ML20040E747
| ML20040E747 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/14/1982 |
| From: | Gallo R, Higgins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20040E742 | List: |
| References | |
| 50-322-81-22, IEB-80-19, IEB-80-20, IEB-81-02, IEB-81-2, NUDOCS 8202050308 | |
| Download: ML20040E747 (10) | |
See also: IR 05000322/1981022
Text
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lj.S. NUCLEAR REGULATORY COMMISSION
Region I
Report No. 50-322/81-22
Docket No. 50-322
Category
B
License No. CPPR-95
Priority
--
Licensee:
Long Island Lighting Company
175 East Old Country Road
Hicksville, New York 11801
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Facility Name:
Shoreham Nuclear Power Station, Unit 1
Inspection at:
Shoreham, New York
Inspection conducted: November 23 - December 31, 1981
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Inspectors:
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J.[. Higgfs, Senior Resident Inspector
date signed
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date signed
date signed
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Approved by:
R. M. Gallo Chief, Reactor Projects Section lA
'date signed
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Projects Branch #1, DRPI
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Inspection Summary:
Inspections on: November 23 - December 31, 1981 (Inspection Report No. 50-322/81-22)
Areas Inspected: Routine onsite regular and backshift inspections by the resident
inspector (92 inspection hours) of work activities, preoperational testing, and
plant staff activities including:
tours of the facility; test witnessing, review
,
of NRC Bulletins and Circulars, review of design change control, maintenance review,
,
and followup on previous inspection findings.
Results: Of the six areas inspected no violations were identified in five areas and
one in the sixth area (failure to follow procedures governing design change control,
paragraph 5.c).
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r202050308 820114
PDR ADOCK 05000322
G
POR
Region I Form 12
(Rev. April 77)
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DETAILS
1.
Persons Contacted
D. Durard , Lead Startup Engineer (L)
T. Gerecke, Quality Assurance Manager (L)
J. Kelly, Field QA Manager (L)
W. Matejek, Lead Advisory Engineer (S&W)
M. Milligan, Project Engineer (L)
J. Morin, Senior Licensing Engineer (L)
A. Mueller, Acting 00A Engineer (L)
R. Perra, Asst. Supt. FQC (S&W)
J. Riley, Lead Startuo Engineer (GE)
J. Rivello, Plant Manager (L)
J. Smith, Manager, Special Projects (L)
W. Taylor, Asst. Supt. FQC (S&W)
D. Terry, Assistant Startup Manag)er (L)
E. Youngling, Startup Manaaer (L
L
- Long Island Lighting Company
S&W - Stone and Webster
The inspector also held discussions with other licensee and contractor
personnel during the course of the inspection including management,
clerical, maintenance, operations, engineerino, testing, quality assurance and
construction personnel.
2.
Previous Inspection Item Update
a.
(closed) Unresolved Item No. (322/81-01-03): Automatic Damper Operation:
Revision 23 to the FSAR, dated October 1981, changes the system description
in paragraph 9.4.4.2 so that it agrees with the actual in plant arrangement
of the Turbine Building Ventilation System. This item is closed.
b.
(closed) Inspector Follow Item No. (322/81-12-13): Review of Repair / Rework
Requests for LDR applicability: Revision 2 to 0AI-10.4-01 which was issued
on 11/30/81 specifies that each Repair / Rework Request must be reviewed by
Operational Quality Assurance to determine if the deficient condition
warrants a LILC0 Deficiency Report (LDR). This item is closed.
,
c.
(closed) Unresolved Item (322/81-12-08): Electrical Wiring Checkout: This
item has been escalated to a violation, as described in paragraph 5.c of
this report. The unesolved item is therefore closed and all followup will
be under the violation, number (322/81-22-03),
d.
(open) Unresolved Item (322/81-12-07): Submerged Electrical Cables:
Safety-related electrical cables in Electrical Manhole No. 2 by the screen-
well
were originally noted to be underwater in July. On July 27, 1981
E&DCR F-35998 was written to install covers /pluas over the manholes. This
was not done and on November 27, 1981 the inspector noted that the cables
were again underwater. The licensee had the manholes pumped dry and covers
installed by December 4,1981.
The inspector questioned the effect of
continued submergence in brackish water on the cables. This item remains open.
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3.
Plant Tour
a.
Discussion
The inspector conducted periodic tours of accessible areas in the plant
during normal and backshift hours.
During these tours, the following
specific items were evaluated:
-- Hot Work: Adequacy of fire prevention / protection measures used.
-- Fire Equipment: Operability and evidence of periodic inspection of
fire suppression equipment and review of fire insurance inspection reports.
-- Housekeeping: Minimal accumulations of debris and maintenance of
required cleanness levels of systems under or following testing.
-- Equipment Preservation: Maintenance of special orecautionary measures
for installed equipment, as applicable.
-- QA/QC surveillance: Pertinent construction and startup activities were
being surveilled on a sampling basis by qualified QA/QC personnel.
-- Security: Adequate site construction security.
-- Weld Rod Control: Observations to determine weld rod was being controlled
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in accordance with site procedures.
With the exception of the below item no discrepancies were identified.
b.
Document Control
During a plant tour, the inspector noted several wiring drawings affixed
to the inside of control room panels. These drawings were not in use but
were not the latest revision and were not marked "V0ID" or uncontrolled.
The inspector questioned this situation. The licensee's representative
stated that personnel are responsible for ensuring drawings being used are
the latest and had them removed to prevent any inadvertent use. A LILC0
Deficiency Report (LDR #0570) was written by Operational Quality Assurance
(0QA) to obtain corrective and preventive action. The inspector also
reviewed the last four 00A surveillances and the last two 00A Audits of
drawing and document control and noted that the area was being addressed
by the licensee. The inspector had no further questions at this time.
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4.
NRC Bulletins and Circulars
a.
Documents Closed
Bulletin 80-19: This Bulletin, titled " Failures of Mercury-Wetted Matrix
Relays in Reactor Protective Systems of Operating Nuclear Power Plants
Designed by Combustion Engineerina", and Rev. I to the Bulletin describe
repeated failures of the subject relays manufactured by the C. P. Clare Co.
The licensee has reviewed his facility and determined, as requested by the
Bulletin, that such relays are not used in the reactor protection. system at
Shoreham. These relays have been added to the Licensee's Deficient Items
List to prevent procurement in the future.
During tours of the plant, the
inspector reviewed documents and observed the components used in various
reactor protection system panels on a random basis and noted that none of the
subject relays were used. This Bulletin is closed.
Bulletin 80-20: Bulletin 80-20, " Failure of Westinghouse Type W-2 Spring
Heturn to Neutral Control Switches", described a malfunction of the subject
switch. The licensee's review of the facility revealed that none of these
switches are used at Shoreham in any Class 1E application. The switches have
been added to the licensee's Deficient Items List to prevent procurement in
the future without corrective action. The inspector independently reviewed
selected plant documents to determine if these switches had been purchased
or used and also toured the facility to observe equipment control switches
actually in place.
None of the subject switches were identified. This
Bulletin is closed.
Bulletin 81-02: This Bulletin, titled " Failure of Gate Type Valves to Close
Against Differential Pressure", along with Supplement No. I to the Bulletin
describe certain Westinghouse and Borg-Warner motor operated gate valves
which would not shut against the required design differential pressure.
The licensee reviewed his facility and determined that none of the subject
valves were used at Shoreham. The valves were added to the Deficient Items
List to preclude procurement in the future. The inspectcr reviewed various'
documents onsite and during plant tours observed, on a random basis, the
motor operated gate valves installed in the plant. None of the subject
valves were identified. The inspector also reviewed valve specifications
SH1-288V, " Motor Operated Carbon Steel Valves 2b in, and Larger" from the
Velan Corp. and noted that the specification required that the motor operators
of all valves be able to open and close the valves against full differential
pressure at specified rates of travel. This Bulletin is closed.
b.
Documents Remaining Open
Circular 81-01: This Circular, titled " Design Problems Involving Indicating
Pushbutton Switches Manufactured by Honeywell Incorporated" describes two
problems that manifest themselves during relamping, namely:
(1) a short
circuit may be induced; and (2) the circuit controlled by the switch may
inadvertently be actuated. The Circular specifically addresses Series 2
indicating pushbutton switches by the Micro Switch Division of Honeywell
Incorporated, but states that the deficiencies cited may be common to other
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indicating pushbutton switches and that holders of construction permits
should scrutinize the design of other pushbutton switches in their facility
for susceptibility to the above problems. The licensee's review revealed
that none of the Series 2 switches were used at Shoreham but the review
did not address similar switches. The inspector toured the facility and
noted several types of indicating pushbutton switches used in the control
room which appeared to be susceptible to the above problems during relampirg.
Somo of the locations where these switches were noted are: the rod select
matrix, main turbine electro-hydraulic control panel, reactor feed pump
turbine control, rod sequence control system, and neutron monitoring system.
This Circular remains open.
5.
Design Change Control
a.
Documents Reviewed
The inspector reviewed the following documents pertaining to design change
control:
- FSAR sections 14 and 17;
- Operational Quality Assurance Manual;
- Engineering Quality Assurance Manual;
- ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of
Nuclear Power Plants;
- Startup Manual ;
- FQC Procedure QC5.2;
- CSI 2.16, E&DCR Implementation Verification Program;
- Startup Instruction No. 2, Electrical Checkout Instructions ;
- Selected Engineering & Design Coordination Reports (E&DCRs); and
- Selected Drawings and weekly drawing summary sheets,
b.
Discussion
The inspector reviewed the above documents to determine the completeness
and effectiveness of design change control methods, particularly during
the time period when systems are under the jurisdiction of the Startup
Group.
Design changes are generally approved via an Engineering & Design
Coordination Report (E&DCR), although sometimes a change to an electrical
system may be approved via a simple drawing revision. When a system is
under construction's jurisdiction all E&DCRs are posted against the controlling
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document (e.g. the drawing) and then at time of system turnover or release
to Startup the system is verified to be constructed in accordance with all
the latest documents including any E&DCRs. After turnover to Startup, all
E&DCRs and drawing revisions are distributed to Startup by Engineering.
The Startup Test Engineer then has the responsibility to review the design
change.
If work nust be done in the field to effect the change, the Test
Engineer must write a Repair / Rework Request to implement the EADCR. He must
also ensure that any design changes are properly incorporated into the Test
Program. With the exception of the below items the inspector identified no
discrepancies in the program.
c.
Electrical Wiring Checkout
The licensee perfonns electrical wiring checks as part of the Startup Test
Program per Startup Instruction No. 2 " Electrical Checkout Instructions"
and Procedure CG.000.007, " Low Voltage Control Circuits". The instruction
also details the evaluations and required documentation when drawings are
revised due to design changes to circuits that have already had their wiring
checkout completed. The inspector reviewed the implementation of this
program and noted that the requirements had not, in all cases, been followed.
This constitutes a violation, as described below and is designated Item No.
(322/81-22-02).
10 CFR 50, Appendix B, Criterion III requires that design interfaces among
organizations be c3ntrolled by the establishment of procedures and that
design changes be subject to design control measures commensurate with those
applied to the original design.
10 CFR 50, Appendix B, Criterion V; Shoreham FSAR, Secticn 17.2.5; and the
LILC0 Operational Quality Assurance Manual, Section 5.3.1 require that
activities affecting quality be accomplished in accordance with documented
instructions, procedures, and drawings.
1.
Startup Instruction No. 2, Rev.1, " Electrical Checkout Instructions",
page 2, requires that the wire checking and functional testing of
electrical circuits be documented by " yellow-lined" elementary diagrams
or drawings called " Yellow-Lined Masters".
Contrary to that requirement, on December 14, 1981 there was no Yellow-
Lined Master in the Startup Resource Center Yellow-Lined Master File
for drawings ESK-11R4204 or ESK-6T2301.
2.
Startup Instruction No. 2, page 2 and 3, requires that prior to the
Preoperational Test the' Test Engineer review changes made to his system
by Engineering and Design Coordination Reports (E&DCRs) and by drawing
revisions. The latest drawing and the Yellow-Lined Master drawing
then must be stamped, dated, and initialed to indicate whether additional
testing is required or whether the design changes do not affect the tests
performed.
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Contrary to that requirement, on December 14, 1981 there was no stamping
or other documentation on the below listed drawings in the Startup
Resource Center Yellow-Lined Master File to indicate that tne latest
revisions had been reviewed by the Test Engineer prior to the Preoperational
Test:
ESK-5R2303, ESK-5R2304, ESK-6P2108, and ESK-6P2111.
3.
Startup Instruction No. 2, page 3, requires that all superseded drawings
be retained in the Yellow-Lined Master File.
Contrary to that requirement, as of December 14, 1981 numerous superseded
drawings were not retained in the Startup Resources Center Yellow-Lined
Master File, including:
ESK-11R4204, original and Rev.1
ESK-6T2301, Rev. 2
ESK-6G1133, Rev. 5
ESK-6P2111, Rev. 3
4.
Field Quality Control Procedure QC5.2, Rev. C, Change 3, paragraph 4.3.4.3
requires that superseded documents, which are retained, be marked "V0ID".
Contrary to that requirement, numerous superseded drawings retained in
the Startup Resource Center Yellow-Lined Master File were not marked
"V0ID", including:
ESK-11R4201, Rev. 3
ESK-11R4202, Rev. 2
ESK-5R4301, Rev.11,11A,12, and 13
ESK-6R4308, Rev. 3
ESK 5R2304,
Rev. 6, 6A, 68, and 6C
ESK-6G1104, Rev. 3
ESK-6G1114, Rev. 2
d.
Additional Program Comments
In addition to the above violation, the inspector noted that the design
change documents (E8DCRs and drawing updates) were not distributed in a
controlled manner to the Startup Test Engineers,who are responsible for
implementing the design changes and for incorporating the changes into the
test program. The inspector also noted that procedures in place do not
fully detail methods to assure and document that each design change,
issued after Startup has jurisdiction of a system, is both incorporated
into the plant and into the test program. Particular areas noted to be
not adequately covered were: documentation of actions for an E&DCR issued
when a drawing change does not result; documentation of action for E&DCRs
and drawing changes for other than electrical drawings; actions to be taken
and resulting documentations when changes occur after the Preoperational
Test has been released for performance.
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Some examples from the Startup Resource Center files are listed belcw to
illustrate the above concerns.
- Drawings ESK-6C4101 and ESK-6C4101A: 'The Yellow-Lined Master drawing
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shows three series "49 " contacts, but EADCR F-32001 changes the circuit
to have only one contact. The documents are unclear as to which arrange-
ment was checked out. Also terminal point 3A was Yellow-Lined, while the
components originally connected to 3A have been reconnected to IA.
- Drawing ESK-6C4101: The Yellow-Lined Master indicates that contact No.11
comes from tank no. 4, while three affecting E&DCRs indicate it is from
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tank no. 3.
- Drawing ESK-11R4201: The Yellow-Lined Master was completed on Rev. 3 on
4/26/79.The Preoperational' Test (PT) was completed in 1980. On 8/20/81
E&DCR F-36378A was issued and on 10/1/81 Rev. 4 was issued. As of 12/14/81
Startup still had jurisdiction of the system, had submitted a package to
the Plant Staff for turnover of the system, yet there was no documentation
in the Yellow-Lined Master to show that the E&DCR and Rev. 4 had been
reviewed to determine if retesting was required.
- Drawing ESK-6G1114: Rev. 3 was the Yellow-Lined Master.Rev. 4 was
issued after PT release and there was no documentaticn to indicate
review for required retesting.
This item is unresolved and is designated as unresolved item no. (322/81-22-03).
6.
Control Rod Drive (CRD) System
a.
Discussion
The inspector reviewed the below documents:
- PT.106.001, " Control Rod Drive System" Preoperational Test;
- Piping and Instrumentation Drawings FM-27A, B, and C;
- FSAR sections 4.23 and 14.1.3.7.18;
- NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line
Nozzle Cracking";
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- Letter from NRC to LILCO dated 3/11/80;
- Letter from GE to NRC dated 11/27/79; and
- Selected Checkout and Initial Operation (C&IO) tests.
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The inspector also toured various portions of the CRD system both in
company with licensee representatives and alone. Based on the document
review and system tours, the inspector compared the installed system and
system test procedure to regulatory requirements and licensee comitments.
The inspector also reviewed C&IO test results to determine if appropriate
acceptance criteria had been met.
The inspector witnessed portions of PT.106.001, which were perfomed in the
main control room and the reactor building including: GD venting, CRD
movement, and CRD scram time testing. During the test the inspector
noted that:
- the test procedure was approved and released for performance by the JTG;
- test procedure was in use by personnel performing the test;
- test equipment was calibrated within required time periods;
- test personnel were suitably qualified;
- quality assurance participation was as required;
- data was logged per the procedure; and
- test acceptance criteria were met for portions observed.
At the conclusion of this inspection the licensee testing and the NRC
review were still ongoing. To date no discrepancies were identified with
the exception of the below item.
b.
CRD System Modification
NUREG-0619 discusses the problem of CRD system return line nozzle cracking.
Part of the solution to this problem was to cap the nozzle and reroute the
return flow. The Shoreham FSAR, section 4.2.3.2.2.3 does not reflect this
modification.
One concern with the revised design, as discussed in the two letters listed
in paragraph 6.a above, is the ability to provide maximum makeup flow to the
reactor vessel from the CRD system in the event of an accident. The
modifications were considered acceptable to the NRC if a plant specific
minimum flow could be demonstrated.
For Shoreham the minimum flow required
is 135 gpm. This will be demonstrated during preoperational testing using
temporary instrumentation. The control room flow indicator, which would
be used by operators under actual accident situations, is off instrument
C11-F001 and is only a 0-100 gpm gage. The inspector stated that this
instrument did not appear to meet the above concerns. These two items
dealing with the CRD system modification are unresolved and are designated
item no. (322/81-22-01).
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7.
Maintenance
The licensee perforns maintenance on systems under Startup's jurisdiction
using the Repair / Rework Request (RRR). The inspector reviewed the portiens
of the Startup Manual describing the use of the RRR and reviewed the 45 WRRs
which have been written for the Standby Liquid Control System (C41). Selected
RRRs were discussed with 'he system Test Engineer and the S&W Lead Advisory
Engineer. For RRRs #C41-25 and 26, issued to overhaul the Standby Liquid
Control Pumps, the inspector noted that the pump vendor manual had been used
vice the permanent plant maintenance procedure.The licensee's : representative
stated that permanent plant maintenance procedures should be used where possible,
and if written and approved ,to check out the maintenance procedures. The Test
Engineer reviewed the Maintenance Procedure and wrote a memo to the Plant Staff,
dated 12/10/81, giving a recommended change to the procedure based on knowledge
gained during the pump overhaul.
The inspector had no further questions as this time.
8.
Unresolved Items
Areas for which more information is required to determine acceptability are
considered unresolved. Unresolved items are contained in Paragraphs 5.c and
6 of this report.
9.
Management Meetings
At periodic intervals during the course of this inspection, meetings were held
with plant management to discuss the scope and findings of this inspection.
The resident inspector also attended the entrance and exit interviews for an
inspection conducted by a region-based inspector during the month.
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