IR 05000322/1985098
| ML20207G874 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/24/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Leonard J LONG ISLAND LIGHTING CO. |
| References | |
| NUDOCS 8701070418 | |
| Download: ML20207G874 (5) | |
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A NOV 2 41986 Docket No. 50-322 Long Island Lighting Company ATTN: Mr. John D. Leonard, Jr.
Vice President - Nuclear P. O. Box 618 Shoreham Nuclear Power Station Wading River, New York 11792 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP)
Report No. 50-322/85-98 This letter refers to the Systematic Assessment of Licensee Performance (SALP)
of the Shoreham Nuclear Power Station for the period March 1, 1985 to February 28, 1986. The subject report was initially forwarded to you by our July 14, 1986 letter (Enclosure 1).
This SALP evaluation was discussed with you and your staff at a meeting at the Region I Office in King of Prussia, Pennsylvania, on July 29, 1986 (see Enclosure 2 for attendees). We have also reviewed your August 26, 1986 written comments to our report (Enclosure 3). Based on our review we have determined that no changes were warranted regarding the findings and conclusions of our initial report. Accordingly this transmits the final report (Enclosure 4).
We found the overall performance at the Shoreham Station to be acceptable during the assessment period. In those areas where appropriate management at_tention, resources, and commitment have been applied, quality performance resulted.
However, instances of personnel inattention to detail, inadequate response to quality assurance audit findings, and failure to adhere to procedures indicate a need for an increased level of senior management attention to plant operating activities to assure that the necessary performance improvements are achieved.
We are also aware of problems with employee morale and staff attrition, due largely to the uncertain future of the plant. We recognize that actions are being taken to address these problems and we will continue to monitor your efforts.
Your cooperation is appreciated.
Sincerely, Original signed by Thomas E. Earley Thomas gD RegionalAdministrator)f l\3 ICIAL RECORD COPY 423FUHRMEI, STER 11/7/86 - 0001.0.0 8701070418 861124 11/20/86 #E40 PDR ADOCK 05000322 0 PDR
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Enclosures:
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1. NRC Region I letter, ,
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to John D. Leonard July 14, 1986 2. SALP Meeting Attendees 3. LILCO letter, John D. Leonard to , l T. Murley, August 26, 1986 4. SALP Inspection Report 50-322/85-98 . ,
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CC w/ encl *
W. Steiger, Plant Manager i s x B. McCaffrey, Manager, Nuclear Operations Support I s R. Kubinak, Director, QA, Safety and Compliance E. Youngling, Manager, Nuclear Engineering Anthony F. Earley, Jr., General Counsel Jeffrey L. Futter, Esquire ,
J. Notaro, Manager, QA Department Director, Power Division Shoreham Hearing Service List Public Document Room (PDR)
Local Public Document Room (LPDR) { .
Nuclear Safety Information Center (NSIC) , !
NRC Resident Inspector
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State of New York *
Chairman Zech Commissioner Roberts Commissioner Asselstine ,3 Y'
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Commissioner Bernthal * ' '
Commissioner Carr
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bec w/ enc 1:
Region I Docket Room (with concurrences) l i Management Assistant, DRMA (w/o enc 1)
Director, DRSS Director, DRS DRP Section Chief B. Bordenick, ELD R. Goddard, ELD Robert J. Bores, DRSS
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- SEE PREVIOUS CONCURRENCEhFFICIAL RECORD COPY 423FUHRMEISTER11/7/86 - 0002.0.0 i 11/07/86 l
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REGION I
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JUL 141986
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Docket No. 50-322 Long Island Lighting Company ATTN: Mr. John D. Leonard, Jr . ~*
Vice President - Nuclear P. O. Box 618 Shoreham Nuclear Power Station Wading River, New York' 11792
, Gentlemen:
Subject: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
REPORT NO. 50-322/85-98 The NRC Region I SALP Board has reviewed and evaluated the performance of activities at the Shoreham Nuclear Power Station for the period March 1,1985 to February 28, 1986. The results of this assessment are documented in the enclosed SALP Board report dated April 21, 1986. A meeting to discuss the assessment will be scheduled in the near future at the Region I offices.
This is an important SALP in that it covers the period of transition during which Shoreham has moved from a phase of preoperational testing to a phase of ( operational testing and low power operation. Based on the observed performance during this period, LILC0 has demonstrated that when adequate management at-
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tention is given, good performance can result. In contrast, however, several areas were identified where improvements are needed. These areas include radiological controls, training and qualification, licensing activities, and assurance of quality.
At the SALP meeting, you should be prepared to discuss our assessments and your plans to improve performance. This meeting is intended to be a dialogue where-in any comments you may have regarding our report may be discussed. Addition-ally, you are requested to provide written comments within 30 days after the meeting delireating your corrective actions and measures instituted to address the noted weak areas of performance.
In addition, in conjunction with the SALP management meeting, we request that you make a presentation on the progress of your program for improvement related to Special Inspection 86-03 and that you be prepared to discuss management's participation in assuring quality work at Shoreham. Specifically, the role of Division Managers in monitoring plant activities is of interest since the re-port notes that numerous administrative burdens appear to restrict the active participation of managers / supervisors at the job site.
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Your cooperation is appreciated.
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Sincerely,
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Thomas E. Morley ,
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Regional Administrator s
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W. Steiger, Plant Manager .
J. Smith, Manager, Nuclear Operations Support R. Kubinak, Director, QA, Safety and Compliance E. Young 11ng, Kanager, Nuclear Engineering Anthony F. Earley, Jr. , General Counsel Jeffrey L. Futter, Esquire J. Notaro, Manager, QA Department Director, Power Division Shoreham Hearing Service List Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector ( State of New York
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. ENCLOSURE 2
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ATTACHMENT I JULY 29,1926 SALP MANAGEMENT MEETING ATTENDEES NRC T. Regional Administrator R. W. Starostecki - Director, Division of Reactor Projects T. T. Martin - Director, Division of Radiation Safeguards & Security W. Johnston - Deputy Director, Division of Reactor Safety H. B. Kister - Chief, Projects Branch No.1, DRP J. R. Strosnider - Chief, Reactor Projects Section 18, DRP J. A. Berry - Senior Resident Inspector, Shoreham R. Caruso - Licensing Project Manager, NRR R. Lo - Licensing Project Manager, NRR J. M. Gutierrez - Regiotal Counsel B. Bordenick - Office of the Executive Legal Director R. Nimitz - Senior Radiation Specialist LILCO W. J. Catacasinos - Chairman of the Board & President J. Dye - Executive Vice President J. D. Leonard - Vice President-Nuclear Operations W. E. Steiger - Plant Manager J. L. Smith - Director, Office of Training B. R. McCaffrey - Manager, Nuclear Operations Support Department E. J. Youngling - Manager, . Nuclear Engineering Department J. A. Notaro - Manager, Quality Assurance Department A. F. Early - General Counsel Suffolk County D. Minor - MHB Technical Associates A. Dyner - Kirkpatrick & Lockhart J. Blough - New York State Consumer Protection Board
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ENCLOSURE *3
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fgf@ LONG ISI_AND LIGHTING COM PANY SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY RC AD e WADING RIVER. N.Y.11792
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JOHN D. LEON ARD, JR.
vtCE PRE 9 DENT NUCLE AR OPERATIONS SNRC-1277 AUG 2 61986 Dr. Thomas Regional Administrator Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Station Corrective Actions Discussed During the SALP Meeting Conducted July 29, 1986 Shoreham Nuclear Docket No.Power 50-322Stati(*n & Unit 1 Reference: NRC letter (T. E. Murley) entitled Systematic P ssessment of Licensee Performance (SALP) Report, No. 50-322/85-99, to LILCO (J. D. Leonard, Jr.)
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Dear Dr. Murley:
In' our meeting on July 29, 1986, we informed you of the corrective actions and measures instituted to address the noted weak areas of performance as described in the referenced letter.
My staff and I have met several times prior and subsequent to our July 29, 1986 meeting to ensure ourselves that we were addressing all items identified in the SALP report. Attachment 1 to this letter documents LILCO's actions and is intended to fulfill the request contained in your letter forwarding the SALP Report.
Should you or any of your staff have questions concerning the actions described in this letter, please do not hesitate to call my office.
Very truly yours, (,
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(r[t' .;' . sTyth-ac,hnD . Leon rd, Jr /
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Vice President - Nu'cle r Operations
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Attachment
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Attachment I
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STATION CORRECTIVE ACTIONS AND MEASURES INSTITUTED ADDRESSING NOTED WEAK AREAS OF PERFORMANCE (SALP REPORT)
The objective of LILCO's corrective actions is to strengthen performance and eliminate those weaknesses identified in the LILCO's senior functional areas rated by the SALP. Board.
management considers the SALP report to consist of important constructive criticism. The actions subsequently described below are either complete or in progress.
I. VICE PRESIDENT - OFFICE OF NUCLEAR A. Assurance of Quality LILCO recognizes the fundamental importance of achieving a high standard of excellence from each individual employee and contractor in the Of fice of Nuclear Oper-ations. At our meeting, we discussed three functional topics and the actions we are taking within each to strive for quality excellence throughout the Office of Nuclear Operations. Those functional topics are quality of work, personnel staffing, and senior management overview. As we reported to you in our letter dated April 18, 1986 (SNRC-1249), several meetings were held within the Office of Nuclear Operations wherein we stressed the importance we place on the concept of l
personal responsibility and safe operations. These meetings were with plant managerial personnel, union stewards, all plant personnel and all Office of Nuclear Operations personnel. At these meetings we also described ~and encouraged the use of our Quality Hotline Program.
In order to_ increase daily interaction and contact between management and employees we have taken the following actions. As part of their normal duties and responsibilities, division managers and section heads are now spending several hours a week conducting physical plant inspections and observing work activities to monitor the quality of work being performed. We have also taken steps to relieve some of the administrative burden from the Plant Manager by strengthening our Operations Staff Division with the addition of an individual with significant operating experience.
Additionally, we are providing administrative assistance to our Plant Staff division managers by assigning an assistant to the Maintenance Manager, providing two watch engineers on the day shift and working to fulfill our commitment to fully staff our radiochemistry
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Attachment I
, SNRC-1277 Page 2 section with qualified personnel. We continue to seek ways of providing additional administrative assistance for our division managers to enable them to increase their presence in the plant and directly oversee their respective operations.
In the area of personnel staffing, we discussed the steps we were taking to decrease attrition and to hire qualified individuals to fill critical vacancies.
To assure you that LILCO is truly committed to improve in this and all t anctional categories of the SALP Report, we discussed the strong support by senior management to complete the actions described at the meeting. LILCO's Nuclear Oversight Committee is very interested in the adequacy of these actions and is charged with the responsibility for reviewing and assessing all of the nuclear activities of the Company.
The Committee is comprised of three members of the Company's Board of Directors, has met ten times in 1935 and a number of times in 1986, and vigorously pursues its responsibilities. In addition to the Nuclear Oversight Committee's frequent presence at Shoreham, we discussed the active support given to the Office of Nuclear Operations by our Executive Vice President who will also pursue the completion of these actions and will spend part of his time at the Shoreham Nuclear Power Station.
II. OPERATIONS DEPARTMENT o
A. Plant Operations and Startup Testing LILCO recognizes the relative importance of this category as evidenced by the large percentage of total NRC time (approximately 60%) applied to inspections of plant operations. Primarily, three subjects were discussed in this performance category: lessons learned j
' from our 5% power test period, control room environment, and attention to detail in the form of procedure adher-ence. Of these three issues, procedural adherence is receiving the greatest amount of LILCO's attention. To
improve operations and ensure greater attention is given to following procedures, station management is
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through night orders and during operator requalification training; section staff meetings have been held to f
discuss events resulting from inattention to detail; I
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, SNRC-1277 Page 3 an Operations Division Self Audit Program has been instituted; administrative procedures in the area of lifted leads and jumpers and station equipment clearance permits have been revised; and startup test procedure training to uncover potential problems, improve procedural compliance, and familiarize test and operating personnel with the tests has been conducted.
Additionally, plant management personnel instituted an Incident Review Board that consists of plant section heads and is responsible to determine root causes of station incidents. To accomplish this, the board receives personnel statements and conducts interviews, assimilates facts, prepares reports, obtains division manager review and plant manager approval of recommendations. Finally, station management personnel (division managers / Review of Operations Committee)
conduct quarterly reviews of reports of abnormal conditions and licensee event reports.
To improve our control room environment, LILCO conducted a detailed review of watch enginaer responsibilities and utilizes two day shift watch engineers. Also, personnel access to the control room has been restricted and pro-cedures revised to require " repeat back" of instructions to minimize misunderstandings. As a result of a human factors review of the control room work area, LILCO plans to rearrange control room furniture, relocate the watch supervisor to the control area, and relocate the secondary alarm station from the control room. Addi-tionally, to enhance the atmosphere of professionalism, new uniforms for control room operators were ordered and received.
At the SALP meeting, our Plant Manager discussed several of the lessons learned from our 5% startup test period.
To instill a team concept between power ascension test personnel and operating crews, test personnel are on six shift rotation and rotate with their respective operating crews. Station management expanded LILCO involvement within the power ascension test group by assigning assistant test directors and test coordinators to actively participate in what was historically a NSSS vendor dominated function. A day shift support engineer was assigned to oversee test reviews and QC perscnnel became involved earlier in the test review process.
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Attachment I SNRC-1277
Page 4 Finally, as a result of lessons learned, LILCO stream-lined test summary reports; reviewed and revised startup test procedures; and initiated formal training of test personnel in accordance with developed lesson plans.
B. Radiological Controls LILCO's overall station corrective action in the area of radiological controls is described in our letters SNRC-1245 and SNRC-1249, dated April 3 and 18, 1986, respectively. At the SALP meeting, our Plant Manager provided you with a progress report of the station's corrective actions in the area of staffing, technician training and qualification, laboratory quality assurance and general laboratory practices.
In these functional areas, we informed you that we have made significant progress towards our staffing objec-tives; a sufficient number of technicians were qualified for backshift coverage to support plant operations; procedures were being revised in the area of laboratory quality control and that oversight of this functional area would transfer from the task force to the section in September 1986; and that the implementation of good laboratory practices was being pursued on a daily basis.
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An inspection of this area to determine the adequacy of our corrective actions was conducted during the week of July 28, 1986. The exit meeting for Inspection 50-322/86-11 occurred on Friday, August 1, 1986, and LILCO was satisfied to learn that the inspection This team found our corrective actions to be effective.
inspection tean indicated that they would recommend closure of all but one open item from special inspection 86-03. It is our understanding that one item remains open and that the item will close when the transfer of responsibility for the Radiation Monitoring System from the Radiochemistry Section to the Computer Engineering i Section is complete.
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III. NUCLEAR OPERATIONS SUPPORT DEPARTMENT A. Maintenance and Surveillance In this performance category, the SALP Report identifier two apparent weaknesses pertaining to our spare parts program: procurement and availability. To address LILCO's corrective steps, the Manager, Nuclear Operations Support Department, described several actions that have been taken to improve our spare parts program.
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Attachment I
. SNRC-1277 Page 5 LILCO initiated a biweekly report card on spare parts and consumables to enable management to identify and trend the relative success of the issuance of these items. Also, a spare parts catalogue arranged with a
' key word sort format is nov available for use on site.
This catalogue will enable the user to quickly obtain SNPS spare parts information concerning items such as gaskets, bolts, etc. Additionally, LILCO expects to complete the construction material transfer program by August 30, 1986. Finally, we briefly discussed the priority ordering system and tracking of requisitions as measures taken to improve our procurement cycle.
The Manager, Nuclear Operations Support Department also discussed two actions that were planned to strengthen the SNPS spare parts program. First, a full inventory of the SNPS warehouse is to be conducted. Its targeted completion date is December 31, 1986. Second, there will be a complete reevaluation of the material control program including its organization and staffing. This reevaluation is expected to be completed by the end of October 1906.
B. Licensing Activities To improve our responsiveness to NRC initiatives that do not directly affect the licensing schedule, the Nuclear Licensing and Regulatory Affairs Division has initiated several actions. The authorized complement of this division was increased and is now currently staffed with a Licensing Section of four engineers. Additionally, we have initiated a monthly meeting between the Nuclear Licensing and Regulatory Affairs Division Manager and the NRC Project Manac r in Bethesda to assure that LILCO is being responsive to all NRC concerns. Internally, the Licensing staff has been directed to inform the Manager, Nuclear Operations Support Department of issues that cannot be promptly resolved. The Department Manager will assure that the Vice President - Nuclear Operations is fully apprais d on such matters. Finally, licensing personnel are dir. "d to ensure that all analyses supporting our signiticant hazards consideration findings which accompany license change requests are performed in accordance with the guidance of NRC Generic Letter 86-03.
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SNRC-1277 Page 6 IV. Training A. Training and Qualification Effectiveness LILCO's newly appointed Director of Training discussed the actions LILCO has taken to direct management attention to establish good training practices in all plant areas. As discussed, LILCO has recognized the need for increased management attention and other concerns raised by the NRC in this SALP Report as evidenced by the expansion of our authorized training complement from nine (9) in 1982 to forty-five (45) in May of 1986; the issuance of a purchase order for the Shoreham simulator in 1984; the approval of the LILCO Training Facility in 1985; and the appointment of a Director of Tra,ining on April 1, 1986.
Since the appointment of a Director of Training, LILCO has taken several specific training related actions. An extensive audit (1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) of personnel training and qualification was conducted and corrective actions have been established for all findings. A task force effort to define a generic program for training and qualifi-cation status and record keeping was initiated and completed. Recommendations resulting from this ef fort are expected to be implemented by November 1986. A monthly review of training and qualification personnel files is conducted by training and user organization personnel. These files are certified monthly by the Nuclear Training Division Manager as' complete or actions are taken to correct deficiencies. LILCO initiated a new accreditation level training program for newly employed radiochemistry technicians, and doubled the frequency of offering for BWR Familiarization training for Office of Nuclear Operations personnel. Finally, we reported that the new 110,000 sq. ft. training facility in Hauppauge, which will house the Shoreham simulator, includes laboratories, classrooms, skill shops and office facilities for over ninety (90) Office of Training personnel, is scheduled to be ready for occupancy in November 1986. The Shoreham simulator is scheduled to begin factory acceptance testing in September 1986 and should be ready for training purposes in May 1987.
LILCO has noted and welcomes the implementation of the SALP Board recommendations for a management meeting and special inspection of training and qualification.
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Attachment I SNRC-1277
- Page 7 V. QUALITY ASSURANCE At the SALP meeting our Quality Assurance Department Manager discussed the results of numerous actions that were accomplished. The QA Department initiated and completed programmatic changes as described in SNRC-1249; enhanced its auditing capabilities by providing QA auditors with training in the areas of plant operations, radwaste, health physics, and radiochemistry; changed its auditing program schedule and team composition as described in SNRC-1249; and provided promotional enhancement of its Quality Hotline Program.
A. Radiological Controls The SALP Report noted a weakness in that individuals performing audit activities in the area of radioactive waste management and transportation had not received adequate training. As discussed by our QA Department Manager, we acknowledged that finding and immediately took and implemented corrective steps. Additionally, as described above, our QA Department conducted and completed an extensive training effort in the areas of health physics, radiochemistry, operations and audit effectiveness as described in SNRC-1249.
The QA Department initiated an audit of the radiochemistry section on July 17, 1986 and we are confident that, as a result of all the actions described above, an effective audit was performed. This audit and its results were evaluated during the NRC followup inspection of Shoreham's radiochemistry section which took place .he week of July 28, 1986. At the exit meeting for inspection 50-322/86-11 we were encouraged by the inspection team's verbal report that the audit was very comprehensive.
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ENCLOSURE 4 (- .
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-322/85-98
- LONG ISLAND LIGHTING COMPANY k
SHOREHAM NUCLEAR POWER STATION ASSESSMENT PERIOD: MARCH 1, 1985 - FEBRUARY 28, 1986 BOARD MEETING DATE: APRIL 21, 1986
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SUMMARY OF RESULTS :
3.1 Facility Performance CATEGORY CATEGORY LAST THIS PERIOD PERIOD
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(3/1/84 - (3/1/85 - RECENT FUNCTIONAL AREA 2/28/85) 2/28/85) TREND *
1. Plant Operations 1** 2 Consi stent
& Startup Testing 3 Declining 2. Radiological Controls 1
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3. Maintenance &
Surveillance 1 2 Cons,istent <
4. Emergency Preparedness No Basis 1 Consistent 5. Security & Safeguards 1 1 Consistent 6.0utage & Modifications N/A 2 Consistent 7. Training & Qualification Effectiveness N/A 3 Declining )
8. Licensing Activities 2 3 Consistent 9. Assurance of Quality N/A 2 Declining
- Trend during the last quarter of the current assessment period.
- The previous SALP rated '. Plant Operations' and 'Preoperational ,
and Startup Testing' as separate functional areas. Each was
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assessed as Category 1.
3.2 Overall Facility Evaluation The functional area ratings assigned in this SALP period show a pattern of inconsistency in the licensee's operation of Shoreham.
While the licensee has demonstrated in several areas the ability
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to achieve high standards of performance, areas of significant weakness exist at the same time.
1 - In comparing the ratings in this SALP period with those of the pre-vious period, one must keep in mind that this period's ratings in- ."
volve an evaluation of licensee performance during a period of initial operational activity and significant outage activity, as
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compared to the previous period of inactivity in most areas other
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than licensing. Additionally, the ratings this period represent a-period of transition for the plant and its personnel. The SALP
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Board acknowledges the difficulty of that transition, especially as compounded by the atmosphere of uncertainty in which employees must i
work. This uncertainty creates a situation where the morale of the personnel at the plant is constantly chall.enged.
Despite these difficulties, the licensee has demonstrated that, when appropriate levels of management attention, resources and commitment are applied, quality performance can be achieved. This is evidenced by the satisfactory completion of the 5% startup test program, actions in closeout of-findings of the special Post Accident lampling System inspection, support for litigation issues, and personnel performances of the onsite portion of the FEMA Full-Scale exercise. However, coh-tinued instances of personnel inattention to detail, failure to adhere
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to procedures, inadequate responsiveness to QA audit findings, and the recent problems in the Radiochemistry section all indicate a need for an increased level of management attention to plant activities.
Preoccupation of management personnel with licensing issues to the detriment of other plant activities has been a weakness noted in previous rating periods, and indications are that this problem has not yet been fully resolved. As a consequence, management has been required to resclve several problems in a reactive mode rather than through a proactive system which identifies and corrects potential l problems in a timely manner. Additionally, attention needs to be
\ increased in the area of planning for potential attrition of experi-enced staff. Although efforts in some areas (specifically the Operations Division) to pre plan for possible attrition are noted in this report, these efforts are not evident throughout the licensee's organization.
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4.0 PERFORMANCE ANALYSIS _
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4.1 Plant Operations and Startup Testing (1831 hrs., 60%)
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A. Analysis Startup Testing In this assessment period, the startup testing activities asso-ciated with the heatup phase of testing were completed. This testing involved the initial heatup of the reactor coolant to rated conditions and culminated in the initial roll of the main turbine to rated speed. Initial criticality was accomplished in the previous assessment period. Except for closeout of test exceptions, the low power testing activities associated with a
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5% low power license were completed during this assessment.
The startup testing activities during this assessment period were more complex and more intense than during the prior as-sessment period. The licensee management resolved a number of NRC concerns identified during low power testing:
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The administrative program was revised to intensify the management involvement in the review and approval of com-pleted test results, definition of acceptance criteria prior to proceeding to the next test condition, and I licensee actions relating to resolution of significant test exceptions.
- There were several observations of friction and apparent lack of cooperation between various groups in the testing and operational activities, and the test briefings for
. operations personnel were initially weak in the discussion of potential plant problems. .The licensee's management
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took prompt action to resolve these differences and im-provement was observed as the low power testing program progressed. The importance of good test briefings should be continually stressed throughout the remainder of startup test activities.
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- The timeliness of the review of completed test activities
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process and dedicated more personnel to perform this activity.
The QA/QC coverage of the startup activities was adequate. QC inspectors were observed performing surveillances during numer-ous startup tests. They have also participated in the review process for all completed testing. The planned QA/QC coverage for the remainder of the test program is adequate and involves
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the continuation of extensive surveillances o'f the performance ~
of testing and the review of all test results.
Management involvement in the startup program was evident.
- They witnessed major testing evolutions and were observed to be directly involved in the resolution of major plant problems such as the the reactor water level divergence problem between the A & B. side and the condensate booster pump minimum flow valve control air supply line rupture problem. The licensee activities relating to the reactor water level problem involved multi-disciplined personnel and was well controlled. The prob-lem was sufficiently resolved to permit continuance of the heatup phase testing and hardware modifications were made dur-ing the recent outage.
Plant Operations In this rating period, the major licensee activity in the area
of plant operations involved the conduct of the low power test-ing progran, up to 5% power.
The performance of plant personnel in this testing program was generally-considered to be good, although errors by licensed operators occurred. The two most signifi ant of these errors involved the opening of two 18" Primary Containment Purge
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{ Valves, in violation of procedures, and the partial draining of the reactor vessel to the suppression pool due to improper valve manipulation.
Two problems also occurred as a result of activities of non-licensed operations personnel. The first of these involved a failure to ensure Suppression Pool level was proper to allow
- maintenance activity on an RHR valve. Due to the level being too high, approximately 7,000 gallons of water was spilled into the Reactor Building upon valve disassembly. The second problem related to failure of personnel to properly complete Station
! Equipment Clearance Permits in accordance with Station Proce-dures. In each instance, licensee corrective actions were ap-propriate. However, the need for greater attention to detail, and the adherence to procedures by personnel are areas in which the licensee needs to focus greater attention. This issue was raised in the previous assessment period as a need for improve-ment.
Staffing of licensed operators at the plant remained at a sta-ble level throughout the rating period. It is significant to t note, that while other areas of the plant experienced large turnovers of personnel, the licens'ed personnel staffing level remained stable. Overtime for licensed personnel was main-tained well within the guidelines of NRC Generic Letter 82-12,
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attributable to fatigue due to overtime. The licensee now ful-
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ly staffs six shifts in the Operations section, and has a class of license candidates in training. The licensee has also ag-
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gressively recruited and hired a large. number of Equipment Operator trainees to ensure against future shortages due to attrition.
In response to NRC initiatives, the licensee took two steps during this rating period to reduce the administrative burden on licensed personnel in the control room. One was the creation of a second day shift watch engineer position. The second was the staffing of a permanent Shift Production Assistant posi-tion. This person provides clerical assistance to licensed
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personnel on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis. The environment in the main con-trol room is an area where improvements could be made. Specif-ically, there are too many people allowed in the control room and the attendant noise level is distracting.
The licensee also established and staffed a System Engineer Section in tne Operations Division during this assessment peri-od. This section recently developed and implemented two com-puter databases for use by operations personnel in tracking plant status. These initiatives in providing management tools for li:ensed operators to better track plant status is noteworthy. ,
I The Systems Engineer section has also provided hands on de-tailed systems training to operations personnel. This contin-uing training, conducted in addition to licensed operator initial and requalification programs, demonstrates the licensee's continued commitment to on going training for li-censed personnel. This area, specifically the licensed opera-
. tor Requalification P ogram, has been judged to be a strength in previous assessment periods, and this new licensee initia-
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tive in the area of licensed operator training reinforces that judgement.
Operator Licensing activity during this period involved the conduct of NRC license examinations at Shoreham in September 1985. Five Senior Reactor Operator and four Reactor Operator candidates were administered written and oral examinations.
All candidates passed the examinations and were granted licens-es. As a result of the high failure rate noted during exami-nations in February 1985, LILCO management had committed to increasing its monitoring and supervision of future operator licensing classes. These most recent results indicated that the licensed operator training program is adequate when given proper management attention.
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Housekeeping at the facility du' ring this peried continues to be '
excellent. In particular, during the~second half of this !
period, while the facility was involved in numerous maintenance ;
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and modification activities, the licensee was successful in i
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maintaining a high standard of plant cleanliness. l One team inspection was conducted to followup the issues iden- l tified during inspections performed in the previous assessment - I period in the area of safe shutdown capability of the plant in i the event of a fire. Technically sound and thorough approaches !
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and timely resolution of issues were observed. The firc protec- >
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tion staffing was observed to be ample and knowledgeable. Ag-gressive action had been taken on previously identified problems.
Observation of the activities of the Review of Operations Com-mittee (ROC) and Nuclear Review Board (NRB) during this rating period indicate that the licensee is effectively utilizing these oversight committees for independent review of plant ac-tivities. NRB involvement in plant audits is evident.
B. Conclusion
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' ' I Rating: 2 ,
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f Trend: Consistent
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C. Board Recommendation
Licensee: . Focus greater attention to ensurir29 personnel
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adherence to procedures =
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NRC: None
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4.2 Radiological Controls, o l(317 h s. 10%)
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A. Analys h (
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, , ,. There were six regiot_ based inspections during this assessment
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l period; five rottine.ahd-one special. Inspection efforts this
. perio.d foc'us?d on licensee corrective action for post-accident
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.' samplin?/and' analysis program deficiencies to support operation beyond 5% power; non-radiological chemistry; radioactive waste
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tr.ic:portation program establishment and implementation; i 3 ? #preoperational and startup testing; and licensee action on clo-
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vare of pravious NRC findings. Other areas reviewed included
%~ Wadiological Controls Organization and staffing; personnel
}f'Y . t' raining and qualification; and external and internal exposure pN U S contro'Is. Special reviews were conducted in the area of radio-
[ 9 i::hemistry as a result of allegations of program deficiencies
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.! 3 ' recd ved by the NRC.
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l Veaknesses identified during the last assessment period were (
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the need to clearly define the responsibilities and authorities of the site and corporate Radiological Controls Organization
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- positions. Also, a need was identified for a walk-through of
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radiation protection program elements ta identify progranmatic
' 1 / weaknesses and inconsistencies.
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The licensee has established in a timely fashion clearly de-fined function responsibilities for each position within the g* ,
site and corporate radiological controls organization. Howev-er, levels of delegated authority for each position have yet to
]/, be established. Program walk-throughs were not conducted as y recommended.
The overall performance in this area relative to the last as-sessment period has degraded. Weaknc nes identified show a
' lack of management attention to assure that identified problems
?- are corrected. Also inadequate and inconsistent control and oversight of day-to-day activities in this area is apparent.
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The degradation is primarily present in the chemistry / radiochemistry area with some examples in the area of radiation protection and radwaste transportation.
Radiation Protection Due to the low radiation and radioactive material source term at the station, implementation of the external and internal exposure control programs was not significantly challenged dur-ing this period. With some exceptions discussed later, the raolation protection program is adequately defined by accept-
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able policies and procedures. Management is generally respon-sive to NRC findings in this area. NRC identified problems are resolved in a timely, technically sound manner. A technically
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competent staff is available_to implement the program, although staff shortages in the technical support area and ALARA coordi-nator positions are areas where attention needs to be in-
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creased. One apparent weakness is a lack of significant operating experience by senior supervisory personnel in the group. The licensee is addressing the matter by using an expe-rienced contracted individual to augment the organizations ex-perience and fill a key position that has been open for some time. This is an acceptable interim solution but should not be viewed as a long term answer.
Regarding training and qualifications, the initial training program for radiation protection personnel is generally well defined and makes a positive contribution to performance of work with few personnel errors. However, there is no continu-ing retraining program to notify radiation protection personnel of safety significant procedure changes or new procedures in a timely manner. This weakness is attributed to inadequate pro-gram development in this area.
The licensee hat established an effective general employee training and retraining program in this area. Training records are complete, well maintained and available. Management has provided adequate training resources and training facilities.
l, To minimize impact on she radiation protection group during the period of low power operations, the high radiation area access control program required by Technical Specification was delet-ed. Although no uncontrolled high radiation areas were identi-fied, the deletion of the program illustrates a lack of attention to maintenance of minimum program elements required by technical specifications. Also, the deletion of the program creates a lack of program maintenance and continuity which is important in familiarizing and educating plant personnel with regard to requirements in this area. Program elements lacking or inadequate included: procedures for high radiation area key control; inadequate procedures for access to traversing incore probes and sub pile room; and inadequate procedures for access to the drywell during fuel movement. The licensee initiated action to establish and up grade procedures in this area in a timely manner when it was brought to management's attention.
Additional attention by management'is needed to ensure continu-ity and adequacy of station radiation protection program ele-ments required by license conditions.
A review of licensee actions to resolve program deficiencies in the area of NUREG-0737 post-accident sampling and analysis found that the licensee took timely, technically sound action to resolve the deficiencies. The. resolution of the findings was effectively managed in that a task force approach was used.
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Records of corrective actions were complete, well maintained and available. Technically qualified personnel were utilized.
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While some problems were encountered in the area of licensee interpretation of requirements, corrective measures were imple-mented in a timely manner. Overall, the licensee was very re-sponsive to NRC findings in this area.
Radioactive Waste Management and Transportation Review of the Radicactive waste shipping program found it to'be generally adequate and properly implemented. Responsibilities of personnel involved with radioactive waste shipping activi-ties were clearly described. Radioactive waste personnel were trained in applicable requirements. Training records were com-plete and well maintained. Shipping procedures were adequate.
The Quality Assurance oversight of radioactive waste transpor-tation activities was found lacking. Individuals performing audits of activities in this area had not received adequate training or qualification. In addition, audit reports of radwaste activities failed to provide adequate indication that the licensee had conformed with the applicable specific quality assurance criteria of 10 CFR 50 Appendix B despite the fact that report summaries indicated that conformance had been veri-fied. This is evidence of weakness in the program for self-identification of problems.
Chemistry, Radiochemistry and Effluent Controls and Monitoring )
The chemistry group is satisfactorily organized for the manage-ment of the station's chemistry, radiochemistry, and effluent monitoring and control programs. However, weaknesses in the area of: staffing, program oversight and control, procedure adequt.y, corrective action program, and corporate support of plant programs has resulted in major programmatic concerns not being identified and corrected in a timely fashion. NRC in-volvement was needed to assure identification and implementa-tion of lasting, comprehensive corrective action.
In the area of staffing, 40% of the professional positions within the site chemistry group are filled by contractors.
l Some key positions have been filled by contractors for an ex-tended period of time. The group experiences the highest turnover rate among the station groups.
Regarding the training and qualification of chemistry person-nel, reviews found that an adequate, documented program exists to select, train, and qualify chemistry technicians. However, a special inspection of training and qualification of chemistry technicians, performed in response to allegations received by the NRC, found that the chemistry. technician training program
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f was not properly implemented. Open book exams and the personal judgement of a chemistry foreman were used to qualify techni-cians rather than the procedurally required check-outs or task evaluations. Based on NRC observations, it appeared that sub-stantive action was not taken by licensee management to address the root cause of the problem until the NRC became involved.
In the area of chemistry and radiochemistry program establish-ment, the program was generally defined by technically accept-able procedures. However, procedures for quality assurance were generally inadequate indicating a clear lack of apprecia-tion by management of the need for accurate, reproducible mea-surements.. Program procedures were not established in a manner to quickly identify and resolve out-of specification chemical / radiochemical measurement data. The deficiencies in the area of quality, assurance are ascribed to inadequate proce-dures, a lack of sufficient technical expertise within the chemistry staff, and a lack of adequate program review and oversight by the corporate Radiation Protection Division.
The deficiencies discussed above were identified during a LILCo quality assurance audit conducted in May and June of 1985.
However, NRC inspection ravealed that the deficiences still existed in February 1986 and that little progress in imple-menting effective fixes had been made. Even after a Corrective
{, Action Request was issued by the Quality Controls Division, the issue was still not promptly and effectively addressed. The Quality Controls Division and Quality Assurance Department's handling of this issue was ineffective. Similarly, plant man-agement was aware of these problems but did not take the neces-sary actions to achieve a timely and effective resolution.
Summary The radiation protection and radwaste shipping programs were not significantly challenged during this assessment period.
However, deficiencies identified indicate a need to improve oversight and control of these program elements. Problems identified in the chemistry and radiochemistry programs indicate a major programmatic breakdown of the chemistry /
radiochemistry program. Inadequate oversight and followup to self-identified problems clearly contributed to the problem.
B. Conclusion Rating: 3 Trend: Declining (
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C. Board Recommendation Licensee . Establish and implement effective oversight and control of the chemistry and radiochemistry pro-grams and assure that the lessons learned from- -
the breakdown are applied to other areas.
. Fully staff the chemistry group and radiation protection groups with qualified permanent personnel NRC: . Conduct an inspection of this area within four months of this SALP to determine the adequacy of licensee corrective actions.
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f 4.3 Maintenance and Surveillance (250 hrs., 8%)
A. Analysis During the previous assessment period, it was noted that the licensee should increase attention to the area of preventive maintenance to reduce the backlog in the preventive maintenance program. It was noted that understaffing appeared to be a prime contributor to this problem.
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The area of preventive maintenance continued to be a problem at the beginning of this rating period. One problem was the docu-mentation of actual maintenance work outstanding on incomplete
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items lists. The list was observed to not be up to date and contained numerous items that had actually been accomplished.
In the second half of this period, progress in correcting this situation was'evider.t.
The maintenance group has also been observed to be backlogged in its evaluation of identified generic problems for applica-bility to Shoreham Station. In one instance identified by an inspector, the failure of a feedwater minimum flow valve, due to vibration induced loss of its antirotation device, may have been prevented by the timely review of IE Notice 83-70, Supple-ment 1, " Vibration-Induced Valve Failures", which had not been
[' evaluated due to the backlog. The licensee has assigned addi-tional manpower to address this problem.
Management followup of identified maintenance problems could be
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more expeditious and thorough. When an inoperative minimum flow valve in the "B" RHR loop lead to the discovery that four bolts which secure the valve operator had sheared off, the scope and priority gisen to inspecting other valves for similar problems was inadequate. While the limited inspection did re-
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veal a broken mounting bolt on the "A" RHR loop minimum flow valves, it was not until an NRC inspector identified a similar problem with a third RHR valve that the scope of the inspection was increased, additional personnel assigned and an earlier than planned shutdewn begun. The final results of the in-creased inspection revealed seven RHR valves with loose mount-
- ing bolts, one with a sheared mounting bolt, one with a loose handwheel, and one with a missing ' handwheel. In addition, it was not until four failures occurred in the control air supply line to the condensate suction booster pump minimum flow valve and a reactor scram occurred on low level, that management was fully involved in the resolution of the problem. However, once management was involved the problem was resolved.
During the previous assessment period, the procurement of spare parts was noted to be a problem. The lack of readily available i spare parts and components continues to be a problem.
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i Conversely, in some cases people were not aware that needed spare parts were already in the warehouse system and this led to delays in planned activities and job completion. -
During this assessment period, maintenance management institut-ed an organization called the Shoreham Information Management System (SIMS). This group is comprised of representatives of all on-site departments and organizations. It's purpose is to coordinate and develop an integrated data base which will be utilized by all organizations associated with Shoreham.
The interface between the maintenance division and other plant .
divisions in the resolution of technical problems is evident.
A recent example 6f this was the coordination of the Computer Section and Security in resolving major computer program errors in the Security Computer. This resulted in an improved avail-ability of the~ Security Computer to 99.4%. This improved availability reduced the need for compensatory measures by the licensee in the security area, thereby reducing personnel constraints.
During the previous assessment period it was noted that the licensee needed to increase attention to a developing problem with the frequency of unnecessary challenges to safety protec-tion systems initiated by surveillance activities. During this rating period, the problem of challenges to safety systems dur- )
ing surveillance activities has not improved.
There were six instances in which maintenance or surveillance activities caused an inadvertent plant shutdown signal to be generated. Three of these resulted in reactor scrams from low power. In one case, the incorrect desiccant was installed in an air dryer, due to an inadequate procedure and personnel unfa-miliar with this routine activity, resulting in low air pres-
! sure and control rod drifts requiring a manual scram. In two cases, automatic scrams occurred due to spurious low reactor water level signals induced during the course of routine sur-veillance activities.
t A number of other personnel errors, creating challenges to ESF l systems, occurred during surveillance activities while the l
plant was in the neutron source outage. Licensee management initiated a comprehensive review to determine if root causes existed for these errors. The licensee met with NRC Region I
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on January 28, 1986 to discuss this matter. Although no spe-
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cific causes could be determined, the licensee did identify
contributing factors to the problem of personnel errors. The i
NRC considers lack of attention to detail by personnel perform-
! ing surveillance activities to be.a contributing factor. The licensee's actions in investigating this matter were prompt, comprehensive, and thorough. Proposed corrective actions, i
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which included evaluation of work scheduling, revision to sur-veillance procedures, hardware modifications, and increasing personnel awarness to the need for attention to detail were appropriate. The effectiveness of these corrective actions will be monitored in the next rating period.
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B. Conclusion Rating: 2 Trend: Consistent C. Board Recommendations Licensee: . Review the system for the procurement and control of spare parts
. Increase management attention to the area of reducing the number of challenges to ESF systems resulting from personnel error NRC: . None (
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4.4 Emergency Preparedness (331 hrs., 11%)
A. Analysis During .the previous assessment period, no rating was.given in the functional area of Emergency Preparedness due to limited observations. During this assessment period, the only activi-ty, other than the observation of training drills by the resi-dent inspectors, related to Emergency Planning was the conduct of a FEMA Full Scale Exercise on February 13, 1986. This drill was conducted without the participation of New York State or Suffolk County officials. The observations by NRC inspectors were limited to the on-site portions of the exercise (including the EOF).
Although this was the first exercise that has been formally observed by the NRC at Shoreham, the NRC observation team noted that the utility staff is thoroughly trained and practiced and is part of a well established emergency preparedness program.
The effectiveness of the plan and its implementing procedures was evident during the exercise as noted by the efficient man-ner in which the utility staff implemented Emergency Plan ac-tions in response to scenario events. Plant procedures and policies were strictly adhered to throughout the exercise.
I The on-site portion of the emergency preparedness program (including the EOF) appears to be well established and operat-ing smoothly. High level management is actively involved in the program and has managed to keep enthusiasm of emergency team members high despite uncertainties with the implementation of the the off-site portions of the plan.
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. The licensee's on-site Emergency' Preparedness organization was activated to the alert level at one time during this assessment period. This activation occurred during Hurricane Gloria. The licensee's actions with regard to plant safety during this ac-tivation were considered very good.
Observation of licensee Emergency Preparedness training drills on a regular basis by the resident inspector (s) showed that Senior Management was completely involved in the training of plant staff. Third party and Quality Assurance Department audits of these drills allowed independent assessments to be made. Corrective actions, in response to areas for improvement identified by NRC or third parties, were promptly and effectively initiated.
The licensee had committed itself!to a quality Emergency Pre-paredness organization, and this commitment has resulted in the level and type of training and management involvement which
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results in a successful program. It is clear that the exten- .
sive management attention given to this functional area result-ed in a high quality performance being demonstrated at all
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levels of the onsite organization.
B. Conclusion Rating: 1 Trend: Consistent C. Board Recommendation Licensee: . None NRC: . None.
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4.5 Security and Safeguards (207 hrs., 7%)
A. Analysis During the previous assessment, no-significant weaknesses were ~
identified, and the licensee's performance in this area was assessed as Category 1. One special and two routine unan-nounced physical security program inspections were performed by Region-based inspectors. Routine resident inspections contin-ued throughout the assessment period. No violations were iden-tified during this rating period.
Licensee management continues to be effective in carrying out..
the security program. This is evidenced by the 3bility of the security organization to cope with changing conditions with regard to law enforcement, modified protected area boundaries, and additional vital areas.
Further evidence of management attention to the security pro-gram is demonstrated by the audit and appraisal programs that have been implemented. In addition to the internal audit by licensee QA personnel, the licensee provides for a comarehen-sive audit of the security program by an independent group of consultants. In such an audit conducted during this assessment period, each deficiency identified received a comprehensive i response by the Site Security Supervisor and prompt corrective action was initiated and completed where necessary. The licensee's desire for an effective program is also demonstrated by continued improvements in the program, as evidenced by the licensee's plans to move the Central Alarm Station and Secon-
, dary Alarm Station (CAS/SAS) operations to larger quarters and, in the case of SAS, to a more favorable location. The location of the SAS in the control room has been an NRC concern for sev-eral years in that the SAS is located in the control room prop-er where it can be a distraction to the operator. The plans also include upgrading the hardware and software syster.s asso-ciated with the alarm stations. Staffing of the program was exemplified by the use of well qualified and dedicated personnel.
There were four events that required reporting in accordance with 10CFR73.71 during the assessment period. Each time, the licensee handled the event methodically and efficiently, and in accordance with the NRC-approved security plan and implementing procedures. The events were promptly reported to NRC and com-plete information was provided.
The security staffing is adequate', but a short~ age in clerical help appears to have resulted in. security supervisors and
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training personnel taking time from their primary functions and i occasionally using overtime to perform record keeping and
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filing duties. Continued use of supervisors and training per-sonnel in this manner requires management attention to assure this does not prove detrimental to the security program.
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The licensee's security force contractor has provided an effec-tive training staff to maintain security force personnel train-ing at an acceptable level. The licensee's security staff ensures the program effectiveness through review and approval of the training program and routine audits. As stated in the previous.SALP assessment, the licensee chose to implement the security program at an early date to ensure time for adequate training and qualification of the security force. The NRC spe-cial inspection conducted in March, 1985 demonstrated the value of this early implementation, in that the inspection found, in re-examining a statistically selected sample of the security force, that they were well qualified for the duties to which they were assigned. This review was further strengthened by the fact that no violations of NRC requirements were identified
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during the assessment period.
During the assessment period, the licensee submitted a revision to the security plan to provide for emergency bickup power gon-erators in the event they would be needed for low power licens-ing. Although the power sources were ultimately not needed, the submittal afforded the NRC adequate time for review and was
[I considered complete and acceptable for implementation.
The area of Security and Safeguards, like Emergency Prepared-ness, is one in which the licensee has demonstrated the ability to perform at a high level of quality. The Security and Safe-guards area is one in which the licensee's performance indi-cates effective actions in identifing and correcting potential problem areas at their own initiative.
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B. Conclusion:
Rating: 1 Trend: Consistent C. Board Recommendation
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Licensee: . None NRC: . None
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i 4.6 Outage and Modifications (131 hrs., 4%)
A. Analysis
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Outage and Modification activities are routinely monitored by resident inspectors. In addition, one inspection of the licensee's modification program was conducted by two region-based inspectors. A significant number of inspection hours related to this area are included under plant oper3tions.
This functional area was not evaluated in previous assessment periods due to Shoreham's status as a construction facility.
During this assessment period, the licensee completed over 60 modification activities in a period of five months. These ac-tivities include; neutron source replacement, completion of EQ modifications, and. modifications to the reactor vessel water level systemc As a^ result of these activities, for most of the last half of this assessment period, the facility was in an outage condition.
The licensee has a separate organizational division for Outage and Modifications which reports to the Plant Manager. The di-vision consists of an Outage Section, Modifications Section, and Planning & Scheduling Section, as well as a section devoted specifically to the Colt diesel generator project. )
The licensee has been unable to fully staff the Outage and Mod-ifications Division with LILCO employees, and while it is the smallest division (with 42 authorized positions), it has the highest vacancy rate for licensee employees (33.3%). The licensee has filled the vacancies with contractor personnel.
The use of large numbers of contractor personnel creates a sit-uation where attrition and contractor rotation introduces in-consistency in performance. Turnover of licensee employees within the Outage and Modifications Division is the lowest in the plant (3.5%), and aggressive attempts to increase the number of full-time licensee employees is evident.
Management involvement in Outage and Modification activities is evident. The Division Manager is frequently observed in the field checking the status of on going jobs, and observing work in progress. Additionally, the presence of Division Managers at datiy planning and scheduling meetings is evident, with the presence of the Maintenance and the Outage & Modifications 01-vision Managers being especially noteworthy. Plant Manager involvement in these meetings is frequent. The presence and involvement of these management personnel has frequently been observed to be instrumental in the resolution of problems and reprioritization of schedules. ,
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The technical resolution of engineering difficulties during modification activities is a strength in the licensee's Outage and Modification Program. Nuclear Engineering-Department and Stone & Webster Site Engineering Office personnel attend daily
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planning and scheduling meetings, and the NED Manager frequent- -
ly is present. Coordination among plant staff, NED, and Stone
& Webster in resolving problems is a strength of the licensee's
! program. Frequently, issues are discussed and resolved on the spot at the daily meetings. NED and Stone & Webster's review of modification activities is thorough and comprehensive. Fre-quent NED assistance in the resolution of procurement or docu-mentation problems is evident.
Ar inspection of activities related to modification activities conducted in the second half of this rating period found the implementation to be generally good. The detail and clarity of modification procedures, knowledge of personnel, involvement and interface of modification and engineering staff, interface of Quality Control, and extensive Review of Operation Committee review of modification packages were observed as strengths in the licensee's program. A need for improvement by the licensee in the areas or control of tags during modification activities, record retention, and attention to detail in the closeout of modification packages were also identified.
Outage and Modification Division Management has established a 1 firm commitment to training and qualification within the divi-sion. Two of the four Outage and Modification Division Section Heads are presently in training to receive SRO licenses, and a third presently holds an SRO license. This knowledge of plant operations, systems, and technical specification requirements is beneficial in the coordination of work activities. In addi-tion, the Modifications Section is involved in frequent train-ing sessions which involves areas ,such as; Administrative controls, hands-on experience, theory, and technical issues.
The Modification Section also conducts training sessions for NED, QC, and operations personnel.
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Prior to the beginning of the Source Replacement Outage in Oc-tober, the licensee sent the Outage Engineer to the Susquehanna Steam Electric Station for 2 months to observe the activities of their cutage group. This training and familiarization ap-peared to be extremely beneficial and is considered to be one of the reasons that the outage was conducted in a successful manner. The licensee uses a number of computer systems and tracking programs to schedule work activities and coordinate outage management. These systems allow management to track completion of scheduled activities and resolve problems which are delaying work activities. ,
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The licensee's performance in the area of Outage and Modifica- ;
tions to date has been effective. However, the organization i has yet to be challenged at a level which is equivalent to that which will occur during refueling outages, or during modifica-
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tions under a full power operating license. -The framework for an organization which will function effectively during full power operations exists. The licensee should increase atten-tion to staffing, and continue the positive steps in the area of training-to ensure that the organization can make the tran-sition with little or no problem.
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B. Conclusion Rating: 2 Trend: Consistent C. Board Recommendation Licensee: Continue efforts to complete staffing NRC: None
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4.7 Training and Qualification Effectiveness A. Anaiysis -
- During this assessment period Training and Qualification-effec-tiveness is being considered as a separate functional area for the first time. Training and qualification effectiveness con-tinues to be an evaluation criteria for each functional area.
Thevariousaspectsof[thisfunctionalareahavebeenconsid-
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ered and' discussed as an integral part of other functional ar-eas and the respective inspection hours have been included in 4 each one. Consequently, this discussion is a synopsis of the assessments related to training conducted in other areas.
Training effectiveness is normally measured primarily by the
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observed performance of licensee personnel, but in the case of Shoreham, with its' extended period of low power operation and outage, this is not possible. Therefore, to a greater degree,
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this assessment has been a review of program adequacy.
The discussion below addresses three principle areas: licensed operator training, non-licensed staff training, and status of INPO training accreditation.
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The training of non-licensed personnel is an area where a sig-f nificant increase in the level.of management attention is war-ranted. Significant probisms were noted by the NRC in a special inspection of the Radiochemistry program at the plant. These included inadequate records, violations of Station Procedures for qualification, and improper on-the-job training. Additional-ly, in areas other than Radiochemistry, the licensee's Quality Assurance Department has discovered numerous problems with train-ing and qualification. Training of non-licensed personnel has
'
been almost completely left to plant technical sections, and Training Division oversight and a'ssistance to these sections is
- not evident. The reliance upon the Technical Sections for i training activities has created an additional burden for the plant staff, which in many cases is already overburdened and understaffed. This split of responsibility has also created
,
' conflicts between plant and training division records, and has i
created situations where the training department has become simply a repository for training files. Training Division l review, audit, or Quality Control of these records is not evident.
Although the licensed operator training program has greatly improved since the last SALP period, the areas of non-licensed
.
operator training and management involvement in training are considered to be areas of significant weakness. Although Divi-sion Management and section supervisory personnel attempt to
.
l individually ensure that effective and valid training is j
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- - - - - -- - . - - . _ - . . _ - - - _ _ . -- -
. _ _ . _ _ _ . __ . _ . ._ ___ _
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> offered to their personnel, the lack of Training Division and Senior Management attention to training has created inconsis .
tency, and in one case, allowed improper implementation of a training program to occur. At the end of this rating period,
-
. the licensee had begun increasing attention to the area of I training by establishing a new position of Corporate Director of Training who will report directly to the Executive
,
Vice-President. NRC will be closely monitoring this area dur-ing the next SALP period to determine whether effective correc-tive act.fons are being made.
The performance of licensed personnel in the control room dur-ing testing, and during transient events initiated by equipment
- malfunctions demonstrated the ability to handle the plant in a
,
competent and professional manner. Knowledge"of system opera-tional characteristics, familiarity with procedures, and ac-i tions on transient response were evident, and are indicative of effective and valid training and requalificaticn for licensed operators. Nonetheless, attention must be given by licensed operators to plant conditions and operating procedures during all modes of reactor operation so as to avoid the types of
problems discussed in Section 4.1, Plant Operations and Startup Testing.
- During this assessment period, the Quality Assurance Department instituted an Operational Training Program for QA, Safety, and ';
Compliance personnel. This program is taught by a licensed SRO. The purpose is to increase the systems and operations knowledge of the attendees to allow them to more effectively perform their jobs. The program includes examinations which
!
must be successfully completed at stages in the program in or-der to continue. This initiative demonstrates a strong commit-ment to training by the QA Department.
-
t The licensee is pursuing the training program accreditation
-
with the Institute of Nuclear Power Operations. Accreditation
.
f should be complete within 2 years of fuel load in accordance .
with the NRC Policy Statement on training. Fuel load occurred at the plant in December 1984. No programs have been accredited to date. The first four programs, in the operations area, are scheduled for Self-Evaluation Report submittal in August 1986.
,
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The remaining programs will be submitted in late 1986 or early 1987.
i B. _ Cone: mion
Rating: 3
,
Trend: Declining '
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.
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C. Board Recommendation Licensee: . Direct management attention to establishing good training in all plant areas
~
. Reassess the reasons for the contrast between
' the training in areas such as Emergency Planning and Security versus other plant areas NRC: . Conduct a management meeting with the licensee in July or August to discuss the adequacy of training and qualification.
.
Conduct a six month appraisal of the Training and Qualification area *
. . Conduct a special inspection into Training and Qualification activities at Shoreham
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4.8 Licensing Activities
. A. -Analysis
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_ During the previous-assessment period, the need for the
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licensee to devote more attention to non-critical path activi-ties, and to prevent hearings and litigation issues from inter-fering with plant staff normal responsibilities were noted.
Additionally, the existence of a restraint on the interchange of information between the licensee and the NRC staff due to the atmo' sphere of litigation which surrounds all activities related to Shoreham was noted. This situation continues to exist, despite a significant reduction in the licensing tempo during the rating period.
.
The licensee's management continued to participate directly in the most major cri'tical path licensing activities during this period, most notably emergency planning, the TDI EDGs, and the GDC-17 exemption. Because these issues were, and in the case of emergency planning still are, on the critical path for li-censing, this management involvement made a positive contribu-tion in assuring quality. During the staff's review of the equipment qualification exemption request, the licensee's man-agement was instrumental in providing additional information in a timely fashion. Similarly, the Vice President for Nuclear Operation has personally participated in the emergency planning process, including the performance of the drill on February 13,
)
1986.
The technical review of the TDI EDGs has also received continu-ous management involvement and support which has been the prin-cipal reason for its success. When the favorable ASLB decision on the TDI EDGs was issued, senior LILCO engineering managers
,
participated personally in the development of the license con-ditions and technical specificati'ons needed to implement the ASLB decision.
Similarly, in the spring,of 1985, LILCO management placed the full resources of the company behind the resolution of security concerns associated with the GDC-17 exemption process.
Notwithstanding the above, however, it was noted that the "sig-nificant hazards" analyses accompanying requests for license amendments have been perfunctory and conclusary, rather than true analyses. In this regard, the licensee's performance is typical of many others (see Generic Letter 86-30). Future 11-cense amendment requests should include sufficient detail for the reviewer to understand the details of the request and the basis for it without resorting to a review of the entire FSAR.
)
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- w s - - - , - . , - ----- ---- , ,------,n- , - - - - - - , - - - - - - - , - - - - - ~ , - - - - , - . , -
, , - - - -
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During the low power testing program a concern was raised by NRC regarding the licensee's interpretation of reporting
'
requirements prior to receiving NRC concurrence on this inter-pretation. This involved a power spike greater than 5% power
-
due to equipment malfunction. Although Facility Operating Li-conse NPF-36 limited the plant to S% power, and required re-porting (via the ENS line) to the NRC operations of violations of this limit,- the licensee initially felt a report wasn't re-
'
quired. The basis for this belief was an, at that time unan-swered, letter to.the NRC regarding the need for ENS reporting of unintentional violations of license conditions. It was only after insistent prodding by the Senior Resident Inspector and the Licensing Project Manager that the licensee reported the event. The performance of the licensee in this matter was not indicative of satisfactory responsiveness to NRC initiatives.
-
,
This incident also demonstrates a need for licensee management to be less concern'ed with public and press reaction to poten-tial reportable events. A similar attitude was evident among licensee management when it became necessary for the licensee to report non-conformance with a license condition on comple-tion of EQ modifications by the November 30, 1985 NRC deadline.
The licensee's technical response to tne resolution of most issues continues to be generally sound. NRC staff reviews dur-ing this rating period have concentrated on the resolution of
' (- portions of larger issues left over from the previous rating period. The licensee's management and staff continue to demon-l strate a good understanding of these issues. Specifically, the
.; licensee's performance regarding the TDI EDGs has been excel-l lent. In the area of fire protection, the licensee's response to the issue of the control of associated circuits for the ADS valves was especially conservative, compared to other l'
,
licensees.
!
However, the licensee's initial response to human factor con-
)
'
cerns raised by the NRC staff related to TDI EDG loading was deficient, and the staff had to prod the licensee to perform a proper task analysis.
As was noted in the previous assessment period, LILCO is will-ing and able to marshal whatever resources are necessary to resolve issues that remain on the critical path for licensing.
The two prime examples of this are the TDI EDG effort and the
'
off-site emergency planning organization, which encompasses over 2000 LILCO employees from throughout the company. Howev-i er, the licensee responsiveness to other initiatives, which are not on the critical path, whether NRC initiated or licensee
!
.
initiated, is still low. This was evident in the time required to respond to open fire protection issues, the issue of the operability of the HPCI, RCIC, and RWCU isolation valves, and the TDI EDG human factors task analysis.
( I
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--,-,,m.,-. - -, ___
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Another example of an issue whose resolution has been delayed is the Probabalistic Risk- Assessment (PRA). During the origi-nal licensing board hearings in 1983, LILCO committed to pro-vide the staff with the results of its PRA, including the
-
consequence analysis section. The licensee submitted the first two parts of the PRA in 1984, but has not, to date, submitted the consequence analysis section, despite continual verbal re-minders from the staff. This has delayed completion of the staff review for over two years.
The delays discussed above can be traced to two fundamental causes. First, an atmosphere of litigation continues to sur-round this project. It has created an over cautious attitude about what is written into formal submittals to the NRC, and how it is written. Consequently, a protracted review process has been establish,ed which inevitably produces delays. In some cases, it has also' reduced the usefulness of letters to the NRC, because of resultant ambiguities.
A second cause appears to be understaffing in the licensee's licensing organization. Three experienced licensing engineers have left that organization in the last year, with a resultant ir. crease in workload for the remaining two engineers. If and when Shoreham is eventually licensed for full power operations, the workload of this group will increase substantially.
Licensee management must take aggressive action to correct this l situation to prevent future serious problems.
B. Conclusion Rating: 3 Trend: Consistent C. Board Recommendation
.
Licensee: .
The licensee should improve its responsiveness to NRC initiatives which do not directly affect the licensing schedule. Submittals should be more thorough, detailed, and specific. Techni-cal Specification changes should be accompanied by true analyses, rather than by perfunctory conclusions.
NRC: Senior NRC management should discuss with senior licensee management their overly cautious attitude about releasing information, so that the flow of necessary information is not impeded.
.
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4 '. 9 Assurance of Quality -
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A. Analysis
.
Management involvement and control in assuring quality con-tinues to be one of the evaluation criteria for each functional area. During this assessment period Assurance of Quality is being considered as a separate functional area for the first time.
.
The vari ~ous aspects of Quality Assurance and Control (QA and QC) program requirements have been considered and discussed as in integral part of each functional area and the respective inspection hours are included in each area. It should be noted that QA is only one management tool available to provide feed-back to management on the quality of work. Consequently, this
discussion is.a sysopsis of the assessments relating to the quality of work conducted in other areas and is not intended to be restricted to a discussion of QA or QC.
The assurance of quality in plant operations is an area where the licensee has demonstrated contradictory performance. Secu-rity and Safeguards, and Emergency Planning are two areas which demo 7 strate that the licensee has the ability to devote the
- necessary time, attention, and resources to assure quality ac-k tivities. However, these areas contrast clearly with training, licensing, and Radiological controls, in that no such commit-ment to quality activities is evident in those areas. Addi-tionally, areas in this report which detail weaknesses in procedural adherence, control of activities, spare parts pro-curement and control, and personnel inattention to detail, point up deficiencies in the licensee's overall implementation of quality activities.
It is evident that when the licensee operates in a proactive posture, with appropriate management and supervisory attention, quality work is the result. It is equally evident that when management attention is lacking, or when priorities are shift-ed, problems develop. The licensee must adjust the attention of management to ensure that an appropriate level of involve-ment exists in all areas to ensure that quality performance is achieved.
At the end of this assessment period, as a result of the prob-lems in the radiochemistry area, the licensee had begun steps to increase the presence of management personnel in the plant.
Daily interaction and contact between management and employees is important in monitoring the quality of work performed and assuring a positive attitude toward assurance of quality. Ac-tion by the licensee in this area is warranted.
(
- - _ _ _ .
.
.
')
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During the previous assessment period a need for improvement was noted in the timeliness and completeness of response to QC Audit findings, and the failure to accomplish the necessary corrective and/or preventive actions within committed times.
During the later portion of this assessment period, these con-cerns were again identified in a special inspection of problems in the Radiochemistry Section, in that audit corrective actions were not vigoursly pursued to progressively higher levels of management for resolution.
Quality assurance department involvement in plant activities is
~
evident, as observed during routine resident inspector tours, and during outage and maintenance activities. An inspection of the modification program by regional based inspectors in the later part of this period noted that the Quality Controls Divi-ston's independence in the selectian of hold points, and the use of different inspectors for package, work, and completed job review was a strength in the program.
Needs for improvement in the licensee's Quality Controls organ-ization were noted in an inspection of the area of radioactive waste activities. The licensee implemented immediate correc-tive actions for this concern. Irrespective of the licensee's responsiveness and corrective actions, these areas indicate a need by the licensee to devote additional management attention to the details of the day to day operation of the quality func- )
tion at Shoreham.
'
The assurance of quality by those organizations involved di-rectly in plant activities, irrespective of the licensee QA Department, is an area which was noted as a strength in the previous SALP period. In that rating period the Operations and Maintenance Departments were specifically mentioned as being noteworthy in their attitude that the assurance of quality for their departments activities was'their responsibility. The decreased level of performance in plant operations, training, and quality assurance during this rating period, indicate a need for re-emphasis on this area. The need for management to in-crease involvement in the assurance of quality for their own departments activities is evident.
B. Conclusion Rating: 2 Trend: Declining ( Although indicated as declining, the trend associated with this functional area can more accurately be described as variable.)
,
f I
- _ _ _ _ _ _ . . ,_- . .~ . . . . - - _ . . . _ _ _ . . . . _ _ _ . _ . _ _ , _ _ _ _ _ _ _ _ . . _ _ - _ _ , . _ _ _ . . _ _ - _ _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ .
. - . .- -
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(
C. Board Recommendation Licensee: . Assess and implement corrective actions to reduce the inconsistent nature of the degree of quality implementation inplant programs
. Review the administrative burden of the Division Managers.
NRC: . Conduct a management meeting with the licensee to discuss assurance of quality activities I
. Conduct a six month appraisal of the Assurance of Quality area
.
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e i
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, . , - - . _ - ..-.._,---,._._.-n__..- - - .
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5.0 SUPPORTING DATA AND SUMMARIES 5.1 Investigation and Allegation Review
-
Three allegations were received during this rating period. One was unsubstantiated.
A second involved concerns related to activities in the Radiochemis-try Section. An investigation in this area by the NRC Office of In-vestigation was begun at the end of this rating period, and is ongoing. Enforcement action related to this allegation is pending.
The third involved calibration of certain instrumentation and con-trols, as well as training and qualification of instrumentation technicians and supervisors. This allegation was the subject of a special inspection conducted in April and May of 1985. Concerns
'
regarding this allegation were resolved.
5.2 Escalated Enforcement Actions Escalated Enforcement action related to activities in the Radio-chemistry area, including management and QA involvement is pending.
5.3 Management Conferences Date Subject )
March 1, 1985 Discuss performance of the Cold License class in February.
April 1-2, 1985 Review the Shoreham Probabilistic Risk Assessment.
June 7, 1985 SALP Management meeting January 28, 1986 Personnel errors and licensee action regarding check valve failures.
In addition, members of the Atomic Safety and Licensing Board toured the plant site on March 25, 1985 in connection with hearings on the GDC-17 exemption request.
.
l
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5.4 Licensee Event Reports .
1. Tabular Listing A. Personnel Error............. 3$,'
B. Design / Man./Const./ Install.. 15 C. External Cause............... 1 D. Defective Procedure.......... 3 E. Management /0uality Assurance Deficiency.................. 0 X. 0ther........................ 7
,. ...
Total................... 58 LER, Reviewed 85-006 to 86-004 2. Casual Analysis a. Personnel errors - there were thirty two LERs involving personnel error. They were: 85-006,85-007, 85-010,85-011, 85-014,85-017, 85-018,85-019, 85-020,85-022, 85-026,85-030, 85-031,85-029, 85-033,85-034, 85-035,85-037, 85-042,85-043, 85-044,85-047, 85-048,85-050, 85-053,85-054, 85-055,85-056, 85-057,85-058, and 86-004. Of these personnel errors, twenty-two resulted in challenges to ESF Systems, including four reactor trips from power. ,
,
The subject of personnel errors, and challenges to safety systems as a result of such errors, was raised with the licensee by the Senior Resident Inspector on December 20, 1985, and was the subject of an NRC/ Licensee Management meeting at the plant site on January 28, 1986. Licensee actions to minimize personnel errors will be monitored during the next rating period.
b. External causes - one LER,85-046, was the result of Hur-ricane Gloria, which hit the plant site on September 27, 1985, causing spurious ESF actuations and resulting in missed fire watches.
c. Bomb Threats - three of the LERs,85-021, 85-059, and 86-003 were the result of b6mb threats that the licensee has received.
(
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t
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5.5 Operating Reactor Licensing Actions 1. Schedular Extensions Granted a. Equipment Qualification - for ventilation damper actuators and H2 Recombiners until December 31, 1985.
b. Inerting Containment - until 120 EFPD have been expended.
2. Reliefs Granted None 3. Exemptions Granted a. GDC-2 Seismic Qualification of Radiation Monitors b. GDC-56 . Containment Isolation Valves c. Appendix J MSIV Leak Rate Testing d. GDC-19 Remote shutdown capability
'
e. 10CFR50.44 Initial Containment Inerting f. 10CFR50.49 Environmant Qualification 4. License Amendment Issued Amendment No. 1 - issued December 6, 1985 - to extend deadline for completion of E0 work. )
5. Orders Issued Numerous orders were issued by the ASLBs, ASLAB, and the Commission related to the ongoir.g licensing hearings.
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O
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- . , - . - . . . - - - ,, ., . , . , . _ _ _ , , -
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Table 1 '
LISTING OF LERs BY FUNCTIONAL AREA SHOREHAM NUCLEAR POWER STATION March 1,1985 - February 28,1986)
NUMBER /CAUSE CCOE TOTAL FUNCTIONAL AREA A. Plant Operations' 12/A 10/B 1/C 3/X 26
& Startup Testing B. Radiological Controls 1/D 1 C. Maintenance & Surveillance 17/A,5/B,2/D 24
~.
O D. Emergency Preparedness 3/A 4/X 7 E. Security & Safeguards O
F Outage & Modifications G. Training & Qualification
Effectiveness
H. Licensing Activities 1. Assurance of Quality 0 Cause codes: A - Personnel Error B - Design, Manufacturing, Construction or Installation Error
-
C - External Cause D - Defective Procedure E - Management / Quality Assurance Deficiency X - Other
.
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T2-1
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l Table 2 LER SYNOPSIS (3/1/85 - 2/28/86)
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SHOREHAM NUCLEAR POWER STATION LER NO SYNOPSIS l
85-006 ECCS Actuation on Personnel Error 85-007 Fire' watches Late in the Control Room 85-008 Auto Start of Emergency Diesel Generator 103 85-009
Steam Leak Detection Div. II Ambient Temperature Hi Alarm Activation ,85-010 Inadvertent RHR Loop B Trip in Shutdown Cooling l 85-011 Auto' Actuation of Control Room Air Conditioning
'85-012 Deficiencies in the Background Screening Process with Temp Force Inc. Employees85-013 HPCI Inverter Circuit Failure
)85-014 Late Fire Watch Patrol in EDG Rooms Due to Personnel Unable to Gain Access85-015 ,
Intake Canal, ultimate Heat Sink Accumulated Sediment Beyond Allowable Limits85-016 Automatic Actuation of Control Room Air Conditioning 85.-017 Two Full Scrams and NSSSS 1/2 Isolation Due to I&C Technicians Working on an Instrument Rack 85-018 ESF Actuatt.*.n Occurred as a Result of a High Flux Signal on IRM Channel 'D'
i 85-019 TPCN Was Not Approved Within the Tech Spec Allowable f
i Time Frame
_
85-020 ESF Actuation Caused by RPV Low Water Level Signtis85-021 Bomb Threat 85-022 High Pressure Scram Caused by Malfunctioning RWCU Blowdown Which Was Being Used to Control RPV Pressure
-
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- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - ._ _
- .
T2-2 (
LER NO SYNOPSIS85-023 RWCU Actuation Caused by Electromagnetic Interferences Possibly Due to Work Activities85-024 ESF Actuation Caused By Low Reactor Water Level 85-025 Missed Daily Channel Checks Due to Improper Implementation of a Station Modification 85-026 Personnel Hatch Failed Full Volume Test l
85-027 RWCU Isolution Due to Blown Fuse in Differential Ci rcuitry 85-028 Missed Fire Watches in the Chiller and the HVAC Equipment Rooms Due to Damaged Door Latch 85-030 Initiation of CRAC/RBSVS "A" Side Due to Technician Bumping Jumper 85-031 RPV Low Level Scram Due to Water Draining Into the Suppression Pool when Suppression Pool Suction Valve Was Opened While che SDC Suction Valve Was Closing
'85-029 Degraded Vital Security Area 85-032 HPCI Isolation Due to High Exhaust Diaphragm Pressure i 85-033 Inadvertent Split of RBCLCW Into Its Accident Mode ("B" Side)85-034 Diesel 101 Service Water Stand Pipe Hinged Cap Wedged Shut 85-035 Reactor Manual Trip Due to Loss of Instrument Air 85-036 RWCU Isolations Oue While Operator Was Adjusting Blowdown Flow 85-037 Reactor Trip While Valving in of Instrument Connected to Variable Leg 85-038 "B" Reference Leg Spiked High Due to Excess Condensate in the Steam i.ine to the Condensing Chamber 85-039 CRAC Initiations During RBSVS Testing 85-040 RBSVS/CRAC Initiation Due to Voltage Dip Caused by
-
Thunderstorms85-041 Bomb Threat
_ - - _ _
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T2-3
-
)
LER NO SYNOPSIS85-042 Mechanical Disturbances Caused Low level Trip 85-043 Reactor Scram Due to Valving in of Test Stand to
~ ~
-
Variable Leg 85-044 RWCU Isolation Due to Technician Error While Working on a Surveillance Procedure 85-045 LPCI Declared Inoperable While HPCI was Out of Service 85-046 ESF Actuations and Suspended Fire Watches Due to Hurricane " Gloria" P,5-047 Auto Start of Emergency Diesel Generator Due to Equipment Operator Error 85-048 RBSVS "B" Side Ini*iation Due to I&C Technician Error 85-049 LLRT Exceeds Allowable Technical Specification Limit 85-050 RBSVS/CRAC "B" Side Initiation Due to Technician Error 85-051 HPCI Check Valve Malfunction Due to Their Valve )
Mechanisms Separating From the Valve Bonnets85-052 RPS Actuation When Switching From RPS " Alt" to RPS
"A" Bus85-053 TPCN-85-721 Not Approved in Time Limit Specified in l Technical Specifications85-054 Loss of RPS Bus "A" When Equipment Operator Opened RPS Bus "A" Circuit Breaker Inadvertently 85-055 Equipment Required to be Environmentally Qualified by 1 November 30, 1985 was not Completed 85-056 Security Guard Found Sleeping at His Post 85-057 RBSVS Initiation Due to Technician Error (Dropped Screwdriver)85-058 NSSSS Isolations Due to I&C Technician Error 85-059 Loss of "B" RPS Bus Due to the EPA Breaker Being Found in the Off Position ,86-001 Containment Atmosphere Sample Not Analyzed in I
Accordance with Technical Specifications
- _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
._ . _ . ~ _ . . . . . . . - _
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T2-4
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LER NO SYNOPSIS86-002 Missed Fire Watch in LPCI MG Set Room 111 Due to
'
Inoperable Door
-
Bomb Threats
.86-003 86-004 Security Guard Failure to Log Personnel Entry
..
G
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w - w -.mrs#- ----.? . >a-- - - . * -
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O T3-1
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)
Table 3 INSPECTION HOURS SUMMARY (3/1/85-2/28/86 SHOREHAM NUCLEAR POWER STATION FUNCTIONAL AREA HOURS % OF TIME A. Plant Operations
& Startup Testing............ 1831* 60%*
8. Radiological Controls........ 317 10%
C. Maintenance & Surveillance... 250 8%
0. Emergency Preparedness....... 331 11%
E. Security & Safeguards........ 207 7%
F. Outage & Modifications....... 131** 4%"*
G. Training & Qualification *** ***
Effectivaness................ .
- *
H. Licensing Activities......... )
- ***
I. Assurance of Quality.........
T0TAL........................ 3067 100%
- Hours expended in facility license activities and operator license activities are not included with direct inspection effort statistics
- Inspection hours by Resident Inspectors in this functional area are included in the plant operations functional area l
l
- Hours expended in these functional areas not included with direct inspection effort statistics as they are included in other functional areas i
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T4-1
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Table 4 ENFORCEMENT SUMMARY (3/1/85-2/28/86)
SHOREHAM NUCLEAR POWER STATION -
A. Violations vs. Functional Area SEVERITY LEVELS FUNCTIONAL AREA I II III IV V DEV TOTAL A. Plant Operations &
Startup Testing 2 2 B. Radiological Controls ,
O C. Maintenance & Surveillance 1 1 D. Emergency Preparedness 0 Security & Safeguards 0 E.
F. Outage & Modifications 0 G. Training & Qualification Effectiveness 0 H. Licensing Activities 0 Assurance of Quality 0 I.
TOTALS BY SEVERITY LEVEL 0 0 0 1 2 0 3 B. Summary REPORT NO. SEVERITY FUNCTIONAL AND DATES LEVEL AREA VIOLATION 85-30 V Plant Operations Failure to 07/29-08/12/85 & Startup Testing implement s/u program in accordance with procedures
.
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T4-2
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_ i Table 4 (Cont'd)
REPORT NO. SEVERITY FUNCTIONAL AND DATES LEVEL AREA VIOLATION 85-42 IV Maintenance & Failure to con-11/1-30/85 Surveillance duct maintenance activities with adequate proceo-ural controls 85-42 V Plant Operations Failure to ad-11/1-30/85 here station procedures 86-03 Pending Radiological Pending 01/27-02/14/86 ' Controls
)
,
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^
T5-1
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Table 5 INSPECTION ACTIVITIES (3/1/85-2/28/86)
SHOREHAM NUCLEAR POWER STATION REPORT NO. &
INSPECTION DATES INSPECTOR AREAS INSPECTED
.
85-13 03/04/85-02/0P/85 Specialist SER and Facility License requirements related to Electrical power supplies 85-14 03/04/85-03/08/85 Specialist Startup Test Program 85-15 03/05/d5-03/07/85 Specialist Non-radiological Chemistry Program
,
85-16 k 03/04/85-03/08/85 Specialist Security Program 85-18 03/01/85-03/31/85 Resident Routine 85-19 04/30/85-05/04/85 Specialist Security Program 85'-20 04/01/85-05/15/85 Resident Routine 85-21 04/09/85-05/10/85 Project Engineer Allegation Followup 85-22 04/10/85-05/10/85 Project Engineer Allegation Followup 85-23 04/29/85-05/01/85 Team Inspection Safe shutdown capability in the event of fire
'
35-24 05/16/85-06/18/85 Resident Routine
,
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o T5-2
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]
Table 5 (cont'd)
.
REPORT NO. &
INSPECTOR AREAS INSPECTED INSPECTION DATES
.
85-25 06/10/85-06/14/85 Specialist Security Program 85-26 '
06/12/85-06/14/85 Specialist Radiological Controls Program 85-27 06/28/85-08/02/85 Resident Routine 85-28 Spdcialist Startup Test Program 06/24/85-06/28/85 Activities 85-29 07/06/85-07/26/85 Specialist Startup Test Program Activities 85-30 08-03/85-08/31/85 Resident Routine s
!
85-31 Specialist Startup Test Program 07/29/85-08/12/85 Activities 85-32 08/12/85-08/30/85 Specialist Startup Test Program Activities
.
85 33 Specialist Security Program 08/26/85-08/30/85 85-34 09/16/85-09/20/85 Specialist Operator Licensing Examinations 85-35 Specialist Startup Test Program 08/30/85-09/13/85 Activities 85-36 09/01/85-09/30/85 Resident Routine 85-37 09/16/85-10/08/85 Specialist
'
Startup Test Program Activities
. _ . . _ _ _ _ _ _ , _ __ , -_
. _ _ . .,
_ _. .. .
"
T5-3
.
)
-
Table 5 (Cont'd) .
REPORT NO. &
INSPECTION DATES INSPECTOR AREAS INSPECTED 85-38 10/21/85-10/25/85 Specialist Radiological Controls 85-39 10/01/85-10/31/85 Resident Routine 85-40 10/15/85-10/18/85 Specialist Non-radiclogical Chemistry Program 85-42 11/01/85-11/31/85 Resident Routine 85-43 12/01/85-12/31/85 Resident Routine 86-01 01/01/86-01/31/86 Resident Routine 86-02 f 02/12/86-02/14/86 Specialist Emergency Planning -
Observation of FEMA Full Scale Exercise 86-03 Team Inspection- Allegation followup -
01/27/86-02/14/86 Specialist & Resident Radiochemistry Program 86-04 02/10/86-02/14/86 Specialist Security Program 86-05 02/01/85-02/28/85 Resident Routine 86-06 02/25/86-02/28/86 Specialist Transportation and Radwaste Programs i
l
.
___ _ - ________ _ _ _ _ _ _ _ _ _ _ _ _ .
y T6-1
- .
,
i Table 6 ,
REACTOR TRIPS AND PLANT SHUTDOWNS POWER DATE LEVEL DESCRIPTION CAUSE & AREA *
04/29/85 SD Reactor trip due to Personnel error -
false low RPV water during a surveill-level signal ance test, technician
'
valved in pressure transmitter causing an indicated level transient AREA - Maint. & Sury.
05/09/85 SD Reactor trip due to Personnel error -
upscale spike on IRM maintenance per-channel 'O' sonnel bumpad incore instrumen-tation cables AREA - Maint. & Sury.
05/21/85 SD Reactor trip due to Personnel error -
false low RPV water during testing, }
level signal a technician valved in a level transmitter creating an oscillation in the variable leg line.
AREA - Maint. & Surv.
06/06/85 SD Reactor trip due to Equipment Failure -
high RPV pressure During a leak test on the vessel using the CRD system &
t RWCU blowdown valve, a defective feedback arm on blowdown valve l
'
controller caused valve to close enough to increase RPV pressure AREA - N/A 07/07/85 Startup N/A
Note - the cause attributed to these shutdowns is the NRC assessment of cause, and may not agree with the licensee's assessment.
--
. . .
r "
>.
.. *,
T6-2
. :
,= Table 6 (Cont'd)
\
_ POWER DATE. LEVEL DESCRIPTION CAUSE & AREA *
07/13/85 '5% Reactor trip during Equipment Failure -
low power testing on Failure of air low vessel level line on FW minimum flow valve AREA - N/A 07/16/85 Startup N/A 07/17/85 < 5% Shutdown for RPV level Planned instrumentation work 07/23/85 Startup N/A 07/25/85 <5% Shutdown for RPV level Planned instrumentation work 07/26/85 SD Reactor trip due to Personnel error -
low RPV water level an operator opened RHR Suppression Pool suction valve prior to shutdown cooling valve
,
being closed AREA - Plant Ops (
07/29/85 Startup N/A 08/24/85 (5% Shutdown for rod Planned sequence exchange and minor maintenance 08/30/85 Startup N/A 08/31/85 1.0% Reactor trip on loss Personnel error -
of instrument air improper replacement of desiccant in air dryer unit AREA - Maint. & Sury.
09/03/85 Startup N/A 09/06/85 1.1% Reactor trip during Personnel error -
surveillance test false low RPV water level signal during testing AREA - Maint. & Sury.
'
, * Note - the cause attributed to these shutdowns is the NRC assessment of the
! cause, and may not agree with the licensee's assessment.
. _ .-
- ____ ________ ____ ____
'}Q T6-3
)
Table 6 (Cont'd)
POWER DATE LEVEL DESCRIPTION CAUSE & AREA *
09/07/85 Startup N/A 09/08/85 1.25% Reactor trip manually Equipuent failure -
initiated RPV level indicators went offscale high due to RPV reference leg problems AREA - N/A 09/09/85 < 5% Shutdown for Planned investigation and repair of RPV water level deviations 09/11/85 Startup N/A 09/12/85 2.0% Reactor trip due to Personnel error -
low water level work activity indication caused hydraulic j
'
oscillation on f level line, creating -
false low level signal AREA - Maint. & Sury.
09/18/85 Startup N/A 09/25/85 45% Reactor shutdown Maintenance activities and
- Hurricane Gloria 10/03/85 Startup N/A 10/08/85 < 5% Reactor shutdown Completion of 5%
test program I
- Note - the cause attributed to these shutdowns is the NRC assessment of the ;
cause, and may not agree with the licensee's assessment.
?
i
_ _ _ _ _ . _ . _ _