also received .during i this assessment period af ter construction of the plant- was .essen-

'

tial.ly~ complete.- In order to objectively. ' address 'these allegations,'

over.1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> of additional inspection were expended to investigat the stated concerns. -Section V. A of this report' generally discusses -

the Investigation and Allegation Review conducted during this SAL ,

The: expenditure of this large inspection effort into the several con-struction disciplines and areas of as-built quality has resulted in a i reaffirmation 'of the NRC position that Seabrook Unit 1 was construc- '

ted in accordance .with its design-bases and regulatory requirement This report also discusses " Training and Qualification Effectiveness" and " Assurance i of Quality" as . separate functional areas. Although these topics, in themselves,' are assessed in the other functional- , i areas through their use as criteria, the two areas provide a synop-sis. For example, quality assurance effectiveness 'has been assessed

.

on' a day-to-day basis by resident inspectors and as an integral as-pect. of specialist inspections. Although quality work is the respon-sibility of. every employee, one' of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. Other major factors that' influence quality,.such as involve-ment' of first-line supervision, safety committees, 'and work atti-tudes,' are discussed. in. each are ..

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7 Facility Performance Analysis Summary 1986 1987 FUNCTIONAL AREA CATEGORY CATEGORY TREND Construction Completion 1 1 Startup Testing 1 1 Plant Operations 1* 2 Radiological Controls *

l Emergency Preparedness 2 1  ;

1 Security and Safeguards *

1 Engineering Support **

2 Licensing Activities 1 1 Training and Qualification *

1 l Effectiveness 10. Assurance of Quality 1 2

  • During the previous SALP period, " plant operations" was evaluated in terms of " operational readiness", which included " radiological controls",

" security and safeguards", and " training / qualification" assessments in one general functional are **During the previous SALP period, Engineering Support was not evaluated as a separate Functional Are .

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IV. PERFORMANCE ANALYSIS- Construction Completion (1349 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.132945e-4 months <br />, 19.4%) Analysis During the previous SALP assessment period, all of the construc-tion disciplines were combined under one functional a re a .

Significant NRC inspection effort, including two team inspec-

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tions and an additional NDE Van inspection, revealed adequate control over construction processes by licensee management and few hardware deficiencies. As construction was nearing com-pletion, as-built inspections by both the resident inspectors and regional specialists confirmed a high degree of plant conformance to the design bases and technical details provided by the . FSAR. A Category I rating was determined, based upon an effective construction management program with resultant evidence of quality hardware, material, components and system During this current SALP period, an assessment of construction l completion was conducted to not only evaluate the plant's as-built. quality, but also. to provide an independent review of the results of inspection effort into allegations involving the plant hardwar Several NRC inspections were conducted to re-view licensee corrective action on previous construction find-ings (e.g., open items and construction deficiency reports) and to investigate the validity of several allegations raised re-garding construction qualit The results of these inspections essentially confirmed previous assessments that Seabrook Unit 1 was constructed in accordance with regulatory requirements and licensing commitment As construction was being completed, an NRC inspection review of all unresolved items and licensee corrective action on pre-vious inspection findings was conducted to determine the readi-ness of Seabrook Unit 1 for issuance of an operating licens This review revealed both an aggressive construction management approach to the implementation of corrective measures, where necessary, and a responsiveness to NRC initiative Routine inspection results also provided evidence that the licensee's internal as-built verification programs (e.g. , the pipe support closecut task team, PAPSCOTT; and the cable tray and support qualification activities) had been implemented in a technically competent manner. Effective licensee controls of both construc-tion completion and the process of reconciling the as-built plant with the design details were noted. A strong QA involve-ment in the conclusion of construction activities and in the assurance of quality records storage and retrievability con-tinued from the previous assessment period into this SALP,

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.x An independent verification of plant quality also arose from NRC:

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followup of a number of allegations regarding the construction processes'. Because of the nature of several of. the stated -con '

' terns and the fact that .they were raised afterfconstruction wa essentially complete, the' quality of hardware and ability of the:

as-constructed system to function as . designed became the focus-of a multidisciplinary NRC inspection effort. 'The effectiveness of licenseeL programs, which had .been inspected in ' progress over the course aof construction,:was Previsited and the' qualification; 4 of. ' personnel - to ' perform safety-related~ activities . reviewe Systems.were opened and inspected;-independent measurements were l, taken;. tests 11n progress were witnessed; . and both design ? and !

-as-built construction records were reviewe This collective NRC inspection effort to investigate the tech'-

nical validity. of several allegations' did not identify. new prob-lems,r but instead confirmed .the effectiveness ~ of licensee cor- ,

rective action in response to known problem areas and provided k-additional assurance of the measure of quality that construction completi(n has receive . Conclusion-Category 1 3. -Board Recommendation None l

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

, Analysis l

During the last assessment period, nearly 2500 hours0.0289 days <br />0.694 hours <br />0.00413 weeks <br />9.5125e-4 months <br /> were ex-pended in the inspection of the preoperational test program of Seabrook Unit 1. Over that course of time, major testing was completed including the pre-core load Hot Functional Test (HFT),

the Engineered Safety Features (ESF) and Loss of Offsite Power (LOP) tests, and the combined Structural Integrity Test (SIT)

and Containment Integrated Leak Rate Test (CILRT). It was de-termined that a high level of performance had been maintained during the entire SALP period and for the majority of the pre-operational test activities. Accordingly, this functional area was given a Category 1 ratin The current assessment period provided the opportunity to assess

'

not only the completion of preoperational testing, but also the conduct of fuel loading and post-core load testing, including another HFT. The completion of the preoperational test program and final closure of the remaining test exceptions proceeded smoothly with the transition into the startup test progra NRC inspection coverage of initial fuel loading, as a startup testing activity, identified a mispositioned valve in violation of operating license conditions. The programmatic deficiencies associated with this problem are described in the Plant Opera-tions section of this repor Licensee preparation of the startup testing procedures was excellont. All 56 startup test procedures were finalized in a timely manner. They were well written and received adequate reviaw and approva Industry experience and NSSS vendor review comments were properly incorporated into the procedures. Major test evolutions were verified and transient test responses were evaluated on the Seabrook site-specific simulator with the eval-uation results incorporated into the test procedure Fuel load and post-core load HFT testing activities were delib-erate and well coordinated. Adherence to procedural controls was well in evidence. The conduct of startup testing was noted to be performed by qualified personnel, who interfaced well with their operations counterparts, and with management involvement in the prompt resolution of equipment problems and test defici-encies. Test records were well prepared and maintained. Test exceptions were few and dispositioned in a technically appro-priate and thorough manne .

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One significant testing issue regarding the emergency feedwater !

(EFW) system carried over from the original HFT, as difficulties had been encountered in the conduct of the turbine driven EFW pump preoperational test. _ The steam supply system to the Terry ;

turbine was redesigned after the identification of the original '

HFT water hammer problems. An NRC zero power license condition mandated successful completion of the subject EFW testing prior to initial criticalit A specific. startup test (ST-53) was formulated te verify system modification and design adequac i During the conduct of this testing, weeping valves were observed !

to affect test conditions which necessitated the continuation of ~

testing with an abnormal valve lineup. .This unusual lineup contributed to an unexpected steam generator' safety valve actu- j ation in February, 198 It also resulted in a testing issue which remains open, since the completion of the post-core load ;

HFT and cooldown in March, 1987 has not yet provided complete !

. evidence that the EFW system functions as designed. The post-core load HFT had to be extended over an approximate six week 3 period to troubleshoot the testing problems which were identi- 1 fied. During this . time, the licensee employed a ' trial-and-adjustment iterative technique to problem solving which is more l

characteristic of a "preoperational" rather than "startup" pro- :

gra Review of the test results with a more systematic and !

analytical approach to resolution of the' problems appeared to be warranted, given that operating license conditions and technical l specifications were in effec The licensee has attempted to !

address all NRC questions on this issue and has planned conduct !

of a special test (STP-101) to verify adequacy of the normal start and operation of the EFW turbine driven pump. Thus, in general the EFW problems and how they have been handled by the l licensee validate the position that the startup testing process is functioning as intended, to identify problem areas, ef fect corrective measures, and retest as necessar I Overall, the NHY startup testing program planning and implemen- s tation have continued to provide the same level of technically competent confirmation of system and component adequacy, as was provided by the preoperational test program. Licensee manage-ment and startup personnel continue to demonstrate not only a responsiveness to NRC concerns, but also a technical determina-tion to objectively verify EFW system operabilit n

. . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -_ - __________ _ _ -________

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12 Conclusion Category 1 l Board Recommendation None

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j iC.. Plant' Operations (2667 hours0.0309 days <br />0.741 hours <br />0.00441 weeks <br />0.00101 months <br />, 38.2%) l l'. . Analysis l

The operational readiness functional area was evaluated in the previousLassessment period in the areas of procedures and staff- i ing,-operator licensing, security and radiological controls. An a overall Category 1 -rating was assessed in this area based upon ,

thorough licensee planning and a high level of management atten-

- tion to the development of . procedures and' programs in- the indi-vidual areas and in the' preparation ~for a receipt of new fue .'

During this assessment period, security and radiological con-  ;

trols will each be evaluated as a separate functional are Maintenance and surveillance activities have been added to the !!

Plant Operations functional area for this 'SALP evaluatio ,i During the current assessment period, core loading, pre-critical-hot functional testing (HFT), and operational controls under the t Technical Specifications provided the bases for evaluating the .;

effectiveness of the station programs and procedures,.which.had" '

been ' under development in the previous period. . Analysis of each {

area contributing to an overall assessment of plant operations '

is discussed separately belo y a) Procedures and Programs 3 The evaluation of procedural and programmatic controls weighed heavily in the assessment of plant operations since i the "zero power" license conditions limited the scope of j

. ope ra tional ' activitie s . As initially inspected by the NRC, 1 the implementation of' the independent verification program  !

was determined to contain certain weaknesses which include j vague selection criteria and inconsistent application among j various station department Other programmatic- areas '

where NRC inspection identified areas of concern included 1 the equipment tagging, valve lineup and temporary modifica-tion programs. These problems were the subject of enforce-ment action on two occasions. Additionally, during startup 'l testing, a violation of the "zero power" license condition 1 concerning locked valves was identifie This violation I related directly to a deficiency in the operational con- l trols for identifying the position of locked valve The l identified program development and implementation problems '

have required concentrated licensee effort to upgrade the affected program .

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In the area of procedure ' development, weaknesses in format,

. content-and. consistency were- first notedL by: the NRC in the operations surveillance procedures and later in plant oper-ating procedures. NHY' task- teams of experienced; operators-

'and _ test engineers were . formed. and a procedure consistency review process was initiated. NRC review of the'se licensee

. efforts revealed a significant improvement in the quality .j and accuracy of these procedure a

' Licensee initiatives and corrective measures in the above two- areas have been. responsive to both internally and i externally generated programmatic. reviews. While the time- -

,

liness of response to certain' procedural concerns has been ,

questioned, management attention to the problem areas, once .i identified by' the NRC, has . been - thorough. Particularly in l the areas of independent verification and .the procedure

- consistency review, quality products have resulted once the !

~ licensee dedicated. sufficient resources to the corrective measures, b) Conduct of Operations  !

Since Seabrook is not a fully operational plant, the basis '

for assessment in this sub-area is nec'essarily limite Notwithstanding the limited . scope of licensee. activities in this area, significant NRC inspection was conducted into i routine operations, response to events / transients and TS i interpretation / reportin Routine daily operation of the plant both in Mode 5, cold I shutdown, and in Modes 3 'and 4 during HFT was excellen A high degree of professionalism and competency of the con-trol room operators was in evidence throughout the perio Control room logs and records showed continuous improvement over.the period. The shift superintendents (SS) are tasked with a high level of responsibility for station operation Their judgement is routinely conservative and demonstrates a safety conscious attitud Individual control room ,

operators and shif t supervisors are vigilant and knowledge- j able and have taken a significant initiative in providing >

quality on-the-job training to licensed operator. candidates on shift. As evidenced by a review of the LERs in Table 4 of this SALP, operator error has been identified as the cause of several inadvertent engineered safety features (ESF) actuations. In one case, improper switch operation resulted in an inadvertent safety injection (SI) while a

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

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second SI was generated due to tagging procedural- erro

On another occasion, a switch misoperation resulted in a

,

diesel generator star In two separate events, substan- .

l tial volumes of RWST water were inadvertently transferred, l

once to the containment and once to the refueling cavit While NRC review of each of these incidents has revealed

)

"

timely corrective action on the part of the operations department, the number- of problems experienced warrants increased management attention to detail in routine, daily operations. Additional operational experience and famil-iarization with a zero power license environment reduced l

the number and frequency of such events during the latter l

part of this SALP perio During this assessment period, the operators were not severely challenged to respond to significant plant trans-ients and events, however, several minor occurrences war-rant discussio In addition to the events related to operator errors, discussed above, several other ESF actua-tions occurred. NRC evaluation of operator response in the

[

control room verified effective use of procedures and

, appropriate operator judgement in restoring the unit to a

! normal configuratio Most notable of the above incidents

! were two inadvertent safety injection actuations caused by malfunctioning control switche The station response to the declaration of an Unusual Event is summarily assessed in the Emergency Preparedness section of this repor No specific technical problems related to the conduct of operations were identified as a result of this event. However, it was noted that an internal dis-agreement between members of the operations staff developed as the event progresse This disagreement, relating to event classification and notification requirements, contri-buted to the delay in reporting and therefore resulted in the issuance of a violatio Additional training and specific delegation of responsibility within the operations department were necessary to clarify operational duty roles within the Emergency Response Organizatio Some dif ficulties were initially experienced in the inter-pretation of Technical Specification (TS) limiting condi-tions for operation (LCO) and the deportability of events under 10 CFR 50.72. The most significant example was the handling of equipment and procedural problems associated with the control building air handling (CBA) system where

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

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eventually, a definition of C8A single train operation had to - be disseminated for generic interpretation by the sta-tion staf Presently, licensee awareness of reporting requirements and the training provided to those individuals responsible for interpreting these requirements have imprnved in the wake of the initial difficultie In another administrative area, however, the paperwork /

nonoperational workload of the Unit Shift Supervisor (USS)

continues to represent a potential problem, since .it diverts his attention from shift operations. This situa-tion has not improved significantly since initial NRC dis-cussion of the concern and merits further station manage-ment attentio With' the exception. of the potential problem related to the USS administrative burden, operations during this SALP period have been conducted safely by qualified personnel, utilizing adequate procedures and controls in accordance with the Technical Specification Certain problems attributable to inattention to detail have been experienced, but appear to have been appropriately disposi-tioned by station management. The real effectiveness of licensee corrective actions in this area can only be measured during future hot testing and operation c) Surveillance During this period the licensee implemented the Westing-house computerized TS Appraisal Program and began conduc-ting surveillanc The licensee instituted this program on an accelerated schedule in order that surveillance were performed in advance of the actual required operability re-quirements, thus enhancing the procedures and establishing baseline data. Additionally, surveillance and operating procedures were utilized as much as possible during the test program to allow additional trial usage. While a few surveillance errors have occurred, the overall surveillance program has been effectiv The licensee also established measures to strengthen this program with new initiatives involving TS log reviews and the surveillance procedure consistency review program referred' to in paragraph a)

abov The NHY Program Support Department Staff which is respon-sible for certain surveillance testing (e.g., ASME Section XI and 10 CFR 50, Appendix J) is highly competent and professional. One notable example of this was the dis-covery by surveillance test engineers of the common mode

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valve' failure on the equipment. hatch a'ir lock doors (dis- !

cussed in section IV.G-of this report). Performance of thel 1 surveillance' on the-hatch doors at that- time was in ' paral- l 1el: to, . but not directly' responsible for identification 'of:

the problem. It was '.the alertness of the surveillance J q

engineer himself that' identified the. malfunction and i eventually. led to the declaration of an Unusual Event. The "

technical support staff has also been extremely responsive to NRC questions and concerns, p

Although the plant has not conducted sustained power oper-ations, .- challenging the capabilities of the surveillance .

programs, inspection to date.which has sampled higher mode 4 operations indicates that licensee efforts in this area are effective and the programs are appropriately staffe d) Maintenance y The licensee.has reorganized the maintenance support' organ-- H

'ization, establishing separate Maintenance and. Technical Support Departments. Electrical, mechanical, and I&C func-tions 'are performed by the mai nter.ance department while !

system support is' provided by individual' system engineers who have been delegated responsibility ' for, the -separate' l systems. This organizational concept hcs provided consis-

'

'tency and accountability in the maintenance chai As a- ;

result, the Maintenance / Technical Suppor t capability has ;

been significantly. strengthened. The mos . visible example '

of this was the primary component coolir gL water heat ex-changer repairs where follow-up to this m.tintenance activ-ity led,to identification of the service water valve. lining !

problems, discussed in'Section IV.G. These two jobs re-quired considerable expenditure of maintenance resources, extensive hardware disassembly and complex special process controls. There has been extensive involvement by Station Technical Support Engineers in the maintenance area. The competence of these system engineers and their supervisors is a licensee strength. Liaison between technical support and maintenance has been an effective part of the work con-trol process. The NHY maintenance organization (including I&C) continues to' demonstrate excellent maintenance tech-niques in the area of pre-staging, cleanliness, temporary support and storage and procedural adherenc .

_ _

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J- j

~ An additional licensee' strength lies in the area -o'f plan-ning and scheduling. Daily' " plan of the day" meetings are effective in the coordination of the diverse requirements of'the many station departments. The computerized planning schedule is kept current so that future planning is based on accurate data. A high degree .of management attention has been directed to the coordinationLof the support activ-ities- of various departments to meet the established'sta-~ '

tion work schedules. A recent positive initiative. involved the establishment of a new - maintenance concept whereby -

preventive and corrective maintenance periods are pre-established for each system on : a . rotating weekly basis, Station maintenance has been conducted in a highly effec -

tive manner with no maintenance-related failure or events identifie Future . plant operations will provide more significant challenges, but- the maintenance and ' repair activities conducted to date indicate well controlled efforts capable of supporting ' more complex operations.' H

Plant operations at Seabrook-have been conducted professionally, safely and conservatively. Initial weaknesses in the develop-ment of procedures and programs .have, for the most part, been-corrected. Licensee efforts in strengthening the tagging pro- 1 gram and the consistency review- of operating procedures are l ongoing. The skills and knowledge of the licensed operating j staff remains a strength and initial problems with_ inattention

~

l to. detail have been overcome. The maintenance and technical !

support organizations remain a significant asset.

< -l 2. Conclusion i Category 2 3. Board Recommendation

Licensee: Station management 'should emphasize attention to de- {

tail in the conduct of routine operations, assess the .i ef festiveness and control of operational programs and !

evaluate methods to reduce operational error E: None i i

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D. Radiological Controls (739 hours0.00855 days <br />0.205 hours <br />0.00122 weeks <br />2.811895e-4 months <br />, 10.6%) e A,

.i % Analysis , 1'

(  !

A Cate' gory I rating, as part of the Operational Readintss area, ' g'

was. provided for this area in the last assessmpt .per.f Ad based upon the observation that the licensee's operattoriab readiness in the four radiological control arets (radiation protection, q waste management,,: transportation and effluent control and ' mon-itoring) axereded that ' routinely found at similar plants at the [i same preoperational stage. This fact was attributed to a high h level of management commitment, the degree of prepla'nning and i

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preparation, and the level of attention to detai This current assessment is based upon both an observation of ongoing plant activities and an evaluation of the programs which ^

have been established. Since radiological conditions at the

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plant were limited, the scope of this assessment necessarily J emphasized programmatic and operational readiness . reviews, '

rather than demonstrated implementation of radiological con-trol It was noted that while the licensee was not greatly i ,

challenged in this functional area during this assessment period, a meaningful evaluation is still pr.ssible based upon review of the limited activities (e.g., fuel road) and the con-trols in evidence during their conduct. ' Pragram areas inciqde In-Plant Radiacion Protection, Radioactive Waste Management, Ef fluent Controls,, Nonradiological Water Chemistry, and Environ-mental Monitoring, Radiation Protection During this assessment period, the licensee continued to make significant progress towards operational readiness in 4 the areas of staffing, training procedures, and equipment and instrumentation. The continued posehce of a motivated  ;

and professional staff and managemeht commitment to the program were evidented by an increase in staffing level (

aimed at commercial operation. .Ine. Radiation Safety l Committee met at the required frecuency and was tracking , I and evaluating program development; implementation, main- /' I tenance, results, and outstanding action items. Formal and l timely evaluation packages on previnusly identified NRC inspector concerns demonstrated licerste responsiveness and attention to these item As a further licensee initia-tive, a supplemental HP training progre.n we developed and implemented. During this period, the 1!cer.see's principal

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l M' N; (corporate) health physicist and the ' licensee QA organiza-tien performed evaluations of the . health physick (HP) pro- ,

gram. The corporate review resulted in several recommenda- l

% i< tidns being evaluated as program enhancements while the QA

'

ahdit < addressed good practices in addition to the regula-

't tpy! t requirements. Both evaluations were timely- and encompassed the full scope of HP activitie f During this appraisal period, primary startup sources were l

.' installed in fuel assemblies in the fuel storage buildin ri !

.

The fuel assemblies were moved into containment hnd loaded into t.>e reactor vessel. Also, calibration of area and '

process radiation monitors and of other radiation detection i instrumentation was conducted. The licensee reported mini- l mal person-rem exposures (less than 1 man-rem for 1986 and i

for the first quarter of 1987), indicating that appropriate I';

radiological controls had been exercised over the limited activities which were conducted during this assessment gj perio I In summary, the licensee has developed an aggressive radia- !

tion protection program in preparation for commercial oper-ation. Considering the nature of the activities conducted ( to date, effective radiolo'g1 cal controls have been imple-mented. When areas for improvement have been identified by l 9 '

j either the licensee or NRC, site and corporate HP manage- q 1, ment has initiated timely and appropriate corrective ;

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< Radwaste Management / Effluent Controls

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The licensee demonstrated aggressive oversight of the i radiochemi stry program in preparing for fuel load and j responded to NRC identified concerns in a timely manne '

Regarding radioanalytical standards submitted to the !

licensee for analysis, disagreements in two samples were 2 resolved promptly, indicating a high level of radiological j chemistry s nagement involvemen The radiological j environmental monitoring program (REMP) is implemented

!. through a clearly designated program which interfaces the site and corporate groups. The scope and method of over-view audit functions were clearly state ;

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Several aspects of the' REMP program implementation 'd'ur.ing

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the preoperational, phase exceeded . regulatory requirement Although not required, the direct radiation monitoring .

environmental TLD program was found to include efforts ' to-meet. criteria for. quality' control found in USNRC' Regulatory

~ Guide 4.13 and ANSI N545. The lic'ensee also,' participates in the International -Environmental . Dosimeter Intercompar-L

.ison project. These licensee initiatives indicate a high level 'of corporate management' awareness,.- commitment ' of

'

i resources and- sensitivity to the needs of this-. progra . Procedures for effluent measurement and' control'are coupled 1 to an ' administrative procedure for surveillance for' comply-ing with- the requirements of the Technical Specification The program -for preoperational and acceptance testing: of radwaste systems was found to be effectiv Test 1excep-tions and identified weaknesses were addressed in a _ timely manne c, .Non-Radiological Water Chemistry During the assessment period, the licensee made . progress .

, in nonradiological water chemistry for monitoring para-meters' of . primary and secondary water and preoperational and acceptance test programs. . Prccedures were found to be technically sound and adequate to meet TS requirement However, an initial inspection of this area identified certain weaknesses. The licensee was unable to analyze samples' in the concentrations normally found in an opera-

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ting reactor. Also, the inadequate calibration of instru-ments was noted. Follow-up inspection in these areas found considerable improv" ants in the sample analysis and

'

quality control in ins leh was upgraded. Again the~11cen-see management demonstrated ti volver snt in the program and responsiveness to inspection recommendation Review of the water chemistry control program indicated a clearly defined policy, competent organization, effective-administrative procedures and adequate resources for imple-mentatio Based in part upo a study done by the station "

chemistry department, the licensee continues to explore additional enhancement options to the present program pf all-volatile treatment (AVT) for secondary side water treatmen I

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- Although the~ fun'ctional ' area was 'not~ severely challenged durin .this assessment period, the . licensee demonstrated levels .:of- s l

, preplanning, preparation and program development co_nsistent with

a; plant- ready - for - operation. In: those' activities - where the'

.

R

radiological controls. were: tested,' good results were achieved.' '

The ~ licensee organization 'is staffed with qualified-: personnel, 4 from the station .HP, and chemistry management.down.. The overall:

-

. performance during this period ' indicates that the site radio-  ?!

logical, effluent control and chemistry ' programs- have been establis.hed with the capability ' to1 effectively support plant:

operation ~ .- !

l 2. Conclusion Category 1

]

3. Board Recommendations None:

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E. Emergency Preparedness (219 hours0.00253 days <br />0.0608 hours <br />3.621032e-4 weeks <br />8.33295e-5 months <br />, 3.2%) ' Analysis

)

During the previous assessment period licensee performance in this area was rated as Category 2 (improving), based upon per-formance during the Near Term Operating License (NT0L) Emergency Preparedness Implementation Appraisal (EPIA) and the first full-participation emergency preparedness (EP) exercise. During the current assessment period, one NT0L appraisal follow-up inspec-tion, one routine safety insp6ction, and one special safety inspection were conducted. Additionally, changes to the Emerg-ency Plan and Emergency Plan Implementing Procedures were re-viewe Although not specifically addressed as part of their f assessment, it should be noted that licensee initiatives for off-site planning have been implemented and preparations by the site staff to support such initiatives are in progress. Licen-see efforts towards obtaining a workable off-site emergency plan reflect a strong commitment by licensee management towards a complete emergency preparedness prcgra Two NT0L Appraisal followup in:;pections were performed in March and June, 1986, specifically to follow up on twenty-four open items resulting from the appraisa While the first of these two inspections concluded on March 28, which was during the last-SALP period, it has been included in this assessment because it represented the conclusion of the EPIA inspection process at Seabrook and the report results were not available until well into this perio Licensee management aggressively addressed i NRC concerns resulting in the closure of twenty-two open iten The remaining two open items are required to be corrected prior i to issuance of a full power licens A routine EP safety l inspection, conducted in March,1987, related to inspection of l the training program, operational status of the emergency pre-paredness program, and security / emergency preparedness program interface Inspection results indicate a comprehensive onsite emergency preparedness program is in plac The special safety inspection conducttd in February, 1987, re-lated to follow-up of the sequence of events and circumstances ;

surrounding the classification of an Unusual Event on l February 11, 1987 and the required notification process. This

'

special safety 11 pection identified a violation of the licen-see's internal procedures. The licensee failed to follow the requirements of emergency procedure ER 1.0, " Classification and Notification of Emergencies at Zero Power", which requires i

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notification of both Massachusetts and New Hampshire within !

fifteen minutes of ~ classifying, any emergency condition (as de-' i fined .in procedure ER 1.1). The causes of the violation, spec-ifically the failure to' notify . Massachusetts "within fifteen minutes, were - related to weaknesses Ein ther training of the operations. management and supervisory staff and are discussed in more detail in Section C.I.b of this repor The- emergency preparedness planning function continues to be

.

controlled by the NHY corporate staff located 'at the plant site and close liaison exists.within the site organization. .09 ring this. assessment period, the position 'of ' Director of Emergency preparedness and additional corporate planner positions were filled by permanent NHY employee The. installation of. equipment and training of personnel to ful-fill their emergency response organization functions, while on-going, .has been substantially completed. First aid capability and nursing coverage have been addeo to-the. staff. Also,.addi-tional personnel to fill the key' emergency response organization )

positions on a twenty-four hour basis are currently involved in

"

qualification activities. The lack of on-shift dose assessment capability has been corrected and the addition of iodine deter-mination for off-site dose estimation-has been complete The licensee has been responsive to NRC initiatives. -This is in evidence not only by the addition and training of personnel to fill key functions within the emergency response organiza-tion, but also by the cooperation provided by NHY on the resolu-tion of NRC issues concerning the emergency plan and procedure Additionally, significant effort has been expo.9ded b/ licensee management toward the resolution of of fsite concerns. Although weaknesses 'in the training of supervisory personnel were uncov-ered during an Unusual Event, this incident was quickly and comprehensively addressed by licensee management. Overall, the commitment and performance by the licensee in emergency preparedness remains hig l 2. Conclusion Category 1 3. Board Recommendation None I

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25- j F. Security and Safeguards (175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br />, 2.5%) Analysis i

l During the previous SALP period, the licensee was assigned a '

Category I rating, as part of the Operational Readiness evalua-tion, for preoperational activities involving security personnel i training and the installation and testing of new systems and equipment for the Unit 1 Physical Security Program. In the cur-rent assessment period two preoperational security program reviews, one routine physical security inspection and one pre-operational nuclear material control and accounting review were conducted, along with physical security inspector participation in a Region I team inspection. No violations were identifie The NRC completed its evaluations and approved the Seabrook Station's Physical Security, Training and Qualification, and i Safeguards Contingency Plans on July 23, 198 i Over the course of this assessment period, the licensee's staff has been involved in monitoring the performance of new security systems and equipment, evaluating the effectiveness of training and procedures and assessing the need for changes based on pro- t gram experience and feedbac Both corporate and station management involvement in and support for the security program were evident and restited in the initial implementation of the Unit 1 Physical Security Program with few identified problem The allocation of sufficient number of technical and support personnel resultea in sound designs, good planning, and timely procurement and installation. Such oversight underscores senior New Hampshire Yankee management's support for an effective security progra Throughout the preoperational phase, the licensee was responsive to the resolution of weaknesses / concerns identified during NRC inspections and in NRC Bulletins, Circu-

,

lars and Information Notices. The licensee also initiated liaison with other Region I licensees, visited other sites, and developed feedback mechanisms to resolve security program .

I issues. This has resulted in security program enhancements being implemented at the Seabrook sit Effective communic.ations exist between the security organization and the other station departments, as evidenced by the station response to security events. Program support and cooperation is also evident from local law enforcement agencies. The licen-see's security organization is actively involved in the Region I Nuclear Security Organization and with other nuclear industry groups engaged in the development of security program standards m and innovative approaches to security issue ,

C

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Twenty-four event reports were submitted in accordance with 10 CFR 73.71 during this period. Twenty-two of these reports resulted from minor problems typical to those encountered during the startup and continued testing and maintenance of new secur-ity equipment and systems, including the security computer and its associated software. While the licensee's event reporting program was found to be acceptable, NRC evaluation revealed that several reports required further clarification from the licensee l with regard to the analysis of causes and planned corrective i

actions. During the latter portion of this assessment period, both an improvement in the quality of event reports and a reduc-l tion in the number of security event reports were note Staffing of both the proprietary oversight and contract security organizations was timely and effective. Management and super-visory personnel appear to be well qualified, experienced and motivated. Clear and concise security procedures were devel-oped, approved and implemented to ensure program cohesivenes Modification of these procedures is continuing in response to feedback and experience gained through use. The self-identifi-cation of program weaknesses and needed improvements by both the

,

contractor and proprietary staffs is encouraged by licensee l management and reviewed in a timely manner. Special emphasis is l currently being focused on the performance of security systems l and equipment, and their reliability. This ef fort is intended to enhance the ef festiveness of both short-term reactive and long-term . preventive maintenance for the systems and equipmen The level of staffing for security equipment maintenance program further reflects the licensee's commitment to a high quality progra The security organization's training and qualification program has been well established with full-time experienced instruc-tors, lesson plans, state of the art instructional aids and adequate facilitie Entry level training and annual requalif-ication training of security force members are administered in conformance with NRC approved criteria. Oversight by the pro-prietary staff ensures that the program is continuously updated to include feedback from operating experience. Members of the security organization were observed to perform their duties in a professional manne During the assessment period, the licensee submitted two revisions to the Security Training and Qualification Plan and a revision to the Safeguards Contingency Plan under the provisions of 10 CFR 50.54(p) and provided its response to the recent mis-cellaneous amendments to 10 CFR 73.55. The revisions were of high quality and indicative of the station management's continu-ing oversight of the program to ensure it is consistent with NRC

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4 performance objectives, Secur_ity personnel ' involved .in plan 3 maintenance are knowledge'able of NRC _ requirement Addition- ;

ally,.'the licensee's program - and procedures to control and  !

account- for special nuclear material were' reviewed and found to- 1 be adequate, as _was the licensee's' plan for the protection of special nuclear material- of low . strategic significance .(new

r fuel).

In - summary, the licensee has established an l effective Physical Security Program. Efforts to improve the' operation and reli-ability of systems and equipment ' and personnel qualif.ication have - continued. The security program is actively supported by.- .

)

other plant functional groups,: as evidenced by the lackof problems _ in _ the maintenance of security equipment,_ response 'to 1 events and other areas where effective ~ interfaces- were necessa r Both corporate and station management ~ support of security programs and initiatives is evident, l Conclusion Category 1-

- 3. Board Recommendation 1 i

Non . .

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I 28  ! Engineering Support (579 Hours, 8.3%) -{

1 Analysis This area was not evaluated as a separate Functional Area during the previous :SALP period, although the engineering services

.provided to support construction activities were considered in the overall assessment of the' construction are During this current SALP period, engineering support to . the station staff is assessed based upon the engineering services provided to ~ the plant maintenance -and modification processes, the analyses performed to address NRC concerns 'and self-identi-fied design problems and the: licen_see's overall. technical ability to . support construction completion and ongoing opera-tions fromL an engineering . standpoint. It is noted that _ during this, period, a reorganization of both the corporate engineering and technical support staffs occurred. . A New Hampshire: Yankee . i engineering organization was established with a smaller in-house review capability than existed during the period of full con-struction .and architect / engineer presence. However, well de-fined agreements with . both UE&C and YAEC were established to provide additional engineering services on an as-required basi The station staff also restructured their technical support capability to align with a system / discipline service orientatio While this licensee reorganization has tailored the engineering staff more directly in support of operational activities, cer-tain problems have arisen during this SALP period which high-light the need for more timely and complete engineering analysis of deficiencies particularly by the corporate engineering staf Examples of such problem areas included NRC identification of a Control Building Air (CBA) system which deviated from system-design commitments provided in the FSAR and also of a Contain-ment Building Spray (CBS) piping design which required upgrade and implementation of a design modification to meet the intent of the pertinent ASME Boiler and Pressure Vessel Code. In each case, licensee events or observations had identified evidence of the problem areas (control room ventilation isolation events in the case of CBA and leaking check valves in the case of CBS),

but were not sufficiently developed by engineering review to effect timely corrective actio Ultimately, in both cases, system modifications were effected and NRR review and approval of the CBA and CBS designs were require .

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

l

.

,1 4

S q

,

Other noteworthy problem areas included the' identification b "

.

the licensee of. tube erosion and pitting problems in the primary i component cooling water (PCCW) heat excha ngers ,- evidence of valve lining detachment and ' degradation. in the Service Water (SW) system, and a common mode failure of equalizing valves in the containment equipment hatch' air lock doors. The latter two 3'

issues represent items which were reported by the licensee unde the provisions of 10 CFR 21. Unlike the handling of the CBA and

CBS problems, however, licensee > reaction by the station . tech-

.

i nical support' staff to these. major problems . was_~ thorough,- j methodical and.well scheduled. Eddy current testing lof the. PCCW - !

heat . exchangers ; was implemented, . resulting in the conduct of i tube plugging and sleeving operation The SW valve ' lining- I configurations were redesigned' and .a comprehensive test program j was implemented to verify adequacy. The equipment hatch air j lock equalizing valve ' linkage was also redesigned to preclude l recurrence of a similar failur i i

The only negative aspect to the . licensee responsiveness to these problem areas. was the fact that the SW lining problems repre- -

sented, in - ef fect, a weakness in the licensee's corrective l action. for a 10 CFR 50.55(e) report issued in 1985. At that time, the original valve rubber-like linings were replaced by "Belzona D&A" elastomer. However, it appears that both the replacement design and the construction bonding process . were defective, resulting in the current problem The licensee's j current approach to both the engineering and process. controls required to repair these valves, however, appears to be thorough i and well directe _l In response to concerns raised by the NRC with respect to the  !

engineering department interfaces with the station staff, the licensee has implemented new initiatives to foster mutual co-operation and reliance on technical expertise to address prob-lems. This cooperation has- evidenced itself in corporate engi-neering management attendance at " plan of the day" meetings, the more timely involvement of the corporate engineering staff in operation decisions related to the FSAR and design basis 1 analysis, and plans to relocate corporate engineering personnel !

from the general office building to offices closer to the plant !

itself. Both the Independent Review Team (IRT) and Independent l Safety Engineering Group (ISEG) appear to be functioning in an !

atmosphere which provides valuable overview to not only site i specific engineering problems, but also generic issues affecting :

the industr Current New Hampshire Yankee Engineering Evalua- I

'

tions from the corporate staff provide a documented, well defined approach to technical questions. Thus, the licensee has demonstrated a willingness to implement programmatic improve-ments not only where deficiencies are identified, but also where weaknesses are perceive ii

__b

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

. .

( 30 As was discussed in Section IV. A with respect to construction completion, engineering support activities related to the design reconciliation of the as-built plant (e.g. , PAPSCOTT) were ef-fectively implemented to assure compliance with the design bases and FSAR commitment Licensee corporate management has demon-strated a willingness to implement design modifications where justified by internal engineering evaluations or independent staff reviews. This -licensee responsiveness to determine and effect the proper engineering solution to identified problems (e.g. , EFW Terry-turbine testing; service water valve lining repairs) continues to represent a licensee strength. The recur-rent nature of some of the problems described here and in other sections of this SALP report does, however, highlight the need for additional licensee attention to adequate control of the corrective work processe In summary, engineering services to the station construction completion, maintenance and modification efforts has evidenced some transitional problems from reliance on a large staff, heavily dependent on architect / engineer (UE&C) support, to a smaller New Hampshire Yankee in-house engineering program. The licensee has recognized these problems and appears not only to understand the need for improvement in support of future opera-tions, but also to have initiated corrective measures to proceed in the proper directio . Conclusion Category 2 l Board Recommendation None

.

__ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - ~ ~ ' - " - - - - - ' - ' " - - - - - - - '-- - - ~ ' '

_ _ _ _ - - _

.. .

H .- Licensing Activities I Analysis This area was rated as Category 1 during the previous assessment-period based upon the required preparations, responses to open items, and.overall readiness with respect to the issuance of an !

operating . licens The previous assessment. concluded 'that .I

,

' management involvement was evident and effective, that a high' {

degree of responsiveness was apparent, and that corporate staf- !

fing levels were sufficient to support licensing . actions. Since the previous assessment period, a license has _ been is' sued to permit fuel load and the conduct of' precritical test A license to. operate.up to five percent power has been requeste The current assessment is based principally on NHY performance  !

in support of those. actions which were required to obtain a fuel l

. load license and which were taken in connection with its request I for issuance of the five percent licens The licensee . has continued' to demonstrate - strengths in their approach to problems from a safety standpoint, in the qualifi-  !

cations and level of staffing and in the active involvement of-corporate management. The licensee has provided 'the needed tech-

.nical capability in the engineering and scientific disciplines to' resolve items of concern to the NRC. Resolutions to tech-nical issues have been consistent and thorough. The licensee has been willing to perform additional studies, as necessary, to answer any outstanding NRC question . Thu s ,- on technical matters, ef fective communications between -the licensee and the NRC staff have been beneficial in processing licensing action The licensee. f acilitated timely resolution of the majority of outstanding licensing issues. . In .most cases, acceptable pro-posals were submitted with the initial licensee response. The overall responsiveness to NRC initiatives was generally satis-factory, except for certain issues, where in the first part of the current SALP period, additional NRC requests were needed to gather ' complete information. For these cases, NHY corporate management involvement and timely action were effective in promoting satisfactory resolutions to the specific problem NHY management has actively participated in licensing actions and generally has maintained awareness and knowledge of current and anticipated licensing activities .during this evaluation period. On several occasions, licensee management has demon-strated not only involvement in licensing, but also p romp t ,

l -

__ - - - _ - -

~.

4h-

!. . -

-

.

,

appropriate corrective ' action to situations where . the respon-siveness to NRC initiatives was deemed unacceptable or not timely. --NHY has also demonstrated a willingness to ' meet with the .NRC Licensing Project Manager to; discuss licensing action status on an as-needed' basis and with a cooperative attitude to resolve problem NHY. licensing and engineering groups have b'een adequately-staffed, as' indicated by the qualified representatives attending-numerous meetings with the NRC, . Competent technical staff have

-

participated' in scheduled reviews and . effected satisfactory

. resolution of open items. The NHY Bethesda Licensing. office has

. remained active throughout this SALP period as a significant licensee -initiative which continues to provide priority atten-

-

tion toL NRC concerns. In ' general, - the licensing group has ef fectively coordinated the effort of providing input from 'the -

,

.differeht functions within the NHY organizatio ' Conclusion

,

Catego'y r 1 3 '. Bosed Recommendation None

> ,

%

i

.

_ _ _ _ _ _ _ . _ _ _ _ _ _ _ - - - _ - - --'

__ _ _

.

-

.: ... ,

J i

l 33 'j

)

' Training and Qualification Effectiveness

'

i Analysis Training and Qualification Effectiveness is an evaluation cri-

.terion for each Functional Area. 'In .this appraisal, it is!also being considered as a separate area and as such, represents c a synopsis of the assessments .in the other areas. Training effec-tiveness is measured by observation of licensee personnel per-formance and through reviews of licensee. programs, _

The limited scope of operations during this assessment period has not allowed for an appraisal - of the - effectiveness. of train-

.

{

ing over the full . range of operational activities:which will be I implemented in the future. However, in those. areas where the measures of licensee performance can be related. to ' training and - !

qualification criteria, this assessment provides an overall i evaluation of the effectiveness of control and conduct of' i licensee work activitie !

In the last SALP period, this functional area was not evaluated !

separately, but Operator Licensing was assessed a Category 1 rating as part of the overall operational readiness appraisa !

During the previous assessment period, the licensee had demon- ;

strated a commitment to quality training. This commitment has remained evident through the current SALP period based upon licensee initiatives in the areas of simulator enhancement and efforts directed toward licensed operator training program accreditation by the Institute of Nuclear Power Operations 3 (INPO).

The first group of operator licenses at Seabrook became due for renewal during this period. Two year license renewals were issued for these individuals. A requalification program eval- q uation was also iritiated to provide a basis for the license >

renewal. To date, this evaluation has consisted of an NRC review of the requalification program and an NRC requalification examination administered to eight licensed operators. Three operators failed one or more portions of the NRC administered !

requalification examination and are being upgraded in accordance +

with the existing NHY requalification program. Training Depart- l ment actions to address NRC identified generic weaknesses and j strengthen the overall program have been initiated and appear i well directed. As had been evident in previous, less formal NRC appraisals of operator training with respect to requalification, the licensee has demonstrated a willingness to devote adequate l resources to the training goals and to commit additional )

resources to upgrade identified areas of weaknes I l

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

_ _ _ . _

M

.,; .

3 .>

,

.34

> 1 It..should be::noted 'that' another initial operator licensing

-

? -

examination .was administered in August,= 1987. . Although this '

examination'was conducted shortly aftere the end of this current SALP assessment period, the results Lindicate ; a high initial >!

. examination pass - rate which is consistent with the previous ~

initial. license' examinations:at Seabrook Station, A review of the LERs and enforcement actions issued during this SALP ' period identified certain problems 'related to training effectiveness. ~As discussed in other Functional Areas, viola-tions resulting from the failure ~ to ' maintain a.. valve': locked-- ,

closed in accordance with license conditions and the failu're to-

'

follow' procedures in notification during_ the Unusual Event, were caused .in part by training deficiencies. Additionally, . incom- i plete operator understanding of - the design bases of . the CBA system design, as noted in Section IV.G, led to a violation, af ter a deviation from FSAR commitments had already been issued l-on the same subject. The problems, however, appear to have been "

isolated examples,, as the' overall training provided the opera- 1 tions staf f.is of high quality with no major generic weaknesse An.eva'luation of the LERs issued during this assessment period identified no specific causal linkage between performance-related problems and the adequacy of trainin In the area of general and specialty training, a reorganization-has consolidated all training functions under the-Training Center Manager who previously was responsible only for licensed operator trainin This change should enhance the overall training effort while reducing the administrative resp'onsibil-ities'of the Station Manage NRC inspectors monitored various licensee training sessions both for the purpose of on-site program familiarity and to assess the '

effectiveness of licensee training in areas such as general employee training, radiological controls and fitness for dut Also, NRC inspections of other functional areas have evaluated the conduct of training (e.g., Technical Specification revision training for operators, entry level and annual requalification for the security force, supplemental HP training, and general EP training provided the licensee Emergency Response Organizatio This inspection effort has confirmed that the training and qual-ification criteria inherent in the implementation of other tech-nical programs have been effectively utilized. Region I special team inspections into allegations regarding Seabrook construc-tion hardware and programs revealed no specific disciplinary ,

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

.

__ _ - _ . _ l

.

. -

,

'

,, -

y,. or

.j..' i 13 -

=

.

l-

.

.-l Thus, 'a review of flicensee1 performance across Lthe. range, of

.

"

'different disciplines,- as .' highlighted 'in .theidifferent' func -

-

tional areas, reveals that- the. conduct of. adequateLtraining and

qualification programs have contributed to the successful'imple- ;

cmentation JoF overall station objectives. An additional example {

'of licensee; philosophy in this regardLwas the wide disseminatio l of technicalinformation, either industry initiated oraNRC' I

! originated, throughout'the station staff. This information flow has effectively increased the; station's awareness to problem areas-in the industry and.has provided guidance.to the technical

' staff for' performance improvement N ' In summ'ary, in those 1 areas 'where : NRC and licensee- evaluation I have identified ;trai.ning related weaknesses, prompt. and ef fec-

.

tive , corrective ' measures, including the retraining of ~ personnel, have'been implemented. With respect.t'o the overall: control' of j training ' functions and ~ performance by statio_n personnel, NRC l inspections over' the course of. this SALP period have found the

-

i licensee programs and_ staff.to be effective, i Conclusion-

.

i,

.. Category 1 - Board Recommendation  ;

'

None i-1

,

j

I

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

. .

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

'

is an integral part of each functional are This appraisal of the assurance of quality is a synopsis of the applicable aspects s of other areas, including worker and supervisor performance, management oversight, and safety review committee activitie During the last SALP period, this functional area was assessed a Category 1 rating based upon an ef fective QA program, which assured construction quality, and the continued management support of QA initiative;.

During the current assessment, an entirely new QA program, that of operational quality assurance, was subject to evaluation along with a new organizational structure, revised interfaces, different work controls, and the necessary shif t from construc-tion processes to maintenance and modification activities. The interdependence of NHY QA policy and procedures with the Yankee AtonHc Electric Company (YAEC) program was eliminated and key personnel responsibilities shifted accordingly. It is note-worthy that the licensee retained sufficient experienced per-sonnel from contractor organizations (e.g., YAEC, UE&C, Westinghouse) to effect a smooth transition into the operational system of control However, certain transitional problems have been experienced in the restructuring of the QA organization to fit its operational responsibilities. While management support of an effective QA program remains strong, the relative strength of the QA organi-zation as an independent force and prime mover in the corrective action process has diminished. This may be the result of and a normal consequence to the establishment of a strong station staff with particularly qualified and technically competent operations, maintenance and technical support groups. However, one negative aspect of this has persisted throughout the current SALP period and relates to the feeling that the station staff can disposition their own problems without the need for QA involvement and that the QA staff mission relates more to pro-grammatic and procedural overview than it does to the effective-ness of control . - - _ _ _ _ _ - _ _ _ _ - - _ - _ _ _ _ _ _ - _ __ _ _

. .

. .

NRC inspection issues which have highlighted this concern include questions into tagging controls, station operating and surveillance procedures, the use of unauthorized operator aids, general housekeeping and corrective action processes, and utilization of Station Incident Reports as an information source for root cause problem analysis. In several of these cases, where a specific NRC recommendation for QA follow up of the identified deficiencies was made, audits were conducted. These q audits proved to be extensive and thorough and generally con" firmed a need for corrective actio However, the fact that such QA reaction to the problems was not routine, but evident only upon NRC interest is a matter that warrants further manage-ment evaluation of their QA program of controls, t

One strongpoint of the present QA program is the effective use

'

of quality control inspections and holdpoints to confirm the 5 proper conduct of special processes. The implementation of such l QC measures has strengthened an already strong maintenance pro-gram in the area of independent checks and assurances of the adequacy of controls in the various discipline Another pro-g rammatic strength is the individual expertise provided by the i

technical support staff. The NHY system engineers, while not QA l

'

personnel, provide a definite measure of effectiveness to the overall station assurance of quality, based upon their knowledge and technical interfacing with other personnel on the station l P.aff and with the QA and engineering organization This strength relates to an overall NHY organizational structure which appears to be effectively working, while still providing a system of independent checks and balance Examples of independent groups within NHY which provide quality services which have supported the successful functioning of the overall organization include the Independent Review Team (IRT),

the Employee Allegation Resolution (EAR) program and the Independent Safety Engineering Group (ISEG). Both the IRT and ISEG have been involved in design evaluations, and the analyses of component failures and human factor problems which have led to reportable events. In the same way with respect to allega-tions, the EAR program has provided a " third party" review of concerns which has not only proved beneficial to the investi-gative process f o'r worker concerns, but also has provided a measure of independence to the normal management review of problems. The IRT and the EAR were also both noteworthy as licensee initiatives which were established and maintained, not because of regulatory requirements, but because of the benefits the licensee knew would accrue from independent self-evaluation Programmatically, these independent groups, along with the Nuclear Safety Audit and Review Committee (NSARC) and the use of special review groups where necessary, have provided a measure of the licensee's ability to self-criticize and thus learn and improve with the corrective action proces __

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

L. . ... .;

1

, . 38'

{

Another licensee internal review group, the Station Operation Review Committee (SORC), has also ' been . active during this assessment period in reviewing program and procedural revision Some ' administrative problems in SORC. effectiveness were iden- i tified by the NRC with respect to the application of safety j review criteria to "nonintent" procedural changes, _ Also, the "

practice of conducting such reviews outside the. scope of the SORC rneeting was questioned, On both these matters, the licen- i

.

see' recognized the . advisability of . instituting . improvements to ,

the SORC and safety . review processes and implemented additional  !

systematic review measures to address.the NRC concern ,

Another program where - NRC ' inspection revealed the need for i further development was the licensee's implementation of a Quality Trending System. Weaknesses . identified ' in .this area -

related to the lack of corporate and QA management attention to i the availability of problem trending mechanisms and ' also to a I database which fails to track the valuable. trending information available in documents other than nonconformance reports, j Licensee . QA management was apprised of these concerns and 'has ,

instituted. program reviews intended to upgrade ,the defined cor- i rective action proces Continued attention to the controls l which integrate plant activities and ' problems (e.g., Station Incident Reports) into a QA trending system,- thus providing insights into the lessons learned, is warrante Overall, in evaluating this _ functional area, in the context of

quality criteria affecting other rated areas, a high level of performance was note Effective work controls, strong first i line supervision, timely QC inspection and a continued emphasis on quality performance, to include management support of QA ,

goals, have resulted in evidence that the plant is being oper- i

^ ated and maintained safely. While some areas requiring improve-ment were identified,. positive licensee initiatives were also noted to sustain the Assurance of Quality during the major transition from construction to operations. A strong quality conscious attitude is evident throughout all levels of the plant i organization. The increased involvement of the QA organization into operational activities and problem analysis should further enhance the overall effectiveness of the quality progra . Conclusion Category 2

0

'

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

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

. .

39 Board Recommendation Licensee: New Hampshire Yankee management should reassess the role of the QA organization in the analysis of opera-tional problems. The licensee should consider expan-I

'

ding the scope of quality assurance functions to more effectively utilize QA as a management tool to recog-nize the generic impact of certain problems, and thus allow corrective action to be directed to related areas of programmatic weaknes NRC: None

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

't

. ...

..

40 ; SUPPORTING DATA AND SUMMARIES

.. . Investigation and-Allegation Revie ]

During .this assessment period, a total of four separate and gener- }

ically categorized allegations were received by . the NRC. One of

these. generic sets of concerns was-multifarious and' involved concerns of. a broad and general. nature. To date, over 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of direct NRC j i- inspection effort have been expended to determine whether quality construction ori. safe operation had been 'o r could be adversely l j

l impacted by this ' set of stated allegations. In. this case, as ..with : j the other' three. allegations, no violations were identifie ~l It is noteworthy that while several of the stated concerns involved nonsafety-related components, NRC inspection treated - these allega- ,

tions rigorously as technical issues to determine if s' ome deficiency '

could be linked to safety-related activities. No linkage was-identi-i fied, and, to date, no hardware problems (either safety or'nonsafety)

!

have been-in evidence. While evaluation of several new concerns ' is in~ progress, the findings 'so far corroborate the quality of con-struction. These results also confirm previous NRC . assessments that-

-over the. course of construction -completion, few hardware . problems have been identified and those that had existed have been adequa'tely-correcte Escalated Enforcement Action None L Management Conferences No conferences with the licensee dealing with enforcement were held during the appraisal period. On June 10, 1986, a management meeting at NRC request was conducted at Seabrook Station to discuss the results of the Region I SALP board convened to evaluate licensee performance from January 1, 1985 to March 31, 198 Review of Licensee Event Reports (LERs) Tabular Listing Refer to SALP Table 4 for Listing of LERs by Functional Area s

e

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

'

g4

-

-

..

,

,. s.-

t

'

41' <

_ Causal Analysis 7 Analysis of the LERs listed in: Table 4' has identified no unac--

ceptable. chains per statistical acceptance criteria.' . An AEOD evaluation of-Seabrook!s LERs indicated that the reports were of

. generally above-averageL quality. . ' Additionally, one ' other non -

. reportable event was' identified which Was lin ed to.a reportable

. ,

event. While the licensee ' had notn recognized this. linkage 'in subsequent reporting, this had no effect on the causal analysis-

.or the'result . Summary of Licensing Activities Significant-NRR/ Licensee Meetings-a. June 26, 1986 --

Operational Readiness of.Seabrook Unit 1 b. August 6, 1986 --

Seabrook : Station. Risk' Management and Emergency Planning,.(RMEP)'. Study. and-Emergency Planning Sensitivity (EPS)

Study c. September 4, 1986--

. Seabrook Fire. Hazards Analysis j u

d. September 8-9, 1986- NRR '& Brookhaven National Laboratory (BNL) Site Tour for RMEP & EPS Studies e. September 23, 1986 - RMEP & EPS' Studies

'f.' March 18, 1987 -

Seabrook Unit 1 Licensing Issues g ' March'25, 1987 --

BNL Report on RMEP & EPS Studies i

". h. May 7, 1937 -

Seabrook Unit 1 Licensing Issues 1. July 30, 1987 -

Utility Compensatory E-Plan for Massachusetts Commission & ASLB/ASLAB Decisions a. October 17, 1986 - Issuance of Facility Operating License (NPF-56) for Zero Power Testing b. November 20, 1986 - ASLAB Denial of Zero Power License Appeal (ALAB-853) by Massachusetts c. January 9,1987 -

Commission Review of ALAB-853 Stays Issuance of Low Power License l

_ _ _ _ _ _ __________ ____--_ __ -_ - E

._ . _

. _ - _ _ _ . .

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l

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d. March 25, 1987 -

ASLB Issuance of Partial Initial Decision on Low Power License e. April 9, 1987- -

Commission' Order (CLI-87-02) Retains

,

in Effect License Stay f. April 22, 1987 -

Full Power ASLB Denial of Licensee Petition to Reduce EPZ g. June 11, 1987 -

Commission Order (CLI-87-03) Denies !

Licensee Motion to Lift License Stay

_ _ _ _ _ _ _ - _ .

- .

I, TABLE 1 INSPECTION REPORT ACTTVITIES Report No. Inspection Hours Area (s) Inspected

  • 86-09 74 Routine Inspection of General and System Operating Procedures l

86-19 86 Routine Inspection of Preoperational Test Program 86-20 439 Routine Inspection of Construction Completion, Preoperational Testing, Training, TMI Action Plan and Previous ;

Items 86-21 43 Routine Inspection of Previous Items

!

86-22 160 Routine Inspection of Chemistry, Effluent Controls and Radioactive Waste Programs 86'23- 122 Routine Inspection of QA Program and Previous items 86-24 37 Routine Inspection of Records Related to reactor Yessel and Internals and Previous Items 86-25 123 Routine Inspection of Occupational Radiological Protection Program 86-26 33 Routine Inspection of Nuclear Material Control and Accounting 86-27 240 Special Team Inspection Comparing Technical Specifications to As-Built Plant 86-28 135 Routine Inspection of Operational Readiness and Previous Items

86-29 74 Routine Inspection of Security l Plan and Implementing Procedures '

l

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

'

Table 1 2 Report No. Inspection Hours Area (s) Inspected 86-30 113 Routine Inspection to Follow up Emergency Plan Implementation Appraisal and Previous Items 86-31 32 Routine Inspection of Startup Test Program and Procedures 86-32 27 Routine Inspection of Fire Protection Program 86-33 37 Routine Inspection of Abnormal and Emergency Operating Procedures and Previous Items 86-34 333 Routine Inspection of Construction Completion, System Design, TMI Action Plan and Previous Items 86-35 110 Routine Inspection of Chemistry, Effluent Controls and Radwaste Programs 86-36 91 Routine Inspection of Operational Readiness and Previous Items

, 86-37 88 Routine Inspection of l

Preoperational Test Program l

86-38 32 Routine Inspection of Radiological Environmental Monitoring Program 86-39 79 Routine Inspection of Occupational Radiological Controls Program 86-40 47 Routine Inspection of Preeperational Test Program 86-41 44 Routine Inspection of Security Plan and Procedures 86-42 -

Inspection Number Not Used

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

.

_

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.

'ht ' g 3 o L "

' Table m s i Report N Inspection Hours Area (s) Inspected 86-43 115 ' Routine Inspection of Seismic'

~ Piping Systems, Pre-Service Inspection ~ Program and As-Built 1

P1 ant-86-44 '68- Routine Inspection of Effluents JI Control and Radwaste Programs

~86-45 36 Routine Inspection of Electrical and I&C Procedures and Previous Items 86-46 358 ,

Routine Inspection o Construction Completion Activities, Design Changes, :

~As-Builts, TMI Action Plan,- >

Previous Items 86-47 '428 Routine Inspection of Testing, License Issuance, Cor'e Loading, Maintenance, Surveillance, ;

Operations and Previous Items 86-48 48 Routine Inspection of Startup Test Program and Procedures; Review of Containment Sit Report 86-49 39 Routine Inspection of Pre-Service Inspection Program and Records and Previous Items

'{

86-50 131 Routine Inspection of Initial Fuel Loading Activities 86-51 97 Special Team Inspection To Review Allegation of As-Built Drawing Discrepancies 86-52 478 Special Team Inspection to Review Allegations by ELP 86-5'3- -

Inspection Number Not Used 86-54 187 Routine Inspection of Operations, - .

Maintenance, Surveillance, 1 Startup Testing and Previous j Items '

___

_-_-

.r .

t Table l 4 Report N Inspection Hours Area (s) Inspected 86-5 . Routine Inspection of Occupational Radiological ..

'

' Controls Drogram and. Previous Items

!

86-56 24 Routine Inspection of Physical Security Program and. Previous Items-86-57 -

Inspection Number Not'Used

.86-58 118 Special' Team. Inspection To Review. Licensee ~ Action on GL 83-28, ATWS 87-01 128 Routine _ Inspection of'

Preoperational Test Program, Test Procedure Review, Test. Witnessing ~j and Test Results Evaluation'

87-02 432 Routine Inspection of .. 4

.

Post-Core' Loading Heat-Up and i HFT, Maintenance, Surveillance, -l Operations and Previous Items i 87-03 '56 Routine Inspection of I&C Surveillance Test Progra '30 Routine, Inspection of Radwaste Program and Pre 0perational Test Results Evaluation 87-05 69 Routine Inspection of Startup Test-Program, Post-Core Loading Hot Functional Testing and Test Results Evaluation 87-06' -

Inspection Number Not Used

. 87-07 583 Special Team Inspection of -j Allegations Raised by ELP 87-08 26 Special Inspection to Follow-up Unusual Event of 02/11/87 87-09 34 Routine Inspection of Post-Core Loading Hot Functional Testing

,

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

_ _ _ _ _ _ -

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' J' m Table 1 ,

5 l

, -

o, ,

Report N Inspection Hour's Area (s) Inspected

~87-10 346' . Routine Inspection of Post-Core '

Loading Heat Up and HFT and- j

~Cooldown,-Maintenance, Training, Operations and Previous Items 87-11- 32 Routine Inspection of Startup Test Program, Post-Core Loadin Hot Functional: Test Witnessing-and Test Results' Evaluation.

'-

87-12 -54' Routine Inspection.of EP Progra'm~,- ,

Organization and Managemen l

. Control, Training and Previous '

Items ,.  ;

87-13 268 Routine Inspection of Design ,

l

.

Control Program, Testing,- .

!

Maintenance, Surveillance and 1 Previous Items 87-14 34 Routine Inspection of Occupational Radiological Controls Program 87-15 33 Routine Inspection of  !

Non-Radiological Chemistry Program 87-17** -

Operator Licensing Examination 87-18 35 Special Inspection of Service Vater Valve Repairs 87-19 -

Operator Licensing Examination 87-20 34 Routine Inspection of Eoutpment Tagging and Temporary Modification Programs-sirst inspection conducted during this SALP period was IR 86-19. 86-09 was subsequently conducted out of sequenc **87-16 report will be included in next SALP perio {

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TABLE '

,

'

9- . INSPECTION HOUR SUMMARYJ .

. ,

. . .

HOURS'

FUNCTIONAL AREA 5 Actual ' Annualized- . Percent

'

IL : Construction' Completion' 1349- 1012 :1 . Startup' Testing.' :1244 932- 17. 8 ': '

  1. ,

a- .o

' '

p Plant Operation '

2667 2000 '3 .'4'-. Radiological Controls 739 554- 1 J

,  : 5.' - Em'ergency Preparednes .

219- 16 .2l 3 U

L 6.:-- Security.'and Safeguards 175 '130- n ,

.

7,.-- Engineering.. Suppor . . Licensing Activities - - -

9.- Training and Qualification -

'

- -

. Effectiveness-

-

~

10. -Assurance'of Qualit .-

-

._____ _____ _____

TOTAL .- '6972 -5226 100.0

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TABLE 3:

a4 g', '- '

>>

. ENFORCEMENT ACTIVITY

+

~

'A,- Violatio'ns Versus Functional Area By Severity Level'

. ;; -

, t No. of Violations in Each Sevarity. Level ic Fun'ctional Area V I V,' III' II 'I ' Total '

.. . 1. -Construction Completion- -

O sy Startup Testing 'O Plant Operations- 1E 4 5 Radiological Controls .

<

<

5. . Emergency Preparedness 1 .1

  • Security-and Safeguards ~ 0

~ Engineering' Support- 0

< 8. , Licensing, Activities

-

0 . Training and Qualification 0

.1 Assurance of Quality'. 0 TOTAL 1 5- ~0 0 0 6 i

.

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-Table 3

'

L2l

' '

q ; Summary

,

. Inspection . Severity Functional Brief-1 Numbe .. Requiremen Leve : Area . Description-

-

86-46 110 CFR 50, 4 Operation Seismic 2 Over ,

'

c APP.'B~ Controls'For-Temporary Equi pment'"

'

i- ~ 86-47~ .10 CFR 50,. 4 Operation . Locked Valve ,f APP. Controls "

.87,-02 '10 CFR-50, 4' Operation CBA Sys;em Noti Ao Operated;I Accordance With Design Requirements

'

87-08' T..S.6.7.1' 4 Emerg. Pre . Failure To Report:

Unusual Event'

.87-13 10 CFR 50.59 4 Operations SW/SCW Temporary

. Modification 87-20 10 CFR 50, Op'erations

~

5 Tagging Program APP. B Deficiencies

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TABLE 4 a LICENSEEEVENTEEPORTS

.

LA . LER By Functional ' Area- .

' Number By Cause Code *'

'

' Functional Area- A! 8 -C- D- E 'X l'.' Plant' Operations 8 2 4 3

?2.LRadiologicalControl '

e ' Emergency. Preparedness Security and Safeguards- Startup. Testing

.,

,

Licensing-Activities

' ' -

. 6 .'

.. Construction Completion - ! l

. Engineering Support- '

,j

. ~ .Trainin'g. Qualification:and

Effectiveness-

@

10. Assurance cf Quality

.___ ___ ___. ___ ___ ___

8'

.

'

TOTAL 2 0 4 3 0

  • Cause Codes'

!

1 A Personnel Error i

B . Design,' Manufacturing, Construction, or Installation Error 9 C - External Cause D - Defective Procedures E - Component Failure X - Other

Cause Codes in this table are based on in:pector evaluations and may differ from those specified in the LE .,

i

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_ _ _ - . - - -

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, Table 4 2 s-

_

t 'LER Synopsis l

<

LER Number Summary Cause 86-001 Normally Locked Closed Valve Found Mispositioned A . l '86-002 ' Inadvertent Safety Injection . :ESF Actuation-- Control Room A-Ventilation Isolation 287-001 ESF Actuation - Control Room E l

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

'

'To Essential Switchgear Bus87-003 Source Range Analog Channel Operational ~ A' -

Tests.Not Staggered 87-004 Containment Equipment Hatch Air Lock B 1 Equalizing' Valves Inoperable

'87-005 Main Control Board Indicators Not B Properly Mounted

._f'

!87-006' ESF Actuation - Loss of-Power To Vita E Instrument Panel 87-007 Solid State Protection System-Auto A Shunt Trip Test i

.,.87-008 Technical Specifications Daily Log A 87-009 ESF Actuation - Improper Tagout Of A MSIV Actuation 3 87-010 ESF Actuation - Main Feedwater D !

Isolation '87-021 ESF Actuation - Loss of Power To a 0

'

>

Vital Bus

'87-012 ESF Actuation - Failure of SI Reset E Switch o

.

____ _ _ _

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

Y e

.e *

,

.

. Table 4 3

.

<

87-013 Area Temperature Monitoring In

'

B Batter / Rooms87-014 ESF Actuation.- Start of EDG "B" 0 i

i

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

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