IR 05000322/1979005
| ML19208B122 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/03/1979 |
| From: | Briggs L, Kister H, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19208B109 | List: |
| References | |
| 50-322-79-05, 50-322-79-5, NUDOCS 7909190077 | |
| Download: ML19208B122 (11) | |
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U.S., NUCLEAR REGULATORY COMMISSION OFFICE'0F INSPECTION AND ENFORCEMENT Region I Report No. 50-322/79-05 Docket No. 50-322 License No. CPPR-95 Priority
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Category A
Licensee:
Lona Island Liahtina Comoany 175 East Old Country Road Hicksville, New York 11801 Facility Name:
Shoreham Nuclear Station Inspection at:
Shoreham, New York Inspection conducted: March 27-30, 1979 Inspectors: /6[w h
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G.'Napuda, Reactor Inspector
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iggfg;Rdactor: Inspector
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R. S. Markowski, Reactor Inspector date signed Approved by:
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$. B. KisteY Chief, Nuclear Support Section dat'e signed No. 2, RO&NS Branch Inspection Summary:
Inspection on March 27-30, 1979 (Report No. 50-322/79-05)
Areas Inspected:
Routine, unannounced inspection by regional based inspectors of P.e-Operational Program in the areas of: QA/QC Program; document control; records; quality verification program; and, licensee action on previous inspection findings.
The inspection involved 78 inspector-hours onsite by three regional based NRC inspectors.
Results:
Of the five areas inspected, no items of noncompliance were identified in four areas and one item of noncompliance was'fdentified in one area (Deficiency - QA procedures were not updated in accordance with established requirements, Paragraph 4.e.(1)).
4bb 79 0919 00T7 Region I Form 12 (Rev. April 77)
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_ DETAILS 1.
Persons Contacted
- D. Durand, Operating QA Engineer
- T. Gerecke, QA Manager
- J. Kelly, Field QA Manager
- L. Lewin, Assistant Startup Manager J. Matson, Records Manager
- J. Rivello, Plant Manager The inspectors also interviewed other licensee and architect-engineer employees during the course of the inspection.
They included Engineering, Startup, Quality, Operations, Office, and other per-sonnel.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Follow Item (76-10-10):
Reactor Vessel Hydrostatic Test procedure not incorporated in preoperational test program.
The subject test procedure, CS 136.001, Reactor Pressure Vessel and Main Steam Line Hydrostatic Test, was approved by the Joint Test Group (JTG), December 21, 1977, and has been incorporated into the test program.
(Closed) Follow Item (76-10-15):
Station Alanns testing to be incorporated into Procedure PT 319.001, Communications System Preoperational Test.
A review of PT 319.001 verified that the station alarms had been incorporated into the Communications System Preoperational Test procedure.
(Closed) Follow Item (76-14-05):
Review records of Station Battery Terminal Resistance.
The inspector reviewed the results of Constuc-tion and Initial Operation (C&IO) Test Procedure CG-000.027-2 for the A, B, and C batteries.
Initial test results indicated that many connections were higher in resi!tance than the maximum acceptable limits.
The licensee has reworked the battery intercell connections since the initial data was taken.
The review indicated that average resistance values were reduced by approximately 66%, i.e., 'A'
battery average values decreased from 68.3 microchms to 25.5 micro-ohms.
The inspector had no further questions on this item.
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The inspector also discussed several other procedures with the licensee which were not incorporated into the test program and are identified in Inspection Report 50-322/76-10.
These procedures have been included in the test procedure index by name and procedure number but have not yet been developed.
These additional items will be reviewed by RI during a subsequent inspection (s).
3.
Quality Assurance / Control Program a.
References Quality Assurance (QA)ger-Quality Assurance Department /All Letter QAM 79-02, Mana
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Personnel, dated March 15, 1979.
Memorandum Senior Vice Presidents Engineering and Project
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Management, and Transmission and Distribution and Operation /All Officers, Department and Division Managers, dated March 2, 1979.
b.
Program Review The licensee had previously notified NRC of an anticipated reorganization and the above references officially announced the consolidation of the previous Enginearing QA Department and the Operational QA organization into one QA Department.
The above documents delineate lines of authority / responsibility and state that the current QA policies / programs as modified by the former document will remain in effect until formally cancelled / superceded.
During discussions with the inspector, the licensee stated that a revision to FSAR Section 17 is being currently readied for submission to NRC:NRR, and pro-cedures et al would be revised as appropriate.
The fnspector stated that he had no further questions at this time and this area will be reviewed during a subse-quentinspection(s).
4.
Document Control a.
References FSAR Chapter 17.1.6A, Document Control, Revision 6
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Engineering Quality Assurance (EQA) Manual Section 6,
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Document Control, Revision 4 7] O tj {> E)
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Startup Manual (SUM) Section 4.1, System Boundary Pack-
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ages, Revision 8 SUM Section 4.2, Test Procedures, Revision 8
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Operational Quality Assurance (00A) Manual Section 5,
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Instructions, Procedures, and Drawings, Revision 1 00A Manual Section 6, Document Control, Revision 1
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00A Manual, Appendix D, Quality Related Document Control
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Responsibility, Revision 0 EQA Procedure (EQAP) 6.1, Document Control, Revision 2
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EQAP 5.1, Engineering Quality Assurance Procedures, Instruc-
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tions, Memoranda, and Change Notices, Revision 4 QAP-S-05.2, Control of Station 0QA Procedures and Instruc-
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tions, Revision 1 b.
Prooram Review The documents referenced a.
were reviewed on a sampling basis to determine that writ.
. measures for the control of administrative and test procedures during the startup phase have been established in accordance with the requirements of FSAR Chapter 17.1D, Transition from Construction Phase to Operation Phase Quality Assurance, Revision 6.
No items of noncompliance were identified; however, one unre-solved item is discussed below.
(1)
Startup Manual Section 1, Introduction, Revision 0, states, in part, "Since this document is intended to be a viable and useful one it will be updated periodically and will be a controlled document."
The inspector stated that the ambiguity of the term " periodic" had already resulted in certain sections of the manual not having been reviewed since 1975 (discussed in Paragraph 4.c(2))
and that the time frame within which a review / updating must be performed needed clarification.
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The licensee stated that this area would be reviewed aad appropriate action taken.
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Pending review of the licensee's action by al during a sub-sequent inspection, this item is unresolved (322/79-05-01).
c.
Implementation
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The inspector selected several controlled manuals (e.g.,
Startup, EQA, 00A, EQAP, etc.) to datermine that they were being controlled, revicwed and updated as required by the procedures re#erenced in subparagraph a above.
The inspector identified one apparent item of noncompliance and an unresolved ite.1 that are discussed below.
(1)
E0AP 5.1, Paragraph 4.6 states, in part, "The Quality Procram Division !4tnager shall annually have effective EQAP's, 20AI's, and associated Change Notices reviewed, corrected, and updated as indicated by the review."
The inspector identified that the following procedures had not been updated though their respective Change 5 Notices were in effect for over one calendar year.
The-procedures and Change Notices are:
EQAP 2.3, Change Notice (CN) #1, dated April 15,
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1977 EQAP 2.8, CN #1, dated April 15, 1977
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EQAP 3.3, CN #1, dated March 10, 1978
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E0AP 4.1, CN #1, dated April 18, 1977
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EQAP 15.2, CN #1, dated July 18, 1977
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EQAP 16.1, CN #1, dated January 3,1977
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The in gactor noted that the status of the procedures could be readily determined since the Change Notices were filed in front of the affected procedures and the current index indicated what procedures were affected by outstanding CN's.
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The inspector informed the licensee that the failure to update the listed procedures was contrary to 10 CFR 50, Appendix B, Criterion V; FSAR Section 17.1.6A; Procedure EQAP 5.1; and constituted a deficiency level item of non-compliance (322/79-05-02).
(2) The inspector determined that the Startup Manual did not reflect the recent reorganization that affected the Engineering and Operations Quality Assurance groups and that the impending FSAR revision submittal may further affect tha manual.'
The licensee stated that this area would be reviewed and appropriate revisions to the manual would be accomplished.
Pending review of the licensee's action (s) by RI during a subsequent inspection (s), this item is unresolved (322/
79-05-03).
5.
Records a.
References FSAR Chapter 17.1.17A, Quality Assurance Records, Revision
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Engineering Quality Assurance (EQA) Manual Section 17,
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Quality Assurance Records, Revision 4
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Startup Manual (SUM) Section 4.7, Records Management, Revision 8 Operations Quality Assurance (0QA) Manual Section 17,
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Quality Assurance Records, Revision 0 EQA Procedure (EQAP) 17.1, Engineering Quality Assurance
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Office File System, Revision 3 EQAP 17.2, Engineering Quality Assurance Records Shoreham
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Permant Plant Files, Revision 1 QAP-S-17.1, Station 0QA Records, Revision 1
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QAP-S-17.2, Station 0QA Use of the Permanent Plant File
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System, Revision !
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b.
Program Review The documents referenced above were reviewed to determine that administrative controls for Startup and Test phase records have been established in accordance with the requirements described in FSAR Chhpter 17.lD, Transition from Construction Phase to Operation Phase Quality Assurance, Revision 6.
No items of noncompliance were identified.
c.
Implementation The inspector toured the "Startup Resource Center" and " Permanent Plant File" record storage facilities and noted that the licensee had already begun to establish the " Permanent Plant File System" inasmuch as the latter facility, which was the A/E's construction phase record repository, was now under the direct supervision of a licensee employee.
The inspector interviewed various licensee personnel and deter-mined that startup phase activities were minimal.
The inspector also detemined that the few records that have been generated were being processed and maintained in accordance with established requirements. The inspector stated that the implementation of the records system with respect to startup activities will be reviewed during a subsequent inspection (s).
No items of noncompliance were identified.
6.
Quality Verification Activities (Audit / Surveillance)
a.
References QAP-S-16.1, Station 0QA Corrective Action, Revision 1
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QAP-S-16.2, Site 0QA Quality Trend Analysis, Revision
QAP-S-18.1, Site OQA Audit Procedure (General), Revision
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QAP-S-18.2, Station Operational Quality Assurance Surveil-
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lance Procedure (General), Revision 1 QAI-10.4-01, Station 00A Repair / Rework Request Control
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Prior to Plant Operations, Revision 0 o
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QAI-14.1-01, Site 00A Review of Conditional Subsystem / System
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Release, Revision 0 QAI-15.1-01, Station 00A Deficiency Control During C&IO
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and Preoperational Testing, Revision 2 QAI-16.1-01, Station 0QA Corrective Action Request Distri-
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bution, Revision 0 QAI-18.1-01, Site 00A Audit Schedule and _ Reports During
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C&IO and Preop Testing, Revision 0 EQAP 18.2, Quality Audit and Surveillance of Field Activities,
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Revision 6 EQAI 18.2.1, Shoreham LILCO Field QA Office Instructions,
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Revision 1 b.
Audits Selected audits and associated corrective actions conducted by the LILC0 Site QA Division Manager and the LILC0 Site Operating QA Engineer were reviewed.
The audits covered the period from June, 1978 to the present.
The selected audits addressed the following ongoing activities being conducted prior to the commencement of safety related system turnovers and subsequent preoperational testing.
Initial spare parts procurement; and, material control
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Personnel qualifications of the LILC0 plant staff; and,
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the management of records conducted by the Plant Staff
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The operation and administration of the SR-2 record retrieval system
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The initial implementation of administrative controls by the Startup group The implementation of an audit / surveillance program
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conducted by the LILC0 Site 00AE
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These audits were r.: viewed to verify that:
The audits were conducted in accordance with established
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procedures and schedules; The audits provided coverage of the LILC0 site organizations
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consistent with the responsibilities assigned; Checklists utilized were consistent with the procedural
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requirements applicable to the audited organization; and,
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Followup action was consistent with established procedures.
No items of noncompliance were identified; however, two items were identified and are discussed below.
(1)
FSAR Section 17.1.2D states that quality assurance proce-dures/ instructions necessary prior to fuel loading will be based on the Operational Quality Assurance Pro-gram (0QA). The 00A program is described in FSAR Section 17.2.
FSAR Section 17.2.2 states that the procedures are derived from the Operational Quality Assurance Manual (00AM).
0QAM Section 16.3.9 requires that reviews of applicable reports be conducted for possible adverse quality trends.
If adverse quality trends are identified this must be documented and corrective action taken.
After discussing the implementation of the procedural requirement with the LILCO Site Operating QA Engineer, the inspector stated that the specific method of per-forming the required review for adverse quality trends needed further clarification.
The licensee acknowledged
- .ne inspector's comments and stated that the manner in which the requirements of 0QAM Section 16.3.9 will be implemented during the transition phase from construc-tion to operations will be determined and documented by July 1, 1979.
Pending review of the licensee's actions by RI, this item is unresolved (J22/79-05-04).
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(2) The inspector noted that, in some cases, the audited organization did not respond in writing within thirty days after receipt of the audit findings. The proce-dure utilized had been written to comply with ANSI N45.2.12, Draft 3, Revision 4, which specifies the thirty day period for written responses where necessary.
The inspector further noted that the lateness of written responses had been internally identified and documented in Audit Report FA-904, dated March 16, 1979.
The inspector further noted that fonnal responses to the audit findings had been secured or a new date estab-lished for fonnal response.
Therefore, no items of noncompliance were identified.
However, the conduct of the 00AE's audit program and associated corrective action will be reinspected during 3 subsequent NRC inspec-tion (322/79-05-05).
c.
surveillance Selected areas of the documented surveillance program per-formed by the 00AE during the period between June,1978 and the present were reviewed to verify that:
Surveillance coverage of activities was consistent with
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established procedures; Checklists were utilized and incorporated qualitative
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and quantitative acceptance criteria as appropriate; and, Deviations /nonconformances were documented.
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No items of noncompliance were identified.
7.
Plant Tour The inspector, accompanied by a licensee representative, conducted a tour of the Control Building (and Control Room.2) LILC0 Deficiency Reports The tour was conducted with respect to two Numbers 266 and 267, which addressed cleanliness of electrical switchgear and cabinets that had been turned over to LILC0 start-up from construction.
The inspector examined, on a random sampling basis, several 4160V breakers and miscellaneous control cabinets.
The examined cabinets were clean with only a light dust accumulation.
General areas observed exhibited acceptable cleanliness with no ee,.m -
lation of fire hazards. This area will be inspected by RI on a continuing basis.
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8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items disclosed during this inspection are discussed in Paragraphs 4.c(2) and 6.b(1).
9.
Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 30, 1979.
The inspectors summarized the purpose, scope, and findings of the inspection.
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