ML20041E735

Responds to NRC Re Violations Noted in IE Insp Rept 50-322/81-22.Corrective Actions:Test Engineers Reinstructed in Correct Implementation of Startup Instructions

ML20041E735
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/19/1982
From:	Pollock M LONG ISLAND LIGHTING CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20041E732	List: IR 05000322/1981022 ML20041E735
References
SNRC-671, NUDOCS 8203110294
Download: ML20041E735 (4)

Text

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uiL La ns 5 ry):. Lo; e gn,c_,,1 February 19, 1982 Mr. Richard W.

Starostecki, Director Division of Resident and Project Inspection U.S. Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406 NRC Inspection No. 81-22 Shoreham Nuclear Power Station, Unit No. 1 Docket No. 50-322

Dear Mr. Starostecki:

This letter responds to your letter of January 14, 1982, which forwarded the report of the routine inspection of acti-vities authorized by NRC License No. CPP R-9 5, conducted by Mr.

Higgins of your of fice on November 23-December 31, 1981.

Your letter stated that it appeared that one of our activities was not conducted in full compliance with NRC requirements.

The apparent noncompliance and our response follow:

Apparent Noncompliance with 10CFR50, Appendix B, Criterion III and V, FSAR Section 17.2.5, and the LILCO Quality Assurance Program 1.

Startup Instruction No.

2, Re v.

1,

" Electrical Checkout Instructions", page 2, requires that the wire checking and functional testing of electrical circuits be documented by

" yellow-lined" elementary diagrams or drawings called

" Yellow-Lines Masters".

Contrary to that requirement, on December 14, 1981 there was no Yellow-Lined Master in the Startup Resource Center Yellow-Lined Master File for drawings ESK-llR4204 or ESK-6T2301.

2.

Startup Instruction No. 2, pages 2 and 3, requires that prior to the Preoperational Test the Test Engineer review changes made to this system by Engineering and Design Coordination Reports (E&DCRs) and by drawing revisions.

The latest drawing and the Yellow-Lines Master drawing then must be stamped, dated, and initialed to indicate whether additional testing is required or whether the design changes do not affect the tests performed.

8203110294 820303 PDR ADOCK 05000322 G

PDR

LONG ISLAND UGHTING COMPANY Mr.

R. W. Starostecki February 19, 1982 Page Two Contrary to that requirment, as of December 14, 1981, although the affected Preoperational Tests had been completed, there was no stamping or other documentation on the below listed drawings in the Startup Resource Center Yellow-Lined Master File to indicate that the latest revisions had been reviewed i

by the Test Engineer:

ESK-5R2303, ESK-5R2304, ESK-6P2108, and ESK-6P2111.

3.

Startup Instruction No.

2, page 3, requires that all super-seded drawings be retajned in the Yellow-Lined Master File.

Contrary to that requirement, as of December 14, 1981 numerous superseded drawings were not retained in the Startup Resources Center Yellow-Lined Master File, including:

ESK-llR4204, original and Rev. 1 ESK-6T2301, Rev. 2 ESK-6Gil33, Rev. 5 ESK-6P2111, Rev. 3 4.

Field Quality Control Procedure QC5.2, Rev. C, Change 3, t

paragraph 4.3.4.3 requires that superseded documents, which are retained, be marked " VOID".

Contrary to that requirement, as of December 14, 1981, numerous superseded drawings retained in the Startup Resource Center Yellow-Lined Master File were not marked " VOID", including:

ESK-llR42 01, Rev. 3 ESK-llR4202, Rev. 2 ESK-5R301, Rev. 11, 11A, 12, and 13 l

ESK-6R4308, Re v. 3 i

ESK-5R2304, Rev. 6, 6A, 6B, and 6C ESK-6G1104, Rev. 3 i

ESK-6Glll4, Rev. 2 l

Corrective Action and Results l

1.

ESK-6T2301 (Rev. 3) has been yellow-lined and is filed in the l

Startup Resource Center.

ESK-llR4204 will be yellow-lined and placed in the Resource Center upon completion of testing.

l I

2.

ESK-5 R2 30 3, Revision 5, just incorporated E&DCRs shown on Revision 4, and no retesting was necessary.

Revision 5 has now been stamped, dated and initialed.

All applicable l

revisions of ESK-5R2304 have been stamped, dated and initialed.

ESK-6P2108 and ESK-6P2111 are under review and the systems under test.

Both will be yellow-lined and stamped, dated and initialed by March 1, 1982 l

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LONO 18LANb LIGHTING COMPANY Mr.

R. W. Starostecki February 19, 1982 Page Three 3.

Startup Instruction No. 2 is being revised to reflect the current requirement of filing only those superseded drawings which have pertinent test data recorded thereon which is not transferable to the latest drawing.

ESK-llR4204, Original and Revision 1, were not retained because no testing had been performed using these drawings.

ESK-6T2301, Revision 3, and ESK-6Gil33, Revision 6, have been yellow-lined in their entirety.

All pertinent test data from previous revisions had been transferred to these revisions, and, therefore, it is not required to retain the earlier revisions.

ESK-6P2111, Revision 4, will be yellow-lined in its entirety and filed by March 1, 1982.

Earlier revisions will be filed only if they contain portinent and nuit-tranaferable test data.

4.

LILCO Startup test documentation is controlled by the LILCO Startup Manual.

in particular, yellow-lined ESKs are con-trolled by Startup Instruction No. 2 which delineates the correct procedure for use of the " Testing Void" stamp.

With respect to ESK-11R4201, Revision 3, ESK-llR4202, Revision 2, and ESK-5R2304, Revisions 6, 6A, 6B and 6C, these systems are currently under test, and the drawings will be reviewed for retest requirements and marked " Void" as appropriate, by March 1, 1982 ESK-5R4301 and ESK-6R4308 will be similarly reviewed and marked at the conclusion of C&IO testing.

ESK-6G1104, Revision 3, and ESK-6 Gill 4, Revision 2, have been reviewed and stamped in accordance with Startup Instruction No.

2.

Steps Taken to Prevent Recurrence A Startup Staff meeting was held on December 17, 1981, and an additional distribution of Startup Instruction No. 2, Revision 1, was made to the Test Engineers present.

The Test Engineers were also reinstructed in the correct implementation of this instruction.

Further, a Test Engineer is being assigned to the Startup Resource Center to review revised electrical drawings and applicable E&DCRs to determine if retesting is required.

The appropriate System Test Engineer will be advised of the results of this review, and the review will be duly noted on applicable documents.

Finally, Startup Instruction No. 2 is being revised and updated to reflect current requirement.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by March 15, 1982.

Very truly yours, sn. J.PM M. S. Pollock Vice President-Nuclear

s.

a STATE OF NEW YORK

)

ss.:

COUNTY OF NASSAU

)

MILLARD S. POLLOCK, being duly sworn, deposes and says that I am a Vice President of Long Island Lighting Company, the owner of the facility described in the caption above.

I have read the Notice of Violation dated January 14, 1982 and also the response thereto prepared under my direction dated l

February 19, 1982.

The facts set forth in said response are based upon reports and information provided to me by the employees, agents, and representatives of Long Island Lighting Company responsible for the activities described in said l

Notice of Violation and in said response.

I believe the i

facts set forth in said response are true.

A/b h

' MILLARD S. POLLOCK l

Sworn to before me this N

day of N

• p, 1982. ~

1

-Bwhn M&D '

ROSA LEE CUVEROS Ntary Pub';0. Ctate of flew York flo. 30 47CC2Cd i

f~ Qualified in !!nnu County CommMan eq.as f/.ar. 30,13[&

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