ML20034A197

SALP Repts 50-498/90-06 & 50-499/90-06 for Jan 1989 to Jan 1990.Category 1 Assigned in Functional Areas of Plant Operations,Maint/Surveillance & Security

ML20034A197
Person / Time
Site:	South Texas
Issue date:	04/03/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20034A196	List: ML20034A195 ML20034A197
References
50-498-90-06, 50-498-90-6, 50-499-90-06, 50-499-90-6, NUDOCS 9004200388
Download: ML20034A197 (27)

See also: IR 05000498/1990006

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INITIAL SALP REPORT

U.S. NUCLEAR REGULATORY COMMISSION ~

REGION IV-

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SYSTEMATIC ASSESSMENT- 0F LICENSEE PERFORMANCE-

50-498/90-06

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50-499/90-06-

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Houston-Lighting & Power Company 3

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South Texas Project, Units 1~and 2

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January 1, 1989, through January. 31,.1990--

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INTRODUCTION

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The Systematic Assessment of, Licensee Performance (SALP) program is an-

integrated NRC staff effort to collect available observations and data

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on a periodic basis and to evaluate licensee performance on the basis-

of this information.: The program is supplemental.to' normal regulatury

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processes used to: ensure compliance to NRC. rules and regulations;. It-

is intended to be 'sufficiently diagnostic to provide a rational basis

~ for allocating NRCLresources and to' provide meaningful feedback 1to the

licensee's-management regarding the NRC's assessment of their facility's;

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performanceLin each. functional area.

An NRC SALP Board,' composed of the staff members listed below, met on-

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March 1,-1990, to review the observations and data on performance and.

to; assess licensee performance in.accordance with-Chapter NRC-0516,_

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" Systematic Assessment of Licensee Performance." :The guidance and ~

- evaluation. criteria: are summarized in1Section III:of- this report. The

Board's findings and recommendations were forwarded to the NRC Region IV

Regional. Administrator for approval and issuance,

This report'is the NRC's assessment of the licensee's safety performance

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at South Texas Project, Units 1.and 2-(STP), for the period January 1,-

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1989, through January .31,1990.

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The SALP Board for STP was composed of:

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Chairman

S. J. Collins, Director, Division of Reactor Projects, Region ~ IV

Members

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L. J. Callan, Director, Division of Reactor Safety, Region IV

A. B. Beach, Director, Division of Radiation Safety and Safeguards,

Region IV

G. M. Holahan, Director, Division of Reactor Projects-III/IV/V and

Special Projects, Office of Nuclear Reactor Regulation (NRR)

E. J. Holler, Chief, Project Section CG Division of Reactor Projects,

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Region IV

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J. I. Tapia, Senior Resident Inspector, Region-IV

G. F. Dick, Jr. , ' Senior Project Manager, Project Directorate IV, NRR

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The following personnel also participated in the SALP Board meeting:

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W. B. Jones, Senior Project Engineer, Region IV

R. J. Evans, Resident Inspector, Region IV

J. F. Rogge, Recional Coordir,ator, Office of the Executive Director for

Operations

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'II. : SUMMARY OF RESULTS

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A.

Overview

STP is a plant with strong management involvement, good operating-

experience with Unit I and startup experience with Unit 2, and a-

strong' commitment to safety. The licensee has adequate resources to

operate two-units and has had good success-in resolving a number of.-

significant engineering problems.

STP is a new plant-and the licensee

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has had a number of problems _not atypical during.the.first~ year of

operation.

The licensee has demonstrated its ability to resolve

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-these problems with the' appropriate concern for safety.

Performance

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in the area of plant' operations increased from a; Category 2 to a-

Category 1-rating and reflected effective management involvement and.

a wel1 trained, professional operations = staff. The Category 2-

improved rating.in the. radiological controls: area' reflected a well--

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managed program adequately handling. the problems. associated.with-the

startup and first refueling outage off a new plant.

The Category l'

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performance in the maintenance and surveillance area was characterized

by sufficient staff and good programs, offset by.personne1' errors

early in the SALP period.

Strong performance in the security area

resulted in an increase from a Category'2 to:a Category I rating.

Performance'in the engineering a.nd technical support area reflected

good success in resolving a number of :.y icant engineering

problems and was assessed a strong Cate-

2.

Category IL performance

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in the safety assessment and quality verification area reflected -

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continued strong management involvement regarding'a commitment to

safety, resolution of complex technical issues, and good

communications with NRC.

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-Although programs assessed at Category 1 performance level are

eligible for reduced inspection effort.by the NRC, we will continue

the fundamental inspection program at your facility due to the

near-term operating license status.

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Functional Area ~

Pravious Performance

Present' Performance

Category (01/01/88 to

Category (01/01/89 to

12/31/88)

01/31/90)

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Plant Operations

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Radiological

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2 Improving

Controls

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Maintenance /

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Surveillance

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Emergency

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Preparedness

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Security

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Functional Areal

Previous Performance

Present Performance

Category-(01/01/88 to.

Category -(01/01/89 to

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12/31/88)-

01/31/90)

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Engineering /

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Technical ~ Su'pport

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Safety Assessment /.

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Quality Verification

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III.: CRITERIA

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Licensee. performance was assessed.in seven selected-functional areas.

Functional areas normally represent: areas significant to nuclear safety

and the environment.

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'The following evaluation. criteria were used, as applicable,-to assess-

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each functional area:

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Assurance of: quality, including management. involvement and control;

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Approach to the resolution of technical -issues from a safety

standpoint;

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C.

Responsiveness to NRC initiatives;-

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Enforcement history;

E.

Operational. events-(including response to,: analyses:of, reporting

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of, and corrective actions for);

F.

Staffing (including management); and

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G.

Effectiveness of training and qualification program.

However, the NRC is not limited to these criteria and others may have

been used where appropriate.

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On :the basis of the NRC assessment, each functional area evaluated 1s-

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rated according to three performance categories. The definitions-of

these performance categories are as follows:

Category 1 - Licensee management attention'and involvement are readily

evident and place emphasis on superior performance of nuclear' safety

or safeguards activities, with the resulting-performance substantially-

exceeding regulatory requirements.

Licensee resources are ample and

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effectively used so that a high level of plant and personnel. performance

is being achieved.

Reduced NRC attention may be appropriate.

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Category 2

Licensee management attention to and involvement in the

performance of nuclear safety or safeguards activities are good. The

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licensee hs attained a level of performance:above that needed-to meet

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regulatory requirements.

Licensee resources are adequate and reasonably-

' allocated so that good plant and personnel performance is being achieved.

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NRC attention may be maintained at normal levels.

Category 3 - Licensee management attention to' and involvement in the

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performance of nuclear safety or safeguards activities are not. sufficient.

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The licensee's performance does not-significantly exceed that needed to

- meet minimal regulatory requirements.

Licensee resources appear to be

-strained or not effectively used.

NRC attention:should be increased above

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normal levels,

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This SALP report includes an appraisal of. performance trends in certain

functional, areas. Determination 'f the performance trend was made

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selectively and was reserved for those instances when it is necessary to

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focus NRC.and licensee attentionJon an area with a declining. performance:

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-trend, or to acknowledge an improving trend in licensee performance.

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The trend, if us'ed, is defined as:

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Improving:

Licensee performance was determined to be-improving during.the-

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assessment period.

Declining:

Licensee performance was determined to be declining during the

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assessment period and the licensee had not taken meaningful steps to

address this pattern.

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IV.

PERFORMANCE ANALYSIS

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A.

Plant Operations

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Analysis

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This functional area consists chiefly of: the control and'

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execution of activities directly -related to operating a plant,

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such as plant startup, power operation, plant shutdown, system

lineups, normal operations, response to transient and off-normal

conditions, plant wide housekeeping, and control room

professionalism.

This area was-inspected on a continuous basis by resident and

region-based inspectors and by an Operational Readiness

Assessment Team (ORAT).

The licensee safely and efficiently completed Unit 2' cold

precritical testing.

Inspectors monitored the licensee's

activities which proceeded on schedule and indicated a planned

program that reflected good-management attention. Hot precritical

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testing was con' ducted successfully.

Observations of-the

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licensee's preparation for achieving initial criticality

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findicated a planned program-that reflected. management attention.

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The reactor _ performance staff displayed extensive knowledge of

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core physics parameters.and:t'est procedure requirements.

The Unit 2 startup program, including low power physics testing,.

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was performed in-accordance with the licensee's procedures'to-

verify compliance with the: Technical Specification-(TS),

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Section 14 of Final Safety Analysis' Report (FSAR), and vendor:

-- design. criteria. The test. program procedures were-well' organized

and. test results packages clearly stated how acceptance criteria

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were. satisfied.' Low power physics testing 1was performed in a

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systematic and' carefully-planned manner. - The licensee safelyL

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'_ completed. necessary testing requirements" for the: power ascension

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! program. Thetoperators exhibited.Lan excellent 1 knowledge;of

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plant systems and procedures.during these plant operations'.

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The 0 RAT, conducted March 13-17,d989, identified strengths

in the licensed operators' Labilities _and. professionalism,;as-

well as management's, involvement and oversight lof operational

activities. Weaknesses ~ were' identified in procedure' compliance,

control of temporary scaffolding, control- of fire ~ and locked-

doors, control of combustible material, steam and water leaks,

equipment nomenclature inconsistencies'with procedures ~, and.

control of compressed gas. cylinders. The~: licensee has

implemented corrective actions:for.the'above weaknesses:

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long-term procedure upgrade program:is presently ongoing.

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The plant operations staff exhibited a professional attitude

in'the operation of the plant throughout thisTassessment period.-

The licensee utilized a five-shift (8-hour / shift)' rotation.

Each shift was properly manned with a higher proportion of

senior reactor operators (SR0s) to reactor operators:(R0s) than

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required._ The shift schedules-provide for a rotating week of

formal classroom training for'each of the five crews.

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mandatory overtime for the shift supervisors has _been required

to meet procedure upgrade ~ schedule commitments.

The licensee has continued their support forlthe University.of.

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Maryland college degree program for its licensed-operators.

Plant management made frequent tours of the contro1~ room and .

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plant.

The operating staff consistently exhibited a high level of

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competence and conservatism when facing the many plant challenges

that occurred during this assessment period.

Licensee management

provided excellent support of.the operations staff which, in-

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turn, led to an increase in the level _of staff professionalism.

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During this assessment period, the licensee successfully -

performed two midloop operating evolutions during the first

Unit I refueling outage. New operating procedures were generated

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to support the first reactor coolant system midloop evelution-in<

accordance with the requirements of Generic Let.tae (GL) S8-17.

The actual-operation at midloop_was a.well planned activity _-

carried out by highly skilled operators.

There were no reactor trips resulting from operator _ error'during

this assessment period.

Fifteen: reactor startups were completed:

without personnel error. The licensee' routinely demonstrated.

conservatism when a potential for safety-significance existed.

As a result of a-Unit 2 trip caused by an_ inverter circuit

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failure, the licensee initiated a-plant reliability' improvement'

program to determine the -cause of all previous planti trips.and-

to _ identify _ possible single: failures in the secondary plantt

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which might cause future plant trips. .0f: the 3 Unit-1 trips and-

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9 Unit =2 trips, 10 were attributed to equipment failure. The

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2 _ remaining trips resulted from improper performance-of-

surveillance tests. The review also disclosed that'8 of the

trips were the result:of balance-of plant (B0P)-initiated

events. -Se.veral single point failure conditions which could,

cause a reactor trip were identified.

Twenty-three design

changes were initiated which, when implemented,-will individually

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serve to reduce the likelihood of-a plant trip.

Four of these

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changes were immediately implemented.

In-addition,'the licensee

determined that a--loose-lead detection program and a BOP visual-

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surveillance program were warranted for critical B0P< controls.

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During the last SALP cycle..the Operations Department committed

to complete a genera 1' enhancement of all operating procedures in-

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response'to concerns raised during an NRC! emergency-operating

procedures (E0P) inspection'. .The concerns involvedLeditorial

errors, inconsistencies in procedural content, and

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inconsistencies between procedure references and plant labeling.

Licensee management actively tracked progress toward completion

of this commitment. At the close of this: assessment period,1the

E0P upgrade program-was.on schedule at about 65 percent complete.

The interdepartmental review and in plant walkdown validation of

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the revised E0Ps had been. completed. The major item remaining

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to be completed is the simulator validation. The off-normal

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operating procedures upgrade program was commenced during this

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assessment period.

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The licensee has a goal to attain a control room annunciator-

blackboard status during normal full power operation. The

licensee also formed a task force to eliminate.those annunciators

which are in alarm during normal plant conditions- at 100 percent

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reactor power. . For Unit 1, all scheduled work items except one

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have been completed.

For Unit'2, all work items have been

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defined and are scheduled to be completed in 1990.

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Weaknesses were noted throughout the SALP period regarding

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general plant housekeeping.

Early in the period, inspectors

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.noted that housekeeping practices were not followed in the

control room regarding the_ accumulation of test equipment within-

the "at-the-control": area.. . Inspections'in remote parts of the

plant, such'as the Met _ tower and the firewater pump house

essential cooling water intake structure, routinely revealed

-loose paper,-dirt, and other. items. There also appeared to be-

an absence-of attention regarding housekeeping l efforts in more-

frequented parts _of the plant such as the. emergency diesel

' generator rooms _and in the radiologically controlled: parts.of.

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the plant.

The 1.icensee appears to'have adequate resources and.

appropriate management involvement regarding_their: ability _

.to operate =two units safely. ;The licensee exhibited strong.

performance;with Unit _1: through the first refueling outage-

and during the startup.of- Unit 2.

During this assessment -

period,- the licensee successfully completed' Unit'2 power

ascension ~ testing and declared the unit.in; commercial operation.

Routine plant operations have-demonstrated consistent evidence

of prior planning and frequent. involvement of licensee management.

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performance Rating

The licensee is considered'to be in Performance Category 1 in

this area,

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3.

Recommendations

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a.

NRC Actions

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NRC inspection effort should be consistent with the

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fundamental inspection program.

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b.

Licensee Actions

The licensee should continue to improve housekeeping

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efforts plant-wide.

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B.

Radiological Controls

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Analysis

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The assessment of this functional area consisted of ac'ivities

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directly related to radiological controls, radioactive waste

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management, radiological. effluent control and monitoring, water

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chemistry controls, and transportation of radioactive materials.

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The radiation protection program was inspected twice by

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region-based radiation specialist inspectors in addition-to

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the routine inspections performed by resident inspectors.

The inspectors also reviewed an issue that was reported in

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September 1989 involving the shipments of sewage: treatment sludge

containing. possible low-levels of Cobalt-58 and -60 to'an offsite

disposal site.

(The licensee _could have avoided this issue if

-information provided'in NRC-Information Notice 88-22 had been

implemented.)

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The radiation protection department staffing is considered ._

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appropriate to provide health physics, support for a two-unit

facility. However, a shortage of. radiation protection; personnel-

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had been experienced at-various times.during this period which -

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caused some minor delays during day shift work activities.

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. permanent-plant staff is supplemented with contractor radiation'

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protection: technicians during extended outages,-but a heavy:

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reliance.is not--placed on; contractor-support for- routine plant

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operations.

The staff _ consisted of a good mix of senior level-

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technicians along with a- number 'of professionals and supervisors-

with strong health-physics. academic backgrounds.

-A~ low turnover;

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rate was experienced within the radiation protection department

during the assessment period.-

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A well defined: train _ing and qualification program had been:

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established for personnel at the' technician level. A plant

systems course was included as partlof the routine qualification

program in order to provide radiation protection personnel La

background concerning systems that could impact health physics

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job coverage.

Supervisors and professionals attend periodic'

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training, but'an organized training program had not'been

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established to ensure that these individuals, maintain and expand

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expertise in their assigned areas.

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The radiation protection program is'well managed and receives

good support.from licensee management,

In practice,. functional

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-areas of responsibility within the radiation protection

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department are well' define _d, although, in some cases personnel-

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position descriptions were written in: a general nature and didL

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not clearly define the job duties- and responsibilities.

The radiation protection manager and other.' department supervisors

attend various staff meetings and play an active role in'the

planning and scheduling of_ plant activities. Good working

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relationships exist- between the radiation protection department-

and other departments, such as operations and maintenance.

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Good quality assessment was evident by the conduct of

performance-based' audits. These-audits were designed to verify

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compliance with approved plant procedures. Audit effectiveness-

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could be improved by expanding the scope'to include comments on-

the adequacy of existing procedures or observations on needed-

improvements.

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Some areas for improvement were identified with the ALARA

program. The program was addressed in-several' separate:

department procedures, in'11eu of an.ALARA-manual. A full-time

ALARA coordinator had been assigned to handle ALARA activities,

however, staffing was minimal-to handle the work load at the

two-unit site. The'ALARA program was designed to address major

ov.tage activities but did not include such programmatic features-

as_ source term evaluations, corrective actions:for chronic.

radiation sources,.such as overhead pipes and drains near

- personnel access routes; nor the use of chemical decontamination -

techniques.

During the ' Unit 1 refueling outage, -it was discovered that an'

ALARA review was not conducted for_a design. change: initiated

prior to' this SALP period by the engineering support < group.

This design change involved several penetrations made in- the

fue1~ handling building which were in line with the fuel transfer

tube.

The licensee's response was to provide: adequate shielding

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' for the penetration' and to ensure that proposed design changes -

will receive ALARA review and' approval.

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The licensee was~ aware of the ALARA program shortcomings and

had initiated actions to improve.this area.

The-licensee had

established an aggressive 100 person-rem goal for 1989. The

actual exposure was about 160 person-rem,-primarily because-of'

unexpected work activities occurring during.the refueling _

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outage. The low person-rem received-during 1989 is a-good

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indication of an effective radiation. protection-program -

In general, radiation protection activities: associated with

the first refueling outage were performed in an acceptable

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manner.

Some problems were observed concerning placement of

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step-off pads and the type of' clothing being worn by personnel

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working.in the containment building. The' licensee demonstrated

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good judgement in the resolution of technical issues, Two

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examples involved the identification and ~ shielding of radiation

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streaming from penetrations in the fuel handling building and

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radioactive contamination' found in the inorganic basin and -

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sewage sludge,

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The radiochemistry and water chemistry programs were inspected.

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once during the assessment period. This included confirmatory

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measurements of-plant liquid and gaseous samples and certified

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standards. The radiological confirmatory measurements involved

separate counting laboratory facilities. for radiochemistry'and

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health physics at each unit.

The. licensee's results for Unit'1

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and Unit 2 indicated very high agreement with NRC analyses

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results consistent with those achieved during the previous

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assessment period. The results for both Units 1 and 2 water

chemistry measurements showed 100 percent agreement, an

improvement in water chemistry analyses over the previous

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assessment: period, lheL licensee had implemented an improved -

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interlaboratory.and intralaboratory quality control ' program

for. chemistry technician performance evaluation. This program

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has proven-to be a strength in the chemistry and radiochemistry

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programs 'as shown by their confirmatory measurements performance -

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during this. assessment period. 'The Electric Power Research ,

. Institute (EPRI) chemistry parameter guidelines along with the

. Westinghouse chemistry: specifications.are specified-in plant

procedures and strictly followed. The, staffing, training,'and-

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qualifications for the chemistry and-radiochemistry programs are

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appropriate to: support a high quality program. 3The personnel

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turnover rate for,these areastwas, low.

Comprehensive: quality

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assurance' audits were performed to determine ^ compliance with

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established procedures.-- No' problems were identified concerning

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the: response to in-house audit findings,--resolution of technical-

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issues,;and responsiveness to NRC initiatives.

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The radioactive waste management program was-. inspected.twice-

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during the assessment period. The licensee _had implemented

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a program that demonstrated compliance with-the-Radiological'-

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Effluent TS (RETS),' the off site dose calculation: manual-(0DCM),

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and the process control: program (PCP).

Liquid'and gaseous.-

release permit programs had been implemented to ensure that-

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proper review was' completed prior'to' making planned releases.

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The areas of-staffing-and personnel training;and qualifications

are considered adequate to implement:a radioactive waste.

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management program. The personnel turnover rate for this area

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was low.

The licensee had conducted a' quality. assurance audit

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of the radioactive waste management area. . Al1 ' identified audit

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and surveillance findings'were; closed in.a' timely manner.

The radioactive material' transportation program was inspected

twice.

No problems,were identified;in this area'. Good'

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implementing' procedures-hadLbeen issued.and the program appeared-

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to be well managed.

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The radiological environmental monitoring program was not

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inspected during this-assessment period.

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The licensee's radiological program has been shown to be

effective and 1s continuing to improve. The radiochemistry andT

water chemistry programs are characterized by good facilities -

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and.well implemented programs.

Additional strengthening of the

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ALARA program should be considered to ensure that complex-

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radiological situations are properly evaluated and controlled.

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2.

Performance Rating-

The licensee is considered to be in Performance Category 2 with

an increasing performance trend in this area.

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Recommendations

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~NRC Actions

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NRC. inspection effort should be consistent with the

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fundamental inspection' program.

Regional initiative . inspections lshould be performed in i

the ALARA area.

b.

Licensee Actions-

Efforts: should be considered-to enhance' the ALARA program.

C.

Maintenance / Surveillance

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Analysi s '

The assessment of: this functional area included all activities

associated with either diagnostic, predictive,, preventive'or

corrective maintenance; procurement,: control, and storage of.

components.-including' qualification controls; installation of

plant modifications; and maintenance of.the plant physical-

-condition.

It. included conduct of all surveillance and inservice-

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inspection (ISI) and testing'(IST) activities.

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The maintenance / surveillance functional area was inspected

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routinely by the resident inspectors,Lperiodically by the-

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regional inspectors, by a system entry retest team (SERT) ~

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inspection, and by an initial:(1 week) maintenance team

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inspection (MTI).

During this assessment period, the maintenance department

successfully supported the completion'of.the first1 refueling-

outage in Unit 1 as well-as: outages'in both units conducted

to inspect r'eactor vessel bottom mounted ~ instrumentation.

The licensee's actions in meeting GL'88-17, " Loss of Decay Heat

1

Removal," were satisfactorily-completed. The. diversity and

arrangement of control-room instrumentation'was considered a

strength.

Training provided to the operators was considered

.)

excellent.

.

In order to focus maintenance initiatives, the licensee

!

implemented a preventive maintenance.(PM),; program enhancement

plan of action during this assessment period. This program

!

,

resulted in a reduced and more focused scope of the PM program

and a reduced PM deferral rate trend.

l

1

The licensee has . initiated an aggressive- program _to redu:e

the backlog of preventive and corrective maintenance tasks.

>

In this respect, the licensee has established a Contract Craft

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Support Group to address open maintenance items. This-group

numbers approximately 100 people, of.which;45:are craftsmen who

are_to augment the existing licensee maintenance department with-

the vemainder comprising the Contract Craft _ Support Group, whose-

sole function will be to reduce the ' outstanding backlog of low -

priority work.

The. licensee has a--strong program for_ determining-the.'need-for

-

retest and identification of appropriate; retest type. Also,

q

good procedures:were developed and implemented for.

f

< postmodifications and.postmaintenance retests.

-A minor weakness

d

'

was identified in that there-were no: documented guidelines for

!

identifying and developing needed' integrated systems'poststartup

'i

retests for extensive modifications.

l

The licensee has an effective work order control system which

utilizes a. data base containing previous work; experience and

,

equipment history. A new work process program was implemented-

1

during the. assessment period.

This program served to clarify =

-

individual responsibilities and requirements;to be contained

within work documents. -The new work process program also

expanded existing instructions from one to five procedures to

establish a better-work document generation-process.

The maintenance department conducted a self-assessment which

resulted in~144 findi.ngs-during-this_SALP~ period. ; Action-items

,

were generated and input into the maintenance department 5 year

-l

action plan. _The. maintenance department reorganized in December

1989, establishing a. separate planning division and manager,

which now provides' dedicated management'to the work planning

affort.

1

Two reactor trips resulted from improper surveillance' activities

~

(personnel error). 'A plant reliability program was developed to

j

identify potentially vulnerable components which could cause a

i

reactor trip.

Design changes were-initiated and additional

surveillances implemented for critical B0P equipment.

j

The licensee's surveillance testing program resulted in a' number

of missed surveillances early in the SALP-period, however,

';

management attention was focused.in this area and recent data-

indicates that the, problem of missed surveillances due to

personnel error was corrected with' surveillance tests performed

as scheduled with high quality procedures.

Inspectors observed

j

that a large filing backlog caused slow retrieval.of data

i

packages and there were several instances of failure to provide-

>

an adequate justification-for determining that-data ent'ry was

'

"not applicable."

Inspectdons of Units 1 and 2 IST program activities found that

l.

the test procedures comprehensively addressed ASME Section'XI~

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Code. requirements, reference : values,L and acceptance criteria.

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Operations personnel demonstrated alertness to' procedural

- details and knowledge of system performance requirements.-

- Review of Unit I ISI activities found a well' organized and

written ISI plan, ' appropriate administrative controls for repair

-

and replacement activities, and satisfactory performance of ISI

~

-

. examinations. 'A noncited< violation was. identified regarding.the

i

failure to~obtain_a quality assurance-review of ISI contractor-

>

special process procedures.

The licensee developed programmatic controls for-

-;

nondestructive. examination (NDE) activities which were

1

,

fully consistent:with_the requirements.of Sections ~III and V

of the ASME Code.

Inspectors ascertained from. visual

inspection of welds, review of-radiographic examination ~

,

film,,and review of.NDE records'that the licensee has

effectively; implemented therNDE program.

. Inspect 1on of--welding activities revealed weaknesses in program

!

implerrentation,.as evidenced by-the identification of violations:

'

pertaining to the failure to monitor in process welding.

.

.'parareters, and the observed commingling of welding materials in

1

. storage. ovens.

Licensee performance in the maintenance and surveillance area'

'

was characterized by: sufficient staff 'and -good programs, offset

by personn'el= errors.early in the SALP period which were

,

subsequently corrected. ' Strong management 1 involvement resulted-

-

in successful completion of-the' Unit 1 first refueling o'utage,

a

including preparations for complex maintenance activities.

2.

Performance Rating

l

The licensee is considered to be in Performance-Category 1 in

'

this area.-

-

3.

Recommendations

a.

NRC Actions

NRC inspection effort should be consistent with the

'

fundamental inspection program,

b.

' Licensee Actions-

The licensee should continue maintenance and surveillance

!

program enhancement activities.

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D.

Emergency' Preparedness

'1.

'. Analysis-

y

. The . assessment of this functional- area included activities .

related to' the establishment.and: implementation of the emergency-

L

plan and implementing procedures, licensee performance during'

~ exercises'and_ actual events.that' test emergency plans, and

!

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interactions with onsiteLand offsite emergencycresponse,

L

organizations- during_ exercise and actual events.

During the Lassessment period,9 region-based and NRC contractorL

q

inspectors conducted two emergency l preparedness inspections.

l

The first. inspection consisted of,the observation and evaluationL

L

of the' annual. emergency response exercise; The secondt

'

L

inspection ' involved a review of the opertaional status

program.

During the emergency response exercise, conducted in-

..

_

1

-April 1989,La significant weakness-was: identified in that the

!

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licensee underestimated the offsite-doses. associated with the -

,

I.

given scenario. This underestimation of the dose projections;

i

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occurred because the licensee'had'not programmed the computer:

I

for dose-assessment calculations 1to account for core degradation

!

indications from the high range' containment radiation-monitor.

-

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'

Another weakness identified was the licensee's inability,to

-

demonstrate timely and effective personnel accountability'during

.:

and after the site evacuation. This was_a repeat' weakness from.

i

the previous 1988 exercise'and recurred _as a result of the

licensee's failure to identify all the factors that contributed

to the delay of personnel accountability in the 1988 exercise.

The emergency preparedness inspectio'n'of t.he licensee.'s

operational status program . identified twosproblem areas. The

first area pertained to inadequate ' training of emergency; response.

personnel,

The second area pertained to':the-licensee not being

able to effect adequate physical security over. emergency

equipment and supplies ~in the two technical support

centers (TSCs).

'

4

The inspectors found that key emergency responders were not able.

-

,to effectively classify a general emergency condition or_make

.

'

proper offsite dose projections. Also,'some of the. interviewees

1

had not received _ training in the latest procedure changes, and

others had not' received hands-on training ~on the computer'used

'

to perform dose projections. . Consequently,-the unfamiliarity

r

with dose assessment and emergency action _ levels exhibited by

these interviewed teams indicated a deficiency in the licensee's

operational readiness to respond to an actual emergency.

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' TheLinspectors also ldentified that the licensee had not .

- established the necessary controls-overLequipment and supplies

1

within the TSCs.

There were. questions raised about the

3

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availability M TSC equipment.and supplies to support a fullyc..

l

functional TSC within the. required 60 minutes.' .This problem had.

l

been identified by the licensee several months ~ prior to the

...

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.

inspection, butl the;11censee's prioritization ofLissues prevented

the intended corrective acti.on from being; implemented in a timely-

'!

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manner.-

i

...

The above issues. indicated a need;for increased. management

~!

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involvement to ensure nthat responders are properly-trained and'

' that problems with potential safety; impact are identified-and'

corrected.

t

During this. appraisal . period, the NRC inspectors ' observed.' good .

' performance in- the ~ control room, technical support center,:and

l

operations support centerb Also, it. appeared that the-licensee.

l

. maintained a well qualified and experienced stafflin'their

emergency preparedness and emergency response organizations;

Apart from the-technical support centers,~other emergency-

,

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response' facilities, such as the control room and the emergencyL

,

operations facility,.were found to have' excellent layouts with~

-readily available. equipment to enable'efficientLimplementation

-(

of the emergency response functions.

,

During the course of the assessment period, the licensee

L

corrected or implemented corrective measures'toiresolve the

L

self- and NRC-identified weaknesses. The' independent audit.

conducted by the licensee's quality assurance department was

found to have been enhanted by the use.of additional emergency

i

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preparedness expertise from:outside'of the licensee's

L

'

organization.

It is notable that the licensee has taken the

.t

initiative to make preparations for conducting-a

)

performance-orientated audit of.theLemergency. preparedness-

7

program during 1990.

'

Despite the repeat weakness involving accountability, the-

licensee's approach to resolution of exercise we'aknesses

demonstrated a clear understanding and control of the. issues.

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Moreover, the licensee's approaches were generally' thorough and

'

technically sound,

g

The issues identified during the annual exercise and the

[

L

operational status. inspection indicated that increased

!

management review is needed in work prioritization, training,

and dose assessment capabilities.

It is apparent, however, from

';

the inspection findings-that the licensee has maintained an

adequate emergency preparedness program with a satisfactory

i

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level of operational readiness to protect the health and safety

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of the public.

Continued refinements are needed before the

licensee's emergency preparedness program will reach full

l

operational maturity.

2.

performance Rating

'[

,

'

The licensee is considered to be in Performance Category 2 in

this area.

3.

Board Recommendations

a.-

Recommended NRC Action

'

The NRC effort should be limited to the fundamental

inspection program.

Regional initiative inspections

should be performed in the areas of training, dose'

>

assessment, and staffing.

b.

Recommended Licensee Action

,

Management attention to the implementation of the emergency

preparedness program should consider the weaknesses

identified and a review of corrective action prioritization.

!

E.

Security

!

1.

Analysis

i

This functional area' includes all-activities that ensure the-

l

security of the plant, including all aspects of access control,

!

security brckground checks, safeguards'information protection,

,

and fitness-for-duty activities and controls.

!

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During the assessment period, this area was routinely reviewed

by the resident inspectors and region-based physical . security

!

inspectors conducted three security inspections. The licensee

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identified several violations of the Physical Security Plan-(PSP)

+

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and procedural requirements.

The violations identified involved

u,

inadequate compensatory measures, inadequate control of licensee

designated vehicles, inadequate lock and key control, and

.

inadequate protection of sC eguards information.

'

The previous SALP period aa lysis referenced a violation for

inadequate compensatory measures.

Two of the licensee-identified

violations were in this program area. Two additional violations

<

were identified by the security force but were not directly

3

attributable to a security program weakness.

These. violations

'

invcived failures by the plant personnel to maintain control

^

over badges and licensee designated vehicles.

All of the

l

violations were properly reported by the licensee.

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During the assessment period, a preoperational NRC inspection

for Unit'2 included those security systems common to both units.

l

The licensee's security systems were determined to be well

designed and functional. The licensee has diligently tested

'

security systems to ensure operability and the licensee has

'

exceeded the regulatory requirement by conducting vulnerability '

'

e

testing of all security systems, ~ The licensee's maintenance

program has ensured that security systems receive prompt and

,

efficient attention,

,

Licensee management has demonstrated a strong commitment-to.

the implementation of the security program, .The securit,

,

management ' staff is professional, knowledgeable, and wel's

,

organized to provide maximum support for the security force,

,

All technical issues were quickly identified and resolved.

All NRC issues were promptly addressed and appropriate action

taken.

In response to the threat of vehicle land bombs,.the

l

licensee. conducted extensive planning for the contingency and

'

completed construction of one vehicle denial system,

1

The security force has an appropriate number of personnel that

appeared to be well trained and dedicated to performing their

.'

security function in an. outstanding manner, While the security

force is provided by a contractor, the licensee made every

effort to integrate the security contractor personnel into the

licensee organization. The licensee conducted an extensive

contingency plan drill program that ensured that all security

shifts could implement contingency requirements. The drill

scenarios were extensive and conducted on a frequent basis.

The quality assurance and compliance programs were effective in

identifying problem areas,

Security management took

effective steps to_ ensure that identified problems did not

recur. The licensee completed a comprehensive audit of the-

security program during the current SALP. period. All findings

requiring corrective action were promptly completed.

Each

finding was properly reviewed and reported to the NRC if required.

The licensee has made significant progress in improving the

security program, The licensing of Unit 2 had no significant

adverse impact on the continued improvement of the secu*ity

program.

2.

Performance Rating

i

The licensee is considered to be in Performance Category 1 in

this area,

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3.

Recommendations

a.

Recommended NRC Actions

l

The NRC inspection effort should be consistent with the

core inspection program,

b.

Recommended Licensee Actions

Licensee management should continue to provide strong.

support to the security program.

,

F.

Engineering and Technical Support

1.

Analysis

-

The purpose of this functional area is-to address the adequacy

!

of technical and engineering support for all plant activities.

'

,

The assessment of this area included all licensee activities

!

associated with the design of plant modifications; engineering

and technical-support for operations, outages, maintenance,.

,

testing, surveillance, and procurement activities;' training; and

j[

configuration management.

.

l

This functional area was inspected on.an ongoing basis by the

[

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resident inspectors and periodically by the region-based

.

l-

inspectors.

'

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During this assessment period, plant engineering personnel-

provided the lead role for coordination of_most major plant

outage evolutions.

These efforts' included the Unit 1 generator

fire recovery, turbine stationary blade cracking outages for

'

'

both units, Unit _1 refueling outage steam generator work, Diesel

4

Generator No. 22 recovery, and the Unit 1 extraction steam

_

,

bellows failure recovery. These efforts were wel1< coordinated,

'

significant, technical challenges, which were handled with'

.

strong attention to plant safety issues.

The reactor performance

~;

engineers conducted the Unit 2 startup power ascension testing

'

program in a competent manner ahead of the: projected schedule.

An example of plant engineering personnel attention to detail

,

and plant safety was the identification of the safety injection

s

system surveillance test anomaly and the resulting

suspension of the Unit I startup.

This action was subsequently

commended by NRC Region IV management in a letter to the licensee.

-

In response to the Unit 1 turbine generator fire which was

[

caused by the failure of-a nonsafety-related component in BOP,

engineering generated a failure mode and effects analysis on

,

other nonsafety-related systems. This analysis was performed on

.

17 systems to determine if system design or a component failure

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could affect overall plant reliaoility.

In September 1989,

"

Unit' 2 tripped on loss of a single DC power source to the

turbine trip solenoid valves., Immediately-following the trip,

=several engineering task forces were organized to review various

,

aspects of improved plant reliability.. The licensee's plant-

engineering department. initiated an infrared thermography.

j

program for use in loose or faulty electrical connections which

-

resulted in the-identification and repair of several electrical-

!

connections reducing the potential . for plant l trips or equipment

1

malfunctions.

,

The licensee initiated a vendor technical manual; update program

to incorporate outstanding amendments for vender technical

1

manuals used by engineering, operations, and maintenance. A

l

total of 338 manuals were reviewed during this SALP period. The

licensee also established a substantial vendor drawing

enhancement program to upgrade substandard drawings identified

in the project document control. database. This program verifies;

legibility and reproducibility of vendor drawings, .Both of

those programs are indicative of a proactive approach by

engineering in ensuring that plant data is maintained and

retrievable.

.

During this SALP period,.two_ station problem reports were issued

which identified the contamination of nonradioactive systems

because of cross-connection.

The corrective actions taken

required a review of systems for interfaces which could provide

potential release points to nonradioactive systems.or to the

i

environment. This review considered anticipated equipment

.

failures and potential system misalignment. As a result of this

I

review effort, four design changes were proposed te reduce the

contamina; ion potential.

In this SALP period, a Quality Engineering Group was established-

.

within the Support Engineering Department in an-attempt to

'

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identify and prevent problems before occurrence.

This-group has

the responsibility of conducting internal-surveillances to

-

ensure that engineering programs and procedures are being

3

followed.

During this SALP period, the licensee initiated a design basis

,

document verification program for selected mechanical,

electrical, and instrumentation and control systems. The

objective of this program is to provide comprehensive,

,

retrievable, verified design basis source documentation and

assure that engineering personnel are cognizant of the design

(

process used and of the requirements and intent of the original-

'

de:,i g n . This effort is a planned 4-year program that repretents

a strong commitment to plant configuration management.

The-

!

configuration management program in the engineering department

'

also includes design deficiency trend reports done on a quarterly

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basis.

Examination of these reports indicates a downward trend

in problems associated with inadequate design information.

.

A special team inspection of the programs implemented to ensure

[

compliance with the environmental qualification (EQ) of

>

electrical equipment- requirements was conducted. The inspection

-determined that the-licensee's EQ file system was difficult to

,

use, but.that the programs for the EQ-related procurement and

-

maintenance activities were good, and the governing procedures

for the overall_EQ program were acceptable. The licensee lacked

.

sensitivity regarding the operability of plant components in

that when the qualification of certain motor operated valves

-

(accumulator outlet valves).that were subjected to submergence-

became questionable, the licensee failed to relate the effect of

this condition on the operability of the valves ~and, hence, to

the effect on facility operations.

Problems in EQ appear to

be attributable to a small EQ staff and heavy reliance on

contractors.

i

Another inspection which was conducted during this SALP cycle

'

determined that the records program was satisfactory and found

!

that record retrieval was accomplished in a timely manner.

Other inspections germane to the engineering and technical

support functional area disclosed weaknesses in the facility

drawings and procedures. The inspection noted that the licensee

had previously identified those weaknesses and was implementing

,

corrective actions. Other inspections identified errors and

,

!

weaknesses in procedures (EOPs, AOPs,' and Alarm Procedures).

L

The licensee's actions are generally conservative, but there did

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l

not appear to be evidence of a critical self-assessment process

regarding procedure details to identify these types of problems.

'

The licensee has maintained a successful licensed operator

training program. The overall passing percentage for R0s and

SR0s is 86 percent. 'The plant simulator 1s- fully operational,

,'

however, significant deficiencies'were encountered with the

simulator during the May and November 1988 operator licensing

examinations.

Modeling inaccuracies, systems limitations,.

,

and system unreliability made.the simulator marginally acceptable

for examination purposes.- The April 1989 examination. indicated

that progress had been made towards correcting these deficiencies.

After the transition from startup operation to full power

>

operation of both units, the licensee focused more resources on

requalification and simulator improvements.

The licensee nas established an effective training program

for nonlicensed personnel.

Strict training requirements have

been established for maintenance personnel which must be met

.

'

before an individual is authorized to perform a given task.

However, no formalized training program has been established for

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system engineers. Although the system engineers have been in

place for.several years, many of the individuals had not been

>

provided training on their respective plant systems.

,

Inspections of the STP precurement program have identified

I

several programmatic weaknesses.

Licensee management response.

.

to this issue has been effective.

Actions taken included review

,

of all previously issued purchase orders and added program

controls and personnel training.

Inspections (150 revealed that

the procurement program had not appropriately addressed .

.

commercial grade procurement and dedication requirements.in the

!

past. The licensee has recognized this weakness and has

developed program requirements and instituted a review of prior

commercial grade procurements.

2.

Performance Rating

The licensee is considered to be in Performance Category 2 in

this area.

3.

Recommendations

a.

NRC Actions

NRC inspection effort should be consistent with the

'

fundamental inspection program.

A regional initiative team inspection should be conducted

,

to more fully evaluate the licensee's engineering

capabilities with focus on direct support of operations,

maintenance, and testing.

,

b.

Licensee Actions

The licensee should continue to provide management attention

in order to improve and strengthen their' engineering and

'

technical support capabilities. Adaitional efforts should

be made to improve the retrievability of EQ files and to

'

resolve questions regarding past commercial grade

i

procurements.

G.

Safety Assessment /0uality verification

1.

Analysis

'

The assessment of this functional area included all licens'ee

review activities associated with the implementation of licensee-

"

policies; licensee activities related to amendment, exemption,

'

and relief requests; and response to generic letters, bulletins,.

and information notices.

The assessment of this functional area

also included ifcensee activities related to resolution of'

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safety issues, 10 CFR 50.59 reviews, 10 CFR Part 21 assessments,

safety committee and self-assessment activities, quality

i

assurance / quality control reviews, and in monitoring the overall

.

performance of the plant.

l

This functienal area' was assessed on a continuing basis

throughout the period.

i

During this period, the full- power license was issued for

Unit 2.

In addition, there were nine amendments issued for

Unit 1 and three for Unit 2.

Notable amendments were the'

>

1ssuance'of combined TS in concert with Unit 2 licensing and the.

staff approval of the use of silver-indium-cadmium control rods.

i

Two of the license amendments did not involve changes to the TS

.;

but were the result offitems identified by the licensee's 50.59-

1

program as unreviewed safety questions.

i

During the period prior to the licensing of Unit 2, there were

-

several issues that surfaced late.in the licensing process that

.

required resolution before licensing.

In response, the licensee

committed the resuurces necessary to address the issues, and the

!

technical approaches were sound.

Further, there was frequent

,

communication initiated by the licensee to determine what

e

information, if any, would be required by the staff. -Top level

-

management involvement was evident throughout the period..

With regard to the license amendn.ents, the licensee's submitthis

.'

consistent'ry showed a clear understanding of the safety aspects

.

of the tecnnical issues.

In.those instances where additional

,

'

information was requested, the licensee was responsive and

,

j

timely to the questions.

The licensee has taken a very conservative approach.in the

implementation of 10.CFR 50.59. screening criteria.- The licensee

"

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established a plant and safety analysis. group within the nuclear

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l

engineering departmeni in a major effort to reduce the likelihood

l

of an inadvertent change without a properly documented safety

.

l-

evaluation. This group provides an in-line review for all

engineering change notices and temporary modifications ~ prior to

,

the review by the plant Operations Review Committee (PORC).

This level of attention to issues associated with 10 CFR.50.59

,

ensures consistency in the content and quality of safety

evaluations.

l

Generally, licensee submittals are made sufficiently ahead'

of the required date. An exception to this is the recent

.

!

relief request from certain Appendix J, Type C, leak rate. test

!

schedules.

-

The licensee submitted 48 licensee event reports (LERs) for

Units 1 and 2..

The LERs were well written and issued in a

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timely manner. A review of reports required by 10 CFR 50.72

indicated that appropriate events were subsequently addressed by

'

an LER.

During this rating period, the licensee's responsiveness to

NRC Bulletins and generic letters continued to be technically

complete and generally timely. Responses to-IE Bulletins 88-10,

• Nonconforming Molded-Case Circuit Breakers," and 88-11. -

" Pressurizer Surge Line Thermal Stratification," were perticularly

'

y

thorough. The licensee was the lead plant in resolving the.

1$$ues raised by the staff in IE Bulletin 88-11.

The licensee

-

responded to e total of six bulletins and 12 generic letters.

=

Generic Letter 89-21 required licensees to provide the status of

implementation of unresolved safety issues.- The response was

accurate and timely, and the backup records retained by the

licensee for each=1 tem were well organized and traceable.-

,

!

Inspection of the quality assurance program found that changes.

i

made to quality assurance implementing procedures since the last

NRC inspection wert both timely and consistent with the Updated

,

Final Safety Analysis Report and the TS.

Satisfactory program.

l

requirements and implementation were noted with respect to

'

design changes and modifications, records, document control,

i

audits, 10 CFR Part 21, and reccipt, storage, and handling of

equipment and materials. Weaknesses, as noted in the engineering

and technical support section of this report, were observed in

the procurement' program during this SALP period.

Inspections-

during this SALP period have identified that the' licensee

consistently performs complete and thorough investigations of

l

the root cause of reactor trips and equipment failures. Of

particular note during this period was the excellent manner in

which the licensee responded in its analysis of the Standby

Diesel Engine No. 22 failure and management'of _ repair and

recovery activities.

Inspection of licensee self-assessment activities during this-

SALP period identified overall effective performance by-the

1

Nucler.r Safety Review Board.(NSRB) and the plant.PORC. NSRB

meetings were well documented and the resolution of concerns was-

generally effective. An exception pertained to a lack of timely

_ ,

resolution of certain unreviewed safety question evaluations

which had been referred back to the PORC for additional

i

infonnation. The licensee immediately corrected this problem in

the course of the NRC inspection.

PORC meetings were also well

documented, with indepth discussion of agenda items and effective

t

followup on required actions. -Review of Independent Safety.

Engineering Group (ISEG) activities indicated that assessments -

were detailed and thorough in ' approach, with some documentation

-

deficiencies noted.

.

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25

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.

The licensee decided to conduct safety system functional

inspections (SSFIs) of key safety systems.

In addition, the

licensee completed and sent to the staff a Level I performance

rating analysis.

Both of these items are considered examples of

>

proactive licensee initiatives as well as positive indications

<

of the management attitude towards safety.

,

I

The licensee continued to communicate safety issues to the NRC -

,.

staff in a. timely, complete manner.- Strong management

i

involvement regarding a commitment to safety and resolution of

complex safet'. i. sues was apparent.

The licensee's audit and

safety assessit.ent programs ' identified . meaningful program -

-

strengths and weaknesses which resulted in the licensee taking

corrective actions.

2.

Performance Rating

I

The licensee is considered to be in Performance Category 1 in

'

this area.

,

3.

Recommendations

'

a.

NRC Actions

?

!

NRC inspection effort should be; consistent 'with the

-

fundamental inspection program.

'

b.

Licensee Actions

The licensee should continue to provide high quality

safety reviews and project a strong safety- attitude to

.t

all plant personnel.

l

.

V.

SUPPORTING DATA AND SUMMARIES

'

.

'

i

A.

Licensee Activities

t

1.

Major Outages

Unit 1

01/20/89 - 03/08/89 Bottom mounted instrumentation (BMI)

measurement and generator repair

,

08/04/89 - 10/15/89 First refueling outage-

Unit 2

11/03/89 - 01/15/90 BMI measurement, maintenance, and

repair of No. 22 diesel generator

2.

Power Limitations

None

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,

.

.

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26

. . -

3.

MeenseAmendments

During the assessment period, there were nine operating license

amendments for Unit I and three operating license amer.cments for

Unit 2.

4.

Significant Modifications

None

B.

Direct Inspection aid Review Activities

~

NRC inspection activity during this.SALP cycle included 48 inspections

performed with~approximately 4,300-direct inspection hours expended.

C.

Enforcement Activity

The SALP Board reviewed the enforcement history'for the period

4

January 1,1989, through January 31,.1990.

This review included'

'

deviations, violations, and emergency preparedness weaknesses and

-

deficiencies tabulated by SALP Category.

.

D.

Confirmation of Action- Letters

l

None

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TABLEr

ENFORCEMENT ACTIVITY-

-(Includes Both STP-I.and STP-2)

.

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' ' TONDT10NAL

NO. 0F VIOLATIONS

,

AREAD

-IN EACH LEVEL

WEAKNESS.

V:

IV DIII' II I'

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A '.' -

Plant-Operations-

2

B. '

Radiological

'1'

Controls

C.

Maintenance /.

5

- Surveillance

D.

Emergency-

4-

'

Preparedness:

'

- E.

Security

5'

F.

Engineering /-

~7

Technical Support

' G.

Safety Assessment /

Quality Verificaticc-

---

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- TOTALS-

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