ML20214R568

Shoreham Nuclear Power Station Initial OL Readiness Assessment

ML20214R568
Person / Time
Site:	05000000, Shoreham
Issue date:	12/31/1984
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213F044	List: ML20213F042 ML20214R426 ML20214R460 ML20214R478 ML20214R485 ML20214R491 ML20214R529 ML20214R545 ML20214R564 ML20214R568
References
FOIA-87-271 NUDOCS 8706080200
Download: ML20214R568 (49)

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I SHOREHAM NUCLEAR POWER STATION INITIAL OPERATING LICENSE

, READINESS ASSESSMENT

] DECEMBER 1984 4

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Prepared by UNITED STATES NUCLEAR REGULATORY COMMISSION-l.

REGION I

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4 CD7060802OO B70602 'O PDR FOIA '

ORABER87-271 PDR  ;

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0 Shoreham Nuclear Power Station Initial Operating License Readiness Assessment i

1.0 Introduction 2.0 Summary of SALP Reports 3.0 Region I Inspection Program 3.1 Construction and Preoperational Inspection Programs i

3.2 Special Team Inspection 3.3 Open Inspection Items 4.0 Quality Assurance 5.0 Enforcement History 6.0 Operator Qualifications 7.0 Technical Specifications l 8.0 Allegations t

9.0 OI Investigations 10.0 Regional Staff Concerns 11.0 Utility and Third Party Engineering Evaluations

12.0 Conclusions J

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1.0 INTRODUCTION

This report provides the basis for the NRC Region I finding, per 50.57(a)(1), that the Shoreham Nuclear Power Station has been constructed substantially in accord with Construction Permit CPPR-95, the Shoreham Final Safety Analysis Report (FSAR) and NRC regulations,and that Long Island Lighting Company is ready to assume the safe low power operation of the facility.

Shoreham is a 2436 MWt General. Electric BWR/4 Boiling Water Reactor, housed in a Mark II concrete containment. -The principal design features are similar to the Zimmer and LaSalle facilities. The site is situated on the north shore of Long Island in the town of Brookhaven, Suffolk County, New York. The Shoreham Nuclear Power Station is wholly owned by the Long Island Lighting Company (LILCO), and is LILCO's first nuclear facility.

NRC Region I commenced inspections at Shoreham in 1973, at the time of 5:

issuance of the Construction Permit, and has issued in excess of 270 reports since that time. As part of many of those inspections, aspects of construction quality have been evaluated. Team inspections have also specifically addressed LILCO's QA Programs. Inspections since February 1976 have included the review of preoperational test procedures, conduct of testing, resolution and approval of test exceptions and results, and turnover of systems in preparation for facility operation, i

Through its inspections and interactions with the applicant, the regional staff has accumulated sufficient information to assess the level of per-formance of LILCO and its major contractors and subcontractors. The Systematic Assessment of Licensee performance Program summarized in Sec-tion 2.0 of this report presents Region I's assessment of LILCO's perform-i ance since 1980. Section 3.0 describes the Region I inspection program including construction and preoperational inspections, special inspections,

' and open inspection items. Section 4.0 describes the quality assurance program at Shoreham. >

Section 5.0 discusses the Shoreham enforcement his-

' tory. Section 6.0 discusses the qualifications of the Shoreham operators.

Section 7.0 discusses the inspections and reviews that have been performed to ensure that the Shoreham Technical Specifications are adequate to sup-port facility operations and reflect the as-built design of the plant.

Sections 8.0 and 9.0 discuss the resolution of allegations related to i

Shoreham and investigations performed by the Office of Investigations, respectively. The Region I staff was requested on three separate occa-sions to identify any concerns that might exist relative to the licensing of Shoreham. The results of those requests are presented in Section 10.0.

Section 11.0 describes utility and third party engineering evaluations that were performed for the Shoreham facility. These evaluations provide i

additional assurance that Shoreham has been constructed to a high level of 3

quality. Finally, Section 12.0 presents the summary and conclusions of the staff's assessment of Shoreham's readiness for operation.

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SUMMARY

OF SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE The performance of LILCO has been assessed four times since the ince of the Systematic Assessment of Licensee Performance (SALP) program.ption The major findings made during the four assessment periods are summarized below.

March 1,1980 - February 28, 1981 LILCO management and overall LILCO performance during this period was rated average. Of 16 specific functional areas assessed,14 were consi-dered average and 2 were considered below average. The two below average areas were (1) Engineering and Design and (2) Reporting. Engineering and Design was rated below average during the period because of discrepa.9cies between the Final Safety Analysis Report (FSAR) and as built systems. A special program had to be implemented by LILCO to identify and correct discrepancies between the FSAR and the plant design and construction.

Reporting was rated less than average due to delays in evaluation of deficiencies for reportability per 10 CFR 50.55e. Inadequacies in licen-see responsiveness were also noted in several areas including followup on QA audit findings, issuance of a consolidated QA manual, and timeliness of responses to NRC bulletins and circulars and other NRC findings. The below average performance in the areas noted above was attributed to inade-quate maragement controls.

March 1, 1981 - February 28, 1982 Overall licensee performance during this period was again considered satis-factory. Of 12 functional areas assessed 10 were rated as Category 2, one was rated as Category 1 and one was ra,ted as Category 3. " Piping Systems and Supports" was the area rated as Category 1. This rating was based on the observation of prompt actions taken by the licensee to cor-rect QA deficiencies identified by their QA audit program.

The area of Engineering and Design was still considered below average as noted in the previous SALP period and was assigned a Category 3 rating.

This rating was a result of the licensee's slow response in resolving this issue and continued discrepancies between the as-built plant and the FSAR.

Also during February of 1982, a special "as-built" team inspection was performed and by Region I personnel to observe as-built conformance to design FSAR requirements.

Following this inspection and a meeting with Region I staff, the licensee instituted a new program, the Shoreham Plant Configuration Review Program, to correct discrepancies between the as-built condition of the plant and the FSAR and design documents, Other observations made during the period included a lack of responsiveness to NRC input regarding closure of open preoperational test items and lack of aggressiveness tems.

in correcting problems in instrumentation and control sys-

3 February 1, 1982 - January 31, 1983 LILCO overall performance during this period was again considered satisfac-tory. Of the 13 areas rated during this period, 12 were considered Cate-gory 2 while one area, housekeeping, was considered Category 3.

With regard to the poor rating in Engineering and Design during the pre-vious periods, the Shoreham Plant Configuration Review Program was aggres-sively implemented by the licensee during this period. Discrepancies between the FSAR and the as built plant were identified and satisfactorily dispositioned by either changes to the FSAR or actual hardware modifica-tions.

A special Readiness Assessment Team (RAT) inspection was conducted during January 10-15, 1983 to determine the operational readiness of Shoreham.

The inspection, conducted by eight regional inspectors concentrated on the areas of construction, preoperational testing, and plant operational staffing. The conclusion based on the inspection was that the plant would not be ready for fuel load for a period of at least six months from the time of the inspection. It was also concluded that the operating staff was qualified and would be ready in time for fuel load.

Poor housekeeping was identified as a major concern during the RAT inspec-tion. The NRC and the licensee agreed upon necessary actions to correct this problem and a Confirmatory Action Letter was issued on January 19, 1983. Subsequent to the issuance of that letter conditions began to improve. (This issue was officially closed in October 1984 after contin-ued monitoring by Region I to ensure continuing acceptable performance.)

There was also a concern during this period regarding the applicant's attitude in the preoperational testing and operational areas. The con-cerns involved the applicant's: (1) reluctance to address issues raised that did not have a specific re detail, and; (3) in some cases,gulatory requirement; inadequate (2) inattention technical followup t.) NRC to find-ings. These problems were attributed to LILCO management's attitude, and a somewhat fragmented organizational structure.

February 1, 1983 - February 29. 1984 During this SALP period, physical construction and preoperational testing of the plant were completed, except for the emergency diesel generators and ventilation system flow testing. Fourteen functional areas were eval-uated. Eight areas were rated Category 1, five areas were rated Category 2, and one area, Emergency Diesel Generators, was rated Category 3. The area of Emergency Diesel Generators received a Category 3 rating as a result of a crankshaft failure and other problems with the Transamerica Delaval, Incorporated (TOI) diesel engines. .The diesel generator issue is being aggressively pursued by LILCO and closely monitored by NRC.

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l A marked improvement in licensee performance and responsiveness was

{ observed during this period. This improvement was attributed to a manage-ment reorganization that took place in 1983 which included relocation of j corporate staff, including the VP-Nuclear, from Hicksville, New York to

the Shoreham plant site. This relocation demonstrated management commit-ment and resulted in a better integrated and more effective organization, i The improved performance resulted in a substantial increase in the number i of Category I ratings (one Category 1 rating had been received prior to  ;

this SALP period). Subsequent to the reor '

t personnel to the plant site, the licensee'ganization s responsesand relocation were found to be of l

timely and effective in addressing NRC requests.

! The SALP report for this period also included an assessment of.the plant's  !

readiness for operation. With the exception of a number of open items -  :

primarily diesel generator and ventilation tests, emergency planning, and '

licensed operator experience - the plant and personnel were evaluated as i qualified and prepared for plant operation, t

1 Table 2.1 summarizes the SALP ratings for the four assessment periods. >

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5 3.0 REGION I INSPECTION PROGRAM 3.1 Construction and Preoperational Inspection programs Region I inspections of construction and preoperational activities i

at Shoreham have been conducted in accordaoce with the program estab-Itshed by the Office of Inspection and Enforcement.

i Four resident inspectors have been assigned to the Shoreham facility at various times since the inception of the NRC's resident program.

Since construction was more than 80?? complete at the time of the ini-tial senior resident inspector's assignment at Shoreham in October 1979, the resident efforts have been focused primarily upon monitoring conduct of the preoparational testing progran. Construction inspec-tions were carried out by region-based inspectors with expertise in the areas of construction.

The construction inspection program at Shoreham is complete, with the exception of the new Colt diesel generator building. To date, 6932 hours0.0802 days <br />1.926 hours <br />0.0115 weeks <br />0.00264 months <br /> of inspection have been performed in the 2510/2512 construction program areas. Currently, the only construction effort still on going is for the Colt diesel generator building. Its construction is approximately 80*4 complete and it has received, to date, a total of 248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br /> of construction inspection.

The preoperational inspection program is also complete. To date.

{ 14,378 hours0.00438 days <br />0.105 hours <br />6.25e-4 weeks <br />1.43829e-4 months <br /> have been performed in the 2513 preoperational test program areas. Region I's preoperational test inspection program was started in February 1976 and completed in October 1984, all systems tested were found to be satisfactory for service.

As of October 1984, more than 22,000 inspection hours have been ex-pended at Shoreham. As a comparison, 15,000 inspection hours had been performed at Limerick Unit 1, and about 18,000 inspection hours had been performed at Susquehanna Unit 1 at a similar stage of com-pletion. Of the 22,000 inspection hours at Shoreham, 6900 hours0.0799 days <br />1.917 hours <br />0.0114 weeks <br />0.00263 months <br /> were devoted to construction. For comparison, similar numbers at Hope Creek, Limerick 1, and Susquehanna 1 were 7600 hours0.088 days <br />2.111 hours <br />0.0126 weeks <br />0.00289 months <br />, 7800 hours0.0903 days <br />2.167 hours <br />0.0129 weeks <br />0.00297 months <br />, and 7100 hours0.0822 days <br />1.972 hours <br />0.0117 weeks <br />0.0027 months <br />, respectively.

Table 3.1 summarizes annual inspection hours, by year, since 1973.

Table 3.2 is a detailed breakdown by program area of individual inspections from 1982-1984, when approximately 66% of the overall inspection hours for $horeham were completed. Findings and comments are also summarized.

reported have been satisfactor-Allconstructiondeficiencies(COR's)sremaintoberesolv 11y currected by LILCO. No open CDR November 28, 1984. A total of 68 CORs were reported at Shoreham.

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This is comparatively low with respect to other similar construction pro l

CDRgrams such as Limerick (131 CDR's) and Susquehanna (138 COR's).

s were trended for causal links in the SALP process; no adverse 1

programmatic trends were noted.

3.2 Special Inspections Desion. Procurement and Construction OA (Report 76-06)

A special inspection was conducted during the period of May 24-27, 1976 to ascertain whether the establishment and implementation of the  ;

Quality Assurance Program in selected areas of design, procurement, and construction was consistent with the status of the project and the Quality Assurance Program described in the FSAR. The inspection -

was conducted by a team of five Region ! inspectors. One infraction and one deficiency identified during the inspection were corrected by the applicant and subsequent NRC inspections determined that full compliance was achieved and the items were closed.

Special 1982 As-Built Team Inspection (Report 82-04)

A special inspection was conducted during the period of February  ;

8-26, 1982 to compare the completed construction and physical install-i ation at Shoreham with regulatory committments and engineering and design documents. The Residual Heat Removal (RHR) system and its supporting subsystems were selected for inspection. Also, a sampling 2

of construction and management control activities such as purchase documentation, material control, quality control inspections, repair and rework, engineering and design changes, and maintenance of com-plated installation were inspected. The inspection was conducted by i

four Region I inspectors and the Shoreham resident inspector.

The inspection determined that the RHR system and its support systems were built as described by drawings and specifications, with only minor discrepancies. These discrepancies and other open items identi-fled during the inspection were satisfactorily resolved by applicant's corrective actions and NRC review.s 0 site Emergency Preparedness Appraisal (Report 82-18) 2 A special inspection was conducted during the period of August 23 to September 2,1982 to verify an adequate state of onsite emergency preparedness. Emergency preparedness areas inspected were: (1) i administration of the prog5)(ram, facilities and equipment, (2) organization, procedures (3) the for implementing training, Emer- (4) gency Plan, (6) coordination with of f-site agencies, and (7) walk-throughs of duties. The inspection was performed by seven Region !  !'

specialist inspectors.

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7 The inspection report identified 21 significant deficiencies which needed to be corrected to properly detect, classify, manage, and mitigate an emergency. Eleven items were identified by the NRC team to be considered by LILCO for improvement. The Itcensee responded to all thirty-two items, and subsequent staff followup resolved all but three of these items whose resolution are dependent on the results of litigation of emergency preparedness by the ASLB, Weld Quality Control - NDE Van (Report 82-19)

A special inspection was conducted during the period of July 19 through August 13, 1982 to determine the adequacy of the licensee's welding quality control program. Shoreham weld quality records were '

reviewed during July 19-30 by QC inspectors at the Region I office for completeness, as well as compliance to FSAR committments, appli-cable codes, standards, and specifications. From August 2-13, an independent verification of actual welds was conducted onsite using the Region I Mobile NDE laboratory. In addition to the required examinations, pipe wall thickness measurements, hardness tests, and material analyses were performed. A random sampling was made to com-pare a representative sample of piping systems, components, pipe size, materials, and shop and field welds to AWS and ASME Class 1, 2 and 3 codes. The items selected had been previously accepted by LILCO based on vendor shop and onsite NDE records and process sheets f rom their contractors. The inspection determined the quality of welding to be acceptable, and all areas examined were within accept-able limits or requirements.

i Operational Quality Assurance (Report 82-34)

A special inspection was conducted during November 29 through Decem-ber 15, 1982 to assess LILCO's preparations for implementation of the Quality Assurance Program for Shoreham operations. The inspection ascertained the readiness of the applicant's programs for operation of the plant. Procedures were reviewed to verify that they were con-sistent with commitments, and that specific activities were clearly detailed. No violations were identified in the areas inspected.

However, specific unresolved items were identified which subsequently received appropriate corrective action. The Operational QA Program for Shoreham was found to be acceptable.

Operational Readinesf_ Assessment Report (83-02) i A special inspection was conducted during the period January 10-15, 1983 to determine the status of operational readiness of Shoreham.

The inspection concentrated in the areas of construction, preopera-tional testing, and plant operational staffing. The inspection was

! conducted by eight regional and/or resident inspectors.

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Four violations were identified during the inspection. Additional items that required resolution prior to a recommendation by Region I relative to a decision on an operating license were also identified.

All violations, open items and unresolved items associated with this

' inspection were adequately addressed by LILCO and subsequently closed by Region I. The team concluded that the plant would not be ready for fuel load for a period of at least six months from the time of

', the inspection. It was also concluded that the plant operating staff personnel were qualified and conscientious, and would be ready to perform fuel load. Interviews with licensee management demonstrated

! that, although collectively there was limited BWR nuclear operations experience, qualified personnel with the requisite experience would be onsite for fuel load and plant operation, in accordance with Shoreham Safety Evaluation Report commitments.

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9 3.3 Open Inspection Items There have been a typically large number of open items generated dur-ing the 11 years of inspection devoted to Shoreham. An esti-mated 200-300 items have existed, at any given time, during that period. LILCO has exhibited an aggressive and thorough approach to resolution of these concerns with Region I and there are no open items remaining from Region I inspections which would preclude issu-ance of a low power license for Shoreham as of November 28, 1984.

However, there are five open inspection items which Region I has recommended to NRR for consideration as license conditions. These items were the subject of separate correspondence dated December 4, 1984.

There are approximately 50 other open items, currently unresolved but being tracked by Region I inspections and addressed by LILCO. In-cluded in that number are items associated with TDI diesels and emergency preparedness. Both of tnose issues are still under litiga-tion by an ASLB, and neither is required prior to 5% power. However, there are no remaining 10 CFR Part 50.55e construction deficiencies on the Shoreham docket, nor are there any outstanding responses to previous violations still pending from LILCO. All applicable IE Bulletins or Circulars have been satisfactorily addressed by LILCO.

The remaining TMI NUREG-0737 items, which still require implementa-tion inspection, number less than ten and involve post-5% power activities such as emergency preparedness and post-accident monitor-ing,

10 4.0 QUALITY ASSURANCE The quality of the design, construction and operation of Shoreham is assured by LILCO Quality Assurance Programs as required by Appendix B to 10 CFR Part 50, the NRC licensing review and inspection process, and third party inspections.

Organization The construction and preoperational testing Quality Assurance Program at Shoreham was administered and executed for LILC0 by Stone and Webster Engineering Corporation (SWEC), the project architect engineer, and General Electric Company, the nuclear steam supply system vendor. LILC0 control over the program was accomplished through audit and surveillance programs conducted by the LILCO Quality Assurance Safety and Compliance (QASC) Organization.

Audits The statistics of Tables 4.1 through 4.8 were provided by LILCO. The Quality Assurance Division (QAD), Quality Control Division (QCD), and Quality Systems Division (QSD) (or their predecessors) have performed audits of the SWEC quality assurance program to ensure its effectiveness.

Tables 4.1 through 4.3 summarize in-excess of 2000 audits conducted during the past 11 years by QAD, QCD, and QSD, including the number of findings and observations. Observations are those items identif'ed during the audits as open items, requiring follow up review to assure aceptable closure. Findings art. those items identified during +be audits as viola-tions of criteria found in design or installation documents. All of the audit findings and open items from audits, performed during the period from 1973 to 1983, have been closed by the LILCO Quality Systems Division.

Over 200 vendor audits were also performed by LILCO, or by SWEC for LILCO, as summarized on Table 4.4.

In addition to their own audits, LILCO contracted Courter and Company as an independent on-site Quality Assurance organization beginning in 1978.

This was at the time that Courter received an ASME N Stamp. Table 4.5 summarizes by year the 217 audits conducted by Courter and Company, and the 318 findings and observations which resulted.

The total number of audits performed, findings and observations made, and the existence of Courter as a third party audit organization are all indicative of an active LILCO QA program over the past ten years, which found problems and pursued corrective actions through to closure.

Stop Work Authority The following LILCO contractors and organizations within LILCO have had the authority to issue stop work orders (SWO) during the Shoreham project:

11 LILCO Quality Assurance Stone and Webster Engineering Company (SWEC)

Courter and Company (Courter)

Reactor Controls Incorporated (RCI)

Nuclear Installation Services Company (NISCO)

Pittsburg-DesMoines Steel Company (PDM) __ .

Keasby/ Bisco Table 4.6 lists the two SW0s that were issued (both in 1973) during the Shoreham project. Contractors at Shoreham were aggressive in resolving quality problems in a timely manner thereby minimizing the number of SW0s.

To Region I's knowledge, the relatively small number of SW0s issued did not result in any quality problems.

Nonconformance Reports Table 4.7 presents by year the 517 nonconformance reports issued by LILCO QAD from 1973 through 1984. LILCO Field Quality Assurance has issued timely corrective (and preventative) action for problems identified by the QA program. Findings of these FQA programs were considered and reviewed extensively by the ASLB.

Table 4.8 summarizes by year the 8748 nonconformances which were identi-fied by the base-level construction QC organizations: SWEC and Courter and Co. SWEC nonconformance findings were documented by Nonconformance and Disposition (N&D) Reports and Courter findings were documented by Noncon-formance Reports (NR). All of these findings have been corrected and re-solved with the exception of 4, which do not impact fuel load since they are associated with the COLT diesel report.

NRC's Inspection Program Section 3.0 of this assessment describes the NRC inspection program at Shoreham. Every inspection conducted by NRC regional-based and resident inspectors has, in effect, observed and verified the quality of the con-struction, testing, and operations at Shoreham. Many of the over 260 total inspections conducted by Region I at Shoreham to date, have focused, in part, on the applicant's QA program. Two special Region I QA inspec-tions were discussed in Section 3.2 (76-06 and 82-34). The QA program was found to be acceptable in both of these inspections.

In addition to routine inspections, Region I has performed inspections in response to allegations regarding the quality of construction at Shoreham, as as discussed in Section 7.0. None of the allegations inspected have resulted in adverse findings with regard to the QA program at Shoreham,  ;

and there are currently no outstanding allegations. t ASLB Hearings Region I personnel participated in the Shoreham ASLB hearings, which considered Quality Assurance. Four contentions regarding QA at Shoreham were admitted, and collectively heard by the Board. The contentions were:

.(1) a pattern of-QA/QC breakdowns existed at Shoreham, as illustrated by

12 NRC cited violations; (2) the QA program for operations did not comply with regulations; (3) the NRC prcgram has not adequately verified the implementation of LILCO's QA program; and, (4) there had been inadequate review and physical inspection of Shoreham. The Region I Staff testimony showed that the cited violations were indicative of problems in individual areas only and were not indicative of a general breakdown in QA. Regard-ing the compliance of the QA program wit,h NRC requirements, it was estab-lished that the FSAR committments did comply with the applicable require-monts and that proper implementation would be verified through Region I inspections. The hearing board found, based on the evidence presented, that the contentions regarding the Shoreham QA program were unfounded.

This was documented in the Board's Partial Initial decision issued in September 1983. The Board's findings, concluded that the LILCO and NRC QA Programs were effective and adequate.

Conclusion In conclusion, based on the Region I staff inspections and ASLB findings the Construction QA program at Shoreham: (1) has met applicable require-ments; (2) has been effectively implemented to date; and (3) has provided reasonable assurance of the quality of construction and design of the Shoreham facility. Moreover, the LILCO operational QA Program is judged to be adequate to support safe facility operation.

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5.0 Enforcement History Notices of Violation have been issued for Shoreham, when appropriate, dur -

ing the construction and preoperational testing of the facility. Table 5.1 summarizes the history of enforcement actions applicable to Shoreham.

since 1981. As discussed in Section 4.0,-the Region I Staff prepared for the ASLB a review and trending of all violations prior to this time as part of.the contentions related to QA. Only one instance has resulted in a Civil Penalty. This Severity Level III violation involved the December 1982 performance of a diesel generator preoperational test. Corrective actions for this violation, specifically in the review and approval-of all preoperational' test results, were subsequently found to be acceptable.

The applicant has been responsive to the enforcement actions taken by the NRC, . including descriptions of their proposed actions to correct the non-conforming conditions and to prevent recurrence. Region I staff and man-agement have evaluated the required responses to ensure that the proposed corrective actions and their implementation were acceptable. Subsequent Region I inspections have confirmed these actions to be proper and timely. '

No outstanding enforcement actions currently exist which would preclude licensing and low power operation of Shoreham.

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- 6.0 Operator Qualifications ,

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There are currently 27 licensed senior reactor operators (SRO) and.14 licensed reactor operators (RO) on the SNPS staff. There are also 8 Shift

' Advisors on the SNPS staff. Figure 6.1 depicts the Shoreham Operations Staff organization, as of September 1984. NRC: operator < licensing exams

-were. first administered at SNPS in August and ' December 1982, 'and February -

1983. No licensing exams have been conducted at Shoreham since that time, although 12 RO and 7 SRO exams are scheduled in February.1985.

Annual requalification exams for the SNPS operators were co' nducted on three occasions -during November 1983 through January 1984. Since August 1983, an ongoing assessment of the Requalification Program at Shoreham has' 4

been conducted by region based specialists. This effort has included a review of the program and the .three annual requalification exams. conducted by the licensee. An onsite audit of the conduct of applicant-administered.

training, as well as observation of requalification simulator; training . l conducted at the. Limerick Training Center, have been performed by Region I  ;

for the SNPS operating crew. The Program is considered excellent, and has. '

several noteworthy features. First, it.has been in effect since-February 1982, even though it is not required until-three months after receipt of-j '

an operating license. Second, the Shoreham program includes simulator. ,

4 training on a semi-annual, rather than the usual annual frequency. Finally, ,

the non-licensed shift technical advisors-(STA) participate in the program. -

The NRR Division of Human Factors Safety Staff approved the Shoreham ,

Licensed Operator Requalification Program in September:1984. NRC Region I staff will conduct an NRC Requalification examination, including. written and oral exams, during the week of 11/26/84 A weakness identified in SNPS's Operations staff, was their lack of hot operational BWR experience. There.are currently no licensed operators at Shoreham with operating BWR experience.-Consequently, several steps were taken to compensate for this lack of experience.

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LILCO committed to have an experienced individual present,-as an advisor, on each shift. LILCO hired, or. has been loaned, eight individuals who J

have held (or presently hold) SR0 licenses, to fill. these shift ' advisor i:

(SA) positions. Region I conducted an evaluation of.the. training and 4

qualification of the SAs, including a review of the shift advisor training

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program and observation of facility-administered certification exams. The conclusions of this evaluation were that the SAs possessed an adequate i knowledge of the SNPS systems, but that they did not possess adequate '

familiarity with SNPS control room boards, indicators,-alarms, and refer-ence material to be certified. In response to this finding,;LILCO has i

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15 placed the SAs in a control room familiarization training program. The SAs will complete this training program in late 1984 or early 1985.

Region I will observe the conduct of the advisor's final oral certifica-tion examination, which will'be completed prior to 5% power, to ensure that the SAs are adecuately familiar with the specifics of the SNPS-control room. -

Other actions that LILCO has taken to compensate for the lack of operator experience include hiring an individual with operating experience for the position of Vice President - Nuclear and promoting the Operations Manager to the position of Plant Manager. These staffing changes satisfy commit-ments made by the applicant to place individuals with greater nuclear operating experience into their management organization.

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7.0 TECHNICAL SPECIFICATIONS Region I has performed a continuing and extensive review of the proposed E

(" Proof and Review Copy") Technical Specifications (TS) for Shoreham, -

since 1981.

i Review of the proposed TS was' performed by the Senior Resident Inspector and routinely documented in the 21 resident inspection reports issued during the period September 1981 through September 1983. These inspec-i tions compared individual system design and test documentation (surveil-lance procedures, FSAR, P&ID's and preoperational test results, etc)-

igainst the configuration of the as-built plant. Portions of the systems-were physl 4. tally verified, during walkdown inspections, to compare the installed equipment to the TS. Preoperational test results were reviewed to verifylthat systems and components had been tested and had performed as

' ' required by-the TS. The inspector's comments and findings were incorpor-ated by the licensee into the proposed TS. .Significant regional comments on the draft TS, including the resident's findings,'were provided by-memorandum dated August 30, 1983, to the NRR Standardization Branch.

4. The most recent SALP evaluation noted that a surveillance program has been initiated and in effect, prior to its being required, for all safety-related systems required for fuel load. Both resident inspectors have observed surveillances during the past year, and this area was rated Category 1 in the last SALP report. Surveillance test procedures have 4

been prepared and are being used by LILCO, such that.their performance demonstrates that the Operational staff can adequately fulfill TS require-i ments. Over 170 inspection hours during the last SALP period were devoted i to Region I's review of the surveillance test program. Inspection Report-

' 83-38 issued on February 7, 1984 discussed a comprehensive review of that I program. Previous inspections (82-34 and 83-29) have also assessed this program, including the use of a computer-based Surveillance Master List to schedule and track surveillances in accordance with appropriate procedures, i Those NRC inspections have found that:

testing is being performed by-qualified-personnel, test results are accurately recorded, compared with, and in accord-ance with TS requirements, systems are properly returned to service.

LILCO Operational QA (0QA) personnel have conducted audits of the surveill-ance program, and have found no significant problems. OQA has also review-ed surveillance records, and continues to observe tests on a sampling.

basis. Surveillance results are being verified by LILCO Compliance per -

sonnel. Region _I has found the program to be'well organized, planned and controlled. 1

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r , . - , ,

,,-r-m,,n- - ,----,--,,N-- - - , - - , ,

, - , , ~ , - - - , c- , , -

5 4 17 8.0 ALLEGATIONS Over 100 allegations have been received, inspected and found to be unsub-stantiated by our technical staff and management since 1980.

In March-April 1983, an list of approximately 40 allegations was received by NRC from an individual who had been employed as-steam fitter.at Shoreham from 1974 to 1977, and again in.1982. Hisconcernsencompassedthedesign,g,bC' construction, and testing of the Shoreham Station over a period of the ,

past ten years. The allegations were evaluated.by the Region I staff and management, and subsequently inspected during the period August-December, 1983. Based on the Region I Staff's investigation, none of .the allegations were found to be substantitated, nor did any involve violations of NRC .

1 regulations. '

Another set of approximately 26 allegations were received by NRC Region I during the period January-March 1983 from a private citizen. Subsequent phone contacts were made with the allegor and the allegor-was interviewed-by Region I's Office of Investigations (0I). Region I technical followup of these~ allegations was accomplished by Inspection 84-04 in February 1984, a report of which was issued on May 1,.1984; None of these allegations were substantitated and no safety concerns were found.

An inspection was conducted from December 1979-March 1980 by a team of. 9 inspectors to address thirty allegations of construction irregularities that were transmitted to the NRC via court testimony, personal interviews,.

magazine articles, and telephone calls. That investigation accounted for over 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of.onsite work and found none of the issues to be.substan-titated.

An inspection was conducted in October-December 1981'(approximately 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of onsite inspection) to investigate two cracked welds that..alle-gedly existed in a 20 inch diameter copper-nickel Service Water System '

pipe. The allegations were unsubstantitated.

An inspection was conducted by the resident inspector during October 1982, j to investigate corroded valves and fiberglass" piping that'were allegedly '

reinstalled without repair. None of these allegations were substantitated. .

. Other individual allegations have been received, both, prior to'and after 1

1980. These have been routinely inspected and closed in individual-in-

.spection reports during the course of Shoreham's_ construction'and pre-operational testing. There currently exist no allegations that impact on a licensing decision for Shoreham.

l

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. - - - - -- - - - - -- ~ -~'" :

18 9.0 OI INVESTIGATIONS The NRC's Office of Investigation (01) has no investigations underway which involve the low power licensing of Shoreham. However, 01 has opened an investigation concerning Transamerica OeLaval, Inc. (TOI), the manufac-turer of the original three Shoreham emergency diesel generators. The applicant is currently attempting to qualify the TDI emergency diesel generators for nuclear service, independent of the vendor. The need for qualified emergency diesel generators, prior to exceeding 5% power, is the subject of a separate licensing board.

4 Y

19 10.0 REGION I STAFF CONCERNS Letters were sent to all members of the Region I technical staff by the cognizant DPRP Branch Chief, on December 14, 1983,' March 29, 1984 and November 2, 1984. Each letter requested the staff to identify any out- "

standing technical concerns not already addressed by inspections or hear-ings. On January 3,1984, one letter of response (dated December 30, 1983) was received which re-iterated known problems with the TDI diesels and their associated test program. The concerns of that letter are being addressed in ongoing reviews of the LILCO diesel recovery program. This and other Region I input is under consideration by the NRC's Task Force evaluating the nuclear service diesel generators supplied by TDI, 1

i i

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-20 11.0 UTILITY AND THIRD PARTY ENGINEERING EVALUATIONS INPO EVALUATION During the week of January 11, 1982, the Institute of Nuclear Power Operations (INPO) conducted a startup assistance visit.at the request of LILCO to assess preparations and readiness for Shoreham operation at that stage of construction (90% complete) and preoperational testing (30% turn-over). The INPO report was . forwarded to NRC Region .I on August 24, 1982.

A total of 46 recommendations were made. Good practice was noted by;INPO in the areas of Organization and Administration,. Operations, Maintenance Technical Support, Training and Qualif.ication, Radiological Prote'ction and Chemistry. The applicant has implemented many of the recommendations made--

by INPO.

.Torrey. pines Review At LILCO's~fnitiative, Torrey Pines Technology (TPT) conducted.an indepen-

" dent review between May and September of 1982 of the complete construction process at Shoreham beginning with procurement and ending with final QC inspection and system turnover to startup.

The TPT effort involved 33,000 manhours and 60 engineers / technicians.

~

Inspection of 6000 components and 11,000 documents included all large-bore pipe supports and the results of 53 preoperational tests, as well as most' primary concrete, 75 welds, and 1600 ASME material certifications. The results of the TPT review were presented to NRC at a meeting at Region I on November 22, 1982.

The'QA program and its implementation were judged.to be satisfactory. The number of deficiencies was small, there was no trend in'the deficiencies, and QA documentation was complete. The overall conclusion was that-the Shoreham construction process properly converted design documents into sound plant features.

Teledyne Review Teledyne Engineering Services (TES)-performed an Independent Design Review of piping and piping supports. An inspe~ction was performed aan a portion of the Low Pressure Core Spray System at Shoreham to verify that design and QA processes were adequately implemented, and that the as-built configura-tion was in compliance with FSAR committments. The TES independent design 4

review took over one year and about 12,000 manhours to complete. A final report was provided to NRC in July 1983.

Observations, findings and concerns identified by TES, were reviewed with' SWEC and LILCO, and subsequently closed. NRR ' reviewed those findings and concluded that they were reasonably justified and appropriately resolved.

The TES report was judged to be well organized and technically extensive providing an in-depth review of Shoreham design, analysis and construc-tion.

21 Shoreham Probabalistic Risk Assessment (pRA)

The applicant-contracted Science Applications Inc. (SAI) in 1981.to perform a PRA for Shoreham. The final PRA report was submitted to the NRR staff in the summer of 1983, with NRC review scheduled to be completed by the end of 1984. Parts of the Shoreham PRA were used in the Reactor Building flooding evaluation conducted by NRR and Region I. The PRA was not liti-gated before the ASLB, and does not impact licensing.

Reinhardt and Associates Study Weld inspection history of the Shoreham reactor pressure vessel was in-dependently reviewed by LILCO's consultant, Reinhardt and Associates, Inc.

during December 1981 through February.1982. ASME preservice inspection (PSI) examinations were observed for Code. practices and NRC regulatory compliance. A final report was issued in April 1982 which concluded that:

the fabricator of the vessel (Combustion Engineering); the PSI contractor (Nuclear Energy Services); and LILCO's applied QA program, were all in compliance with and met the intent of ASME Code and NRC regulatory requirements.

a 5

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22 12.0

SUMMARY

AND CONCLUSION A summary of highlights and results of this assessment include:

In excess of 22,000 inspection hours and 270 issued reports have been devoted to the Shoreham site since issuance of a Construction Permit in April 1973. Close to one-half of those hours were expended in the last two years; two-thirds in the last three years.

All 131 preoperational tests required prior to fuel load have been completed, and all test results have been inspected and approved.

There are no outstanding test exceptions that require resolution prior to fuel load. These inspections were extensive, covering the period 1976-1984, and accounting for almost two-thirds of the total hours.

A special team inspection was conducted in January 1983 to assess the status of plant readiness for fuel. load. The inspection concluded that construction activity and preoperational testing had progressed satisfactorily, such that the plant would be ready for fuel load by the summer of 1983.

LILCO's attention was directed towards final QC inspection, housekeeping, closeout of the Master Punch List'and open inspection items, and turnover of the remaining systems _ undergoing testing to plant staff. Those areas have since been adequately addressed and resolved by LILCO.

' An independent NDE van inspection was conducted in August 1982 to verify the adequacy of the welding quality control program through independent NRC testing. This effort resulted in very good agreement with the licensee's determinations, and confirmed acceptable _ weld quality.

Open inspection items have resularly identified by regional inspec-tions, and aggressively closed by LILCO, such that only 5 remain which are significant enough for license conditions. All construc-tion deficiencies have been corrected.

Quality Assurance has been adequately assessed by regional inspection and independently verified by a number of favorable third party audits. QA contentions were litigated and resolved as part of the ASLB hearings, in which Region I participated. the ASLB found the overall performance, of both LILCO and the NRC staff, to be effective in identifying and correcting deficiencies. No significant adverse trends, indicative of QA/QC program breakdown were found from enforce- l ment statistics. Further, the Board concluded that the testimony of NRC staff and LILCO was credible _and persuasive, and that the QA i Programs for operation of Shoreham will provide adequate protection of public health and ssfety.

i I

23 Extensive, continuing reviews of the. proposed Technical Specifica-tions and the surveillance test program, as part of NRC preopera-tional inspections, have provided reasonable assurance that the TS are. compatible with and accurately reflect as-built plant status.

Approximately 100 allegations have been received and addressed since early 1980 regarding Shoreham activities. With the exception of an ongoing OI investigation related to TDI quality programs, all other concerns have been inspected and resolved.

Plant construction was essentially completed in 1982, and Region I inpsections have verified that the as-built plant has been maintained in an appropriate state of readiness.

Based on the above, it is concluded.that Shoreham has been constructed substantially in accord with Construction Permit CPPR-95, the FSAR, and NRC regulations, and that Long Island Lighting Company is ready to assume the safe low power operation of the facility.

.. . . . . . . ~ . . , _ _ _ . - .- .- ._- _- .. -

Y TABLE 2.1: Summary of SALP Evaluations l Functional Areas Rating (for period ending) 2/81 2/82 2/83 2/84

1. Radiological Controls -

2 2 1

2. Maintenance Avg. 2 2 -1

3. Fire Protection -

2 2 -

4. Security & Safeguards -

2 2 1

5. Initial Fuel Receipt -

2 2 -

4

6. Preoperational Testing Avg. 2 '2 2

7. Plant Operations Avg. -

2 - -

8. Housekeeping - -

3 2

9. Emergency Planning - -

2 2

10. Piping Systems & Supports Avg. 1 2 1

11. Electrical &. Instrumentation Avg. 2 2 2 2

' 12. Engineering & Design Below Avg. 3 2. 1

13. Licensing Activities 2 2 2

14. Soils & Foundations - - -

1

15. Emergency Diesel Generators - - -

3

16. Surveillance Avg. - -

1

17. Readiness for Operation - - -

1 1

18. Committee Activities Avg. - - -

19. Quality Assurance / Control Avg. - - -

20. Concrete Avg. ' - - -

21. Safety Related Structures Avg. - - -

i 22. Preservice Inspection Avg. - - -

23. Reporting Below Avg.'- - -

24. Environmental Protection Avg. - - -

25. Training Avg. - - -

26. Procurement Avg. - - -

Note: " " indicates that this functional area was not'specifically assessed during the subject assessment period.

+

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Enclosure 3.1 Shoreham Inspection program - Annual Breakdown (Hours)

Reports 2510 2512 2513 2514 2515 Total Year Issued Pre 1/31/75 Constr Preop Startup Operations Hours 73-74(a) 13 600 - - - -

600 75(b) 12 148 594 - -

8 750 76 15 -

793 121 - -

914 77 24 -

637 205 28 -

870 78 27 -

847 181 - -

1028 79 24 406 520 518 - -

1444 80 19 -

297 782 -

4 1083 81 23 70 433 1087 -

44 1634 82 35 -

678 3555 27 78 4338 83 42 -

299 4919 59 '270 5547 84(c) 37 -

610 3010 227 104 3951 TOTALS 271 1224 5708 14378 341 508 22159 Notes:

a. 1973-1974 estimates (beginning 4/15/73 CP) are 13 reports and 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />,

b. 1975 MPS Data incomplete, estimate (from actual reports) approximately 750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br />.

c. Through November 1984, up to and including Inspection Report No.'84-41 (4 reports cancelled)

. _ _ _ . ... . -. - - - .. . . . _ = .. -

k Enclosure 3.2 SHOREHAM INSPECTION REPORTS-i YEAR 1984 Program Breakdown Rpt. Period No. Ending . Violations Comments Report Total Constr. Preop..Startup Ops Issued Hours 2512 2513- 2514 2515 84-Ol' 1/13 Level IV Resident review of EDG hold- 2/16 25 -

25 - -

^ down bolt failures 02 2/26 -

Resident review of open items, 3/16 319 -

319 - -

1 and diesel testing 03: 2/11 -

New OG Bldg. construction QA 3/16 46 46 - - -

04 3/1 -

Bower Allegations 5/1 246 - - ~- -

05 2/14 -

EDG Recovery Test Programs 4/9 20 -

20 - -

06 '

2/17 -

Rad Protection & Radwaste 3/30 66 -

66 - -

Waste Programs 07 3/21 -

Preop. procedures & tests 4/25 56 -

56 - -

08 3/2 -

Preop Rad. Enytr & Met Monitor 4/11 34 -

34 - -

i 09 3/3 -

EDG Recovery Program 4/10 28 -

28 - -

, 10 4/22 -

Resident followup-of open 5/1 435 -

435 - -

items; April 14, 1984

) LOOP, Rx. Bldg. flooding review 11 3/22 -

EDG Recovery Program 4/18 88 -

88 - -

. 12 CANCELLED 13 5/2 -

Chemistry and Effluents 6/21 84 -

84 - -

14 4/27 -

Open Items; Bul & Circl 7/16 440 -362 78 - -

15 CANCELLED

16 5/14 -

Resolution of Preop Test 5/31 61 -

61 - -

! Exceptions & Results; Obser-vation of Integrated Electri-cal Test i 17 4/19 -

Review of Ventilation System 6/15 14 -

14 - -

1 Testing; Closure of IE Bulle-i tins and Circulars related to j Radiation Protection 18 5/27 -

Resident closure of open 6/15 317 -

317 - -

items; review of Radwaste Bldg.

flooding, diesel testing 19 5/4 -

Security Program implementa- 6/19 68 -

68 - -

J tion j 20 5/4 -

Startup Program administrative 6/15 39 - -

39 -

controls and IE Bulletin 80-17 i

(BFNPP scram failure) t 21 5/11 -

Closure of IE Bulletins and 7/11 30- -

30 - -

l open items related to welds and materials 22 5/18 -

Review of initial fuel load 7/16 58 - -

58 -

and startup test sequence of activities i

1 t

- - , , , , ,,, , , . , - n.. ,, - . , , , , .. ..n -- , , -- - -.-, ,,,,, -

l Program Breakdown Rpt. Period Report Total Constr. Preop. Startup Ops No. Ending Violations Comments' Issued Hours 2512 2513 2514 2515-23 7/1 -

Resident closure of open items 8/18 213 213 - -

including BISCO allegations; review COLT diesel project 24 6/29 -

New Diesel Building civil 8/1 27 27 - - -

structural activities 25 6/29 -

Closure of Radiation Protec- 8/3 20 -

20 - -

tion open items 26 7/2 -

GM-EMD Test Observation 9/18 46 - -

38 8 27 7/12 -

Startup procedures and 8/27 89- -

28 61 -

open items 28 CANCELLED 29 8/19 -

Resident observation of TDI 8/30 281 -

281 - -

and Integrated Electrical Testing 30 7/11 -

Closure of TDI diesel open 8/13 12 -

12 - -

items 31 7/26 -

Startup test procedure review 9/12 31 - -

31 -

32 9/30 -

Resident review of administra- 10/11 235 -

235 - -

tive controls and Master Punch List 33 9/21 -

Closure of TMI Items 11/9 63 55 8 - -

34 9/21 -

Implementation of Security 11/15 36 -

36 - -

Plan 35 9/14 -

IE Bulletin Followup 10/26 31 31 - - -

36 10/5 -

COLT Diesel Project Unissued 128 66 62 - -

37 10/3 -

Final closeout of Preop. Unissued 26 - ,6 2 - -

Program 38 10/12 -

Fire Protection Unissued 96 - - -

96 39 11/3 -

Resident closure of open 11/23 120 -

120 - -

items l

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)

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SHOREHAM INSPECTION REPORTS YEAR 1983 Program Breakdown Rpt. Period Report Total Constr. Preop. Startup Ops No. Ending Violations Comments Issued Hours 2512 2513 2514 2515 83-01 1/31 -

Resident followup on open 2/8 237 -

237 - -

items and IE Circulars; review of Vendor Manual controls, monitoring of housekeeping 02 1/15 4 Level IV Readiness Assessment Team 1/20 465 118 347 - -

Inspection 03 1/21 -

Fuel receipt, handling and 2/15 40 -

40 - -

storage; Preop Test Program status and implementation 04 1/25 -

RAT Findings - Mtg. 2/28 24 -

24 - -

05 2/28 Level IV Resident followup on open 3/30 399 -

399 - -

items, Bulletins and Circulars Observation of RBSVS Preop Testing; QA Procedure Review; Evaluation of 24 VDC Power i

Supplies 06 2/18 -

Followup on IE Circular 3/15 30 30 - - -

81-08 (Foundation Materials);

review of Settlement Monitoring Program 07 3/4 -

Resolution of Preop Test 3/24 42 -

42 - -

Exceptions; status of Preop test program; witness of 72-hr EDG electrical test runs 08 3/31 Level IV Resident closure of open 4/15 573 -

573 - -

items, bulletins, circulars and TMI 0737 issues; review of MSIV-LCS electrical wiring modifications, ESF reset features, diesel preop test discrepancy (full load rating-nonconservative negative tolerance) 09 4/15 -

TMI 0737 Item Followup 5/5 31 -

8 23 -

10 5/9 Level V Resident followup on open 5/27 363 -

363 - -

items; monitoring of house-keeping; review of STA program, diesel testing, and the oper-ating and mantenance program for 125 VDC station batteries

1 l

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l Program Breakdown j Rpt. Period Ending Violations Comments Report Total Constr. Preop. Startup Ops  !

No.

Issued Hours 2512 2513 2514 2515 i 11 4/16 -

Closure of open items; IE 5/27 94 20 74 - -

Bulletin 80-11 (Masonry Walls);

review of containment struc-tural acceptance test results; preop test procedure review; witness of TOI diesel electrical test runs 4/29 Security 12 -

6/1 40 -

40 - -

j 13 4/28 -

RAT Firidings - Followup 5/23 23 -

23 - -

14 4/29 -

Shielding design review 5/25 21 - -

21 - 1 (TMI 0373 Item II.B.2) 'i 15 5/19 -

Preop test completion status, 6/15 27 -

27 - - '

procedure and test results-  !

t for Offgas System; preparations  ;

for integrated electrical test; '

review of QA program for diesels 16 5/12 -

Resolution of construction 6/7 26 -

26 - -

deficiencies 1

17 6/21 -

Resident followup on open 7/8 337 -

337 - -

items; observation of TDI preop testing; review of control room human factors  !

items completed '

18 6/3 -

Electrical raceway separation 7/6 28 28 - - -

19 6/3 -

Review of ILRT results; wit- 6/24 26 -

26 - -

ness of TDI EDG set testing; status of TDI Operational j Results Program '

20 6/17 -

ILRT review; TDI diesel 7/25 32 -

32 - -

preops, l 21 7/27 Level IV Resident open item followup; 8/15 280 -

280 - -

l i

review of operator requal. '

training, electrical t

separation requirements (ASLB resolution agreement), proce-dures and training for Station ,

l l Blackout i

! 22 6/30 -

TDI Diesel Meeting 7/27 14 -

14 - -

l 23 7/29 -

Preop procedures; EDG testing 8/15 55 -

40 15 -

l 24 7/20 -

Diesel Mtg. w/Suffolk Co. 8/12 28 -

28 - -

25 7/29 -

NDE of Diesel Cylinder Heads 8/15 10 10 - - -

26 8/11 Level IV Huber allegations 8/30 25 -

25 - -

27 11/4 -

Preop and EDG Recovery Testing 1/5 41 -

41 - -

28 8/31 -

Resident followup on open 9/14 260 -

260 - --

items; HPCI initiation design l change; TDI diesel crankshaft i

failure

[ 29 8/26 -

Followup of QA open items 10/17 93 93 - - -

30 9/30 -

Radiation Protection 11/16 110 -

110 - -

l

Program Breakdown Rpt. Period Report Total Constr. Preop. Startup Ops No. Ending Violations Comments Issued Hours 2512 -2513_ 2514 2515 31 9/16 -

Security 11/30 68 -

68 - -

32 10/16 Level IV Resident followup on open 10/27 354 -

354 - -

items; Comm. Gilinsky tour; TOI diesel disassembly and inspection, repair and reassembly 33 11/3 -

Huber allegations 11/20/84 106 106 34 11/18 -

Huber allegations 12/21 29 -

29 - -

35 11/27 -

Resident closure of open 12/24 330 -

330 - -

items; observation of TDI diesel test and repair; review of Reactor Building flood and MSIV leak collec-tion issues 36 11/18 -

Huber allegations 12/5 39 -

39 - -

37 12/9 -

Followup EP Appraisal 2/6/84 270 - - -

270 38 1/22/84 -

Resident closure of open 2/7/84 399 -

399 - -

items; surveillance and diesel testing 39 12/9 -

Huber allegations 12/14 27 -

27 - -

40 12/15 -

Security Program review 1/6/84 27 -

27 - -

41 12/23 -

Huber allegations 7/11/84 25 -

25 - -

42 1/29/84 -

TDI Diesel Recovery Program 4/9/84 99 -

99 - -

SHOREHAM INSPECTION REPORTS YEAR 1982 Program Breakdown Rpt. Period Report Total Constr. Preop. Startup Ops No. Ending Violations Comments Issued Hours 2512 2513 2514 2515 82-01 1/8 -

Followup of IE Bulletins 11/27 30 30 - - -

and Circulars 02 1/31 Level V Resident review of ISI and 2/2 123 -

123 - -

Loose Parts Monitoring Program; followup of fuel pool flooding event; witness of Core Spray and Instr. Air preop tests 03 1/15 -

Fire Protec./ Prev. Program 2/3 26 -

26 - -

04 2/26 2 Level IV, "As-Built" team inspection 5/12 373 146 227 - -

2 Level V of RHR and supporting systems 05 3/29 -

Resident inspection of preop 4/2 51 -

51 - -

procedures and test results 06 3/12 -

Review of preop test proce- 3/30 40 -

40 - -

dures and results for RPS 07 3/17 -

Review of Nuclear Material 5/20 42 - -

42 -

Control and Accounting Program and Security organization 08 5/10 Level V Resident followup of open 5/27 126 -

126 - -

items and IE Circulars; review of CILRT; implementa-tion of electrical separation 09 4/29 -

Security Program review 7/16 38 -

38 - -

10 4/29 Level V Startup Test Program review; 5/24 40 -

13 27 -

witness of LLRT il 5/14 Level V Review of preop test proce- 6/18 72 -

72 - -

dures & results, witness of HPCI and diesel testing, and assessment of 0QA audit of preops 4

12 5/21 -

Followup of construction 5/28 26 26 - - -

deficiency reports 13 6/18 2 Level IV, Resident review of new fuel 7/14 180 -

180 - -

1 Level V receipt training in QA, fire protection, HP and security; observation of RHR preop testing; assessment of control of jumpers and lifted leads 14 7/29 -

Review of training programs 9/3 121 -

121 - -

and preop test records 4

_- __ - ._ -_ = . .. . . .. - _ - _ _ .

1 Rpt. Period Program Breakdown No. Ending Violations Comments Report Total Constr. Preop. Startup Ops Issued Hours 2512 2513 2514 2515 15 7/31 2 Level IV, Resident followup on IE Circu- 8/30 259 -

259 - -

1 Level V lars, new fuel receipt training and processing; review of reactor building polar crane, '

and preop testing for. drywell i floor bypass leakage; observation of containment structural accep-1 tance test; review of process computer displays 16 5/28 -

New fuel receipt and storage 6/23 36 - -

36 4 17 6/4 -

Leak rate testing (LLRT & 6/22 26 3 23 - -

j CILRT) 18 9/2 EP Appraisal 9/30 616 616 - -

19 8/13 Level IV NDE Inspection 10/15 393 .393 - - -

1 20 10/15 -

Preop testing of radwaste 11/16 32 -

32 - -

systems

'; 21 7/29 -

HP Training / Qual Program 10/12 5 -

5 - -

22 8/27 -

Resident followup of open 10/6 46 -

46 - -

items 23 9/18 -

Resident 9/16 147 -

147 - -

, 24 9/10 -

Fire Protection Program 10/15 52 52 - - -

25 8/26 -

Management Meeting for fuel 9/13 17.5 -

17.5 - -

load prerequisites 26 10/13 Level V Resident followup of open 10/29 161 -

161 - -

items; review of vacuum breaker leakage preop test procedure, containment hydrogen / oxygen analyzers 27 10/22 -

Preop test procedures and 11/22 35.5 -

35.5 - -

results 28 10/21 -

Followup of construction 11/23

• 28 28 - - -

deficiencies

29 10/29 -

Allegations of corroded 11/18 27 -

I 27 - -

Screenwell valves and fiber-glass piping problems

30 11/29 Level V Resident followup of open 12/23 214 i

214 - -

items, bulletins and circu-lars, witness of RCIC preop testing; review of MOV wiring i practices ; summary of 11/22/82 management meeting (preparations 31 10/29 for fuel load)  ;

Physical Security Plan review 12/20 64 -

64 - -

32 12/10 -

Leak rate testing, witness of 1/18 102 -

102 - -

ILRT

. . . . _= - -

]

4 Rpt. Period Program Breakdown No. Ending Violations Comments Report Total Constr. Preop. Startup Ops Issued Hours 2512 2513 2514 2515 33 11/19 -

Resolution of Rad. Protection 1/24 94 -

94 - -

followup items; review of IE Circular 81-07 (Control of Contaminated Material), Rad.

Protection Program staffing and training, dosimetry and monitor-ing, and ALARA programs 34 12/15 -

QA Program Team Inspection 1/3 547 -

547 - -

35 12/31 Level III Resident review of diesel 2/24 148 -

148 - -

preop testing and CILRT proce-dures 1

+

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l i

Table 4.1 ANNUAL AUDITS CONDUCTED (1973-1984) by QUALITY ASSURANCE DIVISION (formerly FQC)

~

Year d '

Audits Findings" Observations a 1973 63 - b 147 1974 133 15 D 154 1975 149 166 123 1976 160 130 184 1977 180 121 100 1978 177 109 130 1979 179 146 152 1980 180 102 116 1981 177 59 174 1982 155 52 123 1983 108 76 65 1984 85c 61 46 TOTALS 1746 1037 1514

a. Findings include those items designated as " violations" on the field audit reports. Observations include those items designated as "open item" on the field audit reports.

b. Prior to September 1974, items on field audits were not classified as find-ings or observations. All of the unclassified findings have been listed as observations. ,

c. Includes audits through September 1984, d.

Of records, design control, SWEC and subcontractor work and overall QA program.

Table 4.2 ANNUAL AUDITS CONDUCTED ON SITE (1973-1984) by QUALITY SYSTEMS DIVISION Year Total Audits

• Total Findings Total Open Items 1973 8 8 1 1974 5 6 12 1975 7 17 6 1976 3 5 5 1977 2 7 2 1978 4 3 5 1979 2 0 0 1980 1 0 0 1981 2 8 4 1982 1 2 4 1983 8 48 b 105 1984 8 89 b 60 TOTAL 51 193 -204

a. Of Project, QA, and other LILCO site organizations b.

Include all LILCO Nuclear Review Board (NRC) audits

t i

Table 4.3 Annual Audits Conducted On-Site (1976-1984) by Quality Control Division (Formerly 00A)

Year Audits" Findings . Observations 1976 4 25' O 1977 12 54 0

-1978 13 65 0 1979 12 33 0 1980 14 55 i 23 1981 24 53 17  :

1982 55 81 -35 l 1983 82 129 33 1984 32 53 3

36

! TOTALS 248 548 144 .i i

0 I l  !

a. Of Startup and Plant Staff Activities s

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b I

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a i '

e i l i  !

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- - - , . - - - ----,m,. ,- .r .. ,, , , - ,- . , - , , - - - -

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s t yp Table 4.4 ' -

VENDOR AUDITS PERFORMED BY LILC0/SWEC Year. Audits Findings Open Items 1973 12 6 0 1974 18 69 0 1975 32 76 0

1976 16- 59 0 1977 21 131 '6 1978 14 13 4 1979 22 19 1

, 1980 14 22 5 1981 16 42 4 1982 23 37 14 1983 23 58 9 1984 15 46 18-TOTAL 226 578 61 Note: As of November 28, 1984, 13 findings or open-items remain open.

These numbers do not reflect SWEC Corrective Action Audits to verify

, resolution of previous audit findings.

e 4

I s

l

-. . _. - _. _ _ . _ ~.. . _ _ _ _ _ . _ _ _

j l

Table 4.5 QA AUDITS CONDUCTED BY COURTER AND COMPANYc i

Year -Audits

. Findings __

Observations" 1978 38 85 -

1979 38 34 -

1980 42 28 -

i. 1981 36 61 2 1982 32 75 5 1983 22 22 4 b -

1984 g 2 0 TOTALS 217 307 '11 t a. At present, the records providing information on the number of 'observa-tions in the years 1978-1980 are unavailable.

b.

Through September 1984, and principally for new COLT diesel building piping.

c. Courter & Co. received an N-Stamp, as the piping subcontractor for Shoreham, in 1978.

i I

9 k

-t

,,,,_ . _ . . _ _ _ - _ , , - - e ' ' ~ " ~ '" ~~ "' " '

o Table 4.6

v .

_ Stop Work Orders Issued by

!I I ~ ' LILCO QAD/QSD.

Year Organization Reason for Stop Work Period of-Stop Work 1973- S&W Construction Failure to follow From: June 14 established procedures To: June-26

} during placement of concrete for 1st-

., quadrant, reactor mat.

1973 S&W Construction Unavailability of From:' September 11

(-s installation documenta- To:

tion for 1st lift of September 13 primary containment liner prior to release for concrete placement.

$}

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Table 4.7 ANNUAL NONCONFORMANCE REPORTS issued by QUALITY ASSURANCE DIVISION (FORMERLY FQA)

Year Corrective Action LILCO Deficiency Requests (CAR) Reports (LOR)*

1973 44 -

1974 82 -

1975 31 -

1976 36 -

1977 34 -

1978 30 -

1979 61 -

1980 55 -

1981 26 -

1982 37 1983 21(3) 38 9 b

1984 8 5 TOTALS 482 35

a. Only includes "C" series LOR's issued in accordance with WAP-15.1; "C"

Series LDR's were not issued prior to 7-01-82.

b. Issued through 9-30-84

c. Only 3 CAR's and 2 LDR's remain open, as of 11/28/84. The programs are still on going.

b

,.,y. -

. Table 4.8 ANNUAL NONCONFORMANCES issued by SWEC (N&D) AND COURTER-(NR)

SWEC COURTER YEAR N&D's' b.

NR's 1970 6 -

1971 20 -

1972' 13 -

1973 63 -

1974 136 -

1975 291 -

1976 540 -

1977. 488 -

1978 409 627 1979 735 840 1980 925 483 1981 819 272 1982 928 282 1983 647 64 1984- 192 6 TOTALS c d 6174 2574

a. Nonconformance & Disposition (N&D) Report

b. Nonconformance Reports (NR)

c. 40 SWEC N&D's still open as of November 28, 1984; these relate to be COLT diesel projects

d. No Couter NR's open to date 1

l j

Table 5.1 Shoreham Enforcement History (1981 to Present)

Report No. Severity (Issue Date) Subject Requirement Level 84-45 An incorrect valve lineup, caused Part 50 V (unissued) a spill of several thousand gallons Appendix B of water from the reactor vessel to Criterion V the drywell floor drains 84-01 Reassembly of EDG-101 with Part 50 IV inadequate procedures Appendix B Criterion V 83-32 Inadequate amount of security Security IV 10/27/83 guards posted at spent fuel pool area after receipt of new fuel 83-26 Final QA inspection report of a Part 50 IV 8/30/83 hanger did not agree with as-built Appendix B condition Criterion X 83-21 Division I conduit improperly in- Part 50 IV 8/15/83 stalled and without a solid tray Appendix B bottom cover accepted by QA Criterion III 83-10 Established measures did not assure Part 50 V 5/27/83 that procedure changes were distri- Appendix B buted and used during an EDG Criterion VI surveillance test.

83-08 E&DCR was implemented on main steam Part 50 V

/ /83 isolation valve leakage control system Appendix B without a repair / rework request to Criterion V effect retesting after work completion.

83-05 The checkout and initial operations Part 50 IV 4/15/83 test program did not demonstrate that Appendix B safety-related power supplies would Criterion XI perform satisfactorily.

83-02 QC accepted welds did not conform to Part 50 IV 1/20/83 drawing requirements, nor did QC Appendix B accepted hangers and cable tray Criterion B,V,X supports i

l t

Report No.

Severity (Issue-Date) Subject Requirement Level 83-02 Construction did not notify QC prior Part 50 IV 1/20/83 to working on safety-related equipment Appendix B and improper use of E&DCRs Criterion V-83-02 Diesel generator inspection failed to Part 50 IV 1/20/83 verify conformance with instructions, Appendix B drawings and codes in that QA inspected Criterion X and accepted non-conforming conditions.

! 83-02 Failure of tracking system to effec- Part 50- IV.

1/20/83 tively follow the status of the cold Appendix B set of safety-related spring hangers. Criterion XIV 82-35 Diesel generator test program did not Part 50 III 2/24/83 assure that testing was performed in Appendix B accordance with procedures or that Criterion XI test requirements had been satisfied.

82-30 Activities affecting quality were not Part 50 V 12/23/82 accomplished in accordance with appro- Appendix B priate instructions concerning electri- Criterion V '

cal lugs and leads 82-26 Measures did not ensure the prompt Part 50 V 10/29/82 incorporation of changes into drawings Appendix B made by E&DCR's QA Manual 82-19 Shop weld radiographs did not meet Part 50 IV

, 10/15/82 ANSI requirements for penetrameters Appendix B for each exposure and had not been Criterion IX dispositioned or interpreted.

82-15 Failure to perform valve lineup as Part 50 8/30/82 IV specified in procedure. Appendix B Criterion V QA Manual 82-15 After system inspection and accept- Part 50 V 8/30/82 ance, failure to write a deficiency Appendix B correction order to remove a temporary Criterion V hanger left in place. QA Manual 82-15 Checkout and initial operations tests Par t 50 IV 8/30/52 were not performed and documented in Appendix B conformance with approved procedures. Criterion XI QA Manual

Report No.

Severity (Issue Date) Subject Requirement. Level 81-16 Project procedure P304 fails to Part 50 VI 9/21/84 require reporting a possible report- Appendix B able deficiency to the NRC. Criterion V QA Manual 81-14 Failure to follow various plant - Part 50 IV 9/14/81 tagging procedures and to provide Appendix B proper documentation. Criterion V QA Manual 81-13 Failure to maintain adequate control Part 50 V 10/8/81 of startup manual revision distribu- Appendix B tion. Criterion VI QA Manual 81-02 Requirement for small bore piping Part 50 6/23/81 IV containment isolation valves to be Appendix A located as close to containment as Criterion 55-57 possible was not prescribed by Appendix B instructions, procedures or drawings. Criterion V

, 81-01 Failure to recalibrate instruments Part 50 V 4/1/81 within one year of test performance. Appendix B

, Criterion V

, FIGURE 5.1 OPERATIONS MANAGER 41 TOTAL PERSONNEL REACTOR OPERATING ENGINEER ENGINEER

8 TOTAL PERSONNEL 32 TOTAL PERSONNEL NUCLEAR ENGINEER ENGINEEPS 2 TOTAL PERSONNEL 31 TOTAL PERSONNEL -

' SHIFT TECHNICAL WATCH ADVISORS ENGINEERS 5 TOTAL PERSONNEL 30 TOTAL PERSONNEL WATCH SUPERVISORS 25 TOTAL PERSONNEL OPERATORS i

20 TOTAL PERSONNEL i

i FIG. 13.].2-2 SHOREHAM NUCLEAR POWER STATION STAFF, i

OPERATIONS DIVISION SHOREHAM NUCLEAR POWER STATION - UNIT 1 FINAL SAFETY ANALYSIS REPORT

{

l REV1SiON 33, SEPTEMBER 1984 -

I r +~ - - -- - - - - - - - - -- -* * -

-- -- -~---r= ------~-e- - - - + - -~'--=<---* - ' - - - - * +--- = ** - ' ' - +*-

13/22/84 11:48 tetC RE3 i W.005 033 I

l SHOREHAM NUCLEAR POWER STATION DESIGN, CONSTRUCTION PRE-0PERATIONAL TESTING 4

REGION I REVIEW 0F FINANCIALLY INDUCED SAFETY PRCSLEMS In response to the October 18, Ig84 Memorandum from Chaiman Palladino to W. J.

Dircks, NRC Region I has reviewed the licensee's performance including: (1) l consideration of the four Systematic Assessments of Licensee Performance (SALP's) conducted since the start of the assessment program in March 1980; (2) '

the results of approximately 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> NRC inspection; and (3) the 11cen-see's enforcement history. This review was performed to detemine if safety problems have existed at Shoreham which could be attributable to financial difficulties. It should be noted that the Regional Staff has been ennducting a more extensive evaluation in preparation for an OL readiness assessment by the Regional Administrator. Consequently, the review results herein reflect

several man weeks of effort expended to date on this topic. ,

Particular emphasis was directed to those areas which could provide indicators of the licensee's financial commitment to the plant; e.g., plant staffing and personnel qualifications, plant construction and maintenance activities. inde-pendent engineering evaluations, and plant design changes.

As a result of this special review, Region I has reconfirmed that LILCO has maintained a satisfactory level of safety in the design, construction and preoperational testing of the Shoreham Nuclear Power Station. Further, our determination has indicated that Region I's concarns with certain aspects of the licensee's performance, as evidenced by the SALp reports and enforcement actions, have not been attributed to financial considerations.

The following items highlight the basis.for Region I's determination:

• Acceptable Staffing

- Major reorganization in Spring 1984

- New CEO and VP Nuclear

- Shift Advisors in Control Room

• Acceptable Spare Parts Inventory. Surveillance and Maintenance

- Category 1 SALP rating 1 - comprehensive IE Bulletin and circular responses

- Mechanical snubber and other equipment condition j -

• Acceptable Emergency Response Facilities

- Well equipped TSC I

- SPOS design

- PASF Building j

• Satisfactory Conduct of Mark-II containment confirmatory Program

- Plant design changes l - Lead plant Design Assessment Report

• Satisfactory Independent Engineering Evaluations

- Teledyne

- Torrey Pines

13rdV04 11:49 WC RE3 1 NO.005 034 l

E l

=

Aggressive Approach to Diesel Generator Issues )

- Aecovery Test Program for TDI's  !

- FaAA Failure Analyses i 1

- procurement of Colt Ofesels and new building construction i

- WVBC Units-and San Turbine

. =

) Successful Conduct of Preoperational Test Program

' 6 Well staffed l

- Resolution of Test Exceptions ,

! " All systems turned-over to Operations (except TDI diesels)  !

Aggressive Closure of Open NRC Inspection Items I t

Committment to Training-

- Plant simulator ordered

- Licensed Operator requalification in progress for 2 years 4 NRC Region I has identified problems or concerns with LILCO's performance, re- i sulting in Category 3 assessments in several past 5 alp evaluations; e.g.,

Diesel Generators, Nousekeeping and Engineering and Design.

alty was imposed in July 1983 associated with diesel generator testing.Also, The a civil p i

! causes of these problems were not attributed to financial considerations.

Rather, they were due to weaknesses in the attention given and involvement by

! LILCD seniorthemanagement less. Through SALp in identifying, correcting, and follow-up of plant prob

~

1

program and the enforcement program, Region I has  !

t assured that the licensee implemented necessary prograsmistic changes to improve its performance in those areas. A Readiness-Assessment Team Inspection '

ducted in January Ig83 confirmed that corrective action, in many cases, con-j j The lack of significant BWR operating experience among licensed personnel and plant management has been an NRC concern that is being addressed.

There has i

been some evidence of a reduction in plant staff in the last six months (Opera- i j

l tions and Radwaste Supervisors), attributable to the questi mot caused major evident problems.

There have been approximately 40 NRC inspections, and over 5100 inspection-hours, devoted to Shoreham activities during the past year through September Ig84). September Ig83

! None of these inspections haven ide(tified safety problems which could be attributable to the financial difficulties experienced by LILCD to date. These inspections have focused in part, on: (1) completion

{ of the pr,eoperational test program; (2) the. closure, of the past ten year

of NRC part open 50.55e items including IE Bulletins, Circulars THI-0737 requirements and' construct Test Recovery program; ion deficiencies; (3) the TDI Emergency Diesel Generator j and (4) resolution of allegations. No significant safety problems were identified, nor were any significant violations imposed.

i

LILCO, is, or has been, adversely affected by the financial c company, past er present.

-. - - . - - - . - . . - _ - _ - - - - -