ML20198M420

William Bill Sprinkle, Response to Apparent Violation, IA-20-018

ML20198M420
Person / Time
Site:	Watts Bar, Sequoyah
Issue date:	07/08/2020
From:	Phillips S, Sprinkle W - No Known Affiliation, Stevie Phillips Law, PLLC
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IA-20-018
Download: ML20198M420 (19)

Text

STEVIE PHILLIPS LAW I EE 1253 MARKET ST., STE. 100 CHATTANOOGA, TN 37402 STEVIE@STEVIEPHILLIPSLAW.COM (423) 645-7734 July 8, 2020 NRC Document Control Center United States Nuclear Regulatory Commission Washington, D.C. 20555-0001

.\TIAU. S...MAIL RE: William "Bill" Sprinkle, Response to Apparent Violation, IA-20-018

Dear United States Nuclear Regulatory Commission:

As you may know, I represent Bill Sprinkle, former Manager" of Plant Shift Operations at TVA's Watts Bar Nuclear Plant. Mr. Sprinkle's Response to Apparent Violation, IA-20-018, is enclosed. Mr. Sprinkle is accused of violating the NRC' s rule prohibiting deliberate misconduct, 10 C.F.R. 50.5, 1 by processing a revision to Step 5.2, 1(8] of TVA General Operating Instruction l-G0-1, "Unit Startup from Cold Shutdown to Hot Standby," as "minor/editorial" knowing, allegedly, that it did not meet the criteria for "minor/editorial."

The NRC has set a high bar for allegations of deliberate misconduct. When promulgating 10 C.F.R. 50.5 in 1991, the Commission explicitly stated that the deliberate misconduct rule applies only to individuals with the "intent to act in a wrongful manner." 2 The Commission also made clear that the deliberate misconduct rule "does not apply in cases of negligence, honest mistake, or ignorance,"3 or in cases where people may have made mistakes while acting in "good faith." 4 The Commission further wrote that 50.5 does not include acts done in careless disregard for requirements; rather, 50. 5 is a "narrower" rule that applies only to deliberate misconduct. 5 Indeed, the Commission wrote that, under the deliberate misconduct rule, "the range of actions that would subject an individual to action by the Commission does not differ significantly from the range of actions that might subject the individual to criminal prosecution."6 1

10 CY.R. 50.5(a)(l) prohibits an employee of a licensee from engaging in "deliberate misconduct that causes or would have caused, if not detected, a licensee or applicant to be in violatio_n of any rule, regulation, or order; or any term, condition, or limitation of any license issued by the Commission." Deliberate misconduct is "an intentional act or omission that the person knows: (I) Would cause a licensee or applicant to be in violation of any rule, regulation, or order; or any term, condition, or limitation, of any license issued by the Commission; or (2) Constitutes a violation of a requirement, procedure, instruction, contract, purchase order, or policy of a licensee, applicant, contractor, or subcontractor." 10 C.F.R. 50.5(c).

2 56 Fed. Reg. at 40,679.

3 56 Fed. Reg. at 40,675.

4 56 Fed. Reg. at 40,681.

5 56 Fed Reg. at 40,675.

6 56 Fed. Reg. at 40,675.

Given this narrow set of circumstances in which the Commission intended the ".deliberate misconduct" rule to apply, the standard for deliberate conduct is exceedingly difficult to meet.

Accordingly, the "deliberate misconduct" rule should be reserved for cases that can be established by clear and convincing evidence that someone contemplated an action, knew it would cause a violation, and did it anyway. As Mr. Sprinkle's letter demonstrates, his actions do not come close to meeting this standard bec~use he lacked the "knowledge" that he "would" cause a violation, as required for liability under Rule 50.5. As Mr. Sprinkle readily admits, he simply made a mistake.

• Mr. Sprinkle's willingness to take responsibility for his mistake is characteristic of his personal and professi_onal integrity. Mr. Sprinkle did not retain me until January 2018, well after fully cooperating in at least five interviews related to this investigation.7 We have gotten to know each other well over the past two and a half years. Mr. Sprinkle is a modest man with a strong work ethic and a reputation for honesty. He takes a great deal of pride in having been a TVA manager who his colleagues could rely on to the do the right thing and who would take ownership of his mistakes as well as the mistakes of his team. Not surprisingly, it is deeply upsetting to him to be accused of deliberate misconduct after a long and dedicated career.

In closing, I recognize that this case required a lengthy and fact-intensive investigation by the NRC and other entities. I appreciate the NRC Office of Enforcement staff and Senior

/ Attorney Marcia Simon for their timely responses to calls and emails as we attempted to determine how COVID-19 would impact the NRC' s regulatory process.

Thank you for your careful consideration of Mr. Sprinkle' s response. Please do not hesitate to contact me directly if you have questions or require additional information.

Sincerely, S1I'EVIE PHILLIPS LAW, PLLC Enclosure CC: Kenneth G. O'Brien, Director Division of Reactor Safety United States Nuclear Regulatory Commission, Region III 2243 Warrenville Road, Suite 210 Lisle, Illinois60532-4352 kenneth.obrien@nrc.gov 7

Mr. Sprinkle retained me upon receiving a subpoena to testify before a federal grand jruy. Subsequently, the United States Attorney's Office for the Eastern District of Tennessee informed me via letter that Mr. Sprinkle was merely a witness and not a defendant or putative defendant in their criminal investigation. They also decided not to call Mr.

Sprinkle to testify as a witness before the grand jury.

2

VIA U.S. MAIL AND ELECTRONIC MAIL 3

July 8, 2020 NRC Document Control Center United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 SENtVIA U.S. MAIL RE: Response to Apparent Violation, IA-20-018

Dear United States Nuclear Regulatory Commission:

I am writing in response to Apparent Violation ("AV"), IA-20-018, alleging a violation of the NRC's rule prohibiting deliberate misconduct, 10 C.F.R. 50.S~ Specifically, I am being accused of processing a change to Step 5.2.1 [8] of TVA General Operating Instruction l-G0-1, "Unit Startup from Cold Shutdown to Hot Standby," as <<minor/editorial" knowing, allegedly, that it did not meet the criteria for -"minor/editorial."

By way of background, I have been retired since September 2017. I currently live in Idaho with my wife of thirty-four years. I do not intend to return to the nuclear industry. In my eight and a half years in the United States Navy and twenty-seven years in civilian nuclear

. power, I have never been the subject ofan individual NRC apparent violation. After serving in the Navy, I worked at Arkansas Nuclear One for fifteen years. I spent the last twelve-plus years of my career at TVA. On November 9, *2015, I had been serving as Manager of Nuclear Plant*

Shift Operations for approximately two.years on shift and five years off shift. Although I was a qualified Shift Manager, I was not proficient at the time and therefore not functioning as the on-

. shift Shift Manager but rather iJJ a support role in the OCC. My duties were more like those of an Operations Support Superintendent.

. During my thirty-five-year career, I interacted with the NRC many times. I have tremendous regard for the important and difficult function of the NRC .in enforcing procedural compliance and thereby ensuring public safety. I believe openness and transparency are crucial to the work of the NRC. To that end, I fully cooperated in no less than five investigative interviews between December 2015 and March 2017 with the NRC, TVA-OIG, and'U.S.

Attorney's Office for the Eastern District of Tennessee related to events that occurred at Watts Bar Nuclear Plant (WBN) in Nov:ember 2015. I never asked to have an attorney present for arty of these interviews because I had nothing to hide .:md did not want to do anything to impede the.

. investigative process. I-was unaware that I might have .violated a procedure myself or that I was*

being considered a potential target for sanctions~ But I knew for certain-as I know now-that I have never intentionally violated a procedure.

I do not dispute-with the benefit of hindsight-that I was mistaken to classifv the procedure change as "minor/editorial." I have reviewed the applicable procedures cited in AV No. 2. I now agree with the NRC's d.eterniination that the November 9, 2015 change to Step

5.2.1[8] of TVA General Operatinglnstruction l-GO-1, "Unit Startup from Cold Shutdown to Hot Standby," did not meet the criteria for a "minor/editorial" change because it altered the procedure's "technical content' or sequence of procedural steps" by permitting the operators to draw a bubble at less than 135°F. See 3.2.11 of TVA Procedure NPG-SPP-01.2.1, "Administration of Site Technical Procedures" (Rev. 0002)

I did not, however, deliberately violate procedure. I am absolutely certain that I honestly believed, at the time, that the change was "minor/editorial" and processed it as such in good faith. I have never processed a procedure change as "minor/editorial" knowing that it did not meet the criteria or deliberately violated procedure in any other way. I simply made a mistake.

It is difficult for me to remember the exact circumstances surrounding the change to Step 5.1.2(8], because November 9, 2015 was almost five years ago, and this was one of hundreds-if not thousands--of procedure changes that I was involved with during my time at TV A. To the best of my memory, this is what I recall.

Regarding my analysis, I seem to recall determining that the temperature limit of 135°F was an arbitrary number that provided no specific protection for equipment/system limits. Nor did l 35°F prevent a violation of technical specifications, sirice we were required to perform 1-SI-68-44, "RCS, and pressurizer temperature surveillance." The purpose of 1-SI.:.68-44 is to provide detailed steps to verify that the Reactor Coolant System (RCS) temperature/pressure and pressurizer temperature are in compliance with Technical Specifications during heatup, cooldown, and in-service leak and hydrostatic testing. I do not recall identifying a reason why*

135°F was important in maintaining the limits in the SI-bounded system operating paran1eters.

Thus, I likely concluded that whatever the temperature was when we began to draw a bubble, if we stayed within the limits o'fthe SI, we would not violate teclmical specifications or the system design parameters of the pressurizer and RCS. Therefore, the intent of Step 5.2.1 [8]

was not changed by the procedure revision.* Before and after the revision, we were required to maintain RCS temperature/pressure and pressurizer temperature in compliance with Technical Specifications and design limits.

In retrospect, I suspect the mistake I made was in basing my decision to classify the change as "minor/editorial" solely on the above analysis and my conclusion that the change did not change the intent of the procedure. I would then have failed to adequately consider whether the change, nonetheless, altered the procedure's "technical content or sequence of procedural steps." Having looked back at TV A's then-applicable procedure regarding "minor/editorial" changes, NPG-SPP-01.2.1 Rev. 0002, I realize that intent was not the only criteria.

I do not remember, today, exactly what led to this procedure change or what I thought the result of the procedure change would be. I have reviewed the TVA-OIG report ofmy March 29, 2017 interview. I know that, during that interview, I truthfully conveyed to the best of my memory what occurred on November 9, 2015. But I gave that interview almost a year and a half after the procedure change. Not surprisingly, the report states that l was initially unable to recall the procedure change, and it is apparent from the report that I had difficulty remembering many

. of the details surrounding the change even after being prompted.

2

Frankly, even ifl had a crystal clear recollection of this procedure change at the time of my March 29, 2017 interview, I cannot assume that tVA-OIG's reports accurately and completely convey everything I said. Although I cannot be sure without the recordings or

• transcripts of my interviews, I feel that my statements were generally more nuanced and less conclusory than they appear in the TVA-OIG reports. Consequently, I can only assume my rationale for processing the change is what is expressed in the March 29, 2017 TVA-OIG report; but I cannot say today that the TVA-OIG report is an accurate reflection of what I said on March 29, 20i7 or what !thought on November 9, 2015.

Regarding the allegation in AV No. 2 that I "admitted that the purpose of the procedure change was to stay on schedule," I assume the NRC is referencing the TV A-OIG report of my March 29, 2017 interview. I think it is an oversimplification to say that I; "admitted that the purpose of the procedure change was to stay on schedule." In any event, part of my job on November 9, 2015, was to address procedure issues that impacted the operations department's performance. I am unaware of any rule that would have prohibited me from making procedure changes to allow operators to stay on a schedule. as long as I followed TVA's procedures .. *More importantly, why the procedure change was initiated and why it was processed as "minor/editorial" are separate issues. Even if staying on schedule was a factor in the procedure change itself, it does not logically follow that it also motivated the decision to process the procedure change as "minor/editorial."

I take full responsibility for my mistake. As procedure writer Scott Warrington's supervisor at the time and the Independent Quality Reviewer (IQR), I take full responsibility for how this procedure change was processed.

• I no longer recall my communication to Mr. Warrington on November 9, 2015, about the procedure change. It was my practice, however, to provide minimal information to the procedure writers regarding why a procedure change was requested, because I wanted to ensure that the procedure writer gave me his or her independent assessment. I also have no recollection of discussing with Mr. Warrington whether or why the procedure change should be classified as "minor/editorial." I believe that I would not have told Mr. Warrington about my basis for

• concluding the procedure change was "minor/editorial," assuming I had reached that conclusion by the time I requested that he process the change. Typically, I would only discuss the reasoning for treating a change as "minor/editorial" (or not) if I had a disagreement with the procedure writer's classification.

Regardless of why Mr. Warrington classified the procedure change as "minor/editorial,"

it was my responsibility to catch and correct that mistake. Having worked with Mr. Warrington for many years; I always found him to be a diligent and reliable procedure write.rand a person of unquestioned integrity. I am surprised that both of us made the mistake of interpreting this procedure change to be "minor/editorial," but I cannot believe that Mr. Warrington would have

• deliberately misclassified the procedure any more than I can believe that of myself. Even if Mr.

Warrington was not the honest person I know him to be, there is simply no reason why a procedure writer would ever feel motivated to deliberately misclassify a procedure change as "minor/editorial."

• 3

If anyone should be reprimanded for misclassifying the procedure change, it is me. I should have corrected the mistake as the reviewer of the procedure change. 1 In my opinion, punishing Mr. Warrington for such an innocent mistake would be both unfair to him and damaging to aU procedure writers in the industry who strive to do their best but sometimes make mistakes.

In my opinion, processing the revision to Step 5.2.1 (8] as "minor/editorial" was a relatively insignificant mistake. I do not want to minimize the critical importance of procedural compliance in operating a nuclear power plant; particularly adherence to the requirements for revising procedures in TV A Procedure NPG-SPP~0l .2.1, "Administration of Site Technical Procedures." The procedure change requirements reflect decades of experience and learning in

• the nuclear industry and are absolutely necessary to maintaining safe plant operations. That said, I understand. that the significance of a procedural violation is a factor the NRC considers, so. I want to address this issue.

• First; in assessing the significance of my mistake, it is helpful to review TV A Sequoyah Nuclear Plant's corresponding procedure for drawing a bubble in the pressurizer, which is enclosed. (Ex. 1, TV A General Operating Instruction 0-GO-1, "Unit Startup. from Cold Shutdown to Hot Standby," Step 5.4 (Rev. 0078) (effective 0R-24-15))I often reviewed Sequoyah~s corresponding procedures when assessing procedure changes at WBN. I might have reviewed Sequoyah's procedure for drawing a bubble in the pressurizer on November 9, 2015,

. but I do not remember for sure. I have reviewed it since, though, and, as you can see, it did not contain an arbitrary temperature. limit like the 135°F in WBN's procedure. Rather, Sequoyah's procedure merely required staying within the technical specification's req11ired temperature and pressure limits. IfI reviewed Sequoyah's procedure on November 9, 2015, it would have

• bolstered my opinion that*l35°F was an arbitrary number and that what was needed was staying within the technical specifications' required.limits for the pressurizer and RCS.

. Second, this *procedure change occurred nearly five years ago. The procedure has no doubt been used repeatedly since then. If the NRC believed that misclassifying the change had caused any material impact on plant or personnel safety, I hope that the agency would have done more than wait five years.to accuse me of deliberate misconduct. I can only assume that the NRC has concluded, like me, that there was no long~term impact or negative consequence from my mistaken classification of the procedure change as "minor/editorial."

I did not stand to benefit from this procedure change, and I did not benefit from this procedure change. To be clear, I adhered to procedure at TVA as a matter of principle. I took the.

responsibilities of my license, particularly a commitment to "safety first" very seriously. I understand, however, that you have not worked.'alongside me and do not know me personally, so I feel compelled to address this issue. On November 9, 2015, I had no career aspirations tied to pleasing senior management. I had already met my financial goals for retirement and was not 1

I believe that I was the "sponsor" of this procedure change. To my knowledge, there was no prohibition on my serving as both the sponsor of the procedure change and the IQR. The NRC has not pointed to any specific prohibition, so I cannot assess the substance of this allegation. But I again deny absolutely that I deliberately Violated a TV A procedure when serving as both sponsor and IQR. If that was a procedural violation, I was unaware ofit.

4

• seeking a promotion or a pay raise, nor was I in fear for my job. I had actually come very close to retiring in the summer of2015 but ultimately made the personal decision, after a series of discussions with my wife, to stay on until I turned 55; I am available and willing to assist with corrective-steps. With regard to corrective action,. if there is helpful information I can provide to the NRC or TV A, I will gladly provide it.

Likewise, if there are initiatives to address procedural non-compfamce or safety culture at WBN,

• I will gladly volunteer my time in assisting with those initiatives. If I could go back-*with the benefit of hindsight-I would process this revision differently. The lesson learned, for me, is that when processing procedure changes, they need to be reviewed for whether they alter the procedure's technical content or sequence of procedural steps as well as whether they change the intent of the procedure. In retrospect, I. was not as thorough as I shoul~ have been. Had l carefully applied all of the criteria for "'minor/editorial," changes, I probably would have determined that the criteria were not" met. *

• Thank you for the opportunity to respond to the allegations in AV No. 2. I hope you believe I would never have deliberately misclassified a procedure change, regardless of schedule pressure or any other reason.

• 1-q_J0)fl Sincell_y_,. t

. /IJ/,

. William "'Bill' Sprinkle Enclosure CC: Kenneth G. O'Brien, Director Division of Reactor Safety United States NucJear Regulatory Commission. Region III

• 2243 Warrenville Road, Suite 210 Lisle, Illinois 60532-4352 kenneth.obrien@nrc.gov SENT VIA U.S. MAIL AND ELECTRONIC MAIL 5

Im Sequoyah Nuclear Plant Unit 1 & 2 General Operating Instructions 0-GO-1 UNIT STARTUP FROM COLD SHUTIDOWN TO HOT STANDBY Revision 0078 Quality Related Level of Use: Continuous Use Effective Date: 08-24-2015 Responsible Organization: OPS, Operations Prepared.By: Cheryl D. Hale

. Approved By: Paul Parashak Current Rey;~ion Description Added steps to sections 5.3 and 5.5 for isolation of RVLIS bellows for RCS Sweeps and Vents. (CR 1024096) Revised $tep sequence in section 5.6 for increasing RCS temperature and pressure. (CR'1024634) Added WCC SRO to.Attachment 2 for breach permit status. (CR 1025962) Corrected substeps in Section 5.5.1 for RCS depressurization. (CR 1024572)

• EXHIBIT

-b A l _j_

SQN 0~0-1  ;'

Unit 1 &2 *Rev.001s P*ae-37 of .165 1

Unit

--- Date'---

5.4 Drawing a bubble in the p~ssunzeru:* *: -

• NOTES

1) : Pressurizer enclosur~ temperature should be* maintained as* cool as possible, but

greater than 70°F, arid_ less than 110°F.. ,Enclosure* temperature should be monitored ortrended*using-lCS pointT1001A. - * - * - . - - . *' . .. . . .. :

,. ' .. ' ~ ' . '

2) . Lower compartment.oorilers Aand B ha~e'toe greate~i infl~eri~ o:n tne)iressµrizer enclosure temperature. Rapid enclosure temperature changes- should-be-avoided. .*

(11* ***IF RCS/Pressurizer are NOT water solid, THEN

• -~ * ** ' * ;a'

. GO 1:0 SectiQ0 5'.~ to ~stabli$h_ solid water ce>'n9ltio~s k'rl~: ' _ o

. RETURN to step 5.4[2}.

_[2] 'ENSURE Lower Comp~rtment cooling.units ,are in service, . : ...*

-...iii accordance with 0-SO-30-5. . . . . . . : . . */

[3] IF 0-SI-SXX-068-127.0 is NOT in progress, THEN PERFORM applicable sections of:0-SI-SXX-068-127.0, RCS _

.anqPressurizer Temperc1ture and Pre~~u~ Li(!litS. _- .

• , ,:~... ",; ,-.;  :*' ""* **  :"' *j  : **: * '.. ,

MAINTAIN RCS pressure and temper1;1ture Within Jhe .* '* _

acceptable region of RCS Pressure/Temperature Limits Curve.

USING T1::2a Fig, :4. * * ,* \

• NOte**.

. ,.,. ' .. ' ... ,:~> . i_,' .,:

0-SI-OPS-000-004.0 must be performed~PRIOR TO RCS or SIG, pressure exceed,ing

-200 psig to ensure-rompliance with [CTS] TRM-3 ..7.2 [ITS] TRM TRV.8.7.1 ..1...

1

~ -\/'*/:  :*:r**:'~C * .. ~ " :*. ;.~ ,.,_ -,) .

[5] IF either the. R:CS or ,stearp g~nerator: ~9opqacy ~i<:I~ pr~~µre is:.expected_:\o ~xed 20P ,p$ig,J"HEN 1/: .." . , : .

, -. P.ERFORM.*0-SI-OPS-000-004.0 on an hourly basis to verify

..... temperatures gr~~~~rthan_70.~FJ[CJS]TR 4.7/?-):

([ITS] TRM TRV 8.7.1.1).

• UNTI( RCS*and SIG-pressures ar~ less than 200 p.iig * -

OR an RCPJs placed in service: *,t

• • sc:iN . UNIT STARTUP fROIVfCOLD. 0~00.;1 ,.

Unit 1 & 2 sHurooWN to*1101,_sTANPev. , R-.;.v.. 001a * ....

• • Paae 38 of 1ss**

Unit....,-_ _ D.ate. , , - , . - - -

5.4 Drawing_ a bubble In the pressurizer.(co,:1ti.n1,.1ed) ,,*,***,*-, ,

[6] ENSURE the following:.

• -* HS VALVE

DESCRIPTION,*

• HANDSWITCH * .. POSITION INITIALS POSIT,_ON PZR PORV H8-68-340M P-AUTO CLOSED

.- } ~

PZR PORV ~f1~-68-334A:.* P-AUTO CLOSED

[7] INDEPENDENTLY VERIFY the following:

DESCRIPTION HANDSWITCH HS VALVE INITIALS

~-*

---

+-----------------

PZRPORV HS-68-340AA

-., PQSITIOI\I .. , :::POSITION,:. -- **, i P-AUTO ** GL.O~ED ,....a:_,,,.,.*:.'-....

IV PZR PORv' ** HS:68-334;6;) ; . * ' P~AUT¢) *

'is

1) ', If performance of 1,2-S1:.6ps2b74-f2a:o r~qbirei:i'/max,niu'rrfpre~sure for drawing bubble is limited to ,:1,5.() psig .tO.JX>in~d~.wi~h ~llqw~ pre~s_µ,rft.fOf. 1,?-f~I-OPS-074-128.0, RHRDischatge/Pipihg_YeiiC * .. * , * .::~; * * : ., *... ~: ' ** *, *

• .* i ' ~-:- . ,,.,' ' ' ' ' ' * , ' * * ',.._ * **-*. - '

2) ~Due to elevation differences, wide range RCS pressure i_ndications r~c;tapproximately 25-psig higher than corresponding saturatjon pressure in pressurizer.

3) A bubble was successfully drawn at 48 psig during U1 R18, which allowed RVLIS backfill and cals'in parallel_With drawing*bubble:* , . *. *::. * . * * - . . * ; : ..

, '* . ) . ,'* ! ,*.* ',. ,. .

[8] DETERMINE pressure band to draw bubble (NOT to exceed max :pressure of: '150* psig' if perfomiahce;of*1,2~S-l..:OPS'"074-*,

128.0 is required) AND c6rre~poriding'satufation-temperature:

IV Maximum psig psig. IV

., _ _ __.psig _ _ _ psig

• IV Minimum

SQN 'UNIT STARTUP FRORn.COILQ **-':. 0~0-1 Unit 1 &2 SHUTDOWN TO HOT'STANllBY' < c:: Rev: 0078 **

• • ' . ., .... Paae 39 of.165.

, . ...... ,.Date 5.4 Drawing. a bubble in the presstirizer (continued),'.*; ' ...

ADJUST RCS pressute'io<previoLisly 'detenjti~~~:ptS~sure

[9] * '. I band by performing following: *

[9.1]... . MqNIT.OR Ry9 pr~~~l:l.f~. ~,s.irg ~my of the f9II_0'{Vjrlg:

• -1*.:*:. ,:- . !_ L'.-.:_*.--..--.~*-*: . .'-: . *.--:.':~,-t: *~;/:-:*.:-..:" r_.ji*:::*:- -.-~;-*-**:*..::~.--~:.~::,:-\~**

EQUIPMENT RCS PZR Press-Cold Cal Pl-68-342A

• *: ,PF-68.:.S2 -"*;,

RCS Hot Leg Press Wide Range - - - - - - - - - - ~ ~ -

Pl-68-69

[9.2] ADJUST (HIC-62-81AJ Letdown Pressure Controller in MANUALto determio~cH~C~:pre~.ur~u . ,,. *.. * .

[10] WHEN RCS pressure is greater than 100 psig, THEN; '.. '.;, r: . \: ...' >(,,H *

[10.1] ENSlJRE:[FCV~62-9)d~9P,#1,§eal L9-~kqff.Q.~~~-:

using]HS-62~9A). *

• r10:;1' ENSURE (FCV-62~22]~*-~c*P#2 s~~l'.b~~kgff~Q~~N.' :',

using [HS-62-22A).

• -:~:~ 1<'. *,_I-, :;*~; L'. ~--J- , *:t:'f::_:__ . ,',~ . ~, ,' :: _', i*.<:- ,. J~:.~ -* '\:' *', (

[10.3] ENSURE [FCV-62-35). RCP #3 Seal Leakoff OPEN usir,ig (HS-62~35Al . . ... ,

• .'::_._ ..); :.,. ':. , '" ,_

~*, '*. *.-:;::.~; ;1 .... *. \:3 :'-*,;> \ . :.'.': ..

[10.4] ENSURE (FCV-62-48). RCP #4 se*a1 Leakoff OPEN using [HS-62-48AJ.

[10.5] ENSURE [FCV-62-63). seal return isolation valve OPEN using (HS-62-63Al.

[10.6} ENSURE (FCV-62-61). seal return isolation valve OPEN using [HS-62-61AJ.

[10. 7] INDEPENDENTLY VERIFY [FCV-62-91, RCP #1 Seat Leakoff OPEN.

IV

SQl'i . 'tJijff:stARTUf.'. fROM *cot.cf _., *

• 0::00~1 .

Unit 1 &2 . SHUTDOWN TO HOT.STANDBY. . Rev.'~ 0078 .

. .. . .\.*,, ,.. . Paae40of165, Unit***

• ----- Date.-,----

5.4 Drawing a bubble in the :Pr,?>>s1u,tj~,r (c;_or;t~i.nue,~),,, ,. 1

[10.8] )NP,EP,1;~:DE~TLY Vl;~IFYJFCV.,62-221. RCP #2 S,~-~I Leakoff OPEN. . ... . . . . . ....... .

IV

[10.9]

• N

[10.10] *INDEPE~,QENfLY \}ERIFY[FCV-6248l RCP #4 Seal*

.. Leakoff OPEN!* . .

IV

[10. t1]. ;_ INDEPENDENTLY VERIFY [FCV-62-631. seal return isolation valve is*:QPEN.

IV

[10:12] ' INDEPENDENTLY VERIFY [FCV-62-611. seal return

• , isolation valve is OPEN.

IV

,,:'!::;: ~.. f. I,' i

• i. \~' .: .

[11] MONITOR ttJe followin*g parameters as.RCS pressure*,*,,,

is rising:

• Letdown Heat E~changer Outlet pressure [Pl-62-811: *

[12] ADJU~T .[HIC-62-81A] to ma!ntain* letdown less than 120 gpm during*pressureflise. * . : * .. . ,. '. ,c * . , :.:, ..'. , ** . /t:.' .. '* * *:. ;

[13] WHl;~l~C~ p~essu.re ~~ W!tl'l_ir:t pre~~t~rrninf3.~tband, TH~N

.-*~ ***'.:\ .. , '\;;-- :-; ,* *,:** ". ( *'.: ., *:; ,, *.::~~~;***: .. \_:,. _.,~*:;* ' ::*

ADJUST [HIC-62-81Al and [HlC-§2:93:Al:as.riebessaiy to maintain. RCS pressure.

j_:~::h:-;~,. . *.., -r*t;-:**::".:,.:-* ~:>: ,~'

. ,, ,,'i

< '"'"* h* * --

SQN UNIT STARTUP FROM COLD 0-GO-1 Unit 1 &2 SHUTDOWN TO HOT STANDBY Rev.0078 Page 41 of 165 Unit- - - Date 5.4 Drawing a bubble in the pressurizer (contfiilued)

CAUTION Aligning charging flow through Aux Spray line may result in a small drop in charging flow. RCS pressure should be closely monitored if pressurizer'is water solid.

NOTE Step 5.4[14] may be niarl<ed NiA with: Chemistry approval, if sufficient hydrazine has been added to the pre~suriz~r. *Step may be performed out of sequence (earlier or later), as determined by Chemistry. * *

[14] IF hydrazine injection to the pressurizer is required, THEN .

ALIGN Auxiliary Spray as follows: * * *

[14.1}. CLOSE [FCV-68-340D1 and [FCV-68-340Bl, Normal Sprays to prevent backflow through spray lines,

[14.2] IF performing on Unit 1, THEN REP.~CE control power fuses for 1-FCV-62-84:

UNIT BOARD LOCATION FUSE UNID . INITIALS 1 125V Vital Battery -- --

Ckt. _C-3

.. O-FU~t-250-KEC3~D Board I 1st CV

[14:3] IF performing on Unit 2, THEN REPLACE control power fuses for 2-FCV-62-84:

UNIT BOARD LOCATION FUSE UNID INITIALS 2 125V Vital Battery -- --

Ckt. C-3 0-FU2-250-KGC3-F Board Ill. 1st . CV

[14.4] OPEN [FCV-62-84], Auxiliary Spray Supply valve Jo admit water to pressurizer. * *

[14.5} ENSURE [FCV-62-851 and [FCV~62-861 Alternate and Normal Charging are CLOSED..

[14.6] ADJUST [HIC-62-81A1 and /or [HIC-62-93Al as necessary to maintain stable RCS pressure.

SQN UNiT STARTUP FROM.COLD. o.,GQ-1 ,

Unit 1 & 2 SHUTDOWN TO HOT STANDBY. Rev.0078 Page 42 of 165 Unit._ __ Date 5.4 Drawing a bubble in the pressa,uizer (continµed) ..

[14.7] ADD hydrazine to pressurizer USING 0-SO-62-8

• Reactor Coolant Chemica/Addition and Control.

[14.8] .* OPEN on~ c,f the following: {NIA valve not .used)

VALVE FUNCTION OPEN

,. FCV-62-86. . Nonna! Charging ..

FCV-62~85 Alternate Charging .

[14.9] CLOSE [FCV-62-841. Auxiliary Spray Supply valve.

[14.10] IF performing on Unit 1, TliEN.

REMOVE. controJ power fuses .forJ-FCV-62-84; UNIT BOARD* LOCATION ***FUSE UNID INITIALS 1 125V Vital Battery

-CV-Ckt. C-3 0-FU2-250-KEC3,..D Board .I . '

1st

• . [14.11] IF perfonning on Unit 2, THEN

_REMOVE control power fuse~ .for 2-FCV-62-84:

UNIT BOARD LOCATION FUSEUNID INITIALS 2 1*25V Vital Battery -- --

Ckt. C-3 0-FU2-250-KGC3-F Board Ill . 1st CV

[14:12] ADJUST [HIC-62-81AJ and/or [HIC-62-93AJ

• as necessary to maintain stable RCS pressure;

[15]

• OBTAIN confinnation from Chemistry that RCS chemistry.is within allowable limits for pzr heatup to greater than*180°F.

[16] PLACE Aux Spray in service as necessary USING 1-SO-62-1, Sect. R8, or 2-SO-62:..1, Section 8. 7; Operation of Aux.iliEJry Spray.

• SQN *'tJNIT'STARfUP"FROivf'cdt.o'.* -*. G0-1 Unit 1 & 2 SHUTDOWN to*iio*tstANDBY'*; . Rev. 0078 ;

.... -- :. , _ Page_43.of.1_6~.

Date ..

1) -,[CTS] Pzr heatup rate of100°F*in}one h<>Lir"shaH:*NoT bEH!xceeded (TRNI 3.4.9.2).

_Extreme ~.-re $houlct be tak~n. if a11..PR2. t:u~~te~ are e11ergi_zed~

[IT~] Pzr heatup rate of 100~F in one hoµr~hall_NO,T be exceeded (TRM 8.4.2).

Extreme care shouicfbe'taken if all'PRZheaters-are erietgized~ *_*< '~< ' ,:,,:: ' '~'.I ,, - . '~:r -* *: .*, , : .' '* . . <* .

2) T_he ~TP. above the _pressurizer surge line will d~tect liquid in-surges and o*ut.:.surges, which shows up as an iriditation of a rapid temperature change.

Due to pressurizer surge lirie'sfratificatiori events, heatup and*cooldown rates

• --- . s11ouic1 1>e-mon,tored during au evolutions~- _-cc.12r * * - - - * - * *

• NOTE**

Convection currents with.in .the: pressurizer are (established-when *pressurj_zet-heaters are1 energized. Initial heatup may require alhpte~surizer:h~aters to. be temporarily energized.

(17] INITIATE pzr heatup to predetermined saturation temperature*

~t:e~rtor111i~,gJh~ ,f,~!!°,-~ir:w:,; *--!:'.* . _ ~;[ . __ . '.::Y:, ., ' _  :;: ~

[17.1] PLACE Pressurizer:Pressute-Cohtroller [PIC-68~340AJ **

in MANUAL and driv~. output needle to closed p9sition:... D

'.i :*:*1*:: . . ~<.:.:-/'**:*.,-* ~); ;:::-. \:' ....:.,-:**. *,~::;:::_:*_. ',.:, *._:;

[17.2] * ~-N~~GIZE pressurizer heaters as required. D

... -. :* *.,_,1 . : t-:t **.: - =:--. :* :*:::: - _*_.c:r} ,. . **p:-< ::/**.* :.-_-. .. -

[18] CONTROLptessutizer heatap rats by*cyeling *pzr-heaters.**,*_ .-

as necessary. D NOTES

1) Computer points require:a prefix o, 1-;: or2 be placed~in front.of the 1pointti1umber;* for example, 2T0482A.

• .. i ., *.***

2) [Tl-68-3181 pressurizer surge line (ICS pt.T0482A); m;.&8-3191 oressurizer,liquid-space* (ICS pt T0480A), and (Tl-68.;324] pressurizer vapor-space (ICS pt. T0481A) may be trended to provide temperature change indication during filling, cooling, and heatup operations. *Liquid space-and surge line-temperature *should;:be: approximately equalwherialiquidoutfloWis.present**,**<** 1 *,\*:*,*:'.:.:-: *,*:._.- ,:_

[19] MONITOR the folf9Wing during the* heatupf * -* -. * -,_:-: *~ **. *

- . :/_:*-.-~::_.,:. :* .- , . *_ :~: t:(? .:;r** ;;* *.. - ..*. -.:/*;  ;~~~ .:;*: :, ..

• PZR liquid space temperature [Tlu68-319] (T0480A) D

SQN UNIT STARTUP, FROM.cote~~,.:*.*:::) ~o-Go-1 * * * *

• Unit 1 &2 si-lurDoWN +o-i-lo+*s-rANoev*~.*, :* Rev:.001s ...

, ; . :. . . .. . . . Page 44 of 165 Unit0 **,

' 5.4 Drawing a bubble in th~Pf'it$~J:1.riz,r:(~.ontJ11µ~C'al):. :'-:  :~1

• PZR vapofspace* temperatµf~ [Tf.:68;.3241 (T048'1A}" .. , . .,. -l  :* , ~, , , , , .

'*;* ~** ,y,:PZR surge line,temperaty~e [Tl-68-318,l(T0482A).,

NOTES

.: , ,* ,;:  : '. " * * ;*,,.::,'} ** '. c.i ..:,:;; , * . :: *.',; :**.*(*:,* **iL~::;:.* < : ; -:*~< "{~* ;*:: ;* >:* :_,i:: * ,t * *..  :  ;**~ *:-*:  ;' ~* .*..

., 1) Pressurizer leyel.Jn~icator~ [U-68-339Al; [bl-68-336Al [Ll;.68-3201. or:[Ll-68~.3211 may be used-for verifying pressurizedevel. " ' ,, . .*** ....

f

_ *~:.'.**,:.,:*;_ ,--:: ~*;-' ~.*~  :.<*'.' ~*:.:;*",*;::-,**., ~':*:,.. -r:,:.:' /.::-_~"/',

j * .. ~/" ',, r:1 *.,.!~(-,,.~: ~ :_ :~~ ~?r.,.,.~*."t*-.,, * ,,* -~-

2) vyt:len letd9wo: flow is, gr~ater than charg\ng .flQw and RCS.pressur~ ,i~ ejther stapl_e or slqwly risi.ng: ~~s,te.~m,t>ubble is fgrrl}iOQJf'.:!Qe*p~(j)~4ri:zer. :*, ,: ; " .,,, ,* - ':* - .

[20] *WHEN*pressurizertemperature is,approximately,-saturation

• • temperature, *THEN " '",, *

.* ,. **

• RAISE*letdownflowabove,charging.to'start:reducing: .**,-:.:'**:.

pressurizer,level to,approximately 85%: hotc;aL . .* *

, r~: 1: \:_ ,-, *, . ; ., , 1

, / ,_ ****** ~. .. _. :, ,

LOWER charging flow to be less than '.letdown' to start reducing pre,~$U~f~~:l13:~el t<tlPProximat.~.ly-85%,_,hpt ~L., . ,. :

.:L*;;;L_*,(*"'. i .** :, ' *, '*. , *. *.*,.,./,' .::,,,"":.

[21] IF Auxiliary Spray is in service,' THEN *

': ::~<1-~:.*. *:.: >.** .* :.~*. *!~ -..:.f~*: <. _ . :~.!.:_ .. ~**.*r**~t<**.:3:

REMOVE Auxiliary Spray from service using 1-S0-62-1, Section 8.c8; or.?~S0~2-*1.~f Sectiqn,8:7; *Opf3r:atioltPtAu~/liary, Spray. * *  :*,~- .

,-,.01:ES

1)

• Water in:the. bonnetoUhe PORV wiJI signifiC<(lntly slow the:*valve stroke time,.: .

2) AR-MS-A Window E2 "Pressurizer Power Relief Line Temp High" may annunciate

• .during* performan~..:Qf.,th~ f9!!owin*g step.

[22] *: .,ENSUREPCV -68,-334 and PCV-68~340.pilot chambers.* **

do NOT contain water by performing the,foJlowing:\ , : _,

[22.1] CYCLE [PCV-68-3341. Pressurizer PORV OPEN AND CLOSED UNT_lkCl,0$1; strok~ tim~,i~,l~ss,than.or, . ,':

equal to 2 seconds using rHS:68~334Af * *** * * *" * ,'* # * **

• SQN Unit 1 &2 Unlf ----

5.4 Drawing a bubble iti the:pressunzt!r'(continuedf *L ;-:; *-t /:,, * * **. ~; ,-;;r *i <

. *:. .*

• _. ' . * . . .. ,.! \ * . '* *. :* ~*  ; t'_'* -~ *. *  :. ,. . l * * * ** .. f

[22.21 CYCLE (PCV-68~340A], Pressurizer PORV OPEN and CLOSED_ u~ing-[HS-68-340AA] _____ . . _

UNTIL CL0SE stroke;tihie rs::Ie*sstharf : -_;:. ; -'

• or equal to 2 secdnds::*:1: _,, *' - * <- * * ,, " "': :*

[22.3] E~~lJREJhefollowirig:  ;,:> *.*,i:,__ :  :. ~: -.-.' '

• .: . ~ . *_: '~: .-:.-.- -: . ' . . ** .. - .. ' . . .  : ' *.. *, .* _. .-. - .-:. ; *:/ ......

\  ;

HS VALVE - "

DESCRIPTION HANDSWITCH INITIALS i " ,,

', ,POSITION, ,-,~QSITION \

PZRPORV ** HS-68-340AA . P-AUTO -_ .- - -CLOSED..,* , -

PZR PORV HS-68-334A P-AUTO CLOSED

[22.41 INDEPENDENTLY VERIFY the following:

DESCRIPTION HANDSWITCH

,,',J

• - ...-s* ,,

-VALVE ,,,

INITIALS POSITION POSITION PZR PORV HS-68-340AA P,:AUTO -,..! ..,_, CLOSED ;'.:- .,,:-:*. ,;, ,,,

)* *_*._,*_*.;, "-*: ,, ... IV PZR PORV HS-68-334A P-AUTO CLOSED.,1,.

,,, .. .-: j *;' ~- _":::):.-..- .... '\'

• • ,v

[231 ADJUST [HIC-62-81A] and [HIC-62-83A) to maintain letdown flow and pressure as desired.

[241 INITIATE pressurizer level reduction to approximately 40% to 60%.

[251 IF 1, 2-Sf-OPS-074-128.0, RHR Discharge Piping Vent-to be performed, THEN ENSURE 1, 2-SI-OPS-074-128. O complete prior to exceeding 150 psig. "

NOTE PORV stroke time testing is required to be performed at least once per 18-months in Mode

-3, 4, or 5 with a steam bubble in the pressurizer. The following step may be performed later if required based upon outage schedule. *

[26] ENSURE O-SI-SXV-068-201.0, PORV stroke time testing completed for PORV operability.

U"'it_...___ .D~te-......_ __

5.4 Drawing a bubble in the :pr;~s.$µ~zer;_(~.Otinued).

• *' ,, " ' '! ' ,* .. .. * ' *** ,* ,, * - * . . . ,. *' *.,. ~ ~

.  : **i; ~. '.

[27] IF; th~ unit)~ to._.be:maintained at thi~.plate~u; T:tlEN:,

• • ~ ' , * * *. * . *.*** ' * * . : . : ** *;:*. _,!, * ** ' , - .' .::_~.-~,* .. , . ; **

CONTROL RCS tem,p~r~{clt~;i,.{i~~sJ~~~;1:sb°F" ,q, :,::

and pressure at the predetermined q~rid. . .* ~* *

[28] IF LETDOWN PRESSURE HIGH tal~rm .. ,. ::: *": *~-: '.*::

(M6-C window B4) was previously disabled (Step 6.3[6]),

• THEN **, ... * * *** * ,. .

.. . ENABLE:affect~ciSER*p6irif(U-*1.: ~1£3~: u:2: *1*266) in accordance*with OPDP;:4, Annunciator Disablement.* .

If bubble needs to'be ccill~psed, RCP ne_eds to be started in Section 5.6 pnor to 'returning to O-GO-7.. . *. * .. - ,,., , .

~ :,

• 1

. -**.  :. - *.. * } k .

_[29} IF re~dy *to start an; RCP, THEN

-~~,,' ......

',GO TO Sectiotf5.6. ~. . ~-*-* ,.. ****- , .. ,. ."

End of Section l . * *,*.

• • " *,*: