ML20148A306

SALP Repts 50-498/87-65 & 50-499/87-65 for 1987

ML20148A306
Person / Time
Site:	South Texas
Issue date:	03/11/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148A304	List: ML20148A299 ML20148A306
References
50-498-87-65, 50-499-87-65, NUDOCS 8803180005
Download: ML20148A306 (54)

See also: IR 05000498/1987065

Text

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SALP BOARD REPORT

U.S. NUCLEAR REGULATORY COMMISSION

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)

South Texas Project, Units 1 and 2 (STP)

January 1 through December 31, 1987

8803180005 880311

PDR ADOCK 05000498

Q DCD

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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 operation.

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 report.

This report is the SALP Board's assessment of the licensee's safety

performance at STP for the period January 1 through December 31, 1987.

The SALP Board members for STP were:

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:

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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II. CRITERIA

Licensee performance was assessed in selected functional areas. Each

functional area normally represents areas significant to nuclear safety

and the environment.

One or more of the following evaluation criteria were used to assess each

functional area:

A. Management involvement in assuring quality

B. Approach to resolution of technical issues from a safety standpoint

C. Responsiveness to NRC initiatives

D. Enforcement history

E. Operational and construction events (including response to, analysis

of, and corrective actions for)

F. Staffing (including management)

However, the SALP Board is not limited to these criteria and others may

have been used where appropriate.

Based upon the SALP Board assessment, each functional area evaluated is

classified into one of three performance categories. 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 achieved.

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 achieved.

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

achieved.

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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 area.

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)

A. Plant Operations Not Assessed 2

B. Preoperational 2 2

Testing

C. Startup Testing Not Assessed 2

0. Maintenance Not Assessed 2

E. Surveillance Not Assessed 2

F. Fire Protection Not Assessed 2

G. Quality Programs and 2 (Not Subdivided)

Administrative

Controls Affecting

Quality

1. Construction 1

2. Operations 2

H. Training and 1 2

Qualifications

Effectiveness

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Previous Present

Performance Category Performance Category

Functional Area (07/01/85 to 12/31/86) (01/01/87 to 12/31/87)

I. Emergency 3 2

Preparedness

J. Security 2 3

K. Radiological 2 2

Controls

L. Containments, 1 1

Safety-Related

Structures, and

Major Steel

Supports

M. Piping Systems and 2 2

Supports

N. Safety-Related 2 2

Components -

Mechanical

0. Auxiliary Systems 1 1

P. Electrical Equip- 2 2

ment and Cables

Q. Instrumentation 2 1

R. Licensing 2 2

l Activities

j IV. PERFORMANCE ANALYSIS

A. 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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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 criticality. 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, 1987. ,

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 unit.

During this SALP period the licensed operators worked extensive ,

overtime to support preparation for OL and post-0L activities.

While the licensee meets the requirements for experienced staff 1

levels, there is evidence that more experienced staff, especially

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 months.  ;

Decisionmaking has usually been at a level that ensures adequate

management review. Procedures and policies have been

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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

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cause evaluations. 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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issues. This, in part, may be attributed to learning through

l experience as tasks are faced for the first time.

Notwithstanding these operational difficulties, the licensee  :

exhibits a conservative approach to plant operations activities. 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 control. .

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Of the nine LERs attributed to this functional area, the SALP

Board identified eight as being caused by inappropriate '

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 area. 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 performance. [

i Apparently strong programs exhibited significant weaknesses in

implementation. Operators who had performed very well during

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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

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routinely taken a conservative, conscientious approach to safety [

issues. Performance appeared to begin improving slightly after  ;

i} the appraisal period.

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The SALP Board debated at length whether the licensee should be

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considered Perfomance Category 2 or 3 in this functional area. 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 2.

3. Board Recommendations

a. 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,

b. 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 porsonnel.

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 manner.

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

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requirements of components, systems, and structures.

1. Analysis

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The preoperational testing program for Unit I was essentially

i completed during this SALP period with a major testing effort on

!' 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

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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 systems. Thus, the windows

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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 identified.

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 area.  ;

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 tests.

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 problems. .

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2. 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 area.

3. Board Reconwendation

a. 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 1988.

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b. Recommended Licensee Action

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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)

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 program.

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 rating. ,

1. 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 inspected.

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 '

' the initial comparison. Although the licensee's technical staff

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was able to address specific concerns by verbally describing how

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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

, documented. In response to these concerns, HL&P developed an

! 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 concerns.

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4 The NRC inspectors maintained continuous inspection coverage

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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 work.

2. Conclusion

Because of the delay in the startup of Unit 1, a limited number

of startup activities were inspected during this SALP period.

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 involvement.

The licensee is considered to be in Performance Category 2 in

this area.

3. Board Recommendations

a. 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.

I b. Recommended Licensee Action

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.

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l D. Maintenance

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l This functional area includes all licensee and contractor activities

associated with preventive or corrective maintenance of

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instrumentation and control equipment and mechanical arid electrical

syteras.

l 1. 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

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maintenance activities as Unit i received its low power OL.

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Most of the maintenance activities were bei..g performed for the

first time,

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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 quality.

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 1.

The licensee currently has an effective and ccmprehensive

preventive maintenance program with clear ano complete written

procedures.

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 WCC.

There were instances of improperly planned, performed, or

supervised maintenana activities that resulted in plant delays.

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

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 repirs.

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 training.

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, respectively. Su

LERs were issued from OL issuance through December 1987 that

were results of deficient actions on the part of the maintenance

department.

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2. 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 program. 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 area.

3. Board Recommendation

a. Recommended NRC Action

The routine NRC inspection program should be performed for

maintenance activities on Units 1 and 2.

b. 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 tasks.

Management and supervisory overview should continue in the

area of problem analysis and corrective actions.

E. Surveillance

This functional area includes all surveillance testing activities as

well as all inservice inspection and testing activities. 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.

1. 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

completion.

There were four LERs between August 21 (receipt of low power OL)

and December 31, 1987, in this functional area. The events ,

leadi ng to one of these LERs is also the subject of an escalated

enforcement action. This event concerns the fact that all four

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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 drift.

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 TS.

2. 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 issued.

3. 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

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! 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 area.

4. Board Recommendations

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a. Recommended NRC Action

The current level of NRC inspection effort should continue

l and focus on ensuring the adequacy of and compliance with

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the TS surveillance requirements and implementing

procedures. Unit 1 still has two plant modes which have

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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,

b. Recomended Licensee Action

The licensee should continue to upgrade the TS and

surveillance procedures to ensure that they comply with the

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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

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errors and omissions.

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.

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1. 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

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requirements of 10 CFR 50, Appendix R, and BTP 9.5-1, per FSAR

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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 shutdown.

The licensee's fire protection / prevention program was determined

, to be well designed with no significant deficiencies noted.

Minor areas of concera were evaluated by the licensee and

adequate corrective actions were taken.

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 adequate.

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

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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.

1

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 resolved.

2. Conclusion

i

Licensee management involvement in and commitment to their fire

i protection / prevention program was evident.

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

!

implementation and maintenance of the licensee's program will be

1 assessed in the next SALP.

i

The licensee is considered to be in Performance Category 2 in  ;

.

I

j this area.

3. Board Recomendations

.

j a. Recommer.ded NRC Actions

,

l The level of NRC inspection in this functional area should

' be consistent with the basic inspection program.

(

j b. 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

1

. _ -. , _ _ _ _ _ __ _ , _ _ .,_ ____ . _ . . _ - - _ - - .

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

. .

17

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 correctly.

1. Construction OA Activities

a. Analysis

Nine areas of the quality assurance program were assessed

during this period by resident and region-based personnel.

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 procedures.

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) vendor.

The program was functioning properly as each participant had

developed and implemented procedures to cover the areas

under 10 CFR 50, Appendix B. 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 attention.

The licensee program and staffing were as described in the

reviewed program manuals.

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 ongoing.

Direct HL&P senior management involvement in assuring

quality at STP has been evident and aggressive.

. - _ _ _ _ _ _ _ .

. .

18

b. 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 safety.

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 manner.

The licensee is considered to be in Performance Category 1

in this functional area.

c. 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 program.

(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 2.

2. Operations QA Activities

a. 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 equipment.

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

.

_ _ _ _ _ _ _ - _ _ _ _ _ _ __

. .

19

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) activities.

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,

3

i This effort should be focused on getting in front of

quality issues.

!

_ _ _ _ _ _ _. _ _. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - . .

. .

20

H. 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

1. Analysis

Two cold license examinations were conducted during this SALP period. ,

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 1.

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 1987.

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

achievable.

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 responsibilities.

.

_ _ _ _ _ _ _ _ _ _ _ _

o .

21

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 period.

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 areas.

Those elements deal with emergency preparedness personnel, the

security force and construction craft personnel.

2. _ 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 reversed.

The licensee is considered to be in Performance Category 2 in this

functional area.

3. Board Recommendations

a. 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 continue.

b. 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

. . .

. _ _ _ _ _ _ _ _ _ _ _ _ _

. .

22

design. 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

"

security, QA/QC and general employee training. Additionally,

the training staff must be responsive to the supplemental

, training necessitated by plant problems, current industry

issues, and plant identified operator weaknesses,

i

I. Emergency Preparedness

4

This functional area includes activites relating to the

! implementation of the emergency plan and implementing procedures.

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;--

4

facilities and equipment; staffing; training; assessment; emergency

classification; medical treatment; radiological exposure control;

recovery; protective actions; and interfaces with onsite emergency

response organizations.

i 1. 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 identified.

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

_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ _ . ___ ___ . _ _ _ _ _ . . _ _ _ _ _ _ - _ _ _

e ,

23

and recommendations of the Safe Team, and the corrective actions

of the licensee, and found that they were adequate.

2. 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 licensee.

The licensee is considered to be in Performance Category 2 in

this area.

3. Board Recommendations

a. 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,

b. 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 plant.

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).

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. .

24

,

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, 1987.

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 program.

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 complete.

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 problems.

The f4RC inspectors identified significant design and

construction errors in the security systems that were

attributable to ineffective licensee management controls. These

deficiencies became evident as the licensee attempted to

.

,

. .  :

p

25

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 completion.

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

, requirements.

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 breakdowns.

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 off. 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

1

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 period. t

l

t

_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _

.

26

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 regulations.

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 license.

The licensee is considered to be in Performance Category 3 with

an upward trend.

3. Board Recomendations

a. 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 conditions.

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,

b. 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

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .__ __ _ __ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

>

. .

!

!

27

K. Radiological Controls i

1. 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 / radiochemistry. Inspection activities identified in the

preoperational inspection program were completed during this

assessment period. No violations or deviations were identified.

a. 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.

2

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 period.

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 concerns. 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 audits.

b. Radioactive Waste Management

This functior21 area includes processing and onsite storage

of gaseous, liquid and solid wastes.

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 systems. L

.

-..

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. ..

28

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 program.

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 samples.

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 licente.

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 activities.

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 resolved.

e. Water Chemistry, Radiochemistry, and Confinnatory

Measu rerents

This functional are includes primary and secondary systems

1

affecting plant water chemistry, water chemistry control

program and program implementation, chemistry facilities,

equipment and procedures, and chemical analysis quality

assurance.

1

. _ _ _ _ .

__ _ _ .. _

. . i

29

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

performance.

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 power.

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 initiatives.  ;

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 concerns. [

,

No problems were identified in the transportation of radioactive

materials and water chemistry / radiochemistry areas.

The licensee is considered in Performance Category 2 in this

area.

i

3. Board Recommendations t

a. Recommended NRC Action ,

i

Inspection activities should continue at nonnal levels, f

.

4

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

b. 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 operations.

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

supports. 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,

.

,

1. 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

,

1

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 construction.

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

.-_ -._ - - - _ . - _

_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ __.

. .

!

31

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

1

management took immediate corrective action through direct i

involvement in rectifying the problems that were identified and

providing additional controls to preclude further deficiencies.  !

2. 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 manner. Curing  :

! the 13 inspections, only two deficiencies were identified. The

licensee is considered to be in Performance Category 1.

3. Board Recommendations  !

'

a. Reconinended NRC Action

h

The NRC inspections in this area will be reduced consistent t

l with the completion of construction activities in Unit 2. i

'

3

Unit 1 is complete.

b. 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.

1

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

4

compliance with the applicable codes and other requirements specified  ;

in the FSAR for those systems.

i

i 1. 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

. - . - - . - - . _-_ - - - - _ _ _ _ , - - _ - - - _ - _ . - . _ _ ___ - _ _

. - - _ _ _ _ _ _ _ _ _ _ _ _ _

'

. .

!

32 l

!

!

,

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 2. 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

2. 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 area.

3. Board Recommendations

a. Recomended NRC Action

The inspection effort in this functional area has been

concluded for Unit 1 because construction is complete.

However, the inspection effort should continue comensurate

with the level of construction activities in Unit 2.

b. Recomended Licensee Action

Although licensee management attention is evident,

continued emphisis must be maintained to achieve the

desired level of quality.

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 above.

1. 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

-____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _

. .

33

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

1

pressure boundary. 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 minimal.

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 units.

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 bolts.

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

equipment. 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

!

a. 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 equipment.

l

l

- _ _ _

. .

34

i

b. 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 status.

0. 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 public.

Included here are systems such as HVAC, radwaste, and fire

protection.

1. 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 areas.

!

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. above.

2. 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 area.

>

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_

-O .

35

3. Board Recommendations

a. 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.

,

b. 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 2.

P. Electrical Equipment and Cables

. 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

'

generators, motor control centers, switchgear, electric raceways,

i cable (power, control, and instrument), circuit breakers, relays, and

other interrupting and protective devices.

1. 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

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

!

- - _ - - - - - - _ _ _ - - - - - - - - - - - - - - . - - - - - - . - - _ _ _ _ - - - - _ - - . - - - - - - - - - - - - - - - - - - - - - .- - - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

,

. .

36

2. Conclusion

Management attention and involvement are evident and work

activities associated with safety-related electrical equipment

and cable are being conducted in an acceptable manner. The

licensee is considered to be in Performance Category 2 in this

functional area.

3. Board Recommendation

a. Recomended NRC Action

The NRC inspection effort should be maintained for Unit 2

electrical activities. The NRC inspection effort for

i Unit 1 is complete.

b. 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 2.

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 panels.

1. 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 area.

Corrective action for concerns identified during earlier SALP

periods appear to have significantly improved performance in

this area. Improved training has been evident and effective.

Lessons learned during the construction of Unit 1 are being

applied to Unit 2.

_______ ____

.- .

F

!

37

l

The small number of construction deficiencies found during this  ;

appraisal period indicates that the licensee's inspection and

surveillance programs are well planned and effective. t

'

2. 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 area. T

3. Bo,ard Reconsnendations

a. 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 complete. '

b. 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 2.

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) Actions. 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 issues.

1. 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, 1987.

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:

,

. .

38

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 thoroughness. On occasion

insufficient time was allowed for the proper interaction between

the functional groups within the licensee's organization.

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 threatened.

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 received.

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 needs.

Sometimes, such changes appear to cause short-term problems,

with satisfactory resolution occuring given sufficient time.

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 road.

2. 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 area.

,- , - . .

1

. .

i

39

3. a. 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 plant.

b. 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 status.

,

'

V. Supporting Data And Summaries

A. 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 issue.

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 1988.

B. 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 hours0.0103 days <br />0.247 hours <br />0.00147 weeks <br />3.38645e-4 months <br /> were devoted to Unit 1 and 2,618 hours0.00715 days <br />0.172 hours <br />0.00102 weeks <br />2.35149e-4 months <br /> 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

, . - ~ . . . - .- .

. . .

>'

40  !

'

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 ,

1

Routine construction inspections continued for Unit 2. There were

,

also some inspections of Unit 2 preoperational testing during the

,

latter part of the SALP period. .

Please refer to Tables 1 and 2 for a summary and tabulation,

respectively, of the identified violations, deviations, and F

-

deficiencies in each.SALP functional area for this SALP period.

C. 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 safety.

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 Investigations.

Ar,ther four allegations were being held open pending decisic.1s by

U.S. Department of Labor,

d

Y

~ e-.--n-- ,- c-,., .nn_n..,v. ,n..

- - , _ . - . - _

- -

. . .

.

41

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. This.

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 date.

D. Escalated Enforcement Actions

Escalated enforcement issues were identified in the SALP functional

,

areas of plant operations and security toward the end of the SALP

'

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

,

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 values.

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 events.

E. Licensee Conferences Held During Assessment Period

I

' 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 licensee.

F. Confirmation of Action Letters

None.

G. 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 process.

, ,

_ . . - - - , .-. ,_ _ . _ _. _ ._,-- _ .- .._ ,_ _ -- _ ___, _ _. _... _ .,._.. _ _ . _ . .-

. - _ _ _

. . .

42

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

personnel. 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 response.

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

frequency. Extensive modifications were made to correct these

problems.

One event entailed the inoperability of two trains of containment

spray for diverse reasons which were subsequently corrected.

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 vendor.

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 87-12.

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 3. .

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 - mechanical. This

data is also summarized in Table 3.

,

4 , e--~-, ye,-,wr, yy .-ve,~,,,-.,--.-y-,,.,-y-,-,,,- wm y-y ., y,r-w-r,s.--w---- -,.,v.------ ,-n.v.- e-ww.,---,-,--,-r-- -----,----,..,y.--- - - , -

. .

43

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.

l

l

l

l

_ _ _ _ - _ ,

. .

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

:  :

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.

!

!

!

4 h'

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 No. 1

02/17/83

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

'

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 Frep. 87-12-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) Freo. 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 Freo. 87-12-H-03

1 (To t, Verified Iurino Next Exercise) Status = 0

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[EF 04/10/37 Onsite Radioloacal Contrcls Frecedure not Trainins inadesvate Technical serv. 67-12-H-04

1 follcmed (To be Verified Curire hext Eiercise) Status = 0

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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

. . Table 2

Page 3 of 4

Face No. 2

02/17/83

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

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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

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l VIO 06/26/87 Failure to Fclica Fracedures for Fericrains Ferstenel Errcr Startuo 4 B7-37-V-01

'

I Freccerational Tests Status = 0

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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

,

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

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• * Table 2

Page 4 of 4

Pace No. 3 l

02/17/EB  !

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 NRC.

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 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 3

,

Page 2 of 6

Pace No. 1

02/17/88

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

.

'

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

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

. . . . , Table 3

Page 3 of 6

Paoe No. 2

02/17/83

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 Serv. 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

- 4* Table 3

Page 4 of 6

Face No. 3

02/17/88

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 3.0.3 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 No. 4

02/17/03

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

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' ** o Table 6

Page 6 of 6

Pase No. 5

02/17/83

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

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