IR 05000498/1988088
| ML20247A985 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/20/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247A975 | List: |
| References | |
| 50-498-88-88, 50-499-88-88, NUDOCS 8903290245 | |
| Download: ML20247A985 (29) | |
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~SALP BOARD REPORT-U.S. NUCLEAR REGULATORY COMISSION
REGION IV
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SYSTEMATIC ASSESSMENT 0F LICENSEE PERFORMANCE
.50-498/88-88
;- -;50-499/88-88 Houston. Lighting & Power Company 3 South Texas Project Units 1 and 2
.. January 1, 1988, through December 31,>1988
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. . ' INTRODUCTION l
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The Systematic Assessment of Licensee Performance (SALP) program is an l integrated,NRC staff effort to collect available observations;and data'on ! a periodic basis.and to evaluate licensee. performance based upon this l information. The program is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operatio An NRC SALP Board, composed of the staff members listed below, met on February 10 and 23, 1989, to review the observations and data on performance, and to assess licensee performance in accordance with NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this repor The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuanc This report is the NRC's assessment of the licensee's safety performance at South Texas Project (STP) for the period January 1 through December 31, 198 The SALP Board for STP was composed of: L. J. Callan, Director, Division of Reactor Projects, Region IV R. E. Hall, Deputy Director, Division of Radiological Safety and Safeguards, Region IV J. P. Jaudon, Deputy Director, Division of Reactor Safety, Region IV J. A. Calvo, Director, Project Directorate IV, NRR J E. J. Holler, Chief, Project Section D, Reactor Project Section, l Region IV i
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G. F. Dick, Senior Project Manager, Project Directorate IV, NRR J. E. Bess, Senior Resident Inspector, Region IV J. I. Tapia, Senior Resident Inspector, Region IV The following personnel also participate' in the SALP Board meeting:
*J. L. Milhoan, Director, Division of Reactor Safety, Region IV B. Murray, Chief, Reactor Programs Branch, Region IV **D. M. Hunnicutt, Senior Project Engineer, Region IV R. J. Everett, Chief, Security and Emergency Preparedness Section, Region IV :
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N M. Terc, Emergency Preparedness Specialist, Region IV { D. L. Garrison, Resident Inspector, Region IV R. J. Evans, Resident Inspector, Region IV
* Acted for J. P. Jaudon on February 23, 1989 ** Acted for E. Holler on February 23, 1989 , Licensee Activities Major Outages o Unit I was shut down from September 23, 1988, until October 11, 1988, for bottom mounted instrumentation (BMI)
thimble tube inspection and installation of an isolation valve on each BMI tub o Unit I was shut down from November 30, 1988, until December 8,1988, for installation of vortex suppressors in the three emergency containment sump . Licensee Amendments During the assessment period, there were 2 Operating License Amenr'aents for Unit 1 and issuance of a fuel load / low thermal power license for Unit o The Unit I low thermal power license (NPF-71) was superseded by a full thermal power operating license (NPF-76) on March 22, 198 o The Unit 2 fuel load / low thermal power license (NPF-78) was issued on December 16, 198 o The combined Unit 1 - Unit 2 Technical Specifications (TS)
(Amendment 4) were issued for Unit 1 on December 29, 198 . Major Modifications ;
o Unit 1 BMI thimble tubes were modified to include isolation 1 valves during a scheduled outage from September 23, 1988, l through October 11, 198 Direct Inspection and Review Activities NRC inspection activities during this SALP evaluation period included 87 inspections. The total direct inspection hours expended on inspection activities of Units 1 and 2 were approximately 8,750 during this SALP evaluation period with approximately 4,402 direct inspection hours expended on Unit I and approximately 4,348 direct
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inspection. hours expended on Unit 2. .The inspections included two Operations Readiness Review . Inspections (ORRI) one at each Unit, a . Unit 1 Special Performance Assessment Inspection (SPAI), and a Unitr2 Appendix R 1rspection. Inspections were conducted by the resident-inspectors, region-based inspectors, resident inspectors from other operating sites within Region IV, NRR inspectors, and contract l: inspectors. . I SUMMARY OF RESULTS Overview
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Strong. management involvement, good operating experience with Unit l, and' the ability to apply lessons learned characterize the licensee's performance at STP, Units 1 and 2. Marked improvement since the last SALP' period was 'noted in security. Management's demonstrated commitment.to.the implementation of an excellent security, program has yielded good results and ~ markedly _ improved the licensec's' performance in this area. Similar improvement was noted in plant operations, particularly regarding the licensee's ability to apply the lessons learned from its operating experience. The;results have been an excellent startup effort with Unit 1~- and an exceptionally good fuel load completion with Unit 2. .This management commitment to safety and effectiveness of corrective actio programs is very much evident in the safety assessment and quality verification functional are Performance in the area of radiological controls was also of high qualit However, a review of performance during extended operations is needed to arrive at a comprehensive evaluation in this are Good performance continued in the areas of emergency preparedness, maintenance and surveillance, and engineering and technical support. Some weaknesses in review of procedures associated with ~ operation and maintenance of the plant were-noted as were weaknesses associated with the training simulator. Performance in maintenance and. surveillance appears to have leveled off. Effective maintenance programs are in place, but attention- to implementation is still indicated. Surveillance programs still showed weaknesses regarding late and missed surveillance throughout j the period, and incorrect procedures early in the assessment perio A'special functional area of construction completion and testing was assessed to capture the construction activities for Unit 2 that were not addressed in the other functional areas. Licensee performance was assessed as very good and reflective of the management attention evident in all the functional areas at STP. A rating was not assessed because construction is complete at ST The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation period.
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Previous Present Performance . Performance Category . Category Functional Area 101/01/87to12/31/87) (01/01/88 to 12/31/88) Plant Operations 2 2 Radiological Controls 2 2 Maintenance / Surveillance N/A 2 Emergency Preparedness 2 2 Security 3 2 Engineering / Technical N/A 2 Support Safety Assessment / N/A 1 Quality Verification Construction Completion and N/A Not Rated Testing Preoperational Testing 2 N/A* Startup Testing 2 N/A* Maintenance 2 N/A* Surveillance 2 N/A* Fire Protection 2 N/A* Quality Programs and Administrative Controls Affecting Quality (1) Construction 1 N/A*
(2) Operations 2 N/A* Training and 2 N/A*
Qualifications Effectiveness Containments, 1 N/A* Safety-Related Structures, l and Major Steel Supports i
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-5- Piping Systems 2 _N/A*
and Supports Safety-Related 2 N/A* Components - Mechanical Auxiliary Systems 1 N/A" l Electrical Equipment 2 N/A* and Cables
. Instrumentation 1 N/A* Licensing Activities 2 N/A* *NRC Manual Chapter 0516 was ravised on June 6,1988. This evaluation was ;
performed in accordance with the revised manual chapter. The major change ' involved restructuring of the functional areas
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III. CRITERIA Licensee performance was assessed in eight and rated in seven selected functional areas. Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities cn lack of meaningful observations. Special areas may be added to highlight significant observations. The following evaluation criteria were used, as applicable, to assess each functional area: Assurance of quality including management involvement and control; Approach to resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; Operational events (including response to, analysis of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification progra However, the NRC is not limited to these criteria and others may have been used where appropriat Based upon the NRC assessment, each functional crea evaluated is rated according to three performance categories. The definitions of these performance categories are as follows: I l i _ _ _ _ _ _ - _ . _ _ _ _ -
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-6-Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantiall exceeding regulatory requirements. Licensee resources are ample and ef4ctively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriat Category 2: Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieve NRC attention may be maintained at normal level Category 3: Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively use NRC attention should be increased above normal level I PERFORMANCE ANALYSIS Plant Operations Analysis The assessment of this area consi:ts chiefly of the control and execution of the licensee's operations staff and the activities of licensee management related to plant operations activities at Units 1 and 2. This functional area includes activities such as plant startup, power operation, plant shutdown, system lineups, logging plant conditions, responding to off-normal conditions, manipulating reactor and auxiliary controls, housekeeping, and control room professionalis This functional area was inspected on a continuing basis by the NRC resident inspectors, and by two ORRI Teams, a SPAI Team, and periodically by other Region IV inspector In general, the licensee's performance during startup and commerical operation on Unit 1 was very good. The licensee effectively used the lessons learned during the startup of Unit I to improve the preoperational testing for Unit The skill with which the licensee conducted a safe and efficient fuel load of Unit 2 demonstrated the control of activities gained by the licensee from its experienca with Unit 1. The frequent involvement of corporate management was clearly evident in the day-to-day decisionmaking regarding safe operation of both Unit I and Unit 2.
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During the last SALP period, several programmatic weaknesses were identified which suggested the need for additional management involvement in plant operations. At the beginning of this assessment period, operating problems regarding proper plant mode changes and the interpretation of Technical Specifications were experienced. The licensee directed appropriate management attention to these problems and demonstrated its capacity to learn from its experienc By the i time of the SPAI Team inspection at the 50 percent power plateau l for Unit 1, the licensee's operation of Unit ~1 was assessed as good, with strong programs in place to ensure safe operation of the plan Near the end of the assessment period, an event occurred which demonstrated th? maturity the licensee had gained in operation During a Unit 2 design review, the licensee discovered that vortex suppressors had not been installed in the emergency containment sumps of either Unit 1 or Unit 2. Unit I was operating at 100 percent power at the time of the discover Af ter the situation was identified to appropriate licensee management, the licensee promptly evaluated the safety significance and took appropriate conservative action which included shutting down Unit 1 until corrective actions were complete Thz licensee's work force was very stable with a negligible turnover rat The operations staff consisted of five operations crews which were fully manne Prior to the licensing of Unit 2, each operations crew consisted of up to four senior reactor operators (SRO). With the licensing of Unit 2 in late 1988, some of the experienced crew members that were involved with the startup of Unit I were assigned to Unit 2. This provided Unit 2 with an experience base gained from the successful startup of Unit 1 and negated the need for contractor supplied licensed shift advisors for Unit 1 or Unit Even with this reassignment of personnel, resources for Unit 1 were maintained at 5 operating crews. Each shift consisted of two SR0s and three licensed reactor operators (RO).
The Unit 1 control room operators generally displayed a high degree of professionalism during all phases of normal plant operations. This professionalism was also displayed when the operators were required to respond to complex system challenge During the period from Unit 1 initial criticality to commercial operation, the control room operators were observed by the NRC inspectors to improve their proficiency and became more comfortable with plant operations. Their familiarity and compliance with TS also improved. The effectiveness of operations personnel training and qualifications was demonstrated by the efficient response to several operations l
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L events including the prompt actions of operations personnel in handling:the plant conditions following the catastrophic failur .of a steam driven turbine main feedwater pum Four automatic reactor trips occurred during this SALP perio Two of the four occurred after issuance of the full powe license. Two of the trips were because of hardware failures an the other.two trips were because of maintenance activitie Appropriate responses by licensee personnel led to the plan being safely shut down subsequent to each of these four trip There were two enforcement conferences regarding Unit 1 ._ i
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operations during the SALP period. The first one addressed TS- ! interpretations, including Mode changes that occurred early in the' assessment period. The second. dealt with the _ falsification-of logs'by fire watches. No escalated enforcement actions resulted from the conference The LERs submitted during the SALP period adequately described
.the major aspects of each event, including component-or system failure that contributed to the event, and the.significant corrective actions, taken or planned to prevent recurrenc Th LERs were thorough, detailed, well written, and easy to understand. The narrative sections typically' included specific
, details of the event; the root cause of the event was identified clearly in most cases. The LER information was organized, with separate headings and specific information in each-section'that
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led to a clear-understanding of the event informatio Previous similar occurrences were properly referenced in the LER The licensee's successful conduct of the Unit 2 fuel load was a further demonstration, of the licensee's ability to use feedback from its activities and improve wor'k activities. The fuel loading operations were performed in a safe, effective manner and'were in conformance with the' license, administrative, and procedural requirements. Operating staff performance was professional at all times and shift turnovers were performed in a thorough and orderly manner. Initial fuel loading was the first operation where Unit 2 crews performed systems operations under licensed condition The licensee made steady, continuous progress in this functional are The operations staff exhibited the high level of professionalism which was required to safely operate Unit 1 and complete preoperational testing and fuel loading on Unit The licensed operators demonstrated a good understanding of plant systems and operation ; J - _ - _ _ _ _ - _ _ _ - _ _ _ . . _ -
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'The licensee is assigned a performance category rating of 2 in this are ' 3. Recommendations-a. -NRC Actions NRC-inspection effort in this area should be consistent with the Core Inspection Program. .In addition, selected Regional Initiative Program inspections should be conducted during the next- SALP period (January 1,1989, through January 31,1990) in the areas of preparation for refueling and refueling activitie Licensee Actions The licensee should continue to stress attention to details-throughout'the upcoming assessment period. The consequences'for a given action must be understood fully'
prior to' performing the activity. The licensee should continue to stress. adherence to.its in place control programs. . Management attention .is particularly important during initial criticality, low power. testing, and the power ascension prog' ram for Unit 2 and during the scheduled initial refueling of Unit 1 (presently scheduled for September 1989) to. assure that' required systems and personnel safety are maintained at the current high leve Radiological Controls Analysis The assessment of this functional area for Units 1.and 2 consists of activities directly related to radiological controls including occupational radiation safety (e.g., occupational radiation protection, radioactive materials and contamination controls, radiation field control, radiological surveys and monitoring, and as low as is reasonably achievable programs), radioactive waste management (i.e., processing and onsite storage of gaseous, liquid, and solid waste), radiological effluent control and monitoring (including gaseous and liquid effluents, offsite dose calculations, radiological environmental mo'nitoring, and confirmatory measurements), and transportation of radioactive materials (e.g., procurement of packages, preparation for shipment,' selection and control of shippers, receipt / acceptance of shipments, periodic maintenance of packagings, and point-of-origin safeguard activities).. - - _- - _ - - . - _ .
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-10-The occupational radiation protection program was inspected twice during the assessment period by region-based radiation specialist inspectors in addition to the resident inspector's routine inspections. One violation was identified during the assessment period relating to the occupational radiation protection program. The licensee maintained an adequate number ,
of well qualified radiation protection personne The turnover ! rate was low within the radiation protection staff. Job positions have been established and responsibilities were well defined. Vacant positions are usually filled within a reasonable time. The' licensee's training program appeared to be adequate and instructors were technically qualified. Management involvement and control of quality in the occupational radiation protection area were evident by performance of comprehensive audits and the establishment of program prioritie Decisionmaking was usually at a level that ensured adequate management revie The radioactive waste management aren was inspected once during the assessment period. No violations were identified. Two operational events were reviewed during this assessment perio The licensee has been responsive to NRC initiatives in this area. Five of the seven open items that had been previously identified were closed. Two items remained open concerning additional calibration of gaseous and liquid process radio-activity monitors and verification of representative sampling for airborne effluent discharge pathways. The liquid and gaseous effluent release permit programs have been implemented to assure planned radioactive effluent releases receive management review prior to being released. No significant problems were identified in the areas of effluent releases, effluent monitoring and monitoring instrumentation, effluent release reports, audits, and water chemistry. All preoperational testing had not been completed for the Unit 2 liquid and gaseous radwaste system The licensee's radiochemistry program was inspected three times during the assessment period. No violations were identifie One inspection included radiochemistry and water chemistry confirmatory measurements of actual plant liquid and gaseous samples and prepared certified standards using the NRC, Region IV, mobile laboratory. The licensee's radiological confirmatory measurement results for Unit 1 indicated 98 percent agreement, and for Unit 2 showed 95 percent agreement with the NRC analysis results. The licensee's program was found to be conducted in accordance with approved station procedures and Technical Specification requirements. The licensee's performance for water chemistry and radiochemistry confirinatory measurements were above industry average _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _
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< -11-The licensee's transportation program was inspected once during-
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'this assessment perio The' licensee made.one-radioactive waste-l shipment in late December 1988. The licensee has the necessary procedures and an NRC approved quality assurance program to ensure the implementation-of a proper transportation progra .The licensee maintains an adequate train.ing and qualificatio program in this area.
g The radiological environmental monitoring program was inspectedL
once during the assessment period. This program was well
. documented and staffed. .The licensee's program wasifound to be-conducted in accordance with management approved station-procedures and Technical Specification requirements. The licensee had approved procedures for the collection, processing, and analysis of environmental samples. Annual reports'.had been-submitted on time and in accordance with Technical Specification requirements. The land use census had been conducted as required during the assessment period. The licensee's training and qualification program associated with radiological ' environmental monitoring activities makes a positive contribution, commensurate with procedures and staffing, to the understanding of work and adherence to procedure No problems were identified in the radiological controls area regarding resolution of technical issues and responsiveness to NRC initiative . Performance Rating This licensee is considered to be in' Performance Category 2 in this functional area. The licensee's performance to date appears to be good in the radiological controls are However, additional review of the licensee's performance during extended-reactor operations such as a refueling or major maintenance outage is needed to arrive at a more cceprehensive evaluatio . Recommendations NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program, Licensee Actions Provide increased management attention to preoperational testing of the Unit 2 radwaste systems to assure timely completion.
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-12- Maintenance / Surveillance AnalvQs This functional area includes the' licensee's activities-
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l associated either with surveillance (diagnostic), predictive, prJventive or. corrective maintenance of plant structures, systems and components; procurement,' control, and storage.of components, including qualification controls, and installation
.of plant modification controls; and maintenance of the plant physical conditio It includes conduct.of all surveillanc (diagnostic) testing activities as well as inservice testing and inspection activities. Examples of activities included are instrument calibrations; equipment operability test;.
postmaintenance, postmodification, and postoutage testing; containment leak rate tests; water chemistry controls; special tests; inservice inspection (ISI) and performance tests of pumps and valves; and other inservice inspection activitie This area was inspected on a routine basis by the NRC resident
. inspectors, and periodically by region-based inspectors. In addition, an ORRI was' performed during the period of January 4-8, 1988, by NRC inspectors to assess the licensee's operational performance on Unit 1. An SPAI was performed by a team of NRC Region IV and NRC Headquarters personnel-- during the period June 27 through July 1,1988, to evaluate the licensee's readiness'to operate Unit I at greater than 50 percent of full powe The-' licensee had implemented maintenance and surveillance programs which are common to both units. The maintenance program was well organized and implemented by qualified personnel. A metrology laboratory supported maintenance activities including tool calibration and tool control, and was equipped with the latest available testing equipment. The surveillance program was considered functional but was not as we'll organized as the maintenance progra Licensee management involvement in assuring quality in the surveillance area increased during the assessment perio Surveillance activities and the corrective action requirements were generally well defined and implemented with interdepartmental teamwork. The licensee balanced the resources L available, achieved good quality workmanship and use of
' personnel, and improved equipment availabilit Personnel performance of maintenance and surveillance activities also showed improvement regarding timeliness and accuracy in completing these tasks. The licensee complied generally with procedural and TS requirements. The ORRI identified examples of f maintenance and surveillance activities and procedures that were w________ _ . - _ _ . i
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-13-not adequate to direct or complete a specific activit Some of these activities / procedure problem areas resulted in engineered safety feature (ESF) actuations. For example, I&C technicians used procedures which contained erroneous data. The frequency of ESF actuations decreased during the assessment perio Errors and/or omissions were incorporated into the procedures during the revision proces With regard to maintenance activity, the licensee was assessed in the last SALP period as having the procedures for a strong maintenance program in place, but'as having some problems in implementation. This assessment remained appropriate for this SALP. period as well. There were, however, some improvements in implementation and there continued to be good development of strong maintenance programs. Management commitment was demonstrated by increased emphasis and continued implementation of the maintenance program. Improvement programs included the development of generic maintenance job plans which better defined the frequency at which equipment should be service The licensee spent significant resources in its effort to identify and repair steam and water leaks in primary systems inside containment and secondary systems outside containmen During routine inspections and surveillance, the resident NRC inspectors observed a decrease in the number of systems in which leakage had previously been identified. Also, operation of Unit 1 in TS Limiting Conditions for Operation (LCO) action statements because of equipment operability problems, decreased in frequency following the early operating history after initial criticalit Some weaknesses in the implementation of maintenance programs continued during the assessment period. Maintenance personnel did not always keep operating personnel adequately informed regarding maintenance activities. Maintenance work packages, in some cases, failed to account for TS requirements or provide for proper control of lifted leads and/or temporary jumpers during electrical maintenance activities. The licensee failed to generate required maintenance p acedures for a number of Unit 2
. systems when those systems were turned o/er from the constructo With regard to surveillance activity, the licensee ended the . last SALP with a trend that showed a poor identification of TS requirements and their implementation into surveillance L procedures. This trend continued into the beginning of this SALP perio LERs described errors such as: missed surveillance, surveillance performed late, inadequate posttest reviews, and incorrect calculations of valve stroke time Several violations also were cited in this functional area. The major factors which contributed to the violations and reportable events were personnel errors or scheduling oversight. A U
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reduction in the number of missed surveillance events during the-later part of the assessment period indicated an improvement in control of the surveillance testing progra NRC resident inspectors verified, during numerous observations of surveillance test activities, that testing was complete, data acquisition was accurate, and the acceptance criteria was generally met. When discrepancies were observed by the NRC inspectors, the licensee took prompt corrective actio Adequate staffing and training of personnel in the areas of surveillance and maintenance was evident during the assessment period. Supervision in the plant was good. Qualification 1 programs were in place and contributed to adequate training in this functional are .
! Performance Rating The licensee is considered to be in Performance Category 2 in this are . Recommendations NRC Actions NRC inspections in this area should include the Core Inspection Program. Additional inspection effort should be directed towards the maintenance program and surveillance testing during the scheduled initial criticality for Unit 2 and the scheduled initial refueling for Unit Licensee Actions The licensee should focus on the implementation of what I appear to be good programs in this functional are ; Emergency Preparedness Analysis This functional crea includes activities related to the establishment and implementation of the Emergency Plan and implementing procedures, such as onsite and offsite Plan development and coordination; support and training of onsite and offsite emergency response organizations; applicant performance during exercises that test Emergency Planc; administration and .
implementation of the Plan; notification; radiological exposure ] control; recovery; protective actions; and interactions with l onsite and offsite emergency response organizations during exercise J l
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-15-Four' emergency pre ~paredness inspections were conducted-by NRC l region-based inspectors during the assessment period. One'of these inspections was-the observation of their annual' emergency exercise. One violation and nine deficiencies were-identified this assessment period. Three of the defic'iencies pertained.t exercise weaknesses. 'The violation was due to the failure to
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submit changes of emergency preparedness implementing-procedures to the NRC. The last routine inspection was conducted,to determine the' extent of readiness of the. program after the incorporation of Unit The other routine inspections were performed, in part, to verify that corrective actions'had been taken to ensure that supervisory operations personnel understood-
.certain emergency preparedness concepts that had been noted to be weak during training interview The licensee demonstrated a strong commitment to provide management support to the development of a quality emergenc preparedness program. This was_ evidenced by adequate staffing and effective management support ',o the emergency preparedness program. Additionally, excellent emergency response facilities, equipment, and supplies have been provided. Training and quality assurance programs have begun to yield good result The licensee conducted several independent audits during the-assessment period. Audit. findings were being closely followed, '
corrected, and closed out. The licensee interaction with offsite agencies appeared to be continuous and' adequat Although emergency response facilities appeared _to be basically adequate, the Unit 2 technical support center was not in a complete state of readiness at the time of the last inspectio The licensee committed to the completion of the facility by the time of Unit 2 criticalit Since the Unit 2 technical support center will be supported by the operational support center in Unit 1, the licensee will need to verify that resources can be effectively moved to Unit 2 in a timely manner. The Emergency Plan and implementing procedures need to be modified to document the changes caused by the incor.poration of Unit 2 into the emergency preparedness program. These problems indicated that licensee management lacked initiative in identifying and correcting deficiencies in a timely manne . Performance Rating In general, the results from the annual exercise indicated that the licensee is able to effectively implement the Emergency Plan and procedure The licensee is considered to be in Performance Category 2 in this area. The emergency plan and procedures are to be reviewed to ensure they describe fully the interrelationships of the two unit _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _
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-16-- recommendations NRC Actions The NRC inspection program should consist of coverage of the annual exercise and an operational readiness inspection to review the integration of both units into the emergency -
response progra Licensee Actions Licensee management attention to the operational. readiness of Unit 2 facilities .is indicate In addition, facilities, equipment, and procedures should be tested by walkthroughs, drills, exercises, and quality assurance audits to ensure that operational readiness is maintaine Security Analysis This functional area includes all activities that ensure the security of the plant including all aspects of access control, security background checks, safeguards, and fitness-for-duty
- activities and control During the assessment period, region-based physical security inspectors conducted ten security inspections. Considerabi NRC inspection effort above that normally expected was necessary in order to resolve and followup on findings identified during previous assessment Four violations of the Physical Security Plan (PSP) and procedural requirements were identified. Three Severity Level- IV violations and one Severity Level III violation were identifie These violations were in the areas of lock and key control, protection of safeguards information, compensatory measures, and guard training. Security inspectors accomplished a complete preoperational inspection effort for Unit 2 during the SALP period. No issues were discovered that impacted on the fuel load / low thermal power license for Unit Licensee management has demonstrated a strong commitment to the implementation of an excellent security program. The security management staff is professional, knowledgeable, and well organized. The licensee has expended considerable effort and manpower to make improvement in the area of implementing procedures, equipment, and training. Technical issues and problems are quickly identified and resolved by the security staf NRC initiatives were addressed promptly by security management. Action on the longer term commitment to improve the perimeter detection system is still in progress.
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With the licensing of Unit 2, the licensee-increased the security' force to 270 officers. The training and qualification of these officers significantly improved during this rating period as evidenced by performance during the Unit 2 inspection effor The licensee had an effective quality assurance program. The quality assurance inspectors responsible for security program . audits are knowledgeable and thoroug Security management used I audit findings to enhance or correct the security progra The licensee has made significant, continuing improvements in security since the previous assessment period. Open items and commitments made prior to the licensing of Unit 1, with the exception of the perimeter detection aids issue, have been addressed and actions completed. The recent expansion of the security program to encompass Unit 2 will continue to present isolated problems as new security systems are tested and put into routine us . Performance Rating The licensee is cons red to be in Performance Category 2 in this are . Recommendations NRC Actions The NRC inspection effort rNould continue at its current level in order to address licensee progress in fully implementing the expanded security program caused by the licensing of Unit Licensee Actions
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Licensee management should continue to provide strong support to the security program. Management should also continue to monitor security system performance in order to promptly discover potential problem F. Engineering / Technical Support Analysis The assessment of this area includes licensee activities associated with the desiga; plant modifications; engineering and technical support for operations, outages, maintenance, testing surveillance, and procurement activities; training; configuration management; and fire protection / prevention.
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-18-This functional area was inspected on a continuing' basis by the NRC. resident inspectors, by a special Emergency Operating Procedure team inspection, and periodically by.other Region.IV inspectors, including an-_ inspection of the licensee's fire protection progra During the assessment period, the' licensee's. engineering and technical support groups performed well. The approaches to resolution of technical problems by the licensee demonstrated clear understanding of the issues. The licensee adequately addressed the appropriate criteria in its submittal In particular, in its audit of calculations, the NRC_ staff found that records were complete and well maintained.and that conservatism was routinely exhibited when-the-potential-for safety significance existe . A large number of technical issues were addressed during the SALP_ period including installation of new racks in the spent-fuel pool, the anticipated transients without scram (ATWS) rule, ;
nonconforming materials (NRC Bulletin 88-05), pressurizer-surge i line thermal stratification, BMI thimble tube degradation,_and dealuminization of aluminum-bronze valves and fittings _in the-essential cooling water system. The licensee-ciearly. identified the technical issues involved, proposed approaches that were technically sound and thorough, and proposed timely resolutions that generally were conservative regarding safety. Throughout this assessment period, the quality of justifications for continued operation (JCO) written were sufficient in detail and analyse The NRC (NRR) staff completed the review of the licensee's submittals regarding compliance'with 10 CFR 50.62, the rule on ATWS. The information provided by the licensee showed general understanding of the technical and operating issues as well as understanding and compliance with the ATWS rul The e' valuation and resolution of the problems associated with a Unit I steam generator feedwater pump turbine (SGFWPT) failure and the casign changes demonstrated the licensee's ability to resolve technically difficult problems in a timely and effective manne Engineering support evaluations of this event appeared sufficiently detailed to assure that all of the facts were , available prior to initiating modifications to the SGFPT.
In instances when it was necessary' to request additional information or clarification regarding technical matters, the , licensee displayed an adequate understanding of the issues and L provided complete responses to the NRC staff. The quality of i the engineering for these and other activities indicated that l
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n h s-the' licensee had. technically competent and adequate staf ' f L
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engineering capabilities and was strong in the identification I and resolution of. technical issue NRC-inspectors observed various;preoperational. program' . activities in. Unit 2. These inspections determined that'the"
* -licensee's programs, procedures, personnel, and controls wer developed and implemented in accordance with the preoperational and startup program and regulatory requirements. Management involvement'was evident in the'various phases of construction and preoperational testing of Unit 2,and startup, power-ascension testing, and commercial operation.of Unit 1. Th licensee's preparations.and technical support.for the initial fuel loading of Unit 2 demonstrated management involvement and interdepartmental cooperatio Some weaknesses in.the engineering: design' review area were observed during the SALP period. The' licensee issuedL12 LERs in .this. area. The weaknesses appeared to be in design control and reviews of procedures associated with operation and. maintenance of the plant'.
In the area of procedure development, two: violations were issued because of. inadequate procedure One of the inadequate procedures resulted in several separate hydraulic transients (water hammers) in the main feedwater syste An NRC inspection team conducted an extensive inspection of Unit 2 emergency operating procedures (EOPs). The results of the E0P inspection indicated that the E0Ps were technically adequate, however, improvements were needed in the areas of . human factors, labeling, and tagging of equipment. The tea also concluded that validation of procedures through walkdowns required improvement. -Problems'regarding labeling of equipment in other procedures were also identified by the resident inspectors and by other NRC team inspections durino the SALP perio The licensee's training program for licensed and nonlicensed staff was assessed on a continuing basis by the resident inspectors and several inspections by members of the Region IV staf The NRC reviewed training for engineering and technical personnel. The training programs were generally well defined and implemented. The licensee had an effective on-the-job training program. The trainina department demonstrated improvement and implemented lessons learned in the training
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program. The licensee maintained a well qualified training staf During the appraisal period, two licensing examinations were administered by the NR In May 1988, 17 R0 examinations were -.
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-20-administered with-16 passing. In November 1988, two SRO and 12 RO examinations were administered with both SRO candidates and 7 R0 candidates passing the examination During licensing examinations, NRC personnel observed that the i licensee had no standard method for operators to give or acknowledge receipt or understanding of an order or make a report of actions taken, such as starting a pump or operating a switch. The licensee should improve training regarding the method of communications and acknowledgement of orders in the control roo Significant deficiencies were encountered with the Unit 1 and Unit 2 simulator during.the May and November 1988 operator licensing examinations. Medeling inaccuracies, systems limitations, and system unieliability rendered the simulator marginally acceptable for examination purposes. In May 1988 and November 1988, the licensee stated that new simulator programs disks would be loaded to improve the performance of the simulator. The disks or revised programs had not been installed in the simulator computer and the licensee was marg' ally acceptable in the simulator training are Overall, the licensee's facility training program is an effective progra However, the simulator deficiencies may indicate a weakness in the progra Region-based inspectors reviewed the licensee's fire protection program in a Unit 2 inspection during this assessment perio The licensee had an effective fire protection program and conducted fire drills on both Units at the specified interval A violation was issued because fire watch personnel falsified entries in official log Management was involved in assuring appropriate priorities for fire protection safety. Licensee management displayed a clear understanding of the specific fire protection principles involved and provided sound and conservative approaches to resolution of the technical issue . Performance Rating The licensee is considered to be in Performance Category 2 in this functional are . Recommendations NRC Actions NRC inspections in this area should include the Core Inspection Program. Additional inspection effort should be directed towards determining whether simulator improvements have been accomplished prior to the next scheduled licensed operator examinations at Units 1 and __ . _ _ - _ _ _ _ _ _ __
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-21- Licensee Actions The licensee should focus attention on procedure review and revision, especially regarding equipment labelin Procedures must be adequate to safely direct activitie The licensee should correct simulator program deficiencies and become familiar with the use and operation of any changes in simulator / plant performance parameters prior to the next scheduled licensed operator examinatio j G. Safety Assessment / Quality Verification Analysis This functional area includes all licensee review activities associated with the implementation of licensee policies; licensee activities related to amendment, exemption and relief requests; response to generic letters, bulletins, and information notices; and resolution of TMI items and other regulatory initiatives. The functional area also includes licensee activities related to resolution of safety issues, 10 CFR 50.59 reviews, 10 CFR Part 21 assessments, safety committee and self-assessment activities, analyses of industry's operational experience, root cause analyses of plant events, use of feedback from plant quality assurance / quality control (QA/QC)
reviews, and participation.in self-improvement programs. The I assessment includes the effectiveness of the licensee's quality I verification function in identifying and correcting substandard I or anomalous performance, in identifying precursors of potential I problems, and in monitoring the overall performance of the i plan Licensee management's involvement to assure quality was clearly evident throughout the SALP period. The involvement of corporate management fostered a cooperative attitude and conservative approach on the part of the licensee's staff when resolving NRC staff concerns. Corporate management involvement also was very much evident in the licensee's commitment to safety. Its presence contributed to the ability of the safety committee to be insightful and self critica The licensee was very responsive with the NRC staff in working to resolve technical issues. Responses to NRC concerns were timely and included the requested information. Management involvement was evident and frequently included coordinating site activities to provide the requested informatio For example, in the safety parameter display system (SPDS) review, the licensee described in its submittals each open item and proposed acceptable resolution. The installation of new racks in the spent fuel pool effort also demonstrated the licensee's _ _ - _ ____ _____-__-
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cooperative attitude and conservative approach. The licensee's staff exhibited eagerness to resolve NRC staff concerns related to the safety of the rack: installatio The completeness of the technical submittals, and the effectiveness of communications with the NRC staff, reflect a high level of management attention, involvement, and recognition of safety issue Notwithstanding the licensee's management attention, at least one deviation from commitments was identified regarding the failure to include the use of the reactor vessel head vent system in an emergency procedure. The licensee deviated from their commitment to Branch Technical Position Reactor System Branch 5-2. The deviation was not typical of the licensee's performanc The licensee's corrective action. program has been effectiv The corrective actions usually were detailed and identified the conditions which could result from the identified root caus There were few, if any, repeats of event In May 1988, there ! was a catastrophic failure of one of the' Unit 1 main feedwater ! pump turbines due to a' stuck open throttle valve and subsequent overspeed to destruction. Although the failure involved balance of plant (BOP), the licensee kept the plant shut down while the failure was thoroughly investigated and appropriate solutions develope The licensee generally responded to NRC Bulletins in a timely manne During this assesement period the licensee responded to 10 NRC Bulletins. In its handling of the response to NRC Bulletin 88-05, the licensee performed requested additional testing. The quality of-the submittal showed that significant attention was given to this issu This attention to detail generally was evident in all of the NRC Bulletin response The licensee responded to 8 Generic Letters (GL) during this assessment period. The response to GLs were usually timely and ! contained sufficient information to permit closure of the GLs by NRC inspector In some cases the licensee submitted preliminary responses while work was ongoing. This was considered a positive action in that it kept the NRC staff advised regarding progress. For example, the preliminary response to GL 88-17 conservatively stated that no reduced inventory operations would be conducted with irradiated fuel in ; the reactor until actions stated in the GL were complete ! An SPAI Team formed to assess operation of Unit 1 at the 50 percent power plateau, sampled several 10 CFR 50.59 review Prior to the SPAI, a violation was cited regarding the use of inappropriate material in a steam generator power operated relief valve hydraulic cylinder and pum Failure to properly identify the material or perform the required review appeared to l
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n t -23- - be-an isolated event. The results'of.the.SPAI-team inspectio ' indicated appropriate management awareness of, and' attention to, problems regarding-10 CFR'50.59 review ' The licensee effectively used the Independent Safety Engineering l Group (ISEG) in evaluating licensee event' reports, industry and .
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NSSS operational events, various plant; problems, and hardware and component failures. The ISEG. included personnel who were a -familiar with the plant systems,- components, and operation Several individuals were licensed operators' on Unit I and 2 or- " similar PWR units. The ISEG can.self-initiate evaluations or investigate matters referred to it by the Plant Manager. Items-addressed by the ISEG during the- SALP period included. evaluation of'midl. cop operation and investigation of a construction-oversight that.omitted vortex suppressors from the containment emergency sump The licensee had'7 personnel in the South Texas Project SAFETEAM: organization for most of-the assessment period. The SAFETEAM kept. current on investigations, allegations, and' concerns
: expressed..to the SAFETEAM by HL&P employees, contractor employees, and third parties. The SAFETEAM. investigations-included a review for items that could impact on the continued safe operation of Unit 1 or-the anticipated initial criticality and power' ascension program scheduled for Unit SAFETEAM investigations were routinely raviewed by a multidisciplined group' headed by the nuclear assurance. manage During this SALP pe'riod, en NRC ' team inspected the Plant Operations Review Committee (PORC) as part of the SPAI. Prior to the inspection, a violation had been issued regarding-approval by the PORC ofithe results of a test containing incorrect data. The data ultimately resulted in an erroneously calculated value for the Moderator Temperature Coefficien During'this inspection, the NRC inspectors concluded that PORC appeared to subject identified problem areas to a detailed review and that the PORC focused its attention on safety significant issue The licensee obtained experience feedback from similar operating plants by actively participating in the Westinghouse Owners Group (WOG). Also, a plant reliability task force effectively reviewe'd the operating experience of other plants on a regular basis and recommended changes to plant systems and hardware based on the reviews. Generally, industry operating experience and vendor information were implemented in training and plant revisions to procedure Licensee senior management demonstrated the initiative to be self critical and to ensure that the plant operated in a safe and efficient manne Licensee senior management frequently
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-24-visited the ' control room and other safety related portions of the power block. These management personnel reported their findings and observations directly to the Group Vice President, Nuclear, to ensure that activities were conducted and coordinated in accord with appropriate procedure 'and regulatory requirement The operations QA organization included personnel who were familiar with reactor operations and equipment. QA personnel participated in the licensed operation training program. The operations QA organization was effective in supplementing the QA audit progra ' Quality assurance (QA) audits generally were effective in identifying issue Failures to identify substantive problems were rare. Problems identified were transmitted to line management for resolution, reviewed by the offsite review committee and followed up on to ensure adequate resolutio Operations QA was active in assuring that the QA audit program was effective and that reviews were conducted on a frequent basi . Performance Rating '
The licensee is considered to be in Performance Category 1 in thit are . Recommendations NRC Actions Inspection activities should be maintained consistent with the Core Inspection Program. Selected Regional Initiative Program inspections should be conducted in the areas of corrective actions, review and awareness of 10 CFR 50.59 reviews and results evaluation, and corrective action Trending of events in this area should be initiated when sufficient data is available for a meaningful program, Licensee Actions The licensee should continue implementation and refinement of the programs established in this functional area. The scope of quality assurance audits and surveillance should be reviewed to assure that weaknesses in areas audited are identified and promptly correcte I w-______-_-__
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-25- Construction Completion and Testing Analysis
The assessment of this area included the licensee's completion of Unit 2 construction and required testing and verification of systems in preparation for a fuel load / low thermal power license. This included: containment vessel tendon installation, tensioning, and testing; cold hydrostatic testing of the primary system, inservice inspection baseline data, containment integrated leak rate testing; hot functional testing; and steam generator testing. The assessment also included management effectiveness in developing, implementing, and supporting overall construction and testing activitie This area was inspected on a continuing basis by the NRC resident inspectors and during many inspections by NRC region-based inspectors. The NRC inspections covered the licensee's construction, testing, and fuel loading programs as well as fire protection, security, radiation protection, radwaste handling, and emergency planning efforts. These latter areas are addressed in the appropriate functional area analysis in this repor Work on Unit 2 during the SALP period was characterized by a high level of activity directed toward completion of construction and required testing and verificatio Management involvement was comprehensive and evidenced by policies, directives, and implementing procedures which provided appropriate guidance. Management effectively monitored performance and held middle level line management and the workforce accountable for their actions. Construction and testing were completed on schedule and in compliance with the design basis and commitments identified in the Final Safety Analysis Repor Unit 2 workmanship was generally of high quality. Adequate directives and procedures and good management oversight produced timely and quality results. Construction efforts were completed in a manner consistent with good construction practice In the Unit 2 preoperational testing area, the licensee showed program improvements resulting from lessons learned during Unit 1 preoperational testin The administrative and test procedures were of high quality. Test procedure performance was professional and effectiv Few testing errors were observe Interfacing between operations and test personnel was evident and effective. Appropriate management involvement in testing activities was apparent.
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identified regarding construction activities, consideringLthe large' work effort involved. The violations _ cited 1 reflected minor problems and were an indication of isolated cases of personnel-erroriand not'of programmatic breakdowns. This was attributable, in'large part,-to management attention to identified problem areas and an effective corrective' action progra . Performance Rating No rating is assessed in this area because no construction activity is planned for the next SALP period. Construction activities 1for Unit 2 were assessed as satisfactory prior to the u issuance of a. fuel load / low thermal power license' on December 16, 198 SUPPORTING DATA AND SUMMARIES Licensee Activities ViolationsL See Table-I for a tabulation of the of the. identified violations-in each functional araa for this assessment perio . Major Inspections A major ORRI for Unit I was performed January 4-8, 1988. An SPAI (the 50 percent power assessment inspection) for Unit I was performed June 27 through July 1,1988. An ORRI for Unit 2 was performed November 14-18, 1988. An Appendix R (Fire Protection) inspection for Unit 2 was performed October 3-7, 1988. An NRC Emergency Operating Procedure (E0P)' Inspection of Unit 2 was performed by a' team of NRC personnel October 17 through November 4, 198 . . Enforcement Activity The SALP Board reviewed the enforcement history for the period January 1 through December 31, 1988. This review included the deviations, violations, and emergency preparedness deficiencies tabulated by SALP category in Table There were three enforcement conference The first enforcement conference addressed two issues; the licensee's discovery that while in Mode 3, prior to initial criticality of Unit 1, 7 of the 12 feedwater flow transmitters (FWFT) were isolated and out of service. The isolation of the FWFT was a violation of T l The second enforcement issue regarded voluntary entry into TS 3.0.3. It appeared that while in an action statement, with l
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'2-steam generator PORVs inoperable, the licensee voluntarily-entered TS 3.0.3 to test other PORVs (one PORV at a time).
Subsequently it was determined that-the PORVs were operable-while the test-was being conducted. The enforcement conference carefully defined the framework for entry into and out of TS 3.0.3. A letter.was issued'to the licensee ~as a result of-this enforcement conferenc A second enforcement conference addressed safeguards matter A' Severity Level III-violation was cited, but no civil penalty. was assesse .A third enforcement conference addressed th falsification of-entries in official logs 'oy fire watch personnel. The falsification of-log entries occurred prior to completion of construction.of Unit 1. ~No escalated enforcement- ~ actions resulted from this enforcement cohferenc .In addition, an enforcement conference was held infth'e P.egion IV office on January 26, 1989, to discuss the licensee's failure to install vortex suppressors in the containment emergency' sumps
.(the licensee identified this installation failure in Unit ~ 2 while performing' design review activities). Subsequent inspection by the licensee' determined that vortex suppressors had not been installed in Unit I containment emergency sumps prior to initial criticality and that Unit I had.op'erated since-initial' criticality without the required installation of th vortex suppressors. 'A Severity Level III vio'lation was issued and a $50,000 civil-penalty was pr.oposed on March 17, 1989. .The licensee's. response to the escalated enforcement action is pendin _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _
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e a TABLE 1 ENFORCEMENT ACTIVITY NO. OF VIOLATIONS FUNCTIONAL IN SEVERITY LEVEL AREA DEF DEV V IV III II I r i Plant Operations 1 10 Radiological Controls 2 Maintenance / Surveillance 12 Emergency Preparedness 9 1 Security 3 1 Engineering / Technical Support 5 Safety Assessment / Quality 10 Verification TOTAL 9 0 1 43 1 0 0 Footnote: Failure to install the votrex suppressors in Unit 1 prior to initial criticality was addressed in NRC Inspection Report 50-498/88-73; 50-499/88-73. An enforcement conference was held in the Region IV office January 26, 1989, and a Severity Level III violation and proposed civil penalty issued on March 17, 1989. The licensee's response to the escalated enforcement action is pending.
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