05000498/LER-1994-008, Forwards Errata Sheet for Abstract Page of LER 94-008.W/o Stated Encl

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Forwards Errata Sheet for Abstract Page of LER 94-008.W/o Stated Encl
ML20080H654
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 02/14/1995
From: Martin L
HOUSTON LIGHTING & POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20080H646 List:
References
ST-HL-AE-4998, NUDOCS 9502230201
Download: ML20080H654 (2)


LER-2094-008, Forwards Errata Sheet for Abstract Page of LER 94-008.W/o Stated Encl
Event date:
Report date:
4982094008R00 - NRC Website

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e The Light companySout flouston Lighting & Power esas rject ectr c Genuat og tat n . O. Bos 289 Wadswonh, Texas 77483 February 14, 1995 ST-HL-AE-4998 File No.: G26 10CFR50.73 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Unit i Docket No. STN 50-498 Licensee Event Report 94-008 Renarding a Failure to Stancer Reactor Trio Breaker Surveillance Test Intervals Errata Sheet Letter ST-HL-AE-4738 of March 28,1994, was distributed with two different " Abstract" pages. A dated copy of the original letter with the correct " Abstract" page is attached for replacement.

If you should have any questions on this matter, please contact Mr. J. M. Pinzon at (512) 972-8027 or me at (512) 972-8686.

p i/a . / f7 D 6 L. E. - in Gen al Manager, Nuclear Assurance and Licensing JMP/lf

Attachment:

ST-HL-AE-4738 dated March 28,1994 9502230201 950214 PDR ADOCK 05000499 S PDR 1.F.R- P S \ 9 4 -00 0 RD .U1 Project Manager on Behalf of the Participanu in the south Tens Project

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Houston Lighting & Power Company ST-HL-AE-4998 South Texas Project Electric Generating Station File No.: G26  :

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Leonard J. Callan - Rufus S. Scott Regional Administrator, Region IV Associate General Counsel U. S. Nuclear Regulatory Commission Houston Lighting & Power Company 611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8084 .- Houston, TX 77208  ;

Thomas W. Alexion Institute of Nuclear Power  :

Project Manager Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway  ;

Washington, DC 20555-0001 13H15 Atlanta, GA 30339-5957 l

David P. Loveless Dr. Joseph M. Hendrie  ;

Sr. Resident Inspector 50 Bellport Lane e/o U. S. Nuclear Regulatory Comm. Bellport, NY l1713 ,

P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff f Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Street, N.W. Austin, TX 78756-3189 l Washington, DC 20036-5869 U. S. Nuclear Regulatory Comm.  ;

K. J. Fiedler/M. T. Hardt Attn: Document Control Desk City Public Service Washington, D. C. 20555-0001 P. O. Box 1771 San Antonio, TX 78296 -

J. C. Lanier/M. B. Lee J. R. Egan, Esquire City of Austin Egan & Associates, P.C. '

Electric Utility Department 2300 N Street, N.W.

721 Barton Springs Road Washington, D.C. 20037  ;

Austin, TX 78704  !

G. E. Vaughn/C. A. Johnson Central Power and Light Company P. O. Box 2121 i Corpus Christi, TX 78403  :

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The Light c o m p a n yS uth Texas Project E.lectric GeneratingP.station O. Box 289 Wadsworth, Texas 77483 Ifouston Lighting & Power March 28,1994 ST-HL-AE-4738 File No.: G26 10CFP.50.73

,r U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Unit 1 Docket No. STN 50-498 Licensee Event Report 94-008 Recardinc a Failure to Stancer Reactor Trin Breaker Surveillance Test Intervals Pursuant to 10CFR50.73, Houston Lighting & Power (HL&P) submits the attached Unit 1 Licensee Event Report 94-008 regarding a failure to stagger Reactor Trip Breaker surveillance test intervals. This event did not have an adverse effect on the health and safety of the public but clearly does not meet the standards for expected operational performance.

If you should have any questions on this matter, please contact Mr. J. M. Pinzon at (512) 972-8027 or me at (512) 972-8664.

. F. roth Vice President, Nuclear Generation JMP/ch Attaciuntut: LER 94-008 (South Texas, Unit 1) south Tetas Projec, os/2e ns a 12ami LO -94 \54 - o o n e . U1 Projnt' Manager on Echalf of the Participants

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l Ilouston Lighting & Power Company ST-HL-AE-4738 i South Texas Project Dectric Generating Stati File No.: G26 r Page 2  !

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i Ieonard J. Callan Rufus S. Scott  !

' Regional Administrator, Region IV Associate General Counsel i U. S. Nuclear Regulatory Commission Houston Ughting & Power Company 611 Ryan Plaza Drive, Suite 400 y P. O. Box 61067 i Arlington,TX 76011 Houston,TX 77208  ;

Lawrence E. Kokajko Institute of Nuclear Power k Project Manager Operations - Records Center l U. S. Nuclear Regulatory Commission . 700 Galleria Parkway i Washington, DC 20555 13H15 Atlanta, GA 30339-5957  !

David P. loveless Dr. Joseph M. Hendrie Sr. Resident Inspector 50 Bellport Lane i c/o U. S. Nuclear Regulatory Comm. Bellport, NY 11713  !

P. O. Box 910  :

Bay City, TX 77404-910 D. K.12cker l Bureau of Radiation Control  !

J. R. Newman, Esquire Texas' Department of Health j Newman, Bouknight & Edgar, P.C. 1100 West 49th Street j STE 1000,1615 L Street, N.W. Austin, TX 78756-3189 )

Washington, DC 20036  :

U. S. Nuclear Regulatory Comm. 'l K. J. Fiedler/M. T. Hardt Attn: Document Control Desk j City Public Service Washington, D. C. 20555 .l P. O. Box 1771 i

San Antonio,TX 782%

J. C. Lanier/M. B. Iee l City of Austin  !

Electric Utility Department j 721 Barton Springs Road  !'

Austin,TX 78704 G. E. Vaughn/T. M. Puckett Central Power and Light Company P. O. Box 2121 Corpus Christi,TX 78403

.a... a NRC F'ORM 316 U.S. NUCLEAR REGULATORY Ccact1SSION APPAOVED BY OMB NO. 3150-0104 (5 92) EXPIRES 5/31/95 ESTIMATED BURDEN PER FESPONSE TO COMPLY WITH LICENSEE EVENT REPORT (LER)

["M AP8"c E I E EEIA O2NG s"NE N hsTz dTE $c THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNEB 7714), U.S. frJCLEAR FEGULATORY COMMISSION.

(See reverse for required number of digits / characters for each block) S N, 2 55-0001 D TH WO MANAGEMENT AND BUDGF"$ WM H INGTON . DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)

South Texas Unit 1 05000 498 1 OF 4 TIT 1.E m Failure to Stagger Reactor Trip Breaker Surveillance Test intervals l l

EVENT DATE (5) LER NUMBER (6) l REPORT DATE (7) OTHER PACILITIES INVOLVED (3)

FACILITY NAME DOCitET NUMBER "o"Y" o^Y YE^a YE^^ **L"? "EE" "o"T" D^Y YE^^ 05000 FACILITY NAME DOCEET NUMBER 02 24 94 94 -- 008 --

00 03 28 94 05000 e-THIS REPORT IS SUDMITTED PUR8UANT TO TFE REQUIREMENTS OF 10 CPR Sa (Check one or more) (11)

CPERATING NODE (9) 20.402(b) 20.405(c) 50.73(a)(2)tiv) 73.71(b) 20.40b ta) (1) (1) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c)

LEVEL (10) 20.405(a)(1)(11) SU.36(c)(2) $0.7 3 (a ) (2 ) (v11) OTHER m,,.- +n% , . . , 20.40bta)(1)(111) y 50.73(a)(2)(3) $0.7)(a)(2)(v111)(A) U.pecify m Abstraes below aad

2 0. 4 0$ (a) (1) ( a v) 50.73(a)(2)(11) $0.73(alt 2)(v111)(B)

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LICENSEE CONTACT PCR THIS LER (12) 1 NAME TELEPHQNE NUMBLR (include Area Coce)

Jairo Pinzon - Senior Engineer (512) 972-8027 l COMPLETE ONE LINE FOR EACH swwu==.m. PAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUTACTURER CAUSE SYSTEM COMPONENT MANUFACWRER RD Oh

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On February 24,1994, Unit I was in Mode 1 at 7% power. While reviewing the performance history of the Solid State Protection System surveillance testing, it was determined that the reactor trip breaker surveillances associated with Technical Specifications 4.3.1 and 4.3.2 were not performed in accordance with Technical Specification requirements for staggered test intervals. This event occurred during the period in which the normal cyclic schedule was being re-established at the end of a long outage. The causes of this event were determined to be inadequate methods for assuring staggered intervals are restored following an outage and inadequate training of new Divisional Surveillance Coordinators. Corrective actions include conducting

^ training for responsible surveillance coordinators with scheduling responsibilities for surveillances with Technic.1 Specification stagger requirements and generating Conditional Surveillance Tasks in the Surveillance Task database for each division responsible for surveillance tasks subject to Technical Specification stagger requirements. These Conditional Surveillance Tasks will be required prior to increasing mode changes as appropriate.

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  • l RM 366A U.S. IfUCLEAR E.EGULATORY COpetM3ICBI APPROVED 50 0104 ESTIMATED BURDEN PER RESPONSE TO OMPLY WITH THIS LICENSEE EVENT REPORT (LER) ce s" "a f TEXT CONTINUATION wA g g n. 2 gss-o g g in ewog MA NAGEMENT AND BUDGET. WASHINGTON, DC 20$03.
  • FACILITY BIABEE (1) DOCKET afUBIBER (2) LER BEUISBER (6) PAGE (3)

EE AL R N vEAR South Texas, Unit 1 05000 498 2OF4 94 -- 008 -- 00 TEET (12 more space is required, use additional copies of NRC Forat 366Al (11l DESCRIPTION OF EVENT:

On February 24,1994, Unit I was in Mode 1 at 7Wpower. While reviewing the performance history of the Solid State Protection System functional test surveillance procedures, it was determined that although the subject surveillances were individually within their required intervals, they were not within the grace interval associated with the monthly stagger requirement of Technical Specification Table 4.3-1, Note 7 and Tabl . 3- 1 2, Note 1. Both of these notes state that "Each train shall be tested at least every 62 days on a STAGGEKdD TEST BASIS."

During normal operation of the plant, the stagger requirements are maintained via a combination of the  ;

standard cyclic schedule for surveillance testing, and calendar-based scheduling of surveillances subject to the stagger requirement (as opposed to frequency-based scheduling, which would permit some drift in schedult '

performance from cycle to cycle). The methods of ensuring that stagger requirements are maintained were ,

established following Unit 1 LER 88-040, which addressed a similar event (see discussion under Additional l Information below.) After outages, it becomes necessary to re-establish the surveillance schedule cycle m i order to re-establish the stagger.

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In early January,1994, it was determined the 84 day schedule for surveillance testing on Unit I would be re-established. Adherence to this schedule ensures that stagger requirements am maintained. In accordance with this schedule, the surveillances were scheduled for performance on January 23, 1994, which would have  ;

satisfied the required stagger interval. A few days before January 23,1994, a problem was identified with the i

subject procedures, and it was determined that they should not be performed prior to revision. The Surveillance database was checked and it was determined that the subject surveillances would not reach their " Dead Dates" l until March 10,1994. As such, the schedule was slipped by two weeks to allow time for procedure revision.  ;

It was not recognized that on February 8,1994, the grace period for the performance of either train of the ,

subject procedures based upon the stagger requirement would expire, violating the Technical Specification ,

stagger requirements identified above. The required schedule for resolving these procedural concems was not )

recognized, due to the perception that the surveillances could be performed at any time up to March 10 without i violating Technical Specification requirements. On February 22,1994, walkdowns of the proposed revisions  !

discovered more problems with the proposed changes, causing a further delay.

On February 24,1994, it was identified that the stagger requirements of Technical Specifications were not met and Technical Specification 4.0.3 was applied. At 1447 hours0.0167 days <br />0.402 hours <br />0.00239 weeks <br />5.505835e-4 months <br />, the NRC was notified of the failure to meet the stagger requirements of Technical Specifications. An evaluation of other surveillances subject to stagger requirements was performed, to ensure compliance with all stagger requirements. (Though some additional surveillance testing was conservatively conducted, it was determined on February 25, 1994, that no othe.

surveillances subject to stagger requirements had exceeded their grace periods). Changes to the four subject procedures were approved and made effective. Subsequently, on February 25,1994, at 0552 hours0.00639 days <br />0.153 hours <br />9.126984e-4 weeks <br />2.10036e-4 months <br />, all the required surveillances were satisfactorily performed. and the provision of Technical Specifications 4.0.3 were no longer applicable.

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LED-94\94-00Epo.UI

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F.m assa v.s. NUCI. EAR REQUI.ATORY COestIltSION I A m OVE 50-0104

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94 - - 008 - - 00 4 sxxt Uf anore space is required. use additional copies of b'RC Fom 166Al (11)

DESCRIPTION OF EVENT: (Cont'd) ,

As part of the investigation of this event, a review \vas conducted to determine whether other violations of Technical Specification Stagger requirements have occurred since June 24,1988 (the date of LER l-88-040).

This review identified two other occurrences where the Staggered Testing requirement was not satisfied as i Unit I came out of an outage. These occurrences were as follows: l

  • Following the third refueling outage for Unit 1, the SSPS Logic Train R Functional Test and the SSPS Logic Train S Functional Test surveillance procedures were performed on March 6,1991. The SSPS Logic Train S Functional Test surveillance procedure was next performed on April 23,1991, exceeding the permitted grace period by two days. 1 Following the fourth refueling outage for Unit 1, the SSPS Logic Train R Functional Test and the SSPS Logic Train S Functional Test surveillance procedures were performed on November 23,1992 and November 24,1992 respectively. The SSPS Logic Train R Functional Test was next performed on January 10,1993, exceeding the permitted grace period by two days.

All other surveillances subject to Technical Specification Stagger requirements were reviewed (72 Stagger Groups), and there were no other occurrences of a violation of Technical Specification Stagger requirements. I 1

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CAUSE OF EVENT:

The causes of this event are two-fold. The first was determined to be inadequate methods for assuring staggered intervals are reestablished following an outage; the second involves inadequate training of new Divisional Surveillance Coordinators. i l

l ANALYSIS OF EVENT: 1 I

This condition resulted in the violation of the staggered test basis for the Reactor trip Breaker surveillances as required by Technical Specifications which is reportable pursuant to 10CFR50.73(a)(2)(i)B). There were no adverse safety or radiological consequences as a result of this event. This event did not produce any additional risk to the public.

1.ER- 94 \ 94 - oo6Ro . U2

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HM 366A U.S. NUOLEAA LEGULATORY COMMILOION APPROVED 1 50-0104

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SEQUENTIAL REVISION YEAR " " *"

South Texas, Unit 1 05000 498 4OF4 94 -- 008 -- 00 TEET Ut note space is required, use additional copies of NRC Tosa 366Al (11)

CORRECTIVE ACTIONS:

The following corrective actions have been taken of will be taken as a result of this event:

1. As an interim measure, until the implementation of Corrective Action 4, the Plant Surveillance Coordinator will conduct reviews on a periodicity of approximately two weeks to ensure that Technical Specification Surveillance stagger requirements are maintained.
2. The Plant Surveillance Coordinator has conducted training for Divisional Surveillance Coordinators with scheduling responsibilities for surveillances with Technical Specification stagger requirements.

This training addressed details of STP surveillance program implementation relative to ensuring that Technical Specification Surveillance stagger requirements are not exceeded.

3. Conditional Surveillance Tasks have been generated in the Surveillance Tasks database for each division responsible for surveillance tasks subject to Technical Specification stagger requirements.

These conditional Surveillance Tasks are listed on the Mode Change Reports for Mode ascension up to Mode 3. The responsible surveillance coordinators will thereby be required to review the staggered i due dates for all Surveillance Tasks subject to Technical Specification stagger requirements prior to I each increasing mode change, as applicable.

4. A " Technical Specification Stagger Report," to be generated for responsible Surveillance Coordinator review on a periodic basis (e.g., biweekly) will be developed and implemented. The report will call I to the attention of the responsible surveillance coordinators the need to maintain Technical Specification i stagger requirements which are more limiting than the calculated " Dead Date." This action will be i completed by May 1,1994. j j
5. An interdepartmental Task Force will be formed to develop recommendations for improving the process l for replacing and training new responsible surveillance coordinators. Appropriate corrective actions  ;

I will be developed as necessary.

ADDITIONAL INFORMATION:

! There has been one previous reported occurrence of a failure to stagger surveillance test intervals per Technical Specification require nents, reported under LER l-88-040. That occurrence was attributed primarily to the use of frequency-based s:heduling rather than calendar-based scheduling for some of the surveillances subject to stagger requirements. Though the scheduling method was conected, the corrective actions for that Licensee l Event Report did not pmvide adequate controls to ensure that stagger requirements would be maintained while l

l the calendar-based stagger was being re-established following an outage. Since the time of the previous event, many enhancements to ti.e Conective Action Program have been made which minimize the potential for establishing less than a&quate conective actions. No corrective actions to the current Corrective Action Program are necessaiy as a result of this event.

1ER-94\94-00 BRO.U1

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