ML20009G486

Forwards Addl Info Needed for NRC Review Completion,In Response to NRC Request Re NUREG-0737 Compliance

ML20009G486
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/31/1981
From:	Mccaffrey B LONG ISLAND LIGHTING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.A.1.3, TASK-1.A.2.3, TASK-1.C.2, TASK-1.C.3, TASK-1.C.4, TASK-1.C.5, TASK-1.C.6, TASK-2.B.3, TASK-2.E.4.2, TASK-2.K.3.27, TASK-3.D.1.1, TASK-TM SNRC-608, NUDOCS 8108040332
Download: ML20009G486 (31)

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LONG ISLAND LIGHTING COMPANY s

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,, . m ..i SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY ROAD e WADING RIVER, N.Y.11792 July 31, 1981 py\ b $. .

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4 NRC-608 J ( g#

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Mr. Harold R. Denton, Director N Office of Nuclear Reactor Regulation o* N/.3'/

U.S. Nuclear Regulatory Commission s =d Washington, D.C. 20555 k( %

SHOREHAM NUCLEAR POWER STATION - UNIT I i Docket No. 50-322

Dear Mr. Denton:

Enclosed herewith are sixty (60) copies of LILC0 responses to specific NRC concerns which were previously identified as requiring additional information to complete NRC review.

Attachment A provides a list of the specific responses included.

If you require additional information or clarification, please do not hesitate to contact this office.

Very truly yours, 4

B.R. McCaffrey I" Manager, Project Engineering -

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NRC-608, dated 7/31/81 ATTACHMENT A Additional information is provided for the following items.

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1) NUREG-0737, item II.E.4.2 and SER OI 35 - Containment Isolation Dependability

2) SER 0143 - Loss of safety function after reset

3) NUREG-0737, item II.K.3.27 - Provide Common Reference Level for Vessel Level Instrumentation

4) NUREG-0737, item III.D.l.1- Primary Coolant Sources Outside the Containment

5) NUREG-0737, item I.A.1.3 - Shift Manning item I.A.2.3 - Administration of Training Programs item I.C.2 - Shift and Relief Turnover Procedures item I.C.3 - Shift Supervisor Recoonsibility item I.C.4 - Control Room Access item I.C.5 - Procedures for Feedback of Operating Experience to Plant Staff item I.C.6 - Procedures for Verification of Correct Performance of Operating Activities

6) NUREG-0737, item II.B.3 - Post Accident Sampling

7) NUREG-0737, item II.B.7 - Hydrogen Control

8) SER 01 59 - raatrol of Heavy Loads

9) NUREG-0737, item I. A.1.1 - Shift Technical Advisor l

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SNPS-1 FSAR II.E.4.2 CONTAINMENT ISOLATION DEPENDABILITY The circuitry for reactor vessel sample valves (penetration X-30; valve numbers 1B31*A0V081 and 082) will be modified such that reset -

of isolation signals will not cause the valves to reposition (open) automatically. Although they will open upon reset of the isolation signal, the RHR Heat Exchanger Sample Valves are not containment isolation valves. Circuitry modifications are, therefore, not re-quired for these valves.

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SN?S-1 FSAR Clarification to SER Open Item No. 43 - ESF Reset Controls Preoperational startup testing will be ';urforced that will confirm proper functioning of equipment (in accordance with design requirements) when control systems are reset.

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Clarification for Item II.K.3.27 - Additional Information, Common Refecence Level for Ves' - Level Instrumentation LILCL previously committed to providing a common water level reference by modifying the two fuel zone instrument indications to reflect the '

same reference zero (the bottom of the dryer skirt) as the other nine '

water level indications. The following additional information is provided regerding that modification. -

Presently the two instruments, one fuel zone water level indicator and one fuel zone water level recorder, have a range of +50 to -150 with reference points at 50, 0, -50, -100, and -150.

The instrument face plates will be modified to indicate a common water level reference range using scale values graduated in accordance with standard human factors reqJirements of "1, 2, or 5".

This is consistent with the other water level indications which provide the following indications:

(a) Sudtdown Range: 0 to +400 in increments of 100 inches.

(b) Narrow Range: 0 to +60 in increments of 10 inches.

(c) Wide Range: +60 to -150 with reference points at +60, +50, 0, -50, -100, and -150.

Rev. 7/29/81

SflPS-1 FSAR SUPPLEMENT TO LILCO RESPONSE TO ITEM III.D.I.1 REV. 1 1.

The following ,ystems are not included in the Shoreham leakage reduction and control program for the reasons indicated:

Feedwater, Main Steam Lines and Drains, Recirc Pump Seal Water - systems are non-safety related and will -

be isolated and not operating under accident conditions.

Scram Discharge Volume - system is normally drained and empty; insert and withdrawal lines will be visually inspected for leakage during' inservice hydrostatic testing of the reactor pressure vessel.

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To quantitatively measure leakage of water, the leakage will be collected in a measuring device and timed to determine GPM leak rate. Implementing procedures will establish criteria for initiation of leak rate quantification.

3 HPCI and RCIC will be qualitatively inspected for stetn leakage as indicated by signs of leakage, such as rust, piping discolora-tion of the floor or components under the component being observed, or visual observation of leaking saturated steam.

4. Lines associated with the Post Accident Monitoring System that contain water will be leak checked as described in Paragraph 2 above. Those lines containing gas will he checked by liquid soap bubble testing.

5. LILC0 review of the specific design / construction concerns asso-ciated with I&E Circular 79-21 has detcrmined that Shoreham as presently designed and constructed, pro. ides adequate protection against unplanned radioactive releases. Only one minor improve-ment was recommended as a result of the review, that was the addition of gasketing on two personnel doors in the radwaste buildi ng. This recommendation will be implemented.

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SNPS-1 FSAR I.A.1.3 Shift Manning NHL Position Assure that the necessary number and availability of personnel to can the operations shifts have been designated by the licensee. Adm nistrative procedures should be i

, erit ten to govern the novement of Ley ir dividuals about the plant to assure that ,

qualified individuals are readily available in the event of an abnornal or energency situation. This should consider the reconcendations on overtine in NUREG-0578.

Provisions should be made for an aide to the shift supervisor to assure that, over the long tern, the shift supervisor is f ree of routine administrative duties.

At any time a licensed nuclear unit is being operated in Modes 1-4 for a pressurized water reactor (power operation, startup, hot standby or hot shutdown, respectively) or in Modes 1-3 for a boiling water reactor (power operttion, startup, or hot shutdown, respectively), the mini n shift crew shall include two licensed senior reactor operators, one of whon shall be designated as the shift supervisor, two licensed reactor operators, and two unlicensed auxiliary operators. For a culti unit station, depending upon the station configuration, shift staffing nay be adjusted to allcw credit for licensed senior reactor operators and licenred reactor operators to serve as relief operators on nore than one unit; however, these individuals must be properly licensed on each such unit. At all other times, for a unit loaded with fuel, the nininun shift crew shall include one shift supervisor who shall be a licensed senior reactor operator, ons licensed reactor operator, and one unlicensed auxiliary operator.

Adjunct requirenents to the shift staffing criteria stated above are as follows:

(1) A shift supervisor with a senior reactor operator's license, who is also a nenber of the station supervisory staf f, shall be onsite at all tines when at least one unit is loaded with fuel.

(2) A licensed senior reactor operator shall, at all tines, be in the control roon from which a reactor is being operated. The shift supervisor nay from time to j

tiae act as relief operator for the licensed senior reactor operator assigned to :he control roon.

(3) For any station with more than one reactor containing fuel, the nunber of l licensed senior reactor operators onsite shall, at all tines, be at least one nore than the nunber of control rooms from which the reactors are being operated.

l l (4) In addition to the licensed senior reactor operators specified in (1), (2), and (3) above, for each reactor containing fuel, a licensed reactor operator shall be in the contro'. roon at all times.

i (5) In addition to the operators specified in (1), (2), (3) and (4) above, for each control roon f rom which a reactor is being operated, an additional licensed l reactor operator shall be onsite at all times and available to serve as relief

! operator for that control roon. As noted above, this individual may serve as i relief I.A.I.3-1 7/31/81

operator for each unit being operated frou that control roon, provided he holds a current license for caca unit.

(6) Auxiliary (non-licensed) operators shall be properly qualified to support the unit to which assigned.

(7) In addition to the staffing reqairenents stated above, shift crew assigunents during periods of core alterations shall include a licensed nenf or reactor operator to directly supervise the core alterations. This licensed senior reactor operator uay have fuel handling duties but shall not have other coacurrent operatLoual duties. ~.

Licensees of operating plants and applicants for operating licensees shall include in th2ir adainistrative procedures (required by license conditions) provisions governing required shift staffing and covement of key individuals about the plant. These provisions are required to aasure that qualified plant personnel to man the operational shifts are readily available in the event of an abnornal or emen;ency situation.

These administrative procedures shall alco set forth a policy, the objective of which is to operate the plant with the required staff and develop working schedu!es * .ch that use of overtine is avoided, to the extent practicable, for the plant staff who perforn safety-related functions (e.g., senior reactor operators, reactor operators, health physicists, auxiliary operators, instrumentation and control technicians, and key maintenaace personnel).

IE Circular No. 80-02, " Nuclear Power Plant Staf f Work llours," dated February 1, 1980, discusses the concern of overtime work for nenbers of the plant staff who perforn safety-related functions.

We recognize that there are diverse opinions on the amount of overtine that would be considered permissable and that there is a lack of hard data on the effects of overtire beyond the generally recognized normal S-hour working day, the ef fects of shif t rotation, and other factors. We have initiated studies in this area. Unitl a firmer basis is developed on working hours, the administrative procedures shall include as an interim ne asure the following guidance, which generally follows that of IE Circular No.

80-02.

In the event that overtime must be used (excluding extended periods of shutdown for refueling, major maintenance, or major plant nodifications), the follcwing overtice restrictions should be followed:

l (1) An Individual should not be permf' .;ork more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight (not including shift turnover tine)-

l (2) There should be a break of at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (which can include shift turnover time) between all work periods.

(3) An individual should not work nore than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period.

(4) An individual should not be required to work uore than 14 consecutive days I without having 2 consecutive days off.

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Ilowe ve r , recognizing that circutstances nay arise requiring deviation f rom the above restrictions, such deviation shall be authorized by the plant nanager or his deputy or higher levels of n.inagement in accordance with published procedures and with appropriate documenta: lon of the cause. If a reactor operator or senior reactor e perator ha. been working nore than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during periods of extended shutdown (e.g, at duties nway froa the control board), such individuals shall not be assigned shift duty in the control room without at least a 12-hour break proceeding such an assignment. He encourage the development of a staffing policy that would perait the licensed reactor operators and senior reactor operators to be periodically relieved of prinary duties at the control board, such that periods of duty at the board do not e med about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at a tioc. If a reactor operator is required to work in exc;ss of 8 continuous hours, he shall be periodically relieved of primary duties at the control board, such that periods of duty at the board do not exceed about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at a ti,ne.

The guidelines on overtine do not apply to the shift technical advisor provided he or she is provided sleeping accomuodations and a 10 minute availability is assured.

Operating license applicants shall complete these adminR,crative procedures before fuel loading. Developnent and inplenentation of the administartive procedures at operating plants will be reviewed by the Of fice of Inspection and Enforcement beginning 90 days af ter July 31, 1981.

LILCO Position The Shorehan Station Procedure entitled "Shif t Operations," will be revised prior to fuel loading in order to impienent the following:

1. When in Opertional Conditions 1-3, the shift coop] ene nt shall at a ninimum consist of the following personnel:

a. 1 Watch Engineer (SRO)

b. 1 Watch Supervisor (SRO)

c. 1 Nuclear Station Operator (RO)

d. I Nuclear Assistan* Station Operator (RO)

e. 2 Equipment Operators (non-licensed but trained and qualified l operators)

2. Uhen in Operational Conditions 4 or 5 and whenever the Reactor is loaded with fuel, the shift complement shall at a minicun consist of the following personnel:

! a. 1 Watet Engineer (SRO)

b. 1 Nuclear Station Operator (RO) or 1 Nuclear Assistant Station Operator (RO)

c. 1 Equipment Operator (non-licensed)

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3. During periods of core alteroticas, a licensed senior reactor > perator (aay be a refuel operation restricted licensed senior reactor operator) shall be ntationed on the reiuel floor to directly supervise all core alterations.

This senior reactor operator shall have no other concurrent ope ra tiona l dutics but uay have fuel handling duties.

4. In Operational Conditions 1-3, the Watch Supervisor shall be statto md in the control room. The Watch Engineer may temporarily relieve the Watch Supervisor in the control rooa for short periods such that a licensed senior reactor operato; is always in the control roon assumi:q the con *rol roon conaand function whenever in Operational Conditions 1-3.

5. Uhenever the reactor is loaded with fuel, a Nuclear Jtation Operato? shall be stationed in th control room (when in Operational Conditions 4 or 5, and the Reactor loaded with fuel, a Nuclear Assistant Station Operator may be substituted for the Nuclear Station Operator and hen in Operational Conditions 1-3, the Nuclear Assistant St ation Operator may tenporarily relieve the Nuclear Station Operator for short periods so that a licensed reactor operator is always in the control room whenever the Reactor is loaded with fuel). This requirement is in addition to the requirement for a licensed senior reactor operator when in Operational Conditions 1-3.

6. The shift schedule shall conform to the guidelines provided in the Shorehan Station Procedure entitled " Station Operations - Overtime Selection" as it applies to the scheduling and use of ove-time.

7. The novement in the plant by members of the shif t complenent shall be such that they may be easily and rapidly inforced and/or contacted and dispatched by the control roou operators in the event an emergency situation arises in order to assure that qualified plant personnel to can operational shif ts are readily available.

The Shoreham Station Procedure entitled " Station Operations - Overtime Selection," will be revised prior to fuel loading in order to inplement the following:

1. For those plant personnel who perform safety-related functions (e.g. ,

senior reactor operators, health physicists, equipmeTt operators, instrumentation and control technicians, and key maintenance personnel),

the routine use of overtime shall be avoided to the extent practical.

2. -a the event overtime nust be used (excluding extended periods of shutdown for refueling, major maintenance, or plant nodifications), the following overtime restrictions should be followed:

a. An ladividual should not be permitted to work nore than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight (not including shift turnover time).

b. There should be a break f at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (which includes shif t turnover time) between all work periods.

c. An individual should not work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period.

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d. An individual should not be required to work core than 14 consecutive dcys witno it having 2 consecutive days of f.

3. Deviations froa the above overtime restrictions shall be authorized by the Plant !bna;;er or his assigned deputy in the Plant !!anager's absence. The cause of the required deviation to these overtine restrictions shall be doeunented.

The Equipaent Operators (Shorehams Auxiliary Operators) are trained and qualified as outlined in the Shoreham Station Procedure entitled " Station Operator Training and Omilification Proc. ram." Since the Shorchum i'uclear Power Station containn only one usiit and since no other uutta are operated by LlLGO, the requireueat that Auxili2ry (nc4-licensed) operators be properly qualified to support the unit to which assigned is not a problem at Shoreham. -

Upon completion of the above revisions, the Shorehan liuclear Power Station will be in complete compliance with this Task Action Item.

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S:PS-1 FSAR 1.C.2 Shift and Relief Turnover Procedures NRC Position The licensees shall review and revise as necessary the plant procedure for shift and relief turnover to assure the following:

1. A checklist shall be provided f or the oncoming and of fgoing control"r'cora operators and the oncoming shift supervisor to couplete and sign. The following itcas, as a mininua, shall be included in the checklist:

a. Assurance that critical plant paraneters are uithin allowable liuits (parameters and allowable linits shall be listed on the checklist).

b. Assurance of the availability and proper alignment of all systems essential to the prevention and uitigation of operational transients and accidents by a check of the control console (what to check and criteria for acceptable status shall be included on the checklist).

c. Identification of systens and components that are in a degraded mode of operation pernitted by the Technical Specifications. For such systems and components, the length of time in the degraded mode shall be compared with the Technical Specifications action stateuent (this shall be recorded as a separate entry on the checklist).

2. Checklists or logs shall be provided for completion by the of fgoing and oncouing auxiliary operators and technicians. Such checklists or logs

! shall include any equipaent under uaintenance of test that by themselves I

could degrade a systen critical to the prevention and nitigation of operational transients and accidents or initiate an operational transients l (what to check and criteria for acceptable status shall be included on the checklist); and

3. A systen shall be established to evaluate the effectiveness of the shift and relief turnover procedure (for example, periodic independent verification of systen alignuen.s).

l LILCO Pc Jtion l

l The Shorehan Station Procedure entitled " Shift Operations," will be revised prior to l fuel loading in order to implement the following:

1. The onconing and offgoing control room operators and the oncoming Watch Engineer (Shorehan's Shift Supervisor) shall, prior to relieving their respective watches, coaplete and sign a cher.klist which will include, as a nininun, the following items:

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a- Assurance that critical plant paraneters are within allowable linits (parameters and allowable linits shall be listed on the

, checklist).

b. Assurance of the availability and proper alignment of all systeus essential to the prevention and nitigation of operational transients and accidents by a check of the control console (what to check and criteria for acceptabic status shall be included on the checklist).

c. Identification of systens and components that are in a degrah;d

c. ode of operation permitted by the Technical Specifications. For such system and components, the length of tiac in the degraded node shall be compared with the Technical Specifications action statement (this shall be recorded as a separate entry on the checklist).

2. Of f going and oncoming Equipment Operators (Shorenam's Auxiliary Operators) and technicians shall, prior to relieving their respective watches, complete and sign a checklist which will include any equipment under maintenance or test that by thenselves could degrade a systea critical to the prevention and ultigation of operational transients and accidents or initiate an operational transient (what to check and criteria for acceptable status shall be included on the checklist).

3. Periodic independent verification of the information turned over via the above checklists shall be performed so that the effectiveness of the shift and relief turnover procedure can be evaluated. Deficiencies discovered during this verification shall be identified and submitted to the Operating Engineer for review.

Cenpletion of the above revisions will uake the Shorehan h'uclear Pcwer Station be in complete coupliance with the Task Action Iteu.

1.C.2-2

S!;PS-1 FSAR I.C.3 Shift Supervisor responsibilities hkC Position In letters of Septenher 13 and 27, October 10 and 30, and I ovember 9, - 1979, HRC required licensees and applicants to re riew and revise as r.ecessary plant procedures and directives to assure that the duties, responsibilities, and anthority were properly defined to establish a definite lina of com.m:td and cl :ar delineation cE the conthd decision authority of the supervisor in the control roca relative to other plant runagement personnel. These letters also enphasized the primary management .

responsibility of the shift supervisor for safe operation cf the plant. Training prograns for shift supervisors were required to emphasize and reinforce the responsibility for safe operation and nanagement function of the shift supervisor to assure safe operation of the plant.

LILCO Position This Task Action Iten is included in Item I.A.1.2, Shift Supervisor Adctinistrative Duties and Item 1.C.4, Control Roon Access.

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SNPS-1 FSAR

• I.C.4 Control lhom Access NRC Position The licensee shall uake provisions for liniting access to the control room to those individuals responsible for the direct operation of the nuclear power plant (e.g.,

operations supervisor, shift supervisor, and control roon operators), to technical advisors who my be requ-sted or required to support the operation, and to p red e a ty,na t ed OC personnel. Provistans shall include tue followiu3: -

1. Develop and implement an administrative procedure that establishes the authority and responsibility of the person in charge of the control room to limit access.

2. Develop and inplement procedures that establish a clear line of authority and responsibility in the control room in the event of an emergency. The line of succession for the person in charge of the control roon shall be established and limited to persons possessing a current senior reactor operator's license. The plan shall clearly define the lines of communication and authority for plant management personnel not in direct command of operations, including those who report to stations outside of the control room.

LILCO Position The Shorehan Station Procedure entitled " Main Control Room - Conduct of Personnel,"

will be revised prior to fuel loading in order to implement the following:

1. No personnel, except those whose nornally assigned functions or specific assignments that require access, shall enter the control roon without prior approval of the Watch Engineer. The Uatch Engineer shall have the authority and responsibility to limit access to the control room as required to ensure that a professional atmosphere is always naintained and that the number of personnel in the control roca at any one time does not hinder the safe operation of the plant. This authority nay be delegated to the Watch Supervisor (SRO) when in Operational Conditions 1-3 or to the Nuclear Station Operator (RO) when in any other Operational Condition, if the Uatch Engineer is absent from the Control Room. Efforts by all other plant canagement personnel to linit access to the control room shall be made through the Watch Engine r or the person who has been delegated this authority and responsibility.

2. The Watch Engineer shall normally be the individual who is in possession of the control roon command function. This function nay be delegated to the Watch Supervisor when in Operational Conditions 1-3 or to the Nuclear Station Operator when in any other Operational Condition, if the Watch Engineer is absent from the Control Room. During all abnormal and energency situations, the Watch Engineer shall be in possession of the I.C.4-1 7/31/81

control room connand function or shall be lunediately contacted so he can assume the control command room function if he was absent froa the control roon at the onset of the abnormal or emergency situation. The only Individuals who may relieve the Watch Engineer under any circumstances is an individual in possession of a current senior reactor operators license and should only be accomplished af ter an adequate turnover in performed.

Futhermore, the Uatch Engineer should not be relieved of the connand control room function during abnornal, energency or operational situations unitl the plant is placed in a safe and/or stable condition.

3. At all times, ef forts by any m:mber of the plant staf f to direct activities which affect the safe operation of 'he plant shall be acceaplished th:-ough -

the individual in possession of the cci trol room command f unction.

4. When the Uatch Engineer delegates the control rocu command function, the person to who this function has been delegated shall keep the Watch Engineer fully informed of plant status and operations such that he can easily and rapidly assume the control room coacand function in the event that an abnormal or emergency situation arises.

Completion of the above revisions will nake the Shorehar. Nuclear Power Station in complete compliance with this Task Action Iten.

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O J.C.S Procetur<n for reffnacy. i or Opprating h >;pe r l . n c ..- to Plant Statt liRC Position In accordance witn Task Act2on Plan I.C.S, Procedures for Feedback of Operating Experltnce to Plant Staft (t UHi.G-0 66 0) ,

eacn applicant ;or an operating license Sall prepare procedures to assure that operating ini or:na t ica pertinent to plant sarety both uithin and outside the utility organizatTon in originating continually supplica to operators and other personnel and is incorporated into training and retraining prog rams . -These procedures shall:

(1) Clearly identity organizarinal responsibilities for review ot operatin' experlence, the feedback of pertinent Inf orn.ation to operators and other personnel, and the incorporation of such information into training anc retraining programs; (2) Identify the administrative and tecnnical review steps necesrary in translating recommendations 'y o the operating expe.lence assessment group into plant actions (e.g . , changes to procedures; operating orders) ;

(3) Identify the recipients of various categories of inrormation trom operating experience (i .e . , supervisory personnel, snitt

, technical advisors, operators, ma in tena::ce personnel, health physics techrsicians) or otherwise provide ::euns through wnich sucn information can be readily 1 elated tc une job f un ction s ,

of the recipients; (4) Provice means to assure that af f ected personnel become aware of and understand information of sufficient impor ta r.ce that should not wait for emphasis through rcutine training and

. retraining programs; (5) Assure that plant personnel do not routinely rece.1ve extraneous and unimportant informatica on operating experience in 'such volume that it would obscure priority Information or otherwise detract f rom overi-il job perf ormance and proficiency; .

(6) Provide suitaole checks t'o assure that conrlicting or contradictory inf ormation is not conveyed to operators and other personnel until resolution is reacnec; and, (7) Provide periodic internal audit to assure that the icedback program functions effectively at all level 2.

Each utility shall carry out an operating experience assessment function that will involve utility personnel having collective competence in all areas important to plant safety. In connection with this annessment function, it is important that I.C.5-1 7/31/81

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procedures exist to ausure that_ i mpor t . int i n i or r;n t i on on opera t ing c x pe r i a r.ce orig i s.a ti ng bo t31 watnin a nc' outside -the organization as continually provided t_ o ope ra tors and other personnel, and that it is ancorporated into plant operating procedures and training and retraining progra:as.

Those involved in the assessment of operatine experlence wi11 review informan10n ircm a variety of sources. These include operat.ing inf onaation from the licensee's own plant (s) , '

publicotlons such as IE nullet2ns, Circulars, anc t20 ti c e s,' una pertinent NRC or industrial assessnents of operating experlence.

In some cases, inicrmation may be of sufilcien: 1raporta nce' that it must be dealt with promptly (through instruct 3cas, enanges to operating and emergency procedures, issuance of special enanges.

to operating and emergency procedures, issuance of special precautions, etc.) and must be handled in such a manner to assure that operations manage! cent personnel would be directly involved i in the process. In many other cases, however, isaportan t information will become available which woula 1x.- brought to the

attention of cperators and other personnel for their general information to assure continued safe olant operation. Since the total volume of infonnation hanaled by tne assessment group may be large, it is important that assurance be provided that high-priority matters are dealt with promptly and t-

at discrimination is used in the icedback of other intorr.ation so that personnel are not deluged with unimportant and extraneots inf onna tim, 4o I. '

. the d etrine nt of their overall proficiency. It is .uaporta nt ,

also, that technical review be conducted to preclude premature dissemination of conflicting or contradictory Infor nat.ior,.

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LILCO Position The procedures for the feedback of operating experience and other important '

information to the appropriate Shoreham personnel are outlined below (1) a. The Shoreham Station Procedure entitled Review of Operations '

Committee (ROC) establishes the duties and functions of ROC which include review of Shoreham operating experience. The committee i ncludes the Plant Manager as Chairman, the Chief Operating Eoineer and Chief Technical Engineer as Vice-chairmen, and the various Section Heads as regular members. ROC advises the Plant Manager on all matters related to past, present and future operation and all matters related to public safety. The Review of Operating Committee is an essential part of the plant review program. A continuing effort is performed by the Review of Operations Committee to direct and monitor plant operation, and to plan future activities.

b. hocedures will be written to establish an Independent Safety En9 Pac.ing Group (ISEG) in response to the requirements of NUREG 0737 Item I.B.l.2. Major responsibilities of this group will be the review of the operating experiences of Shoreham as well as those of other stations of similar design, and the examination of appropriate plant operating characteristics and industry and NRC issuances. The ISEG will'be composed of a Chairman and five dedicated multi-disciplined personnel. The Chairman shall report directly to the Manager, Nuclear Oper-ations Support and shall transmit formal analyses and recom-mendations to h'm for presentation to appropriate corporate management.

c. The Shoreham Station Procedure entitled " Required Reading List" j

establishes the Plant Manager, the Chief Engineers, and the Section Hear,s as the organizational personnel responsible for identifying

} per inent information for feedback to operators and other personnel.

Shoreham procedures will give the ISEG the authority to recommend for inclusion in the feedback to operators and other personnel any pertinent information or sienificant operating experience selected from the material it has reviewed.

i d. Shoreham Station Procedure entitled " Training Responsibilities" l makes the Training Supervisor responsible for coordinating the l preparation and revision of training programs and lesson plans.

l I.C.5-3

Section Head: provide recommendations and other input information to the Training Supervisor for the updating of training programs in their section's area of responsibility. At such time they would recommend revision to incorporate the most recent operating experience or other iniportant information into the lesson plans.

(2) Shoreham procedures which are being written to govern the activi4y .

I of the ISEG will establish the following review cycle. The ISEG will perform safety assessments of appropriate NRC issuan~ces, .

vendor technical correspondence, Shoreham LER's and operating experience, and appropriately related INP0/NSAC reports. Based on their reviews, ISEG may make recommendations for appropriate actior +o the Manager, Nuclear Operations Support. He will then send those recommendations which are the responsibility of the plant staff to the Shoreham Plant Manager.

The Shoreham Station Procedure entitled " Technical Correspondence and Bulletins" provides a controlled documented technical review and disposition cycle for all important doc _uments received at Shoreham. The procedure assures that appropriate recommended actions are taken. The procedure will be modified to include ISEG recommendations among the items tracked in this fashion.

(3) The Shoreham Station ~ Procedure entitled " Required Reading List" identifies the groups which may receive the various categories of information from operating experience via the required reading list.

(4) The Shoreham Station Procedure entitled "Requ>ed Reading List" allows for alternate methods such as supervisor lectures, staff meetings, section meetings or preplanned lectures for the expe-i.

ditious propagation of certain information requiring the special attention of station personnel.

(5) The Plant Manager, the Chief Engineers and the Section Heads are responsible for limiting the materials they submit for inclusion on the Required Reading List to essential information only. The Training Supervisor, who administers the circulation of Required Reading Lists in accordance with the Shoreham Station Procedure of the same title, serves as a further check to assue that plant personnel do not routinely receive extraneous and uninportant information on operating experience.

Review of operating experience and other information by the ISEG will serve to separate out extraneous material before it reaches

, the plant in the form of ISEG recommendations. In addition, the material received by ISEG from the INP0/NSAC Significant Event I.C.5-4 i - _

Evaluation and Infonnation Network is initially screened by INP0 and NSAC.

(6) The Plant Manager, the Chief Engineers, and the Section Heads

, are responsible for assuring that the material they submit for inclusion on the Requireo Reading i.ist does not include conflicting ~

or contradictory information. The Training Supervisor, who admin-isters the circulation of the Required Reading List in accordance with-the Shoreham Station Procedure of the same title, serves as a further check to prevent the conveyance of conflicting or contra-dictory information.

The ISEG will note any contradictory or conflicting information in the matericl they review and will thereby prevent its conveyance to operators or other personnel, INP0 and NSAC are taking special measures to avoid. the dissemination of conflicting or contradictory

information via their issuances, thus all material received by j ISEG from INP0/NSAC will have already been screened.once.

(7) Shoreham procedures being written to ' govern the activities of the ISEG will provide for ISEG evaluation of the Shoreham feedback program.

The Training Supervisor or Section Heads may elect to include examination ' questions covering material from the operating experience feedback process that has been incorporated into the Shoreham training program. This would provide an additional quantitative measure of the effectiveness of the feedback cycle.

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1.C.5-5

. . , _ _ . . . . _ _ _ . . _ . . _ _ _ . _ . . . _ _ . __ -. ___ , __ m __

SNPS-1 FSAR I.C.6 Procedures for Verification of Correct Performance of Operating Activities NRC Posi tion it is required (from NUREG-0660) that licensees' procedures be revieued and revised, as necessary to assure that an ef fective systen of verifying the correct performance of operating activities is provided as a ueans of reducing human errors and improving the qual!Ly of nornal operations. This will reduce the frequency of occurrence of , ,

situations that could result in or contribute to accidents. Such a verificaLion systen uay include autonatic system status monitoring, human verification of operations, and Luintenance activities independent of the people performing the activity (see ~

NUREG-0535, Reconuendation 5) or both.

luplement -ton of automatic status monitoring if required will reduce the extent of bunan verification of operations and maintenance activities but will not eliminate the need for such verification in all instances. The procedures adopted by the licensees may consist of two phaces - one before and one after installation of automatic status nonitoring equipment, if required, in accordance with iten I.D.3 of UUREG-0660.

An acceptable progran for verification of operating activities is described below.

The American Nuclear Society has prepared a draf t revision to ANSI Standard N18.7-1972 (ANS 3.2) " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." A second proposed revision to Regulatory Guide 1.33, " Quality Assurance Progran Requirements (Operation)," which is to be issued for public comment in the near future, will endorse the latest draft revision to ANS 3.2 subject to the following supplemental provisions:

(1) Applicability of the guidance of Section 5.2.6 should be entended to cover surveillance testing in addition to naintenance.

(2) In lieu ot cay designated senior reactor operator (SRO), the authority to release systems ; e<uipment for maintenance or surveillance testing or return-to-service may be delegated to an on-shift SRO, provided provisions are made to ensure that the shift supervisor is kept fully informed of systen status.

(3) Except in cases of significant radiation exposure, a second qualified person should verify correct implementation of equipment control neasures such as tagging of equipnent.

(4) Equipment control procedures should include assurance that control-room operators are informed of changes in equipment status and the effects of such changes.

(5) For the return-to-service of equipment important to safety, a second qualified operator shouli verify proper systens alignment unless functional testing can be perforned without compronising plant safety, and can prove that all equipuent, valves, and switches involved in the activity are correctly aligned.

1.C.6-1 7/31/81

' !;0iE: A licensed operator possessing knowledge of the systens involved and the relationship ot the systens to plant safety would be a " qualified" person. The staff is investigating the level of qualification necessary for other operators to perform these functions.

For plants that have or will have automatic systen status noni.toring as discussed in Task Action Plan Iten I.D.3, NUltEG-0660, the extent of human verification of op. rations and maintenance activities will be reduced. However, the need for such verification will not be eliminated in all instances.

LlILO Pos it i on The Shorehan Station Pracedures which govern equipment control measures, maintenance and surveillance activities will be revised prior to fuel loading in order to implement the following:

Control ceasures such .s locking or tagging to secure and identify equipaent in a controlled status shall be required. Control room tagouts shall be designed and installed to prevent obstruction of other instruments, controls, or indicating lights.

The status of inspections and tests performed upon individual items on the nuclear power plant shall be indicated by the use of markings such as stamps, tags, la be ls ,

routing cards, or other suitable means. Suitable neans include id,ntification numbers which are traceabic to records of the status of inspections and tests. items which have not satisfactorily passed required inspections and tests shall be identified where necessary to preclude inadvertent bypassing of such inspections and tests. In cases where required documentary evidence is not available, the associated equipment or naterials must be considered nonconforming. Until suitable docuaentary evidence is available to show the equipment or material is in conformance, af fected systers shall be considered to be inoperable and reliance shall not be placed on such systeus to fulfill their intended safety functions.

Permission to release plant systens or equipment for maintenance, surveillance tests, or return-to-service shall be granted by the on-duty Watch Engineer. This authority j aay be delegated to the on-duty Watch Supervisor provided the Watch Engineer is kept j fully informed of systen status. Prior to granting permission, such operating personnel shall verify that the equipment or system can be released, determine what functional testing of redundant systens is required prior to and during the out-of-service period. Granting of such permission shall be documented. Attention shall be given to the potentially degraded degree of protection when one subsysten of a redundant safety systen has been removed for caintenance or surveillance testing.

In addition to the requirements of the Technical Specifications, additional conditions to be considered in preparing equipment for maintenance or surveillance testing l

include, for example: shutdown margin, method of emergency core cooling; establishuent i of a path for decay heat removal; temperature and pressure of the systen: valves between work and hazardous naterial; venting, draining and flushing; entry into closed vessels; hazardous atmospheres; handling hazardous caterials; and electrical hazards.

l When entry into a closed systen is required, control neasures shall be established to i

prevent entry of extraneous material and to assure that foreign naterial is renoved before the systea is reclosed.

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After permission has been granted to remove a systen from service, it

• hall be nade

' safe to work on. Measures shall provida for protection of equipuent and workers.

, Equipment and systens in a controlled status shall be clearly identified, at a nininum, at any location where the equipment can be operated. When a safety-related system is renoved frua service, independent ve r i fica tion shall be provided to the extent necessary to assure that the proper systen was removed. This nay be accomplished by checking appropraite equipment and controls, or by indirect means such as observation of indicators and status lights. This requiremen' may be waived if the only way of accouplishing it would result in significant radiation exposure. The Control Room operators and the Watch Engineer shall be informed of changes in equipment status and the effects of such changes.

Teuporary modifications, such as temporary bypass lines, electrical jumpers, lifted electrical leads, and temporary trip point settings, shall be controlled by appro'ved procedures which shall include a requireaent for independent verification by either a second person or by a functional test which conclusively proves the proper installation or renoval of the temporary nodification. A log shall be maintained of the current status of such temporary nodifications.

When equipment is ready to be returned to service, operating personnel shall place the equipuent in operation and verify and document its functional acceptability. Attention shall be given to restoration of Larmal conditions, such as removal of jumpers or signals used in naintenance or testing or such as returning valves, breakers or switches to proper start-up or operating positions from " test" or " manual" positions, and assuring that all alarms which are indicative of inoperative status are extinguished. For safety-related equipment, proper alignnent shall be independently verified by a second qualified person before the equipment is returned to service unless all equipaent, valves, and switches involved in the activity can be proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant. A second exception is where such verification would result in significant radiation exposure. The person who performs the verification of correct inplenentation of equipment control measures or proper alignment prior to returning equipment to service shall be qualified to perfora such tasks for the particular system involved, and shall possess operating knowledge of the particular system involved and its relationship to plant safety. This qualification shall consist of training, verification and documentation to ensure that this person does possess operating knowledge of the particular system involved and its relationship to plant safety.

Muni placed into service, equipment should receive additional surveillance during the run-in period. Final acceptance of equipment which is returned to service sball be rude by the on-duty Watch Engineer.

The above revisions will nake the Shorehan Nuclear Power Station in couplete compliance with this Task Action Iten.

1.C.6-3

SNPS-1 FSAR

, 1.n.2.3 Acministration or Training Proa rant URC Pos>.tlon Penuing e-crealtation or trauting 2nstitutions, 11censees and applicants for operating licenses will assure tnat training center and racility instructors who teach systems, inte-grated responses, tranalent, ana simulator courses deronstrate serrior reactor operator (bno) qualifications und be enrolled- in appropriate requalnication programs.

Tn1., is a short term position. In the tuture, accreditauon ot train ng Institutions util niclude review of tne procedure Ior c Cert 1I1Cdtlon ot n1structors. Tne certitication of 1hstructors may, or may not, include successurul comoletion or an SRO exeination.

The purpose or the examnation is to provide Nhc with reasonable assurance during the interna periou, tnat instructors are technically competent.

Tne requuement is directed to permanent me'ahers or traunng start wno teacn tne sun 3ects enumerated above, inclucting mentbers at other organizations who routinely conduct training at the racinty . Tnere is no intention to require guest lecturers who are experts in particular subjects (reacccr tneory,

('- instrumentation, tnermodynamics, health physics, enemistimj, et c. )

to successtully complete an SRO examination Nor is in Intended to require a system expert, such as the instrument and control supervisor teacning tne control roa drive system, to sit for an SRO examination.

LILCO Position It la LILCO*s position that permanent memhers or the training start wno teacn systems, integraten responses, or translents ce quallIled or certuied to teach in the appropriate suDject area.

Tne qualu lcation or certirication or permanent raembers or tne training starr may De accomplishea by either of tne Iollowing-

1. Successtui completion of an Shu certirication examination on an appropriate simulator ; or

2. buccessrul completion or an NRC dRu exantination.

LILCO does not intend to rquire eitter guest lecturers who are experts in particular sut.Jects (reacter tnecry, instrumentation, tnermodynamics, health pnysics, chemistry, etc.) to successrully I.A.2.3-1 7/31/81

,~ SNPS-1 FSAa complete an rJRC SRO examination; or system experts, such as an instrumann and control supervisor teaching the control rod dr.tve system to successrully complete an IntC SRO examinat. ten e

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e SNPS-1 FSAR II.B.3 POST-ACCIDENT SAMPLING (Additional Information)

1) Chloride, pH, and boron analyses are performed by electrode . , _

analysis with vendor assurance and documentation that the associated instrumentation will meet the appropriate environ- ~

mental qualific ation for radiation field reliability. Procedures will be developed prior to fuel load upon receipt of the vendor supplied equipment and instructions.

2) Mutually acceptable procedures for off-site chemical analyses

! will be developed by Lilco and the selected laboratory.

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i 7/31/81

. SNPS-1 FSAR O

II.B.7 IlYDROGEN CONTROL (ADDITIONAL INFORMATION)

1. The hydrogen recombiners will function with an inerted containment. ~~ -

2. The recombiners will recombine 3 SCFM of oxygen with 6 SCFM of hydrogen.

3. Generation of oxygen results only from the radiolytic decomposition of water. The rate varies with temperature and location (drywell, wetwell).

The quantities (rates) are determined frco Fig. 3.1 (attached) of Draft 4 of proposed standard ANSI-N-275, ANS 56.1 June 1976, " Containment Hydrogen Control".

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0 SNPS-1 FSAR b

Item No. 59 - LILC0 Response to Staff Position Regarding Interim Actions for Control of Heavy Loads The following requirements will be implemented at Shorehaa prior to the ,..

placement of new fuel assemblies in the Reactor Building:

~

1) Safe load paths will be de' fined in accordance with the guidelines set forth in Section 5.1.1 (1) of MUREG-0612 with the exception that floor markings will be limited to "where practical" due to the inherent radial and polar pathways traveled by the polar crane.

2) Procedures will be developed and implemented per the guidelines set forth i.n Section 5.1.1 (2) of NUREG n612.

3) Crane operators will be trained, qualified and conduct themselves per the guidelines set forth in Section 5.1.1 (3) of NUREG-0612.

4) Cranes will be inspected, tested, and maintained in accordance with the guidelines set forth in Section 5.1.1 (6) of NUREG-0612.

5) In addition to the above,"s'pecial attention will be given to

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># procedures, equipment, and personnel for the handling of heavy loads over the core. This special review will include: a review of procedures for the movement of the load; a periodic visual inspection af load bearing components of cranes, slings, and special lifting devices to identify flaws or deficiencies that could lead to failure of the corponent; as appropriate, repair and replacement of defective components; and verif.ication that the crane operators have been properly trained and are familiar with specific procedures used in handling these loads.

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A 7/31/81

SNFS-1 FSAR Clarification to Item T.A.1.1 - Shift Technical Advisor INPO STANDARD LILCO TRA?.NING PROGRAM TOTAL EQUIV. ,

EQUlV. EQUIV.

TOPIC iOURS OST HOURS SIMULATOR HOURS TRAINING HOURS i (Note)

. Admin Controls 80 42 8* 50*

(Note)

3. Gen Op Proced 30 3 36* 3*

E. Transient Analy 30 60*: 60*

. Simulator Classroom 50 100 160 ,

Cont Room 50 60

• Redundant reporting of simulator training program as listed in item F.

Note: Additional experience hours in administrative controls and general operating '

procedures are a natural and obvious dccurrence through on the-job. training which the STA's will receive during the period beginning with the completion of the formal training program and ending with plant operation.

7/31/81

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