IR 05000443/1988007

Insp Rept 50-443/88-07 on 880524-0705.No Violations Noted. Major Areas Inspected:Routine Plant Operations,Maint & Surveillance Activities,Physical Security & Licensee Potentially Reportable Occurrences & Operational Events

ML20207B341
Person / Time
Site:	Seabrook
Issue date:	07/29/1988
From:	Haverkamp D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207B318	List: IR 05000443/1988007 ML20207B313
References
50-443-88-07, 50-443-88-7, NUDOCS 8808020306
Download: ML20207B341 (17)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-07 Docket N License N NPF 56 Permit N CPPR-135 Licensee: Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03106 Facility Name: Seabrook Station, Unit N Inspection At: Seabrook, New Hampshire Inspection Conducted: May 24 - July 5, 1988 Inspectors: A. C. Cerne, Senior Resident Inspector, Seabrook Station D. G. Ruscitto, Resident Inspector, Seabrook Station E. H. Gray, Senior Reactor Engineer, Materials and Processes Section, Engineering Branch, Division of Reactor Safety, Regio I Approved By: ~ / mI/ / / 4' 7/b/sf Donald R7 Haverkamp, Chief, Rea& tor Projects Date Section No.3C Inspection Summary: Inspection on May 23 - July 5, 1988 (Report N /Y3-07)

Areas Inspected: Routine inspection by two resident inspectors and one specialist inspector of actions on previous inspection findings; routine plant operations, maintenance and surveillance activities; physical security; licensee potentially reportable occurrences and operational events. Followup of licensee activities in response to NRC Generic Letters, an Information ,

c Notice and a Bulletin was also conducted, as was a followup of certain alle-

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gations and concern Results: Significant licensee resources were expended in closing out the open item on the service water picing corrosion. Routine monitoring of this system will be ongoing in accordance with the licensee's action pla No violations were identifie !

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TABLE OF CONTENTS Page 1. Persons Contacted.................................................... 1 2. Summary of Facility and NRC Activities............................... I Resident Inspector Activities................................... 1 Vi si ti ng In specto r Acti vi ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Plant Status......................................... .......... 2 3. Operational Safety (71707)........................................... 2 4. License Action on Previous Inspection Findings (92701)............... 3 Unresolved Item 86-43-01: Cable Tray Seismic Adequicy........... 3 Inspector Follow-up Item 88-02-02: Service Water Piping Corrosion..................................................... 4 5. Licensee Event Report 88-002 (92700)................................. 5 6. NRC Bulletins, Generic Letters and Information Notices (92701)....... 5 NRC Information Notice 88-19: Questionable Classification of Class 1E Components...................... .................... 5 NRC Generic Letter 81-21: Natural Circulation Cooldown.......... 5 NRC Generic Letter 83-28: Required Action Based on Generic Implications of Salem ATWS Events............................. 6 NRC Bulletin 88-05: Nonconforming Materials Supplied by Piping Supplies, Inc. at Folsom, New Jersey and West Jersey Manufacturing Company at Williamstown, New Jersey........... . 6 7. Maintenance.......................................................... 7 Maintenance Program (62700)..................................... 7 Service Water System Maintenance (62703)........................ 7 (1) Mylar Sleeve and Washer Replacement........................ 7 (2) Service Water System Strainer and Travelling Screen Cleaning................................................. 7 8. Follow-up Issues (92701)............................................. 8 Solenoid Valve Control Circuitry................................ 8 Firemain Backup to Emergency Feedsater.......................... 8 9. Biofouling of Cooling Water Heat Exchangers (TI 2515/77)............. 8 i

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Page 10. Allegation Fo11ow-up................................................. 10

Existence of Concrete Voids and Exposed Rebar................... 10 , Greylining Procedures and Voiding NCRs.......................... 11 I Uncertified We1ds............................................... 11 i Uncertified Piping Material Supplied By Boston Pipe............. 12 Uncertified Electrical Equipment Supplied By Massachusetts ,

Gas and Electric.............................................. 12 t Acceptable Level Installation of the Reactor Coolant Pumps...... 12 Weldolet in the EFW Pump Room with Wrong Taper and Counterfeit Identification Number............................. 13

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11. Management Meetings.................................................. 14

"The NRC Inspection Manual inspection procedure that was used as inspection

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guidance is listed for each applicable report section.

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OETAILS Persons Contacted E. A. Brown, President and Chief Executive Officer W. J. Daley, Licensing Manager

'W. A. DiProffo, Assistant Station Manager T. C. Feigenbaum, Vice President Licensing, Engineering and Quality Programs W. J. Hall, Regulatory Services Manager

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• D. E. Moody, Station Manager G. S. Thomas, Vice President Nuclear Preduction J. M. Vargas, Manager of Engineering

• J. J. Warnock, Nuclear Quality Manager

• Attended exit meeting conducted on July 8,198 Interviews and discussions with other members of licensee and contractor management, and with their staffs, were also conducted relative to the inspection of items documented in this report.

, Summary of Facility and NRC Activities Resident Inspector Activities The Senior Resident Inspector attended meetings with regional man-agement on June 1-3 and June 14-16, 1988 in King of Prussia, Penn-sylvania, r The Senior Resident Inspector participated in an inspe: tion of the Indian Point Unit 2 Nuclear Power Station on June 20 - July 1,198 !

, The Resident Inspectors conducted an inspection of the nuclear facility at the University of Lowell on June 10, 1988.

I The Resident Inspector participated in the NRC evaluation of the 1988 Seabrook Annual Graded Emergency Preparedness Exercise on June 27-30, 198 The findings are incorporated in NRC:RI Inspection Report 50-443/88-0 , Visiting Inspector Activities f On June 1-2, 1988, an NRC:RI emergency preparedness specialist and .

section chief conducted a routine inspection of the NHY emergency preparedness progra During that inspection (Inspection Report 50-443/83-08), the licensee's vehicular alert and notification system was reviewe ;

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On June 20-22, 1988, an NRC:RI Senior Reactor Engineer conducted a  !

routine inspection of licensee activities concerning previously identified inspection findings. The results of that inspection are incorporated into pragraph 4 of this repor On June 27-30, 1988 a special NRC Team Inspection was conducted to evaluate the NHY 1988 Annual Graded Emergency Preparedness Exercis Results of this inspection will be contained in NRC:RI Inspection Report 50-441/88-0 l l Plant Status l l

During this reporting period, the plant remained in operational Mode 5, cold shutdown, with primary temperature between 110 and 140 de-grees F and depressurized. Major maintenance was conducted on the circulating water, service water, residual heat removal, chemical and volume control, secondary component cooling, diesel generator, containment spray and cor. trol building air handling systems as well as other minor work on several secondary systems. Passivation ac-tivities in the secondary systems continue On June 28-29, 1988 the licenseo conducted its annual emergency preparedness graded exercis This full participation exercise involved members of the licensee staff, representatives from the states of Maine and New Hampshire, twelve local New Hampshire towns, as well as evaluators and observers from the Federal Emergency Management Agency and the NRC. Licensee activities included com-pensatory measures for the lack of participation by the Commonwealth of Massachusetts and five local New Hampshire towns. Inspection of this exercise will be reported in NRC:RI Inspection Report 50-443/83-0 . Operational Saf_e_ty t Plant Inspection Tours The inspectors observed work activities in progress, completed work and plant status in several areas during general inspections of the plan The inspectors examined plant equipment for any apparent defects or noncompliance with regulatory requirements or license condition Par-ticular note was taken of the presence of quality control inspectors and quality control evidence such as inspectian records, material identifi-cation, nonconforming material identification, housekeeping and equipment preservatio The inspectors interviewed station staff, contractor, quality inspection and supervi sory personnel as such personnel were available in the work area During control room observation periods, the inspector reviewed control room Icgs and records including night orders, shift journals, shift turnover sheets, completed repetitive task sheets, the temporary modi-

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i fications log, weekly surveillance schedules and control board indica-  ;

tions. Specific note was taken of equipment in "pull-to-lock" conditions, '

equipment tagged, alarm status and adherence to technical specification limiting conditions for operation (LCO) and action statement Also, boron samples, taken from the reactor coolant system and connected water supplies, were spot-checked for concentration, sample frequency and documentation in accordance with specified zer- , jower license (NPF-56)

condition The inspector verified the proper position, in accordance with operational procedure or tag-out controls, of specific valves during system walk-downs and checked the valve status in the contrcl room. Similarly, temporary l modifications and component tagging, maintenance work, and design change i implementation activities, as observed during plant inspection tours, were ,

evaluated for evidence of both proper field controls and coordination of the subject work activity with the control room and operations personnel on shif In certain cases, the operability of specific components and the applicability of the observed work to the TS requirements were dis-cussed with the operator The inspector identified two ntnor discrepancies in material condition These items were provided to the licensee. Action taken on each issue is  ;

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The inspector noted that the identification tag for the circuit breaker feeding cortainment air purge fan CAP-FN-34 was colored red (safety-related) versus black (nonsafety-related). The licensee initiated work request 88 WOO 2461 to replace the labe While touring the primary auxiliary building, elevation 53'-0", the l inspector noted that a splice plate was apparently missing from the '

primary component cooling water (PCCW) heat exchanger head lif ting nonorail. The licensee provided evidence that the splice plate was

used for alignment only and had been removed to prevent interference with the travelling hoist assembl The inspector reviewed design coordination report (DCR)87-193 (through Change Authorization 03),

i and verified that the load analysis took no credit for the splice and i that an analysis of the monorail under a cantilever loading condition was less restrictive than other more limiting loading condition The inspector reviewed the design calculation for the design change and inspected the modifications in the fiel No violations were identifie j 4. Licensee Action on Previous Inspection Findings . Cable T_ ray _ S e i smi (Closed) Unresolved Item 50-443/85-29  !

NRC:RI Inspection Reports and 50-443/B6743_c_A_dequacy.present the !

background of the cable tray systems design and evaluation for l structural integrity and seismic interaction concerns during a (

, seismic event. This unresolved item was concerned with the magnitude j

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of tray displacements and steps taken to assure that displacements would not affect other component Licensee resolution of the seismic adequacy of cable trays and tray supports was made by cable tray walkdown, analysis using computer models, full scale cable tray I test.ing and structural bracing, where necessar l A final licensee walkdown after installation of other plant com- '

ponentt, was made for final verification that interaction concerns were satisfied. The inspector reviewed memorandum CEM 86-565, dated ,

December 19, 1986, sampled the ANCO full scale test reports, toured typical cable support installations including those at elevation 50'

(cable spreading room), elevation 21'6" (switchgear room) and the Train "A" electrical area (from the control building to containment)

and discussed the cable tray seismic problem with the responsible engineers. The video tape of cable tray testing (Cases A, B and C)

at ANCO was reviewed. The inspector concluded that the cable tray seismic concerns including potential displacements have been ade- -

quately addressed. This item is closed (Closed) Inspector Follow-up Item 88-02-02. Service Water Piping Corrosio The finding of local corrosion on the nonsafety-related service water piping to the train "A" secondary component cooling water heat exchanger resulted in a program to further examine safety related service water piping as discussed in NRC:RI Inspection Re-ports f0-443/87-24 and 50-443/88-0 On April 22-26, 1988, the 1 licensee conducted a remote visual examination of approximately 866 feet of the 24-inch diameter train "B" service water piping that is mostly undergroun This examination was performed by PLS Inter-national under control of the service water task team with an in-dependent evaluation of the observations made by the nuclear quality group (NQG).

The NRC inspector reviewed portions of the axial and radial video tape views of the examination process from the pipe entrance point i in the service water pump building just past weld FW-1820, F0304 at the cooling tower, a distance of approximately 824 feet. The piping was noted to be clean and free of biofouling with no evidence of '

significant corrosion. Some fine but acceptable cement lining cracking with areas of rust staining were note No detrimental conditions were identified. The NQG report describes those areas with rust staining including that by the two three-inch transmitters in section E3098-803, which will be included in the station Service Water Monitoring Program to es;ablish if changes occur in these i areas. Based on the results of this examination of the train "B" ,

service water piping internal cement lining and previous observations

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made of the cement lining of safety related piping during system work, the inspector concluded that the safety related service water piping was in an acceptable conditio l

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The final summary report on service water system piping dated June 16, 1988, as prepared by the licensee, was reviewed. This report, which was compiled and prepared by the service water task team, included consideration of corrosion failure analysis (Bioindustrial Technologies, Inc.) and service water system operability assuming underground piping degradation (Engineering Evaluation 88-015). The final summary report provides for assessing the adequacy of the cathodic protection system for the outside of the service water piping and provides for establishing a monitoring program to verify the internal condition of the service water piping on a periodic basi . Licensee Event Report 88-002 This Licensee Event Report (LER) concerning Technical Specification surveillances was closed in i4RC:RI Inspection Report 50-443/88-06. As a routine follow-up to LER 88-002 and a design deviation reported at another nuclear facility, the inspector verified th.t the power supply to the cooling fans for the 4160/480 Vac safety related transformers were also classified as safety relate The cooling fans are powered directly off the 480 Vac load centers via step down transformers. The inspector had no further question . NRC Bulletins, Information Notices and Generic Letters (Closed) NRC Information Notice 88-19: Questionable Certification

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of Class 1E Component In response to this NRC Fiformation Notice, NHY reviewed its procurement program and determined that no com-ponents furnished by the subject vendor, Planned Maintenance Systems, were in use at Seabrook. The inspector reviewed an internal licensee memorendum which described how similar situations would be pro-gec .atically precluded at Seabrook. No violations were identifie (Closed) NRC Generic letter 81-21: Natural Circulation Cooldow This NRC Generic Letter (GL) was issued in May, lMI to addres's lessons learned from the June 11, 1980 natural circulation cooldown at the St. Lucie Unit 1 plant. Since this GL was issued prior to the issuance of an operating license for Seabrook $tation, certain portions of the NRC assessment of the NHY program:, was performed by the NRC Office of Nuclear Reactor Regulation as part of the licensing process. The licensee was required, however, to implement procedures

.ind conduct training as described in the G To provide closure of this issue (identified as Multi Plant Action Item B-66), NRC Tem-porary Instruction 2515/86 was published in April, 198 A natural circulation cooldown test will be performed as part of the startup test program. Test procedure 1-ST-22, was reviewed in NRC:RI Inspection Report 50-443/86-31. Conduct of this test will be fol-lowed as a normal startup testing evolution during the NRC:R1 in-spection program.

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With respect to procedures and training, the inspector reviewed the following procedures:

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ES-0.2 Natural Circulation Cooldown

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ES-0.3 Natural Circulation Cooldown with Steam Void in Vessel (with RVLIS)

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ES-0.4 Natural Circulation Cooldown with Steam Void in Vessel (without RVLIS)

Those procedures address all possible combinations of cooldown in-cluding those situations when rapid cooldown is required ard void formation is expected. Previous NRC inspection of emergency oper-ating procedures has confirmed that training has been and continues to be conducted in the symptom-based procedures. This item (MPA-B 66) and its associated TI are therefore closed, c. (Closed) NRC Generic Letter 83-28: _ Required Actions Based on Generic Implications of Salem ATWS Events._ Previous NRC inspection of this item may be found in NRC:RI Inspection Reports 50-443/86-58 and 50-443/83-04. Licensing review of this Generic Letter (GL) may be found in the Seabrook Safety Evaluation Report (NUREG-0896).

The inspector reviewed the licensee actions taken in complying with section 4.5.1 of GL 83-28. Maintenance Department surveillance procedure MX0507.18, Reactor Trip Switchgear Inspection, Testing and Preventive Maintenance (Rev. 02) included separate steps which in-dependently test the capability to manually trip the breakor via the shunt trip and undervoltage trip features. Also, surveillance was being performed on the shunt trip attachment This action completes closure of GL 83-28 for inspection purposes and satisfies the requirements of NRC Temporary Instruction 2515/6 d. (Open) NRC Bulletin 88-05, with Supplement 1: Nonconforming Materials _ Supplied _ by piping __ Suppl i e s , _ Inc . a Dil som, New Jersey and West Jersey Manuf acturing Companyat Wi D i ams town1 New Jersey 2 On June 1771M5, the resident inspectors and the N W ~$eabrook prohet manager met with licensee representatives to discuss their plans for review, inspection and response to NRC Bulletin 88-0 Suspect WJM fitting and flange material is known to have been sup-plied to the Seabrook sit Field hardness testing is expected to commence the week of July 5, 198 No specific problems were identified with the Itcensee program established to respond to this Bulleti _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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7. Maintenance Maintenance program Previous !!RC inspection reoorts contained concerns in the area of post maintenance testing. These concerns were individually addressed and closed. As a routine follow-up of the maintenance program, the inspector reviewed recently issued procedure MA 3.5, Post Maintenance Testing and determined that the procedure is comprehensive and well written. Of particular note was the section encompassing the Post

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Modification Te'. ting Guides. These guides provide generic guide-lines for the retesting of pumps, valves, heat exchangers, instru- ;

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. mentation, et For specific types of maintenance performed, re-testing requirements are delineated. These guidelines appear to

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provide a significantly improved program to ensure that the retests not only verify that deficiencies have been corrected but also that the work performed has not adversely affected other design feature The inspector had no additional question ,

, , Service Water System (1) Mylar Sleeve and Washer Replacement  !

On June 1, 1938 the inspector reviewd work request 88W341 in the fiel This job involved testing and replacement as necessary ('

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of the mylar sleeves and washers on service water piping flange 1-1827-JTR-0801 in the primary auxiliary building. Testing was

accomplished using the resistance method and those sleeves found

to be less than ten ohms resistance were replace The in-

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spector noted appropriate precautions in the work request

concerning bolt torquing and fastener replacemen No viola-

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tions were identifie (2) Strainer and Travelling Screen Cleaning l

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The inspector observed removal of the Train A Service Water (SW)

strainer (SW-5-10) for cleaning. Repetitive task sheet 88RM0206 !

was reviewed and the strainer examined. A small amount of l marine organisms, primarily starfish were removed. Licensoe !

personnel suspect that the starfish were inadvertently back-t washed off the traveling water screens during lubrication procedures. A change will be made to the procedure to ensure '

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that the screens are backwashed prior to performing the

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i lubricatio The strainer lining was noted to be intact and undamaged, i

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. Follow-up Issues Solenoid Valve Control Circuitry On May 31, 1988 tb6 Inspector met with the cognizant technical '

support engineer and discussed the background behind station in-formation report (SIR)87-057 concerning the control circuit modi-ficatiens to solenoid valves RC-FV-2840, RC-FV-2876 and RC-FV-283 l The change involved the power supplies to the individual solenoids and valve position indicating light The final resolution of the ,

SIR identified the fact that no circuit discrepancy actually existe The' inspector concurred with this finding and had no further ques-  !

tions, l Firemain Backup To Emergency Feedwater i l

The inspector raised a concern that the backup supply of cooling water to the emergency feedwater (EFW) system may be susceptible to clogging. The Seabrook Final Safety Analysis Report indicates that, ,

if hot standby conditions must be maintained for extended perious '

following an accident, operator action may be required to tr snafer the EFW source. Normal makeup to the condensate storage tank is via

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the demineralized water syste This supply is dependent upon of fsite power which may be assumed to be lost until the plant is in cold shutdown. To ensure an adequate backup supply of cooling water ,

to the EFW system, a connection is provided between the fire pro-j tection (FP) and EFV sy items. This connection consists of a four inch diameter fire hose between a nearby FP system strainer and a flange on the suction of the EFW pumps. Since the FP side of the connection is made to the flushing fitting on a FP strainer, the inspector questioned how strainer debris would be prevented from ,

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cath. A request for enginering services was written and dispositioned to increase the freanncy of the strainer flush f ro.n yearly to [

quarterly. Additionally, a portable inline strainer will be added to  !

the hose connection to prevent debris from clogging the line. The inspector had no further question ,

[, Biofou11n2 of cooling Water Heat Exchangers ,

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The Institute of Nuclear Power Operations (INPO) issued Significant ,

Operating Experience Report (SOER) 84-1 in March, 1984 entitled "Cooling  !

Water System Degradation Due to Aquatic Life". NRC inspection was con- f

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ducted to determine the actions taken by NHY to address selected issues

identified in INPO SOER 84-1. This 50ER was the subject of internal [

licensee investigation in accordance with the external or>e ra t i on a l ex- f j perience progra Five INp0 recommendations were made in the specific {

areas of design, inspection procedures and trainin !

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Sased upon the above recommendations, the Operational Engineering Supervisor made a series of Seabrook specific recommendations. These recommendations were addressed to the Station Manager by memorandum in September, 1984. Station staff responses are inclur'ed below with each recommendatio (1) Develop and implement a program to periodically test the thermal efficiency of safety related heat exchangers which are cooled by the service water system, in order to detect degradation of heat ex-changer effectivenes The NHY Technical Support Performance Manual (TSPM) contains in-structions for periodic heat exchanger eddy current and visual ex-

aminations as well as temperature efficiency measurement The inspector reviewed the following instructions:

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TSPM 9.3 Heat Exchanger Performance

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TSPM 5.6 Diesel Generator System Performance The inspector determined that they were adequate to ensure that safety related heat exchangers receive sufficient monitoring to

detect degradatio (2) Complete the chlorine minimization program as currently planne The NHY chlorine management program is described in chemistry pro-cedure CP 4.2. By review of thfs procedure, the inspector determined

that the recommendation was me (3) Approve the draft versions of the alarm response procedures for actions to be taken following alarms in the cooling water syste ! The inspector reviewed Abnormal Operating Procedure 051216.01, Oe-

! graded Ultimate Heat Sink (Revision 01). Operators are keyed into

! 051216.01 by appropriate symptoms such as strvice water (SW) strainer high differential pressure or high temperatures in systems cooled by SW, Appropriate cautions indicate that operation with a SW strainer bypassed should be minimized to prevent pos iible blockage of tubes, On rapid rises in strainer dif ferential pressure, for example, in-itiation of the SW cooling tower is called fo (4) Further evaluate the scenario of service water system strainer high

, differential pressure to determine the need for installation of a

, spare strainer and associated isolation valve in ear:h service water

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The Technical Support Group evaluation of the above item concluded that installation of spare strainers at this time was not warrante The inspector reviewed internal NHY memorandum No.44642 dated May 17, 1988 which provided supporting justification for their evaluation, t The inspect.or agreed that installation of the spare strainers is not necessary at this time since the licensee has instituted the per-formance monitoring system to provide early indication of biofouling effect Based upon the above licensee actions with respect to procedures, '

heat exchanger performance monitoring, biofouling testing and an-alysis and inherent system design features, the inspector concludes that the NHY biofouling program is presently effective and posesses the capability to detect the onset of biofouling should it occu This issue is close .

l This inspection also closes NRC Temporary Instruction 2515/7 . Allegation Followuj Region I inspection reports 50-443/86-52 and 50-443/87-07 have provided the technical bases for the closure of several allegations and concerns raised by the Employee's Legal Project (ELP). Additionally, a publicly available letter, dated February 18, 1988, from Region I to ELP documents the conduct of a meeting between members of the ELP and the Region I staff on December 29, 1987, discusses other ELP questions / concerns, and provides as enclosures certain documented correspondence between the ELP and NRC in 1

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which other concerns are raise During this inspection period, the inspector reviewed all ELP concerns remainin; open and determined that, after initial inquiry into the technical issues, certain of the stated concerns provided sufficient informat9n to permit further inspection followu A summary of these issues is provided, as follows:

(a) Existence of concrete voids and exposed rebar (reference: NRC in-terview with ELP on April 20,1987).

While concrete construction activities were in progress at Seabrook Station, stripping of the concrete forms sometimes revealed small concrete voids, honeycombing and, in certain cases, exposed reba Nonconformance reports (NCRs) were routinely issued to document the need for repairs. Past NRC inspections checked that where the voids were structural in nature, i.e., not superficial or cosmetic, the repair procedures and conduct required high-strength grout appli-cation in a manner that fully enveloped any exposed rebar, per American Concrete Institute rode specification Routine plant inspection / tours by NRC inspectors since the completion of Unit I construction have revealed no problems or remaining nonconforming conditions in this are . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ._ _ . _ _ _ _ _ _ .

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(b) Greylining procedures and voiding NCR's (reference: NRr interview

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with ELP on April 20,1987),

The inspector confirmed the process of both "grey lining" procedures i.e., revising a procedure after some difficulty may have been en-countered in its implementation, and voiding NCR's were conducted under controlled programs at Seabrook Station during construction activities. These are acceptable practices under the provisions that they are properly controlled and result in an as-built product which

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meets design criteria, Past NRC inspections, including major team inspections in 1984 and 1985 examined the design change control process, and particularly the use of NCR's to effect such change No major problems were identified. Revisions to construction specifications and procedures are not uncommon and must be controlled with measures commensurate with original document approval, NRC inspections during the construction phase routinely evaluated the adequacy of such control : (c) Uncertified Welds (reference: NRC interview with ELP on April 20, 1987).

The appropriate welding codes prescribe requirements for the qualification of both welding procedures and welder Maximum thickness of the welded material is one of the welding attributes

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that must be examined to ensure that both the procedure qualification i record (PQR) and welder performance qualification test are consistent

] with the conditions and applications encountered in the field.

a Typfcally, two different welding processes were employed in stainless steel pipe welding at Seabrook Station. Gas tungsten-Arc Welding was

utilized to install the root weld and hot pass, while Shielded i Metal-Arc Welding was used to coeplete the pipe weld join In certain cases, more than one welder was involved in the application I

of these welding processes to the same pipe wel However, sah

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routine practice would not be considered "stacking the welders", as 1 this terminology is used in the stated ELP concern, 1 Routine NRC inspection of welding activities at Seabrook Station during the construction phase have verified that Welding Procedure Specifications (WPS), PQRs, and welder performance qualification tests are all checked prior to the assigi.n nt of a welder to a specific pipe joint, utilizing an approved WPS, QC inspection of the safety-related welding in progress and the assignment of hold points were routine, Although over the coursta of construction certain violations of the welding codes and/or procedures were identified by the NRC and documented in the applicable inspection reports, none of these compliance matters invcived the question of "stacking the welders". Based upon the answers provided by ELP to NRC questions on this particular concern, it appears that some misunderstanding of the

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ASME Boiler and Pressure Vessel Code requirements underlies the stated concern; and no specific information was made available re-garding particular weld Based upon the available information and numerous NRC inspections of weldino activities durtny Seabrook, Unit 1, construction, the in-spector identified no evidence of either a progranaatic or a specific problem with respect to pipe welding, beyond the authorized code qualification thicknesse (d) Uncertified piping material supp'ied by Boston Pipe (reference: ELP letter, dated July 6,1987, to NRC Region I).

The inspector identified that Boston Pipe was a supplier of re-frigeration tubing and fittings, for air conditioning installation at Seabrook Station. While this material was not ASME grade, it could be used in safety-related ventilation system applications because it was procured to ANSI Standard B31.1 requirement The inspector interviewed licensee Employee Allegation Resolution (EAR) personnel and determined that a licensee investigation of this allegation was conducted. The NRC will review the results of this licensee EAR effor (e) Uncertified electrical equipment supplied by Massachusetts Gas and Electric (reference: ELP letter, dated July 6, 1987, to NRC Region I).

Initial inquiry by the inspector revealed that the Massachusetts Gas

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and Electric Supoly Company was a supplier of nonsafety-related I

electrical material to Seabrook Statio The inspector also learned l that the licensee EAR program has conducted an independent review of this allegatio The NRC will review the results of the EAR effort (f) Acceptable level installation of the reactor coolant pumps (refer-ence: ELP meeting with the NRC, as documented in a Region I letter, dated February 18,1988).

(riginally, a concern was raised regarding the modification of the reactor coolant pump support locations. The subject relocation was documented as a design change and reviewed by the NRC as described in inspection report 50-443/87-07 with the conclusion tnat the modi-fication did not overstress the affected piping beyond allowable design code limit During a eeeting between ELp and NRC Region I personnel on December 29, 1987, an additional question on this matter was raised as fol-lows:

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"Is the reactor coolant pump acceptably level aftrr heatup of the system since an engineering change resulted in the base of one support being repositioned?"

The inspector noted that data from the conduct of hot functional testing activities in 1985 and 1987, to include the results of in-strumentation of the reactor coolant pumps, had bien analyzed by both the architect / engineer (UE&C) and nuclear steam system supplier (Westinghouse) engineers and found acceptable. However, the response to this specific question can only be provided by the licensee with Westinghouse inpu The inspector confirmed that NHY engineering personnel are evaluating this issue. The NRC will review the results of this licensee effor (g) Weldolet in the EFV pump room with wrong taper and counterfeit identification number (reference: ELP meeting with the NRC, as documented in Region I letter, dated February 18, 1988).

During the meeting between Elp and NRC Region I personnel on December 29, 1987, it was alleged that a weldolet affixed to an 8"-10" diameter piping elbow in the emergency feedwater (EFW) pump room has the wrong taper and counterfeit identification number scribed on i The inspector subsequently conducted an inspection of the subject EFW pump room area and noted three weldolets, which could by description represent the subject of the stated allegation. Although visual NRC

nspection identified no obvious taper problems, hand-scribed identification markings were found. While this is not unusual for as-built field conditions where rupair and replacement installation activities of ten occur, the licensee was requested to investigate this allegation from the standpoint of both acceptable weldolet material traceability and acceptability of the installed taper conditions. An EAR investigation is still in progress on this matte The NRC will review the results of this licensee EAR effor In addition to the seven Elp concerns documented above, another allegation was reviewed during this inspection period involving the qualification of an Authorized Nuclear Inspector (ANI) trainee to conduct independent inspections and whether there was a deliberate attempt by the ANI in-surance company to conceal the fact that such unauthorized inspections were conducted. Initial inquiry and inspection by the inspector revealed that the Lumbermens Mutual Casualty Company (part of the Kemper Group)

acknowledged that Kemper had an inspector trainee at the Seabrook site from May through December, 1985, but indicated that this inspector had performed work in strict accordance with his training program and that his activities were monitored by the qualified ANI's onsit The inspector reviewed the subject ANI trainee's training program and noted that during a period of time between May 27 - June 21, 1985, seven different qualified site ANI's had signed a form certifying that:

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"Responsibility for the inspections performed by ANI Trainee is f assumed by the respective Authorized Nuclear Inspector that is as- ,

signed to directly supervise his activities All inspections pro- '

vided by the ANI Trainee on behalf of the ANI's are considered ac-ceptable and have been demonstrated to my satisfaction."

Also, the training program documented that upon completion of above certification, the "ANI Trainee will be allowed to independently perform inspections." The inspector confirmed that such a practice and use of an ANI Trainee are in compliance with the ASME Boiler and Pressure Vessel Code,Section III, NCA-5000 requirements. Thus, it appears that facts, as stated in the allegation, are true, but represent neither a noncom-pliance with the Code, nor evidence of wrongdoin Discussion with licensee EAR personnel indicated that the question of an l unqualif ted ANI performing inspections at Seabrook had been raised first in January, 1938 in testimony before the New Hampshire House of Repre-sentatives. A licensee investigation of this allegation was conducte i In order for the NRC to ascertain whether the facts and results of lic-

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ensee investigation on this matter are consistent with the issues raised in the allegation provided to the NRC, further NRC review of the EAR  ;

effort in this regard is warrante '

z In order to clarify the licensee position on the above allegation, and

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likewise un the ELP concerns documented as items (d) through (g) above, a  ;

written response on the conduct of the EAR investigation, its status, and conclusions with respect to each of these five issues has been requested '

of the licensee. Pending receipt of the licensee response, review by the l

NRC and further inspection / investigation, as deemed necessary, the four '

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remaining ELP concerns and the one allegation invoiving ANI Trainee in-spections are considered open items.

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11., Management Meetings

1 At periodic intervals during the course of this inspection, meetings were '

i held with plant management to discuss the scope and findings of this

, inspection. An exit meeting was conducted on July 8,1988 to discuss the I

inspection findings during the perio During this inspection, the NRC

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inspectors received no comments from the licensee that any of their in- ,

spection items or issues contained proprietary informatio No written I material was provided to the licensee during this inspection, except for I i inspector follow-up questions generally discussed in section 3 of this l l report.

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