ML20043H740

Forwards Initial SALP Repts 50-498/90-06 & 50-499/90-06 for Jan 1989 - Jan 1990,including Summary & List of Attendees at 900425 Meeting Re SALP Board Rept & 900509 Response to Initial SALP Rept

ML20043H740
Person / Time
Site:	South Texas
Issue date:	06/20/1990
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hall D HOUSTON LIGHTING & POWER CO.
References
NUDOCS 9006260389
Download: ML20043H740 (3)

See also: IR 05000498/1990006

Text

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i' AM 20150 .in Reply Refcr.To: Dockets: 50-498/90-06 50-499/90-06 Houston Lighting & Power Company ATTN: Donald P. Hall, Group V'ce President, Nuclear P.O. Box 1700 Houston, Texas 77251 This forwards the final report of the Systematic Assessnent of Licensee Perfonnance (SALP) Board Report for South Texas Project-(STP), Units 1 and 2,. for the period of January 1,1989, through January 31, 1990. This final report includes: 1. The initial SALP Board report. 2. A sunanary of and a' list of attendees at our April 25,1990, meeting at STP to discuss the SALP Board report. 3. Your May. 9,1990, response to the initial SALP report. In accordance with Section 2.790 of the NRC's " Rules of Practice " Part 2 Title 10 Code of Federal Regulations, a copy of tais letter will be placed in the NRC's Public Document Room. Should you have any questions concerning this matter, o will be pleased to discuss them with you. Sincerely, Original Signed lly, d , ()1, 111 tit OIM Robert D. Martin Regional Administrator Enclosures: 1. Initial SALP report 2. Meeting sunmary and list of attendees 3. HL&P repsonse to the initial SALP report cc w/ enclosures: Houston Lighting & Power Company ATTN: M. A. McBurnett, Manager Operations Support Licensing P.O. Box 289 / Wadsworth. Texas 77483 / RIV:DRP/D tMRI

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l , , ' Houston Lighting & Power Company- -2- i a City of Austin Electric Utility ATTN: J. C. Lanier, Director of Generation ! 721 Barton Springs Road ' Austin, Texas 78704 City Public Service Board - ATTN R. J. Costello/M. T. Hardt P.O. Box 1771

San Antonio, Texas 78296 Newman & Holtzinger, P. C. i . ATTN: Jack R. Newman, Esq. L f 1615 L Street, NW Washington, D.C. 20036- Central Power and Light Company ATTN: R. P. Verret/D. E. Ward P.O. Box 2121 Corpus Christi, Texas 78403 INPO Records Center 1100 Circle 75 Parkway Atlanta, Georgia 30339-3064

c Mr. Joseph M. Hendrie 50 Bellport Lane . Bellport, New York 11713 , Bureau of Radiation Control State of Texas 1101 West 49th. Street Austin, Texas 78756 Judge, Matagorda County ! ' Matagorda County Courthouse 1700 Seventh Street !. Bay City,' Texas 77414

Licensing Representative ' Houston Lighting & Power Company Suite 610 Three Metro Center Bethesda, Maryland 20814 . , - 6 >

,< .. Houston Lighting & Power Company -3- Houston Lighting & Power Company ATTN: Rufus S. Scott, Associate General Counsel P.O. Box 61867 Houston, Texas 77208 U.S. Nuclear Regulatory Commission ATTN: Resident Inspector P.O. Box 910 Bay City Texas 77414- U.S. Nuclear Regulatory Consnission ATTN: Regional Administrator, Region IV 611 Ryan Plaza Drive. Suite 1000 Arlington, Texas 76011 bectoDMB(IE40) bec distrib. by RIV: R. D. Martin Resident Inspector DRP(2) SectionChief(DRP/D) DRS MIS System DRSS-FRPS Lisa Shea, RM/ALF RIV File R. Bachmann, OGC RSTS 0)erator ProjectEngineer(DRP/D) G. Dicc. NRR Project Manager (MS: 13-D-18) ChairmanCarr(HS: 17-D-1) Records Center, INPO CommissionerRoberts(MS: 16-H-3)) 18-H-1 RRIs at all sites Comissioner Rogers (MS: G. F. Sanborn, E0 CommissionerCurtiss(MS: 16-G-IS) C. A. Hackney, RSLO 17-G-21)) Conynissioner Remick (MS: 16-G-3 A. B. Beach, D:DRSS J.M. Taylor,ED0(MS: L. A. Yandell, DRSS J. M. Montgomery B. Murray, DRSS J. T. Gilliland, PA0 D. A. Powers DRSS l l ,

h .' .. ENCLOSURE 1 .! I r

! ! . O INITIAL SALP REPORT l > - I V.S. NVCLEAR REGULATORY COMMISSION . ' REGION IV 1 SYSTEHATIC ASSESSMENT OF LICENSEE PERFORMANCE a 50-498/90-06 i 50-499/90-06 i

Houston Lighting & Power Company

South Texas Project, Units 1 and 2 January 1,1989, through January 31, 1990 ' , [ k e 9 ) . . i .

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' I. INTRODUCTION The Systematic Assessment of Licensee Performance ($ ALP) program is an l integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis ' of this information. The program is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of their facility's ! performance in each functional. area. An NRC SALP Board, composed of the. staff members listed below, met on March 1, 1990, to review the observations and data on performance and to assess licensee performance in accordance with Chapter NRC-0516, , " Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section 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 l at South Texas Project, Units 1 and 2 (STP), for the period January 1, t 1989, through January 31, 1990. The SALP Board for STP was composed of: Chairman S. J. Collins, Director, Division of Reactor Projects, Region IV Members I C 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 t Special Projects, Office of Nuclear Reactor Regulation (NRR) 1 E. J. Holler, Chief, Project Section D, Division of Reactor Projects, j Region IV 1 J. I. Tapia, Senior Resident Inspector, Region IV G. F. Dick, Jr., Senior Project Manager, Project Directorate IV, NRR 1 The following personnel also participated in the SALP Board meeting: W. B. Jones, Senier Project Engineer, Region IV i R. J. Evans, Resident Inspector, Region IV J. F. Rogge, Regional Coordinator, Office of the Executive Director for Operations ' . . ) . - - - . - - . .. - -- - . . - ~ , .

__ . , ay . ;- , ! f 1. i 3 i ' ' , ! II. SUMMARY OF RESULTS

A. Overview ! STP is a plant with strong management involvement, good operating experience with Unit I and startup experience with Unit 2, and a i 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 i has had a number of problems not atypical during the first year of - operation. The licensee has demonstrated its ability to resolve , these problems with the appropriate concern for safety. . Performance i in the area of plant operations increased from a Category 2 to a j j Category I rating and reflected effective management involvement and a well trained, professional operations staff. The Category 2

improved rating in the radiological controls area reflected a well

managed program adequately handling the problems associated with the- f startup and first refueling outage of.a new plant. The Category 1 l performance in the maintenance and surveillance area was characterized t l. l by sufficient staff and good programs, offset by personnel errors early in the SALP period. Strong oerformance in the security area . resulted in an increase from a Category 2 to a Category I rating, ! Performance in the engineering.and technical support area reflected I good success in resolving a number of significant engineering problems and wat. assessed a strong Category 2. Category 1 performance ' in the safety assessment and quality verification area reflected 3 continued strong management involvement regarding, a committrent to safety, resolution of complex technical issues, and good communications with NRC. 1 . . Although programs assessed at Category 1 performance level are eligible for reduced inspection effort by the NRC, we will continue i the fundamental inspection program at your facility due to the near-term operating license, status. Functional Area Previous Performance Present Performance , Category (01/01/88 to Category (01/01/89 to

12/31/88)- ~61/3:l/90)

1. ' Plant Operations 2 1 , 2. Radiological 2 2 Improving , Controls i 3 Maintenance / 2 1 i Surveillance 4. Emergency 2 2

' Preparedness 5. Security 2 1

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. i 4 Functional Ares Previous Performance Present Performance ~~ Category (01/01/88'to Category (01/01/89 to ' ~ 12/31/88) 01/31/90) 6. Engineering /- 2 2 , Technical Support ' 7. Safety Assessment / 1 1 ' Quality Verification III CRITERIA , t Licensee performance was assessed in seven selected functional areas. ' Functional areas normally represent areas significant to nuclear safety ~ and the environment. , The following evaluation criteria were used, as applicable, to assess each functional area: A.. Assurance of quality, including management involvement and control; B. Approach to the resolution of technical issues from a safety standpoint; C. Responsiveness to NRC initiatives; l ' D. Enforcement history; E.- Operational events (including response to, analyses of, reporting-

of, and correct'ive actions for); F, Staffing (including management); and k G. Effectiveness of training and qualification-program. { However, the NRC is not limited to these criteria and others _may have been used where appropriate. , On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of. j these perform.ance 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 effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriate. Category'2 - Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The l . . . . .

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7 , 5 . licensee has attained a level of performance above that needed to meet l -regulatory requirements. Licensee resources are adequate'and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal levels. Category.3 - Licensee management attention to and involvement in the performance of nuclear. safety or safeguards activities are not sufficient. ~ The licensee's performance does not significantly exceed that necaed to meet minimal-regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal levels.

, This SALP report includes an appr'aisal of performance, trends in c.ertain functional areas. Determination of.the performance-trend was made selectively and was reserved for those instances when _it is necessary to focus NRC and licensee attention on an area with a declining performance trend, or to acknowledge an improving trend in licensee performance. 1 i The trer.d, if used, is defined as: Improvino: Licensee performance was determined to be improving during the assessment period. De_c11ning: Lie:ensee performance was determined to be declining during the assessment peried und the licensee had not taken meaningful steps to address this pattern. IV. PERFORMANCE ANALYSIS l A. Plant Operations ' 1. A_njLysis l This functional area consists chiefly of the control and execution of activities directly related to operating a plant, 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 j professionalism. j , This area was inspected on a continuous basis by resident and region-based inspectors and by an Operational Readiness Assess.nent Team (CRAT). , i 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' testing was conducted successfully. Observations of the licensee's preparation for achieving initial criticality n ,

._ - , ,* +< 6 indicated a planned program that reflected management attention. The reactor performance staff displayed extensive knowledge of core physics parameters and test procedure requirements. The Unit' 2 startup program, including low power physics testing, was performed in accordance with the licensee's procedures to verify compliance with the Technical Specificatien (TS),

Section 14 of Final Safety Analysis Report (FSAR), and vendor l design criteria. . The test program procedures were well organizad ' and test results packages clearly stated how acceptance criteria , were satisfied. Low' power physics testing was performed in a ' systematic and carefully planned manner. The licens2e safely completed necessary testing requirements for the power ascension program. The operators exhibited an excellent knowledge of plant systems and procedures during these plant operations. The ORAT, conducted March 13-17, 1989, identified strengths 1 in the licensed operators' abilities and professionalism, as ' well as management's involvement and oversight of operational i activities. Weaknesses were identified in procedure compliance . control of temporary scaffolding, control of fire and locked

doors, control of combustible material, steam and watre leaks, i equipment nomenclature inconsistencies with procedores, and control of compressed gas cylinders. The licensee has implemented corrective actions for the above weaknesses. A long-term procedure upgrade program is presently ongoing. The plant operations staff exhibited a professional attitude in the operation of the plant throughout this assessment period.

The licensee utilized a five-shift (8-hour / shift) rotation, i Each shif t was properly manned with a higher proportion of i senior reactor operators (SR0s) to reactor operators.(R0s) than , required. The shift scheaules provide for a rotating week of formal classroom training for each of the five crews. Some mandatory overtime for the shift supervisors has been required to meet procedure upgrade schedule commitments. The licensee has continued their support for the University of Maryland college degree program for its licensed operators. 4 Plant management made frequent tours of the control room and 1 plant. l The operating staff consistently exhibited a high level of ,l 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

turn, led to an increase in the level of staff professionalism. { During this assessment period, the licensee successfully performed two midloop operating evolutions-during the first Unit I refueling outage. New operating procedures were generated

_ _ _ _ .a .. , , j i 7 to-support the first reactor coolant system midloop evolution in accordance with the requirements of Generic Letter (GL) 88-17. The actual operation at midloop was a well planned activity carried out by highly skilled operators. l 1 There were no reactor. trips resulting from operator error during j this assessment period. Fifteen reactor startups were completed

without personnel error. The licensee routinely demonstrated i conservatism when a potential-for. safety significance existed. 1 As a result of a Unit'2 trip caused by an inverter circuit i failure, the licensee initiated a plant reliability improvement 1 program to determine the cause of all previous plant trips and to identify possible single failures in the secondary plant i which might cause future plant trips. Of the 3 Unit 1 trips and , 9 Unit 2 trips,10 were attributed to equipment failure. The , 2 remaining trips resulted from improper performance of ] surveillance tests. The review also disclosed that 8 of the i trips were the result of balance-of-plant (BOP) initiated i events. Several single _ point failure conditions which could cause a reactor trip were identified. Twenty-three design ', changes were initiated which, when implemented, will individually serve to reduce the likelihood of a plant trip. Four of these changes were immediately implemented. In addition, the licensee determined that a loose-lead detection program and a BOP visual surveillance program were warranted for critical BOP controls. During the last SALP cycle, the Operations. Department committed to complete a general enhancement of all operating procedures in 3 response to concerns raised during an NRC emergency operating procedures (EOP) inspection. The concerns involved editorial ~ errors, inconsistencies in procedural content, and inconsistencies between procedure references and plant labeling. Licensee management actively tracked progress toward completion of this commitment. At the close of this assessment period, the i E0P upgrade program was on schedule at about 65 percent complete, The interdepartmental review and in plant walkdown validation of the revised E0Ps had been completed. The major item remaining to be completed is the simulator validation. .The off-normal operating procedures upgrade program was commenced during this , assessment period. ' 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 reactor power. For Unit 1, all scheduled work items except one , have been completed. .For Unit 2, all work items have been defined and are scheduled to be completed in 1990, l Weaknesses were noted throughout the SALP period regarding i general plant housekeeping. Early in the period, inspectors

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, . - . . F ! g 4 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 i loose paper, dirt, and other items. . There also appeared to be . an absence of attention regarding housekeeping efforts in more frequented parts of the plant such as the emergency diesel generator rooms and in the radiologically controlled parts of .' the plant. The licensee appears to have adequate resources'and appropriate management involvement regarding their ability > to operate two units safely.. The licensee exhibited strong performance.with Unit I 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. 2. performance Ratina The licensee is considered to be in Performance Category 1 in this area. 3. Recommendations e a. NRC Actions . NRC inspection effort should be cons. stent with the ! fundamental inspection program. b. Licensee Actions The licensee should continue to improve housekeeping efforts plant-wide. B. Radiological Controls 1. Analysis The assessment of this functional area consisted of activities directly related to radiological controls, radioactive waste management, radiological effluent control and monitoring, water chemistry controls, and transportat'on of radioactive materials. i The radiation protection program was inspected twice by region-based radiation specialist inspectors in addition to the routine inspections performed by' resident inspectors. The inspectors also reviewed an issue that was reported in ( , i .. - ~m- ,, >.c- ..e, . r. - -

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September 1989 involving the shipments of sewage treatment sludge containing possible low-levels of Cobalt-58 and -60 to an eff site disposal site. (The licensee could.have avoided this issue if- information provided in NRC Information Notice 88-22 had been implemented.) The radiation protection department staffing is considered appropriate to provide health physics support for a-two-unit facility. However, a shortage of radiation protection personnel . had been experienced at various times during this period which ! caused some minor delays during day shift work activities. The , permanent plant staff is supplemented with contractor radiation ' protection technicians during extended outages, but a heavy reliance is not placed on contractor support for routine plant operations. The staff consisted of a good mix of senior level technicians along with e number of professionals and supervisors

with strong health physics academic backgrounds.. A low turnover rate was experienced within the radiation protection department during the assessment period. . 3 A well defined training and qualification program had been established for personnel at the technician level. A plant systems course was included as part of the routine qualification program in order to provide radiation protection personnel a background concerning systems that could impact health physics job coverage. Supervisors and professionals attend periodic ' training, but an organized training program had not been established to ensure that these individuals maintain and expand expertise in their assigned areas. l The radiation protection program is well managed and receives

good support frm licensee management. In practice, functional

areas of respm sibility within the radiation protection ' department :.re well defined, although, in some cases personnel position descriptions were written in a guneral nature and did , l 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 und scheduling of plant activi*ies. Good working relationsnips exist between the radiation protaction department and other departments, such as operations and maintenance. Good quality assessment was evident by the conduct of- performance-based audits. These audits were designed to verify compliance with approved plant procedures.- Audit effectiveness 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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y3 g .; :.: . 10- Some areas for improvement were ' identified with the ALARA- program. . The program was addressed in several separate department procedures, in lieu of.an ALARA manual. A full-time- ALARA coordinator had.been assigned to handle ALARA activities, however, staffing was minimal to handle the work 1 cad at the two-unit site. - The ALARA program was: designed to address major -outage activities but did not. include such programmatic features as source term evaluations,, corrective actions for chronic -radiation-sources,,such as_ overhead pipes'and-drains ner.r. personnel access-routes; nor<the use of chemical decontamination techniques. 1 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 engineer.ing support. group, _ This design change involved several penetrations made in the fuel handling _ building which were in line with the fuel transfer. y tube. The licensee's response was to provide adequate' shielding 3 for the penetration and to ensure that-proposed design changes I will receive ALARA review and; approval.f ! The licensee was aware of the ALARA program shortcomings ind- had initiated actions to improve this-area. The licensee had j established an aggressive 100. person-rem goal for 1989. The i actual. exposure was about 160 person-rem, primarily because of-~

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unexpected work activities occurring-during'the refueling- outage The low: person-rem received during 1989 is a-good 1 - indication of an effective radiation protection program. In general, radiation protection activities. associated with the first refueling outage were performed in an acceptable ! manner. Some problems were observed concerning placement of . j step-off pads and theLt'ype'of-clothing being worn by personnel ' working in the contain' ment' building. The licensee demonstrated. good judgement in the resolution'of technical issues. Two i , examples invol_ved the identification and shielding of radiation streaming from penetrations in' the fuel handling building and ! , radioactive contamination.found in the inorganic basin and- 1 sewage _ sludge. - ; t The radiochemistry and water chemistry programs were inspected ' once during the' assessment period. This included confirmatory. measurements of plant liquid and gaseous samples and certified 4 standards. _The radiological, confirmatory measurements involved- separate counting laboratory facilities = for radiochemistry and health physics at each unit. The licensee's results for Unit I and Unit 2_ indicated very high agreement with NRC analyses results consistent'with>those achieved during the previous 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 ' . .

. __ _ _ _ _ . _ _ . . , s ., y ? 11- wrmunt period. ThelicenseehadimplementEdanimproved m e<'M. oratory and intralaboratory quality control. program for nmistry technician performance evaluation. .This' program- , has proven to be a strength in the chemistry and radiochemistry ] programs as shown by their confirmatory measurements performanen ' '. during this assessment period. The Electric Power Research' Institute.(EPRI): chemistry parameter guidelines along with'the Westinghouse chemistry specifications are specif.ied in plant: procedures and strictly followed. The, staffing; training,:.and qualifications for the chemistry and radiochemistry programs are. appropriate to support'a high quality program. The personne1' turnover rate for these areas was low. Comprehensive quality assurance audits were performed to determine compliar,ce with established procedures. No problems were identified concerning -L the response to in-house audit findings, -esolution of technical: - issues, and responsiveness to NRC initiatives. i The radioactive' waste management program was inspected twice during the assessment period. The licensee had implemented ' ~a program that demonstrated compliance with the Radiological- Effluent TS (RETS), the offsite dose calculation manual (00CM), and the process control program (PCP)., Liquid and gaseous- release permit programs had been implemented to ensure that proper. review was completed prior to-making planned releases.- The areas of staffing and personnel training and qualifications- are considered adequate to implement a radioactive waste

management program. The personne1' turnover rate for this area was low. The licensee had conducted a quality assurance audit of the radioactive waste management. area. All identified audit 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 implementing procedures had been issued and the program appeared to be well managed.

The radiological-environmental monitoring-program was not inspected during this assessment period. The licensee's radiological program has been shown to_be effective and is continuing to improve. The radiochemistry and water chemistry' programs are characterized by good facilities and well implemented programs.- Additional strengthening of the 'ALARA program should be considered to ensure that complex { radiological situations are properly evaluated and controlled. - 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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.' w . . . . i 12- i a 3. Recommendations a,- NRC Actions - ! NRCzinspection effort should be consistent with the [ fundamental inspection program. , ' . Regional initiative inspections should be' performed in 1 !. the ALARA area. ' q b. Licens&e Actions ' ,

i ' Efforts should be considered to enhance the ALARA program. -C. Maintenance / Surveillance + ' 1. Analysis. 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 modificat %ns; and maintenance of the plant. physical

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condition. It included conduct of all-' surveillance and inservice

inspection (ISI) and testing (IST) activities.- 4 The maintenance / surveillance' functional area was inspected i routinely by the resident inspectors, periodically by the regional inspectors, by a system' entry retest-team (SERT)- , _ inspection, and by an initial (l' week) maintenance team

inspection (MTI). l

During this assessment period, the-maintenance departm'ent L successfully supported the completion of the first' refueling " l outage in Unit I as well as outages'in both units conducted ! to inspect reactor vessel bottom mounted instrumentation.' . ! - l- The licensee's actions in meeting GL 88-17. " Loss of Decay Heat ! ' 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 4 plan of action during this assessment period. This program i resulted in a reduced and more focused scope of the PM program , and;a reduced PM deferral rate trend. ' , The licensee has initiated an aggressive program to reduce '

the backlog of preventive and corrective maintenance tasks. ); In this respect, the licensee has established a Contract Craft l' . , , e._, c ,--s-- --

6' ~ - ' i ' < . , -t 9W.s.- .: = ' , , , . 't o - , , o ~13 , w Support Group to address open maintenance items, ~This group l numbers approximately 100 people, of which 45 are craftsmen who ! ' are to augment the existing licensee mai_ntenance department with' , the remainder comprising the Contract Craft Support Group, whose

L I~ sole function will be to reduce the outstanding backlog of low I priority work. ,

, c ! ' The licensee has a strong program for determining the.need for a retest and identification of appropriate retest type. Also,' y

good procedures were developed and implemented for= ! postmodifications and'postmaintenance retests.; A minor weakness was identified in that there were no documented guidelines for ' identifying and' developing needed integrated systems poststartup retests for extensive modificatio.ns. t

. , The licensee has an effective work order control-system which

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utilizes a data base containing previous work experience and L equipment history. A new work process program was implemented ' during the assessment period. This program served to clarify >

individual responsibilities and requirementf 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. ' g The maintenance department conducted a'self-assessment which . resulted in.'144 findings 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 ' < effort. t l- Two reactor trips resulted from improper surveillance activities' 1

(personnel error). A plant reliability program was develeped.to i.

identify potentially vulnerable components which could cause<a reactor trip. Design changes were' initiated and. additional 4 ' surveillances implemented for critical BOP equipment. ' , 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

4 as scheduled with. high quality procedures. Inspectors observed L that a large filing. backlog caused slow retrieval of data

packages and there were several instances of failure to provide , an adequate justification for determining that data entry was. o , "not applicable." ' 4 Inspections of Units 1 and 2 IST program activities found that- the test procedures comprehensively addressed ASME Section XI l , . , , ,, - . . , _ . , ,# ~ .

, , , . 1 , i. 14- Code requirements, reference' values, and acceptance criteria. - Operations personnel demonstrated alertness to procedural details and, knowledge of system prformance requirements. Review of Unit 1 ISI activities found a'well organized and written !SI~ plan,-' appropriate administrative controls for repair . and replacement' activities, and satisfactory performance of- ISI examinations.. A noncited violation was identified regarding the

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 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 the NDE program. , Inspection of welding activities < revealed weaknesses in program; implementation, as evidenced by the-identif.ication of violations -pertaining:to the failure to monitor in process welding parameters, and the observed commingling of welding materials in. . storage ovens. Licensee performance in the maintenance and surveillance area was characterized by sufficient staff-and good. programs, offset by personnel errors early in the SALP period which were. subsequently corrected. Strong management involvement resulted in-successful completion of,the Unit I first refueling outage, including preparations for comple'x maintenance activities; 2. Performance Rating 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. I

__ _ _ _ _ _ l . ' ' ~. ; * ' i l . 15 , j D. Emergency Preparedness

1. Analysis The. assessment of this functional area includ !' >;tivities

related to the establishment and implementation of the emergency plan and implementing procedures,. licensee performance during exercises and actual events that test' emergency plans, and interactions with onsite and offsite: emergency response. i organizations ~during exercise and actual events. - During the assessment. period, region-based and NRC' contractor i inspectors conducted ltwo emergency preparedness inspections. The first inspection consisted of the observation and evaluation of-the annual emergency response exercise. The second' inspection involved a review'of the opertaional status , program. 1 During the emergency response exercise' conducted in , April 1989, a significant weakness was. identified in that the licensee underestimated the offsite doses associated with the 1 given scenario. This underestimation of-the dose projections occurred because theLlicensee had not programmed the computer for dose assessment calculations.to account for core degradation

t

indications from the high-range containment radiation-monitor. ' Another weakness identified was the clicensee's inability to 1 demonstrate timely and effective personnel _ accountability during l and after the site evacuation. This was a repeat 1 weakness _from ! the previousfl988 exercise and recurred.as a resultiof_the l licensee's failure to identify all the factors that contributed to the delay of personnel accountability in the'1988 exercise. The emergency preparedness inspection of the. licensee's operational. status program identified two problem 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).

'i l 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 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 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. [ , I 1 --. - < v - 4

,# ' , c, . j - 16' l . t The inspectors also identified that the licensee had not established the necessary controls over equipment and supplies 1 within the TSCs.- There werefquestions raised about.the- .; availability of TSC equipment and supplies to support a fully . 1 ' functional TSC within the required 60 minutes.. This problem had- t been identified by the licensee several. months prior to the

inspection,. but the~. licensee's prioritization ~of issues prevented l the. intended corrective action from'being implemented in a timely ' manner. The.above issues; indicated a need for. increased management ~ involvement to: ensure that responders are properly trained and that problems with' potential safety' impact are identified and- j corrected. ( - During this appraisal' period, the NRC inspectors observed good , performance in the, control ~ room, technical support _ center,-and ! operations support center. . Also, it appeared that the licensee 3 maintained'a wells qualified and experienced staff in their

emergency preparedness and emergency response organizations. .; Apart from the technical support' centers, other emergency.

response facilities, such as theLeontrol room and the emergency operations facility,.were found to have excellent: layouts.with r - readily available equipment to enable efficient implementation

- of-the emergency-response. functions.- ' During the course of the assessment period, the;1icensee corrected or implemented corrective measures to resolve the - 4 self- and.NRC-identi_fied weaknesses. The independent audit conducted by the licensee's quality-assurance department was ( found to have been enhanced by the use of. additional. emergency 4 preparedness expertise-from outside of'the licensee's organization. It is notable that the licensee has.taken the initiative to make. preparations for conducting'a_ . , J performance-orientated audit of the emergency preparedness program during 1990. l Despite the repe ' .kness involving accountability, the - licensee's apprca to. resolution of exercise weaknesses t demonstrated a clear understanding and control of the. issues. -

Moreover, the licensee's approaches were generally thorough and ! technically sound. The. issues identified during the annual exercise and the D, 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 y level of operational readiness to protect the health and safety '

4 e , e ,, ,w-, .- a-, --e- , - - a.- -,- - , ,-

. _ _. , .; p.-. , 'I a

, 17. .:

, 1 of the public. Continued refinements are needed before the licensee's emergency. preparedness program will reach full 'q operational maturity. - ,i 2. Performance Rating - The-licensee is: considered to be in Performance Category 2 in this area.s 3. Board Recommendations 1

a.- Recommended NRC Action- , , 1 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 j ! ManagementLattention to the implementation of the emergency preparedness program should consider the weaknesses identified and a review of corrective. action prioritization. ' E. Security 1. Analysis This functional area includes'all activities that, ensure the ^ security of the plant, including a11' aspects of access control, , security background checks, safeguards information protection, ! and fitness-for-duty activities and controls. ' - 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 identified several violations-of,the Physical' Security Plan (PSP)- j and procedural requirements. The-violations identified involved: ! inadequate compensatory measures, inadequate; control.of licensee- designated vehicles, inadequate lock and key: control, and inadequate protection of safeguards information. The previous SALP period analysis 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. attributable to a security program weakness. These violations q involved fr.ilures by the plant personnel to maintain control. over bacy , and-licensee designated vehicles. All of the . violations were p.'operly reported by the 1-icensee. . - . . . - - - .. -. -,

a c . ; : .E . __ , m 18-

During the assessment period, a preoperational=NRC inspection for Unit 2 included those security systems common _to both. units. _ 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 j exceeded.the regulatory requirement by conducting _ vulnerability testing'of'all security' systems- The licensee's maintenance- . . program has' ensured lthat security systems receive prompt and efficient ettention.- Licensee management has demonstrated a strong-commitment to - the implementation of the security program. :The security, management staff. is professional', knowledgeable, and well -organized to provide maximum support-for.the security force.. All technical issues were quickly. identified and resolved.- Al_1 NRC issues were'promptly addressed and appropriate action- taken. In. response.to the= threat of vehicle land' bombs, the- licensee conducted extensive- planning.for the-contingency and completed construction of one vehicle denial system, - t The security force' has an appropriate- number of. personnel that appeared-to be well-trained end dedicated to performing _their security f. unction;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 security program. 2. Performance Rating lhe licensee is considered to be in Performance Category 1 in this area.

. - ... . " a ,i., . . . - \\ 19

> f 3. Recommendations ' - a- Recommended NRC Actions. . t ' The-NRC. inspection effort should be consistent with the core-inspection program, b. Recommended Licensee Actions t Licensee management-should: continue to provide strong . ' support to=the security program. F.- Engineering and Technical' Support 1. Analysis The purpos'e 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 configuration management. ~ ' ! This functional area was inspected onfan ongoing. basis-by the i resident inspectors-and periodically by.the region-based inspectors.- ' During this assessment' period, plant engineering personnel l 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 outsges for - . both units, Unit I refueling outage steam-generator work. Diesel Generator No. 22 recovery, and the Unit 1- extraction: steam bellows failure recovery. These efforts:were well 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.thefprojected schedule. ! ' An example of plant engineering personnel attention?to-detail and plant safety was the identification of the safety-injection system surveillance' test anomaly and the resulting suspension of the Uriit I startup. This action was subsequently , commended by~NRC Rs 'fon'IV management in a' letter to the licensee. ] In response to the Unit 1 turbine generator-fire which was

l

caused by the failure of a nonsafety-related component in BOP, ' e engineering generated a failure ~ mode and effec;,: analysis on- other nonsafety-related systems. This analysis was performed on 1 g 17 systems to determine if system design or a component failure 1 j , f . . 4.. . . . . .. .- - - . . .

. . -.; ;. .: 20 l ~ could affect overall_ plant. reliability. 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 program for use inLloose'or faulty electrical. connections which ! resulted'in the: identification-and repair of several electrical , connections reducing:the'potentiali for plant trips or equipment i malfunctionso ' l The-licensee initiated a: vendor technical manual 1 update program; d to=. incorporate outstanding amendments for' vendor-technical- j manuals.used by_ engineering,_o'perations, and maintenance.- A

otal of 338 manuals:were' reviewed during this SALP period. The l l'censee also established-a substantial' vendor drawing

i

enhancement program to upgrade substandard drawings identified j , ' -in the project document, control database.. This program verifies: J 'legibi.11ty and reproducibility of vendor drawings. Both~of ' ' these programs <are indicative'of a proactive approach by- , _ engineering in ensuring that: plant dats is maintained and 1 retrievable. During this SALP period, two station problem reports were issued I which identified the contamination ~of nonradio e tive systems ! because of cross-connection. The corrective actions taken i required a review 'of. systems for int'erfaces which could provide potential orelease points to' nonradioactive, systems or to ahe environment ,This review considered anticipated equipment- i failures and potential = system misalignment. As a result of.this y review effort, four design _ changes were proposed to reduce the. A contamination potential. ' In this SALP period, a Quality Engineering Group was established . - within the Support Engineering. Department ir an' attempt to 1 , identify and prevent problems before occurrence. This' group has i the responsibility of conducting internal strveillances to ensure that engineering programs and procedires are being followed.- . During this SALP period, the licensee initiated a design basis i document verification program for selected mechanical, J electrical, and instrumentation and control systems. The objective of this program is to provide comprehensive, ! retrievable, verified design basis source documentation and i assure that engineering personnel are cognizant of the-design, ' process used.and of the requirements and intent of.the original- design. This effort is a planned 4 year program that represents 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 -

, . , ,7 e . : c '1 c .( 21 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 I , maintenance activities were good,-and the' governing procedures . 'l forLthe overall'EQ program'were acceptable. The licenseeilacked i sensitivity regarding the operability of plant' components in; , that when thel qualification of tertain motor operated valves- < , (accumulator _ outlet valves) that Mere subjected to submergence.- became questionable, the' licensee Oiled-to relate the effect:of _ 1 1 this condition on the operability of the valves-and, hence, to- .; the effect on facility operations. .ProbbmsLin EQ appear:to ' > be attributable to a smail:EQ staff and heavi reliance.on - contractors.n Arother inspection'which was conducted during this SALP cycle dstermined that the' records--program was-satisfactory and found" tnat record retrieval was accomplisheci in a timely manner. . < Cther 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 _0ther inspections; identified errorsiand' weaknesses in procedures (EOPs, . A0Ps,; and Alarm . Procedures). The licensee's actions are generally conservative,-but there d M not appear to be evidence of:a critical self-assessment process - , regarding procedure details to-. identify l these types of prcblems. 4 i The licensee has maintained a successfulLl_icernd operator training program. The overall passing percentage for;R0s and: , SR0s is 86 percent,- The' plant simulator is 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 1 for examination purposes. The April 1989 examination indicated. - that progress had been made towards correctingLthese 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 has 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 I -.e w r . , - - - , e e - - - - - - -

_ , .= . - . - , -22 system engineers. Althoughithe system engineers have been in; - i place for several years, many of the individuals had not been provided' training on their respective plant systems. Inspections ofLthe STP procurement program have identified 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 .J controls and personnel-training, _-Inspections also revealed that .the procurement program.had not appropriately addressed. ~ commercial grade procurement and dedication requirements-in the o past. The licensee,has. recognized this weakness.and has developed program. requirements and instituted a review of prior commercial grade procurements - j 1 2. Performance Ratino. '! 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 regionaliinitiative team inspection should be conducted to nore fully evaluate' the licensee's engineering . . ' capabilities with focus on direct. support of operations, ' .naintenance, and testing. i i b. Licensee Actions The licensee should continue to provide management attention in order to improve and strengthen their engineering and i technical support capabilities. Additional efforts should

be made to improve the retrievability of EQ files and to ' resolve questions regarding past commercial grade - procurements. ! G. Safety Assessment /Ouality verification ' 1. Analysh The assessment of this functional area included all. licensee 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 licensee activities related to resolution of l l, di

_ _ _ _. . . - , h4 y + ' A , 7, , . 1 ~23' ! J ' . . . f safety issues, 10 CFR 50.59 reviews, 10 CFR.Part 21-assessments', , safety committee and self-assessment activities, quality , assurance / quality control . reviews, and -in. monitoring the overall s performance of-the plant. j ' . i This functional area was assessed on a continuing basis . throughout the period.. 4 During this period, the-full power license was, issued fori ' Unit 2. In' addition, there were nine: amendments / issued for:

- Unit 1 and-three for Unit 2. Notable amendments lwere the issuance.of combined TS'in concert with Unit:2 licensing.and the" staff approval of the use of silver-indium-cadmium controlLrods. Two of the license amendments-did not' involve changes to'the'TS but were the result of items' identified by the licensee's~50.59 program as unreviewed safety questions. - During the period prior to.the licensing of Unit 2,-there were. .j , several issues that surfaced late in the licensing process:that required resolution before licensing. In response, the licensee q committed the resources necessary to. address the issues, and the . ' technical approaches were . sound. - Further, there was frequent . ' communication initiated by.the licensee to determine what- information, if any, would be' required by the staff.- Top level 3 management involvement was: evident throughout'the period..~ ' W u regard to the' license amendments, the licensee's submittals consistently showed a clear: understanding of the safety aspects' 1 L of the technical issues.- In those-instances where additional. information was requested, the licensee was responsive and ' timely to the questions, j The licensee has taken a'very conservative' approach in the implementation of 10 CFR 50.59 screening criteria. The licensee t established a plant'and safety analysis; group within the nuclear engineering department in a major effort to reduce the likelihood of an inadvertent. change without a properly documented safety , evaluation. This group provides an in-line review for all i 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 i ensures consistency ir, the content and quality of safety '! evcluations. 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 writtea and issued'in a L . - -- - - - - aem . .m-- y - ,. ,_ 4 i --.... .y ww,.-9 i m- c

- - _ - - - . _ _ - - __ . - - _ , _ _ _ _ . . - - - _ _ _ - ._ _ - _ . - - . . . _ - . . '8 I i g. .;I^,'

. ! 24 [s timely manner. A review of reports required by<10 CFR 50.72- indicated that appropriate events were subsequently addressed by an LER. 4 . l During this rating period,- the licensee's responsiveness to NRC. Bulletins and generic letters continued to be technically _. 3 complete and generally timely.' Responses; to IT. Bulletins 88-10,

"Nonconfoming Molded-Case Circuit Breakers," ond 88-11, ) " Pressurizer Surge Line -Thermal Stratification,"were particularly~. i " thorough. The licensee was the lead plant'ik resolving the: . issues raised by the staff in. IE Bu11etir_88-11.. The licensee ' responded to' a total of- six Lbulletins and 12 generic . letters. 3 Generic Letter 89-21 required licensees to provide the status of. t implementation of unresolved safety issues. The response was i accurato and timely, and the backup records retained by the" 4 licensee for each item were well organized and traceable.. a Inspection of.the quality' assurance program found that changes- ( made to quality assurance implementing procedures!since the.last. t NRC inspection were both timely.and consistent with the Updated ~ l Final Safety Analysis Report.and the TS. Satisfactory program; requirements and implementation were noted with respect to i design changes and modifications'. records document control. . , . j audits, 10 CFR Part 21,'and receipt, storage, and handling.of equipment ud materials. ,Weaknerses, as noted in the engineering and: technical support section o' this report, were observed in , the procuremei t program during this ~ SALP period.L Inspections j during this SALF period have identified'that the licensee s" consistently perfoms compbte and thorough. investigations of .; 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 < , Nuclear' Safety Review Board. (NSRB) and the plant PORC. L NSRB ! meetings were well documented and the resolution of concerns 'was generally effective. An exception pertained'to a lack of timely 't resolution of certain unreviewed safety question evaluations- which had been referred back to the PORC for. additional infomation.- 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 followup on required actions. Review of Independent Safety- 1 Engineering Group (ISEG) activities indicated that assessments l were-detailed and thorough in approach, with some documentation

deficiencies noted. T _ . _ . , - . _ .-.. ... _m.....,..-.___,,,,.,--.m..._... . 1.,,, ,, . . . . - ~ . ~ . . . . . ._. _ . - - - . . -

q., e.. T 25 , i .

The licensee decided to conduct safety system functional

inspections (SSFis) of -key safety systems.' In addition, the licensee completed and = ant 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. ) The licensee continued. to communicate safety issues to the NRC staff'in a timely, complete manner. ; Strong management {' involvement regarding a commitment to safety and resolution of complex safety issues was apparent.- The. licensee's audit and safety assessment' programs identified meaningful program- > strengths and weaknesses' which resulted in the licensee taking. corrective' actions. , 2. Performance Rating The licensee is considered to be:in Performance Category 1 in j this area. 1 3. Recommendations i a. NRC Actions- NRC inspection effort should be consistent with the ' fundamental inspection program. b. Licensee Actions 4 The licensee should continue to provide high quality. safety reviews and project a strong safety. attitude to all plant personnel. ! V. SUPPORTING DATA AND SUMMARIES i A. Licensee Activities- \\ 1. Major Outages , Onit'l z01/20/89 -'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

-o '/ r ,_ .; - . _ _, t 9: 26 , - .i J3. License Amendments ' .During the_ assessment period, there were nine operating license amendments for Unit I and;three-operating. license amendments for Unit 2. 4., Significant Modifications' 'j l None. ,j , f B.- Direct' Inspection and Review Activities i NRC inspection activity during this SALP cycle inc1'uded 48 inspections: j ~ , performed with approximately 4,300 direct inspection _ hours expended, 1 '-

!

- .C.. Enforcement' Activity- -- , The SALP Board reviewed-the enforcement history forL the' period

' January 1,1989, through January 31 '1990 This review included. 1 . _ , . deviations,--violations, and emergency preparedness weaknesses and .i defziciencies : tabulated .by SALP Category. . '3 D.

Confirmation of Action Letters

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' Surveillance

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4- 3 . Preparedness L E. Security 5- ( .F. Engineering / 7

Technical Support . G. Safety Assessment /- Quality Verification ! -- TOTALS 4 20 i' . k i i I F . ) > - - . .a

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SALP PRESENTATION - SAMCOLLINSbDIRECTOR', 1 J LDIVISION OF REACTORS

. . _ . . . . ' , ! PROJECTS, NRC REGION IVi ' Li , . ,- , .? ) ,E , . ' ' HOUSTON LIGITING'8 POWER C0WANY1 LICENSEE MANAGEENT AND + 1 ? L. .,lf_ t . RESPONSE AND C0ftENTS LSTAFFi

o CLOSING REMARKS- -JOHN M. MONTGOTRY j ' 4

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<- p s 1 . t .? I .. f,yALUATIONCRITERIA- , ' 1. AS58RANCE OF 00ALITY, INCLUDING MANAGEfENT It#0LVEENT ' AND CONTROL 2. APPROACH TO IDENTIFICATION AND RESOLUTION OF TECHNICAL: - - 'lSSUES FROM A SAFETY STANDPOINT 3. RESPONSIVEfESS TO NRC INITIATIVES- 4. ENFORCEFENT HISTORY 5. OPERATIONAL EVEt(fS (It1CLUDING RESPONSE T0, ANALYSIS OF,- . REPORTING OF, AND CORRECTIVE ACTIONS FOR)- p . . 6. STAFFING (IflCLUDING MANAGEtB1T) ! 7 .~ .EFFECTIVEtESS OF 1 RAINING AND QUALIFICATION PROGRAM , , 1 ij

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" - u 3 _' l. D _' ' a .. , x , - ,. , . 'l I n .; SKT10NAL AREA PERFORMANCE CATEGORY , CATEGORY 1 j , , q LICENSEE MANAGEENT ATTENTION AND ltN0LVERNT ARE READILY -l ! e EVIDENT _ AND PLACE EWHASIS ON SUPERIOR PERFORf'ANCE OF 1 NUCLEAR SAFETY OR' SAFEGUARDS ACTIVITIES, WITH THE RESULTING j

. . '! PERFORflANCE SUBSTANTIALLY EXCEEDING REGULATORY REQUIREENTS. " LICENSEE RESOURCES ARE AWLE AND EFFECTIVELY USED S0 THATcA- lilGH LEVEL OF PLAfff AND PERSONNEL PERFORMANCE ~ IS BEING- -q q ACHIEVED. REDUCED NRC ATTENTION f1AY BE APPROPRIATE.- ' . '! ! i ) 1 1 ~ .. . ._-__--_J

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. , , .. . . , ,l ] .: CATEGORY 2

! LICENSEE-MANAGEENT ATTENTION TO AND IfN0LVEENT IN THE

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- PERFORMANCE OF NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES ARE 4 GOOD.- TE. LICENSEE HAS ATTAlfED A LEVEL OF PERFORMANCE ABOVE '! t THAT EEDED TO WET REGULATORY REQUIREENTS; LICENSEE' 1 c q RESOURCES ARE ADEQUATE AND REASONABLY ALLOCATED S0 THAT GOOD !l , , . . PLAfU AND PERSONEL PERFORMANCE * IS BEING ACHIEVED, NRC ~

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ATTENTIONMAYBEMAINTAINEDATNORMALLEVELS.- ' . i t 1 ! ! , ) -

,; . -- -. i ! ! 1 1 y CATEGORY 3: LICENSEE MANAGEENT ATTENTION TO AND INVOLVEENT IN TE .; I PERFORfMNCE OF NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES j ARE NOT SUFFICIENT. THE LICENSEE'S'PERFORfMNCE DOES NOTL - !

SIGNIFICANTLY EXCEED THAT NEEDED TO EET filNIMAL REGULATORY- i . REQUIREENTS,- LICENSEE-RESOURCES APPEAR TO BE STRAlED OR ] NOT EFFECTIVELY USED. NRC ATTENTION SHOU' 9 BE INCREASED) . . -N&mmES. y 1 .< '. - , ,-

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k e 6 - . ) TRENDS WHERE USED: , I If0 ROVING: LICENSEE PERFORPANCE WAS DETERMINED T011E ItPROVING DURING THE ASSESSTNT PERIOD, -DECLINING: LICENSEE PERFORt1ANCE WAS DETERMINED TO BE~ , DECLINING DURING TE ASSESSENT PERIOD AND THE LICENSEE- HAD NOT TAKEN EANINGFUL- STEPS TO ADDRESS THIS PATTERN, . , h 1 i . 1 i ,, I .

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' MANAGEENT ItN0LVEEffT AND ELL TRAINED, PROFESSIONAL OPERATIONS STAFF ' ! GOOD MAINTENANCE PROGRAMS OFFSET BY PERSONNEL ERRORS l

EARLY lil THE SALP PERIOD .; .

SIGNIFICANT PROGRESS IN ItPROVING THE SECllRITY. PROGRAM j

i,. C0fEITENT TO SAFETY AND RESOLifl10N OF C0fPLEX SAFETY l

ISSUES- , i i r 1 y l h , 'k

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ENRGEtCY PREPAREDfESS TRAINING OF RESP 0lERS - E0VIPIENT CONTROLS IN TSC - ,

ENGitEERING Af(D TECHNICAL SUPPORT E0FILESYSTEM - SYSTdM ENGINEER TRAINiilG - .. $ __ _ . , ,, ,

- .__--_ _______ . .: . , PLANT OPERATIONS CATEGORY 1 PROFESSIONAL ATTilllDE BY PLANT OPERAT10t1S STAFF

MANAGEtENT StPPORT OF OPERATIONS STAFF

MIDLOOP OPERATION WELL PLANT D

PLANT REll ABillTY ltFR00ENT PROGRAM

E0P UPGRADE- . RECatFNDED LICENSEE ACTION . CONTINUE T0 ifPR0/E HOUSDIEPING EFFORTS: - - . . . . . . . . .--.,.o. .. ,..

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. S RADIOLOGICAL CONTROLS CATEGORY 2 (llPROVING) , i " , ,

LOW TURNOVER RATE , , F\\* 7 - , . . - . TELL DEFILED TRAINiflG AND OUALIFICATION PROGRAM FOR

TEGINICIANS ' , ' * RAD 1001BilSTRY AND WATER OiEMISTRY PROGRAMS 0%RACTERIZED . BY GOOD FACillTIES AND WELL llPLEtDRED PROGRAMS ' REC 0FfENDED LICENSEE ACTION EFFORTS SHOULD BE CONSIDERED TO ENHANCE ALARA PROGRAM ! ~* , '

- - , - . - - . . . - - - - - , ...---i-.- _ _ _ _ _ _ _ _ ,. , .. MAINTENANCE /$11RVEILLANCE CATEGORY 1

PREVENTIVE MAINTENANCE PROGRAM ENHANCDENT PLAN MORE FOCUSED PM PROGRNi - REDUCED PM DEFERRAL RATE -

EFFECTIVE WORK ORDER CONTROL SYS191S

SllRVEILLANCES MISSED SURVEILLAliCES EARLY IN SALP PERIOD - PROBLEM CORRECTED / SURVEILLANCE TESTS PERFORED AS _. SC[DULED

STRONG RETEST PROGRAM REC 0ftENDED LICENSEE ACTIONS CONTINUE MAlfflENANCE AND SURVEILLANCE PROGRAM ENHANCEtD4T ACTIVITIES _ . . _ . . . . _ . - . . . . . .

rL....>. QERGENCY PREPAREDESS CATEGORY 2

WEAKESSES IN EERGENCY EXERCISE RESPONSE UNDERESTlfuTION OF 0FFSITE DOSES - INABILITY TO PERFORM TIELY AND EFFECTIVE PERSONNEL - ACCOUNTABILITY

WEN tESSES IN OPERATIONAL READIESS UNFAMILIARITY WITil DOSE ASSESSEf6 AND EERGENCY ACTION - LEVELS BY RESPONDERS LACK OF CONTROLS OVER EQUIPIBIT AND SUPPLIES IN TSC -

EXCELLETR EERGEf1CY RESPONSE FACILITIES, EQUIPENT EXCLUDING TSC.

DESPITE WEAKESSES, LICENSEE DEMONSTRATES UNDERSTANDING AND' CONTROL OF BIE ISSUES REC 0ftENDED LICENSEE ACTION i%NAGEENT ATTENT10ft SHOULD CONSIDER IDEtElFIED WENCESSES AND

A REVIEW 0F CORRECTIVE ACTION PRIORITIZATION. - - . . . , - - - , , , , , , , , , , , , , , , , , , , , , , , ,,v ,,

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. .;;lo ; ' ' . . . 1 . 'y ' . , , i I- i SFCURITY - CATEGORY 1-- . > f '- . MANACBENT DEMONSTRATED A STRONG C0mlTENT TO ' ' ' SEClRITY PROGRAM . SECURITY MNAGEENT STAFF IS PROFESSIONAL,

. , ,, ' KNOWLEDCEABLE, AND WELL ORGANIZED < , ' t " ' ' RECOMENnFD LICENOFF ACTIONS ' , MANACBDif SHOULD CONTINUE 10 PROVIDE STRONG SUPPORT ' o . ,

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. - . . - - - - , . . . .; o ENGINFFRING AND TECHNICAL SUPPORT CATE0GRY 2 g = ENGilCERING EFFORTS WERE WELL COORDINATED, HANDLED WITli STRONG.

ATTENT10f1 TO PLANT SAFETY ISSUES, AND RESOLVED SIGNIFICANT TECHNICAL ISSUES. - ,

SUCCESSFUL OPERATOR TRAINING PROGRAM

fl0 FORMAll2ED TRAINING FOR SYSTEM ENGINEERS ' a

PROGRESS i%DE IN CORRECTING SIMULATOR DEFICIENCIES

ItPRWDEhT IN PROCUREENT PROGRAM _

EQ FILE SYSTEM DIFFICULT TO USE. REC 0ftENDED LICENSEE ACTIONS

• -

EFFORTS SHOULD BE l%DE 10 ItPROVE AND MAINTAIN RETRIEVABILITY AND ACCURACY OF E0 FILES AND TO RESOLVE QUESTIONS ON C0ftERCIAL GRADE PROCURDENTS.

l , . . o, c SAFETY ASSESSENT/0UALITY VERIFICA110N i _ CATEGORY 1

CONSERVATIVE APPROACl1 IN IfPLEENTING 10 CFR 50.59 SCREENING CRITERIA

RESPONSES TO NRC BULLETills AND GEERIC LETTERS ARE TECHNICALLY COPPLETE Af4D TI E LY

OVERALL EFFECTIVE PERFORMANCE BY Tile NUCLEAR SAFETY REVlBl BOARD (NSRB), THE PLANT PORC, AND INDEPENDEf(T SAFETY ENGIEERING GROUP (ISEG)

STRONG MANAGEENT ltN0LVEENT REGARDING A C0tHITENT TO SAFETY AND RESOLUT10f10F C0ffLEX ISSUES REC 0lKf4DED LICENSEE ACTIONS

CONTINUE TO PROVIDE HIGH QUAllTY SAFETY REVIDG AND PROJECT A i STRONG SAFETY ATTITUDE TO ALL PLANT PERSONEL i - _ _ _ - _ _ _ _ _ -

.-- .-- - .. . _ _ _ _ _ _ _ . _ _ _ ,.o

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o ENCLOSURE 2 SALP MEETING ATTENDEES Name Affiliation C. Ayala HL&P W. Hamson HL&P R. Hernandez HL&P R. Munter HL&P W. Blair. HL&P M. Carnley HL&P L. Giles HL&P G. Parkey HL&P W. Berry HL&P D. Sanchez HL&P R. Cawthorn HL&P M. Berg HL&P A. McIntyre HL&P D. Keating HL&P T. Jordan HL&P M. Wisenburg HL&P W. Randlett HL&P P. Appleby HL&P R. Balrom HL&P S. Dew HL&P W. Kinsey HL&P J. Green HL&P D. Bohner HL&P J. Westermeier HL&P .G. Vaughn HL&P D. Hall HL&P M. McBurnett HL&P R. Chewning HL&P S. Rosen HL&P J. Loesch HL&P J. Lovell HL&P H. Bergendahl HL&P V. Albert HL&P B. O'Connell HL&P C. Walker HL&P D. Denver HL&P- D. Leazar HL&P S. Shropshire CPL J. Theis TX Dept. Health T. LeTulle Mayor of Bay City J. Montgomery NRC S. Collins NRC F. Hebden NRC J. Wiebe NRC J. Gilliland NRC G. Dick NRC J. Tapia NRC D. Persinko NRC H. Faulkner NRC R. Evans. NRC ..

, , , , . . , . ENCLOSURE 3 The Light com anysovih Tes.: Pr.Jeci Electric Generatins si tion Mounten Ll sing as Power P.O. a.: 2es wed. .eth. Ten.174s3 May 9, 1990 ST-ML-AE-3450 File No.t G25 U. S. Nuclear Regulatory Commission Attention: Document control Desk Washington, DC 20555 South Texas Project Electric Generating Station Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Systematic Assessment of Licensee Performance ReDort! 90-06 Reference: Letter of April 3, 1990 from Robert D. Hartin, NRC Region IV,'to D. P. Hall, HL&P, regarding the above subject. In the referenced letter the NRC provided an opportunity for Houston Lighting & Power to comment on the-Systematic Assessment of Licensee Performance (SALP) Report numbered 90-06 for the period of January 1, 1989 to January 31, 1990. The SALP report and management meeting on April 25, 1990 provided a professional and useful evaluation of the South Texas Project Electric Generating Station performance. Several areas were identified t;hore we could improve our performance, and we are actively working en these areas. HL&P has no other comments on the report. If you should have.any questions, ' ase contact me at (713) 229-7253. 7 (1 7. P. Hall Group Vice President, j Nuclear ' CAA/nl , %'N 0100 70050.; )ff 5 "00CK 0500o4y. vDC A1/049.N13 A Subsidiary of Houston Industries incorporated fL.t y ] l

.o=,ao Housten Lighting & Power Company South Texas Project Electric Generating station ST-HL-AE-3450 File No. : G25 Page 2 cc: Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 George Dick, Project Manager U.S. Nuclear Regulatory Commission INPO Washington, DC 20555 Records Center 1100 circle 75 Parkway J. I. Tapia Atlanta, GA 30339-3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P. O. Box 910 Bellport, NY 11713 Bay City, TX 77414 D. K. Lacker J. R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C. Texas Department of Health 1615 L Street, N.W. 1100. West 49th Street Washington, DC 20036 Austin, TX 78704 D. E. Ward /R. P. Verrot Central Power & Light Cc=pany P. O. Box 2121 Corpus Christi, TX 78403 J. C. Lanier Director of Generation City of Austin Electric Utility 721 Barton Springs Road Austin, TX 78704 R. J. Costello/M. T. Hardt City Public Servico Board P. O. Box 1771 San Antonio, TX 78296 Revised 12/15/89 A1/008.U14 . }}