ST-HL-AE-4208, Provides Addl Info Re Events Leading Up to Declaration of TS 3.0.3 in Plant on 920519 & Presents Expanded Event & Casual Factor Analysis Including Addl Corrective Actions That Util Will Pursue in Conjunction W/Original Corrective Actio
| ML20127H013 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/11/1992 |
| From: | Hall D HOUSTON LIGHTING & POWER CO. |
| To: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20127G949 | List:
|
| References | |
| ST-HL-AE-4208, NUDOCS 9301220146 | |
| Download: ML20127H013 (32) | |
Text
{{#Wiki_filter:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ APPENDIX C The Light company' aesavi' P"""'* "'d'* *'"' 1 " i n a s 'F"P'">"'"""""" 11ouston 1.iewing & 1%.ce 1 eEP T 892 September 11, 1992 l ST-11L-AE-4 2 08 prGION IV File 11o. : G.25 10CFR50 Mr. J. L. Milhoan i Regional Administrator U.S. tiuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX. 76011 South Texas Project Electric Generating Station Units 1 and 2 Docket llo. STil 50-498, STil 50-499 Responses to Questions Raised at 111LC/JiL&l_}Mnacoment Meeti.nc of Aucust 28, 1992
Dear Mr. Milhoan:
This letter transmits additional information regarding the events leading up to the declaration of Technical Specification 3.0.3 in Units 1 and 2 at South Texas Project on May 19, 1992. Attachment A provides liouston Lighting and Power's (llL&P) response to specific questions presented by the !IRC-at the flRC/ItL&P Management Meeting conducted in Arlington, Texas on August 28, 1992. Attachment B is the original investigation results including an event and causal factor analysis. Attachment C provides expanded investigation results with more detailed information concerning this event. This letter also presents an expanded event and causal factor l analysis which includes additional corrective actions that liL&P will pursue in conjunction with corrective actions from the l original investigation. t During the discussion on August 28, 1992, concerning - this
- event, many questions and answers occurred in a-free flow discussion.
STP has reviewed that discussion and the questions as well as the incident itself to ensure that a complete-and accurate presentation of IIL&P's analysis of the event has been accomplished. Two expanded responses are provided to ensure that individual items included in the August 28,-1992, discussion are clear in the context of: (1) the event--itself, (2) the STP analysis, and (3) the -!!RC analysis. 9301220146 930115 i PDR ADOCK 05000498 L G-PDR ,3nbsidiary of flouuon induunes ineotperated
t l r llouston 1.ighting A Power Company ] South 'icm Projed ucctric Generating Station Page 2 ST-HL-AE-4208 File flo.: G.25 10CFR50 During discussion regarding when the Operations Department Manager decided that Technical Specification 3.0.3 was applicable to both units, a response was provided that this occurred at 1540 on May 19, 1992. The Operations Dopartment Manager was not at the 1400 mooting and review of the chronology with him corrects this to 1640 on May 19, 1992. During a discussion on what management guidance was in offect on May 19,
- 1992, concerning implementation of Technical Specification 3.0.3 requirements, the responso indicated that a procedure provided management expectations regarding involuntary entry into Technical Specification 3.0.3.
The management guidance in of fect was contained in a Plant Operations Policios and Practices standard defining management expectations regarding voluntary entry into Technical Specification 3.0.3 and restated the action requirements. The subject is clarified. in the operator initial and requalification training. The uno of the word "proceduro" in the discussion was nonspecific and in this case, inappropriate. Discussion during-the mooting-on August 28, 1992, covered the topic of responsibility of ensuring the technical and regulatory aspects of pursuing a Temporary Waiver of Compliance were addressed. This cubject needs further amplification to ensure that ilL&P management expectations are properly communicated to the NRC. !!L&P recognizes that teamwork must be encouraged in order to best utilize.the exportise of each functional group within :the organization, however, the teamwork must recognito the professional responsibility. boundaries of each functional area. In this regard, llL&P recognizes that one position within the organization should be _ designated to gather and evaluate the information to decide that the correct events occur prior to seeking a Temporary Waiver of Complianco from the NRC. The General Manager, Nuclear Licensing Will have the responsibility to collect this= information, evaluate l the-data against set criteria contained in a station proceduro, decido if pursuit of a. Temporary Waiver of Complianco-is appropriate, and then be 'responsibic for the verbal and written communication with the NRC if a Temporary Waiver of Compliance-is deemed appropriato for_ the-condition. The General Manager, Nuclear Licensing reports directly to the Group Vice President-Huclear, and as such, this assigned-responsibility can not be-overruled by any member of_ the Group Vice President-Nuclear's_ staff. The responsibility for decisions regarding operability and entry _into the Technical Specification limiting condition for operation has been and_ remains with the licensed operators on shif t. Functional organization elements, e.g.,- engineering, health physics, e t c.,- retain their responsibility for' areas of interest; this arrangement is analogous to the_ _ relationship ; of. a quality control and a ~ maintenance department _with their duality _ of responsibility for v. _ - - 4 ~.,wenen w., o,,,u,< w
Ilouston 1.ichunt A lher Com;9ns South Inn l'rogtt Elt(tot Writtanng Station Page 3 ST-llL-AE-4 2 0 8 File 11 0. : G.2L 10 CI'RS O The tJRC also indicated that it is possible that the engineers 1992, decided to delay informing either senior involved on May 18, management or the control rooms (shift supervisors) because the engineers did not have either the authority or desire to work overtime that night. IIL&P's investigation does not reveal any discussion, impression, or decision that any delay in
- thought, informing anyone was caused by a concern regarding overtime.
liL& P pursue this subject as part of an ongoing effort to did, however, improve coordination anr1 information flow between departments. This offort indicater fb when Plant operations representatives contact Engineering w wmont (i.e., manager to manager), engineering support in iL i n 2d in a timely manner in all cases. lack or sensitivity in engineering areas for There is, however, a the Operations responsibility for operability determination. Individual engineers are not always proactive or responsive to questions which originate in operations. A corrective action will be established which covers the department interfaces among operations, engineering and maintenance groups to improve coordination and communication. This incident was regrettable and is considered atypical of South Texas Project performance. The South Texas Project is proud of the steadily inproving station performance which stems from the dedication, and integrity of our people. The improving hard work, station performance is also a measure of our success in completing the transition from construction to an operational method of business. As the attached investigations show, this conducting incident revealed areas where this transformation was imperfect and the listed corrective actions will adjust these items. / / / all Group Vice President-tiuclear WJJ/jkf Attachments: Is) llL&P Response to Specific Questions raised by the !!RC at the August 28, 1992, meeting B) Station Problem Report 92-0201, Rev 0 C) Station Problem Report 92-0201, Rev 1
i ST-HL-AE-4208 - Houston 1.ighting A Power Company I South Texas Projht Electric Generating Station Filo !!o. :- G. 2 5 - Page 4 cc P l Regional Administrator, Region IV Rufus S. Scott -!!uclear Regulatory Commission Associato General Counsel 611 Ryan Plaza Drivo,-Suito 400 Houston Lighting & PoWor Company Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 George Dick, -Project Manager U.S. !!uclear Regulatory Commission INPO Washington, DC 20555 Records Contor 1100 circle-75 Parkway [ J. I. Tapia Atlanta, GA 30339-3064 [ Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrio Commission 50 Bollport Lano P. O. Box 910-Bellport, NY 11713' Day City, TX 77414 D. K. Lacker J. R. Newman, Esquiro Bureau of Radiation Control Newman &_ Holt:inger, P.C. Texas Department of Health 1615 L Stroot, N.W. 1100 West 49th Struct Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M. Puckett Contral PoWor and Light Company P. O. Box 2121 Corpus Christi, TX 78403 J. C. Lanior/M. B. Leo City of Austin e Electric Utility Dopartment P.O. Box 1088 Austin, TX 78767 K.- J. Fiedler/M. T. Hardt City'Public Service Board P. O. Box 1771' San Antonio,-TX -78296 Revised.10/11/91 L4/NRC/ >=----*eruf3- -r.tg-e+p e ry -+-=wp -ymq-wm'- W s penTi L-W-er-{r ip x1' i*-+9- -w'we@y- -q w we w-y+9T-'9
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ST-HL-AE-4 20 8 "11e No.: G.25 r ATTACllMENT A QUESTIo11R_lliO11._TJ1E_lildE/EEC__ MAN AGEMENT CONFERENCE _ llAv.Cd}wT 28, 1992 o i NHC question 1 At what time on May 18, 1992, did the individuals stop investigating the possibility that surveillance of the shunt trip circuitry had not been performed? !!L&P response The individuals stopped work at approximately 1740, May 1992. The basis for suspending the investigation was 18, the belief that the surveillance procedure satisfied the Technical Specification definition of TADOT (Trip Actuating Device operability Test) in that the procedure tested the trip functions, alarms and interlocks associated with the shunt trip relay. Clarification of any requirements involving the testing of individual contacts was to be done the following day. The issue of whether or not overtime should be worked did not arise and was not considered as the issue did not appear to be-a Technical Specification problem. NRC question 2 on May 18, 1992, did the individuals working on the shunt trip surveillance issue recognize the possibility that a plant shutdown might be required if the surveillance had not been performed? !!L&P response The System Engineers and_ Licensing Engineer involved'on May 18,
- 1992, were aware of the plant shutdown possibilities ir oosed by_ an inadequate surveillance of the Reactor Protection System. Ac stated in the response 3, their belief was chat the surveillance to question procedure appeared to satisfy the Technical Specification requirements.
Imc question 3 l~ When. and how did the Shift Supervisor or any Licensed first learn of the shunt trip surveillance Operator L testing issue? What did they learn-at that time? I PAGE 1 OP 3 _.-_,_.u.._._.._.- ~ c ..2
._._____.._.__.m..___ l i l ') i ATTACILMENT A l QUESILQJJS_ PROM THE llidfjURC MAllAGEMENT COliPEREllCE l gli AUGUST 28a 1992 P HL&P responso At approximately 0930, May 19, 1992, an associate of the System Engineer informed the Shif t Technical Advisor and I the Unit 2 Shift Supervisor that a potential issue involving reactor trip breakers existed. The individual 1 knew nothing more than that the issue involved testing i methodologies utilized when surveilling the shunt trip portion of the Reactor Protection circuit. NRC question 4 Is Generic Letter 85-09 referenced in the shunt _ trip-i surveillance procedure as it existed on May 18, 1992? Were the individuals who were-working on the issue aware of the applicability of Generic Letter 85-09 before the 1000 meeting on May 19, 1992? r HL&P responuo Generic Letter 85-09 was not referenced in the-surveillance procedure as it existed on May 18, 1992. No investigating ilL&P personnel were aware of the existence of Generic Letter 85-09 until research revealed a reference to it in the Safety Evaluation Report. The impact of the Generic Letter was realized at approximately 1345-on May 19, 1992. NRC question 5 Was the need to write a Station Problem Report (or the fact that one had _ not been -prepared) discussed at the 1000 Meeting on May 19, 19927 HL&P responso The 1000 meeting _ opened with a discussion about-the Station' Problem Report status-which was in partial draf t. lThe System Engineer felt that insufficient information L l-was available to L take - the issue to the control - room. L Meeting attendees agreed. A plan was - developed :and-immedia*.e ly implemented to determine regulatory requirements. l- .PAGE 2 OF 3 i
ATTACHNENT A QUf4T.LoiLS FROM TlilLlihEE/ffRC Mall &GEMENT CONFEEflLQE QLi AUGUST 28, 1992 NRC question 6 Did anyone from the control room (Shift Supervisor) attempt to contact station management regarding the shunt trip surveillance issue? If so, describe the circumstances and response provided. HL&P response The Unit 2_ Shif t Supervisor attempted to contact various managers on May 19, 1992. Station management was involved with the -Institute of Nuclear Power Operations evaluation and 'tas difficult to reach. Refer to Attachment C for details. NRC question 7 What procedural guidance regarding the implementation of. Technical Specification 3.0.3 was in effect on May 19, 1992? HL&P response A Plant operations Department Poli-y was_in effect that delineated managements expectations regarding voluntary entry into the Technical Specification and restating the action statement requirement. The policy did not address steps-to be taken following entry -into Technical Specification 3.0.3. . Training provided to Licensed Operators by the Nuclear Training Department implies that the operator has -one hour to prepare for a shutdown, commencing a power reduction after that hour. i NRC question 8 Describe the specific details. .of determining inoperability of the shunt trip _ circuit as pursued by the - Nuclear Licensing' and. Plant Engineering Departments. HL&P responso Rdfer to the event timeline provided--in-' attachment C. [ I Attachment C includes specific details 2 supporting-HL&P's response ( to the questions from-the NRC. It also addresses additional' facets of the May 19,-1992-event and.provides further corrective actions .to_be accomplished. _OF 3 PAGE 3 l fi t..
ST-E-M-4 2 0 8 W"TtsCllMimT p Pile No.t 1,25 ST ATIOfJ PHOut.EM REPohT 970201 EV E NI M M BlPllOlt On May 18.1992. at approumately 1700, a cyuern engmeer brought a potential oroblem with the testing of reactor trip circuitry to the attention of the Nuclear Licensing Department. The problem, detected during the biennial procedure review process, appeared to involve unteste contacts in the manual reactor shunt trip crrcuit. Further investigation was conducted and the Corrective Action Group (CAG) Administrator was informed at 0830 May 19,1992 that a potential issue with reactor trip breakers existed. The CAG Administrator mf ormed the Plant Manager and the Plant Operations Manager irnmediately folicwing the 0909 plan of the day meeting. A meeting was called at 1000 May 19,1992 to discuss results and additional avenues of investigation. Attendeesincluded representativesof the Plant Engineering Department, Design Enginer' ring Department, Nuclear Engineering Depar(mont, CAG and the Licensing Departmen Discussions f ocused on the technical aspects of circuit operation and the need f or testing. The conclusion was reached that these contacts should likely be tested, but more inf ormation was required to determine this' conclusively. The meeting concluded at 1200 with a decision to 1400, Efforts were directed towards determining the true requirements reconvene at pertaining to the testing of these contacts, and if these contacts had over been tested at South Texas Project. The Plant Manager was briefed by the Licensing Manager at 1200 May 19,1992, with regard to the likely problem with the operability of the reactor trip circuitry. The Nuclear Regulatory Commission (NRC) Senior Resident inspector was informed of the potential problem at 1230 and invited to attend the 1400 meeting. The meeting reconvened at 1400 May 19,1992, with the NRC Senior Resident inspector and Plant Manager present. Also in attendance were the Institute of Nuclear Plant Operations (INPO), independent Safety Evaluation Group (ISEG), CAG, Design Engineering. -Nuclear Engineering, Plant Engineering and Licensing personnel. (It is notable that no represent of Plant Operations Department was in attendance.) Discussion centered on the Technical Specification (T.S.) requirements regarding the testing of the contacts. The applicability of T.S. 4.0.3 was discussed,- but dismissed as the Licensing Manager concluded that the situation did not constitute a missed surveillance. A decision was reached at af f ccted circuit had not been tested as required by Technical Specifications and the plant was operating outside o_f the required boundaries, implying that T.S. 3.0.3 was applicable. The NRC Senior Resident inspector acknowledged this conclusion, and when queried about the status of when entry into T.S. 3.0.3 occurred, stated 1430. The Plant Manager agreed with this time.The NRC Senior Resident inspector lef t the meeting toinf orm Region IV of the event and.to it. form Nuclear Reactor Regulation (NRR) of a desire for a Temporary Waiver of Compliance. The meeting concluded at approximately 1450 with the Licensing Manager directing the issuance of a Station Problem. Report (SPR). The Plant Manager directed that the SPR be-delivered to the Plant Operations Manager with instructions to confer with him prior to informing the control rooms. The Licensing Manager and Plant Manager proceeded to the Group Vice President's office to brief him on the situation. The briefing concluded at approumately 1530. -Based upon the results of this meeting, South Texas Project management made the decision to pursue a Temporary Waiver of Compliance from the Technical Specihcations.
. - ~ - - - . - ~ ~. 1 i ST ATIOfJ PHoliti.M Gl POH19? 0201 I VUj L DT[,CHIPT IOr_JnCOf_J1'D j ,i A SPR was wotten by the system engmeet at 1520 and dehvered to the Flant fAanager. The j Plant fAanager and System Engineer gave the GPR to the Plant Operations fAanager at 1540 3 j enroute to the (JRC Senior Resident inspector's of fice. A conference call was held between the licensee, tJRR, and Region IV personnel to discuss the request f or a Temporary Waiver o Comphance. During the phone call, at approxunately 1600, the Plant Operations Manager i became concerned about the operability of the shunt trip contacts and contacted the Unit 1 j Operations fAanacer. The Plant Operations Department tAanager was still not aware that a decision had been made at 1430 regarding operability of the contacts. The conferenco call concluded and the licensee rnecting participants retired to the Plant Manager's of fico. A short discuss'an was held about the Plant Operations Department concern over the operabikty of the trip circuitry Dut this conversation was cut short due to a call to return to the NRC Senio Resident inspector's of fice. The group reconvened in the NRC Senior Resident inspector's office at 1615 for a seco conference call Attendecs included the Plant Manager, Licensing Manager, Plant Operation Manager and the Unit 1 Operations FAanager. The initial conversation involved a disc about the proper method for requesting a Temporary Waiver of Compliance and a concern over the licensco's apparent lack of preparation f or this request. The conversation then tu to plant shutdown status. At approximately 1630 statements made over the phone led Plant Operations Department representatives, attending the conference call to conclude th af f ccted circuitry had been declared inoperable at 1430. The Unit 1 Operations Manager le the meeting and discussed the problem with the Plant Operations Support Supervisor. At concluded Technical Specification 3.0.3 was 1640, the Plant Operations Department applicable and a shutdown of both units should commence immediately. i At 1650, the Unit 1 Operations Manager inf ormed the Unit 2 Shif t Supervisor of the proble and directed him to have the unit in mode 3 no later than 2130. The Unit 2 Shif t Superviso concurred with the need to shutdown, but disagreed with the target time for mode 3. The basis for this disagreement was the perception that Technical Specification 3.0.3 is no ef fect until the control room is informed. Upon completion of the discussion with the Shif t Supervisor, the Unit 1 Operations Manager contacted the Unit 1 control room an delivered the same message. At 1701 May 19,1992, the Unit 2 Control room declared entry into Technical Specificatio 3.0.3 and began to shutdown the unit at 15% power per hour. Unit 1 declared entry l l Technical Specification 3.0.3 at 1705 and began to shut down the unit at 30% per hour ( actual entry time for T.S. 3.0.3 was 1430 based upon Plant Manager acknowledgement) PORC convened at approximately the same tirne. The declaration of a Unusual Event place at 1706. At approximately 1745. the NRC granted a Temporary Waiver of Comphance to Techn Specifications regarding the 'eactor top circuit contacts. Shutdown of both units was terminated with power in both units at approximately 80% (NOTE: Based upon the dif f orence in core burnup between units,it took longer to achieve the desired ramp rate i J .1. Both units, therefore, stabih cd at approximately the same power i x-- -=
S1 AIlON PHollt.EM HI:POHi 92 0201 fMMI,YSfiDUMELL Several problems are identified as a result of tins evem, Ilicy are; Failure to initiato an GPR in a timely rnanner. Failure on the part of plant managernent to notify the control room of an operabilit determination. Confusion regarding the applicability of T.S. 4.0.3. Confusion over the proper methodology for obtaining a Temporary Waiver of Compli Confusion regarding the implementation of T.S. 3.0.3. Generic implications of this event include: A potential that other problems have not been, or are not being brought forwa A potential that other management actions may not be consistent with establ timely inanner. A potential that other Nuclear Licensing Department practices need to be forma standards. The potential that Plant Operations Department is isolated from other decisions. The significance of the failure to perform surveillanco testing as required by the The f ailuto to implement T.S. 3.0.3 does not Specifications is addrensed under SPR 92 0200. h represent a significant safety issue as the RPS Contacts in question were dstermin; multiple backup circuits thus allowing the NRC to grant a Temporary Waiver of Com The f ailure to notify the control room of the decision involving entry into T.S. 3.0.3 t ld potential safety significance. A decision of this type, mado under dif f erent conditi Operating Licenso. have an adverso impact with regard to the conditions of STPEGS CAUSES OF THE EVENT: P1 Failure to initiate a SPR in a timely manner. The desire on the part of plant personnel to clarify all f acts prior to informing the control room. Presentation of an SPR of this typo places the Shif t Supervisor in Cause: i ld the a position that f orces an operability determination. Additional f actors nc u e hesitance on the part of personnel to contact the control room prior to obtaining hard evidence of a problern. This hesitance is caused by a combination of discomf ort experienced by the initiator when confronted with dif ficult questions by the control room operators and animpatient behavior displayed by somo Pl Operations staf f when presented with unresolved problem reports.
~' - l ST AllON PROBil.M Hi!PUR192-0201 C Aj )'T ' Uf ) U! ! @!J L _JC or)t31} T he f ailure to notif y the control room of an operatnhty deternunatwn. P2 This involved a conscious decision on the part of the Plant Manager to withhold Cause: inf ortnation prior to the discussion of the issue with the NRC. The Plant Manager stated that the basis f or this decision was that the control rooin operators would He cornmence an immediate shutdown under Technical Specification 3.0.3. believed that the shutdown of both units would be an unnecessary transient on the units and the transmission grid. An additional contributor to this decision was the makeup of personnel involved in the rnectings preceding the operability determination. Five personnel with a Licensing background were present at various times during these meetings. This, coupled with a lack of Plant Operations Department involvement, led the group to a thought process oriented toward building a case for a Waiver of Compliance. The cenf usion regarding the determination of operability, applicability of T.S. 4.0.3, and P3 the dif f erent interpretation by the uruts of T.S. 3.0.3 entry requirements. The applicability of T.S. 4.0.3 in cases where testing has never been perf ormed Cause: Additionally, the requirements f or the declaration of is not defined at S.T.P. entry into T.S. 3.0.3 are not clearly defined. P4 The confusion regarding the methodology for obtaining a Temporary Waiver of coinphance. The Nuclear Licensing Department has no f ormal policy regarding the application Cause: f or a Temporary Waiver of Compliance. The ref erence used in this case was a memo dated June 20,1990 with a copy of the NRR Murley letter attached. CORRECTIVE ACTIONS: flefDC MI d R1 The Plant Operations Manager will develop written guidance regarding the implementation of T.S. 3.0.3 for approval by the Plant Manager. ~ Concurrence _jkw Due d M 9 %_ GlN. Midkit! C m r e c tivo The Corrective Action Group Administrator willinclude specific instructions dealing with C1 " potential operability" problems. and the inf orming of the Shif t Supervisor (s) as soon as possible on these items. in the new Corrective Action Process. p//f/J Z_ s J Q / Duo Concurrence Cy' {apidj~ mw " T. Bowman
i t ST ATIOtJ Pitoilt EM llCPOllT 92-0201 [ CDIUMCTIVF ARTlQDrdCrn31L The Plant Operations Manager will develop fortnal procedures or policies f or approval by C2 the Plant Manager which address the following; i Expected actions to be taken when unresolved problems are brought to the attention of the control room. l - Management expectations regarding operability determinations. - Clarification of the authority to mako operability determinations. - Processes involved with opc6 ability determinations. t - Clarification of the applicability of Technical Specification 4.0.3. Expected actions to be taken upon deterrnination of inoperability. f Clarification of T.S. 3.0.3 including the authority to declaro entry and the expected method of impicmentation. Duo 3 it 't Concurrence N $ N. Miqkitf f The Nuclear Licensing Department Manager will develop a formal proceduto governing C3 the processes involved with obtaining a Temporary Waiver of Complianco. ) M! A Duo 28 2 Concurrence W.J. Judp i The Vice President, tJuclear Generation will discuss the lessons learned from this event C4 with all licensed ooerators. O Qit. - i au-MN Duo M b W.7/81 kt1-Concurrence W.H. Kinsey *(s} The Director. Quality Assurance wiP valuate the generic implications involved with the - C5 timeliness of event reportmg. This evaluation will encompass a review of both open and - closed SPfl's with emphasis placed upon the timeliness of reporting and casos whero-reporting was intentionally delayed. This review will.bo done during the next Corrective Action Audit._ scheduled for completion on July 24.1992. i 214-l91 .d. Due Concurrence
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1 l 5 STATION PROBLEM REPOHT 92 0201 l r CDBJ1fC31YE.ACEOl M CfRL'!)L The Vice President Nuclear Generation will discuss this SPR at the bi weekly status of the role of the Shif t CG meeting to emphastre Executive Managernent's supportDepartinent Managers will be i Supervisor in making operability determinations. ~ instructed to discuss the contents of this meeting with their personnel. ?tft) N Due 4 'iL "s Concurrence _h([wQ W. H. KinsuYJ The Nuclear Licensing Department Mana0er will conduct a review of licensing pra C7 with emphasis placed on the need for formalizing similar documents. 7c1 7 hho 22 GA. Due Concurrence W, J. 06mt[] . CAj)JE TREND _CQQE/ PROB.1EM TYPE CODEt Cairso Codes 1. Failure to use IP 1.45 0 t Written Communications not used. HO1-A Failure to notif y the control room of an operability determination. 2. J Verbal Communications Untimely / Management Systems Evaluations LTA. HO2-8/HO5-D Confusion over the implementation and interpretation of T.S. 3.0.3 and 4.0.3. 3. T4aiesw3-Gordent-bT2/w c,.cgtManagement Systems Programs LTA. 4404 8 1 S,k g@ t Confusion over processes involved in obtaining of a Waiver of Compliance. 4. Management Systems Prograrns LTA/ Task Management Preparation LTA. HOS A/ HOG-A STot Codes Technical SpecificationrLicense Violation. 1. T14 - -, - - -....,=-- -,. -- -, ,,.=--,.,..:-
l l i j l l tii A IIOfJ l'140tlli M itEl'OltT 92 O201 A D.I)l T ID'.' / l _lf JJ O Rf.1/+ 110 t J; A review of previous Station Problern Reports indicates that the f ailure to initiate a problern document in a timely inanner has occurred recently as documented unitat SPR's #92 0128, Previous examples of f ading to inf orm the control 92-0154. 92 016,91-402 and 91-0049. 89 0711 and 88 0477. room of an operatnhty concern are docuinented under SPH's ( ~
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C4f C ui o f ,,ta g O ( S!a [a, CNP clg n C WR aCt E f a "" T w R CSL aC a E C iN(5 FSU n( v { +A T l a. a iW *. eT*4 E( aP ' i v r e A. L E c(s a Rt h{ r $(u SOC e i5S' H n tO t r C ( r0 $0 - (' L x 4 i 1 4 l? =j,)gsj j;Ti[i !i'7lrlli !;f. I l i, ~ e IIME LINE 'AONDAY MAY 18 1500 A Systern Engineer (SE), while perf orming a biennial review, discovered that a portion of the shunt trip circuit may not be tested per Tech. Spec. requirements. Discussed issue with his management. Discussed issue with Licensing. SE noted that =1700 the review was cor'inuing. SE decided that there was high potential that a TUESDAY MAY 19 0800 problem existed. Contacted othcr personnel to attend meeting. CAG informed of problem via Licensing 0830 0940 CAG informs the Plant Manager and Plant Operations Manager that a potential problem exists. 1000 Meeting on subject initiated. Attendecs: Jump Blinka Harrison Riccio Mulligan Schoonover Stansel Head Crawford Hales it was decided, based on the information available, the circuit should be tested. However, it could not be agreed whether it was tenuired to be tested. Three courses of action were proposed. Group was to meet again at 1400 Contact Westinghouse Review relevant WC AP in detail Review maintenance records to see if circuit was tested independently of T. S. surveillance - 1200 Plant Manager brieled on situation 1230 NRC Senior Resident inspector-infortned of potential problern. Personnel gathered f or second meeting. Also in 1400 Plant Manager, INPO, ISEG, attendance were: NRC Senior Resident inspector. Af ter presentation of results of investigation it 1430 was concluded that it was not possible to conclude that the shunt portion of the reactor trip circuitry was operable since one portion had not been completely ~ tested. Plant Manager states that the station is not in compliance with Technical Specifications. 'NRC Senior Resident inspector concurs and states, timo 1430. 1435 NRC Senior. Resident inspector leaves the d meeting to. brief Region IV of.pending_ waiver request. Personnelin the meeting began building. case for Waiver of Compilance.- Licensing Manager directs issuance of a Station 1445 Problem Report. Plant Manager directs Ed Stansel to have the 1450 Problem Report delivered to the' Plant Operations-Manager with instructions to discuss issues with the Plant Manager before calling the Units. '1500 'Wisenburg and Jump briefed Group Vice President on situation, i-b SPR.given to Plant Operations Manager, =1540 4 d a
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+,, ,,,v.,,#-,% ,v ,~,4.---c,E,--y,E e,, y,. -c- ,,,y Met in the Resident inspector's of fice to conduct 1540 conference call with Region IV and NRR for purpose of oral waiver request. Attendees included Wisenburg,- Jump, Harrison, Midkiff, NRC Senior Resident and Resident. 10 minuto delay NOTE: There was a awaiting phone connection. Plant Operations Manager requests that the Unit =1600 1 Operations Manager come to the conference call. End of conference call and reconvene in Plant 1605 Manager's office to await NRC response to waiver request. Plant Operations management begins to question the operability of the contacts. All parties are notified to return to the 'NRC 1610 of fice, Phone call with NRC to further discuss contents 1615 of waiver and commitments. Attendeesincluded Wisenburg, Jump, Midkiff, McCallum, Harrison, NRC Senior Resident inspector and. Resident-Inspector. Discussion held between NRR and Plant Manager _- 1G25 pertaining to the requirement to_ convene PORC - prior to requesting a waiver. l State _ ents made during the conference callalert- =1630 m l Plant Operations management that operability'is [ indeterminate, and that contacts were declared-inoperable at 1430. Plant Operati_ons management decides that Tech. l 1640 Spec. 3.0.3 is. applicable. Unit 1~ ' Ope' rations: Manager exits meeting. E u- "1650 Meetino ends with the direction to convene PORC. Unit 1 Operations Manager contacts the Unit 2 control room to discuss the situation. "1655 Unit 1 O'perations Manager contacts Unit 1 control room to discuss the situation. Unit 2 control room enters Tech. Spec. 3.0.3. 1701 PORC Meeting started 1705 Unit 1 control room enters Tech. Spec. 3.0.3. 1706 Unusual Event (UE) declared 1730 NRC informed of UE 1735 PORC meeting concluced =1745 NRC contacted regarding results of PORC meeting. NRC grants Waiver of Compliance, 1751 Unit 1 terminates shutdown. 1752 Unit 2 terminates shutdown. 1753 UE terminated. 1754 NRC notified that UE terminated. ~ co. m A n, <, ; a ,u: u,c waw numcu,m mosuim S T A T I O N P R O B L E M., 1.yr'. Met e -REPORT y AM - Of _ _ ,/
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4 NO110C At10H DETERM*4 AllCN~ TECH SPEC, ACT10NS y G (ciRCtc o,4c) g 0 noi RcoviRto 3Co (ig.3.*ao) nicocot y ,/3 Nt[D TURTHER INFO /REVEW COMMEN15: C NRC CAttID (O A1C /Duf) u. 5 0 otutR (Pt uca.. t-et u4. c tC) g,-3, _jd om y t ASSiCHvlN I. DUE. PCPOR T Atiot y R[V[W AMIGNf D 10. DUC / f.fE .bb_. ~ .9 W m rN Eg O 'NW tT1G AliON A55t(>41D 10 _ cceJM(HIL __ _ j/ y bM D Att d' JD SPR COCfD:k N.} T]( 0 t NE HI PORIAt%[' - ,ggggg ggg,gpg g(gggg7 ] gg DUO "O O coi 10 Oto[RS (twC. Cic) ct DuE,_ _ 0 1cs t c /no c' W "Ly d Tl ol% Dee w Ccma 1 ST-HL-AE-4208 File No.: G,25 ATTACHMENT C STATION PRODLEM REPORT 92-0201 REV.1 request by the Nuclear Regulatory Commission (NRC), Pursuant to a further investigation into specific event detalla has boon conducted. Questions regarding five specific areas were prosented by the NRC: Area 1 1992, did the individuals At what time on May 18, overing the problem stop investigating the-possibility dithat the shunt trip circuitry had not boon adequately tested? What was the basis for stopping work on the ovening of May 18, 1992, vice continuing the investigation to its conclusion?
- Was a desiro to avoid overtino a factor in the decision to delay the investigation until the following day?
- Did the individuals involved with the investigation recognize the potentiel ramifications of this issue (with regard to plant shutdown) on May 18, 19927
- Woro the individuals involved on May 18, 1992, aware of tho
.l applicability of Generic Letter 85-09 (specifying'the to independently test the contacts) on issues requirement involving Reactor Protection System testing?- In Genoric Letter 85-09 referenced in the shunt trip
- surveillance procedure as'it existed on May 18, 1992?
Area 2 When and how did the Shift = Supervisor or any Licenced
- Operator first 1 carn of the shunt trip surveillance issue?
- What was the nature of the information that was convoyed to the Licenced operators?
- Did any Licenced operator attempt to contact _tho. Plant Manager regardingLthe shunt trip surveillanco issuo?
- -What were the circumstances and timing of.any attempt to contact the Plant Manager?
Area 3 Was the need to writo a Station Problem Report (or a concern that one had not been written) discussed at thcl1000 meeting.on-May 19, 1992? PAGE 1 OF 6- ..m .__ _ _m _ _ -. t STATION PROBLEM REPORT 92-0201 REV. 1 f Area 4 What procedural guidance regarding the implementation of
- Technical specification 3.0.3 was in effect on May 19, 1992?
Area 5
- What are the specific details of determining the inoperability of the shunt trip circuitry as pursued by the Nuclear Licensing and Plant Engineering Departments?
Il{VJSliqATION RESULTS: Area 1 The System Engineer (SE) discovering the problem approached 1992. his'immediate supervisor at approximately-1530, May 18, The Engineering Supervisor directed the SE to contact the Nuclear Licensing Department for an additional opinion. The SE then decided to approach an Electrical Engineer (EE) at approximately 1700, May 18, 1992. Upon review of the procedure and associated drawings, the EE concurred with the concern-of-the SE that this specific surveillance procedure did not test individual contacts. Both individuals wore-aware that failure to adequately test the shunt trip circuit could-constituto a situation requiring a-plant shutdown. The EE considered this procedural enhancement issue vice a plant-be a problem to issue due to his interpretation of the definition of impact in that-the-(Trip Actuating Device Operational Test) TADOT surveillance in question tested the trip function, alarms and interlocks associated with the shunt trip circuitry. Neither individual had any knowledge of the existence ' of Generic _ Letter 85-09 or the Safety Evaluation Report referencing.the Generic Letter on the evening of May-18, 1992. The surveillance procedure in question did not list Generic Letter 85-09 as a reference. The SE then proceeded-to the Nuclear Licensing Department and l informed a Senior Licensing Engineer (SLE) about his concern and-the opinion of the EE. PAGE 2 OF 6 _ - -~- - k L DTATIoN PROBLEM REPORT 92-0201 REV. 1 JRVlDILG ATJ&lLRES U LTS c o n t inupdi. Area 1 cont. Senior Licensing Engineer was aware that the failure to The the Reactor Protection System could result in properly test situation that would require a plant shutdown. A decision awas made at approximately 1730 that while-the SE's concern was valid,_ the Technical Specification requirements wore technically satisfied by meeting the definition of TADOT. Utilization of overtime was not discussed as the problem did not appear to warrant it at the time. All parties concluded work for the evening at approximately 1740. r Area 2 The information relayed to the Shif t Supervisors of Unit 3 and 2 was in the form of rumor prior to the official notification from the Unit Operations Manager. The first information was received at approximately
- 0930, May 19,
- 1992, from an associate of the SE. The associate was conducting business in the Unit 2 control room and told the Shift Technical Advisor (STA) and Shift Supervisor that'a potential issuo existed involving the methodology of testing the shunt trip portion of the Reactor Trip circuitry. The individual did not know any additional information and this issue was dismissed as rumor.
The assumption was made by the Shift Supervisor that the control room would be notified in the event that an operability concern surfaced. During the -- time that
- followed, additional rumors (ie.
maintenance workers) began to surface in both_ Unit 1 and 2 i control rooms. The Unit 2 Shift Supervisor. attempted to. i contact the Unit Operations Manager '_to no' avail. The_ vast majority of managers were involved in support of an evaluation i being conducted by the Institute of Nuclear Power Operations and wore, therefore, difficult to reach. The Unit 2 Shift Supervisor then conversed with the Unit 1 Shift Supervisor in order to obtain information about the issue. The Unit 1 Shif t Supervisor had no additional information and was involved with a technical issue of a different nature-proventing him from devoting attention to the rumors. The agreement'was made that the Unit 2 Shift Supervisor would pursuo the rumor, allowing ~ ~ the Unit 1 Shift Supervisor to continue work on his problem. At approximately 1605, May 19, 1992, a Work Control Conter employee contacted both control rooms to talk about an impending shutdown. The Unit;1 Shift Supervisor.wasl ' alarmed by this conversation and immediately attempted to contact Plant Operations Department Management. PAGE 3 OF 6 m,- +..- ,,m,-- ,9-,,,,.-r -wg. , _ + -,,, y -y ,%_._,.---..e-r.m.e,.r.--..,-wm.,,,,,,e. --+,.-,n STATION PROBLEM REPORT 92-0201 REV. 1 d 11LVlinT1GATLO1U11;SUIml_santimi i Area 2 cont. The Plant Operations Support Division Supervisor was contacted shift Supervisor at approximately 1620 but had by the Unit 1 The Unit 2 Shift no knowledge of the existence of a problem. Supervisor attempted to contact the Plant Manager at 1625. The secretary receiving the call explained that the Plant Manager was in a very important meeting but offered to interrupt. The Unit 2 Shif t Supervisor opted to have the Plant Manager return his call as soon as possibic. The meeting referred to is the 1625 conference call to the Nuclear Commission. The Plant Manager had no chance to Regulatory return the Shif t Supervisor's call bef ore the Unit operations Manager notified the control rooms about the Technical Specification 3.0.3 cituation. Area 3 At approximately 0800, May 19,1992, a third engineer was asked to review the details of the shunt trip circuit. His review and discussion with the SE prompted the SE to begin drafting a Station Problem Report. While writing the report, the SE became concerned that there was insufficient detail surrounding the testing methodology requirements. This lack of detail would result in placing the Shift Supervisor in a situation that required answers that the SE did not have. The SE then contacted his Supervisor and the Senior Licensing Engineer in order to set up a meeting. The meeting began at 1000, May 19,1992. Discussion initially contered around the fact that the SE did not fool that he had sufficient to the Shift information to take the Station Problem Report The attendees agreed with this statement and at Supervisor.during the meeting collectively decided that the one point issue was not a problem due to the TADOT definition. The SE continued to express concern and an action plan was developed to pursue the regulatory basis for testing requirements. Area 4 The Plant Operations Department Policies and Practicos Manual 1992 provided the only guidance in effect during the May 19, Although this policy provided management expectations event. regarding the voluntary entry into Technical Specification 3.0.3 and restated the action requirements, it did not provide specific implementation steps to be taken following entry into the Technical Specification. Training provided to Licensed Operators by the Nuclear Training Department implies that the operator has one hour to prepare for a shutdown and commences power reduction at the end of the first hour. PAGE 4 OF 6 ~ - - - - -. r STATION PROBLEM REPORT 92-0201-REV. 1 1[Gf2TIGATION RESULTS continued: Area 5 specific details of the inoperability determination are The provided in the attached event timeline. The major contributor to the decision to delay pursuit of the issue into the evening of May 18, 1992, was the belief that the definition of TADOT was satisfied. ~ The discovery.of Generic Letter 85-09 on May 19, 1992, prompted the licensee to take action based ~on the requirement that independent testing' of the shunt ' trip contacts he performed. &NALYSIS OF THE EVEJJT: The analysis of the technical issue surrounding testing of the contacts is described in Station Problem Report 92-0200. Analysis the circumstances surrounding the Plant Manager's decision and ofthe application for a Temporary Waiver of Compliance are included in Rev. O of this Station Problem Report. Further investigation into the generic implications identified in the body of Rev. 0 indicates that a more fundamental problem exists. While it is true that the Plant Manager failed to inf orm the control room-of an operability concern, it is also true that approximately twenty other individuals had the opportunity to do so at various times during the event. Additionally, the results of an internal potential problem exists with intra-evaluation indicate that a organizational communications. EVENT CAUSE: Event causes are discussed in Station Problem Report 92-0200 and 92-0201 Rev. O. The cause of the generic problem with licensed operator notification is attributed to a cultural failure to fully. transition from a construction based philosophy utilizing' Nuclear Licensing for all regulatory requirement decisions to-an organa ation. In ' tais particular case it is evident-operational that station persor, el are still reliant on the Nuclear Licensing i for resolution of potential operLbility concerns. This. Department l reliance is inconsistent with the expectations of HL&P management regarding the role of the Licensed Senior Reactor Operator as the Given the individual responsible for making such determinations. nature and scope of this particular event it is apparent that other l ' departments and organizational interfaces have not f ully developed l L to the peint where the Licensed Operator is the sole' point of I contact for all operability" issues. l l h PAGE 5 OF 6 ~.. -.~.-.. - -... - - ~ ~ STATION PROBLEM REPORT 92-0201 REV. 1 COJtRECTIVE ACTIONS: R_emedial R2' An internal evaluation-of operational suppori has been ' e results of conducted by the Nuclear Assurance Departmen'. this evaluation have been incorporated into es + active action C9. Corrective The General Manager, Nuclear Assurance will obtain the C8 services of an independent Industrial Psychologist to assist in resolving organizational interf ace / communications problems Priority associated with the support'of Licensed Operators. shall be directed at those elements that detract from making timely operability deci n07s.
- W Due
/6 d Concurrence Tp/di-dan The results of this offort will be incorporated into C9 action plans that encompass the following: 4 Specific educational attributes regarding the proper
- identification and resolution of problems, will be incorporated in generic station training programs such as General Employee Training and Management and Technical Staff.
training. Due- / I 3 Concurrence I W.H. KinQ)y Efforts-to improve coordination in communications between
- site organizations will be pursued'. The Plant Operations Department and Engineering Department interfaces will'be emphasized.-
/b d i Concurrence / t% _- Due g,_J'. Jordan PAGE 6 of 6 p 5'-... y y m y . ~..,,. - J. +n.,.u
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