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NRO EORM 366(4+6]

u. CLEAR REGULATORY COMMISSION

IXCEHSEE EV&2PZ REPORT (TER)

(See reverse for required number ofdigits/characters for each block)

PROVED BY OMB NO. 31504104EXPIRES 04/30/98

ESTIMATED BURDEN PER. RESPONSE TO COMPLY WITK TRISMANDATOAY INFORMATION COLLECTION REOUESTI SO.O KRS,RFPOATED LESSONS LEARNED ARE OICOAPORATEO INTO TKEUCENSING PROCESS AND FEO BACK TO INDUSTAY'. FORWARDCOMMENTS REGARDING BUADEN ESTIMATE TO TKE INFORMATONAND RECORDS MANAGEMENT BRANCH IT 6 F33]. U.S. NUCLEARREGULATORY COMMISSION, WASKINGTON, OC 2055$ 4OOI, ANDTO THE PAPERWORK REDUCTION PROJECT t3160 0104), OFFICE OFMANAGEMENTAND BUDGET, WAS KWGTON. DC 20503.

FACIUTYIl(V(IEI'II

Susquehanna Steam E(ectric Station - Unit 2oooo( NvM4EIIIEI

05000388PAQE Is)

1 OF 5

Entry into Technical Specification 3.0.3 - Rod Block Monitor Operability Testing

EVENT PATE (5]OAT

LER NUMBER (6)TEA(I SEOVENTIAl REVISION

NUM$EA NUMaQI

REPORT PATE 7]MONI1( OAT FACtulYHAME

OT1tER FACILI I S I VOLVEO (8]OOCIID'VM4ER

0500010 17 97 97 — 007 — 00 11 17 97 FACEI1Y KIJKE OOCKET NVI(4OI

05000ING

MODE (9)

POW R

LEVEL (10)

THIS REPORT IS SUBMI EO

20.2201 (D]

20.2203(a)(1)0.2203(a](2]0]

20.2203(a)(2)(»)»II

20, 3(a] (2) liv)

ZO.ZZ03(a] (2]I»]

20.2203(a)(3) (i)

20.2203la) (3) tii]

20.2203(a) (4)0.3 te)(1

50.36lc](2]

UIAEMENTSOF 1OCFR: l cc oooo5 .73(a](2]li)

50.73(a)(2) (»)

6) (2]llii]

50.73(a)(2)(iv)50. 3la)l Itv]

50. Ia)(2)(VBI

r more] l11]50,73(a] (2](yIII]

50.73(a) l2) (x)

OTHERpacify h Abstrael below

o(»I NRC Fo(m 366A

LICENSEE CONTACT FOR I L R (12)NAME

Stephen J. E)lis - Nuclear Licensing EngineerTELEX(ONE NI»(ISEA II»CLAIAtaa COdt)

717/542-3537

OMPLE E ONE N C IVI NEN ALLURE PES CRISEP IN HIS REPORT (13]CAllS4 sYST6M CQMPONEtc( %44lhF*CTVRER sysTEM Co»VONENT NANVfACTVAER REPORTAILE

To NPabs

SUPPLEMENTAL R ORT X

YES(II Yes, comp]etc EXPECTED SUBMISSION DATE).

(14) EXPECTEOSUBMISSION

DATE (15),

MONTH OAY YEAR

ABSTRACT (Liltto 1400 spaces, I,e., aPproximately 15 sin(]te spaced typewrmen ilneS (16]

On October 17, 1997, at 0920 hours, with Unit 2 in.Condition 1 (Power Operation) at 100% Power, aTechnical Specification 3.0.3 entry was voluntarily made. In accordance with the guidance of NUREG1022, a Technical Specification 3.0.3 entry requires an LER to be submitted within 30 days of the event.The entry was made to allow completion of surveillance testing of one channel of the Rod Block Monitor

'RBM)tafter considering the other available options. There is no provision provided in current TechnicalSpecifications to allow operability testing without entry into Technical Specification 3.0.3. It is PPRI 'sposition that this course of action was the most conservative from a nuclear safety perspective. TheTechnical Specification 3.1.4.3 ACTlON statement had been entered to perform surveillance testing of onechannel of the RBM. Unexpected results had been obtained during the testing. Investigation of theseresults determined that 11 LpRMs were not providing an output to the RBM. The testing resumed prior tothe expiration of Technical Specification 3.1.4.3 ACTION allowable time limit, but was not completedbefore the limit expired, thus requiring Technical Specification 3.0.3 entry. The cause of the LPRM failureshas been traced to inadequate post maintenance testing following earlier work associated with thesecomponents. The failed components were repaired/replaced, testing was completed and the RBM retu«edto operable status. The safety significance of this event was minor, and the health and welfare of thepublic was not compromised. The technical aspect of this event will be reviewed with the work group anda review of associated work plans and procedures will be performed, and appropriate changesimplemented.

NRC FORM 366 (4 35]

4(I(I

NRC FORM 366A(495)

LICENSEE EVENTREPORT g ER)TEXT CONTINUATION

U.S. NUCLEAR REGULATORY

COMMSSION'ACILITY

NAME t1) DOCKET

05000LER NUMBER I6)

YCAll IAl, V H~50l HUMID

PAGE (3)

Susquehanna Steam Electric Station - Unit 2

TEXT (ifmore speceis required, use edditionef copies ofHRC Form 36'O'Al I)7)

388 97 — 007 — 00 2 OF 5

EVENT DESCRIPTION

On October 17, 1997, at 0920 hours, with Unit 2 in Condition 1( Power Operation) at 100%power, a Technical Specification 3.0.3 entry was voluntarily made.

On October 16, 1997, at 0820 hours Technical Specifications Limiting Condition for Operation(LCO) 3.1.4.3 ACTION and 3.3.6 ACTION 60 were entered to perform required surveillances forthe Rod Block Monitor (RBM) (EIIS Code: I). The RBM must be removed from service to perform

~ these surveillances. The ACTION of the most limiting Technical Specification states:

"With one RBM channel inoperative, restore the inoperative channel to OPERABLE status within24 hours and verify that the reactor is not operating on a LIMITINGCONTROL ROD PATTERN;otherwise, place the, inoperable rod block monitor channel in the tripped condition within the nexthour."

A few hours into the testing, unexpected results were observed and testing was halted toinvestigate these results. Since the RBM remained inoperable, the LCO ACTION remained in

~ .> effect. The 24 hour time period expired prior to restarting the surveillance testing. One hourremained before the Technical Specifications ACTION requires that the RBM channel be placedinto the tripped condition. Prior to the expiration of the one hour period, testing was restarted.

., Since testing had begun, the decision was made to voluntarily enter Technical Specification3.0.3, considering that the completion of the surveillance testing would allow this channel of the

, RBM to be restored to service. Technical Specification 3.0.3 was entered at 0920 hours on„October 17, 1997 and exited at 1410 hours on October 17, 1997.

It was determined that the RBM was actually operating as designed. A number of the LocalPower Range Monitors(LPRM) (BIS Code: I) had a zero volt output to the RBM. The RBMcorrectly identified a zero input condition from an LPRM(s) and, automatically eliminated it fromthe averaging circuit. As long as the RBM had more than the required minimum number of'good'PRlVI inputs, it continued to function normally.

CAUSE OF EVENT

The cause of. the unexpected results of the RBM 'surveillance has been traced to the failure ofcomponents in the LPRM output to the RBM. When these components failed, their output to theRBM went to zero volts. 11 LPRMs were identified to have this condition. LPRM output to theAverage Power Range Monitor (APRM) (EIIS Code: I), the Oscillation Power Range Monitor(OPRM) (EIIS Code:I), and to the plant computer were normal. It has been determined that thecause of the failed components stems from a power supply failure in June of 1997. The powersupply had been replaced and outputs to the APRM and computer were checked, but not theoutputs to the RBM. The post maintenance testing following the power supply replacement wasnot adequate, and is considered a root cause of the event.

NRC FORM 366A I4-95)

~=

~ NAC.FOAM 366Als-N)

LICENSEE EVENTREPORT (MR)TEXT CONTINUATION

U,S, NUCLEAAAEGULATOAYCOMMlSSION

FAClLITYNAME l1) DOCKET

05000l.ER NUMBER [6)

YKAA V I NHVM44R NVa444a

PAGE l3)

SUsquehanna Steam Electric Station - Unit 2 388 97 — 007 — 00 3 OF 5

TEXT (Ifmore spece is required, crse ed/donsi copies ofHRC Form 366AJ l17)

Entry into Technical Specification 3.0.3 is required when an inoperable channel of RBM is not inthe tripped condition following the expiration of allowable time limit of Technical Specification3.1.4.3 ACTlON (a); ln order to perform the operability testing, the RBM can not be in thetripped condition. The entry into 3.0.3 is required. The root cause of the Technical Specification3.0.3 entry is an administrative omission in the current Technical Specifications. ImprovedTechnical Specifications contain provisions to perform operability testing on inoperable

.equipment without entry into a shutdown action statement.

Entry into Technical Specification 3.0.3 was determined to be an appropriate and conservativecourse of action given this event.

REPORTABILITYANALYSlS

This Licensee Event Report is being made per 10 CFR 50.73(a)(2)(i)(B), in that NUREG 1022requires the reporting of any entry into Technical Specification LCO 3.0.3.

Technical Specification 3.0.3 was conservatively entered to allow completion of surveillancetesting of one channel of the RBM. As previously noted, one channel of the RBM was removedfrom service to perform surveillance testing. During that testing, unexpected results wereobtained. The time to evaluate these results and then complete the testing was going to exceedthe time allowed by Technical Specifications. Since completion of the surveillance testing wouldallow the RBM to be restored to operable status, the decision was made to resume testing and aTechnical Specification 3.0.3 entry was made when Technical Specification 3.1A.3 ACTION (a)expired. This decision was made after considering the following alternatives:

1. Place the RBM to the tripped condition.

~ Placing the RBM to the tripped condition at this time would only delay restoring it toan operable condition, The problem with the LPRM had been repaired and thesurveillance testing was ready to resume. Restoration of the equipment in the mosttimely manner is consistent with assuring the highest standards of nuclear safety.

~ Placing the RBM to the tripped condition at that time would still require entry intoTechnical Specification 3;0.3 in order to resume testing. The need to enter TechnicalSpecification 3.0.3 for performance of operability testing was a known administrativeshortcoming of current Technical Specifications.

2. Reduce power to <30%, thereby placing the unit in a condition where TechnicalSpecification 3.1.4.3 is not applicable.

NRC FOAM 366A l4 SS)

HUJ LD L'd>tf Lg'k4 uv mv wm tccv uI r)I c; I J I 1PRC IIIIV

NRC FORM 366AI4.95)

XXCENSEE EVENTREPORT (LER)TEXT CONTINUATION

v.s. NUCLEAR REGULATORY COMM)ss)ON

FAG)I.ITYNAME (1)

Susquehanna Steam Electric Station - Unit 2

DOCKET

05000

388

).ER NUMBER (6)N IAI.

aVMBBA )IVMBEa

97 - 007 — 00

PAGE )3)

4 OF 5

TEXT (Ifmore spece is required, ceo eddiuonol copies ofNRC Arm 386AI (17)

~ Anytime a power reduction is undertaken, especially to a relatively low power level,there is an increased challenge to plant operations personnel. Unnecessary challengesto the plant and the operators is not a conservative course of action. There would beno sa'fety benefit derived from a power reduction in this situation.

Based on the above considerations, the decision was made not to trip the RBM and to resumetesting. This course of action is conservative in that it restored the plant eqvipment to anoperable status in the most expeditiovs manner without compromising nuclear safety.

At no time during this event was the ability of the plant to safely shutdown or the health andwelfare'of the public compromised. The significance of this event from a safety standpoint wasminor. The other channel of the RBM was available throvghout this period to provide rod blockprotection, as well as the APRMs to provide core protection in the event of a power transient.

In accordance with the gvidance provided in NUREG 1022, Supplement 1, the requiredsubmission date of this report was determined to be November 17I 1997.

CORRECTIVE ACTIONS

With regard to the Technical Specification 3.0.3 entry, PPSL considers this action appropriate.Improved Technical Specifications addresses this type situation by providing allowance foroperability testing withovt entering a shvtdown action statement LCO. PPSL's improvedTechnical Specification submittal is in review by the commission.

A Technical Specification change request to the current Technical Specifications has beensubmitted to the NRC to extend the LCO ACTION statement allowable time for one RBM channelinoperable from 24 hours to seven days. Improved Technical Specifications also reflects thelengthened ACTlON time limits.

The failed components identified in the LPRMs were repaired/replaced.

The following actions are scheduled to be completed:

A review of the technical aspects of the event with the involved maintenance work groupstressing the importance of comprehensive post maintenance testing.

~ A review of work plans and procedures'associated with the LPRMs, APRMs, and RBMs todetermine and implement satisfactory methods of ensuring that all outputs from the LPRMsare sufficiently tested following work activities.

Evaluate results/conclusions of above review for generic applicability to other systems.

NRC FORM 366A l4 95)

HLAl 1 0 4 'p'V0 LZ OD uv wet.'mm ma ur r sac I Jl ~C, IVIV I ~ ka

NRC 'FORM 366Ag SSI

LICENSEE EVENT,REPORT (LER)TEXT CONTINUATION

U,S. NUCLEAR REGULATORY COMMISSION

FACILITYNAME [1)

Susquehanna Steam Electric Station - Unit 2

DOCKET

05000

388

LER NUMBER I6)YCAR N IAI,

auvarA marsrR

PAGE )3)

97 — 007 — 00 5 OF 5

TEXT (lfmore speceis required, use eddie'opal copies of fVRC Form 366AI (17)

ADDITIONALINFORMATIO

Past similar events: None

Entries into Technical Specification 3.0.3 have been reported on numerousoccasions, although none of the previous reports were a result of a similarcondition.

Failed Component: None

LER written for Technical Specification 3.0.3 entry, the failed componentswere not the reason for submitting this report.

)IRC FORM 3$6A I4 SSI

uo iud wm ma urr sis

REFERENCE 5

IXI M%C

COND)TIONREPORT- EVENTREPORTING FORM QRI81NAl

IdentifyingOrganization:

Operations

Event/Cond.Date:, 10/$ 7/97Time: 0920

'nit012, X

Op Cond I % Power

100'jo100%

SystemNumber

78

CONDITIONREPORT NO.

97Q434

Tech Spec LCO 3.0.3 entered to permit testing of 'A'od Block Monitor

ON 10/16/97 at 0820 hours, the 'A'od Block Monitor (RBM) was taken out of service to performsurveillance SI-278-325A, Semi-Annual Calibration of RBM2A. During the calibration problems wereidentified with LPRM outputs to the RBM2A and documented under CR 97-3414. The LCO Actions underTech Spec 3.1.4.3 and 3.3.6 required the inoperable channel to be restored within 24 hours or place thechannel in the tripped condition within the next hour. Due to the extensive investigation required to resolvethe problems, completion of testing to return the 'A'BMto operable status was going to exceed the LCOAction,Limits. At 0920 hours on 10/17/97 Unit 2 voluntarily entered Tech Spec LCO 3.0.3 due to thefailure to place the 'A'BMin the tripped condition. The 'A; RBM was not placed in the tripped conditionto facilitate testing. At 1410 hours, Mowing completion of SI-278-325A, the 'A'BMwas declaredoperable and LCOs 3.0.3, 3.1.4.3a, and 3.3.6 Action 60 cleared.

D Cont'd.

Rod Block Monitor A

C N

Obtained permission from Operations Supervisor-Nuclear to enter LCO 3.0.3Entered LCO.INC completed surveillanceDeclared A EBM operable and cleared LCOs

F4 bo D Cont'd.

D YES H NQ . QN/A'he

A RBM was inoperable at the time

Originator.

Da neR. Bro h

(Print)

Time: 1450D: JSupe<vis'or. Date: 'o l~ 9 t

Signature

Q I recommend this item for closure.

FORM NDAP-QA-0702-1, Rev 2, Page 1 of 1

OPERABIVTVASSESSMEN7Corrective Action Document 97-3431

'answers to fhe folfowing questions provide the basis forde'cisions of operability for degraded or'non~nformin9»fetyrelated equipment. &ere should be reesoneble essurence ofequipment reliabilityforperforming its intended safetyfunction to decide operability has not been impacted end allow continued operation. Follow-up technical analysis mey berequired to support the reasonable assurance ofoperability documented here.

NOTE: Originator or problem identifier to answer'r support Operations in answering the followingquestions:

ls the affected component still capable of performing all its safety functions with reasonableassurance or reliabi%'ty now and for anticipated changes in plant conditions, e.g., plantstartup7 include a brief explanation of the component's safety function and how thatfunction is affected. (This evaluation should consider possible failures that may resultbecause of the degraded condition and ifother similar equipment might be degraded.):

During the time that LCO 3.0.3 was in affect the A RBM was considered inoperable. TheLCO was not cleared until successful completion of the surveillance.

2. Explain the basis for your conclusion (e.g., analysis, test, operating experience, judgment):

N/A

3. List the mechanism(s) used to administratively control equipment status and correct thedegraded or nonconforming condition of safety related equipment before reliance is placedon the equipment (LCD Log, document in System Status File, Fire Protection System StatusChange Form):

LCOs 3.0.3, 3.1.4.3, and 3.3.6

Iffollow-up technical evaluation is needed to substantiate the initial evaluation of operability, notifythe applicable functional unit supervisor and document this notification and expectation in theimmediate corrective actions taken section of the condition report.

Equipment is operable: HYes .@No

Complete y Date Approved by(Shift Svpeivisor)

l /O l7

FORM NDAP-QA-0703-1, Rev. 1, Page 1 of 1 (File R48-9)

REPORTABXLHYDETEKVQNATION CONDITION REPORT NO:97-3431

PAGE OF

Et~0 .CII~I 4)S

IMMBDIA'HiOR PROMPT NRC REPORTING REQUIRED:

NRC NOTIFICATIONMADE: NO YES TYPE:

BASIS FOR DESTINATION:

1HR 4HR 24HR

Upon review of NDAP-QA-0720 Attachments E, F, G, K,Land R it has been determined there ks no immediateNRG notification required. ln accordance with Attachment H, a thirty day LER is required.

COMP ED XY 0 t I n97

SHIFT SUPERVISOR DA

fORMNDAPQA4720-), REv.o. PAGE I d'2 (FILE R48 2)

TOTAL P. 16

HLV LD LWK) LC LL UO I'Al MW ITCHY IJt I I'4C

PCAF 96-6219

REPORTABILITYDETERMINATION

CONDITION REPORT NO:97-3431

PAGE 1 OF 1

DETAILS OF NUCLEAR COMPLIANCE REPQRTABILITYDETERMINATION

REPORTABLE:

TECH SPEC SPECIAL REPORT:

REPORTABLE PER10CFR50.9/10CFR21:

N P PER 10CFR 0

Y P PER SECTION

Y Q p

REFERRED TO NUCLEAR LICENSING' DATE

REPORT DUEDATE' /0

BASIS FORDETERMINATION'.

Technical Specification Deviations or Shutdowns. None2. Degraded Power Plant Condition. None3. Danger of a Natural Phenomenon. None4. Engineered SafetyFeaturesActua'lion. None5. Important plant System or Slructure Unable to perform Their Function, None6. Loss of one train in multiple Channel Systems. None7. Exposure to Individuals or Releases. None8. Failure of Effectiveness of Packaging. None9. Violation of NPDES Permit. None10. Change of Status or Disability of Licensed Reactor Operator. None11. Defect in Spent Fuel Storage Cask Structure. None12. Reduction in Fffectiveness of a Spent Fuel Confinement System. None

John M Kocher 10/20/97COMPLETED BY DATE

l~w i~/~vSVPV. OPERATINS EXP. SVCS. DATE

FORM NDAP-QAZ720-1, REV. 0, PAGE 2 OF 2 (FILE R43-2)

CONDITIONREPORT - SIGMFICA1VCEREVIEW'CAP

1.974166'ago3 of4

CR NO: 97-3431 UNIT: 2

OPERA G EXPERIENCE SERVICES AND M GE

OESEVALUATOR:

IXVEL:

RESO TYPE RCA

OPERABKIIYAFFECTED?: NO

FUNCTIONALFAXLURE? NO

LEALGRP: OPS / OPS

RESO DUE: Il/6/9/

NON-CONFORMANCE?:

50.59 REQUXRED?: NO

REPORTABLE?: YES

CYCLE: 209

EQUIP FAILURE? yes

'ATEGORY: TEcHSPaceocgZR1

HUMANPERFORMANCE?:

PLANT/SYSTEMOPERATION

MANAGEMENTSUMMARY:

. UNIT2 VOLUNTAMLYENTEIKDEXCH SPEC LCO ACIION3.0.3 WHENTHE A ROD BLOCKMONITOR'"

(RBM)WASNOT PLACED INTHE TRIPPED CONDITIONTO FACILITATE'IZSTING.

THE ACTIONSTA'IDENT FOR THE RBMWAS TO RESTORE 'GK CKQINELTO OPHVBLE STATUS IN24 HOURS OR PLACE THE RBM INTHE 'IMPPED CONDmON. DUE TO THEI.ONG INVESTIGATIONWHICHWAS REQU1RED 'IHERBM WAS NOT PLACED IN 'IHETMPPED CONDITIONBUTLCO 3.0.3 WASENTERED.

'TESTING WAS COMPLETED, THE A RBMDECLARED OPERABLE, AND.ALLASSOCIATED LCOs WERECLEARED.

SIGNIHCANCE: ENTRYINTO LCO 3.0.3 REQUIRES A WRITIENREPORT TO THENRC, (LZR)l

OES CONTACTS: D ROTHE, L WEST, G MEIMLL,R WEHRY

THIS CR IS RELATEDTO CR 97-3414

CAUSE(S)/CAUSALFACTORS:

PAST OCCURRENCES:

4 OTHER CRs IN 1997 ON ENTERING LCO 3.0.3

CORRECTIVE ACTION(S):

EORMNDAPQA4702-3, Rev. 1, Page 1 of 1

~ ~

CONDITIONREPORT - EVALUATION4 ACTIONPLAN

CR NO. 97-3431

EVALUATIONL ACTION PLAN

INVESTIGATION Refer to corrections annotated on Form NDAP~W70M

Technical Specification 3.0.3 was entered to allow operability testing of the Unit 2 "A"RodBlock Monitor. Since an entry into 3.0.3 was made, this Condition Report was generated. ThisCondition Report willa'ddress the administrative issues associate'd with the need to enter Tech Spec3.0.3. The technical issues associated with the 2A RBM are discussed in CR 97-3414.

A timeline of the activities associated with this event are attached. A general discussion of theoverall event willbe discussed herein.

On 10/16/97 at 0820 LCO Action Statements 3.1A.3 Action (a) and 3.3.6 Action 60 wereentered to perform required surveillance's Sl-278-225A and SI-278-325A. The action statementrequires:

IVith one RBM channelinoperable, restore the inoperable channel to OPERABLE statuswithin 24 hours and veri that the reactoris not operating on a LIMITINGCONTROL ROD.

PATTERN; otherwr'se, place the inoperable rod block monitor channel in the tripped condition withinthe next hour".

Approximately 2 hours later, unexpected results were encountered during performance of thesurveillance. The problem was believed to be with the "A"and "C" LPRM outputs to the "A"RBM.WA's V73181 and V731 82 were written to investigate the problem. Since the 2A RBM remainedinoperable, the LCO Action Statements remained in effect.

Discussions were ongoing regarding the course of action to take in order to restore the 2ARBM to an operable status. The decision was made that the 2A RBM would be placed in the trippedcondition as required by TS 3.1.4.3 Action Statement (a) if it could not be restored to an operablestatus jn time.

SAFETYASSESSMENTtsI Cont'd.

The decision to enter Tech Spec 3.0.3 was based on the following objectives:

1. Minimize the period of time the 2A RBM was out of service,

2. Minimize the risk to nuclear safety,

3. Maintain compliance with Tech Specs.

Based on these considerations, a conservative decision was made and the appropriate courseof action followed. There was no nuclear safety significance to this event.

FORM NDAP-QA-0702-4, Rev, 1, Page 1 of 4Q Cont'd.

UD IVV'I MM %CO LN C ll C

CR NO. 97-3431

CONDITIONREPORT- EVALUATION4 ACTION PLAN

'EVALUATION& ACTION PLAN

ROOT CAUSES I CAUSAL FACTORS

NDAP-QAZ?02-? Form Attached

FF PRES HNOPERFORMANCE CRITERIA Q YES Q NO

MPFF +YES HNOREPEAT MPFF P VeS 5g NO

TRAIN desi nate or N/A N/A

NOTE: Form NDAP-QA-0702-7 is not included with this Condition Report since the event wasnot a human performance event.

Entiy into 3,0.3 is required when an inoperable channel of the RBM is not in the trippedcondition following expiration of Tech Spec Action Statement 3.4.1.3 Action (a). In order to performoperability testing, the RBM cannot be in a tripped condition. Therefore entry into Tech Spec 3.0.3 isrequired, The root cause for the entry into Tech Spec 3.0.3 is an administrative omission in currentTechnical Specifications. Improved Tech Specs contains provisions to perform operability testing oninoperable equipment without entry into Tech Spec 3.0.3.

Entry into Tech Spec 3.0.3 was determined to be an appropriate course of action given thisevent.

PAST EXPERIENCE0 Contd.

There have been 4 other Condition Reports documenting entry into Tech Spec 3.0.3 in 1997.Only one of the four was required to perform operability testing (CR 97-3136).

FORM NDAP-QA-0702-4, Rev. 1, Page 2 of 4Q Cont'd.

~ ~

~~

4-

HUQ JD JOKED JCiJC

~ CR NO. 97-343

uD imv ouDv ~D urr s~

CONDITIONREPORT- EVALUATION8 ACTIONPLAN

.EVALUATION8 ACTION PLAN

Does co'ndition require repair or usews~sVlf es corn letea rovalblockon a e4.

ACTIONS TO CORRECT CONDITION

YES Q

FUNC UNIT

NO H

DUE DATE

status.None Required - The 2A RBM was restored to an operable

ACTIONS TO PREVENT RECURRENCE

None Required - Entry into Tech Spec 3.0.3 was anappropriate course of action.

Improved Tech Specs has provisions to allow operabilitytesting of inoperable equipment without entering a shutdown actionstatement.

FUNC UNIT

Cont'd.

DUE DATE

FORM NDAP-QA-07024, Rev. 1, Page 3 of 4Q Cont'd.

HVO ld J VVD JC'd

CR NO. 97Q431

CONDITIONREPORT- EVALUA7ION8 ACTIONPLAN

EVALUATION& ACTlON PLANDescri tion/8asis of "Use-As-ls" or "Re air."

None Required

Desi n and License Documents Re uiring U date.

None Required

PREPARED BY DATE LEAD FUNCT UNIT MANAGER DATE

AFFECTED FUNCT UNITMANAGER

DATE AFFECTED FUNCT UNITMANAGER

DATE

AFFECTED FUNCT UNITMANAGER

DATE MANAGER-NSE8 NUCLEAR MODIFICATIONS

se-As-ls or Re air A rova

DATE

OES SUPERVISORLevel 1 8 Reportable Level 2

DATE

PORC, MEETING NUMBERLevel 1 8 Reportable Level 2

FORM NDAP-QA-0702-4, Rev. 1, Page 4 of 4

DATE.

LD JVVD JC~ JD

CR NQ. 97-3431

uv imv ouaat mv vrr sac IXI MlC IMIM

0 0CONDITIONREPORT- CONTINUATIONFORM

CONTINUATIONFORMI

EVENT REPORTING FORM (0702-1) Q

EVALUATION&ACTION PLAN 0702<

INVESTIGATION H PAST EXPERIENCE QSAFETY ASSESS. D ACTIONS TO CQRR. COND. 0CAUSES Q EVAL. &ACTION PLAN D

ACTIONS TQ PREV. RECURR.CYCLE EXTENSION JUSTIFICATION

On 10/17/97 at 0820 the 24 hour period to restore the 2A RBM to operable status had expired. Atthis time, l&C had completed the repairs to the LPRM's and wa's prepared to resume surveillance testing.ln light of the completed repairs to the LPRM's, the earlier decision to place the 2A RBM to the trippedcondition was reviewed by Shift Supervision and the Operations Supervisor- Nuclear. Since completionof the sutveillance testing would allow the 2A RBM to be restored to an operable status, the decision wasmade to resume surveillance testing. Entry into TS 3.0.3 would be taken when the TS 3.1.4.3 ActionStatement expired. This decision was made after considering the following alternatives:

1. Place the 2A RBM to the tripped condition.

2.

a) Placing the 2A RBM to the tripped condition at this time would only delayrestoring it to an operable status. The problem with the LPRM's had beenrepaired and the surveillance testing was ready to resume. Restoration ofthis equipment in the most timely manner possible is consistent with assuringthe highest standards of nuclear safety.

- b) Placing the 2A RBM to the tripped condition at this time would still requireen'nto TS 3.0.3 in order to resume testing. The need to enter TS 3.0.3 forperformance of operability, testing was a known administrative oversight ofcurrent Tech Specs, The practice of entering TS 3.0.3 to perform operabilitytesting has been accepted by the NRC in the past. Also, Improved TechSpecs corrects this oversight and contains provisions to perform operabilitytesting without entering TS 3.0.3.

Reduce power to < 30%, thereby placing the unit in a CONDITIONwhereby TS3.1.4.3 is not applicable.

a) Any time a power reduction is undertaken, especially to a low power level,there is an increased challenge to plant operations. Unnecessary challengesthe plant and operations personnel is not a conservative course of action anddoes not increase nuciearsafety.

H Cont'd.

FORM NDAP-QA-07024, Rev. 1, Page 1 of 1

HLU-LD LO>c5 Lg: LQ uv mv mm rcco urr inc I 4 I dNC NP Id

CR NO. 97-3431

CONDITIONREPORT- CONTINUATIONFORM

CONTINUATIONFORM

EVENT REPORTING FORM'(0702-1) Q

EVALUATION& ACTION PLAN 0702-4

INVESTIGATION g PAST EXPERIENCE P ACTIONS TO PREV. RECURR.SAFETY ASSESS. Q ACTIONS TO CORR. COND. P CYCLE EXTENSION JUSTIFICATIONCAUSES P EVAL. & ACTION PLAN P

EXT.

Based on the above considerations, the decision was made not to trip the 2A RBM and resumesurveillance testing. This course of action is conservative in that it restored plant equipment to anoperable status in the most expeditious manner without compromising nuclear safety. OP-AD-001requires approvaf of the Manager - Nuclear Operations for a voluntary entry into Tech Spec 3.0.3. Sincehe was unavailable at the time, the Operations Duty Manager (Operations Supervisor - Nuclear) grantedpermission to continue operability testing and to enter TS 3.0.3 when the TS 3.1.4.3 Action Statement (a)expired. The Manager- Nuclear Operations was later notified of and concurred with this decision.

At 0838 Powerplex was restored to obtain a core edit prior to resumption of the surveillance test.Powerplex was blocked'at 0849 and the testing resumed.

At 0920 the TS 3.1.4.3 Action Statement (a) expired arid TS 3,0.3 was entered.

The remainder of the surveillance was performed without incident. Testing was completed at1252. TS Action Statements 3.0.3, 3.1.4.3, and 3.3.6 were cleared at 1410 following closure of the 2WA's that repaired the LPRM's.

Technical As ects of the Event

CR 97~14 willbe assessing the technical aspects of this event. However, the following isknown at this time. The investigation identified that the A & C level LPRM output to the 2A RBM hadfailed downscale. The 2F APRM was not affected nor was the 2A RBM itself failed. The defectivecomponents were replaced and re-tested satisfactorily. The exact cause for the failure is currentlyunder investigation, but is believed to be the result of an earlier electrical transient due to a failedpower supply.

P Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

tQV ld lVPO JC'N VO I%'lr OVQQI AC4 Wl ~ 'le

CR 97-3431 Timeline

Date10/16/97

10/17/97

Time0820

0821

1020

0820

0838

0849

0920

125012521410

Activi /ActionLCO entered for 'A'od Block Monitorinoperable for Sl-278-325A and SI-278-225A

Powerplex blocked to support testing of2A RBMProblems encountered duringperformance of Sl-278-325A due to failedLPRM outputs.'(See CR 97-3414, WA'sV73181, V73182RBM 2A remains inoperable. LCO3.1.4.3,(a) 24 hour period expired. 1

hour remains to place the 2A RBM in the'tn ed condition.Power plex restored to obtain core editbefore RBM testin resumes.Powerpfex blocked and testing of 2ARBM resumes.Tech Spec 3;0.3 entered since LCO3.1.4.3.a expired and the action to place2A RBM in the tripped condition cannotbe completed due to operability testing in .

ro ress.Powe lex monitors restoredSl-278-325A corn Ieted satisfactorilAll LCO's cleared when V73181N73182dosed.

Tech S eclm act3.1.4.3 Action a. and 3.3.6Action 60-24 hrs to restore,otherwise 1 hr to place intrip condition.Im act: 10/17/97 0820

3.1.4.3.aImpact:0920

3.0.3-1 hour to commenceshutdown/ be in Cond 2within the next 6 hours.Im act: 1020/1620

HUG-ld-LJWa LZ LD ub IWI. mm mD urrlVC II I PIC told

CR NO. 97-3431

CONTINUATIONFORM

CONDITlONREPORT- CONTINUATIONFORM

EVENT REPORTING FORM (0702-1) QEVALUATION& ACTION PION 0702<

INVESTIGATION H PAST EXPERIENCE 0 ACTIONS TO PREV. RECURR.SAFETY ASSESS. Q ACTIONS TO CORR. COND. Q CYCLE EXTENSION JUSTIFICATIONCAUSES Q EVAL. &ACTION PLAN Q

EXT.

NOTE TO OES:

ft was necessary to revise the disposition plan for this CR. Attached is a revision to the "Investigation" and;Actions to Prevent Recurrence'hat need to be added to the original CR package. As a result of this

~ revision, 4 new action items are required (See Action to Prevent Recurrence).

~ t%

9 Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

tiVQ ld JVPQ JCi ld ua >mi moo mo vrr sac'

~

~ « I

CR NO. 97-3431

CONDITIONREPORT - CONTINUATIONFORM

CONTINUATIONFORM

EVENT REPORTING FORM (0702-1) Q

EVALUATION8 ACT ON PLAN 0702-4

INVESTIGATION 8 PAST EXPERIENCE Q ACTIONS TO PREY. RECURR.SAFETY ASSESS. Q ACTIONS TO CORR. COND. Q CYCLE EXTENSION

JUSTIFICATION'AUSES

Q EVAL. 8 ACTION PLAN '

EXT.

Following completion of the initial disposition to CR 97-3431, NRC resident inspectors raised questionsconcerning compliance with Tech Spec LCO 3.1A,3.(a) and 3.0.3. Their concern is documented in NRCInspection Report 97-10. It states: Youractionsin response to a failure of the Unit 2 rod block monitorwere observed and, in general, were considered conservative and safety oriented. However, SSESmanagemenf chose to enter TS 3.0.3 and did notinifiafe any acfion to shutdown the unit, asisintendedby the technical specification. The NRC questioned the appropriatenes or fhe decision to enter TS 3.0,3and considered managemenf's decision to intentionally not n.duce power a weakness in implementationof the TS. Ke request the SSES Plant Operation Review Commiffee formallyevaluate the issue fo enter3.0.3 within 20 days. This information wi7Ibe used to evaluate the unresolveditemidenfifiedin fheenclosedinspecfion report and to determine whether further IVRC action is required. "

The following is a re-evaluation of the actions taken on October 17, 1997 concerning the Unit 2 'A'BM.

Issue 1 is the question raised by NRC concerning the appropriateness of entering TS 3.0.3.Issue 2 reviews our actions taken in response to the entiy into TS 3.0.3.

A time line for events associated with this Condition Report is attached,

Applicable sections from Unit 2 Technical Specifications are also attached.

Discussion of Issue 1

At the time of the event the Shift Supervisor believed he had three options to choosefrom.'uspend

testing of the RBM. Place the 'A'hannel in the tripped condition to satisfy LCO Action3.1.4.3.(a). Enter TS LCO 3,0.3, activate the 'A'BMchannel to allow testing to resume.

2. Reduce power to less than 30% of Rated Thermal Power. With-power less th'an 30% the RBM isnot required to be OPERABLE. LCO Action 3.1.4.3.(a) would no longer apply.

gj Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

CONDITIONREPORT CONTINUATIONFORM

CR NO. 97-3431

CONTINUATIONFORM

EVENT REPORTING FORM (0702-1) PEVALUATION&ACTION PLAN 0702<

INVESTIGATION H PAST EXPERIENCE PSAFETY ASSESS. P 'ACTIONS TO CORR. COND. PCAUSES P. EVAL 8, ACTION PLAN P

ACTIONS TO PREY. RECURR,CYCLE EXTENSION JUSTIFICATION

'iscussionof issue 0 cont'd

3. Allowtesting of the 'A'BMto continue. This would mean that compliance with LCO Action3.1.4.3. (a) would not be maintained. As a result, enter TS LCO 3.0.3. A further consideration forthis option was whether an NRC Notice of Enforcement Discretion was needed in order to allowsuch an action.

Options 1 and 2 were viewed by the Shift Supervisor and Operations Supervisor as presenting anincreased risk to nuclear safety, Option 1 required that l&Cstop their surveillance testing, delayed therestoration of the 'A'BMand ultimately resulted in the unit being in TS LCO 3.0,3. The l&C surveillancetesting is performed in'the Lower Relay room in panel 2C608. This panel contains the RBM modulesalong with the APRM Channels and Recirc Flow Units, These later components provide signals to RPS socaution must be exercised when working on RBM. The two surveillances being performed required theremoval of various logic cards, installation of test equipment and manipulation of various test pots insidethe cabinet. Halting this testing, placing the 'A'BMin the trip condition and subsequently restoring the'A'BMto resume testing was viewed as an un-necessary nsk. Option 2 challenged the operators tomanipulate reactor power and placed the unit in a low power operating state. This was viewed as an un-necessary challenge. The RBM system ls designed to provide controls for the movement of Control Rods.Reducing power to 30% would require a significant number of Control Rod movements. With the onechannel of RBM out of service the risks associated with commencing a power reduction were consideredgreater then completing the restoration of the RBM system. Option 3 was considered to be the feastchallenging to Operations and to be within our authority as licensees to exercise on our own. As a result,Option 3 was chosen.,

The question of NRC involvement was reviewed. The conclusion was that we had the legal authority toenter TS LCO 3.0.3 on our own. We have periodically entered TS LCO 3.0.3 in order to perform requiredtesting. This condition was viewed as the same situation. This weakness in our Tech Spec's has beenidentified and willbe corn.cted'by ITS through the addition of a new section of Tech Spec's to addressallowances for testing of in-operable equipment without entry into shutdown action statements.

Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

t1UQ la) JPVO JC'D V4 I 'A4 iXIQO 0 J

~ ~

CONDITIONREPORT - CONTINUATIONFORAf

CR NQ. 97-3431

CONTINUATIONFORM

EVENT REPORTING FORM (0702-1) 0EVALUATION& ACTION PLAN 0702<

INVESTIGATION I PAST EXPERIENCE Q ACTIONS TO PREV. RECURR.SAFETY ASSESS. Q 'ACTIONS TO CQRR. COND. P CYCLE EXTENSION JUSTIFICATIONCAUSES D EVAL. &ACTION PLAN Q

EXT.

The questions then boils down to; 1) Do we have the authority to not comply with an Action Statementrequired by Tech Spec's when we believe the performance of the Action posses undue risk7 2) Ifwedecide to not comply with an Action Statement, is entry into TS LCO 3.0.3 appropriate7 3) How shouldsuch decisions be made and controlled7

A~nal sis

The intent of TS LCO 3.0.3, as introduced in Generic Letter 80-30 was to preserve the single failurecriterion for systems that are relied upon in the safety analysis report. The examples cited in the GL werecases when more than one train or channel of redundant safety related systems were inoperable. In suchcases the new specification 3.0.3 provided direction for shutting down the unit in a reasonable time frame.The GL did not address situations where other provisions of an LCO Action might not be complied with.The Bases Section of our Tech Spec's also reflects this intent The Bases states in part; "The purpose ofthis specification is to delineate the time limits for placing the unit in a safe shutdown CONDITION whenplant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditionsfor Operation and its ACTION requirements. It is not intended to be used as an operational conveniencewhich permits (routine) voluntary removal of redundant systems or components from service in lieu ofother alternatives that would not result in redundant systems or components being inoperable.

A key phrase included in our Tech Spec Bases must be considered; "...notintended to be used as anoperational convenience...". Clearly, any time we are viewed as using entry into TS LCO 3.0.3 as an"operational convenience" we are subject to regulatory review on our use of this Tech Spec provision.The test for "operational. convenience" needs to be developed. Ifwe strictly followall written Tech SpecLCO's, Actions and Surveillance Requirements and find we have no other choice, we can defend that wehave not exercised TS LCO 3.0.3 as an "operational convenience".

In the case of the 'A'BMwe did not exercise this approach. At 0820 the 18 C corrective maintenancewas completed and the surveillance testing had not yet started. We could have placed the 'A'BMin thetrip condition to meet the Action Statement, Once I&Cwas ready to begin the surveillance test at 0849,TS LCO 3.0.3 could have been entered and the 'A'BMcould have been taken out of the trip condition toallow surveillance testing, This fourth option would have allowed compliance with Tech Spec Action

g Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

CONDlTiONREPORT ~ CONTINUATIONFORM

CR NO. 97-3431

CONTINUATIONFORM

EVENT REPORTING FORM (0702-1) DEVALUATION& ACTION PLAN 0702<

INVESTIGATION H PAST EXPERIENCE D ACTIONS TO PREY. RECURR.SAFETY ASSESS. D ACTIONS TO CORR. COND. P CYCLE EXTENSION JUSTIFICATIONCAUSES D EVAL. &ACTION PLAN P

EXT.

Anal sis cont'd

Statements and minimized un-necessary chaftenges and risks to the unit. It a situation similar to theevents associated with the 'A'BMwere to exist in the future, exercising the new fourth option outlinedabove would be the correct action properly balancing compliance and risk issues.

We also could have halted testing prior to exceeding the LCO Action Statement time limit, placed theChannel in the tripped condition, thereby satisfying the Action Statement. At that point we would be in asimilar position to other recent cases where we exercised TS LCO 3.0.3 to allow performance of postmaintenance testing. Not halting the testing and not placing the channel in the tripped condition can beviewed as entering TS LCO 3.0.3 as an "operational convenience . Consideration of the risks associatedwith halting a test in progress'to allow completion of a required Action may provide appropriate justificationfor not considering this to be an "operational convenience".

Another option exists within 10CFR50 for taking actions that depart from the Technical Specifications.10CFR50.54(x) states; A licensee may take seasonable action that departs from a license condition or atechnical specification .... in an emergency when this actionisimmediately needed to protect the publichealth and safety and no action consistent with ficense condition's and technical specification that can..provide adequate or equivalent protectionisimmediately apparent." This provision is cieariy intended toaddress emergency situations. The testing of the 'A'BMdid not fall into that category.

Based on our review of regulations, the answer to the three questions posed above are;

1) Do we have the authority to not comply with an Action Statement required by Tech Spec's when webelieve the performance of the Action posses undue risk? The answer to this question is Yes.Cleariy 10CFR50.54(x) allows licensee's to take actions that depart from our license when neededto protect the health and safety of the public. We must be very dear about the risk we arediscussing when making such decisions, 'Risks to public health and safety are the focus of theregulations.

. 0 Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

Hm-z>-x»a xe'a

~ ~

CR NO. 97-3431

CONTINUATIONFORM

CONDITIONREPORT - CONTINUATION FORM

EVENT REPORTING FORM (0702-1) DEVALUATION8 ACTION PLAN 0702<

INVESTIGATION H PAST EXPERIENCE Q ACTIONS TO PREV. RECURR.SAFETY ASSESS. 0 'ACTIONS TO CORR. COND. Q CYCLE EXTENSION JUSTIFICATION

'AUSESQ EVAL. 8 ACTION PLAN CIEXT.

Anal SiS Cpnt'd

2) Ifwe decide to not comply with an Action Statement, is entry into TS LCO 3.0.3 appropriate'? 'Thedecision to depart from the license can be made under 10CFR50.54(x). Due to weaknesses incurrent Technical Specifications situations arise when a completed Action Statement must bedeparted from in order to perform required testing to return an inoperable piece of equipment toservice'. Improved Technical Specifications(ITS} includes a new LCO 3.0.5 to address thesesituations. Until ITS is approved, entry into LCO 3.0.3 is appropriate for these situations.

3) How should such decisions be made and controlled'Clearly any time a decision is made to not comply with Technical Specifications, appropriatecontrols and decision making is needed. Under emergency conditions the Shift Supervisor hassuch authority. Ifwork activities require entry into TS LCO 3.0.3, the Operations Supervisor andManager - Nuclear Operations must also be involved in the decision. This level of control existstoday and is adequate, Additional written guidance to procedures is warranted to aid in thisdecision making.

Discussion of Issue 2

Once entered, TS LCO 3.0.3 requires actions be taken to place the affected unit in Startup and HotShutdown. This section reads in part;

'...within'one hour action shall be taken to place the unitin an OPERATIONAL CONDITIONinwhich theSpecification does not apply by placing it, as applicablein:

1. At least STARTUP within the next 6 hours,2. At least HOT SHUTDOWN within the following 6 hours,....'

Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

TOTAL P. 16

PllA IJ lVPQ JC ~ CC

CR NO, 97-3431

CONDITIONREPORT- CONTINUATIONFORIH

CONTINUATIONFORM

EVENT REPORTING FORM (0702-1) 0EVALUATION&'ACTIONPION 0702-4

INVESTIGATION g PAST EXPERIENCE Q ACTIONS TO PREV, RECURR.SAFETY ASSESS. Q 'ACTIONS TO CORR. COND. Q CYCLE EXTENSION JUSTIFICATION

'AUSESQ EVAL. 8 ACTION PLAN QEXT.

Discussion of Issue 2 cont'd

The Basis section of Tech Spec's reads in part; "...The time fimits specified to reach lower CONDIT(ONSof operation permit the shutdown to proceedin a controlled and orderly manner thatis well within thespecitied maximum cooldown rate and within the cooldown capabi%ties of the facilityassuming only theminimum required equipment is OPERABLE."

Tech Spec LCO 3.0.3 was entered at 0920 hours. The LCO was cleared at 1410 hours. This is 4 hoursand 50 minutes into the LCO.'o reductions in reactor power were made during this time period. This left2 hours and 10 minutes for the unit to be in STARTUP had any further problems been encountered withthe RBM system< Through out this period the Shift Supervisor maintained oversight on the activitiesassociated with clearing the RBM problems. Testing to declare the 'A'BMoperable started at 0849 andwas completed at 1252. As a result, the Shift Supervisor had reasonable expectations, throughout theLCO Action period, that the LCO would be cleared before he was required to be in STARTUP.

Procedural guidance on Entry into TS LCO 3.0.3 is included in OP-AD-001. There is no guidance onspecific actions that shall be taken by particular times frames to ensure compliance with the Action timelimits. In this particular case the Shift Supervisor was planning for success based on the feedback he wasreceiving from the work group. With no specific guidance, the Shift Supervisor used judgment todetermine if more aggressive actions were needed to reduce power and begin the shutdown sequence.He concluded none were needed. This was reasonable considering the situation but did not leave marginif further problems were encountered with the RBM and unit shutdown was required. *

g} Cont'd.

FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1

@MA ld J770 IC'C9 I v'l tV' M

CR NO. 97-3431

CONDITIONREPORT - CONTINUATIONFORM

CONTINUATIONFORM

EVFNT REPORTING FORM (0702-1) 'Q

EVALUATIONBi'ACTION PLAN 0702-4

INVESTIGATION g PAST EXPERIENCE Q ACTIONS TO PREY. REGURR.SAFETY ASSESS. P ACTIONS TO CORR. COND. Q CYCLE EXTENSION JUSTIFICATION

'AUSESP EVAL. 8 ACTION PLAN PEXT.

Anal sis cont'd

As noted in the Analysis of Issue 1 above, any time we voluntarily enter TS LCO 3.0.3 we should expectan increased level of review and scrutiny from many outside parties, As a result, it is important that wehave very dear expectations associated with actions we intend to take under these situations. It is not .

appropriate to totally rely on the judgment of individuals on-shift to determine when power reductionsshould begin. In the case of an entry into TS LCO 3.0.3, our expectation should be that we begin actionsto reduce power and place the unit in STARTUP in a controlled and orderly manner within 7 hours ofentry. It is not expected that we remain at full power and then discover the need to rapidly reduce poweror initiate a Scram from high power levels in order to comply with the Action statement time periods. Tocleahy communicate these expectations a set of guidelines should be constructed to define expectedactions by the Unit Supervisors when entry is made to TS LCO 3.0.3. The following would be an exampleof the guidelines:

First Hour

Second and Third Hour

Fourth Hour

Fifth Hour

Sixth Hour

Seventh Hour

Unit Supervisor should review GO for shutdown. Work group actions shouldbe underway to dear work items and allow unit to exit TS LGO 3.0.3.

Unit Supervisor should brief shift personnel on shutdown and notify PCC ofpossible shutdown.

By the end of the fourth hour, the unit should be at 90% power.sf

During this hour actions shall be taken'o continue power reduction usingReactor Recirc. and control rods. By the end of the fifth hour the unit shouldbe at 50% power.

Actions continue to drive control rods and reduce power to approximatefy25%.

Manual scram inserted to put unit in STARTUP by the end of the seventhhour.

g Cont'd.

FORM NDAP-QA-07024, Rev. 1, Page 1 of 1

tWQ JB JVOO JC ~ CD

CR NO. 97-3431

CONDITIONREPORT- CONTINUAT/ONFORM

CONTINUATIONFORM

'VENT REPORTING FORM (0702«1) Q

EVALUATION8 ACTION PLAN 0702M

INVESTIGATION Q PAST EXPERIENCE Q ACTIONS TO,PREV. RECURR.SAFETY ASSESS. Q ACTIONS TO CORR. COND. Q CYCLE EXTENSION JUSTIFICATION .

CAUSES 0 EVAL8 ACTION PLAN QEXT.

Conclusion

The specific actions taken by shift personnel during the recovery of 'A'BMon Unit 2 were appropriatewhen viewed from the perspective of minimizing challenges to operations personnel and recognizing theactions being taken by I8 C to return the channel to service. When viewed from the perspective of TechSpec compliance, improvements in our implementation of TS LCO 3.0.3 is warranted. Iffaced with asituation similar to the events of October 16th and 17th, completion of all required Tech Spec Actions shalloccurr. Only after fullycompleting all actions willentry into TS LCO 3.0.3 be considered to allowcompletion of required post maintenance testing and restoration of equipment to OPERABLE. OperationsManagement (Operations Supervisor/Operations Manager) approval willbe obtained prior to TS LCO3.0.3 entry in response to event circumstances not specifically addressed by Technical SpeciTication

Action statements. Once TS LCO 3.0.3 is entered, specfic actions shall be taken to initiate and complete,if necessary, the requirements of the unit shutdown. Four specTiic actions shall be taken:

2.

3.

Clear guidance will be added to OP-AD-001 dealing with voluntary entry to TS LCO 3.0.3. Thisguidance willdeal with removal of redundant equipment from service and with failure to meet LCOAction requirements in other manners.

Clear guidance willbe added to OP-AD-001 dealing with actions to be taken by UnitSupervis'ofS-'nce

their unit has entered TS LCO 3.0.3.

Communication of these changes to operational policy willbe made and training of appropriatepersonnel willbe'held.

CR 97-3431 and LER 50-388/97-007 will be revised to reflect these changes in policy andadditional actions.

Q Cont'd.

= FORM NDAPNA-0702-6, Rev. 1, Page 1 of 1

HUL)-14-15Jd 18: 8 C jI ( PIC Adjs

CR NO.

CONDITIONREPORT - EVALUATION4 ACTIONPLAN

97-3431

EVALUATION8 ACTION PLANDoes condition require impair or usews~s?If es,corn Ietea rovalblockon a e4.

VaS P NOH

ACTIONS TO CORRECT CONDITION FUNC UNIT DUE DATE

ACTIONS TO PREVENT RECURRENCE FUNC UNIT

Q Cont'd.

DUE DATE

Clear guidance should be added to OP-AD-001 dealing withvoluntary entry to TS LCO 3.0.3. This guidance should dealwith removal of redundant equipment from service and withfailure to meeting LCO Action requirements.

2. Clear guidance should be added to OP-AD-001 dealing withactions to be taken by Unit Supervisors once their unit hasentered TS LCO 3.0.3.

3. Communication of these changes to operational policy shouldbe made and training of appropriate personnel should beheld.

4. 'R 97-3431 and LER 50-388/97-007 should be revised toreflect these changes in policy and additional actions.

ops

OpS

Ops

Qpa/Li~s~j

4/1/98

4/1/98

4/15/98

Q Cont'd.

FORM NDAP-QA-0702-4, Rev. 1, Page 3 of 4

CR NO. 9 -3431

CONDITIONREPORT - EVALUATION8 ACTIONPLAN

EVALUATION8 ACTION PLANDescri'on/Basis of "Use-As-Is" or "Re air."

Desi n and License Documents Re uirin U date.

PREPARED BY

I ~

Cl.c~ ~ s a ~r rrATE LEAD FUNCT UNIT MANAGER AT

AFFECTED FUNCT UNITMANAGER

DATE AFFECTED FUNCT UNIT DATEMANAGER

/AFFECTED FUNCT UNIT

MANAGER

OES SUPERVISORLevel 1 & Reportable Level 2

f8'-02 -S ~

PORC MEETING NUMBERLevel 1 & Reportable Level 2

DATE MANAGER-NSE& NUCLEAR MODIFICATIONS

se-As-Is or Re air A rova

/ Q//E/9&DATE

a/w/ca

DATE

FORM NDAP~Q702%, Rev. 1, Page 4 of 4

HLV lD 1005 Ld: 45

v)

ICC,Q Ul I Jl 0 I Jl WC %VIV

CR 97-3431 Timeline

Date10/16/97

10/17/97

Time0820

0821

1020

0820

0838

0849

0920

1250

12521410

Activi /ActionLCO entered for 'A'od Block'Monitorinoperable for SI-278-325A and SI-278-225A

Powerplex blocked to support testing of2A RBMProblems encountered during performanceofSI-278-325A due to failed LPRMoutputs. (See CR 97-3414, WA's V73181,V73 182

RBM2A remains inoperable. LCO3.1.4.3.(a) 24 hour period expired, 1 hourremains to place the 2A RBM in thetri ed condition.Powerplex restored to obtain core editbefore RBM testin resumes.

Powerplex blocked and testing of2ARBM resumes,

Tech Spec 3.0.3 entered since LCO3.1.4.3.a expired and the action to place2A RSM in the tripped condition cannot

'be completed due to operability testing inro ess.

Powe lex monitors restoredSI-278-325A corn leted satisfactorilAllLGO's cleared when V73181/V73182closed.

Tech S ecIm act

3.1.4.3 Action a. and 3.3.6Action 60-24 hrs to restore, otherwise1 hr to place in tripcondition.Im act '0/17/97 0820

3.1.4.3.aImpact:0920

3.0.3-1 hour to commenceshutdown/ be in Cond 2within the next 6 hours.Im act: 1020/1620

P

0 ji

~ & ~

'h ~