IR 05000498/1986019
| ML20212M403 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/09/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20212M400 | List: |
| References | |
| 50-498-86-19, 50-499-86-18, NUDOCS 8703110442 | |
| Download: ML20212M403 (35) | |
Text
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. ;d, ,,. ,. .SALP BOARD REPORTi ~ +.. - - --. . .- . ,. ' '
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, i' + U.S. NUCLEAR REGULATORY' COMMISSION. ' .f - , s.: .. ,_
. , ,. ' ~ . REGION IV ' > SYSTEMATIC ASSESSMENT 0F-LICENSEE PERFORMANCE SALP Board Report 50-498/86-19 and 50-499/86-18 - Houston Lighting & Power Company (HL&P) South Texas Project, Units 1 and 2 (STP) ~ July'1,-1985, through December 31, 1986 4 G703110442 870309 PDR ADOCK 05000498 O PDR i y - ,; ~ w . ,
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. INTRODUCTION- . , ,, . _- m, - .
a _ s a . '. , ., The~ Systematic" Assessment'offlicenseeLPerformance (SALP). program lis an.
, integrated NRC staff. effort to collect available; observations:and data on1 ^ ,
- a periodic basis and to evaluate licensee performance based upon this
' ' - ' -information.- SALP11s supplemental to. normal regulatory processes used to '
- ensure compliance to NRC, rules
- and regulations. cSALP. is intended-to be
' sufficiently diagnostic to~ provide a rationalJbasis for allocating NRC aR _ < resources and to provide meaningful guidance to the clicensee's management.
' to' promote quality and safety of plant operation.
- ' '
- n'NRC'SALPBoard,.composedoflthestAfffmembers-listed lbelow,meton A
LFebruary/12? 1987,Sto-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 summary of.the' guidance and evaluation criteria-is-provided in Section II of=this report.
This' report.is the SALP Board's assessment.of the licensee's' safety-performance at STP for the period July 1, 1985, through December 31,:1986.
. The' SALP Board members for STP were: '
, , , ' ~ R. E. Hall, Deputy Director, Division of Reactor Safety and Projects,. ' ,J.
ag ardo, fChief, Reactor Projects Braiich, Region ~IV, ' G. L. - Constable, Chief, Project Section C, Reactor Projects Branch, . i " Region IVJ a" ' - 'N. P..Kadambi, Project Manager, NRR , e > , ' a , cD. R. Carpenter, Senior Resident. Inspector, Region IV; gr ' r - C..E. Johnson,' Senior Resident Inspector, Region-IV y .., , . - Thefollowingpersonnelalsoparticipated,i.n'thfSALPBordmeeting; [~ l % C. Seidle, Chief, Technical. Support Staff',. Region'IV. i
~ ~ ~ --B."Murray, Chief,' Facilities: Radiological' Protection Section,LRegion IV< ~ ^ '
- D. L. Garrison,' Resident -Inspector, Region IV','
' '
- .,, H.LF. Bundy, Project = Inspector, Region IV
%., - 3 4 e r j' B. A.-Breslau, Project Inspector, Region IV iu.' ' - - . . . i J. B. Baird,' Emergency Preparedness Analyst, RegionilV
.. 1 L J. A. F. ' Kelly, Senior Physical Security Specialist, Region IV i.
J. E. Bess, Reactor Inspector, Region IV > L. D. Gilbert, Reactor Inspector, Region IV F R. G. Taylor, Project Inspector, Region IV _ '
- .
- , ' II. -CRITERIA e F Licensee performance was assessed in selected functional areas.
Each functional area normally represents areas significant to nuclear safety ' ' ' [ and the environment.
f-One.or more of the following evaluation criteria were used to assess each ( functional area: i.
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Management 1 involvement?in a'suring: quality- ~ ~ s , J i+ ' ._
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'_ Approach to1 resolution.offtechnical; issues'from'a safety standpoint ' - ~ ' , . f JC.)
Responsiveness tolNRC initiatives ~ _ ,
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-Operational $and Construction _ events (including response to; analysis- ' ' ~ , ?
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. . However,ithe SALP; Board is"notilimited to these criteria 'and other_s.may1
<} - have been:used'where appropviate.
' - , , % . Based:uponth'e'SA'LP) Board' assessment,each' functions 1 area'evaluat'edis-0 ~' W classified 11nto one of three performance = categories.
The definitions;of " s };
- these performancs~ categories are:
-
Category 1: Reduced NRC attention may be a'ppropriate.
Licensee ~
- management' attention and involvement are aggressive and oriented toward
nuclear safety;clicensee resources are ample and effectively used so that- 'a high" level of performance with respect to operational safety or construction is being achieved.
- " -Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are-a concerned with: nuclear safety; licensee. resources are adequate and are "
- reasonably' effective-so that satisfactory performance with respect to
_ operational-safety or construction is being achieved.
'
. ' Category 3: Both NRC and licensee attention should1be' increased.
.
.. - .. ' L " + Licensee management attention or-involvement is acceptable and considers 7 ^ r T ' nuclear safety, but weaknesses are evident; licensee resources appear to - > > 7 ~be strained or not effectively used so that minimally satisfactory. - ~ .. . . performance with respect to operational safety or constructionKis.being
> ,' : . _ III. SUPMARY OF RESULTS- ' achieved.
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' -~ - - -Ahighlevelofperformancehasbeenachievediktheareas'ofcontainment, ' . safety-related, structures, and major steel supports;1 auxiliary systems;; and training and qualification. An area needing improvement.is^ emergency, <. ,,
- planning, although after the appraisal period it appeared that area was
' .- , improving significantly. Areas requiring continued management attention ' are the corrective action systems and the coordination of construction, - startup,'and operational activities during testing to avoid conflicts.
The NRC staff has noted a high level of performance and dedication to quality in the overall management of STP.
This is reflected in effective fitness for duty and SAFETEAM programs which are fully supported by senior licensee management.
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' ,. ..., 1The licensee's performance is -summarized in theitablejeldw;[along with~d u ~ the performance categories-from the; previous SALP evalu' tion' period: ~ ' ' a f t, ; Previous iv+ Present "f.
.,,. ~ ' Performance Category Performance Category ' , - ' Functional-Area (12/01/83 to 06/30/85) (07/01/85 to 12/31/86) l tA.1 Soils;and.
Not ssessed) . Foundations , B.' Containment,-Safety- '2
1Related Structures, and Major Steel Supports ~ C. Piping Systems
2 and. Supports ' D.: Safety-Related
2 Components-Mechanical .E.' Auxiliary Systems
1 F. Electrical Equip-
2 ment and Cables G. Instrumentation Not Assessed
'H.' Licensing Activities
2 'I. Security
2 J. Radiological Controls Not Assessed
K. Emergency Preparedness Not Assessed
, L. Training and Quali-
1 fication Effectiveness M. Quality Programs and
2 - ' Administrative Controls Affecting Quality N. Preoperational Not Assessed
Testing IV.
PERFORMANCE ANALYSIS l A.
Soils and Foundations During this period only minor work was accomplished in this functional area.
Inspections in this area were not sufficient to provide a basis for evaluation.
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Containment,~ Safety-RelatedStructures[and'Mafor,SteelSupports" A, f 7 , , .
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. Analysis.
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-Seveninspectionswereperformedin.this[ functional ~rea, a e inclu' ding both units, by the resi_ dent inspectors.,,Inladdition, an NRC Construction. Appraisal _ Team (CAT) inspection was _
conducted. -The. inspections were performed in the following' t areas: ' structural concrete, structural steel,.Cadwelding, and" ' post-tensioning systems.
3 g* - .$, fe Concrete placement activities, post-tensioning,'and'in process' mechanical splicing'of reinforcing' steel were found to have been well managed, planned and executed.'..The. CAT' identified one violation which indicated that certain steel sliding' connections had bolts installed to'a torque which exceeded the required ' values.' The cause of the violation.was found to be inadequate - instructions had been provided to the field <for use by craft and quality control (QC). -It should be _noted that a. comparable ~ ~ problem was identified by the NRC in Inspection Report 83-16 but had not been responded to at the time of the _ CAT inspection indicating a. lack.of responsiveness by the licensee.
In response to the.NRC concerns, the licensee has established adequate instructions and has completed all rework'and reinspection of the sliding connections.
This rework was completed by the licensee before they had officially received the violation.
This initiative by HL&P indicates that , management involvement was thorough, well planned and-technically sound.
2.
Conclusion The performance in this functional area has been determined through observation and inspections by the resident inspectors to be well planned and implemented by management as evidenced by the few deficiencies' identified.
The licensee is considered to be in Performance Category 1 in this area.
3.
Board Recommendations a.
Recommended NRC Action The NRC inspection effort in this area may be reduced for Unit 2.
Unit 1 inspections are essentially complete.
b.
Recommended Licensee Action I Licensee management involvement in the area should continue at a level commensurate with construction activities in Unit 2.
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~ Piping Systems aEd Supports , . .1 '. Analysis . There were.seven inspections accomplished in this area during the= assessment period including one by CAT and one by the e ' Nondestructive Examination (NDE) Team. - A total of.eight violations affecting either piping or piping supports were identified.
Four of the violations were related to welding problems; three were of a miscellaneous nature involving debris in pipe, installation of valves with cap screws instead of stud bolts,_and removal of support spring hanger stops without approval. The other violation involved the failure to properly store support components. Six of the violations were identified very early in the assessment period and the.one involving the debris in the pipe was discovered during verification radiography, although the. debris had been introduced into the-pipe much earlier. The issue of storage of components and the unauthorized removal of.the stops from the spring hangers'were identified late in-the assessment period.
It appears that the licensee's enhanced management controls implemented subsequent to the CAT inspection (early in the SALP period) have been effective in reducing quality problems in this area. The licensee identified recurrence of Microbiological Induced ,_ Corrosion (MIC)insomesafety-relatedpipingsystemsandhas _ implemented corrective action including control measures to' preclude further recurrence of MIC in piping and other stainless steel safety-related components. Examples of effective
management controls in this area include a system of holding - foreman level craft supervision responsible for the quality of ' work of their people.
2.
Conclusion I^ Based on the improvements and the management controls N implemented by the licensee in the past year, the licensee is ! considered to be in Performance Category 2 in this area.
3.
Board Reconnendations . a. - Recommended NRC Action I' The inspection effort in this functional area should continue commensurate with the level of construction > activities.
,
b.
Recommended Licensee Action < Although licensee management attention has been generally L evident, continued emphasis must be maintained to assure
! that the desired level of quality is achieved and to ! preclude recurrence of similar deficiencies.
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- D.3 JSafety-Related Components --Mechanical
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'1.' > Analysis ' '
, , _ N'ineinspectionswereperformedinlthisfunctional.areaduring.
' , ' J ~ ~ this SALPcperiod by resident and regional inspectors and one by7
. E the. CAT during which four violations were identified.
. ' = L f.c ' ' Inspection activities reported in this functional' area included
~
W-storage, maintenance,'and. protection of safety-related . ',
- components with some coverage.of.~ final assembly of components:
- ' ' and systems,.such as' reactor vessel; internals, pressurizerg and E._ essential cooling water. ; Areas' examined included the licensee's' permanent plant maintenance (PPM) system including its . application,in the field... fuel storage racks, reactor: internals,. and installed and stored safety-related components.
Early in , '. this SALP.~ period.the failure of the, PPM; system to provide for . the protection a'nd preservation of safety-related equipment and ,' '- components was, widespread. -The. licensee put forth a concerted . , effort to evaluate component status, review protection-requiremen.ts, refurbish suspect equipment, and review the program to make it functional._ By the end of this SALP period, " - 'thd licensee-had a fully functional and acceptable program.
~ Isolated instances of damage to safety-related components . ' including flood damage were identified throughout this period.. Those instances can be attributed to. ongoing construction f .e
activities, normal for construction sites.*'During this -, _ c - assessment period.there was flooding in, Unit 2~which was e q ' reported as a-50.55(e) item because of'p'ssible damage to. ', o ' electrical cabinets located at elevation 10tfeet in the ,. mechanical electrical auxiliary building-(MEAB).
The'caise wasi', determined to be open penetrations in the building structure v
. during an exceptionally heavy rainstorm.. The licensee '4 c t ~ '
',,. -immediately plugged up all penet' rations'to prevept rechr,rence,y i - . ' _ fand' began to evaluate equipment damage.,Upon, completion of the
.
. evaluation'it was determined that no extensive damage ha'd:been i 'i - done to the electrical cabinets'bicause many bre&kers% ere not- ', " J " ,
~ yet installed. 'The licensee's approach to_.equipmeiit girotectionx i' is acceptable, but a continual effort must be put'fo'rthxto keep * ' , , , ' , equipment damage to a minimal ~ level. j' t if l } The CAT inspection' report identified 10 of 12 mechanical items ' ' - that were not in compliance with installation' requirements; also ' - some tanks and heat exchangers had undersize welds.
The' [s resident inspectors performed three inspections'in'this-area in the last part of the assessment period.
' ' - 2.
Conclusions
Management attention and involvement are evident and work ' +
. activities associated with safety-related components are being conducted in an acceptable manner.
The depth and scope of p effort devoted by the licensee to recovering from earlier
unacceptable PPM activities is indicative of the need for-7-j.
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_ ?licenseetis' considered.to be in Performance Category 2=in this
- y< , ifunctional' area.
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1# i3.
' Board RAcommendationst " <
^ ' _ a.' ' Recommended NRC Action-ay c .v' .The NRC_should continue its'present' level'of inspection in ~ '- 'this area.
This: inspection effort should include.those ,
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sy' stems-.and components which have completed the' test . program'as well as those still in the test program'and " ' . those stillEin construction.
~ - ... .. - ~ f ' b '. ' Recommended Licensee Action ~ , n - The 1icensee-Ehould continue efforts'in this functio ~nal - ' area as equipment an'd components'are. installed and become ~ W - ' ' operable.'.~ Normal _ surveillance should be maintained on the-- ~
construction PPM activities and,the corresponding n'uclear ' plant operationLdepartment-(NP00) preventive maintenance " . program.
, E.
Auxiliary Systems' ., , , 1.
-Analysis ' < ' Five'.NRC: inspections were performed in this functional aiea during this period, including a CAT inspection.
The inspections
primarily addressed-heating, ventilation, and air conditioning (HVAC) installation. work. There"were no violations i identified in this area and only minor _ documentation- - . l discrepancies-were noted in the traveler packages ? One item.of' concern was identified by the r'esident i(nspectors-during.this y -
.c q , g m.i period.
It concerned-the qualification and method of C ._- q , < application of Dow Corning 999-sealant around'HVAC2 embedded F angle to prevent air leakage.
This issue has'-been addressen-and.- ' I an acceptable product, qualified for design ba_ sis' accident'l ' ' ^ conditions,.is now used for the applicatione p ' -
, .,~ i - ,, 4"- .,sy _.; ,. TheabsenceofdeficienciesandthelimitedJanount'oflreworki.n? > ' , , this~ area'is indicative of a well planned program;-~ In addition " s .g i-to inspection of the HVAC installationn the resident inspectors ~ - have made routine observations relative to, fire' protection'and-... l ' prevention in all safety-related plant areas (ss they relate"to w\\ ' ~* i, b construction activities.
The licensee's control' of combustible p, ' materials and protection of equipment from combustion sources is [ considered adequate.
E !' 2.
Conclusions Licenseemanagementattentionandinvolvementareevidebt,and QC personnel appear to be well trained in this functional area.
, Corrective action for NRC identified concerns has been taken in p-8- - Y
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' Performance Category 1.in this'functionalsarea, b 5 7 ' MN" - , v, Q - .a . v,,, %w ;jc..., g- - 13. : ; Board Recommendatio.ns eU ]7~ .j ' - w = v , .-- s.. ,
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Recommended'NRC Action- .- s
. [' _ < _ The NRC' inspection'effortJin thisLarea'may be jeduded.-- . A ~ ^ i "^' - consistent with the= level of construction'acti,vities' ' ' < . . . .~ ,' _ (, .b.
~ Recomme$ded Licensee Action ' - , A - Licensee management involvement in this area should- - continue at a level commensurate with construction - ' ^ . activities'in Unit 2.
' i Electrical Equipment and Cables-FJ-
11.
Analysis . Four inspections in the electrical ~ equipment and cables program-
- 5 area were made by region-based; inspectors in-addition to one CAT-inspection..
- The areas inspected' included records', receipt,
, installation, and basic materials.
These-inspections were , performed at'allLpertinent, areas of storage and work locations.
Three violations were. identified which concerned over greasing:. _ of some motors in the storage and maintenanceLprogram (discussed = in'.Section D 'above), improper use of some. bolting material, and Jimproper welding of an electrical cabinet tolan'. embedded plate.
Other areas.of concern were noted by the CAT inspectors'such as~ l deficiencies with~ circuit breaker extenders, barriers,. motor - terminal lugs and insulation. These deficiencies were resolved 'by the licensee in a timely manner.
2.
Conclusion-
, This functional area'has been effectively and satisfactorily 't managed by the licensee.
The licensee is' considered to be'in _ . Performance Category 2 in this area.
- 3.
. Board Recommendations a.
Recommended NRC Action !
, , The NRC should continue its present level of inspection effort in this area consistent with the shifting of work ' p
activities from Unit 1 to Unit 2.
b.
Recommended Licensee Action p ' The licensee-should continue efforts in this' functional i area commensurate with the level cf activity.
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, - During th'is periodihree inspections were' performed. ~ There were-two violations identified by the. resident inspe'ctors onthe ' incore. instrumentation system and one by1the CAT.
The CAT report identified one violation which involved several dimensional and workmanship deficiencies in the. instrumentation area.
Examples included dimensions' exceeding tolerance.1imits,. an. incorrect weld. configuration on a support, a missing support-clamp,'and a support installed in accordance with'an incorrect . drawing detail.
In addition, attachments.were being made to existing supports.without the required engineering review and approvals.
_ The number of construction deficiencies found in the early limited sample of instrumentation indicates that the licensee's inspection and. surveillance programs were not. completely . effective.
The licensee has performed.a 100 percent-reinspection of safety-related instruments and instrumentation-tubing supports to reverify inspection status. The licensee's.
understanding of the~ issues was apparent-and corrective action ~ . was timely.
2.
Conclusion- ~ ' Weaknesses were-identified in this functional area; however,- the . licensee developed a clear understanding of the issues-involved and proceeded with timely responses and acceptable resolutions.
The licensee's actions during the-latter two-thirds of the assessment period have been effective in resolving these concerns and therefore'the licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC. Action NRC inspection effort should be maintained at normal-levels.
L b.
Recommended Licensee Action Management should devote additional attention to prevent recurrence of construction deficiencies in this functional area.
H.
Licensing Activities 1.
Analysis The licensing activity on the STP during this SALP period was characterized by a high level of activity targeted toward issuance of-10- , ' f , en
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' _ ' m . . ; report,(SER)cthe finei environmentalistatementi(FES), theifirst; j'aj , 7.A .. ' - - w supplemental SER (SSER).and the initial Tdrafthof;th technical- &W D - ' ' ,g/ + specifications (TS); JThelCES wa's' issuedLin Ma ch 1986; the SER, s '
' , ' Din April:1986, the FES in August 1986,~ the SSER in 3eh*. ember:1936, , O the 'first draft.of the' TS in November 1986;and the TS second sb '
a ~ .' ' 7 rafttin December-1986.
LicensingLactivity'was, involved to af f m d - ' , lesser extent in the hearings on-the management character and M-' a. ' '
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A v' __ .. ,' _;.. .. .J ^ 3 > 4'. ' ' * s ' Thebasis_forthisappraisal-hasincludedtrequehts'[foradditio ,
i- , . j information,' site visits and meetings at.the NRC ind applicant
' ~ ' g.c - - offices.
Inputs from the following specific l review area's;were > Xs , ? . _ ' p* ' considered inkthe assessment: n j -p - , & ,. , . > . , _ " ' Geologicdland'seismologiEal; review.
[ = + e X ;' o ' Accident evaluation reviewi L
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- Site analy' sis re11ew
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.MechaniF-1 engineering review-3 ' <
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, '1-tReactor.;3tems review
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- Materials engineering; review,
wAe " < . Mechanical power systems review '. 2 Containment; systems review- _ . Compliance with mechanical codes and sta Mards ,' & , V ~ --Instrumentation and ccatrol review i+ . v - ~ ,' , ' Electrical' systems review $ 4* , . ' Fire protection review ' '
- Revior oficJpduct of operations - y . __ - - Planning activities and assiCnment'of prioritiet were performed ' ' 7'~ in_.a generally satisfactory ruiner.
Decision making procedures s . apparently ens <ed adequate management review within the ' . applicant % fuaational groups.
However, on occasion, some-i.
' - '" weakness were detectable in thecoordinatkn Mtween such t group 5.
Cprporfte support to' management at tne site was- ' ' '
- evident. "ihe'h blicant'_s responsiveness to'the CAT inspection findings is anlexample of-the applicant's cmitment to
, achieving a hig( level of qualityc
" , 4~ ' .. ' The applicant displayed a reasonable understanding.of regulatory 'issyes in the licensing area. The technical approaches used ,- were Vercrally conservative. The applicant tends to take the
' initiativt in confronting technical issues which may affect the
project ~ ' '. : o y M The NRC staff's initiatives gere. ally resulted in satisfactory l
~'submittals or' other resp' oases. ' Schedule commf ments were t ' generally met.. Repetitions of submittals were sometimes , required to'cotain acceptable resolutiona.
'
Key pr iti6bs are well> defined and the qualifiestions of the
. persocnel in positions of major importance appear _to be quite ' ' satisfactory.
The applicant appears to take advantage of > experienced personnel from throughout the industry.
It 'is t
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- p
,is considered. average for the current status of the project.
. .' With the exception of the Vice I' resident (VP), NuclearL4. Operations. position,ithere appears to be no major unfilled ' 5,. -openings.' Generally' satisfactory submittals were received by - k the staff;, The applicant'is apparently working-diligently to: fill Lthe VP Nuclear Operations pusition.. g t Q N The' staff has' observed that the applicant's training program-is u of above average qutlity. The resources needed to maintain a-sound: level of training appear.to~have been allocated. The.
'" ,W training program. appears to be making.a positive contribution to the' applicant's' performance.
,
The promptness and completeness of the applicant's reporting of " reportable events was quite satisfactory. The corrective ' actions are generally effective as evidenced by the relative' low
level.of repetition of problems. - A weakness was detectable in '}C the analysis of the events because events which are closed out ' _are sometimes reopened. On some occasions, such as in the area of MIC, insufficient analysis was presented in support of the conclusion, g j The staff has completed four audits of the verification and ~ validation of the Qualified Display Processing. System (QDPS) - a << unique microprocessor based system. The applicant and the 4r~~ F vendor, Westinghouse, appear to be performing the process with diligence and considerable attention to detail. The only
g. ;/ . potential area of weakness observable.at this point has to do with providing adequate documentation for the staff to , j rigorously report on the review.
f The NRC licensing Project Manager has visited the-plant site ' wf about seven times during this reporting period and has observed , ' p, all major areas. His observation.was that the licensee placed i ,' l i strong emphasis on plant cleanliness.
e ! l See Section V.G. for supporting data.
<- L* 2.
Conclusion ' p bJ .. ' Management involvement and control in licensing activities is N '
reasonably effective in assuring quality. The licensee has ' demonstrated an acceptable level of performance in dealing with-
L technical issues. Although the licensee is responsive ~to NRC initiatives, repetition of submittals is sometimes required to ' obtain acceptable resolutions. The applicant's training program - _ appears to be enhancing performance..Although the licensee's event reporting system is generally effective, there is evidence . of insufficient analysis in some instances. There is evidence that the applicant is firmly comitted to achieving a high level ' of quality in performing licensing activities and achieving this quality has been receiving the needed attention. The licensee is considered to be in Performance Category 2 in this area.
-12- 's
I l -,.-. ..,,. -..
. _ _ _ - - _ _ _ _ _ _ _ _ _ _ -
-, , ' L - . '. gf , ^
' c . + 3. '~ Board Recommendations a.
. Recommended NRC Action F r " NRC efforts'should continue at the present level or [O' s.
possibly. increase to' support the applicant's June 1987 fuel ': . load date with continuedJemphasis.on assuring applicant responsiveness.to NRC' initiatives'and adequate' analysis'of, ,, ' reportable events.
_s b.
Recommended Licensee Action s r " Extensive effort will be required by the applicant to -
achieve the current project completion schedule. Continued 3' -emphasis.should be placed on achieving a high level of quality relative to satisfying licensing commitments, n p y L particularly in providing. satisfactory responses to NRC i .ig initiatives and assuring adequate analysis and reporting ~of: w events.
- . I.
Sedurity' + l . t
1.
Analy' sis-L Three inspections were conducted by region-based NRC physical > s security inspectors during the assessment period. One of:the "s inspections was the initial preoperational inspection during - , wnich 27 open items were identified which must be resolved prior ' " sn-T .to fuel load. These open items reflected the' incomplete' status 4t[" 'of the security program that is being developed.
Security i' program development has been organizational 1y divided into two . divisions.
It appears that licensee's corporate management has ~ ,~ taken an' active role in providing substantial ~ resources for the , ' - ' development of the security program.
, . m;
r
. .
- , M Effectiveness of licensee actions is observed in a
- division s
which is operating the access authorization";ifitness'for duty,, ' N ' 'i - . and compliance programs. These are in place ~and4 functioning very well.
The HL&P fitness for duty program whs.jp!plemented.on 'a,, January 1, 1986. -Job applicants are tested ~for drug and alcohol'g - s' x
y '
abuse prior to completion of the pre'-empl' ymentfprocess; and' alls & licensee and contractor personnel are subject to random.
,I '". ', o ' urinalysic testing.
A professional counselor is available'on? % ' - % s i te.~ . . ,. , , ' Another division is responsible for the implement'atiori;of t'he, s physical security systems and operations commitments.
- Completion schedules have been established and ccmpliance-demonstrations projected.
Schedules are dependent on external efforts such as construction.
Concerns about this division's activities have been identified and addressed.
The conc;rns . 1 j h , included the format of the several security plans, the'. _ , supporting procedures which had not yet been drafted for the interim fuel license or the operational security plans, the-13-a.
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f y, - 1.-7afJ v. gay l,4- ., _,l ~ k [;' - & - , ;c ~ f:w'flpll*,3lM y We5.[ v] fj? , - p - _ I ' developmental: organization strb6tu e ;wbthwa i t[fo Ne i %. W '- stageilanditheLphysical" security l systems configurations'anda h C W< Lproposedmethodof.performancetestifg.- f j A s,:, g '* k <j . , , m . ege 9 g.
p , e ry; ' 12.
IConclSion , w , 'W W/
- ' W '
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' y . , I413- , ..m - 3ye ., - T Th61'icensee has;"antample number 7of personnel Esibned toithei - +J '
@$ g.; ' ~~
- securityTorganization'to;. implement >the security plans, but'the
, e'r V management structure;is.still-evolving-and:has not demonstrated' - s - , , effective management ~controliof;the1 security pr.ogram.+ ' , W - 'Installationiof thefsecurity systems appear _sLto.be'on-schedule l ' ' _ '( + < - - - m and the: licensee:has' committed the resources-to complete thist , % , ' c. task but prior' experience at other~ sites ' reflects that testing; ' - -- and acceptance problems'may_be anticipated.
The~1ack of _ , iimplementing procedures (and the? associated training)-was " * , , Lbrought.to theilicensee's-' attention'by the'NRC and-HL&P is. , .,taking~ steps to correct'this matter.. The; licensee-is considered W tolbe-in Performance = Category.21in this-area.
.~ c [~- "3. - Board' Recommendations- \\ , 1af, Recommended NRC Action . ' ,. "I y ' Maintain _ inspection effort as required to comple.te.
' preoperational'insp'ection program and close out open items ' prior to fuel 1oad.
, ~b.
-Recommended Licensee Action I - w-The licensee should complete-the procedures development ,' x - ' effort to be able to fully implement the requirements of.
~ .-the security plan and to maintain'the construction y completion and testing /acceptanc'e schedule of all security _ _ systems. The licensee should plan for_the earliest' " possible lock-down of all areas, required.for Unit 1
operations, to preclude problems similar to~those + ' ^ experienced at other sites which elected to lock-down ', 30, days prior.to fuel load. Timely resolution of all open s . items must be accomplished prior to fuel load.
- < s - J.
. Radiological Controls ~ ~ 1.
Analysis - Four preoperational inspections in the general functional area
of. Radiological.. Controls were performed during this assessment - . , period.by region-based-radiation specialist inspectors.
These inspections primarily focused on Unit 1 and included the following~ specific areas: occupational radiation safety, radioactive waste management, radiological effluent control and ^ ' monitoring, transportation of radioactive materials, and water . s chemistry controls.
No violations or deviations were identified.
. -14-
, . ,
.-
- _ _ _ _ __._._a____.__._.____.______._.,__-._.__.__.m _
.-- , , ' , - '
. " ,. ' > y& ~ , a.
Occupational Radiation Safety.
' -- This' area'was inspected once d'uring the assessment period.. . ' The' inspection-identified 16 open items rela ^ed to - ' incomplete work activities that needed to be resolved prior: to fuel' load. A major concern identified was the low ' level of commercial reactor power plant operating experience.
among the health physics ~ staff. The licensee: responded to this specific concern with a commiitment to hase an adequate number of experienced health. physics personnel onsite prior
- to fuel-loading. Even though work remains.to be completed in the-radiation: protection area, the licensee's proposed program appears adequate in the areas of-organization, a
training,' facilities, equipment and instrumentation,
Jsurveys and controls, ALARA program, and procedures.
' ' b.3 Radioactive Waste Management .This area was inspected once during' the assessment period.
-The inspection identified 12 open items related to , - incomplete work activities that need to be resolved. prior.
.to fuel load. These open items included such matters as-- . performance of ALARA reviews of the as-built gaseous,- ~ liquid, and solid radwaste systems, development of a ~ sampling / analysis program as reconsiended in-IE Bulletin 80-10, development of a corporate radioactive' waste management policy statement, training of radwaste i operators, and completion of preoperational tests Lon gaseous, -
- liquid, and solid radwaste systems.
c.
Radiological Effluent Control'and Monitoring - t The liquid.and gaseous effluent' control and monitoring - program was inspected once during the assessment period.
' TWo open items related to incomplete work activities that p must be resolved prior to fuel load involving testing of j' the' air cleaning systems, calibration of effluent monitors, . and determination of representative sampling were i identified.
The radiochemistry area was inspected once during the assessment period.- Eleven open items related to incomplete work activities that must be resolved prior to fuel load: ' were identified concerning organization, personnel-qualifications, training, systems sampling, QA/QC program, gF' . post-accident sampling, facilities, equipment and ! instrumentation, and implementing procedures. The licensee < p had not completed construction of radiochemistry laboratory p facilities, installation of equipment and instrumentation, - QA/QC procedures, and implementing procedures.
!. The radiological environmental monitoring program was ! inspected once during the assessment period. One open item involving quality assurance (QA) audits was-identified.
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.,. .,,, n 1The licensee has conducted'a routine monitoring program , - around the/ facility since' issuance of the construction.
~ - perait. The licenseelhas been responsive to' NRC concerns" -identified in-environmental inspections conducted during-the past several years' - No significant problems.have'been x . ' identified in this' area.
The 11censee's proposed-- - =' . '
- ;"jj
" radiological environmental monitoring-program forj ' . - Loperations appears to satisfy NUREG-0472.', J - -. , f > , _ , ' ~ ' s y- -/~> - d.
Transportation of Radio'activelMaterials E < - = ~- 2 .
g , - .. . ,. .- . ,, a - This' area ~was inspected once during'the-assessment period; ~ ' - Three open items related to incomplete. work activities that'. $ d' . ~. 'must be resolved prior.to, fuel load we're-identified.
' "
- involving establishing a training,pr~o* gram'to" satisfy IEL. ' c,
' o Bulletin 79-19, and the developmentsof;an audit; program for.
,' ' the transfer, ' packaging,1and transportyof low-leve.1 % . ' ' radioactive waste.
'
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Water Chemistry Controls , f s.; ,? v.
e - .. This.' area'was'-' inspected along with the radiochemistry
- program. The same comments concerning the radiochemistry =
~ program also apply to the water chemistry controls program.
- -
n , ' , -2.
. Conclusions F' - , s v , , . The licensee is making good progress toward implementation ofJ ' ' proper programs-in' the radiation protection, radiochemistry, r , water chemistry,-- and radiological environmental l monitoring
areas.
Considering.the' current status. of the. facility,.the ' licensee's' proposed schedule-for implementation appears adequate.
' .to support plant ^ operation.
< _ It appears that-workCin the liqui _d,-gaseous,.and solid radwaste ' . ; areas'is behind jther; areas inspected. -The licensee is~ . considered in Performance' Category 2 in.this area.
13.
Board Recommendations , a.' Recommended NRC Action ' Inspection activities should continue at normal levels.
The next radiochemistry inspection should include an onsite visit with the NRC mobile laboratory to perform . confirmatory measurements.
b.
Recommended Licensee Action Management attention is needed to assure that identified - ' open items are resolved prior to fuel load.
, _ '* -16- . - ag .i i: . _ _ _. _ _ _. _ _ _ _. _ _ _ _ _ _ _ _. _ _
=
_ m - , ' ,; . ' ,, N ,
- d K.
Emergency Preparedness _ 1.
' Analysis During the assessment period, four emergency preparedness inspections were conducted by region-based and NRC contractor . inspectors. The first three of these inspections.were routine, announced inspections to determine HL&P's progress in developing ' an emergency preparedness program and to establish _a schedule . for conducting an emergency preparedness implementation appraisal.. During the final month of the period, an announced .. emergency preparedness appraisal was conducted at the licensee's-request by a team of NRC and contractor inspectors. The appraisal consisted of an indepth evaluation of HL&P's capabilities and readiness to maintain an emergency planning and preparedness program in accordance with 'the planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50.47,- 50.54 and Appendix E to Part 50.1The major areas evaluated during the appraisal'were administration; organization; training; emergency facilities and equipment; procedures; coordination with offsite groups; and drills, exercises, and walk-throughs.
At the conclusion of the appraisal, the NRC staff reported to the licensee' that a total of 75 deficiencies requiring corrective action had been identified in six of the major areas evaluated. 'In addition, 64 improvement items which should be considered for incorporation into the emergency preparedness program were identified by the NRC' inspection team.
In most cases, the deficiencies identified were ldue to facilities, equipment, and procedures being incomplete at the time of the appraisal. Licensee management acknowledged the appraisal findings and condtted to providing the resources and schedules for timely correction of the deficiencies.
Organizational changes were made during the last part of the period which appeared to demonstrate an increased management comitment to emergency preparedness, and which could significantly improve the licensee's perfonnance in this area.
A new Emergency Preparedness Department (EPD), incorporating all , emergency preparedness staff functions, was created with the EPD Manager reporting directly to the position of Vice President, Nuclear Plant Operations. This new position
appears to have the necessary authority and management involvement.in emergency preparedness activities but was not ' established early enough in the period to achieve program improvements prior to the appraisal. However, the EPD Manager was very responsive to NRC inspector findings durine the appraisal and appeared to be effective in initiating. actions and developing schedules necessary to address the findings.
2.
Conclusion The results of the appraisal indicated that the HL&P comitment to developing and implementing an effective emergency-17- -
, _ __ - - ' - _ - .; x ' d - . , . ,
y preparedness: program'had not been adequate during<most of the kperiod. The number and types of deficiencies identified during J .the appraisal showed that licensee management had' failed to provide oversight and allocation ofiresources to develop and complete the program. Because of this, the apprais'al team could . not determine ~that the HL&P emergency preparedness. program fully met the standards required by NRC regulations'. 'The licensee is considered to be in Performance Category 3 in this area.
' o .-3.
, Board Recommendations . ' -a.
Reconmended NRC Action'. LThe.NRC should, prior to fuel loading, conbuct an emergency preparedness appraisal followup inspection and exercise observation to verify the effectiveness of corrective . actions =and to assure an adequate emergency preparedness ' status.
b.
Recommended Licensee Action Licensee management should give increased attention to the correction of emergency preparedness deficiencies identified during the appraisal in a' time frame consistent with the projected schedules for the graded emergency exercise and licensing decisions. Management should.
maintain'a highl level of attention to program development and implementation throughout the' preoperational period and assure that a fully acceptable level of emergency preparedness is demonstrated during the emergency exercise and appraisal followup inspection to be conducted before fuel loading.
L.
Training and' Qualification Effectiveness 1.
. Analysis Routine inspections of training activities were conducted by the resident inspectors during this SALP period. Additionally, NRC cold licensing written examinations were administered. There were no violations, deviations, or open items within this functional area. The training inspections included reactor operator cold' licensing (lectures and simulator) and training for NP00 craft, construction craft, construction and operations QA/QC personnel, and startup engineers.
Of the 47 candidates who have taken the NRC cold licensing written examination, one Reactor Operator (RO) and 41 Senior Reactor Operators (SR0s) have passed. Subsequent to this SALP period one R0 and 39 SR0s out of the 42 candidates have passed the NRC cold licensing oral examination.
The licensee preparation and execution of training plans and programs has been of high quality and fully acceptable.
-18- . ,
5rc e , . The' licensee has completed and occupied a new' training facility.- with a-full control room simulator for nuclear operator - training. This effort is complete with-the exception of minor-modifications and was available for cold license oral examinations for operation shortly after this SALP period. - The first-. ten creditation programs that the licensee has committed to have completed by 18 months after. fuel load are greater than 50 percent complete.- 2.
Conclusion-The licensee has a well established plan for meeting its training requirements and is executing that plan in an effective manner. Upper management's involvement and support of. staffing and training goals from an early point in this project is evident by the good facilities and the results of the operator licensing examinations. They have met their training schedules to support the plant in a technically sound and competent-manner. The licensee is considered to be in Performance Category 1 in this functional area.
3.
Board Recommendations a.
Reconinended NRC Action Based on the perfonnance of the licensee the NRC could reduce the routine inspection effort in this functional area.
b.
Recommended Licensee Action The licensee should continue their effort to provide ~as high a level of training and preparedness'as possible for plant operation. The phase II and III modification efforts for the simulator should be completed as planned making the simulator identical to the plant. Preparation for i licensing examinations should continue to ensure that an adequate number of well trained operators are available , when needed for Units 1 and 2 startup and operations.
l . M.
Quality Programs and Administrative Controls Affecting Quality 1.
Analysis l The licensee organization for administrative control of STP l reports to a Group Vice President-Nuclear who spends the majority of his time on site.
Key organizational components of the overall project include: operations, construction, and nuclear assurance including QA.
Each of these major key components has a dedicated manager on site that is involved in day-to-day activities.
-19-
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' - s b i L:The QA~ Departmentis divided in$o thfe[ ma h r comp'oiE5t's[ o b t ' h
1 ' frelsted.to' operation'of the planttincluding.the preoper,ational_- C< ~ f ' y*. _ , j and startup activities,.one for construction; and'a third for -;, , -
, % ~ 2 taking,: investigating and ' responding 3 oL employee + concerns. (The ' j.
t > ~
overall-effort'is directed by.the General? Manage'r,-Nu'clearf M'; ' < i ?' iAssurance. The construction.QA group ~ reviews, analyzes"andf ( ^ _ ' ~ ' " m - -
- trends the various' contractor generated;nonconformance reportingE
- _ ; :
> documents'andlissuescorrectiveiactionrequests,4articularly- , , - when significant' conditions' adverse'toTquality are. identified.
' , _ 'During'the" assessment period,:the NRC staff. conducted lin excess ~ ~ , .of 40.inspectio_ns and-expended approximately;10;000l manhours ' . .. . covering'all1 phases of slicensee and contractorractivities?
- N pertaining.to STP. _-Findings identified during these inspections.
. 'have-been discussed in other sections;of.~this SALPzreport.,The.
[' ' inspections performed during the' f.irst 6 months of the' - - assessment = period indicated >a lack;of, construction caft , accountability forltheir work; a lack of attention to detail'on the p' art of,QC' inspectors and by. design; engineer / design reviewers; and a few~ instances where inadequate instructions- . were provided to both.the craft.and the_ inspectors on'how to perform their ' activities. _In response to these broad, generic- - - findings,_the 1icensee.i.ncreased;his presence on_: site by having .. the project manager andithe nuclean assurance manager assume-full time duties at the project and by directing that these and-their subordinate. managers spend a considerable amount'of time in the field observing work.' activities and'in turn being visible; .to the~ site l employees.
In response-to the other concerns, the ' "3: ' licensee'and his contractors. conducted an organized review of-instructions provided to the field personnel to assure thatl.
- . clear, understandable' directions had been'provided'and then .provided expanded training to personnel, utilizing the instructions.
The licensee also required the construction ' contractor.to require that his personnel supervising:
~ installation work: assume signatory r'sponsibility for the e ) quality and quantity of' work of the. personnel _-assigned to them '. _ and devised a monitoring program to aid in the identification
and evaluation'of problem areas.
As a result of-the day-to-day contacts.with licensee personnel in_ management and the various QA/QC~ groups, in the past year,
' the-NRC staff has'found that these personnel have become more !; knowledgeable and aware of plant activities and conditions t ' within their sphere of responsibility, indicating that they are p* , well involved in day-to-day activities.
< r HL&P has demonstrated a high level of management commitment to quality in that they have established a SAFETEAM to encourage I' plant workers to bring their concerns to the utility for disposition.
The SAFETEAM concept allows workers to identify problems without revealing their identity to the utility or . their co-workers.
The NRC staff has inspected this activity and [ has concluded that it appears to be functioning as intended.
p !' -20-r L <
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' g . . $l \\, , J - > , - , - ' -
. . m , {, - --' /. Conclusion ~ ' '
" j;, ' Astnoted in the: preceding SALP assessmentLperiod and'duringithe - '
. ' current period,,the licensee management has taken actions to lassume increasingly stronger control of his project. Management ' 4 presenceland involvement.in the project.as construction of ~ - . Unit 1: nears completion has been specific-and directed.
' Enforcement actions early in the:SALP period _ indicated certain " , , -weaknesses in' management controls and corrective actions;; ~ Lhowever, HL&P's strong response to these findings has resulted-in an overalliimprovement in this area The overall. performance . _ -of the QA'and administrative organizations of the licensee has-continued' to improve. The licensee is considered to be in Performance Category 2 with an improving trend in this area.
y ' 3. - L Board Reconnendations a.
eRecossended'NRC Action ' - ~ The NRC inspection effort should continue at the present level with emphasis shifting toward preoperational and-startup activities.
b.
Recommended Licensee Action The licensee should continue to devote his full management attention to all ongoing' activities in Unit 1 and Unit 2.
' . - N.. Preoperational Testing 1.
Analysis ' Routine inspections of th's functional ~ area were conducted by i the resident-inspectors during this SALp period. No violations ! or deviations were identified. A substantial amount of [ prerequisite (component) testing:andacceptancetestingwere
conducted this assessment period.
!- L During the SALP period 44 of 140 preoperational tests were successfully performed and'40 of 101 acceptance test were performed.
In the area of prerequisite testing, over 70 percent of the testing effort has been completed, results reviewed under the licensee's program and documentation'is complete and on file; 'In the preoperational test preparation area,125 of l.
140 test procedures have been written and approved by the Joint , - - Test Group.
- The preoperational test program scheduling and coordination has been adversely affected by delays in turnover of complete p systems to startup. As a result the licensee has had to conduct partial tests which generally have been adequately controlled and appear to be acceptable.
-21-I- s ,
, ., , The NRC inspections of preoperational testing activities indicate that the preoperational procedures and test performance were acceptable with minor coments. The licensee was responsive to inspectors observations and comments and issues were resolved in a timely manner.
Weak areas in the test program include problem identification and documentation in the chronological test log and occasional poor coordination of testing activities between the construction, startup and operating organizations.
Examples include pressurizer relief tank rupture disc failure, overfilling of diesel fuel oil tank, test failures of reactor makeup water system, and failure of a centrifugal charging pump.
2.
Conclusions The preoperational testing program is being effectively managed and implemented. Although testing delays occurred early in the program due to slow turnover of systems to the startup organization, HL&P has successfully established a more rigorous testing schedule that has resulted in major milestones being met. Continual attention to good test discipline and good test practice will be necessary. The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recomendations , a.
Recommended NRC Action Expanded NRC effort may be required as the number and complexity of the preoperational tests increase.
Unit 2 preoperational testing is scheduled to begin during the next assessment period, b.
Recomended Licensee Action The licensee should increase efforts to support the testing - program.
Increased effort is required to issue approved test procedures in ample time to allow appropriate review as committed to in the STP FSAR. Continued effort should be applied to the proper conduct of tests, especially the [ test prerequisite and the chronological test log areas.
i V.
SUPPORTING DATA AND SUMMARIES A.
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 96.6 percent and Unit 2 as 69.6 percent. NRC Materials License No. SNM-1972 was issued to the i i licensee on December 29, 1986, and fuel receipt for Unit 1 began in January 1987.
i ! -22- , ' ,__ __ _ .. . .. _ - - . - . . .
_ _ - . . . _ _._._.
... --_.. _ _ =t , ,. . , ' S . . b '
a, hreoperationaltestingtob'e'approximately i c - The licensee' reported 430-percent complete for. Unit l'at the end of this report period and ' hot functional testing was initiated in ' January 1987.
, B.
Inspection Activities ' 1.. Violations , 1 - -of the identified violations in each functional area for this 7 See Tables 1 and 2 for a' summary and tabulation, respectively.
assessment period.~
, - . ( . ' 2.
Major Inspections ,;- - ~ A major CAT inspection was performed during the period of October 21 through November 1 and November 12 to 22,1985. The ' inspection identified a number of deficiencies, which included , hardware and design control, indicating a weakness in the construction program.
. " I C.
Investigations and Allegations Review
- At the close-of this assessment period, four cases are pending.
investigation. These deal with harassment, intimidation an , falsification of records. At the close of this assessment period, ' six technical cases are pending inspection.
!. HL&P has demonstrated a high level of management comitment to ' quality in that they have established a SAFETEAM to encourage plant workers to bring their concerns to the utility for disposition. The SAFETEAM concept allows workers to identify problems without . revealing their identity to the utility or their co-workers. The NRC staff has inspected this activity and has concluded that it is !- functioning as intended.
+ l The following allegations.were reviewed and closed by the NRC staff
.during this assessment' period: " , I mismanagement of SAFETEAM " . inappropriate weld rods
, I improper welding practices
failure to follow QC program
improper disposition of an FCR i
inadequate training and supervisory review
' pipe design specifications - possible. security problems
inappropriate SAFETEAM actions '
, * alleged coverup of drug investigation results
intimidation of operations quality control inspectors
preventive maintenance improper
, i polar crane damage ~ * ~ use of out of calibration torque measurement equipment
, coatings applications improper concrete pour packages incomplete
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_ -
- -
i'- -Section:210 information unavailable l f ~ f UN p ' W'7 ' ' ~* -w ' ' -QC inspectorTqualificati,ons falsified ~ s?#N y ' - . ~ pu - - .s;wc i
- D LEscalated Enforcement'A'ctionE
$ ' 7 3, g ;,.;O %/ ~ x ... -.. .. . Mm' ' - -9' . A number.of: potential enforcement actions'were identified-duringTthe?
~ , March 27,.1986, in the' Region IV-office. 'On August 20, 1986,<the NRC.
, CAT: inspection'which were discussed in an' enforcement conference; held' - issued report EA 86-10, which contained a' Severity Level 2III! Notice ~ , ' w ~ of Violation related to deficiencies in' construction activities: identified by the NRC CAT. team and Region;IV inspectors.
Refer toi > , table I for a cross reference of al1~ violations.'and devi.ations'by functional area for-the'SALP; period.- ' L E.
O censee Conferences Held During' Assessment Period , . .The one conference' dealing with regulatory performance and -- enforcement is discussed in Section D above.
~A number of other meetings involving a mutual ~ exchange on various regulatory issues andl . plant status _ discussions:were.also held with the licensee.
, - F.
' Review'ot Construction Deficiency Reports and 10 CFR Part 21 Reports Submitted by the Licensee-The licensee issued 19 deficiency reports per 10 CFR 50.55(e) and/or 10 CFR 21 requirements during this assessment period. To facilitate ~ identification, the licensee's assigned Incident Review-Committee.(IRC) number-is given in the following list: ' Call in Date IRC # Subject 9/85 283 Separation Requirements (Free Air Routing ' of Cable) , '9/85 284 QA Deficiency re: Master Valve List and Valve Installation 10/85 287 Electrical Breakers Connections Not Tight 10/85 288 Ruskin-Fire Dampers Installed Backwards - 11/85 294 Construction Damage to Elec. Penetration Assembly Conductors ' 11/85 300 480V Class IE Circuit Breakers (Inadequate Bus Extensions) 11/85 301 Wiring Problems in Motor Operated Valves 2/86 307 Microbiological 1y Induced Corrosion (MIC) in SI Pump Suction-24- . $. _
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-321? 'c _>w . , ' - ^ . -5/86' . , . f * '., % J.% Q.~.;~ K , .- G.
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-325' ESFILoad Seq'encer.Refet; V J, lh - ' ~ u ~ . - . ' _ ' ~ ' i8/86 _ 1336 Limitorque'MOV' Actuator Declutch Failures y } ' ' - . R(Tripper Fingers) ..
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' . , LEssential Chille'r Trip Switches s-110/86- ,340- ~ 10/86 - 2341- " Unit-2 Flooding Event of 10/23/86- , .11/86.
347 ASME-Flexible' Hose InstallationLDamage '! i c . . Overgreasing"of Electrical Penetrations , '11/86 348' . '
Assemblies ,' , - 12/86T '350-Toxic: Gas = Detectors Loss-of-Power Failure In addition to the above events reported, the licensee is evaluating'..- ' . the.following events for reportability: Call-in-Date-IRC #1 . Subject . , , 8/86-333 Veritrak/Tobar Transmitters Change in Accuracy .9/86 1338 Small Break LOCA Modes 3 and 4 _ Response Uncertainties ' 12/86 349 Water Damage in Unit 1 T " G.
Licensing Activities
NRR/ Licensee Meetings and Site Visits -
July 2-7, 1985 Electrical power systems August 15, 1985 Audit of QDPS ! August 26-29, 1985 Audit of QDPS ' ,
September 9, 1985 Mechanical power systems September 17, 1985 Fire protection October 23, 1985 Effects of faulting-25-i.
I , _. _.. .._ _ . _. _ _. _.._.-. _. _.. _. _. - _,... _. ___.a <. _ ~
~ . .-. . . . ..- .', ' , , , , e + , ,- a , . t Octob'er 24, 1985-Low term cooling /RHR qualification October 25, 1985 Fire. protection October 25, 1985 Emergency plan . November 7, 1985 Site visit to observe Aux & Reactor December.10-12, 1985 Site visit on fire ~ protection January 6,1986 Site visit on geological ' characteristics March 7, 1986 Fire protection March 18, 1986 Audit of QDPS May 27-29, 1986 Site visit on emergency planning June 10-11, 1986 Pump Valve Inservice Testing July 15-16, 1986 Audit of QDPS August 8, 1986 Meeting of TREAT Code August 26, 1986 Site visit on UT of CSS components September 3,1986 Meeting on emergency plan September 16, 1986 Meeting on SQRT/PV0RT audits October 1, 1986 Meeting on pipe break criteria October 30, 1986 Meeting on boron dilution analysis November 6,1986 Meeting on live loads November 17-21, 1986 Site visit on Technical Specifications November 18-19, 1986 Audit of QDPS 2.
Comission Briefings None.
3.
Exemptions and Reliefs a.
Arbitrary Intermediate Breaks b.
Tornado Missile Protection c.. Exemption from GDC-4 under review-26-
n, _ m: - , - . - e - , . . .. ..: n s d;. i.. -6 ' '~ , . License' Amendments _ f4.
n None.
' ~ - 5.
FSAR Amendmen_t_s_ 'b Amendments'49 through 56 6.
ER Amendments , . Amendments 8 and 9 - 7.
-Orders-Issued - None.
8.
' Issues Pending (See next page) . + , 'id t
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- - _ _ _ _- . >. , ';G s - =, NRR Issues Pending Item Status SER Section .
- L Internal flooding analysis Under review 3.4.1, 9.2.7, 9.3.3 Equipment qualification
m. ' Seismic and dynamic qual.
Under review 3.10.1 Pump and valve operability.
Under review 3.10.2 Environmental equipment qual.
Under review 3.11.3 Preservice inspection / inservice Under review, status - 5.2.4, 6.6.1: - inspection program review in SSER 2 Design, verification, and vali-Under review, status 7.1.2
dation of qualified display in SSER 2 processing system Acceptability of isolation between Awaiting information 723.2.5
safety and non-safety systems
- - Tests of aluminum-sheathed and Awaiting information 8.3.3.3 copper-sheathed cable Emergency planning Under review 13.3
Industrial security Under review 13.6
Analysis for boron dilution Awaiting information 15.4.6
event during Modes 4 and 5 Use of TREAT code for small-Under review, status 15.6.5, 6.3.5
break loss-of-coolant-accident in SSER 2 analysis Review of submittals on Generic Converted to 15.8.2 ~ ' Letter 83-28 Confirmatory Item 44 Wear of the bottom mounted Converted to 3.9.2.3
instrumentation thimbles Confirmatory Item 45 Pipe break criteria Awaiting information, 3.6.2
under review, status in SSER 2 f .Onsite meteorological measurements Awaiting information 2.3.3
program
' ' (a) Comparison of new with old system (b) Measurements of precipitation , to resolve anomalous and. in- ' consistent records-28-
, . i , .. . J' s o 9
e
i.
Item Status - SER Section '
Review of stability and safety-Awaiting information,- '2.5.7 data relative to main cooling status in SSER 2 s reservoir dike after filling to ' 49 feet'ms1
Completion of review of report Awaiting information 3.9.3.2 on pressure relief devices Design information on ASME Code Awaiting information 3.9.3.3 Class 1, 2, and 3 component support (Question 210.60)
Steam generator inspection Under review 5.4.2.2.2 Applicability of Diablo Canyon Under review 5.4.7 natural circulation test Analysis for nonisolable small-Combined with 5.3.5.2 break loss-of-coolant accident Open Item on TREAT Code
Reanalysis of loss-of-coolant Combined with Con-6.3.5.3 accident during shutdown firmatory Item below Analyses for 6-inch and 8-inch Awaiting information 6.3.6 breaks with justification for 15.6.5 operator actions Interface between Class IE and Awaiting information 7.3.2.12 circuits
Adequacy of design changes so that Under review 7.3.2.2 main steam isolation valves do not operate on safety injection signal
Procedures for preventive Awaiting information 3.5.2.5 maintenance and operability checks on emergency communica-tion equipment
Inservice Inspection and testing Under review 9.5.3 of emergency de lighting Revision of radwaste process Awaiting information 11.4.2 control program to meet staff guidelines .
Update process and instrumenta-Awaiting information 11.4.2 tion diagrams for solid waste processing-29-
_ - ._ _. - ., . s ., d' , ~ ~ ,- , , a qr m.' - , , Item Status SER Section , s
- . , , .
Report on staff's site visit Under review- - 13.1'.1J3 - " to corporate office and plant -
.. y ,
' Conformance to Generic Letter . Under review '.. "13.1.2.1 - ' ' 84-16 on hot operating experience , Compliance with commitments on Under review 13.5.1.9 administrative procedures Staff review of the procedures Under review 13f5.2
generation package - Plant-specific information on Under review 15.6.3 steam generator tube rupture
Results of the engineering Awaiting information 17.4.3 assurance program
Results of the final verification Under review
and validation program for the final emergency operating procedures Results of investigation of green Under review
Roto-tellite lights under actual operating conditions Results of surveys of lighting, Under review
sound, meter, and communication system when control room work is-completed.
- NUREG-0737 items:
II.E.1.1 Auxiliary feedwater Combined with Open 10.4.9 system evaluation Item on boron dilution event II.K.3 Final recommendations, Combined with Confirm-15.6.5.1 B&O task force atory Item on GL 85-12 Automatic trip of below RCPc Smali-break LOCA under review 15.6.5 methods Compliance with Under review 15.6.5 10 CFR 50.46-30-
y - - - s e.; < < ,
s Item Status SER Section . ' III.A.I.2 Upgrading of' emergency' . Combined with Open 13.3
' support facilities Item on emergency
- r planning
. III.A.2 Emergency preparedness Combined with Open 13.3. > - z Item on_ emergency _ planning - 1'
- ; Compliance with Generic Letter Under review.
15.6.5/1 ~ ' . .85-12 (TMI Item II,K.3.5) RCP setpoint for'small-break LOCAs
, . ' 17;1,58.1' Electrical, instrumentation Under1 review :
- and control systems audits'
-,. '
- 'SPDS audit'
Under review- .: '
- ' Fire Protection Program -
Under review 1 audit
- BMI thimble vibration
' Awaiting information
Implementation report on preopera-Awaiting information .4.4.6.3 ' -~tional testing of the reactor ves-- ' sel_ water level system
Implementation and maintenance Awaiting.information 9. 5.1. 8 in_'effect of all provisions of the approved fire protection program-31- ,
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F- _ , r - - =,
.,
=, e , ~ ' ~ ^ ' ,. TABLE 1 < < ENFORCEMENT. SLM4ARY1 ,. . COM40N TO.BOTH STP 1 AND STP"2 + ~. . = ,.- > - ' ? FUNCTIONAL "NO. OF. VIOLATIONS:IN EACH SEVERITY LEVEL , . AREA: V.
- IV
- III
' , ' [A.
' Soils and. Foundations 18. - Containment, Safety-Related
- 1;
^ Structures and Major-Steel Supports , s C.
. Pip [ingSystemsandSupports-
4- ~*3 - !D.
Safety-Related Components-
- 2 Mechanical
. E. -. Auxiliary Systems - . . .. ' F.' - Electrical Equipment
- 2 and Cables
,, ' G.
Instrumentation-2-
- 1 H.
LLicensing Activities ' , _ , n,
' .. 'I.
Security.
N' '.s, i .- ' ' ' - . c.
. );v' .' j y G' ", ',. <, .. . J.
. Radiological.. Controls ,;.,' : t. t ' , W Os" ( j' ~ K.
Emergency Preparedness ,
- . ,.. - - -. , . ;I , , -L.
Training and Qualification.
.- '. i, ' L JF%. Effectiveness-si L i AM ; :(T] ?T ' l 'E ' ' ~ ".OC r > .l 's ^; . M.
Quality programs'and
3 %
- SL ' l i j ' j.
f~: '" r' ,. - -~ Administrative ~ Controls y.. ((,a {a.J % ',,g- ' + 'Affecting-Quality.- ., %4, y, ~.; .# O'
- *
N .Preoperational Testing l =t - w, a
1*There were no Severity Level I or II violations.
There was one Severity - -Level.III violation which contained 14 parts. The numbers in the Severity p%, - N' . Level III column refer to the. number of parts of the one violation which apply , .to'the associated SALP functional area.
No deviations from licensee ' ' commitments were identified.
' ' _ J
- . m '
- .<..
< - - - .. . - . Table 2 TABULATkONOFVIOLATIONS . lA.
-SoilsandFounbations.
- , No violations were 1'dentified'in this' functional area.
- B. -
Containmeni. Safety-Related-StructuresandMajorSteelSupports Bolts over-torqued for-sliding connections (Severity Level III, I of
. -14 parts, 8612-06)
C.
Piping Systems;and Supports-- .1.
Welding records for supports incomplete (Severity Level V, 8519-01) 2.
Support swa struts improperly stored-(Severity Level IV, 499/8621-01 3.
Hold point for heat treatment signed off improperly (Severity Level IV, 8601-01) 4.- Debrisinpipe'(SeverityLevelIV, 8617-01) 5.
Failure to follow procedures for pipe hangers (Severity Level IV, 8623-02) 6.
Undersized welds on 2-inch schedule 160 sockets (Severity Level III (1 of 14 parts), 8612-02) 7.
Cap screws used in place of studs and nuts or wafer valves (Severity Level III, (1 of 14 parts), 8612-03) 8.
Undersized welds on supports and restraints (Severity Level III (1 of 14 parts), 8612-05) D.
Safety-Related Components - Mechanical
1.
Inadequate preventive maintenance program (Severity Level IV, , 8515-01)
! 2.
Undersized welds on vendor tanks and heat exchangers (Severity i Level-III (1 of 14 parts), 8612-13) l 3.
Mechanical equipment deficiencies (Severity Level III (1 of 14 parts), 8612-04) ' 4.
Inadequate storage protection for auxiliary feedwater pumps (Severity Level'IV, 8606-03)
_ - - -t r- - _~ . - y p.
.+ .. w . , - , . , , f
> . . _,,. - , . E.
Auxiliary Systems m - -
. ^ No violations were designated for this functional' area ~. 4- > . ., . F.
Electrical Equipment and Cables
J- " l/ .. e _ 1.
. Welding on electrical panels not in accordance with engineered drawings (Severity Level IV, 8604-01) + . 2.
Circuit breaker extenders and barriers installed, but not specified (Severity Level III (1 of 14 parts), 8612-11) . 3.
Motor terminal lugs and insulation not in accor^ dance with procurement specifications (Severity Level III (1 of 14 parts), 8612-14) G.
Instrumentation 1.
Work performed on instrumentation system seal plate without a work authorization (Severity Level IV, 8606-01) 2.
Thimble guide tubes on income instrumentation system were not installed as specified (Severity Level IV, 8606-02) 3.
Instruments and instrument tubing supports not adequately inspected (Severity Level III (1 of 14 parts), 8612-01) H.
Licensing Activities No violations were identified in this functional area.
I.
Security No violations were identified in this functional area.
J.
Radiological Controls No violations were identified in this functional area.
K.
Emergency Preparedness No violations were identified in this functional area.
L.
Training and Qualification Effectiveness No violations were identified in this functional area.
M.
Quality Programs and Administrative Controls Affecting Quality 1.
No procedure for re1orting procedural violations (Severity Level V, 8602-01) 2.
Errors in configuration Control Package for modification of M0V's (Severity Level III (1 of 14 parts), 8612-07) -2-
- _ _ _ _ _ . , . 3.
Drawings did not include vendor installation toleraaces (Severity Level III (1 of 14 parts), 8612-08) 4 ~. Installation drawings did not include NSSS required flow restrictions orifices (Severity Level-III (1 of 14 parts), 8612-09) 5.
Issued ~ drawings not correctly translated from FCR/FCN (Severity Level III (1 of 14 parts), 8612-10) 6.
Wrong bolting in purchased equipment (Severity Level III (1 of 14 parts), 8612-12) 7.
Unidentified fasteners used in field assembly of electrical equipment (Severity Level IV (1 of 2 parts), 8612-15) 8.. Failure to issue NCR timely and attach hold tags to noncon-forming equipment (Severity. Level IV (1 of 2 parts), 8612-16) 9.
Failureto'maintaininplacestorageconditions(Severity Level IV, 8631-01) N.
Preoperational Testing No violations were identified in this functional area.
. . -3-
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