ML20054H042

IE Insp Rept 50-322/82-08 on 820330-0510.Noncompliance Noted:Failure to Properly Control Issuance of Documents Re Startup Instructions

ML20054H042
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/26/1982
From:	Gallo R, Higgins J, Paolino R, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20054H027	List: ML20054H026 ML20054H034 ML20054H042
References
50-322-82-08, 50-322-82-8, NUDOCS 8206220518
Download: ML20054H042 (9)

See also: IR 05000322/1982008

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

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Region I

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Report No. 50-322 / 82-08

Docket No. 50-322

License No. CPPR-95 Priority --

Category B

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: March 30 - May 10, 1982

Inspectors: I O b

rSenior Reside t Inspector date signed

J[ hic 1

m 'A - . en li . 8D

RTPao l date' igned

iro Reac or Inspecfor (3/1 & 4/1)

j 4 (L hoca s cn

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S. Richards, Reactor Inspector (3/31 & 4/1) 'datd signed

Approved by:

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R. M. Gallo, Chief, Reactor Projects Section 1A

6/76 f 82-.

date signed

projecn Branch #1, DPRP

Inspection Summary:

Inspections on: March 30-May 10,1982 (Inspection Report No. 50-322/82-08)

Areas Inspected: Routine onsite repular, backshift, and week-end inspections by the

resident inspector (110 inspection hours) and two regDrd.ned inspectors (16

inspection hours) of work activities,preoperational '.erhg and plant staff activities

, including: tours of the facility, test procedura v vie. , tost witnessing, review of

NRC Bulletins and Circulars , review of electri9 'm tion, review of environmental

qualifications, documentation review, participe Mar. i, JLB activities, and followup

on previous inspection findings.

Results: Of the nine areas inspected, no violations were identified in eight areas

and one violation was identified in the ninth area (failure to properly control the

issuance of docteents, paragraph 6).

8206220518 820527

DR ADOCK 05000322

PDR

Regio.. I Form 12

(Rev. April 77)

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DETAILS

1. Persons Contacted

T. Gerecke, Quality Assurance Manager (L)

J. Kelly, Field QA Manager (L)

W. Patejek, Lead Advisory Engineer (S&W)

J. McCarthy, Section Supervisor - FQA (L)

M. Milligan, Project Engineer (L)

K. Nicholas, Lead Startup Engineer (GE)

J. Notaro, Operating Engineer (L)

G. Price, Senior Asst. Project Engineer (L)

R. Reen, Security Supervisor (L)

J. Rivello, Plant Manager (L)

T. Rose, Acting 00A Engineer (L)

C. Seaman, Senior Asst. Project Engineer (L)

J. Smith, Manager, Special Projects (L)

D. Terry, Assistant Startup Manager (L)

R. Werner, 00A Engineer (L)

E. Youngling, Startup Manager (L)

GE - General Electric

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 manaaement, clerical, maintenance,

operations , engineering, testing, quality assurance and construction personnel.

2. Previous Inspection Item Update

a. (open) Unresolved Item No. (322/81-02-05): FSAR Conformance: This item

was also reviewed in inspection reports 81-18 and 81-20. In a letter from

LILC0 to the NRC dated March 11, 1982 the licensee briefly described the

Shoreham Plant Configuration Paview Program. This program was further

described in meetings held for that purpose on April 2,1982 between the

licensee and Region I representatives.

During this meeting the licensee stated that each safety-related system in

the FSAR will be reviewed in this proqram. The review consists of document

review, plant inspections, recording of discrepancies, and followup to ensure  ;

correction of any identified discrepancies. Correction may consist of

engineering disposition, plant changes or FSAR amendment. The licensee

further stated that four engineers are assigned full-time in order to complete

the program by late summer.

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b. (open) Unresolved Item No. (322/81-12-06): Control Room Core Spray

The licensee issued Engineering & Design Coordination

PanelLabeling):

Report (E8DCR No. F-36533A which corrected the disparity in valve

operating switches between loop A and loop B. Both now have four

positions. The *A0V-081 disc position tags were removed. Also the position

indicator light nameplates were changed. The inspector noted that the

conrnon operating switch for valves E21*A0V-081 and E21*M0V-081, which had

previously been labeled only for the A0V, was now labeled only for the MOV.

This item remains open.

c. (open) Unresolved Item No. (322/81-18-01): Steam Condensing Mode Temperature

Indications: This item identified that there is no temperature indication

for RCIC pump suction wager in the steam condensing mode and that the

temperature limit is 140 F. The licensee reviewed this item and stated

(letter LIL-19667 dated March 19,1982) that additional instrumentation

was not required due to: 1. low probability of high suction water temperature.

2. minimal consequences with temperature above

140 F and below 170 F.

3. a local temperature indicator on the RCIC

pump discharge.

The inspector reviewed this information with Region I and stated that this

did not provide adequate assurance that temperature limits for the RCIC

pump would not be exceeded during the steam condensing mode g Licensee pro-

cedure SP 23.121.01 properly cautions against exceeding 140 F but does not

provide either monitoring from control room, or constant monitoring at the

local indicator during startup with periodic logging thereafter. This

item remains open,

d. (open) Unresolved Item No. (322/82-02-06): Loose Parts Detection System

Preoperational Test: This item identified that initial calibration was

performed with no flow in the feedwater line and the calibration certifications

were not available for the test impact device. The inspector reviewed the

vendor's calibration certification for the impact device dated March 8,1982

and noted that it provided an impact of less than 0.5 ft.-lb. and that the

calibration was traceable to the National Bureau of Standards.

The licensee and the vender stated that system calibration with flow in the

feedwater line was the preferred method, although not actually required.

The licensee further stated that the Loose Parts Monitoring Startup Test,

when written, would call for calibration with flow in the feedwater line.

This item remains open pending review of the Startup Test.

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3. Plant Tour

a. Discussion

The inspector conducted periodic tours of accessible areas in the plant

during nomal, backshift and week-end hours. During then 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;

- Housekeeping - Maintenance of required cleanness levels of systems under

or following testing;

- Equipment Preservation - Maintenance of special precautionary measures

for installed equipment, as applicable;

- QA/QC surveillance - Pertinent construction and startup activities were

being surveilled on a sampling basis by qualified 0A/QC personnel;

- Security - Adequate site construction security;

- Veld Rod Control - Observations to determine weld rod was being controlled

per site procedures; and

- Component Tagging - Implementation o f appropriate equipment tagging for

safety, equipment protection, and jurisdiction.

No violations were identified.

4. NRC Circulars

a. Circulars Closed

Circular 78-08:

This Circular, " Environmental Qualification of Safety-Related Electrical

Equipment at Nuclear Power Plants", was issued to highlight the subject

area as a problem one. The licensee has established an environmental

qualification program, submitted the program to the NRC, and had an NRC

audit of that program on site. Specific equipment problem areas are

covered in other NRC Bulletins and Circulars. Thus, this general Circular

is closed.

Circular 76-01:

This Circular, " Crane Hoist Control - Circuit Modifications", describes a

situation where modifications to the fuel cask handling crane allowed the

load to drop without the brakes engaging imediately. The licensee's reply

in 1976 stated that no such modifications were planned for the Shoreham

crane and that the crane's braking system had a history of satisfactory

performance. Due to modifications perfomed on the crane between 1976 and

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1980 the inspector requested that the licensee determine if this response

was still valid. The licensee reverified that the Shoreham crane should

not experience the described problem as documented in letter LIL-19551,

dated March 5, 1982. Inspector review of onsite documents and a tour of

the crane raised no additional questions in this area. This Circular is

closed.

Circular 81-06:

This Circular, " Potential Deficiency Affecting Certain Foxboro 10 to 50

Millempere Transmitters", describes defects in the subject transmitters.

The licensee has reviewed his facility and detennined that such transmitters

are not used at Shoreham. These transmitters 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 various transmitters

installed in the plant, and noted that none of the subject transmitters were

used. This Circular is closed,

b. Circulars Open

Circular 78-12:

This Circular, "HPCI Turbine Control Valve Lift Rod Bending", described a

problem where the High Pressure Coolant Injection (HPCI) Turbine's speed

could not be reduced to zero due to control valve lift rod bending. General

Electric Company issued a Service Information Letter (SIL No. 233) and a

Field Disposition Instruction (FDI) to address the problem. The licensee

reviewed the Circular and SIL, and issued E8DCR No. F-10778 to implement the

recomended modification to the turbine. The inspector reviewed the

documentation associated with the modification and a Field Ouality Control

Inspection Report (QCIR) dated June 29, 1979 which documented witnessing

of modification activities. The FDI stated that the turbine vendor would

> revise turbine documents to reflect the modification, however, inspector

review of the site turbine vendor manual did not reveal any reference to

the modification. This Circular remains open pending resolution of the

vendor manual question.

Circular 78-14:

This Circular, "HPCI Turbine Reversing Chamber Hold Down Bolting", described

a problem where the subject bolts broke and remained inside the HPCI system.

General Electric Company issued SIL No. 274 and FDI # 76/88524 to address

the problem. The licensee reviewed the Circular, SIL and FDI, and issued

E&DCR No. F-14314 to implement the recommended modification to the turbine.

The inspector reviewed completed modification paperwork, including a QCIR

documenting the witnessing of the activities by Field Quality Control. The

inspector also reviewed the turbine vendor manual and the HPCI Turbine

maintenance procedure SP 35.202.01, Rev. O. The maintenance procedure

refers to the vendor manual for turbine disassembly. The inspector noted

that the manual was not detailed enough to even identify the parts that

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were modified by the SIL. The licensee's representative stated that the

acceptability of this would be reviewed. This Circular thus remains open.

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5. Preoperational Testing

a. Discussion

The inspector and P.egion I reviewed portions of three test procedures:

PT.654.003, Rev.1, Primary Containment Leak Rate, Type C

PT.106.001, Rev. O, Control Rod Drive System

SP.22.009.01, with Startup revisions, Inservice Reactor Pressure

Boundary Leak Test

The inspector also witnessed portions of the three tests including: the

Test Panel bypass 'talve leak check and Panel leak check, Control Rod

Drive (CRD) system flow rate test, and Reactor Vessel pressurization.

During the witnessing, the inspector noted that:

- test procedures were in use by personnel perfonning the tests;

- test personnel were suitably _ qualified;

- quality assurance participation was as required;

- data was logged per the procedures; and

- test acceptance criteria were met for portions observed.

With the exception of the items in paragraphs 5.b and 6. no discrepancies

were identified. The inspector also noted that the data collected for

the CRD flow rate test did not appear conclusive enough to demonstrate

that the acceptance criterion of 135 gpm had been met. The licensee had

not completed his evaluation of the data.

b. Leak Rate Test Procedure

Based on the review of PT.654.003 and the test witnessing, the inspector

had four coments.

(1) The equation on page 8 of the procedure was incorrect. The correct

equation is given in ANSI /ANS-56.8-1981.

(2) The valve line up for step 8.1 was incomplete in that the flowmater

isolation valves were not designated as being open.

(3) Containment isolation valve leak tests do not measure test gas

temperature.

(4) The test panel is not verified to be level during calibration or

testing.

This item is unresolved and is designated as Item No. (322/82-08-02).

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6. Documentation

10 CFR 50, Appendix B, Criterion VI and the Shoreham FSAR section 17 require

that measures be established to control the issuance of documents including

changes thereto. Two instances of failure to properly control the issuance

of documents and changes were identified.

The first example relates to control of the Startup Instructions contained in

Appendix 4A of the Startup Manual. Startup Manual section 4.17.3 states that

the Startup Instructions are approved by the Lead Startup Engineer. On April

27, 1982 the inspector noted that Rev. 2 to Startup Instruction No. 2, dated

April 8,1982, which was not formally approved by the Lead Startup Engineer,

was inserted in the Resource Center Startup Manual (Controlled Copy No. 36-1).

The approved Rev. I was removed. The inspector reviewed several other Startup

Manuals, including the Control Room and the Operational Quality Assurance (00A)

controlled copies, and noted that all still contained the approved Rev.1. The

inspector stated that this item was similar to previously identified instances

of failure to properly control changes to the Startup Manual.

The second example relates to approval and issuance of a test procedure. On

April 26, 1982 the inspector noted that the Inservice Reactor Pressure Boundary

Leak Test was being performed using a marked-up permanent plant Station Procedure,

which had been approved by the Assistant Startup Manager. The review and approval

method used for this test was not as described in the FSAR, section 14.1

and the Startup Manual section 4.2. The licensee's representative stated that

the Joint Test Group had discussed this test and concluded that, since it was

not an FSAR required test, that the test review and approval methods of the

FSAR and Startup Manual did not apply.

These two items constitute a violation and are designated Item No. (322/82-08-01).

7. Electrical Separation

The resident inspector, two region-based inspectors and a representative of the

NRC's Office of Nuclear Reactor Regulation toured the site and met with licensee

representatives to review four aspects of electrical separation:

1. The effect of potential missiles generated by failure of the Reactor

Protection (RPS) Motor-Generator Sets on nearby class IE cables.

2. Separation between raceways of redundant class IE divisions.

3. Separation between class IE and non-class IE raceways.

4. Separation of cabling not in a raceway.

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Documents utilized for the review included:

- Shoreham FSAR paragraph 3.12

- Regulatory Guide 1.75-Rev. 2

- Letters from NRC to LILC0 dated August 31, 1981 and March 15, 1982.

Based on the reviews, four understandings were reached:

1. The licensee would conduct a review to determine the effect of any

potential missiles generated by the RPS Motor-Generator Sets and

the results would be provided to the NRC.

2. When minimum separation was not maintained between raceways of

redundant class IE divisions, one of the four options listed in

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the August 31, 1981 letter would be used, with preference given

to options 1, 2, and 3. If option 4 was selected, the specific analysis

would be submitted to the Office of Nuclear Reactor Regulation for review.

3. Vertical separation of five feet would be maintained between class IE

and non-class IE raceways or barriers would be provided between them.

4. The same separation criteria that apply to raceways would be applied

to plant cabling not in raceways.

The implementation of these items will be reviewed in a future inspection.

8 Atomic Safety and Licensing Board (ASLB) Activities

On April 13, 1982 the inspector participated in a tour of the Shoreham site

for the three member ASLB for Shoreham and all parties to operating license

hearings. The inspector also attended portions of the limited public appearances

held before the ASLB as part of the second prehearing conference.

On May 4,1982 the formal hearings for the Shoreham operating license began.

The inspector attended portions of those hearings throughout the week of May 4.

9. Environmental Qualifications

During the week of April 26, 1982 the NRC performed an audit of the licensee's

Equipment Environmental Qualification Program. This program is designed to

ensure that equipment, which must function after an accident such as a loss of

Coolant Accident or a High Energy Pipe Break, is qualified to survive any harsh

environment in which it may be located. The inspector participated in several

meetings between the licensee and the audit team. The results of this audit

will be reported separately by the audit team.

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10. New Fuel Procedures

In inspection 322/82-05 station procedure SP.58.001.01, Rev. 4, Receipt,

Inspection and Channeling of Unirradiated Fuel was reviewed and comments were

provided to the licensee. The licensee subsequently revised the procedure,

incorporating the comments. The inspector reviewed Rev. 5 to this procedure

and had no further comments at this time.

11. NRC Inspector Impersonation

On April 27, 1982 a licensee contractor employee approached two other site

employees and began asking them questions. He stated that he was an NRC

inspector, although he had nothing to identify himself as such. The licensee

performed a brief review of this incident and reported it to the resident

inspector, including the name of the offending individual. The inspector

informed the Region I office., who notified the Federal Bureau of Investigation

(FBI). The FBI came to the site and interviewed the involved personnel. All

followup of this incident will be handled by the FBI.

12. Unresolved Items

Areas for which more inft rmation is required to determine acceptability are

considered unresolved. in unresolved item is contained in Paragraph 5.b of

this report.

13. Management Meetings

At periodic intervals during the course of this inspection, meetings were

held with licensee management to discuss the scope and findings of this

inspection.

The resident inspector also attended selected entrance and exit interviews for

two region-based inspections conducted during the inspection period.

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