IR 05000322/1985099

SALP Rept 50-322/85-99 for Mar 1984 - Feb 1985.Weaknesses Noted W/Control of Plant Evolutions & Timely Resolution of QC Deficiencies.Effective Mgt Involvement & Control of Most Plant Activities Noted

ML20129E252
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/24/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129E241	List: IR 05000322/1985099 ML20129E237
References
50-322-85-99, NUDOCS 8506060407
Download: ML20129E252 (48)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-322/85-99 LONG ISLAND LIGHTING COMPANY SHOREHAM NUCLEAR POWER STATION ASSESSMENT PERIOD: MARCH 1, 1984 - FEBRUARY 28, 1985 BOARD MEETING DATE: APRIL 22, 1985

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SUMMARY OF RESULT .1 Overall Facility Evaluation

. Organizational changes were made at the beginning of the period, with the appointment of a new Chief Executive Officer on down through a new Plant Manager and a major reorganization of the nuclear opera-tions staf The new upper management includes individuals with significant operating experience arid is considered a positive step in preparing for plant operation. The relocation of the Vice President

- Nuclear Operations and most of the corporate engineering staff to the plant site contributed toward increased management involvement and improved support of plant staff and plant operations. Although design change responsibility principally remained with Stone and Webster throughout the period, transfer of responsibility to the LILCo engineering staff continued to increase with development of the Interim Station Modification Progra Construction activity was essentially complete at the beginning of the assessment period, with the exception of the new Colt diesel generator building. Construction of this facility was completed near the end of the assessment perio The construction was performed in a high quality manner in accordance with codes and standards committed - to by LILC The pre-operational test program also was finished during this period, and the resolution of test exceptions and approval of test results were found to be satisfactory. The startup test program was begun, with fuel load and initial criti-cality accomplished successfully with few minor problems. Startup test coverage was provided by NRC round-the clock at the end of this assessment period, and the program was observed to be carefully and conservatively conducted, with appropriate staffing, procedures, and management attentio Preparations for plant operations and development of operational support programs, including maintenance and surveillance, were planned and executed well in advance of license issuance, since' the licensee had been anticipating fuel load prior to this assessment perio Radiological controls, surveillance procedures, and security measures were in place and adequately implemented, well in advance of license issuanc The following weaknesses requiring improved management attention were identified during the perio Regarding actual plant operations, several weaknesses were noted with the control of plant evolutions and the timely resolution of QC deficiencies. The licensed operator requalification training program was judged during the period to be of high quality and successful. However, in regard to the initial license training program, a cold license class examined at the end of the period was found to be badly prepared, and the majority of candidates failed. This appears to have been the result of inade-quate attention on the part of the training manager and not a flawed progra p

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'It is our evaluation that the training department and its' programs are generally goo The _0perator Requalification Training Program, that was put in place prior to issuance of an operating license, is considered very good, and the training program for shift technical advisors is also strong. The training program for shift advisors required revision to include improved knowledge of plant specifics, but ultimately ~ provided acceptable knowledge levels. As stated above, the poor performance on the cold license examinations is, in our evaluation, the result of inadequate management attention due to conflicting priorities and not representative of a programmatic breakdow In ' summary, the licensee has demonstrated effective management in-volvement and ~ control of most plant activities during _this perio It should be noted that these activities were conducted with no operational time constraints and that the licensee proceeded very

' conservatively in plant operation The NRC will closely observe licensee performance, should a higher level power license be issued,

'to ensure that effective management and control of plant activities continues during ensuing phases of operation. In the interim, the licensee should continue their conservative approach to plant opera-

.tions and ensure that other plant activities, such as training, maintenance, and surveillance are not adversely affected by conflict-ing priorities that detract from management involvemen .. =. _

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3.2 Facility Performance Category Last Category Period This Period Recent Functional Area- (2/83-2/84)l(3/84-2/85)I Trend **** Construction Activities ***

1 Consistent Engineering and Design 1 1 Improving Pre-operational and Startup Testing 2** 1 None Maintenance and Surveillance 1 1 Consistent Plant Operations *-

1 Improving Radiological Controis- 1 1 Consistent

. Fire Protection and. Housekeeping 2 2 Improving

- Emergency Preparedness 2 No Basis None Security and Safeguards 1 1 Consistent 10. Licensing 2 2 Consistent

• This area not previously evaluated.

• • Previous SALP only evaluated the Pre-operational Test Progra ***In the previous SALP, this area was broken down into four separate func-

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tional area **** Trend during the last quarter (12/84'through 2/85) of current assessment period.

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4.0 PERFORMANCE ANALYSIS 14.1 Construction Activities (17%)

_During ' this' assessment period, four inspections were conducted by region-based specialists addressing the construction of the new Colt diesel generator building and the settlement monitoring progra Observation of- ongoing structural concrete construction, inspection of in pla'ce structural steel and a review of related Quality Control records demonstrated that these activities were conducted in accord-

-ance with applicable specifications, codes, standards, drawings, and procedures, as originally used in facility construction and as committed to. by the license In addition, examination of Quality Assurance field audits and discussions with licensee QA audit engi-neers indicated an effective QA program with respect to the Colt Emergency Diesel Generator Buildin The-licensee has committed to evaluate settlement data for Category I structures other than the Reactor Building and consider procedures for addressing those structures through the life of the plant. The construction phase settlement monitoring program for the Colt diesel generator building was initiated with the first concrete placement in the basemat. The settlement monitoring program and the engineering design to accommodate differential settlement of interconnecting lines reviewed to date were considered goo The overall QA/QC program implemented with respect to the Colt diesel generator building construction, including the management program the _ audit and ~ inspection program, the procurement program and the vendor receipt and inspection program, were effectively organized and implemente In addition, a review of S&W non-conformance and disposition reports related to safety-related HVAC components demon-strated good performance with respect to procedure and engineering disposition. The licensee's management have effectively demonstrated their involvement and control in assuring quality by well planned and executed surveillance and audit of the architect engineer and

. contractor . design / construction operation The Quality Assurance Program for the Colt facility covered all aspects of the safety-related portion of it's installation, with engineering analysis and calculations to support' identified nonconformance Conclusion:

Rating: Category 1 Trend: Consistent

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Recommendations:

Licensee: See Section 4.10, addressing the need for an FSAR submittal which addresses the design criteria for the Colt

' diesel projec NRC: Future SALPs will not include construction as a functional category.

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4.2 ' Engineering and Design ~(9%)

The Interim Station Modification Program (ISMP) is intended to more fully .' utilize licensee personnel for design changes, while still

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maintaining design responsibility with Stone & Webster Engineering Corporation -(SWEC)_ and maintaining the same level of quality as during - constructio Region-based inspection of the ISMP was performed at the end - of this assessment period. The Nuclear Engi-neering Department's (NED) development and control of design changes and their implementation of the ISMP was audited. This included the processing of design output packages, installation of station modi-fications, and closeout of work and update of affected documents and drawing Management attention was applied towards the program, as evidenced by the development of NED procedures and the involvement of the Review of Operations Committee (ROC) and the Design Review Committee

.(DRC). An example of ROC participation in the review of design changes was the replacement of timers in the MSIV-Leakage Control Syste That modification, which replaced existing timers with longer timers in order to allow depressurization between the inboard and outboard MSIVs, was reviewed by ROC and recommended for further refined safety evaluation before approval of the work. The DRC was observed to consist of key NED personnel, as well as responsible personnel from plant staff and installation engineering, all of whom were knowledgeable and qualified. The DRC evaluates planned modi-

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fications, prepares scheduling, and assigns design responsibility to either contractors or NFD engineers. The approved 1985 workload was observed to be well planned and prioritize Safety evaluations associated with design output packages were found to be of sufficient depth, addressing the required criteria of 10 CFR 50.5 Supportive calculations were available on site, which addressed the bases for those evaluations. Further, responsible NED engineers were knowledgeable of their respective packages and capable of addressing technical details. This was especially evident of the MSIV-LCS modificatio .

The implementation of station modifications was found to be well controlled; and, in particular, the update or tracking of drawing changes to appropriately reflect as-built conditions was verified to be accomplished in accordance with procedures. Effective communica-tion was evident among NED, Stone and Webster, Installation Engineer-i ing, and Operations engineers. Proper attention was given to turn-

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over of completed modifications and system return-to-service from in-sta11ation to operation The Modification Engineering group has been observed to gain experience in installation.

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, NED is currently adequately' staffed. ' Another positive step in the quality 'of design work is the licensee's development of an Engineer-ing - Assurance Group within NED. 'Most of the NED staff- were re-assigned to -the site at the' beginning of this assessment period, and effective communication and interface between plant staff and NED is eviden The support of the onsite Stone and Webster Site Engineering Office (SEO) in resolving design questions and problems has been good. This was- evident by their correct processing and approval of Engineering and Design Coordination Reports, which were reviewed as part of NRC follow-up of selected allegations during this period. -SE0 personnel were a cooperative and knowledgeable source of design information

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required to address those allegation The transition of design responsibility, with SWEC during construc-tion to LILCo as plant operations evolve, has.been effective and done wel Conclusion:

Rating: Category 1

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Improving Recommendations:

Licensee: None

NRC: None

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4.3 Pre-operational and Startup Testing (32%)

Pre-operational Test Program Major testing conducted during the middle of this assessment period, which was witnessed and independently evaluated by NRC inspections, included the Integrated Electrical Test (IET) and special testing of

. the alternate AC emergency power sources for low power operation (20 MW gas turbine and GM mobile diesels). The IET was performed, using all three TDI diesels to verify independence among redundant onsite power. sources- and their load groups during plant response to a LOCA, both with and without a loss of offsite power, in five separate test runs. Independent NRC review of test results, including appropriate personnel and equipment actions, found them to be in accordance with procedural and regulatory requirement Licensee management was present during, and intimately involved in, this last major test evolution. The total load on each ' diesel engine, with both core spray and all four RHR pumps running at rated conditions, ranged from 2650 to 2800 k The pre-operational test program was verified to be satisfactorily completed, including resolution or tracking through startup program, of all pre-operational test exceptions. Management and technical involvement in test exception resolution and final test results review was evident and appropriate. Based on the above, the NRC's pre-operational test program was officially closed in October 198 TDI Diesel Recovery Progren The licensee's overall planning, staffing, and implementation for the retesting of the Transamerica DeLaval, Inc. (TDI) diesel engines has been aggressive and effectiv Planning for the outage, teardown, inspection, and reassembly of EDG-102 was adequate with good staff coverage. However, the schedule for engine 102 slipped when EDG-101 and 103 were torn down for inspectio Procurement of. spare parts was a problem identified previously by the licensee's quality control, particularly wit'. spare diesel connecting-rod bearings ' and bushing The number of part rejections by the licensee reflects poor vendor inspectio Tha licensee is imple-menting a program to require vendor NDE evaluations of bearings and bushings prior to shipment, in addition to onsite licensee inspec-tion Startup Test Program The QA/QC coverage of the startup program during this assessment period has been extensive. QC inspectors were observed to provide 100% surveillance coverage of fuel load activities, and QC performed

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an independent verification of fuel bundle locations following fuel load. Careful planning for continuing QC extensive surveillance-activities throughout the startup test program was noted. During the early review of the startup test procedures, a deficiency was noted in the licensee's review process, specifically, using acceptance criteria derived . from General Electric startup test specifications, rather than those from the FSAR. The licensee took prompt, compre-hensive action by performing and documenting an indepth review to correct these discrepancies and to assure that these differences did not exist in other procedure The initial fuel load was conducted successfully in an organized and conservative manner in accordance with the Technical Specification There was continuous communication between the refueling bridge and the control room during the fuel loading activitie The General Electric Company contract startup personnel performed their func-tions in conjunction with the operating staff. Verification of the core status after fuel load was comprehensive. Installation of the neutron sources, proper placement of the fuel assemblies into the reactor vessel and the achievement of initial reactor criticality were performed in a well-controlled and effective manne The licensee's generally high quality procedures, procedure change control-and personnel training have been strong contributors to their successful completion of these activitie When procedural or equipment difficulties were encountered, the licensee did not hest-tate to halt work, assess the situation and take corrective steps to assure safe operations before proceedin The licensee's upper management have demonstrated extensive involve-ment in assuring quality of the startup program. This was evident through activities of the-Review of Operation (ROC) committee, which meets on a daily basis to appraise day to day operation and evaluate technical issues. These transactions of ROC were closely reviewed, and meetings were randoialy attended by NRC inspectors. During preparations for fuel load and throughout the fuel loading process and initial criticality, members of the plant management staff were visibly involved interfacing with and overviewing shift activities in the plant, particularly in the control room and on the refueling floor. This management presence has been evident during backshift and weekend hours, as well as during the dayshif Resolution of Open NRC Inspection Items A significant effort was applied by the licensee towards the closure of open items from previous NRC inspections and in addressing -TMI NUREG-0737 items, IE Bulletins and Circulars, and corrective action associated with violations. Also during this assessment period, all previously reported construction deficiency reports were resolve There were approximately 70 deficiencies reported since construction began at Shoreham. r

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The licensee aggressively pursued resciution of NRC concerns, espe-cially those with significance for fuel load and impending plant operation, such that only five items were included as conditions to the low power license. There were, on the average, over 100 and, at times, close to 200 open NRC items throughout the first half of this period. A team of 11 NRC inspectors spent two_ weeks onsite in April 1984 addressing 57 of those items and was uble to resolve all or most issues due, in part, to the licensee's preparation, well-kept l records, and responsiveness to the technical concerns raise A Compliance Organization onsite has been in effect throughout this period. This group is devoted to tracking NRC findings, and has been

. responsible for presenting timely and thorough corrective actions in this area. Notable examples which were issues that had been identi-fied in previous periods included the resolution of Reactor Building maintenance-induced flooding concerns, and the corrosion of compo-nents within the suppression pool air space. Sound technical argu-ments and corrective actions were ultimately presented by the licen-see for these issue The ifcensee's effort to resolve IE Bulletins and previous NRC find-ings were prompt and complete. The records supporting the ifcensee's actions were readily available upon request. In those cases where further explanation was required, the licensee provided qualified personnel to provide detailed explanations in a timely manne Therefore, the inspection verifications were carried out effectivel Where no action was required of the licensee by a specific bulletin, the licensee did verify that the particular problem did not exist for their plant. This area reflected notable LILCo management attention, particularly on the part of the Plant Manager and divisional super-visors, in making plant staff aware and available to resolve NRC's concerns, as well as coordinating Stone and Webster suppor Conclusion:

Rating: Category 1 Trend: None, due to intermittent nature of activitie Recommendations: None

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4.4 Maintenance and Surveillance (6%)

This evaluation is based on three inspections in these areas conducted by region-based specialists, as well as ether observations during startup test inspections and by the ' resic'ent inspector r .

Maintenance programs The maintenance program is staffed with qualified, knowledgeable personnel having an average nuclear experience level of- eight years

'for supervisors and four' years for technicians and mechanics. The total average maintenance experience level (nuclear and non-nuclear)

is about. double these numbers in each category. Staffing levels appear to be adequate to support corrective maintenance and surveill-ances; . however, there do not appear to be sufficient numbers of personnel to support the preventive maintenance program. This fact was apparent in inspection of the instrumentation and control pre-ventive maintenance program at the end of this assessment perio Understaffing in this area was evidenced by a backlog of I&C pre-ventive maintenance actions, which was known and identified by the licensee and was attributed to a priority for technicians to support start-up surveillance testin The work control system is well defined and effectively controlled through the Maintenance Work Request (MWR) and the Station Equipment Clearance Permit (SECP) procedures. MWR and associated maintenance procedures have been routinely found in use during random resident inspector observations of maintenance work throughout the plan Plant staff have effectively utilized a plan-of-the-day meeting to prioritize maintenance activitie The licensee has implemented several useful trend analysis programs to highlight important main-tenance/ equipment performance parameters to Station Managemen Trend plots for numbers of instruments and, separately, numbers of annunciators in the control room requiring maintenance are notable examples. Both of these plots show a decreasing trend. The licensee has also established a data base information management system during this period for trending equipment history which will flag equipment failure rates that exceed a defined inquiry level of interest. This system was initially implemented for safety-related equipment, and the licensee intends to expand its use to non safety-related equip-ment as wel Surveillance Program During initial operation under the low power license, several in-stances of inadvertent safety / protection system initiation were caused by instrumentation technicians. A more thorough briefing in the area of sensitive instrumentation, and greater attention to

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detail by the technicians is warranted in order to reduce the frequ-ency of unnecessary challenges to safety protection system Extensive review by NRC of preparations for initial criticality indicates that an excellent surveillance test program is in plac Plant surveillance procedures and test results, inspected in support of startup activities, indicate that the system used by the licensee

~to assure that Technical Specification surveillances are satisfied is-functioning wel Performance of several surveillances was witnessed. In one instance, a deficiency was noted in calibration checking of the front panel recorder (IRM Functional Test). The license took prompt action to correct this and other similar proce-dures (SRM Functional Test and APRM Functional Test) when informed by the inspector. All routine required surveillance tests were found to have been properly scheduled and performed in a timely manne Operations personnel were aware of surveillance tests in progress and

'followed the implementation of each test closel Most tests observed by NRC progressed well, with little or no procedural changes required, with the exception of the 18-month functional test of the MSIV leakage control system. This test, while being performed for the first time, did not proceed according to procedure and required several ad-hoc changes before being satisfactorily complete Licensee personr.;l were observed performing this surveillance using a previously-deleted version of the test, while development'of a work-able procedure was underway. This was judged to be an isolated case based upon the observation of numerous other tests where, when proce-dural difficulties were encountered, approved procedure changes were issued before proceeding. Another problem involved inadequately developed procedures for the Leakage Reduction and Control Program for 9 of 12 systems outside of containment which may become conta-minated or could contain primary coolant sources. The program, in response to NUREG-0737 Item III.D.1.1, was not fully implemented at fuel load as required by Technical Specification Summary In summary, the overall maintenance and surveillance functions appear to be well defined and effectively managed to suppcrt safe plant operation. Further, the licensee has had considerable experience or

" practice" in this regard over the past two assessment periods, and previous SALP reports have noted continued improvement. Plant staff-ing and other aggressive improvements in this area, instituted during the last assessment period, have been maintained throughout the current perio However, management attention to improving their preventive maintenance resources, and towards elimination of un-necessary challenges to safety / protection systems (including review of experience at other nuclear plants), should be continued. While some instances 'of poor work controls were observed, these did not jeopardize plant safety. In fact, when a problem was recognized, work was stopped until the problem could be resolve _

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Conclusion: l Rating: Category 1-

. Trend: Consistent Recommendations:

Licensee: Increased attention should be given to the area of preven-

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tative maintenance and to reducing the frequency of un- j necessary challenges to safety protection systems initiated by surveillance activitie NRC: None

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4.5 Plant Operations (14%)

Plant Operating Staff-The licensee has been successful in hiring an experienced Vice President - Nuclear Operations and has placed an individual with responsible nuclear experience in the Plant Manager positio The need for on-shift operators with previous operating experience is a =relatively recent requirement, to which the licensee responded by selecting several qualified individuals to act as shift advisors, until the licensed operators at Shoreham can accumulate sufficient operating experience of their own. Adequate plans have been made for numbers of licensed operators, and shift advisors are an interim measure to meet new NRC criteri Initial review by the NRC of the shift advisor training program identified a deficiency with the amount of on-shift plant specific familiarization training and a need for increased use of control room walk-through questions on the licensee's certification program. The licensee was responsive to these concerns, and NRC follow-up has found the licensee's subsequent actions to be satisfactor Licensed Operator Traiaing Programs The only activity in the area of initial licensed operator training during this period involved the conduct of NRC " cold license" exami-nations at Shoreham in February 1985. Examinations, both written and oral, were administered to 10 reactor operator candidates, three senior reactor operator candidates, and two non-LILCo employee Instructor Certification candidates. The results of these examina-tions were very poor and indicate a serious deficiency in the LILCo Initial License Training Program. Seven of the 10 reactor operator candidates and all three senior reactor operator candidates failed the examination. The evaluation of written and oral exam results-indicate that their training did not adequately prepare the candi-dates for performing the duties of licensed operator A major reason for this breakdown appears to have been a lack of management attention to the progress of these candidates and a failure to observe, or act upon, the indications that this class was not properly trained. This lack of management attention is evidenced by the fact that no one in a supervisory position in either the training staff or plant operations staff participated in any pre-NRC exam audit or evaluation of these candidates. Additionally, a review of weekly quiz scores and the final written audit exam scores of this class indicate clear deficiencies in knowledge levels of some candidates which were either ignored or not believed by the LILCo staff. The first three groups of license exams conducted in 1982 and

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1983 at Shoreham yielded very strong results and the training program was assessed as strong. The more recent class indicates that the candidates were not adequately trained and prepare After the preliminary examination results were developed, Region I management met with the licensee to review the situation and to try to assess the - implication Licensee management representatives acknowledged the existence of a problem in this area in that they had not been cognizant of the status of the class until after the NRC examination Cited were conflicting priorities with ASLB litiga-tion, fuel load and initial criticality, and TDI diesel testing as contributing to the failure of licensee management to properly supervise and monitor the progress of this license class. On March 20, 1985, LILCo's Vice President - Nuclear met with Region I manage-ment and committed to aggressively pursue corrective action, includ-ing their own internal audit of the examinations (which verified the NRC findings), some disciplinary action, and a four-month augmented retraining program to be overseen by the LILCo Vice President -

Nuclear Operation An August 1985 re-examination of these candi-dates was propose During the assessment period, the NRC continued its review of the Shoreham Licensed Operator Requalification Progra Although, by regulation, Shoreham was not required to have a Requalification Program in place until after the issuance of an operating license, LILCo has had an ongoing program since February of 1983. The NRC has continually been involved in the assessment of the adequacy of this program. The culmination of this assessment was the conduct of NRC-administered Requalification examinations to 25% of the licensed operators at Shoreham in November 198 The purpose of the NRC-administered examinations was to enable the NRC to make a determination as to the renewal of operator and senior operator licenses at Shoreham. Under the regulatory guidelines of 10 CFR Part 55.23(c)(2)(iii), NRC operator and senior operator oral and written exami n tions were given to six SR0s and three R0s at Shoreham in November 1984. The results of these examinations were very good, with all candidates passing both the oral and written examinations and most candidates achieving high written exam scores. Based on these exams and the satisfactory results of other NRC inspections of the Shoreham Requalification Program, license renewals were issued to all operators at Shoreham beginning in March 198 Overall, the Requalification Program at Shoreham continues to be a very strong, operationally-oriented program. The program involves many innovative concepts, such as Technical Specification group exercises, control panel recognition drills, and on paper malfunction exercises using detailed panel and annunciator drawings. The Program also actively involves both the licensed operators and non-licensed onshift personne _

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Plant Evolutions

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During this assessment period, but prior to receipt of the low power license, two incidents occurred which revealed a need for improve-ments in the timeliness and thoroughness of incident follow-up. One

. incident . involved a Radwaste system flexible piping connector which ruptured anc caused flooding of the regenerator evaporator area, and the other inv61ved an improper valve lineup for drainage of reactor vessel water that occurred twice, resulting in flooding of the dry-well floor area. Concern over these events was expressed by the NRC; and, near the end of the assessment period, the licensee subsequently demonstrated significant improvements -in timely and thorough -evalu-ation of plant incident Shoreham received its license to load fuel and test the reactor at up to 0.001 percent power on December 7,1984. Fuel loading began on December 21, 1984, and was completed on January 19, 1985. The licen-see achieved initial reactor criticality on February 15, 198 During these early phases of plant operation, the licensee purposely established a conservative pace as a conscious step towards accommo-dating the existing experience levels of plant personne Licensee management is credited with taking the initiative months before the-low power operating license was issued to implement plant administra-tive controls as if the plant had an operating license. For example, Technical Specification Limiting Conditions for Operation (LCO's)

were identified and tracked, and plant management /NRC resident inspector notification of significant occurrences were made as they would be for an operating plant. The licensee was fully prepared to implement a well developed set of Technical Specifications at the time of low power license issuanc The Control Room environment has continued, throughout this assess-ment period, to be characterized by a professional appearance and atmosphere of businesslike conduct. The licensed operators maintain the control room free of extraneous distractions and' are routinely attentive to plant conditions and annunciators. During the initial stages of fuel load, the heavy incidence of support personnel inter-facing with the Control Room resulted in a need for clarification and stricter enforcement of Control Room access controls; but, this was quickly resolved by plant management and shift supervision. Shift supervision has been effective at maintaining low background noise levels during the conduct of administrative duties with support personnel, to the benefit of licensed operator attention to plant

. operations and statu Based upon observations by NRC staff and management, the overall Shoreham Control Room environment is consi-dered excellen Regular reviews by the resident inspector of the various control room logs (e.g., watch engineer (shift supervisor) log, temporary proce-dure change, lifted lead and jumper logs) have found the logs to be

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complete,. legible and accurate records of plant status. The resident

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inspector has also observed watch engineer. shift-turnovers, on many

occasions,; for proper review by the oncoming and- offgoing watch m engineers jofithe status 'of . plant 1 conditions, plant equipwent main-

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3tenance and test status, logs and current directives. In all cases,

! shift turnovers were found to be well conducted. Also reviewed wer the' administrative controls contained in station procedures for

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returning systems to service which have been . modified or repaired, in . which areas -were identified where clarification was needed in ~

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order to -ensure that the watch -engineer could determine what

. approvals are required prior to return to service. The licensee was-responsive to these. NRC-identified concerns and corrected the proce-

- dural inadequacies. .The licensee has implemented a system to iden-tify adverse trends -in -Licensee Event Reports, reports of abnormal

- conditions, and control room instrumentation and annunciator fail-ures. The Review- of.0perations Committee (ROC) has been functioning smoothly.in-the review and approval of~ assigned procedures, tests and J

modification The licensee's overall performance in the area of plant operation has

- been good; however, some areas for improvement have been noted. Some

. difficulties have been experienced with proper' execution of some of-

'the' seemingly ' simpler tasks in the plant which are performed by - an

. individually-assigned operator or. technicia In recent months, these . occurrences have included: two . operator valve lineup errors

. involving reactor vessel and/or fuel pool water level changes; an

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improper blade guide movement; and four I&C technician-induced system trips - one reactor protection system trip, one emergency core cool-i ing ' system . trip and two reactor water cleanup system -isolation While these' occurrences do not constitute safety problems individ-ually, they.do represent unnecessary. challenges to safety systems and a. general need for improvement by operators and technicians in their attention to detail. The licensee has -taken corrective actions for

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these occurrences which should prove to be effectiv Continued s plant management attention to this area is warranted - in order ' to ensure an improving trend. A need for improvement in the area o Operations management / shift personnel formal' communications (Standing

Orders and Night Orders) has also been identified. This was evid-enced by omission of notification (from management to shift

, personnel) about the NRC/ licensee temporary fire watch agreements and by issuance of shift directives that were not approved in accordance with the requirements for Standing Order In summary, the licensee's operational performance has been generally good. The Shoreham plant management team has exhibited an alert, technically competent and conservative approach to plant operation Quality Assurance for Plant Operations

'It is noteworthy that Operations and Maintenance management consider the assurance of quality for their department activities to be their i

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responsibility, rather than relying on independent QA organization overview of plant activitie During the preparations for, and actual conduct of, fuel loading and initial criticality testing, the level of QC inspector involvement was noted to be satisfactory. Deficiency reports that were written by the licensee's QC inspectors indicated that a thorough overview of activities was provide The BWR familiarization training provided to QC inspectors is considered to be a valuable enhancement of in-spector knowledge levels in preparation for power operatio The licensee developed a revised QA Department organization, in conjunc-tion 'with the transition from construction to operational (low power license) status, and submitted the necessary FSAR changes in September 198 The . licensee was issued a low power license in December 1984; however, as of the end of this assessment period, most of the quality assurance procedures reflecting these organizational changes had not been ' approved and issue The QA Department Manager position, which had been vacant for nine months, was filled shortly after the end of this perio Formal updating of organizational changes requires more aggressive management attentio During the early portion of the assessment period, senior licensee management brought to plant management's attention two problem areas that were characterized as "potentially significant trends adverse to quality." One involved late and/or incomplete responses to audit reports and, the other, failure to accomplish the necessary correct-ive and/or preventive actions within the committed times. NRC review of the Quality Control deficiency reporting / tracking system during the latter portion of the assessment period found the licensee's program, for ensuring that LILCo Deficiency Report (LDR) findings have corrective actions identified in a timely manner, to be lackin This situation resulted in issuance of a violation. The licensee's initial response and corrective actions were considered by the NRC as insufficient; however, subsequent feedback regarding a more aggress-ive follow-up program for establishing LDR corrective actions resulted in a satisfactory respons The Independent Safety Engineering Group (ISEG) is tasked by the Technical Specifications with overviewing plant operation Subse-quent to issuance of the low power license in December 1984, the ISEG was found to be spending 40% of its time on review and update of plant Systems Descriptions and only 20% of its time overviewing plant operations. This distribution of ISEG resources, relative to the priority of their safety overview role, was discussed with licensee management, and a satisfactory realignment of ISEG workforce utili-zation was mad Conclusion:

Rating: Category Trend: Improvin r

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Recommendations:

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Licensee: Continue plant management attention towards maintaining a low incidence of unnecessary cha11anges to_ safety /protec-tion systems, ensuring attention to detail by operators and technicians, and improving communication between Operations personne Continued upper management - attention should be given to ensuring .that.the QA Department and ISEG group provide an

, effective - quality assurance overview for- plant operation NRC: The possibility of attrition of ' experienced staff members due to Shoreham licensing delays exists and should be monitored closely during the next evaluation period.

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l 4.6. Radiological Controls (7%)

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.During this assessment period, there were seven inspections performed by region-based inspectors. Resident inspectors also checked radio-logical controls periodically. Radiation specialists inspected the

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'. licensee's radiation protection program, chemistry program, effluent monitoring and control program, and radioactive waste management and

transportation programs. Also inspected were the ' licensee's pre-operational testing of radioactive waste processing : systems, effluent -

monitoring systems,. and ventilation systems. A special team inspec-tion of post-accident . sampling capability, relative to guidance s . contained in NUREG-0737, was also performe .

During Lthe previous assessment period, weaknesses were identified in the site -radiological -controls organization and in the definition of '

position < responsibilities and. authorities- therei During this ,

assessment period,- the licensee reorganized the plant Radiological Controls Division into. three sections consisting of Health Physics,

. Radiochemistry, and Radioactive Waste. The responsibilities, author-

'ity,- and selection criteria of each division position are appropri-ately define This reorganization is an improvement: over the last assessment period and will provide for better control of radiological activitieszat the site. The Chemistry and Radioactive Waste sections -

were found to be -not fully. staffed; however, the licensee had hired contractor personnel to assist in performing the necessary functions .

of these sections during startup testing. Those contractor' personnel were : adequately ' trained and qualified for their responsibilitie '

The licensee is actively recruiting . to fill identified. vacancie Regarding .the corporate Radiological Controls organization, the licensee has formally -established the organization, defined .the responsibilities and authorities of the group, 'and defined the mini- ;

- . mum selection. criteria for each position specifie . The licensee has established a defined training and qualification program for personnel involved in radiation protection, chemistry and radioactive' waste activitie No deficiencies in the currently established program were identified. Training records were complete, ;

well maintained, and available. Reviews of licensee procedures for l

• radiation protection, chemistry, effluent monitoring and release control, and radioactive waste handling found them to be explicit, i controlled, and followe Some deficiencies were identified in the ;

licensee's airborne radioactivity surveillance procedures; however, these - deficiencies were quickly addressed by the licensee when brought to his attention,'

During this assessment period, licensee implementation of the guidance contained in a number of NRC Bulletins and Circulars was assessed by NRC inspection, addressing such matters as: packaging of low level

. waste - for- transfer and. burial; identification and prevention of

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unmonitored releases;. control of plant staff work hours; and perform-ance of safety evaluations for design changes to radioactive waste treatment systems. The licensee initiated timely, technically sound responses towards these NRC initiatives, and their action on these Bulletins and Circulars - demonstrated consistent evidence of prior planning and _ appropriate . assignment of priorities in addressing

, concerns identified therein. The licensee also gave similar atten-

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tion ' to recommendations provided in NRC Information Notices. For example, for a Notice describing instances of improper use of dosi-metry devices (by personnel at other stations and in order to mini-mize recorded exposure), the licensee modified radiation protection procedures in order to identify, in a timely manner, any apparent misuse of dosimetry devices by Shoreham personne The licensee's overview of and capabilities in the areas of chemical and radiochemical measurements were reviewed. The licensee has a well defined quality control program for chemical and radiochemical measurements. Procedures in this area' address, among other matters, personnel qualifications, applicable acceptance criteria, and correc-tive actions for unacceptable finding The licensee was provided-with actual radioactive test samples (by the NRC) to determine his capability to measure radioactivity in effluents, and satisfactorily analyzed those samples with no identified deficiencies. Radiological controls for loading of neutron sources into the reactor were also observed by NRC inspections, with no unacceptable conditions identi-fie An ' NRC team inspection assessed post-accident sampling capability, and found that the licensee's efforts in this area generally exceeded the ' minimum guidance specified in NUREG-073 For example, the licensee constructed a separate building as' a Post-Accident Sampling Facility (PASF). The PSAF is . equipped with it's own ~ ventilation system and in-line monitoring / analysis equipment which are capable of minimizing personnel exposure during sample collection. Some tech-nical and administrative deficiencies were identified with the Post-Accident Sampling System (PASS), such as: completion of a main-tenance program; high level effluent and chloride analysis capabili-ties; and, procedures for offsite transpor The licensee is aggress-ively moving to resolve these deficiencies. The PASS was not fully operational at the time of the team inspection; and, since the low power license required the establishment of all elements of the sampling program but no exemption to that license requirement had been obtained, the licensee was issued a violation. The licensee is currently training and qualifying all appropriate personnel on the operation of the PASS and anticipates full system operability prior to exceeding 5% powe Routine plant sampling systems are adequate for reactor operations below 5% power, and PASS availability would become significant only for power operation beyond that leve Conclusion:

Rating: Category 1 Trend: Consistent Recommendations: None

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4.7 Fire Protection / Housekeeping (7%)

Fire Protection Region-based inspectors conducted two inspections in this area, and regular resident inspector observations were also documented throughout this assessment period, addressing the control of combus-tible material, the maintenance of portable extinguishers, the conduct of fire watches and patrols, and related housekeeping No fires were experienced during this assessment period; and, as noted during the previous period, fire hoses, boxes and other equip-ment were accessible and regularly maintained operable. As d'scussed below, effective housekeeping practices consistently kept plant areas clean and free of debris. However, the safe shutdown team inspec-tion, discussed later, identified eight deviations from commitments described in the Safety Evaluation Report (SER) and Five Hazards Analysis Report (FHAR) . Fire watches, established during the last three months of this period as a result of the team inspection's findings, were observed- to be diligent, and the licensee's audit and oversight of these activities was effective. Fire Protection Program responsibilities have been assigned to a full time fire protection engineer who reports to the maintenance engineer. Evidence of their dedicated involvement in the Program was observed by the outstanding job ~ of monthly inspection of fire suppression equipment, including portable extinguishers. An example of the licensee's responsiveness to NRC concerns was the anchoring of portable emergency equipment lockers to prevent possible seismic damage to reactor building system Adequate fire protection and prevention provisions were also observed to be employed during the conduct of TDI diesel testing and fuel loa The licensee exhibited a continued understanding and concern for fire protection issues, as illustrated by their intent to hire 10 addi-tional fire protection technicians. These technicians' duties will include not only surveillance activities, but also fire brigade membership which will enhance the effectiveness and cohesiveness of brigade training by replacing the security force's involvemen Licensee management's involvement was demonstrated by the frequency and high level of brigade training provided and the quality and quantity of firefighting hardware found in equipment lockers through-out the plan The licensee was responsive in ' addressing a NRC concern for the condition of certain fire doors (pressure equaliza-tion openings) by initiating a re-certification of the doors by Underwriters Labs. While the licensee's application of their QA program in this area was judged to be thorough and comprehensive, the resolution of findings from the annual audit in January 1984 by the Shoreham Nuclear Review Board has not been prompt in that certain findings still remain open. The licensee had identified this problem in May 1984 and has since committed to expedite closeout and resolve future findings in a timely manne __

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The ' safe' shutdown team inspection identified eight deviations from commitments described in the Safety Evaluation Report (SER) and Fire Hazard Analysis Report (FHAR). Licensee management's evaluation of these issues, including their proposal of permanent corrective action, was quickly and thoroughly developed within five week Following formal -discussion at a management meeting with the NRC staff, a response to all deviations and unresolved items was provided

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two weeks hence. That response is currently under review by NRC, and follow-up of selected items is planned for April 198 .The licensee's FHAR and CSAR for the Reactor Building were considered as ' technically sound; however, supportive information was generally unavailable on site, and the FHAR for outside of Reactor Building was lacking in detail and thoroughness. Procedures used to attain a safe shutdown from outside of the Control Room were found to be generally adequate in attaining an orderly and timely shutdown. Walkthrough of those procedures during the team inspection noted a lack of emergency lighting in certain Reactor Building areas where local operations are to be performed. However, operator training and knowledge of proce-dures appeared to be thorough. In general, fire protection features were observed by the team to be well-designed, save for the defici-encies note Housekeeping As a result of previously identified housekeeping problems, the licensee made a major increase in the size of the facility cleanup force during the last SALP perio During this assessment period, the licensee has continued to make steady -improvements in housekeeping at the plant. Particular areas inspected for cleanliness include the drywell, all elevations of the reactor building, the turbine building, the screenwell, the control building (including the TDI diesel generator rooms), the radwaste building, and the new Colt diesel generator building which was under construction during this perio The licensee has achieved and maintained a level of excellence in housekeeping, which has been noted and documented in six inspection reports within this period; and, this observation has been affirmed by NRC management and staf Conclusion:

Rating: Category 2 Trend: Consistent Recommendations: None

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4.8. : Emergency Preparedness (3%)

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-One specialist inspection was conducted during.this assessment period

which addressed four unresolved . Items from the NRC's August 1982 L Emergency-Preparedness-Appraisa ~Th'e licensee is maintaining an active Emergency Preparedness Program l

and .has ' issued detailed Implementing Procedures for the onsite Emer-l- gency Plan. The emergency training program is well ~defired, detailed L for _ each1 specific assignment in the Emergency Response ~ 0rganization

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and maintained ~ by- the Emergency Preparedness Organization. . The

Emergency Preparedness. Program. continues to receive extensive LILCo.

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management ' involvement. ~ There has been an aggressive approach to1 resolution of emergency planning- issues and an extensive commitment

_

of -resources as indicated by the . size of the Emergency Preparedness staff;. seven Itcensee employees augmented by 13 contractor employee Until an appropriate emergency response exercise is - conducted, how-

!- ever, training effectiveness cannot be evaluated.

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The full power phase of the Shoreham ASLB hearings involves offsite

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emergency planning issues heard before a separate Board, begun at the l: . end of the last assessment period, and concluded in August of this period. LIn response to 32 technical inadequacies identified by FEMA,-

LILCo submitted . Revision 4 to its Offsite Emergency Response Pla Resolution of 24 of the 32 identified inadequacies had been accepted

~

as of the end of' this assessment period. A FEMA graded exercise of Shoreham's offsite emergency plan is, as yet, unscheduled, although LILCo has requested such an exercis '

Conclusion:

Rating: No basis, due to limited observation , ..

Trend: None Recommendations: None a

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L4~.91 Security and Safeguards (5%i

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lDuring ' the : pre-operational ' portion of the . assess. ment . period, plant g management 1 provided * effective oversight in the development 1of the t < i' Security Program and organization. The - licensee ' completed construc-

, 4 m tion and equipment installation for-the. protected and vital areas, as adescribed in the Physical Security Plan, in a timely manner prior to

' issuance of the low, pawer license. In addition, several specialized-

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security program enhancements, such as ~ extra lighting around the in-take area, anti-ramming devices.at vehicle gates and additional tele-vision; coverage of the protected area were implemented. During this-

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a: . period, the licensee . identified an = incident. involving a compromised .

set - of E security ~ examination Prompt.~and extensive . corrective

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actions were~ initiated. This reaction -demonstrated ~ management's

i capability . to analyze and take immediate action to mitigate and'

,

correct a potential proble '

, The Security" P' rogram was imolemented at an early:date to . ensure s Le ' adequate. training and qualifical.isit for the' securit9 - force. This Y initiative was very effective. Additionally, a profe"ssional firearms .

^

-qualification program is in-effect. Armed personnel were observed ,by >

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NRC inspectors to be proficientiin the handling and use -of weapon Security. force personnel l were cbserved .by ~the NRC staff to have

.. progressively improved their cap' abilities during this portion of the

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assessment period and management'p involvement was evident by a relatively trouble-free transif.fp when the low power operating

. license was issue ,

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During the relatively short post-l: censing f portion of the assessment

.+ period, the licensee reported one security event in accordance with

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10 CFR Part 73.71. This event . involved ~ a threat received ' by tele-phone.' The security. force was observed by NRC inspectors relative to interface with'. local' law enforcement authorities and implementation

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of contingency plan actions. The-security force was well coordinated-and implemented -required actions in a methodical and ' organized

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fashion while responding to .the event. This is attributed to manage-ment's. attention to the training and qualification of the security

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. force and early implementation ofz the security progra E'

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Three violations of secu'rity procedures have occurred during the post-licensing portion (since . December 7, 1984) of the assessment 4 period. One ' involved recordkeeping, and two involved ;fsflure to  :

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adhere to procedures by guard force personnel. One ofo the two >

procedural violations was of some concern to NRC, due to its poten-tial indication of a training weakness in at least one member of the h security . force. An evaluation = by the licensee of that perspective

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has been requested by the 'NRC, but was not due at the time, of this i report.' '

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.-In; order to obtain better insights into the licensee's training and qualification program, 'and because of training .and qualifications deficiencies identified at other nuclear power plants, NRC-conducted a special inspection in March 1985, during which members of the security' force - were randomly selected for re-examination in all

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phases of' training. Excellent cooperation was received from licensee management ' personnel who carried out the re examination-effort in an

organized and. professional manner. The results

the re examinations were very favorable and indicated that the security force can effec-tively perform the duties and responsibilities required by the NRC-

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approved Security Pla Conclusion:

Rating: Category 1

' Trend: Consistent Recommendations: None t

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4.10 Licensing The licensee's management participated actively in licensing activi-ties, many of which were associated with the TDI Diesel Generators

. hearings and the GDC-17 exemption proceeding Many significant licensee management changes occurred at the start of this assessment period. A new Chairman of the Board was named, who also serves as President and Chief Executive Officer of the compan A new- Vice President - Nuclear Operations, with extensive nuclear experience, joined the company, and a Plant Manager with operational nuclear experience was assigned. These individuals, most notably the Vice President - Nuclear Operations, have participated actively in resolving licensing issue The Senior Vice President, the Vice President - Nuclear Operations, and senior. plant management attended the NRR Management Readiness meeting in October 1984. The Vice President - Nuclear Operations has been heavily involved in meetings to resolve TDI EDG problems and the GDC-17 proceeding However, after the reorganization in April /May 1984, a promised FSAR revision describing the new management structure took inordinately long (five to six months) to provid The licensee's management consistently exercised firm control over its contractors' activities and maintained good communications between the contractor, their own staff, the NRR staff, and the NRR staff's contractors. We have noted, though, that the extensive litigation before the ASLB has had a chilling effect on the inter-change of information related to contested issue For example, in support of the TDI hearing on the "qua11fieri load", the staff . asked for detailed information on EDG loads in July 1984. We received a partial reply in November, which had been edited so carefully that much of the information it contained was technically useless. Many telephone calls and several more licensee submittals were necessary before the staff received useful answers. In a slightly different vein, the licensee proposed to use revised operating procedures and additional training to minimize the possibility of overloading the EDGs. . Despite oral reminders to the licensee's representatives in November 1984, and a written reminder on December 11, 1984, a team of NRC reviewers found on January 16 - 17, 1985, that the procedural revisions were not complete and were, in some cases, inadequat Furthermore, the team found that the training department had not been directed to develop a training plan for EDGs, despite the fact that hearings concerning the adequacy of that training were scheduled to begin on February 5, 198 The licensee's management and staff have demonstrated a satisfactory understanding of technical issues. The licensee initiated and

.provided major support to the TDI owner's group effort to resolve questions raised as to the adequacy of TDI diesel engines for nuclear service. In its presentation. of its justification for

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exemption from GDC-17, the licensee presented good technical justi-ficatio For these issues, the licensee's response to staff comments has generally been technically sound and presented in a thorough manner in extensive reports and meetings, as supported by test results. The licensee's proposal to do its own offsite emer-gency planning has been especially complete and thorough, notwith-standing certain legal problems associated with the pla In several other areas, such as implementation of Regulatory Guide 1,97 and the development of acceptable protection system setpoint methodology, the licensee's technical response could have been significantly improved by the submission of more detailed design information and a better technical justification for deviation Additionally, the staff feels that the licensee should have tested the TDI EDGs at the engines' normal rated capacity of 3500 KW, in-stead of as-tested rating of 3300 KW, to establish a qualified load value of the engines. The licensee has taken credit for operational capability above 3300 KW; however, this issue is currently before the ASL Because of 'Shoreham's stage of construction, relatively few NRC-initiated licensing issues were resolved during this rating perio The licensee's responsiveness to these few issues which arose varied widely. In general, issues which were required to be resolved prior to licensing, such as fire protection, TDI EDGs, process control program revisions, operator requalification, and equipment qualifi-cation, were addressed expeditiousl Issues which did not impact the issuance of a license, such as the operability of certain isola-tion valves, the development of a protection system setpoint method-ology, and implementation of Regulatory. Guide 1.97, dragged consider-ably. Other issues, such as the remote shutdown panel, thermal hydraulic code modifications, and the control of heavy loads, fell somewhere in betwee Conclusion:

Rating: Category 2 Trend: Consistent Recommendations:

Licensee: Devote more attention to items not on the critical path for licensing. Lessen burden on plant staff with respect to hearings, where it conflicts with normal responsibili-ties. Also, as requested by NRR staff on several occas-ions, a detailed FSAR design description of the Colt diesel generator project, including codes and standards to be applied to its construction, is needed if these engines are to be relied upon for plant operatio NRC: None

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5.0 SUPPORTING DATA AND SUMMARIES

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5.1 Investigations and Allegations Three items were referred to the Region I Office of Investigations during January and February 198 These items are currently under evaluatio Three allegations received during the previous SALP period were found to be unsubstantiated and closed, as were the 40 allegations from a former steamfitter employed at Shoreham. The three allegations in-volved design and installation of cable trays and conduit, weld QA data, and the adequacy of BISCO pressure _ seals for piping penetra-tions. The 40 allegations from the steamfitter involved a variety of concerns associated with the construction, design and testing of the facilit Allegations were received from three separate sources during the present SALP period and are still under evaluatio These involve concerns raised by a former Shoreham QC inspector and a former employee of two subcontractors at Shoreha The other allegation involves a licensed reactor operator's qualification .2 Escalated Enforcement Actions Civil Penalties: Non Orders The three Atomic Safety and Licensing Boards (ASLBs) presiding over the Shoreham OL Proceeding, the Appeal Board (ASLAB), and the Commissioners issued Memoranda and Orders as needed to support the ongoing hearing Confirmatory Action Letters One Confirmatory Action Letter (CAL 84-25) was issued on December 7, 1984, concerning compliance with Criterion 3, Fire Protection, of 10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plant Enforcement Conferences: Non .3 Management Conferences Held During the Assessment Period On November 16,:1984, NRR met with the licensee at the plant site for a review of the licensee's readiness for a low power license, which was issued on December 7,198 Other NRR site visits during the period included four regarding the TDI Emergency Diesel Generators and three General Design Criterion 17 exemption review _

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A management meeting was conducted March 1, 1985, at Region I to discuss candidate performance during the February 18, 1985 cold license examinations at Shoreham. In addition, the LILCo Vice-President - Nuclear met with Regional management to discuss corrective actions regarding the cold license exams on March 20, 198 Visits to the Shoreham site were made by NRC Commissioners Zech, Bernthal, and Asselstin .4. Exemptions Granted The following exemptions to Appendix A, General Design Criteria, of 10 CFR Part 50 have been granted:

GDC-2 - Seismic qualification of certain equipment; GDC-56 -~ Redundant containment isolation barriers; GDC-19 - Remote shutdown capabilit .5 Construction Deficiency Reports (CDRs)

Three CDRs were submitted by the licensee during this assessment period. The CDRs are described in Table 1. Review of these CDRs identified no causal linkage .6 Licensee Event Reports (LERs)

Eight LERs were submitted during the last quarter of +his assessment period. The LERs are characterized by cause in Table 2. No causal linkages were identifie .7 Part 21 Reports Louis Allis submitted a report under' 10 CFR Part 21 to NRC Region I on March 6,1985, concerning seven cracked welds found in coil guar conical baffles installed on the Colt diesel generators at- Shoreham.

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Proposed corrective action included weld repair and an inspection of similar units.

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TABLE 1

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CONSTRUCTION DEFICIENCY REPORTS

.Shoreham Nuclear Power Station (March 1,1984 - February 28,1985)

CDR N Deficiency Cause Code-85-00-01 Emergency Diesel Generator Design / Fabrication Error

' Turbocharger Failure 84-00-02 Corrosion of Emergency Design / Fabrication Error Service Water Strainers

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84-00-03- ' Motor Control Center Room Design / Fabrication Error

. Duct Penetration Not Sealed

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TABLE 2 LICENSEE EVENT REPORTS BY FUNCTIONAL AREA Shoreham Nuclear Power Station (March 1, 1984 - February 28,1985)

Area Number /Cause Code Total 4.1~ Construction Activities -

-4.2 Engineering Design 0 4.3 Pre-op and Startup Testing 2/A, 1/B 3 4.4 Maintenance and Surveillance 0

~4.5 Plant Operations 1/A 1 4.6 Radiological Control .7 Fire Protection and Housekeeping 2/A, 1/D ,3 4.8 Emergency Preparedness 0 4.9 Security and Safeguards 1/X 1 4.10 Licensing -

Total 8 Cause Codes:

A - Personnel Error

'B - Design, Manufacturing, Construction or Installation Error

'C - External Cause D - Defective Procedure

'E - Component Failure X Other

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TABLE 3 ENFORCEMENT SUMMARY Shoreham Nuclear Power Station (March 1,1984 - February 28,1985) Number and Severity Level of Violations and Deviations Severity Level Number

.

Severity Level I 0 Severity Level II 0 Severity _ Level III 0 Severity Level IV 2 -

Severity Level V 5 Deviations 9 Violation vs. Functional Area-Severity Level Functional Area IV V Deviation

~ Construction Activities Engineering and Design

- Pre-operational and Startup Testing 1 Maintenance and Surveillance 1 1 1 Plant Operations 2 Radiological Controls 1 Fire Protection / Housekeeping :7 Emergency Preparedness Security and Safeguards 1 1 1 Licensing-Totals 2 5 9

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Table 3 (Cont'd.)- 39 Violation Details Report Number /. Severity Level /

Inspection Dates Functional Area Subject 84-31- Deviation / Certain test conditions and L -7/23-26/84 Startup acceptance criteria in HPCI and RCIC startup tests do not conform

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to FSAR description Deviation / Improper spacing of fire detectors 12/3-7/84 Fire Protection in Reactor Buildin Deviation / Fire doors degraded because of Fire Protection security modification Deviation / Improper routing of fire pump Fire Protection cables in electric fire pump roo Deviation / No fire damper in duct between Fire Protection HVAC and Chiller room Deviation / Inadequate carbon dioxide density Fire Protection in Battery Room and cable tunne Deviation / Fire detectors in computer room Fire Protection located above suspended ceilin Deviation /- Emergency lighting not available Fire Protection in all area Level V/ Improperly approved Operations 12/15/84-1/31/85 Plant Operations Administrative Directives in use in the control roo Level V/ Twenty-three LDR dispositions not Plant Operations approved by QA within required time perio Level-V/ Failure to establish all PASS

'2/11-15/85 .(proposed) program elements consistent with Radiological low power license. requirement Controls-85-05 Level IV/ Inaccurate inventory of standby 1/21/84-1/25/85 Security lock core Level V/ Inadequate search of a vehicle Security entering the protected area.

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LTable 3 (Cont'd.) -40

Violation' Details (Cont'd.)

Report Number /' ' Severity Level /

Inspection-Dates' Functional Area Subject 85-08 Deviation / QC inspectors lacked proper eye 1/28/85-2/1/85 Surveillance test certificatio Level IV/ Failure to fully establish proce-Surveillance dures_for the Leakage Reduction-Control Program in accordance with Technical Specification .85-12 Level V/ Failure to meet procedural-2/19-22/85 Maintenance requirements for scheduling of I&C preventative maintenanc _

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TABLE 4 s

' INSPECTION ACTIVITIES

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Shoreham Nuclear-Power ~ Station

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K(March :1, .1984 - February 28,1985)-

._ _

Inspectors /  ;

Report N Hours- Areas' Inspected:

284-07 JSpecialist/ Pre operational Procedu're and. Test Results

'56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> -Review and TDI diesel engine repair (84-08- Specialist / Radiation Environmental and Meteorological 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> Monitoring Programs.

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84-09 . Specialist /' TDI Diesel Generator Test Recovery Progra .

.28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> 184-10 Four Residents / Resolution of eight previous open items, 11-

~

435 hours0.00503 days <br />0.121 hours <br />7.19246e-4 weeks <br />1.655175e-4 months <br /> NUREG-0737 items, IE Bulletin 79-08 and Circular 79-24; Review of April-14, 1984

' Loss of Power, TDI-Diesel Overhaul, an ~

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-Potential for Maintenance-Induced-Reactor .

' Building Floodin Specialist /- TDI: Diesel Generator-Test Recovery Qualifi-

~88 hours cation and: Revalidation Progra : Three; Specialists / Chemistry Program and Effluents Radiation 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> . Monitorin .11 Specialists /- -Resolution of 57 previous Open Inspection

'(Team):  : Items; Review of Operational Staffing and 440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> Plant. Operating Procedure Specialist / Pre-operational Test Procedure Review and 61 hour7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br />s- -Results Evaluation; Integrated Electrical-Test Witnes ti

.. ;84-17- Specialist /- Review of Radiological Outstanding Items;

'

14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> IE Bulletin 80-10; IE Circulars 77-14,

'

80-14, and 81-09; Control Room and RBSVS

.HVAC Testin Two Specilists/ Resolution of 14 previous open inspection 317 hours0.00367 days <br />0.0881 hours <br />5.241402e-4 weeks <br />1.206185e-4 months <br /> items, observation of TDI diesel testing, and follow-up of Radwaste Building floodin ~84519 Two; Specialists / Security Program Implementatio '

68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br />

+

.

'

.*a

p

.. . ..

-

_

Table 4 (Cont'd.) 42 Inspectors /

Report N Hours Areas Inspected 84-20 Specialist / Startup Test Program Administrative Controls 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> and Personnel Training; IE Bulletin 80-17, CRD-SDV Modification E Specialist / Follow-up of Outstanding Items concerning 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />s- Radiography; IE Bulletins 80-08 and 13, 82-01 and 03, and 83-0 .Two. Specialists / Fuel Load and Initial Startup Test Program 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> Plannin Three Residents / Colt Diesel Project, Resolution of Open 213 hours0.00247 days <br />0.0592 hours <br />3.521825e-4 weeks <br />8.10465e-5 months <br /> Items, IE Bulletin 80-06 (ESF Reset),

Allegation on BISCO Seals, and NUREG-0737 Item II.B.4 (Training for Mitigating Core Damage), and Follow-up on Security Inciden Specialist / Construction of Colt Emergency Diesel 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> Generator Building - Civil / Structural Activities and Settlement Monitorin Specialist / Outstanding Items, Circulars, Bulletin hours 84-26 -Two Specialists / Evalsation of Pre-o'perational Test 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> Exceptions; NUREG-0737 Item I.D.2 - SPDS; Witness of Backup Emergency Electrical Power (EMDs and Gas Turbine) Testin .84-27 Three Specialists / Fuel Load and Initial Startup Test Program 89 hours0.00103 days <br />0.0247 hours <br />1.471561e-4 weeks <br />3.38645e-5 months <br /> Procedures; Bulletin and CDR Follow-u ~84-29 Two Residents / Routine Resident Inspection of Open Items,

,

281 hours0.00325 days <br />0.0781 hours <br />4.646164e-4 weeks <br />1.069205e-4 months <br /> Allegations, TDI Engine and Integrated

,

Electrical Testing.

r 84-30 Specialist / TDI Diesel Outstanding Item hours

84-31 Specialist Startup Test Procedure Revie hours 84-32 Two-Residents / Resolution of Open Items, Plant Modification 235 hours0.00272 days <br />0.0653 hours <br />3.885582e-4 weeks <br />8.94175e-5 months <br /> Controls, Equipment Trending, Colt Building Construction and EMD Testing.

-

p -

-

. o -'

Table 4(Cont'd.) 43 Inspectors /

Report N Hours Areas Inspected 84-33 Three Specialists / NUREG-0737 Items II.E.4.1 and 2, Dedicated 63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> Hydrogen Penetrations and Isolation Valve Dependabilit Specialist /. Security Program Implementation and Review :

36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of Open Item Specialist / Outstanding Items and Related Electrical 35 hour4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />s- Discipline Bulletins;. Colt Diesel Building Constructio .84-36 Four Specialists / Colt Diesel Building Construction; HVAC 128 hours0.00148 days <br />0.0356 hours <br />2.116402e-4 weeks <br />4.8704e-5 months <br /> Electrical and Vendor Installatio Specialist /- Completion of the Pre-operational Test 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> Progra Three Specialists / Fire Protection / Prevention Program Admini-96 hours stration, Organization and Control Resident / Review of previous Open Items; TDI Diesel 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> Testing; Equipment Storage; LPCI MG-Set Field Inspection;. Administration of Security Guard Examination ' Specialist / Settlement monitoring of structures; Colt 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> Diesel Program QC Documentatio Specialist / Status of, and training for, Fuel Load and >

21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> Startup Test Progra ~

84-43 Specialist / Radiological Controls-Program Organization 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> and Staffing; Related Outstanding Items, Bulletins and Circulars, and IE Notice 84-5 Specialist / Colt Diesel Piping and Supports; IE 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> Bulletins 83-06 and 07 (Tubeline and Ray Miller).

84-45 Resident / Resolution of Seven Previous Outstanding 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> Items and CDR 84-02 (Service Water Strainer Corrosion); Bahnson HVAC Weld Deficiencies; Follow-up of Drywell Floor Spills - Valve Lineup Controls and Fuel Support Piece Misalignment; Witness of TDI Diesel Fatigue Cycle Testing and Handling of Neutron Sources; NRR Operational Readiness Inspec-tion Tour (November 15 and 16).

_

.

_

. .-

Table 4 (Cont'd.) 44 Inspectors / . .

Report N Hours Areas Inspected

.84-46 .Four Specialists / Fire Protection and Safe Shutdown

_(Team) 236 hours0.00273 days <br />0.0656 hours <br />3.902116e-4 weeks <br />8.9798e-5 months <br /> Capability, t 84-47- Two Specialists / Fuel Load and Initial Startup Test Proce-38 hours' dures;'Orywell Vacuum Breaker Surveillanc Two Specialists / Review of pre-fuel load activities and 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> witness of neutron source loading; proce-dures for Tech Spec Surveillances during refueling; IE Notice 84-76, Loss of All AC Power, applicability to STP-31 at Shoreha Three Specialists / Witness of initial fuel loading and control 169 hours0.00196 days <br />0.0469 hours <br />2.794312e-4 weeks <br />6.43045e-5 months <br /> rod friction and shutdown margin testing, including independent verification of SRM data, rod timing and accumulator pressures; RBSVS isolation valve stroke testin Resident / Control of Plant Operations; ISEG Activi-199 hours ties; Shift Turnover and Log Reviews; QA Deficiency Follow-u Examiner / Shift Advisor Progra hours 85-01 Two Specialists / Witness of fuel load activities,. including 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> final' core verification of fuel bundle location; Re-installation of vessel -inter--

nals and head; IRM/SRM Surveillance Testing; GETARS Calibratfor Specialist / HVAC installatio1 and Bahnson equipment 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> deficiencies (IE Notice 84-30).

85-04 Six Specialists / NUREG-0737 Items II.B.3, PASS; II.F.1.1, (Team) 208 hours0.00241 days <br />0.0578 hours <br />3.439153e-4 weeks <br />7.9144e-5 months <br /> Noble Gas Effluent Monitoring; II.F.1.2, Plant Effluent Sampling; II.F.1.3, Contain-ment High Range Monitors; and III. D.3.3, In plant Iodine Monitorin Two Specialists / Securit hours 85-06 Specialist / Follow-up of four Emergency Preparedness 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> Appraisal Previous Open Item ~

,

..

(

- '

.: o

_

Table 4 (Cont'd.)- 45 Inspectors /

Report N Hours Areas Inspected 85-07- Three Examiners / Operator Licensing Exam hours 85-0 Specialist / NUREG-0737 Item III.D.1.1, Leakage Reduction 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> . Program, Administrative and Surveillance Procedure Three Specialists / Witness and review of Initial Criticality 262 hours0.00303 days <br />0.0728 hours <br />4.332011e-4 weeks <br />9.9691e-5 months <br /> and Startup Test Results;. Surveillance Test Program Revie Project Engineer / Eight allegations made by former QC 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inspecto Resident / QA Department Staffing and Personnel Quali-188 hours fications; NED Administrative Controls; Follow-up of Open Items 85-12 Two Specialists / I&C Preventative and Corrective Maintenance 47 hours5.439815e-4 days <br />0.0131 hours <br />7.771164e-5 weeks <br />1.78835e-5 months <br /> Program Three Examiners / Operator Requalification Exam hours

-

, ;6^ = _

46-

-TABLE 5 INSPECTION HOURS SUMMARY

--Shoreham Nuclear Power Station

. (March 1,1984 - February 28; 1985)

Functional Area . Hours- % of Time . Construction' Activities 872 17 - Engineering and Design 465- 9 LPre-operational and Startup Testing 1,664 ~32 ' Maintenance and Surveillance ~ 328 6 Pladt Operations 742- 14 Radiological Controls 379 7 ' Fire Protection / Housekeeping 372 7

' Emergency Preparedness 1 132 3 Security and Safeguards 247 5 1 Licensing? * *

_ Total .5,201**' 100

-

• Hours expended. in facility licensing activities and Operator Licensing acti-

.vities-are not included with direct inspection effort statistic ** Excluding a total of 274 hours0.00317 days <br />0.0761 hours <br />4.530423e-4 weeks <br />1.04257e-4 months <br /> expended on Operator Licensing examinations during the assessment perio