ST-HL-AE-4217, Provides Clarification of Apparent Inconsistencies Identified by Staff Re Info Provided in 920828 Mgt Meeting & Ltr from Dp Hall to Jl Milhoan
| ML20127H034 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/18/1992 |
| 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-4217, NUDOCS 9301220151 | |
| Download: ML20127H034 (4) | |
Text
_
Do/19/92' 15:33 5129728298 002
,.3 APPENDIX D The Light c o mp a n y '"'" '"*' ""')"' """" "*"""8 """
" ' " ' " " " * * *d'" "h T'* *' r r 4 a s liou. ion ti uing & Power t
September 10, 1992 ST-IIL-AE-4 217 File No.: G.25 10CFRSO Mr.
J. L. Milhoan Regional Administrator U.S.
Nuclear Regulatory Commission Region IV 611 Ryan Piar.a Drive, Suite 400 Arlington, TX 76011-90G4 South Texas Project Electric Generating Station Units 1 and 2 Docket No. STN 50-498, STN 50-499 Clarification of Information Provlied in sentenher 11. 1992. Corresppadence Dear Mr. Milhoani This letter provides clarification of apparent inconsistencies identified by your staff regarding information. provided in the md n og ernen t rneu ting of August 28,
- 1992, and the letter from Mr.
D.P.
Hall to Mr.
J.L.
M11hoan dated September 11, 1992.
Apparent Inconsistency 1)
HL&P's presentation led the NRC to believe at the NRC/11L& P Management Conference uti August 28, 1992, that the basis for the system Engineer's decision to discontinue the investigation on the evening of May lo, 1992, was that the issue was of low safety significance _ and the individuals were i
2 unsure of Technical Specification applicability. This appears Lu be inconsistent with the in fo rmation provided in the correspondence of September 11,-1992, i
Responset The individualu involved with the issue on the evening of May 18,
- 1992, were under the impression. that the Technical-specification definition of TADoT (Trip Actuating operational Test) was satisfied.
This led them to believe that the issue was of low safety significance.
The system engineer was still dissatisfied-with the surveillance proceduse testing methodology regardless of compliance with the spirit-of Technical Specification requirements and au such the parties were unsure of Technical Specification applicability tcegarding his concern.
Refer to Attachment C (page 2 of 6,
cres 1) of the September 11,
- 1992, correspondence for additional ciarifinntian.
A O
90 N Subudian.s or lionsoni in.wirie, toeorpormed
,R
09/18/92 15:34 5129729298 003 livuston Lighting & Powcr Company South Texas Project Electric Generating Station Page 2 ST-HL-AE-4 217 File No.: G.25 10CFR50 HL6p's investigation revealed that no individual involved with the issue on the evening of May 18, 1992, had knowledge of. the requirements of Generic Letter 85-09.
There was no reason to censider the utilization of overtime as the surveillance procedure in question tested the trip function, alarms and interiptks of the shunt trip circuit.
In the minds of the individuals involved on the evening of May 18,
- 1992, operability of the shunt trip circuit was not in question.
No discussion was held concerning overtime nor was the monetary corpensation for, ur restrictions on the utilization ur overtime an issue in this decision.
Apparent Inconsistency 2)
HL&P's presentation at the NRC/HL&P Management Conference on August 28, 1992, was that procedural requirements governing Technical specification 3.0.3 contributed to the decision making process of the Plant Manager.
This-10 inconsistent with information provided in the correspondence of September 11, 1992.
Responnes The September 11, 1992, correspondence cover letter addressoa the issue on page 2 of 4.
The une of the word " procedure" during the conference on August 28, 1992, was inappropriate since the guidance being utilized un May 19, 1992, was from interpretation of the Technical-specirleation and operator training.
Two additional points of clarification were raised during the September 17, 1992 phonc call.
Clarification 1)
The NRC was unaware that a Station Problem Report existed at-1000 on May 19, 1992.
Response
HL&P's presentation at the NRC/HL&P Management conference on '
August 28,
- 1992, was based upon the results of the investigation documented in Station Problem Report 92-0201.
Station Problem Report 92-0201, identifies that a contributing factor to the delay in informing the licensed operators was a hesitance on the part of the system Engineer to take a.less than completely derined problem to the control' room.
Attachment C (page 4,
area 3) of the September 11,
- 1992, correspondence, details the decision making process.
- _ --_~
- i 09/18/92 15t34 5129729298 004
. N j
!!ounon Lighting & Power Company South Tezu Projut Eintric Cencratin5 t'ti "
pg 3 S
ST-ilL-AE-4 217 File No.: G.25 10CFR50 1
!!L&P clarifies that the Station Problem Report was in a partial draft forra during the 1000 meeting on May 19, 1992, and remained in this status until the Licensing Manager i
directed that the Station Problem Report be delivered to the control room at 1445 on May 19, 1992.
IIL&P reiterates that corrective actions have been, and will be emphasized to l
prevent recurrence of this event.
Clarification 2)
The NRC is concerned that the control room personnel may have acquired sufficient knowledge of the issue to take action prior to 1655 on May 19, 1992.
Response
The control room operators received only rumor based information during the day on May 19, 1992.
The Licensed Senior Reactor Operators made efforts to obtain information about rumors of a problem.
The assumption was made based upon previous experience that management would inform the control room if a real issue existed.
In this particular event, control room notification did not occur until 1G55.
IIL&P management expectations in this regard were not achieved;.they will be reemphasized.
Any issue involving the operability of equipment must be brought to the attention of the Licensed Senior Reactor Operator on duty.
Refer to Attachment C (page 3,
area 2) for details.
Although no NBC inquiry has been made, a separate letter will be originated by September 30, 1992, further ' defining IIL&P management emphduis on the line management responsibility for the conduct of plant upuration as opposed to the staff or review function of the Liccnoing staff.
Houston Lighting and Power ( HL& P) has attempted to ensure that an occurate description of events has been developed regarding this issue and the events that occurred on May 18 and 19, 1992.
HL&P will provide amplifying clarification upon notification of any other apparent inconsistencies.
Hall Group Vica' President, Nuclear WJJ/Tkf
09/18/92 15:35 5129728298 005
.,g, Houston Lightin5& Power Company ST-HL-AE-4217 South Texas Project Electric Ococrating Station File No.: G.25 Page 4 cc:
Megional Adminintrator, Region IV Rufus S.
Scott Nuclear Regulatory Comminaion Associate General Counsel 611 Ryan Plaza Drive, suite 400 Houston Lighting & Power Company-Arlington, TX 76011.
P.
O.
Box 61867 Houston, TX 77208 Guorge Dick, Project Manager U.S.
Nuclear Regulatory Commission INPO Washington, DC 20555 Recordo Center 1100 Circle-75 Parkway J.
I. Tapia Atlanta, CA 30339-3064 Senior Resident Inspector c/o U.
S.
Nuclear Regulatory Dr. Joseph M.
Hendrie Commission 50 Dollport Lane P.
O.
Box 910 Bellport, NY 11713 Bay City, TX 77414 D.
K.
Lacker J.
R.
Newman, Esquire Dureau of Radiation Control Novman & Holtzinger, P.C.
Texas Department of Health 1615 L Street, N.W.
1100 West 49th Street Washington, DC 20036 Austin, TX 70756-3109 D.
E. Ward /T.
M.
Puckett Central Power and Light Company P.
O.
Box 2121 Corpus Christi, TX 78403 J.
C. Lanier/M.
R.
Lee City of Austin Electric Utility Department l
P.O.
Box 1088 Austin, TX 78767 K.
J.
Ficdicr/M. T._Hardt City-Public Service Board P.
O._ Box 1771 San Antonio, TX 78296 l
Revised 10/11/91 L4/ NRC/