ML20214R485

Initial OL Review Rept for Seabrook Station Unit 1

ML20214R485
Person / Time
Site:	Seabrook, 05000000
Issue date:	10/09/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213F044	List: ML20213F042 ML20214R426 ML20214R460 ML20214R478 ML20214R485 ML20214R491 ML20214R529 ML20214R545 ML20214R564 ML20214R568
References
FOIA-87-271 NUDOCS 8706080166
Download: ML20214R485 (83)

Text

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ATTACHMENT INITIAL OPERATING LICENSE REVIEW REPORT FOR SEABROOK STATION UNIT 1 DOCKET NO. 50-443 PREPARED BY UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I B706080166 870602 PDR FOIA GRABERB7-271 PDR

TABLE OF CONTENTS Pa_ge 1.0 Introduction.... ............................................... I 2.0 Overview of Plant Status........................................ 2 3.0 Facility Construction........................................... 3 3.1 Overview and Status........................................ 3 3.2 Inspection Program History and Findings.................... 3 3.2.1 Routine Region I Inspection Program................. 3 3.2.2 NRC Special Inspections............................. 6 3.2.3 Review of Construction Deficiencies................. 11 3.2.4 Third Party Audits and Evaluations.................. 11 3.3 Quality Assurance for Construction......................... 12 3.4 Facility Construction Summary and Conclusion. . . . . . . . . . . . . . . 13 4.0 Facility Preoperational Testing................................. 14 4.1 Overview and Status........................................ 14 4.2 Inspection Program History and Findings.................... 14 4.3 Facility Preoperational Testing Summary and Conclusions.... 15 5.0 Facility Preparations for Operations............................ 15 5.1 Overview and Status........................................ 15 5.2 Inspection Program History and Findings.................... 15-5.2.1 Facility Operations - Staffing and Programs......... 15 5.2.2 Quality Assurance for Operations.................... 17 5.2.3 Emergency Preparedness Facilities and Program....... 17 5.2.4 Radiological Controls and Fuel Receipt.............. . 18 5.2.5 Security Facilities and Programs.................... 19 5.2.6 Fire Protection Facilities and Programs............. 19 5.2.7 Technical Specifications............................ 20 5.2.8 Third Party Audits and Evaluations................... 20 5.3 Startup Test Program....................................... 21 6.0 Enforcement History............................................. 21 7.0 Systematic Assessment of Licensee Performance (SALP)............ 22 7.1 Overview and Status........................................ 22 7.2 First SALP................................................

7.3 Second SALP................................................

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. 23 7.4 Third SALP................................................. 23 7.5 Fourth SALP................................................ 23 7.6. Fifth SALP................................................. 24 7.7. Sixth SALP................................................. 24  ;

7.8 Seventh SALP............................................... 25 i i l l

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4 8;. 0 A11egations.............. ...................................... 25 8.1 Overview and Status........................................ 25 8.2 Facility Allegation Resolution and Summa ry. . . . . . . . . . . . . . . . . 26 8.3 Licensee Employee Allegation Resolution Program............ 26 9.0 10 CFR 50.57(c) Motion.......................................... 27 10.0 Future Region I 1

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l Actions......................................... 28 11.0 Justification for Interim Operation............................. 29 1

12. 0 S umma ry a n d C o n c l u s i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 I

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i LIST OF ENCLOSURES Enclosure Title l'

1 Special Assessment of the Quality of Construction of Seabrook-Station Unit 1 2 Summary of SALP Evaluations

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Inspection Program Annual Breakdown (Hours) 8 4 Inspection Summary e

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1.0 Introduction J

Public Service Company of New Hampshire (PSNH) applied for a license to con-struct and operate Seabrook Unit 1 (DN'50-443) on July 9,1973, and was issued a Construction Permit (CPPR-135) on July 7,1976. Unit 1 is a Westinghouse four-loop PWR, rated at 1198 MWe and housed in a reinforced concrete contain-ment structure. It is located in the town of Seabrook, Rockingham County, New Hampshire, along with Unit 2, a similarly designed reactor, currently 24%

complete with construction halted and in an " indeterminate status". The units are arranged using a " slide along" concept with certain structures common to both units.

United Engineers and Constructors (UE&C) served as the architect / engineer and construction manager. PSNH has contracted with the Yankee Atomic Electric Company (YAEC) for specific services, to include project engineering, licens-ing, fuel supply and the establishment and implementation of the Quality As-surance Program for design and construction. YAEC will also provide engineer-ing services necessary to support the operation of Seabrook Unit 1.

On June 23, 1984 an organizational change was made to create the New Hampshire Yankee (NHY) Division of PSNH with the primary responsibility for construction, startup and operation of Seabrook. This followed a temporary suspension of construction activities, initiated on April 18, 1984 due to financial ,res-l sures on PSNH. Other organizational changes which released several contrac-i tors from the Seabrook project, replacing them with UE&C as the " direct em-ployment" constructor. Other major construction work stoppages occurred in February,1977 and July,1978 when the NRC suspended the construction permit because of questions regarding the circulating water tunnels and the lack of EPA approval for this cooling system.

NRC Region I began performing inspections at Seabrook in 1973 and has com-pleted over 200 inspections totalling over 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. These inspections j

involved observation of work in progress, examination of completed work, re-view of work control documents, independent measurements and calculations, and the examination of quality records.

i This report describes the process used by the licensee to monitor and control the quality of construction and preoperational testing, discusses the results of independent evaluations of the licensee's performance, and addresses both the inspection program and the Systematic Assessment of Licensee Performance (SALP) program conducted by NRC Region I. The report also discusses facility preparations for operation.

This report presents the basis for the Region I conclusion that (1) Seabrook Unit I has been constructed substantially in accordance with Construction Pnmit CPPR-135, the Final Safety Analysis Report (FSAR), and NRC regulations; and (2) New Hampshire Yankee, as a division of PSNH, is ready to safely operate the facility.

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2 2.0 Overview of Plant Status Construction of Seabrook Unit 1 is essentially complete. All buildings, sys-tems, and equipment have been turned over to the station staff. Some con-struction completion activities such as painting remain to be finished. Ad-ditionally, some minor construction activities in the turbine building remain.

Preoperational testing activities are nearly complete. Some tests remain to be completed and some test exceptions in the areas of heating, ventilation, and air conditioning (HVAC), solid waste transfer, and the station computer remain to be closed out. Where system tests are not complete or rework is ongoing (i.e., resolution of construction deficiencies identified per 10 CFR 50.55(e)), the Technical Specifications will govern the operability of systems and enuipment in the mode for which they are needed.

During the course of NRC inspection and investigation activities at Seabrook Unit 1 since 1973, over 1,000 inspection items requiring tracking and follow-up have been opened. These items include enforcement actions and allegation followup activities as documented in other sections of this report, routine bulletins, circulars, construction deficiency reports, unresolved issues, and l

4 program weaknesses identified by special team inspections. Approximately 50 of these NRC inspection items currently remain open, the other items have been closed in NRC inspection or investigation reports, as appropriate. The status of outstanding items is continually being assessed and updated as Region I inspr:+ %. activities continue. At this time, no open inspection item, cur-rently outstanding, is deemed of such significance as to affect the Region I recommendation for issuance of a low power license.

Testing exceptions noted during the conduct of Hot Functional Testing required partial system design modifications and appropriate retesting. Systems af-fected are: emergency feedwater (recirculation system and Terry turbine cold starts); steam generator blowdown; feedwater recirculation; main steam isola-tion bypass and steam valve operability system functions. Successful comple-tion of additional hot testing during the licensee's planned post-fuel load, hot functional tests to close the open test exceptions is required prior to initial criticality.

In terms of readiness for operation, no major impediments to the low power license issuance have been identified. Procedural preparation and validation continue and it is anticipated that all procedures required for a particular mode of operation will be approved and issued prior to the plant entering that mode.

Prior to 1984, the licensee demonstrated adequate management of Seabrook con-struction and testing activities, primarily through the use of YAEC QA, lic-ensing, engineering and project management services. The establishment of this management structure provided independence and resulted in the construc-tion of a generally quality product. However, some recurrent programmatic problems did arise, as in the area of piping and pipe support construction, discussed later in this report. With the reorganization under New Hampshire 4

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Yankee in 1984, not only were YAEC and UE&C services and functions combined.

under direct senior licensee management overview, but also the respo'nsibility for the quality completion of work,' given schedular goals, was delegated with

' the associated accountability. The impact of such a change in management direction not only improved schedular and budgetary performance, but also provided effective corrective action to some of the persistent problems in the piping and pipe support area. The New Hampshire Yankee reorganization is also viewed as having been beneficial to the preparedness of the operations staff by providing the same management concept and direction to all parts of the Seabrook team.

In ' summary, Seabrook Unit 1 is deemed ready for safe low power operations and '

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testing, subject to the license conditions.

3. 0 Facility Construction 3.1 Overview and Status The construction of Seabrook Unit 1 is essentially complete.: Region I inspections of construction activities at Seabrook have been conducted in accordance with the program established by the Office of Inspection and Enforcement. The objective of these safety inspections is to obtain sufficient information through direct observation in the field, personnel interviews, and review of procedures and records to determine whether construction and installation of safety related components, structures, and systems meet applicable requirements. A significant portion of the inspection effort is directed toward inspection of the applicant's Qual-

,' ity Assurance Program and its implementation in both the Preliminary and Final Safety Analysis Reports. This program has been reviewed by the j

NRC and accepted as documented in the appropriate Safety Evaluation Re-ports.

3.2 Inspection Program History and Findings 1

l 3.2.1 Routine Region I Inspection Program A Senior Construction Resident Inspector was. assigned to Sea-brook in May, 1980. Additional resident inspection resources were dedicated to Seabrook with the assignment of a resident inspector in September, 1982 and a resident entry. level engi-neer was assigned in April,-1985. Currently, there,are two operations resident inspectors on site, who have a combined i total of seven years of Seabrook resident experience and who i

both inspected the conduct of most of the preoperational test program, including the month-long series of tests-integrated into the Hot Functional Testing of.Seabrook systems. By direct observation, independent verification,-daily presence, and both routine and reactive inspection, the resident inspectors have provided an additional measure of assurance that the quality of construction and testing has been achieved and maintained.

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Initial NRC inspection activities commenced at Seabrook in 1973.

Announced and unannounced Region I inspections have been con-ducted since that time at a. frequency consistent with the pace of construction activities as work at the Seabrook site pro-gressed. With the inception of the resident inspection program at Seabrook, NRC on-site coverage of construction work has been provided and supplemented by additional inspections by Region i I specialist inspectors.

In general, Region I inspection resources were directed to the verification of quality performance in the areas of soils and foundations, containment and other safety-related structures, piping systems and supports, safety related components, support 4

activities and systems, electrical power supply and distribu--

tion, instrumentation and control systems, quality assurance, management controls, design and design change control, and corrective action effectiveness. Enclosure 4 identifies the inspections performed, the areas inspected, and significant inspection findings. To date, over 200 inspections have been performed for Seabrook Unit 1. A comparison of Seabrook in-j

' spection hours with those expended at two recently licensed Region I facilities (taken at 90% construction completion as 1

a reference point for comparison purposes) is -illustrated below:

Seabrook Unit 1 Millstone Unit 3 Hope Creek-15600 hours 9100 hours0.105 days <br />2.528 hours <br />0.015 weeks <br />0.00346 months <br /> 7600 hours0.088 days <br />2.111 hours <br />0.0126 weeks <br />0.00289 months <br /> i

The NRC routine inspection program at Seabrook has confirmed 1 ' the overall quality of construction and hardware installed in Unit 1, as well as identified those areas of programmatic con-cern where licensee management attention and corrective action were necessary. Historically, NRC concerns have been raised in the areas of QA program implementation, design and design

! change controls, piping and pipe support construction, and electrical installation. The problems with QA, identified during the early phases of Unit 1 construction, were related to the large number of contractors on site, each with their own separate QA program. It is noteworthy that the continuity.

l and overview of YAEC, in the area of-QA, were able to not only make the QA program effective, but eventually make it one of the strengths of management controls at Seabrook. One key step in this progress occurred in early 1984 when the reporting lines for each contractor site QA organization were redirected 1 from the contractor corporate staff offsite to the onsite YAEC l' Construction QA manager. This management change provided the j licensee a more direct control of the QA function and the ability to implement effective corrective action, when re-quired.

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' Similarly. .in:the area.of design and design change controls, increased YAEC involvement in the engineering overview of UE&C activities provided the necessary direction for improvement in this area of NRC concern. Liaison between Region I and the IE Vendor Inspection Branch (VIB) resulted in the conduct of VIB inspections on site in conjunction with planned audits of the UE&C office in Philadelphia. A subsequent management meet-ing with the licensee and both Region I and the VIB reinforced the NRC position that additional corrective measures were war-ranted in the design change area. With the increased YAEC overview, and with the establishment of the NHY Director of Engineering and his staff fto further manage design activities,

' the programmatic problems. identified in this area were satis-factorily addressed.

The piping and. pipe support discipline historically has repre-sented the area of greatest concern at Seabrook Unit 1. A Region I Immediate Action Letter confirming a licensee stop work order to halt all weld repairs performed by the piping contractor (Pullman-Higgins) was issued in late 1980. While i corrective action on this issue was implemented by the licensee in a timely manner, subsequent routine NRC inspection continued 3

to identify concerns with weld procedures qualification, weld NDE, pipe support installation, and particularly with generic i

interface problems between UE&C and Pullman-Higgins. With_ ;

1 regard to hardware impact, it was noted that significant rework. l

' was required in the piping and pipe supports area to assure quality installation in line with design criteria. All of  ;

j these NRC concerns culminated in Region I convening a special '

Systematic Assessment of Licensee Performance (SALP) Board in February, 1984 to evaluate licensee performance and corrective action in the " Piping Systems and Support" area alone.

Licensee response to the special SALP finding was integrated into the overall change in management direction, which occurred in 1984. At that time, as noted above, the shift in reporting responsibility for contractor QA organizations (in this case, Pullman-Higgins) was implemented and the establishment of New

' Hampshire Yankee took place. Construction management control ~

of the piping discipline was thereby more firmly placed under direct NHY management supervision. These management actions, in congruence with the specific corrective measures for the

' identified technical problems, proved effective in improving the subsequent performance in the piping and pipe supports area.

NRC inspections of this discipline since the implementation of all the corrective actions have' confirmed their effective-ness.

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With regard to the last identified NRC construction concern

involving electrical installation deficiencies, it is noted that interface problems between the installation contractor and the A/E-construction manager, here also, proved to be the

root-cause basis for the programmatic concern. With the re-

placement.of the electrical contractor with a UE&C direct labor force and with additional NHY supervision, effective controls were implemented in this area at the time when the electrical

!' discipline workload was at its most critical period with con- ,

trol and power circuits and systems being tested. <

NRC follow-up inspection of electrical construction, along with routine inspection of all the construction disciplines, con-firmed quality hardware and installation and acceptable licen-see process controls related to this area.

3.2.2 NRC Special Inspections  ?

Several special team inspections of Seabrook Unit I have been conducted to supplement the routine inspection program and to i provide additional assurance of quality. These inspections are listed below with a description of the inspection scope l and conclusions, j!

a. Region I Construction Assessment Team (CAT) inspection -

June / July,1982 i  !

The purpose of this CAT inspection was to evaluate the i

licensee's project management effectiveness by performing +

detailed examinations of quality assurance, construction control, project management and design control. Also, the Region I Mobile Nondestructive Examination (NDE)  ;

i laboratory was used, along with a contractor-supplied 1 l radiographic source and technicians, to perform indepen- l

' dent examination of welds /weldments using Radiography, ,

Magnetic Particle, Liquid Penetrant, Thickness Measure- 3 i

ment, Ferrite Measurement, Hardness Measurement, and  ;

q Visual-Examination.

• The CAT inspection found that the overall project was

] adequately managed. Design control and the effectiveness i

of corrective action were two areas identified as requir-ing additional management attention. Also, one radio-1 graphically examined weld was found to contain a reject-  !

l able linear indication for which repair was required. l i

Corrective action on these issues was effected by the l licensee and all open NRC inspection items have been j closed.

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b. IE Integrated Design Inspection (IDI) - November / December, 1983:

The IDI at Seabrook was based upon an NRC initiative to develop a program to assess the quality of design activi-ties.for a nuclear facility, to include the examination of the as-built configuration, resulting from such design.

• A comprehensive examination of the design development and implementation was conducted for the Unit I containment building spray (CBS) system. The inspection was an in-teroffice NRC effort, conducted with contractor assistance, which evaluated the CBS system design with respect to five major engineering disciplines - mechanical systems, me-chanical components, civil and structural, instrumentation and controls, and electric power.

While a large number of findings and observations were generated in the IDI Report, the summary conclusion indi-

- cated that the problems found in the Seabrook design ap-peared to be confined to specific issues that did not seem to cross discipline boundaries. Each individual issue and finding was addressed by the licensee in response to the IDI report. A follow-up inspection was conducted at ,

the UE&C offices in Philadelphia, PA in November, 1984 Most open inspection items were closed by the NRC Office of IE with certain specific issues being transferred to Region I or the Office of NRR for closure. In June 1986, I

all IDI items were closed.

c. IE Construction Appraisal Team (CAT) inspection - April /

May, 1984:

The objective of this CAT inspection was to evaluate the adequacy of construction at Seabrook Unit I through review of the construction program and selected portions of the

' QA program, with emphasis upon the installed hardware.

Sample inspections were conducted by both NRC personnel and contractors in the following construction areas:

electrical and instrumentation mechanical ,

civil and structural welding and NDE material traceability and controls design change control corrective action systems i

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The overall conclusion reached by the CAT inspection was that hardware and documentation for the various construc-tion areas reviewed were generally found to be in accord-ance with requirements and commitments. Certain program weaknesses were identified, particularly with regard to the design change control process, A/E interface with the

' contractors, and pipe support construction. Subsequent NRC inspection of all of these areas has identified ac-ceptable corrective action on the part of the licensee and has closed all CAT inspection findings.

d. Region I Construction Team Inspection (CTI) - June, 1985:

The purpose of this inspection was to assess the effec-tiveness of the resumption of construction activities 2 (after tit 1984 work cuspension) under the new NHY site organization. A multidisciplinary review of selected

" portions of key safety-related systems for Seabrook Unit i

I was conducted. The systems reviewed and inspected in-cluded the safety injection, residual heat removal, HVAC, and diesel generator jacket water cooling systems.

While the inspection results revealed certain weaknesses in the I&C, design change and welder qualification records

) areas, overall program strengths were found to reside ,vith

' licensee site management, QA effectiveness, and UE&C welding engineering. In summary, the CTI noted a high level of management involvement in the quality and control of site construction activities. All of the CTI inspec-q tion findings have been closed.

e. Region I Independent Measurements Inspection - July,1985:

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The purpose of this irspection was to verify the adequacy l of the licensee's welding and NDE quality control programs.

Utilizing the NRC Mobile Nondestructive Examination (NDE) l Laboratory, Region I engineers and NDE technicians, as-i sisted by contractor personnel with a radioactive NDE

! source, conducted examinations of welds and weldments required of the licensee by code in order to check the licensee evaluation of the original examinations. Also, other confirmatory measurements were taken to indepen-dently determine the quality of selected inspection items.

The following represents a summary of all items examined:

Radiography - 37 welds Socket Weld Gap Measurement - 24 welds Liquid Penetrant - 32 welds Visual Examination - 68 weldments

9 Magnetic Particle - 23 welds Ultrasonic Examination - 6 welds Hardness Measurement - 11 welds l --

- Thickness Measurement - 44 weldments Ferrite Measurement - 24 weldsents

. Alloy Analysis - 5 welds 1 --

Anchor Bolt Length Measurement - 56 bolts . '

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Visual Examination of Steam Generator "J" Tubes -

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8 welds Containment Liner Coating Thickness Measurement -

j 10 readings each at 3 different locations i

The inspection results revealed no unacceptable conditions

! and confirmed the validity of the original licensee NDE, -

{ along with the acceptability of the sample hardware.

i j f. Region I As-Built Team Inspection - March,1985: '

The purpose of this team inspection was to determine whether the systems, structures, and components selected 3

for review were constructed substantially in accordance l' with the descriptions provided in the Final Safety Analysis i

Report (FSAR) and NRC's Safety Evaluation Report (SER).

The inspection also included a comparison of the physical installation with engineering design documents (including i

piping and instrumentation drawings (P& ids) and the ap-plicant's plans for controlling plant configuration and operations during the startup and operational phases.

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'. System walkdowns were performed during which independent dimensional measurements were made. ,

j The "Seabrook Station Probabilistic Safety Assessment" '

j (SSPSA), PLG-0300 by Pickard, Lowe and Garrick, Inc. was reviewed to obtain the potential accident sequences that were significant contributors to core melt frequency and i

offsite risk. This information was used to select the l

systams and components for inspection. The final selec-j tion included Emergency Diesel 18 Emergency Diesel 18 l

Room Ventilation, Service Water Train 8, and Primary Com-ponent Cooling Water Train 8. Limiting the inspection to the "B" train of the selected systems allowed the in-

! spection to cover a greater depth. Other systems in-

! spected included the cooling tower and the reactor coolant

! j pump thermal barrier cooling system. l l

' In summary, all of the systems selected for review were found to have been built and operated in substantial agreement'with the Seabrook FSAR description and the pro-ject design documents. The two inspection findings which were identified related to material traceability and work J

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10 process control issues, and did not affect the accept-ability of the overall system design and construction.

All of the open inspection items from this as-built team inspection have been closed, except one which is currently under review by the Region I staff.

g. Region I Technical Specification (TS) Inspection - May, 1986:

NRC contractor personnel, with the direction of Region I inspectors, conducted an inspection of Seabrook Unit 1 to determine whether the draft Technical Specifications and the FSAR are compatible with the as-built plant con-figuration and operating characteristics and whether the draft TS are definitively measurable. The inspection was concentrated on plant systems, structures and components identified as having particular significance with respect to minimizing the severity of potential accidents and ac-cident consequences. The systems evaluated included:

containment and related support systems, containment spray systems, emergency core cooling systems (ECCS), soluble poison reactivity control (boration) systems, electrical power systems, and selected secondary plant systems and components.

At the time of the inspection, the draft TS consisted of the " Proof and Review" edition with final TS still under development by the licensee in conjunction with the NRC Office of NRR. Selected observations and findings, re-sulting from this team inspection, were a direct result of the " draft" nature of TS used in the inspection. The team concluded that information which is still under de-velopment for incorporation into the final TS and imple-menting procedures appears subjected to sufficient man-agement control to assure adequate completion of the in-corporation / revision process.

One overall conclusion of this inspection was that the TS and implementing procedures reviewed appeared to be compatible with the as-built plant configuration. How-ever, the inspection identified several TS inconsistencies.

The licensee has been working on resolving these incon-sistencies and correcting any procedural errors that may have resulted. Also, Region I has provided NRR, under separate correspondence, a list of those items determined to be TS inconsistencies as a result of this inspection.

Region I plans follow-up inspection activities to close each identified issue.

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11 3.2.3 Review of Construction Deficiencies To date at Seabrook, the licensee has submitted 103 Construc-tion Deficiency Reports (CDR). Of these, subsequent licensee evaluation determined that 17 items were not reportable and the applicable COR's were withdrawn.

The significant deficiencies reported cover a wide range of topics. Licensee sensitivity to reporting and their evaluation to the 10 CFR 50.55(e) criteria have been appropriately applied.

In mid-1983, some problems were encountered when final con-struction deficiency reports were issued to the NRC, For in-stance, when corrective actions outlined in the_ deficiency reports were reviewed by NRC inspectors, they found that some had not been implemented. In response to this problem, the licensee published new guidance on CDR evaluation, tracking, verification and formal report issuance to the NRC. One sig-nificant attribute of the licensee's new CDR policy involved the requirement for verification of corrective action by the QA organization prior to issuance of a final report to the NRC.

Since the initiation of this policy, corrective action on CORs has proceeded well.

Analysis of the CDR's for causal linkage, as is done routinely in conjunction with the NRC Systematic Assessment of Licensee Performance (SALP) reviews, revealed linkage of 21 items be-cause of A/E design errors. This CDR linkage was indicative of problems in the design and design change control area, as discussed in section 3.1.1 of this report. Region I management meetings with the licensee, in conjunction with Vendor Inspec-tion Branch meetings and inspections of UE&C, emphasized NRC concern in this area. As was discussed earlier, the establish-ment of a NHY Director of Engineering has since strengthened the design function. Also, the IDI team inspection identified

' no major weaknesses in the overall design program which would render the Seabrook design process suspect. In fact, the lic-ensee's reporting of design deficiencies has illustrated their program can identify and correct mistakes.

With regard to all of the reported CDRs, licensee corrective action has generally been timely. As of August 28, 1986, eight CDR's were outstanding, pending completion of licensee corrective action and NRC review. All of the outstanding CORs are expected to be closed or disposition will be reviewed by Region I prior to the initial criticality of Unit 1.

3.2.4 Third Party Audits and Evaluations Three INPO-sponsored evaluations of the construction of Seabrook Unit I have been conducted. The first was a Self-Initiated 4

Construction Project Evaluation (October / November, 1982) util-1 l

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l 12 izing an independent team of Northeast Utilities and Stone &

Webster engineers with the Performance Objectives and Criteria of Construction Project Evaluations developed by the Institute of Nuclear Power Operations (INPO) used as the basis for the evaluation.

The following two evaluations (October, 1983 and December, 1984) were conducted by INPO personnel at the Seabrook site and the UE&C design offices in Philadelphia, PA. The INP0 evaluation teams formed at those times examined the areas of organization and administration, design control, construction control, pro-ject support, training, quality, test control, maintenance, technical support, and industry operations experience at the Seabrook project.

A summary determination by INPO during the last construction evaluation indicated that the systems in place to control the quality of design and construction are being implemented ef-fectively. The Region I staff has been briefed on the INPO findings, including licensee responses and corrective action on the individual findings, and has discussed with licensee personnel whether certain findings met the reportability cri-teria of 10 CFR 50.55(e).

3.3 Quality Assurance for Construction The QA program for Seabrook Unit 1 construction is described in the Sea-brook Station PSAR and FSAR and has been implemented through the program and procedural controls dictated by the Seabrook Station Quality Assur-ance Manual. While PSNH has retained the overall responsibility for QA at Seabrook, it has delegated to the Yankee Atomic Electric Company (YAEC) the responsibility for the development, execution, and administration of the quality assurance program. This delineation of responsibility was not affected by the formation of the NHY division of PSNH in June, 1984.

Three levels of QA verification have always been a part of the QA program controls. The first level of quality control is provided by inspection by the contractors of their work and preventive maintenance and receipt inspection by the construction manager (UE&C). The second level of sur-veillance activities is provided by either the YAEC Field Quality Assur-ance Group on site or, in the case of civil / structural activities, by the UE&C Field QA Department. The third level of QA is provided by audits of the site programs conducted by independent YAEC auditors from the YAEC offices in Framingham, MA or by full time YAEC auditors sta-tioned on site. UE&C and Westinghouse (the NSSS supplier) also conduct audits of site organizations and are responsible for the vendor inspec-tion program of their suppliers. Each contractor is also periodically

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l audited by their respective corporate QA staffs. PSNH periodically con-ducts external audits of the YAEC QA program and participates in the conduct of YAEC internal audits of the same program.

Region I has monitored the licensee's construction QA program through the implementation of the routine and special inspections discussed earlier in this report.

The weaknesses discussed in section 3.1.1 were identified early in construction and the licensee took prompt and effec-tive corrective action. The steady improvement of the QA controls being implemented at Seabrook Unit 1 is tracked by the SALP process where the 1984 assessment noted that a " strong and stabilizing QA program exerted a positive influence upon project and construction controls at Seabrook Station". Likewise, the most recent SALP evaluation in May, 1986 recog-nized that "an effective QA program has been and is in place at Seabrook Station and continued management support continues to provide the neces-sary assurance of quality".

Enclosure 1 presents a Special Assessment of the Quality of Construction of Seabrook Station Unit 1, as provided by the licensee's QA organization.

The data provided have not been verified by-the NRC, but indicate QA ac-tivities and actions over the course of Unit 1 construction and testing.

3.4 Facility Construction Summary and Conclusion At 90% construction completion, over.15,000 inspection-hours had been expended evaluating the quality of construction at Seabrook Unit 1. The IE Inspection Program (Manual Chapter 2512) for the construction phase is essentially complete with only the Preservice/ Inservice Inspection and Spent Fuel Storage Rack Inspection modules deferred for later in-spection after license issuance. Numerous team inspections have been conducted at Seabrook with both IE CAT and IDI inspections supplementing the Region I routine and team inspection effort.

Based upon the large amount of inspection hours, the enforcement history (Section 6.0) for facility construction has indicated no major hardware problems. The highest severity level violation issued at Seabrook was a severity Level IV, while the most significant escalated enforcement action was the issuance of an Immediate Action Letter to confirm a lic-ensee stop work on pipe welding. Corrective actions by the licensee on other problems with the piping contractor have been confirmed to have been effective, as were corrective measures taken for early QA and design control problems.

Recent NRC team inspections of the plant and Technical Specification conformance to the plant have found that Seabrook Unit I has been con-structed in substantial accord with the FSAR and NRC requirements. NRC inspection over the course of construction, to include reviews and evaluation of the licensee QA program, has confirmed quality hardware and acceptable standards of construction.

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4.0 Facility Preoperational Testing  !

4.1 Overview and Status The preoperational test (PT) inspection program began in September, 1983 and is essentially complete. The program was conducted by both resident and region-based specialist inspectors. Inspections of test procedures, performance, and results were accomplished, along with an overview of management controls to verify proper implementation of the test program and the requisite involvement of the QA organization.

4.2 Inspection Program History and Findings The NRC preoperational testing inspection program (Appendix A to IE Manual Chapter 2513) is essentially complete with all mandatory tests witnessed and results reviewed, while the primal tests have received over three times the inspection effort required by MC 2513. Particular atten-tion was devoted to certain major integrated tests (hot functional test-ing, reactor coolant system hydrostatic test, the containment structural integrity and integrated leak rate tests). During conduct of these in-tegrated tests, region-based inspection teams, in conjunction with the resident inspectors, provided twenty-four hour sample coverage of the test while in progress. In total, over 3,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> have been expended in the Region I implementation of the preoperational testing program at Seabrook Unit 1. This total includes conduct of portions of the As-Built and Technical Specification team inspections, which were accomplished to compare the as-built plant to the FSAR description.

4 NRC review of selected test procedures indicated an acceptable level of technical adequacy. Witness of the tests confirmed that an adequately-staffed and qualified startup test group was in control of test conduct and that the QA staff was involved in test surveillance and QC activities.

Not more than 100 test exceptions were open at any given time during preoperational testing of Seabrook Unit 1. Some integrated tests (SIT

& ILRT) were successfully completed without a single test exception documented. Region I inspection of the PT test results has verified adequate action on the part of the licensee to close all test exceptions.

During the conduct of the month-long Hot Functional Test (HFT), some significant test exceptions were noted. A water hammer was experienced in the steam lines to the EFW Terry Turbine and other emergency feedwater (EFW) problems with recirculation and flow to the steam generator were experienced. As with the other test exceptions (e.g., main steam bypass and steam dump problems) which require the plant to be hot, system re-  ;

design and reanalysis was necessary. Six specific startup tests (ST) have been written by the licensee to validate system functionality for I the HFT test exceptions, with these ST's to be conducted during the post-core load HFT prior to initial criticality.

l I

15' NRC review of the licensee's preoperational testing progress has con-firmed an adequately managed program with quality test objectives being met and generally acceptable test results being acnieved.

4.3 Facility Preoperational Testing Summary and Conclusions As discussed earlier in this report, a minimal number of actual hardware problems were identified in the construction of Seabrook Unit 1. The good test results attained by the preoperational test program provide additional assurance of the adequacy of Unit 1 construction. Only two violations were issued against the preoperational area since the initi-ation of the preoperation inspection program in 1983. This is further corroborated by the two successive Category 1 SALP ratings (Section 7.0) assessed in the Preoperational Testing area by the last two SALP boards.

Overall a high level of performance was found to exist in the licensee's implementation of the testing program at Seabrook Unit 1. Where system redesign was necessary and further testing is required, further Region I follow-up inspection is planned during the Startup Testing phase.

5.0 Facility Preparations for Operations 5.1 Overview and Status Procedural preparations and validation continue and it is anticipated that all procedures required for a particular mode of operation will be approved and issued prior to the plant achieving the applicable mode.

Activities in preparation for initial fuel load were closely monitored by Region I. Facility staffing, personnel qualificatier.s training and procedure development, and implementation and establishment of operational organization interfaces have been reviewed. These reviews indicate that the licensee has an effective program in place to support the operational phase.

5. 2 Inspection Program History and Findings 5.2.1 Facility Operations - Staffing and Programs New Hampshire Yankee (NHY) will operate Seabrook Station. The Vice President of Nuclear Production located in the NHY Cor-porate Offices onsite, is responsible for corporate management of the station staff, nuclear training center, nuclear services, regulatory services, production services (startup), and emer-gency preparedness. At the station staff level, the Operations Manager, under the Station Manager, is responsible for managing, and controlling the operations department and assuring safe and efficient plant operation.

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16 i L

The licensee plans to operate Seabrook Unit I with six' shift-crews. Each shift will'be under the direction of a Shift s 1

. Superintendent (SS). Reporting to the SS will be a Unit-Shift 2

Supervisor (USS) who-will be in the control room. Either the. ,

i SS or the USS will. fulfill the shift technical advisor (STA) function. Additionally, several senior control room operators '

(SCR0s) and control: room operators.(CR0s) qualified as STAS.

' Both the SS and.USS hold SRO licenses. Also, in the control '

room on each shift will be a SCR0 and a CRO. While both of

' -these operators are required to hold reactor operator (RO) licenses, most of the SCRO's will. hold SR0 licenses. f0f the 38 licensed operators at Seabrook, 32 operators hold SRO lic-enses.

L A summary of the Seabrook operator license examinations is presented below. Of particular note is the high success rate (93%) of the Seabrook candidates who passed the examination on their first attempt.

1 Exam Week Results 1

September 17, 1984 11 SRO Candidates - 10. passed 2 R0 Candidates -

1 passed

, December 3, 1984 4 SRO Candidates -4 passed; 3 R0 Candidates -

3 passed-March 18, 1985 17 SRO Candidates - 16 passed (includes one SR0 retake) .

3 R0 Candidates - 3~ passed (includes one RO retake)-

4 September 30, 1985 _ 5 SRO Candidates - 5 passed (includes one SRO retake)-

These results reflect the us'e of a site-specific simulator, located onsite at.the nuclear training center which was com-missioned in November, 1980, and a generally effective licensed

~

operator training program. .The licensee +111 have at least one SRO per shift with.the required six months hot experience or an approved hot experience equivalency. Also,.a requalifi-cation program for licensed operators at.Seabrook is underway.

and is currently ~being maintained.

' In summary, the staffing and-training program for_Seabrook. '

Unit'l indicates the readinessLof the staff to safely operate l

, the' plant. Positive aspects which support this conclusion are:

the av'ailabilityLof'the plant-specific simulator, the perform-a ance of licensed operators, both from an examination standpoint, e

a

17 and from their performance in,the control room during testing in progress, and the program planned for six shift rotation, and continued training and qualification.

5.2.2 Quality Assurance for Operations The quality assurance for operations is described in Section 17.2 of the Seabrook Station FSAR. Based upon the staff review and as documented in the SER, the Seabrook QA program was de-termined to describe requirements,. procedures and controls that, when properly implemented, comply v;ith the requirements of 10 CFR 50, Appendix B. Also, the organizations-and persons performing QA functions appear to have the required indepen-2 dence and authority to effectively carry out the QA program.

Commencing in January,1986, Region I initiated several opera-tional readiness inspections at Seabrook Unit 1 to review, in part, the Operational QA Program structure and implementation in such diverse areas as administration, audits, procuren.ent control' receipt & storage, records, document control, main-tenance, design changes & modifications, test & measurement equipment, and surveillance testing. The inspection modules associated with these QA program activities are essentially-complete. No areas of concern were identified.

Also, a "Startup Quality Assurance Interface Agreement" between the licensee construction and operations program staffs has been implemented at Seabrook. This QA policy defines various organizational responsibilities and scopes the role of the Operational QA Program from the time of Conditional Acceptance Turnover of components, systems or structures to the initial fuel load of Seabrock Unit 1. The planning and coordination upon which this QA policy is based appears to have provided the necessary direction for QA controls during the transition from construction into operations. Overall, Region 1 inspec-tions into the operational preparedness phase of the Seabrook QA program have identified no substantive weaknesses.

5.2.3 Emercency Preparedness Facilities and Program The Seabrook Station Emergency Plan and Emergency Planning in general were evaluated by the staff during licensing reviews, documented in the Seabrook SER (March, 1983) and Supplements 1 (April, 1983) and 4'(May, 1986).

Region I has conducted two Emergency Preparedness Implementa-tion Appraisals (EPIA) at the Seabrook site, has witnessed the full scale exercise, graded by FEMA, in February, 1986, and has conducted several EP follow-up inspections. The first EPIA, initiated in December, 1985, had to be terminated prior

18 to completion because licensee equipment, training and proce-dures had not been sufficiently completed to allow full as-sessment of the EP program. Since that time and with the_ con-duct of the exercise, in which Region I management also parti-cipated, the licensee had made sufficient progress, such that the appraisal was completed in March, 1986. All but a few of the EP open inspection items have been closed by subsequent Region I review. The remaining open items must be completed prior to the issuance of a full power license, but are not required for the low power license.

The exercise on February 26, 1986 involved the utility and the state of New Hampshire. No major onsite deficiencies in the implementation of an adequate emergency response were identi-fied during the exercise. In general, personnel. involved in the exercise demonstrated a high level of training and knowl-edge of their response functions. Assessment of plant condi-tions and recommendations of protective actions for the public were timely and conservative. The EOF is of adequate size and functioned effectively with both the state of New Hampshire and a response team from NRC Region I participating in the exercise. Several deficiencies were identified by FEMA with offsite response by New Hampshire. These areas will be re-assessed in a subsequent exercise prior to consideration of full power license.

As documented in Supplement 4 to the Seabrook SER, prior to authorizing operation above 5% of rated power, the staff must provide an overall conclusion on offsite EP, in addition to onsite preparedness. For this determination, the findings made by FEMA on state and local emergency response plans must be considered. However, Region I concurs with the overall staff position that the emergency plan is adequate and can be ade-quately implemented for operation up to 5% power.

5.2.4. Radiological Controls and Fuel Receipt Region-based inspections have evaluated the licensee's chemis-try, environmental monitoring, health physics, radiation moni-toring and radioactive waste management programs and facilities.

Although not all testing of solid radwaste and HVAC systems it complete, completion of this work is not expected to impact fuel load or the commencement of low power testing.

In general, the Region I inspections of the above areas af-fecting radiological controls have revealed that adequate management control systems have been established. The inspec-tion items, opened to date, are being followed-up as appropriate 1

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19 to the operational milestone affected by their completion.

Systems necessary for the safe conduct of fuel load activities will be complete prior to Mode 6 in line with licensee commit-ments.

New fuel was received onsite during the period of February to May, 1986. Region I inspections routinely checked licensee fuel receipt and storage activities during that period in line with the Special Nuclear Materials License (SNM-1963) and with

. regard to radiological controls, DOT regulations, and the ade-quacy of operational procedures and operator training for. fuel movement. Overall licensee controls in this area were demon-strated to be effective.

5.2.5 Security-Facilities and Programs The staff has reviewed the Seabrook Physical Security Plan and regional-based security inspectors have conducted several site inspections, including two after the security plan was imple-mented for Unit 1 in May, 1986. Major portions of the plan were implemented then to allow the station personnel, particu-larly the security staff, to exercise the program prior to plant operations. The resident inspectors have also verified, on a sampling basis, implementation of the plan with respect to new fuel receipt, movement and storage. No major problems were identified during the security inspections.

The licensee has retained the services of an experienced con-tract security force (Green Mountain Security Services, Inc.).

This contractor is also employed at Yankee Rowe and Vermont Yankee. A NHY security supervisor is provided on each shift.

Station administrative procedures pertaining to plant security and specific implementation procedures have been approved and issued and were reviewed by regional inspection personnel.

Protected area controls, to include the erection of barriers with respect to Unit 2 access points into Unit I, have been implemented and were verified during Region I inspections.

The NRR/NMSS 10 CFR 73.55 confirmatory security site visit was conducted in February,1986. The licensee has implemented actions to address open items resulting from that visit, as well as those resulting from Region I security inspections.

No open items in the area of security controls or their imple-mentation currently exist to preclude issuance of low power license to PSNH.

5.2.6 Fire Protection Facilities and Programs In January, 1986 an audit team of Region I, NRR and contractor personnel conducted an inspection onsite at Seabrook Unit 1 4

of the licensee's efforts to comply with the requirements of

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I 10 CFR 50, Appendix R, concerning fire protection features to ensure the ability to achieve and maintain safe shutdown in the event of a fire. Only two unresolved items resulted from this audit, both of which were noted to be exemption requests by the licensee to the Office of NRR. These two items have been since closed with NRR concurrence.

As discussed in a memorandum from W. F. Kane, Director, DRP/RI, to T. M. Novak, Director, PA00/NRR, dated August 27, 1986, certain fire protection construction activities (e.g., fire doors, sealant, conduit wrap, cable tray cover installation, and fire damper testing) had not been completed at Seabrook Unit 1. Except for fire doors, this work has been completed.

While work on fire doors is progressing, it is not anticipated that this item will necessarily be finished at the time of license issuance. The licensee has indicated their intention to station fire watches to compensate for uncompleted activi-ties. We understand that NRR is considering removing fire pro-tection requirements from the improved technical specifications.

Therefore, as stated in the August 27, 1986 memorandum, Region I recommends that Section 2.F (formerly 2.C.4) of the draft license be evaluated to determine the completeness and enforce-ability of all fire protection requirements.

5.2.7 Technical Specifications The " proof and review" copy of the Seabrook Technical Specifi-cations was issued for comment in March, 1986. A general re-view of these TS, in conjunction with licensee suggestions for TS improvements, was conducted by Region I with comments sub-mitted to NRR on May 29, 1986. As is discussed in section 3.1.2g of this report, a TS team inspection, utilizing con-tractor personnel under the direction of Region I personnel, was conducted in May, 1986 to determine whether the TS are compatible with the FSAR and as-built plant. The results of that inspection indicate that adequate licensee controls exist to assure that final plant implementing procedures will reflect final TS requirements.

5.2.8 Third Party Audits and Evaluations During the weeks of January 20 and 27, 1986, INPO conducted an assistance visit to Seabrook Station to review site activi-ties and assist in the Unit 1 preparation for operation. Areas reviewed included station organization and administration, operations, maintenance, technical support, training and quali-fication, radiological protection, chemistry, emergency pre-paredness, and operating experience reviews. A follow-up cor-porate assistance visit to New Hampshire Yankee was conducted at the NHY corporate offices onsite the week of February 10,

21 1986. At an exit meeting on February 14, 1986, specific re-commendations, resulting from these INPO assistance visits, were presented to NHY management.

While Region I has not followed-up the INP0 recommendations, the licensee has indicated to Region I that they have evaluated and addressed each one.

5.3 Startup Test Program The licensee's Startup Test (ST) Program was first developed with the initiation of the preoperational testing program (Phase 1-3) and con-tinues with the ST Phases 4-6, which encompasses initial fuel loading, initial criticality and low power tests, and power ascension. All 50 Startup Test (ST) Procedures scoped by the Startup Test Abstracts in Chapter 14 of the Seabrook Station FSAR have been prepared, approved by the Station Operations Review Committee, and issued. An additional six ST's, written to govern further testing to close certain preoperational test program exceptions during post-fuel load hot functional testing are in varying levels of development and approval.

Region I has conducted initial inspections of the Startup Test Program and has found the overall program status, procedures, organization and staffing to be adequate. Controls appear to be in place for initial ft.el loading (Phase 4) and initial criticality and low power testing (Phase

5) to support licensee activities under the low power license.

6.0 Enforcement History The NRC inspection program uses enforcement measures to promote adherence to regulatory requirements, reduce repeated nonconformances, and encourage self-identification and correction of nonconformances. NRC enforcement measures, that is, Notices of Violations, have been issued when necessary. The appli-cant has been required to respond to these Notices of Violation and provide the proposed actions to correct the nonconforming conditions and to take ac-tions to prevent recurrence of similar violations.

NRC inspectors and management have reviewed and evaluated these responses for acceptability. The inspection staff confirms, during subsequent inspections, that corrective actions are properly completed. The following table gives a comparison of Seabrook Unit I enforcement statistics with those of two other plants at a similar point in construction. Early enforcement actions were classified as " violations", " infractions", and " deficiencies" (in descending order of severity) while the more recent reports contain violations categor-ized into severity levels ranging from I to VI (again, in descending order).

22 Below is an enforcement comparison through 90% construction completion:

FACILITY CPPR VIOL INF DEF I II III IV V VI TOTAL INSP HRS Seabrook 1 7/7/76 0 24 9 0 0 0 44 23 0 100 15,600 Hope Creek 11/4/74 0- 19 5 0 0 0 19 13 2 58 7,600 Millstone 3 8/9/74 0 2 2 0 0 0 24 25 1 54 9,100 In evaluating the NRC inspection enforcement history for Seabrook Unit 1, the total of 100 enforcement items is substantially higher than Hope Creek and Millstone 3. However, Seabrook Unit I had 15,600 inspection hours at 90% com-plete compared to less than half of that for Hope Creek. Thus, if comparison were done on the basis of enforcement actions per inspection hours, all three plants would be in the same range of ratios with Seabrook 1 in the middle.

From the standpoint of overall enforcement history, Seabrook 1 is considered an average plant in Region I.

What is more significant is the licensee's overall corrective action effec-tiveness in addressing problems in the areas of QA, design change control, piping and pipe supports and electrical installation, as discussed in Section 3.1.1 of this report. Particularly in the piping area, where an Immediate Action Letter was issued to confirm a licensee stop work order for contractor pipe repairs, the licensee has demonstrated adequate corrective measure im-plementation. This coupled with the determination that numerous NRC inspec-tions have identified relatively few hardware problems, is indicative of an overall high quality construction effort at Seabrook Unit 1.

7.0 Systematic Assessment of Licensee Performance (SALP) 7.1 Overview and Status Since the initiation of the SALP process by the NRC, licensee performance at Seabrook Unit I has been assessed seven times. Each assessment is summarized below:

7.2 First SALP Assessment Period: January 1 - December 31, 1980; SALP Board Date: Febru-ary 13, 1981; Licensee Meeting Date: March 12, 1984 Of the thirteen areas assessed, performance in the area of liner erection was found to be above average with nine other construction areas assessed average ratings and the areas of QA, safety-related structures and piping

& hangers rated below average. Of most significance in this first SALP were the identification of numerous QA problems related to the diverse nature of the numerous contractor programs and particularly with respect to the subpar performance of the piping and pipe support contractor.

Licensee corrective measures to improve the QA program were effective primarily because of the implementation of tighter YAEC controls. How-ever, as discussed in later SALPs, the piping contractor problems were not fully resolved.

23 7.3 Second SALP Assessment Period: July 1,1980 - June 30, 1981; SALP Board Date: Septem-ber 28,1981; Licensee Meeting Date: October 15, 1981 Eleven construction. areas were assessed with all but the foundations and training areas (Category 1) and the design and design change area (Cate-gory 3) receiving Category 2 ratings. Significant improvement was noted in the QA areas from the previous SALP and apparent improvement was also noted in the piping area. The major problem in this SALP was found in the area of design controls, where interfaces between the A/E and dif-ferent contractors were not being sufficiently monitored to properly translate quirements.

all design criteria into specific contractor procedural re-The licensee initiated corrective action in this area to have YAEC engineering personnel become more involved in the engineering and design change evaluations.

7.4 Third SALP Assessment Period: August 1, 1981 - July 31, 1982; SALP Board Date: Sep-tember 13, 1982; Licensee Meeting Date: September 29, 1982 A Category 1 evaluation was assessed in three construction areas - foun-dations, support systems and I&C systems. All six other construction areas, except piping, was assessed a Category 2 rating. In the area of piping systems & supports assessed as Category 3, the piping contractor (Pullman-Higgins) was found to be openly utilizing construction practices in conflict with UE&C specifications. This indicated a direct interface problem between UE&C and Pullman-Higgins for which the licensee initiated an audit of all contractor procedures. Organizational changes in the Pullman-Higgins site management organization were effected, Pullman cor-porate QA auditors were assigned to the site, and YAEC second and third level QA activities were increased. At this point, program effectiveness in this area was of concern to the NRC; however, major problems with hardware were not identified.

7.5 Fourth SALP Assessment Period: July 1, 1982 - June 30, 1983; SALP Board Date: August 8, 1983; Licensee Meeting Date: August 22, 1983 In this SALP, the three areas evaluated as Category I during the last assessment were again rated Category 1, with the additional area of con-tainment & safety-related structures also rated in this highest category.

Four additional construction areas were rated Category 2, with the piping area again rated Category 3. During this SALP period, the licensee had merged the piping activities under a joint UE&C/ Pullman-Higgins organi-zation and " learning curve" problems under the resultant system of con-trols were experienced. Additionally, a Region I Construction Assessment Team inspection had identified significant program weaknesses in this

24 area and the INP0 sponsored Self-Initiated Construct Project Evaluation noted the piping contractor's activities as the most significant area of weakness.

The licensee formed a Sepervisory Support Group dedicated to continuously monitor and evaluate the performance of the piping contractor. Also, the licensee issued stop work orders in specific work areas involving design change implementation by the piping contractor and containment piping penetration installation. To check the effectiveness of these

~ generic, and other specific, corrective measures, the NRC SALP Board directed that another SALP Board be convened in six months to further evaluate the performance in the piping area.

7.6 Fifth SALP Assessment Period: July 2 - December 31, 1983; SALP Board Date: February l 14, 1984; Licensee Meeting Date: March 9, 1984 r

A special SALP Board was convened to assess licensee performance in the piping and pipe supports area alone over the previous six-month period, because of continuing problems identified in that area. While a Category 3 rating was again assessed, improvements were noted over the course of the six-month assessment period. Construction quality was better; better engineering and erection controls were in evidence; and NRC identified hardware problems were minimal. In fact, some of the problems contri-buting to the Category 3 rating, resulted from the licensee's self-iden-tification of the concerns due to a more rigorous surveillance and audit program. Thus, while improvement was noted, additional licensee manage-4 ment attention was solicited to continue the improved trend. Also, an increased level of NRC activity was recommended to measure the total ef-fectiveness of the licensee's corrective action in the piping and pipe supports area.

7. 7 Sixth SALP Assessment Period: July 1, 1983 - December 31, 1984; SALP Board Date:

February 19, 1985; Licensee Meeting Date: March 21, 1985 Seven construction areas were evaluated during this SALP, in addition to assessments of Preoperational testing, operator licensing and plant licensing. Category 1 ratings were given in the areas of containment

& safety-related structures, auxiliary systems, quality programs & man-agement controls, preoperational testing and operator licensing. Three '

other construction areas and plant licensing were assessed as Category 2, while the electrical equipment & cables area was rated as a Category

3. In the piping systems & supports area (Category 2), licensee correc-tive measures implemented since the last SALP were evaluated and found to have produced positive results. Particularly after the reporting line from the piping contractor site QA manager was restructured more directly to the site Construction QA Manager and after New Hampshire Yankee was i

I

25 formed and became more involved in piping activities did the trend indi-cate marked improvement of construction controls in this area. Upper management appeared both attentive and responsive to past NRC concerns in this area and had taken the appropriate corrective measures, which were effective.

In the area of electrical equipment & cables, the Category 3 rating re-flected increased construction activity in this area along with apparent communications problems between the construction manager and the elec-trical contractor. It was noted that most of the identified problem in this area surfaced early in the assessment period, prior to the estab-lishment of the NHY organization. Management plans for corrective meas-ure implementation and the needed retrofit activities on hardware rework were already formulated and in progress. Increased NRC inspection re-sources was directed to confirm the effectiveness of the licensee actions.

7. 8 Seventh SALP Assessment Period: January 1, 1985 - March 31, 1986; SALP Board Date:

May 14, 1986; Licensee Meeting Date: June 10, 1986 During this SALP, all the separate construction activities were evaluated in one area, while the other assessed areas included preoperational testing, fire protection and housekeeping, operational readiness, emer-gency preparedness, the assurance of quality and ifcensing. All areas were rated Category 1 except emergency preparedness which was assessed as Category 2. This evaluation reflected not only continued improvement in the piping area, but effective corrective actions in the electrical area. Overall preoperational testing results were outstanding and the operational readiness area provided an indicator of licensee potential for continued performance at a high level during the operational phase.

8.0 Allegations 8.1 Overview and Status Over the course of construction and testing activities for Seabrook Unit 1, a total of 47 allegations were raised. Four allegations currently remain open, with two of these involved with the electrical records and QC controls and the third relating to painting of the polar crane inside containment. A fourth allegation, opened on Septen.her 22, 1986, involves a series of concerns raised by the Employees Legal Project of Amesbury, Massachusetts. These concerns were included in a letter from the Legal Project to Governor Dukakis requesting that he investigate these issues.

Many of the issues are general in nature, with several a repetition of previous allegations or events already resolved by the licensee and/or the NRC. Initial review of the open allegations has revealed no apparent impact upon the quality of plant hardware.

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26 8.2 Facility Allegation Resolution and Summary NRC inspection and investigation of the allegations that are closed re-vealed no significant hardware impact for the cases that were substanti-l ated. Followup of two allegations did result in the issuance of severity level IV and V violations respectively, but this enforcement action re-i lated to findings of improper process control and inadequate corrective action, rather than confirmation of any acts of willful wrongdoing.

The follow-up of two additional allegations are noteworthy in the amount of inspection effort expended not only by the NRC, but also by the lic-ensee in support of the investigation and in implementation of corrective action, as required. The first item, also reported by the licensee as '

a construction deficiency under 10 CFR 50.55(e) in 1983, involved the falsification of NDE records at Seabrook. Upon confirmation of the sus-pect nature of certain NDE examination performed by one technician, all 2,399 suspect items, both safety-related and nonsafety, were evaluated by the licensee. Over 1,300 NDE re-examinations were conducted. Inde-pendently, the NRC followed-up the licensee corrective action and con-ducted two separate NDE Independent Measurement inspections, utilizing

the Region I Mobile Nondestructive Examination Laboratory, on samples j

of the suspect welds. Additionally, the NRC Office of Investigations conducted an investigation into this allegation with the conclusion that NDE record falsification was substantiated, but that this falsification was an individual, isolated incident of wrongdoing by the subject tech-

nician, i

The other noteworthy allegation involved a diverse set of multiple alle-l gations anonymously communicated to Commissioner J. Asselstine. In order i

i to follow-up the stated concerns, a special, unannounced inspection by a region-based team of inspectors, and led by a Region I Branch Chief, '

, was conducted over a two-week period in 1984. This inspection involved 349 hours0.00404 days <br />0.0969 hours <br />5.770503e-4 weeks <br />1.327945e-4 months <br /> on site and identified no violations related to the allegation.  ;

In two specific areas the allegation was substantiated, but Region I '

inspection found that corrective action by the licensee had already been implemented.

In summary, extensive inspection and investigative effort on both of the above allegations, while substantiating certain of the stated concerns, also confirmed comprehensive and complete corrective measures on the part <

of the licensee.

8.3 Licensee Employee Allegation Resolution Program In February, 1985, the licensee established the Employee Allegation j Resolution (EAR) program at Seabrook Station to investigate, track and respond to allegations / concerns brought to their attention. NRC inter-face with the EAR program has provided both an independent verification I of programmatic actions taken by the licensee to address quality concerns, I

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27 and an effective means of utilizing the licensee inspection resources without compromising the conduct or results of the NRC investigation.

In three specific cases, the EAR program was called upon to investigate and respond to allegations received by the NRC. All three allegations i have been closed with no substantive findings and with independent NRC inspection corroborating both the EAR investigation results, and the im-plementation of corrective measures to avoid similar problematic situ-ations in the future.

9.0 10 CFR 50.57(c) Motion The licensee filed a motion pursuant to 10 CFR 50.57(c) before the ASLB on August 22, 1986, seeking authorization to load fuel and conduct precriticality testing with respect to Seabrook Station, Unit 1. In this motion the licensee indicated that special procedures would be in place to assure that the boron concentration does not go below 2000 ppm. Such procedures would consist of periodic sampling of the water in the reactor and makeup supply, sampling of the contents of makeup water to verify the concentration whenever water is added, and locking all valves which when opened could permit the entry of non-borated water into the reactor coolant system.

In a meeting with NRR on September 3, 1986 regarding this 50.57(c) request, Region I representatives discussed the need for licensee conditions to be im-posed. It was agreed that the verification of licensee implementation of their procedural controls to assure proper boron concentration in accordance with the license conditions would be a Region I inspection function.

In preparation for the required implementation inspections, the Region I resident inspectors initiated a review of the existing licensee special pro-cedures and drawings, marked up with a listing of the designated " locked valves." This initial review identified certain areas where the adequacy of the proposed licensee controls was questioned. It was noted that additional potential flow paths for diluted water would have to be analyzed, the Techni-cal Specification conditions less limiting than the license conditions would have to be addressed, and that additional administrative controls on the identified " locked valves" which could be opened during test conduct would have to be formulated. One concern common to these questions of procedural adequacy was the lack of understanding and delineation of the criteria used by the licensee in evaluating potential flow paths, locked valves, and affected routine procedural or test operations.

At a meeting between the licensee and the NRC staff on September 11, 1986, these questians and concerns were discussed and the licensee committed to conduct additional reviews of the affected systems, operations and procedures to predefine criteria, judged to adequately assure maintenance of the RCS boron concentration above 2000 ppm. These criteria, along with a modified unborated water source "Iocked valve" list and any other pertinent conditions, would then be transmitted by New Hampshire Yankee memorandum to the NRC Office of NRR.

28 At the conclusion of the licensee review, a telephone conference was held on September 16, 1986 in wh'ch the licensee review criteria and results were pre-sented to NRR. Si.bsequent discussions by the resident inspectors with the licensee have crofirmed that eight valves have been added to the " locked valve" list (note: one valve was also removed because of unnecessary redundancy).

The resident inspectors also discussed with the licensee the evaluation cri-teria, the frequency of the required surveillances, and impact on existing procedures and those which must still be revised, and the need for further administrative controls of conditions where the Technical Specifications are not conservative with respect to the 50.57(c) license conditions.

Further discussions between Region I and the licensee, based upon continuing inspection by the resident inspectors, are in progress. As of September 19, 1986, a sample inspection of the system drawings used by the licensee in their review, accomplished to criteria presented by the licensee to the Office of HRR, revealed no deficiencies or errors. Since special procedure issuance and/or revision has not been completed, the adequacy of such procedures will be the subject of continuing resident inspection. However, the resident in-

! spectors have discussed with the licensee a description of the process by which all af fected procedures will be controlled. No programmatic problems have been identified in this process.

Based upon the foregoing and the inspection process to date, Region I has reasonable assurance that the licensee has provided adequate controls, given the assumptions and criteria presented to NRR, to preclude boron dilution be-low 2000 ppm. Given the proper implementation of these controls, the timing of surveillance activities, and the margin of conservatism between the criti-cal boron concentration and the one required by the 50.57(c) license condi-1 tions, Region 1 believes that adequate assurances are or will be in place to preclude inadvertent criticality.

Inspections of the special affected procedures, as they are revised and become available, will continue in line with the routine regional and resident in-spection programs. Special inspections of those licensee controls intended to meet the proposed 50.57(c) license conditions will be conducted on a sample basis once the license is issued and operational activities conducted under this license commence.

10.0 Future Region 1 Actions Region I resident and specialist inspections will continue throughout the startup test program. Results evaluation will be closely monitored.

In the event a license is issued pursuant to the provisions of 10 CFR 50.57(c),

certain specific actions are anticipated. The licensee will implement special procedures to insure boron concentration remains greater than 2000 ppm to en-sure subcriticality is maintained. Region I residents, and specialists if needed, will evaluate implementation of these special procedures by: reviewing the status of locked and procedurally control valves, observing periodic samp-ling for boron concentration, and evaluating any other acticns which have the potential to impact on altering boron concentration.

29 A Readiness Assessment Team inspection is currently planned for near the end of the Power Ascension Test Program and prior to commercial operation. Such an assessment will be particularly significant because of the projected delay in issuance of a Full Power License. If such a delay should occur, resident and specialist inspections will continue to monitor licensed activities and the Readiness Assessment will verify that the Seabrook management, program, hardware and personnel are not adversely impacted by any periods of relative inactivity.

11.0 Justification for Interim Operation Generally, the licensee has prepared for submission to both Region I and NRR a list of incomplete construction and testing work, wnich could be categorized as items requiring justification for interim operation (i.e., "JI0s"). On this list, the scheduled completion milestone is delineated and is generally associated with a certain mode of operation, in which the affected equipment is required to be operable. Region I has evaluated the licensee review pro-cess which generated this JIO list and which links modal milestones to the incomplete work activities. While the basic concept as implemented by the licensee appears sound, any differences regarding which specific work must be completed prior to operating in a given mode will be resolved between Region I and the licensee on a case basis. With respect to licensing activi-ties, it is assumed that the submission of the JIO list by the licensee to NRR will satisfy the licensing need to determine which construction and test-ing activities are not fully completed and the licensee's justification where required.

12.0 Summary and Conclusions The NRC has expended over 20,000 inspection-hours, to date, at Seabrook Unit I to determine if the plant has been built in accordance with FSAR commitments and regulatory requirements and whether management direction was focused on quality. Over the course of the ten years of construction, the Itcensee has demonstrated not only a commitment to quality, but a real responsiveness to NRC concerns as they were identified. YAEC, as the agent for the licensee, has been a very strong and steadying force on the project during this time, particularly in the area of QA program implementation.

The establishment of the New Hampshire Yankee organization has reinforced the quality goals and provided a management structure which has retained re-sponsibility and accountability for getting work completed correctly the first time it's done.

NRC team inspections over the last year in the areas of NDE independent veri-fication, an al-built check of the plant, and a Technical Specification review confirmed that Unit I is a well-built plant, in accord with the design spect-fications. The overall theme of the most recent SALP is construction quality, with few identified hardware problems, and preoperational test results which verify these findings.

30 Where problems were identified by Region I, early in construction in the case of both QA and Design Change Control, corrective action by the licensee was effectively implemented, both with a strong measure of YAEC involvement.

While the piping problems were of a continued concern for a longer period of time, the impact of such problems on installed hardware was closely monitored and licensee management changes were able to reverse the negative performance trend. In not only the piping area, but also the electrical area where prob-lems were later identified, New Hampshire Yankee and its organizational ap-i proach to the issues from a generic standpoint demonstrated both a commitment to address NRC concerns and a capability to complete the construction of a quality nuclear plant.

Region I concludes that Seabrook Station, Unit I, has been constructed sub-stantially in accordance with Construction Permit CPPR-135, the Seabrook Sta-tion FSAR and NRC requirements. Certain construction and testing activities are still in progress and therefore Region I has recommended the appropriate license conditions. Considering the recommended license conditions, the overall Region I conclusion is that the licensee has taken all necessary ac-tions to permit issuance of a low power license.

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ENCLOSURE 1 SPECIAL ASSESSMENT OF THE QUALITY OF CONSTRUCTION OF SEABROOK STATION UNIT 1 (Note: The data in this enclosure has been compiled by the licensee's QA staff.

The writeup and information provided is essentially a licensee analysis and as-sessment. No effort was made by Region I to verify the data or information.)

The quality of Construction of Seabrook Station Unit 1 is predicated upon the fol-lowing:

1. Public Service Company of New Hampshire (PSNH) thru its New Hampshire Yankee Division and delegation to Yankee Atomic Electric Company (YAEC) Nuclear Ser-vices Division has and continues to employ a group of management, engineering, operations and support personnel who have valuable knowledge and experience in the design, construction, and operation of nuclear power plants. The ex-pertise and experience gained by these personnel have been utilized to the maximum extent in the design and construction of Seabrook Station. PSNH delegated to YAEC the responsibility for the development, execution, and ad-ministration of the Quality Assurance Program. The QA Program has been very effective throughout all phases of design, procurement, construction, startup, and preoperational testing.

2. Seabrook Station has received relatively few allegations'which is indicative of a positive attitude toward quality. Management involvement and support of quality as well as an effective QA program contribute to this attitude.

NRC investigations into concerns have not required actions beyond those taken i by the licensee in the normal course of business.

] 3. Region I headquarters personnel have expended considerable manhours of in-1 spection, evaluation, and independent verification time at the Seabrook Sta-tion. Inspections have been indepth, extensive in scope, have included special inspections, mobile laboratory involvement, and many other techniques.

The number of NRC inspections is summarized in Enclosure 3.

4. Special inspections / evaluations conducted at Seabrook Station are:

a. Regional Construction Assessment Team Safety Inspection (CAT); June 21 - July 2,1982.

No major areas of noncompliance or program weaknesses in design or construction,

b. Integrated Design Inspection, November 1 - December 21, 1983.

Overall design appeared to be adequately controlled.

. Enclosure 1 2

4

c. NRC Construction Appraisal Team Inspection (CAT); April 23 - May 4, May 14-25, 1984.

Minor technical deficiencies and program weaknesses resolvable with increased management communication and attention.

d. Construction Team Inspection; June 3-14, 1985.

Three noncompliances, three program strengths, three weaknesses.

4

e. Independent Measurements Inspection; July 15-26, 1985 (NRC Mobile Non-Destructive Examination (NDE) Laboratory.

Verification of the adequacy of welding, non-destructive examination and material analysis quality control program no violations noted.

f. As-Built Team Inspection; March 10-21, 1986.

Plant construction found to be in accordance with design and FSAR

" commitments, team commented additionally on the high. quality of the installation work.

! Seabrook Station did not receive any violations classified as Severity Level

III or above and no civil penalties were assessed.

! 5. The Quality Assurance / Quality Control organization for the Seabrook Station has exercised effective systems of control and assured quality of work at the site location and corporate offices. Inspections performed by the NRC, the

' Applicant's Quality Organization or other agencies have not identified condi-tions which have required total reinspection or reverification programs.

Seabrook Station's Construction Quality Assurance Program is predicated on the philosophy of prevention, planning, early detections, organizational co-operation, and team work. Senior management support of QA has always been a project strong point. The effective control of quality has been demon-strated by the Seabrook Construction Quality Assurance Organization's approval authority for all safety related QA/QC and work procedures. These QA reviews and approvals contributed to programmatic controls and practices which assure that work is performed correctly the first time. The Construction QA organi-zation at Seabrook has identified problems early in the fabrication and in-sta11ation processes and has achieved timely and positive corrective action.

, i

6. The Seabrook Station Quality Assurance Program is reviewed by YAEC QAD at least annually to assure that it is kept current. YAEC performs audits on WRD and UE&C to assure that their programs are kept up to date and effective.

The YAEC program for quality assurance normally involves three control levels:

Level 1 - Quality Control by vendors, constructors, and UE&C on the activities they perform, by YAEC on startup activities. This includes reviews, inspec-tions, and tests.

i

)

Enclosure 1 3 Level 2 - Surveillance of design, fabrication, and construction activities,

'1 including Level I Quality Control. Contractors provide this level for the design and procurement phases. UE&C and YNSD provide additional surveillance on site construction activities.

Level 3 - Audits by YAEC 1}4 Department of activities performed by Level 1 and 2 organizations.

7. The Construction QA Program at Seabrook is also subject to review and verifi-cation of independent organizations.

a. The American Society of Mechanical Engineers (ASME)

b. National Board of Boiler and Pressure Vessel Inspectors

c. Lumbermens Mutual Casualty Company

d. Institute of Nuclear Power Operation (INPO)

e. Public Service Company of New Hampshire Management Audits

f. American Nuclear Insurers

8. The Construction QA organization at Seabrook has the authority to stop work independent of the construction and engineering organizations. This stop work authority was invoked 33 times during the course of construction. The fol-1 lowing summarizes stop work actions initiated by the Seabrook Construction i

QA organization.

Year Description Remarks 1986 None.

?

1985 Hanger installations performed to Hanger drawings withdrawn and

' drawings without required Engi- submitted for required approval.

neering approval.

1984 Safety related and associated All safety related and associated

' cables pulled in trays containing cable pulling stopped. Cable debris, trays cleaned of debris and in-stalled cables reinspected. Site-wide directives issued on tray cleanliness.

1984 Work proceded on an item without Work stopped until NCR disposi-an approved disposition to an NCR. tioned and approved.

I

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

.Enciesure 1 4 Year Description Remarks 1984 Adequate interface lacking be- Cable pulling stopped. Trays tween UE&C and site contractors cleaned and debris removed. All '

for maintaining tray cleanliness. contractors were reminded of their l responsibility for cleaning up their materials.

1984 Required procedures not issued and QA procedures issued for safety QA staff not adequate, related activities. Staff in-creased to provide adequate QA coverage.

1983 Hilti bolt installations not per All work on Hilti bolts stopped, procedure, and involved personnel reindoc-trinated. j 1983 Installation / fabrication packages I/F packages placed on hold until

' for metal bellows flex hose lack- insertion of appropriate criteria ing criteria. in the packages.

I 1983 Plastice mixing operations for Engineering evaluation of plastice safety related areas not properly mixing indicated that the opera-controlled, tion was not safety related.

1983 Material storage areas and mate- Movement in and out of storage -

i rial status indicators. areas restricted. A SWO was issued allowing'only withdrawal of properly identified material from storage. SWO was clotea based on QA evaluation of storage 2

4 i

areas, 1983 Wrong welding procedure specifi- Specific lists of piping IO's

' cation referenced on certain pip- required review and correct.lon ing ISO's. to the proper weld procedure i

specification.

l 1983 Installation of non-safety related Procedure revised to require QC associated cables in nuclear inspections of associated cables.

l island not QC inspected. L t

1983 Sodium hydroxide, PVC solvent Use of sodium hydroxide, PVC

{ cement, and epoxy white enamel solvent cement, and epoxy white with expired shelf life, enamel stopped. Inventory of j all items with shelf life expira-4 tion dates required to be per-formed on monthly basis by QC, i

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. Enclosure 1 5 I

i Year Description Remarks '

t 1983 Non-safety detail use for safety

~

Engineering approved detail for related installations, safety related installations.  !

Training conducted for Engineer- ,

j ing, Construction Supervisica, '

and Quality Control Personnel. .

2 1983 QC inspection deficiencies of low QC inspector retrained. All af-i chloride fireproofing, facted application areas placed i

on hold.

1983 Affected documents not listed on Site engineering personnel re-

, On-The-Spot ECAs. trained. An evaluation of pre-viously issued OTS ECAs performed I to evaluate affected documents.

i 1983 Listing of ECAs on controlled Stop work on all safety related i drawings not per procedure. (piping and supports) work. Ex-1 sting drawings updated. Indoc- ,

l trinated and trained personnel '

1 to procedural requirements.

i 1982 Reinspection and retrofit program Revised procedures to include

' proceeding without approved pro- scope of work and provide in-cedures and inspection documenta- spection forms, tion forms.

I 1982 Implementation program failed to Procedures revised to address j address limited access welding,  !

site position on limited access t a welding, ,

'. 1982 Anchor bolt installation without coreboring procedure, Procedure revised to include  !

coreboring criteria and inspec-tions.

1981 Welding electrode portable ovens Welding procedures updated and not plugged in, welding personnel retrained.

1981 Plug welding of frames without Containment interior plug repairs l use of Weld Data Cards, weld mapped. Field welds as-

!i built. Weld data cards made up for new welds.

1981 TS bolt tensioning / installation. Construction personnel retrained in bolting procedures, i

! 1981 Cadweld tensile test results below Cadweld operator's records re-i minimum. l l viewed and additional testing  ;

performed. l j r i

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Enclosuro 1 6

_ Year Description Remarks 3

1981 Safety related installation of ECA issued to more strictly con- ,

Hilti-Kwik bolts, trol installation and provide margins of safety in torque values. Contractors to retorque all installed Hilti Kwik bolts.

! 1981 Tray splice bolts not certified. Bolt certification for NI and l

MP 5 bolts received from supplier and found acceptable.

1981 Project specification require- Procedure revised to include ments not incorporated into pro- requirements of Project speci-cedure for weld material control. fication.

1981 Weld repair cycles not controlled Procedures revised to include in accordance with Project speci- requirementsofProjectspeci-fication, l fication. ~

1980 Tightening of high strength bolts. All structural tron workers were '

retrained in bolting procedures.

1980 Weld joints for attachment of Engineering revised detail to ,

support channels to anchor bolts provide backing plate to conform '

not in conformance with prequali- withprequalifiedjointdetail, fleid weld joint detail.

1980 Cadweld splices accepted with Affected cadweld splices visually packing material remaining, reinspected. Additional splices -

removed and tested.

1980 P-H repair welding of ASME Sec- Welding procedure revised. Weld- '

tion !!! and safety related work, ing personnel retrained.

1979 Mechanical equipment erection Procedures developed and approved '

without approved procedures, to include these activities.

1978 Rebar installation continued in Work stopped until affected NCRs area that was on hold, were closed. Construction com-l mitted to follow QA program.  ;

l 1977 None.

1976 None.

1975 None.

1974 None.

.Enclosuro 1 7 i

9. The YAEC Construction Quality Assurance organization has conducted audits of i the design and procurement activities performed by Westinghouse (NSSS) and United Engineers and Constructors (AE) as well as audits of YAEC's design, procurement, and review activities. Technical specialists from various dis-t ciplines were assigned to the audit teams, where warranted, to assure techni-l cal aspects of the audit process were reviewed in depth. A summary of the j results of these audits is as follows

! UE&C H.O. No of Audits No. of Items l

1973 2 5 1974 15 67 1975 10 29 1976 6 41 1977 2 17 1978 2 24 1979 2 14 1980 3 74 1981 5 33 1982 5 23 1983 4 39 1984 4 37 1985 5 31 1986 5 5 TOTALS 70 439 Westinchouse No. of Audits No. of items 1973 2 1 1974 6 38 1975 4 24 1976 9 25 1977 6 8 1978 b 11 1979 10 11 1980 15 11 1981 8 3 1982 2 0 1983 5 10 1984 5 2 i 1985 3 6 1

1986 j j TOTALS 81 152 I

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. Enclosure 1 8 l

Internal No. of Audits No. of Items 1974 10 31

! 1975 8 1 i

1976 10 8 1977 15 24 1978 15 22 '

1979 15 24 1980 12 21 1981 15 41 1982 13 34 1983 13 61 1984 14 32 1985 8 28 i 1986 28

__4 TOTALS 152 355

10. The YAEC Construction QA organization has an onsite staff of Quality Assurance  ;

Engineers which conducted routine onsite audits and surveillances of construc- I tion and engineering activities. A summary of the results of these audits and surveillances is as follows:

Year No. of Surveillances No. of Items 1976 6 29 1977 36 52 1978 102 16 1979 183 87 1980 326 86 1981 831 '361 .

1982 2210 1066 1983 2543 1452 1984 1486 881 1985 2726 628 1986 1229 248 TOTALS 11,678 4906 i

t i

Enclosure 1 9 Year No. of Audits No. of Items 1973 4 0 1974 13 14 1975 5 4 1976 34 7 1977 46 36 1978 71 71 1979 68 159 1980 121 95 1981 102 142 1982 85 228 1983 94 338 1984 73 326 1985 92 337 1986 33 94 TOTALS 841 1851 i

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ENCLOSURE 2

SUMMARY

OF SALP EVALUATIONS Ratina (for period ending)

Functional Area 12/80 6/81 7/82 6/83 12/83 12/84 3/86

1. Substructure / Soils and

Foundations Avg. I 1 1 --

1 --

2. Piping Systems and Supports Below 2 3 3 3** 2 --

Avg.

3. Safety Related Components Avg. 2 2 2 --

2 --

4. Support / Auxiliary Systems

! (Including HVAC & Fire ,

i Protection) -- --

1 1 --

1 --

5. Electrical Power Supply

' and Distribution Avg. 2 2 2 --

3 --

6. Electrical (tray and wire) Avg. -- -- -- -- -- --

7. Instrument and Controls -- --

1 1 --

2 --

8. Licensing Activities -- --

2 2 --

2 1

! 9. Containment Liner /

I Structures Avg. 2 2 1 --

1 --

i 10. Safety Related Structures Avg. 2 * * -- * --

1 11. Project Management Effec-l tiveness -- --

2 -- -- -- --

l 12. Properational Testing -- -- -- -- --

1 1 j 13. Quality Assurance / Control Below 2 -- -- -- -- --

1 Avg.

14. Quality Programs and j Management Controls -- -- -- -- --

1 --

15. Operational Readiness 2

(Operator Licensing) -- -- -- -- --

1 --

) 16. Reporting / Corrective i Actions Avg. --

2 2 -- -- --

17. Design and Design Changes --

3 -- -- -- -- --

, 18. Procurement --

2 -- -- -- -- --

. 19. Training Avg. 1 -- -- -- -- --

l 20. Environmental Avg. -- -- -- -- -- --

21. Management Avg. -- -- -- -- -- --

j 22. Concrete Avg. -- -- -- -- -- --

23. Construction -- -- --

j 24. Fire Protection and 1***

i Housekeeping Avg, -- -- -- -- --

1

25. Operational Readiness -- -- -- -- -- --

1

26. Emergency Preparedness -- -- -- -- -- --

2 j 27. Assurance of Quality -- - -- -- - --

1 1

4 Notest

• Functional area not evaluated or no basis for assessment.

! Functional area 10 combined with functional area 9 for evaluation purposes.

Special assessment of only functional area 2.

• • • Functional area 23 is a combination of areas previously reported separately.

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ENCLOSURE 3 INSPECTION PROGRAM I

3 ANNUAL BREAKDOWN (HOURS)

Year Reports Construction Preops. Startup Operations J

Total 1973 1 3 -- -- -- 8 3

i j 1974 5 100 -- -- --

100*

1975 2 11 --

J 11' l 1976 6 54 -- -- --

54  !

i 1977 10 101 -- -- --

1 101 1978 16 523 -- -- --

i 523

1979 10 281 -- -- --

281 1980 13 621 -- -- --

621

l j 1981 14 859 10 -- --

869 F 1

j 1982 16 1560 3 -- --

1563 1983 b l 13 4049 47 -- -- b 4096 1984 C 20 4471 123 -- -- c t

4594 1985 d 34 2879 1829' 12 22 d

i 4742 I

1986 41 _1182 4090 100 i

280 56529 TOTALS 201 16694 6102 112 302 23210 3

Notes: '

I a

Estimated hours - no record of actual hours.

b i Includes an estimated 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> for integrated design inspection.

{ Includes an estimated 2500 hours0.0289 days <br />0.694 hours <br />0.00413 weeks <br />9.5125e-4 months <br /> for construction appraisal team inspection.

d i Includes 567 hours0.00656 days <br />0.158 hours <br />9.375e-4 weeks <br />2.157435e-4 months <br /> for construction team inspection and 654 hours0.00757 days <br />0.182 hours <br />0.00108 weeks <br />2.48847e-4 months <br /> for inde-

pendent measurements inspection.

)

Includes an estimated 340 hours0.00394 days <br />0.0944 hours <br />5.621693e-4 weeks <br />1.2937e-4 months <br /> for emergency preparedness implementation

, appraisal.

I Through June 30, 1986.

I j 9 Includes an estimated 230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> for Appendix R inspection, 637 hours0.00737 days <br />0.177 hours <br />0.00105 weeks <br />2.423785e-4 months <br /> for as-1 built team inspection, and 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> for Technical Specifications inspection, i

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ENCLOSURE 4 INSPECTION

SUMMARY

Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 73-01 3/6/73 Initial management meeting. None.

i 1

74-01 1/7-8/74 Contractor (UE&C) QA piogram None, but several major i

1/10/74 planning and implementation. deficiencies with 10 l 4 CFR 50, Appendix B requirements.

74-02 2/26-27/74 QA program implementation. None, but several 10 2 CFR 50, Appendix B

, deficiencies.

74-03 4/29-5/2/74 QA program implementation. None, but consolidated 2 10 CFR 50, Appendix B deficiencies.

74-04 7/10-12/74 QA program implementation. None.

1

+74-05 10/30-31/74 QA program implementation. None.

l 11/6/74 3

I 75-01 3/4-5/75 Management audit and QA pro- None.

I gram implementation.

75-02 9/11/75 QA program implementation. None.

1 i 76-01 5/4/76 Management meeting and on- None.

I site activities.

76-02 7/14-15/76 Site clearing activities, None.

I QA/QC staff, construction drawings and specifications, t

management audits.

76-03 8/2-4/76 QA/QC implementing proce- None.

2 dures for site preparation and foundation / structural l concrete work, i 76-04 9/15-16/76 Environmental protection None. l 1 program for construction.

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Enclosure 4 2 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions 76-05 10/27-28/76 Impact of construction acti- One deficiency: failure 2 vities on environment. to control turbidity of dewatering effluents.

76-06 12/13-15/76 Contractor QA plans, work None.

1 procedures for concrete and reinforcing steel work.

77-01 2/15/77 Containment area evacuation None.

I status, storage facilities, and storage material.

77-02 4/13-14/77 Environmental protection One deficiency: failure 1 program implementation to perform turbidity (construction phase). measurements of site effluent.

77-03 7/6-8/77 QA procedures and records None.

I for storage and storage maintenance of safety re-lated components, plant tour / inspection.

77-04 7/26-27/77 QA procedures for receiving None.

2 and storage of reactor pres-sure vessel, preparations to unload vessel, and vessel post-hydro test verification.

77-05 8/2/77 Reactor vessel receiving and None.

I transportation to interim /

long-term storage.

77-06 8/26/77 Site preparation and place- None.

I ment of fill concrete in floor of service water trench.

77-07 10/3-4/77 Placement of fill concrete None.

2 at reactor containment area, l site dewatering and runoff  !

water control, storage of reactor vessel.

77-08 10/31/77 Site excavation work activi- None.

I ties and construction water effluent turbidity control.

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Enclosure 4 3 1'

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Inspection Dates / Number- Inspection Enforcement Number of Inspectors Areas Actions j 77-09 12/1-2/77 Environmental protection One deficiency: failure 1 programs (construction). to control effluent turbidity.

77-10 12/5-9/77 Preparatory activities _and None.

12/14/77 QA/QC procedures for concrete 2 and rebar, observations of '

concrete batch plants, con-crete ingredients storage facilities, laboratory test

, facilities, and rebar lay-down areas.

78-01 ' 1/16-18/78 Construction work in pro- One infraction: failure 2 gress, containment liner and to properly control access penetrations proce- master drawing rack dures, field welding on ser- stick files.

vice water piping, cadweld-ing and offsite equipment storage.

78-02 2/14-17/78 _ Foundation preparation and None.

2 rebar installation; geologic '

mapping and approval of rock, i

records of concrete mixing, fill concrete placement, in-spection personnel qualifica-tions, audit reports on con-crete activities.

78-03 2/21-24/78 Sand-cement mix procedures, None.

4 quality assurance programs and procedures for subcon- 6 contractors on testing, str'uctural steel, contain- i

, ment liner and penetrations.

78-04 3/6/78 Surveillance and nondestruc- None.

I tive examination records on underground piping.

78-05 3/20-24/78 Containment concrete base mat One deficiency: failure 1 placement, safety related to comply with 10 CFR components storage and hand- Part 21 posting re- 1 ling procedures, site prepar quirements. 1 lationsblasting records, and l 4 . posting of 10 CFR Part 21. '

% l T 3

. Enclosure 4 4 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 78-06 4/19-21/78 Environmental protection Two deficiencies:

1 programs (construction). Failure to control runoff water turbidity.

t Failure to maintain acceptable drainage patterns at the hemlock ravine vegetation area.

78-07 4/24-28/78 Site preparation records and None.

2 work in progress, foundation records, and containment liner fabrication.

78-08 5/22-25/78 Work activities on contain- None.

1 ment liner fabrication and-installation, concrete place-ment, and licensee action on Bulletins and Circulars.

78-09 6/26-28/78 Concrete placements, con- None.

2 tainment steel fabrication activities, electrode con-trol, and welder and proce-

-dure qualification.

78-10 7/10-14/78 Preparations, QC and con- None.

I crete placement activities '

for the reactor pit struc-ture walls, and rebar instal-lation and cadwelding for the reactor base mat.

78-11 7/21-27/78 Compliance with NRC 6/30/78 None.

1 Order to suspend the con-struction permit effective 7/21/78.

78-12 7/26-8/11/78 Investigation of complaints None.

2 concerning blasting and-other unauthorized work j after construction permit  !

suspended.  !

78-13 9/5-8/78 Piping contractor's QA pro- None.

1 gram, installation of con-tainment reinforcing steel.

1

. Enclosure 4 5 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions 78-14 10/2-6/78 Piping contractor's QA pro- None.

3 gram and work procedures,

. welding of containment liner plate.

78-15 11/6-9/78 Procedures and work activi- None'.

4 ties for safety related piping and components, con-tainment concrete placement activities.

78-16 12/12-15/78 Work in construction area 2

One infraction: failure and material storage area; to control material implementing procedures for storage.

safety related structures and supports.

79-01 1/15-18/79 Work in construction area, None.

3 reactor pressure vessel un-loading and handling proce-dures, concrete placement records.

79-02 1/24-25/79 Investigation of allegation None.

1 that frozen water present on previously placed concrete prior to subsequent concrete placement.

79-03 2/12-15/79 Reactor pressure vessel None.

2 handling load test, elec-trical QA program and pro-cedures.

79-04 3/12-13/79 Construction activities in- None.

2 cluding piping alignment, rebar installation, cadweld-ing, liner plate welding, concrete curing and finish-ing.

i 1

Enclosure 4 6 Inspection Dates / Number Inspection Number of Inspectors Enforcement Areas Actions 79-05 4/3-4/79 Construction activities in- One infraction: failure 2 cluding stripping forms in to electrically con-equipment vault, dewatering nect stored equipment containment for liner plate supplied with space installation, weld prepara- heaters.

tion on containment liner, and concrete compression strength testing, mainten-ance of material stored offsite.

79-06 5/21-25/79 Work activities and records 2

Three infractions:

for concrete, containment, Failure to follow and safety related piping; welding procedures.

and document control.

Failure to control access to warehouses.

> Failure to follow document control ~ pro-cedures.

79-07 8/13-16/79 Construction activities in- Four infractions:

2 cluding containment building Failure to reject un-liner offstand welding and acceptable void in inplace welding of erected cadweld splice.

rings, vacuum testing of liner welds, liner stud Failure to provide de-welding, rebar installation tails in Perini pro-and cadwelding for exterior cedure for major re-wall and interior columns, pairs in concrete, soil backfill compaction and testing, laboratory testing Failure to provide of concrete cylinders and criteria in procedure qualification testing of the for storage of con-new iron workers in cadweld tainment equipment.

splicing; and review of QA surveillance reports. Failure to issue a deficiency report for deficient items un-covered during sur-veillance.

l Enclosure 4 7 )

l Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 79-08 9/4-7/79 QA program for various or- Two infractions:

4 ganizations involved with Failure to provide

.Seabrook Station. details in YAEC pro-cedure for reaudit of open items.

Failure to provide details in UE&C sur-veillance QA procedure for when to verify that prompt corrective ac-tion was taken.

79-09 11/13-16/79 Work activities, record re- One infraction: failure 2 views, welding and nonde- to prescribe corrective structive tests on primary actions by Perini and containment; nonconformance UE&C to preclude place-and disposition reports in ment of concrete until concrete and rebar for all reinforcing steel safety related structures; identified in design and concrete curing. and detail drawing has been installed.

79-10 12/11-13/79 Rebar installation and con- None.

3 tainment liner welding acti-vities, field drawing con-trol, condition of erected structural steel and stain-less steel pipe stored on flatbed trailer, and elec-trical specifications and procedures.

80-01 1/22-25/80 Cadwelding splicing, con- None.

2 crete preplacement and cur-ing activities, equipment maintenance and storage, weld rod control, and in-quiry regarding drug indict-ments of Seabrook construc-tion workers.

80-02 2/6/80 Management meeting to dis- None.

1 cuss establishment of onsite office for full-time NRC in-spector.

Enclosure 4 8 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions 80-03 2/26-28/80 Construction activities in-1 Two infractions:

ciuding temporary storage of Failure to conduct

-material supplies within a required stud _ weld-containment, stainless steel ing inspection, welding and weld rod con-trols, and stud welding pro- Failure to control cedures and controls. changes to assure re-vision of affected contractor procedures.

80 4/14-17/80 Pipe welding controls, cad- One infraction: failure 3 weld reinspection program to provide sequence and corrective action, and for examination of pipe construction activities in- weld repairs to assure cluding containment interior code compliance.

shield walls and exterior building walls reinforcing steel installation and cad-weld splicing, preparations for concrete placement of PAB walls, cold weather protec-tion and curing of control building walls and cadweld splice reinspections.

80-05 5/5-7/80 Environmental protection 1

One infraction: Inade-programs (construction quate environmental phase). control program.

1 Two deficiencies:

i Failure to control dewatering water turbidity.

Exceeding construction permit turbidity dis-charge limit.

80-06 5/19-6/27/80 Containment concrete place-2 One infraction: failure ment, pipe and pipe support to provide appropriate welding, installation of criteria for inspection electrical embedded items of equipment grouting.

and raceway supports and safety related component installation.

i

. Enclosure 4 9 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions 80-07 6/30-8/1/80 Containment and safety re- One infraction: failure lated concrete; safety re- to initiate noncon-

. lated pipe welding, NDE and formance report and support installation; RPV review and disposition internals storage; and stud weld nonconformin safety related steel tension conditions per proce g set bolting and embed in- dural requirements.

stallation.

80-08 7/3/80 Management meeting to dis- None.

I cuss Seabrook construction status, resident inspection program, NRC programs for SALP and independent meas-urements, 50.55(e) report-ing, current NRC enforcement policy, and Seabrook QA pro-gram and implementation.

80-09 8/4-9/5/80 Piping erection, pipe and None.

1 pipe support welding, struc-tural steel erection, compon-ent support welding, and com-ponent storage.

80-10 9/8-10/10/80 Pipe and pipe support erec-1 Two infractions:

tion and welding, structural Failure to install pipe steel erection and welding, support welds in ac-and purchased material cordance with draw-status and records. ings.

Failure to assure that purchased structural steel conforms to the i code requirements specified in procure- l ment documents. l 80-11 9/16-19/80 Containment liner welding, 2

Two infractions safety related pipe welding, Missing inspection and storage of components. sequences on field weld repair process sheets.

Failure to comply with requirements when mak-ing a weld repair of piping.

1

_ 10 Inspection Dates / Number Inspection Number of Inspectors Enforcement Areas Actions 80-11 One deficiency: failure (CONTINUED) to comply with proce-dures when welding on paint.

80-12 10/13-11/21/80 Pipe and pipe support erec- One infraction: failure 3 tion and welding, electrical to perform pipe base duct bank construction and metal repair welding cable tray erection, concrete and final NDE in ac-batch plant operation and cordance with ASME records, anchor bolt instal- and specification re-lation, and investigation quirements.

into concerns about improper site testing practices.

80-13 11/24-12/31/80 Containment internal con- One violation: failure 1 crete placement and liner to control and document wind girder removal, polar engineering review and crane rail installation and approval of a field NDE, piping operations and initiated design change NDE, Kwik-bolt installation (Level V, Supplement and system design considera- II).

tions for electrical work, audit of licensee evaluation program for 10 CFR 50.55(e) reportability.

81-01 1/2-30/81 Safety related components Two' violations:

3 work activities, RPV inter- Failure to include i nals, structural steel and appropriate weld ac-polar crane rail welding and ceptance criteria in rail repair, and pipe support the field hanger draw- j welding. ing change (Level IV, Supplement II).

Failure to follow pro- i cedure in acceptance I of undersized fillet weld (Level V, Supple-ment II).

81-02 2/2-27/81 Pipe welding and support 2

One violation: failure erection, embed installation to perform magnetic and structural steel erec- particle examination tion, and component mainten- on threaded anchor ance and installation. bolts as required by specification (Level V, Supplement II).

Enclosure 4 11-Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 81-03 3/2-4/81 Pipe welding and support Two violations:

1 erection, structural steel Failure to control

. welding and erection, NSSS structural bolting support installation, equip- and welding to code ment storage and maintenance, and procedural re-and component conformance quirements (Level IV, and seismic qualification. IV, Supplement II).

Failure to provide weld length criteria for pipe support in-stallation prior to welding (Level V, Sup-piement II).

81-04 3/12/81 Management meeting to dis- N/A.

cuss SALP bnard results of licensee's performance of 1/1/80-12/31/80.

81-05 4/6-5/8/81 Structrual steel erection Two violations:

1 and welding, pipe welding Failure to consider and support erection, equip- specification and code ment support installation requirements for weld and component installation. ISI in the approval of a pipe support in-stallation (Level V, Supplement II).

Failure to utilize a properly qualified weld procedure for welding a flued head to a con-tainment penetration sleeve (Level IV, Sup-plement II).

81-06 5/11-15/81 Weld metal repairs and non- None.

1 destructive examinations by pipe fabricator, storage of material and moving of No. 3 steam generator.

81-07 5/26-6/26/81 Pipe and pipe support weld-_ One violation: failure ing, pipe storage, electrical to install properly supports and components, and supported electrical Part 21 diesel generator boxes within contain-problems. ment (Level V, Supple-ment II).

Enclosure 4 12 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions 81-08 6/29-8/21/81 Pipe and pipe support weld- None.

2 ing; RPV and other NSSS com-

.ponents, design considera-tions for pipe and electrical cable routing, and miscellane-ous structural connections and QA.

81-09 8/24-10/2/81 Pipe and pipe support instal- Two violations:

1 lation, NSSS supports, con- Failure to install tainment structural connec- adequate structural tions, electrical raceway support welds (Level support inspection and tray IV, Supplement II).

qualification, and contain-ment liner dome lift. F'ailure to preclude installation of NSSS supports with noncon-forming, undersized welds (Level IV, Sup-plement II).

81-10 9/2d-30/81 Proposed physical security None.

1 plan.

81-11 10/15/81 Management meeting to dis- N/A.

cuss SALP board results of licensee's performance from 7/1/80-6/30/,81.

81-12 10/5-11/16/81 Piping QA program, pipe in-4 One violation: failure stallation, welding and sup- to erect instrumenta-ports; concrete placement tion supports in ac-preparation, cadweld splic- cordance with the con-ing, site civil testing, and trolling design docu-containment liner and con- ment (Level IV, Sup-crete interfacing; component plement II).

installation, instrumentation supports; and structural con-nections to include design control over the structural impact of combined loadings.

81-13 11/3-6/81 Machine orbiting, gas tungs- None.

2 ten arc (GTA) butt welding process used to weld Class 1 reactor coolant system pipe and components.

• l Enclosure 4 13 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 81-14 11/17/81- Field fab'rication of rein- One violation: failure  :

1/8/82 forcing steel; pipe instal- to assure applicable 1 -lation, welding and supports; design _ considerations electrical component storage, (i.e., thermal pipe supports and welding; blast growth) were correctly monitoring for safety related translated into pipe 4

effects; and design verifica- support modification tion controls. details (Level V, Sup-plement II).

82-01 1/11-2/12/82 Pipe installation, welding One violation: failure 1 and supports; structural to clearly establish steel connections; electri- and assign responsi-cal raceway supports and con- bility for modification tainment penetration welding; (i.e., stiffening) of i

and cadweld testing program. structural beams necessitated by certain electrical raceway support installations j

(Level.V, Supplement j

II).

82-02 2/16-3/22/82 Pipe installation and pipe Two violations:

i 1 whip restraint erection; con- Failure to adequately tainment penetration and iso- control a containment lation valve installation; penetration welding structural connections; and process (Level IV, electrical cable termina- Supplement II).

tions.

Design failure in specifying undersized fillet welds for pipe l whip restraints. (Level IV, Supplement II).

82-03 3/23-5/3/82 Electrical component procure- Two violations:

4 ment, installation and in- Failure to establish spection; reactor coolant an inspection program

! pipe welding; rebar cadweld- for installed cable j ing; corrective action on tray (Level V, Supple-ground water leakage, support ment II).

erection to include the Kwik-bolt installation program; Failure of QC pipe and .i and followup of 50.55(e)/Part electrical support in-

' 21 item. spections to identify nonconforming condi-tions (Level IV, Sup- -

i plement II).

a

, , , , - -- --r-+ -- ye,,w- ,, , y r--, , y - ,- ,m, ,- - , -- ,, - rg --r re~ -

l

. Enclosure'4 14 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions 82-04 5/4-14/82 control battery installation One violation: failure 6/1-18/82 and inspection; followup of to follow procedures 1 concern regarding concrete and manufacturer's repair sand usage and con- specifications in con-trol; and follouwp to IE Bul- trol battery installa-letins and Circulars, tion and inspection (Level IV, Supplement II).

82-05 5/6/82 Meeting to discuss Opera- N/A.

tional Quality Assurance Pro-gram for Seabrook Station.

82-06 6/21-7/2/82 5

Construction Assessment Team Nine violations:

inspection of project manage- Failure to follow pro-ment, quality assurance, de- cedures for qualifica-sign control, construction tion of auditors (Level control and nondestructive V, Supplement II).

testing.

' Inadequate water stop specification (Level V, Supplement II).

Failure to properly process ECA's (design change documents) (Level IV, Supplement II).

Failure to properly review NCR design changes (Level IV, Supplement II).

Failure to distribute design documents in the area of use (Level IV, Supplement II).

Failure to provide proper directions to pipe welders (Level IV, Supplement II).

Failure to reaudit deficient areas (Level IV, Supplement II).

Enclosure 4 15 4

Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas 4 Actions 82-06 . Failure to provide ade-(CONTINUED) quate protection for  !

equipment in storage '

(Level IV, Supplement j

II). ,

Failure of welds to 4

meet ASME III Code acceptance criteria (Level IV, Supplement II).

Also, 5 significant program weaknesses.

4 82-07 6/14-17/82 Concrete construction of None.

1 primary concrete building exterior wall and dome, control of ground water seepage, and structural

' fill placement, compaction and testing for service 1

water lines.

82-08 7/12-8/23/82 AWS welding, structural steel None.

3 erection, reactor coolant pressure boundary and safety related piping runs and weld-ing, RPV internals condition and stroage, and design / con-struction interface issues.

82-09 8/24-27/82 Concrete construction of None.

1 reactor containment building dome, structural welding within containment building, QA surveillance of structural steel erection, and welding Category I buildings.-

82-10 8/24-9/30/82 Pipe penetrations; pipe weld- Two violations:

1 ing, supports, and whip re- Failure to assure that straints; design issues; and pipe whip restraint corrective action, design documents specify appropriate material requirements '

and quality standards, re: design intent for

'. l l

a' 1

l

Enclosure 4 16 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions i

82-10 high-strength bolting (CONTINUED) applications (Level V, Supplement II).

Failure to implement prompt and effective corrective action in resolution of issue re: questionable pipe erection clearances (Level IV, Supplement II).

82-11 9/20-24/82 Installation and inspection None.

1 of electrical and instrumen-tation components.

82-12 9/28-10/1/82 1

Reactor vessel internals and One violation: failure containment boundary electri- to distribute a safety cal, mechanical and access related design change penetrations. (Level IV, Supplement II).

82-13 10/1-11/5/82 2

Safety related structural One violation: failure steel erection, reactor cool- to conduct and document ant pressure boundary piping an inspection of pipe installation; safety related support Kwik-bolting pipe supports, and design activities per proce-issues. dure hold point re-quirements (Level V, Supplement II).

82-14 11/2-5/82 Refueling water storage tank None.

I and structural support instal-

' lation and erection for reac-tor coolant pumps.

82-15 11/8-12/20/82 Diesel generator coolant sys- One violation: failure 4 tem piping and supports, to adequately control electrical cable routing and status of design separation, including fire changes to a pipe sup-protection, and technical re port installation, re-sponses to design questions. sulting in undersized welds and QA acceptance of same (Level IV, Supplement II).

l 1

Enclosure 4 17 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 82-16 12/21/82- Safety related piping and One violation: failure 1/17/83 support erection issues, and to assure installation 2 . Class 1E cable installation. of Class IE cable in a qualified (i.e.,

seismic) raceway system (Level IV, Supplement II).

83-01 1/17-21/83 Pipe support installation None.

I and allegations concerning welding aspects of hanger (supports) fabrication, in-cluding return end (boxing) welding and welding on radius between web and flanges for NF Class 2 hanger welds.

83-02 1/18-2/28/83 Component installation, pro- Three violations:

1 2 cess controls, containment Failure to control in-piping penetrations, and sta11ation and inspec-engineering controls, tion process on weld i

end preparation and i

component installation (Level IV, Supplement II).

Failure to document and control cable tray support nonconformances to the FSAR and drawing details (Level IV, Sup-plement II).

Failure to maintain records, as evidenced by identification of i

an uncontrolled and

}

erroneous reconstructed installation record i

(Level V, Supplement 4

II).

, 83-03 2/22-25/83 Installation, routing and None.

1 termination of electrical cables.

-_ ,---m-,7, . , -- , wr --,-,,,.a , , .- - - - - , - - ,

. Enclosure'4 18 -

1 Inspection Dates / Number Inspection Number of Inspectors Enforcement Areas Actions 83-04 2/28-3/4/83 Design changes associated None.

3/17/83 with large bore pipe and HVAC 2 . support installation, UE&C onsite' organizational struc-ture and design responsibili-

ties including site /home of-fice interface, implementa--

tion and audits of UE&C pro-cedure AP-15 controlling the design process, and upgrade of control room supply air duct work.

! 83-05 3/1-4/8/83 System and component instal- None.

3 1ation, structural steel f erection,' electrical cable and instrument tubing instal-lation; and control of field drawings for-piping supports.

i 83-06 4/11-5/23/83 Pipe, pipe support and elec- None.

2 trical raceway installation.

4 83-07 5/23-27/83 Reactor vessel internals, 2

Three violations:

i containment structural steel, Failure to perform containment dome concrete. reactor internals work i

placement, steel structures. per procedures (Level and supports in emergency -IV,' Supplement II).

feedwater pumphouse and fuel storage building. Failure to issue a i

! Process Control Sheet with a procedure change (Level V, Supplement-

'I).

4 Failure to maintain proper storage of reactor internals (Level IV, Supplement II).

83-08 5/24-26/83 Electrical system including Two violations:

1 procedures, training, race- Failure to maintain i

way installation, cable in-- motor operator valves' sta11ation and cable termi- limit switch compart- .i nations,

! ments clean and sealed '

' (Level V, Supplement )

l II). l

!. 1 i

l I

I

Enclosure 4 19 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 83-08 Failure to maintain (CONTINUED) safety related cables and raceways clean and free of debris, tools,

' etc., during the con-struction phase (Level V, Supplement II).

83-09 5/24-7/1/83 Piping and pipe support in- One violation: failure 2 sta11ation,. actions on CDR's, to implement adequate and licensee investigation of corrective action to incident reported to NRC. preclude recurrence i

of deviant and noncon-

. forming conditions (Level IV, Supplement II).

83-10 6/7/83 Management meeting to dis- N/A.

2 cuss licensee actions in re-sponse to general NRC con-cerns, re: performance of site piping contractor (Pullman-Higgins), and to specific construction de-ficiency, re: questionable conduct of surface NDE by.

one Pullman-Higgins tech-nician.

83-11 7/5-8/83 Installation of instrumenta- None.

I tion components and systems.-

83-12 8/8-12/83 Corrective action program, One violation: ultra-3 reactor vessel internals,'in- sonic examination for strument tube installation, acceptance of safety and safety related pipe and related components pipe support welding. (fillet welds) without a qualified ultrasonic test procedure (Level IV, Supplement II).

83-13 7/11-8/26/83 RCP "B" weld repairs, NDE, One violation: failure 3 and instrument tubing checks; to follow procedures design change controls; com- in the control and im-

,' ponent testing; and construc- plementatfor of a de- I tion gauge calibration pro- sign change (Level V, gram. Supplement II).

1

-- -, - -. y

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

l Enclosure 4 20  !

i 4

i Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas- Actions 83-14 8/15-19/83 Installation, routing,_and 1

One violation: failure termination of instrumenta- to properly inspect

, . tion and control cables. terminations of small gauge conductors,(Level V, Supplement 1II).

83-15 9/12-10/14/83 Electrical cable and compon- One violation: failure i

2 ent installation and QA, to review design changes licensee field QA surveil- for adequacy of welding lance program, miscellaneous process controls (Level structural issues, and CDR IV, Supplement II).

followup.

83-16 9/27-30/83 Preoperational test program, None.

i 1 preoperational test proce-dure review, and preliminary.

test results review.

83-17 10/17-12/5/83 Containment leak chase sys- Three deviations:

3 tem, containment penetra- ' DG SKV bus duct needs tions, design change con- collar for vibration trol, licensee Self. initiated dampening.-

4 Construction Project Evalu-ation and in process instal- Certain penetration lation of piping, pipe sup- leak chases not con-ports and whip restraints. nected to test piping system.

Recirculation piping encapsulation tank welds do not meet ASME design requirements.

83-18 11/14-18/83 NDE of piping and pipe sup- None.

4 port weldments for re-verifi-cation of previous NDE results.

83-19 11/28-12/1/83 Reactor vessel safe end None.

1 radiographs.

83-20 12/19-22/83 Installation, inspection and One violation: ' failure i

1 testing of electrical and in- to properly install strumentation equipment. equipment per drawing-

requirements (Level IV, Supplement II) i

. Enclosure 4' 21 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 83-21 12/19-22/83 Preoperational and acceptance None.

I test procedure review.

83-22 12/6/83- Small bore piping and compon- Two violations:

1/20/84 ent installation, electrical Recurrent electrical 2 cable inside containment - construction violation routing and component erec- regarding misinterpre-tion, rework activities - tation of design re-construction and preopera- quirements (Level IV, tional testing, certification Supplement II).

of NDE personnel, HVAC proce-dures, licensee Supervisory Work request directions Support Group piping surveil- and authority were ex-lance / audits. ceeded, resulting in partially assembled equipment with an im-proper status (Level IV, Supplement II).

83-23 and 11/1-12/21/83 Integrated Design Inspection None; however, exten-Supplement 1 11/7-9/84 focused on containment build- sive findings regarding 17 Inspectors ing spray system. errors, procedural and Contrac- violations, and incon-tors sistencies identified in report.

84-01 1/23-3/12/84 Piping and pipe support in- None.

5 sta11ation, welder qualifi-cation, electrical cable and terminations, diesel genera-tors, and equipment turnover to startup test group.

84-02 2/28-3/2/84 Preoperational and acceptance None.

1 test procedure review, special test procedure re-view, and system turnover review.

84-03 3/12-16/84 Installation, inspection and None.

2 testing of electrical equip-ment.

84-04 3/13-5/7/84 Diesel generator testing, One violation: inade-4 main control board modifica- quate design and in-tion controls, refueling spection of diesel

Enclosure 4 22 ,

i Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions

,i 84-04 water storage tank erection generator exhaust  ;

(CONTINUED) records, pressurizer relief silencer installation  ;

. valve and associated piping resulted in damage to and pipe support erection,' the component support new UE&C instrumentation and pedestals during in-control procedures, general process testing (Level  ;

' housekeeping and storage of IV, Supplement II).

d equipment and material. 1 84-05 4/17-20/84 Vendor diesel generator test None.

I witnessing and preoperational 4

test procedure review.

j 84-06 4/30-5/4/84 Preservice inspection activi- None.

L 1 ties including program re-

}

view, observations of work in progress, review of NDE. '

procedures, and review of j PSI data.

I 84-07 4/23-5/4/84 NRC Construction Appraisal j Five violations:

5/14-25/84 Team (CAT) inspection to Failure of QA program i 9 Inspectors evaluate adequacy of con- to effectively provide 7 Consultants struction at Seabrook Station control over activities including electrical and in- involving seismic cable 4

i strumentation construction, tray support installa-mechanical construction, tions (Level IV, Sup- )

l i

civil and structural con- plement II). '

' struction, welding and non- l destructive examination, Failure to maintain

! material traceability and j adequate design control i

controls, design change con- (Level IV, Supplement trol and corrective action II).

l systems.

1 Failure to effectively I

perform instructional

}

and procedural activi-ties (Level V, Supple-ment II).

Failure to effectively j implement program for i inspection of activi-ties affecting quality (Level IV, Supplement j l II).

t I

{

l, l

Enclosure 4 23 '

Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 84-07 Failure to assure that (CONTINUED) nonconforming condi-tions have been pro-perly identified, re-viewed, resolved, and evaluated for correc-tive action (Level IV, Supplement II).

Three program weak-nesses: hardware being installed and inspected while design changes continue.

Communication problem between applicant's various management, engineering and con-struction groups (utility, engineering, contractors, and QA/QC personnel).

Weaknesses involving piping support instal-lations have been pre-

.viously identified by NRC Region I.

84-08 5/29-6/25/84 Electrical terminations, RHR One violation: inade-2 line flushing, IE Bulletin quate storage and pre-actions, tank farm chase servation of NSSS com-buildings, CRDM cooling ponents (Level IV, Sup-shroud, steam generator tube plement II).

plugging, and I&C procedures.

84-09 6/12-15/84 Preoperational test procedure None.

I review and verification, and QA interface with preopera-tional testing.

84-10 6/26-8/24/84 Reactor vessel fabrication None.

2 reactor vessel flange seal ring groove repairs, welder recertification, records of reactor vessel nozzle repairs, radwaste piping, and steam I generator nozzle repairs.

Enclosure 4 24 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions 84-11 8/21-24/84 Preoperational test proce- None.

2 dure review and verification, i

-QA interface with preopera-tional testing, and system turnover program.

84-12 8/13-17/84 Special inspection of con-8/27-31/84 One violation: failure struction activities regard- to implement adequate 4 ing concrete walls, steam corrective action to generators, welding, piping, preclude recurrence valves, storage and NCR con- of a forged signature trol, as a result of allega- at an inspection hold tion statement submitted by point (Level IV, Sup-an anonymous alleger, plement II).

84-13 8/27-10/26/84 Instrument cable termina- One violation: inade-2 tions, cable pulling, piping quate records for steam and support welding, steam generator lateral sup-generator lateral support ports installation structures, field QA manual, (Level V, Supplement design changes, ASME Code 4

! II).

Case commitments and 10 CFR 50.55(e) program.

I 84-14 9/17-21/84 Operator licensing examina- N/A.

1 Examiner tions of eleven SRO and two 4 Contractors R0 candidates.

84-15 10/15-19/84 HVAC systems final as-built None.

I conditions and preparation of as-built records.

0 84-16 10/29-11/2/84 Repair of reactor pressure None.

2 vessel nozzle to safe end welds, welding procedures, and welder performance quali-fication.

84-17 10/29-12/17/84 Weld repairs to RPV nozzle 2

One deviation: un-safe ends, ECCS piping system authorized use of a walkdown and procedure re- superseded ASME Code view, reactor coolant piping Case in a design heat treatment records, de- change.

sign and procurement of ori-fice plates and penetration-sealants, nonconformance re-i ports, and system turnover activities, i

l

. Enclosure 4 25 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 84-18 12/3-7/84 Installation of electrical / One violation: accumu-3 instrument components and lation of trash and

. systems and review of QA debris detrimental to records. quality and safety (Level V, Supplement II).

84-19 12/4-7/84 Operator licensing examina- N/A.

3 Examiners tions of four SRO and three 2 Contractors RO candidater.

84-20 12/18/84- Instrumentation and control None.

2/8/85 activities, electrical train 4 separation, safety related piping system walkdown, reac-tor coolant loop piping heat treatment, and vendor audit /

surveillance program.

85-01 2/11-4/5/85 I&C installation, valve in- Two violations:

3 terlock logic and limit Failure of design con-switch installation, RPV in- trol and interfacing ternals records, flow re- between design organi-strictor design and field zations in not trans-installation, and conduct of lating the significance system and component hydro- of maximum flow re-static tests, strictor orifice sizing into drawing details and field instructions (Level IV, Supplement II).

Inadequate nonconform-ing item control as evidenced by condition of two valves (Level IV, Supplement II).

85-02 1/28-2/1/65 Preoperational test procedure None.

I review and verification, test witnessing (Phase I), and QA interface with preoperational testing.

85-03 2/11-15/85 Installation, inspection and One violation: failure I testing of electrical equip- to have identifying ment. nameplates attached to electric equipment (Level V, Supplement II).

Enclosure 4 26 Inspection Dates / Number Inspection Number Enforcement of Inspectors Areas Actions i 85-04 3/18-22/85 Operator licensing examina-

! N/A.

1 Examiner tions of seventeen SR0 and l 4 Contractors .three RO candidates.

l 85-05 2/26-3/1/85 Preoperational test procedure None.

1 review and verification, test witnessing (Phase I), QA in- <

terface with preoperational testing and code hydrostatic test preparations.

85-06 2/25-3/1/85 Fire main loop installation. One deviation: failure to install UL listed hydrant isolation valves.

l 85-07 3/11-15/85 Work performance and inspec- None.

I I tion of HVAC systems as af-fected by 1984 reorganiza-tion and assignment of work to UE&C.

85-08 4/2-5/85 Reactor coolant system hydro- None.

2 static test including test witnessing and independent measurements of metal sur-face temperatures.

85-09 4/8-5/24/85 Instrumentation and control None.

4 activities, system piping component walkdowns, and in-office review of A/E metal-lurgical evaluation contained in a component failure analy-sis report.

85-10 4/15-19/85 Containment structural steel None.

I weld quality, radiography, preservice inspection acti-vity including ultrasonic examination of welds and preparation for eddy current examination of steam genera-tor tubes, and observation of pipe hanger / support instal-lation.

L

. Enclosure 4 27 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 85-11 4/29-5/3/85 Installation of electrical None.

4 I safety related equipment.

85-12 4/29-5/3/85 Acceptance test procedure re- None.

1 view and verification, pre-operational test witnessing, preoperational and accept-ance test results evalu-ation, steam generator eddy current testing, emergency  ;

diesel generator preopera-tional test scope, and QA interface with preopera-tional tesing.

85-13 5/6-10/85 Turnover portion of QA pro- None.

3 gram for preoperational testing, including QA/QC overview and interface

! activities.

85-14 5/13-17/85 Preservice inspection (PSI) None.

I activities including work in progress, NDE procedures, and PSI data.

85-15 6/3-14/85 Construction Team Inspection Three violations:

7 of construction site manage- Seismic installation ment, quality assurance, de- criteria for instrument sign change program, electric tubes crossing a seis-systems, instrumentation and mic boundary were not control, mechanical and translated into instal-structural systems, and weld- lation specifications ing and metallurgy. (Level IV, Supplement i

II).

Two NCRs which docu-mented installation nonconformance of two seismic Category I instrument installa-tions were not sub-mitted to engineering for processing (Level IV, Supplement II).

1

Enclosure 4 28 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 85-15 Inadequate control of (CONTINUED) pipe support design and installation acti-vities (Level IV, Sup-plement II).

Three licensee weak-nesses:

Instrumentation tubing program design.

Design change program.

Welder qualification records.

Three licensee strengths:

Site management.

Site QA function.

UE&C welding engineer- ,

ing efforts.

, 85-16 5/28-31/85 Preoperational test witness- None.

1 ing, preoperational and ac-ceptance test results evalu-ation review, and QA inter- 1

, face.

85-17 5/27-7/5/85 Containment piping penetra- None.

2 tion certifications, review )

and walkdown of EFW HVAC sys-tem, review of licensee docu-mentation concerning cold pull i of piping in response to n allegation.

85-18 6/10-14/85 Preoperational security pro- None.

2 gram review including secur-ity program audit, security plan and implementing proce-  !

dures, management effective-  !

ness, and physical barriers (protected area). )

1 1

Enclosure 4 29 Inspection Dates / Number Inspection Enforcement

Number of Inspectors Areas Actions 85-19 7/1-26/85 Independent measurements in- None.

3 spection, using NRC mobile NDE laboratory, of safety re-lated piping, structural and support weldments fabricated to ASME Code,Section III, Classes 1, 2, and 3, and AWS Code D1.1 requirements.

85-20 7/8-8/27/85 I&C installation, piping and Two violations:

6 component supports, fuel Inadequate design change building ventilation systems control and corrective and spent fuel rack erection, action on limit switch preoperational testing acti- bracket rework (Level vities, and operational IV, Supplement II).

readiness and testing activi-i ties. Corrective action failure on DG pedestal cracking (Level IV, Supplement II).

85-21 7/8-12/85 Preoperational test witness- None.

1 ing, preoperational test pro-cedure review and verifica-tion, preoperational test re-sults evaluation review, QA/

QC interface with preopera-4 tional test program and inde-pendent calculations /verifica-tions.

85-22 7/22-26/85 Testing of safety related None.

I electrical equipment and IE Information Notice followup.

85-23 8/5-8/85 Preoperational test witness- None.

3 ing, preoperational and ac-ceptance test results evalu-ation review, preoperational test program implementation, QA interface and independent calculations.

85-24 10/1-4/85 Operator licensing examina- N/A.

3 Examiners tions of five SRO candidates.

1 5

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

Enclosure 4 30 Inspection- Dates / Number Inspection Number of Inspectors Enforcement  :

Areas- Actions j 85-25 8/28-10/18/85 Pipe snubber and strut erec- One deviation: JQA pro-4 tion, reactor vessel level- gram requirements for '

. indication system (RVLIS) in- tubing installation

' stallation, pressurizer power of RVLIS and RCS wide operated relief valve field range pressure trans-modification, installation of mitters were not com-spent fuel storage racks, mensurate with Reg.

boron concentration and radi- Guide 1.97 requirements.

ation monitoring systems, preoperational test witness- -

ing, hot functional testing

. procedures review, and diesel generator brush holder assem-bly supports. ,

t 85-26 9/23-27/85 Preoperational test witness- None.

I 2 ing, preoperational test pro-cedure review and verifica-tion, preoperational_and ac-I, ceptance test results evalu-i ation review, independent i

verification, and QA inter-I face.

l 85-27 10/15-18/85 Preoperational security pro- None.

2 gram review including secur-l ity plan and implementing procedures, management ef-fectiveness, security or-i

' ganization, security program audit, physical barriers (protected and vital areas),

security system' power supply, access control (personnel),

and training qualification plan.

1 85-28 10/15-17/85 Preoperational inspection of None.

1 radiation safety program in-

' cluding organization and status of health physics, "

radioactive waste, chemistry and I&C departments.

l l

l 4 -

4

- , , - ~ . .,e. , , _ . . , . c--,.--. . _ , _ , ., _ - . - - - ,n _ , . , . . - - , .-,-.m ,_ ,. .- s. . ~ ~ - rm -_. - , ---,r y ---r,; - --

Enclosure 4 31

)

l s

Inspection.

Dates / Number Inspection Enforcement i

Number of Inspectors Areas Actions 85-29 11/4-8/85 Licensee programs for quali- None.

7 $ ik 1 fication of electrical race-s

. ways by testing and stress reconciliation of RCS piping (ASME Class 1).

85-30 10/28-11/27/85 Hot functional preoperational None.

5 test witnessing and test pro-cedure review and.verifica-tion, preoperational and ac-

'. ceptance test results evalu-at' ion review, QA interface and-independent verification.

4 85-31 10/21-12/6/85 Conduct of testing relative None.

7

,O to preoperational test pro-gram and hot functional tests.

85-32 12/9-13/85 Emergency preparedness imple- None.

7 mentation appraisal of emer-gency preparedness program including organization, ad-ministration, procedures, training, and facilities and equipment.

85-33 12/11-13/85 Fire protection program None.

I readiness to receive fuel, including procedures, fire ,

brigade and plant personnel '

training, and observations of I work.

85-34 N/A. Inspection cancelled. N/A. '

85-35 12/9/85- Work activities and testing None '

1/31/86 relative to emergency and i 3 startup feedwater systems  !

redesign / rework, fuel hand- '

ling and storage equipment /

facilities and readiness for fuel receipt, fire protection, piping and isometric drawing controls, and followup of event involving loss of shielding for boron concen- l tration monitor. i i

l l

Enclosure 4 32 i

Inspection Dates / Number Inspection Number Enforcement-of Inspectors Areas Actions 86-01 1/6-10/86 Preoperational test proce- None.

3- dures, preoperational test

.results evaluation review, test program review, indepen-dent verification, and QA/QC interface. ,

86-02~ 1/13-24/86 Preoperational test program

? None.

4 including procedures in areas of receipt, storage and hand- i ling, records, document con-trol, surveillance testing '

and calibration, and test and measurement equipment.

86-03 1/27-31/86 Compliance with 10 CFR 50, _None.

1 Inspector Appendix R, Sections III.G, 4 Others J, and 0 concerning fire pro-tection features to ensure ability to achieve and main-tain safe shutdown in event of fire.

86-04 1/13-16/86 Implementing procedures for None.

2 receipt of special nuclear material of low strategic significance and preoperation security program review in-cluding physical security plan and implementing proce-dures, management effective-ness, and physical barriers-(protected / vital areas).

86-05 1/27-2/7/86 Preoperational quality con- None.

2 trol, maintenance and testing program, preoperational test procedures, maintenance ar.d calibration results, Seabrook QA/QC inspections, safety re-view committees, and procure-ment control' program.

86-06 2/10-28/86 Design changes and modifica- None.

3 tions, QA/QC interfaces, inde-pendent measurements, surveil-lance testing procedures, and

^

maintenance work request pro-4 cedures.

1

Enclosure 4 33 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 86-07 3/10-14/86 Quality assurance of the None 2 startup test program, main-

.tenance program, and test and experiments program.

t 86-08 2/5-6/85 Radiological protection pro- None.

1 gram's preparation for ini-tial fuel receipt.

86-09 4/7-11/86 Preoperational review of None.

4 2 general and system operating procedures and QA interfaces.

86-10 2/24-28/86 Emergency preparedness in- None.

7 spection to observe the lic-ensee's first full scale emergency exercise performed on 2/26/86.

86-11 2/10-14/86 Preservice inspection activi- None.

2 ties including program and procedure reviews and obser- .:

vation of: field activities.

86-12 2/3-3/31/86 4

Containment enclosure venti- One violation: failure lation system and solid rad- to provide sufficient waste system design and con- design for-inclusion i struction, preoperational of specific area of testing activities and test containment enclosure results evaluation, new fuel as part of air space receipt inspection, and TMI ventilated by contain-Action Plan items. ment enclosure air handling system (Level IV, Supplement II).

86-13 1/20-24/86 Preoperational test proce- None.

' 1/25-31/86 dures, test witnessing, evalu-2/1-21/86 ation of test results of com-t 2/24-28/86 pleted tests, independent 2

verification and QA/QC inter-

, face for POT program.

86-14 3/10-21/86 As-built team inspection in Two violations:

6 areas of piping and pipe sup- Traceability was not i ports, instrumentation and maintained for a ser-controls, components (valves, vice water valve and pumps, motors, heat exchan- diesel generator ven-I

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

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

Enclosure 4 34 l

l

i. Inspection Dates / Number Inspection t

! Number Enforcement of Inspectors Areas f Actions 86-14 gers) and electrical power tilation fan motors (CONTINUED) supplies and distribution identification (Level 4

. systems. V, Supplement II).

Work expanded beyond authorized scope of work request and fire penetration in diesel  !

generator room not sealed properly (Level IV, Supplement II).

86-15 3/4-19/86 Procedure review, test wit-t None.

3 nessing and preliminary re-suits evaluation of preopera-i tional containment integrated i leak rate test and structural I.

integrity test.

4

. 86-16 3/17-21/86 I

Preoperational inspection of None.

3 radiation protection program including organization and management controls, train-4 ing and qualifications, ex-i ternal occupational exposure controls and personnel dosi-metry, internal exposure con-i trol and assessment, control of radioactive materials and i

contamination, surveys, moni-toring and maintaining occupa-3 tional exposures ALARA.

86-17 3/3-14/86 Preoperational test program None.

3 including test witnessing of preoperational tests, evalu-ation of test results of com-pleted tests, independent.

verification of test measure-ments, and QA/QC interfaces; and startup test program ad-ministrative controls.

86-18 3/24-28/86 Emergency preparedness imple- None,but several pro-2 Inspectors mentation appaisal to evalu- gram areas identified 3 Contractors ate. adequacy and effective- which were incomplete ness of emergency prepared- or required corrective 4

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

. Enclosure 4 35 l

Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions t

86-18 ness program for Seabrook 1 actions. ,

(CONTINUED) including organization, ad-  !

. ministration, procedures, I training, and facilities and equipment.

86-19 -3/24-28/86 Preoperational test program None.

4/28-5/2/86 including test witnessing, 1 Inspector evaluation of test results, 1 Consultant independent verification of test measurements, and QA/

QC interface.

86-20 4/1-5/23/86 Work activities related to None.

6 waste process building and

~

systems; primary auxiliary building, control building and RHR vaults turnover pre-paration; design and con-struction; preoperational i

testing activities; train-ing programs and TMI Action Plan items; previous find-ings; and techniques pro-posed for NDE examination of reactor coolant piping welds.

86-21 3/31-4/4/86 Resolution of previous in- None.

I spection findings, including electrical and I&C construc-tion deficiency reports fol-lowp actions.

86-22 5/5-30/86 Preoperational inspection of None. '

5 chemistry, effluent controls and radioactive waste pro-

. grams including organization and management, training, procedural development, i facilities and equipment, j

liquid and gaseous radio-active waste systems; con-firmatory measurements, and non-radiological chemistry control.

l 1

l

4

-Enclosure 4 '36 i- ,

j..

Inspection Dates / Number Inspection Number Enforcement

, of Inspectors Areas Actions-86-23 4/14-18/86 ' Readiness of QA program and None.

3 staff to support plant opera-

.tions including QA/QC organi-i -zation, QA/QC surveillance, onsite operating and support staff, and non-licensed train-

ing.

1 86-24 4/14-18/86 Licensee records related to None.

j 1 reactor vessel and internals and licensee's activities re-lated to previous inspection

{ findings.

1

86-25 5/5-9/86 Preoperational inspection of None.

3- occupational radiation pro-tection program including

! previous findings, organi-zation and management con-i trols, training and quali-g fications, external expo-j sure control and personnel-dosimetry, internal expo-sure control and assessment, control of radioactive mate-rials and contamination, sur-veys and monitoring, facili-ties and equipment, and main-

),

taining exposure ALARA.

86-26 5/6-8/86 Initial inspection of nuclear None.

1 material control and account-ing including organization and operation, shipping and t

receiving, storage-and in-ternal control, inventory, records and reports, and-

! management of material control system.

i 86-27 5/5-16/86 Draft Technical Specifica- None, but several areas-f 2 Inspectors tions review to determine identified where clari-3 Contractors whether' draft TS and FSAR are fication of licensee compatible with as-built position or'specifica-i plant configuration and oper- tion correction re- j i

ating characteristics and quired. 1 whether draft TS are defi- 1 nitely measurable.

l ll 1

Enclosure 4 37 1

Inspection Dates / Number Inspection Enforcement i Number of Inspectors Areas Actions 86-28 5/12-22/86 Previous findings, CDRs, IE. None. Some deficiencies 3 Circular, operating programs noted in procedures. l and procedures, licensee con-

' trol of NRC action items, commitments and TS changes, and reactor engineering pro- ,

cedures.

86-29 5/12-15/86 Preoperational security pro- None.

1 gram review of previous find-

'ings.

86-30 6/8-13/86 Emergency preparedness imple- None.

3 mentation appraisal followup revi e,v.

1 86-31 6/2-6/86 Startup program and startup None.

I test procedures.

86-32 5/20-22/86 Fire protection / prevention None.

1 program readiness to load fuel including organization, control of combustible and ignition sources, equipment-maintenance and test program, fire brigade training and QA audits.

86-33 6/2-6/86 Abnormal and emergency oper- None 2 ating procedures.

86-34 5/23-6/30/86 Licensee action on previous Report not issued.

8 findings and CDRs, building turnover preparations and general design and construc-tion activities.

86-35 6/9-13/86 Chemistry, effluent controls None.

3 and radioactive waste pro-grams including water chemis-try control program, effluent measurement and control, pro-cess and effluent radiation

, monitor calibration, chemis-try program and preopera-tional and acceptance test-i ng'.

I

s Enclosure 4 38 Inspection Dates / Number Inspection Enforcement Number of Inspectors Areas Actions 86-36 6/16-23/86 Previous findings, CDRs, IE None.

3 Circulars and Bulletins.

86-37 -6/9-13/86 Preoperational test program None.

1 Inspector including test witnessing, 1 Consultant test procedures review, test results evaluation, test measurements independent verification, and test excep-tions.

86-38 6/23-27/86 Preoperational inspection of None.

2' radiological environmental monitoring program including air, soil, and water environ-mental sampling and meteoro-logical monitoring program.

86-39 6/23-27/86 Preoperational radiation pro- None.

2 tection program review of previous findings.

86-40 6/23-27/86 Preoperational test program None.

1 test exceptions and previous findings.

86-41 6/23-27/86 Preoperational security pro- None.

1 gram review of previous find-ings.

86-42 Inspection Cancelled.

86-43 7/7-11/86 Previous findings, CDRs, None.

3 IEBs, cable tray seismic qualifications, PSI program.

86-44 7/7-11/86 Previous findings of pre- None.

2 operational radiation protec-tion program.

86-45 8/18-22/86 CDRs, electrical procedures, Report not issued.

1 design changes.

.- . - _ - - . _ -