ML20247E189

Forwards Assessment of Self Evaluation Results for Jan-May 1989 Assessment Re Plant Readiness to Continue Power Ascension Testing.Util Self Evaluation & Results of NRC Insp Supported Continuation of Power Testing for Unit 2

ML20247E189
Person / Time
Site:	South Texas
Issue date:	07/21/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8907260109
Download: ML20247E189 (9)

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M W Qlg In Reply' Refer To: '

Dockets: 50-498 50-499-1 L - Ho'uston Lighting & Power Company ATTN: J.~H. Goldberg, Group Vice President, Nuclear P.O.. Box 1700 Houston, Texas .77001 Gentlemen:

This refers to the May 26. 1989, (HL&P self-evaluation of the readiness ofHouston South Texas Lighting & Power Project, Unit 2 Company (STP-2))to continue power ascension testing at power levels greater than 50 percent of rated power and to the NRC's assessment of the self-evaluation results. Our assessment concluded that HL&P's self-evaluation and the results of NRC inspections supported the continuation of power ascension testing for STP-2 through commercial operation. Subsequently, on May 29, 1989, STP-2 proceeded beyond the 50 percent power ascension testing plateau.

. The results of ^ourl assessment are documented in the enclosed report. This special = assessment supplements, but does not supersede our. normal Systematic Assessment of Licensee Performance.(SALP) process.

1: Should you have any questions concerning this report, we will be pleased to discuss them with you.

Sincerely.

Tkmss ? G~$nn ifJames L. Milhoan, Director i Division of Reactor Projects

Enclosure:

Assessment Report 50-498; 50-499 cc w/ enclosure:

Houston Lighting & Power Company ATTN: M. A. McBurnett, Manager

. Operations Support Licensing '

P.O. Box 289 Wadsworth,' Texas 77483

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%> Citiy' PubliclService Board ATTN: :R. J. Costello/M. T. Hardt P.O.-Box 1771.

San. Antonio Texas 78296 o Houston Lighting &. Power Company

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4 ASSESSMENT REPORT

, x U.S. NUCLEAR REGULATORY COMMISSION REGION IV ASSESSMENT OF LICENSEE SELF-EVALUATION 50-498 50-499

' Houston Lighting iPower Company South Texas Project Units 1 and 2 January 1 through May 30,: 1989 I

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1.0 Introduction In its letter to NRC dated March 17, 1989, regarding operation of South Texas Project, Unit 2 (STP-2), above 5 percent reactor power, Houston Lighting & Power Company (HL&P) committed to perform an evaluation of the readiness of the plant staff to operate STP-2 at power levels in excess of 50 percent of rated power. On March 28, 1989, HL&P received a full power license for STP-2. On May 26, 1989, while at the 50 percent reactor power testing plateau, HL&P submitted a self-evaluation of the licensee's readiness to operate STP-2 at reactor power levels in excess of 50 percent.

.NRC reviewed the licensee's self-evaluation to assess HL&P's readiness to operate above 50 percent reactor power and to determine adjustments, if any, to the planned inspection coverage for STP-2. The NRC assessment used the Systematic Assessment of Licensee Performance (SALP)

Report 50-498/88-88; 50-499/88-88, for South Texas Project, Units 1 and 2, which assessed performance of STP-2, January 1 through December 31, 1988, as a departure point. The Region IV operational readiness assessment of STP-2 performed March 13-17, 1989, the monthly inspections by the resident inspectors, and the seven inspections by region based inspectors, conducted January through May 1989, were used as points of reference for the assessment. The focus of the assessment was the depth of licensee resources regarding its capability to safely operate two units.

2.b Overall Ev'aluation NRC assessed HL8P's self-evcluation and determined that the licensee's conclusion, regarding operation of STP-2 in excess of 50 percent reactor power, was in general agreement with NRC inspection findings. NRC also determined that continued inspection coverage, by the resident and region based inspectors as approved in the STP-2 Master Inspection Plan issued on May 23, 1989, was the appropriate inspection effort to monitor continuation of the STP-2 startup program.

This assessment concludes NRC review of HL&P's self-evaluation. Although j the assessment uses SALP methodology, it is in addition to the SALP process. The assessment period of the next STP SALP will not be adjusted for this assessment.

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3.0 _ Assessment Details 3.1 Plant Operations The most recent SALP report for the functional area of Plant Operations nnted that HL&P's performance, during startup and commercial operation on j Unit 1, was good and that the licensee effectively used the lessons j learned during the startup of Unit 1 to improve the preoperational testing i for Unit 2. The SALP noted the frequent involvement of corporate management in the day-to-day decisionmaking regarding safe operation of i

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the plant, the stable operations staff, and appropriate balancing of staff experience. Operations problems experienced early in the SALP period were discussed and the report recommended HL&P management continue to stress attention to details.

The HL&P self-evaluation concluded that in terms of personnel availability, training, definition of roles, communication between units, and configuration; 'nanagement, the Plant Operations Department was ready to continue power 6r.ct.nsion. The self-evaluation noted that there had been few operator-cas :e( operational events in the first 5 months of power ascension test):a of STP-2. The self-evaluation noted some events which it described as events involving human performance and the administrative programs used to document testing requirements and followup actions. The self-evaluation noted that the events demonstrated the need for increased attention to detail by operators in the course of their duties.

The self-evaluation also briefly described several programs focused on assuring management involvement. These included a formal Senior Management Surveillance Program which required the senior HL&P managers to perform monthly walkdowns of both units with results from the walkdowns reviewed by the NSRB Chairman and the Group Vice President, Nuclear.

NRC inspection findings were, in general, consistent with HL&P's self-evaluation. Attention to detail, as noted by HL&P, was an area that should continue to be stressed. On the whole, however, HL&P continued to show improvement as it gained experience with the operation of both STP-1 and STP-2. Management involvement continued to be a strong factor in the licensee's development of, what can best be described as, an operating maturity.

HL&P appeared to have adequate resources and appropriate managenent involvement regarding its capability to operate two units safely. NRC inspection efforts continued at the normal level as approved in the STP-2 Master Inspection Plan in this functional area.

3.2 Radiological Controls The 1988 SALP report for this performance area noted a well qualified staff with a low turnover rate. Management involvement and overall performance were good. The SALP report concluded that, although performance was good in this area, a review of performance during extended operations, such as a refueling or major maintenance outage, was needed to arrive at a more comprehensive evaluation.

HL&P's self-evaluation in this area concluded that adequate staffing and experience existed for two-unit operation and that lessons learned from STP-1 were properly applied to STP-2. The self-evaluation also noted that provisions were in place to supplenent the STP staff with contractor health physics personnel for outages.

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The results of NRC inspections. conducted in this performance area, for the

. period of this review, support the results of the licensee's self-evaluation. Inspection in this area consistent.with the Core Inspection Program was appropriate. Additional inspection by way of Regional Initiatives, regarding extended outages, had been included in the l- Master Inspection Plan to address the scheduled refuelino outage of STP-1.

3.3 Maintenance and Surveillance The most recent SALP report for this functional area indicated a need for better implementation of the maintenar,ce programs that were in place. The report also noted that the surveillance p.ogram showed weaknes,es such as missed surveillance, late surveillance, and incorrect procedures early in the 1988 assessment period.

HL&P's self-evaluation of the Maintenance Department concluded that the department has sufficient numbers of skilled personnel to support safe plant operation. The self-evaluation noted that work practices had been improving and that management involvement, in task prioritization and scheduling, was assuring that maintenance activities were adequate for safe operation of both units. The self-evaluation also referred to a maintenance department self-assessment that identified program inefficiencies, but had no findings affecting quality or safety. Details regarding the assessment were not provided. HL&P's self-evaluation of the Plant Engineering Departnent, which among other things is responsible for scheduling of Technical Specification surveillance, was that surveillance scheduling had generally been performed satisfactorily.

These conclusions regarding maintenance and surveillance were consistent with inspection findings notwithstanding that a significant number of the licensee event reports for both STP-1 and STP-2 were with regard to personnel error, missed surveillance, or missed postmaintenance testing.

HL&P on its own initiative, met with Region IV personnel on May 30, 1989, to discuss, among other things, its actions to correct these occurrences which HL&P characterized as human performance deficiencies. (See Meeting Summary 50-499, datedforwarded June 21, 1989. to HL&P by) letter from Mr. James L. Hilhoan, 50-498; On balance, NRC concluded that HL&P management identification, and involvement in correction of problems in this functional area offset the weaknesses identified. The STP-2 Master Inspection Plan iacluded additional inspection effort directed towards the mainter,ance program and

.urvef'.!ance testing.

3.4 Emergency Preparedness The 1988 SALP report indicated that HL&P had appropriate staffing, effective management support, and excellent response facilities. HL&P's self-evaluation concluded that the Emergency Preparedness Division is ready to support continued power ascension of STP-2. The self-evaluation drew on HL&P's performance during the April 26, 1989, full participation i

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exercise as a basis'for this conclusion. The self-evaluation did note that accounting for_ personnel in a more timely manner was an item identified as needing improvement.

NRC inspectio6 findings supported HL&P's conclusion. The licensee's performance during the full participation exercise was good. Since the exercise, adequate interim actions have been taken to address the personnel accounting problem. In addition to,the annual exercise, the STP-2 Master Inspection Plan included inspection of staffing and training in this functional area.

3.5- Security-The most recent SALP report noted a marked improvement in this functional area during 1988. HL&P's self-evaluation merely stated that the physical security program was demonstrated adequate for two unit operation prior to licensing of STP-2 and remained so at the time of the self-evaluation.

The NRC inspection in this functional area indicated good performance.

The STP-2 Master Inspection Plan reflected a level of inspection appropriate to address HL&P's performance in fully implementing the security program for both STP units.

3.6 Engineering and Technical Support The 1988 SALP *eport noted good resolution by HL&P of difficult technical problems in a timely and effective manner. The report also noted the conservative approach routinely exhibited by HL&P. Some weahnesses in procedure details were discussed and the report recommended that attention be focused on procedure review and revision especially regarding equipment labeling.

HL&P's self-evaluation discussed the success the SuppcrL Engineering Department has had dealing with a number of significant problems regarding

- STP-1 and the depsrtment's ability to take appropriate corrective actions in support of both units. HL&P's discussion of.Overall Station Performance detailed some of the equipment problems that occurred on both STP-1 and STP-2 during STP-2's startup programi The self-evaluation concluded that sufficient engineering depth existed to safely operate both units.

NRC inspection results were consistent with the above conclusion.

Resolution of engineering problems was good once the licensee identified the problem. Regarding the procedure shortcomings identified in the SALP report, insufficient time has passed to see results of the licensee's procedure enhancement efforts. To a large extent, the procedure deficiencies were offset by the training and performance of the operators.  :

Continuing the normal level of inspection consistent with the Core Inspection Prograr vas appropriate. j l

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3.7 Safety Assessnent/ Quality Verification The 1988 SALP report noted that performance in this area clearly demonstrated HL&P's commitment to safety. The completeness of technical submittals, effective corrective actions regarding major issues, and the demonstrated commitment to safe operation all reflected a strong management involvement.

The HL&P self-evaluation of the various departments discussed effective management involvement and the ability to apply lessons learned from the operation of STP-1 effectively to STP-2. The NRC inspection effort produced findings consistent with the observation that a good safety culture existed at STP. Inspection activity consistent with the Core Inspection Program was appropriate for this functional area.

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