ML20062N388

Responds to NRC Re Violations Noted in IE Insp Rept 50-322/82-08.Corrective Actions:Startup Instruction 2, Revision 2,approved by Lead Startup Engineer,Issued 820429 & Distributed Onsite by 820430

ML20062N388
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/25/1982
From:	Pollock M LONG ISLAND LIGHTING CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20062N383	List: ML20062N388
References
SNRC-720, NUDOCS 8208230135
Download: ML20062N388 (4)

Text

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.- e LONG ISLAND LIGHTING COM PANY dasumaamme.mmxj 175 EAST OLD COUNTRY ROAD

• H 1C K SVI LLE, NEW YORK 11801 MILLARD S. POLLOCK v cc nacsec ~r - ~uc"

SNRC-720 June 25, 1982 Mr. Richard W. Starostecki, Director Division of Resident and Project Inspection U.S. Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406 NRC Inspection No. 82-08 Shoreham Nuclear Power Station, Unit No. 1 Docket No. 50-322

Dear Mr. Starostecki:

This letter responds to your letter of May 27, 1982, which forwarded the report of the routine inspection of activi-ties authorized by NRC License No. CPPR-95, conducted by Mr. Higgins of your office on March 30-May 10, 1982. Your letter stated that it appeared that one of our activities was not conducted in full compliance with the NRC requirements.

The apparent noncompliance and our response follow.

l Apparent Noncompliance with 10CFR50, Appendix B, I Criterion VI, and FSAR Sections 17.1.6A, 17.1.6D and 17.2.6 1

1. The LILCO Startup Manual, section 1.3, states that the Startup Manual is a controlled document. The LILCO Startup Manual, section 4.17.3 and 4.17.4, states that Startup Instructions are approved by the Lead Startup Engineer and included in Appendix 4A of the Startup Manual.

Contrary to the above, on April 27, 1982, Rev. 2 to Startup Instruction No. 2, dated April 8, 1982, which was not approved by the Lead Startup Engineer, was inserted in the Resource Center Startup Manual (Controlled Copy No. 36-1) and the approved Rev. 1 to Startup Instruction No. 2 was removed.

Rev. I was still contained in Control Room and Quality Assur-ance Startup Manuals (Controlled Copies No. 22 and 43).

8208230135 820809

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DR ADOCK 05000322 PDR

T Mr. Richard W. Starostecki June 25, 1982 Page Two Corrective Action and Results Startup Instruction No. 2, Revision 2, was approved by the Lead Startup Engineer, Electrical, and issued on April 29, 1982. Distribution of this revision to all controlled copies of the LILCO Startup Manual on site was completed on April 30, 1982.

Steps Taken to Prevent Recurrence A copy of the revised Startup Instruction was placed in the Project Resource Center copy of the LILCO Startup Manual by the Projett Resource Center Test Engineer prior to its being approved by the Lead Startup Engineer. It was verified that this condition did not exist in any other copies of the Manual. To prevent recurrence, responsibility for incorporating revisions into all controlled copies of the Startup Manual has been assigned to the Administrative Aide to the Startup Manager.

Date When Full Compliance Will Be Achieved Full compliance has been achieved.

2. The Shoreham FSAR, section 14.1, and the LILCO Startup Manual, section 4.2, describe the organization and system used for preparation , review, approval and execution of all test procedures . for the preoperational phase.

Contrary to the above, on April 26,.1982, during the pre-

! operational phase, the Inservice Reactor Pressure Boundary

, Leak Test was performed using a procedure not reviewed and l approved per the above system.

General' Comment

LILCO does not concur with the classification of' this finding as a Violation. The Inservice' Reactor , Pressure Boundary Leak Test. being conducted on April 26, 1982, was not a required test, but an . informational test performed in . .

accordance with good engineering . practice to assure LILCO that-construction and installation of the system was satisfactory to date.

In accordance with Startup Manual Section 5. 3. 8, - 7.3 and Startup Instruction No. 1 " Preparation of-Interim Operating Instructions" the approved station procedure SP22.009.01 (Rev. 0) " Inservice Reactor Pressure Boundary Leak . Test"

r Mr. Richard W. Starostecki June 25, 1982 l

Page Three l

had been marked up by a Test Engineer to fit the existing plant conditions for this activity. This instruction was reviewed and approved by the Lead Startup Engineer - NSSS and the Assistant Startup Manager. The review and approval by the Assistant Startup Manager was one level of manage-ment higher than required by Startup Instruction No. 1.

However, the marked up instruction was issued without the correct transmittal form and modification to the instruction number to indicate a Startup Station Procedure or SSP. Tne technical content of the procedure was correct.

The formal Operational Hydrotest will be performed subsequent to fuel load in accordance with Shoreham Technical Specifica-tion, Section 4.0.5.

Nevertheless the following corrective steps have been taken to prevent recurrence.

Steps Taken to Prevent Recurrence The use of the proper Interim Operating Instruction trans-mittal and numbering designations were reviewed with the Lead Startup Engineer - NSSS and the Assistant Startup Manager. Future Interim Operating Instructions will be transmitted and numbered properly.- No further action is required as there was no technical impact on the procedure used.

Date Nhen Full Compliance Will Be Achieved Full compliance has been achieved.

Very truly yours, 977.J.12/4J M. S. Pollock Vice President-Nuclear-cc: . ;Mr. J. Higgins All Parties

r STATE OF NEW YORK )

ss.:

COUNTY OF NASSAU )

i MILLARD S. POLLOCK, being duly sworn, deposes and says that I am a Vice President of Long Island Lighting Company, the owner of the facility described in the caption above. I have read the Notice of Violation dated May 27, 1982, and also the response thereto prepared under my direction dated June 25, 1982. The facts set forth in said response are based upon reports and information provided to me by the employees, agents, and representatives of ~ Long Island Lighting Company responsible for the activities described in said Notice of Violation and-in said response. I believe the' facts set forth in.said response are true.

/'MILLARD S . POLLOCh Sworn to before me this MN"' day of , 1982.

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Wstory Public, State of New York No. 30-470C263 Qualified in Nassau County Comm!ss; ort es;; ires Mar. 30,19.[Y e- w -q--