IR 05000322/1982017

Forwards,For Info,Ie Insp Rept 50-322/82-17

ML20055B429
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/19/1982
From:	Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Brenner L, Carpenter J, Morris P Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8207220245
Download: ML20055B429 (4)

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e July 19, 1982 In the Matter of Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50_322 (0L)

NOTE TO ATTACHED SERVICE LIST Enclosed for your information is a copy of NRC Region I Inspection Report 82-1

Sincerely, J

Bernard M. Bordenick Counsel for NRC Staff

Enclosure:

As stated

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Distribution:

Bordenick/Dewey/Perlis

Repka/ Black /Rawson Reis/Lessy Cunr.ingham/Murray l

Christenbury/Scinto OELD Formal Files (2)

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Docket Files /PDR/LPDR J. Higgans A. Schwencer-116C F. Weinkam/R. Gilbert-330 J. Norris-AR-5008 bSo^1:

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

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(ShorehamNuclearPowerStation, )

Unit 1) )

Lawrence Brenner, Esq.* Ralph Shapiro, Es Administrative Judge Camer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, NY 10016 Washington, Dr. James L. Carpenter *

Administrative Judge Howard L. Blau, Es Atomic Safety and Licensing Board 217 Newbridge Road U.S. Nuclear Regulatory Comission Hicksville, NY 11801 Washington, DC 20555 Dr. Pete" A. Morris * W. Taylor Reveley III, Es Administrative Judge Hunton & Williams Atomic Safety and Licersing Board P.O. Box 1535 U.S. Nuclear Regulatory Commission Richmond, VA 23212 Washington, DC 20555

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Matthew J. Kelly, Es Kirkpatrick, Lockhart, Johnson Staff Counsel & Hutchison

, New York Public Service Comission 1500 Oliver Building l

3 Rockefeller Plaza Pittsburgh, PA 15222 Albany, NY 12223 l

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Stephen B. Latham, Es John F. Shea, III, Es Herbert H. Brown, Es Twomey, Latham & Shea Lawrence Coe Lanpher, Es Attorneys at Law Karla J. Letsche, Es P.O. Box 398 Kirkpatrick, Lockhart, Hill, 33 West Second Street Christopher & Phillips Riverhead, NY 11901 1900 M Street, th Floor Washington, Atomic Safety and Licensing Board Panel * Docketing and Service Section*

U.S. Nuclear Regulatory Commission Office of the Secretary

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Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel *

U.S. Nuclear Regulatory Commission Washington, DC 20555

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COURTESY COPY LIST Edward M. Barrett, Es Mr. Jeff Smith General Counsel Shoreham Nuclear Power Station Long Island Lighting Company P.O. Box 618 250 Old County Road North Country Road Mineola, NY 11501 Wading River, NY 11792 Mr. Brian McCaffrey MHB Technical Associates Long Island Lighting Company 1723 Hamilton Avenue 175 East Old Country Road Suite K Hicksville, New York 11801 San Jose, CA 95125 Marc W. Goldsmith Hon. Peter Cohalan Energy Research Group, In Suffolk County Executive 400-1 Totten Pond Road County Executive / Legislative Bldg Waltham, MA 02154 Veteran's Memorial Highway Hauppauge, NY 11788 David H. Gilmartin, Es Suffolk County Attorney Mr. Jay Dunkleberger County Executive / Legislative Bld New York State Energy Office Veteran's Memorial Highway Agency Building 2 Hauppauge, NY 11788 Empire State Plaza Albany, New York 12223 l

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JUN 2 21982 .

Docket No. 50-322 Long Island Lighting Company ATTN: Mr. M. S. Pollock Vice President - Nuclear 175 East Old Country Road Hicksville, New York 11801 Gentlemen:

Subject: Inspection No. 50-322/82-17 This refers to the routine safety inspection conducted by Mr. W. Rekito of this office on June 1-4, 1982, at Shoreham Nuclear Power Station of activities author-ized by NRC License No. CPPR-95 and to the discussions of our findings held by Mr. Rekito with Mr. R. Werner and others of your staff at the conclusion of the inspectio Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspecto Within the scope cf this inspection, no violations were observe .

In a

REGION I==

Report N /82-17 Docket N .

License N CPPR-95 Priority --

Category B Licensee: Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801 Facility Name: Shoreham Nuclear Power Station Inspection At: Shoreham, New York Inspection Conducted: June 1-4, 1982 Inspector: d /Fa [o /[12/f2_

W. A. Rekito,# Reactor Inspector dite signed Approved by: NMMMu L. H. Beftenhausen, Chief, Test Programs I/2.2/#2 date signed Section, Engineering Inspection Branch Inspection Summary:

Inspection on June 1-4, 1982 (Report No. 50-322/82-17)

Areas Inspected: Routine, unannounced inspection of preoperational test program l

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activities including primary containment penetration leakage rate testing procedures

! and records review and test witnessing, primary containment

structural acceptance test procedure review, primary containment integrated

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leakage rate test procedure review; tours of the facility; and followup on j previous inspection findings. The inspection involved 26 inspector-hours i onsite by one region based NRC inspecto Results: No violations were identified.

l Region I Form 12 (Rev. February 1982)

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DETAILS 1.0 Persons Contacted 1.1 Long Island Lighting Company (LILCo)

• R. Gutmann, Maintenance Engineer

• J. Rose, 0QA Engineer

• C. Seaman, Senior Assistant Project Engineer J. Ricardo, Lead Startup Engineer

• R. Werner, OQA Engineer

• E. Youngling, Startup Manager 1.2 Stone and Webster (S&W)

• S. Aitken, Startup Test Engineer

• W. Matejek, Lead Advisory Engineer R. Thompson, Startup Test Engineer U. S. Nuclear Regulatory Commission J. Higgins, Senior Resident Inspector

• P. Hannes, Resident Inspector The inspector also interviewed other licensee and contractor employees during the course of the inspectio They included operating, maintenance, testing, and construction personne * denotes those present at the exit interview held June 4, 198 .0 Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (322/80-14-06): HPCI turbine exhaust check valve not included in the preoperational leak rate test procedures. The licensee included the requirement to test the subject containment isolation check valve E41-0022 in Procedure PT.654.003, Revision 1, Primary Containment l Leak Rate Test - Type C. This item is resolved.

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l (Closed) Unresolved Item (322/80-14-07): The Suppression Chamber level instruments were not included in the preoperational leak rate test procedures.

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The licensee included the requirement to test the subject instruments and sensing lines in Procedure PT.654.002, Revision 1, Primary Containment Leak Rate Test - Type B. This item is resolved.

, (Closed) Unresolved Item (322/80-14-08): The preoperational leak rate l test procedures specified use of a non-conservative downstream flow measure-l ment metho The licensee revised Procedure PT.654.003 to specify use of the more conservative make up flow measurement method for testing

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penetration X-12 and other The inspector noted that the revised procedure does make use of the downstream measurement method for some penetration tests as a supplemental leakage verification and as a leak path investiga-tive too The inspector discussed the applications of this practice with the licensee and determined that it was useful and adequately controlle This item is resolve (Closed) Unresolved Item (322/82-04-09): The preoperational leak rate test procedure did not provide adequate downstream venting for testing certain valves. The licensee revised Procedure PT.654.003 to provide an adequate downstream vent path for each of the valves identified and reviewed the test procedures for all containment isolation valves (CIVs) in the RHR system to verify test differential pressure was assured across the CIV being tested. The inspector discussed the importance of this concern and proper testing technique with the licensee and was assured that adequacy of test technique was being evaluated during the conduct of each CIV leakage rate test. This matter is considered resolve (Closd) Unresolved Item (322/82-08-02): Several inadequacies and concerns were identified during review of Procedure PT 654.003, Revision 1, Primary Containment Leak Rate Test - Type C, and CIV test witnessing. Resolution of each item is described separatel (1). The licensee acknowledged the flowmeter reading correction equation to be in error ar.d documented the correct equation in the test procedure exceptions lis (2). The procedure guidance for daily test panel bypass valve leakage testing was improved and documented in the test procedure exceptions list. The inspector observed the conduct of this routine check and determined that the technique was adequat (3). The licensee included a test gas temperature measurement as part of each CIV leakage test. For those valves already tested, a conservative assumed temperature of 65 F will be used in the flowmeter reading correction equation. This change is documented in the test procedure exceptions lis (4). The licensee consulted the flowmeter manufacturer and conducted experi-ments which concluded that minor test panel off level conditions during tests had an insignificant effect on the accuracy of these flowmeter readings. This conclusion, along with observations of test technicians practice to check test panel positioning with a leveling instrument, satisfied the inspector's concer )

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', 4 3.0 Containment Local Leakage Rate Testing (LLRT)

3.1 Documents Reviewed

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ANSI /ANS-56.8-1981, Containment System Leakage Testing Requirement FSAR Section 14.1.3, Primary Containment Leakage Rate Test NUREG-0420, April 1981, and Supplement No. 1, September 1981, Safety Evaluation Report related to operation of Shoreham Nuclear Power Station, Unit No. PT.654.003 - Revision 1, Preoperational Test Procedure, Primary Containment Leak Rate Test - Type PT.654.002 - Revision 1, Preoperational Test Procedure, Primary Containment Leak Test - Type Records of Local Leak Rate Test Activities including test results, related repair and retest documentatio Selected Drawings, System Piping and Instrumentation Diagram .2 Scope of Review The inspector reviewed the above documents to ascertain compliance with regulatory requirements of 10 CFR 50, Appendix J, and licensee commitments in the FSAR. The inspector also witnessed LLRT activities, examined special test instrumentation, reviewed qualifications of test personnel and discussed current NRC positions regarding containment leakage rate testin Further details and inspection findings are described belo .3 Testing Program Status The licensee has successfully completed the testing of approximately one half of the 215 CIVs required to be leakage rate tested. However, the licensee explained that unofficial leakage tests were previously conducted on all CIVs and those with unacceptable high leakages were repaired and retested. The remaining CIV official tests and all Type B LLRT of penetration seals are expected to be completed by August, in preparation for the containment integrated leakage rate test scheduled for mid August 198 . . . _ . . _

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3.4 LLRT Procedure Problems Various discrepancies and technical inadequacies of PT.654.003, Primary Containment Leak Rate Test - Type C were previously identified. Their resolution is described in Paragraph 2 of this repor During review of PT.654.002, Primary Containment Leak Rate Test - Type B, two problems were identified. They are described below, along with licensee's actions to resolve each concern. No violations were identi-fie (1) As in the Type C test procedure, the specified equation for correcting the rotameter reading was nonconservative and incorrec The licensee acknowledged this error and initiated a procedure change which corrected the equation. The Startup Manager assured the inspector that this change would be incorporated during the next Joint Test Group (JTG) meetin (2) The method of determining the leakage assigned to the Personnel Airlock Penetration was nonconservative in that it considered door seal leakage only and not leakage past the bypass or equalizing valves. The licensee acknowledged this deficiency and initiated a procedure change to conservatively assign the results of the full airlock test to the penetration leakage for the combined Type B and C leakage total. The Startup Manager assured the inspector that this change would be incorporated during the next JTG meetin .5 Test Witnessing On June 3, 1982, the inspector witnessed a Type C LLRT of CIVs T48 SOV-129A, B. The test was conducted in accordance with approved Procedure PT.654.00 Instrument air was used to pressurize the test volume from the air sample location at the North-West Suppression Chamber Hatch. The tests resulted in minimum detectable leakage and was accordingly found acceptabl The inspector observed the performance of the test to ascertain that prerequisites were met, proper precautions were taken, measuring and test equipment was properly calibrated and the test performed in accordance with the approved p-ocedur No unacceptable conditions were identifie .6 Test Documentation Control During review of PT.654.003 and records of completed Type C tests, the inspector noted numerous minor errors in procedural guidance and test boundary diagrams, many of which were obviously typographica ..

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The Test Engineers recognized most of these and were making appropriate corrections to the official field copy of the test procedure as indivi-dual tests were being conducted. In addition, the test engineers were documenting other changes to the test procedure found necessary for individual test completion and recognized improvement of test methods and procedural guidanc These actions were appropriate, particularly because of the procedure's stated secondary objective to implement and revise as necessary the corresponding Operational Surveillance Procedure. However, the inspector noted that these procedure changes were not being documented on the official test procedure Exception Sheet as required by Sections 4. and 8.3.3 of the Shoreham Startup Manual. After special discussions with the JTG, the Test Engineers recognized the Startup Manual intent to document each procedure change on the exception sheet when recognized as necessary. The inspector verified that the licensee corrected this discrepancy by updating the official test exception sheet with all

, procedure changes initiated to date. These corrective actions satisfied

! the inspector's concer No violations were identifie .7 Drywell and Suppression Chamber Gas Analyzers The four redundant hydrogen and oxygen analyzers described in FSAR Section 6.2.5 and shown on FSAR Figure 6.2.5-1 are designed with

! containment atmosphere sample lines which are normally open, and form a closed loop outside containment. As such, the gas analyzers are a primary containment leakage limiting barrier without remote or automatic isolation capabilities.

l The inspector examined the internal fabrication of the analyzer cabinets and noted the high potential for developing leaks at mechanical tubing fittings and gasketed joints, complicated by limited accessibilit The system test engineer stated that the accessibility problem was currently being evaluated by engineering for possible cabinet modifica-tion The licensee plans to test the leak tightness of these containment boundary components as part of the containment overall integrated leakage rate test but has no plans to include these in the more frequent local leakage rate test program. The inspector requested the licensee to justify not including these components in the Type B local leak rate test procedure intended to test all containment penetrations whose design incorporates resilient seals and gaskets. The Startup Manager stated that an engineering evaluation would be conducted to determine the possible applicability of additional required leak tight testing. This item is unresolved pending NRC review of licensee's further considerations. (322/82-17-01)

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4.0 Containment Structural Acceptance Test (CSAT)

4.1 Documents Reviewed

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Procedure CS.654.001, Primary Containment Structural Acceptance Tes S&W Specification SH1-333, Revision 1, Structural Acceptance Tes FSAR Sections 6.2 - Containment Systems and 3.8.1.7.1 - Concrete Containmen Regulatory Guide 1.18, Revision 1, Structural Acceptance Test for Concrete Containment .2 Scope of Review The licensee's containment is an Over-Under Reinforced Concrete (Mark II) Structure and is to be tested as a prototype containment. The inspector reviewed Test Procedure CS.654.001 to ascertain compliance with regulatory requirements, guidance, and licensee commitments in the FSAR. The inspector also discussed the status of test preparations with personnel responsible for the conduct and acceptance of the test, presently scheduled for June 18, 198 Based on the above review, the inspector identified the following concerns and discussed them with licensee managemen . Primary responsibility for conduct of the test and evaluation of results is delegated from the JTG to S&W Structural Engineering Departmen In addition, the test procedure did not contain clearly specified quantitative acceptance criteria for deflection, strain and concrete crack pattern measurements typical of a standard preoperational test procedure. The inspector questioned how this satisfied the regulatory guidance and administrative controls of the preoperational test progra The Startup Manager explained that administrative control is maintained by direct participation of the Shoreham Startup Department and JTG approval of the procedure as a special construction test procedur He also explained that final acceptance of the test will be by the JTG, following review of a test report completed by the S&W Engineering Department

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4. The containment liner has a test channel system covering every primary liner seam weld. These channels were used during construction for acceptance testing of the liner welds. FSAR Section 3.8.1.7.2 describes the weld channel system as divided into sections with conveniently located test nipples to permit leak tightr.ess tests of the liner seams at any time during the life of the plan The inspector identified an NRC position that all containment liner weld channels be vented to the containment atmosphere during the CSAT and containment integrated leakage rate tests (CILRT) unless the licensee has demonstrated that the weld channels maintain their integrity when subjected to the loading conditions of a Design Basis Accident (DBA). The licensee had no requirement in the CSAT procedure to verify the condition of the subject channels but assumed them to be sealed with threaded plugs in all vent holes. The inspector examined portions of the drywell containment liner and observed several weld channel vent holes without threaded plugs installe The inspector informed the licensee that the validity of the CSAT and CILRT with these channels not vented would require special review and exemption from the NRC general position by the responsible technical review branches of NRC:NR The Startup Manager acknowledged this need and committed to initiate an engineering evaluation to prepare justifications for not venting these weld channels. This matter is considered unresolved pending further licensee evaluations and NRC technical review. (322/82-17-02)

5.0 Containment Integrated Leakage Rate Test (CILRT)

The " Draft" Procedure PT.654.001, Primary Containment Preoperational Inte-

. grated Leak Rate Test - Type A was received but not reviewed during the inspection period. However, the inspector held discussions with licensee representatives responsible for the CILRT currently scheduled for August, t

1982. These discussions included licensee plans for preparation and personnel l

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training, current NRC positions regarding the CILRT and conformance with industry standard ANSI /ANS 56.8-1981, Containment System Leakage Testing requirement In addition, the inspector stated that the unapproved CILRT procedure would l be reviewed during a subsequent inspection. With the exception of the containment liner weld channel issued described in Paragraph 4.2.2, no

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unacceptable conditions were identified at this time.

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6.0 Plant Tours The inspector made several tours of the facility including the reactor containment, reactor building, control room and turbine buildin During these tours, the inspector observed and evaluated operations and activities in progress, and general condition of safety related equipmen In addition, the inspector examined selected primary containment system boundaries and control' of local leak rate test equipment. With the exception of the two unresolved items previously described no unacceptable conditions were identifie .0 Unresolved Items Items about which more infor:0clon is required to determine acceptability are considered unresolved. Eccragraphs 3.7 and 4.2.2 of this report contain unresolved items, 8.0 Exit Interview The inspector met with licensee representatives (see Detail 1 for attendees)

at the conclusion of the inspection on June 4, 198 The inspector summarized the scope and findings of the inspection at that tim With regard to item 322/82-17-02, the Startup Manager stated that an effort to resolve the containment liner weld channel venting issue was already initiated and would be pursued with NRC:NRR prior to the start of the CSAT, currently scheduled for June 18, 1982.

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