IR 05000443/1986099

SALP Rept 50-443/86-99 for Jan 1985 - Mar 1986

ML20198R787
Person / Time
Site:	Seabrook
Issue date:	06/05/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198R772	List: ML20198R771 ML20198R787
References
50-443-86-99, NUDOCS 8606100210
Download: ML20198R787 (42)

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U.S. NUCLEAR REGULATORY COMMISSION

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:

MAY 14, 1986 8606100210 860605 3 ADOCK 0500 gDR t

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l SUMMARY TABLE 3 - ENFORCEMENT DATA i

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l l INTRODUCTION 1 Purpose and Overview l l

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

" 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:

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, ORP (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)

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")

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

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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%

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 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 hours0.0733 days <br />1.758 hours <br />0.0105 weeks <br />0.00241 months <br /> 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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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

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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:

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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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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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 *

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

Licensing 2 1 Consistent

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

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t IV. PERFORMANCE ANALYSIS Construction (3788 hours0.0438 days <br />1.052 hours <br />0.00626 weeks <br />0.00144 months <br />, 48%) Analysis During the previous SALP assessment period, the following functional construction areas were evaluated and rated separately: Containment,

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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 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  :

of several problem area '

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-

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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-

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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.

, The CTI findings, when analyzed in conjunction with the enforcement

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data and negative observations from other construction inspections, appear to share one common attribute -- while process control, documentation, and identification failures were identified, these

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, 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 i

was found to result from deficient construction.

, 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

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As-Built Construction Team Inspection was conducted with a primary ,

inspection focus on hardware. While two severity level V violations

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were identified, the summary conclusion of this inspection was that

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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-

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tion and documentation of certain ASME Code Cases, not only was a

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project position on ASME Code Case adoption and usage announced and disseminated, but also a complete review of all past and present

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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 "

The status of construction during the current assessment period

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provided sufficient opportunity for the inspection of electrical and instrumentation activities, not only because by nature such work

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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

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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

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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,

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verified implementation of a generally effective construction man-agement program with resultant evidence of quality hardware, mate-

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2. Conclusion Rating: Category Trend: Consistent 3. Board Recommendation Non ,

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

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

included the Reactor Coolant System (RCS) Hydrostatic test, the Reactor Protection System test, the integrated system Hot Functional

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

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

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

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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

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(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 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endur-

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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 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

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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 .

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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 commence . Conclusion Rating: Category Trend: Consistent 3. Board Recommendation Non _

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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%) 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

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, Panels whose adequacy was demonstrated through walkdowns of selected

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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

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

maintained in good order, and other plant areas appear to improve as the preoperational testing and turnover process progress.

l 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

,

enters operation . Conclusion Rating: Category Trend: Consistent.

4 Board Recommendation Non .. _ -

.- --

. - . _ __

- .

.

.

, D. Operational Readiness (743 hours0.0086 days <br />0.206 hours <br />0.00123 weeks <br />2.827115e-4 months <br />, 9%) Analysis 5 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-petent, technical training program and the resulting high pass rate

.

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-

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

.

.-

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.

l b. Operator Licensing

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

.

.

.

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

. Three preoperational security program reviews were performed i

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

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

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

,

1 s

.

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

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-

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 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

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

.

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

'

, are developing plans for badging and access provisions for NRC personnel to facilitate future NRC inspections when the Sea-

.

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

!

!

- _

.

.

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 .

.

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;

'

the majority of the technicians present are fully qualified

,

by experience; the site-specific training and qualification manual process is being implemente 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 ,

i work permit procedures was noted, and the licensee has imple-

} 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-

! quire additional licensee attention. Subsequently, the licen-

'

'

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.

> 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.

i

! While the radioactive waste (RW) management, transportation, I and effluent control and monitoring areas did not receive de-j

'

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

, . - , ,,m--- - - - - - - - - - - - - . - , , . , - - - - - - - - - - - - - - - - - - , - ,,--- - -

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

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

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.

l

'

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 i 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 l de,onstrated up to this point.

i Conclusion

,

Rating: Category .

Trend: Consistent.

Board Recommendation ,

)

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.

t

!

!

i

..

!

I

!

,

f I

i

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

.

.

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

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

.

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

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

!,

. _ . _ - - - - _ _ _

e

.

i 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 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

! assessment period (March, 1986). Management reinforcement of qual-

) 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 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

!

'

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-

{ 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 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

! 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

t s - - - - - -m,.-1.-- y w-. ,..r_ --y__..~,,___w- -

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

--

.

.

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

. .

,

n a j 30

!

i t

' Licensing Analysis j

'

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-

.

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

'

'

--

vibration of diesel generator instrumentation

--

containment systems

--

materials engineering

--

emergency preparedness

--

instrumentation and controls

,

--

detailed control room design review j --

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 l 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-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 ,

,

It is noted that the licensee has dedicated substanital resources

!

i 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 1936, the licensee has initiated a substantive I review process to correlate the TS to FSAR commitments and current

]

<

J

.

. . -- _

--- - - . _ . - --

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

[.

f

.

i

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design precautions, limits, and setpoint data. This demonstrates l 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 perio .

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

'

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

'

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

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

-

O e

2. Conclusion Rating: Category Trend: Consistent 3. Board Recommendations Non + --___- - - _ J

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

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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

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Caseload Forecast Panel

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Emergency Preparedness

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Environmental Qualification of Equipment

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Fire Protection / Safe Shutdown

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o

,

a

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Power Systems Review

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Pump and Valve Operability Review Team

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Security

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Seismic Qualification Review Team

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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

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Safety Evaluation Report (SER) - March,1983

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SER (Supplement 1) - April, 1983

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SER (Supplement 2) - June,1983

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SER (Supplement 3) - July,1985

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

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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

'

D on SI valves 85-0G-06 Brown-Boveri circuit breaker switch wiring damage B

'

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

~

85-00-12* Georg , Teu - RUDL computer program erro "

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

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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)

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 -* --

G. Licensing -* --

TOTALS 7912 100

• 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 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

- -

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 are i l

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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