IR 05000322/1985026

Insp Rept 50-322/85-26 on 850612-14.No Violation Noted.Major Areas Inspected:Licensee Action on Outstanding Items, Radiological Controls Organization,Staffing & Training,Ie Bulletin 80-10 & Startup Testing

ML20133L147
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/29/1985
From:	Myers L, Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133L139	List: IR 05000322/1985026 ML20133L137
References
50-322-85-26, IEB-80-10, NUDOCS 8508120510
Download: ML20133L147 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-26 Docket N License N NPF-19 Priority -

Category B Licensee: Long Island Lighting Company 175 East Old York Road Hicksville, New York 11801 Facility Name: Shoreham Nuclear Power Station Inspection At: Shoreham, New York Inspection Conducted: June 12 - 14, 1985 Inspectors: k L . td M R. L. Nimitz, Senior Ra'diation 7lhlBS date Specialist M NI M kos rjt L tl 2 5 L. fi. Myers Radiatio. 4 pecialist date fl l h -

I Approved by: Af\ @ G v@

W.VJ. Pksdiak, Chief, BWR 7 Vi W

date Radiological Protection Section Inspection Summary

Inspection on June 12-14, 1985 (Report No. 50-322/85-26)

Areas Inspected: The following matters were reviewed: licensee action on out-standing items; review of radiological controls organization, staffing and training; IE Bulletin 80-10; general employee training, plant tours, and start-up testing. The inspection involved 35 inspector hours onsite by two region-based inspector Results: No violations were identified. The licensee was found to have ade-quately addressed a number of previous NRC findings. Also, the licensee was found to have a well defined Radiological Controls Organizatio PDR G ADOCK 05000322 PDR

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DETAILS 1.0 Individuals Contacted 1.1 Long Island Lighting Company

• W. Steiger, Jr. , Plant Manager

• J.F. Schmitt, Radiological Controls Division Manager

• R. A. Kubinak, Director, QA, Safety and Compliance

• E.P. Stergakos, Radiological Protection Division Manager

• R. Grunseich, Supervisor, Nuclear Licensing

• N. DiMascio, Health Physics Engineer

• A.R. Muller, Quality Control Division Manager

• N. Marcos, Radiochemistry Engineer

• R. Jongeblood, Staff, Radwaste Section

• T.S. Bulischeck, Staff Engineer 1.2 Contractors

• G. Rhoads, Operations Compliance Engineer, Impell In *B. Kobel, Nuclear Licensing, Impell In *W.L. Sutor, Operations Compliance, Impell In .3 Nuclear Regulatory Commission P.W. Eselgroth, Senior Resident Inspector

• Denotes those individuals attending the exit meeting on June 14, 198 The inspector also contacted other individuals during the cour. 2 of this inspectio .0 Purpose of Inspection The purpose of this routine, ar.nounced radiological controls inspection was_to examine the following:

• Licensee action on previous NRC findings (i.e. open items);

• Radiological controls organization;

• Radiological controls organization personnel training program;

• General employee training program implementation;

• Operability of plant area and effluent radiological monitor-ing equipment;

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• IE Bulletin 80-10; and

• Start-up testin .0 Licensee Action on Previous Inspection Findings

' (Closed) Follow-up Item (50-322/84-43-01) Licensee to revise appro-priate administrative documents to describe the new Radiological Con-trels Organization. The licensee revised all appropriate station ad-ministration documents in a timely manrer to clearly describe the new Radiological Controls Organization (Details section 4.0 of the re-port.)

3.2 (Closed) Follow-up Item (50-322/84-43-02) Licensee to select maximum permissible concentration value/ values for use in estimating person-nel exposure to airborne alpha radioactivity concentrations. The licensee has performed comprehensive reviews of the alpha emitters to be encountered during initial operations of the facility. Based on these reviews, the licensee has selected a conservative methodolo-gy for estimating and limiting exposure to this materia This matter is close .3 (Closed) Follow-up Item (50-322/84-43-03) Licensee to revise descrip-tion of Radioactive Waste Organization responsibilities to reflect recent changes in responsibilities. The licensee revised the appro-priate administrative documents in a timely manner to clearly des-cribe the revised responsibilities. This matter is close .4 (Closed) Follow-up Item (50-322/84-43-04) Licensee to establish a retraining program for members of the Radioactive Waste Organizatio The inspector reviewed and discussed the retraining program for all members of the Radioactive Waste Organization. Excluding the re-training program for Radioactive Waste Operations personnel, a de-fined retraining program, commensurate with an individual's responsi-bilities, was established for all appropriate members of the organi-zation. The programs are acceptable. The licensee is currently re-viewing and revising the Radioactive Waste Operations personnel re-training program. Inspector discussions with licensee personnel indicated the retraining program for the operations personnel will include all appropriate training guidance discussed in IE Bulletin 79-19, " Packaging of Low-Level Radioactive Waste for Transport and Burial," dated August 20, 1979. The licensee is also reviewing ap-propriate industry standards (e.g. ANSI) to identify and incorporate all appropriate training recommendations. The licensee anticipates fully establishing and implementing the radioactive waste operations personnel retraining program by January,1986. This matter will be reviewed during a subsequent inspection (50-322/85-26-01). (Note:

The licensee has an adequate number of trained and qualified person-nel to implement radioactive waste operations through normal operations.)

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3.5 (Closed) Follow-up Item (50-322/84-43-06) Licensee to obtain approval for the radioactive waste material package QA Program. The licen-see's QA Program was reviewed by NRC and found acceptable for radio-active material packages. The licensee's approval expires April 30, 1989. This matter is close .6 (Closed) Follow-up Item (50-322/84-25-06) Licensee to complete post-fuel load IE Bulletin 80-10 action items. The inspector reviewed the implementation of the licensee's post fuel load IE Bulletin 80-10 action items. Discussions with cognizant licensee personnel, review of documentation, and review of in-field work (e.g. installation of check valves) indicated the licensee implemented his post fuel load items. The licensee's actions on this bulletin exceeded the minimum requirements specified therei .7 (Closed) Follow-up Item (50-322/84-25-07) Licensee to provide docu-mentation to demonstrate that the Control Room Ventilation Sys-tem would maintain thyroid dose to personnel in the control room to within General Design Criterion 19 guidanc The inspector re-viewed representative calculations performed by the licensee's con-tractor which indicated the thyroid doses would be within'the appli-cable guidelines. This matter is close .8 (Closed) Follow-up Item (50-322/84-08-01) Licensee to improve the timeliness of submittal of Radiological Environment Monitoring Quali-ty Assurance Reports. The inspector discussed this matter with licensee Radiological Environmental Monitoring Program personnel and reviewed the timeliness of submittal of such report Review of sub-mittal times of the QA reports for. January - April,1985 indicated the reports were submitted in a timely manner. The licensee has significantly improved the timeliness of submittal of the report .9 (Closed) Follow-up Item (50-322/84-08-03) Licensee to revise the training procedures for Radiological Environmental Monitoring Pro-gram (REMP) technicians to indicate what type of training is re-quired and when such training has been successfully completed. The

. inspector reviewed the REMP procedure manual,Section III, REMP Training Program for Field Technicians.Section III clearly indi-cates required training for minimum qualifications, provides for documentation of training dates and sign-offs, identifies retraining required, and requires placement of training documentation in appro-priate files. This matter is close .10 (0 pen) Unresolved Item (50-322/80-02-01) NRC to review licensee main steam isolation valve leakage control system (MSIV-LCS). This matter is discussed in section 6 of this repor .11 (0 pen) Unresolved Item (50-322/80-02-02) NRC to review licensee primary containment atmosphere control system (PCAC). This matter is discussed in section 7.0 of this repor .

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4.0 Organization, Staffing and Training The inspector reviewed the licensee's Radiological Controls Organization, Organization staffing and training. The review was with respect to cri-teria contained in the following:

Technical Specification 6.2, " Organization";

Technical Specification 6.3, " Unit Staff Qualifications";

• Technical Specification 6.4, " Training";

Procedure SP 12.002.01, Revision 7, " Organization and Administration";

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Procedure SP 61.001.01, Revision 5, " Health Physics Program - Policy

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and Objectives";

Procedure SP 71.002.01, Revision 5, " Radiochemistry Section Policy and Objectives"; and

Procedure SP R1.001.01, Revision 0, "Radwaste Program - Policy and Objectives".

The evaluation of the licensee's performance in the area was based on re-view of inplace organizations, discussions with cognizant personnel, re-view of documentation including personnel training records.

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4.1 Organization The inspector review indicated the inplace radiological controls

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organization is consistent with the Technical Specifications and pro-cedural described organizations. The organizations and respective position functional responsibilities and authorities are clearly des-cribe .2 Staffing / Training

The inspector reviewed the staffing and training of the following groups:

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a Radiochemistry Section

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• Radwaste Section

• Health Physics Section

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a Radwaste Operations The review indicated a sufficient number of appropriately trained and qualified personnel are available to support facility operations i during normal operation '

The licensee's training programs in the above areas had been pre-viously reviewed and found acceptable, no significant changes to these programs had been made since the previous review of them.

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5.0 General Employee Training The implementation of the training and retraining program for General Employee's was reviewed against criteria provided in SP Number 12.014.03, Revision 3, " General Employee Training," dated April 10, 1985. The licensee's performance in the area was determined by review of class attendance and tests results and training records of individuals selected at random from the Authorized Complement - Station Organization Char Within the scope of this review, the following was noted:

All personnel had been trained or retrained in accordance with proce-dural requirement * Class attendance and test results records were maintained in an orderly-manne The training and retraining program had been previously reviewed and found to meet the requirements of 10 CFR 19.12 " Instructions to Workers."

The licensee's training programs in the above areas had been previously reviewed and found acceptable, no significant changes to these programs had been made since the previous review of the .0 Main-Steam Valve Leakage Control System NRC Inspection Report 50-322/80-02 identified three concerns associated with the Main Steam Isolation Valve Leakage Control System. The licensee's actions on the three concerns: physical separation; post-acci-dent discharge; and operating procedures, were reviewed. The following doc-uments were reviewed:

• System Description No. 1020.406 (S&W 1E32), "MSIV Leakage Control",

• Procedure SP 23.406.01, Revi; ion 3, "MSIV Leakage Control System",

• Final Safety Analysis Report (FSAR) Section 6.5, "MSIV Leakage Control",

• FSAR, Section 15, " Accident Assessment", and f a Technical Specification 3.6.1.4 "MSIV Leakage Control System".

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The MSIV Leakage Control System controls and minimizes the release of

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fission products that could leak through the closed inboard and out-board Main Steam Isolation Valves (MSIV's) after a loss-of-coolant i accident (LOCA). MSIV leakage is directed to the Reactor Building Standby Ventilation System via the MSIV-LCS inboard and outboard i subsystem.

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6.2 Physical Separation Findings:

The licensee's FSAR section 6.5.3.2 stated that the upstream and down stream subsystem are physically separated. This was found not to be the cas Resolution:

The systems were not required to be physically separated because the MSIV-LCS by design is a post-accident system and not a safe shutdown system. (Reference Inspection Report 50-322/80-02)

The licensee revised section 6.5.3, " Design Safety Evaluation", of the FSAR to specify that the systems were electrically separated. The

reference to physically separated was removed This concern is close *

6.3 Post-Accident Discharge Findings:

The MSIV-LCS discharges into the Reactor Building (i.e. Secondary Containment) Atmosphere. This was considered to be a potential

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problem in that personnel access to the Reactor Building could be limited following post-accident use of the system and possible con-tamination of the reactor building atmospher Resolution:

The licensee does not plan to make routine, post-accident entries in-to the Reactor Buildin The licensee has configured his post-accident operations capabilities to preclude unnecessary entry into this building for such matters as 4 equipment operation or equipment maintenanc Consequently, post-ac-cident radiation exposure to personnel for purposes of operating and/

or performing maintenance of vital equipment in Secondary Containment will be minimized.

, The issue of acceptability of post-accident MSIV-LCS discharge into

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reactor facility Secondary Containment atmospheres (e.g. the Reactor Building Atmosphere of the Shoreham Station) is currently under Generic review by the NRC. Upon 1) completion of this review, 2) evaluation of the review findings, and 3) determination of their generic implications, the NRC will initiate appropriate guidance (as necessary) relative to this issu :

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-A Supplemental Safety Evaluation Report (SSER) of the MSIV-LCS dis-charge to Secondary Containment at Shoreham was performed by the NRC in February,1982. This safety evaluation concluded that the system discharge is acceptable as installe In consideration of the fact that:

1) the licensee does not plan to make routine post-accident entries into the Reactor Building; 2) the licensee has configured his post-accident operations to limit such entries; 3) the issue of MSIV-LCS discharge to secondary containment atmos-phere is currently under generic review by the NRC; and 4) a safety evaluation was performed which indicated the discharge location is acceptable, the current discharge location of the system is considered ac-ceptabl Apprcpriate reviews of the area will be initiated following estab-lishment of NRC generic guidance (as appropriate) on the issue of MSIV-LCS discharge to Secondary Containment atmospher However, the following matters remain open and will be reviewed during a subsequent inspection: (50-322/80-02-01).

Based on a July 10, 1985 telephone conversation with licensee representatives, the following actions will be undertaken:

The licensee will review and revise (as necessary) specific procedures detailing operation of the MSIV-LCS to address the following:

• operation (initially) of the outboard subsystem with Watch Engineer approval;

• reviews of apprcpriate parameters and development of symptoras oriented guidance in the procedures to determine the need to operate the inboard subsystem;

• include appropriate levels of approval (i.e., Emergency Director) prior to start of inboard subsystem;

• correction of a precautionary statement in procedure SP23.406.01 relative to MSIV-LCS discharge location and the potential for contaminating the reactor building atmospher .

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The discussions indicated that above matters will be addressed within 60 day .4 Operating Procedures Findings:

The review of the MSIV-LCS operating procedure, SP 23.406.01, indi-cated it did not contain specific guidance relative to the following:

• Start-up of the system within about 20 minutes post-accident as discussed in Regulatory Guide 1.96, " Design of Main Steam Line Isolation Valve Leakage Control Systems for Boiling Waste Reac-tors",

• the possibility that initiation of the system would not be required if the main condenser was still intac Resolution (20 minutes start time)

Regulatory Guide 1.96 states that a fully automatic quick-acting leakage control system is not required to meet the system objectiv Rather a manually initiated system, capable of being activated within about 20 minutes of an accident requiring use of the system, would be acceptabl The licensee included guidance in procedure SP No. 23.406.01, "MSIV Leakage Control System," section 8.1, Normal Performance, to include guidance relative to inboard and outboard system operation within the recommended 20 minute time perio This concern is close (Note: This guidance may be revised to provide more explicit guidance based on licensee planned action discussed in Section 6.3.)

Resolution (System Start-up not necessary if Main Condenser Intact)

The licensee has reviewed the matter and indicated that the need for operation of the MSIV-LCS should be based on review of additional parameters other than a determination that the Main Condenser is in-tact. The licensee's principle need for operating the system is to preclude migration of post-accident liquids / steam downstream of main steam isolation valves regardless of whether the Main Condenser is or is not intact. This is to prevent effluent releases to the Turbine Building. As a-result, the licensee has not taken action to include specific guidance relative to operation of the system if the Main Condenser is intac This concern is close (Note: The licensee plans to include additional guidance in

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specific procedures relative to separate operation of the inboard and outboard subsystem as discussed in Section 6.3.)

7.0 Primary Containment Atmosphere Control System NRC Inspection Report 50-322/80-02 identifies one concern associated with the Primary Containment Atmosphere Control (PCAC) System. The licensee's action on this concern, PCAC System discharge into Secondary Containment was reviewed. The following documents were reviewed:

System Description No. 1020.402 (S&W IT48), " Primary Containment Post LOCA Hydrogen and Oxygen Control",

• Procedure SP No. 23.402.01, Revision 8, " Primary Containment Post LOCA Hydrogen and Oxygen Recombination",

Procedure SP No. 29.023.03, Revision 10, " Containment Control Emergency Procedure", and

FSAR Section 6.2, " Primary containment Atmosphere Control System".

7.1 General The Primary Containment Post-LOCA Hydrogen and Oxygen Control System monitors and controls the concentration of hydrogen and oxygen generated in the drywell and suppression chamber in the event of a LOC Primary post-LOCA hydrogen and oxygen control is by use of two hydrogen recombiner In the event that both of the 100 percent capacity recombiners fail, a back-up nitrogen dilution / primary con-tainment purge system is available to dilute the containment atmos-phere to maintain post-LOCA hydrogen and oxygen concentration below the explosive leve .2 Purge Discharge Findings:

The nitrogen dilution / primary containment purge system discharges directly to Secondary Containment. Similar to item 6.3 (above), this is considered to be a potential problem in that personnel access to the Reactor Building could be limited following post-accident use of the syste Resolution:

The resolution of personnel access to the Secondary Containment is similar to Section 6.3 above in that:

1) the licensee does not plan to make routine post accident entries into the Reactor Building; i

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2) the licensee has configured his post accident operation to limit such entries; and 3) a safety evaluation was performed by the NRC which indicates the discharge location of the PCAC System is acceptabl However, the following matters' remain open and will be reviewed during a subsequent inspection: (50-322/80-02-02):

Based on a July 10, 1985 telephone conversation with licensee representatives, the following action will be undertaken:

(50-322/80-02-02)

The licensee will review and revise (as necessary) specific procedures detailing operation of the PCAC system to address the following:

development of symptoms oriented procedural guidance based on review of appropriate parameters to determine the need to initiate the system,

the licensee will specify appropriate levels of approval (i.e. , Emergency Director) prior to initiation of the system,

upgrading of precautionary statements relating to discharge of radioactivity into secondary containment atmospher The discussions indicated the above matters will be addressed within 60 day .0 Start-up Testing (Surveys)

The inspector reviewed the Start-up Radiation Survey Program with respect to criteria contained in the following:

ANSI /ANS - 6.3.1, 1980, " Program for Testing Radiation Shields in Light Water Reactors",

ANSI-N323, 1978, " Radiation Protection Instrumentation Test and Calibration",

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Regulatory Guide 1.68, November 1978 "Preoperational and Start-up Test Program for Water-Cooled Power Reactors (LWR)",

Procedure SP No. 12.075.01, Revision 9, " Administration of Start-up Testing", and

Procedure STP No. 2, Revision 3, " Radiation Measurements".

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The evaluation of the licensee's performance in this area was based on discussions with cognizant licensee personnel and review of documentation.

Within the scope of this review, no deficiencies were identifie .0 Plant Tours The inspector made periodic tours of the facility during the inspectio The following was reviewed:

i a Visible condition of plant (e.g. housekeeping);

Condition of radiological control postings and barricading;

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Personnel access control via radiological access control points;

Operability of area radiation monitoring systems;

Operability of plant effluent monitoring systems; and

Staffing of radiological controls personnel during normal and back shift Within the scope of this review, no violations were identified.

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Excluding the following comments, no significant concerns were identifie The following matters were brought to the licensee's attention:

Radioactive Material Storage Area signs on the Refueling Floor were found partially obscured from vie ,

The licensee repositioned the signs in a timely manner.

I * A " Reject Tag" was found hanging on an instrument line associated with Train 'A' of the Reactor Building Standby Ventilation System.

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The licensee initiated an immediate review of the purpose of the tag i

and determined it had not been removed following completion of work on the line. Work orders associated with tag had been closed. The licensee removed the ta : 10.0 Exit Interview The inspector met with licensee representatives (identified in section 1 of this report) on June 14, 1984. The inspector summarized the purpose, scope and findings of the inspectio . l

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The inspector provided to the licensee a copy of Report 50-322/85-0 The inspection report, dated June 5,1985, was released at that time and is available in the Public Document Roo The inspector also brought to the licensee's attention American National Standard ANSI /ANS 6.3.1-1980, "American Nation Standard Program for Testing Radiation Shields in Light Water Reactors (LWR)".

No other written inaterial was provided to or shown to the license ,

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