ML20062E002

Responds to NRC Re Systematic Assessment of Licensee Performance Covering Period 810301-820228. Corrective Actions:S&W Performed Evaluation of FSAR Conformance Program & Project Procedures

ML20062E002
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/21/1982
From:	Pollock M LONG ISLAND LIGHTING CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20062D993	List: ML20062D987 ML20062D996 ML20062E002
References
SNRC-716, NUDOCS 8208060292
Download: ML20062E002 (8)

Text

,

Enchsure 4 emmesma*emawwwman LONG ISLAND LIGHTING COM PANY

[/OffGM/////RJ6#E(*@ B $

175 CAST OLD COUNTRV ROAD H tCKSVi LLE, NEW YORK 11801 Bewcasmaux.ssmuuedi MILLARD S, POLLOCM v.c, msior un ~uc^"

SNRC-716 June 21, 1982 Mr. Richard W. Starostecki SALP Board Chairman and Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406 Systematic Assessment of Licensee Performance (SALP)

Shoreham Nuclear Power Station Docket No. 50-322

Dear Mr. Starostecki:

This letter responds to your letter of May 19, 1982, which forwarded the report of the Systematic Assessment of Licensee Performance (S ALP) for the Shoreham Nuclear Power Station cover-ing the period March 1, 1981 through February 28, 1982. Your letter stated that one area was considered an area of weakness requiring additional management attention and requesting that we advise you of those actions taken or to be taken to improve performance in this area. Our response follows:

Functional Area 10 - Engineering and Design

1. Discrepancies between licensing documents and the facility as designed and constructed have been evaluated on a con-tinuous basis as these discrepancies have been brought to l light. None of these discrepancies have involved concerns l significant to safety. In September 1981, Stone & Webster performed a fornal evaluation of the FSAR Conformance Pro-gram and project procedures and determined that there were no significant or generic differences between licensing and design documents. The NRC, in Inspection Report 50-322/81-20, Section 8, agreed, in general, with that conclusion.

1

2. Discrepancies between the FSAR and the "As-Built" plant identified during NRC Inspections were also evaluated during the Stone & Webster Engineering Corp. FSAR Con-formance Program, and it was determined that none of these discrepancies involved concerns significant to safety.

A QRADOCKOB060292 050003gy B20722 PDR

, s. -

Mr. Richard W. Starostecki June 21, 1982 Page Two Functional Area 10 - Engineering and Design (Cont ' d. )

2. Cont'd.

In a meeting with LILCO and Stone & Webster Engineering Corp.

in November 1981, the NRC was in general accord with the above, although they indicated that an additional review should be done. To this end, LILCO initiated a Shoreham Plant Configuration Review Program (SPCR) to determine the degree of conformance between the "As-Built" plant and the FSAR. This is accomplished by performing a comprehensive survey based on engineering documents and drawings, licensing documents (FSAR) , and plant walkdowns. A presentation on the overall program was given to NRC Region I personnel in April 1982. Completion of this program is scheduled prior to Fuel Load. Thus far, six (6) systems have been reviewed, and no significant findings have resulted. The FSAR will be updated as appropriate in accordance with these findings.

3. The lessons learned from the TMI accident have shown the importance of having accurate, up-to-date drawings available to operating personnel at all times. Fuel Loading is the logical time to assemble a complete set of design and-installation drawings. Accordingly, a program is in place to assure that total configuration of the plant at Fuel Load is accurately reflected by drawings which will be utilized by the station operating staff.

Shoreham Project procedures dictate that certain drawing series' be updated by Fuel Loading. Physical incorporation of engineering changes will be made for the following l drawing series:

I e Flow Diagrams e Machine Location Plans e Elementary Control Diagrams e Instrument Loop Diagrams e Logic Diagrams e Functional Control (HVAC) Diagrams e Instrumentation Drawings e Electrical One Line Diagrams e Wiring Drawings e Security Drawings e Communication Drawings We expect to have the E&DCR backlog on these drawings reduced to a minimum (1 month) backlog by Fuel Load.

Mr. Richard W. Starostecki June 21, 1982 Page Titree Functional Area 10 - Engineering and Design (Cont ' d. )

4. The LILCO resolution of Electrical separation deficiencies is discussed under our response to Functional Area 8.

5. LILCO has moved a containment isolation valve which specif-ically did not meet existing criteria for location as close as practical to containment. Furthernore , LILCO has instituted a field survey of all containment isolation valves for the purpose of reviewing their location. The results of this survey will be forwarded to the NRC resident inspector in June in order to close this item.

6. During a recent (April 1982) Construction Assessment Team inspection, a potential non-conformance to Regulatory Guide 1.62 with regard to requirements for system-level manual initiation of certain safety and support systens was identified. LILCO does not concur with this violation and feels that the Shoreham design does, in fact, comply with the requirements of this regulatory guide. The LILCO response to this violation will clarify our conformance to the regulatory guide.

We have also the followinS comments on other areas of the SALP Report:

Functional Area 1 - Radiological Controls

1. The site ALARA program is nearing completion with two ALARA procedures approved and four additional ALARA procedures drafted and in the review cycle. The four drafted procedures involve ALARA goals and measurement, procedure and design ALARA review, the ALARA Review Committee and ALARA job review. The Nuclear Operations Corporate Policy regarding corporate ALARA interfaces and responsibilities has been.

approved and issued. The ALARA program including policies and procedures will be completed by September 1982.

2. The formal review process for personnel exposures at the Shoreham Station has been established in the ALARA program procedures . The program specifies the review will be performed by the ALARA Review Committee whose members are also Review of Operations Committee members or have similar background and management responsibilities as the Review of Operations Committee members. A report wi.ll be for-warded to the Review of Operations Committee. The ALARA Review Committee is responsible to the Nuclear Review Board.

.. s. .

Mr. Richard W. Starostecki June 21, 1982 Page Four Functional Area 1 - Radiological Controls _ (Cont ' d. )

3. The current Health Physics Section complement consists of the Health Physics Engineer, a Plant Engineer, two Health Physics Foremen and fourteen Health Physics Technicians.

As indicated previously, contract personnel will be used for any fuel load activities where additional manpower is needed. Active recruiting for a Health Physics Plant Engineer, a Health Physics Supervisor and four Health Physics Technicians is still being performed.

4. The Health Physics Technician Qualification procedure has been revised to conform with NRC appraisal findings and INPO guidance. The procedure now contains specific guidance for evaluating a Health Physics Technician's competence in performing job tasks. The Contract Health Physics Technician training program is in the process of being drafted and will be approved and implemented by September 1982.

The retraining program for Health Physics Technicians has been included in the revision to the Health Physics Techni-cian Qualification Program procedure.

Functional Area 2 - Maintenance

1. In the second paragraph, NRC mentions that maintenance is performed on systems turned over to Startup either by Startup or Construction personnel via Repair / Rework. This is a true statement, however, it was not noted that routine preventive maintenance performed under the IOI program is basically implemented by Plant Staff Maintenance personnel. This includes routine filter cleanings, bearing lubrication, etc.

This program has been in effect since the initial startup effort and serves the following purposes: 1) shakedown of permanent plant operating procedures both technical and administrative as the basis for repetitive plant preventive maintenance and 2) training of permanent plant staff per-sonnel who are actively involved in the day-to-day per-formance of these preventive maintenance activities.

Functional Area 3 - Preoperational Testing

1. Paragraph two describes three violations which were issued against the preoperational test program. The first dealt with updating the Shoreham Startup Manual. Towards this end, LILCO has taken action to ensure that future updates of the Startup Manual are made in a timely and efficient

.. s. .

Mr. Richard W. Starostecki June 21, 1982 Page Five Functional Area 3 - Preoperational Testing (Cont'd.)

1. Cont'd.

manner and in fact one person will be solely responsible for updating all controlled Startup Manuals in lieu of updates by the responsible manual holders. Also, the LILCO Operating Quality Assurance organization performs a quarterly surveillance to ensure that the Startup Manuals are being properly updated. The second area dealt with deficiencies in the lif ted leads and jumper area. Relative to this particular aspect, renewed cognizance has been placed on this part of the Startup program via general meetings as well as memos to all Startup personnel instructing them in the applicable portions of the Startup Manual. Also a responsible person has been delegated in the Control Room as directly responsible for the lifted leads and jumper program for the normal two shifts of testing. This person is responsible to make rounds of the main control room panels and other panels within the plant to ensure that there are no unauthorized lifted leads or jumpers in place. As a further enhancement, during the most recent month the on-shift Startup Coordinators have been charged also with making rounds of plant panels to ensure that lifted leads and jumpers are handled in accordance with the applicable procedures. Additionally, the LILCO Operating Quality Assurance Organization performs a monthly surveillance of the program to assure proper implementation.

Regarding the failure to follow requirements for control of design changes this third violation has been addressed by the addition of a full time Test Engineer to the Startup Resource Center to review drawing changes, to i'dentify to the responsible Test Engineer that a change has been accomplished and'to seek resolution as to the need for retesting of the changes.

2. A recent review (as of May 24, 1982) of the status of NRC open itens (i.e. Bulletins, Circulars, unresolved items, violations, infractions, deficiencies, etc.) indicates that two hundred nineteen (219) items have not been closed by NRC Inspection and Enforcement. Approximately forty (40) items are ready for I&E review or awaiting an HRC Inspection Report for closure.

By nid-June, three (3) engineering personnel will be speci-fically assigned the task of providing and/or assuring final closure of these items in a timely manner prior to Fuel Load.

. s. .

Mr. Richard W. Starostecki June 21, 1982 Page Six Functional Area 4 - Fire Protection

1. Audit, surveillance and inspection of the Shoreham Fire Protection Program was commenced by LILCO Quality Assurance during 1981.

2. Quality Assurance requirements applicable to the Fire Protection Program for the operating nuclear station are prescribed in Appendix I to the Quality Assurance Manual.

This Appendix, scheduled for publication by June 25, 1982, satisfies the applicable conditions of NRC Supplemental Guidance, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance".

Functional Area 5 - Security and Safeguards

1. Appropriate steps have been taken to expedite the installa-tion and Startup Testing of the security system in order to meet Shoreham's fuel load scheduling.

2. Shoreham understands its obligations for the timely reporting of certain security events in compliance with federal regula-tions. These reporting requirements will not impact on the

station , prior to the implementation of 10CFR73.55 security measures.

3. The authorities and responsibilities of security managenent positions are defined in the Shoreham's Physical Security Plan, Chapter I. , , ,-

Functional Area 6 - Initial Fuel Receipt

1. Station Procedures 58.001.01 and 58.007.01 have been revised to limit stacking metal shipping containers to a maximum of four high. This is consistent with General Electric's license for the shipping containers and item 12 of LILCO's New Fuel License SNM-1857, 2 Station Procedure 58.001.01 prohibits fuel arrays of four or more fuel bundles outside of the normal fuel storage areas or properly designed fuel shipping containers. This is consistent with General Electric's Service Information Letter (SIL) 152 and item 13 of LILCO's New Fuel License SNM-1857.

3. Maintenance procedures have been written to ensure crane maintenance, testing and operation meet NUREG-0612. Review of Operations Committee (ROC) approval is necessary before new fuel can be transported to the refuel deck.

f Mr. Richard W. Starostecki June 21, 1982 Page Seven Functional Area 7 - Piping Systems and Supports No comment.

Functional Area 8 - Electrical Power Supply and Distribution Significant strides have been taken to resolve electrical separa-tion concerns. The first open inspection item on inadequate cable separation, NRC Inspection Report 79-07, which was originally deferred until all cables were installed, is now being resolved in an "As-Built" Review Program.

We wish to clarify that LILCO and Stone & Webster Engineering Corp. had been resolving electrical separation concerns and deficiencies, where possible, well prior to the April 1, 1982 meeting between LILCO, NP,R and Region I representatives. Of the one hundred eighty (180) deficiencies identified by LILCO as of 12/31/81, twenty- four (24) had been resolved as of 04/09/82. Based on agreements and guidance developed as a result of that meeting, progress has been made in resolving these deficiencies to the point that, as of 05/31/82, only seven (7) of the original one hundred eighty (180) are still outstanding.

Functional Area 9 - Instrumentation and Control Systems No comment.

Functional Area 11 - As-Built Conformance (CAT Inspection)

1. The volume of Engineering and Design Change Reports (E &DC Rs ) ,

while large, is carefully controlled and frequent NRC l audits of this area in the past have shown that the E&DCR control system at Shoreham is adequate.

2. Regarding the separation of cables in transition between raceways, an action plan has been established which will involve the wrapping of cables not meeting separation crite ria . Tests are being performed and additional test data is being procured verifying the acceptability of this course of action. Installation instructions will be ready during June, 1982.

3. Regarding the corrosion of bolts on flanged piping, this potential problem had been previously identified by LILCO and a program is presently underway which entails inspec-tion of flanged joints and verification that the correct bolting material has been installed.

, k..*

Mr. Richard June 21, 1982 Page Eight Functional Area 12 - Licensing Activities A Shoreham Plant Configuration Review Program has been implemented to determine the degree of conformance between the As-Built plant and the FSAR. Deficiencies found during this review will be corrected and the FSAR will be revised to reflect changes or corrections as appropriate. Four (4) engineers are assigned full time to this effort which will be completed prior to Fuel Load.

Very truly yours, N.k Y M. S. Pollock Vice President-Nuclear 1

4 l

I l

- _