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: Difference between revisions

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  , ,.3                  Do/19/92'   15:33             5129728298                                         002 APPENDIX D The Light c o mp a n y '"'" '"*' ""')"' """" "*"""8 """                           " ' " ' " " " * * *d'" "h T'* *' r r 4 a s liou. ion ti uing t    & Power 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.
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)
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
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
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.
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
O       90       N Subudian.s or lionsoni in.wirie, toeorpormed A
Responset The individualu involved with the issue on the evening of May 18,
      ,R                         -
: 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.
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.
No discussion was held concerning overtime nor was                                       the monetary corpensation for, ur restrictions on the utilization ur overtime an issue in this decision.
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)
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.
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.
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.
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.
Two additional points of clarification were raised during the September 17, 1992 phonc call.
Clarification 1)
Clarification 1)
Line 36: Line 59:
===Response===
===Response===
HL&P's presentation at the NRC/HL&P Management conference on '
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.
August 28,
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.
: 1992, was based upon the results of the investigation documented in Station Problem Report 92-0201.
Attachment C (page                 4, area 3) of the September                   11, 1992, correspondence, details the decision making process.
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     l
:i 09/18/92 15t34 5129729298 004
. . N                                                                                                 j l
. N j
i
!!ounon Lighting & Power Company South Tezu Projut Eintric Cencratin5 t'ti "
      !!ounon Lighting & Power Company                                                                 l South Tezu Projut Eintric Cencratin5 S t'ti "
pg 3 S
pg 3                   l ST-ilL- AE- 4 217 File No.: G.25 10CFR50 1
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                         ,
!!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
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.
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)
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.
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===
===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.
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.
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.
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.
                                                                      . . Hall Group Vica' President, Nuclear WJJ/Tkf
HL&P will provide amplifying clarification upon notification of any other apparent inconsistencies.
Hall Group Vica' President, Nuclear WJJ/Tkf


  .,g,                09/18/92           15:35         5129728298                       005 Houston Lightin5& Power Company                                   ST-HL-AE-4217 South Texas Project Electric Ococrating Station                   File No.: G.25 Page 4 cc:
09/18/92 15:35 5129728298 005
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
.,g, Houston Lightin5& Power Company ST-HL-AE-4217 South Texas Project Electric Ococrating Station File No.: G.25 Page 4 cc:
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
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/}}
Revised 10/11/91 L4/ NRC/}}

Latest revision as of 16:26, 12 December 2024

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  STP Nuclear Operating Company icon.png
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)
v • d • e


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/

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