ML20237H987
| ML20237H987 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/12/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237H655 | List: |
| References | |
| NUDOCS 8708250239 | |
| Download: ML20237H987 (39) | |
Text
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Enclosure 1 1
f ' ASSESSMENT OF PLANT COMPLETION AND OPERATIONAL' READINESS (
FOR
. SOUTH TEXAS PROJECT, UNIT 1.
DOCKET NO.'50-498 PREPARED BY-UNITED STATES NUCLEAR REGULATORY C0ltilSSION
~
REGION IV
~
1 l
O 8708250239 870812 PDR ADOCK 05000498 A PDR .
Enclosure 1 TABLE OF CONTENTS i
Page 1.0 Introduction and Background...................................... 1 2.0 Construction Inspection Program History and Status... . . ... . . .... . 2 3.0 STP , Uni t 1 Construction Sta tus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 4.0 Licensee Preoperational Test and Operation Readiness Status...... 4 5.0 NRC Preoperational Test (PT), Startup Testing (ST), and Operational Readiness (OR) Inspection Status..................... 5 6.0 QualityAssurance(QA)........................................... 6 7.0 Eme rg ency P re pa redne s s ( E P ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 8.0 S e c u r i ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 9.0 Systematic Assessment of Licensee Perfonnance (SALP)............. 8 9.1 Overview and Status......................................... 8 9.2 First SALP.................................................. 8 9.3 Work Suspension Period...................................... 8 9.4 Second SALP................................................. 9 9.5 Third SALP.................................................. 9 9.6 Fourth SALP................................................. 9 10.0 Litigation Record Review........................................ 10
- 11. 0 Al l eg a ti on Rev i ew. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 12 . 0 S uma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .p'. . . . . . . . . . . . . . . . . . .12. . . . . . .
13.0 Attachments 13.1 Construction Inspection Program Data i 13.2 Inspection Enforcement History, Violations Infractions, and Deficiencies by Year 13.3 Inspection Enforcement History, Deviations from Comitments i
by Inspection Year .
13.4 Test Deferral Assessment .
13.5 Preoperational Testing, Operational Readiness, and Startup Testing Program Data 13.6 Status of IEMC 2513 Program 13.7 Status of IEMC 2514 Program 13.8 Sumary of SALP Evaluations
l 1
i Enclosure 1 {
Page 1 of 12 j i'
1.0 Introduction and Background South Texas Project (STP), Unit 1 is essentially complete and is ready to I receive a low power license. The following is a summary of the regulatory i history of STP that leads the Region IV staff to conclude that the facility '
is ready to receive a license.
Houston Lighting & Power Company (HL&P), as lead for three other )artners, applied on May 19, 1974, for a license to construct and operate tie two unit STP. Construction Permits CPPR-128 and CPPR-129 were issued on l December 22, 1975. Both units are Westinghouse four loop pressurized i water reactors rated at 1250 MWe. The reactor systems are unique in that they employ the Westinghouse RESAR-41 design utilizing three redundant safety trains and having substantially all of the residual heat removal j system installed within the reactor containment structure. The reactor i containments are of a prestressed, post-tensioned, reinforced concrete !
Cesign.
Brown & Root, Incorporated (B&R) of Houston, Texas, was initially employed j in the dual roles of architect / engineer (A/E) and constructor but was later j replaced by the Bechtel Energy Company as the A/E, and by Ebasco Services I Company as the constructor. Bechtel also assumed the role of construction manager.
B&R initiated construction imediately after construction permits were issued and Region IV initiated 'the routine construction inspection program, Manual Chapter (MC) 2512, in January 1976. From that initial inspection through the end of 1979, Region IV conducted 58 inspections and/or investigations related to the ongoing construction, most of which were aimed at site preparation, backfilling and compaction of foundation soils and the placing of reinforced concrete but with some amount of ,
installation of eguipment and piping being initiated later in the period. l Late in 1979, NRC. management detennined a special investigative inspection t should be performed due to a significant number of allegations related to conflicts between the construction la6er force and it's management and the QA/QC organization and it's management. As a result of this inspection, Inspection Report 79-19, it was detennined that construction should be halted unless the licensee could show good cause for continuing.
After an extensive public hearing, construction was halted in April 1980 and the applicant was assessed a civil penalty in the amount of $100,000 which was paid without contest. Limited restart of construction activities was
- authorized in late 1980 and early 1981 after extensive changes in the ~
construction QA program and procedures were made. In September 1981, the applicent determined that B&R should not continue as the A/E and selected the Bechtel Energy Corporation to replace B&R as A/E. Work was stopped by HL&P to effect the changeover which was initiated on September 24, 1981.
B&R then chose not to continue as the constructor and withdrew from the project in November 1981. The applicant selected Ebasco Services Company l - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __w
l Enclosure 1 Page 2 of 12 to become the constructor. After a sustained period of engineering and construction quality and status review, work was again resumed in uunt 1982 and continued to the present time uninterrupted. During the construction shutdowns ed engineering / constructor transition period, Region IV conducted approximately 80 inspection / investigations both at the project site and in the engineering offices in Houston to assure that these activities were conducted in an organized, quality manner. In addition, NRC Vendor Branch inspectors were assigned to inspect the A/E essentially full time for approximately two man-years during the A/E transition period.
In aggregate, the NRC has performed approximately 300 inspections of STP, Units 1 and 2, involving approximately 40,000 inspector-hours.
Approximately 2/3 of the total time has been comitted to inspections of Unit 1 through and including the review of the organization and procedures necessary to startup and operate the facility.
Except for short periods between the departure of one inspector and arrival of his replacement, there has been resident inspector coverage of STP since September 1979. The present Senior Resident Inspector-Operations has been onsite since December 1983. The present Senior Resident Inspector-Construction and present Residenc Inspector-Construction have been onsite since March 1985. The present Resident Inspector-0perations has been onsite since October 1986.
2.0 Construction Inspection program History and Status The construction inspection program (MC-2512) for Unit I was completed in June 1987 with the completion of the " construction as-built" inspection.
During the construction inspection program, approximately 21,000 inspector-hours have been utilized for Unit 1 inspections including construction-related investigations an~d followups. In addition, another 11,000 inspector-hours have been utilized in the inspection ,of Unit 2 to-date. Many of the findings identified in one unit are equally applicable to the other unit, particularly in the engineering and QA/QC programmatic areas and to a somewhat lesser degree in the area of construction management and supervision.
The licensee was expected to implement actions in both units unless he could provide adequate justification for not doing so. Attachment 13.1 provides a summary of construction program inspection hours and violations and deviations for each year of inspection effort. Attachments 13.2 and 13.3 provide listings of all violations and deviations, respectively, for each inspection year. Those relating to the construction program have a ,.
(2)intheTYPEOFFINDINGcolumn.
Other components of the NRC have made strong contributions to the construction inspection program at STP. The inspector-hours involved in the following contributing inspections have been included in the above sumarized infonnation:
n Enclosure 1 Page 3 of 12 Special Investigative Inspection 79-19, conducted in November and December 1979
_ Non-destructive examination verification by Region I van team, ;
Inspection Report 84-02, in January 1984.
IE Construction Appraisal Team (CAT) inspection, Inspection Report 85-21, in October-November 1985.
Non-destructive examination verification by Region I van team, Inspection Report 86-17, October 1986.
The above inspections (more than 4000 inspector-hours) contributed sign.ificantly.to NRC's understanding the quality of construction of STP.
During the course of the above inspections, 119 individual violations (includingtheinfractionsanddeficienciesshowninAttachment13.2)of NRC requirements were identified. On two separate occasions a number of individual violations were combined and escalated to a higher Severity l Level violation. The individual violations are tabulated in Attachment 13.2.
Also,- seven deficiencies from licensee conunitments related to construction are shown in Attachment 13.3.
As noted previously, the applicant was assessed a civil penalty of $100,000 in 1980 in connection with the Show Cause Order issued by the staff to suspend construction which was based on the Special Investigative Inspection 79-19. A Severity Level III violation was issued based on a cumulative assessment of three separate violations identified during a CAT inspection in 1985. A civil penalty was not assessed for these findings because the applicant had taken strong corrective action innediately after the findings were made known.
The applicant has been responsive to violations and deviations identified 1 and has taken timely and effective co'rrective actions.
l L 3.0 STP, Unit 1 Construction' Status Unit 1 is essentially complete although there are items of work yet to be accomplished which the applicant identified in his Master Completion List-(MCL) and/or Daily Work Activity Schedule (DWAS) by system or area affected. The MCL was designed to include all important plant completion items. On July 10, 1987, the licensee transferred the remaining 1068 items in the MCL to DWAS. An analysis perfonned on July 22,1987, showed that .
346 of the MCL items transferred to DWAS had been closed, leaving 722 of the original 1068 items in DWAS Of the 722 items identified, only 6 were required to be completed prior to fuel loading and they were all field complete. Of the remaining items, 360 were related to plant operational MODE changes. Reviews by Region IV personnel indicate that the rate of )
completion of the items is generally commensurate with the applicant's l
planning. Region IV has concluded that the applicant's prioritization of t ;
I l
Enclosure 1 l
Page 4 of 12 the items and work scheduling appears reasonable and conservative from an operational safety standpoint. On July 13 and 14,1937, an NRC inspector inspected the transfer of MCL items to DWAS and concluded that appropriate work controls had been established.
During the course of construction, the applicant has resorted approximately 400 items that potentially met the criteria for reporta3111ty under 10CFR50.55(e). Approximately 30 percent of these potentially reportable items were subsequently determined to meet reporting criteria. Region IV has routinely evaluated the applicant's management program for evaluating these types of events and found it to be functioning properly. The applicant's corrective actions related to those items which were not classified as reportable have been verified to be adequate on a selective sample basis. The corrective actions related to the reportable items have been reviewed in each case and found to be satisfactory.
The Region IV staff has also fully reviewed the applicant's program for evaluating IE Bulletins (IEBs) Circulars (IECs), and Notices (IENs) and found it to be well managed. Staff followup has been accomplished for all IEBs and IECs. Only one remains to be resolved for low power operation and it is discussed in Enclosure 5. Selective review has been accomplished relative to a substantial sample of IENs and Generic Letters, again with satisfactory results.
All Unit I construction activity needed for fuel load is complete.
Individual remaining work items have been evaluated by the NRC staff and the staff has determined that their deferral will not impact the startup test program or other licensed activities. A schedule with appropriate controls is in place. The applicant has established measures to assure that the remaining work activities will not impact safety-related activities associated with fuel load or plant startup.
4.0 Applicant Preoperational Test and Operational Readiness Status All preoperational tests necessary tbhoad fuel and initiate low power testing for STP, Unit I have been completed and approved by the Plant Operations Review Comittee (PORC). Inspection of test results for selected tests by Region IV inspectors has confirmed the applicant's conformance with Final Safety Analysis Report (FSAR) acceptance criteria.
The applicant has prepared, reviewed, and approved procedures to support fuel load and operation. Region IV inspectors have reviewed the applicant's updated list (Enclosure 2 ST-HL-AE-2283, Attachment 1) of preoperational and acceptance tests which may not be complete at fuel loading. The ,
region agrees with the MODE requirements and dates assigned for completion.
The assessment of individual tests is sumarized in Attachment 13.4.
Enclosure 1 Page 5 of 12 5.0 NRC Preoperational Testing (PT), Startup Testing (ST), and Operational Readiness (OR) Inspection Status Region IV has completed the PT, ST, and OR inspections required by the NRC HC-2513 and MC-2514 which can be completed prior to fuel loading. In excess of 7500 inspector-hours have been expended pursuant to these programs. They include emergency preparedness and security which are individually discussed in paragraphs 7.0 and 8.0, respectively.
Attachment 13.5 provides a sumary of PT, ST, and OR inspection hours and violations and deviations for each year of inspection effort. Those items having a (3) in the TYPE OF FINDING column in Attachments 13.2 and 13.3 relate to the PT and OR program. There were no violations or deviations identified in the ST program. Beyond the inspection requirements of the manual chapters, the staff has observed a significant number of additional tests, and reviewed the results thereof, to gain additional confidence in the quality of the applicant's testing program. It should be noted that Region IV has utilized senior resident inspectors and the more experienced resident inspectors from the other sites in the region during the preoperational inspection effort at STP. Inspection items which remain to be completed later in accordance with the inspection programs and deferred tests are listed in Attachments 13.6 and 13.7 with appropriate milestones.
Region IV will track the conpletion of the tests listed in Enclosure 2 (ST-HL-AE-2283). Results of PT, ST, and OR inspections completed indicate that STP, Unit 1 is ready for fuel loading and operation up to 5 percent power.
The applicant's staffing and training have been inspected. The applicant meets ANSI NI8.1-1971 guidelines for commercial nuclear power plant experience. He has used a number of methods to assure satisfaction of !
guidelines such as the following:
- a. Direct hiring of personnel with the required experience
- b. Hiring contract personnel to augment staff positions until HL&P personnel have acquired the required experience
- c. Implementation of an on-the-job training program
- d. Using experienced personnel from other nuclear sites to assist HL&P on a temporary assignment basis l
The applicant was assessed as Category 1 in the functional area of training -
1 and qualification effectiveness during the latest Systematic Assessment of
- 4 Licensee Perfonnance (SALP) period. Recent inspections have also indicated a strong training program. The applicant has a plant specific simulator onsite and utilizes it in his operator training program. High pass rates
l Enclosure 1 Page 6 of 12 I l l
l i
on NRC reactor operator license exams were achieved (25 of 26,15 of 22, i and 13 of 14, respectively, on the three exams). Of 53 licenses issued, 49 are senior. reactor operator and 4 are reactor operator.
6.0 Quality Assurance (QA)
In the last SALP report (50-498/86-19; 50-499/86-18) a "high level of management comitment to quality" was observed. A strong management presence and involvement in project activities was noted. The applicant was assessed Performance Category 2 in QA with an improving trend. Ove rall ,
the SALP report indicated improved applicant performance during the assessment period. The last SALP assessment related largely to the design and construction QA program which is administered by HL&P Project QA under the General Manager, Nuclear Assurance. This program incorporates various methods of inspection and verification by HL&P, the A/E and the constructor.
Since January 1985, control and administration of audits and surveillance by all three entities has been consolidated under HL&P. Since the reorganization was implemented in 1982, 618 audits and 14,194 surveillance were perfonned as of May 22, 1987. As a part of Project Completion Verification Program. HL&P reviewed and verified as complete and acceptable <
all of the above audit and surveillance reports. {
I Other QA methods employed by HL&P include procurement overview surveillance i and effectiveness inspections (Els). The procurement overview surveillance (
were performed by HL&P and A/E QA personnel and involved observation of j performance of A/E vendor surveillance personnel during surveillance at j selected supplier facilities. A total of 68 overview surveillance were l performed, j An EI is a replication by HL&P of an inspection previously performed by an A/E or constructor quality control (QC) inspector. The twofold purpose is to establish confidence in the associated quality program and support the credibility of in'itial inspections. There were 4466 Els performed.
In 1984, HL&P assumed responsibilitytfor all project qualit All trend data is reviewed by the Trend Program Comittee (TPC)y which trending.
consists of representatives from HL&P, the A/E, and the constructor. The TPC directs trend investigations and issues a quarterly trend report to management highlighting trends adverse to quality and describing the effectiveness of corrective actions taken.
In lieu of an after-the-fact, inde ongoing engineering assurance (EA) pendent design verification program, anprogr ;
l It 1 incorporated internal HL&P EA procedures, a fonnal interface agreement governing communication among HL&P's EA teams, HL&P's STP Engineering Department, and Bechtel to assure independence and objectivity of the technical reviews and assessments performed. An independent oversight comittee composed of outside experts reviewed the major EA program activities and developments. The EA team concluded that:
Enclosure 1 Page 7 of 12 The A/E design process was adequate.
- The design of the systems and features assessed is adequate.
The overall design of STP is adequate and complies with applicable licensing comitments.
The EA team findings were sumarized in a report issued to the NRC via letter ST-HL-AE-2008 dated March 31, 1987.
Some extraordinary QA activities were perfonned as a result of the replacement of B&R as A/E and constructor with Bechtel in late 1981 and Ebasco in early 1982, respectively. A thorough review in accordance with approved procedures was perfonned to ascertain the status and adequacy of both design and construction work previously completed by B&R. HL&P QA performed audits and surveillance of the review process and all activities were appropriately documented.
In addition to the assurances discussed above, numerous independent audits of quality related activities at STP were commissioned by HL&P as discussed in Enclosure 2. The licensee has responded to all findings.
AnOperationsQAInspection(50-498/87-26;50-499/87-26) conducted during the period of April 13 through May 15, 1987, indicated adequate administrative controls and procedures and evidence of management involvement. The licensee is aggressively pursuing resolution of the deviations and open items observed and all those which could impact the licensee's readiness to load fuel have been reviewed for acceptability by NRC inspectors.
7.0 Emergency Preparedness (EP)
As discussed in paragraph 9.5, substantial deficiencies in the EP program were identified during inspections 1(t.the fall of 1986. Since the last SALP, the NRC Region IV inspectors hhve verified that corrective actions have been taken on 100 percent of the deficiencies that were considered as licensing issues (Category 1), and on 86 percent of all deficiencies identified in the emergency preparedness area. The NRC has accepted specific comitments made by the licensee on the remaining 14 percent. The one deficiency which must be resolved prior to low power operation is listed in Enclosure 5 for Region IV followup. The remaining deficiencies have negligible safety impact prior to operation above 5 percent power.
8.0 Security (to be provided later)
i I
l Enclosure 1 1 Page 8 of 12 {
i 9.0 SALP i
9.1 Overview and Status i Since the initiation of the SALP process by the NRC, applicant performance at STP has been assessed four times. Attachment 13.8 shows a comparison of functional area ratings.
9.2 First SALP (50-498/81-37;50-499/81-37)
Assessment Period: July 1, 1980 - June 30, 1981; SALP Board Date:
September 11, 1981; Licensee Meeting Date: October 16, 1981 The Board based their overall assessment on review of the QA program .
corrective action and on observing limited work activity caused by the l IE Investigation Report 50-498/79-19; 50-499/79-19, Show Cause, and Stop Work Orders imposed on B&R, the prime contractor, by the applicant.
The rating was most heavily influenced by B&R's continued inability to correct the root causes of problems and take corrective action in a timely manner. The QA program's success is largely dependent upon the correction of the cause of deficiencies, j Although HL&P had taken affinnative steps and actions in the area described above, the implementation of corrective action measures and procedures was still considered a weak area during that period. 4 Therefore, the overall rating for applicant performance was determined j to be Category 3 (lowest rating) because of HL&P's inability to compel i a significant improvement in B&R's performance in this area. i l
9.3 Work Suspension Period l No SALP RepoTt was issued for the period between July 1,1981, and December 1,7982. NRC Inspection. Report 79-19, released in early 1980, resulted in the issuance of an Order to Show Cause why construction should be allowed to continue. '-HL&P chose to tenninate the services .
of the company originally selected tn perform the architect engineering and construction functions and subsequently engaged Bechtel Power Corporation to act as architect engineer and Ebasco Services, Inc., to l complete the construction of the two units. No significant engineering or construction activities were accomplished during this period. A detailed statusing program for installed equipment and systems was jointly accomplished by Bechtel and the previous constructor prior to . 1 the resumption of construction. Maintenance of the installed equipment .
and warehouse storage were the principal activities being performed during this time.
Enclosure 1 Page 9 of 12 9.4 Second SALP (50-498/83-26;50-499/83-26)
Assessment Period: December 1,1982 - November 30, 1983; SALP Board Date: January 25-26, 1984; Licensee Meeting Date: May 10, 1984 For the period covered by this report, improvement recommendations were made in the following areas: soils and foundations with specific attention to quality control and management oversight; corrective action and reporting with particular emphasis on the process of evaluating the underlying causes for potentially reportable deficiencies and formulation of comprehensive corrective actions and I the system for tracking these items to completion; and material control with regard to correcting existing problems and ensuring the ,
identification and control of all materials used in safety-related j applications. .
The applicant was assigned Category 1 (highest) ratings in the following areas: piping systems and supports; electrical power supply and distribution; and licensing activities. j 9.5 Third SALP (50-498/85-12;50-499/85-12) 1 Assessment Period: December 1,1983 - June 30,1985; SALP Board i Date: August 20, 1985; Licensee Meeting Date: None i
The overall perfonnance at STP was satisfactory. Improvement had been noted in their perfonnance in the areas of safety-related components, training, corrective action and reporting, design and design change control, material control, and quality program and administrative controls. The pre-CAT audit team's efforts have indicated improvement l was needed in the normal inspection process. I 9.6 Fourth SALP-(50-498/86-19; 50-499/86-18)
Assessment Period: July 1, 1985'- December 31, 1986; SALP Board i Date: February 12, 1987; Licensee Meeting Date: None j The overall performance at STP was satisf actory. The SALP Board noted a significant strength of their organization in the apparent overall commitment of HL&P management to complete construction and subsequently operate a safe plant. One example of this coninitment was their Fitness For Duty Program which was instituted to promote a drug free work ,
environment at the STP site. Other areas that indicate a high level of ~
performance include their construction activities associated with containment, safety-related structures, and major steel supports; auxiliary systems; and the training and qualification activities associated with their preparations for reactor operation.
1
_ _ _ _ _ _ _ _ _ _ _ .______________________a
Enclosure 1 Page 10 of 12 An area needing improvement was emergency preparedness. NRC inspections at the end of the SALP period indicated insufficient progress in their readiness to handle emergencies. Meetings and discussions held after the SALP period indicated agressive response to the NRC findings would be taken by HL&P management to achieve adequate emergency preparedness. Progress in this area was demonstrated by a satisfactory graded emergency exercise conducted in April 1987, and subsequent NRC inspections have verified that 86 percent of the deficiencies identified in the emergency preparedness area have been corrected and specific comitments accepted from the licensee for correction of the remaining 14 percent in an appropriate time frame.
10.0 Litigation Record Review In December 1981, the owners of STP filed suit against B&R and its parent, Halliburton, Inc., based on nonperformance by B&R of its contractual obligations to provide A/E and construction management services and its refusal to fulfill its obligations as constructor of STP (HL&P vs. B&R).
B&R was replaced by Bechtel as A/E and construction manager in September 1981.
In preparation for the trial, the parties pursued extensive discovery including depositions, interrogatories, and the preparation of a number of expert reports. A record involving an estimated 32 million pages was l generated in preparation for the lawsuit.
The litigation was settled out of court and the judge lifted his gag order which had sealed the litigation documents. On June 5, 1985, HL&P notified NRC Region IV of their intent to conduct a review of the litigation record filed with the court to determine whether such materials identified safety-related deficiencies in the system, structures, or components of the STP or their associated design or quality documentation. Their fonnal review program was sent to NRC Region IV under cover of a letter dated August 30, {
1985. The NRC review of the program included separate reviews by Region IV, IE, OELD, and NRR staff. At the conclusion of this review, the NRC staff concludedtheHL&Pprogramwasadequa(e.
NRC RIV prepared Regional Office Policy Guide No. 0606 as inspection guidance and con /JCted four inspections of the implementation of the records {
review program. l f
These inspections are documented in NRC Inspection Reports 50-498/85-23 50-499/85-20, and 50-498/86-03. The NRC inspectors concluded that the I
litigation record review had disclosed no safety-related deficiencies which ,
had not previously been identified and resolved.
11.0 Allegation Review
)
Region IV has received and satisfactorily resolved approximately 75 allegations concerning STP since project inception of which the following remain open:
l l
l Enclosure 1 Page 11 of 12 Inability.of some onsite personnel to hear site evacuation sirens l
Possible internal ~ corrosion of small bore pipe l
Undefined GAP allegations The first and second allegations will be resolved prior to initial criticality.
The latter allegation will be inspected when the information is received by the NRC.
Hl.&P has demonstrated a high level of management comitment to resolving allegations by establishing a SAFETEAM for encouraging plant workers to bring their concerns to the utility for disposition. The SAFETEAM concept allows workers to identify problems without revealing their identity to the utility or their coworkers. The NRC staff has conducted three inspections of this activity including a review during the operational readiness inspection (see Enclosure 3), and has concluded that it is functioning as intended.
The following are among those allegations which have been reviewed and closed by the NRC staff:
mismanagement of SAFETEAM inappropriate weld rods improper welding practices failure to follow QC program improper disposition of an FCR inadequate training a supervisory review pipe design specifications possible security problems I inappropriate SAFETEAM actions alleged coverup of drug investigation results
- intimidation of operations quality control inspectors preventive maintenance improper ,
polar crane damage
- use of out of calibration torque measurement equipment coating applications improper
- ----------__________J
l' s h1 Enclosure 1 Page 12 of 12 concrete pour packages incomplete i
inadequate soil compaction electrical construction foreman failed to follow procedures and improperly supervised work j mismanagement of permanent plant maintenance program improper application of coatings to HVAC equipment falsification of qualifications of HVAC QC inspector weld certification falsification 1
structural specifications not being met QC inspector qualifications falsified 12.0 Summary Region IV has completed the inspections (with the exception of security inspections) of. construction and preoperational testing including reviews of the applicant's readiness for fuel loading, startup testing, and subsequent power operation. These inspections have assessed his compliance to Appendix R as well as his programs for security, radiation protection, radwaste handling, emergency planning, and other important aspects of the applicant's readiness. All NRC inspector concerns, which could impact safe operation at less than 5 percent power, have either been resolved to the satisfaction of the inspectors and their managers or entered in the tracking system for resolution prior to the required milestone. These i remaining followup items with their respective milestones are tabulated in Enclosure 5. NRC- inspectors have examined the applicant's tracking systems for safety-related items whicWwill require action subsequent to license issuance. The applicant has'a'ssigned completion dates prior to the required operating mode in each instance and the staff has reviewed these dates for acceptability.
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' f U. 19 7 197? 1979 ISSD 197I 1972 iS N 19&4 ' ? T *- 19 ff I?I' TE.ep itCPECT1;N PER.;O
. . = .. .
Enclosure !
Attachment 13.2-Fate Nc. I Page 1 of 10 06.'2B/67 SOUTri TEIAS FROJECT UNIT 1 - INSFECT10N ENFORCEMENT HISTORY VIOLATIONS (V), INTERACTIONS (!), AND DEFICIEktlES(El BY YEAR TRA*K NO. DESCRIP110N OF FINDINS FINDINGID.
- TYPE OF FIN:!k5 ll INSFECTI0h FICINGS REPORTED FOR INSFECT10N YEAR 1976 (2)
F 1 0002 Tising of test af ter vibroflota tion. 76-03-1-01 I (2)
F 1-0006 PDM Nelder qualification. 76-07-1-02 I (2) 88 INSPECTION FINDINGS REPORTED FOR INSPECTION YEAR 1977 (6)
F 1-0009 Calibration of welding nachines . 77-04-1-03 1 (2)
F 1-0011 Cadeeld procedure. 77-05-1-04 I (2)
' F 1-0012 Cadseld inspection. 77-05 1-05 I (2)
F 1-0014. Surveillance of earthwork. 77-06-E-01 E (2) .,
F 1-0018 Unqualified concrete G.C. I 77-09-1-06 (2)
F 1 0022 No audits of design. 77-12-E-04 E (2) 88 INSFECTION FINDINGS REPORTE!L FOR INSPECT 10N YEAR 1978 (10)
F 1-0023 Cold concrete. .
78-01-1-07 I (2)
F 1-0024 Vibrator spacing. 78-01-1-08 1 (2)
J l
F 1-0027 PLM Inspection. 78-04-I-09 I (2) J l
- A (2) indicates the finding relates to the construction inspection program. A (3) indicates the finding relates to the preoperational inspection program. .
Enclosure 1 Attachment 13.2 Page 2 of 10 Tage No. 2 W : bib 7 SOUTH TEIAS PRDJECT UNii ! - INSFECTION ENFORCEMEEi HISTORY V10i.AT]DNS (V), INFRACTIONS (!), AND DEF]CIENCIES(El BY YEAR T5CKNO. DESCRIFi!DN OF FIN *lNB FlkIINGID. TYPE OF FlkDINS F 1-002B Failure to provide revised draw ings. 76-07-1-10 1 (2)
F 1-0029 Failure to inspect structural s teel. 78-c7-1-!! ! (2)
F 1-0033 Cadseld procedures.
76-15-1-12 1 (2)
F 1-0034 Second shif t cadueld inspection .
E 78-15-I-13 1 (2)
F 1-0038 No housekeeping procedure. 76-16-1-14 I (2)
F 1-0039 No acceptance criteria for negg er test. 78-16-1-15 I (2)
F 1-0040 No maintenance surveillance. 78-16-I-16 I (2) 88 IkSPECTION FINDINGS REFORTED FOR INSPECT 10N YEAR 1979 (42)
F 1-0044 Transcription of records. 79-c2-117 I (2) -
F 1-0045 Dut of date drawings. 79-02 1-1B I (2)
F 1-0047 Material storage. .'
79-C3-1-19 I (2) l~.
F 1-0050 Concrete cleanup and placesent. 79-04-1-20 I (2)
F 1-0051 Storage of saterials. 79-05-1-21 I (2)
F 1-0052 Nonconforsance reporting. 79-05122 1 (2) .
F 1-0057 PDM GA sanuals. 7933123 I (p)
L__ _______ _ ___-__ __ - ________ ______ - _ - ___ ___ _______ _ __ - __ _ __-_ _ __________-___ ____ - ____ __ _
Enclosure 1 Attachment 13.2 i
Page 3 of 10 pg g,, 3 Ge /28/57 SOUTH TEIAS FROJECT Uhli 1 - INSFEC110N ENFORCEMEh1 HISTORY l-V10LAT10NS (V), INFRACTIONS (1), AND DEFICIENCIES (E) BY YEAR TUCK NO. DESCRIF110N OF FINDING FINDIN6 10. TYPE OF F]NDIkS F 1-0058 pet Audits. 79-13-1-24 I (2)
L F 1-0059 FDM organization. 79-13-1-25 I (2)
F 1-0060 Audit checklists. 79-13-1-26 I (2) l i
F 1-0061 Failure to delete GA procedures . 79-13-I-27 I (2) i F 1-0074 Fracedures for Stop Work Releas e. 7914-1-28 I (2)
F 1-0076 Concrete consolidation. 7915-I-29 I (2)
F 1-0079 Subjectiveacceptancecriteria. 7916-1-30 1 (2)
F 1-0!!6 ' Cadselders need requal. 79-19-V-01 Y (2)
F 1-0!!7 Lack of GA/DC independence. 79-19-V-02 V (2)
F 1-0!!8 laptoper concrete practices. 7919-V-03 Y (2)
F 1-0!!9 No insp. for loose rebar. ,, , ,
79-19-V-04 V (2)
F 1-0120 Procedures for qual. of civil i nsp. 79-19-V-05 V (2)
F 1-0121 Failure to complete backfill to spection to qual. procedures. 79-19-V-06 V (2)
F 1-0122 Procedures for sampling of soil . 79-19-V-07 V (2) ;
F 1-0123 Proept conective action on fai led test equip. 79-19-V-0B V (2)
F 1-0124 Failure to document soil lift t hickness. 7919-V-09 V (2) ,
l 1
i
Enclosure 1 Attachment 13.2 rage No, 4 Page 4 of 10 06/28/87
- . SOUTH TEIAS PRDJECT UNIT 1 - INSPECT 10N ENTORCEENT HISTORY VIOLATIONS (V),' INFRACT 10NS (!), AG DEFICIENCIES (E) BY YEAR TEACK NO liSCRIPi!DN OF FINDINS FIGING ID. . TYPE OF FI GINS F 1-0125' Failure to control use of nonco nforaing hasser in soil tests. 71-19-V-10 V (2)
F 1-0126 Failure to control dest. of spl it spoon. 79-19-V-11 V (2)
F 1-0127 Failure to follow code in radio graphy qual. - 7919-V-12 II Y
(2)
F 1-012B Control of out-of-date contract or GA manual 71-19-V-13 V (2)
F 1-0129 Control of cleanliness in meldi ng procedure. 71 19-V-14 V (2)
F 1-0130 Foor radiographic quality. 71-19-V-14 V (2)
F 1-0131 Incorrect radiography interpret ations. 7919-V-16 V (j)
F 1-0132 Reexamination of L.P. Indicatic ns. 79-19-V-17 V (2)
F 1-0133 Control of root openings etc. i n design changes. 71-19-V-18 Y (2)
F 1-0134 Frocedure used af ter experation date. 75-19-V-19 I V
(2)
F 1-0135 Failure to take corrective atti on to control NCR's and FREA's. 75-19-V-20 V (2)
F 1-0136 No procedures for supplemental audits. 71-19-V-21 V (2)
F 1-0137 Failure to perfore supplemental audits. 79-19-V-22 V (2)
F 1-0138 Inadequate audits-unsats seat observed. 71-19-V-23 Y (2) ."
F 1-0139 Failure to audit at required freq. 79-19-V-24 V (2)
F 1-0140 Failure to periora in-depth audit 5. 79-19-V-25 V (2) l
__________-______________-_____N
Enclosure 1 Attachment ;3.2 Fage No. 5 Page 5 of 10 Ce/28/B7 ..
SOUTH TEIAS FRDJECT UNIT 1 - thSFECT10N ENFORCEMENT HISTORY V10LA110NS (V),' INFRAC110NS (1), AND DEFICIENCIES (E) BY YEAR
' TRACK WD.' DESCRIFi!0N OF FINDINS FICIN 6 10. TYPE OF FIGING F 1-0141 Failure to periore supplemental audits. 79-19-V-26 V (2)
F 1-0142 Failure to fo!!on procedures to docusent & correct unsat. cond. 79-19-V-27 V (2)
F 1-0143. . Failure to take timely correcti ve action. 79-19-V-28 V (2) 11 INSPECTION FINDINBS REPORTED FOR INSPEC110N YEAR 1980 (10)
F 1-0147 Reportingtimeliness. 8001-1-31 I (2)
F 1-0148 Liner bulge test. BF01-I-32 I (2)
F 1-0153 Untieely response to NRC. 80-05-1-01 1 (2)
F 1-0154 50.55(e) timeliness. 80-05-1-02 I (2)
F 1-0155 Failuretoreport. BF05-1-03 I (2)
F 1-0156 Storage of saterial. BbO7-1-36 I (2) i F 1-0161 Traceability of enEed esterial. BFIB-I-37 I (2) j '.
F 1-0162 Control of purchased saterial. BFIB-1-38 I (2) .
F J-0163 Response to audit finding. B>lB-1-39 I (2)
F 1-0166 Prevention of use of non- conforming saterial. BF27-V-29-54 V (2) ,
I l
J Enclosure 1 Attachment 13.2 Page 6 of 10 Pa;e No. 6 DeOBIB7 SOUTH TEIAS FROJECT UNii 1 + lhsPEC110N ENFORCEMENT NISTORY V10LAT10NS (V), INFRAC110NS (!), AND DEFICIENCIES (El BY YEAR TR O NO. DESCRIP110N OF FINDING FlCIN6ID. TYPE OF FINDING
]
I 88 '!NSPECT10N FINDINGS REPDRTED FOR INSPECTION YEAR 1951 (4)
F 1-0174 Storage and maintenance. 81-01-V-30-55 V- (2) 1 l
F 1-0178 Air test of grout. B110-V-31-S4 Y (2) I F 1-0163 Recording of visual exas. 81-29-V-01-S5 V (2)
I F 1-0195- Calibration. 81-33-V-01-54 V (2) 88 INSPECTION FlhDINGS REPORTED FOR INSPECilDN YEAR 1982 (3)
F 1-0188 Control & tagging of meld saterial. 82-01-V-01-S5 V (2)
F 1-0189 55.55(e) tiaing. B2-02-V-01-54 V (2)
- F 1-0259 Record retention. B2-16-V-01-54 V (2) 88 INSPECTION FINDINGS REPORTED FDR INSPEti10N YEAR 1963 (7)
F 1-0273 Mecordretention. 83-02-V-01-S5 Y (2)
F 1-0287 Free formed concrete. 83-11-V-01-55 Y (2)
$N F 1-0305 Identification and Control of saterials. 63-17-V-01-S4 V (2)
F 1-0318 Training. B3-20-V-01-SS V (2)
E p
Enclosure 1 Attachment 13.2 L, Fage No'. 7 Page 7 of 10 !
) 06/26/E7 i SOUTH TEIAS PRDJECT UNii ! - INSFECTIDN ENFORCEMENT HISTORY
\'
l
'VIDLAllDNS '(V), INTRACi10NS II), ANL DEFICIENCIES (D BY YEAR TRIO: NO. SESCRIPTIDN OF FINDING FI CING 10. TYFI 0F F1hDINS 1
1 o
F.14322- Oversite - Undersize bolts and nuts. 83-22-V-01-54 Y (2)
. F 1-0323' Failure to tale corrective atti on. 8322-V-02-S5 V (2)
F 1-0325_ Relative density. 63-24-V-02-54 V (2)
.s
.J 88 INSPECTION FINDINGS REPORTED FDR INSPECilDN YEAR 1964 (2)
F 1-0326 Incomplete penetration in weld- sithdraun. (Letter 4/23/64) 8442-V-01-54 V .(2)
F 1-0330 NCR Systes. 8444-V-01-SS V (2) l F 1-0331 Docueent Eontrol. 64-07-V41-54 V (2) 84 INSPECT!DN FINDINGS REFORTED FDR INSPECT 10N YEAR 1985 (7)
- F 14338 Startuptraining. 85-01-V41-55 V (2)
F 14339 Material identification. 85-02-V-01-54 V (2)
F 14342 Failure to follom. . 8546-V-01-64 V (2)
F 14344 . Failure to follom MTE procedure s. #' B547-V-01-54 V (2)
F 1-0345 Failure to have MTE procedures. 8547-V-02-S4 V (2)
F 1-0347 Traceability of saterial in spe at fuel racks (withdrawn by letter dated 1/13/B61.- -
_ . - _ . - _ - _ - _ - - _ - - _ - - - - _ - - - - - - - _ ~ - - - - -
- =
1 + ..
- f. !h, 4 "j , Enclosure 1 F ;4 M Attachment 13.2 Page 8 of 10 K s
, Page No. 6- f,,. ..
s.
Cf J~E/67 -
$dUTR t$stdPRDJECT UNIT 1 - INSFECIl0N ENhMEGT #! STORY 3
V10Ld!DNS (V), INFRAtil0NS II), AND DEFICIENCIES (El Pr FEAR TR E ND. ' DESCRIPTION 0F FINLING 'FI GINB 10. IfPE OF FICING T 'P3 fh -
s' F 14348 MaintAinFerskEtda'd' Equip.85-154 41-S4 V. ()
F 1-0349 Supports welding records. ,
, f5194 01-55 V (2)
P i II INSFECTION FINDINGS REPORTED FOR NSPECT10N YEAR 1964 ' (27) ,
F 1-0411 Hold point fo'r heat treat signa I off improperly.
.06414 01-54 V (2)
\- l
)
F 14422 Nelding of Piping. -
Failure to follom p ourdure for B6-0144s+S4 . ') (2)
GC sign oH of FNHT.
F 1-0421 No procedure for reporting proc edural violations.86-024 41-S5 V (2)
I 1-0424 idleri to properly inspect wel ding of elect. pre! B6-044-01-54 V (2)
- at;ribeents,s -
. F 1-0420 Incore seal plate remorked with out authorirsd. 86464-01 $4 V (2)
F 14429 Thiele tabes to seal plate noi per print. 86-06-V4244 V (2)
. y F 1-0430 inplate storage of equipsant. IAFN Pumps) 86444 4344 V (2)
I r ,
~
F 14433 Instrusent tubing'a'nd support progras (See 95-21-0-25) 86 12-V-01-SS V (2)
[N F 14434 Undediret selds te 2 inch Sch 160 sockets (See B5-21-D-58) 06-12442-S5 V (2) i F 14435 Cap screws used la place of stu ds and nuts on safer valves86-124 4345 V (2)
(See B5-21-0-57) ,
F 1-0436 Mechanical equipment deficien - cies (See B5-21-0-63)66-124 4445 V (2) ,
e F 1443? Undersired melds on supports and restraints (See B5-2i + 26) B6-12445-S5 V (2)
)
- L w-__-____-___ _ _. _ _ _ _ .
Enclosure 1 Attachment 13.2 Page 9 of 10 7 g ,
0o128/87 SDili.4 TEIAS PRDJECT UNIT 1 - INSFECTICE ENIDRCEMENT HISTDRV VIDLATIDNS (V), INTRACilDNS (!), AND DEFICIENCIES (El BY YEM TEACK ND. DESCRIPT!DN DF FINDING FINDIN6 10. TYPE OF FINIlhB F 1-0436 ! Dver tightened structural tolts (See B5-21-D-37) 86-12-V-06-55 V (2)
F 1-D439 Design control of configuration control packages 86-12-V-07-S5 V (2)
(See 85-21-24)
F 1-0440 Use of vendor data in design (See 85-21-0-59)- 86-12-V-08-55 V (2)
F 1-0441 Us'e of NSSS data in design (See 85-24-0-01). 86-12-V-09-55 V (2)
_F 1-0442 lisued drawings not correctly translated fros FCR/FCN 86-12-V-10-55 V (2)
(See 85-21-0-52)
F l-0443 Circuit breaker extenders and barriers (See 85-21-0-19) 86-12-V-Il-S5 V (2)
F 1-0444 Wrong bolting in randos use of equipment (See 85-21-0-48) 86-12-V-12-S5 V (2)
F 1-0445 . Vendor tanks and H! have under- sited melds (See 85-21-0-29). 86 12-V-13-55 V (2)
F 1-0446 - Motor tereinal lugs and insula- tion (See 85-21-0-184& 86-12-V-14-S5 V (2) 65-21-0-188).
F 1-0447 Unsarker botting in randos use of electrical equipment 86-12-V-15-S5 V (2)
(See 85-21-D-47) ,
-F 1-0448 NCR issuance and hold irg appli cation (See 85 2,4,-0-03). 8612-V-1645 V (2)
- r. '
F 1-0452 Failure to follom procedures for maintaining piping systes 86-17-V-01-54 V (2) cleanliness.
F 1-0457 Failure to Follom Procedures. 86-23-V-02-54 V (2)
F 1-0479 HoldTags. 86-26-V-01-54 V (2) ."
I F 1-0510 Failure to maintain inplace storage conditions. 86-31-V-01-54 Y (2) 1 I
C_--_--____________ _ _ _ _ - -
Enclosure 'l Attachment 13.2 Page 10 of 10 Fa;e No. 10 Oc/26/87 SOUTH TEIAS PRDJECT Uhli ! - INSFECTION ENFORCEMEh1 HISTORY V10LAilDNS (V), INFRACTIONS (!), AND DEFICIENCIES (El BY YEAR Tn*Act: ND. DESCRIPT!0N OF Fl@lNS FICINS10. TYFE DF FIGlk3 84 INSPECT!DN FINDINGS REPORTED FOR l( MiON YEAR 1987 (8)
F 1-0748 Failure to follow procedure for record data entry. B743-V-01-54 Y (3)
F 1-0770 Failure to Follow Procedures for Maintaining Cleanliness 87-08-V-01-S4 V (3)
F 1-0771' Failure to Follow Procedures For Performing Test 8748-V-02-S4 V (3) d F 6-089B Three Limitorque Operator Motors had Leads Spliced eith 87-21-V-06-54 V (3)
Unqualified Splices F l-0913 External Surface Contamination of Stainless Steel Piping B7-27-V-01 V (2)
F 6-0911 Failure to Provide Adequate Design Change Control on RHR B7 27-V-02-54 V (2)
Pump Supports F 6-0912 Failure to. Follom Procedure for installation of Bolts 87-27-V-03-54 V (2)
F 3-0919 Failure to Follon Procedures Cosponent Cooling Preop B7-39-V-01-S4 V (3)
Results Revien
_~
1 I
j
l~ ,
Enclosure 1-Attachment 13.3 sq, No, . 1 Page 1 of 2
- !:E/E7 SDUTH TEIAS FROJECT UNIT 1 - INSFECT]DN ENFORCEMENT HISTORf MV!AT10NS (D) FROM COMMITMENTS TABULATED BY INSPECT 10N YEAR TTt.d NC. DES:R!PTIDN OF FINDING FICING 10.
- TYPE OF FINDINB l
l l 38 HV!AT10NS REPORTED FOR INSFEtf10N YEAR 1977 (2)
F 1-0015 Unqualified concrete inspector. 77-c6-0-02 D (2)
F 1-0021 Audit checklists not saintained . 77-12-D-03 D (2) l si EVIAT!DNS REPORTED FOR INSFECTION YEAR 1978 (1) c '
F 1-0041 Level 1 on cadnelder inspection . 76-17-D-05 D (2) l
.si EVIATIONS REPORTED FOR INSPECT 10N YEAR 1979 (g)
F 1-0073 Undated records. 79-14-D-06 .D (2)
F 1-0144 Unrestricted vert. devp. contre te. 79-20-D-06 D (2)
It EV!AT10NS REPORTED FOR INSPECil0N YEAR 1983 (1) (g)
F 1-0311 Bolts not tested. 83-20-D-02 0 88 E VIAi!0NS REPORTED FOR INSFECT!DN YEAR 1964 (1)
F 1-0337 CCN design. 84-16-D-61 D (2) 88 K VIAT!DNS REPORTED FOR INSFECT10N YEAR 1996 )
F 1-0547 Preoperational test procedure Hot Functional Test 86 33-D-01 D (3)
- A (2) indicates the deviation relates to the construction inspection program.
A (3) indicates the deviation relates to the preoperational inspection program.
. _ _ . _ - _ _ _ _ - _ . _ _ _ _ _ _ - . - _ . ~ _
Enclosure 1 Attachment 13.3 Page No. 2
'06/2i/67' SOUTH TEIAS PRDJECT Uhli ! - INSPEET10N ENFORCEMENT HISTDRY DEV!ATIONE (D) FROM COMMITMENTS TABULATED BY INSPEtilDN YEAR TRA:K NO. DESCRIPTION Of FINDINS FIND!N6ID. TiFE OF FIN!!NS 88 DEVIAT10NS REPORTED FOR INSFECT!DN YEAR 1987 (3)
F 7-0903 Failure to Establish Inden Prior to Receipt of Records 67-26-D-04 D' (3)
'F 2-0905 Inadequate Control of Records in Teaporary Working File 87-26-D-06 D (3)
I F 3-0909 Failure to Conduct Performances Testing Fo!!awir.g Plant.
Modifications 87-26-D-10 D (3) e O
L.
l l~
Enclosure 1 Attachment 13.4 Page 1 of 5 TEST DEFERRAL ASSESSMENT The following preoperational and acceptance tests which are not yet complete have been analyzed for plant and system operability. It has been detennined that the j tests are not required to be complete prior to loading fuel, based on the I following criteria:
(1) The system tested is not yet required to place the plant in a safe shutdown condition prior to the listed MODE.
(2) The system tested is not required to mitigate the consequences of any accident prior to the listed MODE.
(3) The system tested is not required to prevent release of radioactivity to the environment prior to the listed MODE.
(4) Specific criteria are also listed for the individual tests.
The NRC inspector has reviewed these tests and their status and agrees with the licensee's conclusions. Additionally, the NRC inspector has reviewed the plant schedule to insure these tests have been scheduled and that the MODE change check sheets also require the completion of these tests prior to changing from one MODE to the required MODE.
The list of preoperational and acceptance tests which are expected to be completed af ter loading fuel and associated conrnents are as follows:
System Procedure (PercentComplete) Discussion 1-BR-P-01 Boron Recycle To be completed prior to MODE 2. There is no (0%) ,
requirement for recycling boric acid earlier.
1-CN-P-01 Communications Test will be completed upon receipt of ENS (99%) phonesi.from NRC. Totally dedicated emergency coninunication is available from HL&P supplied phones at the E0C, TSC, and the CR.
1-EW-P-05 ECW Essential Portion of test required to verify operation Chiller Valves with low Ultimate Heat Sink temperature (was50%-now (<53*F) will be completed by September 30, requires 100% 1987. The valves are presently locked open retest) and the ECW flow balance has been set to ~~
provide proper flow to the Essential Chillers.
1-FW-P-01 Main Feedwater Testing not required to be complete prior to (10%) MODE 4. Main Feedwater Isolation operability not required until MODE 4.
l) o .
-]
Enclosure 1 i Attachment 13.4 I Page 2 of 5 1-HB-P Control Room HVAC System is operable per Tech Specs. The low i (99%) and higli~ flow alarms on the cleanup units are 1 the only items not-tested,- due to design .!
problems. The alarms will;be operable and. 1 tested prior to MODE 2.
1-NK-P-01 Safety-Related The_ systems for which the heat tracing'is Heat Tracing tested in this preop are not required until
( :-
(0%) MODE 3 (auxiliary feedwater) and MODE 2.(PASS, ;
containment monitoring, and boron recycling).
The safety-related' heat tracing will be 1 l tested for each system prior to the required MODE for that system.
1-PS-P-01 Primar Selected PASS valves.must be timed under
'(99%)ySampling dynamic conditions. The PASS is currently a l
MODE 1 restraint, but these valves will be
, tested prior to MODE 2. RCS must be at L
operating temp. and pressure prior to completing this test.
1-RA-P-04 Liquid Effluent Subtest. IRA-RT-8041 testing was field Moniters complete 7-30-87. Test results are in JTG (99%) review and will be transmitted to the vault by 8-7-87. The TGB sump monitor is not required to be operuble prior to MODE 2.
1-RA-P-18 Radiation Monitor System is only needed for personnel reentry System into containment following initial Communication criticality. Test is scheduled to be (98%)_. completed prior to MODE 2, but is scheduled
- to be field complete by 8-3-87.
1-HC-A-02 RCB Carbon Units System >fs not required until MODE 2 since no HVAC airborne radioactivity is generated until (98%) MODE 2.
1-RC-P-06' + Steady State To be completed at full power because Vibration Testing measurements and observations can only be made during full-power conditions (examples:
mainsteamlines,mainfeedifnes) ,
'~
1-RC-P-07 +Thennal Expansion To be completed at full power because measurements and observations can only be made during full-power conditions (examples:
mainsteamlines,mainfeedlines)
1 Enclosure 1.
Attachment 13.4 Page 3 of 5 1-RC P-08' + Transient To be completed at full power because Vibration Testing. measurements and observations can only be made during full-power conditions main steam lines, main feed lines)(examples:
-+ NOTE: Tests 1-RC-P-06, -07, and -08 are vaulted but hot data must be taken and added.
1-RC-P-11 Pressurizer Level Test is to be completed prior to MODE 2. The and Pressure only section which is outstanding is to verify Control SI accumulator isolation valves open automati-(98%) cally on RCS pressure, which can only be-done during MODE 3. (Thevalves.areadministrative1y opened during normal operation;.this test verifies automatic operation which is a backup to the operator's procedure.)
1-SP-P-03 SSPS Response There are four areas not yet tested:
Time Test (1) Overtemperature WT, Overpower WT, and (95%) .RCS RTD response times ~will be gathered prior to MODE 2. The RTD times.cannot be collected until the RCS is filled.
SSPS trip functions from these loops are not required to be functional until the unit is critical.
(2) Urgent alann testing is not required until MODE 4. The alarms do not need to be functional until ESFAS and trip functions are needed in MODE 4.
(3) S/G 1evel transmitter LT527 response j time must be collected prior to MODE 3. l
-- The testing is field complete and will bejpproved prior to MODE 3.
(4) Fiedwater Isolation Valves and Turbine Trip response times are not needed until MODES 4 and 3 respectively. The ESFAS functions do not need to be operable prior to these MODES. The times will j actually be gathered from 1-FW-P-01. .j 1-WL-P-02 Waste Evaporator This test will be completed prior to MODE 2.
(0%) There will be no liquid or solid radwaste -
generated prior to MODE 2.
1-WL-P-03 Liquid Waste This test will be complated prior to MODE 2.
(50%) There will be no liquid or solid radwaste generated prior to MODE 2.
Enclosure 1 Attachment 13.4 Page 4 of 5 1-WS-P-01 Solid Waste This test will be completed prior to MODE 2.
. Processing There will.be no liquid or solid radwaste .
(0%) generated prior to MODE 2. !
1-WS-P-02 Spent Resin . This test will be completed prior to K?DE.2.
Storage Tank There will be no liquid or solid radwn te (25%) generated prior to MODE 2.
1-CU-A-01 -Plant Computer System is_not required until MODE 2 because System (PROTEUS) system monitoring and computational functions (field work are not required until the plant is critical.
complete) 1-CV-A-01 Borenmeter This testing will be completed prior to full (test was ' power operation. Boron concentration will be completed, equip- determined by sampling, which is a more ment failed, precise inethod of determining baron complete retest concentration.
required (50%))
1-FW-A-01 Main Feedwater Test is to be completed at full power because Acceptance Test testing requires main feedwater pumps to be (90%) run at full load. This can be accomplished only at full power conditions with adequate steam supply. !
j 1-LA-A-02 Emergency Normal lighting is available and operational. j Lighting Emergency lighting not potentially impacting )
(70%) prior to MODE 4. All systems are scheduled '
to be completed prior to MODE 4.
1-LA-A-04 Emergency Normat lighting is available and operational.
Lighting Emergencylightingimpactisinsignificant 3 (80%) prior to MODE 4. All systems are scheduled to be completed prior to MODE 4.
1-LA-A-05 Emergency Normal lighting is available and operational.
Lighting Emergency lighting impact is insignificant (70%) prior to MODE 4. All systems are scheduled .
to be completed prior to MODE 4.
1- LA- A-06 Emergency Normal lighting is available and operational. .'
Lighting Emergency lighting impact is insignificant (90%) prior to MODE 4. All systems are scheduled to be completed prior to MODE 4.
Enclosure 1
' Attachment 13.4 Page 5 of 5 l'-LA- A-08 . Emergency Normal lighting is available and operational.
Lighting Emergency lighting impact is insignificant (0%) prior to MODE 4. All systems are scheduled to be completed prior to MODE 4.
The~ following are preoperational and acceptance tests which were originally
- proposed for deferral until after fuel loading in Enclosure 2, but have subsequently been completed:
1-ED-P-01 ~. Rad. Floor Drains All testing complete and transmitted to vm1t.
(100%)
1-ED-P-02' RCS Leak Detection Procedure complete and transmitted to vault. '
(100%)
1-HZ-P-05 Misc. Area Temp. Procedure complete and transmitted to vault.
Surveys (100%) -.
1-RA-P-05 Condenser Vacuum Test is complete and transmitted to vault. 4 Pump Gas Monitor (100%)
1-RA-A-01 Test of RM-11 - Test has been completed and transmitted to vault.
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Attachment 13.5 Page 2 of 2 P P-r F n" . . A- P E F . .p c. ' A.n - j u- r. -.e. c. , A. : TART UP l !!tTEZ;*1 Ff CGF.41 e F0 spot 61El F rt5";'"1 e -
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Enclosure 1 Attachment 13.6 E '
Fage he. 1
'07/16/E7 SOUTH TEIAS FROJEti UNii ! -- STATUE -- 1EKC 2513 FRDBRAM TRAtr. iiD. 1. F . I ' TITLE Fi INSFEti!0N PRDCEDURE STATUS REG.Eh J 5-0213 6452" Solids - Control, Saspling,Moni toring, and Release. 0 8 901 Cooplete 5 J 5-0214 84523 Liquids'- Control, Saepling. Mo nitoring and Release. 0 9 902 Complete 5 J 5-0215- 64524 Bases and Particulate - Contro 1, Saapling, Monitor. & Release 0 3 90% Cosolete 5 J 6-0004 25020 Sales AWTS FU-h5 Systet 0 5 901 Cosplete 6 J 6-0206 B3522 Rad Prot, Plant then Radmaste, & Envirn Organ & Mgt. Controls. 0 9 901 Cosplete 6 J 6-0207 B3523 Rad Prot., Plant Chen, and Rad- maste Training 1 Qualifications 0 3 901 Cosplete 6 J 7-0006 25564 Sales AliiS Follow Up D 3 901 Cosplete 7 J B-0007 25565 TM! Attica Flan Follow Up D 4 901 Cosplete B J B-0228 92719 Safety Evaluation Report Revien and Followup D 9 601 Cooplete B l
i Legend in "Reqd. By" Column:
2 5 - Perform prior to low power testing g; 6 - Perform prior to power ascension -
7'- Perform prior to plant' reaching full power 8 - Perform prior to completion of first refueling
Enclosure 1 Attachtnent 13.7 Page 1 of 2 P4;e No. !
06/25187 SOUTH TEIAS PR0i!ECT UNIT 1 -- STATUS -- IEMC 2514 PR06 RAM STATUS RE00. f *:
TRACK WD. l.P.4 TITLE OF INSFECTION PRDCEDURE 72524 initial Fuel Loading Witnessing 03 01 Ccaplete 2 W 2-0017 3
W 3-0002 35501 GA for Startup Test Progras 038;tCosplete 72592 Initial Criticality Witnessing PWR 09 (I Complete 3 W 3-0030 72596 Precritical Data Review PWR 03 01 Complete 3 W 3-0031 Security Plan and laplementing Procedares 03 01 Complete 3 W 3-0036 '810!B W 3-0037 91020 Managenent Effectiveness 03 01 Complete 3 B1022 Security Organization 03 01 Complete 3 W 3-0038 81034 Security Program Audit' 03 01 Complete 3 W 3-0039 W 3-C040 81042 Testing and Maintenance 03 01 Cosplete 3 W 3-0041 81046 Locks, Keys, and Combinations 03 01 Cosplete 3 W 3-0042 B1052 Physical Barriers Protected Areas 03 01 Cosplete 3 W 3-0043 B1054 Phy Barriers-Vital Areas, Mat. Access Areas & Con Access Areas 00 01 Cosplete 3 W 3-0044 B1058 Security Systes Poner Supply 03 01 Cosplete 3 W 3-0045 B1062 Lighting 03 01 Cosplete 3 W 3-0046 81044 Compensatory Measures 03 01 Complete 3 W 3-0047 81066 Assessernt Aids 03 01 Cosplete 3 W 3-0048 81070 Access Control--Personnel .N! O3 01 Cneplete 3 W 3-0049 81072 Access Control-Packages C3 01 Cosplete 3 W 3-0050 81074 Access Coetrol-Vehicles 03 01Ceeplete 3
.W ~d 051 8101B Detection Aids-Protected Areas 03 01 Complete 3 W 3-0052 81080 Detection Aids-VA, MAA, and CAA 03 Of Complete 3 .
W 3-0053 81084 Alara Stations 03 01 Complete 3 W 3-0054 81088 Coenunications 03 01 Complete 3 W 3-0055 91038 Records and Reports 03 01 Cosplete 3 W 3-0056 81501 Personnel Training & Du.nlifica- tions--Beneral Requirements 03 01 Complete 3
_ _ _ -_ m ~ _ om m n~. _ aa m w oo m a
n_-____- - . - _
Enclosure 1 Attachment 13.7 Page 2 of 2 t-Page No. ,2 06!28/B7 SOUTH TEIAS PROJECT UNIT 1 -- STATUS -- IEMC 2514 PR06 RAM TRA;K NO. -1.F. I TITLE OF INSPECTION PROCEDURE STATUS RE00,Ie:
W 3-005B B! BIO Physical Protection Safeguards IMormation 03 01 Complete 3 W 6-0001 25401 DL Applicant inspection Require sents (il 2514/01 R2) 0 3 901 Cosplete 6 W7-0032 72600 Power Level Plateau Data Reviem (2511 PWR 03 01 Complete 7 N 7-0033 72608- Power Level Plateau Data Review (501) PdR D 3- 01 Cosplete 7 72616 Power Level Plateau Data Review (751) PWR 03' 01 Complete 7 i; W 7-0034 W7-0035- 72624 Power Level Plateau Data Reviem (1001) PWR 03 01 Complete 7 N7-0060 B3521 Radiation Protection - Startup 03 01 Complete 7 N 7-0061 B4521 Radioactive Waste Systees - Startup D3 01 Cosplete 7 U 7-0062 '90501. Reportable Matters-Test Progras 03 01 Complete 7 r
p' j
Enclosure 1 Attachment 13.8 Page 1 of 1 t
SUMMARY
OF SALP EVALUATIONS
~ Rating (for period ending)
'6/81 11/83 6/85 12/86-Functional Area Soils and Found6tions N/A 3 2 N/A A.
Containment, Safety-Related 2 2 2 1 B.
Structures, and Major Steel Supports
N/A 1 2 2 C. Piping' Systems and' Supports Safety-Related Components- N/A 2 2 2 D.
Mechanical E. Auxiliary Systems- 2 N/A 2 l' Electrical Equipment and- N/A 1 2 2 F.
Cables N/A N/A N/A 2 G. Instrumentation Licensing Activities 1 1 2 2
- H.
N/A 2 2 I. Security N/A Radiological Controls N/A N/A N/A 2 J.
N/A N/A N/A 3 K. Emergency Preparedness N/A 1 1 L. Training and Qualification . N/A Effectiveness ib/A 2 2 2 M. Quality Programs and
Administrative Controls Affecting Quality N/A N/A N/A 2 N. Preoperational Testing Corrective Action Reporting 3 3 1 N/A 0.
Design and Design Change N/A 2 1 N/A P. . ,
Control .
Material Control N/A 3 2 N/A !
Q.
l
Enclosure 2
- Page 1 of 36 The Light M m P u y nem,,emtis ,mS s & Pe e, P.o. ses iroe nees,ee.rexs,12ooi <>is> 22s.92ii May 26, 1987 ST HL AE 2149 File No.: G20 10CFR50 M@_S OW12 %
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 My 2 9 g -
- Y South Texas Project Unit 1 Docket No. STN 50-498 Statement of Completion and Request for Low Power Operating License Reference (1) Anticipated Status of STP at Fuel Load January 22, 1986, ST-HL-AE-1576 (2) Anticipated Status of STP at Fuel Load March 13, 1986, ST HL-AE 1620 (3) Anticipated Status of STP at Fuel load January 8, 1987, ST-HL AE-1868 (4) Plant Completion Verification Program February 4, 1987, ST HL-AE-1911 Houston Lighting & Power company (HIAP) will be ready for fuel loading and low power testing of the South Texas Project (STP) Unit 1 as early as June 23,1987, but no later than June 30, 1987. At that time design, construction and preoperational testing required to ensure compliance with the Final Safety Analysis Report (FSAR) and applicable Commission requirements will be completed with few exceptions. Attachment 1 details thcse items which will not be complete at time of fuel load. This list supersedes those of References 1, 2 and 3.
H14P intends to continue the normal licensing update process in order to ensure that current design, construction and preoperational testing ;
commitments are met and proper submittals made to the NRC to incorporate design documents into the FSAR's descriptions.
L1/NRC/ka .
&704orcrtSt-7 1 - / /J .2 1
Enclosure 2 Page 2 of 36 i ST.HL AE 2149 Houston Ughting & Power Company File No.: C20 Page 2 i
1 I
The tracking method utilized to provide a verified basis for plant readiness for operation is the Plant Completion Verification Program, as described in Reference (4). This program, established in January 1987, i j
approximately six months prior to planned fuel load, has required discipline managers to identify and track activities required for fuel load. These l activities have been punch listed and subjected to periodic review by Project j 1
Management and will be reviewed by the Nuclear Safety Review Board (NSRB). I HL&P's goal has been to meet all requirements necessary to load fuel and l operate up to 5% of rated power at the time of receipt of the Operating License. Any work items not completed at the time of fuel load will be documented. The cognizant engineering, construction and operations managers will have evaluated each item and the Plant Operatins Review Committee (PORC) will have approved any safety-related deferrals and will have determined that completion after fuel load will not adversely affect RL&P's ability to safely load fuel and conduct low power testing. These items will be scheduled for completion prior to the operational mode in which they are needed.
Preoperational and Acceptance Tests which may not be completed prior to fuel load are listed in Attachment 2. For each test listed, projected completion and a justification for deferral is provided. Review by PORC has concluded that fuel load and subsequent testing activities can proceed with no adverse effect on the health and safety of the public and that these tests are not an impediment to fuel load and subsequent startup.
Remaining licensing issues, where closing actions by HL&P are not required by the NRC staff prior to fuel load, are listed as Anticipated Conditions of License in Attachment 3.
Exemptions to the General Design Criteria which have been requested are listed in Attachment 4.
HL&P has performed significant review activity to ensure confidence in the design, construction and testing of the South Texas Project. This has included quality program activities, numerous independent assessments and a program to solici.t employee nuclear safety or quality concerns (SAFETEAM).
These activities are summarized in Attachment 5. Based on these reviews HL&P has concluded that the plant has been'4esigned, constructed and tested in accordance with applicable requirements and is ready for operation.
We anticipate commencing activities to support initial core load as early as June 23, 1987, but no later than June 30, 1987. Completion of design, construction, preoperational testing and a review of the deferred work items and preoperational tests by cognizant engineering, construction and operations management, PORC, and NSRB will ensure that there will be no adverse impact L1/NRC/ka
Enclosure 2 Page 3 of 36 ST-HL-AE 2149 File No.: C20 Page 3 to the health and safety of the public from fuel loading and low power testing activities. Accordingly HIAP requests that the Commission be prepared to issue a license authorizing STP Unit 1 fuel loading r.nd operation up to 5 percent of rated power as early as June 23, 1987.
@. 33 J. H. Coldberg Group Vice President, Nuclear JNB/yd Attachments: 1. Items which will not be completed at Unit 1 Fuel load.
- 2. Preoperational and Acceptance Tests That May Not Be Complete at Fuel load.
- 3. Anticipated Conditions of License
- 4. Exemptions to the General Design Criteria
- 5. Bases for Houston Lighting & Power Company's Confidence in the Quality of the Design, construction and Testing of South Texas Project Unit 1.
l~l 9
L1/NRC/ka I
1
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _f
. Enclosure 2 Page 4 of 36
. ST HL AE 2149 File No.: C20 Houston Lighting & Power Company p,g, 4 cc:
Regional Administrator, Region IV M.B. Lee /J.E. Malaski Nuclear Regulatory Commission City of Austin 611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088 Arlington, TX 76011 Auctin, TX 78767-8814 N. Prasad Kadanbi, Project Manager A. von Rosenberg/M.T. Hardt U.S. Nuclear Regulatory Commission City Public Service Board 7920 Norfolk Avenue P.O. Box 1771 Bethesda, MD 20814 San Antonio, TX 78296 Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 1717 H Street Bethesda, MD 20814 Vashington, DC 20555 Dan R. Carpenter
- Thomas E. Murley, Director Senior Resident Inspector / Operations Office of Nuclear Reactor Regulation c/o U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 7920 Norfolk Avenue P.O. Box 910 Bethesda, MD 20814 Bay City TX 77414
- Frank Miraglia Claude E. Johnson Associate Director For Projects Senior Resident Inspector / Construction Office of Nuclear Reactor Regulation c/o U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 7920 Norfolk Avenue P.O. Box 910 Bethesda, MD 20814 Bay City. TX 77414
- Dennis M. Crutchfield M.D. Schwarz, Jr. , Esquire Director, Division of Reactor Projects-Baker & Botts II/IV/V and Special Projects One Shell Plaza Office of Nuclear Reactor Regulation Houston, TX 77002 U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue J.R. Newman, Esquire Bethesda, MD 20814 Newman & Holtzinger, P.C.
a hi g on DC 2b36 T.V. Shockley/R.L. Range 2-Central Power & Light Company *'
P. O. Box 2121 Corpus Christi, TX 78403 1
- Additions to standard carbon copy list ,
L1/NRC/ka Revised 2/3/87 <
1
l.
Eaclosure 2 Page 5 of 36
)
l ST HL AE 2149 File No.: C20 UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION l
In the Matter of 5 I
Houston Lighting & Power i Docket No. 50-498 l
Company, et al., I S
South Texas Project I Unit 1
~
AFFIDAVIT J. H. Goldberg, being duly sworn, hereby deposes and says that he is l Croup Vice President, Nuclear of Houston Lighting & Power Company; that he is I duly authorized to sign and file with the Nuclear Regulatory Commission the l attached Request for Low Power Operating License; is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge and belief.
n
. W J. H. Goldberg /
Croup Vice Pre (ident, Nuclear STATE OF TEXAS i Subscribed and sworn to before me, a Notary Public in and for the State of Texas, this 26 day of May , 1987. l
$' r Nota Public in and f'or Stat f Texas 9
I!i EO0c2 E$'2 . "*
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Enclosure 2 Page 9 of 36 Attachment 2 ST-HL.AE 2149 File No.: C20 Page 1 of 3 South Texas Project Unit 1 3 Preoperational and Acceptance Test That May Not be Complete At Lead TEST COMPLETION BY JUSTIFICATION Preoperational-
~~
o Boron Recycle (BRO 1; Mode 2 Note 6 14.2.12.2-50) o RCS Liquid Leak Detection Mcdc 4 Note 3 (ED02; 14.2.12.2 44) o Feedwater System (FWO1; Mode 4 Note 3 14.2.12.2 65) o Misc. Areas Temperature- Note 7 Note 7 Surveys (HZ05; 14.2.12.2-98) o Safety Related Heat Tracing Mode 4 Note 5 (NK01) l o Radiation Monitoring System Mode 2 Note 9 i Communication (RA18; 14.2.12.2-50) i o RCB Carbon Units (HCO2; Mode 2 Note 10 14.2.12.2-29) o Vaste Evaporator (VLO2; Mode 2 Note 1 14.2.12.2-96) - ..
o Liquid Vaste (WLO3; Ao'de 2 Note 1 14.2.12.2 97) o Solid Waste Processing Mode 2 Note 1 (WS01; 14.2.12.2-95) o Spent Resin Storage Tank Mode 2 Note 1 (WS02; 14.2.12.2 95) ,
Enclosure 2 Page 10 of 36 Attachment 2 ST-HL AE 2149 File No.: C20 Page 2 of 3 TEST COMPLETION BY JUSTIFICATION Acceptance Test o Plant Computer System Mode 2 Note 11 (Proteus) (CUO1; 14.2.12.2-65A o Feedwater System (FWO1; Full Power Note 2 14.2.12.2-65A) o Emergency Lighting Mode 4 Note 4 Systems - (LA; 14.2.12.2-4A) o Test of RM-11 (RA01) Mode 2 Note 8 other Tests o RTD Response Time Testing Mode 2 Note 12 Note 1: System is not needed prior to generation of radioactivity. System preoperational test will be completed prior to initial criticality.
Note 2: Testing to be conducted during power ascension per the FSAR Commitment.
Note 3: System test will be completed prior to Technical Specification mode requirements.
Note 4: Lightirg systems are operational. Testing will be completed prior to leaving cold shutdown condition (i.e. prior to Mode 4).
Note 5: Freeze protection will not be required for the time period encompassed by low power testing. Testing will be completed prior to Technical Specification mode requirements.
Note 6: System is not safety related nor is it necessary prior to the approachtoinitialcritica{i.ty.
Note 7: Safety-related room cooling systems currently are operational.
Remaining area tests will be performed prior to the Technical Specification mode requirements for the systems served by the area cooling.
Note 8: No radioactivity generated until initial criticality.
l -
l Note 9: System provides additional control room monitoring display capability ,
but is not safety-related nor required by Technical Specifications.
Enclosure 2 Page 11 of 36 Attachment 2 l ST HL AE 2149 File No.: C20 Page 3 of 3 Note 10: System is not safety-related and is only needed for personnel reentry into containment following initial criticality.
l . Note 11: System is not safety-related and is not required for pre criticality testing.
Note 12: Testing must occur during hot precritical conditions: No trip function is necessary prior to initial criticality.
94 1
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O
e r; Enclosure 2 Page 12 of 36 Attachment 3 ST HL AE-2149 File No.: C20 Page 1 of 1 7
Anticipated Conditions of License Inservice Inspection Program
- Mitigation Circuitry Steam Generator Tube Rupture
- IDCA in Shutdown Mode
- Turbine Maintenance Program
- i Deferred Preoperational Testing NUREG 0737 - TMI Item Safety Parameter Display System l
1 l
l
'* Gener R issues (not unique to STP) ;i
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Enclosure 2 Attachm[8E'413 f 36 ST HL AE 2149 -
File No.: C20 Page 1 of 1
, Exemptions to the General Design criteria CDC 4 High, Energy Piping Failures CDC-57 Containment Isolation of the Component Cooling
-Vater Return free the Reactor Containment Fan Coolers 4
e l.
O L1/NRC/ka
Eaclosure 2 L Page 14 of 36 Attachment 5 ST-HL AE 2149 File No.: G20 Page 1 of 13 l
?
AASES FOR HOUSTON LIGHTING & POWER COMPANY'S CONFIDENCE IN THE QUALITY OF THE DESIGN, CONSTRUCTION AND TESTING SOUTH TEXAS PROJECT UNIT 1 PART I - PROJECT QUALITY PROGRAM Houston Lighting & Power Company's Quality Assurance Program contains a number of specific features which provide confidence in the quality of design, construction and testing of STP.
- 1. Audits: H14P, Bechtel (BEC), and Ebasco (ESI), have performed numerous audits of project activities. A summary of these audits is as follows:
H14P H1AP YEAR Project QA Operations QA BEC ESI TOTAL 1982 32 0 60 24 116 1983 37 0 57 54 148 1984 38 7 48 47 140 1985 40 7 34 23 104 1986 45 13 30 20 108 1987 11 ', 10 9 9 39
- TOTAL 203 37 238 177 655
- Completed as of May 22, 1987 In January 1985 significant improvement was made in the Project Audit Program by centralizing the control and administration under HIAP Project Quality Assurance. Features of this central control include a single audit schedule and plan, standardized deficiency reporting, reduced redundancy, and more ,
effective use of resources. ,
Enclosure 3 Page 15 of 36 Attachment 5 ST.HL-AE-2149 File No.: C20 Page 2 of 13
- 2. Surveillance s : HL&P, BEC, and ESI have performed numerous surveil-lances of project activities. A summary of these surveillance is as follows:
YEAR TOTAL 1982 2312 1983 1515 1984 3365 1985 2781 1986 3303 1987 918
- TOTALS 14194
- Completed as of Hay 22, 1987 In January 1985 a significant improvement was made in the Project Surveillance Program by centralizing the administration and control of surveillance under HL&P Quality Assurance. Features of this central control include coordinated surveillance schedules, standardized deficiency reporting, reduced redundancy, and more effective use of resources.
- 3. Procurement Overview Surveillance:
In 1983, HL&P instituted a more rigorous process of assessing the performance of BEC Procurement Supplier Quality (PSQ) personnel as they performed audits and surveillance in the facilities of suppliers to STP. HL&P and BEC QA personnel (independently) visited selected supplier facilities to observe PSQ personnel at work. Criteria used for the selection of suppliers and PSQ individuals to be assessed included the complexity of the product being procured, past pr5blems with the supp, lier, and previous deficiencies associated with the specific PSQ rept,esentative. A summary of these Overview Surveillance is as follows:"
YEAR H1AP BEC TOTAL 1983 3 0 3 1984 20 1 21 1985 26 10 36 [ :
1986 5 3 8 TOTALS 54 14 68
Enclosure 2 Page 16 of 36 Attachment 5 ST-HL AE 2149 File No.: G20 Page 3 of 13 4 Effectiveness Inspections (EI):
i An EI is a replication by HLAP of an inspection previously performed by a J contractor / constructor QC inspector. The purpose of this inspection program is twofold; first to establish confidence that a contractor's/ constructor's quality program is effective, and secondly to support the credibility of the initial inspections. EIs are not intended to be a source of acceptance or rejection of work, but rather a means to measure the quality and effectiveness of first line QC inspection activities.
The EI program evaluated the performance of QC inspection activities in disciplines within general plant construction and included storage, installation, fabrication, maintenance, repair, modification, and construction testing as well as the verification of selected closed NCRs and SDRs. In performing EI Activities, qualified QC personnel: 1) verified that the applicable inspection procedures, instructions, and/or checklists provided all pertinent information and; 2) reperformed the inspection. This program assured that the required inspections were effectively performed and documented.
A summary of EI activity is as follows:
YEAR EI's ATTRIBUTES 1981 40 1155 1982 23 497 1983 124 1519 1984 675 24750 1985 2032 68486 1986 1425 37923 1987
- 147 .; ,' 5517 TOTAL 4466 139847
- To March 22, 1987
- 5. Reject Rates:
The Reject Rates Program at STP was instituted to reinforce the ~
implementation of the HL&P management philosophy of craft accountability for quality. The reject rates are computed by commodity and represent
Enclosure 2 Page 17 of 36 Attachment 5 ST-HL AE 2149 L
File No.: C20 Page 4 of 13 the number of rejected inspections identified by Quality control compared to the quantities of a commodity presented for inspection. The reject rates are computed and reviewed weekly by construction and quality personnel to determine actions required. Each commodity Las a target reject rate which has been established by Construction and Quality Assurance Management.
- 6. Trending:
Prior to 1984, HL&P, Bechtel and Ebasco each maintained its own trending
,, program with overview by HL&P. In 1984 HL&P assumed responsibility for the Project Trend Program. The HL&P Trend Analysis Program is a comprehensive program which receives, reviews, encodes and enters into a data base initial issues of documents identifying conditions adverse to quality. Various computer sorts are made, analyzed, and graphs and appropriate comments prepared on a monthly basis. This information is provided to the Trend Program Committea which consists of HL&P, Bechtel, and Ebasco representatives from the QA, Construction, Engineering, and, as appropriate, Management from each company. The Trend Progren Committee reviews appropriate data in a scheduled monthly meetira and establishes corrective action requirements either by assignment to the responsible committee member or by issuing a Trend Investigation Request (TIR) to the responsible company / department for investigation to determine root cause, establish the scope of the problem and provide corrective action. The TIR remains open until the identified trend adverse to quality is corrected.
A' formal Quarterly Trend Report is distributed to appropriate levels of i management. This report consists of compilations of data presented in graphical and written form and is divided into sections which cover hardware commodities, systems (programmatic), suppliers, engineering design and preventive maintenance. This report highlights trends adverse to quality and describes the effectiveness of corrective actions taken.
- 7. Project Completion Verification Program (PCVP):
A.
As part of the PCVP, HL&P Quality' Assurance reviewed and verified as complete and acceptable all audit and surveillance reports issued from 1982 to che present with particular emphasis on the proper closure of deficiencies.
Examples of other items reviewed by HL&P QA for completeness and/or acceptability included:
- a. Installation and inspection quality records *
- b. Procurement quality records (home office)
9 # ' Enclosure 2 Page 18 of 36 Attachment 5 ST HL AE 2149 File No.: G20
'Page 5 of 13 i
- c. Field procurement activities 1
- d. Design quality records
- e. Nonconformance Report (NCR) and other deficiency report close outs
- f. SAFETEAN concerns PART II
+
INDEPENDENT REVIEWS Houston Lighting & Power Company has. initiated a number of additional specific independent reviews which are discussed below.. Indf.vidually and collectively, these reviews provide a significant contribution to our confidence in the quality of the design and construction of the South Texas Proj ect .
1980 WELDING, SOILS. CONCRETE (Show Cause)
Following the Show Cause Order issued to the South Texas Project in early 1980,. detailed reviews of' safety related welding, backfill and concrete construction at STP were performed.- Three panels of independent experts were retained to assure that the reviews were thorough and reliable. 'The results of these reviews were provided to the NRC Staff and served as part of the basis for closure of the 1980 enforcement actions and vara also considered by the Atomic Safety and Licensing Board (ASLA)'in the hearing on the operating license application. The existing structures and construction activities were shown to be adequate and the ASLB concluded that there was reasonable assurance that' the work complied with applicable regulatory requirements.
1980 QUALITY ASSURANCE PROGRAM '
Bechtel Power Corporation,'-which at the time had no involvement in STP, performed an independent audit of the STP Quality Assurance program. The audit identified a number of deficiencies and made specific recommendations for improvement. The deficiencies were corrected and the recommendations for improvement were acted upon by Houston Lighting & Power Company.
1981 QUALITY ASSURANCE PROGRAM .
The Bechtel Power Corporation returned to the project in 1981 to verify the corrective actions taken as a result of the 1980 audit and to conduct another independent audit of the STP Quality
Enclosure 2 Page 19 of 36 I
Attachment 5 ST HL-AE-2149 File No.: G20 Page 6 of 13 Assurance program. The audit identified a number of deficiencies and made specific recommendations for improvement. The deficiencies were corrected and the recommendations for improvement were acted upon by Houston' Lighting & Power Company.
1981 QUADREX The Quadrex Corporation performed an independent review to assess the status of Brown & Root's engineering and its capability to complete the design in accordance'with project schedules. The Quadrex review identified some difficulties that were being encountered in achieving the schedule for design and engineering of the plant and identified two items later determined to be reportable to the NRC under 10 CFR.50.55(e).
1982 TRANSITION PROGRAM In late 1981. HIAP : eplaced Brown & Root as the architect engineer In for the South Texas Project with the Bechtel Energy Corporation.
early 1982 following Brown & Root's withdrawal as theAconstructor, transition H14P selected Ebasco to be the project constructor.
program was put into place by H1AP to ensure an orderly change of responsibilities. The major components of the transition program are discussed below:
A. Engineering Bechtel was obligated to assume design responsibility for all i architect / engineer work on the Project, including work completed by Brown & Root. Before Bechtel could accept responsibility for the adequacy of the existing design and resume design production, the precise status of all engineering and design work had to be ascertained. Bechtel undertook an inydepth review of the entire STP design to evaluate the adequacy of the existing design as well as to determine what work remained to be dene. The engineering and design for STP was divided into 242 hidividual " work packages." Most work i
packages related to discrete physical structures or plant 4 systems, such as particular buildings, piping, or mechanical and electrical systems. Other work packages covered interdisciplinary matters such as licensing documentation, pipe break analysis, and safe shutdown criteria. The latest revisions of the Project documentation were assembled into each )
work package. The number and type of documents in each work package varied depending on its subject matter. Typical work "
l
. i packages might include system design descriptions, logic )
diagrams, flow diagrams, piping and instrument diagrams, equipment specifications, calculations, vendor drawings, f j
isometric drawings, and other documents.
f
Enclosure 2
, Page 20 of 36 Attachment 5 ST.HL AE 2149 l
File No.: C20 Page 7 of 13 Bechtel thoroughly examined the design documents in each .
1 package. Depending on the nature of the work package, Bechtel evaluated the design assumptions and methods of analysis used by Brown & Root, checked to see'if applicable design criteria and technical requirements were met, assessed the adequacy of design verification, reviewed design drawings and calculations for accuracy, and checked that the latest revisions of documents were being used by all disciplines. In its review of the work packages, Bechtel particularly considered findings of h the Quadrex review Which related to the various work packages and collected the results of that review in a separate it -'
interdisciplinary work package.
Bechtel generated a report on each work package and solicited comments as appropriate from cognizant engineers within Brown &
Root and HL&P. Each report included discussion of any technical problems identified by Bechtel, as well as a description of work necessary to complete the design.- After meetings at which the comments on each work package report were reviewed, the work packsgo reports were revised accordingly and transmitted to HL&P for acceptance. HL&P Engineering accepted each work package by signature. That' signature denoted that th. package reflected'an accurate status, and that that status presented an acceptable basis for continuation of effort.
These work packege reports remain part of the Project ,
documentation and were the basis from which Bechtel resumed 'I design production for STP.
B. Construction Bechtel's takeover cf architect / engineer and construction management functions also necessitated that STP be physically )
examined to determine the exact status of construction at the Proj ect.
Among the key aspects sY Bechtel's review of plant construction was a series of "walkdowns" which collectively covered construction at the plant. During these walkdowns, the installed sections of the plant were checked against applicable design drawings Which, as the walkdowns progressed, were marked up to reflect the extent to which construction of the items represented on the drawings had been completed. The walkdowns also assured that construction had proceeded according to the design or, alternatively, recorded the extent of any deviation .
from the design. Following each system walkdown, Bechtel r l
J l
Enclosure 2 Page 21 of 36 g Attachment 5
- l. ST HL AE 2149 l File No.: G20 Page 8 of 13 reviewed the quality control records for completed construction on that system to verify that these records had been properly generated and maintained. Thus, Bechtel's review not only provided for a physical check of completed work but also assured that documentation existed which provided objective evidence that work had been done properly.
In addition, Bechtel and Ebasco conducted special reviews of safety-related ASME welding at STP to verify that all such welds met Code standards. These were accomplished utilizing a transfer of ASME responsibility agreement signed by all the participants, i.e. , Brown & Root, Bechtel, Ebasco, Westinghouse, and Houston Lighting & Power Company and included examination of the welds, radiographs, and documentation. The State of Texas in their capacity as jurisdictional authority, was also a signatory.
The complete transition process in both Engineering and Construction was performed utilizing approved procedures. HIAP Quality Assurance performed both audits and surveillance during the entire process.
C. Quality Assurance The Quality Assurance Programs at South Texas for Bechtel and Ebasco are based upon their Topical Reports which had been approved by the NRC. These Topical Reports were reviewed and modified to fulfill the unique requirements of the South Texas Proj ec t. The existing HIAP Quality Assurance program was rewritten to reflect the division of responsibility and i relationships between the entities. These programs were then submitted to the NRC in a revision to the existing Quality Assurance Program Description for the South Texas Project.
In summary, the transition program that was conducted during 1981 and 1982 provided for a thorough reexamination of all of the completed as well as the in-)rocess work at the South Texas Project.
It provided a significant additional measure of confidence in the acceptability of those efforts and additionally provided a firm basis for our decision for continuation of the project.
Construction work at STP was restarted in mid 1982. <
1982 QUALITY ASSURANCE PROGRAM Four nuclear utilities performed a joint audit of the Quality Assurance program at the South Texas Project. The audit team was -
led by a representative from Florida Power & Light and included r
u Enclosure 2 Page 22 of 36 Attachment 5
(. ST.HL-AE-2149 File No.: C20 Page 9 of 13 personnel from Southern California Edison, Carolina Electric & Cas, and Duke Power. The audit team identified specific recommendations for improvement, and these recommendations were acted upon by Houston Lighting & Power Company.
1982 - ENGINEERING ASStjRANCE PROGR^M 1987 The Engineering Assurance Program was developed and implemented by Houston Lighting & Power Company with the assistance of Stone &
Webster to provide additional assurance that the design of the STP j is technically adequate and meets applicable licensing commitments and requirements. The program consisted of a detailed review of the technical adequacy of the design of representative STP systems and other design features as well as the design process utilized by Bechtel. Topics that were included in the EA program are:
- Soil structure interaction analysis and seismic design
- Design process review
- ASME III pipe stress analysis
- ASME III pipe support design
- Containment pressure / temperature / radiation analysis
- Equipment qualification
- Separation and fire protection criteria
- Control Room HVAC system
- Off-site and medium voltage AC power supply systems
- High.~ energy line break analysis
- Field walkdowns. [
The results of the EA program demonstrate that the portions of the STP design reviewed are technically adequate and comply with the applicable licensing requirements. This conclusion was documented in the Summary Report submitted to the NRC in March 1987.
1983 SELF INITIATED EVALUATION -
A Self-Initiated Evaluation of the South Texas Project was conducted [
by independent consultants utilizing the Institute for Nuclear Power Oper uons Performance Guidelines and Criteria for Construction Proj e cts . The team identified a nunter of good practices and made several recommendations for improve: rent. The recommendations for improvement were acted upon by Hourton Lighting & Power Company.
_ - _ = _ _ _ ___ .-. . _ - _ _. _
. Eaclosure 2 g ,
Page 23 of M I
Attachment 5
' ST.HL AE 2149 File No.: C20 Pase 10 of 13 1985 INSTITUTE FOR-NUCLEAR POWER OPERATIONS CONSTRUCTION PROJECT EVALUATION Representatives.from the Institute for Nuclear Power Operations performed a Construction Project Evaluation. The evaluation resulted in the identification of several Sood practices and made a number of recommendations for improvement.. Those recommendations for improvement were acted upon by Houston Lighting & Power Company.
1985 PRE-CONSTRUCTION APPRAISAL TEAM'(PRE CAT)
. A pre CAT inspection of the STP was conducted by independent contractors. The inspection topics were based upon a review of CAT reports from other projects. The inspection resulted in a number.
of specific recommendations for improvement. MIAP took action to address these areas.
1986 LITICATION RECORD REVIEW .
The Litigation Record
- Review was conducted by an independent contractor. The object of the review was twofold: (1) to examine the litigation record to determine whether it disclosed any previously unidentified safety-related deficiency in the systems, structures, or components of the South Texas Project or their associated design or quality documents; and (2) to document the review process and its results in a retrievable form. To do this, record documents containing factual information relating'to technical aspects of the design and construction, that is, deposition transcripts, answers to interrogatories, and expert reports were reviewed.
Houston Lighting & Power Company employed a screening process to determine which depositions, interrogatories, and expert reports might contain information about technical aspects of South Texas Project design or construction. Those documents, totaling approximately 100,000 pagest were then given a detailed review by the independent contractors.*
- The record created during the litigation between the owners of the STP and the original architect / engineer and constructor of the project, Brown & Root, > ,
Inc., and its parent, Halliburton, Inc.
Enclosure 2 Page 24 of 36 Attachment 5 ST HL-AE-2149 File No.: C20 Page 11 of 13 The review process consisted of a detailed, line-by-line review of all documents identified during the screening process. Each-assertion in these documents.which described a deficiency in systems, structures, or components; classes of systems, structures, or components; processes relating to specific systems, structures, or components; overall South Texas' Project site data; or related design or quality documents was identified. A total of 5151 assertions were identified. These assertions were then analyzed to determine whether they: (1) were not safety-related (and would not adversely affect the operation of safety-related systems, structures, or components); (2) had already been identified by the South Texas Project; or (3) were factually erroneous.
The $151 assertions identified were disposed of as follows: 482 were determined not to be safety-related; the substance of 4662 were shown to have already been identified by the South Texas Project; and 7 were determined to be factually erroneous. The litigation record review disclosed no safety-related deficiencies which had not already been identified for resolution.
1986 LIMITED READINESS REVIEW AUDIT PROGRAM The Limited Readiness Review program was conducted by independent contractors. The selection of topics to be included in this program was based upon review of topics which had proven troublesome at other projects, may have been troublesome at STP, or which were of specific interest to STP. The topics selected were:
- Seismic interaction
- Concrete
- Material control
- Environmental qualification
- Structural steel ;,
- Settlement monitoring, Each audit was a broad scope technical audit conducted by a team of i
l approximately five individuals including technical specialists. The l audit included a review of the pertinent FSAR commitments and the )
translation of those commitments into work-directing documents. The teams also reviewed work in progress and, as appropriate, performed inspections of completed work. .
This program resulted in the identification of several deficiencies.
Each of the deficiencies was corrected and corrective action was taken to prevent recurrence, l
1' l
L l _-
Enclosure 2 Page 25 of 36 Attechm2nt 5 ST HL AE 2149 File No.: G20 Page 12 of 13 M8,6 DELIAN REPORT The Delian Corporation conducted a review of operational readiness of South Texas Project approximately one year prior to tlie planned issuance of the operating license. The review focused on specific actions necessary to assure an effective transition of Unit 1 from construction, through startup, to operations.
The review explicitly examined the following:
a) Strategy and objectives associated with plant operation b) Organization and staffing for operations c) Effectiveness of operations support d) Plans for operations oversight e) Specific management control systems associated with operations and operations support.
The review resulted in a number of recommendations which were acted on by Houston Lighting & Power Company.
1987 INSTITUTE OF NUCLEAR POWER OPERATIONS NEAR TERM OPERATING LICENSE PREOPERATIONAL REVIEW AND ASSISTANCE VISIT Representatives of the Institute of Nuclear Power Operations (INPO) conducted a Near Term Operating License preoperational review and assistance visit in March of 1987. The South Texas Project Electric Generating Station was evaluated against the INPO performance objectives and criteria with a focus on preparation and readiness for operating the station in a safe and reliable manner.*
INPO identified a number of beneficial practices and accom-plishments. Recommendations were also made in a number of areas.
HL&P will act on the recommendations.
1987 INSTITUTE FOR NUCLEAR POWER OPERATIONS CORPORATE SUPPORT EVALUATION Representatives from the Institute for Nuclear Power Operations in May 1987 performed a Corporatt Support Evaluation. The evaluation centered on the interface between corporate activities and the nuclear station. Emphasis was placed on corporate monitoring of station activities, since monitoring is necessary for effective support.
Recommendations which are forthcoming will be acted on by Houston Lighting & Power Company.
- Areas reviewed included a) station organization and administration; b) operations; c) maintenance; d) technical scpport; e) operating experience review; f) training and qualification and; g) radiological protection, and chemistry.
L
-Enclosure 2 Page 26 of 36 Attachment 5 J ST.HL AE 2149 1 File No.: C20 Page 13 of 13 j PART III SAFETEAM SAFETEAM was put into place at the South Texas Project in September 1984.
SAFETEAM provides a forum for employees to identify any concerns that they might have regarding nuclear safety or quality. Those concerns are
,svestigated, corrective actions are undertaken, and a written response is
..ovided to the. person identifying the concern.-
The table below summarizes the activities of SAFETEAM through April of 1987.
Total Contacts 28,600
- Class I Concerns Received 896 Class I Concerns closed 861 I
Class I Concerns Substantiated 192
- Nuclear safety / Quality I substantiated means that the investigation determined that, in whole or in part, the stated concern was accurate.
To. assess the credibility of SAFETEAM among the craft personnel at the South Texas Project, SAFETEAM enlisted the services of an independent contractor in
-the summer of 1986 to perform an Attitude Survey. That Attitude Survey indicated that 92 percent of a sample of craft personnel were aware of SAFETEAM, and that 806 would go to SAFETEAM if they had a concern. Among the members of that sample who had direct knowledge of SAFETEAM, i.e., they had used the program t1emselves or knew of someone who had used the program, ninety seven percent indicated they w'ould go to SAFETEAM with a nuclear quality or safety-related concern.
e
. Enclosure 2 2 @ SOV/G.T : -
i' Page 27 of 36 .h ,
. The Light #
- MlL MmPuy nee,,ee t,8s, , & Pe e, no. nex 3200 iue,,e .re, ,2>ooi <>is> 228 92ii
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July 10,1987 i ST HL AE-2283 j File No.: G20 {
10CTR50 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 1 Washington, DC 20555 South Texas Project Unit 1 Docket No. STN 50 498 Update of Statement of Completion and Request for low Power Operating License
References:
- 1. Letter from G. E. Vaughn to NRC, Document Control Desk dated July 10,1987 (ST-HL-AE-2297)
- 2. Letter from J. H. Goldberg to NRC, Document Control Desk dated May 16, 1987, Statement of Completion and Request for Low Power Operating License (ST HL AE-2149)
Construction and preoperational testing of the South Texas Project Unit 1 (STP 1) will be substantially complete and the Unit ready for fuel loading on July 14,1987. The activities remaining to be completed before fuel loading are the actions to,be taken in response to the observations of the NRC Inspectors during ,the recent NRC inspection of the physical security system.
Those observations and HMP's responses are summarized in Reference 1.
Reference 1 identifies certain action.sNwhich will be undertaken by Houston Lighting 6 Power Company. These actions have been discussed with Region IV personnel, but their acceptability has yet to be established. We believe that subject to completion of those actions identified in Reference 1 earmar'ked for completion by July 14, 1987, that the physical security system will be adequate to support fuel loading and low power operation.
By letter dated July 7,1987 the NRC sent HMP draft page changes to the May 18, 1987, Final Draf t Technical Specifications and requested that HMP f certify that, as revised, the draft Technical Specifications are consistent ..
with the Final Safety Analysis Report, the Safety Evaluation Report and the as-built facility. HMP review is expected to be complete and certification mede to the NRC on July 13, 1987.
1=70 w o W 5-
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Enclosure 2 _
Page 28 of 36 l l
3 L 8 Houuon Lighting A: Power Compan) F 2 Page 2 d
Reference 2 described the anticipated status of STP-1 at the time of fuel loading. The attachment to this letter updates the list of the preoperational and acceptance. tests that may not be completed at the time of fuel loading which was submitted as Attachment 2 to Reference 2. The changes, including added tests, are identified by bar in the right margin. In addition there are some tests, not listed in the attachment, which have been essentially -
completed except for a few individual test open items. The status and achedule of preoperational and acceptance tests have been reviewed with Region i IV. Other aspects of Reference 2 remain up-to-date. I Based on the above information HIAP requests that on July 14, 1987, the
~ Commission issue a license authorizing fuel loading and operation of STP Unit ,
1 at power _ levels not to exceed 5 percent of rated power. j k
D. i J. H. Goldberg Group Vice Pre ident, Nuclear SMH/hg
Attachment:
Preoperational and Acceptance Tests That May Not be Complete at Fuel Load ;
4
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L1/a/ac __
Enclosure 2 Page 29 of 36 ST-HL-AE-2283 File No.: C20 UNITED STATES Of AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Houston Lighting & Power - Docket No. 50-498 Company, et al., -
South Texas Project -
Unit 1
.w..
AFFIDAVIT J. H. Goldberg, being duly sworn, hereby deposes and says that he is Group Vice President, Nuclear of Houston Lighting & Power Company; that he is duly authorized to sign and file with the Nuclear Regulatery Commission the attached Update to the Statement of Completion; is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge and belief.
/
. $2
'J . H. Goldber's y Group Vice President, Nuclear STATE OF TEXAS -
Subscribed and sworn to before me, a Notary Public in and for the State of Texas, this 10E day of , 1987.
41 7 r
.( Notary Publi4/ irL4nd for the Q \ g State of Texas s , a StyDtLY1FITE !
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Eaclosure 2 Page 30 of 36l ,
ST-HL-AE 2283 File No.: C20 Hounon Ughting k Power Compan) p,g, 3 cc:
Regional Administrator, Region IV M.B. IAe/J.E. Malaski Nuclear Regulatory Commission City of Austin 611 Ryan Plaza Drive, Suite 1000 P.O. Box 1088 Arlington, TX -76011 Austin, TX 78767-8814 N. Prasad Kadambi. Project Manager A. von Rosenberg/M.T. Hardt U.S. Nuclear Regulatory Commission City Public Service Board 7920 Norfolk Avenue P.O. Box 1771 Bethesda, MD 20814 San Antonio, TX 78296 Robert L. Perch, Project Manager Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 1717 H Street Bethesda, MD 20814 Washington, DC 20555
~
Dan R. Carpenter
- Thomas E. Murley, Director Senior Resident Inspector / Operations Office of Nuclear Reactor Regulation c/o U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 7920 Norfolk Avenue P.O. Box 910 Bethesda, MD 20814 Bay City, TX 77414 Claude E. Johnson
- Frank Miraglia Senior Resident Inspector / Construction Associate Director For Projects c/o U.S. Nuclear Regulatory Office of Nuclear Reactor Regulation Commission U.S. Nuclear Regulatory Commission P.O. Box 910 7920 Norfolk Avenue Bay City, TX 77414 Bethesda, MD 20814 M.D. Schwarz, Jr., Esquire
- Dennis M. Crutchfield Baker & Botts Director, Division of Reactor Projects-One Shell Plaza II/IV/V and Special Projects Houston, TX 77002 Office of Nuclear Regulatory Commission 7920 Norfolk Avenue J.R. Newman, Esquire Bethesda, MD 20814 ,
Newman & Holtzinger, P.C. !
1615 L Street, N.W.
Washington, DC 20036.
R.L. Range /R.P. Verret .e Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403
- Additions to standard carbon copy list.
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L4/NRC/mb/hg 0 Revised 6/23/87
Enclosure 2 Page 31'of 36 Attachment 1 ST-HL AE-2283 File No,.; G20 Page 1 of 3 South Texas Project Unit 1 Preoperational and Acceptance Tests That May Not Be Complete At Fuel Load TEST COMPLETION BY JUSTIFICATION.
Preoperational o Boron Recycle (BRO 1; Mode 2 Note 1 14.2.12.2 50) o RCS Liquid leak Detection Mode 4 Note 2 (ED02; 14.2.12.2 44) o ECW Essential Chiller (Note 3) Note 3-Valves (EWO5; 14.2.12.2.-88) o Feedwater System (FV01; Mode 4 Note 2 14.2.12.2 65) o Misc. Area Temperature (Note 4) Note 4 Surveys (HZ05; 14.2.12.2-98) o Safety Related Heat Tracing (Note 5) Note 5 (NK01) o Liquid Effluent Monitors - Mode 2 Note 1 (TGB' Sump - RT 8041 only)
(RA04; 14.2.12.2 50) o Radiation Monitoring System Mode 2 Note 6 Communication (RA18; .'
14.2.12.2-50) i' o RCB Carbon Units (HCO2; Mode 2 Note 7 14.2.12.2-29) o Vibration Testing (RC06; Full Power Note 8 ;
14.2.12.2-77) !
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Enclosure 2-Page 32 of 36 Attachment 1 i ST HL AE-2283 File No.: C20 i Page 2 of 3 TEST- COMPLETION BY JUSTIFICATION Preoperational o Thermal Expansion Testing Full Power Note 8 (RC07; 14.2.12.2-77) o Transient Vibration Full Power Note 8 (RC08; 14.2.12.2-77) o Waste Evaporator (WLO2; Mode 2 Note 9 14.2.12.2 96) o Liquid Waste (WLO3; Mode'2 Note 9 14.2.12.2 97) o Solid Waste Processing Mode 2 Note 9 (WS01; 14.2.12.2 95) o Spent Resin Storage Tank Mode 2 Note 9 (WSO2; 14.2.12.2 95).
Acceptance Test o Plant Computer System Mode 2 Note 10 (Proteus) (CUO1; 14.2.12.2-65A o Boronmeter Full Power Note 11 (CV01; 14.2.12.2 48) o Feedwater System (FWO1; Full Power Note 12 14.2.12.2 65A) i o Emergency Lighting Mode 4 Note 13 Systems - (IA; -
14.2.12.2 4A) ~ ,
j ~1 Note 1: System / Monitor is not safety related nor is it necessary prior to the approach to initial criticality.
Note 2: System test will be completed prior to Technical Specification mode I requirements.
Note 3: Majority of test is complete. Portion of test required to vgrify operation with low Ultimate Heat Sink temperature (i.e., <53 ) will '
be completed by September 30, 1987.
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Enclosure 2 Page 33 of 36 Attachment 1 ST HL AE-2283 Tile No.: G20 Page 3 of 3 Note 4: Safety related room cooling systems currently are operational.
Remaining area tests will be preformed prior to the Technical Specification mode requirements for the systems served by the area cooling.
Note 5: Heat tracing is not expected to be required prior to completion of the system test. Operability of affected systems will be maintained in accordance with the Technical Specifications.
Note 6: System provides additional control room monitoring display capability but is not safety related nor required by Technical
, Specifications.
Note 7: System is not safety related and is not needed prior to personnel reentry into containment following initial criticality.
Note 8: To fulfill test requirements full power operating conditions must be established.
Note 9: System is not needed prior to generation of radioactivity. System preoperational test will be completed prior to initial criticality.
Note 10: System is not safety-related and is not required for pre-criticality testing.
Note 11: Monitor not required for plant operations. Boron concentration will be determined by sampling during operations.
Note 12: Testing to be conducted during power ascension per the FSAR commitment.
Note 13: Lighting systems are operational. Testing vill be completed prior to leaving cold shutdown condition (i.e. , prior to Mode 4).
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