IR 05000498/1985012

SALP Board Repts 50-498/85-12 & 50-499/85-12 for Dec 1983 - June 1985

ML20135F059
Person / Time
Site:	South Texas
Issue date:	09/12/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135F031	List: IR 05000498/1985012 ML20135F028
References
50-498-85-12, 50-499-85-12, NUDOCS 8509170138
Download: ML20135F059 (28)

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. - SALP BOARD REPORT

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I U.S. NUCLEAR REGULATORY COMMISSION I

i' REGION IV

i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

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Inspection Report 50-498/85-12 - 50-499/85-12 Houston Lighting & Power Company (HL&P)

l South Texas Project

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Units 1 and 2

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December 1, 1983 - June 30, 1985 i

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. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operatio An NRC SALP Board, composed of the staff members listed below, met on August 20, 1985, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."

A sumary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at South Texas Project for the period December 1,1983 through June 30, 198 The SALP Board was composed of the following members of the NRC staff:

R. P. Denise, Director, Division of Reactor Safety and Projects (Chairman) L. Bangart, Director, Division of Radiation Safety and Safeguards E. H. Johnson, Chief, Reactor Projects Branch G. L. Constable, Chief, Project Section C, Reactor Projects Branch C. E. Johnson, Senior Resident Inspector, Construction N. P. Kadambi, Project Manager G. W. Knighton, Chief, Licensing Branch No. 3 Other attendees who participated in all or part of the Board's deliberations were:

D. L. Garrison, Resident Inspector, Construction D. R. Carpenter, Resident Inspector, Operations B. A. Breslau, Project Inspector W. C. Seidle, Chief, Technical Support Staff J. A. Kelly, Physical Security Inspector D. P. Tomlinson, Reactor Inspector, Construction II. CRITERIA Licensee performance was assessed in 16 selected functional area Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas.

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-t t-2-One or more of the following evaluation criteria were used to assess each functional area: Management involvement in assuring qualit . Approach to resolution of technical issues from safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Reporting and analysis of reportable event . Staffing (including management). Training effectiveness and qualificatio However, the SALP Board is not limited to these criteria and others may have been used where appropriate.

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Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:

Category 1: Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieve Category 2: NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieve Category 3: Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieve The SALP Board has also categorized the performance trend over the course of the SALP assessment period for those functional areas where such a trend was evident. The trend is meant to describe the general or prevailing tendency (the performance gradient) during the SALP perio This categorization is not a comparison between the current and previous

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-3-SALP ratings; rather, the categorization process involves a review of performance during the current SALP period and categorization of the trend of performance during that period only. The performance trends are defined as follows:

Improved: Licensee performance has generally improved over the course of the SALP assessment perio Same: Licensee performance has remained essentially constant over the course of the SALP assessment period.

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Declined: Licensee performance has generally declined over the course of the SALP assessment perio III. Summary of Results

Improvement has been achieved in the areas of safety-related components, i training, corrective action and reporting, design and design change i control, and material control. The most notable improvement was in the quality program and administrative controls functional area, the licensee established a pre-CAT verification team (PCVT) to assess the quality of its construction contractors and conduct a "self" assessment in preparation for the scheduled NRC construction audit tea The PCVT performed system walkdown, hardware inspection and record package review for such systems as safety-related pipe supports and 125Vdc and 4kV AC systems. These concentrated inspections revealed numerous minor hardware problems and documentation discrepancies, which are being corrected. This aggressive inspection effort indicates improvement is needed in the

" normal" quality control verification / inspection proces The licensee's performance and trend are summarized in the table below, along with the performance categories from the previous SALP evaluation period:

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Performance Category Performance Category Latest Functional Area (12/01/82 to 11/30/83) (12/01/83 to 06/30/85) SALP Deriod Soils and 3 2 Not determined Foundations Containment and 2 2 Same Other Safety-Related Structures Piping Systems and 1 2 Same Supports Safety-Related 2 2 Improved Components HVAC NA 2 Same Fire Protection NA 2 Same Electrical Power 1 2 Not determined Supply and

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Distribution Instrumentation and NA NA Control Systems Licensing Activities 1 2 Same Physical Security NA 2 Not determined Training NA 1 Improved Corrective Action 3 1 Improved Reporting Design and Design 2 1 Improved Change Control Material Control 3 2 Improved Quality Program and 2 2 Improved Administrative Controls Preoperational Testing N/A N/A

• Assigned when a trend was evident

0-5-The total NRC inspection effort during this SALP evaluation period consisted of 23 inspections, including routine / reactive resident inspector inspections, for a total of 2,933 direct inspection hours. A large portion of these hours were utilized during the NRC's'NDE van inspection (613 hours0.00709 days <br />0.17 hours <br />0.00101 weeks <br />2.332465e-4 months <br />). Closecut of allegations, open items and followup to the Quadrex report items accounted for more than 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> with the remainder of time devoted to construction inspectio IV. PERFORMANCE ANALYSIS Soils and Foundations Analysis During this period little major soils work was conducted. One NRC inspection of remaining earthwork activities was conducted, in addition, ongoing soils activities are observed on a continuing basis by the resident inspecto Inspection of the soils contractor laboratory and review of in-process backfill inspection reports indicated that the earthwork inspection and testing program has improved in quality control attention and management oversight. No violations or deviations were noted in i these activitie . Conclusions During this assessment period management attention has been evident in this functional area. Licensee Quality Assurance audits and QC oversight appear to have been effective in identifying and correcting deficiencies. The licensee is considered to be in Performance Category 2 for this are . Board Recommendation: Recommended NRC Action The NRC inspection effort in this area should proceed at a

> normal level, consistent with the level of construction activities, Recommended Licensee Actions Management attention to this area should continue to assure that remaining soils and foundation work continues to be carried out in accoruance with NRC regulations. The

' filling of the reservoirs in stages should be closely monitored through the relief wells and other instrumentation. The settlement monitoring program should

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-6-continue to be aggressively carried out to ensure that any deviations from expected values are identified.

Containment and Other Safety-Related Structures Analysis Two inspections were performed in this functional area during this perio In addition, the resident inspectors observed ongoing activities in this functional area on a frequent basis.

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An inspection was performed in the Unit I control room. The area consisted of framing steel at elevation 45'-6" for the drop ceilings over the control room. Configuration and orientation of structural members were examined by the NRC inspecto Random checks on torque of bolts were also performed with

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satisfactory result Installation of additional structural i members and modifications were properly documented. Records

{ such as erection inspection reports, structural welding reports,

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torque testing and bolt-up inspection reports were reviewed and determined to be in accordance with specifications.

I Placement of the Unit 2 containment dome liner was observed during

this period. The Unit 2 containment dome liner was lifted into place and in progress welding was observed by NRC inspector Observation of the lift indicated no discrepancies or problem i No violations or deviations were identified in the NRC l inspection , Conclusion Based on the results of the NRC inspections and ongoing i

observations by the resident inspectors, the performance in this functional area has been determined to be adequate, although discrepancies of minor significance were noted.

. Licensee's management attention and involvement are generally evident. The licensee is considered to be in Performance Category 2 in this are , Board Recommendations I Recommended NRC Action

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The NRC inspection effort in this area should be maintained at the present level.

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. Recommended Licensee Action Licensee management involvement in this area should continue at a level commensurate with construction activities.

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C. Piping Systems and Supports j Analysis One inspection was performed in this functional area during the period. In addition, ongoing activities are observed by the resident inspectors on a frequent basi This inspection

included welding of safety-related piping. No violations or deviations were identified during the NRC inspection in this functional are .

A concentrated pre-CAT inspection by the licensee disclosed

nun.erous discrepancies. Though minor in nature, these nonconformances in the safety related pipe supports caused work

to be stopped and a joint investigation initiated to determine the root cause. A corrective action plan is being developed.

1 Conclusions Management attention in this area is generally evident. The pre-CAT audit indicates current work / inspection practices need to be improved. The licensee is considered to be in Performance Category 2 in this are . Board Recommendations Recommended NRC Action

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It is appropriate to continue or even increase the NRC inspection effort in this important-functional area to be commensurate with the level of construction activities.

Recommended Licensee Action Although management attention to this area has been evident, the increase in construction activities will I

require a corresponding increase in oversight to assure that the required level of quality is achieved. The deficiencies identified during the pre-CAT audit noted above indicate that the normal inspection process should be strengthened. Management attention should be focused

on ensuring that similar deficiencies do not exist in

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-8-D. Safety-Related Components Analysis Inspection of safety-related components during this evaluation period was primarily in the area of storage and preservation of components _in the warehouses, receipt and storage process and inplace/ installed protection. Generally, within this functional area, the licensee's activities were acceptable and in compliance with their commitments. An item of concern dealing with the maintenance of appropriate storage levels for the Unit 2 reactor internals, noted by the NRC inspectors, was corrected by the licensee. Additionally,.several housekeeping items of concern

.were noted in the site tours section of various inspection reports regarding plant cleanliness in the various cleanliness / storage level areas. The licensee responded in a timely manner to all specifically identified items,_however, there was not plant-wide attention to housekeeping. Areas of concern when noted, would be corrected, would remain in order for.a period, while other

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plant areas deteriorate . Conclusions The licensee's actions are timely and adequate manpower is available. The licensee needs to reduce the cyclic pattern of

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inplace protection and housekeeping so as to maintain a constant, controlled, acceptable level of storage protection and housekeeping, particularly_in the plant. The warehouse / lay-down_

area seems less susceptible to cyclic swings of acceptability and is adequately maintained. The licensee is considered to be l in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Action The NRC should continue the inspection effort at the same level, focusing on ' inspection of the inplace storage and maintenance of the safety-related components and general plant cleanliness. Additional NRC inspection is needed on the installation of safety-related components and review of the QA records for components already installed, Recommended Licensee Action Management involvement and oversight in this functional area should increase in order to reduce the cyclic nature of housekeeping and storage activities and maintain a high level of cleanliness and equipment protectio h

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E. HVAC Analysis One inspection was performed in this functional area during this period. In addition, ongoing activities are observed by the resident inspectors on a frequent basis. There was one severity level IV violation in the class 7 HVAC supports involving the failure to properly torque support bolts. Class 7 supports are seismic Category II supports for systems whose continued function is not required, for which the failure of the support could reduce the functioning of one or more other plant safety systems or components to an unacceptable, safety level. The cause of the violation was determined to be that installation was not in compliance with the procedur Inspections were also performed on the safety-related HVAC system examined, located in the electrical penetration room above elevation 35'-0" in the electrical auxiliary buildin The NRC inspector observed configuration, orientation, material

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and welds of both duct sections and supports. There were approximately 20 supports and 44 duct sections in the system inspected. The overall system appeared to be in compliance with procedures and drawings. No violations or deviations were identified directly involving the safety-related HVAC syste . Conclusion .

Licensee management attention and involvement in this functional area are evident; corrective actions for identified problems are generally timely and effective. The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Action The NRC inspection effort should focus on inspection of support structure installation. The inspection effort should be commensurate with the increase of construction activities in this functional are Recommended Licensee Action Management involvement and oversight in this functional area should be commensurate with the level of construction activit ~

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-10-F. Fire Protection Analysis One inspection of fire protection systems was performed during this period and activities were routinely observed by the resident inspectors. Several inspections of housekeeping as they related to fire prevention and protection were also mad Inspection of the fire pump house and equipment and the main loop did not reveal any discrepancies. The water fed system in the facilities are temporary and little other work was observed to be in process. The housekeeping inspections did not reveal any significant plant-wide problem areas related to combustible .

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accumulation or egress blockage. However, a small smoldering fire in the area of the reactor vessel for Unit 1 occurred, indicating the need for continued attention to this functional are . Conclusion:

Site tours by the NRC inspectors have shown that an extensive effort has been made to maintain a high level of fire prevention and protection. The housekeeping is satisfactory in this area and the existing fire protection systems work is satisfactory, but requires continuing attentio The licensee is considered to be in Performance Category 2 in this functional are i Board Recommendations Recommended NRC Action NRC inspection effort should increase commensurate with the present level of activity, with future emphasis given to inspection of construction activities related to fire prevention system installatio , Recommended licensee actions The licensee's attention to the installation of systems should increase due to increased activity in these area The licensee should expedite completion of design according to accepted standards to ensure that construction and inspection proceed in an orderly manne !

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O-11-G. Electrical Power Supply and Distribution Analysis Construction activity in the safety-related electrical area was not extensive this perio NRC inspection concentrated on purchasing, warehousing, storage and material control, although some termination activities were inspected. The NRC inspectors observed the installation of safety-related batteries and on May 28, 1985, the NRC inspectors observed the energization of the standby transformer. The inspection in this area did not reveal any violations or deviation A pre-CAT inspection conducted by the licensee of the 125Vdc and 4kV AC IE safety-related electrical system revealed minor hardware problems and a significant number of discrepancies in the record packages. The licensee has corrected the hardware problems and is correcting the record package deficiencies. The pre-CAT team also noted numerous deficiencies in the electrical cable tray hanger / support program, which are being addressed by the license . Conclusion:

The licensee's effort in storage and warehousing is excellent, however, the normal inspection process must be improved to ensure discrepancies are identified without reliance on special inspection The licensee is considered to be in Performance Category 2 in this are . Board Recommendations NRC Actions The NRC's inspection effort in this area should be increased as the construction effort increase Recommended Licensee Action Licensee management attention should continue to be focused on this area to ensure that adequate quality is achieve The installation of cable and wiring is now picking up along with associated instrumentation and will require a commensurate level of management attentio H. Instrumentation and Control Systems Construction activities in this functional area were limited during this period, other than routine work, and no assessment was mad _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ - - - _ _ _ _ - . _

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I. Licensing Activities l Analysis l

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The licensing activity on the South Texas Project during the

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reporting period December 1, 1983, to June 30, 1985, was

, characterized by a low level of activity in the first half of

. the period and a high level during the second. The change in

, architect engineer and constructor which took place in late 1981, brought about substantial changes to the design and the

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documentation which became evident in the later part of the report perio i I In September 1984, a management meeting was held with the licensee to better understand the schedule for licensing of the first unit of the Project, which called for the loading of fuel ,

j in December 198 It was recognized that the schedule was

aggressive and would require extraordinary effort from the

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licensee as well as the staff. The assessment presented here and substantiated in Attachment A should be viewed in the i perspective of the demands of such an intensive effort. As an l example, there have been 18 meetings with NRR staff in the first i

6 months of 1985. The results of the review being conducted by i the staff will be documented in the Safety Evaluation Report !

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scheduled to be issued in December 198 . Conclusion

The applicant has brought to bear adequate resources to the

South Texas Project and managed the licensing effort in an I

effective way. Based on the detailed evaluations described in Attachment A, the licensee is considered to be in Performance l

Category 2 for this are '

Board Recommendation

, Recommended NRC Action The NRC staff should be sensitive to the unique design I

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features of the South Texas Project, such as fire

protection and instrumentation, the review of which could determine the schedule of the critical path in the

licensing revie j

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! The ifcensee should continue to deploy the necessary resources to support the staff review. The areas where problems could arise due to the unique design characteristics should receive special attention for improvement in performance, t

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-13-J. Physical Security Analysis One inspection was conducted of security-related activities during this assessment period. This inspection consisted of a preoperational review of the security program development. The areas reviewed were the programs for ensuring utility and contractor personnel fitness for duty, the handling of security-related quality concerns, security organization formation and i

the coordination of design and installation of the physical security systems. Concerns were raised about the interfacing of disciplines associated with the development of the programs reviewed, however, no violations were identifie The security organizational design is strong and the plans progressive. There is also good corporate support for the security program initiatives, however, direct lines of communication with security counterparts in the construction elements of the utility and the contractors are not apparen There is concern about the security organization user's apparent lack of involvement in the implementation of the hardware aspects of the security program.

1 Conclusions The planning and development phases of the human and organiza-tional aspects of the security program are making good progres The quality of the leadership within the security organization seems to be sufficiently strong to resolve identified problem The licensee is considered to be Performance Category 2 in this

functional are . Board Recommendatons Recommended NRC Action The level of NRC inspection effort concerning the physical security program should be increased commensurate with the

increase in security activities.

Recommended Licensee Action The respective corporate, operations, and construction management units should improve the interdisciplinary J communications concerning ongoing security-related matters and security program and systems development.

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, -14-K. Training Analysis

! During the assessment period various training activities were I conducted, including reactor operator cold licensing, chemical operator, auxiliary operator, various craft training, QA and orientation, startup department training and numerous "one time" sessions. Although there was one severity level V violation during this period, a few training records were missing signatures / documentation. Reactor operator training was the most significant effort during the assessment period.

Attendance at selected training sessions by the NRC inspector indicates that the level of instruction was acceptable, there j was good class participation, facilities were adequate and the instructors were well prepared. Training material was reviewed on a sampling basis. Some of the early training handouts were

poorly prepared, this was due in part to the design changes being performed on the plant which required last minute changes to the handouts. During later sessions the quality of handouts

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i Operator training includes classroom instruction and simulator training. The length of simulator training will be dependent on the experience, background and required duties of the individual. The training will take place over about Ih years and is planned and being conducted in a timely manne Eight instructors took the NRC Instructor Certification examination, passed, and were granted Instructor Certificate . Conclusion The overall training activities and, specifically, the operator training portion are being conducted in an organized and

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effective manner. The licensee is considered to be in

Performance Category 1 for the training are . Board Recommendations

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, Recommended NRC Action i

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The NRC should continue the inspection effort at the same level focusing on the reactor operating classroom sessions

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and the simulator training scheduled to start in January i 1986. A team inspection to cover the training program for all plant staff positions should be scheduled for early in 1986.

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! Recommended Licensee Action ,

The licensee should continue the positive effort towards training and licensing of the plant operators. Additional efforts should continue to ensure adequate training is provided for nonlicensed personne l l L. Corrective Action and Reporting

Analysis This program was extensively evaluated during the last portion of the reporting period although the inspections and evaluation L generally covered the entire period. No items of concern were i noted in the licensee or contractor programs at the site or in

! the Corporate office. Management attention has been prompt and i the evaluations thorough. The licensee has adopted a low l threshold for reporting potential events to the NRC.

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The applicant's licensing group handles this area of the program (

in a prompt and expeditious manner. The licensee is considered l to be in performance Category 1 in this area, l Board Recommendations j Recommended NRC Action NRC inspection activities in this area should be directed !

at ensuring deficiencies are properly evaluated, corrected and reported where necessar ; Recommended Licensee Action

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Management overview and involvement in this function should continue to ensure that deficient conditions are evaluated [

and corrected, including actions to prevent recurrence, and '

properly reported where require M. Design and Design Change Control

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i Emphasis was placed on this area during this reporting perio l Three inspections were conducted which indicated that there was e improvement in this process. Although one severity level IV violation and one unresolved item for distribution and recall were generated, both of these problems were promptly rectifie ,

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-16-The inspections revolved around the issue, distribution, and recall of a variety of documents. In the last NRC inspection, 42 checks of controlled documents in 11 areas revealed no deficiencie . Conclusion: ,

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Management attention in this area is evident and a positive record of performance was noted in the three inspections during ,

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The licensee is considered to be in a Performance Category . Board Recommendations Recommended NRC Action r The NRC inspection effort in this area should be maintained

! at the present level in order to assure that the system j functions as intended.

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Licensee management should continue their present level of attention and involvement in this are Material Control Analysis The licensee and the construction manager (Bechtel) have made a concentrated effort to clear up earlier material control problems and have programs in place to prevent further problems in this area. NRC STP inspection reports 8504 and 8506 address these areas. Additionally, the " Technical Evaluation of Anchor <

Bolts and Embedded Rods," which addresses NRC inspection report items in this area, was completed and was transmitted to NRC for review in May 1985. During this assessment period, two violations were noted; a severity level V violation for failure to provide direction for the disposition and reinspection of deficient weld filler material and a severity level IV violation for nonpermanent material being installed without correct identificatio ! Conclusion:

Utility management has been aggressively pursuing this problem I area and has addressed NRC inspection report items. There have '

been major improvements in this program. The licensee is considered to be in Performance Category 2 in the area of  ;

material contro !

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. Recommended NRC Action l

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NRC inspection effort should be maintained at the present ;

i level in the review of licensee closure and corrective l l

action to assure that the program remains adequate, j

i f Recommended Licensee Action

! Licensee management involvement should be focused in this j functional area to ensure adequate quality is achieve ,

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i Analysis i During this assessment period, NRC inspectors identified seven

{ violations which included failure to follow procedure in i j torquing bolts, training records missing signatures, failure to l

have a procedure in performing safety-related activities, ,

failure to effectively control documents and failure to provide !

direction for disposition and reinspection of deficient weld !

filler material. Five of these violations are described in '

their respective functional areas.

1 Recently, the licensee took over direct management of the Measurement and Test Equipment (M&TE) program for all test and

)l inspection activities conducted at STP to enhance the control j and traceability of test equipment. Two of the seven violations i indicated above were noted in this area; a severity level V violation for failure to have a procedure and a severity :

level IV violation for not having a procedure to control !'

I tracking recall of M&TE. These were judged not be be

) indicative of a programmatic weaknesses.

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, Several audit and surveillance reports and their responses were '

reviewed for responsiveness and accuracy in correcting root .

! causes and were found to be satisf.ctor !

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} It was determined that the quality control program of the l

constructor examines and records the attributes necessary to l verify that the construction is being performed in accordance

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i with the drawings, specifications, and procedures as required.

1 Observation of construction activities, discussion with crafts ;

and QA/QC inspectors and review of records indicate that the ,

quality control activities are functioning as intended. Audits '

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and surveillances are performed as required. Although the .

t licensee does not approve all site procedures for '

subcontractors, the audit program provides a means for review of I

} these procedure i i 1 During the assessment period the licensee demonstrated an i j increasing level in management control and involvement in all

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safety-related as well as general plant activities. One example i of increased attention is the creation of the "Safeteam" for

) providing an avenue for any site employee to register a concern i d on a safety issue. The Safeteam reports through the licensee's '

i QA department to senior management personnel. All concerns are 5 j investigated and written feedback is provided to the individual '

with the concern. A second example is the creation of the

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Project Compliance Group, whose function is to interface with

the NRC to close out any items of concern the NRC hat from any j source. Both of these programs are functioning deceptabl ! Senior Corporate management is present at the site weekly and 1 are routinely involved in meetings with NRC, contractors, and i other licensee employees covering a broad range of safety and management issues. The NRC inspectors have observed a ,

l continuing effort to strengthen the project team by the addition j

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of experienced people to the licensee and contractor staf . Conclusion l

i With respect to quality assurance and quality control at the

.i South Texas Project, it was concluded that satisfactory [

j performance is being achieve *

The licensee management is directly involved in the activities I and direction of this project. As the key stages of

construction completion are entered, the licensee is applying j the necessary management control to ensure that safety concerns

and activities are adequately addressed in a timely manne l,

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The licensee is considered to be in Performance Category 2 in

{ this functional are ; Board Recommendations [ Recommended NRC Actinn '

i NRC inspection effort will continue at the present level.

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Some areas will increase in effort as construction 1 completion peaks and system turnover and preoperational j testing efforts increas Increased inspection activity l >

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-19-may be required in some areas such as material control to assure that programs implemented by the licensee and contractor provide the desired results, Recommended Licensee Action The licensee's current attention and oversight of the implementation of the quality assurance program should continue as heretofore demonstrated, with recognition of the ongoing change from mostly construction, which still must be maintained, to turnover, testing and operating activitie Preoperaticnal Testing During this assessment period no preoperational tests were conducte NRC inspection activities were therefore limited to review of preoperational test procedures in draft form and the organization of the startup group. This functional area was therefore not assesse V. Supporting Data and Summaries Licensee Activities Construction and design work proceeded on a routine basis during this period. At the end of the assessment period, the licensee reported construction completion on Unit 1 as 84.9% and Unit 2 as 59.7%. Major Inspection Activities Violations See table 1 Major Inspections A major inspection was performed during the period of January 3-29, 1984, concerning code welding. The NRC Mobile NDE van was utilized and the subjects of inspection were material traceability, procedures review of radiographs, personnel qualified, and NDE areas RT, thickness, ferrite, hardness measurements, liquid penetrant and visual examinatio Investigations and Allegations Review During this assessment period, four cases are pending investigatio These deal with falsification of records / intimidation of personne . .

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The following' allegations were reviewed during this assessmen period:

• Failure to report a test failure involving the essential cooling water pipin * Improper rigging practice utilized in the installation and alignment of the reactor coolant pipin * Document control system was operating at a high error rate and error rate was being covered u * Improper cadwelds and welding to rebar in the primary and secondary shield wall * Unqualified QA/QC personnel are sent to another site for 2-4 months then brought back as qualified inspector The technical followup on these allegations are discussed in NRC Region IV inspection report D. Escalated Enforcement Actions Civil Penalties No notices of violations with proposed imposition of civil penalties were issued to the licensee during this assessment perio . Enforcement Orders None E. Management Conferences Held During Assessment Period Conferences In September 1984, a management conference was held with the applicant to better understand the schedule for licensing of the first unit of the project, which called for loading fuel in December 198 __ __ .__ _

o-21- Review of Licensee Event Reports, Construction Deficiency Reports-and 10 CFR Part 21 Reports Submitted by the Licensee Licensee Event Reports (LER)

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Not applicable Deficiency Reports The licensee issued 41 potentially reportable deficiency reports during this assessment period. Ten had subsequently been determined to be not reportabl ; The following is a list of reportable deficiencies reported

during this period:

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Attachment of Cathodic Protection Devices to Pipe

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Failure of AFW Pump Wearing Rings

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• ESF Load Sequencer

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• Control Room Habitability - Hazardous Chemical Release

Commingling of Round Rod Material

• Comsip Standard Bed Catalyst j -

NPSI Snubber Assembly Rear Brackets

A194.2H and A563 Nuts Failed Hardness Test 4 *

Containment Spray pH

W Inverters /Ferro-Resonant Transformers

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Trapeze Type Support Assemblies

Failure of Fire Dampers to Close

Undocumented Weld Repairs to Unit 'l Reactor / Vessel Nozzle -

t j *

Flood Protection Deficiencies

Failure of Non-Seismic CCW Tank Level and Flow Switches

RCP Thermal Barrier Failure

Bostrom-Bergen Anchor Bolts

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• Loss of Heating in FHB Due to LOOP

• Cracks in Structural Steel Used in HVAC Supports

• Magnetics QA Program

• Pipe Support Eye-Rod Interferences

• Unanalyzed Seismic Interaction

• AFW Spool Wall Thickness

• Improper Consideration of Prying Action for Pipe Support Anchorage

• Phoenix Steel Thin Wall Pipe

• Core Exit Temperature Measurement System

Reactor Pressure Vessel Radiographs

• Pipe Support Deficiencies

• Potential Depressurization of the EAB, Control Room and TSC HVAC System

• Diesel Generator Fuel Storage Capacity

125Vdc and 4kV AC System Record Packages 3. Part 21 Reports None

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TABLE 1 ENFORCEMENT SUMMARY COMMON TO BOTH STP 1 AND STP 2 FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL AREA V IV III II I DEVIATIONS Soils and Foundations Containment and Other Safety-Related Structures Piping Systems and Supports Safety-Related Components HVAC 1 Fire Protection Electrical Power Supply and Distribution Instrumentation and Control Systems Licensing Activities Physical Security Training 1 Corrective Action Reporting Design and Design Change 1 1 Control' Material Control 1 1 Quality Program and 1 1 Administrative Controls Preoperational Testing

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4' Attachment A

to the SALP Board Report Docket Nos.: 50-498 50-499 i

FACILITY: South Texas Project, Units 1 and 2 LICENSEE: Houston Lighting and Power Company EVALUATION PERIOD: December 1, 1983 to June 30, 1985 NRR PROJECT MANAGER: N. Prasad Kadambi Introduction This report presents the results of an evaluation of the applicant, Houston Lighting and Power Company, in the functional area of licensing activitie It is intended to provide NRR's input to the SALP review process as described in NRC Manual Chapter 0516 and Office Letter No. 44 dated January 3, 198 The level of staff effort to review the South Texas Project FSAR and ER had been reduced during the period prior to mid-1984 when substantial changes were taking place in the plant design due to the replacement of the architect-engineer and constructor. This required substantial changes in the FSAR and ER. The part year has seen the submittal of about 10 amendments to the FSAR and one to the ER. Most of the amendments have been quite voluminou In September,1984 a management meeting was held with the applicant to better understand the schedule for licensing of the first unit of the Project, which called for loading of fuel in December,1986. It was recognized that the schedule was aggressive and would require extra-ordinary effort from the applicant as well as the staff. The assessment presented in this report should be viewed in the perspective of the demands of such an intensive effor II. Sunnary NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2, or 3) based on a composite of a number of attributes. The performance of the Houston Lighting and Power Company in the functional area of Licensing Activities is rated Category 2. The applicant was rated Category 1 in the functional area during the previous SALP period. The significance of the single rating should be considered in the context of the large number of activities going on during the later portion of the reporting perio III. Criteria The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1. Evaluation criteria with Attributes for Assessment of Licensee Performanc .

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-2 IV. Methodology The major portion of licensing review activity over this reporting period occurred toward the end of the period preparatory to the issue of the Draft Safety Evaluation Report (DSER). The DSER was scheduled for issue in June 1985. Although most of the staff review of the FSAR (which continues to be amended) has been completed, the documentation of the review has not been finalized. Many of the reviewers who have interacted with the applicant while conducting the review have contributed their assessments of the performance observed. Each assessment considered the same attributes as discussed below. The licensing Project Manager combined the individual assessments with his own and arrived as a composite rating for the applicant. A written evaluation was circulated to NRR management for coments before the final draft was prepare The basis for this appraisal has included requests for additional information, site visits and meetings at the NRC and applicants offices. The following specific review areas provided inputs into the assessment:

Mechanical and Design Documentation Review Geological and Seismological Review Detailed Control Room Design Review Fire Protection Review Review of the Training Programs Quality Assurance Program Core Design Review Radiation Protection Program Materials Engineering Review Water Treatment and Coatings Review Control of Heavy Loads Assessment of Performance Attributes The following attributes described in NRC Manual Chapter 0516 were evaluate * Management Involvement and Control in Assuring Quality

• Approach to Resolution of Technical Issues from a Safety Standpoint

• Responsiveness to NRC Initiatives

• Staffing

• Training and Qualifications Effectiveness i Reporting and Analysis of Reportable Events There was no basis for NRR evaluation for Enforcement activities as described in Manual Chapter 051 l

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-3- Management Involvement and Control in Assuring Quality Management involvement in planning, assignment of priorities and use of procedures to control activities are well evident by the significant accomplishments in the licensing review. The information submittals appear to have received adequate management reviews. The information is generally timely, thorough and technically sound. In some cases, it was evident that a great deal of effort was expended to make timely submittal The necessary records are generally complete, well maintained and available. Management has made a commitment to help in any way they can to facilitate information flow into the NRC staff to expedite the review. In general the performance has been consistent with this commitmen On the basis that the applicants' resources are adequate and reasonably effective, a rating of Category 2 is assigned to this attribut Approach to Resolution of Technical Issues from a Safety Standpoint The applicant and his contractors and consultants have generally displayed an adequate understanding of the regulatory issues in the licensing area. The technical resolutions proposed on various issues are generally conservative and based on sound approaches. In certain areas, the applicant has been keen to economize on con-struction costs by requesting that the safety review be consistent with the guidelines applicable to the date of docketing of the OL application. When such issues became significant, the applicant has been generally forthcoming with information which would help the staff conduct the review to the appropriate standard review plan. The applicant has generally acted to promote timely resolution of all technical issue Based on the satisfactory performance in approaching the technical issues, a rating of Category 2 is assigned to this attribut Responsiveness to NRC Initiatives The applicant has been generally responsive to NRC initiative In some cases, such as resolution of issues arising from GDC-51, the mechanical engineering design documentation review, and the instrumentation and control review, the applicant allocated abundant resources to obtain a timely resolution. In other cases, such as the geological and fire protection areas, the responses were not as thorough. At this stage in the review, it appears that the only regulatory issue which has not been expeditiously resolved is conformance to the staff guidance on fire protectio .

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Based on our observation that NRC attention on this attribute should be maintained at normal levels, a rating of Category 2 is assigned here, i

! Staffing In the areas where observation of staffing was possible to a suf- I ficient extent, it is clear that the applicant has personnel of i . sufficient qualification and in sufficient number to conduct the i licensing activities. The responsibilities of the positions are well defined.

j Based on the favorable observations in the area of staffing, a rating of Category 2 is assigned to this attribut Other Attributes The attributes of Training and Qualifications Effectiveness and

.

Reporting & Analysis of Reportable Events were observed by reviewers in just two subject areas. Hence, an overall Category assignment was not made for these attribute VI. Other Functional Areas Instrumentation

'

The South Texas Project has several unique aspects to the instrumenta-tion design. The applicant has been effective in presenting the

!

required information to NRR staff so that the review can be conducte However, the schedule for implementation has been slipped, raising the possibility that the final stages of NRC review may have to be expedited to meet the licensing schedule.

,

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Based on the above, a rating of Category 2 is assigned to this are Plant Cleanliness

' The licensing PM has visited the plant site four times in the previous five months and has observed construction in all the

'

main areas. On some of the tours other staff members have also observed specific areas of the plant. Based on these observations i it is concluded that relatively high standards of cleanliness and !

good housekeeping practices are followed by the South Texas Projec l Based on the above discussion the overall rating of Category 1 is I assigned to this functional are VII. Conclusion A perfonnance rating of Category 2 has been assigned by the NRR SALP evaluation effort for the rating period December 1,1983 to June 30,

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198 I

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SUPPORTING DATA NRR/ Licensee Meeting and Site Visits June 26-27, 1985 MEB Review Meeting June 24, 1985 Site Visit to examine plant features with respect to beyond-design-basis events May 21, 1985 Lineament Analysis data May 21, 1985 Fire Protection Measures May 17, 1985 Design Documentation Review May 7-8-9, 1985 RSB RAI's May 1-2-3, 1985 Environmental Site Visit April 19, 1985 Discussion on Technical Specifications April 4, 1985

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Alternate and Safe Shutdown Capability April 3, 1985 PSB RAI's April 3, 1985 HFEB RAI's

, April 2, 1985 Main Coolant Resevoir March 26-29, 1985 ICSB Audit and Site Visit February 25, 1985 GDC-51 Meeing February 15, 1985 Briefing for new Director, DL January 24, 1985 GDC-51 Meeting January 16, 1985 Fire Hazards Analysis January 7-11, 1985 SGEB Structural Audit December 12, 1984 QDPS Meeting September 13, 1984 Management Meeting on OL review June 12, 1984 EQ Program and Tech. Spec. Preparation May 10, 1984 AFW Reliability Study May 3, 1984 Update to ER-OL Meeting March 1, 1984 Engineering Assurance Program December 14, 1983 Fire Hazards Analysis December 15-16, 1983 NUREG-0737 Action Items December 1, 1983 Caseload Forecast Panel Visit Comission Briefings None Exemptions and Reliefs None License Amendments None FSAR Amendments Amendments 36 through 48 ER Amendments Amendment 7

, Orders Issued None