IR 05000322/1989080

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Insp Rept 50-322/89-80 on 890311-27.Some Items Require Resolution Prior to Operation Above 5% Power.Major Areas Inspected:Assess Facility Power Ascension,Operations & Operations Support Programmatic & Staffing Readiness
ML20248G719
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 04/04/1989
From: Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20248G717 List:
References
50-322-89-80, NUDOCS 8904130545
Download: ML20248G719 (105)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

License: NPF-36 Docket: 50-322 Report:

50-322/89-80 Licensee:

Long Island Lighting Company P. O. Box 018 Shoreham Nuclear Power Station Wading River, New York 11792 Inspection At:

Shoreham Nuclear Power Station (SNP)

Wading River, New York Dates:

March 11-27, 1989 Inspection Team:

See Appendix A Purpose:

To assess Shoreham Nuclear Power Station (SNPS) power ascension, operations, and operations support programmatic and staffing readiness for safe operation.

Conclusion:

Upon resolution of the items identified in the forwarding letter for this report, the Shoreham Nuclear Power Station will be fully ready to operate safely.

Approved by:

& C b %,he 4 /4 f 6 Ebe C. McCabe, Jr., Team Manager Date l

l 8904130545 890404 PDR ADOCK 05000322 Q

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.i SUMMARY This operational. Readiness Assessment Team (0 RAT) inspection concluded that,

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upon resolution of certain issues (Detail 2.3.2 refers), LILCo is prepared to safely operate Shoreham. The quality assurance function was found to be particu-larly good.

Facility management has demonstrated the ability to control activities safely and in accordance with NRC requirements.

LILCo's staff has remained stable enough to reasonably conclude that performance will remain acceptable following licensing.

The licensed staff has remained particularly stable and has received extensive simulator training. Maintenance is being implemented acceptably. A noteworthy predictive maintenance capability has been established through vibration monitoring and oil analyses for rotating equipment.

License amendments and facil-ity modifications have been completed in accordance with NRC requirements, and the design of the ft.ll.ity has been adequately maintained.

Inspection of Environmental Qualification (EO) found an overall sound program.

The licensee has completed.a thorough and accurate self-assessment and has concluded that the Shoreham plant is ready for operation.

2.0 OVERVIEW 2.1 Background.

On March 3, 1989, the NRC Commissioners specified that, before the Shoreham Nuclear Power Station is authorized to operate above 5% power, an operational readiness assessment would be made. This report documents the associated oper-ational readiness team (0 RAT) inspection.

The ORAT was made up of the NRC Region I and the Office of Nuclear Reactor

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Regulations.(NRR) personnel listed in Appendix A.

Team members were selected, based upon training and experience, to inspect readiness for plant start-up, power ascension, operation, and supporting activities. The supporting activities re-viewed included radiological controls, maintenance, surveillance, engineering and technical support, inservice inspection, and environmental qualification. As practicable, the team assessed licensee (LILCo) readiness through (1) activity observation, (2) interviews, and (3) documentation review.

LILCo holds an NRC license authorizing Shorenam operation at up to 5% power.

Shoreham has been shut down since June 1987 except for being taken critical for training during January 1989. This inspection emphasized activities subsequent to June 1E87, with program changes and Shoreham staffing receiving particular at-tention.

In addition to compliance with NRC requirements and commitments to the NRC, the ORAT evaluated readiness for safe operation based on their judgement.

The inspection, its planned scope, and the planned ORAT composition were an-nounced to the licensee on March 9, 1989.

Primary licensee contacts were pre-i designated by the licensee.

During the inspection and associated meetings with

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the licensee, contact was made with operating and support staff personnel and first line supervisors, section heads, department and division managers and staff, cor-porate officers, and a member of the board of directors.

2.2 Inspection Scope The ORAT inspection, which involved 973 inspection hours, checked operational readiness of LILCo personnel and programs. Design adequacy was addressed by the ORAT only insofar as equipment performance, design changes, and environmental qualification were reviewed.

Physical security was inspected separate from the ORAT inspection, and was found to be satisfactory.

Emergency preparedness was not evaluated by the ORAT. Onsite emergency pre-paredness was inspected separately, and was found satisfactory. Offsite emergency preparedness is being addressed by the Office of Nuclear Reactor Regulation.

2.3 Results Summary 2.3.1 Overall Results Shoreham overall readiness for operation was assessed as very good.

This positive finding is a result of conti,ued management and r.taff emphasis on opera-tional programs and training during the extended shutdown period since operation at 5*4 power.

2.3.2 Functional Area Results The results in each inspection area are summarized below.

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Facility Management Management staffing, qualifications, and performance are acceptable. One open item related to the license's transition plans for replacing contractors with com-pany employees is to be, submitted for NRC review.

Plant Operations An ample and well qualified operations staff is ready to operate the plant safely. The licensee has committed that each Shift Technical Advisor will train and perf:rm assigned duties with his or her assigned shift.

Maintenance Maintenance is ready to support operation safely. Maintenance-related licensee commitments are summarized under Engineering and Technical Support.

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Surveillance The operational surveillance function is ready to support operation safely.

Minor procedure adherence discrepancies that did not affect safety will be pursued during routine inspection.

Facility Radiation Protection

'The Shoreham health physics organization is ready to support operation safely and to safely control associated radiation hazards.

Routine NRC inspection will monitor the planned licensee staffing additions.

Effluents, Radwaste, Chemistry, and Environmental Monitoring This' area is ready to support operation safely.

There are no open items.

Engineering and Technical Support This area is ready to support operation safely.

The licensee has com-mitted to a root cause analysis of corrective maintenance items with three or -

more occurrences per year, to assuring that ASME Class 2 and 3 bolting ac--

complished since construction is correct, and to review outstanding maintenance to assure that there will be no adverse safety effects.

These items are to be sumitted for NRC acceptance.

Power Ascension Test Program (PATP)

Projected PATP staffing is acceptable and includes augmentation by General Electric and Stone & Webster. The licensee has incorporated staffing prerequisites as PATP procedure hold points, and has tasked themselves with performing a compre-hensive self-appraisal at about the midpoint of the PATP. There are no open PATP items.

Inservice Inspection / Inservice Testing (ISI/IST)

This area is fully ready to support plant operation safely. There are no open ISI/IST items.

Environmental Qualification (EQ)

The licensee has an acceptable EQ program.

Four items must be resolved prior to operation above 5% power. One of these is the sealing of pressure trans-mitter electrical penetrations. The second is assurance of qualification of limit switch covers in motor-operated valves in Containment. The third item

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l is demonstrating that. equipment is qualified to the post-accident profile.

Item

I four'is assuring the acceptability of motor-operated valves without T-drains in

Containment.

Allegations No safety issues are open.

3.0 Facility Management 3.1. Review Scope Facility management readiness was reviewed by examination of the LILCo organi-zation and staffing (see Figures 1 through 11), discussions with licensee managers, and observation of management involvement in facility activities.

3.2 Assignments and Vacancies Figure 1 shows the Shoreham management organization.

The resume of the.new company President.shows past nuclear experience that includes qualification as an engineer officer of naval nuclear power plants. The Vice President, Nuclear'0pera-tions, has nuclear experience including. service as a station manager 'for an operat-ing Boiling Water Reactor.and as a Commanding Officer of a nuclear submarine. The Assistant Vice-President, ' Nuclear Operations, previously held a senior reactor operator's-license at Shoreham. The Training Director has extensive Navy nuclear experience, and the Quality Assurance and Outage / Modifications Managers hold cur-rent. senior reactor operator licenses at Shoreham.

Figure 1 reflects several recent organizational changes in Shoreham management assignments, with most of these occurring on March 1, 1989. One of these was the promotion of the previous Operations Manager to Plant Manager. The new Operations Manager had not been identified to the NRC as of the inspection end.

The licensee-stated that the selection process and interviews were ongoing and should be com-pleted soon. All candidates were stated by the licensee to be current LILCo em-ployees.

Extensive review of Figures 1 thrc:jh 11 with the licensee resulted in several i

changes to the organization charts. While the staffing numbers were a snapshot of a changing situation, it was concluded that the numbers and qualifications of

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personnel are adequate to support power operation.

3.3 Management Staff Stability and Morale

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I Retirement of the outgoing President was stated to be a mandatory retirement

at age 65 in accordance with company rules.

Other recent staffing changes relo-cated two long time Shoreham managers to other positions in LILCo.

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stability standpoint, the staffing changes were assessed as acceptable and not signif1cantly different from personnel changes experienced at times at other nuc-l lear power plants.

Shoreham managers all exhibited a positive attitude and good morale.

3.4 Management Oversight Activities and Goals The licensee has yearly goals for its Office of Nuclear Operations.

These were found to clearly communicate standards which strive for excellence in plant j

operations and support activities such as maintenance and engineering.

The ORAT

inspection concluded that licensee managars took personal responsibility for achieving improved performance.

The established goals address specific programs for reducing errors, improving plant configuration control, establishing a new work management program, scheduling engineering design and planning milestones for the Supplemental Containment System, planning to keep radiation exposures as low as reasonably achievable (ALARA), and for management development.

Supporting divisions and departments had defined objectives which addressed the Office of Nuclear Operations goals.

Evaluation methods were defined, where applicable, for the objectives.

Dated results were recorded to track progress.

The 31 performance indicators tracked monthly include aspects of operating, I

maintenance, and regulatory performance, and control room instrument and annunci-ator availability.

The licensee also addresses 39 performance indicators in a semi-annual comparison to industry average performance.

Some of these relate only to plant operation, others address related aspects such as emergency power systems'

performance.

The semi-annual report also addresses unplanned reactor trips (scrams)

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and safeguards system actuations, nuclear fuel reliability, overdue preventive maintenance, corrective maintenance backlog greater than three months old, the ratio of preventive maintenance to total maintenance, maintenance worker overtime and radiation exposure, unplanned automatic scrams while critical, feedwater dis-solved oxygen, and personnel skin or clothing contamination.

Salt water cooled heat exchanger performance is tracked also.

Trends are displayed in graphs of differential pressure and cooling water flow to better assure proper performance and to provide preventive maintenance scheduling data.

Some performance indicators are displayed on wall charts for the plant staff.

These include unplanned scrams and safeguards system actuations, rates of produc-tion of solid and liquid radioactive waste, and accumulated personnel radiation exposure.

Inspector review of the licensee's performance data identified no conflicts with operational safety and no deficiencies. The ORAT inspection concluded that the licensee's performance goals and their tracking are a valuable management information tool.

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3.5 Licensee Readiness Assessment LILCo previously assessed its readiness for facility operation above five percent thermal power. This assessment was forwarded to the NRC by letter dated November 18, 1988. NRC Region I, in a December 15, 1988 letter to the licensee, characterized the self-assessment as thorough and of high quality.

ORAT members reviewed the LILCo self-assessment for uncorrected conditions which could adversely affect operation.

None were found.

3.6 Quality Assurance Quality Assurance organization (see Figure 2) effectiveness was examined in-cident to the review of other ORAT inspection areas. The ORAT team found aggres-sive and capable quality assurance and quality control involvement in activities.

A proficient plant operational activity review capability was specifically noted.

Performance of the quality assurance organization was evaluated as a significant licensee strength.

3.7 Onsite Safety Review Committee The performance of the onsite Review of Operations Committee (ROC) is rou-tinely reviewed by the Shoreham resident inspector, and was recently inspected by other NRC personnel (Report 50-322/89-01).

During the ORAT inspection, ROC per-formance was assessed during ROC meeting 89-016 on March 16.

That meeting pri-marily addressed surveillance procedure revisions, but also reviewed open items and actions on problem reports.

The ROC addressed two out-of-tolerance test standards (0hmmeter M&TE #802, PRO 802-3; and Ashcroft pressure gage M&TE #168, PRO 168-10). Actions to assure that these standards had caused no adverse impact on :,afety-related calibrations were assessed as comprehensive.

The ORAT found a thorough review of proposed procedure changes. The changes considered on March 16 were identified by the operating staff as procedure improve-ments, or were necessitated by revised methods or materials used for calibration and testing, Presentations on proposed changes were generally good.

Changes were well researched and prepared in most cases.

The ROC challenged suggested changes that were deemed inadequately substantiated; these were rejected for cause.

The ROC chairman controlled the meeting and led discussions so as to assure probing, thorough reviews.

Overall, ba'sd on ORAT inspection and previous obser-vations, the ROC was assessed as effective.

3.8 Open Items LILCo's transition plan for replacing contractor employees with LILCo em-ployees is to be submitted for NRC revie _ _ _ _ _

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The only other open facility management item involves the need to assure that the Operations Manager, when selected, meets license and Updated Safety Analysis Report (USAR) standards and that the existing condition of the Operating Engineer filling two positions (Operating Engineer and Operations Manager) be corrected.

Routine resident inspection will address this consideration.

3.9 Conclusions on Facility Management Upon resolution of the open item in Detail 3.8, the Shoreham management organization is ready to assure safe operation at power.

4.0 PLANT OPERATIONS 4.1 Review Scope Plant operational aspects were assessed by observation of shift and other operating activities, discussions with operators and the operations staff, inspec-tion of plant operating and emergency procedures, review of operating records (including the last startup to low power operation), review of system status con-trols and logs, and chec'(s of valve line-ups and of the control of system configu-rations.

4.2 Operations Organization and Staffing Staffing of the Operations Division is ample (see Figure 4). A fu'l comple-ment for six shifts is maintained. Although one watch supervisor resigned during the inspection, he was replaced from the qualified staff surplus.

The licensee's current shift schedule assigns licensed senior reactor opera-tors (SR0s) to Watch Engineer (WE), Watch Supervisor (WS), and Nuclear Station Operator (NS0) positions.

Licensed reactor operators (R0s) are assigned to NSO or Equipment Operator (EO) positions.

E0s are assigned to E0 positions.

Radwaste Operators are assigned at the licensee's discretion.

Current assignments are de-picted below.

NSO NSO E0 Rad-WE WS (SRO)

(RO) (RO)

EO Waste (Condition 1, 2, 3)

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LILCo Assignment

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1 Crew A, C, D, E, F:

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Shif t Technical Advisors (STAS) were not assigned as watchstanders during this inspection.

TS 6.2.2 requires an STA on shift during Condition 1, 2, or 3.

The plant remained in Condition 4 (cold shutdown) during this inspection.

Four STAS are available for assignment to operating shifts.

Two reactor engineers are also l

STA qualified.

Based on facility management statements and interviews of operating l

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l shift personnel, the four assigned STAS train on the simulator with their assigned shift, and the other two shif ts are assi_gned a qualified STA for their simulator l

training period.

The licensee has recently hired two STA trainees. Qualifying the new hires.is expected to take six months.

The licensee committed that each

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operating shift would have a qualified STA with'whom they are consistently trained.

A basis for that commitment was the NRC concurrence, received during the ORAT in -

spection, that STA qualified reactor engineers could be assigned to shifts without their reactor engineer functions being impediments to their STA functions.

The ORAT concluded that routine core performance monitoring tasks complement and do not interfere with post-accident STA func + ns.

Shift advisors who are experienced BWR operators are required to be on shift'

in accordance with Attachment 2.to the existing facility license.

The licensee provided resumes of the six current technical advisors.

No inadequacies in their qualifications were identified. -Two of these advisors are relatively new; the

other four participated in previous operation at up to 5*4 power, Discussions with an onshift watch engineer showed that the operating staff considers the advice given by the advisors to be a valuable asset.

Further assessment of shift advisor staffing will be conducted incident to routine inspection of staffing during plant operation.

4.3 Staff Stability and Morale Discussions with Operations management and shift personnel noted a low per-sonnel turnover rate for licensed operators.

This has provided an operating staff that is very familiar with the plant (many participated in preoperational activi-ties), the procedures, and administrative and regulatory requirements. This was noted during interviews conducted with several operating shifts, and during a specific interview with one reactor operator (who also demonstrated a good working knowledge of the facility technical specifications).

STA staffing has been impacted by losses which have been acceptably compensated for, as indicated in Detail 4.2.

There has been a high turnover in the non-licensed plant equipment operator (EO) position.

LILCo compensated by increasing the number of personnel in the group.

EOs received particular ORAT attention to see whether there were adverse

effects from the turnover rate.

None were observed.

EOs interviewed were found I

to be familiar with plant layout and the location of equipment, and showed a good knowledge of system design and operation.

They were also found knowledgeable of procedures and administrative requirements.

Interviews and observations of operating activities showed that operator l

morale is good.

The operators expressed a strong desire to startup and operate I

the plant, and expressed confidence in their ability to do so safely.

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4.4 Operating Shift Professionalism Inspectors routinely observed Watch Engineers perform effectively a's the on-shift management representative, and in the oversight and control of shift activi-ties.

Effective use of the Watch Supervisor for oversight of shift functions and-the direction of reactor operators also was noted.

Shift business and control room written material were strictly controlled by shift personnel and limited to operating activities.

No extraneous written mate-rials or conversations were observed.

Shift management was. observed to control

.the numbers of personnel in the control room " operating" area, and to exclude workers from that area when not a part of the activities at. hand. -This was done especially well during a complex core spray system logic test on March 16.

The inspector observed good communication and coordination between operators during the inspection in general, and during diesel generator testing in particular.

A practice of repeating back operating directives was observed to be used effec-tively during some complex activities. Management encouragement of this practice is desirable, so as to develop it into a routine practice for all shifts.

Panel walkdowns were conducted with licensee personnel. Alarms identified were appropriately explained. Operator knowledge of systems' status was good.

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Overall, all operators in all onshift positions demonstrated high profession-alism in the conduct of activities and in control room protocol.

No inadequacies were identified;

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4.5 Operating and Emergency Operating Procedures Operating procedures were found to be well written, with necessary prerequi-sites and other guidance provided.

Selected tag-outs had been implemented as per procedure. No concerns were identified.

The inspection included a sampling review of onerating and emergency proce-dures.

Review included completed procedures for a previous plant startup to criti-cality, observation of procedure use by operating personnel, and checks of proce-dures in the control room and in the plant to assess whether the procedures work as written.

Plant drawings, flow diagrams, comparisons with physical plant con-figuration, inspector experience and industry standards were the inspection refer-ences.

The operating procedures listed below were reviewed.

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SP 22.001.01, Startup - Cold Shutdown To.20 Percent l

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SP 22.001.02, Reactor Criticality Procedure l

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SP 23.307.01, Diesel Generator 103 Prerequisite Checklist

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SP 29.015.01, Loss of Offsite Power Emergency Procedure

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SP 23.121.01, RHRS Stendby Status Checklist SP 23.307.01, TDI Emergency Diesel Generators

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SP 23.013.02, Loss of Secondary Containment

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SP 23.418.01, HVAC Reactor Building

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The operating procedures were'found to be prepared, approved and implemented L.

in accordance.with technical specification and administrative requirements. -The l

procedures were found to be technically adequate and of good quality.

Failure to periodically review some station procedures was, however, noted to be a minor

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l problem identified by the licensee (see. Detail 7.6).

Emergency operating procedures (EOPs) are prepared to Revision 4 of the Emergency Procedure Guidelines and are presented as flowcharts. The current revision was approved for station use in March 1988.

Classroom and simulator training was conducted on the procedures prior.to approval.

Since implementation of Revision 4, requalification training has placed emphasis on E0P training.

Routine resident inspector monitoring of simulator training and discussions.with operators have found the procedures to be adequate and generally well received.

This finding was confirmed during recent Operator Licensing examination inspections.

The licensee recently assessed the E0Ps.

That assessment evaluated tech-nical ace" m y, human factors elements, and operator implementation.

LILCo concluded that the E0Ps were technically adequate and that the operators would adequately implement the procedures. A number of findings and recommendations were also identified.

Most of these related to improvements or clarifications of procedural steps.

Several identified procedural steps which referenced plant indications that were not readily available to the operators in the control room. -The LILCo assessment also noted that, although the procedures were adequate, a long-term resource commitment was needed to ensure the E0P program would meet station expectations. ORAT review found the LILCo assessment report to be thorough.

LILCo is evaluating the assessment findings and plans to develop a schedule for implementation of the recommendations, Routine NRC inspection will address this aspect.

No unacceptable conditions werc identified during review of the operating or emergency operating procedures.

4,6 Post-Trip Review Process The licensee's post-trip review process includes Procedures SP-21.003.01 and SP-12.009.03, NRC Regulatory Guide 10.1, and NRC Regulatory Guide 1.16.

The post-trip report is the responsibility of the shift technical advisor (STA) in Operational Conditions 1, 2, and 3 and of the watch engineer in Conditions 4 and 5. Plant manager review of the post-trip report is required.

If the cause of the trip (scram) is not known or understood, a Review of Operations Committee (ROC) review is required prior to start-up.

Licensee compliance engineering completes a deportability evaluation to the NRC per SP-1?.009.03.

The inspector reviewed the post-trip reports for scrams on September 7, 1988 and March 18, 1987.

The licensee's evaluations were documented well and the causes of the trips were understood.

In both cases, the trips resulted in no control rod motion because the rods were already fully inserted.

No post-trip review inadequacies were identified, i

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4.7 Procedure Adherence Multiple 0 RAT: inspector' observations'found literal compliance with the operat-ing procedures in use.

(See Detail 6.6 for Surveillance Procedure adherence dis-crepancies.)

4.8 Verification of System Line-Ups The ORAT inspection checked that plant systems.were lined up as needed to-support plant conditions.

This is also routinely reviewed by the resident inspec-tor and was recently found acceptable during Inspection 89-01. The ORAT review included Engineered Safety Feature (ESF) walkdowns in the control room and in the plant to verify alignment per the latest checkoff lists (COLs) on file.

Inspection

~89-01 had covered the rtandby liquid control system, reactor building standby ventilation system, and the hydraulic control units and scram ' discharge volumes of the control rod drive system.

The ORAT inspection included the residual heat removal system, emergency diesel generator EDG-103 and alternate power supplies for Electrical Bus -103, and the 125 VDC electrical distribution system. Also, ORAT members made sampling checks of metal-clad switchgear, motor c_ontrol centers, and electrical distribution boxes ir, the reactor and control buildings. Breaker posi-tions either supported safety system operation or the breaker involved was appro-priately tagged.

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Current COLs were used to verify valve and electrical breaker lineups.

The Review compared COLs with. flow diagrams and the physical plant configuration, with the following results.

Residual Heat Removal (0.HR) System A walkdown was performed with the Equipment Operator (EO) for the RHR "A" and

"C" train valve lineups (an entire RHR walkdown was not performed). The February 18, 1989 COL for the RHR system was used. All valves on the COL had been double-verified.by the'11censee staff.

No discrepancies from the completed COL were found by the inspector. All valves that required locking devices had their locks in place and in good shape.

The inspector observed that the E0 checked all valves using a " hands-on" approach. At no time did the E0 rely solely on visual verifi-cation. Valve IE11*04V-3002A, the RHR Pump "A" suction strainer drain stop check, was found to be missing its red identification (ID) tag.

Valve IE11-01V-3100A,.

the PCV-007A drain, had a loose handle (the hold-down nut was tightened when found).

Some ID tags were difficult to read due to paint which partially covered the tag-descriptions. The E0 properly identified such components, however.

In following-up an RHR tagout (89-02-060) on the system cross-tie header shutoff valve, (E11-F010, #1128 MOV050), all was found to be in accordance with procedure. The hand switch in the control room had been labeled as "thermals re-moved." This valve is required to be kept shut except in certain emergency con-

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l ditions. With the hand switch thermals removed, valve manipulation cannot occur but valve position indication is still provided.

The Watch Engineer confirmed that a tag on the hand switch was unnecessary and that the operators fully understood

the status of the valve.

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The E0 brought the applicable Piping and Instrumentation diagram (P&ID)

with him on the tour for occasional verification and reference.

He exhibited good knowledge of the system.

No inadequacies were noted in RHR line-up or in E0 knowledge.

Emergency Diesel-Generator EDG-103 No inadequacies were identified regarding Emergency Diesel-Generator EDG-103 standby readiness or the availability of fuel, starting air, and cooling.

Labeling of system components was generally very good.

The inspector identified three valves in the fuel oil transfer system (IR43*02V-226C, 202C and 225C) that were properly positioned but not labeled. A plant equipment operator initiated action to replace the missing identification (ID) tags.

The ORAT inspection validated the adequacy of the licensef's program to establish and control systems needed to support reactor startup and operation.

Housekeeping and material conditions were assessed as very good except for the few ID stickers that have fallen off or degraded and the paint on some ID tags.

In no case was operator performance found to be impeded as a consequence.

Licensee actions to n'aintain tagging adequacy were acceptable.

l 4.9 Response to Annunciators and Offnormal Conditions Multiple ORAT checks found operator attention to and response to plant conditions and alarms to be very good.

There was good communication and coordination between operators on shift to assist in responding to alarms on different panels. For example, inspector observations of an operator performing a diesel generator surveillance test on March 16 noted prompt and accurate response to alarms, and a good knowledge of the alarm response procedure and required follow-up actions.

4.10 Nuisance Alarm / Indication Program Licensee tracking of control room alarms and nuisance alarms was l

previously conducted monthly.

Since the licensee's self-assessment, alarms have been manually tracked weekly. The licensee stated that the plant is designed to have no alarms at 100fs power and that simulator operation at 100?;

power shows no alarms.

While shut down in May 1987 the licensee evaluated control room alarms, noting 103 pre-critical alarms and 59 rated pressure / temperature alarms, with 15 alarms due to equipment malfunction. On March 15, 1989 the licensee listed 150 control room alarms, of which 18 were due to out-of-service annunciators.

l The licensee addresses nuisance alarms and malfunctioning indications by

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having control room operators generate maintenance work requests (MWRs) for such conditions.

Three or more such MWRs per year are tracked by the

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Maintenance Department, with the goal being to identify system and/or l

maintenance upgrades.

The Engineering Department develops design changes as appropriate. An example of the effort to reduce unnecessary alarms is an in process design change request which removes control room radwaste alarms

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1 which are reduodant to radwaste control room' alarms,.' based on there being an onshift radwaste operator.

The licensee's goal is less than 18 control room instruments and less than 14 control room annunciators out-of-service (005).

In 1988, the licensee achieved about 23 instruments and about 14 annunciators 00S.

These 00S indicators and annunciators were evaluated as not causing any inability to properly operate the plant.

ORAT review concluded, however, that the timeliness of correction of nuisance /feulty control room alarms and indications.

i merits further NRC follow-up.

That follow-up will be. conducted during routine inspection during plant operation.

4.'11 Shift Routine and Turnover Observations of shift turnovers were completed by various team members, and covered activities by various shif ts during daytime and backshif ts throughout the inspection period.

Shift turnovers were noted to be well orchestrated and complete.

Individuals spoke one-on-one with their counterparts and briefed the oncoming person as to changes in status, upcoming and performed evolutions, etc. Once these updates were completed, the oncoming WE (Watch Engineer) gathered all personnel (including radwaste, chemistry, I&C (Instrument & Control), fire brigade, health physics, and shif t clerk personnel) for an overall brief in which the WE gave detailed guidance for the shift activities.

The WE also made sure that, prior to an evolution, all players knew their responsibilities and set up required communicate-ons.

The plant was in the cold shutdown mode (Condition 4) during the inspection.

No startup or heatup evolutions were in progress. Activities in progress were found satisfactory.

Routine shift activities for releasing systems for work and for the completion of surveillance were observed and found to be accomplished in accordance with administrative requirements.

Operator performance and control manipulations observed during surveillance testing were very. good and demonstrated detailed knowledge of

,

system configuration, operating controls and expected plant responses.

In

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particular, operators performed exceptionally well during a 24-hour run of EDG-101 during the swing shift on March 15.

This test requires diesel loading to be held within the narrow band from 3200 to 3300 KW while the diesel is

!

operating in parallel with the normal station service transformer.

Doing so demands continual operator attention to the controls.

This was done exceptionally well. Also, there was good turnover by the operators, and good use of computer displays for the evolution. Adherence to procedural requirements was noted.

i 4.12 System Status Controls and Logs Plant system operational and startup readiness status was checked by detailed inspector walkdown of the main control board and review of operating logs and equipment status controls (tags, jumpers, etc.).

The ORAT inspection supplemented the reviews completed in inspection 89-01, which covered licensee controls of equipment clearances, jumpers and lifted leads, technical f

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specification LC0 (Limiting Condition for Operation) tracking, and locked valve controls.

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Plant system tagging controls'were verified to be adequate through a-review of equipment clearances 89-3-138 (electrical breaker) and 89-2-60 (valve position). The review included.a verification of proper placement of tags and j

proper positioning of the affected component. Also, control of jumpers and

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tags was discussed with operators. Reference documents. include startup procedures SP 22.001.01 and 22.001.02.

No inadequacies were identified in tagging, operator knowledge of tagging and jumper controls, or the associated i

procedures.

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The Watch Engineer's log was neatly kept and contained an accurate dncription of shift activities.

4.13 Operations Training The inspector reviewed the licensee's training programs and records for licensed operators.

Requalification training was found adequate to support licensing and the Power Ascension Test Program (PATP).

The Office of Training is located offsite in a newly constructed facility specifically designed for training.

Shoreham's nuclear training programs received full accreditation from the Institute of Nuclear Power Operations-(INPO) in September 1988, with licensed and non-licensed operator training programs being accredited in March 1988. A full scope, site specific simulator has been operational since September 1987.

The licensee plans to certify the simulator after the vendor's warranty period expires in early 1990.

The ORAT reviewed the staffing levels and experience for the licensed operator training section (see Figure 3). The full complement of instructors in this section is seven; there are five instructors assigned.

Four of these instructors' maintain licenses on the Shoreham facility and the fifth was previously licensed on two operating BWRs. Two of the instructors were on

" loan" from the Operations department as part of an ongoing rotational program.

These instructors were rotated from Watch Engineer positions at the plant.

This rotational program adds credibility and site specific experience and knowledge to the training staff. Additionally, the section supervisor and l

division manager maintain SR0 licenses and are experienced on the Shoreham

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facility.

There are no replacement license classes or license upgrade classes currently in progress or scheduled for the near future. A surplus of plant operators exists (see Detail 4.2).

The ORAT found the training staff size to be adequate to support the ongoing licensed operator requalification program.

The inspector reviewed the training records for the previous three years of requalification training.

No inadequacies were noted. Attendance at classroom and simulator training sessions has been mandatory since March 1987.

All licensed operators attended all required lessons during the 1988 cycle.

The inspector reviewed the classroom and simulator lesson plans for the 1988/89 requalification training cycles.

Several lesson plans were reviewed in detail.

The scope and detail of the training program, as evidenced by these lesson L____

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plans, was found to be adequate. A yearly training cycle encompasses six total weeks, and the time is equally divided between classroom and simulator training.

Typically, classes spend mornings in the classroom and afternoons in the simulator to better integrate classroom and simulator training. Most of the operators spent approximately 80 to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> in the simulator during the 1988 cycle. This is expected to increase as simulator reliability increases.

The inspector reviewed the annual requalification examinations and found them to be adequate in scope and level of difficulty.

Two operators failed

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requalification examinations in 1988 and received appropriate remedial training.

One, a staff operator, has since passed a re-examination. The other, a shift operator, has been taken off shift until requalification has

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been successfully completed.

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The inspector noted that the first two requalification training weeks of the 1989 cycle were devoted to PATP (power ascension test program) training.

This included classroom instruction and simulator performance of major test procedures.

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In plant observations of and discussions with various WEs, WSs, R0s, and E0s produced the conclusion that the individuals were knowledgeable and worked well together.

Overall, the licensed operator training facilities and programs were found to be adequate to support the licensee's near-term operational plans. The training staff will need to be increased to better support replacement license classes, but this should not impact operational readiness for an extended period.

4.14 Housekeeping and Material Control The condition of safety-related equipment was examined during tours of the main control room,. relay room, emergency switchgear rooms, battery rooms, and Transamerica-DeLaval, Inc. (TDI) emergency diesel generator rooms. The replacement (Colt) emergency diesel generators and safety-related switchgear and motor control centers were inspected. All levels of the reactor building and equipment enclosures were inspected along with parts of the turbine building, radioactive waste areas, and intake structure. All areas in the Containment Drywell were inspected, except for the inaccessible space under the reactor vessel and the area enclosed by the *eactor vessel closure head insulation package.

The plant and its equipment were generally clean and free of material which would impact operation of safety equipment. The Containment Drywell was very clean, with no fluid leaks and no equipment discrepancies.

Equipment care was evident in good cleanliness and preservation. Timely corrective actions for licensee-identified discrepancies were evidenced by the dates on equipment deficiency tags observed during plant tours.

In general, there are good provisions for securing heavy movable equipment (e.g., heavy equipment carts

are bolted to large brackets at storage locations).

Loose heavy equipment was

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noted in several spaces, however. For example, spare breakers were loose behind the metal-clad switchgear enclosures in the safety-related switchgear rooms, and there was a loose cart-mounted heavy shielded container next to the

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traversing in-core probe operating mechanisms. These conditions had been noted to the licensee before.

No analysis of the associated seismic hazard was available.

The loose switchgear was removed, but reinspection found the loose heavy shielded container to be uncorrected.

The securing of heavy equipment will receive ongoing review during routine inspection.

After noting the loose movable equipment, NRC review noted that loose heavy equipment also had been identified by the licensee on March 11-12, 1989 and was documented in licensee quality control report 89-051.

That report was assessed as a comprehensive and detailed examination of plant material conditions.

The minor problems noted with equipment ID tags did not adversely affect component or system operability and corrective actions were promptly initiated in accordance with licensee procedures.

Except for the repetitive problem with securing heavy movable equipment when not in use, facility housekeeping was rated very good.

4.15 Event Reporting Review of the licensee's program to report events to the NRC review encom-passed interviews with compliance engineering personnel, two completed reports of abnormal conditions (RACs), and procedures SP 12.006.01, SP 12.040.01, SP 12.009.02, SP 12.009.07, and SP 12.009.03.

The licensee identifies items reportable to the NRC through RACs. RAC objectives are to review e. -ts of potential safety consequence, to assure immediate notification of NRC as needed, to otherwise determine deportability, to assure c; ective action and root cause determinations, and to document these matters for approval by the Review of Operations Committee (ROC),

Inspector review of the two most recent RACs,88-022 and 89-001, found adherence to procedures, good in-depth evaluation of root causes, appropriate l

event classifications, and thorough ROC review.

LILCo's program for evaluating defects and failures in basic components and producing associated 10 CFR 21 reports was inspected. The Nuclear Operations Support Department (NOSD) is responsible for preparing 10 CFR 21 reports.

Evaluation leading to a 10 CFR 21 report begins with a LILCo Deficiency Report (LDR).

Dispositioning of the LDR includes a deportability determination.

Licensee Event Reports (LERs) are routinely evaluated by the resident inspector.

Periodic review is conducted by the NRC Office for Analysis and Evaluation of Operational Data, with the latest such review being dated November 15, 1988. That review, which was consistent with the resident inspector's findings, concluded that LERs adequately described events, associated failures, and actions to prevent recurrence.

The LERs were assessed as thorough, detailed, fairly well written, and easy to understand.

Root causes were noted to be identified.

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The ORAT review concluded that the licensee's event reporting program is well-defined and properly implemented.

4.16 Communications with Other Departments Observation of licensee activities and meetings during the ORAT inspection noted participation by all cognizant departments and appropriate communications-with the Operations Department.

4.17 Open Items The only Operations open item for the first operating cycle is the assurance that STAS are trained with their respective shifts for all six' shifts (see Detail 4.2).

Numbers of qualified watchstanders will be routinely reinspected.

To assure that the Training staff is adequate for long-term training needs, Training Department staffing will be re-examined before the end of the first operating cycle.

4.18 Plant Operations Conclusions The plant operating staff is fully ready to operate the plant safely, with assurance of STA and other watchstander familiarity with each other being appropriate to assure effective interaction.

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5.0 MAINTENANCE 5.1 Maintenance Review Scope Inspectors witnessed maintenance and discussed maintenance related activities and controls with maintenance supervision, technicians, and I

craftsmen.

Program documents were reviewed. Maintenance staffing and management involvement were assessed.

5.2 Maintenance Management and Organization Station Procedure, SP 31.010.01, " Maintenance Program Description,"

describes the administrative and work control requirements used to govern and document maintenance of safety-related equipment, systems, and structures. The Maintenance and Instrument and Control (I&C) Sections are under the Maintenance Division Manager. Maintenance section work includes activities performed on both mechanical and electrical components.

Instrument and Control work is carried out under SP 41.014.01, Instrument and Control Program.

The Maintenance Manager is supported by the maintenance, I&C, computer engineering, and contract maintenance sections (see Figure 8). ORAT review of the licensee's organization concluded that manpower resources are adequate.

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5.3 Maintenance Staff Stability and Morale The CRAT assessed maintenance staffing by reviewing organization charts and interviewing station management and maintenance personnel. Absenteeism records were also reviewed.

L Maintenance Section turnover has been low over the past year. The Instrument i

and Control (I&C) Section has experienced more turnover: three of six I&C engineer-ing positions and eight of 36 I&C Technician positions are filled by contractors.

Maintenance staff absenteeism was found to be very low (about a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> average)

for the past year. No individuals with high absenteeism were identified.

Person-nel generally displayed a positive attitude. When interviewed, a few individuals expressed dissatisfaction with local tax increases and living costs, but no cor-relation to station work performance was evident.

Maintenance staff morale was assessed as adequate.

5.4 Maintenance Work Observation The inspectors observed work under Maintenance Work Request (MWR) 89-1160 for Core Spray Valve IE21*MOV-33B, which failed during a surveillance test on March

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16, 1989.

Problems identified on the MWR included (1) breaker would not reset and

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(2) breaker flashed when closed.

The maintenance work package was found acceptable.

It contained all required procedures.

Equipment clearance permit 89-3-163 was in the work package and identified the equipment, components, and systems tagged out-of-service. The inspector verified the tagging and observed the troubleshooting of IR24*MCC-1123 breaker 2AD. The foreman was present during the entire activity.

Troubleshooting consisted of visually inspecting the breaker's thermal overloads

and contacts, and insulation resistance-(meqger) testing from the breaker to the

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valve. Megger readings indicated two of tne three phases were open. All contacts and thermal overloads looked good. After troubleshooting at the breaker was in-determinate, checks at the valve found that its motor had failed (two open phases).

Replacement was initiated.

Inspector review of the maintenance history found that preventive maintenance was conducted on the valve on October 24, 1988.

There were few corrective MWRs on the valve.

Its motor had been replaced with a larger one in 1983, per Con-struction Repair / Rework No. E21-221, to decrease valve cycling time. No failure precursors were found.

The ORAT concluded that this core spray maintenance work was conducted per plant procedures and was acceptable.

Previous to the ORAT inspection, the inspector had observed the replacement of a failed Shoreham in-core flux monitor Intermediate Range Monitor (IRM) detector assembly by Instrument and Control (I&C) technicians on January 17, 1989. That work required the support of operations, health physics, and quality control.

Interdepartmental interfaces and the work package were also found acceptable for this case.

Supervision was present during the entire replacement process.

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1 While observing the in process use of SP 35.703,01, the.NRC inspector noted the presence of two different-approved revisions of Vendor Technical Manual GEK 13962 during IRM replacement. The installation work by the I

technicians was being conducted to Revision J; management oversight by thel foreman was conducted to revision G.

This issue was noted on LILCo Deficiency Report (LDR)89-020. There was no impact on IRM replacement, and all work was performed and inspected to the latest revision.

LDR 89-020 was reviewed by the Nuclecr Operations Support Department and the Nuclear Engineering-Department (NED).

LDR disposition requires review of vendor manuals to determine whether revisions.are appropriately controlled.

NED is to review vendor manual revisions for applicability and update the Records Management system as required.. The ORAT also noted that vendor manual instructions for performing work may not embody all the qualities of~an acceptable nuclear procedure.

LILCo agreed that station procedures are a better means of controlling maintenance, and stated that their intent is to provide procedures which stand on their own.

NRC follow-up on use of the correct vendor manual revisions and licensee performance in control of maintenance will be accomplished during routine inspections.

The ORAT concluded that observed maintenance was acceptable.

5.5 Preventive Maintenance The inspectors reviewed Station Procedure SP 12.015.01, " Preventative Maintenance Program," and interviewed personnel involved with the implementation of the preventive maintenance (PM) program.

Program implementation is the responsibility of the Maintenance Manager.

The PM program is normally implemented using Scheduled Activity Worksheets (SAWS) issued for each PM.

If job complexity dictates a more comprehensive work planning document, a Maintenance Work Request is used.

PMs are tracked on the following PM reports: Planning Schedule Report; Working Schedule Report; On-Demand Schedule Report; Completion Report; and Inactive Activity Report.

A PM may be deferred, with the permission of the responsible Section Head, until the next normally scheduled date.

(PMs which are TS surveillance are also tracked as surveillance to assure that equipment operability is maintained.) PM completions are documented by processing the associated SAWS or MWRs and updating PM records.

Some SAWS were being deferred, but none were found to exceed the permitted grace period.

The inspectors selected several safety-related components, such as motor-operated valves, to assess PM program effectiveness, Also, the inspectors checked Agastat relays and ASCO solenoid valves for inclusion in the PM program. No PM inadequacies were identified for motor-operated valves and ASCO solenoids. Of 380 Agastat Type GP relays installed at Shoreham, 276 were replaced in February 1989, af ter relay failures (Inspection Report 50-322/89-01, Detail 2.3, Unresolved Item 89-01-02 refers).

The inspectors reviewed the following maintenance work request packages to verify that the Agastat relays were replaced as required: MWR 89-0622,

. MWR 89-0617, and MdR 89-0621.

No discrepancies were identified.

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The licensee was in the process of adding th'e Agastat GP relays to the PM i

program during this inspection. Based on a determination during plant construction, the Agastat GP relays were to'have been replaced prior to

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i completing the first refueling outage.

Delay in facility licensing resulted in energized Agastat GP relays exceeding their vendor-identified service life before the beginning of the first operating cycle. The licensee.was asked to identify the assurance that facility delay had not resulted in other components exceeding their expected service life as well.

The Acting Nuclear Engineering Department Manager identified LILCo's Agastat relay problem response as being twofold: examination of other first refueling outage commitments and checks for other relays which might have reached their projected service life.

LILCo concluded that no other first refueling outage activities had substituted such a plant activity milestone for a time milestone.

Based on review of NRC information notices and INP0 Nuclear Power Plant Reliability Data System references, no similar vulnerabilities were identified by LILCo for other relays. The ORAT concluded that Agastat relay replacement and these evaluations were adequate to address the safety implications of the Agastat relay problem.

The inspectors'noted that procedures do not specifically identify who is responsible for evaluating equipment performance.to assess PM adequacy and recommend changes.

No associated PM inadequacies were identified, and this item was identified to the licensee as an area for improvement. The licensee assigned this matter to the Systems Engineer for incorporation in a procedure.

.Further NRC assessment will be incorporated in routine inspections.

Overall, the PM program was found to be acceptable.

5.6 Predictive Maintenance Several predictive maintenance activities are performed at Shoreham.

Station Procedure.SP 12.050.01, "Shoreham Nuclear Power Station Plant Performance Monitoring Program," establishes the program and analytical methods for monitoring and trending parameters that could affect unit heat rate, unit availability, or the unit capacity factor.

The Reactor Engineer / Performance Group is responsible for implementation of the Plant Performance Monitoring

'1 Program.

Routine reports to management sunmarize program results and overall plant performance.

j Vibration monitoring and oil wear analyses are used to warn of potential equipment problems.

Vibration data are acquired by permanent and/or portable equipment.

Some vibration measurements can be read in the main control room on panel H11-PNL-VM.

The panel has an analog display, and warning and danger alarms.

It monitors the high pressure coolant injection pump, reactor core isolation cooling pump, reactor building service water pump, reactor recirculation pumps, reactor recirculation motor generator sets, reactor feed i

pumps, condensate pumps, condensate booster pumps, reactor water cleanup pumps, main chillers, and the turbine building closed loop cooling water system pumps.

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i Predictive trending recently identified a problem with Condensate Pump "B" motor IN21-181 MOT-007B.

011 samples taken from the upper and lower bearings on December 20, 1988 and again on January 4,1988 indicated a potential problem.

Vibration measurements were taken and also indicated a potential problem. MWR 89-0456 was initiated on January 23, 1989 to inspect the upper and lower bearings for wear and rebuild as necessary per prediction report recommendations on January 16, 1989. The pump motor was sent to General Electric where it was overhauled, including bearing replacement.

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Based on program nature and results, the licensee was found to have estab-lished a state-of-the-art predictive maintenance program for rotating equipment.

In this aspect, the licensee is considered an industry leader.

5.7 Post-Maintenance Testing Control and documentation of post-maintenance testing are performed using various station procedures.

To better assure that components and systems are fully returned to operable status following maintenance, a new administrative procedure (SP 12.013.03) has been developed but has not yet been issued.

The proposed new procedure was assessed as an improvement over the previous method: it formally and uniformly addresses the manner in which systems and components will be tested, depending on the extent of maintenance.

No post-maintenance testing inadequacies were found during the ORAT inspection.

Post-maintenance testing was therefore rated as acceptable, with an improvement initiative in progress.

5.8 Activity Verification The QA/QC organization has about 65 licensee and contractor personnel (see Figure 2).

No QA/QC staffing inadequacies related to Maintenance were noted.

Interviews with various QA/QC personnel found them to be technically qualified, with sound experience in the particular areas they were auditing.

i Several individuals in the QA organization had previously worked in the Maintenance Division or Nuclear Engineering Department at Shoreham, QA/QC was found active in identifying maintenance weaknesses and problems.

Corrective Action Request (CAR) 88-04 was issued on December 8, 1988 due to several deficiency reports and Priority 1 preventive maintenance activities surpassing scheduled due dates without being extended or deferred as required.

(No equipment inoperability resulted.) CAR 88-05 was issued on December 28, 1988 for improper work practices (bending leak-off piping in order to torque i

nuts, improper use of a weld procedure, not issuing a deficiency report, etc.)

l and incorrect material utilization (ASTM bolting in ASME applications, and unqualified components in safety-related pumps and chillers).

In addition to assuring correction of the individual problems, maintenance management considered CARS 88-J4 and 88-05 to indicate an adverse quality trend in maintenance, and initicted investigation into the probable causes and necessary corrective action. One result was that a spare parts analysis group has been developed to improve material control (see Detail 5.12, 1st Paragraph).

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Overall, CARS, recent QA/QC audits, and surveillance deficiency reports showed that quality oversight of maintenance is technically sound and performance oriented. : The ORAT inspection rated the independent verification function performed by the licensee to be highly effective, and among the best inspected.

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5.9 Work Planning and Prioritization

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. The Work Planning and Scheduling Section of the Outage / Modification Division (see Figure 11), develops long-term work plans and implementing schedules for plant maintenance.

Responsibilities, authority, and lines of i

communication for work planning and work re; Jest preparation were found to be

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L clearly defined and documented in plant Administrative Procedure SP.12.013.01, Maintenance Work Requests (MWRs).

The Lead Work Planner (Day Watch Engineer, an SRO) is responsible for the day-to-day. scheduling and p)anning of maintenance.

New MWRs are reviewed by

the Lead Work Planner for Limiting Conditions for Operation (LCOs) and assignment of priority (1 through 5).

Priority 1 and 2 MWRs require attention

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-within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by the Work Planning / Scheduling section.

A daily work plan development meeting is held with the cognizant foreman, work planning coordinator, and maintenance engineer to evaluate, in detail, the upcoming work day schedule.

Status of priority work is discussed at this meeting. The inspectors observed a meeting and found it to be a useful management tool'.

The meeting addressed completed and deferred maintenance, and material and spare parts problems.

Inspectors also observed the Wednesday weekly work schedule meeting on March 15, 1989.

These meetings are for discussing and planning the next week's maintenance.

Discussion topics included priorities and LCOs involving departmental interfaces. The meeting was assessed as well organized and professionally conducted.

Based on a review of station procedures, attendance at meetings and discussions with the Work Planning and Scheduling personnel, the inspectors concluded that adequate controls exist to properly implement maintenance planning and scheduling.

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Open Maintenance Work Requests (MWRs) as of March 13, 1989 totalled 1589.

This was a 35% decrease from the 2450 MWRs. recorded on June 2, 1988.

The licensee's goal is to reduce the backlog to 1000 MWRs in 1989.

The MWR backlog includes modification MWRs such as those for tie-in of the Colt diesels to plant systems. Discounting.such deferred modifications and other MWRs which represent work for the first refueling outage reduces the

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l maintenance backlog to 1138 MWRs.

Discussions with the licensee showed that

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the 1138 number breaks down as follows:

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ISCHEDULE0lFOR WORKl DONE ITESTEDI l Priority 1.

Threatens life or limb;_ or willl l

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l l result in load reduction or shutdown; or a l

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l 20 l lTS violation while shut down; or impacting l l

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l l critical path.

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Priority 2.

.LCO precludes mode change; or l l

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l action needed to prevent load reduction; or l

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-l la violation.

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l IPriority 3.

Operational significance, but l l

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l lno effect on power output or shutdown, and l 308 l

123 l

l 95 l Ino safety deficiency.

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l l Priority 4.

Not significant to plant l

323 l

82 l

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l loperation.

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l Priority 5.

Unit outage required to l

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.Lcomplete the work.

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l 0 1 0 l l SUBTOTAL i

656 l

215 l

l 221

IT0TAL:

1138 I

I Other trends reviewed and discussed with the licensee include:

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Corrective MWRs greater than three' months old continue to decrease and are below the licensee goal of 50%.

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The ratio of corrective to preventive maintenance is about 10%.

3.

50 MWRs associated with modifications are in the return to service cycle.

I A review of the return to service trend, dated March 16, 1989, indicated

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that the licensee continues to expedite the final review and closecut of MWRs.

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The licensee committed that, prior to start-up, they would justify deferment of all Priority 5 MWRs, complete all Priority 1 & 2 MWRs (which is normal practice), and show that no priority 3 or 4 MWRs are misclassified.

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5.10 Rework Identification / Control Interviews and review of station procedures were used to assess the program for addressing repetitive corrective maintenance.

No specific procedural controls were identified. The licensee stated that they are developing a formal program for identifying repetitive maintenance and

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recurring equipment problems. Notwithstanding the lack of a formal program, the licensee recently reviewed completed MWRs for certain components requiring repeat corrective maintenance three or more times since January of 1988.

Results of this review were analyzed by the Maintenance Section and then forwarded to the System Engineering Section for follow-up.

Inspector review of the items forwarded to the System Engineering Section found that a total of 11 components had three or more occurrences on the same l

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component. The NRC questioned whether such problems indicate likely unnecessary' impact on operation and/or challenges to safety systems.

LILCo committed to assess, before startup, the safety impact of corrective maintenance items numbering three or more times per year.

5.11 Parts'and Material Control Effectiveness of control of material, parts, and components was assessed through activity observation, a tour of the main warehouse and storeroom, personnel interviews, and MWR and procedure reviews.

LILCo had previously.

identified material control problems involving ASME Class 2 bolting material utilized in Class I bolting applications, and commercial grade items and consumables being installed without first receiving a proper dedication evaluation. ~The bolting issue is addressed in Detail 11 of this report. To resolve the commercial grade problem,- the licensee developed an 11 person spare parts analysis group in the Nuclear Engineering Department (NED) to assist in the dedication review process prior to the procurement of any parts, materials, and components. All requisitions, not just safety-related ones, are now submitted to NED for review.

Further, all items from the Material & Stores (M&S) catalog are submitted to NED for technical review before the items are installed in the plant.

The ORAT inspector's review of work in progress on the IRM replacement found the necessary Stores Issue Forms in the work package and the material being installed to be satisfactorily controlled.

A review of the licensee's Successful Issue Program for material found that the requisitioned material has been available about 90*; of the time since January 1988. To enhance the material issue process, the licensee recently added a representative from the warehouse to their Work Planning and Scheduling group.

The ORAT review noted that, of the 83 MWRs on hold for procurement, 22 require parts purchase and 61 have parts on order. One Priority 1 and two Priority 2 MWRs are awaiting material.

The Priority 1 MWR is for replacement of a leaking carbon dioxide isolation valve. A replacement valve was shipped on March 21, 1989 per P.O. 396085. This is an industrial safety issue, not a nuclear one, and the licensee is pursuing correction.

The two Priority (2)

MWRs are associated with gaskets for motor-operated valves IT48*MOV-031B and IT48*MOV-328. These valves are in the Primary Containment Atmosphere Control system. The gaskets were shipped on March 22, 1989 per P.O. 395950. The licensee is tracking these MWRs for completion prior to operation.

An inspection of the warehouse facilities and. administrative processes for receipt and storage of materials was conducted. Several safety-related items were selected at random from the storage areas and documentation of receipt inspection 'and shelf life, if applicable, were reviewed for completeness. All items were found to be stored properly and in compliance with station procedure SP 12.019.03, " Storage of Spare Parts, Materials and Components." No outdated stores were identified. The licensee controls shelf life by using a computer

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program that automatically produces Scheduled Activities Work Sheets which identify end-of-life items for discarding.

During a tour of.the main warehouse the inspectors noted that the facility was adequately being maintained as a Level 8 and C storage area. ' Housekeeping was adequate, but certain shelving areas were nearly full and might contribute to erroneous issue due to overflow.

This was referred to the licensee for consideration.. Based on inspector experience.at operating plants, the licensee's spare parts invento'ry was adequate.

The ORAT-concluded that the control of material, parts, and components was satisfactory and in compliance with NRC requirements.

5.12 Maintenance Training The maintenance training program was accredited by INP0 in September 1988.

The INPO accreditation was based on Station Procedures SP 31.001.01 " Training and Qualification of Maintenance Personnel," and SP 41.011.01, "I&C Technician Qualification Program."

.The Maintenance Engineer and I&C Engineer are responsible for ensuring that personnel assigned to their sections receive proper training and are qualified for the tasks they are to perform.

For certain job tasks, the licensee has developed a program where the individual worker performing the-task is observed by a foreman and then certified by either the Maintenance or I&C Engineer.

Inspector review of the training records for five maintenance personnel showed.that each received general employee training, quality assurance indoctrination, health physics training, and applicable discipline indoctrination training.

Refresher training in these areas was also conducted regularly.

The inspectors reviewed the computer training matrix for each of the maintenance activities observed.

In each case, it was found that the individuals performing the work were qualified for the task.

Maintenance training was evaluated as good.

5.13 Management Support of Maintenance Management commitment to high quality maintenance at Shoreham was evident in the support of activities such as the plant performance monitoring program, pump vibration and oil monitoring programs, monthly MWR trend reports, monthly station performance reports, and the self-assessment conducted in 1988.

Management involvement was also shown on January 19, 1989 when the Vice-President-Nuclear Operations conducted a special meeting with Maintenance and

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QA/QC to gain a better understanding of the maintenance deficiencies denoted in CAR 88-05.

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The Shoreham Safety Engineering and Reliability Section initiated a Reliability Centered Maintenance (RCM) pilot program in November 1988. This pilot program incorporates reliability / availability computer modeling techniques.

The major difference between RCM and traditional preventive maintenance (PM) is that traditional PM addresses failures at the component level without considering failure effects at the system and unit levels.

Doing so discounts reliability features such as component redundancy, ability to isolate, etc.

The RCM methodology being evaluated at Shoreham is a systematic, step-by-step process which analyzes the effects of component failures on plant safety and availability.

The desired result is a set of PM tasks which focus maintenance resuJrces on the components most important to plant safety and availability, with a strong bias towards using state-of-the-art condition monitoring techniques. An RCM pilot program is currently in progress for the Reactor Building Closed Loop Cooling Water (RBCLCW) System.

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The ORAT assessed the LILCo RCM initiative as a positive indicator of management and staff efforts to improve the safety effectiveness of preventive maintenance. Overall, strong management support of maintenance was found.

5.14 Open Items Acceptable safety resolution of Unresolved Item 89-01-02, involving components exceeding their service life (Detail 5.6), was achieved during this inspection.

The unresolved item remains open pending routine review of enforcement considerations.

5.15 Maintenance Conclusions Maintenance is ready to support operation.

6.0 SURVEILLANCE 6,1 Review Scope The technical specification operational surveillance program is defined by procedures SP 12.016.01, Surveillance Program, SP 22.008.01, Operational Surve111ances, and Master Surveillance Schedule Checklists.

Inspection of this area included observation of testing in progress, program organization and controls, staffing, training and qualification of test personnel, procedure adequacy, management and supervisory oversight and controls, and identification and correction of test discrepancies.

ORAT findings and conclusions are summarized below.

6.2 Surveillance Organization and Staffing The Maintenance Division (see Figure 8) contains an Instrument and Control (I&C) Department.

The department's responsibilities include preventive maintenance, corrective maintenance, surveillance, and measuring and test equipment (M&TE).

The inspector noted a high turnover of I&C Engineers.

In November 1988, a licensee self-assessment audit reported three-out-of-four

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engineers.were contractors.

In March 1989,.two contractor engineers were replaced with permanent employees. The current I&C engineers were found knowledgeable of their duties and responsibilities.

Surveillance staffing was assessed as adequate, l

6.3 Staff Stability and Morale Discussions with Instrument and Controls management, engineers, foremen, and technicians identified a high turnover rate in the engineering support area. Two permanent engineers have, however, been added in the past five months. The licensee's self-assessment of the I&C section in November 1988 concluded the turnover had minimal effect, and noted that station management was monitoring personnel resources.

Observation of surveillance and discussions with technicians showed worker confidence in their ability to complete assigned activities.

The attitudes of the individuals contacted were positive.

ORAT inspection assessed.the staff stability and morale of the surveillance group as. adequate to support power operation.

6.4 Observation of Surveillance Tests witnessed included the following.

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SP 24.307.02, Emergency Diesel-Generator Testing, on 3/15/89.

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SP 24.203.04, Core Spray Logic Test, on 3/16/89.

SP 44.201.03, Accumulator Nitrogen Low Pressure Calibration and Func-

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tional Test, on 3/21/89.

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SP 44.202.31, Suppression Pool Low Level Functional Test, on 3/21/89.

EDG-101 was surveilled on 3/15/89 per SP 23.307.01, Appendix 12.8, for operational readings, and per SP 24.307.02 for the overall conduct of the surveillance. Inspector review found that all acceptance criteria were met.

There was good manipulation of the controls. The inspector observed good communications with other control room operators and equipment operators.

Operators demonstrated a good knowledge of plant equipment and controls, and adhered to procedures.

A complex test witnessed and reviewed in detail by the ORAT was core spray logic testing per SP 24.203.04 on March 16. The test verifies proper response of plant systems for simulated accident conditions concurrent with a loss of offsite power. The ORAT inspection found the procedure technically adequate.

Inspector observations confirmed proper operation of EDG-103, the containment isolation system, the residual heat removal (RHR) system, and the core spray

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system (except as noted below for the 33B injection valve).

The ORAT inspection found that licensee controls for test conduct assured

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that prerequisites were met, essential data was collected and test instruments were calibrated, acceptance criteria were met; acceptance criteria assured that systems responded as required by design, technical specifications and safety

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analysis report requirements; and restorations to normal conditions were proper and orderly. The inspector observed a thorough pre-test briefing for all personnel involved in the test.

There was good communication by operators in the control room during the test and good coordination between operators inside the control room and in the plant.

There was good shift management-involvement and supervisory oversight of test activities.

QC surveillance coverage of the test was accomplished by experienced personnel and was thorough bcsed on inspector observations, interviews with QC personnel, and review of QC Surveillance Report 89-05.

One test discrepancy noted by the licensee concerned the failure of "B" core spray injection valve 1H21*MOV-33B to stroke to the full open position upon receipt of the accident signal. The valve is normally closed and its failure to open renders the "B" core' spray system inoperable.

(In such a case, the "A" Core Spray. subsystem and the RHR system are available for core cooling.) Subsequent lice.1see ir,vestigation determined that an open circuit had developed in the valve motor, which was replaced.

Retest was scheduled for after the ORAT inspection.

Two surveillance tests witnessed and reviewed by ORAT inspectors on March 21 were the suppression pool low level functional test per SP 44.202.31 and nitrogen accumulator pressure calibration and functional test per SP 44.201.03.

The tests. verified proper level instrument function and alarm response per TSs 4.6.2.1.d.2 and 4.5'.1.d.1.

The ORAT inspection found the procedures technically adequate. Test prerequisites were met, and proper system responses were obscrved. A discrepancy was noted in the performance of SP 44.202.31.

The discrepancy concerned Restoration Step 8.9.

The technicians drained the low pressure end of the suppression pool level transmitter without a step in the procedure. This item is discussed further in Detail 6.6.

Overall, licensee oversight and control of the logic testing was good.

6.5 Technical Specification (TS) Surveillance Control The onsite compliance group schedules and verifies completion of required surveillance per TS test intervals. The plant production departments are responsible for surveillance program implementation.

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Inspector ru iew of the master test schedules for the weeks of March 14 and 21 verified that surveillance were being performed on time in accordance with the Technical Specifications.

The ORAT inspection checked for proper performance of su~rveillance testing in 1988 and 1989 pursuant to TSs 4.3.1.1-1(12), 4.6.5.3.A, 4.3.3.1-1, 4.6.2.3.A,4.5.1.A.1.A,4.5.1.A.4/C.3,4.3.5.1-1,4.5.1.A.I.8,4.3.3.1-1(1.0),

4.3.7.6.B.2, 4 1.3.1.A.3, and 4.3.2.1-1(3.0).

This review covered testing of the source ra se monitoring, core spray, low pressure coolant injection, reactor protection, service water, and reactor building standby ventilation systems.

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Proper implementation of the operational surveillance program was evident.

Procedures were properly prepared in accordance with SP 12.006.01, technically adequate test methods.

Completion was within the TS prescribed frequencies.

There was meeting of established acceptance criteria and/or noting and properly dispositioning discrepancies.

Procedures were followed as written or exceptions and. changes were processed-in accordance with administrative requirements.

-Supervisory. review of the results was evident.

6.6' Surveillance Procedure Discrepancies During the core spray logic test per SP 24.203.04 on March 16, procedure problems were noted in Appendices 12.3 and 12.4.

These provide p erequisites e.nd the test se.uence for the test of the "B" logic.

Licensee reviews during and after the test identified several discrepancies. These were as follows.

(i) A need to clarify Appendix 12.3 prerequisite steps 15 and 16 regarding notification of groups affected by the test. There was no effect on test performance.

No temporary procedure change (TPC) was needed.

(ii) The need to better identify Fuse F1B in panel 1H11*PNL-627.

There was no effect on test performance; no TPC was needed.

(iii) C'orrection of Appendix 12.4 step 24 to "re-install" the lif ted lead on BB-25 in panel 1H11*PNL-627. Test personnel wrote TPC 89-39 to cover the lifted lead restoration.

(iv) Final configuration for five pieces of equipruent listed in Appendix 12.4 step 82 that differed from expected, but were deemed by test personnel to be the proper system responses.

This did not require a TPC; such discrepancies are evaluated and dispositioned as part of the review to accept the test results.

(v) The need to correct the restoration sequence which omitted:

removing the lock-out inserted in Step 83 on EDG-103; correction of the restoration sequence for restoring Electrical Bus 12, which was de-energized during the test; and performance of the restoration steps in a sequence different than was specified by SP 24

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The inspector questioned whether a TPC should have been writto.

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The actual restoration sequence was reviewed collectively by shift personnel and included a review by at least two **dividuals with senior reactor operator (SRO)

licenses.

Such a rev" - is equivalent to that required for a TPC. Also, actions by plant personnel to restore normal conditions (restoring electrical buser, placing diesels in standby, restoring RPS power, resetting partial RPS logic trips, unblocking safety system injection valves, etc.) were appropriate. The inspector identified no inadequacies in tne revfsed sequence: plant safety was maintained at all times.

Deviatiors from the procedurally prescribed restoration sequence are not allowed oy SP 12.006.01 or by 5P 24.2103.04.

The inspector concluded that a TPC could have been processed concurrent with the restoration actions.

Howeve", since the restoration steps required the use of specific

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operating' procedures to assure proper alignment,.there was no safety inadequacy involved. This matter was classified as a weakness to be-further reviewed do ing routine inspection, and was discussed with the Acting Operations kanager on March 17.

The licensee noted the inspector's comments and initiated action to address this concern.

Test personnel identified the full list of discrepancies to Operations Supervision for consideration in a future revision of the procedure. Test personnel also identified the need to check whether similar discrepancies existed in the portion of the procedure for the test of the "A" side logic.

Inspector review noted that test personnel did not complete steps 99 through 106 of Appendix 12.4 due to the failure of "B" core spray injection valve IH11*MOV-33B, No'TPC was processed for bypassing these steps; that was found proper and in accordance with SP 12.006.01 and 12.016.01.

A procedural discrepancy in SP 44.203.31, Suppression Pool' Low level Alarm Functional Test, involved restoration step 8.9.

The licensee restored the sup-pression pool level transmitter 1E41-LT-013 by draining the low pressure end.

The procedure did not identify this restoration action step.

The additional step did not affect the procedure's intent: proper alarm functions of the transmitter were restored.

The inspector discussed this 'iscrepancy with the licensee's foreman, who initiated action to change the procedure.

None of the procedure discrepancies noted above affected safety.

In all cases, the procedure intent was met, and the discrepancies were forwarded on for ' management review and procedure upgrading.

6.7 Activity Verification The inspector reviewed completed Technical Specification surveillance to assess adherence to procedural prerequisites, verification of completed steps, l

management review, deficiency identification, and corrective actions. The

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procedures reviewed were:

SP 44.654.20, Channel Functional Test of RCIC System Actuation

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SP 24.403.04, Logic Initiation and Functional Test of Loop A Core Spray SP 24.650.04, Channel Functional Test of RHR System Shutdown Cooling

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Mode Isolation SP 44.654.02, Channel Calibration of HPCI System

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SP 24.307.02, TOI Emergency Diesel Generator Testing SP 24.203.04, Core Spray Logic Test

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SP 44.202.31, Suppression Pool Low Level Alarm Functional Test SP 44.201.03, Nitrogen Accumulator Functional for ADS system

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Procedure discrepancies for the observed surveillance are discussed in Detail 6.6.

The ORAT review concluded that the surveillance were adequately reviewed by the watch engineer, compliance engineer, and section head, a

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6.8 Surveillance procedure Review l

A review of the content of Technical Specification surveillance was completed on the four observed surveillance and on the procedures identified in Detail 6.7.

-The review included a step-by-step verification tn determine workability, verifi-cation of qualification of technicians conducting the surveillance, review of sup-porting diagrams in the procedures, data collection, and completion of prerequisites.

-Detail 6.6, preceding, identifies procedural errors and improvement items for procedures SP 24.203.04 and SP 44.202.31.

The discrepancies in these procedures were minor and did not adversely affect safe activity performance.

The licensee initiated action to upgrade the procedures.

Overall, surveillance procedure quality was assessed as satisfactory.

6.9 Surveillance Training The qualifications of technicians conducting the observed surveillance were found acceptable.

The inspector reviewed the surveillance testing training program for Instru-ment and Controls (I&C) technicians, foremen, and engineers.

The review included training record verification, program description, interviews with. individuals, and observations of routine surveillance.

All but one of the I&C technicians have completed the basic qualification program, which includes technical and administrative requirements. As of March 16, 1989, permanent qualifications for surveillance testing had been completed by 22 individuals. The permanent qualification is required for performing TS sur-veillances but, if more than one individual is assigned to a surveillance, only one of them needs to be qualified.

It is the foreman's responsibility to assign activities based on qualification status.

The inspector reviewed surveillance and individuals assigned for March 21, 1989 and found no qualification discrepan-cies.

The technical training program was accredited by INPO in September 1988. As part of the accreditation, the licensee committed to include three specific courses for surveillance testing qualification.

Those courses are process control, Boiling Water Reactor (BWR) familiarization, and I&C systems.

The licensee provided the courses in the technical training program prior to September 1988, but did not backfit this training to surveillance qualification.

I olementation of the modi-fied training program is to be included for new hires First-line supervisor (foreman) training includes periodic on-the,iob-training (0JT) evalui.tions, qualification as an OJT evaluator, and supervisor workshops.

Support engineering staff training includes technical staff general training, simulator training, and control and electrical system overview.

Technical staff refresher training is given annually.

No surveillance training inadequacies were identified.

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6.10 Communications Interface The inspector observed morning meetings between the surveillance engineer, engineering supervisors, and foremen. The meetings were detailed, and discrepancies were resolved.

The surveillance section communicates with other departments incident to per-forming surveillance procedure steps, to resolve QA/QC observations and findings, during operations department daily meetings, in responding to findings and overview by compliance engineering, through corrective maintenance identification via MWRs, and in regard to health physics surveys.

The inspector observed communications between QC, operations, and surveillance personnel during performance of procedural activities.

Those communications were rated as good.

The inspector also reviewed the licensee's self-assessment of QC audits of surveillance in relation to communications with other departments.

No inadequacies were.noted.

The communications interface was found to be effective.

6.11 Management Overview Management administration and control were evident in the master test schedules i

published monthly and weekly for implementation by the production groups. Addi-

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tionally, weekly schedules are used for scheduling daily activities and are re-viewed one week.in advance in a planning meeting ' volving all production' groups.

This meeting allows for inputs from the productio;. groups to determine which tests are ready to be run, resolve schedule conflicts, exploit equipment outages to optimize work schedules, and assure needed manpower and materials are available.

The inspector observed a planning meeting on March 15, and found it to be an ef-fective tool for surveillance implementation.

Discipline foremen meet daily with the surveillance engineer to review work scope changes and resolve scheduling discrepancies. The inspector attended the daily meeting on March 21. That meeting was effective in integrating planned testing with other activities.

Scheduling of weekly surveillance activities was in accordance with SP 12.016.01 during the weeks of March 14 and March 20. No inadequacies were noted in management overview of surveillance scheduling.

I&C supervision provided information on the licensee's data base for trending l

instrument drif t for all-Technical Specification instruments.

Data collection began in 1981. The data base and associated management reviews were assessed as a positive contributor to performance.

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performance of SP-44.201.03.

Good interaction with workers was observed.

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Hanagement overview of surveillance was assessed as good.

0 12 Open Items There are no surveillance items requiring resolution before power operation. The use of-TPCs to change or add procedure steps will be followed-up during routine inspection.

6.13 Conclusions The ORAT inspection concluded that operational surveillance is ready to support power operation safely, 7.0 FACILITY RADIATION PROTECTION 7.1 Review Scope The facility radiation protection program must control exposures to radiation and radioactive material during routine operation as well as during equipment maintenance outages. This review assessed each of the major programmatic building blocks needed to achieve these objectives. Within each area, performance was assessed not only relative tr the applicable regulatory requirements but also relative to current standards of excellence set for the industry.

The inspector specifically determined if the program status is adequate to support a power ascension program.

7.2 Health Physics Organization and Staffing The Health Physics section reports to the Radiological Controls Division Manager as required by the Technical Specifications (see Figure 9). This section's manager is usually titled the Radiation Protection Manager in the industry. At Shoreham this section is headed by by the Health Physics Engineer (HPE). The HPE has the auth)rity to bypass the normal reporting chain to bring radiation safety matters directly to top station management.

The Shoreham Updated Safety Analysis Report (USAR) states that the health physics (HP) Section shall have a minimum complement of 14 personnel. The Technical Specifications require that a fully qualified Senior HP Technician be on site when fuel is in the reactor. Management has authorized a larger staff consisting of 9 supervisory personnel, 22 Senior HP Technicians, 6 Junior HP Technicians and 5 HP Technician Helpers, for a total of 42 personnel.

This staffing level is in line with current industry practice.

In addition, to foster retention, 6 temporary Junior HP Technician positions were approved to allow hiring and training of personnel from the local area.

There are 5 such hires currently in training.

There are 13 Senior HP Technicians and 6 Junior HP Technicians on site.

All supervisory positions are filled.

LILCo has experienced difficulty attracting high caliber personnel for permanent positions. Well qualified and experienced contract personnel were therefore hired to fill the Health Physics Engineer and two other positions.

Several companies provide qualified HP

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Technicians to the nuclear industry to augment staffs during maintenance j

outages, and LILCo plans to use this resource to support Shoreham operation as

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nece s sa ry.

There are currently 4 contracted technicians on site.

Turnover of the HP Section staff has been compensated for with no loss of technical capability. An excellent training and qualification program is available to produce additional staff. Although contractors are used, the inspector concluded that the permanent staff is adequate in numbers and skills to support startup and power operation, and to provide oversight and control of the contractors.

7.3 Staff Stability and Morale Staff turnov.-r has been norral; with the difficulty of obtaining replacements identified as the cause of use of contractors.

A positive attitude was reflected in continued efforts to improve performance, which is already at a high level. Interviews of personnel generally indicated good morale. However, the inspector noted some indications of lowering morale. A few personnel commented that they plan to find work elsewhere if the plant is not granted a full power license soon, but stated that they plan to stay if a license is granted.

The underlying reasons appeared to include a desire to practice their profession under operating conditions and a recognition that, if Shoreham does not operate, there will be little health physics to be done.

Whether their statements indicate a worsening retention problem was not determined, but uncertainty about Shoreham's future was clearly indicated to be adverse to the morale of the health physics staff.

Management has aided retention by displaying a loyalty towards permanent employees.

However, management also acknowledges increasing difficulty in re-cruiting a permanent health physics staff. A notable increased use of contractors is evident at all levels in the HP organization.

The ORAT concluded that the stability and morale of the HP organization is adequate, but that there are indicators that a morale problems may develop.

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The excellent management which has boosted morale needs to be carefully j

continued.

7.4 Work Review During this inspection there was no radiologically significant work in progress. The only protective clothing in use was by two technicians sorting trash in the radwaste building.

However, in mid-January station personnel removed the "C" Intermediate Range Monitor (IRM) from the reactor. The projected hazards were a dose rate of 4 rem / hour on the IRM cable and 10,000 dpm/100cm2 loose contamination on the cable. The work was performed in the

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l sub pile room beneath the reactor lower head.

The inspector reviewed the radiation work permit, ALARA reviews, and radiation survey records for the job.

The licensee did an extensive amount of preplanning for this work.

Special handling tools and a shielded cask were designed and fabricated.

Special mock-up training was provided to the workers.

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Prejob' briefings were also held with all members of the work crew.

Special HP Technician coverage of the job was arranged.

As a result of the preplanning and good control of the work, the total ex-I posure was only 0.023 man-rem.

The licensee demonstrated excellent ability to control hazardous work in this case.

7.5 Personne1' Monitoring Monitoring of personnel exposure at Shoreham Station is accomplished using a four. chip thermoluminescent dosimeter (TLD) System supplied by Panasonic.

This system is widely used in the industry.

The station monitoring program was accredited by the National Bureau of Standards in 1988 as required by 10 CFR

20.202.

The dosimetry system consists of TLDs mounted in a standard badge and pro-cessed through standard TLD readers.

Readouts are converted to millirem exposures using algorithms developed at the University of Michigan. All processing is done at the station.

Dosimeters are collected and read out quarterly. The licensee stated that the cycle time will be reduced to monthly during plant operation.

Collection and processing of dosimeters is done by two technicians and two clerks under direction of a full time supervisor.

Exposure reports to workers are also produced by the group.

Equipment is currently available to badge 5,000 workers, and 1,000 dosimeters are in use.

There are 20 well written procedures dealing with various aspects of dosimetry. Independent QC checks are accomplished by exchanging " spiked" dosimeters with a contractor laboratory.

The inspector concluded.that the licensee is conducting an adequate personnel monitoring program.

7.6 Health Physics Procedures The Technical Specifications recoire that the licensee have adequate procedures to ensure implementation of 10 CFR 20 Standards for Protection i

Against Radiation. The inspector reviewed selected procedures and interviewed selected personnel.

The health physics implementing procedures were found to be of excellent quality. Adequate detail is provided and the particular regulatory requirema ts are cited in references.

The licensee recently instituted an innovative review of procedures called " Rote Day."

When the HP supervisor-j declares a " Rote Day," all procedures in use are taken to the work location and followed. Any difficulty experienced in achieving total compliance is documented and reported to the HP supervisor.

This practical test provides improved assurance of procedure validity.

The inspector noted that three HP procedures did not receive the biennial review by the Plant Review Committee as required by Technical Specifications.

The licensee advised that the NQA Department completed an in-depth review of

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all station procedures on 3/16/89. This audit found that 177 of 1900 station procedures have apparently missed the biennial review.

As a result, Corrective Action Request (CAR) 89-02 was issued against the Plant Manager.

Corrective action was requested by April 1989. This condition was evaluated as being i

adequately corrected, of minor safety significance, not requiring reporting to the NRC, and not being due to inadequate previous corrective action.

The inspector commended the licensee for self-identification of this problem.

The inspector concluded that adequate procedures are in use to ensure implementation of the health physics program. The procedures are clear, well written, and adequate to support full power operation.

7.7 ALARA (As Low As Reasonably Achievable)

Notwithstanding the absence of radiation levels, contamination or radiologically hazardous work, the licensee has maintained a very aggressive ALARA program. Both corporate and line ALARA organizations are in place along with all implementing procedures. Strong support of ALARA is evident at all levels in the organization.

The impetus clearly begins with senior corporate management.

Station management meets quarterly to discuss ALARA performance and provide direction. Aggressive ALARA goals have been set for 1989 by considering various licensing scenarios.

Various plant modifications that have lowered worker exposures at other plants are under consideration.

For example, the licensee plans to install zinc injection if the plant is allowed to operate.

An ALARA poster contest was recently concluded with cash awards. ALARA sensitivity training is in progress as a refresher for station workers; training of managers and design engineers was recently completed.

The inspector concluded that the licensee has a state-of-the-art ALARA program that has solid management backing.

7.8 Radiation Surveys The inspector reviewed the routine radiation survey program for compliance with 10 CFR 20 and the Technical Specifications.

Performance was determined by accompaniment of HP Technicians during routine surveys, review of records, and interviews with personnel.

Qualifications of HP Technicians conducting surveys

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were also verified.

The inspector concluded that the routine survey program is adequate.

Although no radiation fields are present, the technicians conduct thorough surveys of radiation levels, surface contamination and airborne contamination.

Findings were recorded on survey maps.

The number of locations surveyed on each elevation of a building was comparable to surveys at operating stations.

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Surveys were generally done on backshifts.

The inspector concluded that' technician skill'and ability to conduct routine surveys is fully adequate to support plant operation.

l 7.9 Radiologically Controlled Areas All access'to the radiologically controlled areas is through a single control point that separates the Administration Building and the Turbine /

Radwaste/ Reactor Buildings. The control point is continuously manned by.a Level l1 (Senior) HP Technician with one or two Level II (Junior) HP Technicians.

On dayshift there is also a foreman present and a clerk who ensures that personnel are properly wearing dosimetry and not bringing in extraneous material that would end up as radwaste.

The control point has.large power block building floor plan maps that display the latest radiation survey information for use by personnel. Only a few small roped off contamination areas are currently indicated.

Large plexiglass windows allow the technician to observe all movement in or out of the area.

Various records are kept at the control point such as all' active radiation work permits and radiation survey data from the past few weeks.

Personnel exiting the area must pass through sensitive contamination monitors. Tools and equipment are surveyed and released by the technicians.

A tour of the radiologically controlled area and independent surveys by the inspector found no high radiation areas and very few radiation or contaminated areas. The postings that were used appear to be more precautionary rather than warning of actual hazards. Management stated that, during power ascension, the areas that are projected to become high radiation areas will be locked and posted in advance.

The inspector concluded that the current controls exercised are appropriate and conservative for the current radiological conditions. Caution and warning signs are adequately posted.

7.10 Material and Contamination Control No loose trash or tools were observed during tours. There were only a few areas roped off for contamination control. These are primarily in the radwaste building. The lack of surface contamination is due to the absence of contamination in the piping systems and very good radiological controls. All personnel and tools were thoroughly frisked prior to exiting the controlled area. The lack of contamination has not resulted in any noticeable retreat from tight control of material entering or leaving the controlled area.

The licensee previously identified the need for a storage area for contaminated tools.

Plans were developed to build a " hot" tool crib along with

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l a " hot" machine shop and improved traffic patterns in/out of the contrciled area.

These plans are on hold pending issuance of the operating license.

Potentially contaminated material is sorted in the upper elevation of the radwaste building.

Clean trash is segregated and shredded for landfill disposal. Contaminated material is accumulated for disposal as radwaste.

Material and contamination control was rated very good.

7.11 Respiratory Protection The licensee's program to control airborne radioactivity in the plant and to provide respiratory protection for workers was reviewed with respect to 10 CFR 20.103.

The engineering controls available included five 1000 CFM and one 5000 CFM high efficiency air filtering units (tiEPA filters). Assorted size glove bags and plastic drop bags were in stock.

A comprehensive respirator program for workers is available.

It consists of medical evaluation, classroom training, and fit testing. A large supply of filter type, positive pressure and SCBA respirators are available on site.

This equipment is in routine use for protection against industrial hazards such as abestos.

The need to protect against airborne radioactive material is minimal.

Respirators are cleaned, repaired, tested, and inspected on site by qualified HP Technicians.

These foreman and technicians also repair and maintain the radiation monitoring equipment.

Several hundred whole body counts are performed each year on the plant staff by the dosimetry group to detect any uncontrolled inhalaticn or ingestion of radioactive material. All results have been negative.

The inspector concluded that the respiratory protection program is adequate to support plant operation.

7.12 Radiation Measuring Instruments The inspector assessed the availability of radiation measuring instruments through tours of the access control point, controlled area, health physics count room and the instrument repair facility.

The supply of portable instruments issued for use and the reserves in storage are adequate. The health physics count room is well equipped to conduct isotopic analysis of smears and air samples.

Technicians appeared to be knowledgeable regarding the operation of all swipment, Adequate procedures were available.

l All equipment is fairly new, with older equipment having been retired from service.

Very sensitive automatic personnel contamination monitors are installed at the access control point.

Portable continuous air monitors were observed to be in use in several plant locations.

Many repairs are performed on site.

The repair shop is well equipped with j

testing equipment and spare parts.

Non-repairable instruments are returned to j

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the manufacturer.

The inspector concluded that ample supplies of portable and fixed laboratory radiation monitoring equipment are available to support routine operations, emergencies, or an outage.

7.13 Equipment Calibration Radiation measuring equipment is repaired and calibrated by a HP subgroup l

consisting of a foreman and two qualified technicians. Calibration is accomplished using NBS traceable radiation test sources and a commercial Sheppard Model 89 calibrator. Air pumps are calibrated with a secondary standard that is in turn calibrated by Grumman Aircraft Company. A very sensitive computerized trash bag monitor is calibrated using a plastic garbage can with fixtures to position various radiation sources.

Calibration procedures are based on manufacturer's recommendations.

An equipment history folder is maintained on each instrument for trending purposes.

Statistical (Chi-squared) tests are completed on laboratory equipment to allow quality control charts tc be maintained.

Equipment calibration st.itus is maintained in a computer data base which flags due dates.

The inspector noted that calibration of HP equipment follows generally ac-cepted techniques and good industrial practices.

No inadequacies were noted.

7.14 Health Physics Technician Training and Qualification Specific HP Technician training and experience requirements are delineated in Technical Specification 6.3, USAR Sections 12 and 13, and ANSI Standard N18.1-1971. The licensee provides all required training at the W. Dye Training Center. This Training Center has an impressive array of sophisticated laboratory equipment that duplicates all fixed and portable equipment that a technician must operate at Shoreham.

The high quality of the training equipment compares favorably with some in plant equipment found at other stations.

Excellent management support is evident.

A full time staff of four instructors are assigned to this training.

Their resumes indicate mostly nuclear navy experience.

Lesson plan and student handouts have good technical depth and excellent quality.

The training program was INP0 accredited in 1988.

Technician qualification is a piecemeal process. A computer program is used to track each technician's progress in completing the many elements required in each " functional area." Examples of functional areas are radwaste processing, instrument calibration and maintenance, dosimetry systems, respiratory protection, and routine surveys.

Classroom and on-the-job-training, and demonstrated proficiency, are required.

Completing the core functional areas makes a technician a " level II" (junior technician). A level II technician is not allowed to issue radiation work permits or survey areas above 100 mr/hr.

To advance to level I, the technician must gain experience at an eperating station.

In the Fall of 1988, three technicians and a foreman were assigned to the staff at Nine Mile Point

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Station'(BWR reactor) for three months. They performed routine duties during a mid-cycle equipmrit outage at the -station. At the end of the outage they were transferred back to Shoreham Station.

This approach provided excellent-

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compensation for the lack of current operating experience at Shoreham.

The licensee is continuing efforts to "home grow".a staff through hiring Long Island residents.

This has aided the stability and quality of the technician staff. A continuing education program maintains the. proficiency of the existing staff.

Independent oversight of the. training program is provided through annual-reviews by the NQA department. These audits are required by the Technical Specifications and the NRC approved Quality Assurance Plan.

The inspector concluded that the licensee is conducting a very effective qualification program for HP technicians.

Creative approaches and strong management involvement have produced a high quality program.

7.15 General Employee Radiation Protection Training (GET)

The licensee is required to provide general employee training in accordance with 10 CFR 19.12 and training for respirator users 1.n accordance with 10 CFR 20.103.

The status of the general employee training program was determined from:

Tour of the W. Dye Training Center in Hauppauge, N.Y.

  • Interviews with the Technical Support Training Supervisor and

selected instructors.

Review of selected records and procedures

Observation of a training class

The inspector determined that the licensee is conducting an excellent GET training program.

Certification for the program was granted by INPO in 1988.

There are five highly qualified permanent instructors including two ex-secondary teachers, a nuclear engineer, and a reactor operator.

The training facilities are new, modern and well equipped.

No contractors are employed in this program.

Training is highly structured. A " job task analysis" is performed to determine the training objectives.

Lesson plans are then developed. After each lesson the students must complete " job performance measures" to determine the effectiveness of the training.

Instructors are required to visit the station each month to keep abreast of station problems and training needs.

Annual requalification of the entire station staff has been expanded to 2 days. This decision was based on the lack of practice due to absence of radiological conditions in the shutdown plant.

The licensee stated that requalification cycles will be shortened to 6 months when a power license is granted.

This is more frequent than normal industry practic t

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The inspector concluded that management support and commitment to GET training remains excellent. Training programs, staff, and facilities are in place to support full power operation.

7.16 Management Review The Nuclear Quality Assurance Department (NQAD) plays a major role in

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providing management review of health physics programs.

In 1988 the NQA l

Department conducted four indepth audits, five surveillance, and four inspections.

Each of these were effectively conducted by a knowledgeable and well-trained auditing staff. The conclusions and recommendations regarding program weaknesses were always technically sound.

Thus far in 1989, NQAD has conducted 5 surveillance and an audit of procedures. NQAD auditors had made the same findings as the ORAT inspector regarding biennial review of HP procedures (see Section 7.6).

The NQAD manager stated that an excellent working relationship has developed between the NQAD and HP. departments.

There are plans to send NQAD inspectors to other operating power plants as training for Shoreham power operations.

However, the NQAD manager stated that his department has not found any serious weaknesses or trends in the HP department.

Additional oversight is provided by the Corporate ALARA Review Committee

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(CARC).

The CARC committee has management representatives from all station de-partments and meets quarterly. A review of the minutes of meeting and action items indicates this committee is very proactive role this committee in providing direction for the HP programs.

The Corporate Radiation Protection Division has a Health Physics /ALARA

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Section consisting of a supervisor and two HP engineers. This section works

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closely with station HP personnel in setting program goals and objectives.

The inspector was favorably impressed by the proactive roles of management and NQA in the HP programs.

7.17 Communication Interfaces l

Communications between HP personnel and other station departments was

assessed through observation of daily routine activities. The incoming shift I

senior HP technician attends the shift turnover meeting in the control room.

This ensures that HP personnel are aware of plant status and planned work and surveillance.

A minor problem was noted in regard to the solid plexiglass surrounding the access control point.

Both workers and HP technicians were observed

" knocking" on the plexiglass to get each other's attention. Management stated that plans are underway to open sections in the plexiglass.

l The NQA department has instituted a " Hot Line" which allows workers to anonymously raise concerns to management.

All concerns and resolutions are prominently posted cn a bulletin board. One recent concern was related to HP

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technician practices on frisking tools.

The worker noted that technicians do

.not check themselves in the contamination monitors after handling tools.

Resolution is pending.

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The inspector concluded that communications interfaces are adequate.

l 7.18 Open Items There are two health physics open items.

Both are minor and relate to the

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post-accident sampling system (PASS).

Both require the plant to operate at power for resolution. One of these items (Inspector Follow Item 85-04-01) is for verifying that the PASS sample pump collects 1 gpm.

The other open item (Inspector Follow Item 85-04-09) is for conducting a gamma spectroscopic isotope identification on a PASS sample.

No open HP items affect the issuance of a full power license.

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7.19 Facility Radiation Protection Conclusion Based on this review, there is a high confidence that the licensee is able to conduct a proper health physics program for the protection of workers and-the public.

There are mechanisms in place to achieve excellent performance.

8.0 EFFLUENTS, RADWASTE, CHEMISTRY, AND ENVIRONMENTAL MONITORING 8.1 Review Scope This-inspecticn reviewed the licensee's readiness for safe operation in the following areas:

Radiological Chemistry

Non-radiological Chemistry

Liquid and Gaseous Radioactive Waste Controls

Solid Radioactive Waste Control

Air Cleaning Systems

Radiological Environmental Monitoring Program

Meteorological Monitoring Program

The licensee's performance in each area was determined by observation of plant facilities and operations, review of procedures and records, and interview with the licensee staff.

8.2 Organization and Staffing The licensee's chemistry and radwaste organizations (see Figure 10) report through the Manager, Radiological Controls to the Plant Manager.

Radiological and non-radiological chemistry measurements, off site dose assessment from effluent releases, and testing of the air cleaning systems are conducted by the Chemistry Section.

Calibration of effluent monitors is performed by the Computer Engineering Department. Maintenance of the effluent release and

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radwaste computer codes is performed by the Nuclear Engineering Department.

The Radiological Environmental Monitoring Program (REMP) is implemented by two

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groups,' the Environmental Engineering Department in the corporate office and Nuclear Engineering Department in the plant.

The inspector noted that.the licensee has sufficient staffing in these areas. This area was found ready for safe operation.

8.3 Staff Stability and Morale Staffing in the Radwaste Section consists of a Radwaste Engineer (Section Supervisor), 3 other supervisory personnel, and 5 additional staff members.

One position, Radwaste Shipping Engineer, is filled by a contractor. One vacancy exists for a Radwaste maintenance technician.

Current staff, with the exception of the Radwaste Shipping Engineer, have been in the Radwaste section at least 2 years.

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. Although management has experienced some difficulties in recruiting and retaining technicians and other professional staff, they have been successful in doing so.

The recent turnover rate was assessed as normal.

The inspector.

noted that the licensee used the " team approach" technique to resolve difficult tasks. The inspector also noted that the licensee staff exhibited a very positive attitude and good morale.

This area was found ready for safe operation.

8.4 Work Observation During the inspection, maintenance work in the Radwaste building was observed. This work was performed by members of the Radwaste Section, directly under the supervision of the Radwaste Foreman. Work was performed according to procedures, with all operations conducted with appropriate consideration of plant safety and ALARA programs.

This area was found ready for safe operation.

8.5 Semiannual and Annual Reports The inspector reviewed the semiannual effluent release reports for 1987 and 1988. These reports were found to be thorough and to accurately reflect the releases of effluents to the environment.

The inspector reviewed the annual environmental reports for 1986 and 1987.

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These reports provided summaries of the environmental sampling and analyses.

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This area was found ready for safe operation.

8.6 Offsite Dose Calculation Manual (ODCM)

l The.0DCM, now in revision 14 as submitted to the NRC as an enclosure to the July-December 1988 Effluent report, was found to be technically accurate and properly utilized by the licensee in determining doses.

This area was found ready for safe operation.

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8.7 Radiological Chemistry The inspector' reviewed the licensee's radiological chemistry procedures to evaluate the measurement capabilities for the implementation of the following Technical Specification (TS) requirements:

TS 3/4.4.5 Specific Activity (Reactor Coolant System)

TS 3/4.11.1 Liquid Effluent

TS 3/4.11.2 Gaseous Effluent

During the previous inspection (Inspection Report Number 50-322/86-11),

test samples were submitted to the licensee in order to evaluate the licensee's capability to measure radioactivity in effluents. All measurements were in agreement under the criteria used for comparison of results.

During this inspection, the following areas were reviewed to assess the maintaining of the measurement capability:

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Interlaboratory and Intralaboratory comparison results

Calibration records of counting equipment

Analytical results of effluent samples

No major problems were noted in these areas.

The inspector concluded that licensee has an effective program.

This area was found ready for safe operation.

8.8 Non-Radiological Chemistry The inspector reviewed the licensee's procedures, calibration results for j

the chloride monitor, and maintenance records for the post-accident sampling

system (PASS) to determine the implementation of the following Technical

Specification requirements:

TS 3/4.3.7.8 Chloride Intrusion Monitors

TS 3/4.4 Chemistry

TS 6.8.1.(b) NUREG-0737 Requirements (PASS)

During this inspection, a standard PASS sample was submitted to the licensee for boron analysis.

This standard was prepared by Brookhaven National Laboratory for the NRC.

The licensee's analytical result was in agreement using the NRC's comparison criteri.__-. _- _ _ _ _

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The inspector reviewed the quality control program and found that the-licensee implemented the program well in the laboratory.

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l The inspector also reviewed the most recent channel calibration results for the chloride intrusion conductivity monitor (CE-81). The calibration result was acceptable.

This area was found ready for safe operation.

8.9 Liquid and Gaseous Effluent Control The inspector reviewed the licensee's procedures and. liquid / gaseous discharge permits to determine the implementation of the following Technical Specification (TS) requirements:

TS 3/4.11.1 Liquid Effluents

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TS 3/4.11.2 Gaseous Effluents

TS 6.14 Offsite Dose Calculation Manual (ODCM)

The inspector reviewed selected liquid and gaseous discharge permits to determine compliance with the above requirements.

The inspector determined that the licensee was meeting the requirements for sampling and analysis at the frequencies and lower limits of detection established in Tables 4.11.1.1.1-1 (for liquid) and 4.11.2.1.2-1 (for gas) of the Technical Specifications.

The licensee's Chemistry Section is responsible for sampling effluents prior to and during releases. The inspector reviewed the procedures related to the sampling of effluents.

This area was found ready for safe operation.

8.10 Calibration of Effluent and Process Monitors The inspector reviewed the licensee's procedures and the most recent monitor calibration results for implementation of the following Technical Specification (TS) requirements:

TS 3/4.3.7.10, Radioactive Liquid Effluent Monitoring Instrumentation

TS 3/4.3.7.11 Radioactive Gaseous Effluent Monitoring

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l Instrumentation The licensee's Computer Engineering Department is responsible for conducting required calibrations of the liquid and gaseous effluent monitors.

This area was found ready for safe operation.

8.11 Air Cleaning Systems

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I The inspector reviewed the licensee's procedures and the most recent surveillance test results to determine the implementation of the following Technical Specification (TS) requirements.

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TS 3/4.6.5.3 Reactor Building Standby Ventilation System

l TS 3/4.7.2 Control Room Air Conditioning System

TS 3/4.11.2.8 Containment Purging and Venting

The licensee's Chemistry Section is responsible for testing.the components

i of the air cleaning systems. At the present time, the licensee is using a vendor to conduct this testing.

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This area was found ready for safe operation.

8.12 Solid Radioactive Waste Program The inspector reviewed the licensee's procedures and observed other activities to determine the implementation of the following Technical Specification (TS) requirements:

TS 3/4.11.3 Solid Radioactive Waste i

TS 6.8.1.(h) Process Control Program Implementation

TS 6.13 Process Control Program (PCP)

The solid radwaste program is conducted by the Radwaste Section, under the supervision of the Radwaste Engineer, who reports directly to the Radiological Controls Manager.

Procedures for conducting this program were reviewed by the inspector, including those directly relating to the Process Control Program (PCP). The procedures are clearly written and were being properly followed by Radwaste personnel.

Radwaste personnel are responsible for the PCP, maintenance of the radwaste building processing equipment, preparation and packaging of radwaste for shipment, and interfacing with Operations, which staffs the Radwaste Control Room.

The licensee made three shipments of radwaste in 1988, consisting of 4 or 5 High Integrity Containers (HICs) loaded directly onto a trailer.

These containers would normally be placed in a shipping cask for transport but, due to the very low activities of plant radwaste at the present time, this alternate method of shipment was appropriate.

Documentation for these shipments was found to be extensive, with appropriate review by both Radwaste Section management and Quality Control.

This area was found ready for safe operation.

8.13 Radiological Environmental Monitoring Program (REMP)

The inspector reviewed the licensee's implementation of the REMP by means of discussions with licensee personnel, review of analytical procedures (strontium, iodine, gross alpha, gross beta, and gamma measurements),

analytical results, and direct observation of activities. The inspector also observed selected environmental monitoring stations for airborne particulate and iodine. Air sampling equipment at these stations were functioning and were maintained satisfactorily.

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The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitoring Network operated by NRC Region I provides continuous measurement of the ambient

radiation levels around nuclear power plants.

Several NRC thermoluminescent dosimeters (TL$s) are collocated with licensee's TLD stations. The monitoring results of the licensee's TLDs collocated with NRC TLDs were compared (5 stations).

(The collocated TLD stations are not always situated next to each other.) Although there were some minor differences between the NRC and licensee results, they were generally in agreement.

No discrepancies were identified in the licensee's procedures. The inspector concluded that the licensee has an effective program to comply with Section 3/4.12 of the Technical Specifications (Radiological Environmental Monitoring). This area was found ready to support plant operation.

I 8.14 Ouality Assurance for REMP The inspector reviewed the licensee's program for quality < ntrol of analytical measurements for the radiological analyses of environmental media including the EPA Cross-check Program.

Also, the inspector reviewed selected samples of quality control data submitted to the licensee by its contractors, Teledyne Isotopes and Clean Harbors, Inc. These data indicated, with few exceptions, agreement between. EPA spike samples and the contractor's results.

Where discrepancies were found, reasons for the differences were investigated and satisfactorily resolved.

No problems were noted in this area. The inspector concluded that the i

licensee was implementing the quality assurance program effectively. This area was found ready for safe operation.

8.15 Meteorological Monitoring Program The inspector reviewed the licensee's meteorological monitoring system to determine the implementation of Section 3/4.3.7.3 of the Technical Specifications (Meteorological Monitoring Program). Also, the inspector reviewed the licensee's procedures and the most recent calibration results for the meteorological monitoring system: Wind speed; wind direction; and delta temperature. Calibration is required semiannually. The calibration results indicated that the system was properly calibrated.

The inspector also examined the licensee's meteorological monitoring system, including the onsite meteorological tower and the displays in the equipment housed at the base of the tower. All instrumentation was found to be operating properly. There was good agreement between the instruments in the equipment house and the control room.

Both sets of instruments appeared to reflect actual meteorological conditions at the time of the observation.

No problems were noted. The inspector concluded that the licensee has an effective program.

This area was found ready for safe operation, j

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Training of both Chemistry and Radwaste technicians consists of both new

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employee training and periodic retraining, especially in the area of radwaste

shipping and transportation. This is part of the licensee's program to meet l

the requirements of NRC IE Bulletin 79-19.

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This area was found ready for safe operation.

8.17 Audits The licensee's Quality Assurance program consists of program and vendor audits, Quality Control (QC) surveillance, and inspections of in progress plant activities j

based upon predetermined QC hold points.

During 1988, the licensee conducted audits of the REMP, Effluent Monitoring, Radiochemistry and Radwaste programs.

In addition, audits of vendor activities related to the REMP and Radiochemistry programs were conducted.

Audit findings are tracked, in both the monthly Manage-ment Report and the biweekly Open Audit Status List, until resolved. QC surveil-lances include follow-up of audit findings and, in the area of plant chemistry, submission of spiked samples to measure chemistry performance.

This area was found ready for safe operation.

8.18 Management Review Management review in the Chemistry and Radwaste Sections has included Reliability Engineering studies of the Process Control Plan and related equipment, and extensive audits and surveillance of operations in both sections under the direction of the Nuclear Review Board. The Radiological Controls Manager has utilized the results of these studies to make significant improvements in both of these program areas.

f This area was found ready for safe operation.

8.19 Communication Interfaces

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The Radwaste Section has regular, proceduralized interfaces with the Nuclear Engineering Department, which maintains the RADMAN computer code l

utilized in waste classification, with the Operations Division, which staffs

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the Radwaste Control Room, and with the Quality Control Section, which must review and sign off on Process Control Plan steps at predetermined hold points.

The Chemistry Section regularly interfaces with the Nuclear Engineering Department which maintains the Radiation Monitoring System computer codes, the Computer Engineering Section which calibrates the effluent monitors, Operations Division to determine where and at what times plant chemistry and radiological effluent samples must be taken, and Quality Control whose surveillance include the submission of spiked samples to the Chemistry Section for analyses.

This area was found ready for safe operatio r-

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8.20 Open Items There'are no open items in the areas of. effluents, radwaste, chemistry, and environmental monitoring.

8.21 Conclusion In the program areas of effluents, chemistry, radwaste and environmental monitoring, the licensee is ready for safe operation.

9.0 ENGINEERING AND TECHNICAL SUPPORT 9.1 Scope of Review The ORAT evaluated operational readiness of the engineering and technical support organizations through review of the organization and staffing, of modifi-cation and configuration controls, and of interdepartmental interfaces. A sample of in progress and recently completed modifications was reviewed for the effective-ness.and quality of design planning, independent verifications, installation, and testing.

The inspectors also reviewed the backlog of Engineering Evaluation and Assistarice Requests (EEARs) and Station Modification Packages (SMPs) to assess prioriti:ation and the impact of personnel turnover. Working relationships between organizational elements involved in engineering support activities were evaluated through interviews, and during observations during licensee meetings.

Finally, the ORAT reviewed the licensee's recent self-assessment and QA audits and actions.

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on the findings to assess the effectiveness of the licensee's management oversight

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and commitment to program improvements.

9.2 Organization and Staffing The onsite Nuclear Engineering Department (NED) provides the majority of engineering support to the station. As depicted in Figure 5, there are six NED I

divisions: Nuclear Systems Engineering, Nuclear Fuels, Engineering Assurance, Nuclear Project Engineering, Radiation Protection, and Nuclear Analysis. Author-ized complement is 114 All supervisory, positions are staffed with licensee per-sonnel.

Including contractors, there are about 100 persons on board.

Additional personnel at the Office of Engineering in Melville, N.Y. are dedi-cated to support Shoreham. These include: electrical, electrical design, mechani-cal, civil, and mechanical e'esign divisions. The authorized complement is 67 en-gineering personnel.

Curre tly these divisions are staffed with 38 licensee per-sonnel and 23 consultants. The work performed by the Office of Engineering is coordinated through the NED.

There is also a Stone & Webster (S&W) site engineering office with 60 engi-neers on board. Additional S&W personnel were stated to be available if needed.

The plant engineering staff provides routine plant support regarding the day-to-day design issues such as temporary modifications and set point change l

control.

The NED routinely interfaces with * 9 plant engineering staff.

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The inspectors reviewed the backlog of Engineering Evaluation and Assistance Requests (EEARs) and Station Modification Packages (SMPs). At the i

time of the inspection, there were 516 outstanding EEARs and 68 SMPs.

The

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priorities assigned to the EEARs and SMPs were reviewed by the inspectors.

No items requiring accomplishment to. assure safe operation were identified, The

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ORAT concluded that, with the current staff including consultants, the NED and

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PMS can support the Power Ascension Test Program (PATP) and operation during l

the first cycle.

However, the licensee needs to restaff vacant positions, in a timely manner, to reduce the EEAR and SMP backlogs and properly support the first refueling outage.

9.3 Staff Stability and Morale Recently, the NED and the Plant Modification Section (PMS) experienced extensive attrition.

Licensee management hired contractors to fill the vacancies.

Upon receipt of a full power license, the NED expects to restaff vacant positions with permanent LILCo employees within six months.

Licensee management also has authorized 9 additional full time engineering positions (consultants) in NED for the Power Ascension Testing Program (PATP). Those positions will be terminated upon PATP completion.

The licensee's steps to l

compensate for personnel losses were assessed as acceptable.

Interviews with engineering personnel identified no morale problems.

9.4 Modification Controls 9.4.1 Technology Transfer Program The licensee has a Technology Transfer Program for turnover of engineering

and design responsibilities from the Architect-Engineer (S&W). This program l

has ten elements which include staffing and training, the station modification program, and elimination of dependence on S&W.

The S&W procedures, standards, and technical documents have been transferred to the licensee. At the time of the ORAT inspection, the licensee had transferred about 99?J of the. work packages and 64?. of the documents and drawings identified for transfer.

The NED Engineering Assurance Division was established to perform an independent assessment of each NED division's readiness for effective transfer.

Technology transfer is scheduled to be completed by August 25, 1989.

Pending completion of the technology transfer, the licensee had developed an Interim Station Modification Program (ISMP).

This program will continue through the first refueling outage. Under the ISMP, S&W retains verification authority for safety-related design, maintains the design bases for the facility, and provides assistance for engineering supp;ct to the plant. The licensee also performs its own verification of safety-related designs.

9.4.2 Cesign and Modification Control The Interim Station Modification Program invol' a both the NED and plant engineering staffs. When a modification is requested using an EEAR, it is

evaluated and a design modification plan is developed by the NED, All design

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modification plans except cmergency modifications are reviewed and approved by a multi-disciplined Modification Review Committee (MRC). MRC composition includes the Outage / Modification Manager,.the NED Project Division Manager, the Station Modification Engineer, the Plant Systems Engineer, the Radiation Protection Division Manager, the Licensing and Regulatory Affairs Manager, and the QAD Systems Division Manager.

The NED then develops a modification output package which is forwarded to the plant modification section for preparation of a Station Modification Package (SMP).

The SMP provides the details of implementation and is developed by a Cognizant Site Engineer who coordinates implementation, testing, and closeout.

The inspectors attended the MRC meeting on March 16, 1989, reviewed

minutes of previous MRC meetings, and discussed those results with committee members.

The inspectors noted that the MRC provided a wide range of expertise and a productive team approach to reviewing and approving modification plans.

Recommended priorities of design modification plans were also reviewed and.

approved by the MRC.

9.4.3 Station Modifications Reviewed The inspectors reviewed the following station modifications and associated safety evaluations:

SM 87-004: RCIC Manual Initiation Seal-in Circuit Addition.

This modification installed a seal-in contact and removed the momentary contact in the RCIC (Reactor Core Isolation Cooling) manual initiation logic circuit.

The modification seals-in the initiation signal so that the initiation push button need not be held down until the steam admission valve permissive picks up to open the injection valve. That improves ease of the operation.

SM 87-037: Reactor Feedwater Piping Support Modifications. The purpose of this modification was to improve supports on the feedwater piping in order to accommodate loads induced by thermal stratification.

In response to an NRC Information Notice (IN) titled Piping Thermal Deflection Induced by Stratified

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Flow, the licensee determined that certain scenarios during operational evolutions could lead to pipe thermal stratification. Pipe stress analysis of the applicable portion of the reactor feedwater piping was performed to quantify the stress and pipe support load effects. Using this analysis, pipe support for the IN21 feedwater piping was modified. That involved 17 supports at 15 locations.

SM 88-003: RCIC pressure switch replacement. The affected switches, IE51*PS023A and 1E51*PS023C (ASCO Model SB11AKR/TL10A328), are involved in the RCIC isolation logic for motor-operated valves 1E51*MOV042, 1E51*MOV048, and 1E51*MOV049. These pressure switches failed to generate an auto isolation signal at the set point as required by Technical Specification Table 3.3.2-2 Section 4b.

Calibration checks traced the failure to set point drift below the allowable value. Therefore, the modification was proposed to require the replacement of these switches with a newer model ASCO switch which is f

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environmentally qualified, and has an adjustable range of 5-120 psig and over-range protection to 3000 psig. Although the new ASCO switches (Model (

SB21AKR/TG23A42BR) are dimensionally similar to the affected switches, special

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installation considerations needed to be implemented due to their seismic /

j dynamic characteristics. Therefore, the modification required installation of

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a new instrument stand, and minor cabling and raceway alterations.

This modification is subject to Technical Specification 3/4.7.4.- RCIC and 3/4.3.2 -

Isolation Actuation Instrumentation, Table 3.3.2-2 Section 4b. The modification does not require a change to the Technical Specifications.

USAR (Updated Safety Analysis Report) Table 7.4.1-1 was updated to reflect the correct range of 5-120 psig for the RCIC system steam rupply low pressure instrumentation.

For the modification packages reviewed, the ORAT concluded that the safety evaluations were properly conducted, documented, and reviewed by the Review of Operations Committee (ROC).

LILCo evaluations considered changes to the USAR, Technical Specifications, and whether any unreviewed safety question existed.

The inspectors reviewed the engineering and design change reports associated with the modifications and concluded that the changes were generally minor.

The design verifications for the safety-related modification packages included independent review by Stone & Webster (S&W) engineering personnel in accordance with ANSI N45.2.11.

Supplemental multidisciplinary reviews were performed by both applicable S&W and LILCo personnel. The multidisciplinary technical review comments were dispositioned and incorporated into the modification package as applicable.

The inspectors verified that applicable control room drawings were marked up and affected procedures were revised.

Post-modification testing was

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reviewed for technical adequacy and incorporation of code requirements.

No discrepancies were noted.

Modification packages reviewed were well organized and complete.

Engineering design analyses and verifications were effectively developed.

Safety evaluations were adequately performed with clearly stated bases.

9.5 Configuration Controls The licensee has issued Administrative Guidelines for maintaining plant configuration control for changes resulting from Station Modification Packages, Engineering Implementation Packages (EIPs), Temporary Modifications, and Engineering & Design Change Requests. (E&DCRs) as per the Interim Station Modification Program.

The Station Modifications Activities Procedure, SP 12.010.02, Revision 13, requires mark-up of Control Room drawings affected by a station modification and/or E&DCRs.

Temporary Modification Control Procedure SP 12.035.02 also requires that affected Control Room drawings be marked-up.

The above procedures prescribe how the Modifications Engineering Section marks-up Control Room drawings and maintains the marked-up Control Room Drawing Log.

Mark-ups of the controlled set of Control Room drawings to reflect design /

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documentation changes are the responsibility of a Plant Modifications Engineer.

To assure control room drawings indicate the existing plant configuration, drawing revisions are transmitted by the control room Shift Production Assistant to the cognizant Plant Modifications Engineer for determining if the drawings require further mark-up.

The inspectors reviewed plant modification packages requiring design / drawing changes and marked-up Control Room drawings. Modification packages and control room drawings reviewed showed proper implementation of existing procedures and controls. The Configurations Control program was found to be functioning well and in compliance with procedures.

9.6 Temporary Modifications The temporary modification control program functions to assure awareness of operators, maintain conformance with design intent and operability requirements, and preserve plant and personnel safety.

The temporary modification requesting section is responsible for preparing and providing technical input such as implementation instructions, safety evaluations, marked-up drawings, and revised operating procedures. Temporary modification packages are submitted to appropriate groups for review and approval (i.e., Systems Engineering, Modification Engineering, Review of Operations Committee, Plant Manager, and Operations). Watch Engineers have the on-shif t responsibility for authorizing the implementation and removal of temporary modifications.

The Watch Engineer also maintains the Temporary Modification Log Book in the Control Room and assures the issuance and removal of Equipment Information Cards. A Systems Engineer is responsible for reviewing each Temporary Modification to determine its impact on system operability.

The Modification Engineer has overall responsibility for assuring that all plant sections comply with SP 12.035.02, Revision 6, Control of Temporary Modifications.

The Modification Engineer also reviews technical evaluations to determine whether Engineering (NED) review and approval is required.

The Modification Engineer assigns a permit number and updates the Control Room Log Book as appropriate.

Implementation of Temporary Modifications is through Maintenance Work Requests.

The inspectors reviewed Temporary Modifications for technical adequacy and

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to assure that implementation was in accordance with established procedures.

Interviews were conducted with Modifications personnel to understand their awareness of the temporary modifications program, determine the present status of plant tempori.ry modifications, and assess the interfaces between work groups involved in the temporary modifications.

The licensee presently has three tem-porary modifi'.ations in place: TM 85-05-01, which expires on 6/23/89, installed a bearing cooling water line on replacement screenwash pump "B;" TM 87-01-05,

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which expires on 7/19/89, installed a bypass around the D-11 Radiation Moni-

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toring Panel to provide constant flow downstream of the panel (sampling cap-ability is not affected); and TM 87-09-01, which expires on 4/21/89, installed

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a corrosion product sample panel on an existing feedwater sample line.

LILC0 plans to make these TMs permanent through design changes. The ORAT concluded that these items were acceptably implemented. -A review of selected closed temporary modifications and their associated safety evaluations also reflected completeness in technical adequacy and implementation. The licensee's tracking system for temporary modifications accurately reflects the status of items.

This tracking system is reviewed monthly by the plant modifications section.

Logs maintained were found to contain complete and correct status of items.

9.7 Activity Verification The Independent Safety Engineering Group (ISEG) and the Reliability Group are responsible for ensuring that the licensee's engineering efforts are reviewed, evaluated and properly incorporated to assure the adequacy of engineering support. The licensee established the ISEG in fulfillment of a licensing commitment and to comply with a Technical Specification. The function of ISEG is to technically assess and report on the effectiveness and quality of nuclear operations and related safety and environmental programs.

The ISEG reports findings and recommendations to the Manager of Safety Engineering and Reliability, and to the Manager of Nuclear Quality Assurance.

The ISEG interfaces with the Nuclear Review Board, appropriate Department and Division Managers, and other Corporate Management to ensure proper closure of issues in accordance with approved procedures.

The inspectors reviewed a sample of ISEG evaluations including those related to Generic Letter 88-14, Instrument Air Supply System Problems Affecting Safety-Related Equipment, dated August 8, 1988.

These evaluations were well planned with clear statements of purpose and scope.

Final reports contained details of the methodology, research of the concern, and available solutions.

Conclusions and observations were stated in readily understandable form and, when appropriate, specific recommendations were provided in the report. Open items resulting from ISEG reviews were being tracked and updated monthly by the group for closure.

Interviews with the ISEG staff verified appropriate technical knowledge and understanding of their role and function.

The inspector concluded that the ISEG is functioning effectively and in accor-dance with both its charter and the Technical Specifications.

The reliability group is responsible for evaluating the reliability of plant systems and components in order to develop recommendations for improving equipment availability and optimizing plant capacity.

The reliability section assembles and analyze data on plant systems and equipment and on supporting activities, as well as on corresponding data on similar nuclear plants.

The inspectors observed strong emphasis on a study of reliability centered maintenance and its relationship to functional failure analysis.

The inspectors also noted, through interviews and study review, that the group has used a computer software package for detailed analyses incorporating industrial

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and plant specific data for generating fault trees and availability data.

The ISEG staff was both knowledgeable and enthusiastic concerning their product.

Reports were found to be well written.

Conclusions and recommendations were clearly presented.

The reliability group was found to be functioning in ac-cordance with its charter and procedures.

9.8 Interface Effectiveness The Nuclear Engineering Department (NED) routinely interfaces with the plant systems engineering, maintenance, and plant modification sections to support operations, maintenance, surveillance, and modification activities.

The NED typically gets involved with operations and maintenance-related issues through the Plan of the Day meeting and through interfaces with the systems engineers.

Good communications between the NED and systems engineering were noted during the inspection.

In developing Design Modification Plans (DMPs), NED engineers walk down a proposed DMP with the cognizant systems engineer (CSE) and with operations and maintenance personnel (as a team) to collect inputs from all disciplines.

The Modification Review Committee (MRC), composed of various section and division managers in the NED and NDD (Nuclear Operations Depart-ment), reviews and approves DMPs and associated priorities.

The inspectors attended Plan of the Day and MRC meetings and noted that communications and interfaces were effective at all levels of the involved organizations.

9.9 Trainina and Qualification At the time of the inspection, there were 120 degreed engineering personnel including 25 consultants dedicated to Shoreham Station work in the Nuclear Engineering Department (NED) and in the Office of Engineering at Melville, with an average nuclear experience of 12 years. Of these, 39 individuals held Professional Engineer licenses and 72 held advanced degrees.

Nuclear Engineering Department personnel training includes BWR design, BWR simulator, and self study of department and station procedures.

The training program for Cognizant Site Engineers (CSEs) in the Plant Modification Section includes policies and procedures, safety evaluations, weld inspection, examiner certification, QA indoctrination, and BWR familiarization.

There were eight CSEs in the Plant Modification Section, with their nuclear experience averaging 10 years.

Four of the CSEs have also received supplemental training in ASME Section XI Repair, analog controls, vibration analysis, BWR design, and BWR simulators.

The inspectors reviewed the training records and qualifications for selected NED and modification engineers and found the training and qualification commensurate with the duties performed.

In the process of reviewing selected modification packages, the inspectors interviewed CSEs and determined that they were familiar with applicable station procedures, testing requirements, safety evaluations associated with modifications, and all aspects of field conditions affected by the modifications.

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The licensee plans to fill the existing vacancies in both the NED and the Plant Modifications Section with experienced engineering personnel when a full power license is issued.

In addition to the training program, each new CSE is assigned to an experienced CSE for assistance during the training and indoc-trination period.

The new CSE is required to maintain a Training and Indoc-trination card current.

This card documents courses taken, procedure familiari-zation, and writing i a practice station modification for a previously imple-mented design output package.

The c,Jalification should be completed within the first year of duty and ensures that a new CSE is adequately trained.

9.10 Self-Assessment The ORAT reviewed the licensee's recent self-assessment and independent QA audit of operational readiness of the engineering and technical support or-ganizations, and noted that the self-assessment and the QA audit were compre-hensive and objective.

The 11censee's conclusion was that the engi-

ng support organi:ations and programs are generally effective and reao, to support full power operation.

However, the licensee identified a number of items which require resolution prior to startup. ORAT review of the self-assessment found no uncorrected items which require resolution in order to operate safely.

The inspector reviewed the following items with licensee engineering and QA man-agement personnel.

Calibrations of the nydrogen recombiners were not performed in

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accordance with the required frequency.

This has been resolved by the issuance of Station Procedure SP 47.402.02, dated 12/16/88, which provides

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detailed instructions for the performance of cold testing of Hydrogen Recombiners and associated instrumentation.

That satisfies Technical Specification Section 3.6.6.1 and various licensee documents including SP 24.402.01, Post LOCA Hydrogen recombiner functional test, and SP 44.654.06, Drywell and Suppression Pool Hydrogen Recombiner Instrumentation Channel Calibration.

Safety evaluations prepared by the Architect Engineer (S&W) were not

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directly forwarded to the Nuclear Review Board (NRB).

The licensee issueo procedural changes to the project procedures on 11/10/88 to assure that all S&W safety evaluations are forwarded to NRB. All of the S&W safety evaluations, past and present, have b en forwarded to the NRB for review.

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A material deficiency was identified regarding cable tray material

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supplied by M. P. Husky. This problem was originally identified during installation of the cable trays for the Colt diesels. The licensee identified a similar deficiency for a small number of cable trays within the plant.

Licensee engineering analysis for the various in plant conditions determined that the cable trays are acceptable.

Procedures are in place to require re-analysis of the cable trays if additional cable runs are to be added.

A potential noncompliance was identified between USAR commitments for

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GDC 55, 56, and 57 and plant design documents (flow diagrams) in regard to locked valves.

The licensee's engineering department completed its review

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and issued E&DCRs L 1613, L-1613 and L-1613A. The plant staff has been informed of the, specific valves to be locked. When the valve locking has been completed, station design drawings are to be updated. The licensee is holding'the item open pending locking of the valves and drawing change f

completion.

A managemsnt revi u/ decision is needed on implementing the BWR owners

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group water chemistry guidelines. The licensee presently has station modifications in place to address this issue.

Implementation is encom-

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passed by EEAR 86-173, which is in concurrence and awaiting a finalized.

design change package, and EEAR 84-083, which is to have a finalized design change package by May 15, 1989. This item remains open pending completion of the Station Modification process.

Root cause analysis should be programmatically addressed in more

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depth.

The licensee is presently addressing this area through revising and developing procedures to improve root cause analysis practices. On March 2, 1989, 34 Nuclear Operations personnel completed an initial. formal training course on root cause analysis (given by a contractor). A root

.cause analysis procedure which incorporates training course guidance is currently in the review cycle. This procedure, when issued, will provide the licensee with c formal means of performing and documenting root cause analysis.

Previously, root cause analysis was encompassed under engi-neering dispositions contained in nonconformance reports that led to programmatic deficiencies being identified by both NRC inspection and NED sel f-a s ses:nent.

The pending procedure will be used in support of future LDR (LILCo Deficiency Report) dispositions and root cause analysis deter-minations.

The licensee is also developing a formal program to identify repetitive maintenance and recurring equipment problems.

These initi-atives will be further evaluated during routine inspection.

9.11 Manacement Review Effective management oversight of the Engineering and Technical Support area was evident in the sound design change process and modification program, clear organizational responsibilities. effective communications and interfaces, and program improvement, initiatives through self-assessment. The Interim Station N dification Program Oversight Committee, composed of the Assistant VP-Nuclear Operations, QA Department Manager, NED Department Manager, Nuclear Operations Support Department Manager, and Operations Department Manager, performs integrated review of the Interim Station Modification Program (ISMP).

Based on review of the committee meeting minutes and interviews with committee members, the ORAT concluded that licensee management is effectively involved in identifying weaknesses and making program improvements.

For example, the committee determined that the increasing EEAR and design modification plan (DMP)

backlog needed management attention.

Actions to reduce the backlog include focusing resources in this area and re-evalration of low priority EEARs for possible cancellation through Modification Review Committee review.

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9.12 Open Items The inspectors reviewed past NRC open items related to engineering and technical support and determined that none were required for closure prior to restart.

During the ORAT inspection, the licensee committed to review ASME Class 2 and 3 bolting accomplished since the construction phase (see Detail 11.8), to perforin a root cause analysis of corrective maintenance with three or more occurrences per year (see Detail 5.10), and to review maintenance work requests for misclassified items and items which should be completed before startup (see Detail 5.9).

9.13 Conclusions The inspectors concluded that the licensee's engineering support organization is providing adequate support to plant organizations.

The Interim Station Modification Program has effective modification and configuration controls.

Good working relationships were observed between the various i

organi:ational elements involved in engineering support activities.

Review of the licensee's comprehensive self-assessment and QA audits found effective management oversight and confirmed the licensee's commitment to program improvements. Overall, it was concluded that the engineering support organization is ready to suppcrt safe reactor operation.

However, the licensee needs to restaff vacant nositions to support timely completion of the tech-nology t ansfer and to aduce the EEAR and SMP backlogs.

10.0 POWER ASCENSION TEST PROGRAM (PATP)

10.1 Review Scope The team assessed the licensee's PATP organization, staffing plans, staffing qualification and training plans,_ morale, program change control, management involvement and review, open items and QA/QC. The organization has not been fully staffed because no major PATP testing work can be done until a greater than 5'. power license is issued.

The ORAT assessed the licensee's readiness to implement the PATP when the license is issued.

10.2 Quality Assurance and Control for PATP The team assessed the nuclear quality assurance (NQA) plans and staffing to cover the PATP.

Interviews were conducted with NQA managers and staff.

Training was assessed to verify that expertise was adequate to cover the PATP, and audit and surveillance plans were reviewed.

Quality assurance is tasked with ensuring compliance with the PATP. This is planned to be accomplished through around-the-clock coverage of the ongoing PATP and through audits of the program.

The audits and surveillance will be specific to the PATP.

Regular QA audits and surveillance scheduled in the approved 1989 NQAD Audit Schedule, Revision 1, dated March 3, 1989 and the NQAD 1989 Surveillance Schedule dated February 3, 1989, respectively, also will cover the overall quality assurance commitments for Shoreha.__

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On Merch 10, 1989, the quality control manager approved the " Power Ascension Surveillance Program March 1989" which provides an overview of the intended surveillance to be performed at the various testing plateaus.

The program stipulates 24-hour coverage through the warranty run.

The QAD manager stated that a comprehensive audit of the PATP would be conducted during the 25%

testing plateau and another~approximately three months later to assure that all aspects of the PATP program were in conformance with the quality assurance program. The licensee has also established a procedural requirement to perform an overall self-assessment of the PATP at the approximate midpoint of the program. The ORAT concluded that the above audits and self-assessment are acceptable.

The ORAT verified qualifications for eight surveillance personnel who were being considered for around-the-clock PATP on-shift surveillance assignments.

Seven of these surveillance personnel had completed operations training, including simulator training.

One had previously been trained as an SRO.

Examination modules used for the training were inspected and noted to have in-depth tech-nical content. Tne ORAT concluded that the training and numbers of available NQA staff was adequate and acceptable to support the PATP.

The team also noted that the licensee's corrective action processes were well establ.ished.

Adequate management reports and feedback systems are in place to support the PATP.

The management systems were observed to be functioning well. The team concluded that the existing NQA corrective action processes were adequate.

Overall, the team concluded that quality assurance and control.for the PATP was acceptable.

10.3 Qualifications and Training Licensee procedure 12.075.01, Appendix 12.14 establishes the qualification guidelines for the following PATP personnel.

Test Coordinator

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STD&A Engineer

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Shift Test Engineer

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Appendix 12.16 of the procedure provides a checklist, for certification by each individual's supervisor, documenting that the training requirements have been satisfactorily completed. The LILCo Reactor Engineer approves each completed qualification checklist, which is made part of the permanent plant records. All employees receive General Employee Training (GET).

The addi-tional training provided to PATP personnel consists of a self-study course which includes Updated Safety Analysis Report (USAR) Chapter 14, the General Electric specification for the PATP, Administrative Control Procedure SP 12.075.01, and lesson plans for each PATP test. A PATP examination is to be l

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-60 given to verify that the PATP personnel have satisfactorily assimilated the prescribed training.

To be eligiole to be.in the PATP, the above listed personnel must, as a minimum, have a BS in engineering and be qualified as a level II inspector.

Prior to performing PATP testing, the above training and qualification requirements must be satisfied.

LILCo's requirements and training programs meet commitments in the USAR. The ORAT concluded that the PATP qualification and training are acceptable to support power operation. Also, the ORAT

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concluded that the licensee's management controls adequately assure imple-mentation of the training.

In addition to the above personnel, the team reviewed the qualifications and training of the LILC0 Reactor Engineer and of the nuclear engineers who will be involved in the PATP. Their qualifications and training were found acceptable.

10.4 Morale The team assessed morale through interviews and observations with both LILCo and contractor personnel.

Personnel interviewed had all been involved with the program for more than four years.

All of the personnel expressed

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interest in getting on with the PAYP and confidence that the plant would be operated safely.

Several personnel stated that uncertainty about Shoreham's future had at times had a short-term downward impact on their morale but little or no long term effect. The PATP staff has experienced low turnover, indicating good morale.

Thi ORAT concluded that the morale of the PATP staff was acceptable.

10.5 Staffing Prerequisites for Testing The ORAT assessed staffing in regard to safe performance of the PATP.

LILCo Vas contracted for qualified PATP persorinel with both General Electric (GE) and Stone and Webster (S&W).

The licensee plans to initiate contractor staffing phase-in when the NRC issues the full power license.

During inter-views with the LILCo reactor engineer and the GE Manager, it was stated that two senior GE experienced PATP engineers were scheduled to be added to the staff shortly. This additional staff will be used initially for plant specific training of the other PATP staff to be phased on board.

Discussions with the GE manager revealed that GE has provided the licensee with resumes of qualified i

personnel for selection for PATP staffing.

Sampling ORAT review of those re-sumes concluded that the individuals are well qualified.

The team reviewed the PATP testing schedule versus the PATP staff phase-in with the licensee's reactor engineer. The licensee committed to incorporate required hold points in the PATP schedule based on acceptable staffing for the testing to be conducted.

(LILCo procedure 12.075.01, Appendix 12.9, requires a sign-off that the staffing hold point has been met.) PATP organization charts

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in Figure's 12A through 12G of this report show the trained and qualified staffing required before testing is permitted to progress past the designated hold point.

The licensee also has scheduled a two-week period near the end of the second testing plateau (TC-2) and prior to initiating testing at the third plateau (TC-3)

for a self-assessment of the PATP completed to that time (USAR Figure 14.1.4-1 defines TC-2 and TC-3). This assessment period falls approximately midway through the PATP.

Procedure 12.075.02, Appendix 12.4, requires a sign-off that the re-quired self-assessment has been completed.

Based upon the LILC0 self-established staffing requirement, associated hold points in the licensee;s PATP schedule, and the self-established requirement to perform an overall PATP self-assessment (including assessment of PATP staffing)

near the midpcint of the PATP, the ORAT concluded that the licensee's PATP or-ganization and staffing plans are acceptable.

10.6 PATP Program Change Controls 10 CFR 50.59 permits the licensee tc make changes in the PATP program de-scribed in the Updated Safety Analysis Report (USAR) as long as the changes comply with the regulations.

Such changes rnust not involve an unreviewed safety question or modify the Technical Specifications.

NRC Inspection Report 50-322/89-02 in-spected several changes being made under 10 CFR 50.59 and found them generally acceptable.

In one case, additional information was requested. During the ORAT

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inspection, the licensee provided that information. That information concerned justification for not full-stroke testing the Main Steam Isolation Valves (MSIVs)

quarterly while the plant is at power and for deleting the PATP test which will determine the reduction in power necessary to conduct such testing. The licensee plans to full-stroke test MSIVs only in cold shutdown conditions.

Supporting in-formation included a listing of other BWRs that do not test similar valves at power. Deletion of this PATP test was found to be acceptable. This closes open item 89-02-01.

During this inspection, the licensee issued a change that provides an upc..ted PATP organization description for the USAR. The ORAT concluded that this change is an improvement.

Procedure SP 12.075.01 provides administrative and management controls for j

procedure changes including temporary changes to PATP procedures. The ORAT ob-served several improvements and clarifications being made to procedures during the inspection.

The team also noted licensee willingness to improve procedures. This process was found to be functioning adequately.

Overall, the licensee's change control processes were working effectively.

Management involvement and control were assessed as acceptable.

10.7 Management Resiew Procedure SP 12.075.02, Master Startup Activities List, provides administra-tive controls (including signoffs) for assuring that each major power ascension step receives prior review and concurrence by the Review of Operations Committee

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(ROC) and the plant manager. The licensee has also incorporated a new manage-ment review committee, the Station Management Review Committee (SMRC), into j

procedure SP 12.075.01. The SMRC is chaired by the plant manager and is made

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up of all plant division managers. This committee reviews PATP plateau summary reports to assure overall readiness of all aspects of the plant prior to recom-mending ascension to the-next higher testing plateau.

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The Test Review Corrnittee (TRC) is chaired by the reactor engineer.

It is a standing subcommittee of the ROC.

Its members are key PATP personnel. The TRC is procedurally addressed in SP 12.075.01.

Its purpose is to review and approve test results and test exceptions, and to maintain management oversight and control of the PATP. Meeting minutes are maintained and document the dispositioning of each item presented at the meeting.

The addition of the SMRC provides an added level of assurance of the plan,'s readiness to proceed to the next plateau by bringing all of the plant staff's division managers together for the specific purpose of focusing'on overall readiness.

The ORAT concluded that this added strength to the overall-management review process.

Through interviews with PATP managers, the team further assessed management's plans to control the PATP and concluded that:the licen m 's plans, review processes, and controls are adequate.

10.8 Test Status and Scheduling

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Startup testing,. including open vessel testing and plant testing at up to 5'; power, is complete.

USAR Chapter 14 (see Table 14.1.1-1, Test Conditions 1 through 6), describes PATP testing in detail. Required PATP tests include turbine and bypass valve operational measurements, flux profiles at various power levels, loss of of fsite power, shutdown from outside the control room, high pressure coolant injection, and the warranty run.

LILCo plans to complete the testing over about a five month period.

10.9 Open Items There are no PATP open items.

10.10 Conclusion The ORAT concluded that the licensee's PATP management and procedural controls are adequate.

PATP staffing plans and organizational plans were also assessed as adequate.

11.0 INSERVICE INSPECTION / INSERVICE TESTING PROGRAM 11.1 Review Scope This portion of the ORAT inspection reviewed the extent, quality, and imple-mentation of the licensee's Inservice Inspection (ISI) and Inservice Testing (IST)

programs.

It should be noted that neither program is mandatory until the plant becomes operational.

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The IST program is documented in procedure 12.027.01, ASME Section XI Pump and Valve Inservice Testing Program.

Specific pumps and valves to be tested are listed in 80A2903, Inservice Testing of Pumps and Valves.

That document was developed for the licensee by Nuclear Engineering Services (NES).

It-details all of the components to be tested, the types of tests and the test frequencies.

Implementation of the program is the responsibility of the Systems Engineer, who reports to the Operations Manager. The licensee has been using portions of this program since 1983. Testing has been performed in accordance with procedures that contain the details required. These include signatures for system alignments, prerequisites, signatures for steps completed, and acceptance standards.

Planning and scheduling is performed by systems engineering.

Actual testing is performed by. plant operations.

This assures that qualified personnel are operating the plant equipment. The data collected are analyzed by.both plant operations and the Systems Engineering Group. A trend analysis is performed by the Systems Engineer for each valve. This is done by calculating the ratio of the stroke time for the latest test with the previous one. The licensee implemented the IST program in January 1989.

Inservice Inspection (ISI) Program The licensee's ISI program is described in SP 12.027.02, Revision 1, ASME Code Section XI Inservice Inspection Program. Components to be tested are listed in this program.

Implementation is the responsibility of the Maintenance Engineer, who reports to the Maintenance Manager. The Outage Engineer, who reports to the Outage / Modification Manager, is responsible for coordinating ASME Section XI activities with the Maintenance Engineer and Systems Engineer during outages.

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The Nuclear Engineering Department is responsible for the development,

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control, maintenance, and administration of the ISI program including technical review of contractor submitted documents.

The Nuclear Quality Assurance Department (NQAD) is responsible for performing a quality review of the NDE procedures to be used in the ISI program and for performing inspections during plant operations.

Present staffing (see (

Figure 2) includes one Level III examiner in Penetrant Examination (PT),

Magnetic Particle Examination (MT), and Ultrasonic Test Examination (UT). Two individuals are certified as Level II in PT and MT. One examiner is certified

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as Level II in UT.

One individual is also certified as a level II in Eddy Current Examination. These certifications are for a total of three individuals.

In addition the licensee has one contractor individual certified as Level II in PT, MT, and UT on site.

These individuals are assigned to duties

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that include work at other facilities in the licensee's system, and thereby L

retain an improved working' familiarity with their NDE functions.

11.3 Qualification and Training The inspectors reviewed the training and qualification records for the licensee individuals certified in accordance wit'1 SNT-TC-1A, Recommended Practice for Qualification and Certification of NDE personnel.

For the personnel mentioned above, these training and certification records were acceptable.

11.4 Staff Stability and Morale In the Nuclear Engineering Department, about hcif of the permanent LILCo employees have been working for the licensee more than six years. Many have substantially longer service time.

Some of tne ongoing work was directed toward corporate activities not related to the Shoreham plant. A similar situation existed with the certified NDE examiners.

That use of the staff has provided stability and increased morale by reducing the dependence of these i

individuals on the Shoreham plant being licensed.

Overall, ISI/IST staff stability and morale were evaluated as adequate.

11.5 ISI/IST Program and Procedures The purpose of the ISI program is to verify the condition of the welded connections in the plant and to assure that these connections do not degrade during plant operation.

In general the program requires inspection of welds in each 10 year interval.

The purpose of the IST program is to assure, by regularly scheduled testing, that pumps and valves function as designed.

The licensee's ISI and IST programs have been prepared and submitted to the NRC for approval.

NRC approval is not required prior to startup.

Detailed requirements for both of these programs are found in Section XI of the ASME Code. The licensee has elected to initiate the IST program to assure the operability of equipment.

Detailed IST procedures have been written and implemented.

These procedures are clearly identified by their numbering system as being required by the plant Technical Specifications, or as not so required. To verify the performance of these inspections, the inspectors selected components in the service water system for review and walked down selected parts of this system.

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The "A" service water pump was selected since the licensee had visually iden-

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tified erosion / corrosion of the impeller and bowl on this pump. This degra-dation was visually detected by the Outage Manager while the service water pump bay was drained for cleaning.

Surveillance of the system had previously meas-ured adequate flow but had not checked for a decreasing flow trend. The lic-ensee reevaluated the method of analyzing pump data to assure that degraded pumps would be identified through trend analysis.

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The inspectors determined that the licensee is aware of the specific procedures not completed.

The lice.'see plans to complete these procedures in a timely manner. That was i

found to be acceptable.

11.6 Erosion / Corrosion Program Concern regarding erosion and corrosion in balance of plant piping systems has been heightened cs a result of the December 9, 1986 feedwater line rupture that occurred at Surry Unit 2.

This' event was the subject of NRC Information Notice 86-106 issued on December 16, 1986 and its supplement issued on February.

13, 1987. The ORAT reviewed the licensee's actions with regard to the detec-

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l tion of erosion / corrosion in plant components. The inspection was conducted to ascertain the scope of the licensee's program and the r.esults to date.

The licensee initiated an erosion / corrosion program as a result of the Surry incident and developed the program to include approximately 19 components the licensee determined to'be susceptible to this form of degradation.

The in-itial baseline inspection was performed on four two phase components and 15 single phase components in January 1988.

Tha licensee plans to add an addi-tional single phase elbow and 12 components in the reactor water cleanup system and feedwater drains during the first refueling outage.

The service water system is not in the licensee's erosion / corrosion pro-gram.

Required minimum flow has been maintained in the system.

While the service water bay was drained for cleaning, the licensee visually identified the erosion of the serv'ce water puen impeller and bowl (see Detail 11.5), and has developed an extensive program to eliminate this problem.

Based or dis-cussions with the licensee, the ORAT concluded that the licensee performed an extensive root cause analysis to determine the cause of the corrosion of the pump impellers and bowls. The licensee purchased a new pump having Monel im-pellers and bowls. This pump has been placed in service and the pump that was removed is being rebuilt.

Licensee actions were assessed as acceptable (see Detail 11.8).

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In another pcrt of the service water system, severe corrosion of the disk l

occurred in a four-inch valve. To eliminate this problem the disks were changed from a copper nickel alloy to Monel.

Subsequent to this change the

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pipe wall downstream from the valve was found to be eroding.

The licensee established a program to monitor this erosion and plans to change the alloy in this section of pipe to Monel when the wall thickness reaches a predetermined

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I minimum thickness.

1;.7 Conclusions The ORAT concluded that Inservice Inspection and Inservice Testing Pro-grams are ready for full power operation, and that the as-supplemented staffing is sufficient in numbers and qualifications.

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11.8 Previous Inspection Items (Closed)UnresolvedItem(50-322/88-03-01); Testing and Repairs to Reactor

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Building Service Water (RBSW) Pumps The inspectors reviewed the failure analysis reports and the planned correc-tive actions for refurbishment of the impellers and bowls of the RBSW pumps (see Detail 11.6). These changes have been completed for one of the four pumps and are acceptably in process for the other three pumps. The licensee is providing ac-ceptable assurance of RBSW pump operability.

(0 pen) Unresolved Item (50-322/89-01-01): ASME Code Deficiencies l

This item resulted from licensee Quality Assurance audit findings.

The ori-j ginal issue concerned maintenance replacement of ASME Code Class 2 fasteners in

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Class 1 bolted joints.

All Class 1 bolted joints (except the unique and unaffected fasteners used in the Control Rod Drive Mechanisms) were examined and nonconforming material was replaced. The cause was identified as pro:edural control inadequacies in material issue after completion of plant construction, and licensee investiga-tion was extended to Code Class 2 and 3 systems. The next phase, an intelligent sample of work records and inspections, was completed prior to the ORAT inspection.

Although only one bolted joint (ASME Class 3) was found with non-safety ASTM mate-rial, five were identified with qualified material which differed from that speci-fied.

All questionable, different, or non-safety material has been replaced.

Because of these sampling program findings, the licensee agreed to evaluate all ASME Code Class 2 and 3 bolted joints in which improper fasteners may have been used. The as-described review method is computer screening of maintenance and material issue records. As committed during the exit interview, this re-view is to be completed and corrective action taken, if needed, prior to operation above 5'; power.

The ORAT concluded that the licensee has addressed this issue in a prompt-and thorough manner.

Corrective actions have addressed the cause of the errors and the licensee had taken appropriate action by extending their examination based on prior findings. The item remains open pending completion of the lic-ensee's investigation and of any additional corrective action needed.

12.0 ENVIRONMENTAL QUALIFICATION PROGRAM 12.1 Review Scope

The scope of this inspection was to review the licensee's implementation i

of a program to meet 10 CFR 50.49, Environmental Qualification of Electric l

Equipment important to Safety. The team reviewed the environmental qualification (EQ) controls in the following areas:

Technical Information to support qualifications (EQ Files)

Staffing and Training l

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Modifications

Procurement and Spare Parts

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Preventive and Corrective. Maintenance

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Identification and Tracking of Environmentally Qualified Equipment

Quality Assurance

12.2 Organization, Staffing, and Morale The ORAT reviewed the licensee's organization as it pertains directly to Environmental Qualification (EQ). The Equipment Qualification Engineering Section (EQES) is a part of the Nuclear Analysis Division of the Nuclear En-gineering Department.

The EQES is responsible for maintaining EQ documenta-tion, reviewing EQ requirements and relaying EQ requirements to the Maintenance and Instrument and Control Sections.

The EQES currently consists of a section head, an. Electrical Equipment Environmental Qualification Lead Engineer, and two contractors.

Two vacancies are being filled by contractors.

The licenseo plans-to add two additional contractors in the EQES by the end of April 1989 in order to correct the backlog of EQ file upgrades and revisions.

12.3 Qualification and Training ORAT review of the resumes of the personnel in the Equipment Qualification.

Engineering Section noted that the engineers reviewing and approving qualifi-cation documentation have an average of 8 years of EQ experience.

The ORAT observed understanding'and awareness of EQ among the personnel involved in the development, review, and implementation of the licensee's EQ program.

ORAT review of the licensee's EQ training and qualification program found that the basic qualification was the required reading of EQ related procedures.

LILCo engineering personnel are required to recognize the need for EQ review, but the licensee has not yet implemented a formal EQ training program.

Limited scope training addressing current EQ issues was offered to twenty licensee per-sonnel and contractors on November 9 and 10, 1988.

LILCo has committed to develop and implement a formal training program for personnel involved in engineering, implementation, and maintenance.

The licensee's schedule for personnel who directly supervise and perform plant maintenance calls for offerir.g an EQ training session to begin the week of April 3,1989, and to be completed by the end of the second quarter of 1989.

The licensee's engineering personnel involved in the EQ design and evalu.ation processes will also receive formal EQ training. This will include EQ Engineers, Nuclear System Engineers, Instrument and Control Engineers in the Nuclear Engineering Department, ano Electrical Engineers in the Office of Engineering.

That training will consist of a one-day program that will address regulatory requirements, the qualification process and methodology, qualification maintenance, procurement and materials, and trends in the industry. The licensee's schedule is to select a consultant to perform the training and prepare the lesson plans in the second quarter of 1989, and to complete this training during the third quarter of 1989.

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12.4 Environmental Qualification (EQ) List 10 CFR 50.49 requires the licensee to list the electric equipment im-portant to safety and required to remain functional during and following a design basis event. This includes safety-related equipment and non-safety-related equipment whose failure could prevent the operation of safety systems, and certain post-accident monitoring equipment.

During this inspection the ORAT reviewed the licensee's March 3, 1989 Environmental Qualification Status Report (EQSR) which lists the electric equipment requiring environmental qualification (EQ) in accordance with 10 CFR 50.49. A sample review of the EQSR was performed for the Core Spray (CS)

system. The inspector compared the CS flow diagram to the EQSR and concluded that CS system equipment was identified as required by 10 CFR 50.49.

Discus-sions were held with licensee personnel to review the basis for certain elec-tric equipment not identified in the EQSR.

Licensee personnel provided rea-sonable explanations for the omitted equipment.

Interviews with engineering personnel shows that they were aware of the environmental qualification re-

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i quirements for electric equipment important to safety.

l The ORAT also reviewed logic and elementary diagrams pertaining to the operation of certain environmentally qualified motor operated valves (MOVs).

This limited review to ascertain whether the valves would operate as designed under abnormal plant conditions identified no deficiencies.

i During the review of the EQSR the ORAT interviewed engineering personnel

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responsible for its completeness and control; no deficiencies were identified.

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l 12.5 Temperature Profile Fc Environmental Qualification i

The ORAT reviewed the " Environmental Qualification Report for Class 1E Equipment" dated June 27, 1983.

This document contained the temperature profile used for qualifying EQ equipment for various plant areas.

It provides j

the following drywell temperature profile.

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340F - O to 3 Hrs.

320F - 3 to 6 Hrs.

250F - 6 Hrs, to 1 Day 200F - I to 4 Days 150F - 4 to 8 Days The ORAT also reviewed the the following calculations of pipe break and LOCA temperature profiles: Calculation No. 185, Pressure / Temperature Envelope for Environmental Qualification in the Primary Containment, Revision 1, dated February 15, 1983; and Calculation No. 169, Analysis of Containment Transient Response to a Recirculating Line Break, Revision 2, dated July 25, 1983. The profile provided in these calculations follows.

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340F: 0 - 200 seconds.

305F: 200 - 1000 seconds.

240F:

1000 seccnds - 1 day 200F:

1 day - 8 days.

130F: 8 days - 99 days.

The profile identified in the above calculations is not bounded by the temperature profile in the EQ Report for Class 1E equipment.

For example, the temperature profile from Day 5 to Day 8 indicated 200F (degrees Fahrenheit),

but the EQ profile utilized 150F for the same period. Another short note in Calculation No.185 addressed another 30F increase in temperature.

The NRC Shoreham Safety Evaluation Report, Supplement 3, February 1983, states that there is reasonable assurance that the actual post-accident tem-l peratures and pressures will not exceed the profile used for equipment quali-fication. The noted discrepancy between the calculated temperature and the qualification temperature is not consistent with the Safety Evaluation Report.

i Licensee management committed to develop and su' 4t an updated profile.

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an April 3,1989 telephone discussion with the licensee, the need for resolu-tion of this issue prior to operation above 5% power was identified.

12.6 Environmental Qualification Files and Field Verification l

f 12.6.1 Limitorque Motor-Operated Valves (MOVs)

EQDP #88V-03 is the EQ file for Limitorque MOV Actuators, 460 VAC, Class B

& H, Outside Primary Containment. This file covers approximately 160 MOVs at Shoreham Nuclear Power Station (SNPS).

Environmental Qualification is established to NUREG 0588, Category II.

Test Reports Cited are:

Limitorque TR B0058, Limitorque Valve Actuator Qualification for

Nuclear Power Station Service (January 1980).

Limitorque TR B0003, Qualification Type Test Report, Limitorque Valve

Actuators for Class IE Service Outside Primary Containment (May 1976).

Limitorque TR.B0119, Qualification Type Test Report of Multi-Point Ter-

minal Strips For Use in Limitorque Valve Actuators for PWR Service (July 1982).

Limitorque TR B0212, Nuclear Power Station Qualification Type Test

Report, Limitorque Valve Actuators with Type LR Motors for Westinghouse PWR (April 1985).

EQDP #88V-01 is the EQ file for Limitorque MOV Actuator, 460 VAC, Class RH with containment spray for primary containment applications. This file covers about 49 MOVs located inside the SNPS primary containment.

Environmental Qualification is established to the requirements of NUREG 0588 Category II. Test reports cited are:

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Limitorque TR B0058 (Same as EQDP #88V-03).

. Valve Actuators for BWR Service (May 1976).

Limitorque TR 600198, Test of Limitorque Valve Operator to Meet Require-

ments of a Valve Actuator in Nuclear Reactor Containment Environment (January 1969).

Limitorque TR 600456, Qualification Type Test Report, Limitorque Valve

Actuators for PWR Service, (December 1975).

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The following is a list of significant NRC Information Notices (ins) and concerns applicable to MOVs along with the LILCo response.

IN '83-72 (EQN 24), Environmental Qualification of Terminal Blocks (tbs)

SNPS does not use any terminal blocks (tbs) inside containment and'only Mara-than 300 tbs outside. The licensee provided additional analysis using Arrhenius evaluations to show that the 80119 temperature profile envelopes the plant profile, and that the post-accident operability requirement of 180 days is met. The ORAT l

found this issue to be. adequately addressed.

Mmitorque'Under-Voltage

Limitorque TR B0212, which was used by SNPS primarily to qualify the n3< model Limit and Torque Switch, envelopes the plant parameters and was based on type tests-u using degraded voltage. Additionally, Shoreham specifications (e.g. SHI-88V) re-quire that all MOV motors be sized to operate under all service conditions with terminal voltage variation of 10% above and 30% below nominal for 460 VAC appli-cations, and 10% above and 20% below nominal for 125 VDC applications. This issue is adequately' addressed.

IN 86-02, Magnesium Rotors

One MOV, IE11*MOV047, was identified as having a magnesium rotor.

Following engineering evaluation, the magnesium rotor model was replaced with an aluminum rotor model, along with the actuator gears, to provide valve stroke times-within allowable limits. This plant modification was performed under EEAR 87-017. This issue is satisfactorily addressed.

IN 87-08, Degraded Motor Leads in Limitorque DC Motor Operators

The affected motors were identified in the IN by date of manufacture and serial number.

SNPS checked all procurement records and plant stores and warehouse inventory for both original equipment and replacement equipment and determined there were no suspect DC motors on site. Also, open MWRs were reviewed to ensure that there were no DC operators or motors scheduled for replacement. This issue is close _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ __

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Motor Brakes (Dings Brakes)

Three Limitorques were supplied to SNPS with Dings motor brakes. All three of these MOVs have been replaced with MOVs that do not have brakes. Work was per-formed according to E&DCR/ECR H00035.

This issue is closed.

Grease Relief Valves

Inside primary containment, Limitorque MOVs are required to be fitted with grease relief valves on the main gear housing of the actuator.

Plant walkdown of SNPS by ORAT personnel did not disclose any concerns. This item is closed.

IN 86-71, Limitorque In-Compartment Heaters

LILCo's response to this IN was to have the Architect-Engineer review all MOV wiring diagrams in order to identify those with the heaters connected. S&W found there are r.o Environmentally Qualified MOVs at SNPS with electrically energized compartment heaters. This issue is closed.

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Dual Voltage Motors

There has been a general concern that Limitorque MOV dual voltage (230/460V)

motor winding terminations and splices, i.e., the " nylon insulated wire joints" present in some Limitorque MOVs were not traceable to a qualification test. The plant walkdown performed by NRC personnel at SNPS showed these splices to be the environmentally approved "0konite" type. This issue is closed.

T-Drains

Some of the MOVs at SNPS inside primary containment do not have T-drains.

Those MOVs are qualified by Limitorque TR 600198 for the DBA (temperature transi-ent) and by 600376A for radiation, aging, etc. Although these test reports envelope the specific plant parameter, the ORAT questioned the licensee position on NUREG 0588 Section 2.3 (4), which states:

" Category II - Applicable to Equipment Qualified in Accordance with IEEE Std. 323-1971. The staff considers that, for vital electrical equipment such as penetrations, connectors, cables, valves and motors, and transmitters located inside containment or exposed to hostile steam environments outside contai:1 ment, separate effects testing for the most part is not an acceptable qualification method.

The testing of such equipment should be conducted in a manner that subjects the same piece of equipment to radiation and the hostile steam environment sequentially."

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i The licensee presented information to the ORAT to support their position that the installation is qualified. That information relied upon testing which checked radiation and steam environmental qualifications separately.

Subsequent to the ORAT inspection, NRC review concluded that the licen-see's data does not resolve the T-drain issue. Multiple test reports can be used when particular performance data is missing, if the tested specimens have undergone similar preconditioning.

In this case, TR 600198 cannot be used to support the absence of a T-drain because the test specimen was not precondi-tioned by radiation aging.

During an April 3,1989 telephone discussion, the licensee was informed that this matter requires resolution prior to operation above 5% power. On

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April 4,1989, the licensee committed (LILCo letter SNRC 1576) to install T-drains in the valves in question before plant startup.

12.6.2 MOV Field Inspection The ORAT conducted a physical inspection of Limitorque MOVs to determine if their installed configuration was the same as that described in the licen-

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see's documents. The following MOVs were inspected:

IE11*MOV053

1E11*MOV039B

1E41*MOV038

1E41*MOV047 (located inside the drywell)

1E31*MOV031A (located inside the drywell)

During the inspection of MOVs E41*MOV038, E41*MOV047, and B31*MOV031A, the ORAT noted that divider plates were installed between the horizontal trains of the geared limit switch. The licensee stated that these were PVC coated aluminum plates installed, during construction, to provide Class IE/non-1E

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electrical separation in accordance with IEEE 384-1974 and Regulator'( Guide 1.75 Revision 1.

The licensee has described this intent in the SNPS v6AR.

However, during physical inspection of B31*MOV031A, the inspectors observed an example where a spare non-1E cable was bundled with IE cable, negating the possible benefits that the divider plate could provide. There are 16 MOVs with this divider plate configuration inside the drywell and 115 such MOVs in the reactor building. According to the licensee's EQ test reports, the configuration with the divider plate between limit switch cams has not been tested for operability in a harsh environment.

During the ORAT inspa-+1on, no analysis or evaluation was produced to document the licensee's pos.ii.1 that the installed divider plate

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i would have no effect on the environmental qualification of the MOV. Therefore,

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there were no documents provided establishing the environmental qualification i

of the MOVs in accordance with 10 CFR 50.49.

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On March 27, 1989, the licensee provided an analysis to support the

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acceptability of these plates in the EQ application and committed to conduct a

full EQ test by May 1989.

The ORAT acknowledged that a qualification test may confirm acceptability of this configuration.

However, proof of qualification must be concurred in by the NRC before power operation. On March 30, 1989., the licensee proposed replacing the covers for MOVs in the Drywell with the original, test qualified configuration, with MOV qualification outside the Drywell to be based on the analysis. After discussion with NRR project management, the-licensee was informed that such an approach, if supported by 10 CFR 50.59 review, was acceptable.

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The team also noted the installation of torque switches made with Melamine in MOV B31*MOV031A.

These torque switches were identified by Limitorque as representing a common mode failure resulting from long-term post-mold sht 4kage due to' operation at elevated temperatures.

LILCo was notified of this in a limi-torque-supp'ied 10 CFR 21 notification of SMB-000 and 00 actuator defects in j

November 1988.

This notification indicated that this deficiency could effect the valve's ability to perform its intended function.

In its notification, Limitorque recommended that all Melamine torque switches be replaced as soon as possible.

The licensee evaluated this notice during the ORAT inspection and l

identified 18 Limitorque actuators installed with the subject torque switch.

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LILCo has concluded that the failure of the actuators before the first refuel-

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ing outage is highly unlikely due to the failure being age-related fatigue at elevated temperature (above 120 F), with the Shoreham plant temperature being

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well below 120 F to date. Therefore, the Melamine type torque switches will be i

replaced at the first refueling outage, or eighteen months, whichever comes l

l first. The ORAT concurred.

The inspectors noted during the physical inspection that, as documented in the licensee's EQDPs, there were no terminal blocks installed in the MOVs. All field connections observed were noted to be made using Okonite taped splices or Raychem heat shrink tubing.

These installations are acceptable.

The inspectors observed three (3) unidentifiable wires installed in MOV

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1E31*MOV031A. These jumper wires did not have any positive markings traceable to environmental qualification.

Through the review of MOV wiring diagrams, the jumpers were identified as SNPS field installed.

The licensee stated these jumper wires were environmentally qualified because they have procured only qualified wire at SNPS and therefore the observed wires were EQ qualified.

NRC inspection in 86-13 previously identified the presence of unqualified wires in MOVs.

Subsequent to this finding, the licensee had performed a 100% walkdown of all environmentally qualified Limitorque MOVs.

The inspection attributes were as follows:

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If wiring was vendor installed, positively identify by makings as qualified or replaced with one (1) or four (4) types of SNPS environmentally qualified wires.

(b)

If wiring was field installed, identify markings by physical comparison with samples of four types of station EQ wires.

The NRC team reviewed procurement and installation records to verify that the subject jumper wires were environmentally qualified.

Review of these records concluded that these wires were qualified for their use inside the d rywe l l.

12.6.3 Electrical Penetrations The inspectors reviewed Environmental Qualification Documentation Package (EQDP) 445-01 Rev. 4, Electrical Penetrations, and found the package to be auditable.

References were clearly identified and attached, or were easily retrievable.

EQDP 456-01, Revision 4, contained positive statements by the licensee that the equipment is qualified for its application and a qualified life was established as required. The inspector reviewed the test report supporting documentation in ECDP 4546-01, Revision 4, and found no discrepancies.

The inspector also noted that the documentation had been reviewed and approved as required by the licensee's Nuclear Engineering Department Procedure 3.01, Revision 1, The Preparation and Revision of Electrical Equipment EQDPs.

During this inspection the inspector noted revisions made by taping pieces of paper into EQ Documentation Package 129-02 Rev. 1, Coaxial and Triaxial Cable Specification SH1-129.

Due to the possibility of the tape not sticking and the revised information being lost, the team qu- 'ioned this practice.

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licensee indicated that this was an isolated occurrence and that the file was in the condition as received from Stone and Webster, the originators. The inspector brought this to the attention of the licensee's Quality Assurance Audit Section Supervisor.

The inspector had no further questions.

12.6.4 Rosemount Transmitters During the field walkdown conducted during this inspection, the ORAT found an environmentally qualified pressure transmitter, E41*PT001 (series 1152),

with its side covers not properly torqued. The inspector reviewed the licensee's EQ program maintenance practices for these transmitters.

LILCo procedure SP 12.020.01, Revision 1, Environmental Qualification Program, Section 8.3 dated February 9, 1987, requires the files to be reviewed by the Nuclear Engineering Department for maintenance and surveillance requirements.

It also requires excerpts of relevant information to be compiled and distributed to station Maintenance and Instrumentation and Controls (I&C) sections.

These excerpts are then required to be used to make entries into the Preventive Maintenance (PM) Progra __

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The inspector then reviewed the Rosemount Alphaline Transmitter Calibration Procedure, SP-46.001.04,-Revision 5, and noted that the licensee had not previously identified EQ requirements for series 1152 transmitters,'and did not specify which revision of the referenced vendor instruction manual was to be used.

Station procedure change notice (SPCN) to SP-46.001.04 dated March 17, 1989 addresses these concerns.

In addition, the licensee has orally instructed I&C personnel to refer _ to the following I&C documents that distinctly identify EQ equipment for special attention during maintenance.

Analog Instrument Calibration Data Sheet.

  • Instrument Malfunction and Calibration History.
  • These actions are a result cf the licensee's findings in Nuclear Quality Assurance Audit No. 89-01 dated January 31, 1989.

However, the corrective j

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actions were followed through only for Rosemount 1153 models and not for the 1152 models.

The licensee promptly completea these follow-up actions for_the

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1152 models.

In addition, the licensee has taken the following steps to assure that the j

l qualified configuration is maintained when performing routine maintenance on environmentally qualified equipment.

The licensee has initiated SPCNs to include the torquing requirements

and requirements to change head cover 0-rings in all survt illance and preventive maintenance (PM) procedures requiring the covers of Rosemount 1152 and 1153 transmitters to be removed. The 0-rings for all 1153

transmitters that have been serviced since their initial installation have

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been replaced and their covers torqued.

PM scheduled activity worksheets l

(SAWS) that calibrate Model 1153 transmitters have been revised to include EQ requirements, and the PM SAWS for Model 1152 transmitters are be revised in a similar manner.

To determine if there were other areas where similar problems could

exist, the licensee performed a sample inspection of five EQ documentation packages, including Barksdale and Static-0-Ring pressure switches, NAMCO position switches, PYC0 temperature elements, and Barton pressure i

indicating switches.

These were found acceptable.

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i The licensee stated that they found no EQ requirements which would be com-

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promised during routine maintenance. The inspector had no further questions.

12.6.5 IE Information Notices j

i The inspector reviewed the licensee's response to IE Information Notice No. 84-68, identified as NAD-88-2539 Revision 1 dated November 9, 1988.

In-formation Notice No. 84-68 describes a potential deficiency with improperly rated field wiring to solenoid-operated valves (S0Vs). The inspector reviewed EQ Documentation Package (EQDP) 232-01 Rev. 9 on ASCO SOVs and EQDP S1554-2-01, Revision 5 on VALCOR SOVs.

The inspector found the notice addressed in the ASCO file, but did not find the notice addressed in the VALCOR file. The licensee's response to the notice identified 24 VALCOR SOVs with a revised

_ _ _ _ _ - _ _ -

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f qualified life. Although the notice had been properly addressed and the new EQ requirements were forwarded to Ma'.ntenance, the revisions required to the EQDP

'

S1554-2-01 data files had not' beer completed.

The licensee's EQ Engineering Section has an informal tracking system in place for EQDP updates.

In order to help reduce the backlog, the licensee has initiated the temporary hiring of two additional contractors. The licensee also stated i. hat the tracking system would be formalized _to require the proper review and approval as currently implemented for the EQDPs. The licensee has established and implemented a mechanism for addressing information notices relating to equipment requiring environmental qualification.

The inspector had no further questions, j

12.7 Procurement and Spare Parts The team reviewed the licensee's procurement procedures and guidelines implemented to procure replacement and spare parts.

The following procedures were reviewed:

SP 12.019.01, " Procurement of Parts. Materials, Components and

Services."

NAD Guideline A-2, " Shelf Life Program."

  • NCMC Guideline 5.4, " Assignment of. Shelf Life."
  • NED 4.01, " Procurement Control."

,

.

These procedures and guidelines were reviewed to determine if the licensee's procurement program addressed EQ requirements.

In addition, the method of determining the shelf life of procured environmentally qualified components was also reviewed.

Presently, the licensee uses four methods of procurement: Specification, Catalog, Commercial Quality and Verification.

These methods are used to procure both safety and non-safety components. A Nuclear Quality Assurance Audit (89-01) performed in January 1989 identified this procurement process as not being consistent with current industry practice. The licensee is revising their procurement process and is awaiting the approval of the revised program procedure.

The revised program will establish procurement through

" specification" and "non-specification" methods. The specification method is used to purchase safety-related goods and services.

The inspector reviewed procurement records for several environmentally qualified components to verify that appropriate EQ requirements were specified.

The following procurement packages were reviewed:

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_ - _ _ _ _

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.

77.

Purchase Material and'

Order No.

Stores No.

Description 391721 73*50-5302 Namco Limit Switch Cover Gaskets 392137 72*84-0149 Limitorque 0-Ring 395241 72*84-0044 Limitorque 0-Ring 392181 73*72-5009 Rosemount Transmitters 384848 73*72-5027 Rosemount Transmitters The above documents specified the EQ requirements that the procured

!

components must meet for acceptance.

These requirements included conformance i

to IEEE qualification standards and qualification test reports to meet NUREG 588 Category I as required by.10 CFR 50.49.

In' addition, the procurement documents requested shelf life information from the vendor to assure that, when i

a component is installed, its qualification is not compromised.

If the vendor did not specify the component's shelf life, the licensee assigned one based on

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the known composition of the component material in accordance with industry standards and practices.

The licensee has an established program to prevent the~ issuance of any component whose shelf life has expired.

12.8 Electrical Conduit Seals

,

!

The ORAT reviewed licensee EQ file 3915 Revision 6, for Model 1152 Rosemount Transmitters.

The summary evaluation section of this file stated

" Wire passage through the conduit entrance must be sealed in such a way as to maintain the (transmitter) enclosure integrity under the required service conditions."

The ORAT inspected Rosemount Transmitter installations for the above attribute, including transmitter E41*PT001. The Rosemount'Techr.ical Instruc-tions manual issued in June 1978 delineates the need for installing a seal to avoid moisture accumulation into the Rosemount housing.

LILCo had not in-stalled a seal at the wire entrance to the transmitter.

Instead, the licensee chose to seal the conduit at the beginning of the conduit section-That con-l duit's length could be up to 100 feet.

This long conduit run with joints is not designed to be water proof. That approach may permit moisture intrusion into the transmitter.

(The licensee had considered the extended conduit runs with unions and' elbow fittings on the conduits to be water tight.)

The ORAT was later informed that the potential problem on conduit seals, is applicable to all SNPS Rosemount Transmitter installations. The qualifica-i tion of this configuration cannot be established based on the current licensee l

records.

On March 27, 1989, the licensee committed to install a qualified conduit seal at all the required locations by April 15, 1989. This item is to be completed before operation above 5% power.

12.9 Modifications The inspector reviewed the licensee's procedures for plant modifications to ensure EQ requirements are properly addressed.

LILCo's Nuclear Operations Corpor-ate Policy Number 3, Revision 3, identifies the organizational responsibilities

_ _ - _

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l

and interfaces established for Nuclear Station Modifications.

The licensee's program description, PD-NE-01, Revision 5, Nuclear Organization Interim Man-agement Control Program for Station Modifications, includes the interface with the EQ group.

The licensee generates modifications through the following methods.

1)

Design Output Package (LILCo)

2)

Engineering Change Report 3)

Design Output Package (Architect-Engineer)

Procedure NE-01-02 Revision 5 on preparing design change packages addresses the handling of EQ requirements.

These methods require that the EQ Engineering Section review all changes that are related to environmentally qualified equipment.

In addition, Office Engineering and the Nuclear Engi-neering Department provide independent review of Station Modifications. The modification generation and independent review processes were assessed as adequate to identify the need for EQ review.

EQ training scheduled for 1989 should further assure adequate attention for EQ related modifications.

12.10 Maintenance The process of incorporating new information regarding Environmental Qualification into the SNPS maintenance program is contained in four Shoreham procedures:

1.

Procedure NAD 5.01, Review of Environmental Qualification Document i

Packages to Determine Installation, Maintenance and Surveillance Require-ments, dated 2/20/87.

2.

Procedure SP 41.007.01, Implementation of Environmental Qualification Requirements - I&C, dated 4/22/88.

3.

Procedure SP 31.004.01, Implementation of Environmental Qualification

!

Requirements - Maintenance, dated 7/28/87.

)

4.

Procedure SP 12.020.01, Environmental Qualification Program, dated 1/16/87.

Procedure NAD 5.01 describes the process of review by the Nuclear Engi-neering Department (NED) of EQ Documentation Packages (EQDPs) to determine any

,

installation, maintenance, and s-surveillance requirements and of communication of these requirements to the Shoreham Operation Department for implementation.

Information incorporated into the EQDP can originate in the NED, with the vendor, or from other sources such as NRC Information Notices.

Procedure 41.007.01 is utilized once the engineer in charge of the EQDP determines that maintenance action is necessary to maintain Environmental Qualification.

Tr.e procedure is used to provide a detailed method for station personnel to input the Environmental Qualification Program Requirements into the Station Preventive Maintenance (PM) Program.

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Procedure.31.004.01 is used once the the EQ program requirements have been l

input to the PM. program.

This procedure provides a method for incorporating

'

scheduled maintenance activities on EQ Equipment into the PM Program.

Procedure 12.020.01 is used, in part, to alert station personnel that a normal PM on a subject piece of equipment may involve special handling in order to maintain EQ.

Section 8.3.3 states "(These excerpts)...shall be used as guidance to make data entries into the PM Program by the Maintenance and In-strumentation and Controls section.

This is necessary to alert supervisors and technicians of any special requirements or controls necessary to maintain the subject equipment as environmentally qualified."

It is.the ORAT's conclusion that SNPS procedures incorpm e maintenance

!

requirements necessary to maintain EQ of equipment.

Limitorque Lubrication Limitorque geared limit switch assemblies and actuator main gear cases are l

inspected and lubricated (if required) every 24 months per Limitorque Instruction I

'

and Maintenance Manuals SM31-170, L016.320.01 and A43-96, 97.

The geared limit switch is lubricated with Beacon 325, made by Exxon.

The main gear case is lubricated with Exxon Nebula EP-0.

Grease re-mixing and parts coating is accomplished by cycling the MOVs quarterly.

The lubrication procedures at SNPS are adequate.

Both Beacon 325 and Exxon Nebula EP-0 are approved for l

their respective uses in Limitorque MOVs at SNPS.

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12.11 Conclusions Although several items require resolution, the licensee has established the essential aspects of an Environmental Qualification program to comply with 10 CFR 50.49.

Administrative controls are in place to retain the qualification of EQ equipment.

The engineering modification procedures, and the maintenance and surveillance procedures in the Electrical and I&C area, specifically iden-i tify the need for incorporating and retaining EQ requirements.

The upgraded

requirements for retaining the material characteristics of environmentally qualified components during procurement, storage and retrieval are specifically addressed. ORAT sample checks of equipment and records concluded that the licensee's EQ program is sound.

13.0 PHYSICAL SECURITY An operational security program has been in effect at Shoreham since the 5*; license was issued.

The licensee's security programs were not separately assessed as part of the ORAT inspection. A routine, region-based inspection of the security programs was conducted from February 13-16, 1989, with associated Inspection Report 50-322/89-03 being issued on March 13, 1989. The inspection reviewed adequacy of management support,' security program plans and audits, protected and vital area physical barriers, detection and assessment aids, access controls (per onnel, packages and vehicles), security hardware systems,

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_

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maintenance and compensatory measures, security training and qualifications,

and other safeguards information.

The inspection found the licensee's programs T

in full compliance with NRC requirements.

14.0 ONSITE EMERGENCY PLANNING NRC inspection of onsite emergency planning was completed on March 20, 1989.

No inadequacies were identified.

Inspection results are documented in Report 50-322/89-04, issued on March 31, 1989.

15.0 ALLEGATIONS 89-22.

This allegation involved anonymous assertions that several persons are habitual drug users and that certain supervisors knew or should have known of the problem.

Four personnel were named in the allegation.

It was also alleged that drugs were being used onsite.

LILCo was notified of the allega-tion.

The licensee tested the named individuals on the same day the allegation was received and orally informed the NRC that the test results were negative for illegal substances. ORAT and other NRC inspector checks have found per-sonnel to be performing properly.

During the ORAT inspection, the licensee

,

informed the Shoreham resident inspector that the protected area had been

!

searched by a trained drug-sniffine dog, with no drugs being detected.

Formal

'

closure of this item awaits review of licensee documentation, but no safety issue is outstanding.

89-5.

This allegation was received with allegations about another facility.

It was alleged that Neutron Monitoring System connectors were purchased from Radio Shack and that the same problem might exist at Shoreham.

The Shoreham licensee was asked to produce evidence of Nuclear Instrumentation (NI) connector compliance with specifications.

During the ORAT inspection, the licensee produced purchase order documentation showing purchase of NI connec-i tors from the Nuclear Steam Supply System vendor (the part specifier) in one

!

case and from an electronic parts supplier in another.

The licensee identified these two sources as the only suppliers of Neutron Monitoring System.

Con-nectors procured in both cases were to the same General Electric part number.

Connectors from both purchase orders were produced by the licensee.

The parts were similarly bagged and labeled. No lack of control was evident.

In both cases, the connectors' manufacturer was identified as Allied Amphenol Products, RF Connector Operations, Danbury, Connecticut. The allegation that nuclear instrumentation connectors at Shoreham might have been purchased from Radio Shack was unsubstantiated.88-112.

This itcm alleged inadequate General Employee Training.

Resident inspector follow-up (Report 50-322/89-01) found it to be unsubstantiated.

Formal closure is pending.

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i FIGURE 1 SHOREHAM MANAGEMENT ORGANIZATION A. EARLY (4/1/89)

j PRESIDENT & CHIEF

]

OPERATING OFFICER I

<

J. LEONARD VICE PRESIDENT, NUCLEAR OPERATIONS i

S. SKORUP$Kl, ASSISTANT W. STEIGER, ASSISTANT J. NOTAR0 (SRO)

VICE PRESIDENT AND VICE PRESIDENT, MANAGER, NUCLEAR TRAINING DIRECTOR NUCLEAR OPERATIONS QUALITY ASSURANCE C. DAVIERO, MANAGER, J. SCALICE (SRO)

R. KASCAK, ACTING NUCLEAR OPERATIONS PLANT MANAGER NUCLEAR ENGINEERING SUPPORT DIVISION DEPARTMENT MANAGER M. HERLlHY (SRO)

-

OPERATIONS STAFF DIVISION MANAGER

=

-

(VACANT)

L. LEWIN N. DIMASC10 R. PURCELL (SRO)

'

OPERATIONS MANAGER MAINTENANCE DIVISION RADIOLOGICAL CONTROLS OUTAGE / MOO!FICATIONS M. CASE (SRO), ACTING MANAGER DIVISION MANAGER DIVISION MANAGER SRO s LICENSED SENIOR REACTOR OPERATOR i

l r

.

..

.

_ _ _ _

.

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FIGURE 2: SHOREHAM NUCLEAR QUALITY ASSURANCE DEPARTMENT J. NOTARD (SRO)

NUCLEAR QUALITY ASSURANCE DEPARTMENT (NQAD) MANAGER W. MALONEY C. SEAMAN C. SCOTT QUALITY CONTROL QUAL %TY SYSTEMS SAFETY ENGINEERING AND MANAGER MANAGER RELIABILITY MANAGER CLERICAL: 2 + 1 (C)

ASSISTANT: 1 RELIABILITY SECTION

-

-

-

3 + 2 (C)

ENGINEER IN TRAINING: 1

,__

OPERATIONAL ASSURANCE QUALITY ENGINEERING NUCLEAR REVIEW BOARD

--

SECTION: 3 + 2 (C)

--

SECTION

--

STAFF ENGINEER IN-TRAINING: 1 1 + 2 (C)

1 + 1 VACANCY INSPECTION SECTION:

PROCUREMENT SECTION INDEPENDENT SAFETY

-

7 + 5 (C)

-

3 + 1 (C)

-

ENGINEERING GROUP 5 + 1 VACANCY

-

NONDESTRUCTIVE AUDIT SECTION

--

EXAMINATION SECTION:

--

2 + 3 (C) + 2 (V)

5 + 1 (C)

- - -

QUALITY ANALYSIS SECTION LEVEL !!!: PT, 1; MT, 1, 2 + 2 (C)

UT, 1.

CLERICAL: 4 + 2 (C)

LEVEL 11: PT, 2; MT, 2; ECT, 1.

ECT = EDDY CURRENT TESTING ON BOARD: 66 (includes contr6ctors (C))

MT s MAGNETIC PARTICLE EXAMINATION AUTHORIZATION: 63 PT = PENETRANT EXAMINATION NET VACANCIES (V) = 3 UT = ULTRASONIC TESTING

.....

_ _ _ _. _ _ _ _ _ _ _ _ _

i a

e FIGURE 3 SHOREHAM NUCLEAR TRA]NING S. SKORUPSKI DIRECTOR OF TRAINING i

-

SECRETARY: 1 l

(CONSULTANT)

D. TERRY J. JONES I

OPERATIONS AND SIMULATION PRODUCTION TRAINING TRAINING SERVICES TRA!N!NG MANAGER MANAGER MANAGER OPERATOR TRAINING TECHNICAL TRAINING ADMINISTRATIVE t

-

MANAGER: 1

-

MANAGER: 1

-

SUPERVISOR: 1.

CLERK: 1 CLERK: 1 CLERKS: 4 + 6 (C)

__

PERFORMANCE MEASUREMENT SRO/R0 TRNG: 6 + 2 (V)

SCIENCE: 4 + 2(C) + 1(V)

-

SUPERVISOR: 1.

OPERATOR TRNG: 3 + 1 (V)

!&C: 6 + 2(V)

TECHNICAL: 7 +1(C) +1(V)

FACILITIES SERVICES TRAINING COORDINATOR: 1

-

MANAGER: 1 MAINTENANCE TRAINING Engineers 1 (V)

-

MANAGER: 1 Info Coord: 1(C)

)

CLERK: 1 Clerks: 6

_

SIMULATOR: 1 SUPERVISOR Instructors: 2 + 1 (C)

WELDING: 3 + 1(C) + 1(V)

PROGRAM DEVELOPMENT

!

Ops Support: 5 + 1 (V)

MECHANICAL: 5 +3(C) +1(V)

-

SUPERv!SOR: l'

MAINTENANCE ENGINEER: 1 ELECTRICAL /NUC: 3 + 2 (V)

l Software: 1 (V)

Engineer: 2 (V)

SPECIALIST: 1 + 1 (V)

TECHNOLOGIST: 3 + 1 (V)

ARTIST: 2 ADMINISTRATOR: 1 (V)

LILCo + CONTRACTORS (C) = 93 VACANCIES (V) =......... 19

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e i

i FIGURE 4 SHOREHAM OPERATIONS DIVISION l

l (VACANT)

OPERATIONS MANAGER

,

M. CASE (SRO), ACTING l

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8. BEYTIN (SRO)

M. CASE (SRO)

R. JOENGBLOED (STA)

SYSTEMS ENGINEER OPERATING ENCINEER REACTOR ENGlHEER I

--

SHIFT ADVISORS: 6 LILCo ENGINEERS: 5 (CONTRACTORS)

LILCo PERFORMANCE ENGS: 1 CONTRACTOR ENGs: 4 PERF ENG VACANCIES: 1 LlLCO ENG !N TRNG: 1 NUCLEAR ENGs: 2 (STAS)

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NUC ENG VACANCIES: 1 PLANT ENGs: 2 (SRos)

WATCH ENGs: 9 SRos STAS: 4 PLANT ENG VACANCIES: 1

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OLERKS: 5, + 1 VACANCY STA TRAINEES: 2 ENG !N TRNG: 1 WATCH SUPVs: 6 SR0s STAFF SPECIALIST: 1 OPERATORS: 6 Ros, 1 SR0 ASST OPERATORS: 12 Ros EOs: 6 Ros, 23 Eos EO TRAINEES: 1 EO TRAINEE VACANCIES: 3 ENG = ENGINEER R0 = LICENSED REACTOR OPERATOR SUPV s SUPERVISOR SRO = LICENSED SENIOR REACTOR OPERATOR TRNG s TRAINING E0 = PLANT EQUIPMENT DPERATOR STA = SHIFT TECHNICAL ADVISOR

.

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FIGUSE 5 l

$HOREHAM NUCLEAR ENGINEERING DEPARTMENT l

R. KASCAK, ACTING NUCLEAR ENGINEERING DEPARTMENT MANAGER

_-

E. MONTGOMERY J. RIGERT, ACTING H. CHAU W. TUNNEY NUCLEAR PROJECT

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NUCLEAR SYSTEMS DIVISION

--

ENGINEERING ASSURANCE

---

NUCLEAR FUEL DlV!$10N DIVISION MANAGER MANAGEP

.IVISION MANAGER MANAGER I

MECHANICAL: 1 MECHANICS: 1 ENG ASSURANCE: 1 FUEL ENGINEERING: 1 Projects: 2 + 2 (V)

Stress Analysts: 6 Eng: 1 + 1 (C) + 2 (V)

Eng: 2 Design: 1 (V)

Simulator: 1 SYSTEMS ENGINEERING: 1 ENG CONTROL / TRAINING: 1 CORE ANALYSIS: 1 (ACTING)

Fire Protection: i Eng: 4 + 4 (C) + 1 (V)

Eng/ Asst: 2 + 1 (V)

Eng: 2 + 2 (V)

ELECTRICAL /l&C: 1 PROCESS ENGINEERING: 1 Clerical: 9 + 2 Temps Projects: 2 + 1 (C)

Eng: 5 ENGINEERING SERVICES: 1 NUCLEAR I&C: 1 Management Systs: 1 (C)

Eng: 5 + 1 (V)

Flanning: 1 (V)

SCS: 1 (V)

Contracts: 1 Technical Asst: 1 E. STERGAKOS R. CROWE &

R. PACCIONE RADIATION PROTECTION

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NUCLEAR ANALYSIS DIVISION DIVISION MANAGER MANAGERS RADluCHEMISTRY/REMP: 1 SAFETY ANALYSIS: 1 Eng: 2 + 1 (C)

Thermal /Hyd: 4 + 1 (V)

HEALTH PHYSICS /ALARA: 1 MATERIALS ENGINEERING: 1 Eng: 1 + 1 (V)

Metallurgy: 1 + 1 (V)

ANALYSIS: 1 PRA/ RELIABILITY: 1 (V)

Eng: 2 + 1 (C) + 1 (V)

Eng: 1 + 1 (V)

EQUIP QUALIFICAfl0N: 1 Engineers: 1 + 2 (C)

Spares: 3 + 2 (C)

Tech Asst: 1 C = CONTRACTOR ON BOARD: 101 SITE VACANCIES (V): 18 ACTUAL AUTHORIZATION: 114 + 6 OVERHIRES S&W SITE ENGINEERING: 60 ENGINEERS LILCo MELVILLE OFFICE: 61 ENGINEERS

..

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l

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FIGURE 6 SHOREHAM NUCLEAR OPERATIONS SUPPORT DEPARTMENT (NOSD)

C. DAVERIO, NUCLEAR OPERATIONS SUPPORT DEPARTMENT MANAGER R. GUTMAN, ASSISTANT NOSD MANAGER L. BRITT J. DOWD R. SHERON D. CROCKER LICENSING & REGULATORY

---

CONTRACTS AND MATERIAL

--

FINANCIAL SERVICES

---

EMERGENCY PREPAREDNESS AFFAIRS DIVISION MANAGER CONTROL DIVISION MANAGER DIVISION MANAGER DIVISION MANAGER v.,

LICENSING: 5 + 1 (C)

CONTRACTS: 3 + 2 (V)

ADMIN: 12 + 3 (V)

0FFSITE: 15 + 12 (f)

REG: 9 + 2 (C)

INVENTORY MGMT: 1 + 1 (C)

BUDGET: 5 + 1 (V)

ONSITE: 7 + 2 (C)

I PROCUREMENT: 2 COSTS: 6 + 2 (V)

MAT'L: 34 + 3 (V)

RECORDS: 27 + 5 (V)

K. KING, ACTING SITE SECURITY MGR

-

13 + 1 (V)

C = CON 1R ACTOR ON BOARD: 164 AUTHORIZATION: 146 VACANCIES: 17 l

l l

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_ _ _ _

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FIGURE 7 SHOREHAM OPERATIONS STAFF DIVISION M. HERLIHY (SRO)

OPERATIONS STAFF DIVISION MANAGER R. GRUNSEICH P. QUINAN T. MAUGERI COMPLIANCE ENGINEER FIRE PROTECTION / SAFETY ADMiklSTRATIVE SUPERVISOR COORDINATOR

-

PLANT ENGINEERS: $

ASSISTANT FIRE CLERICAL STAFF: 42 SUPERVISOR: 1 + 1 (V)

FIRE SAFETY TECHNICIANS: 10 HAZARDOUS MATERIAL COORDINATOR: 1 (C)

C = CONTRACTOR SRO = LICENSED SENIOR REACTOR OPERATOR V = VACANCY l

_ - _ _

_ _-_

,

,

'.

l

l l

l l

FIGURE 8 SHOREHAM SITE MAINTENANCE DIVISION L. LEWIN (GE-SRO)

MAINTENANCE MGR L. BIELER, ACTING

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SUPERINTENDENT, BUILDINGS AND GROUNDS M. POTKIN (GE-SRO)

R. WE! MAN S. KRUPSKI T. CARRIER MAINTENANCE ENGINEER COMPUTER ENGINEER CONTRACTED MAINTENANCE I&C ENGINEER SUPERINTENDENT

--

IS! ENGINEER: 1 (C)

ENGINEERS: 2 MECHANICAL SUPERVISORS: 2 ENGINEERS: 3 + 3 (C)

PLANT ENGINEERS: 6 FOREMAN: 1 + 1 (V)

ELECRICAL SUPERVISOR: 2 STAFF SPECIALIST: 1 WELDING SUPERVISGR: 1 TECHNICIANS: 7 + 3 (V)

STRUCTURAL SUPERVISOR: 1 STAFF SPECIALIST: 1 RMS SPECIALIST: 1 ADMIN ioPERVISOR: 1 I&C SUPV: 1 (ACTING)

MAINTENANCE SUPERVISOR: 1 LAB TESTERS: 2 MAINTENANCE FOREMEN: 4 TECHNICAL ASSis: 2 (V)

MA!NTENANCE MECHANICS: 17 FOREMEN: 2 MAINT MECH VACANCIES: 2 FOREMEN LOANED OUT: 2 MECHAN!CS "B" : 21 TECHNICIANS: 28 + 8 (C)

MECH "B" VACANCIES: 2 TOOL KEEPER: 1

__

C s CONTRACTOR ISI e INSERVICE INSPECTION SUPV = SUPERVISOR I&C = INSTRUMENT AND CONTROL V a VACANCY RMS = RADIATION MONITORING SYSTEM GE-SRO = RECEIVED CE SRO TRAINING

h (

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FIGURE 9 SHOREHAM HEA1.TH PHYSICS ORGAN!ZAfl0N N. D! MASC 10 RADIOLOGICAL CONTROLS DIVISION MANAGER

-

V. MACKAY NUCLEAR STAFF SPECIALIST

{

M. BURING (CONSULTANT)

HEALTH PHYSICS ENGINEER PLANT ENGINEER: 1 plus ALARA ENGINEER:

HEALTH PHYSICS DOSIMETRY SPECIALIST: 1 1 (CONSULTANT)

1 (CONSULTANT)

SUPERVISOR: 1 HEALTH PHYSICS FOREMEN:

2 + 1 (VACANCY)

LEVEL I TECHNICIANS:

LEVEL !! TECHNICIANS: 11 TECHNICIAN HELPERS:

9 + 4 (CONSULTANTS)

2 + 3 VACANCIES 28 TECHNICIANS AUTHORIZED, 6 VACANCIES, ALARA = AS LOW AS REASONABLY ACHIEVABLE INCLUDING THE 5 OVERHIRES AUTHORIZED.

AUTHORIZED TO HIRE 9 MORE HP TECHS FOR OPERAT!ONS ABOVE 51 POWE *

e.

FIGURE 10 SHOREMAM RADWASTE AND CHEMISTRY ORGANIZATION N. DIMASClO j

"

RADIOLOGICAL CONTROLS DIVISION MANAGER

--

V. MACKAY NUCLEAR STAFF SPECIALIST M. MA P. KWASCHYN RADIOCHEMISTRY RADWASTE SUPERVISOR ENGINEER

-

WORK COORDINATOR: 1 LEAD RADWASTE ENGINEER: 1

--

RADWASTE ENGINEER: 1 RAD 10 CHEMISTRY SUPPORT RADWASTE FOREMAN:: 1 LEAD ENGll;IER: 1

--

RADWASTE MECHANICS:

2 + 1 VACANCY RADWASTE SHIPP!NG ENG: 1C

--

RADWASTE SHIPPING COORDINATOR: 1 FOREMEN:2 CHEMICAL ENGlWEERS: 1 (C)

TECHNICIANS:

CHEMISTS 1 (C)

12 + 4 (C) + 2 (V)

RACl0 CHEMIST: 1 ON BDARD: 34 C = CONTRACTOR VACANCIES (V): 3 ENG = ENGINEER RADWASTE = RADIOACTIVE WASTE i

!~

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I FIGURE 11 SHOREHAM OUTAGE / MODIFICATIONS DIVISION R. PURCELL (SRO)

OUTAGE / MODIFICATIONS MANAGER

OUTAGE ENG: 1 (ACTING)

l COLT DIESEL MANAGER: 1 OUTAGE / PLANNING ENGs:

--

ENGINEERS: 2 + 2 (C)

1 + 1 (C) + 1 VACANCY STAFF ASSISTANT: 1 (C)

R. STARK, ACTING D. DURAND (SRO)

STATION MOOlFICATIONS WORK PLANNING AND I

ENGINEER SCHEDULING ENGINEER ENGINEERS: 6 + 2 (C)

,

+1 (C) ON 4/15/89 (est)

+4 VACANCIES l

STAFF AS$1STANT: 1 PLANNING SUPERVISOR: 1 SCHEDULING S'JPERVISOR: 1 LEAD WORK PLANNERS:

2 VACANCIES, PENDING HIRING AUTHORIZATION l

SR PLANNER / SCHEDULER: 4 PLANNERS: 2 WORK PLANNING FOREMEN: 4 l

PLANNER / SCHEDULER: 1 CLERKS / DRAFTSMEN: 4 PLANNING COORDINATORS: 2 CLERICAL: 2 l

C = CONTRACTOR SR = SENIOR SR0 = LICENSED SENIOR REACTOR OPERATOR I

_ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _

_ _ - - _ _

. _. _

_

. _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - - _ - _ _ _ _ - _.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

FIGURE 12A: POWER ASCENSION TEST PROGRAM (PATP) STAFFING REQUIREMENTS FOR TESTING AT 5% POWER STAFF NUMBERS (x/x) DEPICT THE MINIMUM (REQUIRED) AND PRESENT STAFF (e.g., 2/3 = 2 MINIMUM, 3 PRESENT)

LILCo PATP MANAGER: 1/1 (Reactor Engineer)

_

Jeneral Electric

--

PERFORMANCE OPERATIONS MANAGER: 1/1 ENGINEERS: 0/1 NUCLEAR ENGINEERS: 1/2 LEAD STARTUP, TEST, TEST COORDINATOR: 1/0 Stone & Webs %r DESIGN, & ANALYSIS LEAD ENGINEER: 1/1 ENGINEER: 1/1 l

l STARTUP, TEST, DESIGN, &

SHIFT TEST DIRECTORS: 0/0 VlBRATION & THERMAL ANALYSIS ENGINEERS: 0/0 EXPANSION ENGINEERS: 0/1 DAY SHIFT ENGINEERS: 0/4 SHIFT TEST ENGINEERS: 0/2 THl$ STAFFING SUPPLEMENTS TPE FINAL SAFETY ANAL " 'S REPORT AND THE r

TECHNICAL SPECIFICATIONS

!

,

-

- - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _

_ _ _

__ _.- _ _ _. - _ _ _ _ - - _ - _

.

.

i FIGURE 128: PATP STAFFING REQUIREMENTS FOR OPERATION BETWEEN 5% POWER AND 20% POWER STAFF NUMBERS (x/x) DEPICT THE MIN! MUM (REQUIRED) AND PRESENT STAFF (e.g., 2/3 = 2 MINIMUM, 3 PRESENT)

LILCo PATP MANAGER: 1/1 (Reactor Engineer)

General Electric

--

PERFORMANCE 0PERATIONS MANAGER: 1/1 ENGINEERS: 0/1 NUCLEAR ENGINEERS: 1/2 LEAD STARTUP, TEST, TEST COORDINATOR: 1/0 Stone & Webster DES!GN, & ANALYSIS LEAD ENGINEER: 1/1 ENGINEER: 1/1

_ _..

.

STARfUP, TEST, DESIGN &

SHIFT TES' O! RECTORS: 4/0 VIBRATION & THERMAL ANALYSIS ENGINEERS: 4/0 EXPANSION ENGINEERS: 1/1 i

l DAY SHIFT ENGINEERS: 0/4 SHIFT TEST ENGINEERS: 4/2 PATP s POWER ASCENSION TEST PROGRAM THl$ STAFFING SUPPLEMENTS THE FINAL SAFETY ANALYSIS REPORT AND THE TECHNICAL SPECIFICATIONS

,

_ _ _ _ _ _ _ _ _ _ _ _. _ _ - _ _ _ _ _ _ _ _

__

_

. _. - _ _ _ _.. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. -

_. _ _ - _ _ _.. _ _. _

.

~I

.

FIGURE 12C: PATP STAFFING REQUIREMENTS FOR ACHIEVING 25% POWER PATP s POWER ASCENSION TEST PROGRAM STAFF NUMBERS (x/x) DEPICT THE MINIMUM (REQUIRED) AND PRESENT STAFF (e.g., 2/3 = 2 MINIMUM, 3 PRESENT)

LILCo PATP KANAGER: 1/1 (Reactor Engineer)

Genera! Electric

--

PERFORMANCE OPERATIONS MANAGER: 1/1 ENGINEERS: 0/1 NUCLEAR ENGINEERS: 1/2 LEAD STARTUP, TEST, TEST COORDINATORS */0 Stone & Webster DESIGN, & ANALYSIS LEAD ENGINEER: 1/1 ENGINEER: 1/1

_

STARTUP, TEST, DESIGN, &

SHIFT TEST DIRECTORS: !/0 VIBRATION & THERMAL ANALYS!$ ENGINEERS: 5/0 EXPANSICN ENGINEERS: 1/1 DAY SHIFT ENGINEERS: 0/4 SHIFT TEST ENGINEERS: 5/2 I

_ _. mmm TH1'S STAFFING SUPPLEMENTS THE FINAL SAFETY ANALYSIS REPORT AND THE TECHNICAL SPECIFICATIONS

..

,_. _ _ _ _ _ - - _ - - _ - - _ _ - - _

_ _ _ _ _

w

,

I FIGURE 120: PATP STAFFING REQUIREMENTS FOR TEST CONDITION 2 (STP 821-8.3)

I PATP s POWER ASCENSION TEST PROGRAM STAFF NUMBERS (x/x) DEPICT THE MINIMUM (REQUIRED) AND PRESENT STAFF (e.g., 2/3 = 2 MIN! MUM, 3 PRESENT)

LILCo PATP HANAGER: 1/1 (Reactor Engineer)

General Electric

-

-

PERFORMANCE OPERATIONS MANAGER: 1/1 ENGINEERS: 0/1

-

NUCLEAR ENGINEERS: 1/2 LEAD STARTUP, TEST, TEST COORDINATOR: 1/0 Stone & Webster DESIGN, & ANALYSIS LEAD ENGINEER: 1/1 ENGINEER: 1/1

STARTUP, TEST, DESIGN, &

SHIFT TEST DIRECTORS: 5/0 v!BRATION & THERMAL j

ANALYSIS ENGINEERS: 5/0 EXPANSION ENGINEERS: 3/1 I

DAY SHIFT ENGINEERS: 0/4 SHIFT TEST ENGINEERS: 5/2

THIS STAFFING SUPPLEMENTS THE FlhAL

.

SAFETY ANALYSIS REPORT AND THE TECHNICAL SPECIFICATIONS

.

I

1

_ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ ____.______-__________ _ _ _ ___ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

_

.

r

.

FIGURE 12E: PATP STAFFING REQUIREMENTS FOR TEST CONDITION 2 FOR MAIN STEAM LINE TESTING (STP 806 8.2)

i PATP = POWER ASCENSION TEST PROGRAM STAFF NUMBERS (x/x) DEPICT THE MINIMUM (REQUIRED) AND PRESENT STAFF (e.g., 2/3 = 2 MINIMUM, 3 PRESENT)

LILCo PATP MANAGER: 1/1 (Reactor Engineer)

i General Electric

--

PERFORMANCE OPERATIONS MANAGER: 1/1 ENGINEERS: 0/1

-

NUCLEAR ENGINEERS: 1/2 LEAD STARTUT, TEST, TEST COORDINATOR: 1/0 Stone & Webster DESIGN, & ANALYSIS LEAD ENGINEER: 1/1 ENGINEER: 1/1 STARTUP, TEST, DESIGN, &

SHIFT TEST DIRECTORS: 5/0 VIBRATION & THERMAL

..

ANALYSIS ENGINEERS: 5/0 EXPANSION ENGINEERS: 4/1 DAY SHIFT ENGINEERS: 0/4 SHIFT TEST ENGINEERS: 5/2 THl3 STAFFING SUPPLEMENTS THE FINAL j

SAFETY ANALYSIS REPORT AND THE TECH'ilCAL SPECIFICATIONS

i lU

_ _ _ _ _ _ _

_ _. _ _ _ _

__

_

_

_ _ _

__._

___

__ _

.. _ _ _ _..

. _ _ _ _ _. _ _ _.. _ _ _ _ _ _ _ _ _.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _

e-FIGURE 12F: PATP STAFFING REQUIREMENTS FOR TEST CONDITION 3 PATP = P3WER ASCEN!f0N TEST PROGRAM STAFF NUMBERS (x/x) DEPICT THE MINIMUM (REQUIRED) AND PRESENT STAFF (e.g., 2/3 = 2 MlN! MUM, 3 PRESENT)

LILCo PATP KANAGER: 1/1 (Reactor Engineer)

Gameral Electric

--

PERFORMANCE OPERATIONS MANAGER: 1/1 ENGINEERS: 0/1 NUCLEAR ENGINEERS: 1/2 LEAD STARTUP, TEST, TEST COORDINATOR 1/0 Stone & Webster DESIGN, & ANALYSl$

LEAD ENGINEER: 1/1 ENGINEER: 1/1

-

STARTUP, TEST, DESIGN, &

SHIFT TEST DIRECTORS: 6/0 VIBRATION & THERMAL ANALYSIS ENGINEERS: 6/0 EXPANSION ENGINEERS: 4/1 DAY SHIFT ENGINEERS: 0/4 SHIFT TEST ENGINEERS: 6/2

{

THIS STAFFING SUPPLEMENTS THE FINAL SAFETY ANALYSIS REPORT AND THE TECHNICAL SPECIFICATIONS

>

_ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _______ _

_ _ _

_

_ - _ _. _ - _ _. - _ _ _ - _ _ _ - _. _ _ _ - _ _ - _ _ - - _ __ - _ _ _ _ _ - _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _. - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ -

ws v

FIGURE 12G: PATP STAFFING REQUIRED FOR TEST CONDITION 3 FOR BOP INSTRUMENT V!BRATION DURING HPCI (STP 15 8.3.2)

PATP s POWER ASCENSION TEST PROGRAM STAFF NUMBERS (x/x) DEPICT THE MINIMUM (REQUIRED) AND PRESENT STAFF i

(e.g., 2/3 = 2 MINIMUM, 3 PRESENT)

LILCo PATP KANAGER: 1/1 (Reactor Engineer)

General Electric

--

PERFORMANCE OPERATIONS MANAGER: 1/1 ENGINEERS: 0/1 mummmmma NUCLEAR ENGINEERS: 1/2 LEAD STARTUP, TEST, TEST COORDINATOR: 1/0 Stone & Webster DESIGN, AND ANALYSIS LEAD ENGINEER: 1/1 ENGINEER: 1/1 STARTUP, TEST, DESIGN, &

SHIFT TEST DIRECTORS: 6/0 VIBRATION & THERMAL ANALYSIS ENGINEERS: 6/0 EXPANSION ENGINEERS: 8/1 DAY SHIFT ENGINEERS: 0/4 SHIFT TEST ENGINEERS: 6/2 BOP = BALANCE OF PLANT THIS STAFFING SUPPLEMENTS THE FINAL HPCI s HIGH PRESSURE COOLANT INJECT 10N SAFETY ANALYSIS REPORT AND THE TECHNICAL SPECIFICATIONS

-_ _

_ _ _ _ _ _ _ _ _ _ _

..

-

i APPENDIX A:

INSPECTION TEAM COMPOSITION Team Manager:

Ebe C. McCabe, Jr. Chief, Reactor Projects Section IB (RPS-18), Division of Reactor Projects (DRP), Region I Team Leader:

J. Thomas Shediosky, Haddam Neck Senior Resident Inspector Secretary:

Roberta A. Masica, Shoreham Clerical Aide Team Members:

Stewart W. Brown, Shoreham Licensing Project Manager, Project Directorate 1-2, Office of Nuclear Reactor Regulation (NRR)

Donald L. Caphton, Senior Technical Reviewer, Operational Programs Section, Division of Reactor Safety (DRS), Region I William R. Carpenter, EG & G, Consultant Frank J. Crescenzo, Shoreham Senior Resident Inspector Thomas F. Dragoun, Senior Radiation Specialist, Facilities Radiation Protection Section, Division of Radiation Safety and Safeguards (DRSS), Region I Joseph T. Furia, Radiation Specialist, Effluents Radiation Protection Section (ERPS), DRSS, Region I Peter Habighorst, Resident Inspector, Millstone 2 Jason C. Jang, Senior Radiation Specialist, ERPS, DRSS, Region I Sheri R. Juergens, Acting Reactor Engineer, DRP (General Engineer, NRR)

Paul D. Kaufman, Project Engineer, RPS-18, DRP, Region I Tae K. Kim, Resident Inspector, Pilgrim

,

Thomas Koshy, Senior Reactor Engineer, DRS, Region I Julio F. Lara, Reactor Engineer, DRS, Region I

]

William Raymond, Senior Resident Inspector, Millstone James J. Raleigh, Reactor Systems Engineer, Operational Events Assessment Branch, NRR Clifford D. Sellers, Senior Materials Engineer, Materials Engineering Branch, NRR l

l Robert W. Winters, Reactor Engineer, DRS, Region I t