ST-HL-AE-3110, Readiness to Begin Ascent to Full Power:Self Assessment Rept

Readiness to Begin Ascent to Full Power:Self Assessment Rept

ML20247K324
Person / Time
Site:	South Texas
Issue date:	05/17/1989
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20247K321	List: ML20247K316 ST-HL-AE-3110, Readiness to Begin Ascent to Full Power:Self Assessment Rept
References
ST-HL-AE-3110, NUDOCS 8906010270
Download: ML20247K324 (24)

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Results.

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III.m , Assessment.of' Individual' Departments

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~A'. Plant. Operations

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C. Technical Services ,

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H.. Nuclear Engineering'.

'" .I. Licensing J.' Nuclear Assurance K.-Overall Station Performance 1

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INTRODUCTION The purpose of this report is'to assess-the readiness of the South Texas Project. Electric Generating Station (STPEGS), Unit 2 to' conduct operations at power levels exceeding fifty percent of rated power. Houston Lighting & Power Company (HL&P) performed a

-detailed review of the performance of the physical plant and operating staff of STP Unit 1 prior to operation of that unit at power levels above fifty percent of rated power. In planning to.

perform a review of the performance of Unit 2, HL&P decided _not to_ duplicate the review performed for Unit 1. The Unit 1 review, and other assessments performed in connection with the startup and initial operation of Unit 1, demonstrated the adequacy of the station procedures and programs. The review for Unit 2 therefore did not repeat those assessments.

Two general requirements were determined to be pertinent to the entire operating staff and as such, were evaluated across all departments. These were to:

1. demonstrate the availability of adequate numbers of skilled personnel to support two unit operations; and

2. demonstrate management presence and involvement which reinforces high standards of performance, and which assures that appropriate guidance and training is provided, especially to less experienced individuals.

Finally, a review was performed to assess the performance of key plant departments.

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. Instead,,the, review plan developed forf UnitL2gfocused on ithree. principal areas:-

r b 1. performance of. Unit 2 systems and equipment;'  !

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performance of Unit 2 operating staff; and

3. evalu'ation'of~ station's ability to properly' operate and maintain two units. q Two senior managers, the General Manager, Nuclear. Assurance

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p 'and'the' General Manager, AdministrativeLSupport prepared a review- j

. plan and performed the review. Each manager conducted an.

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evaluation of areas not under'his supervisory control (See Attachment 1). Their reviews consisted of interviews of responsible department managers, written responses to questions and; tours.of work spaces. Thus, the review includes qualitative evaluations as well as quantitative analysis. Based on this information, the senior managers evaluated the:' readiness of each

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department to proceed with two unit operations. This report  ;

documents the results of these evaluations.

At the NSRB meetings of February 8, March 8, and May 18, 1989, the review plan, progress and final report were reviewed 1 and accepted by NSRB.

RESULTS Station Staffinq p

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An evaluation was conducted by each responsible department j manager to assess the adequacy of staffing-in terms'of numbers ,

1 and skills of personnel. This assessment was performed approximately six weeks after receipt of the low power license l L2/JNB06/L  !

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for Unit 2 and ten weeks after turnover of the majority of systems and areas to the Nuclear Plant Operations Department (NPOD) staff. By performing the evaluation at that time, HL&P was able to take an early view of the capability of the plant l

l staff to support two unit operations. Experience from testing and operations to date supports the earlier evaluation.

This evaluation was primarily based on oral presentations by department managers and confirmed that each department has an adequate number of skilled personnel to fulfill their respective responsibilities for assuring the safety of operations of the two units.

In the cases where a department had not yet been called upon to implement the full scope of its ultimate responsibilities the department manager was required to demonstrate adequate planning to properly perform projected future work. Health Physics was such a department, since the radiological conditions on the station are relatively clean, in part due to the short operating history of the units. The Senior Manager reviewed and concurred with the Department Manager's assessment.

During the assessment, a fire outside of the Main Generator shell on Unit 1 necessitated a month long outage on Unit 1 during the initial startup of Unit 2. This outage provided an unexpected opportunity to evaluate plant staff performance during a period of unusually high demands on both units. The review demonstrated the capability of the plant staff to support both units and the capability of management to manage these resources; the outage plan was carefully followed while the Unit 2 startup L2/JNB06/L 05/17/89

continued. Overall, the satisfactory performance in the areas of operations, maintenance, planning and scheduling and engineering support during the outage is considered an important indicator of the readiness of the plant staff to operate both units.

In addition, an independent consultant performed a review of.

station staffing. 1The evaluation included a brief review of-the allocation of work scope between departments and concurrence with anticipated workload so that a check against industry staffing

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levels could be made. The report, received.by HL&P in late February, concludes that current-STP staffing levels are adequate to support two unit operation.

Turnover of personnel, especially of licensed operators and technical supervisors, has been closely monitored by management since the receipt of the operating license on Unit 1.

Now that Unit 2 is in-its final phase'of testing, retention of those key personnel associated with bringing the units online is of special concern. In the last 6 months one licensed operator and a few technical supervisors have resigned. Capable replacements for these individuals have been identified, typically from within the existing staff and adequate numbers of trained staff remain available to safely operate the units. As a final indicator, the total site voluntary turnover in the last six months has been about 3%. HL&P considers this turnover rate I

to be acceptable at this point in the project.

Based upon the factors discussed above, i.e., Department Managers' assessments, successful performance of the unscheduled 1

outage, the contractor's evaluation and control of turnover, L2/JNB06/L 05/17/89 .

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1 staffing is considered:to be. adequate, both in' numbers and in skills'to safely operate both units.

Management Involvement The level of management involvement is-judged to be adequate. ' Personnel necessary for the" operation'of both units are located at the site, not at remote offices. The Station

. Problem Reporting Procedure assigns responsibility to manager j level personnel for correction of problems.- Department Manager level personnel participate in daily meetings to discuss station activities, problems and prioritization of tasks. .This ensures

both. initial management involvement and management follow-up as the items progress.

Management is devoting sufficient attention to NRC findings to assure they are addressed in a timely manner. Findings of the Nuclear Assurance Department.are assigned to managers.for I

resolution. High priority items are being addressed and resolved in a timely manner. Efforts are underway to show improvement in the completion of the lower priority items. In addition, management'has defined a set of Performance Indicators (Attachment 2) which provide insight into overall station performance. Performance Indicators are received monthly. Any Industry overall Indicator displaying a continued negative trend l would require the responsible Department Manager to submit a plan for-improvement to the Executive Committee.

The members of this committee include the Vice President,' Nuclear Operations, the Vice President Nuclear Engineering ane Construction, the NSRB L2/JNB06/L '

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Chairman, the General Manager Nuclear Assurance and the Plant' L Manager.

ALformal Senior Management Surveillance Program is in place which' requires'the senior managers to perform monthly walkdowns

.of both units, including the Control Rooms. Reports from these walkdowns are reviewed by the NSRB Chairman and the Group Vice President, Nuclear. Corrective actions arising from these walkdowns are assigned to the responsible Department Managers for completion.

Operations and Operations Support have removed ene level of management in their respective organizations. This wLs done to shorten.the lines of ccamunication and to improve department responsiveness. . These changes will allow the overall l organization to better meet the needs of the station as it begins commercial operation on both units.

In summary,. active management involvement in station activities is mandated by the manageuent style of the organization and implementation is routinely demonstrated.

This assessment has:been confirmed by'the-NRC. The latest SALP Report for STP, dated March 20, 1989 states that " Management attention was evident and the licensee showed its ability to learn from experience and conduct safe operations."

ASSESSMENT OF INDIVIDUAL DEPARTMENTS In addition to the review of the generic attributes of i adequate plant staffing and management involvement, certain individual departments were assessed to provide additional L

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performedLby the : General- Manager, . Nuclear. Assurance and the c

4 tGeneral Manager, Administrative Support. .A summary ofEthe w

, results of that. review is presented below.

. Plant Operations The Operations' Department has.. a sufficient : number of-m licensed personnel to man a five' shift' rotation using eight hour y

per day l shifts with at~least'one additional licensed operator on-each shift'above the' requirements'of the Technical Specifications. Personnel with hot operating experience gained.

from other operating nuclear units and from STP Unit ~1.have been-divided ~among:the. shifts to provide' seasoned personnel with hot '

l operating experience'on each operating shift for both units. r

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iTraining of operators is judged to be adequate based in part.upon

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there having been few. operator-caused operationalt events in the

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.first five months of low power and. power ascent testing of Unit 2.

An operational event (described in LER 89-011 Unit 2) occurred when an operator omitted two steps in the procedure for p performance of the Main Turbine Operability testing. This resulted in actuation of the reactor trip and safety injection.

. systems'while Unit 2 was in' Mode 3 during heat-up prior to h- criticality on April 10, 1989. Corrective action included T -

l changes to'the' heat-up procedure, counseling'of'the individual

" and inclusion as a lesson learned into the Licensed operator Requalification Program.

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LIn the time period from'early March'to early April.four similar Technical Specification violations occurred; two on each unit. Each involved the administrative programs used to' document

. testing. requirements or follow-up actions and human performance.

The most significant of these (LER 89-010. Unit 2), withdrawal of a shutdown bank-in violation of~ Technical Specifications, is generally illustrative of all. In this case, the-licensed operator failed'to identify in the Operability Tracking Log all of the limitations on the plant, although the procedure required.

such information. As a result, a later shift did not recognize that.-the Technical Specification restriction was applicable and withdrew a shutdown bank. Corrective actions resulting from these events include enhancing the work process program, improvements to the Operability Tracking Log procedures and inclusion of the events in the Licensed Operator:Requalification Program. There have also been events in nonsafety related systems of which two are discussed in the overall Station Performance Section (page 16).

Although overall operational performance hes been satisfactory, these events demonstrate the need for increased attention to detail by operators in the course of their duties. j operations management is working to improve both operator performance and support programs to minimize future occurrence of such events.

The South Texas units are replica plants. As a result, only a few services serve both units. These common services include the fire protection system, the demineralized water system and L2/JNB06/L 05/17/89 l 1 l .

the auxiliary steam systems. The coordination between the shift supervisors in each unit in terms of operational control and use of these services was evaluated and found to be satisfactory. j It was observed that operations Management regularly acts to ensure that changes identified as necessary on one unit (either procedural or hardware in nature) are promptly communicated to the other unit. Decisions to make changes are properly controlled and implemented. This systematic approach to configuration management pays dividends in operator knowledge and involvement, as well as maintaining consistent plant records.

The evaluation concluded that in terms of personnel availability, training, definition of roles and communication between units, as well as configuration management, the Plant operations Department is ready to continue power ascension.

Maintenance The plant material condition receives continual attention, and the Maintenance Department performance is closely monitored.

On May 10, 1989 the corrective maintenance workload was I approximately 2500 total items for both units. This level is not considered excessive at this stage in station startup. However, additional craft personnel have been added to the maintenance l staff to increase the maintenance item workoff rate and improvement is evident. Further staff increases are planned.

1 Maintenance work is prioritized and scheduled using the same methods that have proven successful on Unit 1 to ensure safe operation of the units. Operations management, through daily meetings, is informed of the status of outstanding maintenance l

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requests'and. participates in prioritizing~ maintenance activities.

i The-Work Control Center coordinates maintenance activities to optimize the work done during train outages'and the allocation of manpower.

3 The Maintenance Department has completed a self assessment L

( using INPO' criteria, and.the' assessment process involved an ]

' independent-consultant-and was monitored by various HL&P managers. The' assessment did not result in any findings affecting the quality of maintenance work or the safety of plant operation, but did identify a number of inefficiencies in the program. As a result, an action plan was developed and  !

. implementation has begun.

In conclusion, the department has sufficient numbers of l 1

skilled personnel to support safe plant operation and has a plan 1 to acquire additional personnel to further reduce the maintenance backlog. Work practices have been shown-to be generally ,

effective and improving. Management involvement in task prioritization and scheduling is also assuring that maintenance activities are adequate for safe operation of both units.

f-Technical Services Technical Services is responsible for control of plant chemistry and the site radiation control program including radioactive waste processing, discharge and shipment services.

Staffing is essentially complete, and tasks in support of both l units are being handled adequately. Department staffing is based on normal two unit operation. Provisions are in place to supplement the plant staff with contractor Health Physics personnel for outages.

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Experiences from Unit 1, for example, in chemistry control and the initial shielding surveys, were factored into procedures and hardware utilized in the startup of Unit 2. This has proven effective as no significant chemistry or shielding problems have arisen on Unit 2. Personnel who gained experience in the operation of Unit 1 are included in the staffing rotation on both units. j Since the units have independent discharge paths, discharges from each unit must be carefully controlled. Therefore, two unit operation has been specifically addressed in the Offsite Dose calculation Manual and the operating procedures assure that total plant releases are maintained within acceptable limits.

Performance Indicators (Station Skin and Clothing Contamination and Station Contaminated Areas) show that the programs implemented on Unit 1 have been successful to date.

Continued implementation of these programs is expected to achieve successful results in the operation of both units.

In conclusion, Technical Services has adequate staffing and experience and it is properly applying lessons learned from Unit

1. This group can adequately support two unit power operation.

Emergency Preparedness The Emergency Preparedness Division coordinates the activities of other departments to achieve its goals. With the l

addition of a second operating unit, additional requirements are placed on this group, including additional personnel l accountability, as well as additional access, egress, emergency L2/JNB06/L )

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equipment.and control centers. These factors have been addressed in the Emergency Plan and its' implementing. procedures. Offsite activities are not affected by the addition of the second unit.

A. full participation exercise was held on April 26, 1989. No deficiencies were noted during_the drill. Some areas,were identified as needing improvement. For example, accounting for personnel needed to be performed in a more' timely manner. Two-letters to the NRC (ST-HL-AE-3087 dated May 5, 1989 and ST-HL-AE-3111 dated May 22, 1989) addressed actions to be taken to improve the process of accounting for personnel. Other weaknesses identified are under evaluation. However, none are considered an impediment to continued operation of both units.

In conclusion,-the Emergency Preparedness Division is ready to support continued power ascension.

Security The physical security program for two unit operation was demonstrated to be adequate prior to receipt of the low power license for Unit 2. The Nuclear Security Department has demonstrated the acceptability of equipment, contingency plans and security officer performance for two unit operation. This area is ready to support continued testing of Unit 2.

Plant Engineering The Plant Engineering Department is responsible for providing Shift Technical Advisors (STAS) to the operating ..

shifts, scheduling of required Technical Specification surveillance, evaluation of system performance, and control of the power ascension program. 1 L2/JNB06/L 05/17/89

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A single Shift Technical Advisor serves bothLunits. The addition of the second unit has not proved unduly burdensome to performance of these duties and STA performance ~is considered acceptable.

Surveillance scheduling, which was a problem early in the >

operation of Unit 1, has generally been performed satisfactorily during the Unit 2 initial startup, and Unit 1 has also been free of significant scheduling difficulties during this period. This program has now been serving both units well for over five months.

System engineers now must monitor and evaluate system performance on two units. To date no problems with handling this increased responsibility have been identified. Management is ,

closely monitoring performance to assure that the current i staffing level is adequate. The power ascension testing is being l performed using the same program, procedures and personnel that were successfully used on Unit 1. The test program to date has been effective and tests are well controlled and performed in a timely manner.

This department has demonstrated good performance to date with two unit responsibilities, and is ready to continue with power ascension.

Support Engineering This department is responsible for station design and configuration management. They have been accepting design responsibilities from the contractors in preplanned phases since l

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before'the completion of Unit 1. This process has been carefully managed and is-essentially complete.

They have successfully dealt with a number of difficult technical tasks during the initial operation of Unit 1, including the correction of auxiliary feedwater vibration, the main

.feedpump destructive overspeed and the bottom mounted instrumentation tube vibration problems. They have demonstrated tnua ability to determine the causes of problems and to take appropriate corrective action. The department has sufficient t

experience and manpower to support both units.

Design decisions are carefully controlled including applicability to both units to ensure preservation of' similarity between units. The similarity of the units minimizes both operator training needs and the possibility that differences i

between the units might_cause operator error.

l In conclusion, Support Engineering has demonstrated the ability to support the operation of two units.

Nuclear Engineering Nuclear Engineering is responsible for fuel supply.and management, performance of probabilistic risk and reliability analysis (PRA), the 10CFR50.59 safety evaluation program and calibration of measuring and test equipment.

The Nuclear Engineering Department serves the entire site staff in its review and approval of safety evaluations. These  !

reviews have been performed in a timely manner and have generally improved the quality of the evaluation.

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.b In the area of calibration of' devices, the pe formance has

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[i been satisfactory, and'two unit operation.has posed:no problems.

p atn summary, the Nuclear Engineering staff'is' ready to V . support ~ continued plant testing.

Licensing-4 TheLLicensing Department'is responsible for tracking HL&P

commitments to'the NRC; serving as the primary contact point for communication between HL&P and'the NRC and managing the-Station Problem) Report Program.

The. computerized commitment tracking system has been utilized effectively to ensure that commitment responses are

~ timely. The trend in'the timeliness of station performance meeting. commitments to the NRC is plotted monthly to check overall performance, and has been found to be generally-satisfactory.

The Station Problem Reporting Program has been effective in tracking problems to. conclusion, determining root.cause and obtaining timely responses to corrective actions.

e l l Evaluations to date indicate that the Licensing Department has adequately handled two unit operation and can continue to do so.

f Therefore, Licensing is ready to support the continued power  !

1 ascension testing.  !

g Nuclear Assurance This group performs audits and surveillance of the station l'

activities to ensure conformance to plans and procedures. They l

L have been supporting both units since the low power license was L2/JNB06/L ,

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receive'd for Unit 1. As Unit 2 progressed toward completion,-the nature of'the' station activities they monitor _has changed from construction activities to operations. Added training plans and rotation of personnel'have prepared the department for this transition. In addition, staffing has been increased slightly to i handle a larger workload.

Based on the demonstrated performance to'date and adequate plans to continue their support, the Nuclear Assurance Department is ready to support power ascension.

1 Overall Station Performance An evaluation of the performance of the'two units also demonstrates the station's readiness to continue with power ascension.

During its first 18 months of full power operation, Unit 1

( performance was consistent with expectations for a first unit of 1

a new nuclear utility. Thus far, the performance of Unit 2 has 1

been better, indicating that HL&P has been learning from its experience. This improvement is reflected in the less significant nature of the reportable events. There have also been significantly fewer Emergency Safeguards actuations on Unit

2. Trends in regulatory performance appear to be positive.

I Regulatory commitments are being met in a quality and timely manner.

STP has experienced some equipment problems in the course of

-the Unit 2 startup program. Most notable of these were: ,

o the fire outside of the Unit 1 Main Generator shell which occurred on January 20, 1989; l

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o occurrence of a Unit 2 reactor trip while synchronizing the Main Generator with the grid on April 5, 1989; and o a loose main turbine end plug in Unit 2.

These problems have posed no safety related concerns to STPEGS.

Three events of operational significance have occurred recently which underscore the need to proceed deliberately in the test program. The events, in brief were:

l o damage to a Unit 2 condenser vacuum pump because of ingestion of water during startup on May 17, 1989; o inadvertent diversion of water from the refueling water storage tank (RWST) to the spent fuel pool on Unit 2 on l

May 7, 1989; and o damage to a Mechanical Auxiliary Building Chiller in Unit 1 on April 7, 1989 because of a design deficiency coupled with improperly installed trip fuses.

The first two events are still under investigation. The condenser vacuum pump problem is presently attributed to lack of guidance for the operators, and the operators not following the temporary modification procedure. The preliminary findings with regard to the water diversion from the RWST are that the operators failed to use appropriate procedures. Immediate corrective actions included counselling of individuals as well as discussion of the event with all shift crews. Additional ,

1 corrective actions will be determined when the investigations are complete.

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-Design changes.are.being made to preclude.the third event iI from occurring:again. In addition, the equipment clearance l i procedure was also' determined-to be deficient with respect to L control of breaker fuses. The procedure is being revised to t

' correct the deficiency.

1 The, Maintenance Department and Plant Operations Department have been timely in the resolution of these problems. Where l

longer range actions are required, they are planned and. ongoing.

On May 12,- 1989, the operating staff determined that the pressurizer level indication'in Unit 2 did not meet Technical Specification requirements for agreement between channels. The

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unit was shutdown for repairs; and after proper agreement among i

the three channels was obtained, the unit-was restarted on May l 14, 1989. HL&P will provide further information in accordance with normal reporting requirements by June 11, 1989.

In summary, the above evaluations conclude that: .

o adequate numbers of skilled personnel are available to support two unit operations; j o management involvement is present and effective; j

o reviews of irdividual departments demonstrate adequate present performance and projects the capabilities to support two unit operations; and o overall station performance is acceptable and lessons learned are being applied effectively to Unit 2.

Accordingly, HL&P concludes that the station is ready to continue with the power ascension testing of Unit 2 at power levels above 50% of rated power.

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,1 Assignment of' Areas for Evaluation

- General-Manager, Administrative Support ~

o operations Lo Maintenance o Technical ^ Services "o. Emergency Preparedness o Nuclear Assurance-o Security' General Manager, Nuclear Assurance o Plant Engineering.

o Support Engineering o Nuclear Engineering o Licensing i

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, ATTACHMENT 2 Page 1 of 2 South Tel:as Project Electric Generating Station Performance Indicators I. Industry Overall Indicators (INPO) 1-U1 Unit One Equivalent Availability Factor 1-U2 Unit Two Equivalent Availability Factor 2-U1 Unit One Unplanned Automatic Scrams While Critical 2-U2 Unit Two Unplanned Automatic Scrams While Critical 3-U1 Unit One Unplanned Safety System Actuations 3-U2 Unit Two Unplanned Safety System Actuations 4-U1 Unit One Forced Outage Rate 4-U2 Unit Two Forced Outage Rate 5-U1 Unit One Thermal Performance 5-U2 Unit Two Thermal Performance 6-U1 Unit One Fuel Reliability 6-U2 Unit Two Fuel Reliability 7 Station Collective Radiation Exposure 8 Station Low Level Solid Radioactive Waste Volume 9 Station Industrial Lost Time Accident Rate 10-U1 Unit One Safety System Performance 10-U2 Unit Two Safety System Performance II. NRC Comparison of NTOL Plants 11-U2 Unit 2 Reactor Protection System Actuation Events per 1000 Critical Hours <= 15% Power (since initial criticality) 12-U2 Unit 2 Reactor Protection System Actuation Events per 1000 Critical Hours > 15% Power (since full power authorization) 13-U2 Unit 2 Engineered Safety Features Actuation Events other than Reactor Protection System (since issuance of low power license) 14-U2 Unit 2 Significant Reportable Security Events ,

(since issuance of low power license) 15-U2 Unit 2 Other Significant Events That Require NRC Immediate Notification Reports (since issuance of low power license)

III. Other Performance Indicators 16-U1 Unit One Net Generation MWHr l

16-U2 Unit Two Net Generation MWHr l 17 Station Skin and Clothing Contamination 18 Station Contaminated Areas 19-U1 Unit One Chemistry Performance Index 19-U2 Unit Two Chemistry Performance Index 20 NRC Notices of Violation (Station) 21 Total Station LERs 22 Station Operating Experience Review Status (SOERs) 23 Outstanding Station Commitments L2/JNB06/P l

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ATTACHMENT 2 Page 2 of 2 III. Other Performance Indicators (Continued) 24 Ratio of. Preventive to Total Maintenance 25-Ul Unit One Corrective' Maintenance Workload 26 Station Corrective Maintenance Backlog Greater than 3:

Months 27-Ul Unit One Out-of-Service Control Room' Instruments' 27-U2 Unit Two Out-of-Service Control Room Instruments 28 Station Temporary Plant. Modification Status 29 Station' Deficiency Report Effectiveness 30 Training Accreditation Status 31 HL&P Staffing 32 HL&P Personnel Turnover Rate 33 HL&P Station Overtime 34 Station Project Capital (SSR3333) Budget Performance-35 Station Capital Budget Performance 36 Station O&M Budget Performance 37 Station Production Costs per Net KWHR j

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Houston Lighting & Poker Cornpany ST-HL-AE-3110 File No.: G32.01.05 Page 3 cc:

Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting &' Power Company Arlington, TX 76011' P. O. Box'1700 Houston, TX 77001 George Dick, Project Manager

-U.S. Nuclear Regulatory Commission INPO -

Washington, DC 20555 Records Center 1100 Circle 75 Parkway Jack E. Bess Atlanta, GA 30339-3064 Senior Resident Inspector / Unit 1 c/o U.S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P.O. Box 910 Bellport, NY 11713 Bay City, TX 77414 J. I. Tapia Senior Resident Inspector / Unit 2 c/o U.S. Nuclear Regulatory Commission P. O. Box 910 Bay City, TX 77414

-J R. Newman, Esquire Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036 R. L. Range /R. P. Verret i Central Power & Light Company J P. O. Box 2121 i Corpus'Christi, TX 78403 R. John Miner (2 copies)

Chief Operating Officer l City of Austin Electric Utility 721 Barton Springs Road 1 Austin, TX 78704 l

R. J. Costello/M. T. Hardt '

City Public Service Board P. O. Box 1771 San Antonio, TX 78296 l

Revised 12/21/88 i

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