ML20247A985
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| 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) | |
See also: IR 05000498/1988088
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~SALP BOARD REPORT-
U.S. NUCLEAR REGULATORY COMISSION
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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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I. ' 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 operation.
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
report. The Board's findings and recommendations were forwarded to the
NRC Regional Administrator for approval and issuance.
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,
1988.
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
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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 ,
A. Licensee Activities
1. 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 tube.
o Unit I was shut down from November 30, 1988, until
December 8,1988, for installation of vortex suppressors in
the three emergency containment sumps.
2. 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 2.
o The Unit I low thermal power license (NPF-71) was
superseded by a full thermal power operating license
(NPF-76) on March 22, 1988.
o The Unit 2 fuel load / low thermal power license (NPF-78) was
issued on December 16, 1988.
o The combined Unit 1 - Unit 2 Technical Specifications (TS)
(Amendment 4) were issued for Unit 1 on December 29, 1988.
3. 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, 1988.
B. 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.
.
II. 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 action.
programs is very much evident in the safety assessment and quality
verification functional area.
Performance in the area of radiological controls was also of high quality.
However, a review of performance during extended operations is needed to
arrive at a comprehensive evaluation in this area.
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 period.
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 STP.
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)
A. Plant Operations 2 2
B. Radiological Controls 2 2
C. Maintenance / Surveillance N/A 2
D. Emergency Preparedness 2 2
E. Security 3 2
F. Engineering / Technical N/A 2
Support
G. Safety Assessment / N/A 1
Quality Verification
H. Construction Completion and N/A Not Rated
Testing
I. Preoperational Testing 2 N/A*
J. Startup Testing 2 N/A*
K. Maintenance 2 N/A*
L. Surveillance 2 N/A*
M. Fire Protection 2 N/A*
N. Quality Programs and
Administrative Controls
Affecting Quality
(1) Construction 1 N/A*
(2) Operations 2 N/A*
0. Training and 2 N/A*
Qualifications
Effectiveness
P. Containments, 1 N/A*
Safety-Related Structures, l
and Major Steel Supports
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Q. Piping Systems 2 _N/A*
and Supports
R. Safety-Related 2 N/A*
Components - Mechanical
S. Auxiliary Systems 1 N/A"
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T. Electrical Equipment 2 N/A*
and Cables
.U. Instrumentation 1 N/A*
V. 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:
A. Assurance of quality including management involvement and control;
B. Approach to resolution of technical issues from a safety standpoint;
C. Responsiveness to NRC initiatives;
D. Enforcement history;
E. Operational events (including response to, analysis of, reporting of,
and corrective actions for);
F. Staffing (including management); and
G. Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been
used where appropriate.
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:
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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 substantially.
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 appropriate.
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 achieved.
NRC attention may be maintained at normal levels.
Category 3: Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to
meet minimal regulatory requirements. Licensee resources appear to be
strained or not effectively used. NRC attention should be increased above
normal levels.
IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. 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 professionalism.
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 inspectors.
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 2. 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 experience. 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 plant.
Near the end of the assessment period, an event occurred which
demonstrated th? maturity the licensee had gained in operations.
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 discovery.
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
completed.
Thz licensee's work force was very stable with a negligible
turnover rate. The operations staff consisted of five
operations crews which were fully manned. 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
2. 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 challenges.
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
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events including the prompt actions of operations personnel in
handling:the plant conditions following the catastrophic failure.
.of a steam driven turbine main feedwater pump.
Four automatic reactor trips occurred during this SALP period.
Two of the four occurred after issuance of the full power.
license. Two of the trips were because of hardware failures and.
-the other.two trips were because of maintenance activities.
Appropriate responses by licensee personnel led to the plant.
being safely shut down subsequent to each of these four trips.
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 conferences.
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 recurrence. The.
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 information. Previous
similar occurrences were properly referenced in the LERs.
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 conditions.
The licensee made steady, continuous progress in this functional
area. 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 2. The
licensed operators demonstrated a good understanding of plant
systems and operations.
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-2. Performanc'e Rating
'The licensee is assigned a performance category rating of 2 in
this area.
' 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 activities.
b. 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 level.
B. Radiological Controls
1. 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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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 personnel. 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 priorities.
Decisionmaking was usually at a level that ensured adequate
management review.
The radioactive waste management aren was inspected once during
the assessment period. No violations were identified. Two
operational events were reviewed during this assessment period.
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 systems.
The licensee's radiochemistry program was inspected three times
during the assessment period. No violations were identified.
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 averages.
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The licensee's transportation program was inspected once during-
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'this assessment period. 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 program.
-.The licensee maintains an adequate train.ing and qualification.
program in this area.
g The radiological environmental monitoring program was inspectedL 1
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 procedures.
No problems were identified in the radiological controls area
regarding resolution of technical issues and responsiveness to
NRC initiatives.
2. 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 area. 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 evaluation.
3. Recommendations
a. NRC Actions
The NRC inspection effort in this area should be consistent
with the routine inspection program,
b. Licensee Actions
Provide increased management attention to preoperational
testing of the Unit 2 radwaste systems to assure timely
completion.
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C. Maintenance / Surveillance
1. AnalvQs
This functional area includes the' licensee's activities-
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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 condition. It includes conduct.of all surveillance.
(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 activities.
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
power.
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 program.
Licensee management involvement in assuring quality in the
surveillance area increased during the assessment period.
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 availability.
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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not adequate to direct or complete a specific activity. 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 period.
Errors and/or omissions were incorporated into the procedures
during the revision process.
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 serviced.
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 containment.
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
criticality.
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
constructor.
With regard to surveillance activity, the licensee ended the
. last SALP with a trend that showed a poor identification of TS L. requirements and their implementation into surveillance L procedures. This trend continued into the beginning of this
SALP period. LERs described errors such as: missed
surveillance, surveillance performed late, inadequate posttest
reviews, and incorrect calculations of valve stroke times.
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
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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 program.
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 action.
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 area.
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2. Performance Rating
The licensee is considered to be in Performance Category 2 in
this area.
3. Recommendations
a. 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 1.
b. Licensee Actions
The licensee should focus on the implementation of what I
appear to be good programs in this functional area. ;
D. Emergency Preparedness
1. 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
exercises. J
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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.to.
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 2. 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 interviews.
The licensee demonstrated a strong commitment to provide
management support to the development of a quality emergency.
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 results.
The licensee conducted several independent audits during the-
assessment period. Audit. findings were being closely followed,
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corrected, and closed out. The licensee interaction with
offsite agencies appeared to be continuous and' adequate.
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 inspection.
The licensee committed to the completion of the facility by the
time of Unit 2 criticality. 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 manner.
2. Performance Rating
In general, the results from the annual exercise indicated that
the licensee is able to effectively implement the Emergency Plan
and procedures.
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
units.
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J. recommendations
a. 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 program.
b. Licensee Actions
Licensee management attention to the operational. readiness
of Unit 2 facilities .is indicated. In addition,
facilities, equipment, and procedures should be tested by
walkthroughs, drills, exercises, and quality assurance
audits to ensure that operational readiness is maintained.
E. Security
1. 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 controls.
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 assessments. 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 identified. 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 2.
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
staff. 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
effort.
The licensee had an effective quality assurance program. The
quality assurance inspectors responsible for security program .
audits are knowledgeable and thorough. Security management used I
audit findings to enhance or correct the security program.
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 use.
2. Performance Rating
The licensee is cons red to be in Performance Category 2 in
this area.
3. Recommendations
a. 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 2.
b. Licensee Actions
*
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 problems.
F. Engineering / Technical Support
1. 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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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 program.
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 submittals. 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 existed.
. 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
analyses.
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 rule.
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
manner. 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.
1
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 1
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-the' licensee had. technically competent and adequate staff. '
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engineering capabilities and was strong in the identification I
and resolution of. technical issues.
NRC-inspectors observed various;preoperational. program' .
activities in. Unit 2. These inspections determined that'the"
*
-licensee's programs, procedures, personnel, and controls were.
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. The.
licensee's preparations.and technical support.for the initial
fuel loading of Unit 2 demonstrated management involvement and
interdepartmental cooperation.
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 procedures. One of the inadequate
procedures resulted in several separate hydraulic transients
(water hammers) in the main feedwater system.
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 team.
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
period.
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
staff. 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
staff.
During the appraisal period, two licensing examinations were
administered by the NRC. In May 1988, 17 R0 examinations were
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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 examinations.
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 room.
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 area. Overall, the
licensee's facility training program is an effective program.
However, the simulator deficiencies may indicate a weakness in
the program.
Region-based inspectors reviewed the licensee's fire protection
program in a Unit 2 inspection during this assessment period.
The licensee had an effective fire protection program and
conducted fire drills on both Units at the specified intervals.
A violation was issued because fire watch personnel falsified
entries in official logs. 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 issues.
2. Performance Rating
The licensee is considered to be in Performance Category 2 in
this functional area.
3. Recommendations
a. 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 2.
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b. Licensee Actions
The licensee should focus attention on procedure review and
revision, especially regarding equipment labeling.
Procedures must be adequate to safely direct activities.
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 examination. j
G. Safety Assessment / Quality Verification
1. 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
plant.
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 critical.
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 information. 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: installation.
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 issues. 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 performance.
The licensee's corrective action. program has been effective.
The corrective actions usually were detailed and identified the
conditions which could result from the identified root cause.
There were few, if any, repeats of events. 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
developed.
The licensee generally responded to NRC Bulletins in a timely
manner. 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 issue. This attention to detail
generally was evident in all of the NRC Bulletin responses.
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 inspectors. 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 completed. !
An SPAI Team formed to assess operation of Unit 1 at the
50 percent power plateau, sampled several 10 CFR 50.59 reviews.
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 pump. Failure to properly
identify the material or perform the required review appeared to
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be-an isolated event. The results'of.the.SPAI-team inspection.
' indicated appropriate management awareness of, and' attention to,
problems regarding-10 CFR'50.59 reviews.
'
The licensee effectively used the Independent Safety Engineering l
Group (ISEG) in evaluating licensee event' reports, industry and .
.
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 operations.
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 sumps.
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 2. SAFETEAM
investigations were routinely raviewed by a multidisciplined
group' headed by the nuclear assurance. manager.
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 Coefficient.
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 issues.
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 procedures.
Licensee senior management demonstrated the initiative to be
self critical and to ensure that the plant operated in a safe
and efficient manner. Licensee senior management frequently
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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
requirements.
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 program.
' Quality assurance (QA) audits generally were effective in
identifying issues. 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 resolution.
Operations QA was active in assuring that the QA audit program
was effective and that reviews were conducted on a frequent
basis.
2. Performance Rating '
The licensee is considered to be in Performance Category 1 in
thit area.
3. Recommendations
a. 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 actions.
Trending of events in this area should be initiated when
sufficient data is available for a meaningful program,
b. 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 corrected.
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H. Construction Completion and Testing
1. Analysis
1
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 activities.
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 report.
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 verification. 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 Report.
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 practices.
In the Unit 2 preoperational testing area, the licensee showed
program improvements resulting from lessons learned during
Unit 1 preoperational testing. The administrative and test
procedures were of high quality. Test procedure performance was
professional and effective. Few testing errors were observed.
Interfacing between operations and test personnel was evident
and effective. Appropriate management involvement in testing
activities was apparent.
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Overall, relatively few violations of NRC requirements were
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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
program.
2. 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, 1988.
V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activities
1. ViolationsL
See Table-I for a tabulation of the of the. identified violations-
in each functional araa for this assessment period.
2. 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, 1988.
3. . 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 1.
There were three enforcement conferences. 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 TS. 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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_- _ - _ _ _ _ _ - - - _ _ _ _ _ - .- . _ _
- - _ __.
_ _ _ - _ -__ - . _ - _ - __ _-.
-
.-
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. -
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" , ~27-
1 .
'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 conference.
A second enforcement conference addressed safeguards matters. A'
Severity Level III-violation was cited, but no civil penalty. was
assessed. .A third enforcement conference addressed the.
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 cohference.
.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 the.
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
pending.
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, _ __
,
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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
A. Plant Operations 1 10
B. Radiological Controls 2
C. Maintenance / Surveillance 12
D. Emergency Preparedness 9 1
E. Security 3 1
F. Engineering / Technical Support 5
G. 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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