ML19347E214

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Partial Safety Evaluation Report Related to the Operation of the South Texas Project,Units 1 and 2.Docket Nos. 50-498 and 50-499.(Houston Lighting and Power Company)
ML19347E214
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/30/1981
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML19347E208 List:
References
NUREG-0780, NUREG-780, NUDOCS 8104240261
Download: ML19347E214 (39)


Text

._ __

O NUREG4780 Partial Safety Evaluation Report related to the operation of South Texas Project, Units 1 and 2 Docket Nos. 50-498 and 50-499 Houston Lighting and Power Company Sections 1.1,13, and 17 If.S. Nuclear Regulatory

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4/13/81 TABLE OF CONTENTS fage 1

INTRODUCTION AND GENERAL DESCRIPTION OF PLANT....................

1-1 1.1 Introduction................................................

1-1 13 CONDUCT OF OPERATIONS............................................

13-1 13.1 Organizational Structure of Applicant.......................

13-1 13.1.1 Introduction......................................

13-1 13.1.2 Corporate Organization............................

13-2 13.1.3 Plant Staff Organization..........................

13-10 13.1.4 Summa ry a nd Co ncl u s i o ns...........................

13-18 13.2 Training....................................................

13-19 13.3 Emergency Planning..........................................

13-20 13.4 Review and Audit............................................

13-20 13.4.1 Plant Operations Review Committee (PORC)..........

13-20 13.4.2 Nuclear Safety Review Board (NSRB)................

13-21 13.4.3 Independent Safety Engineering Group (ISEG).......

13-21 13.4.4 QA Program Evaluation Committee...................

  • 13-21 13.4.5 Summary and Concl usions...........................

13-21 13.5 Selected Plant Proceuures............

13-21 13.5.1 Control Room Access...............................

13-22 13.5.2 Shift Relief and Turnover.........................

13-22 13.5.3 Shift Supervisor Responsibilities.................

13-22 13.5.4 Feedback of Operating Experience..................

13-22 13.5.5 Summary and Conclusions...........................

13-23 17-1 17 QUALITY ASSURANCE................................................

17. 2 Quali ty Assurance During the Operations Phase..............

17-1 17.2.1 Genera1...........................................

17-1 17.2.2 Organization......................................

17-1 17.2.3 Quality Assurance Program.........................

17-5 17.2.4 Conclusions.......................................

17-6 17.2.5 Outstanding Quality Assurance Issues..............

17-7 iii

LIST OF FIGURES Pagg 13.1 HL&P Corporate Organization for Nuclear Activities...............

13-3 13.2 HL&P South Texas Project Support........................

13-8

13. 3 HL&P Qual i ty Assurance Organi zation..............................

13-11

13. 4 STP P l a n t O rgan i zati o n...........................................

13-12 13.5 Shift Organization...............................................

13-16 17.1 HL&P Organization for Operations.................................

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Supporting STP...................................................

13-4 13.2 Education and Experience Sumaries for Key STP Plant Personnel...

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1 INTRODUCTION AND GENERAL DESCRIPTION OF PLANT 1.1 Introduction This partial Safety Evaluation Report is being issued in response to a Commis-sion Order of September 22, 1980. The Commission Order was a result of a request of intervent that separate hearings be held on the issues raised in the Show Cause Order and Notice of Violation issued by the Office of Inspection and Enforcement on April 30, 1980.

In its Order of September 22, 1980 the Commission denied the request of intervenors and directed the Atomic Safety and Licensing Board to consider in the context of an expedited partial operating license proceeding, contentions or issues that might be identified relative to the Quality Assurance Programs at the South Texas Project (STP).

In addition, the Board was asked to consider the management competence and character of the Houston Lighting and Power Company (Applicant or HL&P).

The Commission Order further directed the Board to issue an early preliminary decision on these limited issues following the expedited portion of the operating license hearing.

As a result of the Commission Order, the NRC staff has completed its evaluation of those portions of the application dealing with management capability and the quality assurance program for the operating license as reported in this partial SER.

It is recognized by the staff that the management organization and the attendant operating organization are still to be finalized.

Hence, the staff's evaluation has been based on current plans as expressed in the Final Safety Analysis Report, as amended, and as obtained during discussions with representatives of the applicant during a visit to the corporate office and Applicant's plant site.

Recognizing that future amendments may further alter the licensee's organization and proposed activities, the NRC staff will continue to monitor the developments in these two areas and update the contents of this partial SER when the final SER is developed and issued at a later date.

The final SER will be issued as NUREG-0781 and will incorporate the sections contained in this partial SER, revised where necessary, and will contain the remainder of Chapter 1 and other Chapters of the SER.

As a result of its review, the NRC staff concludes that the Applicant's planned management and operating organizations meet the requirements of current NRC rules and regulations, are in conformance with NRC guidelines, and are acceptable to the NRC staff, except for the following issues that need to be resolved:

1.

At this time HL&P plans do not provide for a Shift Technical Advisor as currently required by the NRC.

This issue must be resolved prior to the issuance of an operating license.

2.

The NRC staff has not completed its review of the listing of sytems, structures, and components that should be under the control of the quality assurance program.

Additional information may be required' from tb applicant to complete this evaluation.

1-1

13 CONDUCT OF OPERATIONS 13.1 Organizational Structure of Applicant 13.1.1 Introduction During the period February 17-19, 1981, members of the NRC staff visited the corporate office of Houston Lighting and Power Company (HL&P) in Houston, Texas, and the South Texas Project (STP) nuclear plant located near Bay City, Texas.

The purpose of the visit was to review the proposed organization for operation of STP from the level of the senior corporate officer, who will be in overall charge of nuclear operations for the Applicant, down to and including the pro-posed operating staff at the plant; to determine the extent to which HL&P corpo-rate management is and will be involved with, informed about, and dedicated to the safe operation of the STP plant; to examine the qualifications of those senior management officials who have been identified as members of the operating organization; and to examine whether sufficient technical resources have been or will be provided te adequately support safe plant operation.

The projected fuel load date for Unit 1 of the STP nuclear plant at the time of the NRC staff visit was September 1983.

As a result, we did not expect the staffing for the final operating organization to be in place, nor did we expect that HL&P's plans for the exact make-up of the organization for plant operation would be finalized.

Visits such as this normally are conducted within a few months of actual fuel load.

However, this early visit was required in order to respond to the Commission Order, dated September 22, 1980, which directed an expedited operating license hearing on issues relating to quality control, including matters relating to corporate management capability and attitude.

Beginning with a meeting on February 17, 1981 at its corporate office in Houston, HL&P provided the NRC staff with a thorough briefing on its proposed organiza-tion for operation of STP.

This briefing was followed by discussions with corpor-ate personnel sufficient for the staff to gain an insight into the responsibilities and attitudes of the individuals and an understanding of how they actually fit into the operation.

This pattern was repeated at the STP site as regards the plant personnel.

The NRC staff also had the benefit of contact with the IE Resident. Reactor Inspector to obtain his views.

The staff evaluation of the organization and management structure for opera-tion of the STP plant is' based primarily on the information obtained from HL&P during this visit.

In those cases where the information obtained varies from what has previously been filed on the STP docket, HL&P will be required to amend the STP FSAR to incorporate the revised information.

Our evaluation was based upon the guidelines of NUREG-0731, " Guidelines for Utility Management Structure and Technical Resources," draft report dated September 1980, and the requirements outlined in NUREG-0737, " Clarification of TMI Action Plan Requirements."

Since this is a preliminary review, we expect that there will be further changes to the preposed operating organization as planning is refined between now and 13-1

the fuel load date.

Accordingly, an additional, followup review of the organi-zational structure and management for operation of the STP plant will be made before fuel load.

13.1.2 Corporate Organization The planned corporate organization to control and support the STP plant opera-tion is shown on Figure 13.1.

The senior corporate officer in charge of the nuclear program is the Executive Vice President of HL&P.

He is responsible for all nuclear activities within HL&P related to design, engineering, construc-tion, nuclear fuel, operation and quality assurance and he reports directly to 1

the President and Chief Executive of HL&P.

Fossil plant construction and opera--

tions and matters related to transmission of power are the responsibilities of others within the HL&P corporate organization and not the Executive Vice President.

The current Executive Vice President is presently devoting his attention almost exclusively to nuclear matters.

j Reporting directly to the Executive Vice President are the Vice President, Nuclear Engineering and Construction, the Manager STP Quality Assurance, the Director Nuclear Fuels, and the Manager Nuclear Operations.

Table 13.1 provides summary qualifications of the present incumbents in these positions and others in the corporate structure.

13.1.2.1 Engineering and Technical Support The Vice President, Nuclear Engineering and Construction is responsible for nuclear project management and for the engineering, licensing, health physics and construction of the HL&P nuclear plants.

The Manager, South Texas Project, the Manager, Allens Creek Project, and the Manager, Nuclear Services report to the Vice President, Nuclear Engineering and Construction.

13.1.2.1.1 The Manager, South Texas Project directs the activities of the project management organization, which is split between the corporate office in Houston and the STP plant site.

He has responsibility for the management, engineering, purchasing, construction, startup, coordination scheduling, cost control and reporting of the STP nuclear project progress during the design and construction phase.

He interfaces with the nuclear steam supply system project manager, and the architect-engineer / constructor project manager for management decisions affecting the STP plant.

Figure 13.2 provides an overview of the Nuclear Engineering and Construction organization, including the STP Project Management organization.

13.1.2.1.1.1 Engineering, procurement, project control services, accounting, and project administration activities are provided through the Houston office by the Project Manager, Houston Operation. Technical activities related to the STP plant design and construction are concentrated primarily under the control of the Project Engineering Manager and the Licensing and Technical Coordinator, as shown on Figure 13.2.

As of the time of the Staff visit, these two groups had 59 full-time members representing over 400 man years of experi-ence, of which 277 man years are in nuclear design, construction and operation.

1 13-2

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Table 13.1 EDUCATION AND EXPERIENCE SUMMARIES (JRKEYHL&PPERSONNELSUPPORTINGSTP Number of Professionals Reporting Name Title Education Applicable Experience Directly to Each EXECUTIVE MANAGEMENT G. W. Oprea, Jr.

Executive Vice President BA, BSEE 28 years 6

NUCLEAR ENGINEERING AND CONSTRUCTION

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J. H. Goldberg Vice President BSME, MSNE 25 years (Nuclear)

SOUTH TEXAS PROJECT D. G. Barker Manager BSME, MENE 15 years 4

4 J. W. Briskin Project Manager, 20 years 5

Houston Operations J. G. White Licensing & Technical BSME, MSME 6 years (6 Yrs.h'ucicar) 1 4

Coordinator A. J. Granger Project Engineering BSEE, MSNE 8 years (7 Yrs. Nuclear) 3 i

Manager L. K. English Site Manager LL. B 29 years (12 Yrs. Nuclear)

B. F. Duncan Start-up Manager BSNE, U.S. Navy 18 years (18 Yrs. Nuclear)

Nuclear Power School H. E. Orban Construction Supervisor BSEE 30 years (14 Yrs. Nuclear)

R. I. Moles Plant Superintendent BSEE 15 years

Table 13.1 (Cont.)

EDUCATION AND EXPERIENCE SUMMARIES FOR KEY HL&P PERSONNEL SUPPORTING STP Number of Professionals Reporting Name Title Education Applicable lxperience Directly to Each J. L. Blau Supervising Project BSME 6 years (2 Yrs. Nuclear) 4 Engineer, Houston Engineering l

G. L. Parkey Supervising Project BSNE 6 years (6 Yrs. Nuclear) 3 Engineer, Site Engineering L. D. Richards Lead Project Engineer, BSNE 6 years (5 Yrs. Nuclear) 4 t

Licensing J. R. Molleda Lead Project Engineer, BSME 6 years (5 Yrs. Nuclear)

Mechanical / Nuclear R. A. Raymond Lead Project Engineer, BSCE 7 years Civil / Architectural S. L. Rogan Lead Project Engineer, BSEE 7 years Electrical /I&C A. W. Harrison Lead Project Engineer, BSNE, MSNE 7 years Special Engineering Support R. R. Russell Lead Site Engineer, BSNE 4 years Mechanical / Nuclear G. W. Steinman Lead Site Engineer, BSCE 5 years Civil / Structural 1

Table 13.1 (Cont.)

EDUCATION AND EXPERIENCE SUMMARIES i

FOR KEY HL&P PERSONNEL SUPPORTING STP Number of Professionals-Reporting Name Title Education Applicable Experience Directly to Each R. H. Mac Gillivrey Lead Site Engineer, BSEE 23 years j

Electrical /I&C G. J. Gibbs Lead Project Engineer, BSCE 3 years Environmental L. Johnson Security Coordinator 21 years

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g QUALITY ASSURANCE R. A. Frazar Manager, STP QA BSCHE 12 years R. L. Ulrey Manager, Houston QA 17 years j

H. G. Overstreet Project QA Supervisor 7 years (7 Yrs. Nuclear)-

NUCLEAR OPERATIONS (Later)

NUCLEAR SERVICES 2

i J. R. Sumpter Manager

.85 Engineering, 10 years (10 Yrs. Nuclear)

-- 3 Science, MSNE, Ph.D.NE

Table 13.1 (Cont.)

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EDUCATION AND EXPERIENCE SUMMARIES FOR KEY HL&P PERSONNEL SUPPORTING STP Number of Professionals Reporting Name Title Education Applicable Experience Directly to Each J. G. White Principal Engineer, BSME, MSME 6 years (6 Yrs. Nuclear) 3 Nuclear Engineering R. D. Gauny Principal Health Physicist BS Physics Math, 9 years (9 Yrs. Nuclear) 4 MS Biophysics L. R. Jacobi Supervising Engineer, BSNE, MSNE 3

Nuclear Safety and Licensing j

R. L. Baron Supervising Health BS Physics, 8 years-(5 Yrs. Nuclear) 5

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Physicist MSNE NUCLEAR FUEL

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R. P. Murphy Director, Nuclear Fuel BS, Math, MSNE 8 years (8 Yrs. Nuclear) i R. D. Jarvis Lea; Yngineer BSNE 7 years (7 Yrs. Nuclear) e 1

HOUSTON LIGHTING & POWER CO.

SOUTH TEXAS PROJECT SUPPORT EXECUTIVE VICE PRESIDENT G.W. OPREA, JR.

VICE PRESIDENT NUCL. ENG. & CONSTR.

DIRECTOR MANAGER J.H. GOLDBERG l

MANAGER NUCLEAR FUELS NUCLEAR OPERATIONS STP QA R.P. MURPHY R.A. FRAZAR U

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D.G. BARKER LICENSING & TECH.

COORDINATOR J.G. WHITE PROJECT MANAGEMENT ORGANIZATION l

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PROJECT MANAGER SITE MANAGER HOUSTON OPERATION L. K. ENG!.ISH J.W. BRISKIN i

i STA'RTUP CONSTRUCTION PURCHASING BUDGET AND' CONTROLS ENGIN'EERING I

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PROJECT PROJECT PROJECT MANAGER SUPERINTENDENT PURCHASING MANAGER CONTROLS MANAGER' ENGINEERING MANAGER B.F. DUNCAN I.P. MORROW B.L. D0DSON C.A. McCLURE A.J. GRANGER FIGURE 13.2

An additional 39 individuals representing over 290 man years of nuclear experi-Gnce were involved in a staff role part time.

Part of the Houston office.

technical staff, some 16 engineers, were physically located at the STP site in the Site Engineering Group.

13.1.2.1.1.2 The Project Site Manager reviews and directs, where required, the Brown & Poot construction activities.

He also provides direction to HL&P personnel in the areas of construction site purchasing, security, startup, accounting, and construction planning and control. The startup group is presently directed by the Assistant Plant Superintendent.

Startup procedures are being written and the intent is to use assigned plant personnel to perform the startup tests so they will gain maximum experience in the specifics related to plant components and systems prior to actual plant operation. Westinghouse personnel and other consultants are also included in the startup group to provide specialized testing expertise.

13.1.2.1.2 The Manager, Nuclear Services is responsible for nuclear engineering, health physics, and nuclear safety and licensing.

He exercises this responsi-bility through three subordinate divisions.

The Nuclear _ Engineering Division-is responsible for all nuclear engineering activities on HL&P nuclear projects.

The Health Physics Division provides design, laboratory, training and operation services.

It presently has 11 professional personnel and seven technicians assigned, representing over 160 man years of nuclear experience.

The Radiation Protection Supervisor at the STP site reports to the health physicist in the operational services chain of the Health Physics Division. The Nuclear Safety and Licensing Division is responsible for nuclear licensing and safeguards analysis on STP.

13.1.2.1.3 At such time as Unit 1 of the STP plant becomes operational, technical support necessary to assure safe and reliable operation will be provided by the organization now under the control of the Vice President, Nuclear Engineering and Construction.

The exact organizational structure i

necessary to provide this technical support has not yet been settled, although

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present plans are that the existing Site Engineering Group will form the founda-tion for the technical group supporting plant operation.

The emphasis probably will be on a site-located technical supp]rt organization, with back up support available from the headquarters offices, and technical specialty support from outside sources as required.

The Applicant has stated that overall technical support will be consistent with the guidelines suggested in NUREG-0731.

Preliminary plans are for a staged transition from the current technice organi-zation supporting design and construction to that required to support plant operation.

Prior to Unit 1 operation, technical support at the site will be provided both to Unit 1 startup and to Unit 2 construction.

At the appropriate times, this will shift to support of Unit 1 operations and Unit 2 startup.

The final support configuration will support operation of both Units 1 and 2.

The intent of HL&P is to have on its staff individuals who are technically capable of performing design verification for all technical areas, particularly i

those that are uniquely nuclear. The utility management recognizes the necessity for a utility to have in-depth expert knowledge of and involvement in technical f

13-9

matters affecting plant operation, and it has stated its commitment to developing and maintaining that knowledge and involvement.

13.1.2.2 Quality Assurance The adequacy of the Quality Assurance (QA) program of the STP plant is presented in Section 17.2 of this Partial Safety Evaluation Report. We examined the organization for operational quality assurance as it relates to the overall organization as discussed below.

The Manager of STP QA now is located at the STP site, but reports directly to the Executive Vice President.

The principal function of the existing STP QA organization is to provide programmatic direction to the Brown & Root QA organi-zation. A separate QA group in Houston now provides document review, vendor surveillance and corporate auditing functions.

Within the next few months, the HL&P QA organization is to change to that shown on Figure 13.3 where a corporate QA Manager will become responsible for all quality assurance matters company wide.

Under this new organization, the STP QA Manager will still provide on-site management of QA matters for design and construction.

However, at such time as Unit 1 becomes operational, quality assurance activities related to Unit 1 will become the responsibility of the Operations QA Manager, to whom the STP Operations QA group will report.

The exact organization for the site operations QA has not yet been set, although it is expected that site QA activities for operation will be subdivided into quality engineering, quality control, quality surveillance, and audits.

13.1.2.3 Opeutic.,s The Manager of Nuclear Operations, who reports directly to the Executive Vice President, will be responsible for directing the plant management of both the South Texas Project and, when it becomes operational, the Allens Creek Nuclear Generating Station.

This position is now vacant, but HL&P is actively recruiting someone with extensive experience in nuclear power and in power plant operation.

This is a critical management position and it is recognized as such by HL&P.

13.1.2.4 Nuclear Fuels The Director of Nuclear Fuels is responsible for nuclear fuel procurement and analysis.

At the present time, there are a total of five professionals with a combined total of 29 years nuclear experience working in this group.

The group is now studying the extent to which HL&P should develop an in-house capability to peform in-core fcel management.

i 13.1.3 Plant Staff Organization The proposed organization of the STP plant staff is shown on Figure 13.4.

It subdivides the plant activities into six broad areas of operations, training, i

technical support, radiation protection, maintenance, and administration.

The plant staff now consists of about 100 persons out of a projected total i

13-10

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1981 J.L. COLSTON J.W. L0ESCH 1981 OPERATOR REACTOR MAINTENANCE OPERATIONS TRAINING ENGINEERING ENGINEERING i

RADIATION ADMINISTRATIVE I.

PROTECTION SUPERVISOR SIMULATOR CHEMICAL SUPERVISOR ELECTRICAL 1981 TRAINING OPERATIONS G.L. JARVELA MAINTENANCE GENERAL CHEMICAL RADIATION MECHANICAL TRAINING ANALYSIS PROTECTION MAINTENANCE ADMINISTRATION i

RESULTS INSTRUMENT &

ENGINEERING CONTROL FIGURE 13.4 i

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requirement of about 360.

A qualification summary of principal plant staff personnel is presented in Table 13.2.

The total size of the staff is being projected on the basis of a project plan which identifies all known tasks that must be accomplished by the plant staff up through commercial operation of Unit 2, and which estimates the resources required to accomplish these tasks.

Currently, plant personnel are heavily involved in the preparation of procedures; in addition, they will conduct much of the preoperational testing of Unit 1.

The plant operators, electricians, instrumentation and control (I&C) technicians and chemical technicians will be assigned to the preoperational startup test engineers and will participate in the actual tests, thereby gaining valuable knowledge about plant systems and components prior to actual plant operation.

13.1.3.1 Plant Operations The plant operating organization for two-unit operation is now estimated to consist of about 78 people under the direction of the Operating General Super-visor, who will be licensed as a senior reactor operator (SRO) on each unit.

Six Operating Supervisors (shift supervisons), 11 Watch Supervisors (senior control room operators), 22 Head Operators / Operators (control room operators),

and 30 Operator Trainee / Auxiliary Operators are planned.

In addition, provisions have been made to include an Administrative Aide.and a PBX Clerk on each shift, as well as a radiation protection technician and a chemical technician for each unit on each shift.

The proposed shift organization is shown on Figure 13.5.

On back shifts, the Operating Supervisor will be in charge of the station.

The numbers and qualifications of shift personnel proposed meet the guidelines of NUREG-0731 anu the requirements of NUREG-0654 and, accordingly, are acceptable.

In addition, while not a part of the operating organization, each shift will also have a chemical operations group assigned to handle chemical process systems including the demineralizer systems, radioactive waste processing systems and non-radioactive waste processing systems.

This group will relieve the plant operators of the necessity to train on and operate the chemical process systems.

The fire brigade will be staffed by personnel from the chemical operations group under the direction of the Chemical Operations Foreman, with advice provided by a licensed operator.

As of the time of the NRC staff visit, HL&P planned to assure necessary technical expertise available on shift by upgraded qualifications of shift supervisors and other control room personnel.

By so doing, HL&P felt that assignment of a Shift Technical Advisor (STA) on each shift would not be necessary.

This is a possibility'which is provided for in NUREG-0731 and NUREG-0737 as a long-term approach.

However, we advised HL&P that final decisions regarding the long-term need for STAS had not yet been made by the NRC and that there could very well be a requirement imposed that HL&P provide an STA on each operating shift at STP.

HL&P plans to use a six-shift rotation for STP.

This would provide for a minimum of five days of training in each 42-day shift cycle.

Present plans are to have operators on the staff for both units in time for cold licensing on Unit 1.

The Applicant thus anticipates that between 40 and 50 candidates will take the initial cold licensing examinations.

13-13

Table 13.2 EDUCATION AND EXPERIENCE SUMMARIES FOR KEY STP PLANT PERSONNEL Name Title Education Applicable Experience R. I. Moles Plant Superintendent BSEE 15 years (4 Yrs. Nuclear)

B. F. Duncan Assistant Plant Superintendent BSNE, U.S. Navy 18 years (18 Yrs. Nuclear)

Nuclear Power School SR0 - Research Reactor Operating Section K. C. Kline Operating Supervisor H.S. (GED) 16 years (11 Yrs. Nuclear)

SR0 - Prairie Island l

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T S. J. Eldridge Watch Supervisor H.S.

15 years (10 Yrs. Nuclear)

SR0 - H.B. Robinson T. L. Templeman Watch Supervisor H.S. +

10 years (8.5 Yrs. Nuclear)

SRO - ANO 1-Training Section J. L. Colston Training General Supervisor H.S. +

22.5 years (5.5 Yrs. Nuclear)

Technical Section J. W. Loesch Technical General Supervisor BSChE 10 years (3 Yrs. Nuclear)

T. A. Godsey Lead Reactor Engineer BS - Ind. Arts 15 years (6.5 Yrs. Nuclear)

D. A. Leazar Reactor Engineer BSNE 3.5 years (3.2 Yrs. Nuclear)

R. L. Burgess Results Engineer

-BSchE 6 years (3.5 Yrs. Nuclear)

. -.. _. ~. = _ _ -

Table 13.2 (Cont.)

EDUCATION AND EXPERIENCE SUMMARIES FOR KEY STP PLANT PERSONNEL Name Title Education Applicable Experience M. R. Ebel Results Engineer BSNE 6 years (3.5 Yrs. Nuclear) i L. S. Burt Results Engineer BSME 5 years (3.5 Yrs. Nuclear)

C. D. Wren Results Engineer BSRPE 3 years (2.5 Yrs. Nuclear)

B. D. Fellers Chemical Analysis Supervisor H.S.

9 years (6 Yrs. Nuclear) 2 Maintenance Section J. L. Ryan Electrical Supervisor BSEE 11 years (2.5 Yrs. Nuclear)

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A. I. Rylander Instrument & Control Supervisor BSEE 13 years (3 Yrs. Neclear)

W. S. Blair Mechanical Supervisor H.S.

15 years (3 Yrs. Nuclear)

Radiation Protection Group j

G. L. Jarvela Radiation Protection Supervisor H.S.

30 years (19 Yrs. Nuclear) 1 l

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I OPEF,ATOR UNIT 1 CHEMICAL UNIT 2 OPEF ATOR CHEMICAL OPERATOR CHEMICAL R0 OPERATOR OPERATOR R0 4

AUXILIARY CHEMICAL CHEMICAL CHEMlCAL AUX 1LIARY AUXILIARY AUXILIARY AUXILIARY OPERATORS OPERATOR OPERATORS OPERATOR OPERATORS FIGURE 13.5

i 13.1.3.2 Technical Section The plant technical section, under th? direction of the Technical General Supervisor, will be composed of about 83 persons, divided into the areas of reactor engineering, chemical analysis, chemical operations, and result engi-neering.

About half of these individuals are in the chemical operations group which, as noted earlier, will provide on-shif t coverage for operation of chemical process systems.

The reactor engineering grocp consists of a lead reactor engineer and a reactor engineer for each unit.

The two individuals now assigned to this group are developing core physics and thermal-hydraulic testing programs, and are working on the startup test program, as well as developing procedures for receipt, inspection, storage and accountability of fuel.

The chemical analysis group consists of a supervisor, four chemical technicians, three chemical monitors and a nuclear plant chemist. Assigned personnel cur-rently are writing procedures, developing training materials, conducting the pre-operational environmental sampling program, and providing chemical analysis support for hydros.

The group eventually will have about 23 people assigned.

A chemical technician will be assigned on each shift for each operating unit.

The results engineering group will consist of about 11 results engineers and two engineering aides operating under the direction of a lead results engineer.

Currently, four individuals are assigned to this group.

The results engineers will prepare test procedures, perform tests, and prepare test reports for initial startup and post-maintenance testing and will conduct performance testing of all plant systems as required.

13.1.3.3 Radiation Protection The radiation protection group eventually will have two health physicists and about 30 radiation protection technicians operating under the direction of the Radiation Protection Supervisor, who reports functionally to the Assistant Plant Superintendent.

However, this supervisor receives technical direction from the corporate health physics organization to assure independence.

As noted above under Plant Operation, one radiation protection technician will be part of the normal staffing for each shift at each operating unit.

13.1.3.4 Maintenance The Maintenance General Supervisor will direct the activities of a Maintenance Engineering Supervisor, an Electrical Maintenance Supervisor, and Mechanical Maintenance Supervisor, and an Instrument and Control Supervisor.

A total of about 128 personnel are planned for the plant maintenance staff. To date, the specialty supervisors, three foremen, five electricians, ten mechanics, eleven I&C technicians and six apprentices are assigned.

The maintenance group will provide support for initial plant testing and will assume responsibility for plant systems as they are turned over following test.

Currently, the maintenance groups are writing procedures and developing spare parts requirements.

13-17

Thus far, the Applicant has been hiring personnel with prior nuclear experience, primarily from the military services.

Plans are to continue this approach inso-far as possible.

However, HL&P is aware that a shortage of experienced personnel is developing. Accordingly, once the journeyman positions are filled and the various training programs have been established, HL&P anticipates that personnel without prior experience can be hired and trained for the maintenance tasks.

Pending development of these technicians in adequate numbers, HL&P plans to obtain additional personnel, if necessary, on a temporary basis from the con-structor or by contract from other outside organizations.

13.1.4 Summary and Conclusions The HL&P corporate organization and staffing at the time of the NRC visit in February 1981 was oriented toward support and control of the design and con-struction phases of the South Texas Project.

Discussions with corporate officers revealed their personal involvement with the STP effort and their commitment to provide the executive direction and support necessary to assure safe plant construction and operation.

HL&P stated that protection of public health and safety is of paramount importance and this will be communicated to the HL&P staff throughout the lifetime of the plant, emphasizing the responsibility of each employee to perform his or her job in a way that assures public safety.

Planning for the transition from design and construction to plant operation is underway, but detailed plans are not yet completed.

In the tentative design of the technical support structure, HL&P has taken advantage of the experiences of other utilities who now have plants in operation by sending HL&P personnel for training visits to those plants and, in addition, has had consultants study the matter.

As noted earlier, the utility is aware of the importance of having an in-depth capability on the staff to technically support plant operations.

Current staffing efforts are aimed at assuring that this technical expertise will be available.

The plant staf f organization for operation is along conventional lines and is generally acceptable.

At the present time, staffing is on the order of 25%

complete and HL&P is actively recruiting additional qualified personnel.

HL&P recognizes that there is an industry-wide shortage of qualified personnel and the proposed training program (see Section 13.2) is designed to bring people on board at the entry level and provide them the necessary training to qualify them to work at the plant.

HL&P is planning to take advantage of the training opportunities inherent in having plant operations and maintenance personnel actively participate in the preparation of startup test procedures and in the actual tests.

In our view, this emphasis on having the plant staff involved throughout the startup test program will provide good training for the plant staff and will help assure a competent staff at the time Unit 1 is ready for operation.

Overall, we find that the HL&P corporate management is intimately involved with the current construction activities at the STP plant and that they are aware of the plant status.

Plans for the transition from construction activities to plant operation are well underway.

HL&P management has stated its dedication to safe plant construction and operation and its intent to assure that this object se is paramount in the minds of all HL&P personnel involved with the STP plant.

13-18

r-In our conversations with HL&P personnel from the level of the Executiva Vice President down to members of the plant staff, we found them to be knowledgeable and involved.

The plans for technical support of plant operation, both at the plant level and the corporate level, are still under development, but they appear to be in general accordance with industry practice and staff guidelines.

Accordingly, we find that HL&P has been making and is continuing to make adequate plans for the safe operation of the STP plant. We consider that HL&P management has a good understanding of the problems that will be involved in the startup and operation of the STP plant.

However, we expect that the details of the propsed organizational structure and the projected number of people required to support safe plant operation probably will change as the planning proceeds and the Unit 1 fuel load date draws nearer.

Our contacts with the HL&P management personnel revealed an awareness of the status of the plant construction and the plans for transition to plant opera-tion, a personal involvement in the construction oversight and planning, and a positive attitude to do what is necessary to assure that the plant can be com-pleted and operated safely.

13.2 Training The STP training program is divided into the areas of operator training, simu-lator training and general training under the direction of the Training General Supervisor. The training group will consist of about 21 persons, but this number may be adjusted as necessary.

The training program is being developed under the philosophy that the operator is the first line of defense in preventing a casualty or addressing an emer-gency situation.

Realizing that it is impossible to cover all possible con-tingencies in procedures, the objective of the HL&P training program is to equip each operator with the information he needs to perform an assessment of any given situation and with the ability to make judgments using this informa-tion to evaluate plant conditions.

The goal of the training program thus is to assure that each operator has an understanding of what he is doing and why.

To date, HL&P has provided training for operators, supervisors, plant management personnel and engineers by sending them to the Westinghouse training center at Zion, Illinois.

As a result of this training,17 individuals have been certi-fied to date at the SR0 level and an additional eight at the R0 level.

In addition, eight individuals who already had qualifications for cold license have attended a short Westinghouse course to qualify them on commercial PWRs.

An on-site license training program is under development and training will be initiated at the site probably during the spring of 1981.

The Applicant has ordered a plant-specific simulator which should be delivered by mid-to-late 1983, at which time it will be incorporated into the site train-ing facility.

Pending availability of the STP simulator, HL&P will continue to use the Westinghouse facility at Zion.

The Applicant recognizes the industry-wide shortage of qualified nuclear plant operators.

In an effort to develop and keep qualified operators, after Unit 1 fuel load, the STP training program will be structured to bring people in at the entry level and provide the necessary training for them to progress all 13-19

the way to SRO.

Requalification training for all operators will be provided on a continuous basis.

The general training program is still being developed.

However, it is planned that this training will include apprentice training programs for maintenance personnel, as well as advanced specialty training.

It also will cover training for the radiation protection and chemical personnel and general employee training for other plant staff.

We have reviewed HL&P planned training program for the STP plant and we find it to be quite comprehensive.

HL&P recognizes the importance of a plant specific simulator and has one on order that is scheduled to be available for use in the training program in late 1983.

The simulator should be of considerable assistance in the plant training program.

We endorse HL&P's plans to use plant staff personnel in the startup test program for Unit 1.

Valuable experience for plant staff members will be gained, which i

should enhance their ability to safely operate Unit 1 at the time it becomes aperational.

Details regarding the licensed operator training program are still under review by the staff.

We will review the details of the overall training program before issuance of an operating license to assure that it fully meets our guidelines.

However, at this stage of the licensing process, we find it to be acceptable.

13.3 Emergency Planning The Applicant is in the process of revising the emergency plan for the STP plant to be in accordance with NUREG-0654 and to interface with the new State of Texas emergency plan.

Specific review of the STP emergency plan will be done at a later date.

However, we can now conclude that HL&P is aware of the emergency planning requirements and is taking appropriate action for this stage of the licensing process to comply with NRC's emergency plan requirements.

Plans are underway to assure that adequate numbers of properlv trained personnel will be available to staff the Technical Support Center and the Emergency Operations Facility to provide support to the plant staff in the event of an emergency.

13.4 Review and Audit The Applicant's provisions for review and audit of plant safety related activities are discussed below.

13.4.1 Plant Operations Review Committee (PORC) 1 A Plant Operations Review Committee has been established and has been meeting on a monthly basis since July 1978.

The Plant Superintendent is Chairman of the PORC. Other members are the Assistant Plant Superintendent, the Operating General Supervisor, the Technical General Supervisor, the Maintenance General Supervisor, the Reactor Engineer, the Radiation Protection Supervisor, the Plant Quality Assurance Supervisor, and the Site Engineering Representative.

A quorum consists of five members including the Plant Superintendent or Acting Plant Superintendent (Chairman) and the Plant QA Supervisor or his alternate.

At least two members other than the Chairman must be permanent members.

The pri-mary activities of the PORC thus far have been the review of plant procedures 13-20

that affect nuclear safety.

The assigned responsibilities of the PORC include those described for such committees in the Standard Technical Specifications.

13.4.2 Nuclear Safety Review Board (NSRB)

A Nuclear Safety Review Board is to be established in the near future.

The Vice President, Nuclear Engineering and Construction will be the designated Chairman.

Other members are the General Manager, Fossil Power Plant Engineer-ing; the Manager, Nuclear Operations; the Manager, Quality Assurance; the Manager, Nuclear Services; the Director, Nuclear Fuel; Nuclear Plant Superinten-dents; and the Supervising Engineer, Nuclear Safety and Licensing.

Initial activities of the NSRB will be devoted primarily to review of PORC minutes, but the assigned responsibilities of the NSRB include nine areas as described for such review boards by the Standard Technical Specifications.

The NSRB also will conduct corporate audits of facility performance on a prescribed schedule.

13.4.3 Independent Safety Engineering Group (ISEG)

An Independent Safety Engineering Group will be established as discussed in NUREG-0731.

It will function at the plant site, but will report offsite _ to corporate management up through the Vice President, Nuclear Engineering and Construction.

Responsibilities of the ISEG include those spelled out in NUREG-0731, including review of operating experiences of the STP units and plants of similar design.

13.4.4 QA Program Evaluation Committee In addition to the above mentioned groups, whose functions are required to be performed for each plant, the Applicant also has estab1shed a QA Program Evalua-tion Committee, chaired by the Executive Vice President.

This Committee provides a vehicle for executive management review of the HL&P QA prcgram.

13.4.5 Summary and Conclusions We have reviewed the existing and planned organizations and duties for perform-ing review and audit functions.

We find them to be in accordance with the guide-lines as set forth in Regulatory Guide 1.33, Draft NUREG-0731 and NUREG-0737.

Accordingly, we find these plans to be acceptable at this stage of the review process.

Prior to fuel load, we will reexamine HL&P's plans and procedures for performing review and audit to assure that they are acceptable.

13.5 Selected Plant Procedures As mentioned earlier, plant personnel are now engaged in preparation of plant procedures.

Development of the Plant Procedures Manual is underway, with about 8% of the procedures now approved and an additional 9% of the procedures under development.

A total of more than 1600 procedures have been identified for inclusion in the manual.

Selected safety-related procedures will be reviewed by the NRC prior to fuel load.

However, there are a number of administrative procedures related to organization and management that are of specific interest as a result of the lessons learned from the TMI-2 accident, and the NRC staff inquired into the status of these as noted below.

13-21

_ __ _ _ _ _. _ ~ _

13.5.1 Control Room Access Plant procedures will limit normal access to the control room to those indi-viduals responsible for direct operation of the plant, technical advisors, and specified NRC personnel, and will establish a clear line of authority, responsi-bility, and succession in the control room.

The Watch Supervisor (senior control room operator) may approve special access for good cause.

13.5.2 Shift Relief and Turnover Plant procedures for shift relief and turnover will require signed check-lists and logs to assure that the operating staff, including auxiliary operators and maintenance personnel, possess adequate knowledge of critical plant parameters, system status, availability and alignment.

13.5.3 Shift Supervisor Responsibilities A corporate management directive will be issued prior to issuance of an operating license which clearly establishes the command duties of the Operating Supervisor (Shift Supervisor) and emphasizes his primary management responsibility for safe operation of the plant.

Plant procedures will clearly define i.he duties, responsibilities and authority of the Operating Supervisor and other licensed personnel.

Administrative functions that detract from or are subordinate to the Operating Supervisor's management responsibility for assuring the safe operation of the plant will be delegated to other personnel not on duty in tae control room.

Toward this end, as noted earlier under Plant Operations, an Administrative Aide and a PBX Clerk will be assigned to each shift.

13.5.4 Feedback of Operating Experience Procedures are also necessary to assure that operating experiences from the industry and from the HL&P nuclear plants are identified and evaluated, and that pertinent information is made available to appropriate HL&P personnel.

At the present time, HL&P obtains information regarding industry operating experiences from NRC issuances and from the publication, Nuclear Power Experi-ence Reports.

In addition, HL&P subscribes to the NOTEPAD service provided by the Institute of Nuclear Power Operations and the Nuclear Safety Analysis Center, which screens Licensee Event Reports and advises utilities of potentially signi-ficant events.

Information cbtained from these sources is screened by the Nuclear Safety and Licensing Division for applicability and importance and is then sent to the appropriate technical personnel, including those in operations, for necessary action.

In addition, the Manager of the Nuclear Services Depart-ment and the STP Plant Superintendent are members of the EEI Nuclear Operations Subcommittee which meets three times each year to exchange information concerning operational experiences.

The Applicant plans to continue these activities during plant operation.

After the initial screening by Nuclear Safety and Licensing, applicable operating experiences will be transmitted to the Independent Safety Engineering Group for assessment.

Recommendations for implementation will be forwarded to the cognizant group for action.

Use of the Independent Safety Engineering Group will assure a centralized control of operations experience review.

13-22

13.5.5 Summary and Conclusions We have reviewed the HL&P's commitments in the above specific areas and we find them to be in accordance with staff requirements.

We therefore find them to be acceptable for this stage of the operating license review process.

The NRC will evaluate these procedures once they have been prepared to assure that they adequately address the subject areas mentioned above and will monitor HL&P's implementation and performance subsequent to the issuance of an operating license.

13-23

~

_ _,. _._..- __ ~- -

17 QUALITY ASSURANCE 17.2 Quality Assurance During The Operations Phase 17.2.1 General The quality assurance program for the operations phase of Units 1 & 2 of the South Texas Project is described in Chapter 17 of the STP Final Safety Analysis Report.

The STP FSAR was submitted by Houston Lighting & Power Company which is responsible for designing, constructing, and operating the South Texas Project. We assessed HL&P's quality assurance program for the operations phase to determine if it complies wiL, the requirements of 10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and with applicable quality assurance related Regulatory Guides and ASHI Standards listed in Table 17.1.

The basis of our review was Section 17.2 of the Standard Review Plan (NUREG-75/087, Revision 0, 11/24/75).

17.2.2 Organization The structure of the organization responsible for the operation of the South Texas Project and for the establishment and execution of the operations phase quality assurance program is shown in Figure 17.1.

The Manager, Quality Assurance has overall responsibility for the quality assurance program for HL&P's nuclear generating stations during the operations phase.

The Manager, Quality Assurance reports directly to the Executive Vice President of tne HL&P.

The authority and responsibility of the Manager, Quality Assurance to direct and administer the quality assurance program have been granted in writing by the President of the HL&P.

The Manager, Quality Assurance is responsible for the authorization, prepara-tion, and approval of the quality assurance procedures covering operation, maintenance, modifications, inservice inspection, and stores activities for use at the South Texas Project.

He also audits station activities and reviews the adequacy of the quality assurance program for the South Texas Project.

The Manager, Quality Assurance and his subordinate managers have the authority to stop unsatisfactory work as well as to stop further processing of unsatisfac-tory material.

Reporting to the Manager, Quality Assurance through the Operations Quality Assurance Manager is the Plant Quality Assurance Supervisor who has respon-sibility for administering the quality assurance requirements and procedures established for the operating phase of the South Texas Project.

Reporting to the Plant Quality Assurance Supervisor is the Plant Quality Assurance Staff which has responsibility for implementing the operations portion of the quality assurance program.

The Plant Quality Assurance Supervisor and his staff are responsible for quality assurance and quality control activities at the South Texas Project plant during the operations phase.

17-1

4 TABLE 17.1 QA Guides and Standards 1.

Regulatory Guide 1.8, Revision 1-R, " Personnel Selection and Training,"

5/77 (endorses N18.1).

2.

Regulatory Guide 1.28, Revision 0, " Quality Assurance Program Requirements (Design and Construction)," 2/79 (endorses N45.2).

3.

Regulatory Guide 1.30, Revision 0, " Quality Assurance Requirements for 4,

the Installation, Inspection, and Testing of Instrumentation and Electric Equipment," 8/72 (endorses N45.2.4).

(

i 4.

Regulatory Guide 1.33, Revision 2, " Quality Assurance Program Requirements l

(Operation)," 2/78 (endorses N18.7).

i 5.

Regulatory Guide 1.37, Revision 0, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants," 3/73 (endorses N45.2.1).

6.

Regulatory Guide 1.33, Revision 2, " Quality Assurance Recuirements for Packaging, Shipping, Receiving, Storage, and Handling or Items for Water-Cooled Nuclear Power Plants," 5/77 (endorses N45.2.2).

7.

Regulatory Guide 1.39, Revision 2, " Housekeeping Requirements for Water-Cooled Nuclear Power Plants," 9/77 (endorses N45.2.3).

8.

Regulatory Guide 1.58, Revision 1, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel," 9/80 (endorses N45.2.6).

9.

Regulatory Guide 1.64, Revision 2, " Quality Assurance Requirements for the Design of Nuclear Power Plants," 6/76 (endorses N45.2.11).

10.

Regulatory Guide 1.74, Revision 0, " Quality Assurance Terms and Definitions,"

2/74 (endorses N45.2.10).

l 11.

Regulatory Guide 1.88, Revision 2, " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records," 10/76 (endorses N45.2.9).

12.

Regulatory Guide 1.94, Revision 1, " Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants," 4/76 (endorses N45.2.5).

13.

Regulatory Guide 1.116, Revision 0-R, " Quality Assurance Requirements for Installation, Iaspection, and Testing of_ Mechanical Equipment and Systems,"

5/77 (endorses N45.2.8).

14.

Regulatory Guide 1.123, Re 'ision 1, " Quality Assurance Requirements for Control of Procurement of IBems and Services for Nuclear Power Plants,"

7/77 (endorses N45.2.13).

17-2

I l

l TABLE 17.1 (Continued) l'.GuidesandStandards

15. ANSI N45.2.12 ' ' aft 3, Ref. 4 - 2/74), " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants," American National Standards Institute.

16.

Regulatory Guide 1.146, Revision 0, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants," 8/80 (endorses N45.2.23).

6 4

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The HL&P quality assurance organization is responsible for (1) establishing i

quality assurance indoctrination and training programs for personnel per-forming quality-affecting activities; (2) reviewing and approving quality assurance procedures and instructions; (3) assuring that personnel quali-fications are current and applicable to the work being performed; (4) assuring that design and procurement documents include applicable quality assurance requirements; (5) performing pre-award evaluation of suppliers and surveillance and inspection at the supplier's facilities; (6) reviewing and verifying satisfactory completion of corrective actions; (7) performing final acceptance inspections of maintenance, modification, and operations activities; and (8) conducting internal audits of these activities and external audits of suppliers.

These quality assurance personnel have the authority to (1) identify quality-related problems that may involve a "stop work" decision; (2) initiate, recommend or provide solutions; and (3) verify implementation of solutions.

The STP Plant Superintendent, who reports to the Executive Vice President through the Nuclear Operations Manager as shown in Figure 17.1, is responsible for the operation and maintenance of Units 1 & 2 of the South Texas Project.

The Plant Superintendent is assigned the specific responsibility for overall facility management including operation, maintenance, and technical super-vision.

His staff includes an Operations Section responsible for the safe operation of the plant; a Maintenance Section responsible for mechanical, electrical, and instrumentation and control maintenance at the plant; a Techni-cal Section responsible for technical support in the areas of engineering and chemistry; a Radiation Protection Section; and a Training Section.

The STP Plant Superintendent and Nuclear Operations Manager are directly accountable to the Executive Vice President for assuring that all QA problems identified by the independent QA organization are fully resolved.

17.2.3 Quality Assurance Prograi..

HL&P has structured its STP QA program for the operations phase to satisfy Appendix B to 10 CFR Part 50 and the provisions of the NRC guidance shown in Table 17.1.

This QA program for the operation of Units 1 & 2 of the South Texas Project is implemented by means of written policies, procedures, and instruc-tions.

These documents control quality-related activities involving safety-related items in accordance with the requirements of Appendix B to 10 CFR Part 50 and with other applicable regulations, codes, and standards.

The QA organization is responsible for assuring that procedures and instructions provide for complete and adequate QA requirements.

In addition, QA personnel conduct reviews, inspections, and audits to verify the effective implementation of the entire QA program.

HL&P's QA program requires that implementing documents encomptes detailed controls for (1) translating codes, standards, regulatory requirements, technical specifications, engineering requirements, and process requirements into drawings, specifications, procedures, and instructions; (2) developing, reviewing, and approving procurement documents and changes thereto; (3) prescribing all quality-related activities by documented instructions, procedures, drawings, and specifications; (4) issuing and distributing approved documents; (5) purchasing items and services; (6) identifying materials, parts, and components; (7) performing special processes; (8) inspecting and/or testing materials, 17-5

equipment, processes, and services; (9) calibrating and maintaining measuring and test equipment; (10) handling, storing, and shipping items; (11) identifying the inspection, test and operating status of items; (12) identifying and dispositioning nonconforming items; (13) correcting conditions adverse to quality; (14) preparing and maintaining quality assurance records; and (15) auditing activities which affect quality.

The HL&P indoctrination and training program assures that personnel performing activities affecting quality are knowledgeable in QA requirements, implementing procedures, and instructions; that they have competence and skill in the performance of their quality related activities; and that this competence is maintained through periodic retraining.

Quality is verified through checking, reviewing, surveilling, inspecting, testing, and auditing quality related activities.

The QA program requires that quality be verified by Plant Quality Assurance or other Quality Assurance Department personnel.

Inspections are performed by qualified QA personnel in accordance with procedures, instructions, and checklists which are reviewed by the quality assurance organization and approved by the Plant Operating Review Committee.

The QA organization is responsible for establishing and implementing the audit program.

Audits are performed in accordance with pre-established written checklists by qualified QA personnel not having direct responsibilities in the areas being audited.

Periodic audits will be performed by the Quality Assurance Department to evaluate all aspects of the quality assurance program including the effectiveness of the QA program implementation.

The QA program requires the review of audit results by the person having responsibility in the area audited to determine and take corrective action where necessary.

Continued deficiencies, or failure to implement corrective action, will be reported in writing by the QA organization to the appropriate executives within the HL&P.

Follow-up audits are performed by QA personnel to determine that nonconform-ances and deficiencies are effectively corrected and that the corrective action precludes repetitive occurrences.

Audit reviews, which indicate perform-ance trends and the effectiveness of the QA program, are conducted by the QA organization and reported to responsible management for review and assessment.

i 17.2.4 Conclusions Based on our detailed review and evaluation of the QA program description contained in Chapter 17 of the Final Safety Analysis Report for Units 1 & 2 of the South Texas Project, we conclude that:

1.

The organizations and persons performing QA functions have the required independence and authority to effectively carry out the QA program without undue influence from those directly responsible for e st and schedule.

17-6

2.

The QA program, with the exception of the outstanding issue described in Section 17.2.5 below, describes requirements, procedures, and controls that, when properly implemented, comply with the requirements of Appendix B to 10 CFR Part 50 and with the acceptance criteria contained in Section 17.2 of the Standard Review Plan (NUREG-75/087, Rev. 0).

Accordingly, the staff concludes that the description of the HL&P QA program, with the exception of the outstanding issue noted below, is in compliance with applicable NRC regulations.

17.2.5 Outstanding Quality Assurance Issue The staff has not completed its review of the listing of systems, structures, and components that should be under the control of the QA program.

Upon receipt of review results from the NRC staff reviewers, additional information may be required from the Applicant to.]mplete this evaluation.

17-7

.. - -. _ ~

U U.S. NUCLE AR CEGULATORY COMMISSION

,,7 BIBLIOGRAPHIC DATA SHEET NUREG-0780 4 TITLE AND SUBTITLE (Add Volume Na. of appropriate)

2. (Leave blank)

Partial Safety Evaluation Report Related to the Operation of the South Texas Project, Units 1 and

3. RECIPIENT'S ACCESSION NO.

2

7. AUTHOR (S)
5. DATE REPORT COMPLETED M ON TH l YEAR Acril 1981
9. PERFORMING ORGANIZATION NAME AND M AILING ADDRESS (Include lip Codel DATL 9EPORT ISSUED l

Office of Nuclear Reactor Regulation 9ri1 1981 U.

S. Nuclear Regulatory Commission

, _ ft,,, y,,,,,

Washington, D. C.

20555

8. (Leave Nank)
12. SPONSORING ORGANIZATION N AME AND M AILING ADDRESS (include Ira Codel p

Same as 9 above

11. CONTRACT NO.
13. TYPE OF REPORT PE RIOD COVE RE D (inclusdve dales) 15 SUPPLEMENTARY NOTES
14. (Leave o/ r' Al Pertains to Docket Nos. 50-498 and 50-499
16. ABSTR ACT (200 words or lessi This Partial Safety Evaluation Report provides the results of the NRC staff review relative to the " Conduct of Operations" and "i.uality Assurance During the Operations Phase" for the South Texas Project.
17. KE Y WORDS AND DOCUMENT AN ALYSIS 17a DE SC RIP T ORS 7tt IDENTIFIERS OPE N ENDE D TERMS r

18 AV AILABILITY ST ATEMENT 19 SE CURITY CLASS (Th,s report)

21. NO. OF P AGES Unclassified 20 SECURITY CLASS /T/us papf 22 PRICE NGC FORM 335 47 77)