ML20127G973

Insp Repts 50-498/92-17 & 50-499/92-17 on 920526-29 & 0828- 0915.No Violations Noted.Major Areas Inspected:Circumstances Surrounding 920519 Event That Resulted from Sys Engineer Discovery of TS Surveillance Requirement Never Implemented

ML20127G973
Person / Time
Site:	South Texas
Issue date:	01/14/1993
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20127G949	List: ML20127G947 ML20127G973 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 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
References
50-498-92-17, 50-499-92-17, NUDOCS 9301220135
Download: ML20127G973 (29)

See also: IR 05000498/1992017

Text

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AP.PJNDIX A

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-498/92-17

50-499/92-17

Operating Licenses:

NPF-76

NPf-80

Licensee:

Houston Lighting & Power Company

P.O. Box 1700

Houston, Texas 77251

facility Name:

South Texas Project Electric Generating Station (STP), Units 1

and 2

Inspection At:

STP, Matagorda County, lexas

inspection Conducted:

May 26-29 and August 28 through September 15, 1992

Inspectors:

J. I. lapia, Senior Resident inspector, STP,

Project Section D. Division of Reactor Projects

W. f. smith, Senior Resident inspector, Waterford-3,

Project Section A, Division of Reactor Projects

R. A. Kopriva, Senior Resident inspector, Cooper Nuclear Station,

Project Section C,-

ivision of Reactor Projects

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Approved:

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Ud[-e 'l N" b

Arthur 1. Howell,1151, Project Section D.

Division of Reactor Projects

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Inspection Summary

Areas inspected:

A special inspection was e.onducted to determine the

circumstances surrounding a May 19, 1992, event that resulted from a system

engineer's discovery of a Technical Specificatton Surveillance Requirement

that had never been implemented and to assess the implementatica effectiveness

of licensee's programs and procedures for_ identifying and correcting

conditions adverse to quality.

The inspection also reviewed the circumstances

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of a September 3, 1992, event that resulted from a loss of power to the

digital rod position indication system and.the subsequent initiation of plant

shutdown of Unit 1.

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Results:

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five apr arer,t violations were identified:

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(1)

The first apparent violation involved a failure to satisfy a

Technical Specification Surveillance Requirement.

Failure to

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oerform the required surveillance test of the manual reactor trip

circuit shunt trip coils resulted because the surveillance

procedure did not independently test the shunt trip feature

(Section 1.2).

_

(2)

The second apparent violation involved the failure of cor * rant

licensee personnel to immediately inform the Shift Supers

ars of

a Teshnical Specification surveillance deficiency, once it was

known.

This notification was required by the licen;ee's station

i

problem reporting procedure (Section 1.3),

(3)

The third apparent violation involved a failure to implement

adequate corrective action for a problem identified on April 9,

1992, which concerned a perceived adverse impact associated with

the initiation of station problem reports (SPRs).

This failure

contributed to the lack of the initiation of an SPR on May 18-19,

1992 (Section 1.4).

(4)

The fourth apparent violation involved a failure on June 8 and

September 3, 1992, to follow procedures for the issuance of

guidance pertaining to Technical Specifications (Section 2.3).

(5)

The fifth apparent violation involved a failure to provide

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complete and accurate information to NRC pursuant to 10 CFR 50.9

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(Section 3).

The lact

cedural guidance for requesting a temporary waiver of

,

complian s

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c:nsidered a weakness (Section 1.3).

The lack of time requirements for determining the operability of safety-

related systems er.d components that are in an indeterminate status was

considered a weakness (Section 1.3).

The inspectors identified instances in which events that are required to

be reported to NRC pursuant to 10 CFR 50.72 were not reported within the

speci fied time.

An additional example was identified by NRC during

another inspection and a Notice of Violation was issued (Section 1.4).

Summary of Inspection Findings:

Apparent Violation 498;499/9217-01 was opened (Section 1.2).

Apparent Violation 498:499/9217-02 was opened (Section 1.3).

.

Apparent Violatier. 498;499/9217-03 was opened (Section 1.4).

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Apparent Violation 498:499/9217-04 was opened (Section 2.3).

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Apparent Violation 498;499/9217-05 was opened (Section 3).

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Attachments;

Attachment 1 - Persons Contacted and Exit Meetings

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Attachment 2 - Simplified Diagram of Auto / Manual Reactor Trip Circuit

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DETAllS

1 PLANT SHUTOOWN INITIATED BECAUSE A TECHNICAL SPECIFICATION SURVEILLANCE

REQUIREMENT WAS NOT SATICFIED (UNITS 1 AND 2)

(93702)

1.1 Overview

On May 19,1992, at 5:01 and 5:05 p.m.,

the licensee initiated an orderly

shutdown of Units 2 and 1, respectively, pursuant to Technical Specification (TS) 3.0.3, which requires, in part, that, when a Limiting

Condition for Operation is not met, except as provided in the associated

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action requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the

unit in a mode in which the TS does not apply.

Both units were operating at

full power.

This action was initiated because the licensee identified that a

manual reactor trip system surveillance had not been adequately performed,

thus rendering both trains of the reactor trip system inoperable for both

units.

Technical Specification 3.3.1, Table 3.3-1, specifies that the minimum number

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of operable channels of the manual reactor trip function is two.

To verify

operability of these channels, Table 4.3-1 of TS Surveillance

Requirement 4.3.1.1 requires, in part, that the reactor trip breaker shunt

trip (ST) feature be tested independently at least once per 18 months while

testing the manual reactor trip function.

During a review of the applicable

surveillance test procedure, a System Engineer discovered that the independent

test had not been implemented since initial startup of each unit.

Not meeting

this surveillance requirement rendered both trains of the reactor trip system

inoperable for eacn unit.

At 2:30 p.m.,

on May 19, 1992, licensee management

declared both units to be in TS 3.0.3 but did not inform the Shift Supervisor

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until approximately 5 p.m., or about 1 1/2 hours beyond the time required by

TS 3.0.3 to initiate action to shut down the units.

Further, the licensee

failed to take this action until prompted by NRC (after NRC was informed by

the Plant Manager that the units had been in TS 3.0.3 since 2:30 p.m.) during

a conference call that the licensee had initiated to request a temporary

,

waiver of compliance (TWOC) from the applicable TS Surveillance Requirement.

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A Notification of Unusual Event (NOVE) was declared in accordance with the

licensee's emergency plan at 5:06 p.m.

At approximately 5:45 p.m., NRC

granted a TWOC from the provisions of TS 4.3.1.1, Table 4.3-1, Functional

Unit 1, until a one-time emergency TS amendment could be reviewed by NRC.

The

shutdown of both units was terminated at approximately 80 percent power, at

which time the licensee exited the NOUE.

The licensee was subsequently

granted a one-time, emergency TS amendment on June 2, 1992, to allow continued

operation of both units, without performing the surveillance, until the next

planned or unplanned shutdown of each unit.

1.2 Manual Reactor Trj_p_ Surveillance

lhe inspectors conducted a review of the technical aspects of the surveillance

test omission.

TS Surveillance Requirement 4.3.1.1, Table 4.3-1, Functional

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Unit 1, Note 14, requires that a Trip Actuating Device Operational

Test (TAD 01) of the manual reactor trip actuation undervoltage and 51 circuits

be performed.

Note 14 requires that these circuits be tested independently.

Attachment 2 of this report is a diagram that depicts an auto / manual reactor

.

trip circuit.

HS1 and HS2 are the designators for the two manual reactor trip handswitches.

Each control room has two manual reactor trip handswitches

,

with two outputs on each switch.

One output actuates the Train R reactor trip

breakers and the other actuates the Train S reactor trip breakers.

Operation

of either switch deenergizes the undervoltage coils in all the main and bypass

trip breakers through the R and S logic trains.

At the same time, the shunt

trip coils on all breakers are energized in order to trip the breakers.

The portion of the diagram within the dotted line represents the modification

which resulted from the Salem Anticipated Transient Without Scram (ATWS)

event.

This modification was installed in the main breaker ST circuit as

y

required by Generic Letter 83-28, " Required Actions Based on Generic

Implications of Salem ATWS Events."

item 4.3 of Generic Letter 83-28

established the requirements for the automatic actuation of a ST attachment

for Westinghouse plants.

The automatic ST modification was based on the

generic design developed by Westinghouse under the sponsorship of the

Westinghouse Owners' Group.

The generic design was submitted to the NRC on

June 14, 1983, and a Safety Evaluation Report was issued on August 10, 1983,

endorsing the design.

The modification provides for automatic actuation of

the reactor trip breaker ST mechanism on a condition which deenergizes the

undervoltage coils.

The " Block" designation within the dotted line represents

the " Block Auto Shunt Irip" switch.

This switch is intended to be used during

the TADOT voltage measurements to preclude sensing the application of power to

the ST coil via the automatic ST feature.

This switch must be depressed in

order to independently verify the operability of the ST and undervoltage trip

circuits for the manual reactor trip function, as required by TS for the main

trip breakers.

The ST circuit on the bypass breakers can be tested

independently by measuring the voltage across the ST coils.

During a biennial review of Surveillance Procedure IPSP03-RS-0002, Revision 2,

" Manual Reactor Trip TAD 0T," a system engineer determined that the' procedure

did not independently test the manual ST function because. the " Block Auto -

Shunt Trip" switch was not' required to-be manipulated during:the TA00T. This

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step is necessary in order to test the set of contacts that directly completes

a current path to the ST device, which trips the breaker.

AsLa result, these

contacts had not been independently tested by the manual reactor trip TADOT

procedure.

The system engineer also noted that the surveillance procedure

f ailed to independently verify operabil_ity of the ST- circuit _ on the reactor

trip bypass breakers because voltage was not measured across the bypass

breaker ST' coils during the TAD 0T.

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The . inspectors reviewed Generic Letter 85-09, " Technical Specifications for

Generic Letter 83-28, item 4.3."

Ge7evic Letter 85-09 was issued to all

Westinghouse pressurized water reactor licensees and applicants, including

South Texas Project (STP), to inform the licensees- and applicants- that. TS

changes should be proposed to explicitly require independent testing of the.

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undervoltage and ST circuits during power operation and independent testing of

the control room manual switch contacts during each refueling outage. The

inspectors noted that Generic Letter 85-09 provided explicit guidance on

independent testing of the ST circuit in that it stated that the " Block Auto

Shunt Trip" switch would have to be used to preclude sensing the application

of power to the ST coil via the automatic ST feature.

Although the licensee's

15 reflected this independent testing requirement, the appropriate test

methodology was never incorporated into the subject surveillance procedure.

Licensee personnel could not explain how the omission occurred.

The failure to satisfy the requirements of TS Surveillance Requirement 4.3.1.1

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is an apparent violation (498;499/9217-01).

The licensee has initiated

actions to revise the TADOT procedures in order to properly perform the TADOT

during the next shutdown of each unit.

1.3 ticensee Identification and Correction of Problem

The inspectors reviewed the procedures and programs that the licensee had in

place to disposition the problem described in Section 1.2 and conducted

interviews with involved personnel. After reviewing and evaluating

Interdepartmental Procedure IP-1.450, Revision 8, " Station Problem Reporting,"

the inspectors concluded that the problem reporting process at STP, if

followed, appeared adequate to ensure the prompt identification,

documentation, reporting, and correction of safety-related problems.

The

inspectors also reviewed Interdepartmental Procedure IP-1.58Q, Revision 1,

" Preparation of Justifications for Continued Operation (JCO)." This procedure

interfaced with Interdepartmental Procedure IP-1.45Q in that, when an SPR was

submitted to the Shif t Supervisor, the Shif t Supervisor was responsible for

determining whether the deficiency described in the SPR rendered any safety

systems inoperable as defined in the TS.

The inspectors noted that, if the

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SPR resulted in an " indeterminate" condition concerning the operability of

safety-related systems or components, the Plant Manager was to be contacted

and the Shift Supervisor was to indicate on the SPR that a JC0 was required.

The inspectors determined that plant operation could continue with safety

systems in an indeterminate condition for an indefinite period since there was

no explicit guidance on when the JC0 must be completed.

The inspectors

considered this lack of procedural guidance to be a weakness.

However, the

inspectors did not iden-ify any examples in which a TS allowed outage time was

exceeded without appropriate action taken while a JC0 was being processed.

The JC0 procedure addressed the possibility that a TWOC may be appropriate in

certain instances.

However, there was no reference made to any procedure to

follow in requesting a TWOC.

The inspectors verified that there was no such

procedure in place.

The inspectors considered this lack of procedural

guidance to be a weakness.

The inspectors discussed with the licensee the JC0 procedure and its

relationship to the SPR procedure. The licensee stated that they were

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developing a new corrective action program that will replace the SPR -

procedure, and that the two NRC-identified weaknesses already were being

addreased.

The inspectors conducted reviews of the SPRs and other documentation related

to the shutdown event described in Section 1.1 and interviewed key licensee

personnel involved in order to gain an understanding of how the licensee

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handled the problem and whether the actions taken were in accordance with the

licensee's corrective action program.

The inspectors identified the following.

event chronology:

On May 18, 1992, at approximately 3:30 p.m., a system engineer

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identified a potential TS surveillance deficiency in: Station.

Procedure IPSP03-RS-0002, Revision 2, " Manual-Reactor Trip TAD 0T " th:t,

if valid, may render both redundant trains of the manual-reactrc t 1?

circuits for both- units-inoperable.

Because the' System Enginet*

realized that such a condition may require both units to be. shut uver

he discussed the. issue with his supervisor and a nuclear licensins-

supervisor at approximately 5 p.m.

However, since additional ~reiiew vas

needed to determine whether the surveillance deficiency wasfvalie, the y

decided not to work overtime on the potential problem, but agreet to

initiate a thorough study of the issue the following day.

On May 19, 1992, at approximately 8:15 a.m., the Licensing Manager-was

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informed of the potential problem.

On May 19, 1992, at approximately 8:30 a.m., the Corrective Action.

Group (CAG) Administrator was informed of the potential problem.

The

CAG Administrator informed the Plant Manager and the Plant Operations

Manager at approximately 9:40 a.m., after the: plan-of-the-day meeting.

The Plant Operations Manager told- the_ inspectors that_ he did not

understand the shutdown implications of the deficiency at that_ time.and_

went on to other meetings.

At 10 a.m., a meeting was held to discuss the technical aspects of:the

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trip circuit and the requirements for TS surveillance testing, fThe

meeting was attended by plant engineering and licensing personnel.

By

12 noon, no conclusive determination had:been made and. individuals were

assigned various tasks in order to obtain-additional-information.

They-

decided-to reconvene the meeting at 2 p.m.-

At _approximately 12 noon,- the Plant Manager was briefed by the Licensing;

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. Manager that there was a likely problem regarding operability of_'the

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reactor trip circuitry.

At approximately 12:30'p'.m.,;the NRC Senior Resident Inspector'(SRI) was

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informed of the potential problem-and was told that there would be a

meeting at 2Jp.m. to further discuss the issue.

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At 2 p.m., a meeting was held by plant engineering and licensing

personnel.

The Plant Manager, the SRI, Institute of Nuclear Power

Operations representatives, and independent Safety Engineering Group

personnel were also present.

No Plant Operations Department personnel

were present.

Licensee personnel die. cussed the TS surveillance

requirements as they related to the circuits in question.

The

applicability of TS 4.0.3, which allows a delay of the applicable TS

action requirements for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (for those TS that have allowed

outage times that are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), to implement a missed

surveillance or obtain a TWOC from NRC, was discussed. The

applicability of TS 4.0.3 was dismissed by the licensee because the

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subject surveillance requirement had never been performed.

At 2:30 p.m., with no apparent Plant Operations Department involvement

since 9:30 a.m., the Plant Manager concluded that the manual reactor trip circuit in question had not been tested, as required by TS, and

that both units were not in compliance with TS Surveillance

Requirement 4.3.1.1.

As a result, the Plant Manager concluded that a

shutdown of both units was required by TS 3.0.3.

The SRI acknowledged

the declaration and departed to inform Region IV management and to

discuss a potential licensee request for a lWOC since the circuits could

not be tested while the reactors were at power.

At approximately 2:45 p.m., the Licensing Manager directed the issuance

of an SPR.

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At approximately 2:50 p.m. , the Plant Manager directed that the SPR

(92-0200) be delivered to the Plant Operations Manager with inst ructions

for him to discuss the issue with the Plant Manager before informing

both control rooms.

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By 3:30 p.m.,

the Plant Manager and Licensing Manager had briefed the-

Group Vice President, and the decision was made by the licensee to

pursue a TWOC request.

At approximately 3:40 p.m., the Plant Operations Manager was given the

SPR while he was in route to the SRI's office.

This appeared to be the

first time a Plant Operations Department representative became involved

in the process.

The Plant Operations Manager told the inspectors that

he still did not recognize the plant shutdown implications of the SPR at

that time.

At approximately 4 p.m., a conference call commenced between the

licensee, Region IV personnel, and Office of Nuclear Reactor

Regulation (NRR) personnel, to discuss the licensee's request for a

TWOC.

The licensee was not prepared to answer NRC's questions, nor had

the Plant Operations Review Committee (PORC) concurred in the TWOC

request as required by NRC guidance that was available to and previously

used by the licensee.

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At approximately 4:15 p.m., a second conference call was convened in the

SRI's office with licensee management personnel, Region IV personnel,

and NRR personnel. During that conversation, when Region IV management

questioned the licensee as to the status of the actions required by

IS 3.0.3, it became apparent that the Shift Supervisors of both units

had not been informed that TS 3.0.3 had been invoked by the Plant

Manager at approximately 2:30 p.m.

As a result, the required plant

shutdowns had not been initiated, nor had an NOVE been declared.

The

Shift Supervisors of both units were immediately informed by the Unit 1

Operations Manager following the completion of the conference call.

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At 5:01 p.m., Unit 2 commenced a shutdown in accordance with TS 3.0.3.

At 5:05 p.m., Unit I commenced a shutdown in accordance with TS 3.0.3.

At 5:06 p.m., an NOUE was declared in accordance with the licensee's

emergency plan.

At approximately 5:35 p.m., the'PORC meeting concluded with a

recommendation that the Plant Manager approve the TWOC request.

At approximately 5:45 p.m., a TWOC was granted by NRC, and power was

levelled at about 80 percent on both units.

This TWOC allowed for

continued operation of both units until an emergency TS amendment could

be reviewed by NRC.

The one-time TS amendment was subsequently app

ed

on June 2, 1992.

Interdepartmental Procedure IP-1.45Q, Revision 8, " Station Problem Reporting,"

Step 6.1.1, requires that any person who discovers a condition that may impact

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the safe and reliable operation of the plant shall originate an SFR and, if

the condition appears to require immediate response, the originator shall

report the condition immediately to the Shift Supervisor.

Contrary to this

requirement, on May 18, 1992, a condition that had the potential to impact the

safe and reliable operation of the plant was discovered during the review of

Surveillance Procedure IPSP03-RS-0002, Revision 2, " Manual Reactor Trip

TA00T," and an SPR was not originated.

In addition, on May 19, 1992, after

generating an SPR and knowing that the condition required immediate response,

cognizant licensee personnel did not report the condition immediately to the

Shift Supervisor.

Failure to follow Interdepartmental Procedure IP-1.45Q is

an apparent violation (498:499/9217-02).

1.4 Review of SPRs

The inspectors reviewed other completed and in-process SPR records in order to

assess the degree of compliance with the established programs and procedures.

The inspectors reviewed operability and reportability determinations and

evaluated the acceptability and timeliness of corrective actions taken or

planned by the licensee.

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The inspectors reviewed Procedures IP-1.45Q, IP-1.58Q, and OPGP03-ZA-0088,

Revision 1, " Station Procedure for Nonsafety-Related Request for Action

Program." Ten SPR packages that had been issued during 1991 and 1992 were

reviewed, of which the majority had been completed.

Some SPRs reviewed

required operability and reportability determinations.

Operability

determinations of equipment appeared to be accurate and timely and complied

with TS and plant procedures.

Some of the SPRs reviewed included JC0 reports

which had been generated as a result of particular operability determinations.

The JCOs complied with the licensee's procedure and appeared to be adequate.

Upon completion of the SPR reviews, the inspectors found that the scope of the

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licensee's corrective actions program appeared to be adequate.

The

inspectors, however, made the following observations pertaining to the

implementation of the SPR program.

First, there were approximately 495 SPRs

written in 1991, and 214 SPRs written (as of the time of the May 26-29 portion

of the inspection) in 1992.

The inspectors determined that there were

numerous extensions requested, and granted, to complete the SPRs.

The

inspectors noted that numerous extensions, resulting in delayed corrective

actions, could lead to repetitive problems.

Second, the inspectors identified

that certain events were not reported to NRC in a timely manner.

The

inspectors identified a few SPRs in which it took the licensee several days to

determine whether a system actuation (e.g., an engineered safety feature

system actuation) was required to be reported to NRC in accordance with

10 CFR 50.72 and 50.73. On several occasions, reporting of certain actuations

to NRC was required, but they were reported late. This issue was previously

identified by NRC (refer to NRC Inspection Report 50-498/91-30; 50-499/91-30).

An additional example of failing to satisfy the 10 CFR 50.72 time requirements

was identified by NRC in August 1992 during the conduct of a routine resident

inspection.

A Notice of Violation was issued for this occurrence (refer to

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NRC Inspection Report 50-498/92-26; 50-499/92-26).

The inspectors also reviewed SPR 92-0128. which was issued on April 9, 1992,

to investigate the cause of a reactor coolant system excessive couldown

transient. As a result of the investigation, the licensee determined that

there was a reluctance on the part of plant personnel to use the station

problem reporting process.

Several statements by personnel knowledgeable of

the transient indicated that, in their opinion, the problem resolution system

did not solve problems and that the adverse impact associated with the

initiation of an SPR was not conducive to its use. The corrective action

planned to address this issue was to reiterate the requirement for personnel

to initiate an SPR when events occur or issues arise that need management

attention to ensure that the appropriate evaluations are performed.

The

inspectors considered this corrective action to be inadequate because it did

not address the underlying causes of the perceived adverse impact associated

with the initiation of an SPR.

The inspectors concluded the failure to

initiate an SPR in a timely manner for the May 18-19, 1992, event also to have

been caused, in part, by a reluctance of some station personnel to initiate an

SPR because of a perceived adverse impact.

The failure to implement effective

corrective actions is considered an apparent violation of the requirements of

10 CFR 50, Appendix B, Criterion XVI (498:499/9217-03).

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2 PLANT SHUTDOWN INITIATED BECAUSE OF A LOSS OF DIGITAL R0D POSITION

INDICATION (93702)

2.1 Overview

On September 3,1992, the Digital Rod Position Indication (DRPI) system in

Unit I was declared inoperable because of a f ailure of both power supplies.

As a result, the action statements of TS 3.1.3.2 could not be met and TS 3.0.3

was entered at 10:49 a.m.

Attempts to repair the system within the 1-hour

allowance of TS 3.0.3 were unsuccessful and, at 11:49 a.m.,

an NOUE was

declared and operators began taking actions to shut down the reactor.

At

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1:52 p.m., reactor power reduction was commenced from 86 percent.

The unit

had been in a power coastdown in preparation for the upcoming refueling

outage. While continuing with the reactor shutdown, instrumentation and

control personnel were able to identify the source of the problem and

initiated the replacement of one of two power supplies.

At 2:15 p.m.,

the

power supply replacement was completed, and the DRPI system was returned to

operabl e . Also at this time, the reactor power reduction was terminated after

reaching 75 percent.

TS 3.0.3 was exited at 2:26 p.m. and, at 3:04 p.m.,

operators commenced increasing reactor power at 5 percent per hour.

The

reactor was returned to 85 percent power during the morning of September 4,

1992.

2.2 Licensee Identification and Correction of the Problem

The DRPI system is powered by two power supplies with an auctioneering

function to permit power supply transfer in the event of a failure of one

power supply.

Power supply failure, as sensed by low output voltage, is

annunciated to alert control room operators of a power supply problem. During

this event, both power supplies failed and there was no indication on the main

control haard of a power supply failure.

Preliminary investigation into the

cause of the failure indicated that the backup power supply was in a degraded

condition, such that output voltage was sufficient to indicate satisfactory

standby operation but, when loaded, was not able to maintain rated voltage.

At the end of the inspection, the licensee was continuing to investigate the

cause of the failure of both power supplies.

2.3 Licensee Policy for Complying with TS 3.0.3

As a result of the event on May 19, 1992, the Plant Operations Manager issued

a memorandum on June 8, 1992, to the Policies and Practices Manual providing

guidance to plant operators upon entering TS 3.0.3.

This memarandum stated

that, "It is the policy of the Plant Operations Department that when we enter

a Technical Specification statement requiring the unit to be placed in Mode 3

in the next six hours we will immediately upon entry into that six hour time

block:

Declare an unusual Event based on a shutdown required by Technical

Specifications, and

-__-__-_

_ _ _ _ _ _ _ - _ _ -

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

__

_ _ __ ______

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12-

Commence an orderly plant shutdown in accordance with OPGP-ZG-0006,

e

' Plant Shutdown from 100% to Hot Standby' at a rate of approximately 20X

per hour.

The ramp rate may be adjusted with the permission of the Unit Operations

Manager."

During this event, control room operators were in the process of implementing

this guidance when, at 11:48 a.m., 2 minutes before entry into the 6-hour time

block, a f acsimile was received in the control room from the Plant Operations

Manager

This facsimile was a memorandum, dated September 3, 1992, which was

-

intended to supersede the June 8, 1992, memorandum,

it stated, "It is the

policy of the Plant Operations Department that when we enter a Technical

Specification action statement requiring the unit to be placed in Mode 3 in

the next six hours we will upon entry into the six hour time block:

Up to two hours may be used for emergency repair or troubleshooting at

the Shift Supervisor's discretion.

In all cases the Shift Supervisor

shall allow sufficient time for a controlled and orderly shutdown,

After the two hours have expired or earlier at the discretion of the

Shif t Supervisor, declare an Unusual Event based on a shutdown required

by Technical Specifications, and

Commence an orderly plant shutdown in accordance with OPGP-ZG-0006,

.

' Plant Shutdown from 100X to Hot Standby' at a rate of approximately 20X

per hour.

The ramp rate may be adjusted with the permission of the Unit Operations

.

Manager."

-

This second memorandum resulted in a certain degree of confusion on the part

of some operators because they were being directed to change the method of

TS 3.0.3 implementation while they were preparing to implement the June 8,

1992, guidance.

There was no basis provided with the memorandum and it

appeared to have contradicted the requirements of Procedure OERP01-ZV-IN01,

" Emergency Classification," which, according to plant operators, they had been

trained to interpret as requiring the declaration of an NOUE after the

expiration of the TS allowed outage time for those TS that require a plant

shutdown.

For this event, the Shift Supervisor declared an NOUE at the end of

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, consistent with past practice.

The inspector conducted interviews of various licensed operators subsequent to

the event and determined that there was a general feeling that the change to

existing policy during an event was inappropriate.

Most operators interviewed

also believed that the contents of the memorandum should have been more

appropriately handled through a formal TS Interpretation.

The inspector reviewed the licensee's procedures for the control of formal

interpretations of TS requirements.

Procedure OPGP03-ZO-0018 Revision 4,

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" Technical Specification Interpretation Control," is required to be used for

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those situations which are not clearly or specifically addressed by wording in

the TS.

The procedure also states that its purpose is to provide'a mechanism

for approving clarifications and formal interpretations of the TS.

In

addition, Procedure OPGP03-Z0-0040, Revision 0, " Maintenance of the Operations

Policies and Practices Manual," states that memoranda from whatever source

that are potentially TS interpretations should be formally routed by the

initiating authority through the formal evaluation process for inclusion in

Addendum 1 of the TS.

Addendum I is the document that contains all TS

Interpretations.

Both the June 8 and the September 3, 1992, memoranda

provided guidance which is not clearly or specifically addressed by the

-

wording in TS 3.0.3.

As a result, the Plant Operations Manager should have

utilized Procedure OPGP03-ZO-0018 instead of issuing memoranda to provide

guidance to the control room operators for implementing TS 3.0.3.

The failure

to follow the procedural requirements of Procedures OPG03-ZO-00lG and

OPG03-ZO-0040 is considered an apparent violation (498;499/9217-04).

3 MANAGEMENT MEETING (30702)

As a result of the special inspection on May 26-29, 1992, a meeting was held

on August 28, 1992, in the Region IV office to permit the NRC to gain a better-

understanding of tre licensee's actions relative to the May 19, 1992, event.

NRC requested that the following issues.be addressed:

Provide a detailed chronology as well as a description of the facts

surrounding the period from the initial identification of the potential

deficiency by the System Engineer, apparently'at 3:30 p.m. on May 18,

1992, until the Shift Supervisors were notified of the condition on

May 19, 1992.

Given the implications associated with the potentially

missed surveillance (i.e., apparent TS violation and potential for-plant

-

shutdown), why was this issue not pursued until conclusion during the

evening of May 18, 1992.

Given that the Plant Manager was directly involved in the operability

determination and that there apparently was a piocess in place to ensure

that theRShift Supervisors are informed of contitions such as this

(i.e., the SPR procedure), why were the Shift Supervisors not informed

of this condition until prompting by the NRC?

Given that STP managers and staff have successfully utilized the.TWOC

process-on several occasions in the past and have at least requested the

use of the process more than any other facility in Region IV, why was

the process not followed for this particular event? Describe the-nature

of any deliberations specific to-the TWOC process that occurred prior to

initiating a conference call-with NRC on May 19, 1992.

Provide a full description of senior management's expectations relative

to issues that have the potential.for plant shutdown.

In' addition,

describe senior management's understanding of-and involvement-in the

_

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issue on May lo, 1992. What are the corrective actions taken or planned

to prevent recurrence of this and similar events?-

What was the process for making the operab'ility. determination and

subsequent determination of the applicability of the appropriate-TS?

Did this process conform to established guidance? What is management's

expectation and guidance relative to implementing the requirements nf

TS 3.0.37

The licensee presented.a chronology of the event and detailed the corrective

actions that were taken or planned. Appendix B is a copy of the material that

the licensee presented at this meeting.

During this meeting, the licensee

acknowledged that the SPR procedure had not been properly implemented.

The

licensee stated that an SPR should have been originated on May 10, 1992, and

that the control room operators should have been informed of the problem at

the time of discovery.

The former plant manager indicated that the licensed

control room operators should have been informed of the condition at

2:30 p.m.: however, he stated that his priorities were to make the best safety-

judgement (i.e., there was adequate safety basis for not shutting down both

units because of this condition), to request a TWOC from NRC as soon as

possible, and then inform the licensed operators. He stated, that on May 19,

1992, he was convinced that he could comply with the license requirements and

still get a TWOC before it was necessary to direct a shutdown of both units.

As a result of this meeting, the licensee committed to provide additional

information requested by NRC and respond, in writing, to several questions

asked by NRC.

These included:

At what time on May 18, 1992, did the individuals stop investigating the

possibility that surveillance of the ST circuitry had not been

performed? Was overtime a consideration in not continuing to

investigate this potential problem on May 18, 1992?

On May 18, 1992, did the individuals working on the ST surveillance

issue recognize the possibility that a plant shutdown might be required

if the surveillance had not been performed?.

When and under what circumstances did the Shift Supervisors or any other

licensed operator become aware of the ST surveillance testing issue?

What did thev learn at'that time?

Was Generic Letter 85-09 referenced in the ST ' surveillance procedure

.

that existed on May 18, 1992? Were the individuals who were reviewing-

the issue on May 18, 1992, aware of the applicability of Generic

letter 85-09 before the 10 a.m. meeting on May 19, 1992? Provide the

specific details of determining the inoperability of the ST circuit as

pursued by the Nuclear Licensing and Plant Engineering Departments.

Was the need to write an SPR (or the fact that one had not been

prepared) discussed any time prior to 2:30 p.m. on May 19, 1992,

particularly at the 10 a.m. meeting on May 19, 1992?

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Did anyone from the control room-(shift supervisor) attempt to contact

station management regarding the ST surveillance-issue? If so, describe

the circumstances and response provided.

Provide a copy of the procedural guidance that existed on May 19, 1992,

regarding the implementation of TS 3.0.3.

Provide a copy of the licensee investigation of the May 19, 1992, event.

_

The licensee provided a written response 05. September 11, 1992 (Appendix C).

At the September 15, 1992, exit meeting, NRC noted, in general terms, that

there were some inconsistencies between the September 11, 1992,: written

response and previous verbal responses to NRC questions at the August 28,-

1992, management meeting and information obtained by the inspectors during the

conduct of the special inspection.. The details of these discrepancies are

.

provided in the following paragraphs.

3.1

Decision to Discontinue Investigation on Ma_y 18. 19_92

During the first portion of the special inspection that was conducted _during__

the period of May 26-29, 1992, the inspectors determined from interviews with

licensee personnel, that, since additional reviews were needed to determine

whether or not the-licensee was complying with the applicable TS Surveillance

Requirement, they would not work overtime but pursue the issue the following-

morning. At the August 28, 1992, management meeting, licensee management

personnel stated that the bases for not pursuing the issue on the evening of

May 18, 1992, were:

(1) the' safety <ignificance was low because there was

multiple redundancy associated with the reactor trip system; and'(2)-the

individuals involved were not certain of the TS Surveillance Requirement.

However, in the supplemental response of September 11, 1992, the. licensee

indicated that these individual believed that the subject surveillance

s

procedure satisfied- the applicable TS Surveillanc'e Requirement, and -the only_

valid issue of concern was whether the surveillance procedure test methodology

was appropriate.

Subsequent to the August 28, 1992,- management meeting,_ discussions with the

two System Engineers who were reviewing the potential surveillance deficiency

'

on May 18, 1992, revealed-that only one of- these individuals believed that the =

surveillance procedure satisfied the TS Surveillance Requirement, while the

1

System Engineer who identified the surveillance deficiency believed that there-

was a potential that the TS Surveillance Requirement was not satisfied by. the

surveillance procedure. _10 CFR 50.9 requires,;in part, that-information

provided to NRC shall be complete and-accurate.in all material' respects. _The

l

failure to accurately respond-to_NRC's request for.informatio_n relative to the

discontinuation of:the licensee's review of the shunt trip devicelsurveillance

deficiency on May 18,:1992, constitutes an example of an' apparent violation of

10 CFR 50.9 (498;499/9217-03).

'

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'3.2

Procedural Requirements for implement-ing TS 3.0.3

During the August 28, 1992, management meeting, the former-Plant Manager

stated that there was a procedure-that-implemented the requirements of

TS 3.0.3 that prevented-him from directing the licensed operators to not-

initiate--a power reduction-immediately after the expiration of I hour _-

following the entry into TS 3.0.3.

When questioned further by NRC, he stated

it would have taken longer than I hour to implement the procedure revision-

process in order to change the guidance to the operators.

The former Plant

Manager stated that, as a result, the operators would have commenced the

shutdowns of both units before a procedure revision could be implemented,

thereby making unnecessary the need for.a TWOC.

In the September 11

1992, response, the licensee indicated that.the only

t

guidance in effect during the May 19, 1992, event that pertained to TS 3.0.3l

was contained in the Plant Operations Department Policies and-Practices

Manual. Although this policy provided management expectations regarding the

voluntary entry into TS 3.0.3 and restated the action requirements, it did not

provide specific implementation steps to be taken following entry into

TS 3.0.3.

Although not specified in the licensee's response, NRC determined

<

that the same guidance (in the form of a TS Interpretation) is also contained

in Addendum 1 of the Houston Lighting & Power Company TS.

The inspectors

concluded that the information provided at.the management meeting was.

,

'

inaccurate. The failure to provide accurate.information to NRC constituted-

the second example of an apparent violation of 10'CFR 50.9 (498;499/9217-05).

3.3

Initiation of an SPR

During the August 28, 1992, managemcnt-meeting, NRC-asked whether the

initiation of an-SPR was discussedoat any time on May 19, 1992, prior to-

2:30 p.m., particularly at the 10 a.m. meeting which was attended by the

Nuclear Licensing Manager. The Nuclear Licensing. Manager stated that he did

not ask about-the initiation of an SPR after he became aware of the issue at

approximately 8:15 a.m., on May 19, 1992,- and_he was not certain-whether._an

_

'SPR was discussed at the 10 a.m. meeting.

On the basis _ of the information'

provided in the September 11, 199T, response, the status of a draft SPR was

discussed at'the beginning of the 10 a.m. meeting.

3.4 Additional Supplementary Information

'

-The licensee submitted an additional written response on September 18, 1992,

'

(Appendix D), to provide clarification of the apparent discrepancies that- were

- identified following the September 15, 1992, exit meeting.

NRC reviewed this,

additional information 'and: found that it provided no additional pertinent

information relative to the issues discussed in Sections 3.1-3.3.

,

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ATTACHMu

1

1~ PERSONS CONTACTED

1.1.

Licensee Personnel

• • C. Ayala, Supervising Engineer, Nuclear Licensing

'

• J. Blevins, Supervisor, Procedure Control

• C. Bowman, Corrective Action Group (CAG) Administrator

1. • M. Chakravorty, Executive Director, Nuclear Safety Review Board

• R, Chewning, Vice President, Nuclear Support

1. • R. Dally-Piggott, Engineering Specialist, Nuclear Licensing

• D. Denver, Manager, Nuclear Engineering

,

• S'. Eldridge, Senior Consulting Saecialist, Quality Assurance

• R. Garris, Manager, Nuclear Purciasing and Material Management-

.

• J. Gruber, Director, Independent Safety Engineering Group

.

+ *D. Hall, Group Vice President

1. • A. Harrison, Supervising Engineer, Nuclear Licensing

• S. Head, Consulting Engineer, CAG

1. • T. Jordan, General Manager, Nuclear Assurance

+#*W. Jump, Manager, Nuclear Licensing

.

• W. Kinsey, Vice President, Nuclear Generation

1. • D. Leazar.. Manager, Plant Engineering

+ *J. Ledgerwood, Consulting Engineering Specialist, CAG

• J. Lovell, Director, Nuclear Generation Projects

• M. Ludwig, Administrative Participant Services

• M. McBurnett, Manager, Integrated Planning and Scheduling

• T. Meinicke, Senior Consultant, Planning and Assessment

1. • G. Midkiff, Manager, Plant Operations

• H. Pacy, Division Manager, Design Engineering Department

+#*G. -Parkey, Plant Manager

• G. Ralston, Manager, Facilities-

• K. Richards, Division Manager, Maintenance

• • S. Rosen, Vice' President, Nuclear Engineering

• J. Sharpe, Manager, Maintenance

• B. ledder, Supervisor, Procurement- Quality - Assurance -

• L. Weldon,-Manager,' Operations Training

+ *M. Wisenburg, Special Assistant to Group Vice President

1.2 Contractor Personnel (Newman and Holtzinger)-

' #G.~ Edgar

1. J. Newman

+W. Baer

1.3 Owner Representative .

+M. Hardt,. Director, Nuclear Division, City Public-Service Board

San Antonio-

l.4 NRC Personnel

~

1. A. Beach, Director, Division of Reactor Projects (DRP), Region IV

+S.

Black Director, Project Directorate IV-2 (PDIV-2), 0ffice of-Nuclear

Reactor Regulation (NRR)

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40. Boal, investigator, Region-lV Office of Investigations

+W. Brown, Regional Counsel, Region IV

+S. Collins, Director, Division of Reactor Safety, Region IV

+G. Dick, Senior-Project Manager, NRR

1. +R. Evans, Resident inspector, DRP, Region IV

+#J. Gilliland, Public Affairs Officer, Region IV

• G. Guerra, Radiation Specialist. Intern, DRP, Region IV

+T. Gwynn, Deputy Director, DRP, Region IV

B. Hayes, Director, Office of Investigations

+#A. Howell,_ Chief, Project Section D, DRP, Region IV

• R. Kopriva, Senior Resident inspector, DRP, Region IV

+J. Milhoan, Regional Administrator, Region IV

+J. Montgomery, Deputy Regional Administration, Region IV

+G. Sanborn, Enforcement 0fficer, Region IV

• W. Smith, Senior Resident inspector, DRP, Region IV

1. • J. Tapia, Senior Resident inspector, DRP, Region IV

• Denotes personnel that attended the exit meeting on May 19, 1992.

1. Denotes personnel that attended the exit meeting on September

, 1992.

+ Denotes personnel that attended the management meeting on August ~ 28,.1992.

In addition to the personnel listed above, the inspecto'rs contacted other-

personnel during this inspection period.

2 EXIT MEETING

An exit meeting was conducted on May 29 and again on September 15, 1992.

During these meetings, the inspector reviewed the scope and findings of the

report.

On January 4,1993, durit g a telephone conversation conducted betwee:

NRC and the licensee, the licensee was informed of an additional apparent

violation that is documented in Section 3 of this report.

The licensee did

not identify as proprietary any information provided to, or reviewed by, the

inspectors,

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ATTACFJ4ENT 2:

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APPENDIX B

' '

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SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION

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HL&P - NRC MANAGEMENT MEETING

j

TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

j

AUGUST 28,1992

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HL&P - NRC MANAGEMENT MEETING

TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

AUGUST 28,1992

AGENDA

_

e Opening Remarks

D. P. Hall

e Event Chronology

.W.J. Jump

e Specific Information.

M. R. Wisenburg

f

e Corrective Actions

G. L Parkey

'

e Closing Remarks

D. P. Hall

'

.

e m -

TECHNICAL SPECIFICATION O.0.3 ENTRY ON MAY 19,1992

EVENT CHRONOLOG1

Monday, May 18

=1530

e System Engineer discovered possibility that a portion of the shunt trip

circuit may not be tested in accordance with Technical Specification

requirements

Not sure whether this' portion of circuit may have been tested under

-

other procedures

Uncertainty as to precise scope / meaning of Technical Specification

-

e issue discussed with immediate supervisor

'

issue discussed with Nuclear Licensing

=1700

e

Review of procedures and drawings not yet complete; Technical

e

Specification' requirements still not fully understood; Insufficient

information to conclude that a probiera actually existed

-

Tuesday, May 19

= 0815

e Licensing Manager informed of potential problem

0830

e Corrective Action Group (CAG) Informed of potential problem

0940

e CAG informed Plant Manager and Plant Operations Manager of

potential problem

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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

E_ VENT CHRONOL _OGY (Continued)

Meeting conducted with attendance by Plant Engineering Department,

Tuesday, May 19

1000

e

Design Engineering Department, Nuclear Engineering Department, CAG,

and Nuclear Licensing

e Conclusion reached that the contacts should be tested; however,

whether testing was required by Technical Specifications was still

unknown

Meeting adjourned with plans to meet again at 1400

1200

e

e Four actions discussed in meeting were to be completed:

- Contact Westinghouse concerning bases for Technical Specification

- Review relevant WCAP in detail

- Review Maintenance records for testing of shunt trip

- Review Generic Letter

e Nuclear Licensing Manager briefed Plant Manager on status, pending

actions, and 1400 meeting

1230

e Nuclear Licensing Manager briefed NRC Senior Resident inspector on

situation

2

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TECHNICAL SPECIFICATION 3.0.3 ENTHY ON MAY 19,1992

i

EVENT CHRONOL _OJX (Continued)

Tuesday, May 19

1400

e Meeting reconvened with additional attendance by: Plant Manager,

INPO, independent Safety Engineering Group (ISEG), and NRC Senior

Resident inspector

Plant Operations Department not present at meeting

e

1430

e Conclusion reached that shunt trip portion of the reactor trip circuitry

had not been tested and that it was required to be tested

e Licensee determined to be operating outside of 8ts required boundaries,

and that Technical Specification 3.0.3 was applicable

e NRC Senior Resident Inspector informed of this conclusion, and notes

that 1430 was the time at which it was determined that Technical Specification 3.0.3 was applicable

1435

e Senior Resident inspector left meetireg to brief other NRC personnel.

HL&P believed his intent was to discuss the 3.0.3 condition and HL&P's

consideration of request for Temporary Waiver of Compliance. -

1445

e Meeting concludes with Nuclear Licensing Manager directing the

issuance of a Station Problem Report (SPR)

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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

EVENT CHRONOLOGY (Continued)

Plant Manager directs that SPR be delivered to Plant Operations

Tuesday, May 19

1450

e

,

Manager with instructions to discuss issues with the Plant Manager

before informing the Control Rooms

1500

e Plant Manager and Nuclear Licensing Manager brief Group Vice

President on the situation and plan to request Temporary Waiver of

Compliance

i

1540

e SPR delivered to Plant Operations Manager en route to Senior Resident

inspector's office for conference call with NRR and Region IV

o Conference call conducted to discuss HL&P plans to request a

Temporary Waiver of Compliance

e Conference call attendees include Plant Manager, Nuclear Licensing

Manager, Plant Operations Manager, and Senicr Resident inspector

Plant Operations Manager concerned about operability of shunt trip

~1600

e

~

contacts

e Plant Operations Manager contacts Unit 1 Operations Manager

4

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TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

EVENT CHRONOLOGX (Continued)

NRC advised

e Conference call ends for NRC closed discussion.

Tuesday, May 19

1605

Licensee that call would be resumed after the NRC discussion.

e Licensee attendees retire to Plant Manager's office

e Second conference call occun in Senior Resident inspector's office

1615

e Unit 1 Operations Manager is present for second conference call

Method for requesting Temporary Waiver of Compliance was initially

discussed, with conversation later turning to plant shutdown status

e

e Statements made during conference call lead Plant Operations

=1630

representatives to conclude that affected circuitry should have been

declared inoperable at 1430

e Plant Operations determines that Technical Specification 3.0.3 was

1640

applicable and a shutdown of both units should immediately commence

e Unit 1 Operations Manager contacts Unit 2 Shift Supervisor to inform

=1650

him of the situation and directs unit shutdown

5

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TECHNICAL. SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

EVENT CHRONOLOGY (Continued)

Tuesday, May 19

~1655

e Unit 1 Operations Manager contacts Unit 1 Shift Supervisor to inform

him of the situation and directs unit shutdown

1701

e Unit 2 Control Room declares entry into Technical Specification 3.0.3

and commences shutdown

1705

e Unit 1 Control Room declares entry into Technical Specification 3.0.3

and commences shutdown

e Plant Operations Review Committee meeting commences

1706

e Unusual Event declared

1735

e Plant

Operations

Review

Committee

meeting

concludes

with

i

recommendation that Plant Manager epprove Temporary Walver of .

Compliance

NRC grants Temporary Waiver of Compliance

1745

e

6

.

e

W

-"--' -

--

-

-

-

-

-

-

.

- -

-

. - -

.

.

-

-

-

- .

'

_ _ _ _

.

TECHN'ICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

EVENT CHRONOLOGY

(Continued)

-Tuesday, May 19

1751

e Unit 1 terminates shutdown

.

5

1752

e Unit 2 terminates shutdown

I

'

1753

e Unusual Event terminated

.

SPECIFIC INFORMATION

o Control Room Notification

,

,

'

.

.. I

r

7

.

.,

. .

-

i.

m-

_ __ _ _ __ _ _ _ _ _ _ _ _ _ .

_ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _

TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

CORRECTIVE ACTIONS

Testing of the manual shunt trip will be performed during the next outage where the plant is

e

in MODE 3 or lower for each unit.

Testing of the manual shunt trip will be performed

periodically during future refueling outages.

e A verbal Temporary Waiver of Compliance was granted by the NRC on May 19,1992, followed

by a written authorization on May 21, 1992.

A license amendment to the Technical

Specifications was approved by the NRC on June 2,1992.

As an immediate action, the surveillance procedures which test the trip function of tiie reactor

e

trip and bypass breakers were reviewed for similar deficiencies with no adverse findings.

e . An indepth review of ESFAS and reactor trip surveillance procedures for one train of one unit

is underway to ensure they adequately meet Technical Specification requirements.

In each

instance where a discrepancy has been noted, an SPR has been promptly provided to the

control room. This review will be completed by November 3,1992.

Written guidance was developed regarding the implementation of Technical Specification 3.0.3.

e

8

.

.

.

TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

_C_ORRECTIVE ACTIONS (Continued)

!

Instructions dealing with " potential operability" problems and promptly informir.g the Shift

e

Supervisor have been included in the new Corrective Action Process which becomes effective

on September 9,1992.

j

Formal procedures are being developed which address the handling of unresolved problems

i

e

from an operations standpoint and how operability decisions are made and implemented.

These procedures will be developed by September 25,1992.

A formal procedure is being developed governing the processes inv ilved with obtaining a

.

Temporary Waiver of Compliance. This procedure will be completed by September 25,1992.

,

I

The Vice President, Nuclear Generation, discussed the lessons learned from this event with

e

the licensed operators.

i

An evaluation of the timeliness of problem identification has been conducted to determine

e

whether issues are normally provided to the control room in a timely manner.

l

,

9

.

..

v

.

-

TECHNICAL SPECIFICATION 3.0.3 ENTRY ON MAY 19,1992

l

.

CORRECTIVE ACTIONS (Continued)

!

o -The event was discussed at the regular site management status meeting to emphasize

i

Executive . Management's support of the role of the Shift Supervisor in making operability

i

determinations.

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Licensing processes were reviewed to determine the need to provide formal guidance on how

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to perform other non-routine activities such as the Temporary Waiver of Compliance.

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