IR 05000322/1989009

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Insp Rept 50-322/89-09 on 891109-900128.No Violations Noted. Major Areas Inspected:Operations,Maint,Surveillance, Committee Activities & License Conditions
ML20012D192
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 03/15/1990
From: Doerflein L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20012D189 List:
References
50-322-89-09, 50-322-89-9, NUDOCS 9003270031
Download: ML20012D192 (12)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-322/89-09 Docket No.

50-322 License No.

NPF-82 Licensee:-

Long Island Lighting Company P. O. Box 618 Shoreham Nuclear Power Station Wading River, New York 11792 Facility Name:

Shoreham Nuclear Power Station Inspection At:

Shoreham, New York Inspection Period:

November 9, 1989 to January 28, 1990 Inspector:

F. J. Crescenzo, Senior Resident Inspector Approved by:

M Lui 15 90 L. T. Doerfle n, Chief

'Dat'e o

Reactor Projects Section 2B Inspection Summary: 11/9/89 - 1/28/90 (Report 50-322/89-09)

Areas Inspected:

Routine inspections of operations, maintenance, surveillance, committee activities and license conditions. One hundred forty hours of direct inspection effort were expended.

Results: No violations or inadequacies were identified.

No significant events or_ challenges to plant systems occurred during the period.

Lay-up of plant systems has progressed rapidly and the licensee is now on schedule with this program. The fitness for duty requirements of 10 CFR 26 were adequately implemented. Two whiskey bottles were found inside the protected area. The person (s) responsible for the bottles were not found. The licensee implemented a program of random pat-down searches for persons entering the protected area in response to discovery of the whiskey bottles. The licensee adequately resolved diesel fuel oil problems. An NRC monitored emergency planning exercise was conducted.

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h TABLE OF CONTENTS

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1.0 Facility Activities..........................................

I 2.0 Previous Inspection Items....................................

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3.0 System Layup.................................................

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4.0 License Amendment Application................................

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5.0 Fitness for Duty Training.........................

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6.0 On Site Alcohol Consumption..................................

7.0 Fuel Oil Problems............................................

8.0 Personne1....................................................

9.0 Management Meetings..........................................

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10.0 Reassignment of Resident Inspector...........................

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DETAILS 1.0 Facility Activities

The licensee continued with the system lay-up process.

Significant

progress was made in this area. No significant plant events occurred

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during the ;.criod. An inadvertent actuation of containment isolation valves in the Reactor Water Cleanup system occurred on December 12,

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1989. The cause for this actuation stemmed from an inadequate System Layup Implementation Package (SLIP) procedure related to High Pressure

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Coolant Inspection (HPCI) System. The preparer did not anticipate

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closure of the valves when two breakers normally associated with the HPCI system were opened. The isolation was promptly reset and the valves restored to normal position.

A number of significant licensing documents were submitted by the licensee during the period.

Two apparently isolated discoveries of onsite alcohol consumption were made. The licensee adequately implemented the fitness for duty rules of 10 CFR 26.

Staffing continued to remain relatively stable although several key personnel left the facility.

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The Licensee conducted an Emergency Preparedness drill of the onsite team in December. An NRC team monitored the licensee's performance during the exercise. No significant deficiencies were noted.

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l 2.0 Previous Inspection Items (92701)

I 2.1 (Closed) 85-04-01 and 85-04-09 Upgrade of Post Accident i

Sampling These items have remained open to allow verification that equipment and procedures for Post Accident Sampling Facility operations are

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l valid. All technical and equipment upgrade issues have been long resolved and closure was pending full power operations to permit sufficient system flows and activity levels. These items were last reviewed in the Shoreham Operational Readiness Team Inspection 50-322/89-80.

That review found the items to be minor in nature and confirmed the need for power operations in order to allow closure.

Based on the minor significance of these items and the licensee's l

contractual commitment not to operate the facility, these items are

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administrative 1y closed.

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j 2.2 (Closed) 89-01-01 ASME Program Deficiencies

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i This item addressed the licensee's discovery of improper post-construction application of ASME fasteners in various systems.

l Historical details are contained in inspection reports 50-322/89-01, 89-80, 89-04.

Inspection Report 89-04 documented the completion of the licensee's

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actions to identify and disposition improper fasteners installed in the plant. The item remained open pending completion of the licensee's root cause evaluation.

The root cause was determined to be inadequate training of maintenance personnel. Maintenance personnel were trained to identify fastener dimensional requirements

S om applicable engineering documents but were not adept at distin-guishing the specific ASME class.

The licensee's training department has incorporated this training into the maintenance training program.

This item is closed.

2.3

_ Closed) 89-10-01 Emergency Plan Classification Guidance (

During the most recent Emergency Response drill in December 1989, the onsite Emergency Response team in the control room failed to identify an Unusual Event (UE) given a complete loss of Meteorological

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monitoring.

It was noted that the alarm response procedure for loss of mete-orological monitoring did not flag entry to an UE. All other Emergency Action Levels were noted in the alarm response procedures (ARP) where applicable. This was thought to be the root cause for the failure to identify the EAL.

l The licensee has approved and implemented a change to ARP 1409 to have the operators refer to the emergency plan when all meteorological instrumentation is lost.

The inspector verified the adequacy of this

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change.

This item is closed.

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2.4 (Closed) 89-07-01 NCV for Suspension of Containment Leak Rate Testing Inspection Report 50-322/89-07 documented a non-cited violation for discontinuing containment leak testing in violation of test frequency requirements of 10 CFR Appendix J.

The violation resulted from the licensee's misinterpretation of the requirements i

and was unrelated to the otherwise adequate testing program.

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Upon identification of the potential violation, the licensee took action to resume leak rate testing.

The licensee is now in full compliance with leak test requirements and is continuing with the testing program as necessary to maintain compliance. As this

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violation was unrelated to the adequacy of the program, no program-

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matic corrections were needed to achieve compliance. The licensee's I

decision to resume testing and the completion of outstanding penet-ration testing is sufficient to close this issue.

The licensee has submitted an application for exemption from the leak testing frequency requirements. This item is closed.

3.0 System Lay-up The licensee has made significant progress on its System Layup Implementation Package (SLIP) program.

This program provides specific instructions for lay-up of systems classified as PROTECTED

(see NRC inspection report 50-322/89-91 for a more detailed program description).

As noted in inspection report (50-322/89-07), the licensee had been lagging behind schedule for the SLIP program. The new plant manager directed his staff to prepare a new schedule and has emphasized this program as a top priority. The new schedule was issued in early December.

This schedule shows completion of the SLIP program in early May 1990.

Completion of SLIP activities has become a top priority at the facility. At the close of this inspection period the licensee was on

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or ahead of the new schedule.

The licensee anticipates that the process may be completed ahead of schedule.

During this inspection period, the licensee completed implementation of 16 SLIP packages. A substantial percentage of the remaining SLIP packages are well into the preparation or implementation process.

,l Most PROTECTED wet systems have been drained including all emergency core cooling systems (ECCS), the suppression pool, and the condensate and feed system. The licensee was progressing with draining of the condenser hotwell and circulating water system at the close of the L

period.

In terms of volume, thrse systems represent the bulk of water l

(and potentially contaminated water) to be drained and processed.

Other wet systems which remain to be drained include the control rod drive (CRD), service water and chilled water systems. These present special problems because portions of these systems will remain filled and operable.

Progress on development of these SLIP packages continues.

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The remaining PROTECTED systems do not involve draining. Generally, these will entail valve lineups or switch and breaker alignments.

These systems do not appear to present special problems although some will remain partially operable,

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i Following completion of the SLIPS the licensee will concentrate on

long term facility disposition. This will include dispositioning of the fuel, long term system monitoring, license transfer and other significant licensing actions.

4.0 License Amendment Applications The licensee submitted several licensing documents this period. These include application to terminate offsite emergency preparedness, application to amend the facility license to reduce technical specifi-cation requirements consistent with the defueled status, application

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for exemption from requirements of 10 CFR 50 Appendix J (containment leakage testing), and application to modify the security plan.

Acceptability of these submittals is under review by the NRC's Office of Nuclear Reactor Regulation (NRR).

5.0 Fitness for Duty Training The inspector nonitored the licensee's fitness for duty (FFD) training.

The training was required to instruct Shoreham personnel on implemen-tation of 10 CFR 26 which became effective January 3, 1990.

The inspector monitored two classes. One was for non-supervisory and escort personnel and the other was for supervisors. Both provided adequate overview of the new rule but were lacking certain details of LILCo's implementation procedure. This was because the licensee's procedure was still in the review and approval process.

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inspector determined that the training provided sufficient information

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for personnel to understand the process.

The inspector noted that the procedure was approved and implemented by January 3,1990 as required.

The inspector had no further questions.

6.0 Alcohol Bottles Found On Site The licensee found two whiskey bottles inside the protected area during the inspection period. The licensee could not identify the responsible parties.

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The first discovery occurred on November 28, 1989. The plant manager i

had ordered an extensive cleanup effort in the administration and i

services building. As part of this effort a supervisor found a partially consumed pint bottle of whiskey hidden in the basement area of the building. The bottle was confiscated and clandestine efforts

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were made to identify the owner (s).

Identification efforts were unsuccessful and the plant manager took action to re-emphasize rules

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restricting on-site alcohol consumption.

Following this, an employee came forward and reported seeing the bottle some months before. The employee had not reported the finding at that time. The employee denied responsibility for the bottle. No personnel actions were taken against this e.nployee but he was counseled om his responsibility to promptly report such observations. This topic was also emphasized

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in the fitness for duty training provided to all employees during December.

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The licensee could not conclusively determine the age of the bottle nor how long it might have been in hiding. The area where the bottle was discovered is frequently used by a number of employees and departments for various purposes. No single department or

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employee group is responsible for the area. As such, none could be singled out for heightened investigation. The bottle was turned over to LILCn Corporate security for further investigation. No formal report to the NRC was required concerning the matter; however, the resident office was promptly alerted after discovery of the bottle.

l The second discovery occurred on January 5, 1990.

Fire protection

technicians were performing routine surveillance of firs detectors l

in the overhead spaces of the 150 foot elevation of the Reactor Building. While performing the surveillance, a technician spotted

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an empty pint whiskey bottle which had been hidden in the corrugated steel which forms the overhead.

The technician promptly reported the discovery to station management.

The area of discovery is a rarely traveled space. As with the first l

discovery, no information as to responsibility may be inferred from l

the location.

It is known that the platforms used to access the area were erected approximately three years ago. The licensee suspects the bottle may have belonged to a contractor associated with platform erection. Here again however, the licensee has no conclusive evidence to data the bottle or its placement.

The licensee implemented random pat-down searches of personnel entering the protected area during the last week of December.

These searches are conducted specifically to detect unauthorized entry of alcoholic

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beverages and augment the normal detection devices. Although security personnel have always been alert to entry of alcohol, the normal detection proced.ures and devices are not designed to detect entry of such.

The licensee is not certain at this time whether the pat-down searches will continue indefinitely.

The licensee is also considering scaling back the number and frequency of pat down searches.

Since beginning the searches no illegal or unauthorized substances have been detected.

The inspector had no further questions.

7.0 Fuel Oil problems Inspection Report 50-322/89-07 documented the licensee's problems with onsite diesel fuel oil. Numerous oil samples had failed analysis for oxygen stability as well as other parameters. The inspector concluded that the licensee's actions to resolve this matter have been adequate.

Seven onsite fuel oil tanks were associated with the failures.

These included three 7-day supply tanks for the Trans-American-Delaval (TDI) diesels, three 7-day supply tanks for the Colt diesels

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and a million gallon tank located outside the protected area.

The million gallon tank was used for bulk deliveries and storage of oil.

The TDI diesels are the standby AC sources required by the Technical Specifications.

In Shoreham's current defueled mode, only two of the three TDI's are required to be operable. No other diesels, nor the million gallon tank, are subject to Technical Specifications or license restrictions.

The licensee contracted with a vendor to clean the oil in the TDI 103 tank and in one of the Colt tanks.

The oil in TDI 101 tank was replaced and the oil in the third TDI tank (102) was left as-is after samples analyzed in late October showed this oil to be acceptable.

No actions were taken with fuel oil in the remaining two Colt diesel tanks and the million gallon tank.

Oil in these tanks remains unsatisfactory for use in the TDI machines.

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changes were made to preclude transfer of oil from the unsatisfactory tanks to the TDI tanks.

The vendor cleaned the oil by recirculating the tank contents through a temporary filter apparatus.

The two tanks which were subjected to this process were not drained. Although the oil was cleaned, the tanks themselves were not cleaned of residue or " tank bottoms." The TDI 201 tank was wiped clean of residue after draining and prior to refill with new oil.

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The licensee has also modified its fuel oil delivery procedure.

Previously, bulk deliveries were made to the million gallon tank.

Makeup for the onsite diesels was accomplished by a ferry tanker from the million gallon tank.

The licensee now makes bulk deliveries directly to the Colt tank which was subjected to the oil cleaning process. Makeup for the TDI diesels comes from this tank via an installed fuel oil transfer system. The million gallon tank and the remaining two Colt tanks are no longer sampled to Technical Specifi-cation standards. These tanks are not being used as TDI makeup sources.

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All oil analysis parameters were satisfactory for the one Colt and three TDI tanks following the actions taken in mid-November. The most recent samples, taken at the close of this inspection period, were also well within required specifications for the one Colt and TDI 101 and 103 tanks.

However, the TDI 102 tank failed oxygen stability and carbon residue analysis. The TDI 102 diesel has been inoperable for several months due to lapsed mechanical surveillance and will remain inoperable so long as its fuel oil is unsatisfactory.

The licensee has chosen not to restore the TDI 102 to operable status.

The Technical Specifications do not preclude this action.

Although the immediate problem seems to be resolved for the TDI 101 and 103 tanks, the root cause for the sudden failures has not been conclusively determined.

The licensee attributes the cause to be a buildup of insoluble impurities in the tanks.

The oxygen stability test method is described in ASTM D 2274-70.

The analysis requires the sample to be filtered through a 0.8 micron filter.

The filtered sample is then heated and exposed to pure oxygen for a period of time.

Following this, the oil is again filtered through a 0.8 micron filter and a determination of the oxygen stability is made based on the amount of insoluble impurities remaining on the second filter. According to the licenses, large quantities of insoluble impurities sized less then 0.8 microns would cause failures.

These would pass through the first filter, grow in size or coagulate as they oxidized, and become entrapped in the second filter. The licensee found support for this theory in the fact that the vendor who cleaned the oil found a significant quantity of 0.45 -

0.8 micron sized solids in the oil.

The licensee suspects the cause for the sudden siceltaneous failures in several tanks was related to cleaning and inspectQ n activities

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conducted last spring.

These were performed acenrding to routine 10 year service interval requirements.

Each of the TDI tanks was drained, cleaned, pressure tested, and refilled.

In order to drain the tanks without wasting fuel oil, the contents were transferred among the i

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three TDI and the Colt tanks. The numerous fuel oil transfers are i:

thought to have stirred up solids normally settled in the tank bottoms and suspended them throughout the tanks thereby causing the rash of failures.

However, failures were not seen in samples taken immediately following i

the cleaning operations conducted last spring.

Failures did not i

appear in any of the tanks until mid-August, well after the last tank was refilled. Also, this does not explain oxygen stability failures in the million gallon tank which was not cleaned or otherwise subjected

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to abnormal fuel oil transfer operations. According to the licensee's theory, the TDI and Colt tanks oil analysis should have failed immedi-ately following refill operations and the million gallon tank should

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not have failed the analysis.

The licensee cannot, at this time, explain these inconsistencies.

Despite the absence of a consistent theory to explain the sudden rash of failures, the licensee firmly believes the root cause to be insoluble impurities.

The licensee ruled out sampling and/or analysis errors. The same technicians, procedures, and apparatus were used to conduct sampling i.

both before and after tank cleaning last spring. The sampling pro-l cedure was reviewed and the technicians closely monitored following the failures.

No inconsistencies were found.

There is no evidence

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I to suggest the technicians have varied their application of the sampling procedures. There is no evidence to suggest the technicians may have falsified records or acted in violation of the sampling procedures. Quality Control (QC) inspectors have always monitored each sample taken from the TDI tanks. Although QC emphasis was on tank cleanliness rather than proper sampling technique, QC presence added independent oversight of the sampling process.

Lastly, the recent failure of the oil in the TDI 102 tank (which was not cleaned or replaced) would tend to rule out sampling errors since the same techniques were used for all four tanks.

As noted in Inspection Report 50-322/89-07, the licensee conducted an audit of the qualified analysis contractor, Saybolt.

The licensee sent chemistry technicians to the contractor's laboratory to observe the analysis process. The licensee also had other contractors confirm the qualified contractor's results. No inconsistencies were noted. This evidence ruled out analysis errors.

The licensee has ruled out possibilities that the fuel oil vendor may have supplied defective oil or that the additions of biocide agents may have affected the analysis. All shipments of fuel oil were sampled at the vendor's depot. No unsatisfactory results were

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S obtained. The licensee contacted several oil specialists regarding i

the biocide agents. All have stated that addition of the particular biocide agent should not have produced the failures in oxygen stability.

The inspector found the licensee's actions regarding this problem j

to be adequate. The licensee conducted a thorough investigation and appears to have adequately considered all possible causes for the failures.

The availatale evidence best supports the licensee's conclusion that the root cause for the failures was the presence of insoluble impurities. The inspector also noted the licensee has complied with Technical Specifications for diesel operability. The l

diesels were promptly declared inoperable upon receipt of unsatis-factory sample results.

The oil which was replaced or cleaned is

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acceptable and the problem seems to be resolved at this time.

Routine sampling required by the Technical Specifications should be adequate to discover any future recurrence of the problem.

The inspector had no further questions.

8.0 Personnel Staffing levels remained stable although several supervisors were transferred from the Shoreham project or left LILCo.

These included the Operations Division manager, the Security Division manager, the Compliance Department manager, and the Instrument and Controls Department manager. The inspector reviewed the qualifications of people selected as replacements for these personnel. No deviations from Updated Safety Analysis Report (USAR) requirements were noted.

The licensee has not selected a permanent replacement for the Security Department manager. The position is posted and the selection will be reviewed by the NRC when filled.

The inspector also conducted a review of the Plant Manager's qualifications relative to the USAR requirements.

No deviations or

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discrepancies were noted.

9.0 Management Meetinos

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Periodic meetings were held with station management to discuss inspection findings during the inspection period. A summary of findings was also discussed at the conclusion of the inspection.

No proprietary information was covered within the scope of the inspection.

No written material was given to the licensee during the inspection period.

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The NRC Region I Branch Chief, Section Chief, Project Engineer, and NRR Project Manager visited the site during the inspection period.

Discussions were held with the licensee to update current activities and facility plans. Routine inspection tours of the facility were

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also conducted.

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10.0 Reassignment of Resident Inspector The Shoreham Senior Resident Inspector was reassigned to another i

Region I site effective January 27, 1990.

Inspection of Shoreham.

will continue via routine visits from NRC headquarters and Region I based inspectors, who will act as the NRC resident inspector while onsite, t

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