IR 05000387/1991007
| ML17157A754 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/12/1991 |
| From: | Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157A753 | List: |
| References | |
| 50-387-91-07, 50-387-91-7, 50-388-91-07, 50-388-91-7, NUDOCS 9107230211 | |
| Download: ML17157A754 (62) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
Inspection Report Nos.
.50-387/91-07; 50-388/91-07
=
License Nos.
Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name:
Inspection At:
Susquehanna Steam Electric Station Salem Township, Pennsylvania Inspection Conducted:
May 14 - June 24, 1991 Inspectors:
G. S. Barber, Senior Resident Inspector J. R. Stair, Residen ns r
Approved By:
In tion umma J. ', C ie, Reactor rojects Section 2A Dat ll R
'
p
'
~rit (71707)
Routine observation of protected area access and egress control indicated good control by the license Executive Summary (Continued)
En ineerin /Techni l
(71707, 92720, 93702)
The "C" Emergency Diesel Generator exhibited a slow'start on June 19. The licensee attributed the slow start to voiding in'the fuel supply header which was caused by the installation of a flowingvent modification. Compensatory measures have been established and corrective actions are being implemented.
Safet As e sment/A ran f
ualit (40500, 90712, 92700, 92701)
A total of 90 Significant Operating Occurrence Reports were reviewed during the period, 5 of which were followed up in this report.
No unacceptable conditions were noted.
A management meeting was held between the NRC and the licensee on June 20 to discuss the licensee's plans to upgrade their environmental qualification (EQ) program and their EQ binders.
The licensee's presentation is provided in attachment DETAILS 1.
SUMMARYOF OPERATIONS 1.1 Inspection Activities The purpose of this inspection was to assess licensee'activities at Susquehanna Steam Electric Station (SSES) as they related to reactor safety and worker radiatio'n protection.
Within each inspection area, the inspectors documented the specific purpose of the area under review, the scope of inspection activities and findings, along with appropriate conclusions.
This assessment is based on actual observation of licensee activities, interviews with licensee personnel, measurement of radiation levels, independent calculation, and selective review of applicable documents.
Abbreviations are used throughout the text. Attachment 1 provides a listing ofthese abbreviations.
1.2 Susquehanna Unit 1 Summary Unit 1 operated at or near full power throughout the inspection period.
Scheduled power reductions were conducted during the period for control rod pattern adjustments, surveillance testing, and maintenance.
One ESF actuation occurred on June 8 when power was lost to the
"A" RPS bus resulting in Division I containment isolations and automatic initiations of the "A" SGTS and "A" CREOASS.
See Section 2.2.1 for a discussion of the event.
1.3 Susquehanna Unit 2 Summary Unit 2 entered the inspection period with the unit at 100 percent full power, following power ascension and testing after completion of the unit's fourth refueling outage.
The unit operated at or near full power throughout the inspection period.
Scheduled power reductions were conducted during the period for control rod pattern adjustments, surveillance testing, partial arc testing, single loop testing, and maintenance.
Three ESF actuations occurred during the inspection period.
Two of these were due to loss of the "A" RPS bus on May 15 and May 30 resulting in Division I containment isolations and automatic initiations of the "A"SGTS and "A" CREOASS.
See Section 2.2.1 for a discussion of these events.
The third ESF actuation was on June 24 when an isolation of the RWCU system occurred during an instrumentation calibration.
See Section 2.2.2 for a discussion of the event.
2.
OPERATIONS 2.1 Inspection Activities The inspectors verified that the facility was operated safely and in conformance with regulatory requirements.
Pennsylvania Power and Light (PP&L) Company management control was evaluated by direct observation ofactivities, tours of the facility, interviews and discussions with personnel, independent verification of safety system status and Limiting Conditions for Operation, and review of facility records.
These inspection activities were conducted in accordance with NRC inspection procedure 7170 The inspectors performed 21.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of deep backshift inspections on May 24 from 2:00 a.m.
to 6:00 a.m.; June 21 from 2:00'a.m. to 6:00 a.m.; June 22 from 8:00 a.m. to 3:15 p.m.; June 23 from 9:00 a.m. to 1:00 p.m.; and, June 28 from 3:00 a.m. to 6:00 a.m..
2.2 Inspection Findings and Review of Events 2.2.1 Reactor Protection System Electrical Protection Assembly Breaker Trips At 11:31 p.m. on June 8, while at 100% power, Unit 1 received a half scram and primary containment isolations due to the loss of normal power to the "A" Reactor Protection System (RPS) bus.
The normal power supply was interrupted when both RPS Electrical Protection Assembly (EPA) breakers tripped open.
Normally, motor generator (MG) sets powered from 480 VAC engineered safeguards system motor control centers provide 120 VAC power to the RPS while EPA breakers downstream of the MG sets provide protection in case of overvoltage, undervoltage, or underfrequency.
The opening of the EPA breakers was unexpected since none of these conditions existed.
The fail safe design of the RPS led to the actuation of several Engineered Safety Features and system isolations upon loss of power to the bus.
The major actuations were auto initiations of standby gas treatment and control room emergency outside air supply; and isolations of reactor building HVAC, reactor water cleanup, and recirculation pump cooling water.
Operators transferred the "A" RPS bus to its alternate power supply and reset the half scram.
The licensee verified that all plant systems responded as expected, reset the isolations, and restored the affected systems to their normal alignment.
The spurious trip of the EPA breakers was initially attributed to a faulty EPA logic card.
This card was replaced and the licensee restored the normal power supply on June 21.
The licensee's investigation of spurious EPA breaker trips was already in progress due to two previous events which occurred on Unit 2 at 6:20 p.m. on May 15 and at 9:25 a.m. on May 30. The licensee is investigating all three events simultaneously because plant indications and response were the same in each case.
ENS notification was made, at 12:42 a.m. June 9, per 10 CFR 50.72(b)(2)(ii).
As a result of the May 15 breaker trip, the licensee organized a task team to review the event and to reduce the frequency of EPA breaker trips.
The team developed and implemented a
comprehensive plan to evaluate possible root causes.
It included assessment of any operational or design changes which may be necessary.
During their investigation, the licensee discovered current oscillations on the ground bus of the RPS distribution panel which were larger than expected.
The licensee's preliminary finding indicated that the ground bus may have been connected to station ground and not the instrument ground as called for in the design.
This item is under review as a possible cause for the EPA breaker trips.
Spurious EPA breaker trips are a common industry problem. A study ofEPA breaker trips prepared by General Electric Nuclear for the BWR Owners Group is currently under review by the task team,
The inspector reviewed the licensee's plan, discussed the issue with the lead engineer, and observed portions of the field investigation.
The comprehensive plan and use of a contractor, experienced in this area, were positive contributions the their investigation.
The licensee's plan to reduce EPA trip frequency and to improve EPA reliability appears to be thorough and proceeding at an adequate pace.
During all three events, ESF systems and components functioned as designed.
The inspector has no further questions at this time.
2.2.2 Reactor Water Cleanup System Isolation - Unit 2 At 10:00 p.m. on June 24, a Reactor Water Cleanup System (RWCU) isolation occurred when the inboard isolation valve (F001) closed due to a high differential temperature (dT) signal in the RWCU pump room.
The high dT signal occurred when Instrumentation and Control (1&C)
technicians were performing the monthly main steam line tunnel dT instrumentation calibration (SI-283-209). Step 6.1.5 ofthe procedure required that the thermocouple calibrator be connected to test block TJ1 jack 13.
Due to a communication error, the calibrator was connected to the wrong test block, i.e. TJ1 jack 3, simulating a high dT signal that caused automatic isolation of the F001 valve. Valve response was per design and no complications resulted from the isolation.
Operators immediately recognized the error and restored the system to its normal lineup in a timely manner.
The appropriate Emergency Notification System call was made to the NRC at 11:20 p.m. ~
The licensee counseled the individuals involved on'he importance of clear and concise communications.
In addition, the licensee formed a review group to identify potential causes and to recommend corrective action.
Their actions were underway at the end of the report period.
The licensee plans on submitting a Licensee Event Report (LER) to document root cause(s)
and corrective action. The adequacy ofthe licensee's root cause identification and planned corrective action will be reviewed during review of the Licensee Event Report.
The inspector has no further questions at this time.
3..
RADIOLOGICALCONTROLS 3.1 Inspection Activities PP&L's compliance with the radiological protection program was verified on a periodic basis.
These inspection activities were conducted in accordance with NRC inspection procedure 71707.
3.2 Inspection Findings Observations of radiological controls during maintenance activities and plant tours indicated that workers generally obeyed postings and Radiation Work Permit requirements.
No inadequacies were note.
MAINTENANCE/SURVEILLANCE 4.1 Maintenance and Surveillance Inspection Activity V
On a sampling basis, the inspector observed and/or reviewed selected surveillance and maintenance activities to ensure that specific programmatic elements described below were being met.
Details of this review are documented in the following sections.
4.2 Maintenance Observations The inspector observed and/or reviewed selected maintenance activities to determine that the work was conducted in accordance with approved procedures, regulatory guides, Technical Specifications, and industry codes or standards.
The following items were considered, as applicable, during this review: Limiting Conditions for Operation were met while components or systems were removed from service; required administrative approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and quality control hold points were established where required; functional testing was performed prior to declaring the involved component(s)
operable; activities were accomplished by qualified personnel; radiological controls were implemented; fire protection controls were implemented; and the equipment was verified to be properly returned to service.
These observations and/or reviews included:
Area Radiation Monitor Calibrations per WA P10428 performed on May 23, 1991.
Control Structure Chilled Water System Temperature Controller TIC 08612B adjustment per WA S16604 performed on June 14, 1991.
Replacement of Standby Liquid Control Accumulator IT207A bladder per WA S13640 on June 17, 1991.
Troubleshooting of "C" Diesel Generator Slow Start on June 19, 1991.
4.3 Surveillance Observations The inspector observed and/or reviewed the following surveillance tests to determine that the following criteria, ifapplicable to the specific test, were met:
the test conformed to Technical Specification requirements; administrative approvals and tagouts were obtained before initiating the surveillance; testing was accomplished by qualified personnel in accordance with an approved procedure; test instrumentation was calibrated; LimitingConditions for Operations were met; test data was accurate and complete; removal and restoration ofthe affected components was properly accomplished; test results met Technical Specification and procedural requirements; deficiencies noted were reviewed and appropriately resolved; and the surveillance was completed at the required frequenc These observations arid/or reviews included:
SO-153-004, Quarterly Standby Liquid Control Flow Verification performed on June 17, 1991.
SO-024-001C, Monthly Diesel Generator "C" Operability Test, performed on June 19, 1991.
SO-251-002, Quarterly Core Spray Flow Verification, Loop "B" performed on June 21, 1991.
4.4 Inspection Findings The inspector reviewed the listed maintenance and surveillance activities. The review noted that work was properly released before its commencement; that systems and components were properly tested before being returned to service and that surveillance and maintenance activities were conducted properly by qualified personnel.
Where questionable issues arose, the inspector verified that the licensee took the appropriate action before system/component operability was declared.
No unacceptable conditions were identified.
5.
EMERGENCY PREPAREDNESS 5.1 Inspection Activity The inspector reviewed licensee event notifications and reporting requirements for events that could have required entry into the emergency plan.
5.2 Inspection Findings No.events were identified that required emergency plan entry. No inadequacies were identified.
6.
SECURITY 6.1 Inspection Activity PP&L's implementation of the physical security program was verified on a periodic basis, including the adequacy ofstaffing, entry control, alarm stations, and physical boundaries.
These inspection activities were conducted in accordance with NRC inspection procedure 71707.
6.2 Inspection Findings The inspector reviewed access and egress controls throughout the period.
No unacceptable conditions were note.
ENGINEERING/TECHNICALSUPPORT 7.1 Inspection Activity The inspector periodically reviewed engineering and technical support activities during this inspection period.
The on-site Technical (Tech) section, along with Nuclear Plant Engineering (NPE) in Allentown, provided engineering resolution for problems during the inspection period.
The Tech section generally addressed the short term resolution ofproblems; and NPE scheduled modifications and design changes, as appropriate, to provide long term problem correction. The inspector verified that problem resolutions were thorough and directed to preventing recurrences.
In addition, the inspector reviewed short term actions to ensure that the licensee's corrective measures provided reasonable assurance that safe operation could be maintained.
7.2 Inspection Findings 7.2.1 Emergency Diesel Generator "C" Slow Start On June 19, the "C" Emergency Diesel Generator (EDG) failed its monthly operability surveillance due to a start time in excess of the required 10 seconds.
The licensee declared the
"C" EDG inoperable and entered TS LCO 3.8.1.1.
Investigation into the cause determined that the slow start was due to a fuel delivery problem resulting from a voided fuel supply header.
The licensee believes that the cause of the voiding in the fuel header was due to an injection pump flowing vent modification performed in August of 1990.
The flowing vent modification was installed to alleviate an injection pump overheating problem at idle or low power operation.
This same modification was also installed on EDGs "A", "B" and "D" between August and October 1990. The licensee believed that voiding was ofprimary concern only in the "D" EDG since it was the only EDG that had previously exhibited a slow start.
Upon consulting with the vendor, Cooper-Bessemer Company, the flowing vent design was modified on the "D" EDG by adding loop seals to prevent fuel header voiding in May 1991. The remaining three EDGs were to be modified during their next 18 month inspection outages scheduled for September to October 1991.
However, as a result of this event, the licensee is planning to expedite the installation of this modification such that the remaining EDGs are modified by the end of July.
As compensatory measures, the "A"and "B" EDGs were started to assure operability. Both EDGs started and achieved rated speed, frequency and voltage within the required time limit. The "C" EDG was subsequently restarted twice with start times of 7.7 and 7.6 seconds.
The second run was the operability surveillance which the "C" EDG completed successfully.
Hence the "C" EDG was declared operable and the TS LCO 3.8.1.1 exited.
The licensee plans to submit a licensee event report to the NRC on this event, its cause, and corrective actions.
Pending installation of the planned modifications, the licensee stated that they willstart the "C" EDG on a weekly basis and the "A" and "B" EDGs biweekly. The licensee believes that these testing frequencies willassure operability since the voiding process is very slow as demonstrated
by several successful starts on 30 day intervals since the original modification was installed in 1990. The biweekly starts for the "A"and "B" EDGs appears justified since previous successful starts were performed at intervals of up to 19 days..
L The inspector observed the slow start of the "C" EDG on June 19, and the troubleshooting effort by maintenance personnel to determine the cause.
Discussions were conducted with engineering and maintenance personnel on the potential causes of the slow start.
In addition, the inspector reviewed and walked down the flowing vent modifications on the EDGs, and the loop seal modification performed on the "D" EDG in order to evaluate the voiding problem and its correction. The licensee's determination ofthe cause and corrective actions appeared reasonable, and the compensatory measures appear adequate to preclude a slow start due to fuel oil header voiding.
The inspector concurs that the corrective modifications on the "A", "B", and "C" EDGs should be installed on an expedited schedule and discussed this with licensee.
The licensee committed to install the loop seal modification on the "A", "B", and "C" EDGs by August 16.
During event review, the inspector noted that licensee's pre-installation design review of the initialflowing vent modification failed to recognize the potential for fuel oil header voiding. The inspector noted that flowing vent modification used an existing tap offof the injector drive pump that provided a straight through flowpath to the FO day tank. This path in conjunction with any small air leaks at the higher elevations of the fuel supply header would be sufficient to cause voiding. The use of a loop seal should preclude the draining ofFO back to the day tank.
Based on the licensee's compensatory measures and planned actions, the inspector has no further questions at this time.
8.
SAFETY ASSESSMENT/QUALITY VERIFICATION 8.1 Licensee Event Reports (LER), Significant Operating Occurrence Report (SOORs),
and Open Item (OI) Followup 8.1.1 Licensee Event Reports The inspector reviewed LERs submitted to the NRC office to verify that details ofthe event were clearly reported, including the accuracy of the description of the cause and the adequacy of corrective action.
The inspector determined whether further information was required from the licensee, whether generic implications were involved, and whether the event warranted onsite followup. The following LERs were reviewed:
@nihil 90-033-01 Diesel Generator "D" Piston Pin Bushing Failure.
This revision to LER 90-033 provided the final root cause determination for the piston pin bushing failure which was that an arched piston bore led to the bushing failure.
See NRC Inspection Reports 90-25 and 91-02, for previous discussions and evaluation Fire Damper Not Installed in Fire Rated Barrier.
This revision to LER 91-003 provided the determination that the fire barrier with the missing damper does not separate redundant safe shutdown equipment or cables, has no effect on the safe shutdown analysis, and does not protect safety-related equipment.
Unit 2 91-004-00 Technical Specification Noncompliances During Refueling Bridge Surveillances.
This LER documented the withdrawal of a control rod with Standby Liquid Control inoperable on two occasions on March 14 and March 15, 1991 while the unit was in the refueling mode. T.S. 3.1.5 requires all control rods to be inserted when SLC is inoperable except for those control rods removed per T.S. 3.9.10.1 or 3.9.10.2.
During these times the licensee did not comply with the specifications T.S. 3.9.10.1, which required all other control rods in a five-by-five array to be inserted and disarmed.
The cause of the events was determined to be personnel error by control room operators in that they incorrectly evaluated restrictions on a caution tag on the Reactor Manual Control System withdraw pushbutton.
The operators mistakenly thought that the caution tag did not apply and that the refueling bridge surveillances could be performed.
Therefore, the array of control rods were not dlsai'med.
In addition, the surveillance procedures did not contain prerequisites to confirm that the five-by-five array had been disarmed.
Immediate corrective actions completed were to hydraulically disarm the array of control rods around the control rod to be withdrawn and implement the caution tag package.
Actions taken to prevent a
recurrence included reemphasis of the importance of compliance with controls on tagged devices and revisions to surveillances to include confirmation steps that all applicable LCO requirements are satisfied prior to performance.
In addition, the licensee is evaluating a T.S. change to allow for withdrawing one control rod to test refuel bridge interlocks with SLC inoperable.
The inspector reviewed this event with the licensee and determined that the actions taken by the licensee appear adequate to preclude a recurrence of the event.
This event constitutes non-compliance with the requirements ofT.S. 3.1.5, in that the control rod was withdrawn one notch for refueling bridge testing with SLC inoperable and the specifications T.S. 3.9.10.1 not satisfied.
However, since the licensee met the requirements of 10 CFR 2 Appendix C Section V. G. 1, no violation was issue Emergency Diesel "A"Failure During 18 Month Surveillance Testing. This LER documented the failure of the "A" Emergency Diesel Generator (EDG) to reach rated speed and pick up load during an 18 month LOCA-LOOP surveillance test on April22, 1991.
The licensee could not positively determine the root cause of the failure but believed the most likely cause was due to a sticky pneumatic valve that was not repeatable during testing.
Several start attempts including the operability surveillance were successfully performed following investigation into the failure.
The "A" EDG was returned to operable status on April 23 and the 18 month LOCA-LOOP test successfully reperformed on April 24.
91-007-00 ESF Actuations Due to an RPS EPA Breaker Spurious Trip.
This LER documented the loss of the primary power supply to the "A" RPS power distribution panel and the corresponding division 1 containment valve closures, including the auto initiations of the "A" SGTS and "A" CREOASS.
Plant systems responded normally to this event and no complications resulted.
All isolation signals were reset and the SOTS and CREOASS returned to standby.
The most probable cause was attributed to a faulty EPA logic card which was replaced.
In addition, a task team was organized by the licensee to review the problems occurring with the RPS to determine enhancements to reliability, and an EPA study prepared by the vendor for the BWR owners group is being evaluated for possible improvements.
This event is reviewed in Section 2.2.1.
No unacceptable conditions were identified.
8.1.2 SigniTicant Operating Occurrence Reports SOORs are provided for problem identification and tracking, short and long term corrective actions, and reportability evaluations.
The licensee uses SOORs to document and bring to closure problems identified that may not warrant an LER.
The inspectors reviewed the followingSOORs during the period to ascertain whether: additional followup inspection effort or other NRC response was warranted; corrective action discussed in the licensee's report appears appropriate; generic issues are assessed; and, prompt notification was made, ifrequired:
~nit i 47 SOORs, inclusive of 1-91-098 through 1-91-144.
iintt 2 43 SOORs, inclusive of 2-91-115 through 2-91-160.
No unacceptable conditions were identifie The following SOORs were comprehensively reviewed by the inspector:
1-91-140 Documented an ESF actuation due to the loss of the "A"RPS bus when both EPA breakers tripped open on June 8.
This event is reviewed in Section 2.2.1.
1-91-156 Documented a slow start of the "C" EDG on June 19, during a monthly operability test.
This event is reviewed in Section 7.2.1
~
2-91-135 Documented an ESF actuation due to the loss ofpower to the "A"RPS bus when both EPA breakers tripped open on May 15.
This event is reviewed in Section 2.2.1.
2-91-149 Documented an ESF actuation due to the loss ofpower to the "A"RPS bus when both EPA breakers tripped open on May 30.
This event is reviewed in Section 2.2.1.
2-91-160 Documented an isolation of the RWCU System on June 24 due to an error made during an instrumentation calibration.
This event is reviewed in Section 2.2.2.
8.1.3 Open Items 8.1.3.1 (Closed)
UNR 50-387/87-09-02, Fifth Diesel Generator HVAC Part
Followup On April 15, 1987, the licensee identified a number ofHVACductwork design deficiencies for the Fifth Emergency Diesel Generator (DG).
These deficiencies were reported to the NRC.
Some of these deficiencies could have potentially rendered the HVAC system inoperable followingan Operating Basis (OB) or Safe Shutdown Earthquake (SSE).
The loss of the HVAC system, and its corresponding safety related support function, would cause the fifth or "E" DG to become inoperable.
The licensee issued NCR 86-1275 to document inadequate design control by the vendor that was installing HVACductwork. Upon further investigation, the licensee expanded the magnitude of the problem to include deficiencies related to:
1.
, 2.
3.
4.
5.
6.
design control process ductwork and ductwork support design analysis techniques anchor bolt design document signoff conflicts between as-built drawings and actual field conditions These deficiencies were subsequently evaluated as significant and reported to the NRC in PLA-2846 dated April 15, 1987 pursuant to 10 CFR 2 The inspector reviewed the deficiencies and agreed with the licensee's assessment of their safety significance.
He also noted that the licensee initiated corrective action to prepare as-built drawings for the HVAC ductwork and duct supports and to reanalyze the system response to a seismic event using conservative assumptions.
The licensee performed the following four specific actions to address each of the design deficiencies identified in the 10 CFR 21 report.
1)
Field walkdowns were performed to assure that the "general" locations and configurations of supports and ductwork matched the appropriate drawings.
Any discrepancies were noted and the appropriate drawings revised.
2)
Allductwork support base plate configurations (surface mounted and embedded plates)
were walked-down and reconciled with the as-built drawings.
3)
Any weld configurations that were unclear on the drawings were walked-down and the drawings were revised to reflect the inspection results.
4)
The licensee completely reanalyzed the ductwork system (ductwork and supports) based on the as-built configurations.
Fifteen specific calculations (NG-C-MHR-124, 125, 127-135, 137-140) were performed.
The results indicated that the fifthDG HVACductwork was capable of performing its design function during an OBE and SSE.
NCR 86-1275 was closed on June 5, 1987.
The inspector reviewed the licensee actions to correct the identified design deficiencies and noted that the licensee promptly performed the required walkdowns.
The calculations were reviewed and found to be discussed with an NRC specialist inspector with seismic calculation expertise.
Based on these discussions, the calculations were found to be thorough and comprehensive.
In addition, the inspector walked down accessible portions of the system and noted that seismic supports for the system were in place and attached to surface mounted and embedded plates.
The supports shown on PP&L drawing No. FF65109 were compared with the field installation and found to be in agreement.
The overall condition of the supports and their attachments was found to be adequate.
Based on the above, this item is closed.
During the walkdown, the inspector noted that inner doors for the HVAC supply fan plenum were left open.
Although these fans are not required to be physically independent, the open door bypasses the design function of the backdraft damper.
The licensee addressed this concern by closing the two doors (one per train) and agreed to label the doors requiring them be kept closed except for routine passage.
No inadequacies were note.
MANAGEMENTAND EXITMEETINGS 9.1 Routine Resident Exit and Periodic Meetings The inspector discussed the findings of this inspection with station management throughout and at the conclusion of the inspection period.
Based on NRC Region I review of this report and discussions held with licensee representatives, itwas determined that this report does not contain information subject to 10 CFR 2.790 restrictions.
9.2 Inspections Conducted By Region Based Inspectors
~Dates s
S~ub'ect Inspection
~Re rt No.
Reporting
~lns ector 6/17 - 6/21 Fuel Pool Cleanout/
Routine HP 91-08 Noggle 9.3 Management Meeting - Environmental Qualification Program and Binder Upgrade Project A meeting was held on June 20, 1991 at the Region I offices between the NRC and PP&L management.
A list of the attendees at the meeting appears as Attachment 2 to this report.
The meeting was held at the licensee's request to present the current status of the Environmental Qualification (EQ)
Program and Binder Upgrade.
The presentation included licensee Management Perspective, EQ Program Discrepancy status, EQ Binder assessment, EQ Binder upgrade and conclusion and is included as Attachment 3.
The program presented by the licensee appeared to be well thought out, comprehensive and easily implementable.
Additional contractor resources are available to preclude adverse impact on the day;to-day EQ program.
Currently, five EQ binders have been upgraded in form and content, eight are in the upgrade process, and six will be released for upgrade on June 30, 1991.
The remaining 62 EQ binders will be reviewed and upgraded at the rate of 11 per quarter.
The upgrade of all 81 EQ binders is scheduled to be completed by December 31, 1992.
The licensee indicated that there have been significant reductions in the backlog of EQ discrepancies.
They attributed this to increased management attention and resources.
Forty-five of 63 engineering discrepancies have been closed and the others are being reviewed for closure.
The licensee's stated motivations for the upgrade is to ensure nuclear safety, satisfy the public that the licensee is responsibly managing Susquehanna, and to plan and implement the EQ maintenance more efficientl ATTACHMENT1
~Ab i i Li AD ADS ANSI-CAC CFR CIG CRDM-CREOASS-DG DX ECCS-EDR EP EPA ERT ESF ESW EWR FO FSAR-HVAC-ILRT ISAAC JIO LCO LER LLRT-LOCA-LOOP-MSIV-NCR NDI NPE NPO NQA NRC OI PC PCIS PMR PORC-QA Administrative Procedure Automatic Depressurization System American Nuclear Standards Institute Containment Atmosphere Control Code of Federal Regulations Containment Instrument Gas Control Rod Drive Mechanism Control Room Emergency Outside AirSupply System Diesel Generator Direct Expansion Emergency Core Cooling System Engineering Discrepancy Report Emergency Preparedness Electrical Protection Assembly Event Review Team Engineered Safety Features Emergency Service Water Engineering Work Request Fuel Oil Final Safety Analysis Report Heating, Ventilation, and Air Conditioning Integrated Leak Rate Test Instrumentation and Control Justifications for Interim Operation Limiting Condition for Operation Licensee Event Report Local Leak Rate Test Loss of Coolant Accident Loss of Offsite Power Main Steam Isolation Valve Non Conformance Report Nuclear Department Instruction Nuclear Plant Engineering Nuclear Plant Operator Nuclear Quality Assurance Nuclear Regulatory Commission Open Item Protective Clothing Primary Containment Isolation System Plant Modification Request Plant Operations Review Committee
,Quality Assurance
Attachment
RCIC-RG RHR RHRSW-RPS RWCU-SGTS-SI SO SOOR-SPING-TS TSC WA Reactor Core Isolation Cooling Regulatory Guide Residual Heat Removal Residual Heat Removal Service Water Reactor Protection System Reactor Water Cleanup Standby Gas Treatment System Surveillance Procedure, Instrumentation and Control Surveillance Procedure, Operations Significant Operating Occurrence Report Sample Particulate, Iodine, and Noble Gas Technical Specifications Technical Support Center Work Authorization
ATTACHIVIFAT2 Management Meeting Attendee List Environmental Qualification Program and Binder Upgrade Project Pennsylvania Power & Light Company (PP&L)
w T. Gorman, Engineering Supervisor J. Kinney, Licensing Group Supervisor A. Derkacs, Engineering - EQ R. Hoopes, Project Manager J. Blakeslee, Manager - Nuclear Modifications U.S. Nuclear Regulatory Commission R. Paolino, Senior Reactor Engineer, DRS J. Raleigh, Acting Project Manager, NRR A. Blough, Chief, Project Sections Branch No. 2, DRP C. Anderson, Chief, Electrical Sections, DRS P. Kaufman, Project Engineer, DRP S. Barber, Senior Resident Inspector, Susquehanna
Attachment
SUSQUEEhQ DNA STEAM EI.ECTRrc STAT>ON JUNE 20, 1991 Management Perspectives J.A. Blakeslee, Jr.
Mgr. - Mods EQ Program Discrepancy Status T.A. Gorman Supervising Eng.
EQ Binder Assessment A.P. Derkacs Sr. Project Eng.
y'
EQ Program Upgrade R.E. Hoopes Project Manager Conclusion J.A. Blakeslee, Jr.
Mgr. - Mods
~
WE HAVE A NEW OUTLOOK ON EQ ISSUES.
~
SINCE WE LAST MET WE HAVE TAKEN SEVERAL KEY ACTIONS.
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WE HAVE CLEANED UP OUR DEFICIENCY BACKLOG.
~
WE HAVE CLOSED
DISCREPANCIES, INCLUDING 37 NCR'S, ALL NQA AUDIT FINDINGS AND DEFICIENCY REPORT.
~
WE HAVE COMPLETED AN INDEPENDENT ASSESSMENT OF OUR EQ BINDERS.
A COMPREHENSIVE EQ PROGEVB/I UPGRADE IS NEEDED AND IN PROGRES PP I MPI KTKD TI COMPLETED COMPREHENSIVE ASSESSMENT OF EQ BINDERS.
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INITIATED AS A RESULT OF SBGT DAMPER SEAL CONCERN
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THIRD PARTY ASSESSMENT COMPLETED IN 1990
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CONCLUDED THERE ARE NO REPORTABLE ITEMS, NO IMPACT ON THE OPERATING PLANTS
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REINFORCED NEED TO IMPROVE QUALITYOF BINDERS
CHANGED OUR APPROACH TO CLOSING DISCREPANCIES.
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DISCREPANCY PROGRAM IS EFFECTIVE IN IDENTIFYINGAND CLOSING ISSUES
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NEW ISSUES BEING DISPOSITIONED UNDER DISCREPANCY PROGRAM PRIORITY IS BASED ON SAFETY SIGNIFICANCE
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EQ BACKLOG OF OLD EQ NCR'S HAS BEEN ELIMINATED
PP L
m
A i n EQ Program Upgrade is a
major department commitment.
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binder upgrade project has been prioritized, planned and approved five binders are complete and eight others in progress
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remainder (68) to be completed in 1992
K DI REPAN Y TATU
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EFFECTIVE EQ PROGRAM
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DOCUMENTATION MUST BE UPGRADED DISCREPANCIES WILLRESULT
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EFFECTIVE DISCREPANCY MANAGEMENTPROGRAM AGGRESSIVELY CLOSING EQ DISCREPANCIES
r
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PR RAM RELATED NQA DEFICIENCY REPORT NQA AUDIT FINDINGS
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E IPME T RELATED NON CONFOMCANCE REPORTS ENGINEERING DISCREPANCY REPORTS
.PR RE
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SIGNIFICANT REDUCTION IN BACKLOG - CLOSED 90 ITEMS
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PROMPT ASSESSMENT OF SAFETY SIGNIFICANCE-OPERABILITYAND REPORTABILITY
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ALLDEFICIENCIES HAVE PLAN FOR CLOSURE
PR RAM RKLATKDDI RKPAN IK
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NQA DEFICIENCY REPORT ON EQ CLOSED NQA AUDIT FINDINGS ON EQ-CLOSED 1991 NQA AUDIT YIELDED NO FINDINGS
E E
PME RELATED DI REPAN IE
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NON CONFORMANCE REPORT 37 OF 38 CLOSED ALL 32 COMMITTED NCR'S CLOSED BY END OF U2-4RIO REMAINING OPEN NCR HAS BEEN ASSESSED FOR SAFETY SIGNIFICANCE BEEN EVALUATEDFOR OPERABILITY AND REPORTABILITY BEEN DISPOSITIONED AND PLANNED FOR CLOSURE
E E
MENT RELATED DI REPAN IE (Cont'd).
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ENGINEERING DISCREPANCY REPORTS 45 OF 63 CLOSED ALL OPEN EDR'S HAVE BEEN ASSESSED FOR SAFETY SIGNIFICANCE, REPORTABILITYAND OPEKQ3ILITY BEEN PLANNED FOR CLOSURE MOST OPEN EDR'S ARE THE TYPE OF ISSUE BEST CLOSED IN THE CONTEXT OF BINDER UPGRAD ~
SAFETY SIGNIFICANT EQ ISSUES FOUND
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ARE THERE OTHERS?
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ASSESSMENT DONE TO FIND OUT SEPTEMBER TO DECEMBER 1990
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NO OTHERS FOUND
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ASSESSMENT WAS SELF-INITIATED MANAGED BY PPAL THOROUGH INDEPENDENT
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DEVELOP ASSESSMENT PLAN
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DO ASSESSMENT PRIORITIZE FINDINGS BASED ON SAFETY
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FIX HIGH PRIORITY ITEMS IMMEDIATELY
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DO MANAGEMENTASSESSMENT OF RESULTS
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FIX LOW PRIORITY ITEMS IN UPGRADE
CONTRACTOR GIVEN PAST EQ DEFICIENCIES NCRS EDRS AUDIT FINDINGS NRC INSPECTION REPORTS AND NOVS
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ALSO INDUSTRY EVENTS REVIEW PROGRAM (IERPS)
LOG
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DEVELOPED PROCEDURE AND CHECKLISTS 21 AREAS OF REVIEW 84 INDUSTRY DOCUMENTS
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REVIEWED AND APPROVED BY PP%L DOCUMENTED IN SEA-EQ-006
P~LA (Cont'd.)
If
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CONTRACTOR GIVEN ENGINEERING DISCREPANCY DEFINITION.
DEFICIENCY WHICH COULD IMPACT SAFE OPERATION OF PLANT HARDWARE IN PLANT MIGHT NOT BE QUALIFIED
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TOLD TO PRODUCE EDRS FOR FINDINGS THAT MET DEFINITION PPAL WOULD FURTHER ASSESS
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RECEIVED WEEKLY REPORTS ON FINDINGS
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NO SIGNIFICANT SAFETY ISSUE3
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NO IMMEDIATEQUALIFICATIONCONCERNS
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FINDINGS DOCUMENTED IN SEA-EQ-007
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PPA,L NQA AUDITED SEA-EQ-007 NO FINDINGS
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NEED MORE STANDARD EQ POSITIONS SOME EXISTING NEED TO BE MORE EXPLICIT
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MINIMIZEMULTIPLE DOCUMENT CHANGES FOR ONE PLANT/PROGRPdvI CHANGE
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NEED EXPLICIT, CLEARLY DOCUMENTED SUSQUEWQ4NA SES SPECIFIC ASSESSMENTS PERFORMANCE REQUIRED FOR HARSH ENVIRONMENT SAFETY FUNCTION BASIS FOR EQ MAINTENANCEREQUIREMENTS
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NO NEWS THESE ARE REASONS WE WANTED TO DO UPGIVQ)E
RADK PR T
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WILLADDRESS EVERY FINDING
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STANDARD EQ POSITION ADDED
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BINDER PRIORITY PARTIALLYBASED ON ASSESSMENT RESULTS
K PR RAM RADK PR T
UPGRADE THE EQ PROG1VAI SO THAT IT IS RECOGNIZED AS AN EXCELLENT PROGRAMMA
RADKM TIVATI N ENSURE DESIGN INTEGRITY ENSURE NUCLEAR SAFETY (OPERATE WITHIN DESIGN BASIS)
SATISFY OUR PUBLIC THAT WE ARE A
RESPONSIBLE OPERATOR OF SUSQUEHANNA MANAGEEQ BINDERS MORE EFFICIENTLY PLAN AND IMPLEMENT EQ MAINTENANCEMORE EFFICIENTLY
UP RADE F PERFORM THE EQ PROGludvT UPGRADE WITHOUT ADVERSELY IMPACTING DAY TO DAY EQ EFFORT IN SUPPORT OF SUSQUEHANNA CONCLVSION: UTILIZE A
PPA,L PRO JECT MANAGER OUTSIDE OF THE NORMAL DAY TO DAY EQ FUNCTION TO PLANANDMANAGE THE PROGRAM UPGRADE
K PR RAM RADE PE UPGRADE 81 EQ BINDERS UPGRADE EQ PM ACTIVITIES (2000)
DEVELOP A RELATIONALDATABASE
PR RAM RADE BENEFIT QUALIFICATIONLOGIC FULLYDOCUMENTED AND CLEARLYWRITTEN OUT IN EACH BINDER hQQNTENANCE AND SURVEIL&87CEINFOKMATION BETTER MAINTENANCE DIRECT ACCESS TO EQ INFORMATION AT COMPUTER TERMINALS
RADE METH D L Y
EFFECTIVELY PLAN EQ PROGIVAI UPGRADE EFFECTIVELY PLAN AND DEVELOP FORMAT AND CONTENT OF UPGRADED BINDERS LAYFOUNDATIONFOR FUTURE INTEGRATIONINTO ELECTRONIC ENVIRONMENT EFFECTIVELY MANAGETHE IMPLEMENTATION
ALITY CONTRACT BULKOF SCOPE (5 BINDERS COMPLETE, 8 WORlVNG, 68 SCHEDULED)
REVISED DESIGN STANDARD FOR EQ BINDERS DEVELOPED TRAINING PROGRAdvf FOR UPGRADE WO&MRS IDENTIFY UPGRADE INSTRUCTIONS FOR EACH BINDER PERFORM A TECHNICAL REVIEW AND EDIT OF EACHUPGRADED BINDERTO INSURE CONSISTENCY APPROVE EACH UPGRADED BINDER
K PR RAM RADE PR
'r RED LE DETAIL NUMBER OF BINDERS IN THE UPGRADE PROJECT BINDER UPGRADES COMPLETE BINDER UPGRADES IN PROGRESS BINDER UPGRADES TO BE RELEASED BY 6/30 BINDER UPGWG3ES SCHEDULED
PRIORITIXATIONBASED ON:
KNOWN PROBLEM AREA OR NEED COMPONENT LOCATIONS (INSIDE OR OUTSIDE CONTAINMENT)
CURRENT CONDITION OF BINDER RECOMMENDATIONOF UPGRADE SUPPORT VENDOR INPUT FROM EDR PROGWB8
BINDER UPGRADE SCHEDULE (68)
60
I N
D
E R
S
20
6/91 9/91 12/91 3/92 TIME 6/92 9/92 12/92 BINDERS RELEASED
~ UPGRADES COMPLETED
EQDF-31B ACTUATOR ITT NH90 TYPE HYDROMOTOR EQPL-E3B CABLE VALCOR 1/C 414 AWG 600V FOR DC EQPL-E6B RELAY AGASTAT EGP AND ETR EQDF-46 SOLENOID VLV TARGET ROCK 75KK PROCESS VALVE EQPL-E13 TERMINATION CANNON CE-9446-98 FOR SRV SOLENOID
WILLBE MPLETED BY 12/
EQEL-80 HPCI TERRY WOODWAIU3 HPCI TURBINE CONTROL EQDF-04 MCC 480V 8c 120/208 AC DISTRIBUTION PANELS e
EQDF-41 POS TRANSF.
TEC ACOUSTIC SRV POSITION SYSTEM EQDF-43 LIMITSWITCH NAMCO EQ-180'S EQDF-50 LIMITSWITCH NAMCO EQ-740'S EQEL-68 LIMITSWITCH NAMCO EQ-740'S EQEL-11 PRES. SWITCH STATIC-0-RING 12N e
EQPL-E6 RELAY AGASTAT E7000
I K
R E
EQDF-14 CABLE RAYCHEM INSTRUMENT Ec SPECIALTY EQDF-19 AUTO TRANSFER RUSS AUTOMATIC POWER TRANSFER SWITCH A CONTROL CABLE EQDF-21 CABLE BIW POWER 4, CONTROL CABLE EQDF-29 INSTRUMENTS VARIOUS HVAC INSTRUMENTS EQDF-35 ANALYZER COMSIP DELPHI H2/02 ANALYZER EQDF-44 SOLENOID VLV CIRCLE SEAL SV 315-9103-3 PILOT
BI ER RADK HED ED (62)
REMAINDER OF BINDERS IN THE UPGRADE PROJECT SCHEDULED FOR RELEASE AT THE RATE OF 11 BINDERS/QUARTER THROUGH THE 4TH QUARTER OF 1992
D DEALYVITH AT%'K FIND CHANGES TO EQ BINDERS VIA UPGRADE EFFORT (DOCUMENTATIONINCONSISTENCIES, ETC.)
"ELIMINATINGTHE DELTA" PROGRPdvf DISCREPANCIES HANDLED THROUGH THE DISCREPANCY MANAGEMENTPROGRAM ENGINEEKNG DEFICIENCY REPORTS NON CONFORMANCE REPORTS
E PR RAM RADE PR T RE AP WELLPLANNED SUPPORTS THE SCHEDULE EACH BINDER CONSIDERED INDIVIDUALLY CONSISTENT EFFECTIVELY MANAGED
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WE HAVE CLOSED OLD DISCREPANCIES AND OUR NEW PROGRAM AND OUTLOOK WILL ASSURE NEW EQ ISSUES WILLBE PROMPTLY AND PROPERLY EVALUATED.
OUR EQ PROGRAM ASSESSMENT IS COMPLETE AND HAS ASSURED THERE ARE NO SIGNIFICANT SAFETY ISSUES.
~
WE ARE UPGRADING THE EQ PROGRAM FOR THE FUTURE WITH A
COMPREHENSIVE BINDER UPGRADE TO BE COMPLETED BY THE END OF NEXT YEAR.