IR 05000322/1989091
| ML20005D941 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/18/1989 |
| From: | Crescenzo F, Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20005D940 | List: |
| References | |
| 50-322-89-91, NUDOCS 9001020298 | |
| Download: ML20005D941 (28) | |
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I U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-322/89-91 Docket No.
50-322 License No.
NPF-82 Licensee:
Long Island Lighting Company P. O. Box 618 Shoreham Nuclear power Station Wading River, New York 11792 Facility Name: Shoreham Nuclear Power Station Inspection At: Wading River, New York Dates:
September 18, 1989 - September 22, 1989 Reporting Inspectors:
F. J. Crescenzo, Senior Resident Inspector, Shoreham P. Kaufman, Project Engineer, Projects Branch 2 S. Brown, Project Manager, NRR F. A11enspach, Operations Engineer, NRR R. Hogan, Emergency Preparedness Specialist, NRR Prepared by:
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\\dnEfti F. J. Crescenzo, SF 1, Shoreham N Da'te V
Approved by:
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L. T. Doerflein, Thief Date Reactor ProjectsISection 2B AREAS INSPECTED: A special team inspection was conducted to document and assess resource reductions at Shoreham since approval of the settlement agreement with New York State.
The areas inspected include systems, staffing, licensing and emergency preparedness.
RESULTS:
Pending further NRC review for completeness and consistency with cther facilities, the licensee's position on the Technical Specifications for the defueled condition is unresolved. The discrepancy between the licensee's current organization and the Technical Specification description was previously identi-fied and was under NRC staff review (see section 4.6). Plant systems are being maintained in a reasonable state of readiness although not necessarily operable.
Plant organization and program functions remain intact except in very few cir-cumstances. Staffing levels are adequate given current plant status although significant staffing reductions have been implemented.
Licensing functions remain intact. Onsite and offsite emergency preparedness staffing and resources are in compliance with the NRC approved plan and with license conditions.
I 9001020298 891218 PDR ADDCK 05000322
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SUMMARY 1.1 Purpose and Scope A special team inspection was conducted to document and assess resource reductions at Shoreham since licensee approval of the settlement agreement with New York State. Within each area, the inspectors documented changes made or anticipated. These changes were compared with available standards to assess safety and regulatory impacts.
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1.2 Areas Examined The areas inspected include systems, staffing, licensing and emergency preparedness.
1.3 Summary of Findings Two issues were identified concerning compliance with licensee requi rements. The first involves an unresolved issue on the licensee's position on Technical Specifications for the defueled condition. This issue is unresolved pending NRC review for completeness and consistency with other facilities. The second issue is a discrepancy between the licensee's current organization and the Technical Specification description which was previously identified and is under NRC staff review, Plant systems are being maintained in a reasonable state of readiness although not necessarily operable. The licensee's program to place the facility in long term lay-up condition is still being developed.
The team found this program to be advancing in a reasonable manner.
Plant organization and program functions remain intact except in very few circumstances. Adequate safety evaluations justify deviations from the facility description.
Staffing levels are adequate given current plant status although significant staffing reductions have been implemented.
Licensing functions remain intact. Plans to scale back this function appear reasonable although the staff is reviewing the licensee's proposal to defer regulatory items.
Plans to defer deficiency dispositions appear adequate. Onsite and offsite emergency preparedness staffing and resources are in compliance with the NRC approved plan and with license conditions. Where applicable, safety evaluations of changes made to the facility (as described in the USAR)
were properly completed by the licenset and were found acceptable by the team.
2.0 BACKGROUND On June 28, 1989, LILCo shareholders approved an agreement with New York State which LILCO, among other things, would not operate the Shoreham Nuclear Power Station (SNPS).
During a meeting held at Region I on June 30, 1989, LILCo stated its intention to comply with the contractual
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obligations of the agreement and outlined its plan for SNPS.
This plan included, defueling of the reactor, reductions in maintenance and surveil-lance activities consistent with a defueled condition and, reductions in staff consistent with the reduced maintenance, surveillance, and operational requirements at SNPS.
LILCo also assured the NRC that it intended to abide in all respects by the terms of its operating license for SNPS. These intentions were confirmed in a letter from LILCo (A. F. Early, Jr.) to NRC (W. Russell), dated July 5,1989.
A management meeting was Feld between the NRC and LILCo on July 28, 1989 at NRC Headquarters in Bethesda, Maryland. At that meeting, LILCo reiterated the above in somewhat greater detail and the NRC requested LILCo to provide a written description of its program to define the operational
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status of equipment in the defueled condition and to reduce staffing at the facility, This was provided in a LILCo (W. E. St< iger Jr.) letter SNRC-1626 to NRC (W. T. Russell), dated August 31, 1989; subject: " Staffing Report." SNRC-1626 stated that staffing levels were based on a Technical Specification review to determine the minimum levels of activity necessary to comply with license requirements with all fuel in the spent fuel pool.
The initial review " conservatively considered" that Limiting Conditions for Operation (LCO's) applicable in OPERATIONAL CONDITIONS 4, 5, * (fuel movement in secondary containment), "whenever" and "at all times" would
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apply when all fuel was in the spent fuel pool.
The letter further noted that a subsequent "more detailed" eyaluation was conducted to include commitn:ents made in licensing documents other than Technical Specifications.
Although it was not explicitly stated in SNRC-1626, this subsequent review-was modified in that it assumed LCO's for OPERATIONAL CONDITIONS 4 and 5 would not apply with all fuel in the spent fuel pool.
From this review, plant systems were classified as either OPERABLE or not.
Those not OPERABLE were further classified as FUNCTIONAL, SECURED, or PRESERVED. An analysis was then conducted to determine the minimum staffing levels necessary to maintain the systems in accordance with the classifications.
In a letter from the NRC (T. Murley) to LILCo (A. F. Earley, Jr.) dated August 30, 1989, the licensee was requested to provide written assurance that:
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All systems required for safety in the defueled mode would be maintained in fully operable status.
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All systems required for full-power operation of the facility would be preserved from degradation, with such maintenance and custodial services and appropriate documentation as may be necessary to ensure l
such preservation.
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An adequate number of properly trained staff to ensure plant safety l
in the defueled state, including the ability to cope with malfunctions, a
accidents, and unforeseen events would be maintained.
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The licensee was also requested to prepare the submittal prior to a manage-ment meeting with the NRC scheduled for late September 1989 and to be prepared to discuss status of Shoreham's approved Emergency Plan at that meeting.
LILCo responded to these requests in a letter (A. F. Earley, Jr.) to NRC (T. E. Murley) dated September 19, 1989. That letter restated substantive portions of SNRC-1626 to outline the program to classify systems; however, the SECURED classification was eliminated.
This letter also did not
explicitly recognize that LCO's applicable in OPERATIONAL CONDITIONS 4 and
5 would not apply in the defueled condition.
A description of the programs to preserve non-operable systems and the assurances requested were also provided.
Defueling of the Shoreham reactor commenced on July 5,1989 and was completed in early August 1989. All irradiated reactor fuel was removed from the vessel and transferred to the spent fuel pool. The refueling cavity was drained, the reactor vessel internals reassembled, and the reactor vessel head restored to position.
The reactor vessel head studs were not re-tensioned. The drywell head and shield plugs were reassembled.
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Staffing levels have been reduced from a level 1275 on May 31, 1989 (593 LILCo, 118 LILCo Corporate Support, and 564 Contractors) to a post defueling level of 769 (433 LILCo, 97 LILCo Corporate Support, and 239 Contractors).
3.0 SYSTEMS 3.1 Technical Specifications The licensee has adopted a position that none of the operational conditions defined in table 1.2 of the Technical Specifications accurately describe Shoreham's current configuration (no fuel in the reactor vessel). Accordingly, the licensee has applied specifications 3/4.0.1 to disregard Limiting Conditions for Operation (LCO's) and l
surveillance requirements applicable in one or more of the operational i
conditions described in table 1.2 (absent further qualification).
The licensee continues to comply with specifications applicable "at all times" or "whenever." Additionally, the licensee intends to l
maintain operzble those systeus required to handle irradiated reactor l
fuel in the secondary containment.
This latter requirement is most often designated by footnote to applicability statements. Attachment A is a compilation of Technical Specifications the licensee considers applicable in the defueled condition, i
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4 The inspector did not identify any safety concerns with the licensee's position on the Technical Specifications for the defueled condition. The inspector concluded that those requirements necessary for safe storage of fuel in the spent fuel pool would be met by the above application of Technical Specifications.
Notwithstanding, the defueled mode / operational condition is not specifically defined in the Technical Specifications and the
- adequacy of the licensee's position is unresolved pending further NRC program office review for completeness of applicable requirements and consistency with other facilities considering deconmissioning (UNR 50-322/89-91-01).
3.2 System Operability The licensee does not plan to operate the facility at power. This fact, coupled with the applicability of Technical Specifications described above, was applied to develop the " minimum posture" system configuration. The minimum posture configuration was then used as an assunption to determine staffing and resource reductions.
Plant systems under minimum posture are classified as OPERABLE, FUNCTIONAL, and PROTECTED. These classifications were developed by the Operations Department and Systems Engineering personnel.
The classifications were reviewed and approved by the Review of Operations Committee (ROC) and ultimately by the Plant Manager. The classifi-cation process represents the first of three phases to place the
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facility in long term lay-up.
Phase II and III involve development and implementation of specific lay-up instructions for PROTECTED systems and is described in paragraph 3.3 below. A complete listing of plant systems according to their classification is displayed in Attachment B to this report.
l OPERABLE systems were classified by considering requirements of i
Technical Specifications, commitments made in the Updated Safety Analysis Report (USAR) and Fire Hazards Analysis Report (FHAR). The tern OPERABLE is defined according to the Technical Specification definition. This requires compliance with Limiting Condition for Operations (LCOs) without reliance on action statements for systems required in OPERATIONAL CONDITIONS
"at all times," and "whenever."
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A number of the systems classified as OPERABLE may not be operable in all functions or all system trains.
For example, the B21-Nuclear Boiler system is classified as OPERABLE; however, only the vessel level instrumentation will remain operable.
Similarly, only two of
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the three diesel generators will be maintained operable although the
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R-43 Diesel Emergency Power system is classified as OPERABLE.
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circumstances are allowed by Technical Specifications. The LCO for the particular system must be referred to in determining the minimum
system operability requirements for the defueled condition.
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Certain systems classified as OPERABLE are not specifically required
in the defueled condition or are not addressed in technical specifi-
cations. These systems are included in the OPERABLE category because the particular system performs one or more functions necessary to comply with an associated LCO.
For example, the Reactor Water Cleanup system is not specifically addressed in the Technical Specifications; however, its sampling function is necessary to comply with specif1-cation 3/4.4.4 (Chemistry) which is applicable "at all tirces." For
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these systems " operability" means it can perform the required function (s).
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This is distinguished from the " FUNCTIONAL" classification described below because there, the system's function does not impact Technical Specifications in the defueled condition.
FUNCTIONAL systems are those not required to be OPERABLE by Technical Specifications but necessary for other reasons such as industrial safety or habitability.
These systems will remain functional for
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their intended purposes.
PROTECTED-systems are those systems not required by Technical Specifi-
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cations which do not provide any other function necessary for safe or
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routine operation of the facility in the defueled condition. These systems will be layed up in accordance with the System Lay-up Implementation Packages (SLIP) described in paragraph 3.3 below.
Pending resolution of the unresolved issue discussed in Section 3.1, the inspector found the licensee's program to classify systems consistent with Technical Specifications when no fuel assemblies are in the reactor vessel.
3.3 System Lay-up The licensee established a Lay-up Task Force comprised of a Systems Engineer, Compliance Engineer, Nuclear Engineer and Radiochemistry Engineer.
The task force was to develop and implement lay-up instructions for plant systems that will be PROTECTED, As noted above, this activity represents phases II and III of the lay-up program.
To date, the task force has met on 13 occasions The task force will continue to meet on a regular and frequent basis throughout the development and implementation phase e 9.
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Phase II of the program involves development of System Lay-up Implementation Packages (SLIPS) for each system. These packages will specifically define a system's configuration for long term lay-up.
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The packages will include valve and breaker alignments, tagging orders, system boundary definitions, and a safety evaluation which considers
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impact of the lay-up on plant operation in the defueled condition.
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desired configuration and to monitor or perform preservation activities where applicable.
The packages will not address maintenance or surveillance requirements in the lay up configuration.
The licensee maximized use of existing programs and procedures which govern plant activities to control the SLIP process. A System Engineer Guiceline (SEG) 3.9, ' Lay-up of Secured Systems" was issued to provide direction and a consistent method for the preparation of SLIP packages.
In addition, SEG 3.10, " Dry Lay-up of Wet Systems" was in draf t form
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during this inspection. This guideline was established to provide special instructions for the dry lay-up process of wet systems. All SLIPS will be reviewed and approved by the Review of Operations
Committee (ROC).
Following ROC approval, the SLIP package is ready
for implementation.
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Marked-up system boundary drawings (P&ID's)
Valve lineup checklist
Secured annunciator list
Lifted lead and jumper permit request (as required)
Component power supply checklist
Station Equipment Clearance Permit Request with tagging order
Safety evaluation
Implementing Maintenance Work Request
Approval cover sheet
Special lay-up/ draining instructions (as required)
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Other special instructions (as required)
The specific lay-up configurations and instructions for the various PROTECTED systems are being developed.
The licensee has consulted
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several outside sources on lay-up requirements including: EPRI Np-51065, " Plant Lay-up and Equipment Preservation Sourcebook,"
contractor surveys (ie. Impell and Multiple Dynamics Corp), and l
utility surveys (ie. TVA, WPPSS, Philadelphia Electric Company, and
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Cleveland Electric Illuminating Company).
Lay-up of water systems that will be PROTECTED is also in the development stage.
The licensee is evaluating both a wet and dry lay-up process and has contacted outside expertise in these areas.
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As of this inspection, two SLIPS had been ROC approved. Neither of these had been implemented. Thus, no plant systems have been " layed i
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The two SLIPS which are ROC approved are N36-Extraction Steam System and N23-Miscellaneous Drains Secondary Plant System. These i
were considered " easy" systems and were expedited through the system t
partly to test the process. The licensee continues to evaluate and i
adjust the development process as necessary. A total of 10 SLIPS are in the preparation stage and as noted, all protected systems will
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eventually have an associated SLIP package.
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I Phase III will involve implementation of the $ LIP packages. The SLIP packages will utilize the licensee's existing maintenance work request i
program, tagout process and system operating procedures (where
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possible) to configure the system. Thus, special procedures or unique administrative controls will be minimized.
The securing of systems
will be performed by both maintenance and operations personnel. A controlled working copy of the SLIP package will be maintained in the control room valve lineup file.
In addition, a copy of the SLIP package will be filed with the Systen Engineering group and a record copy filed in the Shoreham records retrieval system.
r The inspector found the licensee's approach to system lay-up of PROTECTED systems to be reasonable.
The process to develop SLIP packages appears to consicer all relevant factors of safety and preservation. The process also appears to be compatible with the existing procedural framework at the facility. The licensee is, however, just beginning application of the process.
3.4 Surveillance and Maintenance of Systems
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The surveillance program necessary for compliance with Technical Specifications will remain essentially as-is. The scope of r
surveillance actually conducted has been significantly reduced to
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encompass only those systems classified OPERABLE in the defueled condition.
The computerized surveillance tracking program remains activo and continues to issue Station Activity Worksheets (SAWS) for systems required operable in conditions 4, 5, *, "At all times," and
"Whenever " Surveillance activities for 4 and 5 have typically been deferred by the cognizant departments.
Prior to the settlement, the licensee typically performed surveillance necessary to maintain the facility in a position where an entry to OPERATIONAL CONDITION 2 could be made within a short period (target of 30 days).
This required performance of surveillance activities which otherwise could have been deferred.
This policy has been abandoned and the result has been a significant reduction in c
surveillance actually performed.
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The licensee is evaluating whether certain surveillance activities not required by Technical Specifications should be continued. This
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would be considered.if the activity impacted system preservation.
The licensee has not developed criteria by which to evaluate whether
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a particular surveillance activity should be continued.
r The majority of preventive maintenance activities are being completed and not deferred. However, some preventive maintenance (PM) activities are being deferred on certain plant systems per the licensee's existing PM procedure SP 12.015.01, " Preventive Maintenance Program".
Status of Maintenance and Instrument & Control (I&C) PMs since July 1989 is as follows:
Overdue Priority I and 2 PMs 22 - mechanical 18 - electrical 1 - I&C
Completed PMs - 431 - mechanical & electrical 160 - I&C
Deferred PMs - 177 - mechanical & electrical 251 - I&C Many of the mechanical / electrical PMs were deferred because they could
not be performed, or there was a manpower shortage, due to defueling activities.
Most of these were monthly PMs and as such have been subsequently performed since completion of defueling. Most of the I&C PMs deferrals were related to calibration checks scheduled on the plant systems to be put in lay-up.
PM activities are being maintained for the defueled condition of the plant. The licensee's existing PM program will continue to track the operational life of components and Environmental Qualification of components.
However, the actual component replacements for systems other than OPERABLE are being deferred.
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Corrective maintenance activities have been reduced primarily for three reasons.
First, a number of systems have been shutdown and therefore present fewer opportunities to fail. Second, reduced surveillance activity has realized a proportional effect in the number i
of failures requiring corrective maintenance. Third, some identified corrective maintenance has been deferred based on operability require-
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ments. The backlog of maintenance work requests (MWRs) is presently l
1380. The MWR backlog has only increased by 242 since the Operational Readiness Assessment Team inspection conducted during March 1989, i
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I The licensee is still in the process of developing t'ne long term
i monitoring and maintenance requirements associated with the plant
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systems that are to be PROTECTED and put into either a dry lay-up or l
wet lay-up condition. These requirements will be developed following completion of phase II of the SLIP Program.
In this way, the lay-up
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l-configuration and monitoring requirements will be known. The inspector
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noted that the license has yet to develop criteria for evaluating whether a particular maintenance activity should be continued.
In the interim, as noted above, the majority of preventive maintenance F
activity continues to be performed.
In addition to program reviews, the inspector toured the facility to assess physical condition.
No gross indications of system disrepair or parts scavenging were noted during the tours.
Housekeeping was
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The inspector concluded that plant systems are being reasonably maintained (pending resolution of the unresolved issue discussed in
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Section 3.1) while the licensee develops the custodial surveillance and maintenance activities for the plant systems scheduled for lay-up.
Corrective maintenance and surveillance activities have been reduced.
3.5 Procedures
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The licensee intends to deactivate surveillance procedures for activities it no longer will perform. " Deactivated" means the procedure will no longer be performed or maintained up-to-date. The
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procedure will not be deleted and it will still be possible to retrieve records of its performance from the SAWS data base.
Currently the licensee has not deactivated any plant operating procedures. A number of PM procedures were deactivated in the radio-chemistry department. These PMs were associated with calibrations of conductivity monitors in the condensate system, none of which are
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I safety related.
To date these procedures are the only procedures to be deactivated. The licensee will evaluate deactivating other procedures concurrent with lay-up implementation.
Since the system preservation / lay-up program started, the following procedures have been revised to assist in the actual lay-up implementation stage:
SP 12.006.01, Revision 24, " Station Procedures - Preparation, Review, Approval, Change Review, and Cancellation"
SP 12.011.01, Revision 23, " Environmental Qualification Program" l
l SP 12.015.01, Revision 15, " Preventive Maintenance Program"
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i Also, two systems engineering guidelines, SEG 3.9 and SEG 3.10 were initiated to provide uniform guidance for preparation of SLIPS and dry lay-up instructions of wet systems.
The preventive maintenance procedure was revised to indicate that if Environmental Qualification (EQ) PMs are deferred the EQ engineer has to be notified so an operability assessment of the component can be made.
If EQ PMs are deferred beyond the extension due date the operations department Watch Engineer will enter the item into the control room Limiting Condition for Operations log book.
Thus, deferred EQ items will be tracked and will require resolution prior to declaring the component operable.
The inspector found the new or revised procedures accurately reflect the licensee's system lay-up program and that existing procedures will be adequately integrated into the lay-up process.
3.6 Conclusions The adequacy of the licensee's interpretation of Technical Specifi-cations for the defueled condition is unresolved pending NRC review for completeness and consistency with other facilities considering decommissioning.
The licensee's classification of systems and appli-cable maintenance and surveillance requirements are dependent upon resolution of this issue.
Notwithstanding, it appears that the licensee is taking reasonable steps to preserve plant systems. No indications of gross deterioration or scavenging of parts were noted.
Progress has been made in defining the long term lay-up configuration but a great deal of work remains in this area.
Long term maintenance and procedure status remains to be defined.
4.0 STAFFING 4.1 program Staff Reductions 4.1.1 Plant Staff The inspector reviewed the plant staff established for the current status of the Shoreham Nuclear Power Station (SNPS).
Staffing levels and positions were determined from organization charts dated September 15, 1989 and through discussions with plant staff department managers.
The total number of currently authorized plant staff is 268.
This number is broken down by division to: Operations Staff
Division - 44, Operations Division - 58, Maintenance Division - 101,
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Radiological Controls Division - 46, Outage / Modifications Division -
L 19, and the Plant Manager - 1.
During the period of inspection, some divisions were staffed over the authorized numbers.
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The SNPS Updated Safety Analysis Report (USAR) describes minimum staffing levels for Operations Division as 41, Maintenance Division 46, and the Radiological Controls Division 31. The USAR does not contain staffing numbers for the Operations Staff Division or the Outage / Modifications Division.
The SNPS Technical Specifications, Section 6, does not specify plant staffing levels except for shif t manning and the fire brigade. The shift staffing levels specified in the Technical Specifications for cold shutdown condition are one Senior Reactor Operator (SRO), one Reactor Operator (RO), and one Equipment Operator (EO),
LILCo plans to staff each shift with two SR0's, one RO, and four E0's. The licensee may need to adjust these numbers and the 6 shift rotation due to the attrition of licensed operators.
At present there are 11 SRO's assigned as Watch Engineers or Watch Supervisors, at,d 11 RO's assigned as Nuclear Station Operators or Assistant Nuclear Station Operators (the Assistant Nuclaar Operator category will be deleted but the individuals retain W There are 2 additional SR0's in the Operations Division and about 5 licensed operators staffed as Equipment Operators.
Since the Technical Specifications require only 1 SR0 and 1 RO on each shift with the plant in a shutdown condition, there does not appear to be a problem maintaining the required staffing levels in the near term.
The Technical Specification requires a fire brigade of f1ve individuals.
A fire brigade of five individuals is being maintained.
The Technical Specification require that a Shift Technical Advisor be on shift wnenever the unit is in Condition 1, 2, or 3.
Since the plant is in a defueled condition LILCo has deleted this position from the plant staff, and reassigned the individuals within LILCo.
4.1.2 Nuclear Operations Support Division (NOSD)
The inspector reviewed the staffing of NOSD, NOSD reports to the Assistant Vice President, Nuclear Operations and provides support in the areas of financial services, licensing, contracts and materiai controls, and security.
At the time of full power licensing this division had about 154 individuals including 38 consultants (authorized - 164). The current planned staff is 88 individuais including 3 consultants.
This reduction includes the transfer of Emergency Preparedness (32 individuals, 22 authori:ed) to Corporate Services.
The reduction in numbers in NOSD has been the result of reduced activities in the areas of contracts, modifications, procurement activities, new orders for materials, new requisitions, purchase orders reviewed, requests for materials information, reorders of parts and receiving reports processed.
No functions have been deleted from this division except for transfer of Emergency Preparedness, noted abov _-_ -_
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The staffing levels of NOSD are not described in the facility USAR.
The inspector found the staff reductions to be reasonable given the reduced workload.
4.1.3 Nuclear Quality Assurance
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The inspector reviewed the staffing of tha Nuclear Quality Assurance
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Department (NQA). The staffing of this division has been reduced
from an authorized number of 63 to 40.
Of the 40, 10 are Non
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Destructive Examination (NDE) personnel who may report offsite:
o depending on workload at the site or other LILCo facilities. There i
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has been no change in the requirements or description of the e
operational Quality Assurance Program.
The inspection workload has been reduced consistent with the reduction in plant activities. Two pro-active activities, conduct of a safety system outage and modifi-
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cation inspection, and optional training for NQA personnel, were i
eliminated.
The NQA staffing levels are not described in the facility USAR nor
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the NQA program descriptions. The inspector found the NQA staffing
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reductions reasonable given the reduced workload.
4.1.4 Nuclear Engineering Department The inspector reviewed the staffing of the Nuclear Engineering Department (NED).
The NED has been restructured from the six
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divisions described in the USAR to four divisions.
The Engineering Assurance Division and the Radiation Protection Division have been dissolved. The engineering assurance function, not required by the
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Technical Specifications, was deleted and the functions of the Radiation Protection Division, with a reduced level of activity because of the status of SNPS, were transferred to the Nuciear Analysis Division.
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The activities of scheduled plant modifications, long-term engineering studies / evaluation, program updates for equipment qualifications, spare parts classification / dedication, and some licensing initiatives with current schedules have been put in a deferred category. The NED staff has been reduced from 78 LILCo and 17 consultants (114 had been authorized) to 48 LILCo employees with plans to go to 45 individuals and about 11 consultants.
Neither the USAR nnr the Technical Specifi-cations specify or describe staffing levels for the NED.
In addition to NED, the LILCo Office of Engineering provides technical support for SNPS.
The authorized support was 53 individuals but was at a level of 43 individuals and 19 consultants prior to the setttement with the State of New York. This support has been reduced to a invel
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of 24 LILCo employees, 3 contractors, and 5 consultants.
For the most part, the individuals supporting SNPS on a full time basis are still within the Office of Engineering.
LILCo will continue to main-
tain engineering service contracts with organizations such as Stone &
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Yebster and General Electric and continue to have access to personnel
in other LILCo engineering departments.
The inspector found the reduced staffing levels in this area reasonable given the reduced workloads.
4.2 Maintenance of Minimum Staffing Levels LILCo has stated that for the near future, they will maintain a staff of about 268 individuals at SNPS.
This is being supported by a budget commitment of about $50 million. The licensee should be capable of maintaining a stable number of total staff at Shoreham given this amount of financial commitment.
The inspector noted that although the total figure appears reasonable, NRC reliance on it alone could mask staffing shortages concentrated in one area or in key supervisory positions. Also this figure is a
" snapshot" number representing the staff in September 1989. With the exception of Technical Specifications, there are few obstacles to preclude the licensee from making further significant staffing reductions without NRC involvement.
These concerns were addressed to Station Management.
The licensee committed to promptly notifying Region I of any significant staffing changes which occur in the future.
"Significant" is to include personnel changes in first line supervisory positions and above.
The inspector noted that although staffing at SNPS has been reduced, a large percentage of individuals that were released from Shoreham remain in the LILCo organization (no longer assigned to SNPS) and
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would be available if needed.
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4.3 Safety Evaluations of Staff Reductions i
The inspector reviewed safety evaluations addressing the reductions in staffing and technical support for $NPS.
Safety evaluations were performed in accordance with 10CFR50.59.
The safety evaluations reviewed were:
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SNRC-1615 - Organization / Personnel Changes Shoreham Nuclear Power Station, dated 7/19/89.
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Radiological Controls Division Staff Reduction, dated 9/6/89.
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$NPS - OPS Staff Division, dated 9/13/89.
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Operations Division Staff Reductions, revised, dated 9/12/89.
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5.
Termination of Shift Technical Advisor Services, dated 9/6/89.
6.
Delete the Requirement to Staff Shift Technical Advisors and Nuclear Engineers under the Conditions of the LILCo and New York
State Settlement Agreement, dated 9/1/89.
7.
Change Emergency Plan Section 5.2 to Read: The Onsite Fire Brigade will be Manned by the Shift Watch Supervisor, one Fire /
Safety Technician and Three Equipment Operators, dated 8/23/89.
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8.
Reduction of Staff in the Maintenance Division of SNPS, dated
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9/6/89 9.
Special Safety Evaluation - Reduction of Outage / Modification Division Staffing, dated 9/6/89 and Rev. I dated 9/20/89.
10. Nuclear Engineering Department - Safety Evaluotion 89-057, dated i
9/8/89.
11. N050 Safety Evaluation on SNRC-1626 (NOSD staffing reduction),
dated 9/8/89
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12. Nuclear Quality Safety Evaluation, SE0A-89-007, dated 9/12/89.
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The inspector found all the safety evaluations reviewed to be adequate.
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4.4 Continued Training of Minimum Staff LILCo plans to keep their training organization and training programs in place.
In particular, LILCo is continuing their requalification program for licensed operators.
However, no classes for newly licensed
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operators are planned. With respect to unlicensed plant staff the utility has 10 programs accredited by INPO and are planning to continue with this program.
However, they have dropped their member-ship in INPO and requested associated membership based on their part.
ownership of Nine Mile Point 2.
It is not clear at this time whether INPO will continue to accredit the programs at SNP3.
4.5 Qualifications of Minimum Staff The inspector reviewed the qualifications of key personnel relative to the qualifications stated in the facility USAR and the Technical e
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l Specifications.
These qualifications were based on ANSI N18.1-1971 l
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which SNPS has committed to in Section 6.3 of the Technical Specifi-cations. An exception to this standard was noted in the qualifications of the Health Physics Engineer. This person shall meet or exceed the
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qualifications described in Regulatory Guide 1.8, 1975.
t The inspector found the qualifications of key personnel comply with USAR commitments and Technical Specification requirements except for the Radiological Controls Division manager.
This person is required
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to have a certain level of experience at power levels above 20%. The present manager lacks this experience but is otherwise a highly experienced and technically competent manager.
LILCo, by letter dated August 8, 1989, notified the NRC of this discrepancy and committed to obtaining the necessary experience should the plant operate. Also,
the licensee adequately performed a safety evaluation per 10 CFR 50.59 to address this deviation from the USAR commitment. The inspector
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found this discrepancy and the licensee's commitment to obtain the necessary experience if the plant operates to be adequately documented.
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4.6 Organization
The inspector found the SNPS organization to be consistent with that
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described in the USAR.
Excepting elimination of certain program
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functions in the NED (see paragraph 4.1.4), all program functions i
have remained intact despite staffing cuts.
The inspector noted the licensee's current organization is not in
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compliance with the Technical Specification description.
This is due
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to a reorganization made on January 1, 1988.
That reorganization was
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the subject of a LILCo (J. D. Leonard, Jr.) letter SNRC-1403 to the NRC (Document Control Desk), dated December 8, 1987 (see also, NRC Inspection Report 50-322/87-20).
The licensee also submitted license amendment application #14 to delete the organization chart from Technical Specifications consistent with the guidance of NRC Generic Letter 88-06. The inspector noted that this discrepancy was not related to the recent reductions in plant staff.
The inspector determined that resolution of this discrepancy was the subject of other NRC review / action.
The inspector noted the absence of a Vice President Nuclear for SNPS.
This was due to a personnel reassignment which left that position vacant. The reassignment was the subject of a LILCo (J. D. Leonard, Jr.) letter, SNRC-1615 to the NRC (Document Control Desk) dated July 20, 1989.
That letter stated that the Assistant Vice Pi.sident would assume the duties, responsibilities and authority of the Vice President effective August 1, 1989.
The Vice Presidert was eassigned within the company and is available to be recalled if necessary.
The Vice President's new responsibilities include the Office of Training, the
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i corporate QA department, the emergency planning group, the non~
destructive testing group, and the Nine Mile Point Unit 2 oversight group.
4,7 Conclusions
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The inspector concluded that the staffing, technical support, and program functions for $NPS meet requirements as described in the SNPS
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USAR and as required by the SNPS Technical Specifications, except where noted above.
Variations in staffing levels from thuse described
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in the USAR were properly evaluated in accordance with 10 CFR 50.59.
The inspector found staffing levels reasonable for the current plant
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status. The inspector found the current staffing level significantly below the levels immediately prior to full power licensing. Vari-etions from the organization found in the Technical Specifications are unrelated to the scope of this inspection and are being resolved
through other NRC action, 5.0 LICENSING-
c 5.1 "RC Complience Memoranda (Bulletins, Generic Letters, etc.)
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The inspector reviewed the Nuclear Operations Support Department (N050) procedures, NOSD staffing, LILCo's position on deferral of
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regulatory activities, and LILCo's tracking systems, t
LILCo, in its letter of September 27, 1989 submitted its position on deferral of regulatory activities.
LILCo is proposing to defer
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certain current and future generic request information and related implementation activities based on its review of applicability to the Shoreham defueled condition.
LILCo also plans to defer commitments made in anticipation of full power operation.
LILCo will record and track these deferred items on the Shoreham Administrative Tracking
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System (SATS) which is covered by NOSD procedure 23.
j The inspector found that an adequate framework for tracking deferred items exists.
The NOSD staffing and resource levels are adequete to accomplish the tracking program. However, the acceptability of LILCo's proposal in the letter dated September 17, 1989, to defer such activities is currently under staff review.
5.2 Licensir.g Condit:cns Compliance The inspector reviewed documentation to verify compliance with the license conditions listed in section 2.c and attachments to license NPF-82.
Based on that review and the plant status it was determined that the licensee is currently in full compliance with those conditions.
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i 5.3 Deficiency Tracking Programs The inspector reviewed the procedures governing LILCo Deficiency i
Reports (LOR) and Maintenance Work Requests (MWR). The LDR and MWR procedures were being revised to address long term deferral. The
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inspector reviewed the proposed revisions and found they would provide l
reasonable direction for tracking deferred items.
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t Procedure QA-15.1, Control of Nonconformance is being revised to i
include instructions for deferral of LOR's.
There are currently 33 deferred LDR's and they are being tracked on a QC internal tracking system. The QC Managers intend to enter and maintain tracking data in SATS.
The details and procedures to accomplish data transfer remain to be developed.
5.4 Lonclusion The system to track deferred regulatory activities appears adequate.
i The acceptability of deferring these activities, as proposed by
LILCo in a letter dated September 17, 1989, is currently under staff
. review. The staff's findings on this matter will be provided later in a separate document.
The licensee has complied with all license conditions of NPF-82.
The procedures for tracking deferred LDRs and MWRs are being revised.
The early revisions appear to be acceptable. The tracking systems are mature, functional, and capable of tracking the new data entries.
6.0 EMERGENCY PREPAREDNESS 6.1 Program Reductions The licensee's onsite emergency preparedness organization consists of
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six staff niembers which is a reduction of three since obtaining their full power license.
The reduction is reasonable due to a reduction in licensing activities.
The licensee is maintaining its emergency preparedness program with the current staff.
There have been a few changes in the onsite program. One change is the frequency of drills from approximately three per quarter to one per quarter. A change in the normal organization, implemented on August 1, and a change in personnel who constitute the fire brigade, implemented on August 29, required an emergency plan revision.
Although LILCo notified the NRC of the organization change on July 20, 1989, they had not revised the emergency plan. Based on the inspector questioning and prior to the end of this inspection, LILCo was preparing a revision to the plan regarding the organizational change and change to the fire brigade :omposition for submittal to the NRC in accordance with 10 CFR 50.54(q).
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18 The licensee's offsite emergency preparedness organization consists of fourteen staff members which is a reduction of nine since obtaining their full power license. The reduction is primarily due to the termination of litigation activities. The licensee is maintaining its offsite emergency preparedness program with the current staff.
The following changes have been made to the offsite program as a result of the minimum pcsture study:
The drill frequency has changed from three per quarter to one
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per quarter as was changed for the onsite drill program.
The annual reception center practical drill will be a tabletop
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discussion with some demonstration instead of a full hands-on performance.
The school evacuation drill for new bus drivers scheduled for
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September was cancelled.
Bus driver classroom training and retraining is continuing.
The siren test frequency has been changed from monthly to
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quarterly.
Outdoor lot improvements for some of the transportation transfer
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points have been deferred.
Facility-specific plans and procedures are not being developed
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for newly identified special facilities. The licensee is providing generic plans and procedures depending on the type of facility, i.e., nursing home, preschool, etc.
Transportation requirements, however, are being arranged for each facility's specific needs.
Distribution of public information brochures for the 10-mile
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Emergency Planning Zone (EPZ), 50-mile EPZ and schools has been deferred. This is required only for operations above 5 percent rated power.
A Brentwood facility staff person designated to begin the
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Emergency Operations Center (EOC) set-up has not been placed on-call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
This is required only for operations above five percent rated power.
None of these changes require local emergency response organization (LERO) plan revisions nor do they reduce the effectiveness of the LERO plan.
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6.2 Onsite Staff Readiness As a result of plant staff departures, the licensee changed the staffing of the onsite emergency response organization (ERO) from a three team complement for all ERO positions to a three team complement for key ERO staff positions on pagers (nineteen positions) and a two team complement for on-call positions that are not on pagers (seventy-nine positions).
The plan description does not require a specific number of teams but rather requires each position be filled 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
With the new ERO staffing plan, the licensee identified ten personnel shortages (of the 98 positions noted above) and twenty-three personnel requiring training on August 14, 1989. On September 6, there were twelve personnel shortages and seven personnel requiring training.
The licensee is continuously identifying qualified personnel to fill the vacancies and scheduling training for these personnel, Neverthe-
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less, every ERO position can be filled 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day by available personnel.
The training coordinator reviews the emergency response organization about every two weeks to identify personnel whose training has expired.
The personnel are deleted from the call-out computer and scheduled for training.
The emergency preparedness organization is notified immediately when personnel with an assigned ERO position leave the company.
The frequency of the training status review and the
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immediate notification of staff departures enables the emergency l
preparedness organization to assure that the ERO can be fully staffed-at all times.
As
.. ult of the departures of Shoreham staff, the EP organization i
h, eased monitoring of the ERO staffing.
Management is notified of status every two weeks. The increased effort to staff and the ERO has been offset by the reduced drill preparation effort
.e EP organization does not appear to be understaffed.
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' site (LER0) Staff Readiness Staffing of the local emergency response organization (LER0) has not changed since full power licensing.
LER0 is staffed by non-Shoreham LILCo employees and contractors; consequently, it has not been impacted by the Shoreham situation.
The LERO organization is reviewed approximately every two weeks to determine personnel shortages in the three-shift LERO complement. LERO has a shortage of eighteen persons, three of which hold key positions.
However, all positions can be filled 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
Staffing shortages are filled and training is scheduled as necessary.
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As of September 12, training had expired for 209 personnel out of a total of approximately 3020 personnel required for a full 3-shift
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complement.
This is a small percentage of the total LERO and is
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typical of the number of expired training at any one time.
Training is scheduled monthly for personnel whose training has expired. All 209 personnel have been scheduled for training in October.
6.4 Resource Readiness Both onsite and offsite equipment and facilities are being maintained.
Onsite drill records, communications checks, and equipment inventories are being maintained as required by plan and procedures.
No dis-crepancies were identified.
All offsite lease agreements including transfer points and bus and ambulance comoanies are in place.
Instrument calibration continues biannually.
Facilities and equipment are being maintained including the decontamination trailers.
All LERO phone lists are updated quarterly.
Th'e frequency has rema5ned the same for all offsite emergency preparedness surveillances since full power licensing except the siren testing, as noted in Section 6.1.
The onsite training program has remained unchanged.
Notices of required training are sent to ERO staff supervisors prior to expiration to allow time to schedule training.
If personnel still miss retraining they are removed from the onsite ERO call-out list until they have attended retraining.
The inspector reviewed the training records of all recent personnel
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changes to ERO assignments to assure that no untrained personnel were i
on-call. One person had not completed training, but training was scheduled to be completed before the change is to become effective.
6.5 Conclusions The licensee is maintaining the emergency preparedness program in compliance with applicable requirements.
Emergency preparedness activities and resources, which were maintained in excess of requirements, have been curtailed since adoption of the settlement.
These reductions did not require changes to the NRC approved emergency plan and the emergency preparedness activities, and resources are still above the minimum emergency planning requirements.
The two changes to the emergency plan involving the organization were minor in nature and would not reduce the effectiveness of the emergency plan.
The licensee was preparing submittals concerning these plan changes fo-NRC review.
7.0 MANAGEMENT MEETINGS An exit meeting was held on September 22, 1989 to discuss the preliminary findings of the inspection team.
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ATTACHMENT A-
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APPLICABLE TECHNICAL SPECIFICATIONS TECHNICAL SPECIFICATIONS APPLICABLE "AT ALL TIMES" TECH SPEC PAGE 3.3.7.2 SEISMIC MONITORING INSTRUMENTATION................. 3/4 3-62 3.3.7.3 METEOROLOGICAL MONITORING INSTRUMENTATION.......... 3/4 3-65 3.3.7.10 RADI0 ACTIVE LIQUID EFFLUENT MONITORING
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INSTRUMENTATION.................................... 3/4 3-84
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3.3.7.11 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION.................................... 3/4 3-89 3.4.4 CHEMISTRY..........................................
3/4 4-13 3.4,6.1 REACTOR COOLANT SYSTEM PRESS / TEMP LIMITS........... 3/4 4-19 3.7.3 FLOOD PROTECTION...................................
3/4 7-11-3.7.6 SEALED SOURCE CONTAMINATION........................ 3/4 7-20 3.7.7.1 FIRE SUPPRESSION WATER SYSTEM......................
3/4 7-22 3.7.8 FIRE RATED ASSEMBLIES..............................
3/4 7-34
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3.7.11.1 SETTLEMENT OF REACTOR BUILDING.....................
3/4 7-39 3.7.11.2 DIFFERENTIAL SETTLEMENT ACROSS THE STRUCTURE....... 3/4 7-40 3.7.11.3 PENETRATION DIFFERENTIAL SETTLEMENT................ 3/4 7-41 3.8.4.3 REACTOR PROTECTION SYSTEM ELECTRIC POWER MONITORING 3/4 8-26 3.9.7 C R AN E T RAV E L....................................... 3 / 4 9 - 9 3.11.1.1 LIQUID EFFLUENTS................................... 3/4 11-1 3.11.1.2 RADI0 ACTIVE EFFLUENTS - DOSE....................... 3/4 11-5 3.11.1.3 LIQUID RADWASTE TREATMENT SYSTEM................... 3/4 11-6 3.11.1.4 LIQUID HOLDUP TANKS................................ 3/4 11-7
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g-3.11. 2.1 - GASE0VS EFFLVENT DOSE RATE........................-. 3/4 11-8 e
3.11.2.2 DOSE - NOBLE GASES..................................3/4 11-12
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3.11.2.3~ DOSE - IODINE 131, IODINE 133, TRITIUM AND-s RADIONUCLIDES IN PARTICVLATE FORM..................
3/4 11-13
- 3.11.2.5' VENTILATION EXHAVST TREATMENT SYSTEM............... 3/4 11-15 -
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_3.11.3 SOLID RADI0 ACTIVE WASTE.............................3/4 11-20 3.11.4-TOTAL DOSE - RADIOACTIVE EFFLVENTS................. 3/4 11-21 3.12.1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM...... 3/4 12-1 3.12.2 LAND VSE CENSUS......................................3/4 12-12
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3.12.3.
LINTERLABORATORY COMPARISON PROGRAM................. 3/4-12-13 i
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TECHNICAL SPECIFICATIONS APPLICABLE AT "*" AND WHENEVER TECH SPEC PAGE 3.3.2 ISOLATION ACTUATION INSTRUMENTATION................ 3/4 3-9 3.3.7.1 RADIATION MONITORING INSTRUMENTATION............... 3/4 3-57 3.3.7.9 FIRE DETECTION INSTRUMENT.......................... 3/4 3-81 3.3.7.14 DIESEL GENERATOR 3300 KW ALARM..................... 3/4 3-97 3.6.5.1 SECONDARY CONTAINMENT INTEGRITY....................
3/4 6-37 3.6.5.2 REACTOR BUILDING AUTOMATIC ISOLATION VALVES........ 3/4 6-38 3.6.5.3 REACTOR BUILDING STANDBY VENTILATION............... 3/4 6-40 3.7.1.2 PLANT SERVICE WATER SYSTEM - SHUTDOWN.............. 3/4 7-4 3.7.1.4 U LT IMAT E H EAT S I N K................................. 3 /4 7-7 3.7.2 CONTROL ROOM AIR CONDITIONING SYSTEM............... 3/4 7-9 3.7.7.2-DELUGE SYSTEMS..................................... 3/4 7-25 3.7.7.3 CO2 SYSTEMS........................................ 3/4 7-27 3.7.7.5 FIRE HOSE STATIONS................................. 3/4 7-29 3.7.7.6 YARD FIRE HYDRANTS AND HOSE HOUSES................. 3/4 7-32 3.7.9 AREA TEMPERATURE MONITORING........................ 3/4 7-36 3.8.1.2 A/C SOURCES - SHUTD0WN............................. 3/4 8-9 3.8.2.2 D/C SOURCES - SHUTD0WN............................. 3/4 8-13 3.8.3.2 DISTRIBUTION - SHUTD0WN............................ 3/4 8-15 3.8.4.2 MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION.. 3/4 8-24 3.9.9 WATER LEVEL - SPENT FUEL STORAGE P00L.............. 3/4 9-11 3.11.2.8 CONTAINMENT PURGING AND VENTING.................... 3/4 11-18
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ATTACHMENT B SYSTEM CATEGORIZATION OPERABLE SYSTEMS SYSTEM NUMBER SYSTEM TITLE B21 NUCLEAR BOILER C71 REACTOR PROTECTION 011 PROCESS RADIATION MONITORING D21 AREA RADIATION MONITORING F12 SERVICING AIDS (FUEL)
FIS REFUELING Gil RADWASTE G33 REACTOR WATER CLEANUP M43 FIRE PROTECTION H50 REACTOR BUILDING STANDBY VENTILATION (RBSV) & CONTROL ROOM CHILLED WATER P41 SERVICE WATER j
P64 METEOROLOGICAL MONITORING j
R11 STATION TRANSFORMER (NSS & RSS)
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R21 NONSEGREGATED BUSES R22 METAL CLAD SWITCHGEAR R23 LOAD CENTERS AND UNIT SUBSTATIONS R35 AC INSTRUMENT POWER R36-AC UNINTERRUPTIBLE (VITAL) POWER
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R42 BATTERY POWER (125VDC)
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R43 DIESEL EMERGENCY POWER
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R62 STATION PROTECTION AND METERING l
R71 FIRE DETECT & STATION SECURITY i
R81 HEAT TRACING S23 138/69KV SWITCHYARD POT. TRANSF.
S24 138KV SWITCHYARD RELAY PANELS T21 REACTOR BUILDING T22 REACTOR BUILDING SUPERSTRUCTURE
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T23 REACTOR PRIMARY CONTAINMENT T31 REACTOR BUILDING (RB) CRANES, HOISTS AND ELEVATORS T41 REACTOR BUILDING VENTILATION T46 REACTOR BUILDING STANDBY VENT U41 TURBINE BUILDING VENTILATION V41 RADWASTE BUILDING VENTILATION W12 SCREENWELL CANAL X41 MISC HEATING, VENTILATION AND AIR CONDITIONING (HVAC)
X60 DIESEL GENERATOR VENTILATION
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X61 CONTROL ROOM AIR CONDITIONING Y25 BARGE DOCK AND WATERFRONT Z94 SEISMIC MONITORING Z96 POST ACCIDENT SAMPLING
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I FUNCTIONAL SYSTEM SYSTEM NUMBER SYSTEM TITLE B11 REACTOR ASSY B41 FUEL POOL COOL & CLEANUP M41 HEATING & AUX BOILER M42 DOMESTIC WATER M44 SANITARY SEWAGE N61 BUILDING SERVICE MISC, N34 LUBRICATING OIL N39 TURNING GEAR N42 HYDROGEN SEAL N43 GENERATOR STATOR COOLING N45 GENERATOR HYDROGEN & CO2 PURGE N71 CIRCULATING WATER 061 PLANT SECURITY P11 CONDENSATE TRANSFER & STORAGE P21 DEMINERALIZER & MAKEUP WATER P33 SAMPLE SYSTEM P43 TURBINE BUILDING CLOSED LOOP COOLING WATER (TBCLCW)
P50 COMPRESSED AIR P71 LOW CONDUCTIVITY & SERVICE WATER DRAINS R24 MOTOR CONTROL CENTERS R34 AUXILIARY GROUNDING R41 DC INSTRUMENT POWER (48VDC)
R51 COMMUNICATION (IMIPA PLANT)
RS2 COMM-TELEPHONE (LEASED LINE)
R53 COMM-SOUND (POWERED TELEPHONE)
R54 COMM-RADIO R55 CLOSED CIRCUIT TV R61 UNIT PROTECTION & METERING S21 PLANT SUBSTATION S25 69KV SWITCHYARD / GAS TURBINE T51 REACTOR BUILDING LIGHTING V31 TURBINE BUILDING (TB) CRANES, HOISTS, ELEVATORS U51 TURBINE BUILDING LIGHTING V31 RADWASTE (RW) CRANES, HOISTS AND ELEVATORS V51 RADWASTE BUILDING LIGHTING W23 CHLORINATION X37 SECURITY BUILDING X46 0FFICE BUILDING HVAC X50 0FFICE BUILDING ANNEX X70 SECONDARY ACCESS FACILITY Y46 CATHODIC PROTECTION Y51 YARD LIGHTING
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PROTECTED SYSTEMS SYSTEM NUMBER SYSTEM TITLE B31 REACTOR WATER RECIRCULATION C11 CONTROL ROD DRIVE (CRD) HYDRAULIC CONTROL t
C32 FEEDWATER CONTROL C41 STANDBY LIQUID CONTROL C51 NEUTRON INSTRUMENTATION C61 REACTOR REMOTE SHUTDOWN 091 PROCESS COMPUTER E11 RESIDUAL HEAT REMOVAL E21 CORE SPRAY E32 MSIV LEAKAGE CONTROL E41 HIGH PRESSURE COOLANT INJECTION E51 REACTOR CORE ISCLATION COOLING M60 MAIN CHILLED WATER I
N11 MAIN STEAM N21 CONDENSATE AND FEEDWATER N22 HEATER RELIEF AND VENT LINES N23 MISC DRAINS SECONDARY PLANT N24 SEALING WATER
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N25 FEEDPUMP TURBINE SUPERVISORY INSTRUMENTATION (TSI)
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N31 TURBINE
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N32 TURBINE CONTROL N33 SEAL AND RADWASTE STEAM N35 MOISTURE SEPARATOR REHTR & DRAINS N36 EXTRACTION STEAM N37 MAIN TURBINE SUPERVISORY INSTRUMENTATION
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N41 GENERATOR N44 VACUUM PRIMING & AIR REMOVAL N51 EXCITATION N52 CONDENSATE DEMINERALIZER N62 RADWASTE OFFGAS i
P42 REACTOR BUILDING CLOSED LOOP COOLING WATER (RBCLCW)
P63 RADWASTE SOLIDS HANDLING P65 VIBRATION MONITORING R13 ISOLATED PHASE BUS S22 138KV TRANSFORMER BREAKER T24 PRIMARY CONTAINMENT INERTING T47 PRIMARY CONTAINMENT COOLING T48 PRIMARY CONTAINMENT ATMOSPHERIC CONTROL T49 PRIMARY CONTAINMENT INTEGRATED LEAK TEST PANEL X62 LONTROL ROOM SELF CONTAINED AIR SUPPLY 292 EXCESS FLOW CHECK VALVES Z93 POST ACCIDENT MONITORING
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