ML20203D427

SALP Rept 50-322/85-98 for Mar 1985 - Feb 1986

ML20203D427
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/14/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203D424	List: ML20203D417 ML20203D427
References
50-322-85-98, NUDOCS 8607210208
Download: ML20203D427 (55)

See also: IR 05000322/1985098

Text

. .

..

>

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-322/85-98

LONG ISLAND LIGHTING COMPANY

SHOREHAM NUCLEAR POWER STATION

ASSESSMENT PERIOD: MARCH 1, 1985 - FEBRUARY 28, 1986

BOARD MEETING DATE: APRIL 21, 1986

.

B607210208 960714

PDR ADOCK 0b000322

O PDH

_ - _ _

.

. .

.

.

.

_

TABLE OF CONTENTS _

Page

1.0 INTRODUCTION.............................................. I

1.1 Purpose and 0verview................................. I

I

1.2 SALP Board and Attendees.............................

1.3 Background........................................... 2

5

2.0 CRITERIA..................................................

7

3.0 SUMMARY OF RESULTS........................................

3.1 Facility Performance................................. 7

3.2 Overall Facility Evaluation.......................... 7

'

4.0 PERFORMANCE ANALYSIS............................... ...... 9

4.1 Plant Operations and Startup Testing. . . . . . . . . . . . . . . . . 9

4.2 Radioloqical Controls................................ 13

4.3 Maintenance and Surveillance......................... 18

4.4 Emergency Preparedness............................... 21

4.5 Security and Safeguards............... .............. E3

4.6 Outage and Modifications............................. 25

4.7 Training and Qualification Effectiveness............. 28

4.8 Licensing Activities................................. 31

4.9 Assurance of Quality................................. 34

5.0 SUPPORTING DATA AND SUMMARIES.......................'...... 37

5.1 Investigations ar.d Allegations Review................ 37

5.2 Escalated Enforcen.ent Action......................... 37

5.3 Management Conferences............................... 37

5.4 Li ce n see Ev e nt Re po rts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

5.5 Operating Reactor Licensing Action s. . . . . . . . . . . . . . . . . . 39

TABLES

Table 1 Tabular Listing of LERs by Functional Area............ T1-1

Table 2 LER Synopsis.......................................... -T2-1

Table 3 Inspection Hours Summary.............................. T3-1

Table 4 Enforcement Summary................................... T4-1 l

Table 5 Inspection Activities................................. T5-1 l

Table 6 Reactor Trips and Plant Shutdowns..................... T6-1 i

i

l

<

r

, 1

<

1

i

l

4

t

, , - - -

- - - , --

. .

.

1

_

1.0 INTRODUCTION

.

1.1 ~ Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an inte-

grated NRC staff effort to collect available observations and data

on a periodic basis and evaluate licensee performance based upon

,

' this informatidn. SALP is supplemental to normal regulatory pro-

cesses used to ensure compliance to NRC rules and regulations. SALP

is intended to be sufficiently diagnostic to provide a rational ba-

sis for allocating NRC resources and to provide meaningful guidance

to licensee management to promote quality and safety of plant con-

struction and operation.

A NRC Shoreham SALP Board, composed of the staff members listed in

l

Section 1.2 below, met on April 1986, to review the collection of

!

performance observations and data and assess LILCO's performance in

accordance with the guidance in NRC Manual Chapter 0516, " Systematic

Assessment of Licensee Performance." A summary of the guidance and

evaluation criteria is provided in Section 2.0 of this report.

This report is the SALP Board's assessment of LILCO's performance at

the Shoreham Nuclear Power Station for the period March 1, 1985,

through February 28, 1986.

1.2 SALP Board Members

Chairman:

i R. Starostecki, Director, Division of Reactor Projects j

~

l

Members: 1

W. Kane, Deputy Director, Division of Reactor Projects

H. Kister, Chief, Projects Branch 1, Division of Reactor Projects

W. Butler, Director, BWR Project Directorate 4, NRR

R. Bellamy, Chief, Emergency Preparedness & Radiological Controls

Branch, Division of Radiation Safeguards & Security

J. Durr, Chief, Engineering Branch, Division of Reactor Safety

J. Strosnider, Chief, Reactor Projects Section IB

J. Berry, Senior Resident Inspector, Shoreham l

R. Caruso, Licensing Project Manager,.NRR

Other Attendees:

!

C. Warren, Resident Inspector', Shoreham

D. Florek, Lead Reactor Engineer, Test Programs Section, DRS

R. Fuhrmeister, Reactor Engineer, Reactor Projects Section IB

l R. Lo, Licensing Project Manager (Designee), NRR

I

. . - -. . .

.. .- . . ,- - -

. .

..

.

2

-

!

_

1.3 Background

Long Island Lighting Company was issued Construction Permit CPPR-95

for the Shoreham Nuclear Power Station (Docket No. 50-322) on April

14, 1973. 'The permit authorized construction of a 2436 MWt General

Electric BWR/4 reactor with a Mark 11 pressure suppression-type con-

tainment. General Electric was selected as the NSSS supplier and

Stone and Webster Engineering Corp. as the architect engineer for

the project. Construction was completed by a unified construction

organization, 'tiermed UNICO, consisting of the licensee, their archi-

tect engineer, and General Electric personnel.

Construction was completed in early 1984. Operating License NPF-19

was issued on December 7, 1984, authorizing fuel loading and low

power cold criticality testing at up to 0.001% rated thermal power

or 24.36 kWt.

'

The facility achieved initial criticality on February 15, 1985.

Operating License NPF-36 was issued on July 3,1985, authorizing

facility operation up to 5% rated thermal power. The licensee com-

pleted low power testing on October 8, 1985.

Licensee Activities

At the end of the previous assessment period, the facility achieved

initial criticality and commenced low power physics testing author-

ized by Operating License NPF-19. Initial criticality, and shutdown

margin testing was completed at the end of that period.

During the first quarter of this assessment period, the licensee

completed Control Rod Drive (CRD) open vessel retesting, and per-

formed reactor startups and shutdowns for training. Licensing hear-

ings and litigation on the 5% license took place.

On July 3,1985 the licensee received Operating License NPF-36, au-

thorizing facility operation up to 5% power. The reactor achieved

criticality on July 7, 1985 and the licensee commenced low power

testing. Low power testing continued through July 14, 1985 when a

mechanical malfunction caused a scram on low reactor water level.

The reactor was restarted, and on July 18, 1985 was manually shut-

down to investigate deviations in reactor vessel water level indica-

tion. The reactor was restarted on July 29, 1985 after repair of i

the water level instrumentation, and the low power testing program

continued with rated temperature and pressure being achieved on Au-

gust 7, 1985. The reactor was shutdown for rod sequence exchange on

August 24, 1985.

j On August 30, 1985 the reactor was again made critical. A personnel

'

error during the replacement of desiccant in an air dryer caused a

reactor scram on loss of instrument air on August 31, 1985. Low

power testing resumed on September 3, 1985. A personnel error

i

! >

l

_ _ . - . .

. ____ _ . - _ _

. .

3

.

.

caused the it.ird reactor scram during a surveillance test on Septem-

ber 6, 1935. -

,

-

-The licensee declared an Unusual Event on September 8,1985 due to

deviations in the reactor water level narrow range indication. The

reactor was shutdown on September 10, 1985 for investigation and

repair of the problem. Between September 10 and 18, 1985 the

licensee investigated the deviation problem. Resolution of the de-

viation problem involved the addition of ant,ther pipe support on the

reference leg;' The licensee then resumed low power testing and the

main turbine was initially rolled to synchronous speed on October 6,

1985. The licensee completed low power testing on October 8, 1985,

and the reactor was shutdown.

After completion of the low power test program the licensee entered

an outage to replace thesstartup neutron sol'rces in the reactor ves-

sel, and to complete modifications required for environmental quali-

fication of electrical equipment. Source replacement was completed

on October 26, 1985.

On November 4, 1985, during inspection of the HPCI turbine exhaust

check valves, it was discovered that the valves had failed. One of

the two RCIC check valves, during their removal, was also discovered

to have failed. The cause of these failur2s was determined to be the

lack of an adequate locking mechanism on the capscrews which held

the valve disc mechanism to the valve bonnet. In subsecuent inves-

tigation the licensee determined that this problem was due to im-

proper assembly by the valve manufacturer.

The licensee completed all modifications required for environmental

qualification on December 30, 1985. At that time the licensee de-

cided to keep the facility in an outage condition, and to implement

permanent fixes to the reactor vessel water level reference legs.

The need for these permanent changes resulted from the level devia-

tions which had occurred during the 5% Test Program. The modifica-

tion involved the shortening of the steam piping from the reactor

vessel to the reference leg condensing chambers, and the addition of i

more insulation to the piping.

At the end of this assessment period, the facility was in the final

stages of the outage, with pre-startup preparations in progress.

Table 6 provides a description, including the cause, of all reactor

trips and plant shutdowns during this assessment period.

Inspection Activities

During this one year assessment period, 3,067 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> of direct NRC

inspection were expended at Shorehara. *

.

1

.

- - - .- _ _

.

. .

..

.

4

.

Of the total hours during this one year assessment period,1,802

were performed by Region I-based specialist inspectors and 1,265 by

resident inspectors stationed at the site. A senior resident in-

- spector was on-site-throughout the assessment period, and another

resident inspector reported on site in January 1986. A significant

_

-

amount of inspection effort during this period was devoted to the

low power test program and subsequent neutron source and reference

leg replacement outages. Due to limited inspection activities in the

fire protection, area, it is not included as a separate functional

area in this report. Inspection activity in the fire protection

area is included in the Plant Operations and Startup Testing func-

tional area.

.

Tabulations of inspection activities and associated enforcement ac-

tions are cor.tained in Tables 3, 4 and 5. The percentage of total

inspection time devoted to a functional area, tabulated in Table 3,

is included at the heading of each area analyzed in Section 4.

,

This report also discusses " Training and Qualification Effective-

ness" and " Assurance of Quality" as separate functional areas. Al-

though these topics, in themselves, are assessed in the other

functional areas through their use as evaluation criteria, the two

areas provide a synopsis. For example, the effectiveness of manage-

ment involvement in assuring quality work has been assessed on a

day-to-day basis by resident inspectors and as an integral aspect of

specialist inspections. Although quality work is the responsibility

of every employee, one of the management tools to measure this ef-

fectiveness is reliance on quality assurance inspections and audits.

Therefore, the licensee's use of QA/QC functions is one factor, but

not the sole factor, used in assessing "Assarance of Quality." Oth-

4 er major factors that influence quality such as involvement of

first-line supervision, safety committees, and worker attitudes,

also are discussed in the respective functional area.

- The functional. areas in this report have~been modified to accommo-

date Shoreham's unique operational status. The areas of maintenance

and surveillance have been combined into one area, argi plant opera-

tions has been combined with startup test activities into one area.

The topic of fire protection is not addressed as a separate

functional area since no team inspections were performed. The

relevant inspector observations regarding fire protection and

housekeeping are included in the appropriate areas.

l

l

1

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

__ _

. .

.

1

5

2.0 CRITERIA

Licensee performance is assessed in selected functional area's which vary,

-

depending on whether the facility is in the construction, preoperational,

or operating phase. Each functional area normally represents areas

significant to nuclear safety and the environment, and are normal

programmatic areas. Special areas may be added to highlight significant

observations.

One or more of the'following evaluation criteria were used to assess each

functional area:

1. Management involvement and control in assuring quality.

2. Approach to resolution of technical issues from a safety standpoint.

3. Responsiveness to NRC initiatives.

.

4. Enforcement history.

5. Reporting and analysis of reportable events.

6. Staffing (including management).

7. Training and qualification effectiveness.

To provide a consistent evaluation of licensee performance, attributes

associated with each criterion and describing the characteristics appli-

cable to Category 1, 2, and 3 performance were applied as described in

NRC Manual Chapter 0516, Part II and Table 1.

Based upon the SALP Board assessment each functional area evaluated is

classified into one of the following three performance categories. The

definitions of these performance categories are:

Category 1: Reduced NRC attention may be appropriate. Licensee manage-

ment attention and involvement are aggressive and oriented toward nuclear

safety; licensee resources are ample and effectively used such that a

high level of performance with respect to operatin.al' safety or construc-

tion is being achieved.

Category 2: NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and are con-

cerned with nuclear safety; licensee resources are adequate and are rea-

sonably effective such that satisfactory performance with respect to

operational safety or construction is being achieved.

Category 3: Both NRC and licensee attention should be increased.

Licensee management attention or involvement is acceptable and considers

nuclear safety, but weaknesses are evident; licensee resources appeared

strained or not effectively used such that minimally satisfactory

. .

l

~

6

-

performance with respect to operational safety or construction is being

achieved.

The SALP Board has also assessed the licensee's performance during the

last quarter of the assessment period to the overall performance for the

entire SALP period. That comparison was used to trend licensee perfor-

mance as:

Improving: Licensee performance has generally improved over the last

quarter of the current SALP assessment period.

Consistent: Licensee performance has remained essentially constant over

the last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last -

quarter of the current SALP assessment period.

Natwithstanding the allowance permitted by a Category I rating to reduce

NRC attention, NRC oversight at Shoreham will be maintained at a high

level if a full power license is issued. Due to the nature and scope of

activities during power ascension and start-up testing, NRC inspection

oversight will not be reduced; it is NRC policy to conduct annual

appraisals for plants in such a phase for two years after operations

start.

.

e

.

. .

I

_

. 7

3.0 SUMMARY OF RESULTS  :

3.1 Facility Performance

CATEGORY CATEGORY

LAST THIS l

'

PERIOD PERIOD

^

(3/1/84 - (3/1/85 - RECENT

FUNCTIONAL AREA 2/28/85) 2/28/85) TREND *

1. Plant Operations 1** 2 Consistent

& Startup Testing

2.Radiclogical Controls 1 3 Declining

~

3. Maintenance & .

Surveillance 1 2 Consistent

4. Emergency Preparedness No Basis 1 Consistent

S. Security & Safeguards 1 1 Consistent

6.0utage & Modifications N/A 2 Consistent

7. Training & Qualification

Effectiveness N/A 3 Declining

8. Licensing Activities 2 3 Consistent

9. Assurance of Quality N/A 2 Declining

• Trend during the last quarter of the current assessment period.

• • The previous SALP rated ' Plant Operations' and 'Preoperational .

and Startup Testing' as separate functional areas. Each was

assessed as Category 1.

3.2 Overall Facility Evaluation

The functional area ratings assigned in this SALP period show a

pattern of inconsistency in the licensee's operation of Shoreham.

While the licensee has demonstrated in several areas the ability

to achieve high standards of performance, areas of significant i

weakness exist at the same time. 4

l

'

-

In comparing the ratings in this SALP period with those of the pre-

vious period, one must keep in mind that this period's ratings in- ~

volve an evaluation of licensee performance during a period of

initial operational activity and significant-outage activity, as

compared to the previous period of inactivity in most areas other

than licensing. Additionally, the ratings this period represent a

period of transition for the plant and its personnel. The SALP

. _ . .

. .

8

1

-

l

Board acknowledges the difficulty of that transition, especially as ,

compounded by the atmosphere of uncertainty in which employees must i

work. This uncertainty creates a situation where the morale of the

personnel at the plant is constantly chall_enged.

Despite these difficulties, the licensee has demonstrated that, when

appropriate levels of management attention, resources and commitment

are applied, quality performance can be achieved. This is evidenced

by the satisfactory completion of the 5% startup test program, actions

in closecut of-findings of the special Post Accident Sampling System

inspection, support for litigation issues, and personnel performances

of the onsite portion of the FEMA Full-Scale exercise. However, con-

tinued instances of personnel inattention to detail, failure to adhere

to procedures, inadequate responsiveness to QA audit findings, and

the recent problems in the Radiochemistry section all indicate a

need for an increased level of management attention to plant

activities.

Preoccupation of management personnel with licensing issues to the

detriment of other plant activities has been a weakness noted in

previous rating periods, and indications are that this problem has

not yet been fully resolved. As a consequence, management has been

required to resc1ve several problems in a reactive mode rather than

through a proactive system thich identifies and corrects potential

problems in a timely manner. Additionally, attention needs to be

increased in the area of planning for potential attrition of experi-

enced staff. Although efforts in some areas (specifically the

Operations Division) to pre plan for possible attrition are noted

in this report, these efforts are not evident throughout the

licensee's organization.

.

e

9

%

. .

9

.

4.0 PERFORMANCE ANALYSIS

4.1 Plant Operations and .itartup Testing (1831 hrs., 60%)

- -

A. Analysis

Startup Testing

In this assessment period, the startup testing activities asso-

ciated with the heatup phase of testing were completed. This

testing involved the initial heatup of the reactor coolant to

rated conditions and culminated in the initial roll of the main

turbine to rated speed. Initial criticality was accomplished

in the previous assessment period. Except for closecut of test

exceptions, the low power testing activities associated with a

5% low power license were completed during this assessment.

The startup testing activities during this assessment period

were more complex and more intense than during the prior as-

sessment period. The licensee management resolved a number of

NRC concerns identified during low power testing:

- The administrative program was revised to intensify the

management involvemer.t in the review and approval of com- ,

pleted test results, definition of acceptance criteria i

prior to proceeding to the next test condition, and '

licensee actions relating to resolution of significant

test exceptions. l

- There were several observations of friction and apparent

lack of cooperation between various groups in the testing

and operational activities, and the test briefings for

operations personnel were initially weak in the discussion

of potential plant problems. .The licensee's management

took prompt action to resolve these differences and im-

provement was observed as the low power testing program

progressed. The importance of good test briefings should

be continually stressed throughout the remainder of

startup test activities.

- The timeliness of the review of completed test activities i

was initially identified as an area for improvement. Dur- l

ing the low power testing the licensee improved the review

process and dedicated more personnel to perform this

activity.

The QA/QC coverage of the startup activities was adequate. QC l

inspectors were observed performing surveillances during numer-

ous startup tests. They have also participated in the review

process for all completed testing. The planned QA/QC coverage

for the remainder of the test program is adequate and involves

,

e

- - - - - -

i'

. .

,

.

.

. 10

.

~

the continuation of extensive surveillances of the performance

- of testing and the review of all test results.

Management involvement in the startup program was evident.

~

- They witnessed major testing evolutions and were observed to be

directly involved in the resolution of major plant problems

such as the the reactor water level divergence problem between

,'

the A & B. side and the condensate booster pump minimum flow

valve control air supply line rupture problem. The licensee

activities relating to the reactor water level problem involved

multi-disciplined personnel and was well controlled. The prob-

lem was sufficiently resolved to permit continuance of the

heatup phase testing and hardware modifications were made dur-

ing the recent outage.

l

Plant Operations -

in this rating period, the major licensee activity in the area

of plant operations involved the conduct of the low power test-

ing program, up to 5% power.

The performance of plant personnel in this testing program was

generally considered to be good, although errors by licensed

operators occurred. The two most significant of these errors

involved the opening of two 18" Primary Containment Purge

Valves, in violation of procedures, and the partial draining of

the reactor vessel to the suppression pool due to improper

valve manipulation.

Two problems also occurred as a result of activities of non-

licensed operations personnel. The first of 1"ese involved a

failure to ensure Suppression Pool levr,1 was rreper to allow

-

maintenance activity on an RHR valve. Due tc tSe level being ,

too high, approximately 7,000 gallons of water was spilled into

the Reactor Building upon valve disassembly. The second problem <

related to failure of personnel to properly complete Station

Equipment Clearance Permits in accordance with Station Proce-

. dures. In each instance, licensee corrective actions were ap-

propriate. However, the need for greater attention to detail,

4

and the adherence to procedures by personnel are areas in which

the licensee needs to focus greater attention. This issue was

raised in the previous assessment period as a need for improve-

ment.

Staffing of licensed operators at the plant remained at a sta-

ble level throughout the rating period. It is significant to

note, that while other areas of the plant experienced large

turnovers of personnel, the licens~ed personnel staffing level

i

remained stable. Overtime for licensed personnel was main-

tained well within the guidelines of NRC Generic Letter 82-12,

and no errors or omissions by personnel appeared to be

,

.

- - - e - - . ~ _.v,-. -,v w up. ---+ -,e-s

. .

11

_

attributable to fatigue due to overtime. The licensee now ful-

ly staffs six shifts in~the Operations section, and has a class

.

of license candidates in training. The licensee has also ag-

.

gressively recruited and hired a large number of Equipment

Operator trainees to ensure against future shortages due to

attrition.

In response to NRC initiatives, the licensee took two steps

during this rating period to reduce the administrative burden

on licensed personnel in the control room. One was the creation

of a second day shift watch engineer position. The second was

the staffing of a permanent Shift Production Assistant posi-

tion. This person provides clerical assistance to licensed

-

personnel on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis. The environment in the main con-

trol room is an area where improvements could be made. Specif-

ically, there are too many people allowed in the control room

and the attendant noise level is distracting.

The licensee also established and staffed a System Engineer

Section in the Operations Division during this assessment peri-

od. This section recently developed and implemented two com-

puter databases for use by operations personnel in tracking

plant status. These initiatives in providing management tools

for li:ensed operators to better track plant status is

noteworthy.

The Systems Engineer section has also provided hands on de-

tailed systems training to operations personnel. This contin-

.

'

uing training, conducted in addition to licensed operator

initial and requalification programs, demonstrates the

licensee's continued commitment to on going training for li-

censed personnel. This area, specifically the licensed opera-

. tor Requalification Program, has been judged to be a strength

in previous assessment periods, and this new licensee initia-

tive in the area of licensed operator training' reinforces that

judgement.

Operator Licensing activity during this period involved the

conduct of NRC license examinations at Shoreham in September

1985. Five Senior Reactor Operator and four Reactor Operator

candidates were administered written and oral examinations.

All candidates passed the examinations and were granted licens-

es. As a result of the high failure rate noted during exami-

nations in February 1985, LILCO management had committed to

increasing its monitoring and supervision of future operator

licensing classes. These most recent results indicated that

the licensed operator training program is adequate when given

proper management attention. -

.

. . . , . a-

.

. .

..

.

12

.

.

~

Housekeeping at the facility during this period continues to be

excellent. In particular, during the second half of this

~

period, while the facility was involved in numerous maintenance

.

and modification activities, the licensee was successful in

-

maintaining a high standard of plant cleanliness.

One team inspection was conducted to followup the issues iden-

tified during inspections performed in the previous assessment

period in'the area of safe shutdown capability of the plant in

the event of a fire. Technically sound and thorough approaches

and timely resolution of issues were observed. The fire protec-

tion staffing was observed to be ample and knowledgeable. Ag-

gressive action had been taken on previously identified problems.

Observation of the activities of the Review of Operations Com-

cittee (ROC) and Nuclear Review Board (NRB) during this rating

period indicate that the licensee is effectively utilizing

~

these oversight committees for independent review of plant ac-

tivities. NRB involvement in plant audits is evident.

B. Conclusion

.

Rating: 2

Trend: Consistent

C. Board Recommendation

'

Licensee: . Focus greater attention to ensuring personnel

adherence to procedures

NRC: . None

.

%

!

.

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

. .

..l

13 ,

.

.

4.2 Radiological Controls (317 hrs.,10%)  ;

,

A. Analysis

.

There were six region based inspections during this assessment

period; five routine and one special. -Inspection efforts this

period focused on licensee corrective action for post-accident

sampling and analysis program deficiencies to support operation l

beyond 5% power; non-radiological chemistry; radioactive waste

transportation program establishment and implementation;

preoperational and startup testing; and licensee action on clo-

sure of previous NRC findings. Other areas reviewed included

Radiological Controls Organization and staffing; personnel

training and qualification; and external and internal exposure

controls. Special reviews were conducted in the area of radio-

chemistry as a result of allegations of program deficiencies

received by the NRC.

Weaknesses identified during the last assessment period were

i

the need to clearly define the responsibilities and authorities

'

of the site and corporate Radiological Controls Organization

positions. Also, a need was identified for a walk-through of j

radiation protection program elements to identify progranmatic

i weaknesses and inconsistencies.

The licensee has established in a timely fashion clearly de-

fined function responsibilities for each position within the

site and corporate radiological controls organization. Howev-

4 er, levels of delegated authority for each position have yet to

be established. Program walk-throughs were not conducted as

recommended.

-

The overall performance in this area relative to the last as-

sessment period has degraded. Weaknesses identified show a

- lack of management attention to assure that identified problems

are corrected. Also inadequate and inconsistent control and

oversight of day-to-day activities in this area is apparent.

The degradation is primarily present in the

chemistry / radiochemistry area with some examples in the area of

'

radiation protection and radwaste transportation.

l Radiation Protection l

i

. '

Due to the low radiation and radioactive material source term

" at the station, implementation of the external and internal

exposure control programs was not significantly challenged dur- 1

ing this period. With some exceptions discussed later, the- l

radiation protection program is' adequately defined by accept-

able policies and procedures. Management is generally respon- i

sive to NRC findings in this area. NRC identified problems are l

resolved in a timely, technically sound manner. A technically

,

6

'

.

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

.

. ,

.

.

14

.

.

competent staff is available.to implement the program, although

staff shortages in the technical support area and ALARA coordi-

nator positions are areas where attention needs to be in-

. .

creased. One apparent weakness is a lack of significant

operating experience by senior supervisory personnel in the

group. The licensee is addressing the matter by using an expe-

rienced contracted individual to augment the organizations ex-

perience and fill a key position that has been open for some

time. This is an acceptable interim solution but should not

be viewed'as a long term answer.

Regarding training and qualifications, the initial training

program for radiation protection personnel is generally well

defined and makes a positive contribution to performance of

work with few personnel errors. However, there is no continu- l

ing retraining program to notify radiation protection personnel

<

of safety significant procedure changes or new procedures in a

~

timely manner. This weakness is attributed to inadequate pro-

gram development in this area.

The licensee has established an effective general employee

training and retraining program in this area. Training records

are complete, well maintained and available. Management has

provided adequate training resources and training facilities.

To minimize impact on the radiation protection group during the

period of low power operations, the high radiation area access

control program required by Technical Specification was delet-

ed. Although no uncontrolled high radiation areas were identi-

fied, the deletion of the program illustrates a lack of

attention to maintenance of minimum program elements required

by technical specifications. Also, the deletion of the program

- creates a lack of program maintenance and continuity which is

important in familiarizing and educating plant personnel with

regard to requirements in this area. Program elements lacking

o- inadequate included: procedures for high radiation area key

control; inadequate procedures for access to traversing incore

probes and sub pile room; and inadequate procedures for access

to the drywell during fuel movement. The licensee initiated

action to establish and up grade procedures in this area in a

timely manner when it was brought to management's attention.

Additional attention by management'1s needed to ensure continu-

ity and adequacy of station radiation protection program ele-

ments required by license conditions.

A review of licensee actions to resolve program deficiencies in

the area of NUREG-0737 post-accident sampling and analysis

found that the licensee took timely, technically sound action

to resolve the deficiencies. The resolution of the findings

was effectively managed in that a task force approach was used.

Records of corrective actions were complete, well maintained

and available. Technically qualified personnel were utilized.

. .

15

.

While some problems were encountered in the area of licensee

'

interpretation of requirements, corrective measures were imple-

mented in a timely manner. Overall, the licensee was very re-

sponsive to NRC findings in this area.

Radioactive Waste Management and Transportation

Review of the Radioactive waste shipping program found it to'be

generally adequate and properly implemented. Responsibilities

of personnel involved with radioactive waste shipping activi-

ties were clearly described. Radioactive waste personnel were

trained in applicable requirements. Training records were com-

plete and well maintained. Shipping procedures were adequate.

.

The Quality Assurance oversight of radioactive waste transpor-

tation activities was found lacking. Individuals performing

audits of activities in this area had not received adequate

training or qualification. In addition, audit reports of

radwaste activities failed to provide adequate indication that

the licensee had conformed with the applicable specific quality

assurance criteria of 10 CFR 50 Appendix B despite the fact

that report summaries indicated that conformance had been veri-

fied. This is evidence of weakness in the program for self-

identification of problems.

Chemistry, Radiochemistry and Effluent Controls and Monitoring

The chemistry group is satisfactorily organized for the manage-

ment of the station's chemistry, radiochemistry, and effluent

monitoring and control programs. However, weaknesses in the

area of: staffing, program oversight and control, procedure

adequacy, corrective action program, and corporate support of ,

plant programs has resulted in major programmatic concerns not l

being identified and corrected in a timely fashion. NRC in-  !

.

volvement was needed to assure identification and implementa- l

tion of lasting, comprehensive corrective action. l

In the area of staffing, 40% of the professional positions

within the site chemistry group are filled by contractors.

Some key positions have been filled by contractors for an ex-

tended period of time. The group experiences the highest

turnover rate among the station groups.

Regarding the training and qualification of chemistry person-

nel, reviews found that an adequate, documented program exists

to select, train, and qualify chemistry technicians. However,

a special inspection of training and qualification of chemistry

technicians, performed in response to allegations received by

the NRC, found that the chemistry. technician training program j

,

e

ar- e- ~y.- - _ . , . - -s,, sec ,--.9.+. .-evwI

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

. .

,

..

.

16

.

was not properly _ implemented. Open book exams and the personal l

l

judgement of a chemistry foreman were used to qualify techni-

cians rather than the procedurally required check-outs or task i

evaluations. Based on NRC observations, it appeared that sub-

stantive action was not taken by licensee management to address

the root cause of the problem until the NRC became involved.

In the area of chemistry and radiochemistry program establish-

ment, the program was generally defined by technically accept-

able procedures. However, procedures for quality. assurance i

were generally inadequate indicating a clear lack of apprecia-

tion by management of the need for accurate, reproducible mea-

surements.. Program procedures were not established in a manner

1 to quickly identify and resolve out-of-specification

chemical / radiochemical measurement data. The deficiencies in

l the area of quality. assurance are ascribed to inadequate proce-

l

dures, a lack'of sufficient technical expertise within the

chemistry staff, and a lack of adequate program review and

oversight by the corporate Radiation Protection Division.

!

The deficiencies discussed above were identified during a LILCo

' quality assurance audit conducted in May and June of 1985.

However, NRC inspection ravealed that the deficiences still

j existed in February 1986 and that little progress in imple-

menting effective fixes had been made. Even after a Corrective

Action Request was issued by the Quality Controls Division, the

issue was still not promptly and effectively addressed. The

Quality Controls Division and Quality Assurance Department's

. handling of this issue was ineffective. Similarly, plant man-

agement was aware of these problems but did not take the neces-

sary actions to achieve a timely and effective resolution.

Summary

The radiation protection and radwaste shipping programs were

not significantly challenged during this assessment period.

However, deficiencies identified indicate a need to improve

oversight and control of these program elements. Problems

!

identified in the chemistry and radiochemistry programs

indicate a major programmatic breakdown of the chemistry /

radiochemistry program. Inadequate oversight and followup to

!

.

self-identified problems clearly c~ontributed to the problem.

'

B. Conclusion

Rating: 3

Trend: Declining

!

.

s

I

--- - --,

,-c - - - - , - . -

a .s. -- e

. . .

..

17

C. Board Recommendation

Licensee .

Establish and implement effective oversight and

control of the chemistry and radiochemistry pro-

grams and assure that the lessons learned from-

the breakdown are applied to other areas.

. Fully staff the chemistry group and radiation

protection groups with qualified permanent

-

personnel

NRC: .

Conduct an inspection of this area within four

months of this SALP to determine the adequacy of

licensee corrective actions.

.

G

N

.

9

l

.

i

- _ _ _ = _ , W@wy 'w, _ _

'

. .

..

.

18

'.

,

4 .- 3 Maintenance and Surveillance (250 hrs., 8%)

A. Analysis

During the previous assessment period, it was noted that the

licensee should increase attention to the area of preventive

maintenance to reduce the backlog in the preventive maintenance

program. It was noted that understaffing appeared to be a

prime contributor to this problem.

..

The area of preventive maintenance continued to be a problem at

the beginning of this rating period. One problem was the docu-

mentation of actual maintenance work outstanding on incomplete

items lists. The list was observed to not be up to date and

contained numerous items that had actually been accomplished.

In the second half of this period, progress in correcting this

situation was' evident.

The maintenance group has also been observed to be backlogged

in its evaluation of identified generic problems for applica-

bility to Shoreham Station. In one instance identified by an

inspector, the failure of a feedwater minimum flow valve, due

to vibration induced loss of its antirotation device, may have

been prevented by the timely review of IE Notice 83-70, Supple-

ment 1, " Vibration-Induced Valve Failures", which had not bean

evaluated due to the backlog. The licensee has assigned addt-

tional manpower to address this problem.

Management followup of identified maintenance problems could be

more expeditious and thorough. When an inoperative minimum

flow valve in the "B" RHR loop lead to the discovery that four

bolts which secure the valve operator had sheared off, the

scope and priority given to inspecting other valves for similar

problems was inadequate. While the limited inspection did re-

.

veal a broken mounting bolt on the "A" RHR loop minimum flow

valves, it was not until an NRC inspector identified a similar

problem with a third RHR valve that the scope of the inspection

was increased, additional personnel assigned and an earlier

than planned shutdown begun. The final results of the in-

creased inspection revealed seven RHR valves with icose mount-

ing bolts, one with a sheared moun, ting bolt, one with a loose

handwheel, and one with a missing handwheel. In addition, it

' was not until four failures occurred in the control air supply

line to the condensate suction booster pump minimum flow valve

and a reactor scram occurred on low level, that management was

fully involved in the resolution of the problem. However, once

management was involved the problem was resolved.

During the previous assessment period, the procurement of spare

parts was noted to be a problem. The lack of readily available

spare parts and components continues to be a problem.

.

_ _. _,

. .

19

'

,

Conversely, in some cases people were not aware that needed

spare parts were already in the warehouse system and this led

to delays in planned activities and job completion. ~

During this assessment period, maintenance management institut-

ed an organization called the Shoreham Information Management

System (SIMS). This group is comprised of representatives of

all on-site departmente and organizations. It's purpose is to

coordinate and develop an integrated data base which will be

utilized by all organizations associated with Shoreham.

The interface between the maintenance division and other plant

divisions in the resolution of technical problems is evident.

A recent example 5f this was the coordination of the Computer

Section and Security in resolving major computer program errors

in the Security Computer. This resulted in an improved avail-

ability of the Security Computer to 99.4%. This improved

availability reduced the need for compensatory measures by the

licensee in the security area, thereby reducing personnel

constraints. j

During the previous assessment period it was noted that the

licensee needed to increase attention to a developing problem

with the frequenr.y of unnecessary challenges to safety protec-

tion systems initiated by surveillance activities. During this

rating period, the problem of challenges to safety systems dur-

ing surveillance activities has not improved.

There were six instances in which maintenance or surveillance

activities caused an inadvertent plant shutdown signal to be

generated. Three of these resulted in reactor scrams from low

power. In one case, the incorrect desiccant was installed in an

air dryer, due to an inadequate procedure and personnel unfa-

miliar with this routine activity, resulting in low air pres-

sure and control rod drifts requiring a manual scram. In two

cases, automatic scrams occurred due to spurious low reactor

water level signals induced during the course of routine sur-

veillance activities.

A number of other personnel errors, creating challenges to ESF

systems, occurred during surveillance activities while the

plant was in the neutron source outage. Licensee management

initiated a comprehensive review to determine if root causes

existed for these errors. The licensee met with NRC Region I

on January 28, 1986 to discuss this matter. Although no spe-

cific causes could be determined, the licensee did identify

contributing factors to the problem of personnel errors. The

NRC considers lack of attention to' detail by personnel perform- ,

ing surveillance activities to be a contributing factor. The I

licensee's actions in investigating this matter were prompt,  !

comprehensive, and thorough. Proposed corrective actions, j

.

_ - .

.

. .

..

20

'.

l

'

which included evaluation of work scheduling, revision to sur-

veillance procedures, hardware modifications, and increasing

personnel awarness to the need for attention to detail were

appropriate. _The effectiveness of these corrective actions

will be monitored in the next rating period.

B. Conclusion

Rating: 2

.

Trend: Consistent

C. Board Recommendations

Licensee: .

Review the system for the procurement and

contr.ol of spare parts

. Increase management attention to the area of

reducing the number of challenges to ESF systems

resulting from personnel error

NRC: . None

'

.

w

e - ,, n.--

_ _ _ _ _

_ _

. .

..

21

.

4'. 4 Emergency Preparedness (331 hrs., 11%)

~

A. Analysis

During .the previous assessment period, no rating was-given in-

the functional area of Emergency Preparedness due to limited

observations. During this assessment period, the only activi-

ty, other than the observation of training drills by the resi-

dent inspectors, related to Emergency Planning was the conduct

of a FEMA Full Scale Exercise on February 13, 1986. This drill

was conducted without the participation of New York State or

Suffolk County officials. The observations by NRC inspectors

were limited to the on-site portions of the exercise (including

the EOF).

Although this was the first exercise that has been formally

observed by the NRC at Shoreham, the NRC observation team noted

that the utility staff is thoroughly trained and practiced and

is part of a well established emergency preparedness program.

The effectiveness of the plan and its implementing procedures

was evident during the exercise as noted by the efficient man-

ner in which the utility staff ime' 2mented Emergency Plan ac-

tions in response to scenario events. Plant procedures and

policies were strictly adhered to throughout the exercise.

The on-site portion of the emergency preparedness program

(including the EOF) appears to be well established and operat-

ing smoothly. High level management is actively involved in

the program and has managed to keep enthusiasm of emergency

team members high despite uncertainties with the implementation

of the the off-site portions of the plan.

The licensee's on-site Emergency Preparedness organization was

activated to the alert level at one time during this assessment

period. This activation occurred during Hurricane Gloria. The

licensee's actions with regard to plant safety during this ac-

tivation were considered very good.

Observation of licensee Emergency Preparedness training drills

on a regular basis by the resident inspector (s) showed that

Senior Management was completely involved in the training of '

plant staff. Third party and Quality Assurance Department

audits of these drills allowed independent assessments to be

made. Corrective actions, in responte to areas for improvement

identified by NRC or third parti ~es, were promptly and effectively

initiated.

The licensee had committed itself to a quality Emergency Pre-

paredness organization,.and this commitment has resulted in the

level and type of training and management involvement which

l

.. .

- - - - -

.

-

.

. .

..

.

22

.

results in a successful program. It is clear that the exten- .

sive management attention given to this functional area result-

ed in a high quality performance being demonstrated at all

levels of the onsite organization.

,

.

B. Conclusion

Rating: 1

Trend: Consistent

C. Board Recommendation

Licensee: . None

NRC: .

None,

i

.

4

.

s

f-~"~- -v-,, ,- - , , . . - - . - , _ , . , ,, _

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

. .

..

1

23

~

4

,

4'. 5 Security and Safeguards (207 hrs., 7%)

A. Analysis

'During the previous assessment, no significant weaknesses were ~

identified, and the licensee's performance in this area was

assessed as Category 1. One special and two routine unan-

nounced physical security program inspections were performed by

Region-based inspectors. Routine resident inspections contin-

ued throughout the assessment period. No violations were iden-

tified during this rating period.

Licensee management continues to be effective in carrying out-

the security program. This is evidenced by the ability of the

security organization to cope with changing conditions with

ragard to law enforcement, modified protected area boundaries, ,

and additional vital areas. l

Further evidence of management attention to the security pro- l

gram is demonstrated by the audit and appraisal programs that

have been implemented. In addition to the internal audit by

' licensee QA personnel, the licensee provides for a comarehen- 1

'

sive audit of the security program by an independent group of

consultants. In such an audit conducted during this assessment-

period, each deficiency identified received a comprehensive

response by the Site Security Supervisor and prompt corrective

action was initiated and completed where necessary. The

licensee's desire for an effective program is also demonstrated

by continued improvements in the program, as evidenced by the

l licensee's plans to move the Central Alarm Station and Secon-

l

dary Alarm Station (CAS/SAS) operations to larger quarters and,

in the case of SAS, to a more favorable location. The location

of the SAS in the control room has been an NRC concern f6r sev-

eral years in that the SAS is located in the control room prop-

er where it can be a distraction to the operator. The plans

also include upgrading the hardware'and software systems asso- ,

ciated with the alarm stations. Staffing of the program was I

exemplified by the use of well qualified and dedicated

personnel.

There were four events that required reporting in accordance-

with 10CFR73.71 during the assessment period. Each time, the

licensee handled the event methodically and efficiently, and in

accordance with the NRC-approved security plan and implementing

!

procedures. The events were promptly reported to NRC and com-

plete information was provided.

The security staffing is adequate', but a short' age in clerical

help appears to have resulted in security supervisors and

training personnel taking time from their primary functions and

occasionally using overtime to perform record keeping and

.

I

e

r'. r y -o ,, w y--, .

m. -_m_-_9, ,,-p m99 ..gm. .-,,.3,,.w. p. ,,- - pr. .-,gy, em -w . - g -%be-g,g,p., g- .sW --

.

. .

..

24

.

.

.

~

filing duties. Continued use of supervisors and training per-

sonnel in this manner requires management attention to assure ,

this does not prove detrimental to the security program. ,

-

The licensee's security force contractor has provided an effec-

tive training staff to maintain security force personnel train-

ing at an acceptable level. The licensee's security staff

ensures the program effectiveness through review and approval

of the training program and routine audits. As stated in the

previous.SALP assessment, the licensee chose to implement the

security program at an early date to ensure time for adequate

training and qualification of the security force. The NRC spe-

cial inspection conducted in March, 1985 demonstrated the value

of this early implementation, in that the inspection found, in

re-examining a statistically selected sample of the security

force, that they were well qualified for the duties to which

they were assigned; This review was further strengthened by

the fact that no violations of NRC requirements were identified

during the assessment period.

4

During the assessment period, the licensee submitted a revision

to the security plan to provide for emergency backup power gen-

erators in the event they would be needed for low power licens-

ing. Although the power sources were ultimately not needed,

the submittal afforded the NRC adequate time for review and was

considered complete and acceptable for implementation.

The area of Security and Safeguards, like Emergency Prepared-

ness, is one in which the licensee has demonstrated the ability

to perform at a high level of quality. The Security and Safe-

guards area is one in which the licensee's performance indi-

cates effective actions in identifing and correcting potential

problem areas at their own initiative.

B. Conclusion:

Rating- 1

Trend: Consistent

C. Board Recommendation

Licensee: . None

NRC: . None

.

=

m

-

-- g*.

l

'

. .

.1

25 j

.

4.6 Outage and Modifications (131 hrs., 4%)

A. Analysis

~

Outage and Modification. activities are routinely monitored by

resident inspectors. In addition, one inspection of the

licensee's modification program was conducted by two

region-based inspectors. A significant number of inspection

hours related to tnis area are included under plant operations.

This functional area was not evaluated in previous assessment

periods due to Shoreham's status as a construction facility.

During this assessment period, the licensee completed over 60

modification activities in a period of five months. These ac-

tivities include; neutron source replacement, completion of EQ

modifications, and, modifications to the reactor vessel water ,

2

level systemc As a' result of these activities, for most of the

last half of this assessment period, the facility was in an

outage condition.

The licensee has a separate organizational division for Outage j

and Modifications which reports to the Plant Manager. The di-

vision consists of an Outage Section, Modifications Section,

and Planning & Scheduling Section, as well as a section devoted

specifically to the Colt diesel generator project.

The licensee has been unable to fully staff the Outage and Mod-

ifications Division with LILCO employees, and while it is the

smallest division (with 42 authorized positions), it has the

highest vacancy rate for licensee employees (33.3%). The

licensee has filled the vacancies with contractor personnel.

The use of large numbers of contractor personnel creates a sit-

uation where attrition and contractor rotation introduces in-

consistency in performance. Turnover of licensee employees

within the Outage and Modifications Division is the lowest in i

~

the plant (3.5%), and aggressive attempts to increase the number

of full-time licensee employees is evident.  ;

Management involvement in Outage and Modification activities is

evident. The Division Manager is frequently observed in the

field checking the status of on going jobs, and observing work

in progress. Additionally, the presence of Division Managers ,

at daily planning and scheduling meetings is evident, with the 1

presence of the Maintenance and the Outage & Modifications Di-

vision Managers being especially noteworthy. Plant Manager

involvement in these meetings is frequent. The presence and

involvement of these management personnel has frequently been

observed to be instrumental in the resolution of problems and

reprioritization of schedules. ,

!

-

m*

. . - - - . . . . . . . -

\

. .

j

..

' 26

. l

_

l

,

'

Tha technical resolution of engineering difficulties during

modification activities is a strength in the licensee's Outage

'

and Modification Program.- Nuclear Engineering-Department and I

Stone & Webster Site Engineering Office personnel attend daily

planning and scheduling meetings, and the NED Manager frequent-

-

-

ly is present. Coordination among plant staff, NEO, and Stone

& Webster in resolving problems is a strength of the licensee's

program. Frequently, issues are discussed and resolved on the

spot at the daily meetings. NED and Stone & Webster's review

of modification activities is thorough and comprehensive. Fre-

,

quent NED assistance in the. resolution of procurement or docu-

mentation problems is evident.

An inspection of activities related to modification activities

conducted in the second half of this rating period found the

implementation to be generally good. The detail and clarity of

modification procedures, knowledge of personnel, involvement

and interface of modification and engineering staff, interface

of Quality Control, and extensive Review of Operation Committee

review of modification packages were observed as strengths in

i the licensee's program. A need for improvement by the licensee

in the areas or control of tags during modification activities,

record retention, and attention to detail in the closecut of

modification packages were also identified.

4

Outage and Modification Division Management has establis.hed a

firm commitment to training and qualification within the divi-

sion. Two of the four Outage and Modification Division Section

Heads are presently in training to receive SRO licenses, and a

third presently holds an SRO license. This knowledge of plant

operations, systems, and technical specification requirements

is beneficial in the coordination of work activities. In addi-

tion, the Modifications Section is involved in frequent train-

ing sessions which involves areas such as; Administrative

'

controls, hands-on experience, the'ory, and technical issues.

!

The Modification Section also conducts training sessions for

NED, QC, and operations personnel.

' Prior to the beginning of the Source Replacement Outage in Oc-

tober, the licensee sent the Outage Engineer to the Susquehanna

,

i Steam Electric Station for 2 months to observe the activities

of their outage group. This training and familiarization ap-

i

peared to be extremely beneficial and is considered to be one

of the reasons that the outage was conducted in a successful

manner. The licensee uses a number of computer systems and

tracking programs to schedule work activities and coordinate

outage management. These systems allow management to track

completion of scheduled activities and resolve problems which

l

are delaying work activities.  ;

I

,

-

- - -w mw-yp, e ,p,p-ee----'g y-e - + 7-+.yg-w p.yp--,-c--p.w. - ---,--p-----y - v- -

-wy- --.w.

. .

.

27

.

The licensee's performance in the area of Outage and Modifica-

tions to date has been effective. However, the organization

has yet to be challenged at a level which is equivalent to that

which will occur during refueling outages, or during modifica-

tions under a full power operating license. -The framework for

an organization which will function effectively during full

power operations exists. The licensee should increase atten-

tion to staffing, and continue the positive steps in the area

of training-to ensure that the organization can make the tran-

sition with little or no problem.

.

B. Conclusion

Rating: 2

Trend: Consistent

C. Board Recommendation

Licensee: Continue efforts to complete staffing

NRC: None

,

a

l

-

l

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

--. - -

. ,

..

.

28

.

'.

_

4.7 Training and Qualification Effectiveness

A. Analysis _

- During this assessment period Training and Qualification-effec-

tiveness is being considered as a separate functional area for

the first time. Training and qualification effectiveness con-

tinues to be an evaluation criteria for each functional area.

The various aspects of this functional area have been consid-

ered and discussed as an integral part of other functional ar-

eas and the respective inspection hours have been included in

each one. Consequently, this discussion is a synopsis of the

assessments related to training conducted in other areas.

Training effectiveness is normally measured primarily by the

observed performance of licensee personnel, but in the case of

Shoreham, with its' extended period of low power operation and

outage, this is not possible. Therefore, to a greater degree,

this assessment has been a review of program adequacy.

l

The discussion below addresses three principle areas: licensed

operator training, non-licensed staff training, and status of

INPO training accreditation.

The training of non-licensed personnel is an area where a sig-

nificant increase in the level.of management attention is war-

ranted. Significant problems were noted by the NRC in a special

inspection of the Radiochemistry program at the plant. These

included inadequate records, violations of Station Procedures

for qualification, and improper on-the-job training. Additional-

ly, in areas other than Radiochemistry, the licensee's Quality

Assurance Department has discovered numerous problems with train-

ing and qualification. Training of non-licensed personnel has

~

been almost completely left to plant technical sections, and

~

Training Division oversight and assistance to these sections is

- not evident. The~ reliance upon the Technical Sections for

training activities has created an additional burden for the

plant staff, which in many cases is already overburdened and

understaffed. This split of responsibility has also created

conflicts between plant and training division records, and has

created situations where the training department has become

simply a repository for training . files. Training Division l

review, audit, or Quality Control of these records is not i

evident.

Although the licensed operator training program has greatly

improved since the last SALP period, the areas of non-licensed

operator training and management. involvement in training are

considered to be areas of significant weakness. Although Divi-

sion Management and section supervisory personnel attempt to

individually ensure that effective and valid training is

,

1

.

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

- _ _ . _ _ ------,.--w-n,w c.-,,, au ,,- - - , . , , - - - _ ,

__ -___ __

.

.

29

-

offered to their personnel, the lack of Training Division and

Senior Management attention to training has created inconsis-

tency, and in one case, allowed -improper implementation of a

training progran to occur. At the end of this rating period,

the licensee had begun increasing attention to the area of

training by establishing a new position of Corporate Director

of Training who will report directly to the Executive

Vice-Fresident. NRC will be closely monitoring this area dur-

ing the next SALP period to determine whether effective correc-

tive actions are being made.

The performance of licensed personnel in the control room dur-

ing testing, and during transient events initiated by equipment

malfunctions demonstrated the ability to handle the plant in a

competent and professional manner. Knowledge"of system opera-

tional characteristics, familiarity with procedures, and ac-

tions on transient response were evident, and are indicative of

effective and valid training and requalification for licensed

operators. Nonetheless, attention must be given by licensed

operators to plant conditions and operating procedures during

all modes of reactor operation so as to avoid the types of ,

'

problems discussed in Section 4.1, Plant Operations and Startup

'

Testing.

During-this assessment period, the Quality Assurance Department

instituted an Operational Training Program for QA, Safety, and

Compliance personnel. This program is taught by a licensed

SRO. The purpose is to increase the systems and operations

knowledge of the attendees to allow them to more effectively

perform their jobs. The program includes examinations which

must be successfully completed at stages in the program in or-

der to continue. This initiative demonstrates a strong commit-

ment to training by the QA Department.

The licensee is pursuing the training program accreditation

-

with the Institute of Nuclear Power Operations. Accreditation

'

should be complete within 2 years of fuel load in accordance .

with the NRC Policy Statement on training. Fuel load occurred

at the plant in December 1984. No programs have been accredited

to date. The first four programs, in the operations area, are

scheduled for Self-Evaluation Report submittal in August 1986.

The remaining programs will be submitted in late 1986 or early

1987. .

B. Conclusion

!

Rating: 3

Trend: Declining

.

P

J

!

-

m.-- _ ,, ,.._ . , , , , .

9 y 2-- e. ---v-- -

P-e--

. .

.

30

.

_

C. Board Recommendation

Licensee: . Direct management attention to establishing good

training in all plant areas

'

. Reassess the reasons for the contrast between

the training in areas such as Emergency Planning

and Security versus other plant areas

NRC: . Conduct a management meeting with the licensee

in July or August to discuss the adequacy of

training and qualification.

.

Conduct a six month appraisal of the Training

and Qualification area "

.

Conduct a special inspection into Training and

. Qualification cctivities at Shoreham

,

6

9

%

>

,e , - v-- -- ~ - - - , ,, - - , - -

_ _ - _ _ _ - _

.

'i

31

4.8 Licensing Activities l

,

-

A. -Analysis

- During the previous-assessment period, the need for the

~ licensee to devote more attention to non-critical path activi-

ties, and to prevent hearings and litigation issues from inter-

fering with plant staff normal responsibilities were noted.

Additionally, the existence of a restraint on the interchange  !

of information between the licensee and the NRC staff due to

the atmo'phere

s of litigation which surrounds all activities

related to Shoreham was noted. This situation continues to

exist, despite a significant reduction in the licensing tempo ,

during the rating period.

The licensee's management continued to participate directly in

the most major critical path licensing activities during this

period, most notably emergency planning, the TGI EDGs, and the

GDC-17 exemption. Because these issues were, and in the case

of emergency planning still are, on the critical path for li-

censing, this management involvement made a positive contribu-

tion in assuring quality. During the staff's review of the

equipment qualification exemption request, the licensee's man-

agement was instrumental in providing additional information in

a timely fashion. Similarly, the Vice President for Nuclear

Operation has personally participated in the emergency planning i

process, including the performance of the drill on February 13,

1986.

The technical review of the TDI EDGs has also received continu-

ous management involvement and support which has been the prin-

cipal reason for its success. When the favorable ASLB decision

on the TOI EDGs was issued, senior LILCD engineering managers  ;

participated personally in the development of the license con-

ditions and technical specificati'ons needed to implement the

ASLB decision.

Similarly, in the spring,of 1985, LILCO management placed the

full resources of the company behind the resolution of security

concerns associated with the GDC-17 exemption process.

Notwithstanding the above, however, it was noted that the "sig-

nificant hazards" analyses accompanying requests for license

amendments have been perfunctory and conclusary, rather than

true analyses. In this regard, the licensee's performance is

typical of many others (see Generic Letter 86-30). Future li-

cense amendment requests should include sufficient detail for

the reviewer to understand the details of the request and the  !

basis for it without resorting to a review of the entire FSAR.

~

.

___

.

.

32

4

During the low power testing program a concern was raised by

NRC regarding the licensee's interpretation of reporting

'

requirements prior to receiving NRC concurrence on this inter-

pretation. This involved a power spike greater than 5% power

due to equipment malfunction. Although Facility Operating Li-

cense NPF-36 limited the plant to 5% power, and required re-

porting (via the ENS line) to the NRC operations of violations

of this limit, the licensee initially felt a report wasn't re-

quired. The basis for this belief was an, at that time unan-

swered, letter to.the NRC regarding the need for ENS reporting

of unintentional violations of license conditions. It was only

after insistent prodding by the Senior Resident Inspector and

the Licensing Project Manager that the licensee reported the

event. The performance of the licensee in this matter was not

indicative of satisfactory responsiveness to NRC initiatives.

This incident also demonstrates a need for licensee management

to be less concern'ed with public and press reaction to poten-

tial reportable events. A similar attitude was evident among

licensee management when it became necessary for the licensee

to report non-conformance with a license condition on comple-

tion of EQ modifications by the November 30, 1985 NRC deadline.

The licensee's technical response to tne resolution of most

issues continues to be generally sound. NRC staff reviews dur-

ing this rating period have concentrated on the resolution of

portions of larger issues left over from the previous rating

period. The licensee's management and staff continue to demon-

strate a good understanding of these issues. Specifically, the

licensee's performance regarding the TDI EDGs has been excel-

lent. In the area of fire protection, the licensee's response

to the issue of the control of associated circuits for the ADS

valves was especially conservative, compared to other

,

licensees.

However, the licensee's initial response to human factor con-

cerns raised by the NRC staff related to TDI EDG loading was

deficient, and the staff had to prod the licensee to perform a

proper task analysis.

As was noted in the previous assessment period, LILCO is will-

ing and able to marshal whatever resources are necessary to

resolve issues that remain on the critical path for licensing.

The two prime examples of this are the TDI EDG effort and the

off-site emergency planning organization, which encompasses

over 2000 LILCO employees from throughout the company. Howev-

er, the licensee responsiveness to other initiatives, which are

not on the critical path, whether NRC initiated or licensee

initiated, is still low. This.was evident in the time required

to respond to open fire protection issues, the issue of the

operability of the HPCI, RCIC, and RWCU isolation valves, and

the TDI EDG human factors task analysis.

-

- -

w

.

.

33

.

~

Another example of an issue whose resolution has been delayed

is the Probabalistic Risk- Assessment (PRA). During the origi-

nal licensing board hearings in 1983, LILCO committed to pro-

vide the staff with the results of its PRA, including the

~

-

consequence analysis section. The licensee submitted the first

two parts of the PRA in 1984, but has not, to date, submitted

the consequence analysis section, despite continual verbal re-

minders from the staff. This has delayed completion of the

staff review for over two years.

The delays discussed above can be traced to two fundamental

causes. First, an atmosphere of litigation continues to sur-

round this project. It has created an over cautious attitude

about what is written into formal submittals to the NRC, and

how it is written. Consequently, a protracted review process

has been established which inevitably produces delays. In some

cases, it has also reduced the usefulness of letters to the

NRC, because of resultant ambiguities.

A second cause appears to be understaffing in the licensee's

licensing organization. Three experienced licensing engineers

have left that organization in the last year, with a resultant

ir. crease in workload for the remaining two engineers. If and

when Shoreham is eventually licensed for full power operations,

the workload of this group will increase substantially.

Licensee management must take aggressive action to correct this

situation to prevent future serious problems.

B. Conclusion

Rating: 3

.

Trend: Consistent

C. Board Recommendation

.

Licensee: .

The licensee should improve its responsiveness

to NRC initiatives which do not directly affect  ;

'

the licensing schedule. Submittais should be

more thorough, detailed, and specific. Techni- .

cal Specification changes should be accompanied

by true analyses, rather than by perfunctory

conclusions.

NRC: Senior NRC management should discuss with senior

licensee management their overly cautious attitude

about releasing information, so that the flow of

necessary information is not impeded.

.

.

.

.

34

.

1

~

4.9 Assurance of Quality- -

_

A. Analysis

_

Management involvement and control in assuring quality con-

tinues to be one of the evaluation criteria for each functional

area. During this assessment period Assurance of Quality is  !

being considered as a separate functional area for the first l

time.

The varidus aspects of Quality Assurance and Control (QA and

QC) program requirements have been considered and discussed as

in integral part of each functional area and the respective

inspection hours are included in each area. It should be noted

that QA is only one management tool available to provide feed-

back to management on the quality of work. Consequently, this

discussion is.a sydopsis of the assessments relating to the

quality of work conducted in other areas and is not intended to

be restricted to a discussion of QA or QC.

The assurance of quality in plant operations is an area where

the licensee has demonstrated contradictory performance. Secu-

rity and Safeguards, and Emergency Planning are two areas which

demo 1 strate that the licensee has the ability to devote the

necessary time, attention, and resources to assure quality ac-

tivities. However, these areas contrast clearly with training,

licensing, and Radiological controls, in that no such commit-

ment to quality activities is evident in those areas. Addi-

tionally, areas in this report which detail weaknesses in

procedural adherence, control of activities, spare parts pro-

curement and control, and personnel inattention to detail,

point up deficiencies in the licensee's overall implementation

of quality activities.

It is evident that when the licensee operates in a proactive

-

posture, with appropriate management and supervisory attention,

quality work is the result. It is equally evident that when

management attention is lacking, or when priorities are shift-

ed, problems develop. The licensee must adjust the attention?

of management to ensure that an appropriate level of involve-

ment exists in all areas to ensure that quality performance is

achieved.

At the end of this assessment period, as a result of the prob-

lems in the radiochemistry area, the licensee had begun steps

to increase the presence of management personnel in the plant. -

Daily interaction and contact between management and employees

is important in monitoring the quality of work performed and

assuring a positive attitude toward assurance of quality. Ac-

tion by the licensee in this area is warranted.

_

_ __

35

-

During the previous assessment period a need for improvement

was noted in the timeliness and completeness of response to QC

Audit findings, and the failure to accomplish the necessary

corrective and/or preventive actions within committed times.

During the later portion of this assessment period, these con-

cerns were again identified in a special inspection of problems

in the Radiochemistry Section, in that audit corrective actions

were not vigoursly pursued to progressively higher levels of

management for resolution.

Quality' assurance department involvement in plar.t activities is

evident, as observed during routine resident inspector tours,

and during outage and maintenance activities. An inspection of

the modification program by regional based inspectors in the

later part of this period noted that the Quality Controls Divi-

sion's independence in the selection of hold points, and the

use of different inspectors for package, work, and completed

job review was a strength in the program.

Needs for improvement in the licensee's Quality Controls organ-

ization were noted in an inspection of the area of radioactive

waste activities. The licensee implemented immediate correc-

tive actions for this concern. Irrespective of the licensee's

responsiveness and corrective actions, these areas indicate a

need by the licensee to devote additional management attention

to the details of the day to day operation of the quality func-

tion at Shoreham.

The assurance of quality by those organizations involved di-

rectly in plant activities, irrespective of the licensee QA

Department, is an area which was noted as a strength in the

previous SAlp period. In that rating period the Operations and

Maintenance Departments were specifically mentioned as being

noteworthy in their attitude that the assurance of quality for

their departments activities was'their responsibility. The

-

decreased level of performance in plant operations, training,

and quality assurance during this rating period, indicate a neen l

for re-emphasis on this area. The need for management to in- l

'

crease involvcment in the assurance of quality for their own

departments activities is evident.

B. Conclusion

Rating: 2 j

Trend: Declining ( Although indicated as declining, the trend

associated with this functioral area can more accurately be

described as variable.)

,

9

%

T

. .

.

36

.

C. Board Recommendation

Licensee: . Assess and implement corrective actions to

reduce the inconsistent nature of the degree of

quality implementation inplant programs

. Review the administrative burden of the Division

Managers.

NRC: . Conduct a management meeting with the licensee

to discuss assurance of quality activities

.

Conduct a six month appraisal of the Assurance

of Quality area

,

b

4

4

s

I

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

-- - _-

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

.

l

.

1

37 ,

,

, ,

5.0 SUPPORTING DATA AND SUMMARIES

5.1 Investigation and Allegation Review

-

Three allegations were received during this rating period. One was

unsubstantiated.

A second involved concerns related to activities in the Radiochemis-

try Section. An investigation in this area by the NRC Office of In-

vestigation vas begun at the end of this rating period, and is

ongoing. Enforcement action related to this allegation is pending.

The third involved calibration of certain instrumentation and con-

trols, as well as training and qualification of instrumentation

technicians and supervisors. This allegation was the subject of a

special inspection conducted in April and May of 1985. Concerns

'

regarding this allegation were resolved.

5.2 Escalated Enforcement Actions

Escalated Enforcement action reiated to activities in the Radio-

chemistry area, including management and QA involvement is pending.

5.3 Management Conferences

Date Subject

March 1, 1985 Discuss performance of the Cold License class in

Februa ry.

April 1-2, 1985 Review the Shoreham Probabilistic Risk Assessment.

June 7, 1985 SALP Management meeting

January 28, 1986 Personnel errors and licensee action regarding

check valve failures.

In addition, members of the Atomic Safety and Licensing Board toured

tha plant site on March 25, 1985 in connection with hearings on the

GDC-17 exemption request.

.

,-

.

. .

.

.

38

.

5.4 Licensee Event Reports .

1. Tabular Listing

A. Personnel Error.......... .. 32-

B. Design / Man./Censt./ Install.. 15

C. External Cause............... 1

D. Defective Procedure.......... 3

E. Management / Quality Assurance

Deficiency.................. 0

X. 0ther........................ 7

,. ---

Total................... 58

LERs Reviewed

85-006 to 86-004

2. Casual Analysis

a. Personnel errors - there were thirty two LERs involving

personnel error. They were: 85-006,85-007, 85-010,85-011, 85-014,85-017, 85-018,85-019, 85-020,85-022,

85-026, 85-030,85-031, 85-029,85-033, 85-034,85-035,

85-037, 85-042,85-043, 85-044,85-047, 85-048,85-050,

85-053, 85-054,85-055, 85-056,85-057, 85-058, and

86-004. Of these personnel errors, twenty-two resulted in

, challenges to ESF Systems, including four reactor trips

from power.

-

The subject of personnel errors, and challenges to safety

systems as a result of such errors, was raised with the

licensee by the Senior Resident Inspectcr on December 20,

1985, and was the subject of an NRC/ Licensee Management

meeting at the plant site on January 28, 1986. Licensee

actions to minimize personnel errors will be monitored

during the next rating period. ,

l

b. External causes - one LER,85-046, was the result of Hur-

ricane Gloria, which hit the plant site on September 27, ,

'

1985, causing spurious ESF actuations and resulting in

missed fire watches.

I

Bomb Threats - three of the LERs,85-021, 85-059, and

1

c.

I

86-003 were the result of b6mb threats that the licensee

has received. (

l

i

,

- - . .

' .w .

3

. .

. . .

39

.

5.5 Operating Reactor Licensing Actions

1. Schedular Extensions Granted _

a. Equipment Qualification - for ventilation damper actuators

and H2 Recombiners until December 31, 1985. -

b. Inerting Containment - until 120 EFPD have been expended.

2. Reliefs Granted

None

3. Exemptions Granted

a. GDC-2 Seismic Qualification of Radiation Monitors

b. GDC-56 Containment Isolation Valves

c. Appendix J MSIV Leak Rate Testing

d. GDC-19 Remote shutdown capability

e. 10CFR50.44 Initial Containment Inerging

f. 10CFR50.49 Environment Qualification

4. License Amendment Issued

Amendment No. 1 - issued December 6, 1985 - to extend deadline

for completion of EQ work.

5. Orders Issued

Numerous orders were issued by the ASLBs, ASLAB, and the

Commission related to the ongoing licensing hearings.

.

G

v

. .

,

..

,

T1-1

.

Table 1

LISTING OF LERs BY FUNCTIONAL AREA

'

SHOREHAM NUCLEAR POWER STATION

March 1, 1985 - February 28,1986)

NUMBER /CAUSE CODE TOTAL

FUNCTIONAL AREA

12/A 10/B 1/C 3/X 26

A. Plant Operations'

& Startup Testing

1/D 1

B. Radiological Controls

17/A,5/B,2/D 24

C. Maintenance & Surveillance '

0

D. Emergency Preparedness

7

I

E. Security & Safeguards 3/A 4/X

0

F Outage & Modifications

G. Training & Qualification 0

Effectiveness

0

H. Licensing Activities

I. Assurance of Quality 0

Cause codes: A - Personnel Error

'

B - Design, Manufacturing, Construction or Installation

Error

-

C - External Cause

D - Defective Procedure

,

E - Management / Quality Assurance Deficiency

X - Other

\

-

l

\

\

.

_ -. . - - - -

. .

T2-1 l

.

Table 2

LER SYNOPSIS (3/1/85 - 2/28/86)

-

SHOREHAM NUCLEAR POWER STATION

LER NO SYNOPSIS85-006 ECCS Actuation on Personnel Error

85-007 Firewatches Late in the Control Room

85-008 Auto Start of Emergency Diesel Generator 103

85-009 Steam Leak Detection Div. II Ambient Temperature Hi Alarm

Activation ,85-010 Inadvertent RHR Loop B Trip in Statdown Cooling

'85-011 Auto Actuation of Control Room Air C-cditioning

85-012 Deficiencies in the Background Screening Process with

Temp Force Inc. Employees85-013 HPCI Inverter Circuit Failure

85-014 Late Fire Watch Patrol in EOG Rooms Due to Personnel

Unable to Gain Access85-015 Intake Canal, Ultimate Heat Sink Accumulated Sediment

Beyond Allowable Limits85-016 Automatic Actuation of Control Room Air Conditioning

85.-017 Two Full Scrams and NSSSS 1/2 Isolation Due to I&C

Technicians Working on an Instrument Rack

85-018 ESF Actuation Occurred as a Result of a High Flux

Signal on IRM Channel 'D'85-019 TPCN Was Not Approved Within the Tecn Spec Allowable

Time Frame

- 85-020 ESF Actuation Caused by RPV. Low Water Level Signals85-021 Bomb Threat

85-022 High Pressure Scram Caused by Malfunctioning RWCU

Blowdown Which Was~Being Used to Control RPV Pressure

l

l

+

l

i

!

. .

~ .

T2-2

'.

LER NO SYNOPSIS85-023 RWCU Actuation Caused by Electromagnetic

Interferences Possibly Due to Work Activities85-024 ESF Actuation Caused By Low Reactor Water Level

85-025 Missed Daily Channel Checks Due to Improper

Implementation of a Station Modification

85-026 Personnel Hatch Failed Full Volume Test

85-027 RWCU Isolation Due to Blown Fuse in Differential

Circuitry

85-028 Missed Fire Watches in the Chiller and the HVAC

Equipment Rooms Due to Damaged Door Latch

85-030 Initiation of CRAC/RBSVS "A" Side Due to Technician

Bumping Jumper

85-031 RPV Low Level Scram Due to Water Draining Into the

Suppression Pool when Suppression Pool Suction Valve

Was Opened While the SDC Suction Valve Was Closing

85-029 Degraded Vital Security Area

85-032 HPCI Isolation Due to High Exhaust Diaphragm Pressure

85-033 Inadvertent Split of RBCLCW Into Its Accident Mode

("B" Side)85-034 Diesel 101 Service Water Stand Pipe Hinged Cap Wedged

Shut

85-035 Reactor Manual Trip Due to Lo'ss of Instrument Air

85-036 RWCU Isolations Due While Operator Was Adjusting

Blowdown Flow

85-037 Reactor Trip While Valving in of Instrument Connected

to Variable Leg

85-038 "B" Reference Leg Spiked High Due to Excess

Condensate in the Steam Line to the Condensing

Chamber

85-039 CRAC Initiations During RBSVS Testing

85-040 RBSVS/CRAC Initiation Due to Voltage Dip Caused by

Thunderstorms85-041 Bomb Threat

.

..

T2-3

.

LER NO SYNOPSIS85-042 Mechanical Disturbances Caused Low Level Trip

~

85-043 Reactor Scram Due to Valving in of Test Stand to

-

-

Variable Leg

85-044 RWCU Isolation Due to Technician Error While Working

on a Surveillance Procedure

85-045 LPCI Declared Inoperable While HPCI was Out of Service

85-046 ESF Actuations and Suspendad Fire Watches Due to

Hurricane " Gloria"85-047 Auto Start of Emergency Diesel Generator Due to

Equipment Ope'rator Error

85-048 RBSVS "B" Side Initiation Due to I&C Technician Error

85-049 LLRT Exceeds Allowable Technical Specification Limit

85-050 RBSVS/CRAC "B" Side Initiation Due to Technician

Error

85-051 HPCI Check Valve Malfunction Due to Their Valve

Mechanisms Separating From the Valve Bonnets85-052 RPS Actuation When Switching From RPS " Alt" to RPS

"A" Bus85-053 TpCN-85-721 Not Approved in Time Limit Specified in

Technical Specifications85-054 Loss of RPS Bus "A" When Equipment Operator Opened

-

RPS Bus "A" Circuit Breaker Inadvertently

85-055 Equipment Required to be Environmenta11y Qualified by

November 30, 1985 was not Completed

85-056 Security Guard Found Sleeping at His Post

85-057 RBSVS Initiation Due to Technician Error (Dropped

Screwdriver)85-058 NSSSS Isolations Due to I&C Technician Error

85-059 Loss of "B" RPS Bus Due to the EPA Breaker Being Found

in the Off Position .86-001 Containment Atmosphere Sample Not Analyzed in

Accordance with Technical Specifications

~

l

>

I

-]

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

. .

..

' T2-4

. i

-

\

'

1

LER NO SYNOPSIS

4 86-002 Missed Fire Watch in LPCI MG Set Room 111 Due to

Inoperable Door

.

,86-003 Bomb Threats

!86-004 Security Guard Failure to Log Personnel Entry

...

h

'.

I

I

l

'

.,

!

!

.

)

"

l

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

_.

. .

..

T3-1

.

.

Table 3

INSPECTION HOURS SUMMARY (3/1/85-2/28/86

.

SHOREHAM NUCLEAR POWER STATION

_

FUNCTIONAL AREA HOURS  % OF TIME

A. Plant Operations

& Startup Testing............ 1831* 60%*

B. Radiological Controls........ 317 10%

C. Maintenance & Surveillance... 250 8%

0. Emergency Preparedness....... 331 11%

E. Security & Safeguards........ 207 7%

F. Outage & Modifications....... 131** 4%**

G. Training & Qualification *** ***

Effectiveness................

• *

H. Licensing Activities.........

• • • ***

I. Assurance of Quality.........

T0TAL........................ 3067 100%

• Hours expended in facility license activities and operator

license activities are not included with direct inspection

effort statistics

• • Inspection hours by Resident Inspectors in this functional area

are included in the plant operations functional area

• • • Hours expended in these functional areas not included with

direct inspection effort statistics as they are included in

other funr.tional areas

I

.

%

l

-

. .

.-.

T4-1

'

.

-

Table 4

ENFORCEMENT SUMMARY (3/I/85-2/28/86)

.

SHOREHAM NUCLEAR POWER STATION

i

A. Violations vs. Functional Area

SEVERITY LEVELS

FUNCTIONAL AREA I II III IV V DEV TOTAL

A. Plant Operations &

Startup Testing 2 2

O

B. Radiological Controls ,

C. Maintenance & Surveillance I 1

0

5 0. Emergency Preparedness

Security & Safeguards 0

E.

Outage & Modifications 0

F.

G. Training & Qualification

0

Effectiveness

Licensing Activities 0

H.

Assurance of Quality 0

I.

TOTALS BY SEVERITY LEVEL 0 0 0 I 2 0 3

B. Summary

REPORT NO. SEVERITY FUNCTIONAL

AND DATES LEVEL AREA VIOLATION

85-30 V Plant Operations Failure to

07/29-08/12/85 & Startup Testing implement s/u

program in

accordance with

procedures

.

-

- ,--

a w +- -n,.- p mm -- --,-y q. - -~ -

y y

______ ____ -

. .

. .

T4-2

.

.

_

Table 4 (Cont'd) -

._

REPORT NO. SEVERITY FUNCTIONAL

AND DATES LEVEL AREA VIOLATION

~ 85-42 IV Maintenance & Failure to con-

11/1-30/85 Surveillance duct maintenance

activities with

adequate proced-

'

ural controls

85-42 V Plar.t Operations Failure to ad-

11/1-30/85 here station

procedures

Pending Radiological Pending

86-03

. 01/27-02/14/86 ' Controls

.

5

1

i *

,

y-- --- w- . .-, - w----.+.i- -. y .,p4., . -.,o - _ 9.*r --e7^-^--*-- ----W"

N **"T"*""*F

i

-

. .

.

.

.

T5-1

.

.

Table 5

- INSPECTION ACTIVITIES (3/1/85-2/28/86)  !

l

SHOREHAM NUCLEAR POWER STATION

REPORT NO. &

INSPECTION OATES INSPECTOR AREAS INSPECTED

85-13

03/04/85-02/08/85 Specialist SER and Facility

License requirements

related to Electrical

power supplies

.

85-14

03/04/85-03/08/85 Specialist Startup Test Program

85-15

03/05/85-03/07/85 Specialist Non-radiological

Chemistry Program

85-16

03/04/85-03/08/85 Specialist Security Program

85-18

03/01/85-03/31/85 Resident Routine

85-19

04/30/85-05/04/85 Specialist Security Program

85~-20

04/01/85-05/15/85 Resident Routine

85-21

04/09/85-05/10/85 Project Engineer Allegation Followup

85-22

04/10/85-05/10/85 Project Engineer Allegation Followup

85-23 i

04/29/85-05/01/85 Team Inspection Safe shutdown i

capability in the event

of fire

1

-

l

85-24

05/16/85-06/18/85 Resident Routine

=

1

!

~

r

- - -

~ --

.

' '

. .

T5-2

.

Table 5 (cont'd)

__

REPORT NO. &

INSPECTION DATES INSPECTOR AREAS INSPECTED

,

_

85-25

06/10/85-06/14/85 Specialist Security Progrtm

85-26

06/12/85-06/14/85 Specialist Radiological Controls

Program

85-27

06/28/85-08/02/85 Resident Routine

85-28

06/24/85-06/28/85 Specialist Startup Test Program

Activities

85-29

07/06/85-07/26/85 Specialist Startup Test Program

Activities

85-30

08-03/85-08/31/85 Resident Routine

85-31

07/29/85-08/12/85 Specialist Startup Test Program

Activities

85-32

08/12/85-08/30/85 Specialist Startup Test Program

Activities

'

85-33

08/26/85-08/30/85 Specialist Security Program

85-34

09/16/85-09/20/85 Specialist Operator Licensing

Examinations

85-35

08/30/85-09/13/85 Specialist Startup Test Program i

Activities

!

85-36

09/01/B5-09/30/85 Resident Routine

85-37

09/16/85-10/08/85 Specialist

'

Startup Test Program

Activities

,

. .

-, .

,

"

T5-3

.

.

.

Table 5 (Cont'd)

_

REPORT NO. &

INSPECTION DATES INSPECTOR AREAS INSPECTED

-

85-38

10/21/85-10/25/85 Specialist Radiological Controls

85-39

10/01/85-10/31/85 Resident Routine

85-40

10/15/85-10/18/85 Specialist Non-radiological

Chemistry Program

85-42

11/01/85-11/31/85 Resident Routine

85-43

12/01/85-12/31/85 Resident Routine

,

86-01

01/01/86-01/31/86 Resident Routine

86-02

02/12/86-02/14/86 Specialist Emergency Planning -

Observation of FEMA

Full Scale Exercise

86-03 Team Inspection- Allegation followup -

01/27/86-02/14/86 Specialist & Resident Radiochemistry Program

86-04

02/10/86-02/14/86 Specialist Security Program

86-05

02/01/85-02/28/85 Resident Routine

1

86-06

02/25/86-02/28/86 Specialist Transportation and

Radwaste Programs

l

.

1

l

i

I

--

_ . _.

. .

.-

T6-1

.

.

Table 6

_

REACTOR TRIPS AND PLANT SHUTDOWNS

PDWER

DATE LEVEL DESCRIPTION CAUSE & AREA *

04/29/85 SD Reactor trip due to Personnel error -

false low RPV water during a surveill-

level signal ance test, technician

valved in pressure

transmitter causing an

indicated level

transient

AREA - Maint. & Surv.

05/09/85 SD Re' actor trip due to Personnel error -

upscale spike on IRM maintenance per-

channel 'D' sonnel bumped

incore instrumen-

,

tation cables j

'

AREA - Maint. & Sury.

05/21/85 SD Reactor trip due to Personnel error -

false low RPV water during testing,

level signal a technician

valved in a level

transmitter creating an

oscillation in the

variable leg line.

AREA - Maint, & Surv.

06/06/85 SD Reactor trip due to Equipment Failure -

high RPV pressure During a leak

test on the vessel

using the CRD system &

RWCU biowdown valve,

a defective feedback

arm on blowdown valve

controller caused valve

to close enough to

increase RPV pressure

AREA - N/A

07/07/85 Startup N/A

-

• Note - the cause attributed to these shutdowns is the NRC assessment of

cause, and may not agree with the licensee's assessment.

.

1

. - _ _ __.

.

. .

.: -

T6-2 ,

-

'. Table 6 (Cont'd)

POWER

DATE_ LEVEL DESCRIPTION CAUSE & AREA *

07/13/85 '5% Reactor trip during Equipment Failure -

low power testing on Failure of air -

low vessel level line on FW minimum

flow valve

AREA - N/A

07/16/85 Startup N/A

07/17/85 < 5% Shutdown for RPV level Planned

instrumentation work

07/23/85 Startup N/A

07/25/85 (5% Shutdown for RPV level Planned

instrumentation work

07/26/85 SD Reactor trip due to Personnel error -

low RpV water level an operator opened

RHR Suppression vool

suction valve prior to

shutdown cooling valve

being closed

AREA - Plant Ops

07/29/85 Startup N/A

08/24/85 (5% Shutdown for rod Planned

sequence exchange

and minor

maintenance

08/30/85 Startup N/A

08/31/85 1.0% Reactor trip on loss Personnel error -

of instrument air improper replacement

of desiccant

in air dryer unit

AREA - Maint. & Sury.

09/03/85 Startup N/A

09/06/85 1.1% Reactor trip during Personnel error -

surveillance test false low RPV

water level signal

during testing

AREA - Maint. & Sury.

• Note - the cause attributed to these shutdowns is the NRC assessment of the

cause, and may not agree with the licensee's assessment.

1

l

.,-:

T6-3

.'

Table 6 (Cont'd)

POWER

DATE LEVEL DESCRIPTION CAUSE & AREA *

09/07/85 Startup N/A

09/08/85 1.25% Reactor trip manually Equipment failure -

initiated RPV level

indicators went

offscale high due to

RPV reference leg

problems

AREA - N/A

09/09/85 < 5% Shutdown for Planned

investigation and

repair of RPV water

level deviations

09/11/85 Startup N/A

09/12/85 2.0% Reactor trip due to Personnel error -

low water level work activity

indication caused hydraulic

oscillation on

level line, creating

false low level signal

AREA - Maint. & Sury.

09/18/85 Startup N/A

09/26/85 < 5% Reactor shutdown Maintenance

activities and

Hurricane Gloria

10/03/85 Startup N/A

10/08/85 45% Reactor shutdown Completion of 5%

test program

Note - the cause attributed to these shutdowns is the NRC assessment of the

cause, and may not agree with the licensee's assessment.

L__