View source for SNRC-1156, Responds to NRC Re Violations Noted in Insp Rept 50-322/84-50.Corrective Actions:Operating Administrative Directives Withdrawn from Control Room & Will No Longer Be Used to Transmit Matl to Operations Staff

{{Adams
| number = ML20128C446
| issue date = 03/14/1985
| title = Responds to NRC Re Violations Noted in Insp Rept 50-322/84-50.Corrective Actions:Operating Administrative Directives Withdrawn from Control Room & Will No Longer Be Used to Transmit Matl to Operations Staff
| author name = Leonard J
| author affiliation = LONG ISLAND LIGHTING CO.
| addressee name = Murley T
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000322
| license number = 
| contact person = 
| document report number = SNRC-1156, NUDOCS 8505280295
| title reference date = 02-14-1985
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 6
}}

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           %               m-mb                                 SHOREHAM NUCLEAR POWER STATION P.O. BOX 618 NORTH COUNTRY ROAD e WADING RIVER, N.Y.11792 JOHN D. LEONARD, JR.
       . VICE PRE $1 DENT. NUCLEAR OPERATIONS March 14, 1985                                                                         SNRC-1156 Dr. Thomas E. Murley Regional Administrator - Region I office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406 Response to Violations Inspection Report 50-322/84-50 Shoreham Nuclear Power Station - Unit 1 Docket No 50-322

==Reference:==
Letter from NRC (H. B. Kister) to LILCO (J. D.
Leonard) dated February 14, 1985, forwarding Inspection Report 50-322/84-50

==Dear Dr. Murley:==

Attached (Attachment 1) please find LILCO's reply to the two violations cited in Appendix A of the reference letter.
We trust that this is satisfactory. Should you have any questions, please contact this office.
Very truly yo.urs,
(
D ML
[).
3 n D.
Leonard, Jr.        '
Vi:e President - Nu l ar Operations W'G:ck Attachment cc:       P. Esc 1groth                                                                             ,
I 850528029k DR ADOC             h QPDR22                                                                 'I

      ,R     ,                                                                                          j r                                                                                          l; ATTACHMENT ~l.
v,          :SNRC-1156 i
VIOLATION
         ,                                                                                            {
A.       10 CFR 50, Appendix B, Criterion V, sand'Shoreham FSAR Section-17.2.5 requires that activities affecting quality be pre-scribed by, and accomplished in accordance with appropriate
  -                         instructions, procedures, or drawings. . Station Procedure'No.
                           -21.008.01, Operations Standing. Orders,'-states'that standing orders are provided at Shoreham Nuclear Power Station to' provide, written l directives of-continuing applicability.to operations personnel.for routine and certain non-routine
                           -activities or the conduct of operations and requires the
       ^
Operating Engineer to submit these order to the Chief Operating Engineer.or, in his absence, the Chief Technical Engineer for= approval.
LContrary to the above, as of January 10, 1985, typewritten dire ~ctives, approved only by the Operating Engineer in a binder entitled, " Operations Administrative Directives", were
:found'in the: Control Room covering the-following types of activities:
o     Maintaining systems operability status o     Annunciator status and response o     Operation of radwaste systems o     -Surveillance Test Program
                           .This is a' Severity Level V violation (Supplement-I)
Corrective Steps Which-Have Been Taken and Results Achieved-
                  .The Operating Administrative Directives (OADS) were established w                 with -the intent of being used to distribute personnel administra-
                   'tive~ matters to members'of the plant operations staff. The OADS were not intended to be used to. distribute operating orders. As noted.in the Inspection Report, the OADS were not being used as originally designed. When-the discrepancy was brought to the 44              fattention of'LILCO management on January 11, the OADS were Timmediately withdrawn 1from the Control Room.
Corrective Steps Which Will Be Taken To Prevent Recurrence JTo; prevent recurrence, the OADS will no longer be used to transmit anyfmaterialL to.the Operations Staff.       The mechanism for relaying the types of information that was in the OADS.will be either the Night: Orders _or the Administrative Procedures both of which receive appr "riate levels of review and approval.
                                   .Date When Full' Compliance'Will Be' Achieved ThelPlant-was;in compliance after the OADS were removed'from the 4               ' Control Room on January 11.
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Att:chment-1                                                        1
         -        SNRC-1156.
Page 2 VIOLATION                              l B. 10 CFR 50, Appendix B, Criterion XVI and Shoreham FSAR Section I 17.2.16 require that conditions adverse tn quality be promptly identified and corrected.
Contrary to the above, as of January.3, 1985, there were 23 LILCO deficiency reports (LDRs) greater than 90 days old, having no Quality Assurance' Department approved corrective action.
This is a Severity Level V violation (Supplement I)
Corrective Steps Which Have Been Taken and Results Achieved The LILCO Deficiency Report (LDR) was the method adopted by Quality Assurance in 1976 to inplement the requirements of 10 CFR 50 Appendix B, Criteria 15. The program that LILCO uses to document and track significant deficiencies or trends adverse to quality will continue to be the Corrective Action Request. This document requires timely response by noting a response date and, requires both corrective and preventive actions in accordance with the requirements-of 10 CFR 50, Appendix B, Criteria 16 and FSAR Section 17.2.16. This program is described in the LILCO QA Manual and QA procedures.
The LDRs referenced in this response represent approximately 1% of the total LDRs issued by the QC Division,-and were all issued prior to receipt of the operating license. During LILCO's review of this matter, it was determined that there were three additional LDR's greater than 90 days old, thus resulting in a total of 26 LDR's-to be addressed.
The procedure for Quality Control Division LDRs was revised in December of 1984 to initiate 30 and 60 day letters noting undispo-sitioned LDRs to upper management. This process began as scheduled in December, 1984. The corrective and preventive action planned by LILCO will continue to include this concept of notification for undispositioned LDRs.
In addition, the LDRs in question (see list and present status in Attachment 2) were divided into five categories and these categories evaluated for significance.
: 1. Procurement LDRs The six LDRs in this category are examples of minor procedural discrepancies, part number changes, a failure to follow receiving procedures for non-safety related equipment and follow-up of items on QC " hold". These items involve
:non-repetitive activities, minor discrepancies and/or minor procedural discrepancies which do not constitute a pattern indicating significant adverse trends.

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                      ' Attachment'l-SNRC-1156 Page 3
: 2. Measurement and Test' Equipment (M&TE) / Calibration LDRs The.four LDRscin this category have-all been dispositioned, accepted by QA, and do not represent significant recurring deficiencies. .LDR-1844 was closed January 8, 1985, and LDR-2341. requires reverification of bolt torque values.
                              .During a recalibration_the subject torque wrench was found out-of_ tolerance by -2%. The expected completion date for this verification is April 15, 1985.
Research of the other two LDR's deficient conditions estab-lished that, for.LDR-2403, the M&TE had not been used and, for LDR-2324, recalibration did not reflect any out of tolerance condition.
                    ~ 3. . Damaged and Missing Equipment Damaged Equipment Station Modification (SM) 84-028 was initiated by L-E&DCR L-432 on February fl7,1984. The station modification was designed to. allow control ofLemergency diesel generator jacket water temperature at low EDG power. levels by temp-         )
orarily. removing thermal relief valve internals assuring constant-flow through-the cooler. This was a temporary solution and Engineering Evaluation and Assistance Request (EEAR) ~ 84-086. was initiated by the plant on February .24,1984 to address a permanent solution.
During implementation of SM 84-028.it was noted that the. valve internals were damaged and this was documented in'LDR-2155 and LDR-2215. As the damaged components were those to be removed per the station modification the immediate action had been prompt'and correct. The.LDR's were issued to document the
                             .as-found condition. The final disposition was pending the issuance of the engineering package associated with the EEAR.
Station Modification 84-028 was completed on March 15, 1984 and'its three associated MWR's, 84-1380, 1419, and 1420, were returned to service with all damaged components properly removed.
The LDR's were not dispositioned until Engineering scheduled EEAR 84-086.to be worked in the third quarter of.1985.
Physical-work and testing will be completed after the final design package is issued.
Missing Equipment LDR 2092 identified four (4) missing conduit supports and braces. Disposition was to install above per E&DCR's F-40265E and F-42070A, on March 14, 1984. Above work was assigned a
                              ~1ow priority, during a period where EMD diesel generators and other high priority items were being worked. MWR 84-4907 was

Atttchm2nt 1 SNRC-1156 Page 4 written to Maintenance to perform the work on August 27, 1984.
The MWR was put on hold due to Maintenance constraints. A requisition was written - (S-06639) on December 4, 1984, and is currently in engineering technical review. As soon as the purchase order is issued and the material is received the MWR will be worked.
: 4. Procedural LDRs Of the nine LDRs in this category, seven have been closed and the two remaining have now been dispositioned.
The LDRs did not include repetitive type deficiencies and did not represent a significant adverse quality trend. The deficiencies identified the processing of revisions to station procedures, inspections of non-safety related welds, auxiliary boiler chemistry, housekeeping, identification of a non-safety related valve operator, approval, by procedurally unauthorized personnel, of weld requisitions, and minor repair / replacement procedural discrepancies.
: 5. Bahnson LDRs
                  'The Bahnson HVAC LDRs represent a single engineering evalu-ation effort by LILCO. These LDRs are the result of possible nonconformances in Bahnson's air conditioning units (ACU's) as identified by IE Notice 84-30 and are being tracked separately by LILCO and the NRC under Inspection Item 84-29-01.
Corrective Steps Which Will Be Taken To Prevent Recurrence In addition to the procedural changes for 30 and 60 day letters, if a LDR has remained unanswered ~after 90 days, the QA Manager will transmit a request to the responsible action party requesting evaluation of LDR significance and information concerning an estimated Yompletion date. Included will be a notification of this action to the Vice President of Nuclear Operations and the Director, Quality Assurance Safety and Compliance. Failure to respond to this request-will result in the issuance of a Corrective Action Request.
Date When Full Compliance Will Be Achieved The ninety (90)- day notification described above will be in effect April 1, 1985. The status of compliance for the various categories of LDR's was described above. In addition, the attached Table, "NRC -Report /LDR Status", provides the current status of each individual LDR.

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Attachment 2                                                                                                        .:;-
SNRC-1156                                                                                                            -
NBC REPORP .                                                              I ' *' ' '
IDR Status as of 3/14/85.
Safety     Year. Disposition      Disposition . Date IDR IDR #        -Related   Issued    to QCD-      Accepted (KD ' Closed               Renarks
: 1. Procurenent i
* 1.1 1840                    1983        Yes           .Yes-        2/27/85 1.2 2352-                   1984        No                                       Requires Purchasing input.
* 1984 1.3 2368                                No                                     [NED letter 2/.26/85. Disposition in.
;          1.4 2379
* 1984        No                                   1, progress.
l          1.5 2457                    1984-       No                                       Working on cleanup of Hold area in j
T.TTm Waretrxse j
1 1.6 2485                    1984        Yes     ,
Yes.        2/12/85.
2   M&TE/Calib.          *
* 1983        Yes            Yes-2.1 1844                                                           1/8/85 I          2.2: 2324
* 1984        Yes            Yes                      ' Review for closure 2.3 2341
* 1984      .Yes             Yes 4                                                                                           Verification of torque values 2.4 2403                    1984        Yes            Yes         2/18/85
: 3. Damaged /Miss.                                   '
<          Equip.               *
* 1984        Yes l          3.1 2092                                               Yes                       Maintenance Work Bequest 84-4097 issued 4
3.2. 2155
* 1984        Yes            Yes.
3.3 2215                    1984        Yes            Yes                    I,[Report Engineering 84-086 Evaluation issued. and Analysis i
{      4. Procedures           *
*
* Yes 4.1 1538                    1983                       Yes         1/8/85
* 1983        Yes 4.2 1736                                               Yes         1/14/85 4.3 1759
* 1983        Yes Yes         1/8/85 4.4   1982                  1984        Yes            Yes         1/8/85 4.5   2355
* 1984        Yes i                                                                 Yes         2/27/85
* 1984-       Yes 4.6   2455                                             Yes         2/19/85
:
* 1984       .Yes I
4.7   2466                                             Yes                       Warehouse Roof Ieak Repair 4.8   2488                  1984        Yes            Yes         3/7/85 j         4.9   1928                  1983       'Yes            Yes
: 5. Bahnson ACU's         *
* j        '5.1    2470          *. 1984        Yes.            No                    fSite. Engineering office ocupleted
  ~
5.2 2471
* 1984:       Yes No                  ,    evaluation. Sent to QCD to review 5.3 2472                    1984        Yes             No                       for disposition acceptance.
5.4 2473                    1984      .Yes              No                     5 e}}