IR 05000498/1987065: Difference between revisions

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{{Adams
{{Adams
| number = ML20148A306
| number = ML20153D663
| issue date = 03/11/1988
| issue date = 08/26/1988
| title = SALP Repts 50-498/87-65 & 50-499/87-65 for 1987
| title = App to SALP Board Repts 50-498/87-65 & 50-499/87-65 for 1987
| author name =  
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-498-87-65, 50-499-87-65, NUDOCS 8803180005
| document report number = 50-498-87-65, 50-499-87-65, NUDOCS 8809020279
| package number = ML20148A304
| package number = ML20153D654
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 54
| page count = 29
}}
}}


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{{#Wiki_filter:9 9 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
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O APPENDIX TO SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION


==REGION IV==
==REGION IV==
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SALP Board Reoort 50-498/87-65 and 50-499/87-65 Houston Lighting & Power Company (HL&P)
SYSTEMATIC ASSESStiENT OF LICENSEE PERFORMANCE NRC Inspection Report 50-498/87-65; 50-499/87-65 Houston Lighting & Power Company (HL&P)
South Texas Project, Units 1 and 2 (STP)
SouthTexasProject, Units 1and2(STP)
January 1 through December 31, 1987 8803180005 880311 PDR ADOCK 05000498 Q DCD
  .lanuary 1 through December 31, 1987 NV go90% W O


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MEETING SUMMARY Date:  April.13, 1988 Licensee: Houston Lighting & Power Company (HL&P)
Facility: SouthTexasProject, Units 1and2(STP)
License: NPF-76/CPPR-129 Docket: 50-498; 50-499 SUBJECT: SALP MEETING AT STP On April 13, 1988, the Deputy Regional Administrator, Region IV, members of the Region IV staff, and an NRR representative met with representatives of
.HL&P in an open meeting at STP to discuss the SALP Board Report covering the period January 1 through December 31, 1987. A copy of the NRC material presented at the meeting is attached. The meeting was held at the request of NRC, Region I After opening remarks by the Deputy Regional Administrator, the Directo Division of Reactor Projects, Region IV, presented each of the functional areas evaluated in the SALP Board Report using Attachment 2 as an outline. An opportunity for comments regarding each of the SALP categories was made available. The HL&P representatives provided general remarks regarding the SALP Board Repor Attachment:
NRC Material Presented at Meeting


I. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operatio An NRC SALP Board, composed of the staff members listed below, met on February 12, 1988, to review the collection of performance observations and data to assess the licensee performance in accordance with trie guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at STP for the period January 1 through December 31, 198 The SALP Board members for STP were:
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J. L. Milhoan, Director, Division of Reactor Safety R. L. Bangart, Director, Division of Radiation Safety and Safeguards L. J. Callan, Director, Division of Reactor Projects G. L. Constable, Chief, Project Section D C. E. Johnson, Senior Resident Inspector, STP D. R. Carpenter, Senior Resident Inspector, STP N. P. Kadambi, Project Manager, NRR The following personnel also participated in the SALP Board meeting:
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J. M. Montgomery, Deputy Regional Administrator I. Barnes, Chief, Materials & Quality Programs Section R. J. Everett, Chief, Physical Security Section D. R. Hunter, Chief, Technical Support Section W. C. Seidle, Chief, Test Programs Section J. E. Gagliardo, Chief, Operational Programs Section B. Murray, Chief, Facilities Radiological Protection Section W. L. Fisher, Chief, Nuclear Materials and Emergency Preparedness Branch D. M. Hunnicutt, Senior Reactor Inspector, Project Section D D. L. Garrison, Resident Inspector, STP J. E. Bess, Resident Inspector, STP H. F. Bundy, Project Engineer, Project Section D R. P. Mullikin, Project Engineer, Project Section B N. M. Terc, Emergency Preparedness Specialist J. A. F. Kelly, Senior Security Inspector J. P. Clausner, Observer, French IPSN-CEA
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UNITED STATES NUCLEAR REGULATORY CCtNISSION SYSTEMATIC ASSESSENT OF LICENSEE PERFORMANCE EETING HOUSTON LIGHTING & POWER CWPANY SOUTH TEXAS PROJECT, UNITS 18 2 JANUARY 1,1987 - DECEMEER 31,1987 SOUTH TEXAS PROJECT VISITORS CEN1ER APR!i.13,1988 10 _


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3  i II. CRITERIA Licensee performance was assessed in selected functional area Each functional area normally represents areas significant to nuclear safety and the environmen One or more of the following evaluation criteria were used to assess each functional area: Management involvement in assuring quality Approach to resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Operational and construction events (including response to, analysis of, and corrective actions for) Staffing (including management)
However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categorie The definitions of these performance categories are:
Category 1: Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety or construction is being achieve Category 2: NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieve Category 3: Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieve . .
 
III. SUMMARY OF RESULTS A high level of performance has been achieved in the areas of containments, safety-related structures and major steel supports; auxiliary systems; instrumentation; and quality programs and administrative controls affecting quality relating to the construction program. Weaknesses were identified in the areas of plant operations and security. Strong programs for operations did not result in a high level of performance subsequent to issuance of the low power license. The SALP Board debated at length whether to classify performance in the operations area as Performance Category 2 or 3 before deciding that a Performance Category 2 indicating satisfactory overall performance was the proper rating. NRC reviews conducted subsequent to the SALP period indicate that acceptable corrective action programs have been implemented and positive results are being achieved. Deficiencies in the emergency preparedness area identified in the previous SALP period have been resolved and the licensee is now considered satisfactory in this are The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation period:
Previous Present Performance Category Performance Category Functional Area (07/01/85 to 12/31/86) (01/01/87 to 12/31/87) Plant Operations Not Assessed  2 Preoperational  2  2 Testing Startup Testing Not Assessed  2 Maintenance  Not Assessed  2 Surveillance  Not Assessed  2 Fire Protection Not Assessed  2 Quality Programs and 2 (Not Subdivided)
Administrative Controls Affecting Quality Construction  1 Operations  2 Training and  1  2 Qualifications Effectiveness
 
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I SALP PROGRAM ORJECTIVES i
IMPROVE LICENSEE PERFORMANCE PROVIDE A BASIS FOR ALLOCATION OF l
NRC RESOURCES l


i Previous  Present Performance Category Performance Category Functional Area (07/01/85 to 12/31/86) (01/01/87 to 12/31/87) Emergency  3  2 Preparedness Security  2  3 Radiological  2  2 Controls Containments,  1  1 Safety-Related Structures, and Major Steel Supports Piping Systems and 2  2 Supports Safety-Related  2  2 Components -
l IMPRWE NRC REGULATORY PROGR#i (
Mechanical Auxiliary Systems 1  1 Electrical Equip- 2  2 ment and Cables Instrumentation  2  1 Licensing  2  2 l  Activities j IV. PERFORMANCE ANALYSIS Plant Operations This functional area consists chiefly of the activities of the
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licensee's operational staff (e.g. , licensed operators, shift l  technical advisors, and auxiliary operators). It is intended to be limited to operating activities such as: plant startup, power operation, plant shutdown, and system lineups. Thus, it includes activities such as reading and logging plant conditions; responding to off-normal conditions; manipulating the reactor and auxiliary controls; plant-wide housekeeping; and control room professionalism.


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>      6 1. Analysis    ,
This area received significant hRC inspection during the SALP period including observation of control room activities during ,
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preoperational testing, hot functional testing, initial fuel '
loading and early mode changes up to Hot Standby -(Mode 3) but not including initial criticalit NRC inspections in this area included teams of inspectors from other Region IV sites, the Region IV office, and NRC headquarters working with the resident inspectors at STP. Frequent visits to the plant site
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by the NRC Project Manager and NRC Region IV management i    representatives contributed additional insight into the quality of activities in this area. An operational readiness review was completed in July 1987. A low power operating license (0L) was
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issued on August 21, 198 ,
Generally, the licensee can be characterized as having strong programs. Operating procedures were in place and of good ,
overall quality. Staffing within the Nuclear Plant Operation '
Department (NP00) appears to be adequate for an operating uni During this SALP period the licensed operators worked extensive ,
overtime to support preparation for OL and post-0L activitie While the licensee meets the requirements for experienced staff 1 levels, there is evidence that more experienced staff, especially
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at supervisory and middle management levels, could have reduced
!    the plant problems experienced. NPOD has hid several i    reorganizations including a change of Vice President of Nuclear Operations during this period. That position was vacant for ;
I    approximately 7 month ;
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Decisionmaking has usually been at a level that ensures adequate management revie Procedures and policies have been l
occasionally violated as evidenced by the violations, deviations, and Licensee Event Reports (LERs) tabulated in v Tables 2 and 3. LERs have been, on occasion, repetitious which
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would indicate inadequate corrective actions or inadequate root l
cause evaluation r
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The licensee has had many operational difficulties during this SALP period as evidenced principally by the LERs and enforcement .
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l issues. This, in part, may be attributed to learning through l     experience as tasks are faced for the first tim Notwithstanding these operational difficulties, the licensee :
exhibits a conservative approach to plant operations activitie l There were 25 LERs, 9 of which were primarily attributed te t
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plant operations problems during the 4 months the licensee had an OL. Most of these can be attributable to causes under the !
licensee's contro .


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PERFORMANCE ANALYSIS AREAS FOR SOUTd TEXAS PROJECT, UNITS 18 2 PLniT OPERATIONS B.- PREOPERATIONAL TESTING STARTUP TESTING PAINTENANCE SURVEILLANCE FIRE PROTECTION QUALITY PROGRAMS N O ADMINISTRATIVE CONTROLS AFFECTING OUALITY 1. CONSTRUCTION 2. OPERATIONS TRAINING AND 00AL1FICATIONS EFFECTIVENESS EMERGENCY PREPAREDNESS SECURITY RADIOLOGICAL C0fRROLS C0fRAlteENTS, SAFETY-RELATED STRUCTURES, AND PAJOR STEEL SUPPORTS PIPING SYSTEt43 AND SUPPORTS SAFETY-1 LATED C0FFONENTS -
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MEOWi! CAL AUXILIARY SYSTEMS 1 ELECTRICAL EQUIPtENT    :
Of the nine LERs attributed to this functional area, the SALP Board identified eight as being caused by inappropriate  '
AfD CABLES INSTRtFENTATION    i LICENSING ACTIVITIES i
personnel actions. One deviation involving failure to meet a commitment to the NRC was identified. Two violations have been issued for failure to follow procedures. One additional violation resulted in escalated enforcement and dealt with failure to have the high head safety injection system operable i while in a plant mode that required it to be operable. This was compounded by operation in this mode for a protracted period of time, presenting ample opportunity for several shifts of licensed operators to identify the error, either by routine activitie; or board walkdown at shift turnover. This event  .
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highlighted weaknesses in the licensee's control of safety ;
system status, particularly during plant mode changes. Further !
the licensee's initial corrective actions following this event were inadequate as e.videnced by the identification of similar ;
' concerns regarding operator control of safety system status by ,
an NRC inspection team several weeks later. Several other LERs, ^
violations, and deviations are covered in other SALP areas that in fact have a shared responsibility with this are P
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, 2. Conclusions    1
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The licensee's performance in this functional area up to the
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issuance of the low power license appeared to be fully  .
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satisfactory. After the license was issued in August 1987 a I i number of events challenged the operations staff and revealed l weaknesses that had not been previously observed. The licensee [
j has not been able to successfully control some concerns  ;
i expressed by the NRC, specifically in the areas of LERs and !
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Technical Specifications (TS) surveillance compliance. Progress toward full power licensing has been slowed by a series of f a problems. These delays have been in part due to equipment i
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failures but corrective actions have not always been efficient ;
or initially effective. The trend for the last 4 months of the j appraisal period indicated decreasing performanc [
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i Apparently strong programs exhibited significant weaknesses in implementation. Operators who had performed very well during t
j training and while taking NRC licensing exams made mistakes in
* the plant that could have been avoided. The licensee has  .
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generally tried to be responsive to NRC concerns and has l
routinely taken a conservative, conscientious approach to safety [
issues. Performance appeared to begin improving slightly after ;
i} the appraisal period.
j The SALP Board debated at length whether the licensee should be j
considered Perfomance Category 2 or 3 in this functional are i
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' Performance prior to OL was considered to be Performance
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Category 2. Performance after OL was more indicative of a Performance Category 3 although the data was somewhat limited, j
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The board concluded that based on strong programs and clear evidence that HL&P is learning from the recent errors that have occurred that overall performance in this functional area is Performance Category . Board Recommendations Recommended NRC Action NRC Region IV began an augmented inspection effort at STP in Jann ry 1988. Inspection efforts should continue at the current high level on Unit 1 until the licensee has demonstrated an increased level of performance in this functional area. As Unit 2 enters into the Lulk of the preoperational test program, NRC inspection effort should increase to follow operations support of that program, Reconsnended Licensee Action The licensee should continue to fill staff positions with experienced individuals. HL&P management should continue aggressive follow through of activities to ensure that TS requirements are clearly understood by NP0D porsonne The licensee should continue to strive for a reduction in operator errors by improved training and continued emphasis on compliance to plant procedures. They should move forward in a deliberate, controlled manne B. Preoperational Testing This functional area covers the preparation, conduct, and evaluation of test results for preoperational tests performed by the startup organization under the direction of the licensee's staff to
! demonstrate the proper functioning and conformance to design j
requirements of components, systems, and structure . Analysis
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i The preoperational testing program for Unit I was essentially i  completed during this SALP period with a major testing effort on
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!'  the key plant systems. The hot functional test was the culmination of an extensive test program on Unit 1 and included 21 individual subordinate preoperational tests and several l acceptance tests (nonsafety-related systems). Those portions of l
preoperational tests that were not completed prior to 0L issuance were converted to plant test procedures and are being completed as plant mode conditions allow. This incomplete
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!  testing was a result of the compressed testing schedule which l  prevented completion of some testing as scheduled because of unavailability of required support system Thus, the windows
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O e r    FUNCTIONAL AREA PERFORMANCE CATEGORY CATEGORY 1 REDU D NRC ATTENTION f%Y BE APPROPRIAT LIGNSEE fW4AGiffiT ATTENTION NfD IfNOLVEfffU ARE AGGRESSIVE AfD ORIEfGED TOWARD NUCLEAR SAFETY; LIGNSEE RES00RGS ARE AMPLE AffD EFFECTI\ELY USED S0 THAT A HIGH LEVEL OF PERFORfWJG WITH RESPECT TO OPERATIONAL SAFETV IS BEING /,CHIEVE . . __ ___ . _ ___
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I CATE@RY 2 NRC ATTENTION SHOULD BE t%ItiTAINED AT NORt%L LEVEL LIGNSEE MANAGEtENT ATTEtCION AND ltN0LVEtENT ARE EVIDENT AND ARE CONGRNED WITH iAJCLEAR SAFETY; LIGNSEE RESOUR&S ARE ADEQUATE AND ARE REAS0tMBLY EFFECTIVE SO THAT SATISFACTORY PERFORt%NG WITH RESPECT TO OPERATIOfML SAFETY IS BEING ACHIEVE :
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for some testing were missed. The NRC inspectors reviewed each test section not completed during the preoperational test phase :
for impact on pre-OL test requirements and agreed with the l licensee's deferral. The NRC has applied significant inspection resources to the preoperational test program during this SALP period, in part due to the compressed testing schedule of the licensee. All tests selected by the NRC for review were '
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evaluated, witnessed and the results reviewed. No significant problems were identifie The licensee has a highly experienced and aggressive Startup organization which allowed for a smooth and effective preoperational testing phase. In spite of having a strong team, there were occasional efforts that led to solving tne problems ,
and getting on with the testing without regard to proper !
documentation. This attitude led to or contributed to the violations noted in Table 2 for this functional are ;
There were two violations for failure to follow procedures !
during this SALP period. One of these events resulted in !
damages to the residual heat removal (RHR) system during hot functional testing. The other oealt with failure to provide the '
required verifications on temporary inodifications and in preoperational test As a result of the lessons learned in the Unit 1 testing program, the initial testing in Unit 2, which has been limited i to primarily prerequisites testing and some electrical .
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preoperational testing, has been effective and without significant problem .
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      , Conclusion    f The licensee's performance in this functional area has been generally effective and acceptable. The informal attitude displayed by the licensee with regard to dealing with test problems or anomalies was mitigated by the depth of experience of the test group. On occasion, issues were dealt with expeditiously, but not in accordance with udministrative procedures. The licensee is considered to be in Performance Category 2 in this functional are . Board Reconwendation Recommended NRC Action During the upcoming SALP period, the level of inspection should be at a level commensurate with the Unit 2 schedule which indicates that the bulk of preoperational test p ogram on Unit 2 will occur during 198 _ - _ - - - _ _ _ _ _ _ _ .
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s Recommended Licensee Action
  . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . ____ __________-_ _ ___ __ _ _______ _ _ _ CATEGORY 3 BOTH NRC AND LICENSEE ATTEt(TION SHOULD BE INCREASED. LIGNSEE t%fMGEMENT ATTENTION OR ltNOLVEENT IS ACCEPTABLE AND C0t4SIDERS FAJCLEAR SAFETY, BUT WEAKtESSES ARE EVIDENTI LIGNSEE RESOURGS APPEAR TO BE STRAINED OR NOT EFFECTIVELY USED S0 THAT Mitilt%LLY SATISFACTORY PERF0 WANG WITH RESPECT TO CPERAT10tML SAFETY IS BEING ACHIEVED,
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The licensee should continue efforts in this functional area as Unit ' preoperational testing escalates. Management and supe .,ory overview of field activities should emo' 1 size the r ad to comply with Startup Administrative Ir uctions il Safety Analysis Report (FSAR)
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con.altments, b..a nRC Regulatory Guides that the licensee has committed to follow. Particular attention should be given to avoiting repeating the errors made in Unit 1 preoperational testing during the Unit 2 prcoperational test progra C. Startup Testing
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This functional area covers the preparation, conduct, and evaluation of test results for testing conducted following the issuance of the operating license. It starts with initial fuel loading and    ,
precritical tests, and continues until the plant reaches coreercial  .
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operating status at or near its licensed power ratin , Analysis
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!  Inspections of the licensee's program and procedures and initial l core loading were performed during this SALP period. The licensee's startup activities up to Mode 3 were also inspecte However, because of problems involving the auxiliary feedwater system, the startup did not proceed past Mode 3 and the plant was in Mode 5 at the end of the SALP period.


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Inspections were performed to determine whether the licensee's administrative control programs and startup procedures fulfilled FSAR and NRC Regulatory Guide (RG) 1.68, "Initial Test Programs for Water Cooled Nuclear Power Plants," commitments for the STP startup program. The NRC inspectors identified a number of concerns regarding satisf action of RG 1.68 commitments during  '
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'  the initial comparison. Although the licensee's technical staff
EVALUATION CRITERIA i
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1. thfMGEKffT IfN0LVEKf6 AfiD C0f4 TROL IN ASSURING OUALITY 2. APPROACH TO RESOLUTION OF TEOf41 CAL ISSUES FROM A '
was able to address specific concerns by verbally describing how l
SAFETY STANDPOINT 3. RESPONSIVENESS TO NRC INITIATIVES 4. EtEORCEEffT HISTORY S. OPERATIONAL EVENTS (If4CLUDING RESPONSE T0, AfMLYSIS OF, AffD CORRECTIVE ACTIONS FOR)
each comitment was met, they had difficulty in describing i  overall compliance with RG 1,68 commitments. The NRC inspectors were concerned that comitments might be missed if not clearly
6. STAFFING (INCLUDING VN4AGEKffT)
,  documented. In response to these concerns, HL&P developed an
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!  overall startup program document and made procedural changes
!  which together with the previous procedures clearly demonstrated  l '
fulfillment of RG 1.68 requirements and resolved identified procedural concern '
4 The NRC inspectors maintained continuous inspection coverage i
during initial core loading. This evolution was performed in a
;  safe, effective manner and was free of major problems. One i  violation relating to replacement of the fuel handling system  ,
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transfer cart shear )in without a maintenance work request was identified. Althougl closely associated with the maintenance functional area, the root cause of this violation was associated with a startup activity and the operations shift supervisor's inappropriate approval of the wor . Conclusion Because of the delay in the startup of Unit 1, a limited number of startup activities were inspected during this SALP perio Although the licensee initially could not clearly demonstrate program and procedure conformance to RG 1.68, an overall. program document was developed and appropriate procedure changes were made in a timely manner. The licensee's performance during initial core loading was indicative of an adequate program and strong management involvemen The licensee is considered to be in Performance Category 2 in this are . Board Recommendations
: Recommended NRC Action i     The NRC inspection effort should be at normal levels in
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response to startup activities for Unit 1.
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I Recommended Licensee Action
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i      Licensee management should aggressively monitor changes in i      plant status and ensure good coordination of startup j      activities and power ascension testing with normal plant j      operations.
 
l l Maintenance l
l    This functional area includes all licensee and contractor activities
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associated with preventive or corrective maintenance of
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instrumentation and control equipment and mechanical arid electrical syteras.
 
l Analysis
!     This SALP period saw a rapid acceieration in tne requirements for maintenance support. This was due to a reduction of l    construction support a', HL&P took almost full control of Unit 1 l
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maintenance activities as Unit i received its low power OL.
 
l Most of the maintenance activities were bei..g performed for the first time, l
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The licensee's m3intenance organization is generally staffed appropriately for Unit 1 activities and there is an appropriate staffing plan for Unit 2. They utilize vendor representatives, consultants, and contractors as required to support the plant staff. Maintenance programs and procedures are in place and of good overall qualit Spare parts are generally available in the warehouse. Some parts that were not readily available for Unit I were removed from Unit 2 or the construction warehouse to support the needs of Unit The licensee currently has an effective and ccmprehensive preventive maintenance program with clear ano complete written procedure The administrative aspect of maintenance wcs generally acceptable in regard to work M ckage preperation and flow of documentation. There were examples of inadequate control of completed data sheets (quality records) and varying levels of effectiveness within the work control center (WCC) system. The WCC is not an exclusively maintenance function but maintenance must be an integated function of the WC There were instances of improperly planned, performed, or supervised maintenana activities that resulted in plant delay This appears to be an irterface problem among the various responsible groups. An erarrple is the ECW/CCW heat axchanger repair for Unit I during which craftmen were allowed to improperly remove failed tubes. This resulted in the need to
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weld on the tube sheet, which was improperly performed because t    no toock up or qualification welds were performed. Repair to the standby diesel generators required rework due to inadequate initial repir Some maintenance problems are the result of inaaequate training of the various crafts. The weakest area seems to be the instrumentation and control (IAC) function which is evidenced by LERs and NRC inspection findings attributed to improper I&C maintenance activities. Overall, the craft trainirg is acceptable with only occasional examples of inadeouate general or detailed trainin The licensee received one violation and one deviatiun during this SALP period for failure to follow procedures and f ailure of preventive maintenance (PM) and maintenance work request (W R)
programs to fully meet FSAR commitments, respectivel Su LERs were issued from OL issuance through December 1987 that were results of deficient actions on the part of the maintenance departmen _ .. -._ . -. . -
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13 Conclusion The licensee appears to have the elements of a strong maintence program in place. Some problems have been observed in the implementation of this progra While some issues of concern have been identified in this functional area, no major problems have been identified. Where problems have been observed the NRC inspectors have observed the licensees management and corrective action system working to resolve the problem and prevent future occurrence. The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendation Recommended NRC Action The routine NRC inspection program should be performed for maintenance activities on Units 1 and Recommended Licensee Action The licensee should continue its staffing effort to support Unit 2 activities. The licensee should continue upgrading maintenance procedures based on experience gained and training the various crafts on plant specific job task Management and supervisory overview should continue in the area of problem analysis and corrective action E. Surveillance This functional area includes all surveillance testing activities as well as all inservice inspection and testing activitie Examples of activities included are: instrument calibrations, equipment operability tests, containment leak rate tests, special tests, inservice inspection and performance tests of pumps and valves, and all other inservice inspection activities.
 
; Analysis The surveillance procedures were written and a dry run conducted pelor to receiving a low power OL. For the most part they are administratively acceptable, clearly written and of sufficient detail. The major difficulty is that several cases of failure to meet the TS surveillance requirements have been identified after the plant has been in a mode requiring their satisfactory completio There were four LERs between August 21 (receipt of low power OL)
and December 31, 1987, in this functional area. The events ,
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leadi ng to one of these LERs is also the subject of an escalated enforcement action. This event concerns the fact that all four t
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channels of pressurizer pressure-low safety injection were set below (in the non-conservative direction) the requirements of the TS. The licensee had justified the required TS value to NRR based on the uncertainty of the Veritrak instrument drif Despite the fact it was their requested value, the surveillance procedure had the wrong pressure value. Additionally, the licensee had conducted at least two reviews of the TS to reconcile the TS to all plant procedures. The other four LERs also dealt with surveillance procedures that failed to meet the reouirements of the T . Trend Since the end of the SALP period, more examples have been identified of failure to have the surveillance procedure reflect the TS requirements. The licensee has conducted various reviews of the Unit 1 TS and some identified inconsistencies have come from reviews of Unit 2 activities. While the NRC encourages the licensee to keep searching for errors in the surveillance program, it is of concern that more examples of failure to provide adequate surveillance for TS requirements continue to be identified 5 months after the low power operating license has been issue . Conclusion There is still a concern about the adequacy of the identification of TS requirements and their implementation into surveillance procedures. The licensee's program with respect to
 
!    quality of procedures, staff to perform tnem, and implementation
!    of tests in a timely manner to preclude missed tests is acceptable. The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations
!
' Recommended NRC Action The current level of NRC inspection effort should continue l      and focus on ensuring the adequacy of and compliance with
,
the TS surveillance requirements and implementing procedures. Unit 1 still has two plant modes which have
.
l not been reached plus initial criticality and power ascension testing. TS and surveillance compliance will be a critical element of the NRC inspection efforts for those scheduled activities, Recomended Licensee Action The licensee should continue to upgrade the TS and surveillance procedures to ensure that they comply with the
!
!
  ---
    - . - . - - . - . .  . _
_ _ _ - _
 
n    ;
      ;
v , ,
o i
le 15  !
  ,
      ;
l      !
      :
low power OL. When the full power, license is granted to Unit 1, a revised TS will be included. This revised TS i must be reconciled to the surveillance program and procedures to preclude a recurrence of the same type of
-
errors and omission F. Fire protection f
This functional area includes routine housekeeping (combustibles, l' etc.) and fire protection / prevention program activities. Thus, it includes the storage of combustible material; fire brigade staffing and training; fire suppression system maintenance and operation; and those fire _ protection features provided for structures, systems, and components important to safe shutdown.
 
' Analysis j  This area was inspected by NRC region-based inspectors, resident inspectors, headquarters inspectors, and contractor personnel.
:  During this assessment period, a team inspection was performed to inspect the establishment and implementation of the fire protection / prevention program, and compliance with the
 
requirements of 10 CFR 50, Appendix R, and BTP 9.5-1, per FSAR
  .
  .
commitmentsandSafetyEvaluationReport(SER) evaluation. It includes the storage of combustible matericl; fire brigade staffing and training; fire suppression system maintenance and operation; housekeeping; and those fire-protection features 4 provided for structures, systems, and components important to safe shutdow The licensee's fire protection / prevention program was determined
  ,
,  to be well designed with no significant deficiencies note Minor areas of concera were evaluated by the licensee and adequate corrective actions were take Specifically, the NRC team reviewed procedures for the control of combustible materials and housekeeping for the reduction of fire hazards; control of disarmed or inoperable fire detection or suppression systems, maintenance and surveillance of fire suppression, detection, and emergency comunications equipment; personnel fire fighting qualifications; fire protection staff responsibilities; fire emergency personnel designation as well as plans and actions; and controls for welding, cutting, grinding, and other ignition sources. There were no ieficiencies noted in these areas and the licensee's QA program ior fire protection appeared adequat The NRC team also inspected the reactor coolant pump oil collection system, emergency lighting for safe shutdown equipment and the physical installation of fire protection, detection, and suppression systems to meet commitments made to
I e
r STRENGTHS j
        :
COOD PROGRAMS Al'S INPi. ACE FOR OPERATION OF UNIT TE QUAL.lTY ASSURANCE PROGRAM FOR CONSTRUCTION OF UNIT 2 IS l BEING PERFORE D IN AN EFFECTIVE MANNE MANAGEE NT INVOLVEE NT IS EVIDENT IN All. ACTIVITIES RELATED TO CONSTRUCTION AND OPERATION i
        )
        !
        ;
f
    ,   i i
        ?
I l
      -
r I
        ;
        !
I l
        '
        ,
        '
l
        >
l
        ?
        !
t
        !
        )
        >
f
        {
f
.__


. - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _    _ _ _ _ _ _ _ _ _ _ _ _ _____________
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
    .    .
 
i i
'
the NRC. Deficiencies noted in these areas were: additional detectors needed, one additional portable fire extinguisher needed, unavailable test data for some seismic gap fire seals i        and a 3-hour rated fire wall, and additional fire dampers needed. These items were promptly acted upon by the licensee and adequate corrective action was taken.
 
Also inspected were the plant's ability to achieve and maintain post-fire safe shutdown capability, including alternate shutdown
;        capability, associated circuits concern, and safe shutdown comunications. The NRC inspectors noted some minor procedural deficiencies, as well as a lack of an analysis for a possible i        fire due to an open circuit in the secondary of a current
,
transformer and communications problems during an emergency. All
!        deficiencies were adequately resolve . Conclusion i
Licensee management involvement in and commitment to their fire i        protection / prevention program was eviden The NRC inspectors found no significant deficiencies in the licensee's fire protection / prevention program. All NRC concerns and questions were promptly reviewed and adequate corrective
'
action taken or initiated on a timely basis, i        The licensee's program is such that the consequences of a fire 1        should not affect the safe operation or shutdown of the plant.
 
l t        This SALP period focused on the programatic aspects of the
!
!
licensee's fire protection / prevention program. The
.. .
!
EAKNESSES SECURITX SECURlW DEFICIENCIES RESULTED IN A SIGNIFICAf(T DELAY IN THE ISSUANG OF THE OPEP! JING LIENS OPERATIONS STRONG PROGRAMS FOR OPERATIONS DID NOT RESULT IN A HIGH LEVEL OF PERFORfMNE SUBSEQUF.ffT TO ISSUANE OF TK LOW POWER LIE NS .
implementation and maintenance of the licensee's program will be 1        assessed in the next SALP.
          !
t
          !
i
          !
_____ ______ _ _ _ _ _ _ .      - - _ . - _ _ _


i The licensee is considered to be in Performance Category 2 in  ;
-
.
_, _ _ - _ _ - _ - - - _ - -
I j        this are . Board Recomendations
_ _ _ - _ _ - - . _ _ - - _ _ _ - - - - - _ - - - - - _ - _ _ _ _ _ _ _ _ _ _
.
  .
j Recommer.ded NRC Actions
,
l          The level of NRC inspection in this functional area should
'          be consistent with the basic inspection program.
 
(
j Recommended Licensee Actions
!
The licensee's management should continue the level of i          attention in the fire protection / prevention program and
:
ensure that the program is adequately implemented and I          maintained.
 
O I
 
  . _ -. , _ _ _ _ _ __ _ , _ _  .,_ ____  . _ . . _ - - _ - - .
 
- _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
    . .
 
G. Quality Programs and Administrative Controls Affecting Quality This functional area includes all management control, verification and oversight activities which affect or assure the quality of plant activities, structures, systems, and components. The area may be viewed as a comprehensive management system for controllir.g the quality of work performed as well as the quality of verification activities that confirm that the work was performed correctl . Construction OA Activities Analysis Nine areas of the quality assurance program were assessed during this period by resident and region-based personne The inspection of onsite design activities included controls for engineering drawings and changes and their compliance with the FSAR. The process was verified from the initial concept through the issuance of final or as-built drawings. Procedures were found to be in place and adequate for calculations, design reviews as required, preparation of documents, approvals and revisions to drawings, specifications and procedure The management review of the overall quality assurance program focused on the management and effectiveness of the programs and the interfaces with the engineering, constructor, and nuclear steam supply system (NSSS) vendo The program was functioning properly as each participant had developed and implemented procedures to cover the areas under 10 CFR 50, Appendix It was noted that the entire licensee quality assurance organization was physically based on the project site. This aspect assured that the quality functiops were properly managed and problem areas addressed in an expeditious manner with upper management attentio The licensee program and staffing were as described in the reviewed program manual The implementation uf the construction QA program has been characterized by aggressive pursuit of identified safety concerns as exemplified by several audit findings in the structural steel and electrical areas. The QA surveillance program identified major documentation deficiencies in the structural steel area in the latter part of the last appraisal period and corrective action is still ongoin Direct HL&P senior management involvement in assuring quality at STP has been evident and aggressiv . - _ _ _ _ _ _ _ .
  . .
18 Conclusion The quality assurance program at the site is being performed in an effective manner. Licensee management attention and involvement in this functional area is evident, aggressive, and oriented toward nuclear safet They are involved in quality issues on a daily basis and problem areas are promptly addressed. Inspection, surveillance, and audit programs are in place and being effectively implemented. Changes from the construction to the preoperations and operations mode requirements are being made in an orderly manne The licensee is considered to be in Performance Category 1 in this functional are Board Recomendations (1) Recommended NRC Action NRC effort in this area should consist of the minimum inspection needed to assure the continued effectiveness of the licensees QA progra (2) Recomended Licensee Action The licensee should continue the current level of emphasis on their construction QA program through completion of the construction phase of Unit . Operations QA Activities Analysis
,
'
An extensive inspection of the licensee's quality program
<  was conducted that included the QA Plan, program and administration; audits; preoperational testing QA; plant surveillance program; measuring and test equipment; tests and experiments; document control; records; maintenance; design changes and modifications; procurement control; and receipt, storage, and handling of materials and equipmen This inspection effort found that the QA program was in
.'
place; however, some implementation problems were evident as exemplified in the inspection findings. For example, seeral volumes of operator logs could not be reacily found because they had not been properly controlled, f  Additional inspection findings that reflect on performance
,  in the operations QA functional area were identified during
!  other NRC inspections. There was one violation dealing with
!  failure to follow procedures for temporary modifications, f
.
 
_ _ _ _ _ _ _ - _ _ _ _ _ _ __
. .
 
Three additional deviations were cited for failure to meet a comitment to the NRC dealing with audits of the WCC, anonymous drug tips, and Independent Safety Engineering Group (ISEG)reportfollowups. Minor inspector observations were passed on to licensee management for attention. These observations, although not constituting violations, did highlight programatic weaknesses in such areas as QC coverage and documentation of preoperational tests, QC shift activities log, and QC coverage of maintenance (repair) activitie Operations QA was assigned the task of reviewing the TS surveillance requirements and surveillance procedures for proper integration. This review was completed and all differences were reportedly reconciled. However, subsequent to this review additional inconsistencies were still being identified. One of these inconsistencies led to an escalated enforcement action. See Section V.D for details, b. Conclusions Many aspects of this functional area are working well; however, the enforcement actions show weaknesses in the implementation of the program. The performance of operations QA/QC has been acceptable but is not viewed as aggressive. The licensee is considered to be in Performance Category 2 in this functional area, c. Board Recommendation (1) Recomended NRC Action The NRC inspections should continue at the present level in regard to the quality attributes related to all plant inspection activities. Inspection related to administrative control and management overview l'
should be emphasized to assure that the licensee is being responsive to NRC comitnents and OL requirements.
 
; (2) Recommended Licensee Action The licensee should devote appropriate resources to ensure compliance with comitments and provide adequate management overview of this functional area,
 
i This effort should be focused on getting in front of quality issues.
 
!
 
_ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - . .
. .
20 Training and Qualification Effectiveness
          -
This functional area includes all activities relating to the effectiveness of the training / retraining and qualifications program conducted by the licensee's staff and contractors for the following categories of facility training:
          !
  *
non-licensed operators
  *
control room operators
  *
senior control room operators / shift supervisors
  *
shift technical advisors
  '
instrument and control technicians
  *
electrical maintenance personnel
  *
mechanical maintenance personnel
  *
radiological protection technicians
  *
chemistry technicians
  *
onsite technical staff and managers Analysis Two cold license examinations were conducted during this SALP perio ,
In January 1987, 41 senior reactor operator (SRO) and 3 reactor operator (RO) operating examinations were administered to candidates that had previously passed the written examination; 39 SR0s and 1 R0 passed. In May 1987, 11 SR0 and 3 R0 written and operating examinations were administered; 10 SR0s and 3 R0s passed. Some of the last group were retakes, thus at year end 1987, the licensee had 50 SR0 and 4 R0 licensed operators. These numbers of licensed operators fully support the licensing and operation of STP, Unit The licensee is considered as having a very good performance for the cold license examination. One generic weakness was identified to SYP in the licensing examination reports for January and May 198 i Candidates routinely plant emergencies or had difficulty transients mitigating with the plantornot responding at power (to major i.e., in
          '
Modes 5 or 6).
 
The licensee has a schedule to have 11 training packages submitted to INPO for accreditation within 2 years of fuel load (August 1989). The licensee had been making progress towards early completion of these submittals, but during this assessment period efforts have been diverted towards other training responsibilities. Work is continuing towards the INP0 accreditation and the original schedule date seems achievabl The Training Department has been responsive to identified needs for their support. This support was evident in the training and requalification of the security force, update of licensed operators on plant procedures, and retraining on plant events that were demonstrated as being not clearly understood by plant personnel. They were generally responsive in a timely manner to initiatives for this support. The staffing is adequate, qualified and capable of performing their responsibilitie .
 
_ _ _ _ _ _ _ _ _ _ _ _
o .
 
Some weaknesses in other SALP areas could be traced to training inadequacies. Examples were licensed operator problems in implementing certain emergancy procedures and inadequate instrumentation maintenance personnel performance of certain work
< functions. Also, inadequate training was the root cause of certain problems in implementing the security plan as discussed in Section IV.J. These weaknesses were the root causes in some of the 25 LERs and 13 security event reports (SERs) made since OL issuance through the end of this SALP perio There were no violations or deviations in this area during this SALP period with the exception of those relating to the security department which initially had the responsibility for their own training. Some aspects of training are covered in other SALP area Those elements deal with emergency preparedness personnel, the security force and construction craft personne . _ Conclusion The training provided to personnel appears to be sufficient and timely to promote satisfactory performance. The resources needed to maintain the level of training continues to be allocated. The licensee has a well established plan for meeting its training commitments and is executing that plan in a generally effective manner. They have a well defined program for incorporating plant changes into the plant simulator. The licensee is generally responsive to the needs for retraining or refresher training while meeting their licensing requirements. Training within the security department had been unacceptable but that trend has been reverse The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Action During this stage of plant life, the NRC should continue to provide an inspection effort at a level to verify adequate continued training of Unit i licensed staff and initial training of Unit 2 licensed staff. Coverage of retraining on emergency procedures, plant identified problems, and industry experience issues should continue. Inspections of security training and non-licensed operator training (to include "on-the-job" training) should also continu Recommended Licensee Action The licensee should continue the level of effort required to achieve tneir licensed operator training and retraining obligation for Units 1 and 2. They should continue to upgrade the simulator to ensure it accurately reflects the current plcnt
  . . .
  . . .
o PLANT OPERATIONS CATEGORY 2 CORRECTIVE ACTIONS HAVE NOT ALWAYS BEEN EFFICIENT OR INITIALLY EFFECTIV '
PERFORf%NE DECLINED AFTER ISSUANG OF OPERATING LIENS TKRE IS GOOD EVIDENE THAT HL&P IS LEARNING FROM THE REENT ERRORS N4D THAT PERFORMAN E IS IMPROVIN RECCft1 ENDED LICENSEE ACTION THE LIENSEE SHOULD MOVE FORWARD IN A DELIBERATE, C0fRROLLED FWiNE .
I
              !
              (
- - - - - _ _ _ _ _ _ - - _ _ _ - _ _ _ _ - - _ _ - - - -          _ _ ____.____ a


      . _ _ _ _ _ _ _ _ _ _ _ _ _
i
  . .
  * *
PPEOPERATIONAL TESTING CATEGORY 2
    ,
THE TEST PROGRNi HAS BEEli GEfERALLY EFFECTIVE AND HAS HAD FEW PROBLEMS, PEC0fHEffDED LICENSEE ACTION EwHASIZE THE NEED TO COMPLY WITH ALL C0FNITMEfRS.


desig Efforts should be directed towards the INP0 accreditation of the 11 training programs. They should provide support as required for other plant training needs such as
l
"
    '
security, QA/QC and general employee training. Additionally, the training staff must be responsive to the supplemental
i
,  training necessitated by plant problems, current industry issues, and plant identified operator weaknesses, i
I. Emergency Preparedness


This functional area includes activites relating to the
____ ___
! implementation of the emergency plan and implementing procedure l' Thus, it includes such activities as licensee's performance during exercises which test the licensee, state, and local emergency plans; plan administration and implementation; notification; communications;--
.. .
STARTUP TESTING
  [AIFGORY2 PERFORMAf4CE DURING INITIAi CORE LOADING WAS INDICATIVE OF AN ADEQUATE PROGRM1 AND STI.ONG f%NAGEfENT IfNOLVEPENT. A DELAY IN T11E STARTUP OF UNIT 1 HAS RESULTED IN A LIMITED NUMBER OF STARTUP ACTIVITIES BEING INSPECTED DURING THE SALP APPRAISAL PERIO REC 0ftENDED LICENSEE ACTION ENSURE GOOD COORDINATION OF STARTUP ACTIVITIES NO POWER ASCENSION TESTING WIT 11 NORf%L PLNiT OPERAT10f4 ,
i I
l
    ;
    :
1    \
E


facilities and equipment; staffing; training; assessment; emergency
_. . - . __ _ _ - _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
; classification; medical treatment; radiological exposure control; recovery; protective actions; and interfaces with onsite emergency response organizations.
  .. ,
 
i Analysis
,
During the assessment period, six emergency preparedness i  inspections were conducted by region-based and NRC contractor
!  inspectors. The first of these inspections was the observation
! and evaluation of the annual emergency response exercise by a team of NRC and contractor inspectors. During the exercise, 16 deficiencies resulting from the prior emergency preparedness j  appraisal were closed. The licensee's performance during the annual graded exercise was adequate indicating that emergency l  actions would be taken to protect the health and safety of
:  emergency workers and the general public. During the exercise, i
four new deficiencies were identified. The NRC inspector noted
!  that the licensee had taken remedial actions to reduce the l  probability that these deficiencies would be repeated in a
;  similar situation. Exercise deficiencies by their nature l  usually require that corrective actions be observed during the dynamic process of an exercise; therefore, inspections of the same are deferred to the next evaluation.
 
l  The other five inspections were routine announced inspections to follow up on the deficiencies that remained open from the emergency preparedness appraisal conducted in December 1986,
,
;
'
when a total of 75 deficiencies were identifie The licensee now has corrected all energency preparedness area deficiencies identified by the appraisal, except for three deficiencies pertaining to the post-accident sampling system. An allegation that the site evacuation alarm could not be heard within the site office buildings was investigated by the licensee's Safe Team. The NRC inspector reviewed the findings l
t
t
        ;
MAINTUlANCE CATEGORY 2 THE ELEFENTS OF A STRONG f%lf!TEftANCE PROGRAM APPEAR TO BE IN PLAC SOK PROBLEMS HAVE BEEll OBSERVED IN THE IMPLEWiiTATION OF TlilS PROGRA MANAGEf1EilT AND CORRECTIVE ACTIOil SYSTEMS APPEAR TO BE WORKlflG TO RESOLVE THE IDENTIFIED PROBLEM REC 0 MENDED LICENSEE ACTION THE LICEf4SEE SHOULD CONTINUE STAFFING EFFORT TO SUPPORT    '
UNIT 2 ACTIVITIES AND C0ffT!fiUE UPGRADING PAINTENAN&
PROCEDURES BASED ON EXPERIENC ,


_ _ _ _ _ _ _ _ _ - _ _  _ _ _ _ . _ _ _ _ _ . ___ ___ . _ _ _ _ _ . . _ _ _ _ _ _ - _ _ _
i
e ,
 
and recommendations of the Safe Team, and the corrective actions of the licensee, and found that they were adequat . Conclusions The results indicated that the licensee demonstrated, during their annual exercise, their ability to implement their emergency plan and procedures. In addition, they had successfully corrected deficiencies resulting from the December 1986 emergency preparedness appraisal inspection. This was possible because of effective prior planning and management control implemented since the last SALP evaluation. The correction of the four appraisal-identified deficiencies, their basically adequate emergency response actions during the annual exercise, and the establishment of management controls in the emergency preparedness area indicate that the licensee's present emergency preparedness status is satisfactory. However, deficiencies identified during the emergency exercise showed that training methods and procedures require additional improvements which are currently being pursued by the license The licensee is considered to be in Performance Category 2 in this are . Board Recommendations Recommended NRC Action The NRC should conduct routine inspections and exercises to verify that the various aspects of their emergency preparedness program can function adequately during the operational phase, Recommended Licensee Actions Licensee management should continue to ensure that facilities, equipment, and procedures are tested by walkthroughs, drills, exercises, and routine internal quality assurance type inspections to verify that their emergency preparedness posture remains adequate for an operating plan J. Security This functional area includes all activities whose purpose is to ensure the security of the plant. Specifically it includes all aspects of the licensee's security program (e.g., access control, security checks, safeguards).
 
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.  .
 
          ,
1. Analysis Thirteen inspections were conducted by region-based NRC physical security inspectors during the assessment period. Eight of the inspections were preoperational inspections, and five were conducted after issuance of the low power OL. Substantial program area deficiencies were recorded during the preoperational inspections, and 11 apparent violations were iJentified since issuance of the low power OL. Required program area corrections were not completed by the initially scheduled date of licensing and because of the incomplete status of the security program, licensing was delayed until August 21, 198 It was not until late in this assessment period that decisionmaking for the security program was escalated to a level that was effective and ensured adequate management review. Many of the outstanding issues needed extensive correction to bring them to the point of adequacy at the time of licensing. In some relevant security areas, program policies were poorly stated or were nonexistent and had to be subsequently generated, in order to be acceptable, several other issues, which related to security management, security organization, training and i
qualifications of security personnel and the effectiveness of
'
intrusion detection and assessment eouipment, were identified as conditions in paragraph 2.F of the OL. These items will be tracked by Region IV personnel as corrective action progress is made. HL&P was issued a low power OL at the point where progress in the security program development had reached a level of sufficiency to meet the regulatory requirements. To achieve that goal, the licensee's corporate management did take an active role in restructuring the security organization and transferring experienced and effective managers into positions of authority. These managers were provided substantial
,
resources for the necessary corrective measures for the imediate and long range development of the security progra Prior to the issuance of the low power OL, HL&P management's implementation of their own security program readiness schedules was consistently missed or mistakenly reported as being Inspections determined that training records were not
,
l      complet correct, incomplete, or not available. The licensee did not adequately disseminate within their own organization the results l
of NRC inspections or HL&P quality assurance audit findings which would have alerted the licensee to potential problems in security that could impact licensing. Considerable NRC effort
,
and repeated security plan submittals by the licensee were
!    needed to obtain acceptable resolutions to identified problem The f4RC inspectors identified significant design and construction errors in the security systems that were attributable to ineffective licensee management control These deficiencies became evident as the licensee attempted to
.
 
,
. .    :
p
 
demonstrate the effectiveness of the security system and major system upgrades were necessary. The licensee is presently performing a substantial security system enhancement, and an initial review by Region IV personnel at the end of this assessment period indicated that the corrective measures are on schedule for a September 1988 completio During the preoperational inspection, the NRC inspectors noted that security positions were poorly defined and the organizational structure ineffective, causing security personnel to be confused about responsibilities. An interim organization was put into effect just before issuance of the low power license and was instrumental in bringing the security program to ,
a point of adequacy for licensing. The organization was L stabilized by the end of this assessment period and strong expertise was put into positions of leadership within the utility and the contractor security operations. Since the i establishment of the new security organization, event reporting and analysis by the licensee has been effective in meeting the
, requirement Since receiving the low power OL, the licensee has encountered major difficulties in keeping the security program in compliance
'
with NRC regulations and their own security plan. HL&P's failure i or inability to lockdown the site and practice the security .
j systems and procedures for a meaningful period of time prior to !
l licensing resulted in the occurrence of three major violations I and multiple minor violations since issuance of the low power OL. These occurrences were indicative of programmatic breakdowns of segments of the overall program. A number of {
escalated enforcement activities are pending as a result of l these programmatic breakdown The expansion of the uniformed security ranks through the recruitmen+ of better qualified security officers has had a twofold effect. First, the officers hava an improved
;
comprehension of the procedures to be followed and second, they have provided relief to those officers who were required to work
,
l long and tiring shifts without days of It is likely that this enhancement contributed greatly to the reduction of errors on the part of the security officers that became evident toward the
 
end of this assessment period. The entire security officer and r
supervisory training package has been revised. The responsibility for its management and the newly assigned i l
i security supervisor have been transferred to the HL&P Training l Division. The improvements visible at the end of the assessment period were considered substantial by the NRC inspectors in comparison with the original HL&P security training effort. The
,
    'p l
inadequacies of the original training program were considered to be the root cause of most of the problems that occurred during this assessment perio t l
t
 
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _  . _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _
  .
 
2. Conclusion This reporting peried reflects a wide divergence in licensee performance. The licensee entered into the period with serious security program deficiencies; they exited the evaluation period on a positive trend of security program improvements. For example, it appears that the licensee now has an ample number of
  '
  '
professional personnel and contract uniformed officers, who are properly trained and assigned to the security organization, to implement the security plans and satisfy the regulation Installation of the redesigned security systems is actively underway and appears to be on schedule. The licensee has continued to provide the resources necessary to complete the task of rebuilding the perimeter, intrusion detection system and the assessment aids, all of which were conditions of the fuel load licens The licensee is considered to be in Performance Category 3 with an upward tren . Board Recomendations Recommended NRC Actions Maintain the expanded inspection effort as required to complete the startup inspection program and to close out the open items related to the licensing condition Perform the security operations inspection program following full power authorization in accordance with SALP Category 3 requirements. In addition, the preoperational
,
inspection program for STP, Unit 2 nust be initiated and
'
the associated NRC inspection procedures completed, Recommended Licensee Actions The licensee should complete the actions described in commitments made to the NRC in Section 2.F of the low power OL and HL&P letter ST-HL-AE-2407 dated November 17, 1987.
,
l For STP, Unit 2, the licensee should plan for the earliest
:    possible lockdown of all areas to ensure proper I
implementation of the security organization, security
'    systems, and procedures in accordance with the approved physical security plan to prevent a recurrence of the Unit I situation. Each of these areas should have continued management and QA oversight.


--
l
l
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _  .__ __ _ __ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
            >
    . .
            !
            !
K. Radiological Controls      i Analysis
            ,
Eleven preoperational inspections were performed in the general functional area of Radiological Controls during the assessment period by region-based radiation specialist inspectors. These inspections primarily focused on Unit 1 and included the following program areas: occupational radiation safety; radioactive waste management; radiological effluent control and monitoring; transportation of radioactive materials, and water / radiochemistr Inspection activities identified in the preoperational inspection program were completed during this assessment perio No violations or deviations were identifie Occupational Radiation Safety
            :
This functional area includes controls by licensees and contractors for occupational radiation protection, radioactive materials and contamination controls, radiological surveys and monitoring, and ALARA programs.
This area was inspected three times during the assessment period. Several concerns were identified in this area at the start of the assessment period. The licensee had taken necessary actions to close all but one concern by the end of the assessment perio The licensee's actions to resolve NRC concerns identified as open items presented several problems. The licensee did  [
not meet their commitment dates for completing actions to    i close open items and in several cases the initial proposed    i actions lacked thoroughness and depth to permit resolution  i of the item. Several open items required considerable NRC    !
inspection effort before the licensee implemented the necessary action to resolve the NRC concern The inspection results identified a reluctance on the part of management within the radiation protection department to    I discuss health physics problems with plant management. No    t problems were identified in the areas of staffing, enforcement, preoperational events, training, implementing procedures, and internal audit Radioactive Waste Management This functior21 area includes processing and onsite storage of gaseous, liquid and solid waste This area was inspected five times during the assessment    ,
period. The licensee has re elved the NRC concerns    I involving ALARA reviews of as viilt radwaste system L
            ;
            .
            -..
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. ..
issuance of a management radwaste policy statement, and
,  training. However, the licensee had not resolved two open items regarding preoperational testing of the radwaste systems in order to demonstrate the capabilities of these systems, c. Radiological Effluent Control and Monitoring This functional area includes gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, radiological environmental monitoring, and the results of NRC's confinnatory measurements progra The liquid and gaseous effluent control and monitoring program was inspected four times during the assessment period. The licensee has resolved the NRC concerns 2  involving the testing of air cleaning systems, calibration of effluent monitors, and collecting representative liquid and gaseous sample The licensee has completed verification of vendor calibration results of the liquid and gaseous effluent monitors by performing response tests with solid radioactive sources. The licensee plans to perfonn followup calibrations with actual liquid and gaseous d  calibration standards within 6 months after receiving a 1  full power licent d. Transportation of Radioactive Materials This funtional area includes procurement and selection of d  packages, preparation for shipment, selection and control of shiprers, delivery to carriers, receipt / acceptance of
,
shipnents by receiving facility, periodic maintenance of 1  packagings and, for shipment of spent fuel, point of orioin j  safeguards activitie f  This area was inspected four times during the assessment period. The licensee has not made any radioactive shipments, but the necessary procedures have been developed to ensure the implementation of a proper transportation program. All NRC concerns in this area have been resolve e. Water Chemistry, Radiochemistry, and Confinnatory Measu rerents This functional are includes primary and secondary systems
affecting plant water chemistry, water chemistry control program and program implementation, chemistry facilities, equipment and procedures, and chemical analysis quality assurance.
. _ _ _ _ .
__ _ _ .. _
. . i
L t
The water chemistry and radiochemistry programs were inspected three times during the assessment period. One of :
the inspections included confirmatory measurements of prepared water and radiochemistry standards. The results ,
of the licensee's water chemistry analytical measurements ;
i  indicated 94 percent agreement. The result of the radiochemistry confirmatory measurements showed 98 percent agreement. These results are within expected industry performanc The licensee had not completed resolution of an open item ,
concerning the Post Accident Sampling System (PASS). This
      '
item involves testing the PASS to demonstrate performance of the system. In order to perform the tests, the plant must be at least at Mode 4 to have sufficient temperature and pressure. The licensee committed to perform the necessary testing before exceeding 5 percent powe Management involvement in this area was evident by the development and implementation of a comprehensive audit progra'1 No problems were identified in the areas of staffing, qualifications, resolution of technical issues, ,
procedures, and response to NRC initiative ;
i      ,
2. Conclusions
      !
      '
The licensee has not met the scheduled completion dates for preoperational testing of the radwaste systems. As a result,
,
all the concerns associated with these systems have not been .
i closed. Concerns were identified regarding management l'
involvement and oversight of the radiation protection program.
-  The licensee has recognized the need to improve management !
      '
l capabilities in the radiation protection area and recently established a new manager position to address these concern [
,
No problems were identified in the transportation of radioactive materials and water chemistry / radiochemistry area The licensee is considered in Performance Category 2 in this are i 3. Board Recommendations    t Recommended NRC Action  ,
i Inspection activities should continue at nonnal levels, f
.
Special inspections should be conducted to verify operability of the PASS and radwaste systems. An onsite inspection with the mobile laboratory should be perfonted, ,
-
after the plant has achieved the necessary power level, to verify confirmatory measurements of radiochemistry samples, j
i
      -
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
        ,
I e .
l 30 Recommended Licensee Action Management attention is needed to assure that:
    (1) preoperational tests of the radwaste systems are  '
completed, and (2) an aggressive radiation protection program is implemented during plant operation L. Containments, Safety-Related Structures and Major Steel Supports
,  This functional area includes all activities related to the  !
'
structural concrete and steel used in the containment (incluc'.ing the ;
basemat) and safety-related structures, and major steel equipment  i support It includes all aspects of structural concrete; liner plate erection and fabrication, and containment post-tensioning; structural steel used in safety-related structures (welded and
'
bolted), and major steel equipment supports (for reactor vessel, reactor coolant pumps, steam tanks, heat exchangers, etc.)genearators, pressurizer, polar crane,
    .
, Analysis Thirteen construction inspections were performed in these three categories, which included Units 1 and 2, by resident and regional construction inspectors. The inspections were performed in the areas of: concrete, Unit 1 structural integrity test / integrated leak rate test (SIT /ILRT), post i    tensioning of Unit 2, protective coatings, structural masonry j    construction, and structural steel.
. The SIT /ILRT on Unit I was performed on schedule and significantly exceeded the design requirements. The testing was
,
observed to be efficiently managed and well prepared. The i    results were clearly defined, recorded and easy to interpret as illustrated in the final report. NRC inspections found that the l
concrete testing laboratory subcontractor was thorough in the i    sampling and testing areas. The protective coatings have been
,
applied according to the specifications in a manner consistent i    with good construction practices. The structural masonry walls were found to meet the criteria of IEN 79-02 and 79-14 and project specifications for design and constructio l
:    The post tensioning by the subcontractor has been in conformance !
to his approved quality manual and job specifications. Overall performance in this area was excellent. The three areas of structural steel erection and welding were performed with excellent results. Overall, very few deficiencies were noted in these areas in relation to the large amount of work effort that has been performed. Two violations were identified during the i
'    verification of structural steel as-built configuration l    inspection. One violation cited that the bolting in two I    residual heat removal (RHR) pump supports in Unit 2 was loose; i
      .-_ -._ - - - _ . - _
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . .
          !
this error was due to the fact that torque values used were inadequate. Corrective actions have been initiated and    .
determined by the NRC to be satisfactory.
'
In the second violation, it was identified that the drawings required a certain size fillet weld, however, a smaller weld was made. The licensee established by calculations that the smaller    .
weld was satisfactory. It was noted that the licensee    l
management took immediate corrective action through direct    i involvement in rectifying the problems that were identified and providing additional controls to preclude further deficiencie ! Conclusion i  The licensee, engineering, and construction management involvement is aggressive and evident in day to day construction  i activities as observed by the resident inspectors. Positive i  results were seen in the completion of Unit 1 the ongoing work,    ,
;
and completion of systems in Unit 2. The work appears to be    l progressing on schedule in an orderly systematic manne Curing :
!  the 13 inspections, only two deficiencies were identified. The licensee is considered to be in Performance Category . Board Recommendations      !
' Reconinended NRC Action h
The NRC inspections in this area will be reduced consistent  t l  with the completion of construction activities in Unit i
          '
Unit 1 is complet Recommended Licensee Action Management attention should be maintained at the same level in Unit 2 to assure that the desired quality is achieved.
,
M. Pjping Systems and Supports      ;
j  This functional area includes those safety-related piping sytems i
described in 10 CFR 50.2(v) and RG 1.26, quality groups A, B, and C.
It is intended to be limited to the primary pressure boundary and j  other safety-related water, steam and radioactive waste piping
<
systems. It includes those quality checks necessary to ensure
compliance with the applicable codes and other requirements specified    ;
;  in the FSAR for those system i i Analysis      ,
There were 13 inspections accomplished in this area during this  !
i  assessment period including an as-built verification inspection for both Units 1 and 2. A total of three violations affecting i
. - . - - . - - . _-_ - - - - _ _ _ _ , - - _ - - - _ - _ . - . _ _ ___  - _ _
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        !
32  l
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!
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either piping or pipe supports were identified. The three violations were as follows: spattered paint, insulation glue, and lubricants were observed on the external surfaces of safety-related piping; the construction support group failed to
'
maintain the cold position of a spring hanger after balancing the system; and pipe supports were found to incorrectly have protective coatings on machined surfaces. These three violations occurred in Unit 1 and do not indicate a major programatic weakness. It app % r: the licensee's responses to the violations have enhanced management controls and have reduced recurrence of similar deficiencies in Unit Examples of these management controls include the following: retraining QC and crafts personnel; and enhancing the procedure by addition of hold points and more inspection commitments,  i Conclusion Deficiencies were identified in this functional area by the NRC and the licensee's own QA program; however, licensee's responses to these deficiencies were timely with acceptable resolutions, j
        '
Licensee management is evident and effective. The licensee is considered to be in Performance Category 2 in this are . Board Recommendations Recomended NRC Action The inspection effort in this functional area has been concluded for Unit 1 because construction is complet However, the inspection effort should continue comensurate with the level of construction activities in Unit Recomended Licensee Action Although licensee management attention is evident, continued emphisis must be maintained to achieve the desired level of qualit N. Safety-Related Components - Mechanical This functional area covers mechanical components such as pressure vessels, pumps, and valves located in, and attached to, the piping systems described abov . Analysis The residents and region based construction inspectors performed 10 inspections in this functional area during this period. These inspections were perforTwd primarily on equipment in the reactor containment buildings that was stored in place or either partially or completely installed. The inspections were in
-____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __  _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _
  . .
;  Units 1 and 2 and involved all facets of the construction and quality process including storage, maintenance, verification of quality requirements and final installation. The components that were examined included the reactor vessel internals, residual heat removal system, safety injection and an assortment  I of Class 1 and 2 systems components within the reactor C Niant
pressure boundar The plant permanent maintenance (PPM) for the items inspected was found to be adequate in that no items of concern were reported. Housekeeping and cleanliness of
',
mechanical equipment has improved considerably due to improved management attention at all levels and improved craft work habits and attention to detail. A continuous program of cleaning and maintenance has been established in order to keep i
equipment damage minima ;  Three areas of concern were noted. The first was the leak on a
~
Vnit 1 code safety valve inlet flange during reactor coolant system filling and venting activities. This was due to improper installation of the valve. This item was reported as a
.
:
deficiency to the NRC and the rework was followed by a resident
,
inspector. The second item of concern was the failure of tubes  '
,
in the component cooling water heat exchangers in both unit This problem required analysis, testing, modification, and
;
rework of the tube bundle. This deficiency was reported to the
-
NRC as a 10 CFR Part 21 item. Reporting and rework on both
-  items of concern were completed in accordance with approved i  procedures and the licensee comitments. Inspection of the spent fuel storage racks identified a third violation which involved improper torquing of the fuel rack hold down bolt This problem was due to the failure of the designer to include torque values in installation procedures.
l i  2. Conclusion i
Licensing management attention to detail and their involvement in the program is evident. The craft, supervision, quality and I  management appear to be aware of the requirements concerning the equipmen Corrective action for identified concerns and i
problems has been effective. The licensee is considered to be
;
in Performance Category 2 in this functional area.
I I  3. Board Reconinendations    I
!
: Recommended NRC Action l
NRC inspection should continue at the present level until
!        The l J
completion of the plant construction activities.
i inspection emphasis should remain on major critical safety-related equipmen l l
- _ _ _
  . .
  . .
t'
  .S118yEILLANT  l CATEGORY 2 CONCERN ABOUT THE ADEQUACY OF THE IDENTIFICATION OF TS REQUIRENNTS AND IWLEENTATION OF THESE REQUIREENTS INTO SURVEILLANG PROGDURE PROGRNi TO PRECLUDE MISSED TESTS IS ACEPTABL REC 0FfE GED LICENSEE ACIjpg
  .
NRC ENCOURAGES THE Ll&NSEE TO KEEP LEARCHING FOR WEAKNESSES IN THE SURVEILLANCE PROGRA . - . .


i Recommended Licensee Action The licensee program and attention should continue at its
-  present level and possibly increase as equipment is finished and prepared to be turned over to startup for testing. The plant operations departments should interface  T and maintain the equipment in an acceptable statu . Auxiliary Systems This functional area includes those safety-related auxiliary systems included in the nuclear facility which are essential for the safe shutdown or the protection of the health and safety of the publi Included here are systems such as HVAC, radwaste, and fire protectio . Analysis Four inspections were performed in this area during the rating period. These were performed by resident construction, regional, headquarters, and consultant personnel. Observation of this functional area has indicated that the licensee is maintaining a consistent ano effective program in maintaining quality. Two inspections involved heating, ventilating and air  i conditioning systems in which one violation of requirements with two examples was noted: these concerned the comingling of fasteners and completed construction not meeting the drawing detail requirements. These violations were minor in nature and did not indicate a programatic breakdown. It was noted that licensee management has been responsive and has taken imediate corrective action in these problem area !
The fire protection program inspection was reviewed for the overall establishment and implementation of the program and its compliance with the requirements of 10 CFR 50, Appendix R which is discussed in detail in F. abov . Conclusion Personnel are well trained and knowledgeable and management involvement in the processes of inspection is aggressive and evident. This is evidenced b deficiencies (10 CFR 50.55(e)y theduring
    ) identified smallthis number of constructio appraisal period. This area has shown consistent improvement. Licensee management attention increased during the latter part of the appraisal period by implementing a program to enhance the inspection effort of the HVAC activities in which the violations were identified. The licensee is considered to be in Perfomar..e Category 1 in this are >
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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35 Board Recommendations Recommended NRC Action The NRC inspection effort should be reduced in the HVAC area in Unit 2. The inspection effort should continue at the normal level for the other auxiliary systems.
_
 
.. .
, Recommended Licensee Action Even though licensee management has been attentive, and aggressive in the installation and inspection of safety-related HVAC, this effort should continue in order to assure that the desired level of quality is achieved and maintained in Unit P. Electrical Equipment and Cables
FIE PROTECTION CATEGORY 2 CONCERNS AND OUESTIONS WERE PROMPTLY REVIEWED NO ADEQUATE CORRECTIVE ACTION WAS TAKEN OR IfliTIATED Off A T!fELY BASIS BY TIE LICENSE PROGRNi IS SUCH THAT TIE CONSEQUEf4CES OF A FIRE SHOULD f0T AFFECT THE SAFE OPERAT10ft OR SHtJTDOWN OF THE PLAN PEC0ffEf0ED LICENSEE ACTIONS PN4AGEFENT SHOULD C0ffTINUE THE LEVEL OF ATTENTION IN THE FIRE PROTECTION / PREVENTION PROGRNi N4D ENSURE THAT TIE PROGRNi IS ADEQUATELY IMPLEFEffTED NO PAINTAlfE ,
. This functional area includes safety-related electrical components, cables and associated items used in the electrical systems of the plant, such as: motors, transformers, batteries, emergency diesel
r
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          .
generators, motor control centers, switchgear, electric raceways, i cable (power, control, and instrument), circuit breakers, relays, and other interrupting and protective device . Analysis Nine inspections in the electrical equipment and cables program area were performed by region based inspectors including the electrical as-built inspection in Unit 1. There were also
        -
, followup inspections for closures to IE Bulletins (IEB), IE l
      . _ _ . _ . - - . - - . ,_,,.3
Notices (IEN), IE Circulars (IEC) and Part 21 reports. The i
_
areas inspected included records, receipt inspection, storage j and installation of the following areas: cable trays, conduit, i supports, cable, electrical terminations Class IE batteries, blind crimp splices on dual voltage motors and various
          - - _, ,,, .. .
.
electrical components. The inspection also covered QA and I procedures activities, design change control, and construction l testing / calibration activities, in the areas inspected, there l was one violation and four unresolved items identified in the followup of IES 85-03, "Motor Operated Valve Common Mode Failure
! During Plant Transients, Due to improper Switch Settings." The l violation involved Limitorque valve operators with dual voltage motors that had motor leads with blind barrel crimp splices
.I which had not been qualified. As a result of the violation, the licensee has inspected all Limitorque valve operators with dual i
voltage motors and found that all 23 had the blind barrel crimps i  splices in motor leads. The splices have since been replaced with in-line splices which were insulated with Raychem WCSF-070 shrink tubing.
 
.
l
l
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    *
!
00ALITY PROGRAMS AND ADMIhSI'RATIVE CONTROLS AFFiCTI NG 0. AL: TY CA"EGORY 1 (CONSTRUCTION)
 
CA 'EG01Y 2 (OPERATIONS)
- - _ - - - - - - _ _ _ - - - - - - - - - - - - - - . - - - - - - . - - _ _ _ _ - - - - _ - - . - - - - - - - - - - - - - - - - - - - - - .- - - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
THE QUALITY ASSURANCE PROGRAM FOR C0t1STRUCT10N IS BEING PERF0 PIED IN AN EFFECTIVE TWINE KVlY ASPECTS OF THE OPERAT!0f4S CA ACTIVITIES ARE ':ORKING WELL. HOWEVER, THE ENFORCEFEtiT ACTIONS SHOW WEAKNESSES IN THE IMPLEFENTATION OF THE PROGRA THE PERFORMANCE OF OPERATIONS 0A/0C HAS BEEN ACCEPTABLE BUT IS ?OT VIEWED AS AGGRESSIV REC 0ftfENDED LICENSEE ACTION SHOULD CONTINUE CURRENT LEVEL OF EWHASIS Off CCNSTRUCTION GA PROGRA%
                ,
THE OPERATIONS CA PROGRAM SHOULD DEVOTE APPRCPRIATE RESOURCES TO ENSURE COMPLIANCE WITH CCtNITMENTS AND PROVIDE ADEQUATE FWiAGEFEf6 OVERVIEW OF THIS FUNCTIONAL AREA. THIS EFFORT SFOULD BE FOCUSED ON GETTING IN FRONT OF QUAL.lTY ISSUE _ _ _ _ _ _ - -
    . .
. .
36 Conclusion Management attention and involvement are evident and work activities associated with safety-related electrical equipment and cable are being conducted in an acceptable manne The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendation Recomended NRC Action The NRC inspection effort should be maintained for Unit 2 electrical activities. The NRC inspection effort for i        Unit 1 is complet Recommended Licensee Action Licensee management involvement in this area should continue at a level comensurate with construction activities with continued attention on the NOV identified with Limitorque valve operators with dual voltage motors for Unit Q. Instrumentation This functional area covers safety-related instrument components and systems that are designed to measure, transmit, display, record and/or control various plant variables and conditions. The Reactor Proctection System and the Engineered Safety features Actuation System are two plant systems utilizing such devices as: sensors, transmitters, signal conditioners, controllers and other actuating devices, recorders, alarms, logic devices, instrument air supplies, racks, and panel . Analysis During this period three inspections were perforned. These inspections were perforred by regional inspectors in the areas of QA programs and procedures; storage and housekeeping; installation; construction testing and calibration; design change control; and recnrds. No violations or deviations were identified in this functional are Corrective action for concerns identified during earlier SALP periods appear to have significantly improved performance in this area. Improved training has been evident and effectiv Lessons learned during the construction of Unit 1 are being applied to Unit _______ ____
TRAINING AND QUALIFICATION EFFECTIVENESS CATEGORY 2
.- .
      ~
F
MANAGEFENT IS GENERALLY RESPONSIVE TO THE NEEDS FOR RETRAINING OR REFRESHER TPAINING WHILE FEETING LICENSING t REQUIREFEtG TRAINING WITHIN THE SECURITY DEPARTMENT HAD BEEN UfRCCEPTABLE BUT THAT TREND HAS BEEN REVERSE REC 0ffENDED LICENSEE ACTIONS C0ffT!NUE TO PURSUE INP0 ACCREDITATIO MANAGEMEffT SHOULD CONTINUE TO UPGRADE THE PLAfC SPECIFIC SIMULATOR TO ENSURE IT ACCURATELY REFLECTS THE CURRENT PLNiT DESIG l _ _ - - - _ _ _ ._ _ __ __
      !
.. .
EMERGENCY PREPAREDNESS CATEGORY 2 THE L! NSEE DEf0NSTRATED THE ABILITY TO IPPLEffffT THEIR EFERGENCY PLAN AND PROCEDURES DURING THE #4NUAL EXERCIS THE LI NSEE SUCCESSFULLY CORRECTED DEFICIENCIES IDENTIFIED DURING THE DECEMBER 1986 EFERGENCY PREPAREDfESS l APPRAISAL INSPECTIO DEFICIENCIES IDENTIFIED DUR!f1G TIE APRIL 1987 EFERGENCY EXERCISE IflDICATED Ti%T TRAINING FETHODS AND PROCEDURES REQll! RED ADDIT 10NAL IPPROVEFENTS, hHICH ARE BEING PURSUED BY THE LICENSE RECOWENDED LICENSEE AcTrofis t
LIGNSEE fW1AGEFENT SHOULD CONTINUE TO ENSURE THAT FACILITIES, EQUIPFENT, AND PROCEDURES ARE TESTED BY WALKTHROUGHS, DRILI.S. EXERCISEE, AND ROUT!fE INTERNAL QUALITY ASSURANG TYPE INSPECTIONS TO VERIFY THAT THE!R EFERGEfC/ PREPAREDNESS POSTURE REF% INS ADEQUATE FOR Ni CPERATiliG PLANT.


l The small number of construction deficiencies found during this ;
l 1     I
appraisal period indicates that the licensee's inspection and surveillance programs are well planned and effectiv t
      ' Conclusion The perfonnance in this functional area has been determined through observation and inspections by regional inspectors to be well planned and implemented with aggressive management involvement. The few deficiencies that did occur were properly identified and corrective actions were implenented to the extent that repetitive events rarely occurred. The licensee is considered to be in Perfomance Category 1 in this are T Bo,ard Reconsnendations Recoamended NRC Action i
NRC inspection effort should continue at a reouced level cocrnensurate with the level of construction activities in Unit 2. The inspection effort for Unit I construction ,
activities in instrumentation is complet ' Recormended Licensee Action  l Although licensee management attention is evident,  ;
continued emphasis inust be maintained to assure a high level of performance with respect to achieving construction quality in Unit *
R. Licensing Activities
      ,
This functional area includes all activities supporting the NRC review of the application for and the issuance of the Operating License, and amendments thereto. It includes the NRC review of  '
exemption requests, relief requests, schedular extensions, responses to generic letters and bulletins, and TMI (NUREG-0737) Action In .
addition, it includes an assessment of licensee activities related to !
design and safei,y issues. It also includes NRC meetings that detit with significant licensing issue . Analysis The licensing activity durin'j this SALP period Januarv 1 through December 31, 1987, was directed toward issuance of th. :ow power OL. During this period, three supplemental safety evaluation reports were issued and the low power OL was issued on August 21, 198 The basis for this appraisal has included consideration of the SALP inputs provided by the technical staf f as part of the safety evaluation. The following were the areas involved:
       ,
       ,
1      :


_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
  . .
  . .
 
SECURITY & SAFEGUARDS CATEGORY 3 SIGNIFICAIR WEAKNESSES IN SECURITY MAf;AGEMENT, SECURITY ORGANIZATION. TRAINING NO QUALIFICATIONS OF SECURITY PERSONNEL. THE LACK OF EFFECTIVr. NESS OF THE SECURITY PROGRAM DELAYED ISSUANCE OF THE LOW POWER Oh! RATING LICENS CORPORATE FW4AGEMNT TOCK AN ACTIVE ROLE IN RESTRUCTURl'4G THE SECURITY ORGNilZATION NID TRANSFERRING EXPERIENCED #to EFFECTIVE MANAGERS If4TO POSITIONS OF Alm 0RIT SIGNIFICANT DESIG1 AND CONSTRUCTION ERRORS IN THE SECURITY SYSTEMS WERE IDEIRIFIED N O CORRECTED BY PROVIDING THE RESOURCES NECESSARY TO COBPLETE THE TASK OF REBUILDING THE PERlfETER, INTRUSION DETECT 10f4 SYSTEM, NO A3SESSMENT AID THE SECURITY ORGANIZATION APPEARS TO HAVE AN AFPLE NUMBER OF PROFESSIONAL PERSONNEL AND CONTRACT UNIFORE D OFFICERS, L'O MEET TRAINING REQUIREMENTS, TO IFPLEENT THE SECURITY PLANS AND SATISFY THE REGULATION AN EXTENSIVE SECURITY PROGRN4 UPGRADE l$ UNDERWAY IN
Reactor Systems, Chemical Engineering, Mechanical
  ~
Engineering, Materials Engineering, Electrical and Instrumentation Plant Systems, Structural Engineering, Human Factors, Safeguards Performance Evaluation, Region IV (GL83-28),andLicensing The licensing activities throughout the SALP period were governed by extremely aggressive and overly opitimistic schedules. In most cases, the licensee was unable to meet their self-imposed schedules due to the difficulty and unpredictability of the problems which arose. Planning activities and assignment of priorities accentuated meeting the schedular objectives sometimes at the expense of thoroughnes On occasion insufficient time was allowed for the proper interaction between the functional groups within the licensee's organizatio The licensee has shown adequate understanding of the regulatory issues, with the technical approaches being generally conservative. The exceptions appear to occur when schedular objectives are threatene The NRC staff's initiatives generally resulted in satisfactory submittals or other responses, but occasionally after multiple iterations. Two examples which illustrate the terdency to allow aggresive schedules to undennine standards relate to the information initially provit'ed on the problems associated with the auxliary feedwater system and the wear of instrumentation tube thimbles. The staff found that the first submittals on these issues were not sufficiently comprehensive and were lacking in depth. Interaction with the staff improved the
,-
que.lity of the information receive Key positions in the licensees organization appear to be filled by well qualified individuals. There is a willingness to make organizational changes quickly to meet changing need Sometimes, such changes appear to cause short-term problems, with satisfactory resolution occuring given sufficient tim The licensee has not hesitated to recognize the need for corrective actions resulting from problems or events. The actions appear to be aggressive, but sometimes insufficiently b roa . Conculsions i-Management involvement and control in licensing activities appropriately emphasizes quality but, on occasion, does not allow sufficient time to achieve it. The technical expertise directed toward resolving regulatory issue is satisfactory. The licensee is responsive to NRC initiatives. The licensee is considered to be in Perfonnance Category 2 in this are ,- , - . .
 
. .
i 39 Recommended NRC Action NRC review efforts should continue at the current normal levels. The staff intends to ensure that the licensee
    -
maintains high standards in addressing the operational aspects of the plan P.ecommended Licensee Action The time lines and quality of the reports to NRC should be improved as the licensee's technical staff makes the transition to fully operational statu ,
' Supporting Data And Summaries Licensee Activities Construction was completed on Unit 1 and the NRC issued Low Power Operating License NPF-71 for STP, Unit 1, on August 21, 1987. Core loading was accomplished over the next several days. The licensee i  then initiated his precritical startup testing program, liardware problems involving tube leaks in the component cooling heat exchangers and piping and support cracking resulting from water
<  hammer in the auxiliary feedwater systera delayed planned startup activities. The highest plant mode achieved was hot standby (Mode 3). The plant was in cold shutdown (Mode 5) at the end of the SALP period. The outstand;ng technical issues involved NRP review of HL&P's resolution of the auxiliary fecdwater hammer problem and the generic Westinghouse incore instrument thimble tube wear issu Construction prcceeded on schedule for Unit 2 and was approximately 86 percent complete at the end of the SALP period. Preoperational testing was conmenced for Unit 2 and was approximately 7 percent complete at tne end of the SALP period. Most cf the preoperational testing accomplished was in the electrical area. The Unit 2 primary cold hydrostatic testing was performed in late Febrtary 198 Inspection Activities
'
NRC Region IV performed 74 inspections 1:4volving 13,508 direct
'
inspection hours during the SALP period. Of the total hours, 10,890 hours were devoted to Unit 1 and 2,618 hours were devoted to Unit 2. Most of the inspection hours rela;ed to preoperational testing and operational preparedness reviews for Unit 1. The following reports documented the larger scale inspections for Unit 1:
  *
InspectionReport(IR) 50-498/87-03, New Fuel Receipt Witnessing, Review of Technical Specifications, Hot Functional Test Witnessing
 
  ,  . - ~ . . .  - .- .
  . . .
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40  !
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ACCORDANCE WITH LICENSE C0f141TMENTS AND SUPFLEMENTARY SIP LETTER THE SECURITY PROGRNi HAS SHOWN A POSITIVE UPWARDS TREND IN  !
THE LAST QUARTER OF THIS EVALUATION PERIO RECOMMENDED LICENSEE ACTIONS FOR UNIT 2 THE LICENSEE SHOULD PLAN FOR THE EARLIEST
        '
POSSIBLE LOCKDOWN OF ALL AREAS TO ENSURE PROPER
.,
IffLEKfRATION OF THE SECURITY PLA TtE LICENSEE SHOULD CONTINUE TO C0ff41T THE NECESSARY RESOURCES TO COMPLETE THOSE ACTIONS IDENTIFIED IN THE FUEL LOAD LICENSE AND THE LATEST REVISION CF THE PHYSICAL SECURITY PLN ;
i
i
,
  *
IR 50-498/87-08, Technical Specifications Review, integrated
'
Leak Rate Test and Structural Integrity Test Witnessing, Preoperational Test Results Review, Startup Testing Program Review, As-Built Plant to Documentation Reconciliation, Operational Steffing and Training Review, and TMI and GL-83-28 Act;on Item Followup-IR 50-498/87-12, Witnessing Exercise of the Emergency Plan and Procedures IR 50-498/87-17, Review of the Fire Protection Program and Program Implementation    -
.
IR 50-498/87-26, Review of the Operations Quality Assurance Program and Program Implementation
  * IR 50-498/87-27, Followup on IE Bulletins and Circulars, Significant Construction Deficiencies and Part 21 Reports, and As-Built Inspection for Electrical, Structural, and Piping Systems
,
IR 50-498/87-37, Overall Startup Program and Procedure Review 1
,
  * IR 50-498/87-39, Preoperational Test Results Review, Operational L
'    Procedures Review, TMI and GL 83-28 Action Items Fellowup and Temporary Modification Program Review  -
i    IR 50-498/87-45, Operational Readiness Review  ,


Routine construction inspections continued for Unit 2. There were
___ _ ___ _______ ___- _____
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P&l0LOGICALCONTROLS
  ,
  ,
also some inspections of Unit 2 preoperational testing during the
CATEGORY 2 LIGt1SEE'S RADIATION SAFETY PROGRNi /PPEARED TO LACK THOROUGHNESS AND DEPTH If1 RESOLVING ITEMS IDEf(TIFIED DURING THE PREOPERATIOflAL PROGrwt. LICENSEE WAS NOT TIFELY IN CLOSING OUT ITEMS IN THIS ARE CON &RNS RAISED BY THE NRC IN THE AREA 9 0F WASTE FWMGEFENT AND EFFLUEf(T MONITORING HAVE BEEN ADDRESSED BY TIE L!%NSEE. F#tAGEFEf6 IfNOLVEFENT WAS EVIDEffT IN THE AREA 0F WATER CHEMISTRY, RADl0 CHEMISTRY, AND CONFIRPATORY MEASUREFENT AT THE TifE OF THE SALP REPORT, PREOPERATIONAL TESTING FOR ALL RADWASTE SYSTEMS HAD NOT FET SCFEDULED COFPLETION DATE REC 0ftENDED LICENSEE ACTION
,
,
latter part of the SALP perio .
ESTABLISH BETTER C0ftUff! CATION BETHEEf1 THE RADIATION PROTECTION DEPARTFEfR AND PLANT PANAGEFEffT TO ENSURE THAT RADIATION PROTECTION PROBLEMS REGIVE THE NEGSSARY ATTENTIO l
Please refer to Tables 1 and 2 for a summary and tabulation, respectively, of the identified violations, deviations, and  F
      ,
        -
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deficiencies in each.SALP functional area for this SALP perio : Investigations and Allegations Review Two investigations were close! during the SALP period. Three
.
investiga'.fons remained open at the end of the SALP period. None of the investigations remaining open contained concerns which  ,
potentially could impact plant safet Fifty allegations were closed by Region IV during the SALP period. At the end of the SALP period seven allegations were being actively
.
pursued by the Region IV technical staff and/or allegations
;
coordinator. Three allegations were being held open pending the completion of investigations by the NRC Office of Investigation Ar,ther four allegations were being held open pending decisic.1s by U.S. Department of Labor, d
Y
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In addition to the above allegation inspections and investigations, an NRR team, referred to as the Safecy Significance Assessment Team (SSAT), began a review of the Government Accountability Project's (GAP) allegation files during the SALP period. Thi resulted in an inspection of the allegations on-site during the week beginning January 18, 1988. The results of this inspection had not yet been published by this SALP Board meeting dat Escalated Enforcement Actions Escalated enforcement issues were identified in the SALP functional
_ - _ _ _ _ _
. .
P CONTAlftBfT, SA ET'-R1ATD S"RUCTURES AND MAJORS ti_ SU%fES CATEGORY 1 THE LICENSEE, ENGINEERING, NfD CONSTRUCTION fW4AGEbEf6 IfNOLVEMENT IS AGGRESSIVE AND EVIDEN REC 0ftENDED llCENSEE ACTION MANAGEBEf6 ATTENTION SHOULD BE f%INTAINED AT THE SME LEVEL IN UNIT 2 TO ASSURE THAT THE DESIRED CUALITY IS ACHIEVE _ - _ _ _ _ _ _ _ _ _
,
,
areas of plant operations and security toward the end of the SALP
  ,
'
PIPING SYSTEMS AND SUPPORTS CATEGORY 2 RESPONSES TO IDENTIFIED DEFICIENCIES WERE T!KLY WITH ACCEPTABLE RESOLUTION Ll&NSEE FANAGEMNT IS EVIDENT AND EFFECTIV RECOME NDED LICENSEE ACTION CONTINUED EMPHASIS MUST BE PAINTAINED TO ACHIEVE TK DESIRED LEVEL OF QUALIT . _ _ _ _ _ _ _
period. Items of concern in the plant operations area were discussed with the licensee in a meeting at the NRC Arlington, Texas, office on December 30, 1987. As of SALP Board date a Severity Level III violation (EA 87-240) citing two operational events with a proposed
.. .
,
SAFETY-RELATED COMP 0NEfffS - ECHANICAL CATEGORY 2 ATTEhTION TO DETAIL AND IfNOLVEFENT IN THE PROGRAM IS EVIDEN CORRECTIVE ACTION FOR IDENTIFIED CONCERNS AND PROBLEMS HAS BEEN EFFECTIV REC 0ffMED LICENSEE ACTION ATTENTION SHOULD CONTl?AJE AT ITS PRESENT LEVEL AND POSSIBLY INCREASE AS EQUIPMENT IS FINISHED AND PREPARED TO BE TURNED OVER TO STARTUP FOR TESTIN .
civil cumulative penalty of $75,000 had been issued to the licensee.
      :
:  The events involved the plant entering Mode 4 on October 31, 1987, with high head safety injection valves shut in violation of TS and the plant entering Mode 3 on November 24, 1987, with pressurizer pressure-low safety injection trip setpoints set less conservatively than TS required value An enforcement conference to discuss security related events which i  occurred during this SALP period was held in the NRC Arlington, Texas, office on January 19, 1988. As of SALP Board date no enforcement action had been taken relative to those event ; Licensee Conferences Held During Assessment Period I
J
'  The two conferences dealing with regulatory performance and enforcement are discussed in Section V.D. above. A number of other
  '
n'eetings involving a mutual exchange on various regulatory issues and plant status discussions were also held with the license Confirmation of Action Letters Non Review of Licensee Event Reports (LERs), Construction Deficiency Reports (CDRs), and 10 CFR 21 Reports Submitted by the Licensee Houston Lighting and Power Company submitted 25 LERS covering the
,
period from August 21 through December 31, 1987. The large number of LERs in a short time span is typical for a new plant startup. Five of
.
the LERs have been tentatively ranked significant by the AE0D screening proces ,        ,
_ . . - - - , .-. ,_ _ . _ _. _ ._,-- _ .- .._ ,_ _ -- _ ___, _ _. _... _ .,._.. _ _ . _ .  .-
 
      . - _  _ _
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Two of the LERs were caused by personnel errors that led to the degradation and failure of ventilation radiation monitors in one case and the control room toxic gas monitors in the other case. The licensee attributed these events to unfamiliarity on the part of the participants and provided additional training for the appropriate personne In the first instance., the system status lights did not provide adequate information so that recovery was unnecessarily delayed. The licensee is examining further corrective actions in this area. Loss of the toxic gas monitors occurred during maintenance of that system and it was thought that the many alarms during the evaluation may have engendered a casual respons One event involved failures and/or excessive vibrations in all the auxiliary feedwater trains within a short time span. This event was
,
attributed to basic design deficiencies which resulted in piping with
!
a natural frequency in the same range as the fluid oscillating frequenc Extensive modifications were made to correct these problem One event entailed the inoperability of two trains of containment spray for diverse reasons which were subsequently correcte The last event of interest involved improper motor shaft-to-pinion
            '
keys that were supplied by the valve operator vendor. In a separate report, another similar problem was identified for keys from a different valve vendo All of these events appear to be within the spectrum of expected situations during plant startup operation. The LERs appear to be
'
reasonably complete, however, several of them were issued late e.g.,
LERs 87-16, 87-11, and 87-1 In aodition to five significant LERs discussed above, Region IV cfassified LER 87-12 and LER 87-17 as significant. They involved
  ~
entering Mode 4 with all high nead safety injection valves shut in violation of TS and entering Mode 3 with pressurizer pressure-low safety injection trip setpoints set less conservatively than TS required values, respectively, and are discussed with regard to
,
escalated enforcement in Section V.O. above. Of the 25 LERs, Region IV classified 12 in the maintenance functional area, eight in plant operations, and five in surveillance. There were also 13 security event reports. This data is summarized in Table .
There were 23 construction deficiencies (CDRs) reported by the licensee during the SALP period. Of the 23 CDRs, Region IV classified 12 in the electrical equipment and cables functional area, two in instrumentation, one in piping systems, one in preoperational
;  testing, and seven in safety-related components - mechanica This data is also summarized in Table 3.
:
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4 , e--~-, ye,-,wr, yy .-ve,~,,,-.,--.-y-,,.,-y-,-,,,- wm y-y ., y,r-w-r,s.--w---- -,.,v.------ ,-n.v.- e-ww.,---,-,--,-r-- -----,----,..,y.--- - - , -


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  . .
  . .
AUXILIARY SYS1 EMS CATEGORY 1 PERS0fiNEL ARE WELL TRAINED MiD KN0btEDGEABL LICENSEE t%NAGEMENT ATTENTION INCREASED DURING THE LATTER PART OF THE APPRAISAL PERIOD BY IMPLEfftRING A PROGR/M TO ENHANCE THE INSPECTION EFFORT OF THE HVAC ACTIVITIES IN ,
hHICH VIOLATIONS WERE IDEfff! PIE i REC 0Ffff0ED LICENSEE ACTION THE LICENSEE SHOULD CONTItME EFFORTS If4 ORDER TO ASSURE THAT THE DESIRED LEVEL OF CUALITY IS ACHIEVED N O MAINTAINED IN UNIT ,
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Included in the above figures are one LER and three CDRs which were also reported under 10 CFR 21 (Part 21). They are identified in the REFERENCE block of Table 3 as LER 87-03, IRC-370, IRC-400, and IRC-408. They related to sheared keys on the shafts of actuator motors, failed resistance temperature detector tests, overheating of emergency diesel generator high voltage panels, and tube failures in the component cooling water heat exchangers.
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  . .
  . .
TABLE 1 ENFORCEMENT SUMMARY INCLUDES BOTH STP 1 AND STP 2 FUNCTIONAL  *NO. OF VIOLATIONS IN AREA EACH SEVERITY LEVEL V : IV : III *DEV : *DEF
ELECTRICAL EQUIRiWT AND CABLES CATEGORY 2 PANAGEMENT ATTEffTION AND llNOLVEMENT ARE EVIDEll WORK ACTIVITIES ASSOCIATED WITH SAFETY-RELATED ELECTRICAL EQUIPffNT AND CABLE ARE BEING CONDUCTED IN Ni ACCEPTABLE PANNE RECOf4 ENDED LICENSEE ACTION LICENSEE PANAGElEilT IfNOLVEFENT IN THIS AREA SHOULD C0fRINUE AT A LEVEL C0ftENSURATE WITH CONSTRUCTION ACTIVITIES.
  : :  :
A. Preoperational Testing : 2 :  :
B. Startup Testing  : :  :
C. Plant Operations  : 2 : 1 1 :
D. Maintenance  : 1 :  1 :
E. Surveillance  : :  :
F. Fire Protection  : :  :
G. Quality Programs and : :  :
Administrative Controls : :  :
Affecting Quality : 2 :  5 :
H. Training and Qualification : :  :
Effectiveness  : :  :
1. Emergency Preparedness : :  : 4
*J. Security  : :  :
K. Radiological Controls : 1 :  :
L. Containment, Safety-Related : :  :
Structures, and Major Steel : :  :
Supports  : 3 :  :
E. Piping Systems and Supports 1: 2 :  _:
N. Safety-Related Components - : :  :
Mechanical  : 1 :  :
  ~
0. Auxiliary System  : 1 :  : ,
P. Electrical Equipment and : :  :
1 Cables  : 1 :  :
    :
l Q. Instrumentation  : :
*There were no Severity Level I or 11 violations. "DEV" refers to deviations from licensee connitments and "DEF" refers to deficiencies icentifiea in the emergency preparedness functional area. Enforcement actions in the security area were pending at the end of the SALP period.
 
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TABLE 2-NRC INSPECTION FINDINGS The following pages tabulate, by SALP functional area, the deficiencies (DEF),
deviations (DEV), and violations (VIO) cited by NRC inspectors relative to licensee activities at STP during the SALP period. The ur.it for which the item
      -
is applicable is listed under the type of item in the extreme left column with a "1" meaning it applies to Unit I and a "2" meaning it applies to Unit 2. The
"DATE" column refers to either the date of discovery of the item or ending date of the report period. The "REFERENCE" column on the extreme right contains the unique Region IV tracking number for the item described in the "SUBJECT or DESCRIPTION OF NRC FINDING" column. A number in the "S" column adjacent to the
"REFERENCE" column refers to the severity level assigned to the associated violation. The "PR0XIMATE CAUSE" column contains the root cause for occurrence
- of the associated item as determined by the SALP Board. The "0RGANIZATION" column contains the licensee organization which the SALP Board believed was most' closely associated with the root cause for the item. Under the tracking number in the "REFERENCE" column, the NRC status of the item is given where "0" indicates the item is open, "C" indicates the item has been closed by the NRC, and "R" indicates an NRC inspector has stated an intention to close the item,
'
but the closing NRC inspection report has not been issued.
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* *        Table 2 Page 2 of 4 Face N /17/83 SOUTH TEXAS FROJECT (Units 1 & 2) - NRC INSFECTION Flh31kSS i
_ _ _ - _ _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _
Frcs January 1. 1987 throuch Decester 31. 1987 TVFE CATE SLIBJECT cr IESCRIFi10N CF NRC FlhDINS  PR0llMATE CAUSE ORBANIZATICW S REFERENCE Unit        Status &
     ,
Consents
. ..
  '
INSTRlENTATION CATEGORY 1 TfE FEW DEFICIENCIES THAT DID OCCUR WERE PROPERLY IDENTIFIE *
il Salo Functional Area - Ausi11ary Systess V10 09/04/87 Failure to Follce Procedure for Installation of Frocedure Nonct,aoliance (cnstruction 4 87-48-V-01 2 Nats and Bolts      Status = 0 il Salo functitnal Area - Containeents SR Structures VIO 06/26/87 Failure to Frovide Adecuate Desien Channe Cortrel tesion Review Inadeouate Enoineerino 4 87-27-V-02 1 on EHR Puso Succorts     Status = 0 V10 C6/26/97 Failure to Follom Frecedure f cr Installation of Frocedures inadeouate Construction 4 67-27-V-03 1 Bolts      Status = 0 V10 11/25/67 Weldino Class 9 Fer.etratien Cover Flate to a Sucerviscrv Controls Construction 4 87-70-V-01 2 A5PE Class 3 Stractural Chancel Beas n/o Det    Status = 0 il Salo Functional Area - Electrical Ecuiseent & Cables VIO 05/01/87 itree Lleitcrove Oceratcr Motors had leads S:liced Enciteerino Diersicht Encineerino 4 67-21-V-06 1 with Uncualified Solices      Staths = C 18 Sale Functional Area - Esercency Frepartness EEF 04/10/87 Fadiclosical Assesssent was not Satisf actcrv (To Trainino & Freced. Inadec ate Esercencv Fre H-01 1 be Verified Durtns Nest bercise)    Status = 0 CEF 04/10/37 Ccncent of Cceraticn for Inalant Teams rct Trainiro & Frtced. Inadeewate Esercent) Fre B7 12-H-02 1 Ef fective (To be verified Dsrins Next Esercise)    Status = 0 CEF 04/10/S7 Fadiolecical Centrols for Field Teans net Cesslete trainino inadeouate Esercency Fre H-03 1 (To t, Verified Iurino Next Exercise)    Status = 0 I
CORRECTIVE ACTIONS WERE IMPLEFEfRED TO THE EX5.l4T THAT REPETITIVE EVEffTS RARELY OCCURRE RECCffENDED LICENScE ACTION    :
l
ALTHOUGH LICENSEE FWWifENT ATTENTION IS EVIDENT, CONTif0ED EMPHASIS MUST BE h%INTAINED TO ASSURE A HIGH LEVEL OF PERFORtWiCE WITH RESPECT TO ACHIEVING CONSTRUCTION QUALIW IN UNIT [
[EF 04/10/37 Onsite Radioloacal Contrcls Frecedure not Trainins inadesvate Technical ser H-04 1 follcmed (To be Verified Curire hext Eiercise)    Status = 0 l
        :
r il Salo Functi pal Area - Mainter nce LEV 07/02/57 Failure of FM ard Md Frosraes to Peet FSAR Fers:v el Errcr  Mair.t es a n c e 57-4 N -Oi 1 Fec.1 resents      Status = C V10 OE/31/87 Failure to Fctic Frecedures for Pair,ter ance Eu:ervis;rv Error Flar,t Oceraticn 4 67-%-V-01 1        Status = 0
i


. .        Table 2 Page 3 of 4 Face N /17/83 50VIH TEIAS FROJECT (Units i b 2) - kRC 1NS5ECTION FlNDlWSS Free Januarv 1. 1987 throuoh Deceeber 31. 1987 TYPE DATE SUBJECT or LESCRIFilCN CF NRC FlNDIN3  FR0!! MATE CAUSE OFs5Ahll4110N S REFERENCE Unit        Status &
        .
Consents
!! Salo Fusitticnal Area - Picino Svstens and Suposrts V10 05/08/57 Failure to Correctly Apply Coatinas and Install SucerviservControls Construction 5 B7-19-V-03 2 Hilti folts and HVAC Class 7 Secocrts    Status a C V10 06/27/87 External Surf ace Contanination of Stainless Steel Manacement Controls loadeouate Construction 4 67-27-V-01 1 Finina      Status = R V10 07/03/87 Failure *o Follce Procedure For Adjustino Sprino tesion Interface Inadecuate Construction /SU 4 87-40-V-01 1 Har.oer s      Status = 0 Il Sale functional Area - Plant Deerations DEV 12/15/07 Failt,re to Meet Cosaiteents Recardino LCO Status Panacesent Failure  Plant Oceratien 87-77-D-02 i in Ccotrol Roca Leo      Status = 0 V10 10/26/67 Failure to Felice Froce:!ure f or Beric Acid Fersonnel Error Technical Serv. 4 87-64-V-01 1 Minino      Status = 0 V10 11/30/37 Mode Chance Without Reouired Coerable ECCS Fica Fersonnel Error F! ant Oceration 3 67-71-V-02 1 Fatts/Fressuriter Fress.-Les SI Tric Setocint    Status = 0 Errce V10 R/04/87 Doeration of Toxic Gas Mcnitors in 'Not in Analvre Ocerator Error  Plant Oceration 4 67-75-V-01 1 P. ode' Contrary to f e:hnical Specifications    Status = 0
:
l ac Salo functicnal Area - Freccerational Testico V10 04/10/67 Failure to Fcilen Frecehres For Feriornino Test Ferscnnel Error  Startvo 4 8 7-05-V-02 1        Statas = C l
l VIO 06/26/87 Failure to Fclica Fracedures for Fericrains Ferstenel Errcr Startuo 4 B7-37-V-01
'
I Freccerational Tests      Status = 0 i
18 3als Functional Area - Cuality Frcorass b Admin. Ccn.


t l DEV 05/15/B7 Fulure to Establish Index Fricr to Fietelot of Panacesent failure Admin. Services 57-26-E-04
        !
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1 Feccr ds      Status = 0 i
l IEV C5/15/B7 Inadeocate Control of Fecords in Teosorarv urkinc Paracesent Inattentics Flant toeratten 67-26-D-06 1 File      Status = 0 tiV 12/15/97 Failure to reet Ccesitatnt Fesardito tte Aadit cf Manaceaent Failure  h ality Assuran 67-77-0-01 1 WCC Activities      Statas = 0 i
I


* *      Table 2 Page 4 of 4 Pace N l 02/17/EB        !
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SOUTH TEIAS FROJECT (Units 1 & 2) - WRC INSFECTION FINDIN35 Frca January 1. 1987 throuoh Decenter 31. 1987 TYFE DATE SUBJECT or DESCRIPilCN DF NRC FlhDlWS  FROIIMATE CAUSE CRBANIZATION S FEFEFENCE 1! nit        Status k Consents DEV 12/15/87 Failure to reet Ccasitaent Resardiro Anonvaous Manacearnt Failure Security 87-77-D-03 1 truo Ties      Status = 0 CEV 12/15/87 Failure to Meet Ccealtaent Fegardino Fescense to Management Failure  Quality Assuran 87-77-D-04 I ISEB Fenort      Status = 0 V!D 04/10/87 Failure to Folle= Frocedcres for Maintaining Manacearnt Error Startuo 4 87-09-V-01 1 Cleanliness      Status = C V!D 06/26/87 Failure to follom Frocedures for Tescorary Fersonnel Errcr Startuo 4 87-39-V-02 1 Mcdificaticns      Status = 0 Il Salc Functiocal Area - Radiolooical Contrcls V10 03/08/87 Failure to Follca Frocedure ic>r Record Data Entry Fersonnel Error  Technical Serv. 4 87-03-V-01 1        Status = C 18 Salo Functional Area - Safetv-Related Con:onents V10 11/25/87 Ssent Fuel Rachs not Frecerlv Salted  Frocedares (nadeouate Ennineerino 4 97-70-V-02 1        Status = 0 18 Salo Fuicticr.al Area - Security V10 11/20/67 t'ailure to Tasaer Alare on Alara Terainel Dcs Personnel Errer Security S7-72-V-02 1        Status = 0 V10 11/20/37 Failure to Folle. Precette fer Issaance of Fersonnel Error Security 67-72-V-01 1 Esercenty Searit, te,      Status = E
 
  . .
.
TABLE 3 LICENSEE REPORTS The following pages tabulate, by SALP functional area, the construction deficiency reports (COR), licensee event reports (LER), and security event reports (SER) which were provided relative to STP activities during the SALP period to the NRC by the licensee. The unit (s) for which the item is applicable is listed under the type of item in the extreme left column with a
"1" meaning it applies to Unit 1, a "2" meaning it applies to Unit 2, and "B" meaning it applies to both units. The "0 ATE" column refers to either the date the licensee discovered the item or the date it was first reported to the NR The "REFERENCE" column on the extreme right contains the licensee's unique tracking number for the item described in the "SUBJECT or DESCRIPTION OF THE LICENSEE REPORT" column. The."PR0XIMATE CAUSE" column contains the root cause
~ for occurrence of the associated item as determined by the SALP Board. The
"0RGANIZATION" column contains the licensee organization which the SALP Board believed was most closely associated with the root cause for the ite Under the tracking number in the "REFERENCE" column, the NRC status of the item is given where "0" indicates the item is open, "C" indicates the item has been closed by the NRC, and "R" indicates an NRC inspector has stated an intention !
to close the item, but the closing NRC inspection report has not been issue i
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Table 3
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Page 2 of 6 Pace N /17/88 SO'JTH TEIAi FROJECT (Units 1 & 2) - LICENSEE REFCRIS Frca January 1. 1937 throuch Decester 31. 1987 TIFE DATE SUBJECT or DESCRIPil0N OF THE LICENSEE REPORT FR0llMATE CAUSE ORBANIZATICN REFERENCE Unit        Status &
Ccasents il Salo Fur <ctional Area - Electrical Equionent & Catles CLR 01/06/87 Failure of Liouidticht Flexible Corduit  resion inadeouate Enoineerino IRC 0354 5        Status = C C3 01/12/87 Failure of Telenechanione J13 4-Pole Felais Unknown  Enoineerino IRC 0355 B        Status * C CM 01/16/87 Failure to Correct Installation Deficiencies for Corrective 6ctiren ineffective Construction IRC-0356 B Eus Bar Estensions & insulation Barriers    Status = C CLR 02/11/57 Failure of DC Contacts Used in inductive Circuits Desion inadeouate  Enoineering IRC-0363 B        Status = C CIR 02/19/87 Incerrect Installation cf Electrical Solices Usino Frocedures inadeouate Construction IRC-0364 5 Ravchen Heat Shrink Material      Status = C CM 02/27/67 Environmental EHetts en N,lon and Teflon Ties for Desion inadecuate  Enoineerino IRC-0366 B Class lE Cables Will Reduce Strenoth Below tesion    Status = C CM 04/28/07 EAB HVAC Fan Mctors Failed Due to Coerating at interface inadeoaate Enoineerino 14-0383 8 Greater Than Naseolate lead      Status = C CDR 06/18/B7 undertoroved Ecltino cf Telesesanioce Class IE C s Frecedures Inadecuate Enoineerino IFC-0372 B Nellifies Seissic Gaalification      Status = C CCR 07/14/s? Inadeccate Statino of Acastat SF Series Relavs Design Error  Encineerino IRC-0397 B        Status = 0 CM 07/17/B7 Cesica teiect in Es3 Lead Secuencer  Desi3n Error  Enoineerina IFC-0378 5        Status = 0 CCR 07/27/87 EM Hioh Witace Fanels 0,erheatino (Part 21) Desion Error  En m eerino IRC-0400
,
,
B        Status = 0 t
.
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CCR 09/18/97 Material Incorrectiv installed in Class lE Caole Procedures Ncaccioliante Ccostruction IFC-0433 2 Soltces      Status = 0 i
< ,
18 Salo Functional Area - Instrueentation l
LICENSING ACTIVITIES      l CATEGORY 2 fMNAGEEffT IfNOLVEEf6 AND CONTROL Ifi LICENSING ACTIVITIES APPROPRIATELY EWHASIZES QUALITY BLIT, ON OCCAS!0N, DOES NOT ALLOW SUFFICIENT TIME TO ^'HIEVE I j i
l CR 03/09/i7 RCS RTD Time Fesnnie Fails to Peet FSAR L 15 :esi n inade w ate Er oir,eer i no IE;-0370 B Fetirements (Par t 21)      5tatu, a C CG 07/05/87 lacrcser Fettenir,o of Val es on ESF Feist Iestor. Error  Enoiretrino IFC-0395 B        Status = 0
THE TECHillCAL EXPERTISE DIRECTED TOWARD RESOLVING     -
 
REGULATORY ISSUES IS SATISFACTOR THE LICENSEE IS RESPONSIVE TO NRC INITIATIVE ,
. . . . ,      Table 3 Page 3 of 6 Paoe N /17/83 SOUTH TEIAS FROJECT (Units 1 L 2) - LICEhSEE FEFORIS Fros January 1. 1987 throuoh Deceaber 31, 1957 T)FE CATE SUBJECT or TESCRIFil0N OF THE LICEkSEE REFCRT PR0!! MATE CAUSE CASANIZATION REFEREhCE Unit        Status t Cenents 18 Salo Functional Area - Maintenance LER 08/28187 Actuator Motor Shaft-to-Pinion tevs Sheared Due to Unkneen  Enoineerina LER 87-03 1 Incorrect and Defective Material IPart 21)    Status = 0 LED 09/05/37 Fersennel Errcr Causes Loss of Flow to CR HVAC FM Trainino inadecuate Technical Serv, LER 87-06 1 Resultino in Actuation of Pecirculatico Mode    Status = 0 LER 09/06/8) Toxic Bas Monitor Defective Ficw S* itch Causes Ecuionent Failure Maintenance LER 87-07 1 Control Roon HVAC Actu tion to Recirculaticn Mcde    Status = 0 LER 09/26/87 Accarent Failt.re of RM Causes FEB Ventilatien Ecuipment Failure Maintenance LER 87-10 1 Svsten hto-Actuaticn to Filtratien Mcde    Status = 0 LER 10/17/87 Control Roca Fecirc. Actuation Due to Toxic Monitor Ecuicient failure Maintenance LER 87-11 1 Malfuntien      Status = 0 LER !!/05/97 AFW A Train Cross-Cennect Line Fucture Mcde 3) Cesion Error Enoineerino LER 87-16 1        Status = 0 LER 11/13/97 Toxic Monitcr Tricoed on Hich Cencentration Administrative Controls Maintenance LER 87-14 i N244/NH3     Status = 0 LER 11/28/87 CR HVAC Transfer to Recirculation MMe he to Tosic Eouicient Failure Maintnance LER 67-20 1 Bas Mcnitt,r Failure      Status = 0 LER 11/30/37 Actuation of ESF IG Curiro Trctbleshectino of E5F Unknomo  Maintenance LER 87-21 1 Secuencer      Sca'.us = 0 LER 12/03/67 Keys Foand out of Keveavs en Mctor Coerated Valves Frocedure Inadecuate Maintenance LER 87-23 i        Status = 0 LER 12/08/87 Inadvertent Control Rcca/Auriliary EJildino Persennel Errcr Technical Ser LER 87-24 1 Ventilation Actuatien    Status = 0 LER 12/07/87 'A' Train hs Strio. EDS Start and Loadino Cai. sed unnnen  Maintenance LER B7 45 1 hr Instantareous UV Sional    Status = 0 Il Salo Furctienal Area - Fionna S.stess and kroorts CDR 04/07/E7 CVCS Water kanner Event Cast;es hocorts  teston Inacecuate Enaineerina IFC-0377 5        Status = C f
RECCANENDED LICENSEE Actron THE TIMELINESS AND QUALITY OF THE REPORTS TO NRC SHOULD BE IMPROVED AS THE LICENSEE'S TECHNICAL STAFF MAKES TK TRANSITION TO FULLY OPERATIOfML STATU !
 
l
- 4*      Table 3 Page 4 of 6 Face N /17/88 S0VIH TEIAS FROJECT (Units ! L 2) - LICEhSEE REPORTS Free January 1.1997 throuch December 31, 1987 TYPE DATE SUBJECT or CESCRIPil0W CF THE LICENSEE FEPCRT FROI!MTE CAUSE ORBAN!!A11DN REFERENCE Unit        Status &
          !
Ceasents 11 Salo Functional Area - Flant Ccerations LER C8/26/87 Loss of Sasole Flon to Centaicsent Purce RM Causes Personnel Inattention Flant Oceration LER 87-02 1 Centainment Ventilation isolation    Status = 0 LER 07/03/97 Personnel Errer Pesults in loss of Saaste Flev to Perscnnel Error  Plant Cteration LER 87-04 1 CR Vent. FJi and Causes Acteation of Recirc. Mode    Status = 0 LER 09/04/07 Fersennel Error and Incorrect Ocerater Resconse Trainino Inadeouate Flant Doeration LER 87-05 1 Causes Auto-Actuaticn to Fecirc. Moce f or CR H'iAC    Status = 0 LER 11/02/87 51 Cold Leo inj. Valves Found Closed When Recuired Ccerator Inattention Flant Operation LER 87-12 1 Goen      Status = 0 LER 11/02/27 Toxic Gas Monitcr Lcss of Power Initiates CR HW Fersonnel Error  Enoineerino LER 87-13 1 Fecirculation      Status = 0
          <
"
          $
LER !!/21/87 Essential Chillers Heater Circuits Of f - 15 3. Personnel inattention Plant Coeratien LER 87-15 1 Entered      Status = 0 LER 11/24/5' ECW Train Resoval Free Service Fesults in 2 Trains Eouicaeni lailur e Plant Deeratica LER 87-1B 1 of Containment Scrai Inocerable    Status = 0 LER 12/06/B7 Tcnic Gas Penitcrs found ht in the Analyze Mode Trair. ins inadecuate Flant Doeration LER 67-22 1        Status = 0 i
it Salo Functional Area - Free:eratic,al Testino CER 03/12/87 CCW Water Hasser Event Kesults in Danaced Susperts Ccerater Errcr  Startto IRC-0372 1 ar.d Ficin      Status = C 18 Sals Functienal Area - Safetv-Related [caeccents Ctn 01/27/B7 Diesel Startir:0 Air Header Filter 20 1s Lcese (L' nit Desicn inadeouate Enaineerino IRC-035B
'
1 1 onlv)      Status C CDR 03/27/B7 Stean Generatc< Pcher Coerated Felief Valves Failed Fersonre! Error  Eno./Maint./ Con IRC-0374 B Actuators & Scdv-To-Bonnet Leais    Status = C CIA 04/06/E7 FI Vessel Tee crary Full-Flon Filters Failed Deston Defect Encineerino II<C-0378 B        Status a C C04 07/03/37 ecd Fcso Eearino Failure Caused tv Loss of Irstrumentaticn ina:eccate Er;cineering IFC-0374 B Lutricatico Water      Status = 0
 
- '* *      Table 3 Page 5 of 6 Paae N /17/03 50VIH TEIAS FROJECT (Units 1 & 2) - LICEhSEE REPORTS Fron January 1.1937 thrcuch teceeber 31. 1787 TffE DATE SUBJECT or DESCRIPi!CN OF THE LICENSEE REFORT FR0llMTE CAUSE OR6ANIZATICN REFERENCE Unit        Status &
Consents CDR 07/28/87 Cracked ED8 Fuel Iniector hozzles  Unkncan  Encineerino IRC-0319 B        Status = 0 CLR 10/06/87 CCW Heat Exchancer Tube Failure (Part 21) Desicn Defect Enoineerino IRC-0403 B        Status = 0 CDR 11/06/87 Interrect RHR Valve Installation  Vendor Errer Startue IRC-0410 1        Status = 0 Il Salo Functional Area - Securitv SER (8/23;27 Security Of ficer Inattentive at Fcst    SER 87-01 1        Status = 0 SER C8/30/87 Vital Area Eadce and Kev Card Taken Froa Protected    SER 87-02 1 Area      Status = 0 SER 09/01/87 Securttv teacuter Coc oneet - Voluntarv ictal    SER 87-03 1 Evstes Failure      Status = 0 SER b7/05/87 Eaoloite Given krono lad;edev Card - Unauthorized    $ER 27-04 1 Access      Status = 0 SER 09/05/87 Security Svsten Eneroency Evacuatica rode    SER 87-05 1 Mistakenlv Activated    Status = 0 SER 07/12/87 Securitv Dcor Feund Clcsed and unlocked With Alara    SER 87-07 1        Status = 0 SER 09/15/37 Breach of Secerity he to Renval of Fenetration    SER 87-03 1 Seal      Status = 0 SER 09/19/87 Security Dotr Fcund la:receriv Secured    SER 87-09 1        Status = 0 SER 07/25/87 Badoe/ Kev Card Ressved Free Frctected Area ihru    SER 87-10 1 Marth Bate      Status = 0 SER 09/30/87 Security Svsten Failure Without Frocer Ccasensatico    SER 87-12 1        Status = 0 SER 10/04/i7 Watta Ferson Renowed His f adce/revcard Free    EER 67-13 1 Frctected Area      Statui = 0 l
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          ;
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  . . _ _ . -_ -.. . . . - _ _ - - .. . _ _ - _ _ - _ . - _ . _ .  . - - _ _ . _
  ' ** o      Table 6 Page 6 of 6 Pase N /17/83 SOUTH TEIAS FROJECT (Units 1 & 2) - LICENSEE REFoHTS Free Januarv 1.1987 throuch December 31. 1987 TVFE DATE SUBJECT or DESCPIPilDN OF THE LICEk3EE SEFORT FROIIMATE CAUSE 055ANIZAT10N REFERENCE Unit        Status &
Ctatents SER 11/23/37 Terminated Ferson Alle=ed Access to Frcte:ted Area    SER 87-14 1        Status e 0 SER 12/02/37 Fersonnel Entered A Vital Area Withcot    SER 87-15 1 Authorization      Status = 0 il Salo Functicmal Area - Surveillance LER 09/18/87 Frocedural Inadeouacy Causes Surveillance Procedure Inadeouate Etioineerino LER 87-09 1 Deficiency Fesultine in 15 Violation    Status = 0 LER 11/24/87 All Chant.els of Fressurizer Pressure-Lew 51 Frocedure Error Enoireerino LER 87-17 1 Setcoints Found Eelen TS Limits    Status = 0 LER 11/24/87 Slave Relav Test for C5 Actuation Frea 5555 Frecedure inadecuatv Entireetine LER 87-19 1 leadeouate      Status = 0 LER 12/12/87 Failure to Reet the Fecured Testino for    LER 87-26 1 Undervoltace eith Saf etv Iniection    Status = 0 i
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Latest revision as of 03:13, 24 October 2020

App to SALP Board Repts 50-498/87-65 & 50-499/87-65 for 1987
ML20153D663
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/26/1988
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153D654 List:
References
50-498-87-65, 50-499-87-65, NUDOCS 8809020279
Download: ML20153D663 (29)
v • d • e


Text

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O APPENDIX TO SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

SYSTEMATIC ASSESStiENT OF LICENSEE PERFORMANCE NRC Inspection Report 50-498/87-65; 50-499/87-65 Houston Lighting & Power Company (HL&P)

SouthTexasProject, Units 1and2(STP)

.lanuary 1 through December 31, 1987 NV go90% W O

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MEETING SUMMARY Date: April.13, 1988 Licensee: Houston Lighting & Power Company (HL&P)

Facility: SouthTexasProject, Units 1and2(STP)

License: NPF-76/CPPR-129 Docket: 50-498; 50-499 SUBJECT: SALP MEETING AT STP On April 13, 1988, the Deputy Regional Administrator, Region IV, members of the Region IV staff, and an NRR representative met with representatives of

.HL&P in an open meeting at STP to discuss the SALP Board Report covering the period January 1 through December 31, 1987. A copy of the NRC material presented at the meeting is attached. The meeting was held at the request of NRC, Region I After opening remarks by the Deputy Regional Administrator, the Directo Division of Reactor Projects, Region IV, presented each of the functional areas evaluated in the SALP Board Report using Attachment 2 as an outline. An opportunity for comments regarding each of the SALP categories was made available. The HL&P representatives provided general remarks regarding the SALP Board Repor Attachment:

NRC Material Presented at Meeting

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UNITED STATES NUCLEAR REGULATORY CCtNISSION SYSTEMATIC ASSESSENT OF LICENSEE PERFORMANCE EETING HOUSTON LIGHTING & POWER CWPANY SOUTH TEXAS PROJECT, UNITS 18 2 JANUARY 1,1987 - DECEMEER 31,1987 SOUTH TEXAS PROJECT VISITORS CEN1ER APR!i.13,1988 10 _

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I SALP PROGRAM ORJECTIVES i

IMPROVE LICENSEE PERFORMANCE PROVIDE A BASIS FOR ALLOCATION OF l

NRC RESOURCES l

l IMPRWE NRC REGULATORY PROGR#i (

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PERFORMANCE ANALYSIS AREAS FOR SOUTd TEXAS PROJECT, UNITS 18 2 PLniT OPERATIONS B.- PREOPERATIONAL TESTING STARTUP TESTING PAINTENANCE SURVEILLANCE FIRE PROTECTION QUALITY PROGRAMS N O ADMINISTRATIVE CONTROLS AFFECTING OUALITY 1. CONSTRUCTION 2. OPERATIONS TRAINING AND 00AL1FICATIONS EFFECTIVENESS EMERGENCY PREPAREDNESS SECURITY RADIOLOGICAL C0fRROLS C0fRAlteENTS, SAFETY-RELATED STRUCTURES, AND PAJOR STEEL SUPPORTS PIPING SYSTEt43 AND SUPPORTS SAFETY-1 LATED C0FFONENTS -

MEOWi! CAL AUXILIARY SYSTEMS 1 ELECTRICAL EQUIPtENT  :

AfD CABLES INSTRtFENTATION i LICENSING ACTIVITIES i

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_ . . ._

- _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

O e r FUNCTIONAL AREA PERFORMANCE CATEGORY CATEGORY 1 REDU D NRC ATTENTION f%Y BE APPROPRIAT LIGNSEE fW4AGiffiT ATTENTION NfD IfNOLVEfffU ARE AGGRESSIVE AfD ORIEfGED TOWARD NUCLEAR SAFETY; LIGNSEE RES00RGS ARE AMPLE AffD EFFECTI\ELY USED S0 THAT A HIGH LEVEL OF PERFORfWJG WITH RESPECT TO OPERATIONAL SAFETV IS BEING /,CHIEVE . . __ ___ . _ ___

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I CATE@RY 2 NRC ATTENTION SHOULD BE t%ItiTAINED AT NORt%L LEVEL LIGNSEE MANAGEtENT ATTEtCION AND ltN0LVEtENT ARE EVIDENT AND ARE CONGRNED WITH iAJCLEAR SAFETY; LIGNSEE RESOUR&S ARE ADEQUATE AND ARE REAS0tMBLY EFFECTIVE SO THAT SATISFACTORY PERFORt%NG WITH RESPECT TO OPERATIOfML SAFETY IS BEING ACHIEVE :

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. _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . ____ __________-_ _ ___ __ _ _______ _ _ _ CATEGORY 3 BOTH NRC AND LICENSEE ATTEt(TION SHOULD BE INCREASED. LIGNSEE t%fMGEMENT ATTENTION OR ltNOLVEENT IS ACCEPTABLE AND C0t4SIDERS FAJCLEAR SAFETY, BUT WEAKtESSES ARE EVIDENTI LIGNSEE RESOURGS APPEAR TO BE STRAINED OR NOT EFFECTIVELY USED S0 THAT Mitilt%LLY SATISFACTORY PERF0 WANG WITH RESPECT TO CPERAT10tML SAFETY IS BEING ACHIEVED,

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EVALUATION CRITERIA i

1. thfMGEKffT IfN0LVEKf6 AfiD C0f4 TROL IN ASSURING OUALITY 2. APPROACH TO RESOLUTION OF TEOf41 CAL ISSUES FROM A '

SAFETY STANDPOINT 3. RESPONSIVENESS TO NRC INITIATIVES 4. EtEORCEEffT HISTORY S. OPERATIONAL EVENTS (If4CLUDING RESPONSE T0, AfMLYSIS OF, AffD CORRECTIVE ACTIONS FOR)

6. STAFFING (INCLUDING VN4AGEKffT)

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r STRENGTHS j

COOD PROGRAMS Al'S INPi. ACE FOR OPERATION OF UNIT TE QUAL.lTY ASSURANCE PROGRAM FOR CONSTRUCTION OF UNIT 2 IS l BEING PERFORE D IN AN EFFECTIVE MANNE MANAGEE NT INVOLVEE NT IS EVIDENT IN All. ACTIVITIES RELATED TO CONSTRUCTION AND OPERATION i

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EAKNESSES SECURITX SECURlW DEFICIENCIES RESULTED IN A SIGNIFICAf(T DELAY IN THE ISSUANG OF THE OPEP! JING LIENS OPERATIONS STRONG PROGRAMS FOR OPERATIONS DID NOT RESULT IN A HIGH LEVEL OF PERFORfMNE SUBSEQUF.ffT TO ISSUANE OF TK LOW POWER LIE NS .

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o PLANT OPERATIONS CATEGORY 2 CORRECTIVE ACTIONS HAVE NOT ALWAYS BEEN EFFICIENT OR INITIALLY EFFECTIV '

PERFORf%NE DECLINED AFTER ISSUANG OF OPERATING LIENS TKRE IS GOOD EVIDENE THAT HL&P IS LEARNING FROM THE REENT ERRORS N4D THAT PERFORMAN E IS IMPROVIN RECCft1 ENDED LICENSEE ACTION THE LIENSEE SHOULD MOVE FORWARD IN A DELIBERATE, C0fRROLLED FWiNE .

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PPEOPERATIONAL TESTING CATEGORY 2

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THE TEST PROGRNi HAS BEEli GEfERALLY EFFECTIVE AND HAS HAD FEW PROBLEMS, PEC0fHEffDED LICENSEE ACTION EwHASIZE THE NEED TO COMPLY WITH ALL C0FNITMEfRS.

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STARTUP TESTING

[AIFGORY2 PERFORMAf4CE DURING INITIAi CORE LOADING WAS INDICATIVE OF AN ADEQUATE PROGRM1 AND STI.ONG f%NAGEfENT IfNOLVEPENT. A DELAY IN T11E STARTUP OF UNIT 1 HAS RESULTED IN A LIMITED NUMBER OF STARTUP ACTIVITIES BEING INSPECTED DURING THE SALP APPRAISAL PERIO REC 0ftENDED LICENSEE ACTION ENSURE GOOD COORDINATION OF STARTUP ACTIVITIES NO POWER ASCENSION TESTING WIT 11 NORf%L PLNiT OPERAT10f4 ,

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MAINTUlANCE CATEGORY 2 THE ELEFENTS OF A STRONG f%lf!TEftANCE PROGRAM APPEAR TO BE IN PLAC SOK PROBLEMS HAVE BEEll OBSERVED IN THE IMPLEWiiTATION OF TlilS PROGRA MANAGEf1EilT AND CORRECTIVE ACTIOil SYSTEMS APPEAR TO BE WORKlflG TO RESOLVE THE IDENTIFIED PROBLEM REC 0 MENDED LICENSEE ACTION THE LICEf4SEE SHOULD CONTINUE STAFFING EFFORT TO SUPPORT '

UNIT 2 ACTIVITIES AND C0ffT!fiUE UPGRADING PAINTENAN&

PROCEDURES BASED ON EXPERIENC ,

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.S118yEILLANT l CATEGORY 2 CONCERN ABOUT THE ADEQUACY OF THE IDENTIFICATION OF TS REQUIRENNTS AND IWLEENTATION OF THESE REQUIREENTS INTO SURVEILLANG PROGDURE PROGRNi TO PRECLUDE MISSED TESTS IS ACEPTABL REC 0FfE GED LICENSEE ACIjpg

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NRC ENCOURAGES THE Ll&NSEE TO KEEP LEARCHING FOR WEAKNESSES IN THE SURVEILLANCE PROGRA . - . .

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FIE PROTECTION CATEGORY 2 CONCERNS AND OUESTIONS WERE PROMPTLY REVIEWED NO ADEQUATE CORRECTIVE ACTION WAS TAKEN OR IfliTIATED Off A T!fELY BASIS BY TIE LICENSE PROGRNi IS SUCH THAT TIE CONSEQUEf4CES OF A FIRE SHOULD f0T AFFECT THE SAFE OPERAT10ft OR SHtJTDOWN OF THE PLAN PEC0ffEf0ED LICENSEE ACTIONS PN4AGEFENT SHOULD C0ffTINUE THE LEVEL OF ATTENTION IN THE FIRE PROTECTION / PREVENTION PROGRNi N4D ENSURE THAT TIE PROGRNi IS ADEQUATELY IMPLEFEffTED NO PAINTAlfE ,

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00ALITY PROGRAMS AND ADMIhSI'RATIVE CONTROLS AFFiCTI NG 0. AL: TY CA"EGORY 1 (CONSTRUCTION)

CA 'EG01Y 2 (OPERATIONS)

THE QUALITY ASSURANCE PROGRAM FOR C0t1STRUCT10N IS BEING PERF0 PIED IN AN EFFECTIVE TWINE KVlY ASPECTS OF THE OPERAT!0f4S CA ACTIVITIES ARE ':ORKING WELL. HOWEVER, THE ENFORCEFEtiT ACTIONS SHOW WEAKNESSES IN THE IMPLEFENTATION OF THE PROGRA THE PERFORMANCE OF OPERATIONS 0A/0C HAS BEEN ACCEPTABLE BUT IS ?OT VIEWED AS AGGRESSIV REC 0ftfENDED LICENSEE ACTION SHOULD CONTINUE CURRENT LEVEL OF EWHASIS Off CCNSTRUCTION GA PROGRA%

THE OPERATIONS CA PROGRAM SHOULD DEVOTE APPRCPRIATE RESOURCES TO ENSURE COMPLIANCE WITH CCtNITMENTS AND PROVIDE ADEQUATE FWiAGEFEf6 OVERVIEW OF THIS FUNCTIONAL AREA. THIS EFFORT SFOULD BE FOCUSED ON GETTING IN FRONT OF QUAL.lTY ISSUE _ _ _ _ _ _ - -

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TRAINING AND QUALIFICATION EFFECTIVENESS CATEGORY 2

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MANAGEFENT IS GENERALLY RESPONSIVE TO THE NEEDS FOR RETRAINING OR REFRESHER TPAINING WHILE FEETING LICENSING t REQUIREFEtG TRAINING WITHIN THE SECURITY DEPARTMENT HAD BEEN UfRCCEPTABLE BUT THAT TREND HAS BEEN REVERSE REC 0ffENDED LICENSEE ACTIONS C0ffT!NUE TO PURSUE INP0 ACCREDITATIO MANAGEMEffT SHOULD CONTINUE TO UPGRADE THE PLAfC SPECIFIC SIMULATOR TO ENSURE IT ACCURATELY REFLECTS THE CURRENT PLNiT DESIG l _ _ - - - _ _ _ ._ _ __ __

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EMERGENCY PREPAREDNESS CATEGORY 2 THE L! NSEE DEf0NSTRATED THE ABILITY TO IPPLEffffT THEIR EFERGENCY PLAN AND PROCEDURES DURING THE #4NUAL EXERCIS THE LI NSEE SUCCESSFULLY CORRECTED DEFICIENCIES IDENTIFIED DURING THE DECEMBER 1986 EFERGENCY PREPAREDfESS l APPRAISAL INSPECTIO DEFICIENCIES IDENTIFIED DUR!f1G TIE APRIL 1987 EFERGENCY EXERCISE IflDICATED Ti%T TRAINING FETHODS AND PROCEDURES REQll! RED ADDIT 10NAL IPPROVEFENTS, hHICH ARE BEING PURSUED BY THE LICENSE RECOWENDED LICENSEE AcTrofis t

LIGNSEE fW1AGEFENT SHOULD CONTINUE TO ENSURE THAT FACILITIES, EQUIPFENT, AND PROCEDURES ARE TESTED BY WALKTHROUGHS, DRILI.S. EXERCISEE, AND ROUT!fE INTERNAL QUALITY ASSURANG TYPE INSPECTIONS TO VERIFY THAT THE!R EFERGEfC/ PREPAREDNESS POSTURE REF% INS ADEQUATE FOR Ni CPERATiliG PLANT.

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SECURITY & SAFEGUARDS CATEGORY 3 SIGNIFICAIR WEAKNESSES IN SECURITY MAf;AGEMENT, SECURITY ORGANIZATION. TRAINING NO QUALIFICATIONS OF SECURITY PERSONNEL. THE LACK OF EFFECTIVr. NESS OF THE SECURITY PROGRAM DELAYED ISSUANCE OF THE LOW POWER Oh! RATING LICENS CORPORATE FW4AGEMNT TOCK AN ACTIVE ROLE IN RESTRUCTURl'4G THE SECURITY ORGNilZATION NID TRANSFERRING EXPERIENCED #to EFFECTIVE MANAGERS If4TO POSITIONS OF Alm 0RIT SIGNIFICANT DESIG1 AND CONSTRUCTION ERRORS IN THE SECURITY SYSTEMS WERE IDEIRIFIED N O CORRECTED BY PROVIDING THE RESOURCES NECESSARY TO COBPLETE THE TASK OF REBUILDING THE PERlfETER, INTRUSION DETECT 10f4 SYSTEM, NO A3SESSMENT AID THE SECURITY ORGANIZATION APPEARS TO HAVE AN AFPLE NUMBER OF PROFESSIONAL PERSONNEL AND CONTRACT UNIFORE D OFFICERS, L'O MEET TRAINING REQUIREMENTS, TO IFPLEENT THE SECURITY PLANS AND SATISFY THE REGULATION AN EXTENSIVE SECURITY PROGRN4 UPGRADE l$ UNDERWAY IN

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ACCORDANCE WITH LICENSE C0f141TMENTS AND SUPFLEMENTARY SIP LETTER THE SECURITY PROGRNi HAS SHOWN A POSITIVE UPWARDS TREND IN  !

THE LAST QUARTER OF THIS EVALUATION PERIO RECOMMENDED LICENSEE ACTIONS FOR UNIT 2 THE LICENSEE SHOULD PLAN FOR THE EARLIEST

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POSSIBLE LOCKDOWN OF ALL AREAS TO ENSURE PROPER

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IffLEKfRATION OF THE SECURITY PLA TtE LICENSEE SHOULD CONTINUE TO C0ff41T THE NECESSARY RESOURCES TO COMPLETE THOSE ACTIONS IDENTIFIED IN THE FUEL LOAD LICENSE AND THE LATEST REVISION CF THE PHYSICAL SECURITY PLN ;

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P&l0LOGICALCONTROLS

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CATEGORY 2 LIGt1SEE'S RADIATION SAFETY PROGRNi /PPEARED TO LACK THOROUGHNESS AND DEPTH If1 RESOLVING ITEMS IDEf(TIFIED DURING THE PREOPERATIOflAL PROGrwt. LICENSEE WAS NOT TIFELY IN CLOSING OUT ITEMS IN THIS ARE CON &RNS RAISED BY THE NRC IN THE AREA 9 0F WASTE FWMGEFENT AND EFFLUEf(T MONITORING HAVE BEEN ADDRESSED BY TIE L!%NSEE. F#tAGEFEf6 IfNOLVEFENT WAS EVIDEffT IN THE AREA 0F WATER CHEMISTRY, RADl0 CHEMISTRY, AND CONFIRPATORY MEASUREFENT AT THE TifE OF THE SALP REPORT, PREOPERATIONAL TESTING FOR ALL RADWASTE SYSTEMS HAD NOT FET SCFEDULED COFPLETION DATE REC 0ftENDED LICENSEE ACTION

,

ESTABLISH BETTER C0ftUff! CATION BETHEEf1 THE RADIATION PROTECTION DEPARTFEfR AND PLANT PANAGEFEffT TO ENSURE THAT RADIATION PROTECTION PROBLEMS REGIVE THE NEGSSARY ATTENTIO l

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P CONTAlftBfT, SA ET'-R1ATD S"RUCTURES AND MAJORS ti_ SU%fES CATEGORY 1 THE LICENSEE, ENGINEERING, NfD CONSTRUCTION fW4AGEbEf6 IfNOLVEMENT IS AGGRESSIVE AND EVIDEN REC 0ftENDED llCENSEE ACTION MANAGEBEf6 ATTENTION SHOULD BE f%INTAINED AT THE SME LEVEL IN UNIT 2 TO ASSURE THAT THE DESIRED CUALITY IS ACHIEVE _ - _ _ _ _ _ _ _ _ _

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PIPING SYSTEMS AND SUPPORTS CATEGORY 2 RESPONSES TO IDENTIFIED DEFICIENCIES WERE T!KLY WITH ACCEPTABLE RESOLUTION Ll&NSEE FANAGEMNT IS EVIDENT AND EFFECTIV RECOME NDED LICENSEE ACTION CONTINUED EMPHASIS MUST BE PAINTAINED TO ACHIEVE TK DESIRED LEVEL OF QUALIT . _ _ _ _ _ _ _

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SAFETY-RELATED COMP 0NEfffS - ECHANICAL CATEGORY 2 ATTEhTION TO DETAIL AND IfNOLVEFENT IN THE PROGRAM IS EVIDEN CORRECTIVE ACTION FOR IDENTIFIED CONCERNS AND PROBLEMS HAS BEEN EFFECTIV REC 0ffMED LICENSEE ACTION ATTENTION SHOULD CONTl?AJE AT ITS PRESENT LEVEL AND POSSIBLY INCREASE AS EQUIPMENT IS FINISHED AND PREPARED TO BE TURNED OVER TO STARTUP FOR TESTIN .

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AUXILIARY SYS1 EMS CATEGORY 1 PERS0fiNEL ARE WELL TRAINED MiD KN0btEDGEABL LICENSEE t%NAGEMENT ATTENTION INCREASED DURING THE LATTER PART OF THE APPRAISAL PERIOD BY IMPLEfftRING A PROGR/M TO ENHANCE THE INSPECTION EFFORT OF THE HVAC ACTIVITIES IN ,

hHICH VIOLATIONS WERE IDEfff! PIE i REC 0Ffff0ED LICENSEE ACTION THE LICENSEE SHOULD CONTItME EFFORTS If4 ORDER TO ASSURE THAT THE DESIRED LEVEL OF CUALITY IS ACHIEVED N O MAINTAINED IN UNIT ,

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ELECTRICAL EQUIRiWT AND CABLES CATEGORY 2 PANAGEMENT ATTEffTION AND llNOLVEMENT ARE EVIDEll WORK ACTIVITIES ASSOCIATED WITH SAFETY-RELATED ELECTRICAL EQUIPffNT AND CABLE ARE BEING CONDUCTED IN Ni ACCEPTABLE PANNE RECOf4 ENDED LICENSEE ACTION LICENSEE PANAGElEilT IfNOLVEFENT IN THIS AREA SHOULD C0fRINUE AT A LEVEL C0ftENSURATE WITH CONSTRUCTION ACTIVITIES.

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INSTRlENTATION CATEGORY 1 TfE FEW DEFICIENCIES THAT DID OCCUR WERE PROPERLY IDENTIFIE *

CORRECTIVE ACTIONS WERE IMPLEFEfRED TO THE EX5.l4T THAT REPETITIVE EVEffTS RARELY OCCURRE RECCffENDED LICENScE ACTION  :

ALTHOUGH LICENSEE FWWifENT ATTENTION IS EVIDENT, CONTif0ED EMPHASIS MUST BE h%INTAINED TO ASSURE A HIGH LEVEL OF PERFORtWiCE WITH RESPECT TO ACHIEVING CONSTRUCTION QUALIW IN UNIT [

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LICENSING ACTIVITIES l CATEGORY 2 fMNAGEEffT IfNOLVEEf6 AND CONTROL Ifi LICENSING ACTIVITIES APPROPRIATELY EWHASIZES QUALITY BLIT, ON OCCAS!0N, DOES NOT ALLOW SUFFICIENT TIME TO ^'HIEVE I j i

THE TECHillCAL EXPERTISE DIRECTED TOWARD RESOLVING -

REGULATORY ISSUES IS SATISFACTOR THE LICENSEE IS RESPONSIVE TO NRC INITIATIVE ,

RECCANENDED LICENSEE Actron THE TIMELINESS AND QUALITY OF THE REPORTS TO NRC SHOULD BE IMPROVED AS THE LICENSEE'S TECHNICAL STAFF MAKES TK TRANSITION TO FULLY OPERATIOfML STATU !

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