ML20147G936
| ML20147G936 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, 05000000, Shoreham |
| Issue date: | 07/09/1985 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Dick W AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20147G281 | List: |
| References | |
| FOIA-88-56 NUDOCS 8803080348 | |
| Download: ML20147G936 (4) | |
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gr 37 JUL 9 1985 Information in this record was deleted in a ord a freedom of Information
Dear Mr. 01ck:
This refers to your March 5,1985 interview with Mr. W. Lazarus of this office and specifically about our conduct of the Readiness Assessment Team Inspection at Shoreham in January 1983. As committed to you in our letter of April 10, 1985, we have appraised the concerns which you expressed regarding: (1) LILCo's Quality Accountability Program; (2) NRC followup of individual inspection find-ings; and (3) the overall conclusions of our readiness team.
We appreciate j
your bringing these concerns to our attention, and offer the following pertinent considerations.
The purpose of the Readiness Assessment Team Inspection was to assess LILCo's overall readiness to load fuel at Shoreham. The consensus reached by the team was that the plant would not be ready for fuel load for a period of at least 5 to 6 months from the time of the inspenion.
That conclusion was based upon our exTmination of a number of signific. ant indicators, one of which was the quality and results of final QC construction inspections.
However, the team also assessed the progress of Shoreham's Preoperational Test Program including emergency diesel testing, system turnover priorities, and the trecking and dis-position of test exceptions and outstanding commitments to the HRC such as un-resolved inspection items and IE Bulletins and Circulars. Also evaluated were improvements towards plant housekeeping and fire protection practices, the development of station administrative and operating procedures, and the use of controlled drawings.
Finally, the team reviewed the qualifications and re-sources of LILCo staff assigned to operational programs.
All of these were factored into our determination of the status of operational readiness of the Shoreham facility and an eventual recommendation for issuance of an operating license.
One finding of the Readiness Assessment Inspection was that additional atten-tion by LILCo management was needed in the area of final system inspection.
Identification of component discrepancies during inspections following the baseline QA/QC Program for construction were resulting in high rejection Of particular concern were large and small-bore pipe hangers, cable rates.
tray and conduct supports, and structural steel. Since LILCo management agreed that acceptance of construction should receive "front-end" attention, so as not to rely heavily upon final QA/QC inspections to correct deficiencies, initia-
.l tives were undertaken to improve the quality and effectiveness of both con-1 struction activity and final field QC inspection. As you are aware, a Quality I
Accountability Program was promptly formulated at the conclusion of the Readt-ness Inspection, as generally described in a January 1983 letter to our Senior Resident Inspector and in more detailed letters to this office in February and March 1983.
The scope and conceptual guidelines for the program were also dis-cussed during a management meeting at NRC Region i on January 25, 1983, and again at a meeting held onsite on April 6,1983.
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Mr. W. G. Dick 2
Regular observation by our 3enior Resident Inspector of these quality enhance-ment measures during the period January through June 1983, verified that con-struction activities were being surveilled on a sampling basis by qualified LILCo personnel.
Region I management were periodically appraised of program status not only during the meetings described above, but also by the Senior Resident Inspector's observations and our review of the Quality Accountability Reports generated through June of 1983. As part of the program the statistics associated with Deficiency Correction Orders (OCO's) and Nonconformance and Disposition Reports (N&Ds) were analyzed for the four principal work categories of interest.
These data showed no obvious adverse trends, and that the fre-quency of findings (rejections) which resulted in corrective field rework had been maintained at or reduced to acceptably low levels by the end of May 1983.
Our May 6, 1983 letter to LILCo noted the aggressive steps taken in response to these issues.
Further, during NRC followup of individual findings from the team inspection, the implementation of the Field QA Verification and Quality l
Accountability Programs was surveyed.
The programs were judged to be in accord with the intent of the guidelines and commitments established by LILCo to as-sure that items accepted by final QC inspection met acceptable standards.
LILCo management attention towards construction accountability, and in trending and evaluating inspection findings, was observed to be evident and effective.
These conclusions were documented in NRC Region I Inspection Report No. 50-322/83-13 istued on May 23, 1983.
A copy of that report is attached for your information.
While most types of rework items were determined to be minor in nature, the intent of our assessment was (and continues to be) to monitor the effectivenss of LILCo's QA prograrrs.
Our conclusion, which was af firmed by the Shoreham i
Atomic Safety and Licensing Board in their September 1983 Partial Initial Decision, was that these programs were effective and generally timely in the detection and followup of construction deficiencies.
What the Board concluded was that LILCo's QA program met the NRC requirements outlined in Appendix B to 10 CFR part 50. Notwithstanding the mathematical rigor of statistical sampling techniques, the licensing board and NRC Staff concluded that sound technical judgement was applied and a solid foundation established for providing reason-able assurance of adequate protection of the health and safety of the public.
The findings of NRC inspections, both prior to and after the Readiness Assess-ment, have verified that no lapses, breakdowns or inconsistencies exist in LILCo QA programs for Shoreham construction, preoperational testing and opera-tion.
This judgement was integral to and consistent with our recommendation for issuance of a low power operating license for Shoreham on December 7,1984.
Sincerely, 0[iginal Signad 3 ;
7 Richard W. Starostecki, Director Division of Reactor Projects
Enclosure:
NRC Inspection Report No. 50-322/83-13 0FFICIAL RECORD COPY LTR DICK - 0002.0.0 06/04/85
Mr. W. G. Dick 3
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Allegation File for RI-85-A-0037 /
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[\\s ALLEGATION RECElpT rep 0RT Date/ Time 4eceived: $ C C 7 8 $ / l.[! D O a e.
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Address Phone:
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Yes No X Impi Alleger's j
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[A/At 01lfe 2 Docket No.: 60322 Allegation Summary (brief description of concern s)): 7~f c. M2( h Je b & W ua f
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Number of Concarns:
(for Allegation panel Only)
Enployee Receiving Allegation: 7.1.7ukewc(( er (first two initials and last name)
Type of Regulated Activity: (a) j Reactor (d) _ Safeguards (b)
Vendor (e) ~ Other:
(c) _ Materials (Specify)
Materials License No. (if applicable):
Functional Area (s):
(a) Operations
_ (e) Emergency Preparedness J ((b) Con:t.ruction (f) Onsite Health and Safety c) Safeguards.
(g) Of f site Health and Safety
_ (d) Transportation
_ (h) Other:
InbrmMion In 9IS *$ ; $ 3 c nictma000 igg:ru mCae,toniror, m A. g~s-(Fevised June 1984)
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