ML20246C986
| ML20246C986 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Beaver Valley |
| Issue date: | 05/20/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20246C819 | List: |
| References | |
| FOIA-89-226 NUDOCS 8908250211 | |
| Download: ML20246C986 (2) | |
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.F NUCLEAR REOULATORY COMMIS$10N 9
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KIN 3 C F PAU558 A. PENNEYLVANI A 19106 Docket No. 50-412 MAY 2 01987 MEMORANDUM FOR:
Thomas E. Murley, Director, Office of Nuclear Reactor l
Regulation FROM:
William T. Russell, Regional Administrator, Region I l
SUBJECT:
BEAVER VALLEY POWER STATION UNIT 2 OPERATING LICENSE j,
RECOMMENDATION This memorandum provides the Region I assessment and recommendation for issuance of an operating license for Beaver Valley Power Station Unit 2 pursuant to 10 CFR 50.57(a).
This recommendation is based on the Region I evaluation documented in the enclosed Initial Operating License Review Report with special note of the fol-l lowing:
l 1.
The construction and preoperational testing inspection programs have verified that Beaver Valley Power Station Unit 2 has been constructed substantially in conformance to the construction permit and the application, the provisions of the act, and the rules and regulations of the Commission, as required by 10 CFR 50.57(a)(1) and (2).
2.
We have concluded that Duquesne Light Company is capable of operating the plant safely.
While a few systems remain to be tested, successful completion of these activities is controlled by Technical Specifications in such a way that systems required to be operable for a particular mode of operation, in-cluding Mode 6, must be declared operable before that mode is entered.
3.
Each Region I professional employee was requested by memorandum dated January 6, 1987, to-!dentify any unaddressed safety concerns of which they were aware concerning Beaver Valley Power Station Unit 2; no concerns were identified.,
Other significant elements of this recommendation include:
1.
The evaluation is based on more than 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of NRC field inspection to data.
2.
As-built inspections have found substantial conformance between the facility and the FSAR, SER, and Technical Specifications.
3.
Region I independent NDE examinations conducted in 1981, 1934, and 1986 con-
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firmed acceptable weld c,uality, welding and material controls, and implemen-tation of the Beaver Valley Power Station Unit 2 NDE program in accordance with ASME Code commitments.
4.
Inspection of allegations raised to Region I with respect to construction have 1
I identified ra significant hardware impact and no unresolved safety issues.
Two new allegations have come to our attention recently. These allegations 8908250211 890816
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-226 PDR
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Memorandum for Thomas. E. Murley 2
BEY 2 0 W are being evaluated in accordance with regional procedures.
A preliminary evaluation of these allegations indicates that they do not raise significant hardware or safety issues that would preclude issuance of a license permitting leading fuel and operations up to five percent rated thermal power.
During initial operations as part of routine inspections, plant and staff conform -
ance to license ccnditions and Technical Specifications, including operability requirements for the various operational modes, will be reviewed upon license
. issuance and frequently thereafter.
In' conclusion, I found that Beaver Valley Power Station Unit 2 has been constructed substantially in accordance with Construction Permit CPPR-105, the Beaver Valley Power Station Unit 2 Final Safety Analysis Report, and NRC regulatory requirements.
.I also found that, subject to the license conditions of Attachment I to NPF-64, the licensee is' capable of operating their plant.
A.T
- "A.A William T. Russell.
Regional Administrator
Enclosure:
Initial Operating License Review Report cc w/ enc 1:
V. Stello, ED0 J. Taylor, DEDRO R. Starostecki, NRR
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Thompson, NMSS F. Miraglia, NRR
- 5. Varga, NRR B. Boger, NRR J. Stolz, NRR P. Tam, NRR W. K6ne, RI W. Johnston, RI T. Martin, RI E. Wenzinger, RI L. Tripp, RI J. Benil, RI l
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INITIAL OPERATING LICENSE REVIEW REPORT FOR BEAVER VALLEY POWER STATION, UNIT 2 DOCKET NO. 50-412 PREPARED BY:
UMITED STATES NUCLEAR REGULATORY COMMISSION l
REGION I l
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TABLE OF CONTENTS PAGE 1.0 Introduction...................................................
1 2.0 Overview of Plant Status.............................................
2-3.0 Facility Construction................................................
3 E
'3.1 Overview and Status.............................................
3' 3.2 Inspection Program History and Findings..........................
3 3.2.1 Routine Region I Inspection Program......................
3 3.2.2 NRC Special Inspections..................................
4 3.2.3 Thi rd Party Audi t s and Eval uation s.......................
11 3.3 Quality Assurance for Construction..............................
12 34 Facility Construction Summary and Conclusion....................
13 4.0 Facility.Preoperational Testing......................................
.1 -4 4.1 Overview and Status.............................................
14 4.2 Inspection Program History and Findings.........................
14 4.3 Facility Preoperatione.i Testing Summary and Conclusions.........
15 5.0 Facility Preparations for Operations..................................
16 5.1 Overview'and Status...............................,.............
16 5.2 In spection Prog ram Hi sto ry and Fi ndi ng s _........................
16 5 2.1 Facility Operations - Staf fing and Programs..............
16 5.2.2 Quality Assurance for 0peraticns.........................
17 5.2.3 Emergency Preparedness Facilities and Program............
18 5.2.4 Radiological Controls and Fael Receipt...................
TO 5.2.5 Security Facilities and Programs.....,...................
20 5.2.6 Fi re Protection Facilities and Programs.................
21 5.2.7 Te chni ca l Spe ci fi cati en s................................, 21 5.3 Startup Test Pregram........................................... 21 l
6.0 Enforcement History..........................
23 7.0 Systen.atic Assessment c' Licensee Performance (SALP)................
24 7.1 Overview ar.d Status.............................................
24 7.2 First SALP.......................................-..............
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'7. 3 Second SALP.....................................................
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7.4 Third SALP......................................................
25 7.5 Fourth SALP.....................................................
25 7.6 Fifth SALP......................................................
26 7.7 Sixth'SALP......................................................
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'7.8 Seventh SALP.....................................................
'27 8.0 A11egations...........................................................
28 9.0. Future Region I Actions...............................................
29 10. 0 S umma ry a n d C o n c l u s i o n s..............................................
30 LIST OF ENCLOSURES Enclosure' Title 1
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Special-Assessment of Quality of Construction of Beaver Valley Power Station, Unit 2 2
Summary of SALP Evaluations 3
luspection Program Annual Breakdown (Hours) 4
. Inspection Summary l
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1.0' Introduction Duquesne Light Company (DLC) and joint applicants applied.for a license to construct Beaver Valley Power. Station, Unit 2 (BVPS-2) on October 20, 1972..
Construction Permit CPPR-105 was issued on May.3, 1974.
BVPS-2 is: located on' a 501-acre site, predominantly owned by DLC, in' Shipping-port Borough,. Beaver County, Pennsylvania, on the south bank of the Ohio River.
The site is approximately 25 miles northwest of Pittsburgh, Pennsylvania, and 5 miles east of East Liverpool, Ohio.
Immediately to the west of the BVPS-2 E
reactor location and also onsite are the Beaver Valley Power Station, Unit
.1 (BVPS-1) and the Shippingport Atomic Power. Station (SAPS). BVPS-1 is a-similarly designed reactor.
SAPS terminated operation October 1, 1982, and is in the process of being decommissioned by the U.S. Department of. Energy (USDOE).
BVPS-2 is a three-loop pressurized water reactor. nuclear steam supply system (NSSS) furnished by Westinghouse Electric Company (WEC). ~The turbine generator
.is also furnished by WEC. The plant is similar in design to BVPS-1 and other plants recently licensed by USNRC. The balance of the plant,. including the containment structure, was designed and constructed by the applicant with the assistance of their agent, Stone and Webster Engineering Corporation (SWEC).
The NSSS is designed for a warranted power output of 2660 MWt with an elec-trical output of approximately 836 MWe.
'DLC has operated BVPS-1 since its licensing in 1976 and was the manager of SAPS for the Division of Naval Reactors, USDOE, for more than 20-years.
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USNRC Region I began performing inspections at.BVPS-2 in 1973 and has com-pleted over 200 inspections totalling over.20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />..These inspections involved observation of work in progress, examination of completed work, re-view of work control docuruents, independent measure:aents and calculations, and examination of quality records.
This report describes the process used by the applicant to ronitor and control l
the quality of construction and preoperational testing, discusses the results l
of independent evaluations of the applicant's performance, and addresses bcth
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the inspection program and the Systematic Assessment of Licens9e Performance i
conducted by Region I.
The report also addresses facility preparations for i
operation.
This report presents the basis for the P,egion I conclusion that (1) Beaver
-l Valley Power Station, Unit 2 has been capstructed subt,ttntially in accordance l
with Construction Permit CPPR-105, the Final SOcty Analysis Report (FSAR),
j and USNRC. regulations; and.(2) Duquesr.e Light Cesmpany is ready to operate the facility rafely.
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2.0 Overview of Plant Status p
Construction of BVPS-2 is essentially complete. Buildings, systems, and equipment necessary to support pending operations have been turned over to l
the station staff. Some construction such as main steam isolation valve re-placement, cable wrap and tray cover installation, and other miscellaneous work activities such as painting remain to be finished. Additionally, some minor 1 construction activities in the turbine building remain. - Preoperational L
testing activities are nearly complete.
Some tests remain to be completed and some test exceptions in the areas of Loss of Offsite Power testing and Auxiliary Feedsater Pump testing remain to be closed out. Where system tests are not cemplete or rework is ongoing (i.e., resolution of construction de-ficiencies identified per 10 CFR 50.55(e)), the Technical Specifications will' govern the operability of systems and equipment in the mode for which they are needed.
During the course of NRC inspection and investigation activities at BVPS-2; over 1,000 inspection items requiring tracking and followup have been opened.
These items include enforcement actions and allegation followup activities as documented in other sections of this report, routine bulletins, circulars, construction deficiency reports, unresolved items, and program weaknesses-
' identified by'special team inspections. Approximately 25 of these NRC in-spection items remain open, the other items have been closed _in NRC inspection or investigation reports, as appropriate.
The status of outstanding items is continually being assessed and updated as Region I inspection activities continue. At this time, no open inspection item, currently outstanding, is deemed of'such significance as to affect the Region I recommendation for 1ssuance of a low power license.
Testing exceptfons noted during the conduct of Hot Functional Testing required retesting cf the Auxiliary Feedwater System. Successful completion of limited j
additional hot testing during the applicant's planned post-tcel load, hot
- functional tests to close the open tett exceptions 'Is cr:ouired prior to in-itial criticality. This matter is governed by Technical Specifications.
In terms of readiness for operation, no major impediments to the low power license issuance have been identified. Procedural preparation end validation continue and it is anticipated that all procedures required for a particular mode uf operation will be approved end issued prior to the plant entering that i
' w>de.
The applicant has demonstrated edequate managemnt of BVPS-2 construction and testing act' vities.
In summary, SVPS-2 is deemed reacy for safe icw power operation and testing.
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3 3.0 Facility Construction 3.1 Overview and Status The construction of BVPS-2 is essentially complete. Region I inspections of construction activities have been conducted in accordance with the program established by the Office of Inspection and Enforcement. The objective of these safety inspections is to obtain sufficient information through direct observation in the field, personnel interviews, and review of procedures and records to determine whether construction and installa-tion of safety-related components, structures, and systems meet applic-able requirements. A significant portion of the inspection effort is directed toward inspection of the applicant's Quality Assurance Program and its implementation as described in both the Preliminary and Final Safety Analysis Reports.
This program has been reviewed by the NRC and accepted as documented in the Safety Evaluation Report.
3.2 Inspection Program History and Findings 3.2.1 b utine Region I Inspection program Initial NRC inspection activities commenced at BVPS-2 in 1973.
Anncunced and unannounced Region I inspections have been con-ducted since that time at a frequency consistent with the pace of construction activities as work progressed. With the in-ception of the resident inspection program at BVPS-2, day-to-day NRC onsite coverage of construction work has been provided and supplemented by adoitional inspections by Region I specialist inspectors.
_6 A Senicr Construction Resident Inspector was assigned to BVPS-2, August 5, 1981. Adfitional resident inspection resources were dedicated with the assign'nent of a Construction Resident In-spector in October L84.
Currently, there are two Operations Resident Inspectors on site, who devote apprm imately uno-half of their efforts to Unit 2.
They have inspected the conduct of most of the preoperationa'i test program, including the series of tests integrated into the Hot Functional Tes;ing j
program.
By direct observation, independent verification, i
dai'iy presence, and beth routine and reactive inspection, the
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resident inspectors have previded an additional measure of assurance that the quality of construction r.nd testing has beei achieved and maintained.
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In general, Region I inspection resources have been directed i
to the verification of quality performance in the areas of l
soils and foundations, containment and other safety-related j
structures, piping sys*, ems and supports, safety-related cor:-
l ponents, support activities and systems, electrical power sup-ply and distribution, instrumentation and control systems, l
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quality assurance, management controls, design and design change control,.and corrective action effectiveness. Enclosure 4 identifies the inspections performed, the areas inspected, and significant inspection findings. To date, over 200 in-spections have been performed for BVPS-2. A comparison of.
inspection hours with those expended at two recently licensed Region I facilities (taken at 90% construction completion as a reference point for comparison purposes) is illustrated below.
BVPS-2 Millstone Unit 3 Seabrook 1.
12,300 Hours 9100 Hours 15,600 Hours The NRC routine inspection program has confirmed the overall quality of construction and hardware installed in BVPS-2, as well as identified those areas of programmatic concern where applicant management attention and corrective action were neces-sary. NRC concerns have been raised in the areas of: control of measuring and testing equipment, adherence to procedures, storage and protection of equipment both in temporary areas and permanent positions, evaluation and disposition of weld indications identified by radiographs and ultrasonic examina -
tions, cleanliness control during hydrostatic testing, system restoration during preoperational testing, reflection of in-plant changes in preoperational tests, and implementation of the QA program. Weaknesses were also identified in the accept-ance criteria provided to QC inspectors, the calculations and specifications provided by engineering, the engineering dis-position of Nonconformance and Disposition Reports, and evalu-ation of issues potentially reportable to NRC. These issues have been satisfactorily resolved.
3.2.2 NRC Special Inspections L
Seseral special team inspections have been corducted to suppic-l ment the r'outire inspection program and to provide vdditional assuran:e of qt.ality. These inspections are listeo below, in-cluding a c'escription of the inspect 5cn scope and conclusions.
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Redon I Itidepen(eut Measurennts Inscection, July 6-152 1981; inspectj en Rgport 50-412/81-03 l
l The purpose of this inspectica was to perfr,rm an indepen-dect inspectior of the r,eutron shield tank being fabricateo I
at the Pabccck and Wilcox Coapany, Mt. Vernons Indiana.
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The following represents a summary of items examined:
Ultrasonic thickness checks - 4 Lamination scan - 1 l
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I Magnetic particle examinations - I weld and 2 gussets Radiographic examinations - 2 welds No items of noncompliance were identified, b.
Region I Construction Team Inspection (CTI), April 11-29, 1983; Inspection Report 50-412/83-05 The purpose of this inspection was to evaluate the ade-quacy of the applicant's construction and quality assurance programs and the programs' effectiveness in assuring con-formance with regulatory requirements and the applicant's commitments. The inspection also examined interrelation-ships between organizations and interfaces between the activities examined to assess the effectiveness of con-struction quality assurance and design control.
The CTI concluded overall construction management to be a strength of the project as demonstrated by the control of work to assure meeting quality standards.
There was evidence'of cooperation with Site Quality Control (SQC) in the correction and resolution of problems. The ap-plicant demonstrated an effective program for the training of Quality Control and Construction personnel. A strong program for housekeeping, storage, and maintenance of equipment was in place; management involvement in the implementation of the program was evident.
Concerns or weaknesses in the program were noted. The Engineering Department of the Nuclear Construction Divi-sion,.0LC. was ferred in December 1982, but, as of Apriii 1983, no charter for the organization had been established.
Design centrol by the architect engineer site Engineering Group was onef fective with respect to lack of identifica-tion and documeetnion af design impact, discrepancies in reqctrements for electrical groands, defi:foncier, in supervision and centrol of training requirements, and lack
. of identification of qualified reviewers. This resulted in citation of one violacion (Level Y) and three uevi-ations whic'.> have been satisfactorily resolved.
Region I Independent Measu emer.ts Inr.pectiogSepte.rche c.
24 - Octorar 10 1934;__1r,spection Repert' 50-44b84-1T~
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The purpose of this inspectfen was to verify the adecuacy of the applicant's welding and nondestructive examination quality control program. Utiliting the NRC Mobilt Non-destructive Examination (NDE) Laboratory, Region I engf-
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l" neers'and NDE' technicians, assisted by contractor person-nel, duplicated those examinations required of the appli-l-
cant by the regulations and evaluated the results.
In; addition to the required examinations, several other con-firmatory examinations designed to. verify conformance with material specifications were performed and' compared to quality assurance records.
The following represents a summary of items examined:
Radiographic examination: 35 welds.
Penetrant examination: 22 safety-related ASME Class 1 and 2 pipe weldments and adjacent base metal..
Visual examination: 44 weldments.
Magnetic particle examination: 12 pipe weldments, ASME Class 3.
Ultrasonic examination: 97 Hilti anchor bolts.ex-amined for length.
Corcrete test: 3 areas tested to determine compres-sive strength.
Hardness measurement: 19 welds.
Thickness measurement: 40 welds.
Ferrite measurements: 20 pipe welds.
Alby analysis: 9 steinless steel pipe welds to-verify material type.
The inspection revealed no unacceptable conditions and confirmed the validity of the applicant's NDE and the 1
acceptability of the hardware simpled. Licensee records -
vere consideted to be a strength, d.
Reaton I Construction Team Inspection (CTI L Mar.:h 18-29 DEf3p$1on Report 5F412/85-o'/
i The purpose of th h inspection was to determine the ef-I fectiraness of the applicant's management in directing the construction of BVPS-2 in accordance with NRC requirements, applicant commitments, and industry standards. This was accomplished by performing in-depth examinations in the.
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areas of management controls, design contro15, quality -
assurance, and construction including the electrical, mechanical, and piping disciplines.
A coordinated examination was made of the component cool-i~
ing water system by all engineering discipline team mem-bers. Portions of the system were selected and detailed examinations.were made of the piping, supports, valves, l,
heat exchangers, pumps, and electrical components. The examinations consisted of visual observations to verify that the equipment met the drawings and specifications.
The quality documentation was, reviewed to confirm that appropriate inspections had been performed.
An area given snecial attention was that of the engineer-ing construction interface. During the previous year-the NRC had identified a weakness in the area of the engineer-ing/ construction interface. The applicant committed to take several initiatives to attempt to improve performance in this area. An examination was made of these initi-atives and their implementation.
In general, the team concluded that the quality of con-struction was good. No major problems were identified during the inspection.
The applicant made significant overall progress in improving the engineering / construction interface with regard to addressing problems and weak-nesses identified in the 1984 SALP. This involved the initiation and implementation of several programs to cor-rect the problems _and strengthening the Site Engineering Group staff by the addition of key experienced personnel.
There were indications of lingering problems in the ensi-neering/ construction interface for electrical construction activities.
Changes in the project over the past year from a construction-only phase to a construction /startep
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phase resulted in frequent changes in DLC project manage-ment and the Nuclear Construction Division with three differet:t individuals handling the duties of DLC Project Manager. The Dtc Nuclear Construction Division procedures manual was in need of substantial revisfon. No specific site construction problems were atte!buted tc the DLC deficiencies in the prnfect maaagerent trea, s
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m Results: Three violations were identified in the five areas inspected. One in the area of ciectrical construction with several exemples of problems resulted from failure to follow precedures. Another in the area of engineering /
construction interface (electrical) involved failure te maintain or retrieve records to support considerations of side wall pressure in cable pull calculations. The
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8 third violation related to numerous examples of failure to follow procedures involving a lack of attention to de-tail in providing correct administrative information on documents. All violations and concerns identified during this inspection has been satisfactorily resolved.
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Reaion I Independent Measurements Inspection, June 9-20, 1986; Inspection Report 50-412/86-13 The purpose of this inspt ction was to perform an indepen-dent examination of selected piping weldments that were previously inspected and accepted under the applicant's Preservice Inspection Program. Also examined were struc-tural steel weldments. piping supports, and cable tray support weldments to ascertain the adequacy of construc-tion fabrication and of the welding quality control pro-gram to assure safety and reliability during plant opera-tion. QC/QA records were reviewed to ascertain compliance to governing codes, standards, and regulations.
The following is a summary of items examined:
Visual and liquid penetrant examination of 40 fuel rack assemblies.
Visual and liquid penetrant examination of 3 spent fuel racks.
Checks of dimer,sions, support location, support welding, e.ra loose or broken support members of 32 caole tray and conduit supports, and 12 pipe supports.
Visual (weld irspection and surface material er.amina-tion) and dimensional inspection of steeta generator lower support assemblies A, B, and C.
Ultrasonic examination of 16 full penetration weld-meerts or the pressurizer competent suppcrt.
Compressive strer.gth test of concrete pour.ed i<rcund f
the reacte? containment.
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Ultrasersi; exafuination of 20 pfpe Widmer.ts tu verify Edequer:p of the apMicent's prenevice irspection (PSI) progt2m.
4 Two violations wree identified during that inspection; om concerning an unacceptable conditiuh in base material and one concerning liquid penetrant indications in weld-ments.
Both violations have beer resolved.
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Technical' Assurance Audit Program Inspections, June 2-6 m
1986; Inspection Report 50-412/86-17, and July 28-30 and E
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_ August 4-5, 1986; Inspection Report 86,
The purpose of thesel inspections was to evaluate and re -
view the program plan and in-depth technical audits that-verify the design aspects of BVPS-2. -As a_ result of these two inspections, the NRC team concluded thatn
,The Hazards Analysis Program Audit was performed in.
sufficient technical depth and scope to provide an evaluation of the design.in the hazards protection.
area; Design review of the fuel building was performed in sufficient technical depth to evaluate the design process as related to building structure; and The applicant's design basis earthquake (DBE) program is a detailed and thorough confirmation of the in-
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corporation of design commitments as detailed.in the FSAR into project design criteria ~ documents, proce-dures, and other design guidance.
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Region I Appendix R Inspection, March 9-13, 1987: In-spection Report 50-412/87-17 The purpose of this inspection was to verify the appli-cant's ability to shutdown the plant safely in the event of a-fire, and to verify the adequacy of the plant's emergency lighting system and oil collection system pro-vided for the ree nor coolant pumps.
The following were inspected:
The capability to achieve and maintain hot shutdown and the capability to bring the plant to cold shut-o?wn conotti., in the event of a fire in areas where remote shutd:t capability is provided.
Fire protection features provided to maintain one train of equipment needed for safe shutdown free from fire damage.
The emergency lighting system for areas of the plant required for safe shutdown.
Cable tray supports in the cable spreading room were noted to be unprotected, contrary to guidance contained in Generic Letter 86-10. The applicant could not determine i
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if qualification tests had been performed on the unpro-tected supports.
This item must be resolved prior to criticality (Unresolved Item 87-17-01).
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Region I As-Built Team Inspection, March 16-27, 1987; Inspection Report 50-412/87-20 The purpose of this inspection was to verify that. selected systems had been constructed with an acceptable level of quality and in substantial conformance with NRC require-i ments, applicant commitments, and design specification.
Systems selected for inspection were those associated with i
meeting reactor safe shutdown and core cooling require-ments.
The inspection included portions of the following:
p Reactor coolant and high and low pressure safety injection systems.
Control room, control building, battery rooms, and diesel generator building HVAC systems.
AC and DC electrical power systems.
Instrumentation and control systems associated with RCS loop 3, high head safety injection pump C, and low head safety injection pump B.
The Piping Stress Reconciliation Program and Building Loads
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Verification Program were inspected.
Based on the sample of systems and hardware inspected, e
the "as built" condition of the plant was concluded to be substantially in accordance with NRC requirements and applicant commitments and of acceptable quality.
Two minor violations resulted from this inspection:
Multiple examples of failure of applicant QC inspec-tions to identify minor hardware and labeling de-ficiencies.
Failure to identify by proper color coding the as-signed electrical chain or channel of certain safety related electrical equipment.
Many of these deficiencies were corrected soon after identification. All were minor in nature.
None of the deficiencies affect equipment operability or issuance of an operating license.
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Region I Technical Specifications Inspection, March 30 -
April 10, 1987; Inspection-Report 50-412/E7-34 The purpose of this inspection was:toLinspect p1' ant sys-tems, structures and components'.which have particular-significance in_ minimizing the' severity of potential.acci-dents and accident consequences, to~ determine whether:the draft Technical-Specifications (TS) and the Final Safety )
Analysis Report (FSAR)'are compatible with the as-built l
plant configuration and operating characteristics. A -
E secondary purpose of the inspection ~was to~ ensure that l
the draft TS requirements are measurable.
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' Systems involved included: containment and support systems, containment spray systems, emergency core cooling systems, I ;'
soluble poison (boron) reactivity control systems, elec-
'trical power systems, auxiliary feedwater system,. service-water system, and ultimate heat sink.
Except for minor discrepancies, TS were found to be de-finitive and compatible with the as-built plant. The-applicant's programs for establishing and implementing surveil. lance and operating procedures responsive to'TS were in place.
The Technical Specification preparation and implementation process appears to be functioning properly. The TS and implementing procedures reviewed appear to be compatible with the as-built plant configuration.
That information which'is still under development for in-corporation ir,to the TS and implementing procedures ap-pears to be subject to sufficient management control to assure adequate completion of the process.
Selected specific findings will be subject to hRC re-inspection of applicant actions as part of the routine inspection program.
3.2.3 Third Party Audits and Evaluations There have been three INPO-sponsored evaluations of the con-struction of BVPS-2. The first evaluation was self-initiated and used the performance objectives and criteria of construc-tion project evaluations developed by INPO as the basis for.
evaluation. This audit was conducted onsite and at the Stone and Webster Engineering offices in Boston, Massachusetts in November 1982. The team included engineers from DLC, Ohio Edison, Toledo Edison, Quadrex Company, and Energy Consultants, Inc. Two more evaluations were conducted by INPO personnel
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during May 1983, and November and December 1984. These teams evaluated the areas of organization and administration,. design control, construction control, project support, training,
-l quality, and test control at both the BVPS-2 site and Stone and Webster offices. They also observed work and test per-formance onsite.
3.3 Quality Assurance For Construction The QA program for Beaver Valley Power Station, Unit 2 is described in the PSAR and FSAR and has been implemented through the program and pro--
cedural controls dictated by the BVPS-2 Quality Assurance Manual.
During the early phase of construction, the applicant delegated first and second level overview of activities to the project architect-engineer, Stone and Webster Engineering Corporation (SWEC).
SWEC was also re-sponsible for third level overview (audits) of site activities and, in turn, the applicant conducted audits of the architect-engineer on-and off-site.
The applicant continued to enhance'and improve its QA program throughout the construction phase. This resulted in increased applicant involvement so that, approximately midway through construction, a major evolution in QA/QC methodology occurred. The applicant established an expanded QA/QC organization that assumed the first and second levels of quality verification for Unit 2.
(This group was independent of the group per-forming a like function for Unit 1.) The audit group continued their level 3 overview of both units. The second level overview (monitoring and surveillance) function was strengthened as the preoperational testing phase approached in order to maximize scheduling flexibility and optimize staff system testing resources.
Region I has monitored the applicant's construction QA program through the implementation of the routine and special inspections discussed in this report. The consistent performance of the QA controls being imple-mented at BVSP-2 is tracked by the SALP process. The SALP evaluation i
in May 1986 recognized that proper management now is in place to system-atically provide adequate assurance of quality for remaining construction and testing activities.
Enclosure I presents a Special Assessment of the Quality of Construction of BVPS-2 as provided by the applicant's QA organization. The data pro-vided have not been verified by the NRC, but indicate QA activities and actions over the course of Unit 2 construction and testing.
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3.4 Facility Construction Summary and Conclusion At 90% construction completion, over 12,000 inspection-hours had been expended evaluating the quality of construction at BVPS-2. The IE In-spection Program (Manual Chapter 2512) for the construction phase is complete.
Numerous team inspections have been conducted supplementing the Region I routine inspection effort.
Based upon the large number of inspection hours, the enforcement history for facility construction has indicated no major. hardware problems. The highest severity level violation issued was a Severity Level IV. Cor-rective actions by the applicant have been confirmed to have been effec-tive.
Recent NRC. team inspections of the plant and Technical Specification conformance to the plant have found that BVPS-2 has been constructed in substantial accord with the FSAR and NRC requirements. NRC inspection over the course of construction, including reviews and evaluation of the applicant QA program, has confirmed quality hardware and acceptable standards of construction, T
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4.0 Facility Preoperational Testing 4.1 Overview and Status The preoperational test (PT) inspection program began in January 1985 and is appr,ximately 95% complete. The program to date has been con-ducted by b n h resident and region-based specialist inspectors.
Inspec-tions of tet ; procedures, performance, and results were accomplished, along with an overview of management controls to verify proper implemen-tation of the test program and the requisite involvement of the QA or-ganization.
4.2 Inspection Program History and Findings The NRC preoperational testing inspection program (Appendix A to IE Manual Chapter 2513) is approximately 95% complete with all mandatory tests witnessed. The primal tests have received over three times the inspection effort required by MC 2513.
Particular attention was devoted to certain major integrated tests (tot functional testing, reactor cool-ant system hydrostatic test, the containment structural integrity, and integrated leak rate tests).
During conduct of these integrated tests, region-based inspection teams, in conjunction with the resident inspec-tors, provided twenty-four hour sample coverage of the test while in progress. 'In total, over 3600 hours0.0417 days <br />1 hours <br />0.00595 weeks <br />0.00137 months <br /> have been expended to date in the Region I implementation of the preoperational testing program at Beaver Valley Unit 2.
NRC revie.w of selected test procedures indicated an acceptable level of technical adequacy. Witness of the tests confirmed that an adequately staffed and qualified startup test group was in control of test conduct
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and that the QA staff was involved in test surveillance and QC activities.
The Hot Functional Test (HFT) program was conducted smoothly without significant interruption, completing 7 days ahead of the 42 days sched-uled. A moderately small number of test exceptions, 260, remained open t
at the end of the HFT program. As of April 30, 1987, 621 of 878 (71%)
i preoperational test sections had been completed with 259 test deficien-l cies open of 1463 total deficiencies identified. As of May 15, approxi-mately 135 test deficiencies remained open. These deficiencies are being assessed by the applicant and prioritized for completion prerequisite to fuel load, initial criticality, and power ascension. A region-based specialist is following applicant efforts.
The Containment Integrated Leak Rate Test (CILRT) and Containment Struc-tural Acceptance Test (SAT) were successfully completed in February 1987.
The Loss of Offsite Power (LOOP) test was successfully completed May 17, 1987.
Some significant test exceptions have been generated in the course of the Preoperational Test (POT) program, A significant exception is the main steam isolation valve (MSIV) item. Generic mechanical problems with i
0 15 these valves had been identified early in the POT program. A well-con-ceived recovery plan consisting of removal of valve internalsLto permit conduct of the HFT program was effective. On March 16, 1987, the appli-cant announced the decision to replace the main steam isolation valves-(MSIVs) with a three-week delay in project fuel load and subsequent-milestones. Hot functional testing of these valves remains to be com-pleted.
Additional hardware p'roblems were encountered with reactor coolant pump (RCP) C and charging pump C.
In the case of RCP C,'two pieces of a sheet metal personnel safety guard from a steam generator became lodged in the pump. The pump was repaired prior to HFT Charging pump C did not meet output requirements; the problem was successfully addressed by the-applicant.
NRC review of the applicant's preoperational testing process has confirmed an adequately managed program with quality test objectives being met and.
generally acceptable test results being achieved.
4.3 Facility Preoperational Testing Summary and Conclusions As' discussed earlier in this report, a minimal number of actual hardware problems were identified in the construction of Beaver Valley 2..The good test results attained by the preoperational test program to date provide additional assurance of-the adequacy of Unit 2 construction.
Only two. violations were issued against the preoperational area since the initiation of the reoperation inspection program in 1985.
As described in the FSAR, some preoperational tests are to be conducted after core loading. Additional retests were also required to be per-formed after core loading to resolve test deficiencies based on the priority listing.
Further Region I inspections will be conducted after core loading to close out the preoperational test activities. Overall, a high'1evel of performance was found to exist in the licensee implemen-tation of the testing program at Beaver Valley 2.
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5.0 Facility Preparations for Operations 5.1. Overview and Status Procedural preparations and validation continue and it is anticipated that all procedures required for a particular mode of operation will.be approved and issued prior to'the plant achieving the applicable mode.
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Activities in preparation for initial fuel load are being closely moni-tored by Region I.
Facility staffing, personnel qualifications, training and procedure development, and implementation and establishment of opera-tional organization interfaces have been reviewed. These reviews indi-cate that the applicant has an effective program in place to support the operational phase.
5.2 Inspection Program History and Findings 5.2.1 Facility Operations - Staffing and Programs DLC will operate and maintain BVPS-2.
Responsibility for Nuc-lear power operations is assigned to the Nuclear Group which is headed by a Senior Vice President. This individual and the Nuclear Group are located at the plant site. The Senior Man-ager, Nuclear Operations, reports to the Senior Vice President and will be responsible for operations, maintenance, radio-logical controls, and planning when the unit enters the operat-ing phase. The Vice President, Nuclear, also reports to the Senior Vice President and is responsible for management of the following: Nuclear Construction, Nuclear Training, Administra-tive Services, and Nuclear Safety. Additionally, the Offsite Review Committee reports to the Vice President, Nuclear.
A summary of operator experience, training, and initial licens-ing status is presented below.
BVPS-2 currently has 10 licensed senior reactor operators and 6 licensed reactor operators. A second examination for an ad-ditional'20 candidates is planned for the week of May 18, 1987.
All candidates have completed a cross-training program which j
was approximately eight months in length. The program included classroom training on system differences between Unit I and Unit 2, in plant familiarization, lectures on procedures and technical specifications, and simulator training. All candi-dates who entered the cross-training program have completed the Unit 1 training program.
l All candidates in the first group have previously been licensed on Unit I at either the operator or senior operator level.
Fourteen of the second group were previously licensed elsewhere.
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. Twenty-seven Unit =2. license candidates have been licensed on' Unit.1 for over two years.
Seven candidates have just recently beenflicensed on Unit 1 but have no operational experience'on Unit 1...Three of the remaining candidates have. extensive.
operating experience at the Shippingport Atomic Power Station.
The, loss of 34 licensed operators at Unit 1 should not'present a problem since Unit _1 presently has 94 licensed operators.
Only four candidates.who sat for the' January 23,- 1987, examina-tion hold college degrees; three degrees were in geology, mathematics,.and physical. education. Within the second group of candidates were. ten' degrees in science (BS), one degree in.
- sociology; one MS in education (undergraduate degree in physics); and two associate degrees, one in' electrical tech-nology and the other in. pollution' control.
Results of the. January 23, 1987, examinations. indicate that the candidates are adequately traired. The cardidates'were-evaluated as having an above average understanding of the Emergency Procedures and the bases for the procedures. The candidates displayed some weaknesses in-the area of systems and equipment which were unique to Unit 2.
Also the candidates
' displayed some unfamiliarity with the locations of components-and equipment outside the main control room. Of the 19 candi-dates, 2 SR0 and 3 RO candidates did not pass.
A proposed revision to the BVPS-2 operations organization com-pletely separated t5e Unit I and Unit 2 Operations Departments.
As a. result, no operator at Beaver Valley will be dual-licensed on Unit 1 and 2.
A proposal by the applicant to dual-license senior reactor operators may be made after Unit 2 has.been operated at power.
As stated above, initial examinations indicated that the can-didates for licenses at BVPS-2 are adequately. trained. The fact that most of the operators have been previously licensed on Unit I and have had a significant amount of operating ex-peribnce provides assurance that'the applicant will be able to safely operate the facility.
5.2.2 Quality Assurance for Operations c,-
The quality assurance for operations is described in Section 17.2 of the BVPS-2 FSAR.
Based upon the staff review and as documented in the SER, the BVPS-2 QA_ program was determined to describe requirements, procedures, and controls that, when properly implemented, comply with the requirements of 10 CFR 50, Appendix B.
Also, the organizations and persons performing QA functions appear to have the required independence and authority to effectively carry out the QA program.
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18 Commencing in November 1986, Region I initiated several opera-tional readiness inspections at BVPS-2 to review, in part, the Operational QA Programs structure and implementation in such d'iverse areas as administration, audits, procurement control, receipt and storage, records, document control, maintenance,
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design changes and modifications, test and measurement equip-ment, and surveillance testing. The inspection modules associ-ated with these QA program activities are essentially complete.
The applicant QA organization's effectiveness to identify and effectively resol u deficiencies was a concern to the staff near the end of construction.
Licensee management did not l
appear to employ the quality organization to its fullest cap-ability. This area will continue to receive review during the inspection program.
An integrated Startup Group was established and a QA Manual was developed that defined and described various organizational responsibilities and requirements. This group's responsibili-ties begin at the turnover of systems (or parts of systems) from construction, continue through preoperational and startup testing of these components / systems, and end with the accept-ance of the component / system by plant operations. The imple-mentation of the QA program appears to have provided the neces-sary assurance that the plant is ready for the operational phase.
Region I inspections will continue to review the ef-festiveness of applicant management involvement and quality verification activities.
5.2.3 Emergency Preparedness Facilities and Program A meeting was held between NRC Emergency Preparedness staff and senior applicant staff in January 1987 to discuss the Emer-gency Preparedness Implementation Appraisal (EPIA) for Unit 2 and determine the readiness of the program to receive an EPIA.
The inspectors noted at that time, that final installation and turnover of certain essential equipment (Digital Radiation Monitoring System), formal review and approval of the Unit 2 Emergency Plan and Emergency Plan Implementing Procedure (EPIP),
and training of emergency response personnel on new procedures were incomplete.
The EPIA was conducted at the site during March 1987 and the inspectors found that the progress made by the applicant in completing the outstanding items was less than expected.
It was determined that:
The Unit I and Unit 2 Emergency Plan Implementing Proce-dures (EPIP) had been drafted but had not been completed; l
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19 Training had been conducted on the draft procedures and J
the Plan, but was noted to be inadequate in some areas; I
Training for the Beaver Valley emergency response staff j
might be required on final procedures and new hardware will be necessary; i
Portions of the draft Plan and EPIPs needed to be reviewed for completeness (i.e., Emergency Action Levels, notifi-cations, Dose Assessment, and Protective Action Recommen-dations);
A wall still existed between the Unit I and Unit 2 Control Room which does not allow for sharing common equipmer.t (presently in Unit 1) for emergency response (i.e., MIDAS, meteorological data);
Designated emergency preparedness equipment such as the Digital Radiation Monitoring System (DRMS) was not yet available; Necessary auxiliary equipment or instrumentation had not been installed, calibrated, or operationally tested; and The Technical Support Center did not have all of the re-quired information and documents (selected as-built draw-ings) to support an emergency.
A follow-up inspection to the EPIA was conducted April 21-23, 1987.
This inspection concentrated on those items prerequisite to fuel load including a review of the approved Emergency Plan and EPIPs; installation, acceptance, operability of required equipment; and observation of changes made to emergency re-sponse facilities.
The follow-up inspection indicated that some items necessary to support fuel load remained incomplete.
These included station assembly areas, turnover of the evacu-ation alarm, and placement of the emergency equipment.
These items will be required to be completed prior to fuel load.
Other items identified, such as weaknesses of certain facili-ties (e.g., alternate EOF), the completion of calibration pro-cedures for non-radiation process monitors, training on final i
procedures and equipment, and furnishing of as-built drawings to the Technical Support Center, must be completed prior to commencing power ascension.
An inspection which includes walk-throughs of the operating staff to determine training effectiveness for response to Unit 2 procedures will be conducted prior to criticality.
20 5.2.4 Radiological Controls and Fuel Receipt s
i The first shipment of new fuel was received onsite and unloaded 1
on September 3, 1986.
Four inspections have been conducted l
by region inspectors, two in the area of radiation protection and two in effluent controls' and chemistry programs since that time.
Resident inspectors have also performed routine reviews:
h of these program areas.
The onsite Chemistry and Health Physics' staff has been' organized to support operation of both units. The Radiological Controls organization and staff will be common to both units;-however, a different Director of Radiological Operations will be as-signed for each plant. There will be some common procedures, equipment, and facilities.
The applicant has adequately identified priority items that are currently being addressed prior to operation. Preoperational testing of the Digital Radiation Monitoring System has not been completed.. Advanced planning'to identify and track items based on plant differences and on program areas to be upgraded was evident.
Licensee intent to make major capital purchases of high quality equipment, to improve the overall quality of pro-cedures, and to improve exposure control by adding additional physical access control to various radiation areas were noted.
The effluent control responsibilities are' shared by separate organizations, Chemistry and Radiological Controls. Review indicates that the applicant has established an organization to support combined Unit I and 2 operations. Separate unit responsibilities are provided below the chemistry Supervisor and kadcon Foreman.
Permanent staffing of these organizations' is almost complete. The applicant adequately' completed develop-'
ing the preoperational test procedures for the effluent moni-tors, process sample stations, and radioactive waste systems.
Liquid and process sampling system preoperational testing is in progress, and is adequate to date.
5.2.5 Security Facilities and programs An inspection was conducted.in January 1987, the results of which indicated that work to integrate Unit 2 into the Site Security Program was significantly behind schedule. During a mid-February meeting with the applicant, the applicant con-firmed that the security program could be a critical path item.
Subsequently, the applicant applied additional manpower re-sources to the program.
The Site Security Plan was submitted February 19, 1987. During a meeting at that time, the appli-cant affirmed the completion of a significant portion of the wL- _ - __ _ - ---
g3 previously remaining work and projected integration of Unit 2 with the Site program by mid-April. On April'13, 1987, the=
applicant implemented the security plan for Unit 2 protected :
area; however, additional. measures for vital areas were not '
implemented at that time.
Inspections in April and early.May 1987 indicated that'there are no outstanding items that could preclude fuel load.
5.2.6 Fire protection Program-and Facilities In February 1987, an NRC inspection of the fire protection.
program was conducted to assess readiness to load fuel. The program was found to be well established.
Certain activities have not been completed (e.g., testing of carbon dioxide and halon gas systems, fire brigade training, surveillance test reviews, and installation of a number. of. fire barriers). While work is progressing in these areas,.it is.
possible that not all fire barriers will be completed by fuel load.
The applicant was advised that.in this event the NRC must be informed and any compensatory measures approved.
An inspection of fire protection. features that ensure safe shutdown capability in the event of fire-(Branch Technical Position BTP9.5.1) was completed March 15, 1987.
1 5.2.7 Technical Specifications (TS)
The " proof and review" copy of the BVPS-2 Technical'Specifica-tions was provided to the applicant in January 1987. A review of these TS was conducted from March 30 - April 10, 1987 by the NRC.with contractor support.
The purpose of the review f
is to ensure the TS accurately reflect an appropriately control the plant in its as-built configuration.
The TS were found to be definitive and compatible with the as-built plant. The applicant's program for establishing and im-plementing surveillance and operating procedure responsive to j
TS were in place.
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5.3 Startup Test Prograin 1
i The applicant's Startup Test Program was first developed with the initi-I ation of the Reoperation (PO) testing program and continues with the l
Initial Startup Test (IST) program, which encompassed initial fuel load-1 ing, post core loading, and criticality and power ascension testing.
Twenty-eight out of thirty-six IST procedures scoped by the Startup Test l
Abstracts in Chapter 14 of the Beaver Valley 2 FSAR have been prepared, approved by the Joint Test Group (JTG) and Onsite Safety Committee, and L
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' issued. The'. remaining eight.IST procedures are in various stages of the.
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development and approval-process..'Among those, six-IST procedures ~have
.been written and initially reviewed by the JTG.
Region I has. conducted: initial inspections of the Startup Test Program.
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and has.found'the overall status, procedures, organization, and staffing level to be adequate. Controis appear to' be in-place-for. initial fuel loading and initial criticality and low power testing to support applicant
. activities under.the operating license.
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23' 6.0 Enforcement History
.The NRC inspection program uses enforcement measures to promote adherence to regulatory requirements, reduce repeated nonconformances, and encourage self-identification and correction of nonconformances. NRC enforcement measures, that is, Notices of Violations, have been issued when necessary..
The appli-cant has been required to respond.to these Notices of Violations and provide the proposed actions to correct the nonconforming conditions and to take actions.to prevent recurrence of similar violations.
NRC inspectors and management have reviewed and evaluated these responses for acceptability. The inspection staff confirms, during subsequent inspections, that corrective actions are properly completed. The following te.ble gives a comparison of BVPS-2 enforcement statistics with those of two other plants at a similar point in construction.
Early enforcement actions were classified as " violation," " infractions," and " deficiencies (in descending order of -
-severity) while the more recent reports contain violations categorized into severity levels ranging from I to VI (again, in cescending order).
Below is an enforcement comparison through 90% construction completion.
FACILITY CPPR VIOL INF DEF I II III IV V IV TOTAL INSP HRS BVPS-2 5/3/74 0
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0 41 13 0 71 12,300 Seabrook 1 7/7/76 0
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0 44 23 0 100 15,600 Millstone 3 8/9/74 0
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0 24 25 1 54 9,100 In evaluating the NRC inspection enforcement history for BVPS-2, the total of 71 enforceinent items falls midway between that for Seabrook and Millstone
- 3. 'If a comparison were done on the basis of enforcement actions per inspec-l tion hour, all three plants would fall in the same range.
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l 7.0 Systematic Assessment of Licensee Performance (SALP) 7.1 Overview DLC's performance has been assessed seven times under the SALP program.
A tabulation of the results of these assessments is presented in Enclos-
-ure 2.
7.2 First SAlp (March 1~,1980 to February 28, 1981) i Unit construction was 40% complete at the time of the assessment. Areas covered included concrete placement, structural steel welding, pipe welding and radiography, electrical and instrumentation installation procedures, equipment storage, and repair of the neutron shield tank.
A strength was noted in the utility's reporting of construction defi-ciencies (six construction deficiency reports). Three noncompliance were' identified during the period in the areas of used welding electrode disposition, evaluation and disposition of a radiograph indication, and improper storage of a component.
7.3 Second SALP (September 1, 1980 to August 31, 1981)
This assessment had a six month overlap with the previous period. At period end, unit construction was approximately 44% complete.
A high level of management attention and involvement was noted in the.
control of construction activities. This was demonstrated by applicant responsiveness to NRC reporting requirements for construction deficien-cies which could have safety implications, by significant utility atten-tion to NRC Circulars, and by effective management of field quality con-trol efforts. QC management was aggressive in their interfaces with and control of contractor / vendor organizations in pursuit of quality matters and resolution of quality related problems. Additionally, the applicant's day-to-day involvement and coordination with their architect-engineer was noted to be a key factor in successfully resolving individual in-spection related issues.
An extensive NRC inspection, using the Region I NDE van and equipment, of welds associated with piping systems and supports showed excellent correlation with results found in applicant records. This provided as-surance that documentation being generated accurately recorded work that had been accomplished.
,, u A repeat noncompliance was identified in the storage of safety-related I
piping. This weakness continued into the next SALP period.
l Subsequent to NRC inspector identification of inferior welds on cable tray fittings, a number of additional cable tray welds were found to be deficient. The applicant issued a stop work order on installation of all I
safety-related cable tray fittings.
Extensive rework was necessary.
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A three month gap existed between this and the previous assessment period.
l This gap did not impair the. third SALP evaluation since no significant l'
- findings were. identified during that period. At SALP period end, unit construction was 63% complete.
Construction activities in the area of soils and foundations were found:
to be well planned and managed with close monitoring by appropriately l
trained' quality control personnel. Similar conclusions were reached.
l regarding construction of containment and other safety-related structures, and installation of safety-related components'and power distribution equipment.
As noted'in the previous SALP period, the applicant's QC management was aggressive in their interfaces with. contractors in resolving quality matters. This strength was demonstrated in the resolution of two signi-ficant deficiencies in the piping and support welding program. These concerned failures to tag and correct nonconforming conditions in a timely manner and inadequacies in the sampling program used to select fit-up inspections. The applicant reorganized their QC department and hired additional inspectors to. allow closer monitoring of pipe welding activities.
An inspection utilizing Region I mobile NDE. lab indicated that piping and support welds were of good quality with excellent material trace-ability and records.
A widespread, continuing weakness was identified in the storage of items in construction areas.
Performance in this SALP evaluation area was determined to be Category 3.
A corrective action program was implemented which included the following: actions: consolidated the storage program under a single supervisor with authority to immediately correct problems; identified, consolidated, and controlled storage areas; removed voided material; increased management and QC surveillance; and established special " cleanness" zones for items requiring special attention.
Im-provements were noted in this area following the close of the SALP period.
7.5 Fourth SALP (December 1, 1982 t'o March"31, 198d
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At SALP period end, unit construction.was 77% complete. The plant was entering the phase of system checks and turnovers.
Problems in the engineering area similar to those noted in the previous SALP recurred.
It appeared that design documents were not receiving adequate constructability reviews. This led to numerous problems because of unclear or missing design details or incorrect application of design criteria. A large number of design changes and reinspection of piping and electrical supports were necessary because of such deficiencies.
On pipe supports alone, it was estimated that over 6600 pipe supports i
26-would require some degree of reinspection.
Resolution of problems iden-tified with cable separation was slow due to inadequate prioritization.
These later problems were also: attributed primarily to engineering de-ficiencies. The widespread nature and effect of engineering deficiencies contributed to Category 3 performance ratings in three SALP areas (Piping
. Systems and Supports, Electrical Power Supply and Distribution,.and En-gineering/ Construction Interface).
During the SALP period, in response to growing NRC concerns in the engi-neering area, an " engineering confirmation program" was initiated to (1)' assure that a comprehensive engineering data base would be trans-ferred to the facility upon plant completion, (2) assure all licensing and design commitments have been met, and (3) to identify and schedule all remaining engineering activities necessary for licensing and opera--
tion.
Following the SALP, actions were taken to improve the engineering /-
construction interface. -These included establishment of a construct-ability review group onsite, drawing clarifications, a program to provide feedback on clarity of engineering instructions, senior management in-volvement in the trend reporting program, increased management presence in the. plant, and organizational changes which strengthened OLC's control of the project.
Significant improvement over the previous SALP period was noted in the storage of safety-related components.
7.6 Fifth SALP (April 1,1984 to March 31, 1985)
At SALP period end, unit construction was estimated to be 85% complete.
4 Improveme'nt was shown in the engineering / construction interface which was reflected in better performance rating in the three areas of the last SALP which had been categorized as Category 3.
Some lingering engineering / construction interface problems were identi-fied in the electrical / instrumentation area, e.g., retorquing of spring nuts required because proper torque was not specified during installation.
It was determined that additional attention to separation problems in-volving instrumentation tubing and internal panel wiring was needed.
The Quality Assurance / Quality Control organization was found to be ef-fective in assuring quality through independent audits, daily inspection activities, and reinspection efforts.
7.7 Sixth SALP (April 1,1985 to March 31, 1986) i At SALP period end, unit construction was estimated to be 93% complete.
An overall improvement trend continued.
Specifically, management atten-tion and involvement resulted in Category 1 assessments in four func-tional areas.
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0 A general: concern was expressed that the NRC continues to identify prob-lems that should have been identified and/or prevented by applicant con-trols.
It appeared that applicant overall review and control activities were too narrowly focused on "backend" activities (i.e., QC inspection to assure.that installation is in_accordance with specifications and' drawings)._ " Front end". activities were often the root causes of problems and did not"always receive adequate review (with attention to detail) and management attention. For example, more emphasis needed to.be placed on whether design / installation meets criteria and is capable of perform-ing its intended function.
Recognition was given to several positive, successful applicant efforts.
These included the Ir.tegrated Construction Support Group, Constructabil-ity review teams, engineering confirmation program, quality improvement management program, establishment of a separate Quality Assurance group responsible for QA/QC of startup activities, and use of an Electrical Plan to track and resolve outstanding electrical / instrumentation problems.
7.8 Seventh SAlp (April 1, 1986 to February 28, 1987)
Continued improvement in the overall level of performance was' demon-strated during this assessment period. Several applicant initiatives were generally effective in addressing or anticipating problems. These in-itiatives included the Design Endorsement Program for design verification, the Operational Readiness Review Team for assuring necessary procedures and programs are in place for license receipt, and the Quality. Concerns Program for aggressively soliciting potential employee concerns; High levels of management involvement in day to day activities was evident.
Weekly on~ site meetings were attended by the Chairman of the Board thereby demonstrating the active involvement of senior corporate management.
Overall construction activities were found to be well managed with evi-dence of good construction quality levels in installed hardware. The QA program appeared to be somewhat limited as a management tool due to' the scope and priority of its activities. The preoperational test pro-gram was considered to be a notable strength.
Housekeeping was generally good with the maintenance and preservation to turned over hardware also a strength. The applicant made good progress in the area of operational readiness, although some added involvement by NRC was necessary to obtain timely security program development.
Insummary,duringthisassessmentperiod,theapplicantdemonskratedthe ability to coordinate and manage the many related, complex activities that occur at-this stage in project life, i
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h 8.0 ' Allegations Over the course of.-the construction and testing of BVPS-2, 12 allegations were raised. _ Of these,. five dealt with materials' matters and seven with personnel.
Only one of. the personnel-oriented allegations, which is 'still under investi-gation..might be substantiated; the remaining six, including alleging harass-ment / intimidation.were not substantiated. One allegation stemming'from the mishandling of'a spill originating in Unit 1 was not substantiated as alleged (the spill was properly handled as' witnessed by.the NRC Branch Chief and Sec-tion Chief who were onsite); however, a citation was issued.
Two allegations remain open..One deals with excessive use of overtime on the part of the security contractor and the other concerns alleged improper in -
sta11ation of cable wrapping. Both are expected to be resolved from a tech-nical standpoint prior to power escalation.
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'29 9.0' Future: Region I Actions
'Kesion.I. resident and specialist inspections will. continue throughout the startup test program.
Results evaluation will be monitored closely.
An Operational _ Team Inspection will be conducted during the power ascension-program to assess the facility's operational effectiveness, particularly as it pertains to transition from the startup testing phase to normal operation.
l The. inspection will; focus on the adequacy of control-of operational,' surveil-lance testing,-and maintenance activities.
Particular emphasis will be placed on plant management oversight and review of these activities.
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10.0 Summary and Conclusions The.NRC'has expended over 12,000 inspection hours, to'date, at Evaver Valley Unit 2, to. determine'that the plant has been built in accordance with FSAR commitments' and regulatory. requirements and whether management direction was focused on quality. Over the course of the 13 years of construction, the applicant has demonstrated not only a commitment to quality, but a responsive--
. ness to NRC concerns as they were identified, llRC team inspections in the areas of NDE independent. verification, an As-built check of the plant, and a Technical Specification-review confirmed that Unit 2 is a well-built plant, in accordance with the design specifications. The overall theme of the most recent SALP is construction quality, with few iden-tified hardware problems, and preoperational test results which verify these findings.
Where problems-were identified by Region I, early in construction in the case of both QA and Design Change Control, corrective action by the applicant was effectively implemented.
Region I concludes that' Beaver Valley Power Station, Unit 2, has been con-structed substantially in accordance with Construction Permit CPPR-105, the FSAR, and NRC requirements, Certain construction and testing activities are still in progress and therefore Region I has recommended the appropriate
-license conditions. Considering the recommended license conditions, the overall Region I conclusion is that the applicant has taken all necessary actions to permit NRC issuance of an operating license.
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ENCLOSURE 1 SPECIAL ASSESSMENT OF THE QUALITY OF CONSTRUCTION OF BEAVER VALLEY POWER STATION UNIT 2 NOTE: The data in this enclosure have been compiled by the applicant's Quality Assurance staff. The write-up and information is essentially a applicant analysis and assessment.
No effort has been made by the Region I staff to verify the data or information, nor have they been used in the staff evaluation.
Duquesne Light Company as agent for the CAPC0 group of utilities has and continues to employ a group of management, engineering, operations, and support personnel who have extensive knowledge and experience in the design, construction, and opera-tion of nuclear power plants.
The Duquesne Light experience extends from the initial construction and subsequent 25 years of operation of the Shippingport Atomic power Station starting in 1955.
In addition, Duquesne Light personnel have been directly involved in the design, construction, operation, and maintenance of the Beaver Valley Unit I nuclear power station since 1969.
Experienced personnel in all phases of plant activities have been assigned to the Beaver Valley Unit 2 (design similar to BV-1) since 1974 and have successfully brought the plant to its present initial startup testing status prior to the scheduled fuel load date of April 30, 1987. The Stone and Webster and Westinghouse organizations have performed in similar roles as A/E constructor or NSSS supplier associated with all three plants.
i The construction QA Program at BV-2 has been particularly effective as a result of the Duquesne Light direct management and supervision provided by its personnel.
This program is described later in the document.
A Quality Concerns program has been in effect to provide an opportunity for all site personnel to indicate any concerns related to the quality of any phase of plant instruction in a confidential manner. To date, no significant quality con-cern has been identified which would result in rework of plant construction.
Each individual must indicate in writing the opportunity for an interview prior to com-pletion of site employment for any reason.
- ,g In 1985 the Quality Improvement Management Program (QIMP) was instituted to promote the participation of Contractor Management in reviewing quality performance indi-cators, assessing the causes for adverse performance trends and instituting cor-rective measures for performance improvement.
The NRC Region I personnel have expended considerable effort in the inspection, evaluation, and independent verification of the Beaver Valley Unit 2 construction activities starting at initial site mobilization of craft personnel in 1976 (see 1 ). These activities included special inspections, mobile NDE labora-tory involvement, and comparison with experiences at other plant sites. These activities are summarized later in this document.
f. : *%
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..m LSpecial: inspections have been performed of the design and construction activiti.es through-the plant completion.. Both.NRC and Duquesne Light initiated inspections have.been performed. The following is a brief listing of these activities:
1.
- Systematic Assessment-of Licensee Performance (SALP) Evaluations Six (6) NRC annual evaluations NRC Inspection Report'1etters 81-04, 82-03, 83-10, 84-06, 85-98, and 85-99 have been performed since March'1980 and the l ratings of the activities have been very satisfactory as indicated in Attach-ment'2.
2.
'INPO Construction Audits
[ Text deleted by NRC Region I.]
3.
Construction Team Inspection (CTI)
An in-depth audit of. construction practices was performed by NRC/ contractor personnel during the period 4/12-29/83 (Inspection Report 50-412/83-05) and 4/25-30/85 (Report 50-412/85-07). Approximately 1300 and 1000 manhours were expended respectively and a favorable evaluation was received. The areas of' inspection included construction management, engineering and design, Quality Assurance and control, housekeeping, electrical, construction piping and sup-ports,_and training..The NRC report stated that construction management was considered to.be a strength of the project; the applicant and Stone and Webster management were actively involved and aware of work status and problems and I
cooperation with site quality control personnel was identified at all levels.,
l-4.
In-Depth Technical Audits The te.hnical support of the construction activities has been examined in depth. The accuracy and compliance of design output to applicable NRC and Industry codes' and standards has been of major importance in order that proper direction be given to construction forces responsible for. installation and quality control. NRC Inspection Reports 84-06, 84-16, and 85-99' document the inclusion that the DLC/SWEC in-depth technical audits were conducted in suf-ficient depth to support the finding that design control and implementation was satisfactory. The NRC inspections at'DLC/SWEC Site and HQ locations from 7/28/86 to 8/5/86 (500 manhours) provided this conclusion. NRC HQ I&E Divi-sion letter dated 7/7/86 also states that the Engineering Assurance Audits and Duquesne Light Design Basis Endorsement and Confirmation Program (3/83 to present) was an acceptable substitute for an Independent Design Inspection as a means for providing NRC additional assurance that the design of BV-2 complies with FSAR commitments and NRC regulatory requirements. The DLC/SWEC
a,
~
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~.
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33 involvement in the detailed design review audits represented an activity i
starting in 1983 and required over 125,000 engineering manhours by DLC and I
SWEC.
The Beaver Valley Unit 2 project has been constructed in accordance with ons Duquesne Light Company Quality Assuranca Program.
The Site Quality Control Program is a Duquesne Light. program which hea been applied to all. major contractors.
Field Construction Procedures were developed which have been common to all major con-tractors.
The Quality Assurance Manager is responsible for maintaining and managing the
)
Duquesne Light Company Quality Assurance Program and is authorized to report qual-
)
ity problems directly to any level of management necessary to ensure corrective t
action. Duquesne Light personnel are required to act in strict accordance with the applicable requirements of the Duquesne Light Quality Assurance Program, and management gives full support to maintaining and effective quality program. Addi-1 tionally, contractors who perform activities affecting quality on safety related items are required to comply with applicable requirements of the Duquesne Light Quality Assurance Program. The Quality Assurance Unit is staffed with competent individuals who have the experience and knowledge necessary to ensure that the Duquesne Light Company Quality Program is effectively implemented and maintained.
There are presently over 500 man years of nuclear industry experience in the Qual-ity Assurance Unit.
The Duquesne Light Company Quality Assurance Unit periodically reviews the status and adequacy of the Quality Assurance Program to that the Quality Assurance Program remains in compliance with the applicable codes, standards, and regulations which may change or be modified periodically. This review also assures that the Quality Assurance Program is kept current with changes in the organizational structure of functional responsibilities within Duquesne Light Company. A management review of the status and adequacy of the Duquesne Light Company Quality Assurance Program has been conducted annually for the Duquesne Light Company corporate management.
The Duquesne Light Company Quality Assurance Program at BV-2 is also subject to l
review and audit by independent organizations.
1.
Cooperative Management Audit Program (CMAP) 2.
Factory Mutual Engineering (ANI, ANII) 3.
Institute of Nuclear Power Operation (INPO) 4.
National Board of Boiler and Pressure Vessel Inspectors One indication of Duquesne Light Company's ability to implement and maintain an l
effective quality assurance program is reflected in the NRC SALP evaluations.
The most recent evaluation resulted in four areas being rated Category 1 and the re-maining five areas were rated Category 2.
These results are supportive of the fact that Duquesne Light has constructed Unit 2 in a quality manner and that it will be operated in a manner to ensure public and plant safety.
l i
_ - = - - _ _ - _ _ - _.
u v
.y 34 I
The construction of' Unit 2 has progressed with a minimum of quality problems. The ability of the Site Quality Control organization to respond to quality issues has been a strong point of this.' subject. An overall evaluation of Duquesne Light Com-'
pany's QC inspectors has shown competent and effective performance of their re-sponsibilities. This can be attributed to a centralized; comprehensive training and certification program which is administered by Duquesne Light for all of its inspectors. Exit interviews are conducted of all inspectord leaving the-site to-ensure any quality issues are addressed.
No significant items have.been identified during these exists.
Duquesne Light Company maintains overall control of the Quality Assurance Program through a comprehensive program of planned and periodic audits. The audits are designed to assure Duquesne Light Company that the Duquesne Light Company organiza-tions, the Architect Engineer / Constructor (SWEC), the NSSS Supplier (Westinghouse),
and the Contractors and Subcontractors are conducting their activities in accord-ance with the Duquesne Light Company Quality Assurance Program and 10 CFR 50, Ap-pendix B.
Representatives of the Duquesne Light Company Quality Assurance Unit have participated in the Architect Engineer / Constructor and NSSS Supplier auditing activities.
The applicable quality assurance program of the Architect Engineer /
Constructor is audited at least annually or at least once within.the life of the activity, whichever is shorter.
S&W(AE/ Contractor)
No. of No. of No. of and Westinghouse (NSSS)
Audits Findings Other Items 1973 2
13 8
1974 10 62 1-1975 2
3 0
1976 8
62 4
1977 11 50 9
1978 6
44 9
1979 4
10 0
1980 11 21 14 1981 4
9 3
1982 8
14 16 L
1983 8
14 20 L
1984 6
3 15-l 1985 8
26 26 1986
_7 7
21 TOTALS 95 338 146 The Duquesne Light Company Quality Assurance Organization has also conducted audits of safety-related activities performed by Duquesne Light Company organizations and Stone and Webster con. tractors and subcontractors and has participated in audits of Stone and Webster and Westinghouse. A summary of the results of these audits follows:
_---__---___-__.c-._---.__.--
k Q#M
- ,. ;c
- 35
- Other:
No. of-No. of
'No. of
" Audits' Findings
. Other items -
-t Audits.
1973 1
8-0 1974 14:
'70 7
1975 5
15 0-1976.
21.-
'146 0
1977 ~-
23
-73 26-1978 29
-106 113 1979
, 32 108 42 1980
' 24 64 40-1981 30 52' 41
-1982-21 46 34 e
1983L 27 69 77
.1984 30-74 87 l1985 32 83 82 1986 31 60.
66 TOTALS ~
320 974 615
- "No. of Other Items' include Observations, Areas of Concern, and Comments.
The Duquesne Light Company Site Quality Control organization has provided in process and final: inspections of materials and contractor activities in each discipline.
as follows:
INSPECTION rep 0RTS-Year Mechanical Electrical Structural Receipt 1987
'2,481 27,157 300 775
- 1986 32,650
-147,400 2,975 6,021 1985 23,582 99,950 1,760 5,135
- 1984 20,157-62.940 2,611
'4,397 l.
' 1983 15,610-53,100 2,805-4,191 1982 5,248 26,000 2,363-3,020 1981.
2,009 22,000 1,566 1,828 1980 645 4,600 813
.1,369 1979 1,021' 7,400 1,250 2,666 1978 l',037 7,600 1,260 2,480 1977-
'42 4,300 638 1,603 1976' 16 900 612 929 TOTALS 104,498 463,347 18,953 34,414
____L_-_--_-----------
- - - - - - ^ - - - ^ ' ' ^ ' " ' ' ^ ^ ' ' ' ~ ~ ' ^ ~ ' ' ' ' ^ ^ ^ ' ^ ~
UM ** *
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2 f
4
- Test Nonconformance
- Construction:
. Year.
J Reports-Reports
' Deficiency Reports
.1987-2,073-333 364-1986 15,728:
4,694 4,240 1985-23,513 3,614 4,261.
'1984 17,006 3,256 4,707 1983' 12,611.
2.335 2,066 1982 9,438:
873 118-
'1981-6,293 598-II-1980
-7,241 356 9
1979 4,825 445 13
-1978 3,526 692 1
1977
-2,033 277 1976 1,248 236 TOTALS'
-105,535 17,709 15,790 t
- 0nsite Test Labs The Duquesne Light QA/QC Organization has the authority to stop work independent' of the Project Engineering and Construction organizations. The standard process of issuance for BV-2 Stop Work directives has traditionally involved advisements-from QC to Construction Management with the majority of Stop Work directives being issued by the' Construction Manager's Office.
. The following list summarizes stop work actions issued for the BV-2 project with those initiated by QC directive or advisement indicated by an asterisk (*).
Year Description Resolution 1986 MSIV's - Stop Work issued due to prob- -Review of BV-2 MSIV's indi-lems identified with similar MSIV's at cated subject problems did another project.
not affect BV-2 to the same degree.
~ 1986 Insufficient information provided on Drawings revised by Engi-instrumentation isometric. drawings.
neering.'4 sn 1986 Discrepancy between actual and design Design change issued by l
location of control rod drive mechanism Engineering.
shroud.
1986 Possible over pressurization of radi-Design change issued by ationi monitors from the instrument air Engineering.
supply.
1986 Damage to MSIV roller bearing, roller Bearing replaced by vendor bearing pin, latching arm and latching and minor indications re-arm pin.
paired.
= _ -- -
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37 Year Description Resolution 1985*
1200 ton cement test sample fails to Analysis of Batch Plant silo meet strength criteria.
material verifies accept-ability.
1985 Incorrect material used in the manu-Replacement brackets were facture of Paul Monroe hydraulic snub-installed.
ber brackets.
1985 Conflict in design requirements of in-Drawings revised by Engi-sta11ation and separation of instrument neering.
tubing.
1984*
Linear indications identified in hex Based upon additional tests head nuts.
performed on lots delivered, some nuts were scrapped while other were accepted.
1984' Stop Work issued by DLC Engineering Engineering review was per.
until a reassessment of Class 2 piping formed, welds-subject to PSI /ISI examination could be completed.
1984-Installation of 10 fire barriers is Drawings revised by Engi-redundant.
neering.
1984*
Drawings for large bore rack type Drawings reissued by En-hangers require review block for veri-gineering.
fication of constructability.
1984*
Large number of color separation viola-Cables were removed and tions being identified by QC in build-panels were redesigned.
ing service panels.
1984*
Additional Engineering ir.structions re-Specification revised.
quired for supporting pipe during post weld heat treating operations.-
1984*
Additional instruction needed pertain-Temporary supports for ing to protection of cable during re-cables were designed.
pairs to electrical penetrations.
e 1984*
SpBV-100 Technique Sheets are not in Technique Sheets for incore compliance with the Field Construction instrumentation tube welding Procedure, were revised.
1984*
Unacceptable welds identified on PBI Small bore clamp anchors supplied small bore hanger - four bolt were redesigned.
clamp anchor supports.
38-Year Description Resolution 1983*
Parker Hannefin Weld-Lok fittiregs -
Engineering review indicated i
failure to pass LP Examinations.
that acceptance criteria-applied by QC was not ap-plicable.
Fittings were accepted.
1983*
Coating of embedded plates halted until Construction installed ID ID tags indicating plate thickness were plates.
sffixed.
1983*
Cracks identified in Grinnell and Power Special tests of Power Piping two and three bolt pipe clamps Piping and Ginnell clamps and riser clamps.
verified their acceptability.
1983*
Cracking.was identified in cosmetic Engineering dispositions welding on RCS steam generator nozzles. to N&D's provided instruc-tion for corrective action and welding technique.
1983*
NKC-60 cables cannot be pulled without E&DCR 2PQ-0188 issued to violating the minimum bend radius re-revised criteria.
quirement.
1983*
1200 ton in process test sample; Type Engineering revised spect-II cement does not meet modified fication to require standard strength criteria.
ASTM C150 criteria.
1983*
Concrete aggregate stockpiles are Supplier applied covers and frozen.
steam to correct problem.
1983 Lack of proper welding details for duct Duct support drawings were supports.
revised by Engineering.
1982 NRC identified that insufficient cri-35 welds were redesigned; teria was provided by Engineering to 31 welds were repaired; 31 ensure adequate size of trunnion to welds required drawing re-pipe welds.
vision; and 4 welds were voided.
1980*
Weld material control by the mechanical Contractor revised program.
contractor was not adequate.
1980*
Lack of complete information on mechan-Contractor revised technique ical contractor's technique sheets for sheets.
stainless steel welding.
I L____
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39 Year-Description Resolution 1
l1979*
Rebar in crane wall not in accordance Portions of the concrete with drawing.
wall were removed, required i ^,
rebar was installed, and wall repaired.
1976*
Lack of proper construction procedures Construction procedures were and training for cadwelding.
issued and task orientation of workers was conducted.
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ATTACHMENT 2-BEAVER VALLEY 2 SALP REPORT 4/1/8S 4/1/84 12/1/82 12/1/81 Thru Thru Thru Thru Functional Area 3/31/86-3/3/85 3/31/84 11/30/82
.j i
Soils and' Foundations 1-Containment and Other Safety-Related
. Structures 1
1 2
1 i
Piping and System Supports 2
2 3
1 Safety-Related Cor.ponents 1
1 1
1 Support Systems 2
1 1
2 Electrical Power Supply and Distribution 2
2 3
l' i
Instrumentation and Control Systems 1
2 2
' Licensing Activities 1
2 2
2 Storage of. Safety-Related Components 2
1 3
Engineering / Construction Interface 2
3 2
Preoperational/Startup Testing 2
2 Quality Assurance and Administrative l
Controls 2
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42 ENCLOSURE 2
SUMMARY
OF SALP EVALUATIONS RATING PERIOD 9/80-12/81-12/82-4/84-4/85-4/86-Functional Area 2/813 8/81 11/82 3/84 8/85 3/86 2/872 1.
Substructure, Soils and A
1 1
NB Foundations 2.
Liner, Containment and A
2 1
2 1
1 Other Safety-Related Structures 3.
Piping and Supports (in-A 2
2 3
2 2
cluding weldin preservation) g NDE and 4.
Safety-Related Components A
NB 1
1 1
1 5.
Electrical Power Supply A
2 1
3 2
2 and Distribution 6.
Instrumentation and Control A NB NB 2
2 1
7.
Quality Assurance A
2 2
1 8.
Support Systems (ine'" ding A
NB 2
1 1
2 fire protection) 9.
Licensing Activities NB 2
2 2
1 1
10.
Storage of Safety-Related 3
1 2
Components
- 11. Engineering and Engineer-2 3
2 ing/ Construction Interface 12.
Management and Management A
1 Control of Contractors 13.
Concrete A
14.
T raining A
15.
Reporting AA 16.
Environmental Protection A
17.
Preoperational/Startup 2
2 2
Testing 18.
Operational Readiness 2
KEY:
A = Average AA = Above Average 1, 2, 3 = Category Per MC 0516 l
-- = Not Assessed NB = No Basis or Inadequate Basis for Assessment 2 = 3/8/80 - 2/28/81 2 = Overall assessment of Construction during the latest period was Category 1.
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.43 ll ENCLOSURE 3
' INSPECTION PROGRAM ANNUAL BREAKDOWN (HOURS)'
Year:
Reports.
Construction Preops
.Startup. Operations.. Total
-1972-1973
- 2' 12*
12*-
1974 4
90*
90*^
l1975 2
42*
42*
1976 6-174*
.174*
1977
- 10 276 276-1978-
'14 496 496 1979 10 382 382-1980 10 446.
446 1981' 8
755 755 1982 13 1826 1826.
~
1983 17 2003 2003 1984 18 2520 120 2640 1985 25 3239 247 3486 1986 46 2742 1651 478 7871 1987**
22 596 1614 175 265 2650
- Estimated inspection hours.
- As.of 4/30/87.
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44' ENCLOSURE 4 INSPECTION
SUMMARY
FOR BEAVER VALLEY POWER STATION. UNIT 2 Inspection Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas ~
Noteworthy Findings 73-01 8/21-9/17/73 Quality Assurance program for Significant finding:
2 construction.
The program was found not to meet require-ments of 10~CFR 50, Appendix B, in 9 criteria.
73-02 11/26-30/73 Review of Revision 1 of DLC None.
1
-QA procedures.
74-01 5/14-17/74 QA program implementation.
None.
74-02 5/28-31/74 Laboratory proof tests of None.
I concrete design trial mixes.
74-03 8/12-16/74 QC program related to exca-Infraction: Control of 1
vation, backfill, and founda-measuring and test tions.
equipment does not conform to established procedures.
74-04 8/26-29/74 Environmental monitoring Deficiency: Air was 2
program.
not sampled and analyzed at each specific loca-tion as required.
75-01 4/23-25/75 Environmental monitoring None.
2 program.
75-02 6/18/20/75 Audit for conformance to Deficiencies: Failure 2
FSAR and QA program design to follow Engineering review commitments.
Management procedures.
Discrepancies with re-spect to performance and documentation of design review.
1 76-01 2/9-12/76 Site preparation and founda-None.
)
2 tions.
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~45 Inspection.
Dates / Number Inspection Enforcement Actions /
Number of Inspectors-Areas Noteworthy Findings 76-02 5/4-7/76-
_ Review procedures,. records, Infraction: Licensee 2
and work activities for site senior. inspectors did preparation and foundations; not complete required i
review DLC QA/QC procedures, indoctrination and l
training.
76-03 5/18-21/76 Environmental monitoring None.
3 program.
76-04 7/12-14/76' Containment foundation.
None.
2 76-05 9/14-16/76 Foundations.
None.
3
~
76-06 11/2-5/76 Design change requirements None.
1 involving site foundation soil densification.
77-01 1/25-28/77 Environmental monitoring None.
I programs.
77-02 2/1-4/77 Administrative controls re-Deficiency: Failure 2
lated to Category I fcunda-to train personnel tions and containment base performing activities material.
affecting safety (77-02-01).
77-03 3/14-18/77 QA aspects of foundations.
None.
1 77-04 5/16-18, Containment foundation Infractions: Failure 24-25/77 to provide documented 2
procedures.
Failure to provide for testing of concrete vibrations.
77-05 6/13-15/77 Containment base material.
None.
I 77-06 7/18-21/77 Reactor containment QA pro-Infraction: Failure 2
gram; electrical cable tray to perform all required installation.
inspections for safety-related pipe welds.
77-07 9/13-16/77 Containment liner erection; Infraction: Failure 2
storage / maintenance of to follow procedure safety-related equipment.
for storage.
46 l
^
i Inspection Dates / Number Inspection Enforcement Actions /
Humber of Inspectors Areas Noteworthy Findinos 77-08 10/25-28/77 Containment.
None.
1 77-09 11/30-12/2/77 Containment liner erection.
None.
3 77-10 12/19-21/77 Pressure vessel lift and None.
2 transportation.
78-01 1/10-12/78 NRC Circulars and Bulletins. None.
2 78-02 1/10-13/78 Environmental protection None.
I program.
78-03 1/17/78 Transportation of steam None.
I generators, 78-04 2/7-10/78 Contractor (piping) QA pro-None.
I gram.
78-05 3/8-10/78 Reactor vessel and steam None.
I generator storage; struc-tural welding and NDE proce-dures.
78-06 4/4-6, 11, Construction QC procedures None.
12/78 containment wall concrete 2
placement.
78-07 4/11-14/78 Containment penetration.
Infraction: Failure 2
to follow cadweld procedures.
78-08 5/8-11/78 Containment.
None.
2 78-09 6/6-9/78 Electrical installation; None.
4 safety-related piping, safety related structures and supports.
78-10 7/11-14/78 Containment structural steel None.
I and penetrations.
78-11 8/21-24/78 Construction of boric acid None.
I tanks.
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47 Inspection Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas Noteworthy Findings I
I 78-12 Containment building rebar None.
I and concrete.
78-13 10/24-26/78 Auxiliary building construc-None.
2 tion.
78-14 12/11-14/78 Containment rebar installa-2 tion, exterior wall erection.
79-01 1/29-31/79 Containment penetrations and None.
2 liner.
79-02 2/28-3/1/79 Environmental protection Deficiency: Failure 2
program.
to control effluents from concrete disposal.
79-03 3/6-9/79 Equipment storage; welding Infraction: Failure QA procedures.
to provide proper weld slopes for piping diameter transitions.
79-04 4/9-10/79 Containment and auxiliary None.
2 building construction.
79-05 7/23-26/79 Concrete QC program; equip-Infraction: Failure 3
ment storage and maintenance to provide adequate document control.
procedure for equipment maintenance and protec-tion.
79-06 8/27-30/79 Compliance with ASME certi-None.
1 fication; compliance with 10 CFR 21; safety-related steel structure QC.
79-07 10/16-19/79 QC program; piping fabrica-None.
2 tion and installation; struc-tural steel fabrication and erection.
j' 79-08 11/6-8/79 QC program for handling and Infraction: Failure 2
installation of pipe, to comply with specs receipt and storage of pipe, for pipe hanger and support preservation.
N7 l
y 48.
g Inspection Dates / Number Inspection Enforcement Actions /
I Number of. Inspectors Areas Noteworthy Findings i
l 79-09 12/10-13/79 Pipe welding; structural Infraction: Failure 3
steel welding procedures;-
of c'rawings to require welder qualifications.
mair tenance of vertical separation of cable trays.79-179 12/10-13/79 Investigation of allegation Allegations were un-1/8-9, regarding welder qualifica-substantiated.
14-16/80 tions.
2 80-01 1/15/80 Allegation investigation.
Allegation not sub-1 stantiated.
80-02 1/7-11/80 Allegation investigation.
Two of six allegations substantiated, interr;al audits not performed in required. time period; training program not adequate to satisfy regulatory requirements.
80-03 3/25-28/80 QC program for concrete None.
2 placement; storage and main-tenance of equipment.
80-04 4/7-31/80 Pipe welding; welding Infraction: Failure 3
records; structural steel to provide evidence welding procedures and of evolution and dis-welder qualifications.
position of indications in weld radiographs.
80-05 6/4-6/80 Environmental protection None.
I program.
80-06 6/2-6/80 Pipe welding and records; Infraction: Failure 4
structural steel welding and to return used/ damaged welder qualifications; elec-weld electrodes.
trical and instrument QC.
80-07 7/7-10/80 Structural steel installa-None.
I tion; storage of equipment.
I l
L________________-.-.-_-__..---
j.;+ ::
- 4..
49 Inspection Dates / Number Inspection Enforcement Actions /
Number of Inspectors-Areas Noteworthy Findings 80-08 8/11-15/80 Electrical cable and tray None.
3-procurement QC; containment-line dome records; steam generator support welds; in-dependent verification of pipe weld thickness.
80-09 9/22-24/80 Turnover of project inspec-None.
3 tor responsibilities; con-crete placement; settlement monitoring program; QC pro-cedures.
1 80-10 12/2-4/80 Concrete placement-records; None.
1 2
shear wall design deficiency; neutron shield tanks; crane-wall repair.
81-01 2/2-5/81 Concrete placement; settle-None.
1 ment monitoring; seismic calculations.
81-02 5/5-7/81 Project inspector turnover; Noncompliance: Failure 2
facility tour.
to provide adequate storage for piping (Level IV).
81-03 7/6-15/81 Direct independent inspec-None.
3 tion of neutron shield tank with NDE Mobile Lab.
81-04 5/19/81 SALP Management Meeting.
81-05 6/15-25/81 Cable tray qualification None.
data; storage and mainten ~
ance of electrical equip-ment; vendor QA program.
81-06 8/3-7, 17-21, Tour of construction activi-Violation: Inadequate 9/30/81 ties; construction proce-protection of electri-1 dures for pipe cleanness cal controls (Level and installation.
IV).
','Q
50
{
Inspection Dates / Number Inspection Enforcement Actions /
l Number of Inspectors Areas Noteworthy Findings 1
81-07 8/18-21/81 Concrete placement; backfill' None.
I compaction tests; settlement monitoring program; signifi-cant deficiency in structural design of control room exten-sion.
81-08 10/1-16; Construction activities, None.
11/9-20, welding records; neutron 30/81 shield tank; procedures; con-crete drilling for imbeds.
82-09 12/1-31/81 Control room rebar design Violation: Failure deficiency; fuel transfer to establish quantita-canal concrete; HVAC duct tive acceptance cri-installation; piping records, terial (Level IV).
receipt inspection reports, component storage.
82-01 1/2-2/26/82 Piping installation, storage, Violations: Failure 4
NDE laboratory direct in-to achieve proper weld spection.
control (Level IV).
Failure to assure con-
-trol of delta-ferrite in stainless steel welds (Level V).
82-02 3/1-4/7/82 Piping and hangers; struc-Violations: Failure 3
tural steel and supports; to provide quantitative' welder and procedure quali-criteria to assure fications.
adequate weld size (Level IV).
Failure to perform fit-up in-spection to an accept-able inspection program (Level IV).
82-03 3/25/82 SALP Management Meeting.
82-04 4/7-5/6/82 Concrete placement and test-Violation: Failure 1
ing; QA manual.
to comply with QA manual (Level IV).
82-05 4/5-8/82 Safety-related cable, cable None.
I trays and conduit.
i l
________________a
l a-T* '
51
-i.'
L Inspection Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas Noteworthy Findings.
'82-06 5/7-6/1/82 Containment liners, supports None.
2 installation; weld material control; NDE; storage con-trol; circulars and 10 CFR 21 Reports.
82-07 6/2-7/6/82
. Containment liner; supports Violations: Failure 1
installation; Class 1 pipe to control and identify welds; storage; NDE, follow-nonconforming Category.-
up on 10 CFR 50.55(e) re-I material (Level IV),
ports.
Failure to perform in-spection of containment
. liner IAW specifica-tions (Level IV).
82-08 7/7-8/2/82 Welding; NDE; instrument Violation: Failure to 4
calibration; drawing con-protect electrical.
trol; electrical installa-panels from airborne tion; storage, contaminants (Level IV).
82-09 8/3-31/82 Welding; heat treatment; Violation: Failure to 1
steam generator nozzle re-follow procedure for pair; concrete; material preserving valve seals storage.
seals (Level IV).
82-10 8/9-13/82 Pressure vessel storage and
- None, 1
maintenance, vessel lift, 1
and transporting and field rigging and installation.
82-11 9/1-10/1/82 HVAC supports; electrical Violation: Failure to
(
1 conduit; containment pene-restrict drawing toler-i trations; nonconformance and ances within engineering i
disposition reports; field calculations boundary, construction procedures; QC_ failure to perform training; construction defi-engir,eering calcula-
)
ciency reports.
tions, and failure to establish as-build conditions on HVAC supports (Level IV).
~82-12 10/5-7/82 Safety-related cable instal-Violation: Failure to l
1 lation; cable trays / conduit. provide adequate physi-j cal protection and in-
{
plant storage of safety-related electrical equipment (Level IV).
I 1
I i
1
o V.; 2 ; : ;,.
i
' Inspection Dates / Number Inspection Enforcement Actions /-
Number cof Inspectors Areas
. Noteworthy Findings 82 10/4-11/2/82 Weld activities; NDE; pipe None.
I support installation; pro-cedure reviews.
82-14 11/2-12/10/82 Repair welds; NDE of elec-Violation:. Improper 1
trical penetrations and.
NDE requirements ~for primary piping; hydrostatic electrical penetration tests; 10 CFR 50.55(e).re-(Level IV).
port followup; painting and-coating.
83-01 1/3-7/83.
Welding, NDE, QA/QC on Violation: Use of a 1
reactor coolant pressure stainless steel weld-boundary piping and vessels.
ing' procedure for in-and other safety-related conel welding (Level piping.
IV).
83-02 1/3-31/83 Electrical cable tray con-None.
2.
nections, installation of spare penetration covers, repairs to piping, controls of contaminants on stainless steel.
83-03 1/24-27/83
~ Safety-related cables, cable None.
I trays / conduits and equipment.
83-04 2/1-3/31/83 Record review of. shop fabri- ' Violation: Failure to 1
cated pipe and HVAC fire provide ~ instructions dampers; piping and support for installation of installation; concrete; NDE, temporary supports 10 CFR 50.55(e) followup.
(Level IV).
83-05 4/11-29/83 Construction Team Inspec-Violation: Failure to -
7 tion'- construction manage-calibrate a torque ment; QA; design control; wrench calibration equipment storage and main-fixture within required tenance; electrical con-due date and use of struction; piping and sup-miscalibrated fixture port installation.
(Level V).
Deviation: Failure to comply with require-ments of ANSI N45.2.11 for design control, j
[
l>
L L "..
53 Inspection Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas Noteworthy Findings 83-05(Continued)
Frogram weaknesses:
(1) lack of a charter and program for Engi-neering Department of DLC Nuclear Division; (2) design control by AE's site Engineering Group ineffective.
83-06 3/3/83 Environmental protection None.
2 program.
83-07 5/2-31/83 Design control, pressure Violation: Failure to 1
tests of piping systems; currently consider dead program review of tank weight when performing fabricator; FSAR commit-calculations for pipe ments.
support (Level IV).
83-08 6/27-7/1/83 Piping installation and re-Violation: Failure to lated QC records.
comply with require-I ments for QA procedure for control of hold tags (Level V).
83-09 6/1-7/1/83 NDE, QC training, procedure Deviation: Failure to 1
reviews; document review of meet commitment date shop fabricated piping, site for performing inspec-modifications; torquing of tion of pipe supports supports.
for excessive baseplate gaps.
83-10 7/18-21/83 Installation of safety-None.
I related electrical and in-strumentation equipment.
83-11 7/12-8/26/83 10 CFR 50.55(e) followup; Violation: Failure to I
heat treatment of pipe welds; perform post weld heat material certifications; treatment in accordance specification and field pro-with procedure (Level cedure review, storage, weld IV).
qualifications; battery placement; DLC engineering activities.
83-12 9/26-30/83 Safety-related instruments-None.
I tion installation and associ-ated wire / cable circuits.
I
- s f 'e s..
-54' Inspection Dates / Number-Inspection Enforcement Actions /
Number of Inspectors Areas Noteworthy Findings 83-13 10/3-31/83 10 CFR 50.55(e) followup; Violation: Failure to-1 installation of structural install washers over steel; NDE of electrical long-slotted holes in penetrations; personnel structural steel (Level qualifications; procedure IV).
reviews.
83-14 11/1-3/83 Safety-related electrical /
None.
1 instrumentation installation.
83-15 11/1-30/83 Electrical support installa-Significant. item:
1 tion; piping fabrication; Omission of tolerances mechanical shock arrestors; on drawing details re-pipe weld and QC inspection sulted in installation of electrical supports; of supports which do seismic classification; ven-not have calculations dor documentation.
justifying installed conditions.
83-16 11/21-22/83 Stainless steel piping weld-None.
1 ing.
83-17 12/1/83 -
NDE; hydrostatic tests; Potential problem: Need 1/16/84 fabrication process; supports to assure all water 1
installation; welding checks; removed from components storage of batteries; pumps after hydro test.
and heat exchangers.
84-01 1/17-2/21/84 FSAR; post weld heat treat-Item: FSAR description 1
ment; storage; pipe instal-of spent fuel racks lation record review.
different from items being fabricated.
84-02 2/6-10/84 Support welding; drawing None.
2 control.
.ag Te 84-03 2/22-3/23/84 10 CFR 50.55(e) followup; Violations: Exciter 2
hydrostatic tests; fabrica-control panel wiring tion processes; installation not in accordance with of supports; electrical panel specifications (Level and cable installation; IV). QC performing radiography; construction inspection using a startup testing.
procedure which in-accurately descibed acceptance criteria (Level IV).
]
..'p;>
[
55-Inspection-Dates / Number 1. Inspection Enforcement Actions /
' Number of Inspectors Areas Noteworthy Findings.
n-84-04' 4/2-5/84 Safety-related electrical None.
3 equipment installation; elec-trical separation program.
84-05
'4/16-5/25/84 Design and inspection of.
Allegation not sub-
.1 Category 2 components; Alle
. stantiated.
gation RI-84-A-43.
SALP Report.
84-06 84-07 6/1-7/23/84 Allegation RI-83-A-88; 10 Allegation not sub-3 CFR 50.55(e) followup; cable stantiated.
separation; constructability Concern: Turnover of review team.
service water system.
with large: number of items with construction complete.
DLC system walkdowns without pro-cedure.
84-08 7/16-20/84 Installation and termination Violation: Failure to 3
of instrument cables..
follow installation procedure (Level V)..
84-09'.
7/24-8/24/84 10 CFR 50.55(e) followup; Violation: Protection I
storage; reactor vessel in-of personnel air lock ternals, N&D dispositions; not provided.to prevent fire protection; steam damage of sealing sur-generator tube rolling faces or support of records.
doors to prevent sag-ging (Level IV).
Deviation: 4 failures to implement controls
.for cable tray overfill.
w......
84-10 8/13-17/84 Installation of instrumen-Violation: Failure to 3
tation and electrical equip-seal electrical equip-ment storage.
ment in storage against dirt and dust.
84-11 9/4-7/84 HVAC electrical, piping, and None.
I equipment supports.
1.
7-a:
56 Inspection
' Dates / Number Inspection Enforcement Actions /
Number
- of Inspectors ~
' Areas tioteworthy Findings 84-12 9/10-14/84 Turnover portion of the QA.
Violation: Walkdown 3
program for preoperational group personnel not testing.
certified as qualified for their assignments (Level V).
84-13 9/10-14/84-Post weld heat treatment; None.
2 welds and welding; welder performance qualification; filler metal control.
84 8/24-10/5/84 10 CFR 50.55(e) followup; Concern:. Numerous. pip--
2-QC reinspection program of.
ing and HVAC supports supports, electrical cable;.
fail to meet current CRNs; engineering confirma-'
drawings. NRC concerns tion program; drawing con-regarding QC inspector trol; seismic and environ-performance and effec-mental qualification, tiveness of QC super-vision; quality of construction work pre-sented for QC inspe'c-tion.
84-15 9/24-10/19/84 Independent measurements in-None 5
spection (NDE van) of safety-related selected piping, structural and support weld-ments to ASME and AWS code.
84-16 10/9-11/19/84 Storage of components; con-None.
2 struction of spent fuel and refueling cavity liner; electrical and instrument j
tube support installation; repair of MSIV, post weld 4
heat, treatment; reactor upper internals, N&D dis-positions.
84-17 10/29-11/1/84 Safety-related electric None.
2 equipment installation; color separation program.
I
v.
j 57 i
i Inspection Dates / Number Inspection Enforcement Actions /
j Number of Inspectors Areas Noteworthy Findings 84-18 11/20/84 -
Storage of RCS components, Violation: RCS piping 1/2/85 fuel pool coolers and bat-and components not 2
teries; installation of properly sealed to strut pipe supports, protect from exposure to environment and i
airborne contaminants (Level IV).
Concern: Weakness of maintenance program q
for installed plant equipment.
I 1
f 84-19 12/17-19/84 Safety related electrical None.
I cable and equipment instal-lation.
j l
85-01 1/7-11/85 Preoperational test and pre-None.
I 2
operational preparedness in-spection program.
85-02 1/21-25/85 SIS piping; pipe supports; Violations: Failure i
3 RV internals; preservice in-to issue controlling spection.
documents for valve disassembly (Level IV).
Penetrant indication on RPV internals assembly (Level V),
85-03 1/2-2/1/85 Storage of components; in-None.
2 sta11ation of pipe supports; Comment: Good control polar crane maintenance; found in weld electrode weld material control and control program.
certification; welding and inspection procedures.
85-04 1/28-2/1/85 Safety-related instrument Violations: Failure 2
components and systems.
to include separation as an attribute check in inspection program (level IV).
Failure to include design cri-teria in design docu-ment (Level V).
Fail-i ure to follow proce-dures requiring inde-pendent supports for 4
redundant instrument 4
tubing (Level IV).
m-
~L ~
l F.
I, 58~
l Inspection Date's/ Number Inspection Enforcement Actions /
Number of Inspectors Areas'
-Noteworthy Findings-85-05 2/4-3/1/85 Control of hold tags,.in-Violations: Hold / reject 2'
spection disposition of-tags not' removed as electrical panel wiring required and work on separation; cable pull; a component tagged.as ticket control; pipe weld-HOLD (Level IV).
In-ing; installation of elec-spection disposition.
trical pull boxes.
and rework of elec -
^
trical, wiring without-
. implementing QA. program (Level IV).
Unsatis-factory dispositioning of N&D (Level IV).
85-06 3/4-29/85 Pipe weld radiographs; None.
2 welder qualification; N&D reports.
85-07.-
3/18-29/85 Construction Team Inspection. Violations: Failure 8
to follow procedures.
in electrical con-struction (Level IV).
Failure to retrieve records in' electrical construction interface (Level IV)..
Numerous examples of failure.to follow procedures in-volving lack of atten-tion to detail in pro-viding current adminis-trative information in documents (Level V).
Concerns: Organiza-tional changes. result-ing in turnover of NCD Project Manager; lingering problems in engineering construc-tion interface.
85-08 4/14-19/85 Preoperational test program; None.
1 RCS hydrostatic test; test program QA/QC.
___m__
c,.
59 Inspection Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas-Noteworthy ' Findings 85-09 4/15-5/14/85 -Electrical cable pulling;-
None.
3 rebar cadweld;- instruments-tion welding; welder quali-fication; N&D dispositions;-
excessive feedwater transient analysis review.
85-10 4/29-5/3/85 Safety-related electrical /
None.
2 instrument installation.
85-11 5/13-17/85 Environmental monitoring-None.
I program.
85-12 5/13-17/85 Safety-related mechanical None.
1 equipment installation.
85 5/23-6/28/85 10 CFR 50.55(e) followup; Violation: Failure'to 2-seismic design; piping sup- -meet procedure' require-ports; rigid way struts; re-ments (Level IV).
work of components; N&D dis-position.
Deviation: Failure to meet Reg Guide 1.29.
Concern: Control of rework and/or dis-assembly of installed components.
85-14 6/24-28/85 Preservice inspection pro-Violation: Failure to 1
85-15 7/8-12/85 Review of previous elect-None.
1 trical area findings.
85-16 7/1-8/5/85 Piping supports;.instrumen-Violation: Lack of 3
tation tubing installation; corrective action on material and equipment con-N&D reports (Level IV).
trol; test of station bat-teries; 5 KV cable termina-tion.
85-17 Not Used.
85 18 8/12-16/85 Preoperational testing QA None.
3 program.
i f
1
i;,,
y.
.l
- 60 y
l-Inspection
' Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas Noteworthy Findings i
4 85-19 8/6-9/16/85 Pipe supports; rework on.
Concern: Numerous systems turned over to start problems in methods up group; eddy current test used to tighten and of steam generator tubes.
lock nuts on pipe clamps and supports.
85-20 8/26-30/85 Containment building exterior.None.
I wall concrete closure;-IE Bulletin 79-02; settlement
{
monitoring.
85-21 9/17-10/22/85 HVAC supports; flex conduit' Violation: Failure of 3
and condulet installation; a QC inspectur to per-weld material control;-con-form adequate specific crete placement in contain-inspection of two HVAC ment building exterior wall.
supports (Level IV).
85-22 9/23-27/85 Preventive maintenance pro-None.
j 1
gram for emergency diesel I
generators.
85-23 10/28-11/1/85 Instrument and electrical.
Violation: Failure to i
'2 equipment.
incorporate instrument tube slope requirements 1
in design drawings re-
'l leased for construction (Level IV).
85-24 10/21-25/85 Structural, piping, and None.
1-electrical supports.
1 85-25 10/23-12/2/85 Electrical installations; Violation: Conflicting l
3 monorail systems; environ-information on two de-mental qualification; elec-sign documents result-trical rework control; main ing in use of wrong l
. steam piping field welds; type terminal block ISI procedures.
for feewater isolation valve (Level IV).
Deviation: Failure to implement Reg Guid 1.29 requirements pertaining to seismic design and construction of non-i safety-related systems such as monorails whose failure could affect
{
safety-related systems.
j
[
.j 1 L[.
61 4
1
- Inspection Dates / Number Inspection Enforcement Actions /-
Number of Inspectors Areas Noteworthy Findings 85-26 12/3/85 -
Limitorque operators; equip-Concern: Adequacy of
-1/6/86 ment layup; QA/QC program;.
QC inspections on sys-2 main steam piping to huxili-tems. turned over.to ary feedwater turbine; pre-DLC Startup Group.
service examinations; fire protection supports.
86-01 1/6-30/86 Initial test program open Concern: Verification 1
items of BV-2 SER (NUREG-of system restoration 1057); RCS hydrostatic test; during preoperational RPS and EDG testing.
testing and use of temporary procedures.
86-02 1/6-2/10/86 Environmental qualification; Concerns: Control of 2
flexible conduit installa-tools and equipment, tion; cleanliness controls test control and over-during flushing; pipe sup-all reactor vessel port clearance measurements; cleanliness control; steam generator shot peening; installation of un-reviews of engineering dis-qualified electrical positions.
connectors; installa-tion problems with flexible conduit in-
~
volving disengaged or loose couplings.
86-03 1/27-2/7/86 Instrument and electrical None.
2 equipment.
86-04 2/1-28/86 Preoperational program im-None.
2 plementation; EDG qualifica-tion and proof testing; re-circulation spray and quench spray system preoperational tests..
s 86-06 2/24-28/86 Preservice inspection acti-None.
2 vities.
86-06 3/1-31/86 Preoperational program im-None.
2 plementation; containment integrated leak rate proce-dures; recirculation and quench spray system pre-operational test procedures.
-m_____.______
"O, 1 l%
- g 62 i
1:
Inspection _
Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas Noteworthy Findings
'[
86 4/1-5/9/86 Preoperational program im-Concerns: RCS and CVCS
'2 plementation; RCS cold hydro-cleanliness leading status test; EDG and high to sheet metal intro-head safety injection pump duction into RCP 21C proof test; QC during test-suction; nozzle dam ing.
in primary system.
J 86-08 4/14-21/86 RCS hydrostatic test.
None.
I 86-09 Not Used.
86-10 4/2-6/86 Electrical systems and com-None.-
1 ponent installation.
86-11 5/19-22/86 Preoperational test program; None.
1 JTG approved preoperational test procedures; approved test results; QA/QC inter-face activities; indepen-dent review of design as-pects of auxiliary feed pump turbine steam supply line regarding water hammer.
86-12 5/10-6/13/86 Preoperational program im-None.
3 plementation; RCS hydro test evaluation and system restor-ation; EDG exhaust hood fail-ures.
85-13 6/9-20/86 Mobile NDE laboratory in-Violations: Unaccept-2 spection of structrual sup-able indication in base ports, fuel racks and pre-metal (Level IV).
service weldments.
Liquid penetrant in-dications in weldments (Level IV).
86-14 6/17-20/86 Nonradiological chemistry None.
2 programs.
86-15 6/14-7/21/86 Preoperational program im-None.
3 pigmentation; AFW pumps Phase 1 testing; battery Phase 2 testing; electrical separa-tion programs, i
I
. =
Inspection Dates / Number Inspection Enforcement Actions /
Number of Inspectors Areas Noteworthy Findings 86-16
-6/17-20/86 Nuclear material control and None.
I accounting.
86-17 6/2-6/86 Technical Assurance Audit None.
Program inspection.
86-18 7/7-11/86 JTG preoperational test pro-None.
2 cedures; JTG-approved test results of cold hydros; QA/QC interface; manual and motor operated valve and SFP bridge hoists and perform Phase I test results.
86-19 7/14-18/86 Reactor vessel installation None.
I records; installation modifi-cation and QC of safety-related systems.
86-20 7/21-25/86 JTG-approved preoperational None.
I procedures; containment in-strument air compressor test; QA/QC interface; human error deficiencies; motor operated valves Phase 1 test results.
86-21 8/25-10/3/86 Preoperational program im-Violation: Controlled 5
plementation; new fuel re-area barrier degraded ceipt.
(Level V).
.86-22 8/18-22/86 Preoperational test program; None.
2 QA/QC interface; independent review and inspection of 8 temporary strainers.
86-23
.7/28-30, 8/4, Technical Aassurance Audit None.
5/86 Program inspection.
7 86-24 9/2-4/86 Operations, maintenance, and None.
2 QA.
86-25 9/2-5/86 JTG-approved test procedures None.
j l-1 and approved test results; QA i
interface; main steam isola-I tion valves.
l l
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64
\\
Inspection Dates / Number Inspection Enforcement Actions /
l Number of Inspectors Areas Noteworthy Findings 86-26 9/8-12/86 Preservice inspection pro-None.
I gram and results.
86-27 9/15-19/86 Preoperational test program; None.
1 MSIV Phase 1 tests.
86-28 9/30-20/3/86 Preoperational test program; Violations: System I
witnessing of preoperational changes not properly tests of CVCS, pressurizer reflected in preopera-level and protection channel tional tests (Level calibration.
IV).
Failure to assure that all system pre-requisites were satis-fied prior to testing (Level V).
86-29 9/29-10/3/86 Instrumentation and control Violation: Improper 1
and electricei systems and reporting per 10 CFR components.
50.55(e) (Level III).
86-30 9/29-10/3/86 Instrument and instrument None.
I cable installation.
86-31 10/4-11/5/86 Fuel receipt; security, aux-Violation: Failure to.
6 iliary feedwater system; provide appropriate emergency diesel generators; criteria to QC inspec-solid state protection sys-tors and failure to tem; RTDs; RCS; high energy verify conformance with line break in safeguards clearance requirements building on rigid sway struts.
86-32 10/20-24/86 Preoperational test program; Deviation: Not deter-1 QA interface; test of un-mined NPSH available coupled turbine; MSIV.
fcr recirculation
. system spray pumps.
86-33 10/20-24/86 MSIV operability; MSSV im-None.
I proper ring settings.
86-34 10/20-24/86 Preoperational activities Concern: Administrative 2
related to radiation protec-weaknesses in RWPs and tion; receipt, handling, and vehicle survey records.
l control of new fuel.
j i
86-35
- None, l
I l
.c te,
h if 65 Og Inspection-Dates / Number Inspection-Enforcement Actions /
Number-of Inspectors _ Area's Noteworthy Findings
'86-36 11/17-21/86 Preoperational testing QA None.
2 program.
86-37 10/20-24/86 Preservice. inspection acti-None.
1 tivies.
86 11/3-7/86 Preoperational test program; None.
1 procedure review; test wit-nessing; test results review; QA interface; EDG record re-view and inspection.
86-39 11/3-30/86 Fuel receipt; hot functional None.
6 testing; potential failure of multiple ECCS pumps; TMI Action Plan; AFW system test-ing; MSSV testing.
86-40 11/17-21/86 Preoperational test program; None.
2 hot functional tests; QA interface; latch release test of MSIV-A operator.
86-41 11/17-21/86 Installation / rework of elec-None.
I trical cable for separation; degraded grid voltage motor starting transients.
86-42 12/2-5/86 Procedure preparation and None.
2 staffing for operations; maintenance and IOL in preparation for OL.
86-45 12/8-12/8,6 Preoperational test program None.
2 for process monitoring and radioactive waste systems; chemistr.v and effluent.
j controls.
w su 86-46 12/8-11/86 Electrical splices and ter-Violation: Failure to mination using heat shdnk follow procedures re-tubing.
quiring deburring of sharp edges in contact with safety-related cable (Level IV).
(
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4 66 p
Inspection Dates / Number Inspection Enforcement Actions /
Number of, Inspectors Areas-Noteworthy Findings
'87-01 1/5-9/87:
Procedure preparation, staff-None'.
2, ing and implementation for.
operations, maintenance, and I&C, in preparation for OL.
87-02 1/17-2/28/87 Preoperational test program. Violation _: Failure to 5
implementation, EDG sequence include appropriate start testing, TMI Action criteria for inspection Plan requirements, charging of HVAC equipment sup-pump test deficiencies, reac ports-(Level IV).
tor trip system, reactor ves-sel pressure transient protec-
' tion, CO actuation of fire 2
dampers, HVAC seismic sup-ports. containment integrity.
87-03 1/12-16/87 QA program; receipt inspec-None.
4 tion, storage and handling, design change and modifica-tions; onsite safety commit-tee, non-licensed training program.
87-04 1/12-16/87 Preoperational test proce-
.None.
2 dure review, initial startup testing program status, QA/QC interface with preoperational testing.
87-05 1/26-30/87 Security Department Training None 3
Program.
87-06 1/26-3/30/87 Operator Licensing Examina-None.
4 tions.
9: '
87-07 Cancelled j
87-08 1/3/87 Report of meeting regarding l
4
~,.
NA Operations Training Program.
f 87-09 2/20-13/87 Radiological coritrols pre-None.
2 operational activities.
i 1
_ia___________
j
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i
- 9 0 :
5-
' 67 Inspection Dates / Number Inspection Enforcement Actions /-
Number of Inspectors
- Areas Noteworthy Findings
'87-10 2/2-13/87 Preoperational test witness-None.
2 ing, review of operating pro-cedures in preparation for plant operation, QA/QC inter-face with preoperational testing activities.
87-11 2/3-6/87
. Fire protection program, None.
I procurement / installation procedure, QA combustible material control / hazard reduction program, opera-bility and maintenance of fire protection system.
87-12 2/9-14/87 Preoperational containment None.
2 structural acceptance test and containment integrated leak rate test preliminary results evaluation.
87-13 2/17-19/87 Radiography of regenerative None.
2.
heat exchanger welds and preservice inspection iden-tified deficiencies.
87-14 3/2-6/87 Emergency Preparedness Im-None.
8 pigmentation Appraisal 87-15 2/23-27/87 Document control, records None.
I management.
87-16 3/16-20/87 TMI Action Plan status and None.
1 Emergency Operating Proce-dures.
4 87-17 3/9-15/87 Fire Protection program com-Protection of cable pliance with 10 CFR 50 Ap-room cable tray sup-pendix R and Generic Letter ports is unresolved.
86-10.
1.
87-18 3/1-4/5/87 Preoperational test program, Violations: Inadequate 1
5 TMI Action Plan implementa-design control (Level tion, containment surveys V); Inadequate accept-screen installation; control tance criteria speci-room temporary wall removal, fied for cable tray HVAC controls, cable tray installation (Level inspection.
IV).
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I Inspection Dates / Number Inspection Enforcement Actions /
Number
- of-Inspectors Areas' Noteworthy Findings l-87-19 3/9-13/87 Preoperational test program, None.
2.
test witnessing,' test re-port review, QA interface.
87-20 3/16-27/87 Regional'As-Built Team In--
. Violations: Failure l'
9 spection.-
to implement QC pro-cedures affecting safety-related inspec-i tions (Level V); Safety-related electical-equipment was found not to be identified as committed in FSAR (Level V).
87-21 3/9-13/87 Report Pending 87-22 3/16-20/87 QA programs for maintenance, None.
4 design change and modifica-tions, test and experiment control, measuring and test equipment control, procure-ment control, offsite review committee operational safety.
87-23 3/30-4/10/87 Report Pending 87-24 3/23-27/87 Report Pending 87-25 4/6-10/87 Report Pending 87-26 3/30-4/3/87 Report Pending 87-27 3/30-4/3/87 Report Pending 87-28 3/30-4/J/97 Report Pending 87-29 4/6-24/87 Report Pending 87-30 4/6-10/87 Report Pending 87-31 4/6-17/87 Report Pending 87-32 4/6-15/87 Report Pending 87-33 4/21-24/87 Report Pending
}
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' 6 9 '-
Inspection
. Dates / Number
' Inspection.
Enforcement Actions /.
Number of Inspectors.
Areas Noteworthy Findings 87 3/30-4/10/87 Technical Specifications As-None.
3 Built Inspection.
87-35
_.4/3-5/31/87; Inspection In Progress 87-36 4/20-24/87 Report Pending 87-37 4/20-5/1/87:
Report Pending.
87 5/11-15/87.
Report Pending 87-39--
5/4-8/87 Report Pending Ci_1_ _ _ _ _. _ _ _. _ _. _ _... _ _ _ _ _ _ _. _.
J/RIAI ASSOCIATES R4alttory inform: tion & Support Syst ms 1407 Marco Drive Mitchellville, MD 20716
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301/249-9672 301/249 7846 May 17,.1989 -
OGW-89-170 FREEDOM 0F INf0RMAT10N Mr. Donnie H. Grimsley, Director ACT REQUEST Division of Rules and Records
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Office of Administration U.S. Nuclear Regulatory Commission g,gg,77
. Washington, DC 20555
SUBJECT:
FREEDOM OF INFORMATION ACT REQUEST
Dear Mr. Grimsley:
Pursuant to the Freedom of-Information Act..please make available in the.Public Document Room all documents described in the Appendix to this letter. That infor-mation should include all attachments and enclosures to the original
~ document (s).
Thank you for a prampt response to-this request.
I can'be reached at.301/249 9672 if there is a need to speak with me about this request.
I Si rely your ;
JA)$.L 0.e)ia G. V liiams Enclosure (s) i 1
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w APPENDIX.TO' OGW-89-170::
Please.make available.in the Public Document Room:
Le Copies'of drafts ofL Comanche Peak Steam Electric Station " Final Open Item Transmittal" letters..in accordance with the NRC Inspection Procedure
~
'94300B.
e' Copies:of the " Final Open Item Transmittal" letters in accordance with the NRC Inspection Procedure 94300B for-all plants. licensed since'1984;-
these plants are to include:
Catawba 1 Susquehanna 2 Callaway 1 LaSalle 2
-WNP.2
. Grand Gulf 1 Diablo Canyon 1-Limerick 1 Byron.1.
1 Shoreham' Waterford 3 Palo Verde 1 Wolf Creek Fermi 2
.Diablo Canyon 2 River Bend Millstone 3 Palo Verde 2 Catawba _.2 Perry 1 Hope Creek Clinton Seabrook 1 Braidwood 1 Harris 1 Nine Mile Point 1 Byron 2 Vogtle 1 Beaver Valley 2 South Texas 1 Palo Verde 3
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DEC 61984
.. Docket No.'50-322 4
f MEMORANDUM FOR:
Harold R. Denton, Director, Office of Nuclear Reactor l
Regulation l
'FROM:
. Thomas. E. Murley,- Regional Administrator
SUBJECT:
SHOREHAM NUCLEAR POWER STATION LOW POWER LICENSE RECOMMENDATION-4 I and the NRC Region I staff recommend the issuance of a Low Power Operating
. license for Shoreham.
The bases for this recommendation are contained in an extensive Readiness Assessment Report, which.is attached. The results of that evaluation are summarized below and form the the basis for our recommendation.
1.
The construction and preoperational test inspection programs have been completed, and our staff has determined that LILCo has met license commitments and the as-built Shoreham design is in accordance with NRC regulations.
2.
A comprehensive Region I staff evaluation has concluded that Long Island Lighting Company is ready for fuel load and capable of safe low power operation of Shoreham.
3.
Each' Region I professional was requested by memoranda dated December 14, 1983; March 29, 1984, and November 2, 1984, to identify concerns beyond those already addressed by either inspection reports or staff testimony.
No concerns were expressed by anyone in Region I relative to the issuance of a low power operating license for Shoreham.
Highlights of the evaluation include:
i In excess of 22,000 inspection hours have been devoted to the Shoreham site since issuance of a Construction Permit in April 1973.
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 exceptiora which require resolution prior to fuel load.
A special team inspection was conducted in January 1983 to assess the status of plant readiness for fuel load. The inspection focused on the areas of construction, preoperational testing, and plant operational staffing. The conclusions from the inspection were that the plant would 0FFICIAL RECORD C0pY SHOREHAMNT0L MEti0 - 0001.0.0 12/04/84
} ?A % f 19 4 4 S la _ ff S
7 NaroldR.Denton 2
i not be ready for fuel loading until the summer of 1983.
Subsequently, those. activities necessary to prepare the plant for fuel load were completed and the SALP report for the period ending February 29, 1984 found the plant and personnel ready for fuel load and low power operation.
An independent NDE inspection was conducted by Region I during August 1982 to verify the adequacy of the welding quality control program.
The results of the inspection indicated that the quality of the welding was acceptable.
Based on our inspections and reviews, Region I has concluded that the quality assurance program at Shoreham has resulted in a high quality of construction and will support safe facility operation. The ASLB confirmed the acceptability of the QA program in its finding.
Plant construction was essentially completed in 1982, and Region I has verified through continuing inspections that the as-built plant has been maintained in an appropriate state of readiness.
Extensive, continuing reviews of the proposed Technical Specifications and the surveillance test program, as part of NRC preoperational 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. ' All of these allegations have been addressed and satisfactorily resolved.
In addition, we plan to continue our inspections and evaluations to monitor LILCO's preparation and the plant's suitability for subsequent power escalation. During the next several months, we plan to include the following in our efforts:
An evaluation of the requalification program for licensed operators and Shift Advisor plant familiarity (December 1984).
It should be noted that the licenses for the operators are shortly due for renewal and LILCO has had a requalification program in effect for the past 2 years.
A SALP Board is scheduled for first quarter 1985 to review licensee performance through February 1985.
An operational assessment team inspection will be performed towards the end of the Startup Test Program to assure that the licensee has properly considered test results, and to evaluate LILCO's readiness for Shoreham full power operation.
We will monitor the ASLB hearings and work with FEMA to assure that the licensee has a well developed and maintained off-site emergency response capability.
LILCO has proposed the conduct of a graded emergency plan exercise, during the week of February 11, 1985.
OFFICIAL RECORD COPY SHOREHAMNTOL MEMO - 0002.0.0 12/04/84
Ji Q '.
Il
"" Harold R. Denton 3
We will' monitor the activities of LILCO, the Industry Owners Group, and NRC Task Force' relative to the resolution of the emergency diesel generatcr issue and provide required Regional inspections and reviews where necessary.
In_ conclusion, I find that'Shoreham has been constructed substantially in
' tions,. and that the Long Island Lighting Company is ready t low power operation of the facility.
Ordgreal fcned by s
Ec asc. rurley l
Thomas E. Murley Regional Administrator Attachments:
I.
Region I Readiness Assessment Report 2.
October 19, 1984 Region I Memorandum' cc (w/ attachments):
W. J. Dircks, EDO R. C. DeYoung, IE l
J. Davis, NMSS D. Eisenhut, NRR' T. Novak, NRR A. Schwencer, NRR R. Caruso, NRR R. Starostecki T. Martin H. Kister P. Eselgroth
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SHOREF APIN TO MEMO - 0003.0.
12/04/84
i SHOREHAM NUCLEAR P0k!ER STATION INITIAL OPERATING LICENSE READINESS ASSESSMENT DECEMBER 1984 I
Prepared by UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I l
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4 Shoreham Nuclear Power Station Initial Operating License Readiness Assessment n:
' 1. 0 Introduction 2.0. Summary of SALP Reports 3.0 Region I Inspection Program 3.1 Construction and Preoperational Inspection Programs 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 8.0 Allegations 9.0 01 Investigations 10.0 Regional Staff Concerns 11.0 Utility and Third Party Engineering Evaluations 12.0 Conclusions I
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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 1
Final Safety Analysis Report.(FSAR) and NRC regulations,and that' Long LIsland 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
. 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.
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-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-L 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 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 additional asserance that Shoreham has been constructed to a high level of
. 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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- 2.0 SUMMARV 0F SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE The performance of LILC0 has been assessed four times since the ince of thef 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' discrepancies-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: deportability 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 management 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 rated as Category 3.
" Piping 1
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 irspection was performed by Region I personnel to observe as-built confermance to design and 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 in correcting problems in instrumentation and control sys-tems.
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3 February-1, 1982 - January 31, 1983 LILCO overail performance. during this period was again considered satisfac-
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tory. 0f 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 Re'adiness 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 regulatory requirement; (2) inattention to Ldetail, and;-(3) in some cases, inadequate technical followup to NRC find-ings. These problems were attributed to LILC0 management's attitude, and a somewhat fragmented organizational structure.
Febr uary 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 (TDI) diesel engines.
The diesel generator issue is being aggressively pursued by LILCO and closely monitored by NRC.
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r 4-A~ mar' ked improvement in licensee performance and responsiveness was
- observed during this period. This improvement was attributed ~to a manage-mentLreorganization;that.took' place in 1983 which included relocation.of corporate-staff, including'the VP-Nuclear,'from Hicksville, New York to
'the Shoreham plant' site.
This relocation demonstrated management commit-ment and resulted.in a1better' integrated and more effective organization.
The~ improved performance resulted in a substantial increase in the number of Category I ratings (one Category I rating had been received prior -to this SALP period). Subsequent to the reorganizationLand relocation of.
personnel to.the plant site, the licensee's responses were found to be
.. 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 vent 11ation' tests, emergency planning, and licensed operator experience
.the plant _and personnel.were evaluated as qualified.and prepared'for plant operatior..
JTable 2.1 summarizes the'SALP ratings for the four assessment' periods.
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0-5 3.0 REGION I INSPECTION PROGRAM 3.1 Construction and Preoperational Inspection Programs Region I inspections of construction and preoperational activities at Shoreham have been conducted in accordance with the program estab-lished by the Office of Inspection and Enforcement.
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 program.
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% 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 in.spection 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.
I 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 Shoreham were completed.
Findings and comments
)
are also summarized.
All construction deficiencies (CDR's) reported have been satisfactory-ily corrected by LILCO.
No open CDR's remain to be resolved as of November 28, 1984. A total of 68 CDRs were reported at Shoreham.
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6 This' is comparatively low with respect'.to-other similar construction
. programs such as Limerick (131 CDR's) and Susquehanna (138-COR's).
CDR's were trended for causal links in the SALP process; no adverse
-programmatic trends were noted,
.3.2 Special' Inspections Design, Procurement and Construction OA-(Report 76-06)
A special-inspection was conducted during the period of May'24-27, L.
1976-to ascertain whether the establishment and implementation of the L
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 I inspectors. One infraction 1
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-ation at Shoreham with regulatory commitments and engineering and design documents. The Residual Heat Removal (RHR) system and its supporting subsystems were selected for inspection.' Also, a sampling L'
of construction and management control activities such as purchase documentation, material control, quality control inspections, repair l
and rework, engineering and design changes, and maintenance of com-pleted 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-fied during the inspection. were satisfactorily resolved by applicant's corrective actions and NRC reviewpj Onsite Emergency Preparedness [ppraisal (Report 82-18)
A special inspection wasivM conducted during the period of August 23 to September 2,1982 to verify an adequate state of onsite emergency preparedness.
Emergency preparedness aress inspected were:
(1) administration of the program, (2) organization, (3) training, (4) facilities and equipment, (5) procedures for implementing the Emer-gency Plan, (6) coordination 9th off-site agencies, and (7) walk-throughs of duties. The inspection was performed by seven Region I specialist inspectors.
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The inspectio'n report identified 21 significant deficiencies which:
- needed to be corrected to properly detect, classify, manage, and mitigate an emergency.
J1even items were identified by the NRC team-to.be considered by LILCO for improvement. The licensee r_esponded 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 t'o determine 'the adequacy of the licensee's
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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 committme-ts, 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 LILCD based.on vendor shop and onsite NDE records'and process sheets from their contractors.
The inspection determined the quality of welding to be acceptable, and all areas examined were within accept-able limits or requirements.
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 Readiness Assessment Report (83-02)
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 conduct.ed by eight regional and/or resident inspectors.
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8 Four violations were identified during the' inspection.-Additional items that required resolution prior to a recommendation by Region _IL relative to.a decision on an operating license were also11dentified.
~All. violations open items and unresolved' items associated with this-inspection were adequately addressed by LILCO and subsequently closed' by Region-li. 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-L3.3 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 those 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.
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4.0- QUALITY ASSURANCE The' quality of'the design,, construction and operation of.Shoreham.is assured by LILC0 ' 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 LILCO by Stone and Webster Engineering Corporation (SWEC), the project architect engineer, and General Electric-Company, the nuclear steam supply system vendor.
L1LCO control'over the program was accomp31shed 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 Contrul Division (QCD), and Quality Systems Division (QSD) (or their predecessors) have performed audits of the SWEC quality assurance program to ensure its effectiveness.
1
~ 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 identified during the audits as open items, requiring follow-up review to assure aceptable closure.. Findings are those items identified during the 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 LILC0 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 (SWD) during the Shoreham project:
=_ __- - _
-V 4
'x., N 11 LILC0 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, 1
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, L
'and there are currently no outstanding allegations.
ASLB Hearings Region I personnel participated in the Shoreham ASLB hearings, which considered Quality Assurance.
Four contentions regarding QA at Shoreham l
were admitted, and collectively heard by the Board. The contentions were:
(1) a pattern of QA/QC breakdowns existed at Shoreham, as illustrated by
1 c:
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- NRC cited violations; (2) the QA1 program for. operations.did not comply
' with regulations; (3). the NRC program. 'has not' adequately verified the
~
implementation of LILCO's-QA program; and, (4) there had been inadequate Treview and physical inspection of Shoreham..The Region'I. St,aff testimony:
showed that the cited violations were11ndicative'of problems in' individual areas only and were not indicative ofia? general breakdown. in QA.. Regard-g
'ing the compliance of.the QA' program with NRC requirements, it was estab-lished that the FSAR commitments did comply with:the ' applicable: require-ments'and that. proper implementation would be verified through Region I inspections.- The he'aring board,found, based or the evidence presented,
- that the contentions regarding the Shoreham QA' program were unfounded.
~
This was documented in the Board's Partia1' 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; ar.d (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.
p
'13 L5.0L' 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 instanceihas'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.
/;
14 6.0 : Operator Qualifications 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 R0 and 7 SRO exams are scheduled in February 1985.
Annual requalification exams for the SNPS operators were conducted on three occasions during November 1983 through January 1984.
Since August 1983, an ongoing assessment of the Requalification Program at Shoreham has 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 conducted at the Limerick Training Center, have been performed by Region I for the SNPS operating crew.
The Program is considered excellent, and has l
several noteworthy features.
First, it has been in effect since February 1982, even though it is not required until three months after receipt of an operating license.
Second, the Shoreham program includes simulator training on a semi-annual, rather than the usual annual frequency. Finally, i
the non-licensed shift technical advisors (STA) participate in the program.
j The NRR Division of Human Factors Safety Staff approved the Shoreham-l 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.
1 LILCO committed to have an experienced individual present, as an advisor, J
on each shift.
LILCO hired, or. has been loaned, eight individuals who have held (or presently hold) SR0 licenses, to fill these shift advisor (SA) positions.
Region I conducted an evaluation of the training and qualification of the SAs, including a review of the shift advisor training program and observation of facility-administered certification exams. The I
conclusions of this evaluation were that the SAs possessed an adequate f
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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I 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 adequately 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. Tnese 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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e 16
-7.0 TECHNICAL SPECIFICATIONS Region I has performed a continuing and extensive review of the proposed
(" Proof and Review Copy") Technical Specifications (TS) for Shoreham, since 1981.
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-tions compared individual system design and test documentation (surveil-lance procedures, FSAR, P&ID's and preoperational test results, etc) against the configuration of the as-built plant.
Portions of the systems were physically verified, during walkdown inspections, to compare the installed equipment to the TS. Preoperational test results were reviewed to verify that 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.
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 surveillance during the past year, and this area was rated Category 1 in the last SALP report.
Surveillance test procedures have been prepared and are being used by LILCO, such that their performance demonstrates that the Operational staff can adequately fulfill TS require-ments. Over 170 inspection hours during the last SALP period were devoted 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 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 surveillance in accordance with appropriate procedures.
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. 00A has also review-ed surveillance records, and continues to observe tests on a sampling basis.
Surveillance results are being verified by LILCO Compliance per-i sonnel. Region I has found the program to be well organized, planned and controlled.
V a
e-17 L
8.0 ALLEGATIONS 1
Over 100 allegations have been received, inspected and found to be unsub-stantiated by our technical staff and management since 1980.
i 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. His concerns encompassed the design, 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 substantiated, nor did any involve violations of NRC 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 (OI).
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 substantiated 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 unsubstantiated.
An inspection was conducted by the resident inspector during October 1982, to investigate corroded valves and fiberglass piping that were allegedly reinstalled without repair. None of these allegations were substantiated.
Other individual allegations have been received, both prior to and after 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 allegauves that impact on a licensing decision for Shoreham.
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IB 9.0 01 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 DeLaval, Inc. (TDI), 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 5'4 power, is the subject of a separate licensing board.
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10.0. REGION I STAFF CONCERNS Letters were 'sent to all members of the Region I technical staff by the cognizant OPRP 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 'nder consideration by the NRC's Task. Force u
evaluating the nuclear service diesel generators supplied by TDI.
t I
IQ-___
.e-20 11.0 UTILITY AND THIRD PARTY ENGINEERING EVALUATIONS INPO EVALUATION i
During the week of January 11, 1982, the Institute of Nuclear Power Operations (INPO) conducted a startup assistance visit at the request of l
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 INP0' in the areas of Organization and Administration, Operations, Maintenance Technical Support, Training and Qualification, Radiological Protection and Chemistry. The applicant has implemented many of the recommendations made by INPO.
Torrey Pines Review At LILCO's initiative, 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 inspection was performed on 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 commitments.
The TES independent design 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.
1
]
b 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.
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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 fuei 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, closecut of the Master Punch List and open inspection items, and turnover of the remaining systems undergoing testing to plant staff.
Those areas have since beer, 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-ment statistics.
Further, the Board concluded that the testimony of NRC staff and LILC0 was credible and persuasive, and that the QA Programs for operation of Shoreham will provide adequate protection of public health and ssfety.
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)
Extensive, continuing reviews of the proposed Technical Specifica-tions and the surveillance test program, as part of NRC preopera-tional-inspections, have provided reasonable assurence that the TS are compatible with and accurately reflect as-built plant status.
Approximately 100 allegations have been received and addressed since m-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 complated 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.
,/ '
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TABLE 2.1:
Summary of SALP Evaluations Functional Areas Rating (for period ending)
-2/81 2/82' 2/83
_2/8_4. '
.1.
Radiological' Controls 2
2 1
2.
-Maintenance
. Avg.
2 2
-1
'3.
Fire Protectior.
2 2.
4.
Security & Safeguards 2
2 1-5.
' Initial Fuel Receipt.
2
-2 6.
Preoperational Testing.
Avg.
~2'
~7..
Plant Operations' Avg.
2'
- 2 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
- 12., Engineering & Design.
Below Avg. 3 2
1
'13.. Licensing Activities 2'
2
'2 114.. Soils & Foundations 1
15.- Emergency.. Diesel Generators 3.
- 16. l Surveillance-Avg.
1 17-Readiness for Operation l'
18.'
Committee Activities Avg.
- 19. Quality Assurance / Control Avg.
- 20. Concrete Avg.
- 21. Safety Related Structures Avg.
- 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'specifica11y' assessed during the subject assessment period.
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.-.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 />.
Through November 1984, up to and including Inspection Report No. 84-41 (4 c.
reports cancelled)
L
4
..2 SHOREHAM INSPECTION REPORTS YEAR 1984 Program Breakdown Dpt. Period Report Total Constr. Preop. Startup Ops To.
Ending Violations Comments Issued Hours 2512 2513 2514 2515 24-01 1/13 Level IV Resident review of EDG hold-2/16 25 25 down bolt failures 92 2/26 Resident review of open items, 3/16 319 319 and diesel testing 33 2/11 New DG Bldg. construction QA 3/16 46 46 D4 3/1 Bower Allegations 5/1 246 15 2/14 EDG Recovery Test Programs 4/9 20 20 36 2/17 Rad Protection & Radwaste 3/30 66 66 Waste Programs D7 3/21 Preop. procedures & tests 4/25 56 56 D8 3/2 Preop Rad. Envir & Met Monitor 4/11 34 34 D9 -
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 L1 3/22 EDG Recovery Program 4/18 88 88 U2 CANCELLED L3 5/2 Chemistry and Effluents 6/21 84 84
- 4 4/27 Open Items; Bul & Circl 7/16 440 362 78 L5 CANCELLED
.6 5/14 Resolution of Preop Test 5/31 61 61 Exceptions & Results; Obser-vation of Integrated Electri-cal Test
,7 4/19 Review of Ventilation System 6/15 14 14 Testing; Closure of IE Bulle-tins and Circulars related to Radiation Protection 5/27 Resident closure of open 6/15 317 317 items; review of Radwaste Bldg.
flooding, diesel testing 5/4 Security Program implementa-6/19 68 68 tion 9
5/4 Startup Program administrative 6/15 39 39 controls and IE Bulletin 80-17 (BFNPP scram failure) 2 5/11 Closure of IE Bulletins and 7/11 30 30 open items related to welds and materials 5/18 Review of initial fuel load 7/16 58 58 and startup test sequence of activities l
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Program Breakdown.
Ept. Pariod.
Report Total'Constr. Preop. Startup Ops 3tv Ending Violations Comments; Issued Hours 2512
-2513 2514' 2515:
j.
di 7/11 Resident closure of open items.8/18' 213 213-including BISCO allegations;-
1 review COLT diesel project-24 16/29
. New Diesel Building civil 8/1
.27 27
. structural activities
!!F,6/29
. Closure of Radiation Protec-8/3 20 20L tion open items
!6 -
.7/2-GM-EMD Test Observation 9/18 ~
38 8
?7J 7/12
. Startup procedures and 8/27 89 28-61 open items-
?8 L CANCELLED
!5L 8/19 Resident' observation of TDI 8/30.281 281
- and Integrated Electrical Testing 8/13.
12-10 7/11 Closure'of TDI diesel'open 12 items lli 7/26.
. Startup test procedure > review 9/12 -33 31-9/30
' Resident review of administra 10/11 235
.235 tive. controls.and Master. Punch-List 13 9/21~
Closure'of TMI Items' 11/9.
63 55 8
KF 9/21' Implementation of Security 11/15' 36 36.
' Plan 9/14~
IE Bulletin Followup 10/26 31 31 G.
10/5' COLT Diesel Project Unissued 128 66 62-SD 10/3'
- Final-closeout of Preop.
.Unissued 26 26 Program-GL 10/12 Fire Protection Unissued 96 96 11/3 Resident closure of open 11/23 120 120 items i
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1.-
SHOREHAM INSPECTION REPORTS YEAR 1983
,Rpt. ' Period _.
Program Breakdown Report Total Constr. Preops Startup Ops
' No.
Ending Violations Comments Issued Hours 2512
.2513 2514 2515 1
L83-
' 01 1/31-Resident followup on open' 2/8:
237 237-items and IE Circulars; review
.of Vendor Manual controls, monitoring of. housekeeping J 02 '
1/15 4 Level.IV Readiness Assessment Team '
1/20 465~ 118 347
'03 1/21
-Inspection 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 Supplies 06-
'2/18 Followup'on IE Circular.
3/15 30 30 81-08 (Foundation Materials);
review of Settlement Monitoring Program 107 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, 4
diesel testing, and the oper-ating and mantenance program for 125 VDC station batteries
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,t
, t:
g
+,.
I Program Breakdown
=Rpt.. Peri od' Report Total Constr.'Prtop Startup Ops No.
Ending Violations Comments' Issued Hours 2512 2513 2514 ~2515
' 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 TDI diesel electrical s12 test runs 4/29 Security 6/1 40 40
-13 4/28 RAT Findings - Followup 5/23 23 23 14 4/29 Shielding design review.
5/25 21 21 (TMI-0373 Item II.B.2) 15 5/19 Preop test completion status, 6/15 27 27 procedure and test results 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 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 f 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 Results Program
' 20-
'6/17 ILRT review; TDI diesel 7/25 32 32 preops.
, 21 7/27 Level IV Resident open item followup; 8/15 280 280 review of operator requal, training, electrical separation requirements (ASLB resolution agreement), proce-dures and training for Station Blackout
.22 6/30 TDI Diesel Meeting 7/27 14 14 23
- 7/29 Preop procedures; EDG testing 8/15 55 40 15 241 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
- 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 change; TDI diesel crankshaft failure
-29
~8/26 Followup of QA open items 10/17 93 93 30 9/30 Radiation Protection 11/16 110 110 I
.t, a -,
,e-l- ' i a
8 H
I L
Program Breakdown
'Rpt, Period Report; Total Constr. Preop..Startup Dps.
J No.
'Ending : Violations Comments Issued Hours 2512 2513 2514.
2515 311 9/16:
. Security 1 11/30 68 68' i32: '10/16 Level.IV Resident. followup on open 10/27 354 3541 items;~Comm. Gilinsky tour; TDI' diesel disassembly and inspection, repair and reassembly
. 33: '11/3 :
34-11/18 Huber allegations 11/20/84 106 106 Huber allegations 12/21-29 29 35' 11/27 Resident closure of open-12/24 330 330 items; observationLof TDI diesel test and repair; review of Reactor Building flood'and MSIV leak collec-
- tion issues 3IS.
11/18
- Huber allegations 12/5_
39' 39 E37 ' 22/9 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 i
l l
- _ _ - - _ - - _- _ _J
- V 4
SHOREHAM INSPECTION REPORTS YEAR 1982 Program Breakdown lpt.
Period Report Total Constr. Preop. Startup Ops so.
Ending Violations Comments Issued Hours 2512-2513 2514 2515 B2 -
01-11/8L Followup of IE Bulletins 11/27 30 30 02'.
and Circulars 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
$31 1/15
. Fire Protec./ Prev. Program-
.2/3 26 26
$4
-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
!8.
and Security organization 5/10 Level V Resident followup of'open 5/27 126 126 items and IE Circulars;_
review of CILRT; implementa-tion of electrical separation D9 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 11 -
5/14 Level V Review of preop test proce-6/18 72 72 dures & results, witness of HPCI and diesel testing, and assessment of OQA audit of preops 12 - 5/21 Followup of construction 5/28 26 26 deficiency reports (3
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 b4' 7/29 Review of training programs 9/3 121 121 and preop test records i
i
___.______.____________-____.____m
1 Iqp Program Breakdown Rpt.
period.
- Report Total Constr. Preop. Startup Ops No.
Ending Violations Comments I_ssued Hours 2512 2513 2514 2515-L15-7/31-2 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 floor bypass leakage; observation of containment structural accep-tance. test; review of procoss computer displays
. 16 5/28
.New fuel receipt and storage 6/23 36 36 17 6/4 Leak rate testing (LLRT &
6/22 26-3 23 L
CILRT) 18
~9/2
.EP Appraisal 9/30 616 616 l19-8/13 Level IV NDE Inspection 10/15 393 393 20-10/15
. Preop; testing of radwaste 11/16 32
'32 systems
!21' 7/29 HP Training / Qual Program 10/12 5
5-22s 8/27' Resident followup of open 10/6 46.
46 items 23 9/18 Resident 9/16 147 147 124-9/10.
Fire Protection Program 10/15 52
.52
. 25!
8/26 Management Meeting for fuel 9/13 17.5 17.5 load prerequisites 12 6 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 27 Screenwell valves and fiber-glass piping problems 30 11/29 Level V Resident followup of open 12/23 214 214 items, bulletins and circu-lars, witness of RCIC preop testing; review of MOV wiring practices ;. summary of 11/22/82 management meeting (preparations for fuel load) 31-10/29 Physical Security Plan review 12/20 64 64
'32 12/10 Leak rate testing, witness of 1/18 102 102 ILRT
J Program Breakdown Rpt.
Period Report Total Constr. Preop. Startup Ops No.
Ending-Violations Comments 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 i
k i
l
7 l
7..
Table 4.1 ANNUAL AUDITS CONDUCTED (1973-1984) by QUALITY. ASSURANCE DIVISION (formerly FQC) d
~ ~
Year Audits Findings" Observations a 1973 63 b
147 1974 133 15 154b 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 Findings include those items designated as " violations" on the field audit a.
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.
Includes audits through September 1984, c.
d.
Of records, design control, SWEC and subcontractor work and overall QA program.
1 l
1
Table 4.2 ANNUAL AUDITS CONDUCTED ON SITE (1973-1984) by QUALITY SYSTEMS DIVISION a
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 105b 1984 8
89 60b TOTAL 51 193 204 Of Project, QA, and other LILCO site organizations a.
b.
Iaclude all LILC0 Nuclear Review Board (NRC) audits I
i 1
c i
Table 4.3 Annual Audits Conducted On-Site (1976-1984) by Quality Control Division (Formerly 00A) a
. Year' Audits Findinas Observations 1976 4.
25 0
1977 12 54 0
1978 13 65 0
1979 12 33 0
1980 14 55 23 1981.
24 53 17 1982 55 81 35 1983 82 129 33 1984 32 53 36 TOTALS 248 548 144' a.
Of Startup and Plant Staff Activities 1
i 1
\\
Table 4,4 VENDOR AUDITS PERFORMED BY LILCO/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.
Table 4.5 QA AUDITS CONDUCTED BY COURTER AND COMPANYc Year Audits.
...-- Findings
--. Observations a 1978 38 85 1979 38 34 1980 42 28 1981 36 61 2
1982 32 75 5
1983 22 22 4
b 1984 9
2
.O TOTALS 217 307 11 At present, the records providing information on the number of observa-a.
tions in the years 1978-1980 are unavailable.
b.
Through September 1984, and principally for new COLT diesel building piping.
Courter & Co. received an N-Stamp, as the piping subcontractor for c.
Shoreham, in 1978.
l 1
)
I 4
Table 4.6 Stop Work Orders Issued by LILC0 QAD/QSD I
I 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 installation documenta-To:
September 13 tion for 1st lift of primary containment liner prior to release for concrete placement.
i Table 4,7 y.
ANNUAL NONCONFORMANCE REPORTS issued by QUALITY ASSURANCE DIVISION (FORMERLY FQA)
Year Corrective Action LILCO Deficiency Requests (CAR)
Reports (*LDR)"
1973 44 1974 82 1975 31 1976 36 1977 34 1978 30 1979 61 1980 55 1981 26 1982 37 21(3) 1983 38 9
D 1984 8
5 TOTALS 482 35 Only includes "C" series LDR's issued in accordance with WAP-15.1; "C" a.
Series LDR's were not issued prior to 7-01-82.
b.
Issued through 9-30-84 Only 3 CAR's and 2 LDR's remain open, as of 11/28/84. The programs are c.
still on going.
l l
L ___ _
Lo -
Table 4.8 ANNUAL NONCONFORMANCES issued by SWEC (N&D) AND COURTER (NR)
SWEC COURTER a
b
_ YEAR N&D's 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
c d
TOTALS 6174 2574
'Nonconformance & Disposition (N&D) Report a.
b.
Nonconformance Reports (NR) c.
40 SWEC N&D's still cpen as of November 28, 1984; these relate to be COLT diesel projects d.
No Couter NR's open to date l
1 i
1
_ _ - _ =
lW' co Table 5.1 Shoreham Enforcement History (1981 to Present)
Report No.
Severity (Issue Date)
Subiect 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
> 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 E&DCR was implemented on main steam Part 50 V
/./83 isolation valve leakage control system Appendix B without a repair / rework re. quest 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 i
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 3
L'1 1.__..
(
i I
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&OCR'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 IV 8/30/82 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 Part 50 IV 8/30/52 were not performed and documented in Appendix B conformance with approved procedures.
Criterion XI QA Manual I
s' c
r Report No.
Severity (Issue Date)
Subject Requirement Level 82-13 Leads were lifted and jumpers were Part 50 IV 7/14/82 installed without proper tagging.
Appendix B Criterion V 82-13 LPCI injection valve low pressure Part 50 IV
-7/14/82 permissive opening was not annunciated Appendix B and had no indicator light.
Criterion III 82-13 No documentation available to assure Part 50 V
7/14/82
' that all testing was performed in Appendix B accordance with written procedures.
Criterion XI 82-11 Failure to perform service testing on
.Part 50 V
6/18/82 three batteries every 18 months.
Appendix B Criterion XI 82-10 Flow measuring and test equipment panel Part 50 V
1 5/24/82 for local leak rate testing not Appendix B properly calibrated.
Criterion XIII 82-08 Procedures and instructions used Part 50 IV 5/27/82 without being properly reviewed and Appendix B approved.
Criterion VI 82-04 Manual initiation circuitry for LPCI Part 50 IV 5/12/82 systems do not provide signals to Appendix B start and assure correct valve Criterion III
- position, 82-04 Failure to maintain RBCLCW system as-Part 50 V
5/12/84 built configuration in accordance with Appendix B drawing requirements after final Criterion II inspection and acceptance.
82-04 Inadequate housekeeping and fire pro-Part 50 V
5/12/82 tection practices in EDG, and Appendix B pumphouse rooms Criterion V 82-04 Use of simple check valves on HPCI Part 50 IV 5/12/82 steam drain line that penetrates Appendix B primary containment, instead of Criterion III containment isolation valves, t
82-02 No recordt maintained to furnish Part 50 V
l 2/2/82 evidence of jet pump tensioner Appendix B hydraulic pressure or hold-down Criterion XVII r#
beam preload f orce.
L ___ __ :_- _ _ -
- 5 f
Report No...
Severity (Issue Date)-
Subject Requirement Level 81-16 Project procedure P304 fails to Part 50 VI j
.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 smell bore piping Part 50 IV C/23/81 containment isolation valves to be Appendix A located as close to containment as Criterion 55-57 possible wae not prescribed by Appendix B instructions, procedures or drawings.
Criterion V 81-01 Failure to recalibrates instruments Part 50 V
4/1/81 within one year of test performance.
Appendix B Criterion V 1
l l
l t
__m__._m_.
. - - - - - - - - - - - - - - - ^ -
- ./ -
FIGURE 6.1-h
~
OPERATIONS MANAGER 41 TOTAL PERSONNEL REACTOR OPERATING ENGINEER ENGINEER-8 TOTAL PERSONNEL 32 TOTAL PERSONNEL
~
NUCLEAR ENGINEER ENGINEEPS
) 2 TOTAL PERSONNEL 31 TOTAL PERSONNEL 5HIET TECHNICAL WATCH ADVISORS ENGINEERS 5
TOTAL PERSONNEL 30 TOTAL PERSONNEL WATCH SUPERVISORS 25 TOTAL PERSONNEL OPERATORS 20 TOTAL PERSONNEL u
-FIG. 13.].2-2 SHOREHAM NUCLEAR POWER STATION STAFF, OPERATIONS DIVISION 4
SHOREHAM NUCLEAR POWER STATION - UNIT 1 FINAL SAFETY ANALYSIS REPORT i
REVISION 33, SEPTEMBER 1984
. _ _____