IR 05000443/1986099

Forwards,For Info,Te Murley 860605 Ltr to Util Transmitting SALP Rept 50-443/86-99.Related Correspondence

ML20206J645
Person / Time
Site:	Seabrook
Issue date:	06/20/1986
From:	Sherwin Turk, Turks S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Harbour J, Luebke E, Wolfe S Atomic Safety and Licensing Board Panel
References
CON-#286-730 OL, NUDOCS 8606270231
Download: ML20206J645 (1)

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UNITED STATES

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,x Sheldon J. Wolfe, Esq. , Chairman Dr. Jerry Harbour Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington , D.C. 20555 Washington, D.C. 20555 Dr. Emmeth A. Luebke Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of PUBLIC SERVICE COMPANY OF NEW IIAMPSIIIRE, et al. --

(Seabrook Station, Units 1 and 2)

Docket Nos. 50-443 OL and 50-444 OL

Dear Administrative Judges:

Enclosed for your information is a June 5, 1986 letter from Thomas E.

Murley, Regional Administrator, NRC Region I, to Robert J. Harrison ,

President and CEO, Public Service of New llampshire, enclosing the NRC Region I Systematic Assessment of Licensee Performance (SAPL) Report No.

50-443/86-99 for Seabrook Station, Unit 1. You may wish to note that the Applicants' off-site emergency preparedness is among the items evaluated (at pp. 25-26) .

Sincerely, ( /Q Sherwin E. Turk Deputy Assistant Chief flearing Counsel ec: With Enclosure-Service list

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1 JUN 0 51986 -

Docket No. 50-443 O

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Public Service of New Hampshire ATTN: Mr. Robert J. Harrison President and Chief Executive Officer P. O. Box 330

Manchester, New Hampshire 03105

Gentlemen

Subject

Systematic Assessment of Licensee Performance (SALP) Report No.

50-443/86-99 i'

On May 14, 1986, the NRC Region I SALP Board reviewed and evaluated the performance of activities associated with the Seabrook Station, Unit 1. This assessment is j documented in the enclosed SALP Board report. A meeting has been scheduled for

June 10, 1986 at 10:00 a.m. at the site to discuss this assessment. That meeting

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is intended to provide a forum for candid discussions relating to the performance

evaluation.

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At the meeting, you should be prepared to discuss our assessment and your plans

to ensure continued emphasis upon those activities which would have a positive ef-i fect upon your performance through Seatrook's transition into the operations phase.

l Any comments you may have regarding our report may be discussed. Additionally,

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you may provide written comments within 30 days after the meeting.

Following our meeting and receipt of your response, the enclosed report, your writ-ten response (if deemed necessary), and a summary of our findings and planned ac-tions will be placed in the NRC Public Document Room.

I Your cooperation is appreciated.

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Sincerely, i

OrigYnal Maned tiy

! thomas I. Murlev Thomas E. MurTey i Regional Administrator

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Enclosure:

NRC Region I SALP Report No. 50-443/86-99 I

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REGION I==

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-443/86-99

PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE SEABROOK STATION, UNIT l'

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

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BOARD MEETING DATE:

MAY 14, 1986

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SUMMARY l

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TABLE 3 - ENFORCEMENT DATA i

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I. INTRODUCTION A. Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this in-formation. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC j resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation.

An NRC SALP Board, composed of the staff members listed below, met on May 14, 1986 to review the collection of performance observations and data and to assess the licensea performance in accordance with the guid-ance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Per-formance". A summary of the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's performance at the Seabrook Station for the period January 1,1985 through March 31, 1986. This SALP differs significantly from previous Seabrook Station assessments. For the entire assessment period, Unit 2 has been in an ( " indeterminate" status with licensee work confined to preventive main-3 tenance, preservation and protection activities and the construction completion required to support Unit 1 operation. Therefore, licensee performance related to Seabrook Unit 2 has not been assessed, although some inspection (See Note in Table 2) has been performed of licensee efforts with regard to Unit 2. Also, construction related activities have been combined into one functional area with emphasis not so much on the individual disciplines, but more upon constuction completion and readiness for operation. New functional areas were added to address other plant operations and readiness aspects of licensee performance.

B. SAlp Board:

Chairman:

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

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

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

E. Wenzinger, Chief, Projects Branch No. 3, DRP T. Elsasser, Chief, Reactor Projects Section 3C, DRP V. Nerses, Project Manager, PWR Project Directorate 5, NRR ,

A. Cerne, Senior Resident Inspector

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Other Attendees '

W. V. Johnston, Deputy Director, DRS J. R. Johnson, Chief, Operational Programs Branch, DRS W. J. Lazarus, Senior EP Specialist, DRSS J. R. McFadden, Radiation Specialist, DRSS D. Ruscitto, Resident Inspector M. M. Shanbaky, Chief, Facilities Radiation Protection Section, DRSS

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

C. Background

Public Service Company of New Hampshire (PSNH) applied for a license to construct and operate the Seabrook Station (DNs 50-443 and 50-444) on July 9,1973, and was issued Construction Permits (CPPR-135 and CPPR-136)

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

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

l The units are arranged using a " slide-along" concept with certain struc-tures common to both units. PSNH has contracted with the Yankee Atomic Electric Company (YAEC) for services which, include project administra-tion, facility design control, construction coordination, quality assur-ance, and licensing. For the purpose of this report, these YAEC services are considered synonymous with PSNH activities.

' On June 23, 1984 the New Hampshire Yankee Division (NHY) of PSNH was created with the primary responsibility for construction of Seabrook

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Station. While some of the organizational interfaces and responsibili-ties between PSNH and YAEC have been restructured to accommodate the formation of NHY, at this time, PSNH continues to retain overall re-spensibility for all activities related to Seabrook, as is specified in

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the Construction Permits. Proposed organizational changes seeking to

' name the New Hampshire Yankee Electric Corporation (i.e., NHY incorporated and separated from PSNH) as the new managing agent for Seabrook Station have not yet been effected. Thus, use of the generic term (" licensee")

in this SALP currently constitutes recognition of not only the ultimate I

responsibility of PSNH, but also the specific duties of both NHY and

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a. Licensee Activities At the beginning of this SALP assessment period, the licensee pro-jected Unit I construction to be 83% complete. The site work force, still building up from the 1984 work suspension, numbered about 2500 personnel,1400 of whom were craft. As construction continued, priorities were directed to the support of preoperational testing i

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

, major testing progressed through the period with the conduct of the Reactor Coolant System Hydrostatic Test in April, 1985; Hot Func-tional testing during November, 1985; and Engineered Safety Features

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testing, Loss of Offsite Power testing and the Containment Struc-tural Integrity and Integrated Leak Rate testing in early 1986. -

Additionally, six plant buildings were completed and turned over to the control of the plant staff.

By the end of the assessment period, only 3% of the plant systems remained in a construction status awaiting turnover to the startup test staff. The remaining construction work, not yet substantially complete, includes insulation and fire sealant installation, paint-ing, activities in support of the remaining preoperational testing, building turnover, and design modification rework. Preservice in-spection, ASME Code stamping, and piping and pipe support stress reconciliation programs are also continuing. The construction work force, as of March 31, 1986 was approximately 3500 personnel, about 2200 of whom were craft. The licensee estimates Unit I to be 98%

complete.

' Other licensee activities during this SALP period included continued operator licensing, emergency preparedness, and operational readiness ;

i planning and program reviews. New fuel was initially received on *

site in February, 1986 and an Emergency Drill, exercising NRC, the l '

State of New Hampshire and licensee response, was also conducted in February, 1986. As of March 31, 1986, a station staff in excess of 500 personnel, in addition to a New Hampshire Yankee corporate staff, were in residence at the Seabrook site.

l The licensee projects a Fuel Load Date (FLD) of June 30,1986 for Seabrook Unit 1.

b. Inspection Activities Two NRC resident inspectors were assigned throughout the assessment period witt a third inspector assigned on site since May, 1985.

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A total of 53 inspections were performed with 7912 hours0.0916 days <br />2.198 hours <br />0.0131 weeks <br />0.00301 months <br /> dedicated to the inspection of Unit 1 activities. This corresponds to 6330

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hours on an annualized basis. An additional twelve hours were utilized to confirm licensee preventive maintenance, preservation and protection efforts on Unit 2. NRC inspections conducted during this SALP period are functionally categorized below, with the five types of team inspections listed separately by their unique scope.

Region I Specialist Inspections Number Construction 8 Preoperational Testing 15 Fire Protection 2 Operational Readiness 4 Radiological Controls

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Operator Licensing 2 Resident Inspections 9 Team Inspections Management Reorgarization 1 NDE Independent Maasurements 1 EP Appraisal 2

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Safe Shutdown (Appendix R) 1

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As-Built Plant 1

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The nine resident inspections noted above represent continuous on-site coverage of licensee activities throughout this assessment period. A distribution of inspection hours, by functional area is shown in Table 2. Enforcement data, resulting from these inspection activities, are summarized in Table 3.

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This report also discusses the " Assurance of Quality" as a separate functional area. Although this topic is assessed in the other func-tional areas as one of the evaluation criteria, discussion of this area separately provides a synopsis. For example, quality assurance effectiveness has been assessed on a day-to-day basis by resident inspectors and as an integral aspect of specialist inspections.

Although quality work is the responsibility of tvery employee, one of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. These and other major factors that influence quality, such as involvement of first-line supervision, safety committees and worker attitudes, are discussed in each area.

c. Other Activities An NRC Caseload Forecast Panel visit to Seabrook was conducted on September 4-5, 1985 to assess the status of Unit 1 construction.

Their review found the June 30, 1936 fuel load date (FLD) to be reasonable, but recognized that funding and schedular uncertainties, known to exist at that time, made the achievement of fuel load dur-ing the third quarter of CY 1986 more likely.

i It is noted that subsequent to the Caseload Forecast Panel visit to Seabrook, the joint owners of Seabrook Station voted to authorize full-construction funding and. proceed with all scheduled construc-tion activities, effective October 1, 1985.

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

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

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ing water system commenced that same day.

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

70-3027), authorizing the receipt, possession, inspection and stor-age of fuel assemblies and other radioactive materials 19, 1986. for eventual Initial i use at Seabrook Unit 1, was issued on December fuel receipt and storage on site, in accordance with the provisions of the 10CFR70 license, commenced in Febraury, 1986.

A Prehearing Conferer.ce for the EP phase of the ASLB hearings was 25-26,1986. In conducted in Portsmouth, New Hampshire on March accordance with the ASLB Memorandum and Order, dated January 17, 1986, the hearings for New Hampshire Offsite Emergency 21, 1986.Planning

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Contentions are scheduled to commence on July The " Proof & Review" edition of the Seabrook Technical Specifica-The licen-tions (TS) was issued for comment in late March,1986.

see, Region I and the Office of NRR are currently involved in re-view activities for TS conformance te FSAR commitments, plant-specific as-built conditions, and operational safety considerations.

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II. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in the construction, preoperational, or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Special areas may be added to highlight significant observations.

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

i 1. Management involvement and control in assuring quality.

2. Approach to resolution of technical issues from a safety standpoint.

3. Responsiveness to NRC initiatives.

4. Enforcement history.

5. Reporting and analysis of reportable events.

i 6. Staffing (includingmanagement).

l 7. Training and qualification effe:tiveness.

l Based upon the SALP Board assessment each functional area evaluated is clas-l sified into one of three performance categories. The definitions of these performance categories are:

1 Category 1. Reduced NRC attention may be appropriate. Licensee management

attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of

performance with respect to operational safety is being achieved.

Category 2. NRC attention should be maintained at normal levels. Licensee j management attention and involvement are evident and are concerned with nuclear

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safety; licensee resources are adequate and reasonably effective so that l satisfactory performance with respect to operational safety is being achieved.

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

management attention or involvement 's acceptable and considers nuclear safety,

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

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effectively used so that minimally satisfactory performance with respect to a operational safety is being achieved.

The SALP Board also assessed each functional area to compare the licensee's i performance during the last quarter ot* the assessment period to that during

the entire period in order to determine the recent trend for each functional area. The trend categories used by the SALP Board are as follows

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Improving: Licensee performance has generally improved over the last quarter of the current SALP assessment period.

Consistent: Licensee performance has remained essentially constant over the last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last quarter of the current SALP assessment period.

Notwithstanding the allowance permitted by a Category 1 rating to reduce NRC attention, NRC oversight at Seabrook Station will be maintained at a high level if a low power license is issued. Due to the nature and scope of acti-vities conducted during low power testing and power ascension, it is NRC policy that close scrutiny be provided for the first two years of operation.

Subsequent SALP evaluation will therefore be done on a 12 month frequency ir-respective of the good performance noted in this report.

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j III. SUMMARY OF RESULTS i

! A. Overall Facility Evaluation J

During this assessment period, the licensee's overall performance re-flected not only a commitment to safety and quality construction, but also evidence of effective planning and conduct of activities directed toward fuel load and safe operations thereafter. The inspection effort

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

An evaluation of a broad spectrum of ifcensee activities was necessary because of the nature of ongoing construction completion, preoperational

testing, and operational preparedness activities. Hardware quality has

been found to be in conformance with design requirements and system in-l stallation has met licensing commitments. The preoperational test pro-1 gram has confirmed the existence of quality construction with generally

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outstanding test results and minimal number of test exceptions. In al-

most all cases, a high level of performance was achieved with evidence i of effective planning for those areas where program implementation could

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

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

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

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Regarding operational preparedness, thorough planning and a high level

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

l and procedures are very much in evidence. Licensed operator training i and the preparation and receipt of new fuel are noteworthy examples of

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the effectiveness of the licensee's programs. Also, the licensee's de-velopment of the security program represents effective management plan-ning to integrate experienced staff supervisors with a trained contract-

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security force. In summary, where operational programs have been imple-J mented, the quality exhibited during construction appears to have carried 1 over during the transition process from construction into operations.

l While licensee responsiveness to operational issues has been appropri-

! ately directed, it should be noted that these programs are still under l development. Future inspection and assessment of the full prcgram im-i plementation will provide an ongoing measure of their effectiveness.

As Seabrook Unit I now enters a new phase of program development, im-plementation, and work priorities, this overall facility evaluation should be considered both a positive reflection of past licensee per-formance, as well as an indicator of licensee potential for continued performance at a high level during the operational phase.

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B. Facility Performance CATEGORY CATEGORY LAST THIS PERIOD PERIOD (7/1/83- (1/1/85- RECENT I FUNCTIONAL AREA 12/31/84) 3/31/86) TREND *

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2 1 Consistent Preoperational Testing 1 1 Consistent Fire Protection and Housekeeping N/A 1 Consistent Operational Readiness N/A 1 Consistent Emergency Preparedness N/A 2 Improving Assurance of Quality 1 1 Consistent (See Trend at the end of Section IV.F)

Licensing 2 l' Consistent

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

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

1. Analysis i

During the previous SALP assessment period, the following functional construction areas were evaluated and rated separately: Containment,

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

Piping Systems & Supports (Category 2); Safety-Related Components-Mechanical (Category 2); Auxiliary Systems (Category 1); Electrical Equipment and Cables (Category 3); and Instrumentation (Category 2). The summary of these SALP results noted a significant improve-ment in the piping systems & supports area, but declining trends in the electrical and instrumentation areas because of apparent programmatic problems. Management attention to routine problems (e.g., housekeeping) was solicited to: (1) correct deficiencies,

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and (2) provide direction to an improvement in the trend in this area. During the previous SALP period it was also noted that posi-tive steps had been taken in the way of a project restructuring and organizational realignment to eliminate some of the interface and control difficulties which had been identified as the root cause of several problem areas.

During this current assessment period all construction disciplines have been combined under one functional area. In recognition of both the management reorganization, which started during the pre-vious SALP period, and the problems raised by the previous SALP, a Construction Team Inspection (CTI) was conducted in June, 1985 to asses. the effectiveness of the resumption of construction acti-vities under the new site organization. Particular inspection emphasis was placed upon the electrical and instrumentation areas, as well as engineering interface controls, where problems had pre-viousiy been identified. The results of this CTI (three violations, three weaknesses, and three strengths) provided no indication of programmatic deficiencies. In fact, the site management organiza-tion (i.e., the area directed by the CTI scope to be the focal point of inspection effort) was identified as a licensee program strength.

The CTI findings, when analyzed in conjunction with the enforcement data and negative observations from other construction inspections, appear to share one common attribute -- while process control, documentation, and identification failures were identified, these problems / errors did not appear to lead to an adverse impact on the hardware itself. It is noted that of the seven enforcement items grouped in this construction functional area, only one violation was found to result from deficient construction.

, This theme of hardware installation and construction in compliance with design requirements and licensing commitments appears to be

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

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As-Built Construction Team Inspection was conducted with a primary inspection focus on hardware. Vhile two severity level V violations were identified, the summary conclusion of this inspection was that Seabrook Unit I was constructed in substantial agreement with the FSAR. Additionally, an NRC independent measurements inspection of 68 weldments, utilizing the Region I Mobile Nondestructive Examina-tion (NDE) laboratory, in conjunction with a review of licensee radiographs for over 150 welds, identified no weld deficiencies or hardware problems.

The NDE van inspection in July, 1985 did document some concerns re-garding the conduct of the Preservice Inspection (PSI) program at .

Seabrook Unit 1. An unresolved item was written to track several PSI questions involving data keeping, calibration, weld surface preparation and plans for ultrasonic (UT) examination of the loop cast stainless steel (SS) elbows. Subsequent NRC inspections noted adequate licensee resolution to most of these questions. A recent, joint NRR/ Region I inspection of a demonstration of the UT technique

planned for the loop cast SS elbows revealed not only technical acceptability, but responsiveness on the part of the licensee. The basic concerns regarding the PSI program, as raised by the NDE van inspection, have since been closed, although NRC follow-up of two specific items remains.

As in the case of the PSI issue, other NRC inspections in this func-tional area have raised questions more of a program and process control nature, than of the identification of ~1mproper construction.

Such issues include the improper usage of selected revisions of ASME Code Cases, failure to implement commitments to Regulatory Guide (RG) 1.97, and the questionable adequacy of criteria for final building verification and cable tray testing qualification. For all of these items, licensee action to address the concerns has been complete and responsive.

For example, when problems were identified with the licensee adop-tien and documentation of certain ASME Code Cases, not only was a 1 project position on ASME Code Case adoption and usage announced and '

disseminated, but also a complete review of all past and present Code Case usage was initiated. Both design and procurement speci-fications were checked. Such comprehensive corrective action was followed through by the licensee even though no evidence of material or construction defects existed as a result of the identified im-proper Code Case usage. In fact, licensee completion of their in-vestigation, with subsequent NRC review, revealed the lack of any adverse hardware impact.

The status of construction during the current assessme'nt period provided sufficient opportunity for the inspection of electrical and instrumentation activities, not only because by nature such work l l

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Thirteen NRC inspections examined either in process or as-built work in these disciplines. Additionally, NRC team inspections reviewed j such activities in conjunction with the scope of the CTI objectives.

While some violations were identified, the overall findings of the NRC inspection effort into the electrical and instrumentation dis-ciplines confirmed the general effectiveness of licensee corrective measures initiated during the latter part of the previous SALP period. Analysis of all the inspection items, not just enforcement data, indicates a consistent theme of concerns with process and design control issues with no evidence that the questioned controls had resulted in incorrect construction. While some of these issues but remain open, licensee actions to address the questions appear to be pointed in the proper direction.

Similarly, an analysis of the CDRs (See Table 1) reported during this assessment period reveals no real trend of programmatic defi-ciencies in this construction functional area. NRC review of in-terim and final 10CFR50.55(e) reports, as applicable, and involve-ment in the in process troubleshooting of several of these defi-ciencies has confirmed adequate liaison with the vendors and working interfaces among engineering, constru-tion, and test personnel to expeditiously solve the known problem as well as investigate any generic impact.

Thus, in summary of the assessment of construction activities, sig-nificant NRC inspection effort has identified few hardware deft-ciencies and the licensee appears to have adequate control over their self-identified construction problems. While some concerns over process controls were noted, they appear to have received ade-quate licensee attention. One CTI near the beginning of the as-sessment period evaluated construction management and programs, while another CTI at the end of the period examined the as-built plant hardware. These team inspections, in concert with resident and specialist inspections over the course of the entire SALP period, verified implementation of a generally effective construction man-agement program with resultant evidence of quality hardware, mate-rial, components and systems.

2. Conclusion Rating: Category 1.

Trend: Consistent 3. Board Recommendation ,

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

1. Analysis During the last assessment period, preoperational test activities were just commencing. NRC review of the preoperational test pro-gram verified adequate controls and program direction. One specific

problem area was noted in that unauthorized work activities on com-ponents under the jurisdiction of the Startup Test Department (STD)

lI were identified. The licensee responded with programmatic correc-tive action. A high level of performance was maintained in this

area during the previous SALP period; however, this assessment was j based upon a limited NRC inspection effort.

l l Over the course of the current assessment period, the bulk of pre-operational testing for Seabrook Unit I was accomplished. NRC in-spections devoted effort to the witnessing of tests in progress and

, the review of approved test procedures and test results. Signifi-cant tests conducted and witnessed by the NRC during this time period i included the Reactor Coolant System (RCS) Hydrostatic test, the

Reactor Protection System test, the integrated system Hot Functional l Test (HFT), the Engineered Safety Features (ESF) and Loss of Offsite Power (LOP) tests, and the combined Structural Integrity Test (SIT)

and Containment Integrated Leak Rate Test (CILRT). It is noteworthy that all of these tests, also being major schedular milestones, were provided significant management oversight to ensure conduct in con-

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cert with schedular presssures and other construction priorities.

! Despite a situation where the pressure for progress might be per-ceived to be contrary to the quality objectives of the test program, the subject tests were performed, witnessed and reviewed with

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generally outstanding results. .

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

I tions requiring system redesign, the SIT /CILRT resulted in no test exceptions being noted and the RCS hydro identified only one RCS boundary leak (other than the expected flanged joints) in an in-strument tube. NRC questions on ESF testing have been raised with regard to valve interlocks and safety-injection "S" signal reset design, but in each case the conduct of the test was found to agree with the system design, as stated in the FSAR. Thus, the NRC con-cerns related to design, not testing, issues. Similarly, for other testing activities (e.g., diesel generator operation), the problems that have arisen provided validation of the test objective itself.

STO troubleshooting of some diesel generator air start problems 4 (identified during Phase 1 testing in 1984) ultimately led to the I discovery of an undersized diesel starting air vent line (reported

as a 10CFR50.55(e) design deficiency in 1986 (see Table 1). This issue currently remains an open NRC inspection item. Another NRC

! inspection item on the diesel generators was a concern regarding the sequence of LOCA/ LOP testing with respect to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endur-

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,,--,r.--.-m, - . , , .,,w. ,-----g , - - -er,--- -~ , - - - -,. - ,-~ - -en... .- r-,, . - - - > - - -

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ance runs of the diesels, as per Regulatory Guide 1.108. This issue was satisfactorily resolved when the licensee agreed to duplicate stable diesel generator temperature conditions (as determined by the 24-hour run test) as an initial condition to the performance of the hot LOCA/ LOP sequencing load test.

The most significant system problems identified, to date, during preoperational testing were noted during HFT. In particular, with respect to the Emergency Feedwater (EFW) system, a water hammer was experienced in the steam lines to the Terry Turbine and EFW recir-culation and flow to the steam generator problems were noted; ex-tensive system redesign was required. As was the case with other HFT problems (i.e., feedwater recirculation vibration, main steam bypass, steam dump, and steam generator blowdown exceptions), the system / component rework will be functionally retested during the startup hot functional testing, after core load, but prior to in-itial criticality. The licensee's coordination between its engi-neering, construction, and test staffs to effect the correct system redesign on the above items has been comprehensive. NRC personnel have been briefed and kept informed of all significant developments and NRC inspection relative not only to the above items, but all HFT activities resulted in no significant adverse findings.

While the HFT identified certain major items requiring retest, the remainder of the preoperational test program (i.e., Phase 2 & 3 tests) to date, represents a verification of system readiness for operations with relatively few problems. At any given time during this SALP period, as preoperational testing was conducted in accord-ance with the more than one hunored each preoperational and accept-ance test procedures, the number of open test exceptions remained below 100 in number, ,Preoperational testing has, in general, met its objectives with respect to Unit I components and systems and in fact has identified several of the construction deficiencies, reported under 10 CFR 50.55(e), listed in Table 3. The trend for the number of remaining work items, as tracked on the licensee In-complete Items List (IIL), is downward as the total items currently number less than 4000 for the first time since pre-HFT in mid-1985.

NRC inspection in this functional area has identified only one violation, although it was a repetitive item from the last SALP period involving an unauthorized work activity. Licensee corrective action has not yet been reviewed by the NRC, however, the STD record in the resolution of problems encountered to date in testing has been both comprehensive and complete. A high level of performance was found to exist in this functional area during the prior SALP period based upon limited data. During this SALP period, that high level of performance has been maintained over the course of the majority of preoperational test activities.

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This evaluation corroborates the finding of a minimal number of actual hardware problems identified in the construction area. Lic-ensee performance in this area reflects aggressive management in-volvement and serves as an impetus for and the STD to sustain such a level of testing performance as construction is completed and operations and the startup testing phase commences.

2. Conclusion Rating: Category 1.

Trend: Consistent 3. Board Recommendation None.

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

1. Analysis This area was not evaluated during the previous SALP period, al-though some housekeeping concerns were raised as they impacted the acceptability of safety-related components.

During this assessment period, a Region I team inspection was per-formed to evaluate the licensee's efforts to comply with the re-quirements of 10CFR50, Appendix R, concerning fire protection fea-tures necessary to ensure the ability to achieve and maintain safe shutdown in the event of a fire. Two Region I specialist inspec-tions into the Fire Main Loop installation and the readiness of the Fire Protection Program, particularly as it relt,ted to fuel receipt onsite, were also conducted. Additionally, routine resident in-spections have examined fireproof coating material applications, fire sealant installation, and cable separation and routing activi-ties. Housekeeping, as appropriate to the status of the Unit 1 plant conditions during construction, testing and building turnover to the plant staff, were observed during random plant inspection-tours.

Electrical separation concerns have been raised during both this and previous SALP periods. Where nonconforming conditions have been identified (e.g., less than six inch wire spacing internal to panels), the licensee had committed to corrective rework to retrain and separate the cables / wires or install barriers, as required by the applicable IEEE Standards. However, a recent licensee submittal to NRR of an " Analysis of Electrical Separation Criteria for Sea-

' brook Station" establishes the basis for the adoption of certain new separation criteria at Seabrook, as determined by analysis and testing. Thus, previous long-standing commitments for the correc-tion of electrical separation deviations need not be implemented if NRR approves the licensee proposal to relax the separation cri-teria, based upon site-specific testing. Similarly, the Region I team inspection identified two Appendix R exemptions in the areas of emergency lighting and the reactor coolant pump oil collection system. Each of these exemptions requires further NRR review to determine the acceptability of the plant design and to resolve the open inspection items.

Generally, with respect to the Appendix R team inspection at Sea-brook, both the corporate and site management were found to be ag-gressively pursuing fire protection issues to their proper resolu-tion. The licensee's fire ha:ard analysis was thorough and detailed.

The licensee has made several modifications to achieve compliance with Appendix R,Section III.G separation requirements. The licen-see also had many redundant means of achieving a plant safe shutdown in the event of a fire, including two redundant Remote Shutdown

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Panels whose adequacy was demonstrated through walkdowns of selected portions of the procedures to safely shut down the plant. Walkdowns have further demonstrated that procedures were well planned and adequate procedural training was given to the operators.

l The inspections team's conclusion was that the licensee's fire pro-taction program, when fully completed and implemented, will be ade-quate for its intended purpose. A major contributing factor is the rapport maintained by the fire protection staff and management and the increased awareness of the plant's personnel of fire protection concerns. Other NRC inspections of fire protection at Seabrook have

confirmed this conclusion, even though one apparent deviation from '

l FSAR commitments was identified. The installed Fire Loop hydrant isolation valves had not been procured as U.L. listed components,

! as was committed. The licensee, however, provided a comparison of 1 the installed valves with similar U.L.-listed valves and demon-l strated that the existing valves are acceptable for their intended

service. Another inspection item identified a discrepancy between .

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

start the fire pumps from the control room. This issue is being pursued by the licensee with the Office of NRR.

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

, (discussed in Section IV.A of this report) noted acceptable levels of site cleanliness. Resident inspections have noted that the ac-ceptability of site housekeeping appears to be dependent upon the i status of plant activities; construction areas require continual  :

j attention, buildings turned-over to the plant staff appear to be j maintained in good order, and other plant areas appear to improve i

i as the preoperational testing and turnover process progress.

The housekeeping problems raised during the past SALP appear to have

been adequately addressed by plant management. Continued attention -

to this area, as well as to the resolution of the noted fire pro-tection licensing issues with NRR, is necessary to provide a con-

, sistency to the licensee's approach to fire protection as the plant j enters operations.

2. Conclusion i

Rating: Category 1.

l Trend: Consistent.

! 3. Board Recommendation

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None.

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

i 1. Analysis J

This functional area was evaluated in the previous assessment period only from the perspective of Operator Licensing. In that area, a

, Category I rating was assessed based upon evidence of a highly com-t petent, technical training program and the resulting high pass rate of SRO/R0 candidates in their initial licensing examinations. Dur-ing the current SALP period, the functional area of Operational

,

Readiness has been expanded to include consideration of procedures j and staffing, radiological controls, and security, in addition to'

operator licensing. Analysis of each of these areas is discussed

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separately below.

t a. Procedures and Staffino During the current SALP period four separate Region I inspec-tions were conducted in such areas as plant maintenance and surveillance procedures, design change and modification con-trols, and operational QA/QC program administration and con-trols. Resident inspections have examined the plant readiness

for fuel receipt and storage, and licensee plans / implementation of their commitments to meet the TMI Action Plan requirements specified by NUREG-0737. Also, several IE Bulletins and Cir-culars, of an operational nature, sent to Seabrook Station for i

information only, were reviewed in conjunction with licensee measures to address the concerns raised by these generic docu-ments.

,

No enforcement findings or unresolved safety issues have been I

identified as a result of these operational preparedness in-

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

ment to have the Fuel Building and the appropriate fuel hand-l ling and storage systems completed and tested prior to new fuel i

i receipt ensite was noted. Scheduled fuel receipt was first delayed to allow time to meet such a commitment and subse-j quently, removal of the new fuel from the storage casks was j

further delayed to provide for additional testing of the fuel

building ventilation systems. NRC inspection of the new fuel

! - -

arrival, movement and storage revealed adequate security meas-

ures in place, the utilization of approved new fuel handling

and inspection procedures, knowledgeable operations personnel, and general compliance with the provisions of the Special Nuc-lear Materials license issued by the NRC Office of NMSS.

! NRC inspections of licensee plans for controlling specific

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

i calibration, inservice testing, material storage, records storage, procurement, safety review committees, and admini-

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strative procedures all resulted in a finding of adequate pro-gress and proper direction by the licensee operations staff i

in addressing proper quality controls and generic industry in-

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itiatives. The status of operating and emergency procedures was not amenable to inspection during this assessment period, since most procedures were still in draft form. However, it was noted that the operating personnel had utilized these pro-

, cedures, where appropriate, during the conduct of preopera-tional testing, to troubleshoot procedural problem areas.

While the development of operating procedures is dependent 4 upon Technical Specification approval, management attention

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to their program for operating procedure issuance is warranted

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to provide not only a generic site perspective on the way regulatory guidance (e.g., NUREG-0737) is to be handled, but also assurance that these procedures can be reviewed and edited J

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

In the same vein, licensee actions to demonstrate compliance with NUREG-0737 commitments have not been timely, as sufficient progress on certain TMI Action Plan requirements had not been made by the end of this assessment period. Licensee management attention was directed to this area, and since the end of the assessment period, greater progress appears evident. Continued

management responsiveness to all remaining operational pre-

paredness areas and items is necessary to assure Seabrook Unit 1 plant readiness for fuel load and operation, i

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

nonlicensed training program, and other training conducted to

!

correct or prevent problems which have arisen in the construc-

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tion and preoperational test areas. One NRC concern in the area of noniteensed training was raised in that nb matrix and

,

' comprehensive schedule of such training was yet available to demonstrate that all personnel training needs would be ful-i filled. Since the identification of that item, NRC reinspec-

, tion has found the licensee responsive to this concern and has

taken adequate action to allow closure of the open item.  ;

b. Operator Licensine During the current assessment period, two operator license ex-

' aminations were administered during the weeks of March 18, 1985 and September 30, 1985. Of the 17 senior reactor operator (SRO) and 3 reactor operator candidates examined in March, only i one SRO candidate was denied a license. All 5 senior reactor operator candidates participating in the September examination were issued licenses. This included the candidate previously

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denied a license during the March exam.

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i l j The licensee began its first replacement operator training

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

and 5 senior reactor operator candidates is presently scheduled !

l for a July 1987 operator license examination.

i j In addition to operator training, the licensee has demonstrated

! a strong commitment to the enhancement of the simulator's

! operational capabilities. A new modern high speed computer

is being installed to improve system response time and fidelity and to provide a larger storage capacity.

The simulator malfunction list provided for the March 1985 ex-amination contained several malfunctions with only a cursory description. The licensee was informed of this weakness at

the March 1985 operator license examination exit meeting. This i same weakness was again identified during the September 1985 i examination. It continued to make the development of quality i simulator scenarios difficult for operator license examination j purposes.

l The first group of cold license candidates was examined in

September, 1984. These operators and those that closely fol-1 lowed will be scheduled for renewal near the proposed time of j fuel load and the follow-on startup test program. Based on this and the fact that none of the operators will have been able to make " active use" of their licenses during the previous ;

two years, the NRC staff has begun ~ selective monitoring of the licensed operator requalification training program. This pro-gram was implemented immediately after the last cold license training class ended. To date, the licensee has demonstrated a strong commitment to quality requalification training that

, not only addresses the operator's need for skill and knowledge i reinforcement, but also identifies unique areas of specialized l training that are required in preparation for the upcoming '

startup test program. The licensed operator requalification j training program at Seabrook is considered an additional j

'

strength in the already strong operator licensing training !

program.

{

r With respect to licensed operator training and qualification !

at Seabrook, the licensee continues to devote substantial re- l 1 sources _to the training program. The licensee training staff i l appears to be both technically competent and professional, i i

Responsiveness on the part of the licensee to suggestions to I improve training has been evident. i t

c. Security l

Three preoperational security program reviews were performed I

during the assessment period by region-based inspectors. Rou-i tine resident inspections continued throughout the assessment i l period.

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l The effectiveness of the licensee's planning for the security l program was evident from the first preoperational review. De-I velopment of the security program was on schedule and station

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administrative proceJures pertaining to plant security and security program irplementing procedures had been prepared and approved for use. Management attention was evident from the selection of personnel and the organization of key staff post-tions. The station security organization is directed by an experienced Security Program Manager, assisted by a Site Security Supervisor. Four experienced functional supervisors are assigned to provide guidance and coordination in developing and implementing the program. Early establishment of these program featuras enabled the regional inspectors to conduct an in-depth analysis of the Physical Security Plan, Training and Qualification Plan and Security Contingency Plan even be-fore the receipt of new fuel on site. It also enabled the NRC's Office of Nuclear Material Safety and Safeguards to com-plete its plan reviews and an onsite program review expedi-tiously and with a minimum of effort. The experience and pro-fessional attitude of the licensee security management and staff were evident.

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

With the receipt of fuel on site in February 1986, the resident inspectors routinely checked security controls for the fuel building where the new fuel assemblies are being stored. Also, while not part of the Seabrook physical security program to be implemented during operation, security controls of various areas of the plant where preoperational testing activities were in progress were inspected to confirm compliance with proce-dural requirements and preoperational test assurance controls.

These NRC inspections revealed that the appropriate program-matic security controls were being properly implemented.

Licensee management and security supervisors have provided a workable system for allowing NRC inspectors "immediate unfet-tered" access to Seabrook Station for inspection purposes and are developing plans for badging and access provisions for NRC personnel to facilitate future NRC inspections when the Sea-brook Physical Security Plan is implemented. While NRC in-spection effort during this SALP period cannot provide a com- i plete assessment of the licensee's security controls, both the

, lack of significant problem areas and management responsiveness l to security issues provide evidence of properly directed lic-ensee efforts in this area. Since the Physical Security Plan

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will be implemented for Seabrook Unit 1 in sufficient time prior to planned fuel load for the licensee to identify problem areas, management attention to security controls should be focused in such a way as to address corrective measures, where required.

d. Radiological Controls During the latter part of this assessment period, three in '

spections were conducted by region-based radiation specialists into the following areas: readiness for preoperational inspec-tions in radiation protection, radioactive waste management, transportation, and effluent control and monitoring; prepara-tion for initial fuel receipt; initial fuel receipt; and, radiation protection.

During this assessment period, the radiological controls de-partment was involved in the management control system via the

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station operation review committee (SORC), radiation safety committee (RSC-ALARA), and frequent routine management meetings.

All interfaces between the health physics (HP), radioactive waste, chemistry, instrumentation and control, and training had not been fully defined and documented. Corporate responsi-bility for appraisal of the radiation protection prcgram was not clearly stated with regard to scope and frequency. Plan-ning and scheduling appeared adequate in that licensee provided readiness dates for preoperational inspections generally re-mained unchanged during the inspection period.

General employee and radiation worker training programs were in progress. While supplemental health physics training for self-monitoring had not yet been fully defined, active planning in this area was apparent from discussions with the licensee.

The Quality Assurance organization has initiated their sur-veillance program and plans to audit the radiation protection program on an annual basis, which exceeds standard requirements for audit frequency. The external personnel dosimetry system received NAVLAP certification during this inspection period.

Acceptable quantitative ALARA goals have been established.

While procedural deficiencies in ALARA procedures were identi-fied, the HP staff committed to resolve them by fuel load.

Satisfactory changes to the ALARA procedures were initiated.

One revision has completed the licensee's review and approval process while the other is currently going through this step.

The fact that considerable responsibility for implementing ALARA principles had been placed with job supervisors was ex-i

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

ALARA training for job supervisors and upper level management '

had already been recognized by the licensee.

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F Adequate management control systems are in place in the area of HP. There is an adequate number of supervisory and profes-sional staff possessing acceptable educational and experience credentials. A simulated fuel receipt was conducted prior to the initial fuel receipt in February 1986. Approximately fifty percent of the radiation protection technicians are on hand; the majority of the technicians present are fully qualified by experience; the site-specific training and qualification manual process is being implemented.

Dosimetry procedures were found to be adequate, but not com-prehensive. However, this was compensated by a strong training -

program in the dosimetry area. One deficiency in the radiation work permit procedures was noted, and the licensee has imple-mented an approved revision which corrected the deficiency.

Procedures for fuel receipt and the posting and controlling of a radiologically-controlled area (RCA) were found to have been effectively used. Recordkeeping was adequate, but docu-mentation of the dose assessment methodology was found to re-quire additional licensee attention. Subsequently, the licen-see remedied this NRC concern about dose assessment methodology documentation. Additional data is required to support the beta dosimetry methodology and is presently being developed by the licensee.

A whole-body-counting program is available and in use. A real-time computer-based personnel training and dosimetry record-i

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keeping system is being utilized. During this inspecticn period, additional portable survey mete s, respirators, and air samplers have been added to the licensee's equipment stores, while even more equipment is on order. However, testing and turnover of certain systems to the station staff is not yet complete.

While the radioactive waste (RW) management, transportation, and effluent control and monitoring areas did not receive de-tailed inspections during this assessment period, NRC inspec-tors did review the organizational reporting lines and responsi-bilities and did interview responsible supervisors in these disciplines. The laboratory facilities were observed to be spacious, well kept, and well equipped. Emphasis on multiple levels of quality control was apparent from discussions with chemistry personnel. It was noted that RW supervisory and technician staffing is almost complete and that health physics training to be provided to radioactive waste handling personnel is being developed.

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Several new fuel shipments have been received, and adequate radiological controls and attention to DOT regulations were observed. Work controls were demonstrated to be effective for fuel receipt and for controlling and posting of RCAs. The planned operational survey and monitoring program is acceptable.

The operational readiness of the four radiological controls areas (radiation protection, waste management, transportation and effluent control and monitoring) in regard to organization and management controls, staffing and training, work controls and procedures, and facilities and equipment exceeds what would be routinely found at a plant like Seabrook Station Unit 1 at this preoperational stage. Since radiological controls func-tions have not yet been adequately challenged by operational requirements, a full assessment cannot be made at this time.

However, based upon supervisory awareness of the problem areas and what still needs to be accomplished, the Radiological Con-trols Program appears to be heading on a proper course. This positive trend should continue, provided that the management commitment, the degree of preplanning and preparation, and the attention to detail remain at the same level that has been demonstrated up to this point.

2. Conclusion Rating: Category 1.

Trend: Consistent.

3. Board Recommendation A normal level of inspection activity on part of the NRC shall be maintained during the next SALp assessment period due to the pre-operational nature of the findings in this area.

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

1. Analysis This functional area was not evaluated during the previous SALP.

During this assessment interval, New Hampshire Yankee (NHY) has placed considerable emphasis on the area of emergency preparedness as they have approached their projected fuel load date. Two NRC team inspections were conducted to perform the NTOL Emergency Pre-paredness Implementation Appraisal (EPIA), and a third inspection was conducted to evaluate licensee performance during a full parti-cipation exercise.

The emergency preparedness function is controlled by a corporate staff that is located at the site. This staff maintains a close liaison with the site organization. The organization and staffing is ample, principally consisting of a Director of Emergency Planning, a Radiological Assessment Manager, an Emergency Preparedness Super-visor, and two Senior Emergency Planners. The position of Director of Emergency Planning is temporarily filled by a contract consultant.

Installation of equipment and training of personnel to fulfill their emergency response organization functions is ongoing but has been substantially completed based on observations made during the two appraisal inspections and the exercise. The EPIA was begun during December, 1985, based on the applicant's firm judgement that they had reached a condition in which the emergency preparedness program could be adequately evaluated. However, the appraisal had to be terminated prior ta completion because equipment, training, and procedures had no. )een sufficiently completed to assess the EP program. This appeared to be indicative of inadequate planning on the part of the licensee. Sufficient progress had been made by February,1986 so that the first full-scale exercise was conducted on February 26 and the appraisal was completed on March 28, 1986.

The principal concerns identified during the appraisal are a lack of sufficient numbers of qualified individuo's to fill the key emergency response organization positions during an emergency on a twenty-four hour basis (presently only a primary and one alternate are qualified) and lack of on-shift dose assessment capability.

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

key EP position prior to issuance of a full power license and to provide shift personnel with a programmed calculator to meet the requirement to perform dose assessment at two, five, and ten miles, prior to the arrival of the augmentation emergency response staff.

The exercise on February 26, 1986 involved the utility and the state of New Hampshire, as the Commonwealth of Massachusetts Emergency

, Plans had not yet been submitted for review by FEMA. No major on-l site deficiencies in the implementation of an adequate emergency l response were identified during the exercise. In general, personnel )

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F involved in the exercise demonstrated a high level of training and knowledge of their response functions. Assessment of plant condi-tions and recommendations of protective actions for the public were timely and conservative. The EOF is of adequate size and functioned effectively with both the state of New Hampshire and a response team from NRC Region I participating in the exercise. Several deficien-cies were identified by FEMA with offsite response by New Hampshire.

These areas will be reassessed in a subsequent exercise prior to consideration of a full power license. That exercise is also ex-pected to include participation by Massachusetts.

There has been excellent cooperation on the part of NHY with the NRC on the resolution of issues concerning the Emergency Plan and procedures.

2. Conclusion

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Rating: Category 2.

Trend: Improving.

3. Board Recommencation Continued licensee attention to EP issues and to the resolution of the open items resulting from both the EPIA and the emergency exer-cise is warranted.

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9 F. Assurance of Quality

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1. Analysis During the previous SALP period, " Quality Programs" was assessed a Category I rating based primarily upon the strong and stabilizing

, influence that the QA program at Seabrook has had upcn project and construction controls. During this period, quality program effec-tiveness has been assessed by both resident and specialist inspec-tors. Various aspects of this functional area have been considered and discussed, as appropriate, as integral evaluation criteria in other functional areas and the respective inspection hours are in-cluded in each one. It is noted that management involvement in as-suring quality is one attribute that is considered in the assessment of licensee performance for all areas. Consequently, this area is a synopsis of these discussions relating to the quality of work, and management's role in assuring it.

An NRC team inspection (the first CTI discussed in Section IV.A of this report) dedicated significant inspection resources to licensee ,

management programs and quality assurance. Two of the licensee strengths documented in that inspection were attributed to Site Management and Quality Assurance. New Hampshire Yankee (NHY) man-agement was recognized for both its positive management support of quality and the establishement of new programs and directives (e.g.,

the Independent Review Team, the Employee Allegation Resolution program, the Piping and Pipe Support Closecut Task Team, and the reorganization of site engineering under one director). The site QA function was cited as a strength because of the implementation of effective audit and trending programs and for its responsiveness in initiating comprehensive corrective actions.

A review of the enforcement data in Table 3, reveals that of the four violations attributed to this functional area, two involved improper handling of Nonconformance Report (NCR) dispositions and i two involved incomplete follow-up of corrective action on Construc-tion Deficiency Reports. Thus, in all four cases, the site QA pro-gram was instrumental in finding the subject problems, but licensee measures were not sufficiently complete to assure proper correc-tion / repair of the identified problems. These examples represent somewhat of a continuing negative theme from the last SALP where licensee correspondence to the NRC on CDRs and enforcement actions was found at times to be incomplete and corrective repair / rework was not always timely.

l As was discussed in the CTI as a strength, the initiation of cor-l rective action at Seabrook appears to be well directed. However, the total assurance of quality depends upon every licensee employee, and particularly upon supervisory level responsiveness to the prob-lems. If corrective measures are not followed through in the same

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comprehensive vein as the inspection program that first identified the items, the results are continuing problems and, as was noted in the preoperational test area (Section IV.8), recurrent enforce-ment findings. Management attention to this concern is warranted as new operational programs are developed and different technical areas come under inspection.

Despite the examples of corrective action problems, noted above, i

NRC inspections have generally identified a minimal number of prob-lems, particularly in the hardware area. This was substantiated by the as-built team inspection (CTI) conducted at the end of this assessment period (March, 1986). Management reinforcement of qual-ity objectives is evident not only in the support of the QA program, but also in first-line craft and supervisor training and in project

, policy statements routinely issued by the construction manager to prevent individual problems from becoming generic issues.

A "Startup Quality Assurance Interface Agreement" between the con-struction and operations QA program staffs, and with the concurrence of the station manager and the startup test department manager, has been implemented. This Seabrook QA policy defir.es various organi-zational responsibilities and scopes the role of the Operational QA Program from the time of Conditional Acceptance Turnover (CAT)

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

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

the basis for such a QA policy appears to be well thought out and j should provide the necessary direction for the further implementa-

t tion of QA controls as the transition into operations continues.

NRC specialist inspections into the operational preparedness phase of the Seabrook QA program have identified no substantive weaknesses.

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Licensee QA interface controls for design changes, maintenance, procurement, and testing activities appear to be working as addi-

, tional components and systems achieve CAT status. Licensee attempts

! to achieve some measure of practice in the implementation of such l controls, by initiating the program first for nonsafety-related

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equipment, have successfully identified some problem areas requiring

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program revision.

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

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

i grammatic controls that assure quality appear well directed. The licensee's initiation of an FSAR Consistency Review has provided programmatic response to previous NRC concerns regarding errors in

.the FSAR and has established a better basis for the continued de-velopment of test criteria and operational proedures. Other man- .

agement initiatives, like the establishment of a site licensing  !

office and a site organizational restructuring, have provided a better framework for responding to NRC concerns and other quality l

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

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an effective QA program has been and is in place at Seabrook Station and continued management support continues to provide the necessary assurance of quality.

2. Conclusion Rating: Category 1.

Trend: Consistent. Such a consistent trend recognizes continued management attention to quality programs during the transition phases of the Seabrook project from construc-tion to preoperational testing and on to operational '

readiness.

3. Board Recommendation None.

.

- - - , -

,,,- - : ~

,...n_,_, . , ,,, ,- e

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

. .

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G. Licensing 1. Analysis During the last assessment period, the licensee's overall perform-ance in the plant licensing area was considered satisfactory and improving with evidence of licensee management attention and in-volvement.

During this current SALP period, the basis for this analysis was the licensee's performance in support of the following licensing actions, which were either completed or active during the current assessment period:

--

fire protection

--

vibration of diesel generator instrumentation

--

containment systems

--

materials engineering

--

emergency preparedness

--

instrumentation and controls

--

detailed control room design review

--

electric power systems

--

environmental qualification of electric equipment

--

seismic and dynamic qualification of mechanical & electrical equipment

--

licensed operator requalification

--

safety parameter display system

--

technical specifications During the latter half of calendar year 1985, licensing actions on the part of the licensee began to pick up considerably. This clearly was necessary because a number of SER outstanding issues needed re-solution. During this SALP reporting period licensee's management involvement in licensing actions improved significantly. The lic-entee's management has been accessibla and available to assure that necessary corporate decisions are arrived at to bring about resolu-tion of NRC concerns. Of particular note is the licensee's manage- l ment involvement in the Seabrook proposed Technical Specification (TS) improvement program. The staff has determined that many of the objectives in the licensee's TS improvement program coincide t with those of the NRC program to improve TS. The licensee's effort '

in this area has been sizable and represents a commendable reflec-tion of licensee management's involvement and commitment to this program.

It is noted that the licensee has dedicated substanital resources to the development of appropriate Technical Specifications (TS) for Seabrook Unit 1. With the issuance of the " Proof and Review" edi-tion of TS in March 1986, the licensee has initiated a substantive ,

!

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

l l

l

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f

-

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i

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design precautions, limits, and setpoint data. This demonstrates good initiative on the part of the licensee to determine and provide objective evidence that the plant can be safely operated as licensed.

As noted in the previous SALP report, the licensee's management has established an office in Bethesda, Maryland to provide ready atten-tion to NRC concerns. This has continued during the current evalu-ation period.

The licensee generally demonstrated an understanding of issues dur-ing meetings and discussions with the NRC staff and in its submit-tais to the staff. The licensee generally exhibits conservatism where the potential for cafety significance exists. The approach to resolution of technical issues is viable and generally sound and thorough. The licensee was willing to perform additional studies as necessary to resolve technical issues. Generally, when the NRC and the licensee held differing technical positions, the licensee provided a sound basis for his position. Some exceptions occurred in the containment systems, control room design portion and safety parameter display system portion of the safety review. In these cases, the licensee was slow in demonstrating a clear understanding of the issues. However, once the licensee began to understand the problems, the staff received acceptable responses.

Positions within the licensee's organization are identified and authorities and responsibilities are defined. The licensee's lic-ensing and engineering groups appear to be adequately staffed as indicated by representatives who have attended numerous review meetings. Generally, sufficient technical staff are participating in review meetings to effect resolution of open items. The licen-see's licensing staff has demonstrated a much needed cooperativeness in resolving difficult issues. Staffing at the Seabrook Unit 1 plant appears adequate for the status of the plant as it prepares for operation.

The licensee is responsive to a majority of NRC concerns and has taken the initiative to resolve issues by requesti'ng conference calls and meetings and has then followed up with responsive submit-tals. In general, responses have been technically sound and ad-dressed NRC concerns in a professional manner. The licensee pro-vided effective licensing liaisons between their technical staff and NRR. Except for certain of the technical issues noted above, licensee responses have been timely.

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

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

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9 2. Conclusion Rating: Category 1.

Trend: Consistent 3. Board Recommendations None.

.

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

..

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V. SUPPORTING DATA AND SUMMARIES A. Construction Deficiency Reports (CDRs)

Twenty-four CDRs were reported by the licensee during the assessment period. Of this total, five potential deficiencies were subsequently withdrawn by the licensee with NRC inspection confirming the validity of the licensee analysis and resultant cancellation. All reported de-

' ficiencies are listed in Table 1 and were evaluated and discussed, as appropriate, in the affected functional area.

While analysis of the listed CDRs for causal linkage has identified no unacceptable chains per statistical acceptance criteria, it was noted that seven of the ten deficiencies analyzed as vendor problems were re-lated to the electrical discipline. This appears to be consistent not only with CDR data from the previous SALP period where eight of a total 22 CDRs were caused by vendor problems in electrical components, but also with other NT0L plant data where electrical component deficiencies are more numerous than those reported in other disciplines. Both the status of construction progress and the nature of preoperational testing acti-vities as the plant approaches operations, tend to identify and accentu-

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

!

grammatic problem with electrical CDRs and no additional corrective measu~es, other than those taken to correct the individual deficiencies, are believed necessary since no generic electrical problem appears to j exist.

,B. Investications and Allegations Review

,

During this assessment period five allegations were received, only one i

of which is open with an investigation by the NRC Office of Investiga-tions currently in progress. The other four allegations were inspected

and closed with no sLbstantive negative findings resulting from the NRC follow-up of the stated concerns.

i Additionally, the investigation / inspection of five allegations reported during previo0s SALP periods were completed during this assessment period.

Four of these allegations were unsubstantiated, while NRC follow-up of the fith revealed that the licensee had identified the problem and re-ported it under the provisions of 10 CFR 50.55(e). NRC inspection of i the resulting CDR confirmed adequate licensee corrective action and meas-

! ures taken to prevent recurrence of the problem. ,

j Early in this assessment period, the licensee established the Employee

'

Allegation Resolution (EAR) program at Seabrook Station to investigate, track and respond to allegations / concerns brought to their attention.

NRC interface with the EAR program has provided both an independent verification of programmatic actions taken by the licensee to address

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

', spection resources without compromising the conduct or results of the t

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

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

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i NRC investigation. In three specific cases, the EAR program was called upon to investigate and respond to allegations received by the NRC. All three allegations have been closed with no substantive findings and with independent NRC' inspection corroborating both the EAR investigation re- i sults, and the implementation of corrective measures to avoid similar '

problematic situations in the future. ,

!

C. Escalated Enforcement Action None.

D. Management Conferences j March 21,1985 - a special, announced management meeting at NRC re-  !

1.

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

to evaluate licensee performance from July 1,1983 to December 31, j 1984.

'

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

! NRC/ Licensee agreement to discuss the Seabrook project status and i schedule and to review licensee initiatives in the areas of the

, Employee Allegation Resolution (EAR) program, an FSAR consistency j review, and establishment of a site licensing office, i '

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

'

1 NRC/ Licensee agreement to discuss the Seabrook Staion cable tray J

design and seismic tray testing in progress, intended to qualify l extensive bracing redesign.

I 4. October 16,1985 - a special, announced management meeting upon mutual NRC/ Licensee agreement to discuss the project construction, licens-j ing and state regulatory hearing status and emergency planning

'

schedules.

I i E. Licensing Activities i

l 1. NRR Site Visits, Audits and Management Meetings

, The following listing represents those subject areas where the NRR

'

personnel have visited Seabrook Station for the purpose of conduct-ing activities related to Unit I licensing. A significant number of meetings were also conducted between the applicant and NRR per-

'

, sonnel with meeting notices and summaries documenting the discussion topics, as applicable.  ;

i --

Cable Tray Support Qualification i

--

Caseload Forecast Panel 1

! --

Emergency Preparedness  !

--

Envirenmental Qualification of Equipment

--

Fire Protection / Safe Shutdown

)

,

, - - n--. .-.--,---v-,,.n. -m . - ~ . - , -.-- --- - ,,-- ,,,.,,,,_.,-,--,-n,- ,n ,- , ,., - - _ - - ,.m, .,- . . . , - - . .

. - - - - - . . - - .v,

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Power Systems Review

--

Pump and Valve Operability Review Team

--

Security

--

Seismic Qualification Review Team

--

Tecnnical Specification Review Also, on September 27, 1985, the Director of the Office of NRR met with applicant representatives at Seabrook Station to discuss the project status and tour the plant to observe Unit I construction progress.

2. Licensing Documents .

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The following listing represents the documents issued, to date, by NRR as part of the Operating License review for Seabrook Unit 1.

--

Final Environmental Statement (FES) - December,1982

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Safety Evaluation Report (SER) - March, 1983

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SER (Supplement 1) - April, 1983

--

SER (Supplement 2) - June, 1983

--

SER (Supplement 3) - July,1985

--

Technical Specifications (" Proof and Review" edition) - March, 1986

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TABLE 1 CONSTRUCTION DEFICIENCY REPORTS (1/1/85 - 3/31/86)

SEABROCK STATION CDR NUMBER DEFICIENCY CAUSE CODE 85-00-01 Failure of Gould molded case circuit breakers to B

, pass trip test

!

85-00-02* Missing cation bed demineralizer radiography A 85-00-03* Reduced discharge head for the service water C pumps 85-00-04 Lining problem in the Airflex' instrument air 0 hoses

,

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

"

on SI valves 85-00-06 Brown-Boveri circuit breaker switch wiring damage B j 85-00-07 Questionable HVAC heat load design calculations E 85-00-08* Incompatible grease in fan motor bearings A 85-00-09 Inadequate spacing between battery cells and rack B

<

85-00-10 Logic deficiency in the EFW high flow isolation E signal 85-00-11 Incorrect time delay links in circuit breaker over- B current trip devices

,

85-00-12* Georgia Tech STRUDL computer program error E

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

,

and valves 85-00-14 Excessive leakage in nitrogen gas supply contain- B ment isolation valves 85-00-15 Salt water spill from the service water system in A the water system in the auxiliary building i

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

)

!

!

I

__ __. _ . _ _ _ . _ . . _

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

_ - _ _ _ _ _ _ _

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T-1-2

.

CDR NUMBER DEFICIENCY CAUSE CODE 85-00-17 Binding of contacts in Gould motor control B starters 85-00-18 Disc malfunctions in Dresser valves used in gas B systems 85-00-19 Misapplication of Type MDR relays in the solid B state protection system 85-00-20 Failure of HVAC air dampers to close under certain C air flow conditions 85-00-21 Improper terminal boards used in the uninterruptible B power supply inverters 86-00-01 Design deficiency in undersizing the diesel genera- E ter air vent line 86-00-02 Pressurizer pressure transmitter drift in excess of C design basis 86-00-03 Impact of a P-10 permissive malfunction on protec- E tive system functions Cause Codes A-Personne)/ProcedureError 0 - Construction Error 8 - Vendor Problem E - Design Error C - Component Failure

• Reported by the licensee as a potential CDR and subsequently cancelled. Basis for nonreportability was reviewed by NRC and item is considered closed.

. _ . . __ ._

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TABLE 2 INSPECTION HOURS SUMMARY (1/1/85 - 3/31/86)

SEABROOK STATION FUNCTIONAL AREA HOURS % OF TIME A. Construction 3788 48 B. Preoperational Testing 2451 31 C. Fire Protection and Housekeeping 296 4 D. Operational Readiness 743 9 E. Emergency Preparedness 634 8 F. Assurance of Quality -* --

G. Licensing -* --

TOTALS 7912 IUD

• Hours expended in these activities are either included in other functional areas or considered not to be direct inspection effort.

NOTE: Additionally, a total of 12 inspection hours were expended during this as-sessment period in the review of preservation, protection and prevent 1tive

maintenance activities, for Seabrook Unit 2 (a plant still in an indeter-minate status).

.

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TABLE 3 -

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

SEABROOK STATION A. Number and Severity Level of Violations Severity Level I -

Severity Level II -

Severity Level III - 0 Severity Level IV -

, Severity Level V -

Deviation -

TOTAL T3-

.

B. Violations vs. Functional Area IV V DEV.

A. Construction 4 2 1 B. Preoperational Testing 1

- -

C. Fire Protection and Housekeeping 1 -

D. Operational Readiness - - -

E. Emergency Preparedness - - -

F. Assurance of Quality 4 - -

G. Licensing - - -

TOTALS * 10 2 2

_

• NOTE: The total number of Severity Level IV violations listed vs. functional area is one greater than the total issued (ie: Section A above). This occurred because of the issuance in the 86-14 inspection report of a single violation containing multiple findings, each in a different functional area.

- . - - - - - - + - ,

_

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. *

T-3-2

,

C. Listing of Violations SEVERITY FUNCTIONAL rep 0RT SUBJECT LEVEL AREA Failure to translate flow restrictor IV A 85-01 sizing tolerances into the design details 85-01 Failure to document and track noncon- IV F forming conditions for all affected components 85-03 Failure to attach required nameplates V A to safety-related equipment 85-06 Failure to install UL approved valves in DEV. C the fire protection water supply system 85-15 Failure to control design / construction IV A interfaces with regard to pipe support installation 85-15 Failure to detail installation criteria IV A for instrument tubing crossing siesmic -

boundaries 85-15 Incorrect dispositioning of nonconform- IV F ance reports on instrument tubing 85-20 Failure to implement complete corrective IV F action on identified component pedestal cracking problems 85-20 Failure to control a design change and IV F implement adequate corrective action on valve bracket rework 85-25 Failure to comply with commitments to DEV. A to NRC Regulatory Guide 1.97 86-12 Failure to translate an enclosure build- IV A ing ventilation design requirement into the construction details 86-14 Failure to follow procedures in fire IV B/C sealant and preoperational testing activities 86-14 Failue to adequately control component V A identification

. _ . .