IR 05000322/1986008

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Insp Rept 50-322/86-08 on 860301-0415.Violation Noted:Work Performed on EDG103 Under Maint Work Request 86-0746 Completed W/O Evidence of Written Procedures or Job Plan to Describe Work Procedure
ML20198R148
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 05/21/1986
From: Strosnider J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198Q944 List:
References
50-322-86-08, 50-322-86-8, IEIN-84-17, NUDOCS 8606090457
Download: ML20198R148 (12)


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REPORT NO.

50-322/86-08 DOCKET N0.

50-322 LICENSE NO.

NPF-36

LICENSEE:

Long Island Lighting Company P. O. Box 618 Shoreham Nuclear Power Station Wading River, New York 11792 INSPECTION AT: Wading River, New York INSPECTION CONDUCTED: March 1 - April 15, 1986 INSPECTORS:

John A. Berry, Senior Resident Inspector Cla C. War en, Resident Inspector

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APPROVED:

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6/1//8(,

p/ R. Strosnider, Chief, Reactors Projects Date Signed

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V5ection 18, Division of Reactor Projects SUMMARY:

During the inspection period, March 1, 1986 through April 15, 1986, the inspec-tors observed activities associated with the completion of the reactor level reference leg modification outage and activities related to preparation for plant startup.

As a result of this inspection effort one violation was identified for insuffic-ient maintenance procedures (see Section 4.2).

Five items were opened for inspector followup and five items were closed as a result of this inspection.

In addition to the activities above, the inspectors attended an Enforcement Conference at Region I Headquarters in King of Prussia, Pennsylvania on March 20, 1986. The Enforcement Conference was held to address the findings in Shoreham Special Inspection Report 50-322/86-03.

Further information on the proceedings can be found in Conference Report No. 50-322/86-03.

This inspection involved 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of inspection.,

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DETAILS 1.

Status of Previous Inspection Items 1.1 (Closed) 85-25-01:

Licensee Actions on Industrial Experience

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The licensee had previously been provided with a copy of the " Report

i to Congress on Abnormal Occurrences, July - September 1984". This report discussed degraded isolation valves in Emergency Core Cooling Systems at various Nuclear Plants and the associated corrective actions.

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The Licensee's Independent Safety Engineering Group conducted a review of the aforementioned report and prepared Project Report ISEG85-053 to document this review, a copy of which was provided to

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the Resident Inspector.

The Licensee's report concludes that events similar to those described in the " Report to Congress on Abnormal Occurrences, July -

September 1984" will not occur at Shoreham. This conclusion is based on Technical Specification Surveillance sections 4.4.3.2.2, 3/4 6.1 and 3/4 6.3, which require that reactor coolant system

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isolation valves be tested on a periodic basis and prior to being returned to service. The licensee's procedures require that this

i testing be performed with the reactor depressurized. Additionally,

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the Emergency Core Cooling Systems design provides an unisolable relief valve for the low pressure piping in each system.

The

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inspector's review determined that all concerns have been satis-l factortly resolved. This item is closed.

l 1.2 (Closed) 86-05-02, RHR Weld Failure

Inspection Report 86-05 detailed the multiple failures of a 3/4 inch

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sockolet weld in a test connection on the Residual Heat Removal i

System Shutdown Cooling Suction Line. A third failure of the sockolet occurred on March 3, 1986 and the analysis of the failure

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mode and licensee actions in response to that analyses had not been I

completed at the time Inspection Report 86-05 was issued, i

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Analysis of material removed from the failed sockolet by an

independent metallurgical laboratory showed the failure to be stress

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induced. The licensee determined that the excessive stress was

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derived from relative motion of approximately 1/4 inch between the i

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3/4 inch line and its pipe support.

This cold spring occurred when

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the friction fit support moved down the vertical section of large bore pipe on which it was mounted.

This movement was the result of

vibration during system startup, coupled with poor hanger

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reassembly.

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The sockolet repairs were completed on March 9, 1986 with care taken to insure proper hanger reassembly. The residual heat removal system has since been in the shutdown cooling mode on numerous occasions with no additional problems.

The inspector concurs with the

licensee's' evaluation and resolution of this problem, this item is closed.

1.3 (Closed) Notice of Violation 50-322/85-12-01

Inspection 50-322/85-12 identified that the licensee was not in compliance with Technical Specification surveillance requirements in that numerous safety related preventive maintenance items had not i

been performed by their due dates.

The licensee has implemented the following corrective actions in answer to the Notice of Violation in Inspection Report

50-322(85-12-01):

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The Preventive Maintenance Procedure, SP 12.015.01, has been revised to stipulate that no Priority I preventive maintenance activities will be allowed to exceed their extension dates.

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The authorized complement of I&C technicians has been increased from 26 to 31 and the actual number of technicians increased from 21 to 28.

l The Instrumentation and Control section has achieved full

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Priority I I&C Preventive Maintenance Compliance.

The inspector reviewed the implementation of these corrective i

actions and had no further questions. This item is closed.

1.4 (Update) 85-20-01, I&E Information Notice 84-17 l

IE Information Notice No. 84-17 identified a concern related to the j

failure of the nitrogen inerting and purge line at Hatch Unit 1.

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was determined that this failure was thermal stress induced with the thermal stress caused by the application of cold nitrogen during the i

purging process.

l The licensee review of IE Information Notice No. 84-17 concludes

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that similar failure at Shoreham is unlikely for the following reasons:

The nitrogen system at Shoreham is designed to provide nitrogen

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gas at 70 degrees F.

Nitrogen gas at this temperature would not

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produce the thermal gradient necessary for pipe failure.

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I Design Output Package No.84-275 addresses the concern of gross

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failure of the nitrogen vaporizer / heater train and temperature control valves. Such a failure could allow liquid nitrogen to pass through the piping into the containment.

Solenoid valves will be installed to prevent this flow should system temperature fall below 40 degrees F.

Electric heat tracing and insulation will be installed between

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the discharge of the vaporizer / heater trains and the secondary

containment penetration.

This modification will prevent gas i

temperature from falling below 70 degrees F. during periods of cold weather and low system flow.

These actions are addressed in licensee letters-SNRC-1082 and 1098,

dated September 18, 1984 and November 8, 1984 respectively.

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The inspector reviewed the licensee evaluation and had no further questions.

This item is closed.

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1.5 (Closed) 86-06-03, Transportation Activities Inspection Report 86-06 identified that the licensee did not have a copy of the vendors Topical Report for radioactive waste solidifica-tion on site as suggested in the NRC Branch Technical Position.

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licensee received on site copies of Westinghouse Topical Reports to meet the requirements of the NRC Branch Technical Position Paper.

i The following Topical Reports were received:

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Topical Report on Cement Solidified Waste to Meet the Stability _

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Requirements of 10CFR61.

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Topical Report on Hittman Mobile In-Container Dewatering and

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Solidification System.

This item is closed.

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2.

Review of Facility Operations

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2.1 Plant Status Summary i

During the period covered by Inspection Report 86-08 the licensee j

conducted activities directed at concluding the water level reference leg outage. Upon completion of outage activities in mid March, the licensee began preparations for reactor startup and resumption of testing in late March. Minor equipment failures

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and resultant procurement problems, coupled with requirements for repair and retest have prevented facility startup during this

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inspection period.

The facility has completed all surveillances and outstanding maintenance required for startup with the exception of

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condenser tube leak repairs.

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Investigation into the scope and cause of the tube leaks are

underway and the licensee has decided not to commence a reactor j

startup until the results of the investigation have been analysed.

2.2 Operational Safety Verification f

l The inspector toured the control room daily to verify proper shift l

manning, use of and adherence to approved procedures, and compliance

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with Technical Specification Limiting Conditions for Operation.

Control panel instrumentation and recorder traces were observed and l

the status of annunciators was reviewed.

Nuclear instrumentation and reactor protection system status were examined.

Radiation monitoring

instrumentation, including in plant Area Radiation monitors and ef-j fluent monitors were verified to be within allowable limits, and ob-served for indications of trends.

Electrical distribution panels were examined for verification of proper lineups of backup and t

l emergency electrical power sources as required by the Technical Specification.

The inspector reviewed Watch Engineer and Nuclear Station Operator

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logs for adequacy of review by oncoming watchstanders, and for proper

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entries. A periodic review of Night Orders, Maintenance Work j.

Requests, Technical Specification LCO Log, and other control room-logs and records were made.

Shift turr: overs were observed on a periodic basis.

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I The inspector also observed and reviewed the adequacy of access j

controls to the Main Control Room, and verified that no loitering by unauthorized personnel in the Control Room Area was' permitted.

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inspector observed the conduct of Shift personnel to ensure adherence to Shoreham procedures 21.001.01, " Shift Operations" and

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21.004.01, " Main Control Room - Conduct for Personnel".

The inspector noted that on-shift personnel conducted themselves in

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a dedicated and professional manner, and that watchstanding

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personnel were fully aware of plant status and ongoing activities.

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No unacceptable conditions were identified.

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2.3 plant and Site Tours

l The inspector conducted periodic tours of accessible areas of plant t

and site throughout the inspection period. These included:

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Turbine and Reactor Buildings, the Rad Waste Building, the Control

Building, the Screenwell Structure, the Fire Pump House, the

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Security Building, and the Colt Diesel Generator Building.

i During these tours, the following specific items were evaluated:

I; Fire Equipment - Operability and evidence of periodic

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j inspection of fire suppression equipment; i

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Housekeeping - Maintenance of required cleanliness levels; Equipment Preservation - Maintenance of special precautionary

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i measures for installed equipment, as applicable; o

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QA/QC Surveillance - Pertinent activities were being surveilled

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on a sampling basis by qualified QA/QC personnel;

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Component Tagging - Implementation of appropriate equipment tagging for safety, equipment protection, and jurisdiction; Personnel adherence to Radiological Controlled Area rules,

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including proper Personnel frisking upon RCA exit;

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Access control to the Protected Area, ir.cluding search j

activities, escorting and badging, and vehicle access control; j

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Integrity of the Protected Area boundary.

l No unacceptable conditions were identified.

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2.4 Administrative Matters 2.4.1 Review of Operations Committee (ROC)

Several Review of Operations Committee Meetings were attended by the inspector during the inspection period.

During these meetings, the inspector verified the required Technical Specification composition and quorum for the committee. The inspector also verified that appropriate reviews of safety evaluations and issues were presented.

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No unacceptable conditions were identified.

2.4.2 Plant Organizational Changes Mr. W. Kesner relinquished, effective April 4, 1986,

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the responsibilities as the Screening and Badging Administrator. At this time no replacement has been i

named.

Mr. S. H. Daniel III was named Radiochemistry

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Engineer replacing Acting Radiochemistry Engineer,

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Mr. R. Jongeblood who will become the Reactor Engineer. Official transfer of responsibilities will occur upon the completion of the turnover now in progress.

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3.

_ Licensee Reports l

3.1 In Office Review of Licensee Event Reports The inspector reviewed Licensee Event Reports (LERs) submitted to the NRC to verify that details were clearly reported, including accuracy of the cause description and adequacy of corrective action.

The inspector determined whether further information was required

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l from the licensee, whether generic implications were involved, and

whether the event warranted onsite follow-up.

The following LERs i

were reviewed:

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LER NUMBER TITLE

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86-005 RBSVS/CRAC "B" Side Initiation During

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I&C Surveillance

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!86-006 Rad Chem Surveillance Procedure not l

Performed by Extension Date 86-007 RBCLCW Split Due to Low "A" Head Tank Level 86-008 RBCLCW Split While I&C Technician was

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Performing a Surveillance

!86-009 Reactor Trip During APRM Functional

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Test

  • 86-010 Suspected Leakage to Station Vent j

Radiation Monitor Yields Non-Representative Sampling

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j 86-011 Ultimate Heat Sink, Accumulation of i

Sediment i

!86-012 Failure to Meet Action Statement for j

Loss of Continuous Monitoring of the

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Station Ventilation Exhaust Due to Loss of Power to Sample Pump i

86-013 Continuous Fire Watch in Relay Room

Not Met Due to Fire Watch Person Being Asleep j

86-014 Full Reactor Low Level Trip While I&C j

Technician was Valving in Pressure j

Transmitter

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LER NUMBER TITLE 86-015 Continuous Fire Watch Required by Tech. Spec. 3.7.8 was Missed Due to

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Fire Watch Being Stuck in Elevator

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86-016 Seismic Monitoring Recorders in

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Control Building Out of Service for l

More than 30 Days.86-051 HPCI Check Valve Malfunction -

i Supplemental Inspector Followup item 86-08-01.

Four station radiation

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monitors were supplied by Kaman with purge valves

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j reversed. Licensee evaluation of monitor operation is j

currently in progress.

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No unacceptable reports were identified.

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4.

Monthly Surveillance and Maintenance Observation 4.1 Surveillance Activities I

The inspector observed the performance of various surveillance tests to verify that; the surveillance procedure conformed to technical specification requirements, administrative approvals and tagging

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requirements were reviewed and approved prior to test initiation, j

testing was accomplished by qualified personnel, current approved procedures were used, test instrumentation was currently calibrated, j

limiting conditions for operation were met, test data was accurately

and completely recorded, removal and restoration of affected j

components was properly accomplished, and tests were completed j

within the required Technical Specification frequency.

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SP 24.307.01 Emergency Diesel Generators Start and Load Test i

SP 24.307.04 Bi-weekly Testing of the EMD Diesel Generators

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i SP 24.405.01 Reactor Building Standby Ventilation System Filter

Train Operability Test SP 27.307.01 Emergency Diesel Generator Air Compressor Test SP 24.654.01 Containment Air Lock Operability Test-No unacceptable conditions were identified.

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4.2 Maintenance Activities The inspector observed the conduct of various maintenance activities

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throughout the inspection period.

During this observation, the inspector verified that; maintenance activities were conducted

.within the requirements of the plant's administrative procedures and

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technical specifications, proper radiological controls were j

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implemented and observed, proper safety precautions were observed, and that activities which have the potential to impact plant operations are properly coordinated with the control room.

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The inspector observed maintenance activities which removed and replaced a failed sockolet weld in a test connection to the residual heat removal system.

This was the final repair of the failed joint covered in Inspection Report 86-05. All activities observed during the performance of this repair were satisfactory. No unacceptable activities were observed.

Repair and retest of both diesel air start air compressors for EDG 102 were observed. No unacceptable conditions were observed.

Work to replace the jacket water circulating pump on EDG 103 was observed on April 15, 1986.

No written procedures, either specific

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or generic, were required by Maintenance Work Request No. 86-0746.

This lack of approved written procedures appears to be in conflict with Regulatory Guide 1.33.

The provisions of Regulatory Guide 1.33

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are required by Technical Specification 6.8.1, consequently it appears that this activity was not performed in compliance with all Technical Specification requirements.

i Maintenance Section Procedure 31.010.01 provides guidance to the maintenance foreman in determining whether written instructions need i

be provided or if the job in question is within the scope of section 9.1 of Regulatory Guide 1.33, which allows some maintenance activities to be performed using skill of the craft rather than detailed written procedures. There appears to be a significant difference in the scope of activities allowed to be performed without written procedures between Regulatory Guide 1.33 and Maintenance Section Procedure 31.010.01.

The leeway allowed by SP31.010.01 allowed work to be performed on

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EDG103.

The lack of written instruction to cover this activity appears to be in violation of Technical Specification Section 6.8.1.

(50-322/86-08-02).

5.

Review and Followup of I&E Notices, Bulletins and Generic Letters

5.1 I&E Notices The inspector reviewed notices issued by the Office of Inspection j

and Enforcement during the inspection period. This review was to determine; if the subject of the notice was applicable to the

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Shoreham Nuclear Power Station, and if followup of the licensee's action was required by the inspecto ~

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The following IE Information Notices were received during the per[od covered by Inspection Report 86-08:

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IE Notice No. 86-14:

PWR Auxiliary Feedwater Pump Turbine j

Control Problems.

IE Notice No. 86-15:

Loss of Offsite Power Caused by Problems in Fiber Optics Systems.

i IE Notice No. 86-16:

Failures to Identify Containment Leakage i

Due to Inadequate Local Testing of BWR

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Vacuum Relief System Valves.

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I IE Notice No. 86-17:

Update of Failure of Automatic Sprinkler System Valves to Operate.

IE Notice No. 86-18:

NRC On-Scene Response During a Major Emergency.

IE Notice No. 86-19:

Reactor Coolant Pump Shaft Failure at

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Crystal River.

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IE Notice No. 86-20:

Low Level Radioactive Waste Scaling Factors

10 CFR Part 61.

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IE Notice No. 86-21:

Recognition of American Society of i

Mechanical Engineers Accreditation Program i

for N Stamp Holders.

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IE Notice No. 86-22:

Under-response of Radiation Survey i

Instrument to High Radiation Fields.

IE Notice 86-15: Loss of Offiste Power caused by Problems in

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Fiber Optics Systems is not applicable at Shoreham because no

fiber optics are used in the switchyard protection scheme.

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IE Notice 86-19 relates to Reactor Coolant Pumps used in PWR

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application and is not applicable to Shoreham.

IE Notice 86-14 relates to possible overspeed trip and lockout

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j of Terry turbine driven pumps equipped with ' Woodward governors.

The reactor core isolation cooling system at Shoreham is

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equipped with such a pump and turbine combination. The i

licensee's evaluation of this Notice to determine if any j

procedural changes or equipment modifications are necessary is j

not yet complete and this item will be considered Inspector j

Followup Item 86-08-03.

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IE Notice 86-16: Failure to Identify Contaiment Leakage Due to

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Inadequate Local Testing of BWR Vacuum Relief System Valves.

Due to the generic nature of this Notice it is applicable to Shoreham.

Inspector review of the licensee's evaluation of leak rate testing procedures to insure proper test methodology will be Inspector Followup Item 86-08-04.

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IE Notice 86-17: Update of Failure of Automatic Sprinkler

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System Valves to Operate.

This Notice addresses the failure of 6 inch deluge and preaction fire protection control valves (model C) manufactured by Automatic Sprinkler Corporation of

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America.

Inspector review of the licensee's action addressing

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these valves in use at Shoreham will be Inspector Followup Item 86-08-05.

6.

Licensee Response to Confirmatory Action Letter 86-05

In response to Confirmatory Action Letter 86-05, the Inspectors conducted followup inspections to insure that the LICB-SBES Actions complied with the content of CAL 86-05.

The retraining and requalification of five Radiochemistry Technicians to provide adequate backshift technician coverage was required by CAL 86-05 prior to the licensee commencing plant startup.

The licensee submitted documentation to the inspectore to confirm that these specific actions had been taken prior to starti,,.

i The inspectors conducted in-Jepth review of all activities associated with

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the Radiochemistry Technician requalification effort. This effort included an in-depth screening of the task analysis provided by the licensee to in-sure that training was provided on all routine surveillance items required by Technical Specification.

The inspectors also reviewed the completed qualification and training documents for the five technicians being quali-fied for back shift assignment to insure completion and procedural com-pliance.

The inspectors attended Technical Specification training con-ducted by the Day Watch Engineer for the Radiochemistry Technicians which addressed Radiochemistry related Technical Specifications.

In addition to followup inspections to insure the retraining and requalification of technicians was adequate, the inspectors met with the

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acting Radiochemistry Engineer, Radiological Controls Division Manager and the Head of the Radiochemistry Task Force on April 14, 1986 to monitor progress on commitments made to the NRC in LILCO letter SNRC-1245.

The licensee indicated that the requalification proctss was well under way with five technicians completely requalified by April 16, 1986.

Retraining by Dr. K. K. Taylor in the proper use of Chemistry Control I

j Charts, correlation between ph and conductivity, and chloride stress corrosion have been completed.

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A procedure change has been implemented to eliminate one level of management within the radiochemistry section.

The elimination of the Radiochemistry Supervisor position is intended to improve communication within the section in the future.

The licensee has contracted an outside assessment company to perform independent audits of the radiochemistry section, at six month intervals, to insure that improvement in section performance continues.

These evaluations will continue until upper management is satisfied that section performance is up to industry standards.

In response to NRC concern involving the timeliness of the radiochemistry section response to licensee Quality Assurance Audit findings, the Plant Manager has issued directives to insure timely action is taken to any future QA Audit findings. All licensee Division Managers are new required

to attend any Quality Assurance entrance and exit interviews for sections I

under their control.

Corrective actions and corrective action reports in response to QA Audit findings are to be completed within 30 days of report issuance.

These corrective action reports will be submitted to the Plant Manager to insure his awareness of all corrective actions.

The inspecters are satisfied that the actions taken oy the licensee in retraining and requalification of Radiochemistry Technicians are thorough and correct and satisfied t'1e requirements of CAL 86-05 pertaining to technician qualification.

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7.

Management Meetings At periodic intervals during the course of this inspection, meetings were held with licensee management to discuss the scope and findings of this inspection.

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Based on NRC Region I review of this report, and discussions with licensee representatives, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.

The inspectors also attended entrance and exit interviews for inspections

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conducted by region-based inspectors during the period.

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