ML20127A100
| ML20127A100 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/31/1985 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Leonard J LONG ISLAND LIGHTING CO. |
| References | |
| NUDOCS 8508050407 | |
| Download: ML20127A100 (4) | |
See also: IR 05000322/1985099
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JUL 311985
Docket No. 50-322
Long Island Lighting Company
ATTN: Mr. John D. Leonard, Jr.
Vice President - Nuclear.
P. O. Box 618
Shoreham Nuclear Power Station
Wading River, New York 11792
Gentlemen:
Subject: Systematic Assessment of Licensee Performance - Report No. 50-322/85-99
This letter refers to the Systematic Assessment of Licensee Performance (SALP)
of the Shoreham Nuclear Power Station for the period of March 1,1984 through
February 28, 1985, initially forwarded to you by our May 24, 1985 letter
(Enclosure 1). This SALP evaluation was discussed with you and your staff at
a meeting held in Wading River, New Ycrk on June 7,1985 (see Enclosure 2 for
attendees). We have reviewed your July 9,1985 written comments (Enclosure 3)
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and herewith transmit the final report (Enclosure 4).
Our overall assessment is that you and your staff demonstrated effective manage-
ment involvement in and control of plant activities, with a conservative ap-
proach to plant operations and safety. We attribute the improved performance
to the substantial improvements that were made in the LILC0 management organi-
zation at the beginning of the evaluation period. We recommend that you
continue the cautious, deliberate approach to plant operations and that you
ensure the other plant activities such as training, maintenance and surveil-
lance are not adversely affected by conflicting priorities that detract from
effective management involvement.
We acknowledge your discussion of program and staffing improvements in Licensed
Operator Training, Maintenance Programs and Radiological Controls. Your actions
in response to the above plus other observations made in the SALP report will
continue to be reviewed during future inspections at the facility. No reply to
this letter is needed.
OFFICIAL RECORD COPY 153 CONNER 7/17/85 - 0001.0.0
8500050407 850731 '
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PDR ADOCM 05000322 d
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Long Island Lighting Company 2
Your cooperation is appreciated.
Sincerely,
Origfnel signed by
Thomas E. mutl et
Thomas E. Murley
Regional Administrator
Enclosures:
1. NRC Region I Letter, T. Murley to J. Leonard, May 24, 1985
2. SALP Meeting Attendees, June 7, 1985
3. LILC0 Letter, J. Leonard to T. Murley, July 9,1985
4. SALP Peport No. 50-322/85-99
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OFFICIAL RECORD COPY 153 CONNER 7/17/85 - 0001.1.0
07/30/85
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Long Island Lighting Company 3
cc w/ encl: -
W. Steiger, Plant Manager
J. Smith, Manager, Nuclear Operations Support
R. Kubinak, Director, QA, Safety and Compliance
E. Youngling, Manager, Nuclear Engineering
Edward M. Barrett, Esquire
Jeffrey L. Futter, Esquire
J. Notaro, Manager, QA Department
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Shoreham Hearing Service List
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New York
Chairman Palladino
Con.missioner Roberts
Commissioner Asselstine
Commissioner Bernthal
Commissioner Zech
bec w/ encl:
Region I Docket Room (with concurrences)
J. Goldberg, OELD: HQ
J. Taylor, IE
R. Starostecki, Director, DRP
W. Kane, Dep. Dir., DRP
Director, DRS
Director, DRSS
'J. Strosnider
E. Conner
- RI:DRP * RI:DRP * RI:DRP * RI:DRP
Conner /sm Strosnider Kister Starostecki
7/ /85 7/ /85 7/ /85 7/ /85
RI:DRA
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Murley
7/ /85 7/30/85
, *See previous concurrence page
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0FFICIAL RECORD COPY 153 CONNER 7/17/85 - 0002.0.0
07/30/85
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long Island Lighting Company 2
cc w/ encl:
W. Steiger, Plant Manager
J. Smith, Manager, Nuclear Operations Support
R. Kubinak, Director, QA, Safety and Compliance
E. Youngling, Manager, Nuclear Engineering
Edward M. Barrett, Esquire
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Jeffrey L. Futter, Esquire
J. Notaro, Manager, QA Department
Shoreham Hearing Service List
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New York
Chairman Palladino
Commissioner Roberts
Commissioner Asselstine
Commissioner Bernthal
Commissioner Zech
bec w/ encl:
Region I Docket Room (with concurrences)
J. Goldberg, OELD: HQ
J. Taylor, IE
R. Starostecki, Director, DRP
W. Kane, Dep. Dir., DRP
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Directo5 Did'
Director, DRSS
J. Strosnider
E. Conner
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Strosnider Kister Starostecki
7 J7/85 7/l9/85 7$/85 7/' 85
R A RI:RA
A n Murley
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0FFICIAL RECORD COPY 153 CONNER 7/17/85 - 0002.0.0
07/17/85
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UNITED STATES
n OSure 1
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3, k NUCLEAR REGULATORY COMMISSION
REGloN 1
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KING OF PRUS$l A. PENNSYLV ANI A 19406
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F"N 2 4 lE
Docket No. 50-322
Long Island Lighting Company
ATTN: Mr. John D. Leonard, Jr.
Vice President - Nuclear
P. O. Box 618
Shoreham Nuclear Power Station
Wading River, New York 11792
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No. ~
50-322/85-99
The NRC Region I SALP Board has reviewed and evaluated the performance of
activities at the Shoreham Nuclear Power Station for the period of March 1,
1984, through February 28, 1985. The results of this assessment are documented
in the enclosed SALP Board Report dated April 22, 1985. A meeting to discuss
the assessment is scheduled for June 7, 1985, at 2:00 p.m. at the Shoreham
Education Center in Wading River, New York.
At the SALP meeting, we request that you be prepared to discuss this assessment
and your plans to improve performance. The meeting is intended to be a
dialogue wherein any comments you may have regarding this report may be
discussed; and, if there is additional information which you believe could
alter the assessment, please feel free to identify such matters. Additionally,
you may provide written comments within 30 days after the meeting. Considera-
tion of any points raised during the meeting or in your written comments will
be reflected in my characterization of your overall safety performance which
will be provided as part of the final SALP package.
Your cooperation is appreciated.
Sincerely,
/
Thomas E. Murley
Regional Administrator
Enclosure: .
SALP Report No. 50-322/85-99
cc w/ encl:
W. Steiger, Plant Manager
J. Smith, Manager, Nuclear Operations Support l
R. Kubinak, Director, QA, Safety and Compliance i
E. Youngling, Manager, Nuclear Engineering )
Edward M. Barrett, Esquire ;
Jeffrey L. Futter, Esquire !
Manager, QA Department
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Shoreham Hearing Service List
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Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
, NRC Resident Inspector
- State of New York.
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Enclosure 2
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Shoreham SALP
Management Meeting
Attendence June 7, 1985 l
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.Long Island Lighting Company
L. Britt I
W. Catacasinos i
B. Germano
R. Grunseich
R. Kascsak
L. Klan i
R. Kubinak ;
D. Lankford
J. Leonard
L. Lewin
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R. Loper ;
B. McCaffrey. :
A. Muller
J. Notaro
R. Reen :
J. Scalice .;
J. Schmitt !
J. Smith
W. Steiger
E. Stergakos
D. Terry
E. Youngling
U. S. Nuclear Regulatory Commission "
R. Caruso
P. Eselgroth
H. Kister
T. Murley -
R. Starostecki
News
C. Amezcua '
R. Brand
C. McVery
D.' Scott .
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Enclosure 3 I
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(fgg@ LONG ISLAND LIGHTING COM PANY
SHOREHAM NUCLEAR POWER STATION
P.O. DOX 018, NORTH COUNTRY ROAD . WADING RIVER. N.Y.11792
JOHN D. LEONARD, JR.
VICE PRESIDENT NUCLEAR OPER ATIONS
July 9, 1985 SNRC-1190
Dr. Thomas E. Murley
Office of Inspection & Enforcement
Region I
U. S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA 19406
Systematic Assessment of Licensee Performance
Shoreham Nuclear Power Station
Docket 50-322
Dear Dr. Murley:
This letter provides LILCO's response to your letter of May 24,
1985 which forwarded the report of the Systematic Assessment of
Licensee Performance (SALP) for the Shoreham Nuclear Power
Station covering the period of February 1984 through February
1985. The SALP meeting held on June 7, 1985 provided a useful
forum for the constructive exchange of information regarding this
report. You have my assurance that LILCO will act to ensure
continued positive performance and improvement, as appropriate,
in the functional areas delineated in the SALP report.
Several of these steps were discussed at the June 7, 1985
meeting and I will take this opportunity to expound on some of
these areas. In the area of Licensed Operator Training,
candidates for " cold licenses" will start full plant walk-
throughs and NRC level written examinations in July. LILCO will
also have an independent audit examination of candidates. In
addition, LILCO has hired two instructional technologists to
augment the training staff in support of accreditation and two
former consultants who have successfully completed SRO exams on
the Shoreham plant, who will perform operator training.
In the area of Maintenance Programs, and as discussed in letter
SNRC-1182, positions have also been allocated for additional
personnel to better support the I&C preventive maintenance
program.
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With regard to Radiological Controls, LILCO's efforts are
dedicated to ensuring Post Accident Sampling System availability
h prior to exceeding 5% of rated power. LILCO is implementing
) appropriate modifications, procedural changes, and maintenance
(' activities responsive to the unresolved items that were generated
in Inspection Report 85-04. Further details on these activities
were discussed with Region I personnel during a recent inspection
(June 21, 1985) and were described in a recent letter
- (SNRC-1186).
The details of actions being taken on most of the other specific
functional areas will be coordinated with the resident and other
inspectors during their inspections at Shoreham or with Mr. R.
- Caruso of NRR, as appropriate.
Overall, I am very gratified with this latest SALP assessment
report. The ratings received were a direct result of hard work
by our nuclear organization. We intend to maintain this high
degree of performance this next year and throughout Shoreham's
operation.
Should you have any questions, please contact this office.
Very truly yours,,
-74.' 06 ft l O
D. Leonard
Vi.e President - Nu lear Operations
R '/cf ,
cc: R. Caruso
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Enclosure 4
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT 50-322/85-99
LONG ISLAND LIGHTING COMPANY
SHOREHAM NUCLEAR POWER STATION
ASSESEMENT PERIOD: MARCH 1, 1984 - FEBRUARY 28, 1985
BOARD MEETING DATE: APRIL 22,1985
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 Purpose and Overview . . . . . ............... 1
1.2 SALP Board and Attendees . . . . . . . . . . . . . . . . . . 1
1.3 Background . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.0 CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.0. SUMMARY OF RESULTS. . . . . . . . . . . . . . . . . . . . . . . . 6
3.1 Overall Facility Evaluation. . ............... 6
3.2 Facility Performance . . . . . . . . . . . . . . . . . . . . 8
4.0. PERFORMANCE ANALYSIS. . . . . . . . . . . . . . . . . . . . . . . 9
4.1 Construction Activities. . . . . . . . . . . . . . . . . . . 9
4.2 Engineering and Design . . . . . . . . . . . . . . . . . . 11
4.3 Pre-operational and Startup Testing. . . . . . . . . . . . 13
4.4 Maintenance and Surveillance . . . . . . . . . . . . . . . 16
4.5 Plant Operations . . . . . . . . . . . . . . . . . . . . . 19
4.6 Radiological Controls. . . . . . . . . . . . . . . . . . . 25
4.7 Fire Protection / Housekeeping . . . . . . . . . . . . . . . 27
4.8 Emergency Preparedness . . . . . . . . . . . . . . . . . . 29
4.9 Securi ty and Sa fegua rds. . . . . . . . . . . . . . . . . . 30
4.10 Licensing. . . . . . . . . . . . . . . . . . . . . . . . 32
5.0 SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . . . 34
5.1 Investigations and Allegations Review. . . . . . . . . . . 34
5.2 Escalated Enforcement Action . . . . . . . . . . . . . . . 34
5.3 Management Conferences . . . . . . . . . . . . . . . . . . 34
5.4 Exemptions Granted . . . . . . . . . . . . . . . . . . . . 35
5.5 Construction Deficiency Reports. . . . . . . . . . . . . . 35
5.6 Licensee Event Reports . . . . . . . . . . . . . . . . . . 35
5.7 Part 21 Reports. . . . . . . . . . . . . . . . . . . . . . 35
TABLES
Table 1 Construction Deficiency Reports. . . . . . . . . . . . . . 36
Table 2 Licensee Event Reports . . . . . . . . . . . . . . . . . . 37
Table 3 Enforcement Summary. ...... . . . . . . . . . . . . . 38
Table 4 Inspection Report Activities . . . . . . . . . . . . . . . 41
Table 5 Inspection Hours Summary . . . . . . . . .........46
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1.0. INTRODUCTION
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1.1 Purpose and Overvie9
The Systematic Asses'sment of Licenseo Performance (SALP) is an
integrated MC staff effort to collec.t available observations and
data on a periodic basis and evaluate licensee performance based upon
this information. SALP is supplemental to normal regulatory
processes used to ensure compliance to NRC rules and regulations.
SALP is intended to'be 'sifficiently diagnostic to provide a rational'
basis for allocating NRC resources and to provide meaningful guidanc'e
to licenste managementi to promote quality and safety of(pl e.nt
construction and operation. '
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A NRC Shoreh;a SALP.,ijoard, composed of the,f staff members li' ster! in
Section 1.2 below, met or April 22, 1985, to review the collection;pf ,
performance observations' and data and assess LILCc's performance bn
accordance with; the guidance in NRC Manual Cf apter 1516, " Systematic l' 3 i
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Assessment of Ocensee Performarce." A summary.9f, tne guidanca and ,,
evaluation criteria is provided;in ,3ection II of this' report. '
This report is the SALP Board's assessment of LILCc's performance at 'I
the Shoreham Nuclear Power Station fo- the period March 1, 19M , (
through February 28,t1985. N
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1.2 SALP Board 's \ 3,
NRCSALPBoardNmbers: l .
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Chairman ' ' '
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R.W.Starostecki, Director,DivisionofReactorhojects '
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T. T. Martin, Director, Division of Radiation Safety and Safeguards o
W. Kane, Deputy.0irector, Division of Reactor Projects
L. Bettenhau;en( Chief, OperationA Branch, DRS. .
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H. B. Kister, Chief, Projects' Branch 1, Div.ithn of Reactor Projects 'n -,1
J. Strosaider, Chief, Reactor Projpcts Sectfon IB "
A. Schwencer, Chief, Licensf;'g' Brugh 3, NRR - k' t ' ..
R. Caruso, Projtct Manager,9'RR[1 ;( '
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P. Eselgroth, Senior Resident Inspector,sShoreham
Other NRC Attendees:
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J. J. Joyner,' Chief, .NMSS'Ceanch, DRSS l4 -
E. Kelly, Project Engineer, M ctor Pr9fects Section IB
W. Pasciak,, Chief, BWR RPS,'tEPRF6, DRSL~'
B. Bordenick, Office of thelEAc'utive Lagal Director
N. Blumberg,' Lead Reactor Ergineer, OPS, OB, DRS !
J. Berry, Reactor Engineer Examiger, RPS 10, PB 1, DRP ,
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1.3 Background
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,Long Island Lighting Company was issued Constructidn Permit CPPR-95
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for the Shoreham Nuclear Power Station (Docket No. 50-322)xon April
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, j4, 1973. ' Tha permit authorized construction of a 2436 MWt Aneral i
N ; Electric ~ 8,WRW reactor with a Mark 11 pressure suppressdort type
i cpntainment. General Electric was selected as the NSSS supplfer and,-
i Stone and Webster Engineering Corp. as the architect engineer for'the s
project. Construction was completed by a unified construction
organizatior., termed UNICo, consisting of the licensee, their archi- ' ,
tect engineer, and General Electric personnel. Construction was
complete at i the beginning of this assessment period, with the X
exception of the new Colt diesel building, estimated to be 98% ~ 'N
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finishedaspftheendofthisperiod. Operating License NPF-19 was [
issued on December ,7, 1984, authorizing fuel loading and low power
, cold criticality testing at up to 0.001% rated thermal power or 2435
! kWt.
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During this period. ponstruction of the main facility was, complete,.
, and the Colt diew) 'N lding was finished) with the exception .of ;
g g painting and waikwayg % tallations. Run-in testing of the new'4430 a
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kW Colt-Pielstick diesel engines;was begun on February 14, 1985, and
% ,'. testing of all three engipes is scheduled to be completed in April s
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) 1985. All pre-operational testing has been completed, all systems
have been turned over to plant staff, and all test results have been
approved and test exception _s resolved or designated for tracking and
resolution during startup ' testing. The Tran< america DeLaval, Inc.
diesel test recovery program was completed. To supplement the TDI
diesels, and as an alternate source of electrical power during low
power operatdon four mobile GM diesel generators and a 20 MW gas
turbine with deadline, black-start capability were installed.
Licensee persoqnel were extensively involved in resolution of NRC ,
open inspection items and parti:1pation /n the ASLB hearings durirg ^
this period. ,
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\ Fuel' loading commenced on December 21r 1984, and was completed with ' '
relatively few problems on January 19, 1985. !
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Initial criticality
, occu. red! on February 15, 1985. *
Lic'erlsiNg ' Activities '
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Lic$nsingiear,ingsduringtheassessmentperiodwereconductedbefore
three different Atomic Safety Licensing Boards (ASLB) on TDI diesel
engine qual /fication, offsite emergency preparedness, and low power. i
safety issues. .Several licensing issues were resolved, as reporte'cl
in four supplements (Nos. 5 - 8) to the SER. Staff FSAR review is.
now complete. The Office of Nuclear Reactor Regulation staff
perforned a major review, litigated before an ASLB, of a requested
.' exempt /on from General Design Criterion (GDC) 17, Electric Powei-
{ (. Systemj,ofAppendixAto10CFRPart50.
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A low power license authorizing fuel load and cold criticality test-
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, ing (Phases I and,II of low power operation), was issued on December
7, 1984. On February 12, 1985, the Commission ruled that the ASLB
decision extending the low power license to Phases III and IV would
become effective on February 19 (later extended to February 25), and
3 a 5*4. power license could then be issued. However, on February 21,
b l) 1985, the Appeal Board . vacated the . ASLB's low power decision and
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remanded it for further consideration of security contentions. A
full power license is dependent on ASLB decisions on emergency plann-
, ing and the diesel generators. These Board decisions are currently
scheduled for April and Ny 1985, respectively.
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Inspection Activities
4
g ( During this assessment period, approximately 5,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of direct
NRC inspection were expended at Shoreham, bringing the total number
of NRC inspection hours at the facility to approximately 24,300 since
1973. Of the total hours during this one year assessment period,
approximately 3,100 were performed by Regien I-based specialist
inspectors and 2,100 by! resident inspectors stationed at the site.
A senior resident inspector was on site -thrcughout the assessment
period, and another residen.t was on site until November 1984. A
', significant amount of inspection effort during this period was
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devoted to the resolution of open NRC inspection item prior to
license issuance.
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Two team inspections were sperformed by region-based specialists,
assessing the Post-Accident Samrii':g System in February 19AS and Fire'
\ . frotection/ Safe Shutdown provisions f a-Decertbe'r 1984.
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The results of the inspectians des'cribed aaove !
tpd input from the NRC l
q Office of Nuclear Reactor Regulation on licensing activities form the .
O basis for the functional area analyses contained in Section 4 of this ,
s report. Further tabulations of inspection acttvitieg and associated. <
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enforcement actione are cortained in Tables 3, 4 and 5. The percent-
age ,of total inspection tiae devoted to a functional area, tabulatedy,
in Ta0le 5, is included a+ 9e heading of, each area analyzed 17. ,
Section 4.
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2.0 CRITERIA
The following criteria were used as applicable in evaluation of each
functional area:
1. Management involvement in assuring quality.
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2. Approach to resolution of technical issues from a safety
standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history.
5. Reporting and analysis of Licensee Event Reports, 50.55(e) reports l
and Part 21 items.
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6. Staffing (including management). ;
7. Training effectiveness and qualification.
To provide consistent evaluation of licensee performance, attributes
associated with each criterion and describing the characteristics applic-
able to Category 1, 2, and 3 performance were applied as described in NRC
Manual Chapter 0516, Part II and Table 1.
The SALP Board conclusions are categorized as follows:
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Category 1: Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used such
that a high level of performance with respect to operational safety or
construction is being achieved.
Category 2: NRC attention .should be maintained at normal levels.
( Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
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reasonably effective such that satisfactory performance with respect to
operational safety or construction is being achieved.
Category 3: Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appeared
strained or not effectively used such that minimally satisfactory
performance with respect to operational safety or construction is being
achieved.
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The SALP Board has also compared the licensee's performance during the
last quarter of the assessment period to the overall performance for the ,
entire SALP period. That comparison was used to trend licensee perform- 1
ance as " Improving", or " Consistent" (essentially the same), or
" Declining".
The recommendations for NRC attention, where noted in each of the 10
functional areas assessed, are applicable if Shoreham remains in its
presently-licensed low power (Phases I and II) operational conditions.
Region I will allocate ' appropriate additional resources if the licensee
is permitted to heat up and pressurize and continue with their Startup and
Power Ascention Test Program up to (and beyond) 5% power. This is
consistent with past staff practice for other newly-licensed facilities or
those that have experienced extended long-term shutdowns.
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6
3.0 SUMMARY OF RESULTS
3.1 Overall Facility Evaluation
Organizational changes were made at the beginning of the period, with
the appointment of a new Chief Executive Officer on down through a
new Plant Manager and a major reorganization of the nuclear opera-
tions staff. The new upper management includes individuals with
significant operating experience and is considered a positive step in
preparing for plant operation. The relocation of the Vice President
- Nuclear Operations and most of the corporate engineering staff to
the plant site contributed toward increased management involvement
and improved support of plant staff and plant operations. Although
design change responsibility principally remained with Stone and
Webster throughout the period, transfer of respcnsibility to the
LILCo engineering staff continued to increase with development of the
Interim Station Modification Program.
Construction activity was essentially complete at the beginning of
the assessment period, with the exception of the new Colt diesel
generator building. Construction of this facility was completed near
the end of the assessment period. The construction was performed in
a high quality manner in accordance with codes and standards
committed to by LILCo. The pre-operational test program also was
finished during this period, and the resolution of test exceptions
and approval of test results were found to be satisfactory. The
startup test program was begun, with fuel load and initial criti-
cality accomplished successfully with few minor problems. Startup
test coverage was provided by NRC round-the-clock at the end of this
assessment period, and the program was observed to be carefully and
conservatively conducted, with appropriate staffing, procedures, and
management attention.
Preparations for plant operations and development of operational
support programs, including maintenance and surveillance, were
planned and executed well in advance of license issuance, since the
licensee had been anticipating fuel load prior to this assessment
period. Radiological controls, surveillance procedures, and security
measures were in place and adequately implemented, well in advance of
license issuance.
The following weaknesses requiring improved management attention were
identified during the period. Regarding actual plant operations,
several weaknesses were noted with the cor. trol of plant evolutions
and the timely resolution of QC deficiencies. The licensed operator
requalification training program was judged during the period to be
of ' high quality and successful . However, in regard to the initial
license training program, a cold license class examined at the end of
the period was found to be badly prepared, and the majority of
candidates failed. This appears to have been the result of inade-
quate attention on the part of the training manager and not a flawed
program.
.
7
It is our evaluation that the training department and its programs
are generally good. The Operator Requalification Training Program,
that was put in place prior to issuance of an operating license, is
considered very good,. and the training program for shift technical
advisors is also strong. The training program for shift advisors
required revision to include improved knowledge of plant specifics,
but ultimately provided acceptable knowledge levels. .As stated
above, the poor performance on the cold license examinations is, in
our- evaluation, the result of inadequate management attention due to
conflicting priorities and not representative of a programmatic
breakdown.
In summary, . the licensee has demonstrated effective management in-
volvement and control of most plant activities during this period.
It should be noted .that these activities were conducted with no
operational time constraints and that the licensee proceeded very
conservatively in plant operations. The NRC will closely observe
licensee performance, should a higher level power license be issued,
to ensure that effective management and control of plant activities
continues during ensuing phases of operation. In the interim, the
licensee should continue their conservative approach to plant opera-
tions and ensure that other plant activities, such as training,
maintenance, and surveillance are not adversely affected by conflict-
ing priorities that detract from management involvement.
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3.2 Facility Performance
Category Last Category
Period This Period Recent
Functional Area (2/83-2/84)l(3/84-2/85)I Trend ****
1. Construction Activities ***
1 Consistent
2. Engineering and Design 1 1 Improving
3. Pre-operational and Startup Testing 2** 1 None
4. Maintenance and Surveillance 1 1 Consistent
5. Plant Operations *
1 Improving
6. Radiological Controls 1 1 Consistent
7. Fire Protection and Housekeeping 2 2 Improving
8. Emergency Preparedness 2 No Basis None
9. Security and Safeguards 1 1 Consistent
"10. Licensing 2 2 Consistent
- This area not previously evaluated.
- Previous SALP only evaluated the Pre-operational Test Program.
- In the previous SALP, this area was broken down into four separate func-
tional areas.
- Trend during the last quarter (12/84 through 2/85) of current assessment
period,
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4.0 PERFORMANCE ANALYSIS
4.1 Construction Activities (17%)
During this assessment period, four inspections were conducted by
region-based specialists addressing the construction of the new Colt
diesel generator building and the settlement monitoring program.
Observation of ongoing structural concrete construction, inspection
of in place structural steel and a review of related Quality Control
records demonstrated that these activities were conducted in accord-
ance with applicable specifications, codes, standards, drawings, and
procedures, as originally used in facility construction and as
committed to by the licensee. In addition, examination of Quality
Assurance field audits and discussions with licensee QA audit engi-
neers indicated an effective QA program with respect to the Colt
Emergency Diesel Generator Building.
The licensee has committed to evaluate settlement data for Category I
structures other than the Reactor Building and consider procedures
for addressing those structures through the life of the plant. The
construction phase settlement monitoring program for the Colt diesel
generator building was initiated with the first concrete placement in
the basemat. The settlement monitoring program and the engineering
design to accommodate differential settlement of interconnecting
lines reviewed to date were considered good.
The overall QA/QC program implemented with respect to the Colt diesel
generator building construction, including the management program,
the audit and inspection program, the procurement program and the
vendor receipt and inspection program, were effectively organized and
implemented. In addition, a review of S&W non-conformance and
disposition reports related to safety-related HVAC components demon-
strated good performance with respect to procedure and engineering
disposition. The licensee's management have effectively demonstrated
their involvement and control in assuring quality by well planned and
executed surveillance and audit of the architect engineer and
contractor design / construction operations. The Quality Assurange
Program for the Colt facility covered all aspects of the safety-
related portion of it's installation, with engineering analysis and
calculations to support identified nonconformances.
Conclusion:
Rating: Category 1
Trend: Consistent
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10
Recommendations:
Licensee: See Section 4.10, addressing the need for an FSAR
submittal which addresses the design criteria for the Colt
~
diesel-project.
NRC: ~ Future SALPs will not include construction as a functional
category.
.
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11
4.2 Engineering and Design (9%)
The Interim Station Modification Program (ISMP) is intended to more
fully utilize licensee personnel for design changes, while still
maintaining design responsibility with Stone & Webster Engineering
Corporation (SWEC) and maintaining the same level of quality as
during construction. Region-based inspection of the ISMP was
performed at the end of this assessment period. The Nuclear Engi-
neering Department's (NED) development and control of design changes
and their implementation of the ISMP was audited. This included the
processing of design output packages, installation of station modi-
fications, and closeout of work and update of affected documents and
drawings.
Management attention was applied towards the program, as evidenced
by the development of NED procedures and the involvement of the
Review of Operations Com:nittee (ROC) and the Design Review Committee
(DRC). An example of ROC participation in the review of design
changes was the replacement of timers in the MSIV-Leakage Control
System. That modification, which replaced existing timers with
longer timers in order to allow depressurization between the inboard
and outboard MSIVs, was reviewed by ROC and recommended for further
refined safety evaluation before approval of the work. The DRC was
observed to consist of key NED personnel, as well as responsible
personnel from plant staff and installation engineering, all of whom
were knowledgeable and qualified. The DRC evaluates planned modi-
fications, prepares scheduling, and assigns design responsibility to
either contractors or NED engineers. The approved 1985 workload was
observed to be well planned and prioritized.
Safety evaluations associated with design output packages were found
to be of sufficient depth, addressing the required criteria of 10 CFR
50.59. Supportive calculations were available on site, which
addressed the bases for those evaluations. Further, responsible NED
engineers were knowledgeable of their respective packages and capable
of addressing technical details. This was especially evident of the
MSIV-LCS modification.
The implementation of station modifications was found to be well
controlled; and, in particular, the update or tracking of drawing
changes to appropriately reflect as-built conditions was verified to
be accomplished in accordance with procedures. Effective communica-
tion was evident among NED, Stone and Webster, Installation Engineer-
ing, and Operations engineers. Proper attention was given to turn-
over of completed modifications and system return-to-service from in-
stallation to operations. The Modification Engineering group has
been observed to gain experience in installation.
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NED is currently adequately staffed. Another positive step in the
quality of design work is the licensee's development of an Engineer-
ing Assurance Group within NEO. Most of the NED staff were re-
,
assigned to the site at the beginning of this assessment period, and
effective communication and interface between plant staff and NED is
evident.
4
The support of the onsite Stone and Webster Site Engineering Office
(SEO) in resolving design questions and problems has been good. This
was evident by their correct processing and approval of Engineering
and Design Coordination Reports, which were reviewed as part of NRC
1 follow up of selected allegations during this period. SE0 personnel
were a cooperative and knowledgeable source of design information
required to address those allegations.
The transition of design responsibility, with SWEC during construc-
tion to LILCo as plant operations evolve, has been effective and done
well.
,
Conclusion:
.
Rating: Category 1
Trend: Improving
Recommendations:
Licensee: None
'
NRC: None
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13
4.3 Pre-operational and Startup Testing (32%)
Pre-operational Test Program
Major testing conducted during the middle of this assessment period,
which was witnessed and independently evaluated by NRC inspections,
included the Integrated Electrical Test (IET) and special testing of
the alternate AC emergency power sources for low power operation (20
MW gas turbine and GM mobile diesels). The IET was performed, using
all three TDI diesels to verify independence among redundant onsite
power sources and their load groups during plant response to a LOCA,
both with and without a loss of offsite power, in five separate test
runs. Independent NRC review of test results, including appropriate
. personnel and equipment actions, found them to be in accordance with
procedural and regulatory requirements. Licensee management was
present during, and intimately involved in, this last major test
evolution. The total load on each diesel engine, with both core
spray and all four RHR pumps running at rated conditions, ranged from
2650 to 2800 kW.
The pre-operational test program was verified to be satisfactorily
completed, including resolution or tracking through startup program,
of all pre-operational test exceptions. Management and technical
involvement in test exception resolution and final test results
review was evident and appropriate. Based on the above, the NRC's
pre-operational test program was officially closed in October 1984.
TDI Diesel Recovery Program
The licensee's overall planning, staffing, and implementation for the
retesting of the Transamerica DeLaval, Inc. (TOI) diesel engines has
been aggressive and effective. Planning for the outage, teardown,
inspection, and reassembly of EDG-102 was adequate with good staff
coverage. However, the schedule for engine 102 slipped when EDG-
101 and 103 were torn down for inspection.
Procurement of spare parts was a problem identified previously by the
licensee's quality control, particularly with spare diesel connecting
rod bearings and bushings. The number of part rejections by the
licensee reflects poor vendor inspection. The licensee is imple-
menting a program to require vendor NDE evaluations of bearings and
bushings prior to shipment, in addition to onsite licensee inspec-
tions.
Startup Test Program
The QA/QC coverige of the startup program during this assessment
period has been extensive. QC inspectors were observed to provide
100% surveillance coverage of fuel load activities, and QC performed
_
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14
an independent verification of fuel bundle locations following fuel
load. Careful planning for continuing QC extensive surveillance
activities throughout the startup test program was noted. During the
early review of the startup test procedures, a deficiency was noted
in the licensee's review process, specifically, using acceptance
criteria derived from General Electric startup test specifications,
rather than those from the FSAR. The licensee took prompt, compre-
hensive action by performing and documenting an indepth review to
correct these discrepancies and to assure that these differences did
not exist in other procedures.
The initial fuel load was conducted successfully in an organized and
conservative manner in accordance with the Technical Specifications.
There was continuous communication between the refueling bridge and
the control room during the fuel loading activities. The General
Electric Company contract startup personnel performed their func-
tions in conjunction with the operating staff. Verification of the
core status after fuel load was comprehensive. Installation of the
neutron sources, proper placement of the fuel assemblies into the
reactor vessel and the achievement of initial reactor criticality
were performed in a well-controlled and effective manner. The
licensee's generally high quality procedures, procedure change
control and perscnnel training have been strong contributors to their
successful completion of these activities. When procedural or
equipment difficulties were encountered, the licensee did not hesi-
tate to halt work, assess the situation and take corrective steps to
assure safe operations before proceeding.
The licensee's upper management have demonstrated extensive involm-
ment in assuring quality of the startup program. This was evident
through activities of the Review of Operation (ROC) committee, which
meets on a daily basis to appraise day to day operation and evaluate
technical issues. These transactions of ROC were closely reviewed,
and meetings were randomly attended by NRC inspectors. During
preparations for fuel load and throughout the fuel loading process
and initial criticality, members of the plant management staff were
visibly involved interfacing with and overviewing shift activities in
the plant, particularly in the control room and on the refueling
floor. This management presence has been evident during backshift
and weekend hours, as well as during the dayshift.
Resolution of Open NRC Inspection Items
A significant effort was applied by the licensee towards the closure
of open items from previous NRC inspections and in addressing TMI
NUREG-0737 items, IE Bulletins and Circulars, and corrective action
associated with violations. Also during this assessment period, all
previously reported construction deficiency reports were resolved.
There were approximately 70 deficiencies reported since construction
began at Shoreham.
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15
The licensee aggressively pursued resolution of NRC concerns, espe-
cially those with significance for fuel load and impending plant
operation, such that only five items were included as conditions to
the low power license. There were, on the average, over 100 and, at
times, close to 200 open NRC items throughout the first half of this
period. A team of 11 NRC inspectors spent two weeks onsite in April
1984 addressing 57 of those items and was able to resolve all or most
issues due, in part, to the licensee's preparation, well-kept
records, -and responsiveness to the technical concerns raised. A
Compliance Organization onsite has been in effect throughout this
period. This group is devoted to tracking NRC findings, and has been
responsible for presenting timely and thorough corrective actions in
this area. Notable examples which were issues that had been identi-
fied in previous periods included the resolution of Reactor Building
maintenance-induced flooding concerns, and the corrosion of compo-
nents within the suppression pool air space. Sound technical argu-
ments and corrective actions were ultimately presented by the licen-
see for these issues.
The licensee's effort to resolve IE Bulletins and previous NRC find-
ings were prompt and complete. The records supporting the licensee's
actions were readily available upon request. In those cases where
further explanation was required, the licensee provided qualified
personnel to provide detailed explanations in a timely manner.
Therefore, the inspection verifications were carried out effectively. '
Where no action was required of the licensee by a specific bulletin,
the licensee did verify that the particular problem did not exist for
their plant. This area reflected notable LILCo management attention, 1
particularly on the part of the Plant Manager and divisional super-
visors, in making plant staff aware and available to resolve NRC's
concerns, as well as coordinating Stone and Webster support.
Conclusion:
Rating: Category 1
Trend: None, due to intermittent nature of activities.
Recommendations: None
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16
4.4 Maintenance and Surveillance (6%)
This evaluation is based on three inspections in these areas
conducted by region-based specialists, as well as other observations
during startup test inspections and by the resident inspectors.
Maintenance Programs
The maintenance program is staffed with qualified, knowledgeable
personnel having an average nuclear experience level of eight years
for supervisors and four years for technicians and mechanics. The
total average maintenance experience level (nuclear and non-nuclear)
is about double these numbers in each category. Staffing levels
appear to be adequate to support corrective maintenance and surveill-
ances; however, there do not appear to be sufficient numbers of
personnel to support the preventive maintenance program. This fact
was apparent in inspection of the instrumentation and control pre-
ventive maintenance program at the end of this assessment period.
Understaffing in this area was evidenced by a backlog of I&C pre-
ventive maintenance actions, which was known and identified by the
licensee and was attributed to a priority for technicians to support
start-up surveillance testing.
The work control system is well defined and effectively controlled
through the Maintenance Work Request (MWR) and the Station Equipment
Clearance Permit (SECP) procedures. MWR and associated maintenance
procedures have been routinely found in use during random resident
inspector observations of maintenance work throughout the plant.
Plant staff have effectively utilized a plan-of-the-day meeting to
prioritize maintenance activities. The licensee has implemented
several useful trend analysis programs to highlight important main-
tenance/ equipment performance parameters to Station Management.
Trend plots for numbers of instruments and, separately, numbers of
annunciators in the control room requiring maintenance are notable
examples. Both of these plots show a decreasing trend. The licensee
has also established a data base information management system during
this period for trending equipment history which will flag equipment
failure rates that exceed a defined inquiry level of interest. This
system was initially implemented for safety-related equipment, and
the licensee intends to expand its use to non-safety-related equip-
ment as well.
Surveillance Program
During initial operation under the low power license, several in-
stances of inadvertent safety / protection system initiation were
caused by instrumentation technicians. A more thorough briefing in
the area of sensitive instrumentation, and greater attention to
.
17
detail by the technicians is warranted in order to reduce the frequ-
2
ency of unnecessary challenges to safety protection systems.
Extensive review by NRC of preparations for initial criticality
indicates that an excellent surveillance test program is in place.
Plant surveillance procedures and test results, inspected in support
of startup activities, indicate that the system used by the licensee
to assure that Technical Specification surveillances are satisfied is
functioning well. Performance of several surveillances was
witnessed. In _one instance, a deficiency was noted in calibration
checking of the front panel recorder (IRM Functional Test). The
license took prompt action to correct this and other similar proce-
dures (SRM Functional Test and APRM Functional Test) when informed by
the inspector. All routine required surveillance tests were found to
have been properly scheduled and performed in a timely manner.
Operations personnel were aware of surveillance tests in progress and
followed the implementation of each test closely. Most tests
observed by NRC progressed well, with little or no procedural changes
required, with the exception of the 18-month functional test of the
MSIV leakage control system. This test, while being performed for
the first time, did not proceed according to procedure and required
several ad-hoc changes before being satisfactorily completed.
Licensee personnel were observed performing this surveillance using a
previously-deleted version of the test, while development of a work-
able procedure was underway. This was judged to be an isolated case
based upon the observation of numerous other tests where, when proce-
dural difficulties were encountered, approved procedure changes were
issued before proceeding. Another problem involved inadequately
developed procedures for the Leakage Reduction and Control Program
for 9 of 12 systems outside of containment which may become conta-
minated or could contain primary coolant sources. The program, in
response to NUREG-0737 Item III.D.1.1, was not fully implemented at
fuel load as required by Technical Specifications.
Summary
.
In summary, the overall maintenance and surveillance functions appear
to be well defined and effectively managed to support safe plant
operation. Further, the licensee has had considerable experience or
" practice" in this regard over the past two assessment periods, and
previous SALP reports have noted continued improvement. Plant staff-
ing and other aggressive improvements in this area, instituted during
the last assessment period, have been maintained throughout the
current period. However, management attention to improving their
preventive maintenance resources, and towards elimination of un-
necessary challenges to safety / protection systems (including review
of experience at other nuclear plants), should be continued. While
some instances of poor work controls were observed, these did not
jeopardize plant safety. In fact, when a problem was recognized,
work was stopped until the problem could be resolved.
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18
!
Conclusion:
Rating: Category 1
Trend: Consistent
Recommendations:
Licensee: Increased attention should be given to the area of preven-
tative maintenance and to reducing the frequency of un-
necessary challenges to safety protection systems initiated
by surveillance activities.
NRC: None
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I
4.5 Plant Operations (14%)
(
l Plant Operating Staff
l
l The licensee has been successful in hiring an experienced Vice
President - Nuclear Operations and has placed an individual with
responsible nuclear experience in the Plant Manager position.
The need for on-shif t operators with previous operating experience is
! a relatively recent requirement, to which the licensee responded by
selecting several qualified individuals to act as shift advisors,
until the licensed operators at Shoreham can accumulate sufficient
operating experience of their own. Adequate plans have been made for
numbers of licensed operators, and shift advisors are an interim
measure to meet new NRC criteria.
Initial review by the NRC of the shift advisor training program
,
identified a deficiercy with the amount of on-shift plant specific
l familiarization training and a need for increased use of control room
walk-through questions on the licensee's certification program. The
~
, licensee was responsive to these concerns, and NRC follow-up has
found the licensee's subsequent actions to be satisfactory.
Licensed Operator Training programs
The only activity in the area of initial licensed operator training
l during this period involved the conduct of NRC " cold license" exami-
l
nations at Shoreham in February 1985. Examinations, both written and
oral, were administered to 10 reactor operator candidates, three
senior reactor operator candidates, and two non-LILCo employee
Instructor Certification candidates. The results of these examina-
tions were very poor and indicate a serious deficiency in the LILCo
Initial License Training Program. Seven of the 10 reactor operator
candidates and all three senior reactor operator candidates failed
the examination. The evaluation of written and oral exam results
indicate that their training did not adequately prepare the candi-
dates for performing the duties of licensed operators.
A major reason for this breakdown appears to have been a lack of
management attention to the progress of these candidates and a
failure to observe, or act upon, the indications that this class was
not properly trained. This lack of management attention is evidenced
by the fact that no one in a supervisory position in either the
training staff or plant operations staff participated in any pre-
NRC exam audit or evaluation of these candidates. Additionally, a
review of weekly quiz scores and the final written audit exam scores
of this class indicate clear deficiencies in knowledge levels of some
candidates which were either ignored or not believed by the LILCo
.
staff. The first three groups of license exams conducted in 1982 and
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l :
i 1983 at Shoreham yielded very strong results and the training program
l was assessed as strong. The more recent class indicates that the
candidates were not adequately trained and prepared.
After the preliminary examination results were developed, Region I
management met with the licensee to review the situation and to try
to assess the implications. Licensee management representatives
acknowledged the existence of a problem in this area in that they had ,
not been cognizant of the status of the class until after the NRC
examinations. Cited were conflicting priorities with ASLB litiga-
tion, fuel load and initial criticality, and TOI diesel testing as
contributing to the failure of licensee management to properly
supervise and monitor the progress of this license class. On March '
20, 1985, LILCo's Vice President - Nuclear met with Region I manage-
ment and committed to aggressively pursue corrective action, includ-
ing their own internal audit of the examinations (which verified the
NRC findings), some disciplinary action, and a four-month augmented
retraining program to be overseen by the LILCo Vice President -
Nuclear Operations. An August 1985 re-examination of these candi- r
dates was proposed.
During the assessment period, the NRC continued its review of the
Shoreham Licensed Operator Requalification Program. Although, by
regulation, Shoreham was not required to have a Requalification
Program in place until after the issuance of an operating license,
LILCo has had an ongoing program since February of 1983. The NRC has
continually been involved in the assessment of the adequacy of this
program. The culmination of this assessment was the conduct of
NRC-administered Requalification examinations to 25% of the licensed
operators at Shoreham in November 1984.
The purpose of the NRC-administered exarrinations was to enable the
NRC to make a determination as to the renewal of operator and senior
operator licenses at Shoreham. Under the regulatory guidelines of 10
CFR Part 55.23(c)(2)(iii), NRC operator and senior operator oral and
written examinations were given to six SR0s and three R0s at Shoreham
in November 1984. The results of these examinations were very good,
with all candidates passing both the oral and written examinations
and most candidates achieving high written exam scores. Based on
these exams and the satisfactory results of other NRC inspections of
the Shoreham Requalification Program, license renewals were issued to
all operators at Shoreham beginning in March 1985.
Overall, the Requalification Program at Shoreham continues to be a
very strong, operationally-oriented program. The program involves
many innovative concepts, such as Technical Specification group
exercises, control panel recognition drills, and on paper malfunction
exercises using detailed panel and annunciator drawings. The Program
also actively involves both the licensed operators and non-licensed
onshift personnel.
__ _ __
L
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l 21
i Plant Evolutions
During this assessment period, but prior to receipt of the low power
license, two incidents occurred which revealed a need for improve-
ments in the timeliness and thoroughness of incident follow-up. One
incident involved a Radwaste system flexible piping connector which
ruptured and caused flooding of the regenerator evaporator area, and
the other involved an improper valve lineup for drainage of reactor
,
vessel water that occurred twice, resulting in flooding of the dry-
'
well floor area. Concern over these events was expressed by the NRC;
and, near the end of the assessment period, the licensee subsequently
demonstrated significant improvements in timely and thorough evalu-
ation of plant incidents.
Shoreham received its license to load fuel and test the reactor at up
to 0.001 percent power on December 7, 1984. Fuel loading began on
December 21, 1984, and was completed on January 19, 1985. The licen-
see achieved initial reactor criticality on February 15, 1985.
During these early phases of plant operation, the licensee purposely
established a conservative pace as a conscious step towards accommo-
dating the existing experience levels of plant personnel. Licensee
management is credited with taking the initiative months before the
low power operating license was issued to implement plant administra-
tive controls as if the plant had an operating license. For example,
Technical Specification Limiting Conditions for Operation (LCO's)
l were identified and tracked, and plant management /NRC resident
!
inspector notification of significant occurrences were made as they
would be for an operating plant. The licensee was fully prepared to
implement a well developed set of Technical Specifications at the
time of low power license issuance.
The Control Room environment has continued, throughout this assess-
ment period, to be characterized by a professional appearance and
atmosphere of businesslike conduct. The licensed operators maintain
the control room free of extraneous distractions and are routinely
attentive to plant conditions and annunciators. During the initial
stages of fuel load, the heavy incidence of support personnel inter-
,
facing with the Control Room resulted in a need for clarification and
'
stricter enforcement of Control Room access controls; but, this was
quickly resolved by plant management and shift supervision. Shift
supervision has been effective at maintaining low background noise
levels during the conduct of administrative duties with support
personnel, to the benefit of licensed operator attention to plant
operations and status. Based upon observations by NRC staff and
management, the overall Shoreham Control Room environment is const-
dered excellent.
Regular reviews by the resident inspector of the various control room
logs (e.g., watch engineer (shift supervisor) log, temporary proce-
dure change, lif ted lead and jumper logs) have found the logs to be
!
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--m- - ,---- .- -.r -,-yi- - -w w -p-a - e er - -Tr-- ---,r-.-%w-iy-r-i----c--w-e---m -y&-
, - . - -----g-4' -
-m-e- ---+--
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22
complete, legible and accurate records of plant status. The resident
inspector has also observed watch engineer shift turnovers, on many
occasions, for proper review by the oncoming and offgoing watch
engineers of the status of plant conditions, plant equipment main-
tenance and test status, logs and current directives. In all cases,
shift turnovers were found to be weil conducted. Also reviewed were
the administrative controls contained in station procedures for
returning systems to service which have been modified or repaired,
in which areas were identified where clarification was needed in
order to ensure that the watch engineer could determine what
approvals are required prior to return to service. The licensee was
responsive to these NRC-identified concerns and corrected the proce-
dural inadequacies. The licensee has implemented a system to iden-
tify adverse trends in Licensee Event Reports, reports of abnormal
conditions, and control room instrumentation and annunciator fail-
ures. The Review of Operations Committee (ROC) has been functioning
smoothly in the review and approval of assigned procedures, tests and
modifications.
The licensee's overall performance in the area of plant operation has
been good; however, some areas for improvement have been noted. Some
difficulties have been experienced with proper execution of some of
the seemingly simpler tasks in the plant which are performed by an
individually-assigned operator or technician. In recent months,
these occurrences have included: two operator valve lineup errors
involving reactor vessel and/or fuel pool water level changes; an
improper blade guide movement; and four I&C technician-induced system
trips - one reactor protection system trip, one emergency core cool-
ing system trip and two reactor water cleanup system isolations.
While these occurrences do not constitute safety problems individ-
ually, they do represent unnecessary challenges to safety systems and
a general need for improvement by operators and technicians in their
attention to detail. The licensee has taken corrective actions for
these occurrences which should prove to be effective. Continued
plant management attention to this area is warranted in order to
ensure an improving trend. A need for improvement in the area of
Operations management / shift personnel formal communications (Standing
Orders and Night Orders) has also been identified. This was evid-
enced by omission of notification (from management to shift
personnel) about the NRC/ licensee temporary fire watch agreements and
by issuance of shift directives that were not approved in accordance
with the requirements for Standing Orders.
In summary, the licensee's operational performance has been generally
good. The Shoreham plant management team has exhibited an alert,
technically competent and conservative approach to plant operations.
Quality Assurance for Plant Operations
It is noteworthy that Operations and Maintenance management consider
the assurance of quality for their department activities to be their
__ _
_
.
'
23
responsibility, rather than relying on independent QA organization
overview of plant activities.
During the preparations for, and actual conduct of, fuel loading and
initial criticality testing, the level of QC inspector involvement
was noted to be satisfactory. De.ficiency reports that were written
by the licensee's QC inspectors indicated that a thorough overview of
activities was provided. The BWR familiarization training provided
to QC inspectors is considered to be a valuable enhancement of in-
spector knowledge levels in preparation for power operation. The
licensee developed a revised QA Department organization, in conjunc-
tion with the transition from construction to operational (low power
license) status, and submitted the necessary FSAR changes in
September 1984. The licensee was issued a low power license in
December 1984; however, as of the end of this assessment period, most
of the quality assurance procedures reflecting these organizational
changes had not been approved and issued. The QA Department Manager
position, which had been vacant for,nine months, was filled shortly
after the end of this period. Formal updating of organizational
changes requires more aggressive management attention.
During the early portion of the assessment period, senior licensee
management brought to plant management's attention two problem areas
that were characterized as "potentially significant trends adverse to
quality." One involved late and/or incomplete responses to audit
reports and, the other, failure to accomplish the necessary correct-
ive and/or preventive actions within the committed times. NRC review
of the Quality Control deficiency reporting / tracking system during
the latter portion of the assessment period fourri the licensee's
program, for ensuring that LILCo Deficiency Report (LDR) findings
have corrective actions ident;fied in a timely manner, to be lacking.
This situation resulted in issuance of a violation. ' The licensee's
initial response and corrective actions were considered by the NRC as
insufficient; however, subsequent feedback regarding a more aggress-
ive follow-up program for establishing LDR corrective actions
resulted in a satisfactory response.
The Independent Safety Engineering Group (ISEG) is tasked by the
Technical Specifications with overviewing plant operations. Subse-
quent to issuance of the low power license in December 1984, the
ISEG was found to be spending 40% of its time on review and update of
plant Systems Descriptions and only 20% of its time overviewing plant
operations. This distribution of ISEG resources, relative to the
priority of their safety overview role, was discussed with licensee
management, and a satisfactory realignment of ISEG workforce utili-
zation was made.
Conclusion:
Rating: Category 1.
Trend: Improving.
_
..
24
Recommendations:
Licensee: Continue plant management attention towards maintaining a
low incidence of unnecessary challanges to safety /protec-
tion systems, ensuring attention to detail by operators and
technicians, and improving communication between Operations
personnel.
Continued upper management attention should be given to
ensuring that the QA Department and ISEG group provide an
effective quality assurance overview for plant operations.
NRC: The possibility of attrition of experienced staff members
due to Shoreham licensing delays exists and should be
monitored closely during the next evaluation period.
c
F'
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25
4.6 Radiological Controls (7'O
During this assessment period, there were seven inspections performed
by region-based inspectors. Resident inspectors also checked radio-
logical controls periodically. Radiation specialists inspected the
licensee's radiation protection program, chemistry program, effluent
monitoring and control program, and radioactive waste management and
transportation programs. Also inspected were the licensee's pre-
operational testing of radioactive waste processing systems, effluent *
monitoring systems, and ventilation systems. A special team inspec-
tion of post-accident sampling capability, relative to guidance
contained in NUREG-0737, was also performed.
During the previous assessment period, weaknesses were identified in
the site radiological controls organization and in the definition of
position responsibilities and authorities therein. During this
assessment period, the licensee reorganized the plant Radiological
Controls Division into three sections consisting of Health Physics,
Radiochemistry, and Radioactive Waste. The responsibilities, author-
ity, and selection criteria of each division position are appropri-
ately defined. This reorganization is an improvement over the last
assessment period and will provide for better control of radiological
activities at the site. The Chemistry and Radioactive Waste sections
were found to be not fully staffed; however, the licensee had hired
contractor personnel to assist in performing the necessary functions
of these sections during startup testing. Those contractor personnel
were adequately trained and qualified for their responsibilities.
The licensee is actively recruiting to fill identified vacancies.
Regarding the corporate Radiological Controls organization, the
l licensee has formally established the organization, defined the
responsibilities and authorities of the group, and defined the mint-
mum selection criteria for each position specified.
l
'
The licensee has established a defined training and qualification
- program for personnel involved in radiation protection, chemistry and
l radioactive waste activities. No deficiencies in the currently
established program were identified. Training records were complete,
well maintained, and available. Reviews of licensee procedures for
l radiation protection, chemistry, effluent monitoring and release
!
control, and radioactive waste handling found them to be explicit,
controlled, and followed. Some deficiencies were identified in the
licensee's airborne radioactivity surveillance procedures; however,
these deficiencies were quickly addressed by the licensee when
- brought to his attention.
During this assessment period, licensee implementation of the guidance
i contained in a number of NRC Bulletins and Circulars was assessed
l
by NRC inspection, addressing such matters as: packaging of low level
waste for transfer and burial; identification and prevention of
__
-- - =. - - _ - - . . . .- .
!
.
26
!
!
unmonitored releases; control of plant staff work hours; and perform-
ance of safety evaluations for design changes to radioactive waste
treatment systems. The if censee initiated timely, technically-sound
responses towards these NRC initiatives, and their action on these
l Bulletins and Circulars demonstrated consistent evidence of prior
- planning and appropriate assignment of priorities in addressing
i
concerns identified therein. The licensee also gave similar atten-
l tion to recommendations provided in NRC Information Notices. For
example, for a Notice describing instances of improper use of dosi-
I
metry devices (by personnel at other stations and in order to mini-
mize recorded exposure), the licensee modified radiation protection
procedures in order to identify, in a timely manner, any apparent
l
'
misuse of dosimetry devices by Shoreham personnel.
!
The licensee's overview of and capabilities in the areas of chemical
and radiochemical measurements were reviewed. The licensee has a
well defined quality control program for chemical and radiochemical
mea sureme its. Procedures in this area address, among other matters,
personnel qualifications, applicable acceptance criteria, and correc-
tive actions for unacceptable findings. The licensee was provided
l witt actual radioactive test samples (by the NRC) to determine his '
capalility to measure radioactivity in effluents, and satisfactorily
analped those samples with no identified deficiencies. Radiological
controls for loading of neutron sources into the reactor were also
observd by NRC inspections, with no unacceptable conditions identi-
fled.
An NRC team inspection assessed post-accident sampling capability, I
and found that the licensee's efforts in this area generally exceeded I
the minimum quidance specified in NUREG-0737. For example, the
licensee constructed a separate building as a Post-Accident Sampling
Facility (PASF). The PSAF is equipped with it's own ventilation
system and in-Ifne monitoring / analysis equipment which are capable of
minimizing personnel exposure during sample collection. Some tech-
nical and administrative deficiencies were identified with the
Post-Accident Sampilng System (PASS), such as: completion of a main-
tenance program; high level effluent and chloride analysis capabili-
ties; and, procedures for offsite transport. The licensee is aggress-
ively moving to resolve these deficiencies. The PASS was not fully
operational at the time of the team inspection; and, since the low
power license required the establishment of all elements of the l
sampilng program but no exemption to that license requirement had i
been obtained, the licensee was issued a violation. The licensee is
~
currently training and qualifying all appropriate personnel on the
operation of the PASS and anticipates full system operability prior
to exceeding 5*; power. Routine plant sampling systems are adequate
for reactor operations below 5's power, and PASS availability would
become significant only for power operation beyond that level.
Conclusion:
Rating: Category 1
Trend: Consistent
Recommendations: None
.
'
27
4.7 Fire Protection / Housekeeping (7%)
Fire protection
Region-based inspectors conducted two inspections in this area, and
regular resident inspector observations were also documented
throughout this assessment period, addressing the control of combus-
tible material, the maintenance of portable extinguishers, the ,
conduct of fire watches and patrols, and related housekeeping.
No fires were experienced during this assessment period; and, as
noted during the previous period, fire hoses, boxes and other equip-
ment were accessible and rcquiarly maintained operable. As discussed
below, effective housekeepir.g practices consistently kept plant areas
clean and free of debris. Hcwever, the safe shutdown team inspec-
tion, discussed later, identified eight deviations from commitments
described in the Safety Evaluation Report (SER) and Five Hazards
Analysis Report (FHAR). Fire watches, established during the last
three months of this period as a result of the team inspection's
findings, were observed to be diligent, and the ifcensee's audit and
oversight of these activities was effective. Fire Protection Program
responsibilities have been assigned to a full time fire protection
engineer who reports to the maintenance engineer. Evidence of their
dedicated involvement in the Program was observed by the outstanding
job of monthly inspection of fire suppression equipment, including
portable extinguishers. An example of the licensee's responsiveness
to NRC concerns was the anchoring of portable emergency equipment
lockers to prevent possible seismic damage to reactor building
systems. Adequate fire protection and prevention provisions were
also observed to be employed during the conduct of TDI diesel testing
and fuel load. '.
The licensee exhibited a continued understanding and concern for fire
protection issues, as illustrated by their intent to hire 10 addi-
tional fire protection technicians. These technicians' duties will
include not only surveillance activities, but also fire brigade
membership which will enhance the effectiveness and cohesiveness of
brigade training by replacing the security force's involvement.
Licensee management's involvement was demonstrated by the frequency
and high level of brigade training provided and the quality and
quantity of firefighting hardware found in equipment lockers through-
out the plant. The licensee was responsive in addressing a NRC
concern for the condition of certain fire doors (pressure equaliza-
tion openings) by initiating a re-certification of the doors by
Underwriters Labs. While the licensee's application of their QA
Program in this area was judged to be thorough and comprehensive, the
resolution of findings from the annual audit in January 1984 by the
Shoreham Nuclear Review Board has not been prompt in that certain
findings still remain open. The licensee had identified this problem
in May 1984 and has since committed to expedite closecut and resolve
future findings in a timely manner.
!
!
.
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28
The safe shutdown team inspecticn identified eight deviations from
commitments described in the Safety Evaluation Report (SER) and Fire
Hazard Analysis Report (FHAR). Licensee management's evaluation of
these issues, including their proposal of permanent corrective
action, was quickly and thoroughly developed within five weeks.
Following formal discussion at a management meeting with the NRC
~s taff, a response to all deviations and unresolved items was provided
two weeks hence. That response is currently under review by NRC, and +
follow-up of selected items is planned for April 1985.
l
The licensee's FHAR and CSAR for the Reactor Building were considered j
as technically sound; however, supportive information was generally l
unavailable on site, and the FHAR for outside of Reactor Building was
lacking in detail and thoroughness. Procedures used to attain a safe
shutdown from outside of the Control Room were found to be generally
adequate in attaining an orderly and timely shutdown. Walkthrough of
those procedures during the team inspection noted a lack of emergency
lighting in certain Reactor Building areas where local operations are i
to be performed. However, operator training and knowledge of proce- ;
dures appeared to be thorough. In general, fire protection features ,
were observed by the team to be well-designed, save for the defici-
encies noted.
Housekeeping
As a result of previously identified housekeeping problems, the
licensee made a major increase in the size of the facility cleanup i
force during the last SALP period, p
During this assessment period, the licensee has continued to make '
steady improvements in housekeeping at the plant. Particular areas
inspected for cleanliness include the drywell, all elevations of the
reactor building, the turbine building, the screenwell, the control
butiding (including the TOI diesel generator rooms), the radwaste
building, and the new Colt diesel generator building which was under '
construction during this period. The licensee has achieved and 7
maintained a level of excellence in housekeeping, which has been
noted and documented in six inspection reports within this period; ;
and, this observation has been affirmed by NRC management and staff. !
t
Conclusion: ;
Rating: Category 2 i
Trend: Consistent
l
Recommendations: None
l
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'5.
4.8 Emergency Preparedness (3*.') g ,'
,
One specialist inspection.was cons /cted dbrdg this assessment period r
which addressed four unreso Ned items from the '
NRC's August 1982
EmergencyPreparedney. Appraisal./
Is i-
3
The licensee is maf t.taining art !ctive Energency Preparedness Program
and has issued detailed Implemertirs 'Pocedures for the onsite Emer-
gency Plan. The etergency training proyam is well defined, detailed
for each specific aisignmenti' in the' Emergency Response Organization ,
and maintained by1 t6e: Emergency Preparedness Organization. The
Emergency Preparednktd Program continue to receive extensive LILCo ,( \
management involvement. Den has beui aa aggressive approach to f % '
resolution of emergency planning issues and an extensive committ.ent ' ,
of resources as indicated by the size of the Emergency Preparedness 'n Q ,
staff; sevsn licensee employees augmented by 13 contractor employees.
Until an appropriate emergency re ponse exercise is conducted, how-
ever, training effectiveness cannot be evaluated.
The full power phase of the $horehte ASLB hearir.gs involves offsite
emergency plariling issues heard befort a separate Board, begun at thy ,
end of the last assessment period, and concluded in August o' this
period. In risponse to 32 toQnica1' inadequacies identified 'opfEMA,
LILCo submitted Revision 4 to its ~ 0,'fsite Emergency Response Plan.
'
Resolution of 24 of the 32 identified inadequacies had been accepted
as of the end of this assesscrent period. A FEMA graded exercise 'of
Shoreham's of fsite emergenci plan is, as yet, unscheduled, although
LILCo has requested such an exercise. ,
,
Conclusion:
Rating: No basis, du<t to limited observat. ons.
't
' '
Trend: None s
+
Recommendations: None ,
5
,
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4.9 Security and Safeguards (5%)
Analysis '
During the pre-operational portion of the assessment period, kant
management provided . effective jo'versight in the development of the
'
4 Security Program arc ~ organization. The licensee completed construc-
I
,
tion and equipment tnsta.llation for the protected and vital areas, as
described in the Physical Security Plan, in a timely manner prior to
issuance of the low power license. In addition, several specialized
security program enhancements, such as extra lighting around the in-
take area, anti-ramming devices at vehicle gates and additional t' ele-
,
\ '
vision coverage of the protected area were implemented. During this
, period, the licensee identified an incident involving a compromised
{' set of security 2xarrination s. Prompt and extensive corrective
)
A \ actions were initiated. This reaction demonstrated management's
, g , caoability to analyzq ,and take immediate action to mitigate and '
g
,
, cdcrect a potential, problem.
. The Security Program was implemented at an early date to ensure
adequate training and qualification for the security force. This
initiative was very effective. Additionally, a professional firearms
y qualification program is in effect. Armed personnel were observed by
N NRC inyectors to be proficient in the handling and use of weapons.
e
'
'
Security force personnel were observed by the NRC staff to have
progressively inproved their capabilities during this portion of the
, assessment
relativ? ly pe.".id and management's involvement was evident by a
treuble-free transition when the low power operating
license was d ued. '
(
.
/ During the relatively short post-licensing portion of the assessment
' period, the licen',ee reported one security event in accordance with
10 CFR Part 73.71. Tnis event involved a threal, received by tele-
i
phone. The sederity force was observed by NRC inspectors relative to
interface with local law enforcement authorities and implementation
of contingency plan actions. The security force was well coordinated
and imp'emented required actions in a methodical and organized
fashion while responding to the epent. This is attributed to manage-
ment's attention to the training and qualification of the security
force and early implementation of the security program.
Three violations of security procedures have occurred during the
post-licensing portion (since December 7, 1984) of the assessment
period. One involved recordkeeping, and two involved failure to
adhere to procedures by guard force personnel. One of the two
procedural violations was of some concern to NRC, due to its poten-
tial indication of a training weakness in at least one member of the
security force. An evaluation by the licensee of that perspective
,has been requested by the NRC, but was not due at the time of this
' report. -
'
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,
31
)
.
In order to obtain better insights into the licensce's training and
qualification program,. and because of training and qualifications
l deficiencies identified at other nuclear power plants, NRC conducted
i
'
.a special inspection in March 1985, during which members of the
security force were randomly selectad for re-examination in all
- phases of traininsj. Excellent cooperation was received from licensee
management personnel who carried out the re-examination effort in ar )
organized and professional manner. The results: the re-examinations
l
'
were very f avorable and indicated that the security force can effec-
tively perform the. duties and responsibilities required by the NRC-
approved Security Plan.
Conclusion-
.
Rating: Category 1
Trend: Consistent
l
l Recommendations: None
, t
d
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%
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,
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,
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- _ _ _ - _ _
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32
4.10 Licensing
C
"
The licensee's management participated actively in licensing activi-
ties, many of which were associated with the TDI Diesel Generators
hearings and the GDC-17 exemption proceedings.
Many significant licensee management changes occurred at the start
of this assessment period. A new Chairman of the Board was named,
who also serves as President and Chief Executive Officer of the
company. A new Vice President - Nuclear Operations, with extensive
nuclear experience, joined the company, and a Plant Manager with
operational nuclear experience was assigned. These individuals, most
notably the Vice President - Nuclear Operations, have participated
actively in resolving licensing issues. The Senior Vice President,
the Vice President - Nuclear Operations, and senior plant management
attended the NRR Management Readiness meeting in October 1984. The
Vice President - Nuclear Operations has been heavily involved in
meetings to resolve TDI EDG problems and the GDC-17 proceedings.
However, after the reorganization in April /May 1984, a promised FSAR
revision describing the new management structure took inordinately
long (five to six months) to provide.
The licensee's management consistently exercised firm control over
its contractors' activities and maintained good communications
between the contractor, their own staff, the NRR staff, and the NRR
staff's contractors. We have noted, though, that the extensive
litigation before the ASLB has had a chilling effect on the inter-
change of information related to contested issues. For example, in
support of the TDI hearing on the " qualified load", the staff asked
for detailed information on EDG loads in July 1984. We received a
partial reply in November, which had been edited so carefully that
much of the information it contained was technically useless. Many
telephone calls and several more licensee submittals were necessary
before the staff received useful answers. In a slightly different
vein, the licensee proposed to use revised operating procedures and
additional training to minimize the possibility of overloading the
EDGs. Despite oral reminders to the licensee's representatives in
November 1984, and a written reminder on December 11, 1984, a team
of NRC reviewers found on January 16 - 17, 1985, that the procedural
revisions were not complete and were, in some cases, inadequate.
Furthermore, the team found that the training department had not been
directed to develop a training plan for EDGs, despite the fact that
hearings concerning the adequacy of that training were scheduled to
begin on February 5,1985.
i
1
s- The licensee's management and staff have demonstrated a satisfactory
,
t understanding of technical issues. The licensee initiated and
.'
provided major support to the TDI owner's group effort to resolve
questions raised as to the adequacy of TDI diesel engines for
nuclear service. In its presentation of its justification for
t
_
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_
.
33
exemption from GDC-17, the licensee presented good technical justi-
fication. For these issues, the licensee's response to staff
comments has generally been technically sound and presented in a
thorough manner in extensive reports and meetings, as supported by
test results. The licensee's proposal to do its own offsite emer-
gency planning has been especially complete and thorough, notwith-
standing certain legal problems associated with the plan.
In several other areas, such as implementation of Regulatory Guide
1.97 and the development of acceptable protection system setpoint
methodology, the licensee's technical response could have been
significantly improved by the submission of more detailed design
information and a better technical justification for deviations.
Additionally, the staff feels that the licensee should have tested
the TDI EDGs at the engines' normal rated capacity of 3500 KW, in-
stead of as-tested rating of 3300 KW, to establish a qualified load
value of the engines. The licensee has taken credit for operational
capability above 3300 KW; however, this issue is currently before the
ASLB.
Because of Shoreham's stage of construction, relatively few NRC-
, initiated licensing issues were resolved during this rating period.
The licensee's responsiveness to these few issues which arose varied
widely. In general, issues which were required to be resolved prior
to licensing, such as fire protection, TDI EDGs, process control
program revisions, operator requalification, and equipment qualifi-
cation, were addressed expeditiously. Issues which did not impact
the issuance of a license, such as the operability of certain isola-
tion valves, the development of a protection system setpoint method-
ology, and implementation of Regulatory Guide 1.97, dragged consider-
ably. Other issues, such as the remote shutdown panel, thermal
hydraulic code modifications, and the control of heavy loads, fell
somewhere in between.
Conclusion:
Rating: Category 2
t Trend: Consistent
Recommendations:
Licensee: Devote more attention to items not on the critical path
for licensing. Lessen burden on plant staff with respect
to hearings, where it conflicts with normal responsibili-
ties. Also, as requested by NRR staff on several occas-
ions, a detailed FSAR design description of the Colt diesel
generator project, including codes and standards to be
applied to its construction, is needed if these engines are
to be relied upon for plant operation.
NRC: None
_
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.
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_ _ _ _ _ _ . . _ - - - - - - - - - - -
.
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34
'
5.0 SUPPORTING DATA AND SUMMARIES
5.1 Investigations and Allegations
Three items were referred to the Region I Office of Investigations
during January and February 1985. These items are currently under
evaluation.
Three allegations received during the previous SALP period were found
to be unsubstantiated and closed, as were the 40 allegations from a
former steamfitter employed at Shoreham. The three allegations in-
volved design and installation of cable trays and conduit, weld QA
data, and the adequacy of BISCO pressure seals for piping penetra-
tions. The 40 allegations from the steamfitter involved a variety
of concerns associated with the construction, design and testing of
the facility.
Allegations were received from three separate sources during the
present SALP period and are still under evaluation. These involve
concerns raised by a former Shoreham QC inspector and a former
employee of two subcontractors at Shoreham. The other allegation
involves a licensed reactor operator's qualifications.
5.2 Escalated Enforcement Actions
Civil Penalties: None.
Orders
The three Atomic Safety and Licensing Boards (ASLBs) presiding ,ver
the Shoreham OL Proceeding, the Appeal Board (ASLAB), and c,
Commissioners issued Memoranda and Orders as needed to support the
ongoing hearings.
Confirmatory Action Letters
One Confirmatory Action Letter (CAL 84-25) was issued on December 7,
1984, concerning compliance with Criterion 3, Fire Protection, of 10
CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants.
Enforcement Conferences: None.
5.3 Management Conferences Held During the Assessment Period
On November 16, 1984, NRR met with the licensee at the plant site for
a review of the licensee's readiness for a low power license, which
was issued on December 7, 1984.
Other NRR site visits during the period included four regarding the
TDI Emergency Diesel Generators and three General Design Criterion 17
exemption reviews.
_
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35
A management meeting was conducted March 1, 1985, at Region I to
discuss' candidate performance during the February 18, 1985 cold
license examinations at Shoreham. In addition, the LILCo Vice
President - Nuclear met with Regional management to discuss
corrective actions regarding the cold license exams on March 20,
1985.
Visits to the Shoreham site were made by NRC Commissioners Zech,
Bernthal, and Asselstine.
5.4 Exemptions Granted
The following exemptions to Appendix A, General Design Criteria, of
10 CFR Part 50 have been granted:
GDC-2 - Seismic qualification of certain equipment;
GDC-56 - Redundant containment isolation barriers;
GDC-19 - Remote shutdown capability.
5.5 Construction Deficiency Reports (CDRs)
Three CDRs were submitted by the licensee during this assessment
period. The CDRs are described in Table 1. Review of these CDRs
identified no causal linkages.
5.6 Licen'see Event Reports (LERs)
Eight LERs were submitted during the last quarter of this assessment
period. The LERs are characterized by cause in Table 2. No causal
linkages were identified.
5.7 Part 21 Reports
Louis Allis submitted a report under 10 CFR Part 21 to NRC Region I
on March 6,1985, concerning seven cracked welds found in coil guard
conical baffles installed on the Colt diesel generators at Shoreham.
Proposed corrective action included weld repair and an inspection of
similar units.
L
- _.
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36
TABLE 1
CONSTRUCTION DEFICIENCY REPORTS
Shoreham Nuclear Power Station
(March 1, 1984 - February 28,1985)
CDR No. Deficiency Cause Code
85-00-01 Emergency Diesel Generator Design / Fabrication Error
Turbocharger Failure
84-00-02 Corrosion of Emergency Design / Fabrication Error
Service Water Strainers
84-00-03 Motor Control Center Room Design / Fabrication Error
Duct Penetration Not Sealed
. - - - ._ . . . .- - . . - - _ _
i
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.. 1
37
4
TABLE 2 ~
LICENSEE EVENT REPORTS BY FUNCTIONAL AREA
Shoreham Nuclear Power Station
(Ma'rch 1,1984 - February 28,1985)
Area Number /Cause Code Total
4.1 Construction Activities -
4.2 Engineering Design 0
'4 . 3 Pre-op and Startup Testing 2/A, 1/B 3
14 . 4 Maintenance and Surveillance 0
4.5. Plant Operations. 1/A 1
4.6 Radiological Controls 0
4.7 Fire Protection and Housekeeping 2/A, 1/D 3
4.8 Emergency Preparedness 0
- - 4.9 ' Security and Safeguards 1/X 1
4.10 Licensing -
Total 8
'
Cause Codes:
A - Personnel-Error
B - Design, Manufacturing, Construction or Installation Error
C - External Cause
'
D - Defective Procedure
E - Component Failure
X - Other
4
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v r- e,--r- y
-f
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38
TABLE 3
_
ENFORCEMENT SUMMARY
Shoreham Nuclear Power Station
(March 1,1984 - February 28,1985)
A. Number and Severity Level of Violations and Deviations
Severity Level Number
Deviations 9
B. Violation vs. Functional Area
Severity Level
Functional Area IV V Deviation
1. Construction Activities
2. Engineering and Design
3. Pre-operational and Startup Testing 1
4. Maintenance and. Surveillance 1 1 1
5. Plant Operations 2
6. Radiological Controls 1
7. Fire Protection / Housekeeping 7
9. Security and Safeguards 1 1
10. Licensing
Totals 2 5 9
..
"
Table 3 (Cont'd.) 39
C. Violation Details
Report Number / Severity Level /
Inspection Dates Functional Area Subject
84-31 Deviation / Certain test conditions and
7/23-26/84 Startup acceptance criteria in HPCI and
RCIC startup tests do not conform
to FSAR descriptions.
84-46 Deviation / Improper spacing of fire detectors
12/3-7/84 Fire Protection in Reactor Building.
Deviation / Fire doors degraded because of
Fire Protection security modifications.
Deviation / Improper routing of fire pump
Fire Protection cabl.es in electric fire pump
room.
Deviation / No fire damper in duct between
Fire Protection HVAC and Chiller rooms.
Deviation / Inadequate carbon dioxide density
Fire Protection in Battery Room and cable tunnel.
Deviation / Fire detectors in computer room
Fire Protection located above suspended ceiling.
Deviation / Emergency lighting not available
Fire Protection in all areas.
84-50 Level V/ Improperly approved Operations
12/15/84-1/31/85 Plant Operations Administrative Directives in use
in the control room.
Level V/ Twenty-three LDR dispositions not
Plant Operations approved by QA within required
time period.
85-04 Level V/ Failure to establish all PASS
2/11-15/85 (proposed) program elements consistent with
Radiological low power license requirements.
Controls
85-05 Level IV/ Inaccurate inventory of standby
1/21/84-1/25/85 Security lock cores.
Level V/ Inadequate search of a vehicle
Security entering the protected area.
---
- . - .. - - - . - - --. .. ..- . .- . --. .
4
_
i
,. .-
Table 3 (Cont'd.) 40
a
f
C. Violation Details (Cont'd.)
v l
Report Number / Severity Level /
Inspection Dates Functional Area Subject
l
85-08- Deviation / QC inspectors lacked proper eye
. 1/28/85-2/1/85 Surveillance test certification,
l Level IV/ Failure to fully establish proce-
1
Surveillance dures for the Leakage Reduction
i Control Program in accordance
j with Technical Specifications.
1
85-12 Level V/ Failure to meet procedural
- 2/19-22/85 Maintenance requirements for scheduling of
1 I&C preventative maintenance.
i
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5
,
,
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!
4
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4
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_
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41
TABLE 4
INSPECTION ACTIVITIES
Shoreham Nuclear Power Station
(March 1,1984 - February 28, 1985)
Inspectors /
Report No. Hours Areas Inspected
84-07 Specialist / Pre-operational Procedure and Test Results
56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> Review and TDI diesel engine repairs.
84-08 Specialist / Radiation Environmental and Meteorological
34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> Monitoring Programs.
84-09 Specialist / TDI Diesel Generator Test Recovery Program.
28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />
84-10 Four Residents / Resolution of eight previous open items, 11
435 hours0.00503 days <br />0.121 hours <br />7.19246e-4 weeks <br />1.655175e-4 months <br /> NUREG-0737 items, IE Bulletin 79-08 and
Circular 79-24; Review of April 14, 1984
Loss of Power,_TDI Diesel Overhaul, and
Potential for Maintenance-Induced Reactor
Building Flooding.
84-11 Specialist / TDI Diesel Generator Test Recovery Qualifi-
88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> cation and Revalidation Program.
84-13 Three Specialists / Chemistry Program and Effluents Radiation
84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> Monitoring.
84-14 11 Specialists / Resolution of 57 previous Open Inspection
(Team) Items; Review of Operational Staffing and
440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> Plant Operating Procedures.
84-16 Specialist / Pre-operational Test Procedure Review and
61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br /> Results Evaluation; Integrated Electrical
Test Witness.
84-17 Specialist / Review of Radiological Outstanding Items;
14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> IE Bulletin 80-10; IE Circulars 77-14,
80-14, and 81-09; Control Room and RBSVS
HVAC Testing.
84-18 Two Specilists/ Resolution of 14 previous open inspection
317 hours0.00367 days <br />0.0881 hours <br />5.241402e-4 weeks <br />1.206185e-4 months <br /> items, observation of TDI diesel testing,
and follow-up of Radwaste Building flooding.
84-19 Two Specialists / Security Program Implementation.
68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br />
.
r
..
Table 4 (Cont'd.) 42
Inspectors /
Report No. Hours Areas Inspected
84-20 Specialist / Startup Test Program Administrative Controls
39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> and Personnel Training; IE Bulletin 80-17,
CRD-SDV Modifications.
84-21 Specialist / Follow-up of Outstanding Items concerning
30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> Radiography; IE Bulletins 80-08 and 13,
82-01 and 03, and 83-02.
84-22 Two Specialists / Fuel Load and Initial Startup Test Program
58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> Planning.
84-23 Three Residents / Colt Diesel Project, Resolution of Open
213 hours0.00247 days <br />0.0592 hours <br />3.521825e-4 weeks <br />8.10465e-5 months <br /> Items, IE Bulletin 80-06 (ESF Reset),
Allegation on BISCO Seals, and NUREG-0737
Item II.B.4 (Training for Mitigating Core
Damage), and Follow-up on Security Incident.
84-24 Specialist / Construction of Colt Emergency Diesel
31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> Generator Building - Civil / Structural
Activities and Settlement Monitoring.
84-25 Specialist / Outstanding Items, Circulars, Bulletins.
20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />
84-26 Two-Specialists / Evaluation of Pre-operational Test
46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> Exceptions; NUREG-0737 Item I.D.2 - SPDS;
Witness of Backup Emergency Electrical Power
(EMDs and Gas Turbine) Testing.
84-27 Three Specialists / Fuel Load and Initial Startup Test Program
89 hours0.00103 days <br />0.0247 hours <br />1.471561e-4 weeks <br />3.38645e-5 months <br /> Procedures; Bulletin and CDR Follow-up.
84-29 Two Residents / Routine Resident Inspection of Open Items,
281 hours0.00325 days <br />0.0781 hours <br />4.646164e-4 weeks <br />1.069205e-4 months <br /> Allegations, TDI Engine and Integrated
Electrical Testing.
84-30 Specialist / TDI Diesel Outstanding Items.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
84-31 Specialist Startup Test Procedure Review.
31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />
84-32 Two Residents / Resolution of Open Items, Plant Modification
235 hours0.00272 days <br />0.0653 hours <br />3.885582e-4 weeks <br />8.94175e-5 months <br /> Controls, Equipment Trending, Colt Building
Construction and EMD Testing.
__
_
'
..
Table 4 (Cont'd.) 43
Inspectors /
Report No. Hours Areas Inspected
- 84-33 Three Specialists / NUREG-0737 Items II.E.4.1 and 2, Dedicated
63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> Hydrogen Penetrations and Isolation Valve
Dependability.
84-34 Specialist / Security Program Implementation and Review
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. of Open Items.
84-35 Specialist / Outstanding Items and Related Electrical
35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> Discipline Bulletins; Colt Diesel Building
Construction.
84-36 Four Specialists / Colt Diesel Building Construction; HVAC
128 hours0.00148 days <br />0.0356 hours <br />2.116402e-4 weeks <br />4.8704e-5 months <br /> Electrical and Vendor Installation.
84-37 Specialist / Completion of the Pre-operational Test
26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> Program.
84-38 Three Specialists / Fire Protection / Prevention Program Admini-
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> stration, Organization and Controls.
84-39 Resident / Review of previous Open Items; TDI Diesel
120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> Testing; Equipment Storage; LPCI MG-Set
Field Inspection; Administration of Security
Guard Examinations.
84-41 Specialist / Settlement monitoring of st-uctures; Ccit
1
23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> Diesel Program QC Documentation.
84-42 Specialist / Status of, and training for, Fuel Load and
21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> Startup Test Program.
84-43 Specialist / Radiological Controls Program Organization
19_ hours and Staffing; Related Outstanding Items,
Bulletins and Circulars, and IE Notice
84-59.
84-44 Specialist / Colt Diesel Piping and Supports; IE
23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> Bulletins 83-06 and 07 (Tubeline and Ray
Miller).
84-45 Resident / Resolution of Seven Previous Outstanding
70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> Items and CDR 84-02 (Service Water Strainer
Corrosion); Bahnson HVAC Weld Deficiencies;
Follow-up of Drywell Floor Spills - Valve
Lineup Controls and Fuel Support Piece
-
Misalignment; Witness of TDI Diesel Fatigue
Cycle Testing and Handling of Neutron
Sources; NRR Operational Readiness Inspec-
tion Tour (November 15 and 16).
- - __. - . _ - _ .- . ..
<
_
,,*
Table 4 (Cont'd.) 44
Inspectors /
Report No. Hours Areas Inspected
84-46 Four Specialists / Fire Protection and Safe Shutdown
(Team) 236 hours0.00273 days <br />0.0656 hours <br />3.902116e-4 weeks <br />8.9798e-5 months <br /> Capability.
84-47 Two Specialists / Fuel Load and Initial Startup Test Proce-
38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> dures; Drywell Vacuum Breaker Surveillance.
-84-48 Two Specialists / Review of pre-fuel load activities and
38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> witness of neutron source loading; proce-
dures for Tech Spec Surveillances during
refueling; IE Notice 84-76, Loss of All AC
Power, applicability to STP-31 at Shoreham.
84-49 Three Specialists / Witness of initial fuel loading and control
169 hours0.00196 days <br />0.0469 hours <br />2.794312e-4 weeks <br />6.43045e-5 months <br /> rod friction and shutdown margin testing,
including independent verification of SRM
data, rod timing and accumulator p*essures;
RBSVS isolation valve stroke testing.
84-50 Resident / Control of Plant Operations; ISEG Activi-
199 hours0.0023 days <br />0.0553 hours <br />3.290344e-4 weeks <br />7.57195e-5 months <br /> ties; Shift Turnover and Log Reviews; QA
Deficiency Follow-up.84-145 Examiner / Shift Advisor Program.
10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />
-85-01 Two Specialists / Witness of fuel load activities, including
108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> final core verification of fuel bundle
location; Re-installation of vessel inter-
nals and head; IRM/SRM Surveillance Testing;
GETARS Calibrations.
85-02 Specialist / HVAC installation and Bahnson equipment
32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> deficiencies (IE Notice 84-30).
85-04 Six Specialists / NUREG-0737 Items II.B.3, PASS; II.F.1.1,
(Team) 208 hours0.00241 days <br />0.0578 hours <br />3.439153e-4 weeks <br />7.9144e-5 months <br /> Noble Gas Effluent Monitoring; II.F.1.2,
Plant Effluent Sampling; II.F.1.3, Contain-
ment High Range Monitors; and III. D.3.3,
In plant Iodine Monitoring.
85-05 Two Specialists / Security.
75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />
85-06 Specialist / Follow-up of four Emergency Preparedness l
108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> Appraisal Previous Open Items. l
_
Table 4 (Cont'd.) 45
Inspectors /
Report No. Hours Areas Inspected
85-07 Three Examiners / Operator Licensing Exams.
144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />
85-08 Specialist / NUREG-0737 Item III.D.1.1, Leakage Reduction
38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> Program, Administrative and Surveillance
Procedures.
85-09 Three Specialists / Witness and review of Initial Criticality
262 hours0.00303 days <br />0.0728 hours <br />4.332011e-4 weeks <br />9.9691e-5 months <br /> and Startup Test Results; Surveillance Test
Program Review.
85-10 Project Engineer / Eight allegations made by former QC
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inspector.
85-11 Resident / QA Department Staffing and Personnel Quali-
188 hours0.00218 days <br />0.0522 hours <br />3.108466e-4 weeks <br />7.1534e-5 months <br /> fications; NED Administrative Controls;
Follow-up of Open Items
85-12- Two Specialists / I&C Preventative and Corrective Maintenance
47 hours5.439815e-4 days <br />0.0131 hours <br />7.771164e-5 weeks <br />1.78835e-5 months <br /> Programs.
85-19 Three Examiners / Operator Requalification Exams.
120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />
l
l
r
v 46
TABLE 5
l
INSPECTION HOURS SUMMARY l
Shoreham Nuclear Power Station
(March 1,1984 - February 28,1985)
Functional Area Hours % of Time
1. Construction Activities 872 17
2. Engineering and Design 465 9
3. Pre-operational and Startup Testing 1,664 32
4. Maintenance and Surveillance 328 6
5. Plant Operations 742 14
6. Radiological Controls 379 7
7. Fire Protection / Housekeeping 372 7
8 Emergency Preparedness 132 3
9. Security and Safeguards 247 5
10. Licensing * *
Total 5,201** 100
- Hours expended in facility licensing activities and Operator Licensing acti-
vities are not included with direct inspection effort statistics.
- Excluding a total of 274 hours0.00317 days <br />0.0761 hours <br />4.530423e-4 weeks <br />1.04257e-4 months <br /> expended on Operator Licensing examinations
during the assessment period.
. . .