ML20237J721
| ML20237J721 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/14/1987 |
| From: | Lo R Office of Nuclear Reactor Regulation |
| To: | Miraglia F, Starostecki R, Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8708180305 | |
| Download: ML20237J721 (16) | |
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UNITED STATES 8
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August 14, 1997 Docket No. 50-322
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l MEMORANDUM FOR:
Frank J. Miraglia, Director l
Associate Director for Projects
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j Steven A. Varga, Director i
Division of Reactor Projects I/II
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Richard W. Starostecki, Associate Director for Inspection and Technical Assessment Lawrence Shao, Director Division of Engineering and Systems Technology Charles E. Rossi, Director Division of Operational Events Assessment James G. Partlow, Director
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Division of Reactor Inspection and Safeguards Frank Congel, Director l
Division of Radiation Protection and Emergency l
Preparedness Jack W. Roe, Director Division of Licensee Performance and Quality 1
Evaluation l
THRU:
Walter R. Butler Director Project Directorate I-2 Division of Reactor Projects I/II FROM:
Ronnie Lo, Project Manager i
Project Directorate I-2 j
Division of Reactor Projects I/II i
SUBJECT:
DRAFT NRR INPUT FOR SALP - SHOREHAM NUCLEAR STATION UNIT 1 Enclosed is a draft of the NRR input for the SALP for the Long Island Lighting Company.. This draft report is based primarily upon the mini-SALP evaluations enclosed with SEs prepared during this SALP period for Shoreham.
Please i
review the draft evaluation and provide any coments you feel appropriate.
All comments received by August 24, 1987 will be considered for incorporation in the final report.
B708180305 870814 DR ADOCK 0500 2
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-A s-no l Please note that the licensee overall evaluation for " Licensing Activities" is a Category 2.
The assigned SES for this plant is W. Butler.
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Ronnie Lo, Project Manager Project Directorate I-2 i
Division of Reactor Projects I/II
Enclosure:
As stated DISTRIBUTION Docket Fi.le y NRC PDR Local PDR PDI-2 Reading SVarga/BBoger WButler RLo/GRivenbark M0'Brien 1
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l Please note that the licensee overall evaluation for " Licensing Activities" is
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a Category 2.
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The assigned SES for this plant is W. Butler.
Ronnie Lo, Project Manager Project Directorate I-2 Division of Reactor Projects I/II l
Enclosure:
As stated l,
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
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Docket No. 50-322 FACILITY:
Shoreham Nuclear Station, Unit No. 1 LICENSEE:
Long Island Lighting Company EVALUATION PERIOD: March 1, 1986 to July 31, 1987 PROJECT MANAGER:
Ronnie H. Lo I.
INTRODUCTION This report contains NRR's input to the SALP review for the Shoreham Nuclear Station, Unit No. 1 (Shoreham)..The assessment of the licensee's performance was conducted according to NRR.0ffice Letter No. 44, "NRR Inputs to SALP Process," Revision'1, dated December 22, 1986.
This Office Letter incorporates NRC Manual Chapter 0516, " Systematic Assesscent of Licensee Performance."
II.
SUMMARY
NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2, or 3) based on'a composite of a number of attributes.. The single final rating should be tempered with judgement as to the significance of the individual elements.
Based on this approach, the performance of the Long Island Lighting Company in the. functional area - Licensing Activities - is rated Category 2.
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III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.
IV. METHODOLOGY This evaluation represents the integrated inputs of the Project Manager (PM)-
and those technical reviewers who expended significant amounts of effort on -
Shoreham licensing actions during the current ~ reting period. Using the guidelines of NRC Manual Chapter 0516, the PM and each reviewer ~ applied specific-evaluation criteria to the relevant licensee performance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1, 2, or
- 3) to each attribute. The reviewers included this information as part of each '
Safety Evaluation. input transmitted to the Division of Reactor Projects I/II.
The PM, after reviewing the SALP inputs of the technical reviewers, combined this information with his own assessment of licensee performance and, using appropriate weighting factors, arrived at a composite rating for the licensee.
This rating also reflects the coments of the NRR Senior Executive assigned to Shoreham SALP assessment.
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l A written evaluatiorh was then prepared by the PM and circulated to NRR 1
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management for commdnts which, where provided, were incorporated / n the fidal i
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The bpd1's for this appraisal was the liceps'ee's performance in suppof t of licensing actions that were either compkted or,'had a significant level' of activity during the rating period.. There Were a total of 26 active tetions at the beginning of the rating period for Shoreham. Actions were,added to the e
plant specific. actions for<a total of 32 actions by t% etcd of the rei:ng period >. S We 'hcv'e closed M actions, daring the rating par,f od and have' 20 pending actions at the end of this' rating' period. The actions and a partial list of completions consittini 'oi' ansdment requests, nemptien r$ quests, respcoses to I
generic letters. TMI,itw&, end Jicensee initiated actioni are:
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- 10 TMI (NURFG 0757) Action' (4 C$inpleted).
Some of the completed aqt.%ns in
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'this category are:
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9 Reductica Nf Challenges and Faf fures of Re!1ef Valves (I' tem II.K.3.16)
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,si Port-Accident Sampling System of f site Analysis ' Capability (Item II.B.3){
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Quantification of Iodine and Partic. pates in Gaseous. Effluents (ItemII.T.1)
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Shift Technical Advisor (! tem I. A.I.7,).
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14 Multi-Plant Action (6 completed)$ Sude'of the completed actions i.n this category are z
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t F, ire Protection, Appendix R (A 17) '
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r r c 10.CFR.50.62, Implementation of Salem ATWS ?ules
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Salem ATWS Item 2.1.1, 3.1. 3, 3'. 2. 3 1
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y Standby Lhuid Control System (A-20),,
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i 10PlantSpecificA$tions(4 Completed). Somo of the completed actions in l
this category are:
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Process Ccntrol Prograo Technical Specifications a
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Sample Analysis Freque jcy Technical Specifications '
tM1k Sample Location Technical Specifications 1
Containment _eakage System Technicsl Speciiirations t
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I 3-i V.
ASSESSMENT OF PERFORMANCE ATTRIBUTE The licensee's performance evaluation is based on a consideration of the seven attributes specified in NRC Manual Chapter 0516.
These are:
i Management Involvement and Control in Assuring Quality Approach to Resolution of Technical Issues from a Safety Standpoint Responsiveness to NRC Initiatives Enforcement History Reporting and Analysis of Reportable Events Staffing (Including Management)
Traini,ng and Qualification Effec'iveness In addition to the above, Housekeeping and Control Room Behavior is discussed. A summary of the SALP ratings in each crea is shown below.
SUMMARY
OF SALP RATINGS 1
Criterion Rating i
Management Involvement and Control in i
Assuring Quality 1
l Approach to Resolution of Technical Issues 2
Responsiveness to'NRC Initiatives 1
Enforcement History 2
Operational Events 2
Staffing 1
l Training 2
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Housekeeping and Control Room Behavior 1
Composite Rating 2
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. A.
Management Involvement and Control in Assuring Quality l
The licensee's management participated directly in several of the major licensing activities during this period, most notably in emergency planning, request for authorization to operate at 25% power level and the resolution of Appendix R issues. With the satisfactory resolution of Appendix R issues, emergency planning adequacy is the only issue preventing the licensee to operate Shoreham above the 5% low-power testing level. The management involvement in emergency planning continues to be intense, as demonstrated by the support throughout the hearing process on contentions that developed from the February 13, 1986 emergency drill and the contentions on the adequacy of relocation centers. The expediency and the quality of responses to the staff's inquiries on the technical bases for the 25% power request also demonstrates the management's commitment to support its licensing activities.
In addition to involvement on matters that are on the critical path for licensing to operate Shoreham above 5% power, the licensee's management also strived to improve the quality of other licensing activities during this l
period. 'At the direction of the Vice President, Nuclear Operations, the licensee's management staff visited the NRR Project Manager on a regular basis to review the status of licensing activities and to discuss certain technical -
issues with the NRR technical staff. These meetings were often attended by i
representatives of the interveners. Nonetheless, discussions during those meetings were non-inhibitive and productive; for example, these meetings l
resulted in the timely resolutions of Appendix R issues and the surveillance requirements for the Reactor Coolant System leakage detection system.
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The management's commitment to safety was further evidenced by safety l
enhancements that went beyond the minimum regulatory requirements.
For example, during this SALP evaluation period, the licensee has increased the capacity of the Standby Liquid Control System (SLCS) such that it is equivalent to 200% of the requirement of 10 CFR 50.62, ATWS rule.
In addition, the licensee has made progress on the Colt EDGs tie-in work. The Colt EDGs will be redundant to the existing TDI EDGs to provide emergency AC power. The licensee also has taken initiatives on a conceptual study to enhance containment integrity in the event of a severe accident.
It is apparent that the Licensee's management believes that because of the contested nature of the licensing proceedings, these extra safety features at Shorcham are warranted.
The direct involvement of the licensee's technical department managers in licensing issues also helped in the improvement of the quality and timeliness of its submittals and responses to the staff's questions.
During this period, the licensee's Licensing Division issued weekly summary reports and held scheduled weekly briefings with the department managers. This close coordination enabled the licensee to substantially improve on the quality of analyses that accompanied the submittals for licensing activities.
In December 1986, the licensee issued a 16-volume updated Safety Analysis Report. The report was prepared under the direction of the licensee's senior l
management. The report is well organized, thorough and free of errors. The l
high quality of the report is another illustration where the licensee's management involvement is apparent, i
On the basis of these obsenstions, a rating of Category 1 is assigned for l
this attribute.
B.
Approach to Resolution of Technical Issues from a Safety Standpoint The licensee's technical response to the resolution of most issues continued to be sound. During this rating period, the staff completed its review of the outstanding issues related to fire protection.
The fire protection issues related to the control of the ADS and the controls of high-low pressure system interfaces in the event of a fire.
The apprcach by the licensee to resolve these issues showed a clear understanding of the plant systems and the analysis performed was realistic and yet allowed for substantial safety margins to exist. There were, however, instances where the licensee's initial evaluations and approaches to resolve technical issues appeared to be superficial and required the NRC staff to probe for alternatives and satisfactory solutions.
Two of those cases were the issues related to quantification of post-accident effluents (NUREG-0737, Item II.F.1) and the surveillance requirements of the RCS Leakage Detection Systems (Inspection Report It'em 85-04-12). Although the licensee arrived at technically sound and acceptable solutions, it resulted in substantial delays for closing those two issues.
On the basis of the above observations, a rating Category of 2 is assigned for this attribute.
C.
Responsiveness to NRC Initiatives LILC0 made substantial effort to improve on this attribute during this SALP evaluation period. The improved capability of the SLCS, the change of the MSIV set-point, the improved reliability of the ARI system are some examples of areas where this improvement was evident.
In all those cases, the submittals and subsequent responses to the staff's inquiries were technically sound and thorough. LILC0 was responsive to the staff's initiatives for enhancement of containment integrity in the event of a severe accident. The LILC0 management recognizes that a number of the areas the staff had suggested for possible improvements were already satisfied by the Shoreham Mark II containment configuration.
Nonetheless, the licensee intends to design and construct a Supplemental Containment System (SCS) which could provide a filtered vent path for relieving containment pressure in the event of a severe accident which threatens containment integrity.
It demonstrates that LILCO is willing to exceed the minimum regulatory requirement in responding to NRC's initiatives for enhancing safety.
During the previous SALP period, we pointed out that apparently because of the litigative atmosphere that surrounds this project, the licensee appeared to be overly cautious in interactions with the staff. This resulted in ambiguities and delays in the submittal of information.
During this SALP rating period, the licensee made notable progress in being more direct and responsive. A number of open and extensive discussions between the licensee's technical staff and the NRR staff took place. Although the representatives from the interveners were present in a number of these discussions, they were non-inhibitive and resulted in productive alternatives to resolve issues, i
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I Based on these observations, the rating for this attribute is Category 1.
D.
Enforcement History The Project Manager has occasionally had the opportunity to participate or observe the inspections and audits at the site during the rating period. The licensee has taken actions to resolve deficiencies, deviations and open items in a satisfactory manner. The licensee's contact with the resident, regional and headquarters personnel was professional.
Based on the Project Manager's observation, the SALP rating for this attribute is Category 2.
E.
Operational Events J
The licensee held the 5% low power operating license during the entire SALP rating period. The Shoreham plant was operated twice, from August 4 to September 1, 1986 and from May 22 to June 8, 1987.
During this SALP period, j
the licensee reported 63 non-security events per 10 CFR 50.72 to the NRC l
Operations Center.
In addition, 48 LERs were issued per 10 CFR 50.73. The only event of significance was the Loss of Off-site Power event (LOOP) on March 18.-
l 1987 when the Shoreham Station suffered a loss of both the Normal and Reserve 1
Station Service Transformers. The licensee's management immediately initiated an investigation and correctly identified the root cause. The analysis was timely and thorough; and the corrective action through procedural modification in the control process was acceptable, j
Based on the review of the reported events and the presentation to the NRC staff following the LOOP event by the licensee's management, we recommend an average-plant rating of 2 for this attribute.
F.
Staffing During this rating period, NRR reviewed and approved two backup Shift Technical Advisors (STAS). This licensing action terminated the Shoreham License Condition 2.c.(7)(a) which requires the NRC approval of the first group of seven backup STAS. The licensee has sufficient licensed personnel to fully staff six operating shifts. With the approval of seven backup STAS, the operating staff appears to be adequately staffed. The licensing staff added four professionals to the division. This aggressive licensee action corrects l
the deficiencies identified during the previous SALP evaluation period. As a result, licensing activities have been thorough and timely.
Considering the l
increased work load associated with the 25% power request and the licensee's ability to cope with it, it appears that the Licensing Division staffing level l
would be adequate for operations exceeding the 5% power level, if such authorization is granted.
Based on the above observation, the rating Category for this attribute is 1.
G.
Training and Qualification Effectiveness During this SALP rating period, LILC0 implemented a number of actions to strengthen training and personnel qualification programs. A separate Training Office was established with substantial increase in personnel and budget.
. The Shoreham simulator has been installed in the new training facility.
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Training programs were being submitted for INP0 accreditation.
In addition, the training and personnel qualification records were being centralized in a computer based system which can '>e accessed by the technical departments.
It is apparent that the LILC0 management recognizes the importance of quality assurance through adequate training and is willing to invest in its personnel resources. However, many of the programs were relatively new and continued NRC attention is warranted.
l Based on the above observation, the SALP rating for this attribute is Category 2.
H.
Housekeeping and Control Room Behavior
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The licensee generally maintains a high standard for plant housekeeping and cleanliness.
It is evident that management emphasizes the importance of l
physical and radiological cleanliness.
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During two tours of the control room, the Project Manager observed that the l
control room was clean and quiet with no unnecessary personnel present.
The personal conduct of the operating staff and staff crews has always been 1
l observed to be highly professional and helpful.
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l The SALP rating of Category 1 is assigned to this area.
I VI.
CONCLUSION During this SALP rating period, LILC0 has made important progress to improve on a number of attributes; most notably in the areas of technical interactions with.the NRC staff, staffing and training and qualification. These improvements demonstrate the commitment and involvement of LILCO's senior management to assure safe operations and to obtain authorization to operate Shoreham above 5% power. However, a number of programs were relatively new and continued attention by the NRC staff is warranted.
The licensee's greatest strengths appear to be in the following areas:
Management Involvement and Control in Assuring Quality - Involvement and commitment to quality by the licensee's management is vigorous and innovative. The result is apparent in the high quality of submittals and the resolutons of many technical issues.
Responsiveness to NRC Initiatives - It is apparent that the licensee's management believes that extra efforts beyond the minimum regulatory requirements is warranted for Shoreham in view of the litigations in the licensing proceedings.
Responsiveness to NRC safety initiatives has been
.l outstanding.
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8-The following area needs attention:
Training and Qualification Effectiveness - The Training Office is new and a number of ambitious programs are being undertaken.
NRC's continued attention is needed in this area to assure the accomplishments that these new efforts sought to achieve can be fully realized.
Based on the evaluation of the above criteria, an overall SALP rating of I
Category 2 is assigned to the area of " Licensing Activities" l
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Record of Meeting and Official Documents
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NRR/ Licensee Meeting
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Licensing Status 08/01/86 09/04/86 10/16/86 l
11/25/86 01/13/87 1
02/19/87 i
04/22/87
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Fire Protection.
10/02/86 f
I DCRDR 11/03/87 1
25% Power 04/30/87 j
Supplemental Containment System 07/21/87 2.
NRR Site Visits / Meetings I
Emergency Planning 05/29-06/05/86
' Management Discussions 03/12/87 a
25% Power 05/12-05/13/87 3.
Commission Meetings None l
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Schedular Extensions Granted None l
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. Reliefs Granted None i
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Exemption Granted 10 CFR 171, Annual Fee 04/20/87 i
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License Amendments Issued i
Amendment No.
Title Date 2
Noble Gas Monitoring 03/04/86
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Process Control Program, 11/03/87 Radwaste Management 4
Radwaste Sampling and 12/09/86 Milk Samples 5
MSIV Setpoint 05/04/87 6
SLCS 05/18/87
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. Other Technical Request Approvals Post Maintenance Testing (ATPS 3.1.3,3.2.3) 04/09/86
- Analysis of Post-Accident RC Samples 05/20/86 Qualifications of Backup STAS 05/07/86 12/09/86 Post-Accident Effluents Monitoring 02/13/87 Appendix R Compliance 02/25/87 l
- ATWS Rule Compliance 06/08/87 r
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Emergency Technical Specification Issues None 9.
Orders Issued Numerous Commission Orders related to EP Proceedings t
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Licensing Activities 1.
Analysis Although a 5% low-power testing license was issued on July 3,1985, controversy surrounding emergency planning issues has, to date, prevented the issuance of a l
full power license. During this SALP evaluation period, the licensee performed I
two rounds of low-power testing. The reactor was critical for a total period of less than 5 weeks. Consequently, the staff has not had to perfonn nearly the number of technical evaluations that might be expected for a plant at this stage of life. Except for issues related to emergency planning,.all pre-full-power licensing issues have been resolved. During this period, two important issues, Appendix R and the ATWS Rule, were reviewed and approved by the NRR Staff. On April 14, 1987, the licensee submitted a request before the i
Commission for authorization to operate Shoreham at 25% power. The request was i
accompanied by an extensive analysis on severe accidents at 25% power level and the demands on emergency planning under those circumstances. Although the NRR I
technical review was suspended following the Ccmissions' ruling on July 11, 1987, the licensee's interaction with the NRR staff during the review demonstrated that its staff has significant technical capability and thorough understanding of the Shoreham plant and its safety systems. These attributes -
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will become important factors in future performance if and when the licensee is authorized for operations above the 5% power level.
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I During the previous assessment period, it was noted that the licensee's I
analysis accompanying its requests for license amendments were perfunctory and I
with a minimal amount of bases.
It was also noted that the licensee's responsiveness was slow on issues not on the critical path for full-power licensing. Those concerns were attributed to twc fundamental causes.
- First, I
the. licensee had an overly cautious attitude about formal submittals tc the NRC because of the atmosphere of litigation that surrounds this project. A second cause appears to be understaffing in the licensee's licensing organization. Since the beginning of this evaluation period, the licensee has taken aggressive actions for improvement. Although the atmosphere of litigation has not abated, the corrective actions taken by the licensee's senior management produced notable improvements in the area of licensing activities.
Management involvement in the licensing area has been intense. Progress in licensing activities were not inhibited by the effort necessary to support two Licensing Board hearings related to emergency planning contentions. The Licensing Division management met with the NRR Project Manager and technical reviewers on a regular basis to discuss the status and progress in the resolution of open licensing actions. These meetings were often attended by representatives from the interveners. Nevertheless the discussions were open, non-inhibitive and extremely productive.
In addition, the licensee's Licensing Division issued weekly summary reports and held scheduled weekly briefings with the licensee's technical department managers.
This close coordination enabled the licensee to substantially improve on the quality of analysis that accompanied the submittals for licensing actions.
In general, these submittals were timely, thorough and of high technical quality.
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l The licensee's responses to resolve safety issues continued to be technically l
sound. During this SALP evaluation period, the NRR staff completed its. review l
of the outstanding issues related to fire protection. The fire protection l
issues related to the control of the ADS and the controls of high-low pressure systems interfaces in the event of a severe fire in the control room. The 1
l approach by the licensee to resolve these issues showed a clear understanding of the plant systems and the analyses performed were realistic and yet allowed for substantial safety margins to exist. There were, however, other cases l
where the licensee's initial submittals appeared to be superficial and required the NRC staff to probe for alternatives and solutions. Two of those cases were issues related to quantification of post-accident effluents (NUREG-0737, Item II.F.1) and the surveillance requirements of the Reactor Coolant System Leakage Detection Systems (Inspection Report Item 85-04-12). Although the licensee arrived at technically sound and acceptable solutions, it resulted in substantial delays to close those two issues.
However, it should be noted that
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those two issues were initiated prior to this SAlp evaluation period and do not fully reflect the recent efforts for improvements.
The licensee made good progress in responding to NRC initiated actions. The improved capability of the SLCS, the change of the MSIV set-point and the improved ' reliability of ARI are some examples of these accomplishments.
In addition, the licensee has initiated the conceptual design of a filtered containment vent for enhancement of containment integrity in the event of a severe accident. The staff's initiatives for containment enhancement were primarily directed at Mark I containments.
Nevertheless, the licensee noted l
that a number of areas the staff has suggested for possible improvements were already satisfied by the Shoreham Mark II containment configuration. The licensee's commitment to this major effort demonstrates its willingness to i
exceed the minimum regulatory requirement in responding to NRC's initiatives 1
l for enhancing safety.
l The licensee has made notable progress to be more direct and responsive. This was especially recognized during the discussions the NRC staff had with the licensee on the analysis related to the 25% power request. Although the representatives from the interveners were present at the meetings and obtained copies of all the questions and responses, the licensee's dialogues with the l
NRC staff were extremely expeditious and not inhibitive.
The licensee has added a number of professionals to strengthen its Licensing Division staff. Tne Licensing Division is staffed with personnel who are l
technically competent and knowledgeable about the Shoreham facility.
In addition, the group does an outstanding job in coordinating the efforts I
required from other technical departments. As a result, licensing activities were timely and of high technical quality. Considering the increased workload l
for the 25% power request and the licensee's ability to cope with it, it l
appears that the Licensing Division is adequately staffed for operations exceeding the present 5% power level.
During this SALP evaluation period, the licensee took major steps to improve personnel training. A separate cooperate level Training Office was established with substantially increased stG f and budget. The Shoreham simulator was installed. Training programs were being submitted for INP0 accreditation.
It is apparent that the licensee's management is committed to the improvement of personnel performance through quality training. This effort will result in long term benefits in safe operation of the Shoreham facility.
t i In summary, the licensee has made substantial improvement in the area of licensing activities. This resulted from a number of factors:
intense involvement by the management, strengths in its technical capability, effectiveness of its licensing group and improvements in its training programs. However, a number of these improvements were only instituted since the beginning of this SALP evaluation period. Continued NRC attention to monitor the licensee's efforts is warranted.
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