IR 05000387/1996008

Discusses Insps 50-387/96-08,50-388/96-08,50-387/96-09 & 50-388/96-09 on 960611 & 0909 & Two Investigations Conducted at Facility.Forwards NOV & Proposed Imposition of Civil Penalties in Amount of $210,000

ML20141D349
Person / Time
Site:	Susquehanna
Issue date:	06/20/1997
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Byram R PENNSYLVANIA POWER & LIGHT CO.
Shared Package
ML20141D353	List: IR 05000387/1996008 ML20141D556
References
50-387-96-08, 50-387-96-09, 50-387-96-8, 50-387-96-9, 50-388-96-08, 50-388-96-09, 50-388-96-8, 50-388-96-9, EA-96-270, EA-96-347, EA-97-054, EA-97-54, NUDOCS 9706270197
Download: ML20141D349 (8)

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j \ UNITED STATES

[ g NUCLEAR REGULATORY COMMISSION

L j REGloN l Q p 475 ALLENDALE ROAD l

• c KING oF PRUSSIA, PENNSYLVANIA 19406-1415

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l June 20,1997

EA's96-270; 96-347; & 97-054 l

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Mr. Robert Senior Vice President - Nuclear

! Pennsylvania Power.& Light Company

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2 North Ninth Street

Allentown, Pennsylvania 18101 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES

- $210,000

(NRC Inspection Report Nos. 50-387 & 50-388/96-08;96-09)

Dear Mr. Byram:

This letter refers to two NRC inspections conducted at Susquehanna Steam Electric Station

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between June 11,1996, and September 9,1996, as well as two investigations conducted

{ by the NRC Office of Investigations (01) at your Susquehanna nuclear facility. During the first

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inspection, four apparent violations of NRC requirements were identified, three of which related to a misalignment of an electrical breaker for the 'E' diesel generator. Those three violations involved not having the required number of operable diesel generators, inaccurate electrical distribution surveillances, and f ailures to implement procedures. The fourth violation related to a non-licensed operator's failure to follow your administrative procedures for controlling the status of equipment associated with the Standby Liquid Control system. During the second inspection, one apparent violation was identified involving a single Core Spray system test line containment isolation valve being opened and deactivated for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during performance of preventive maintenance, without the required actions being taken in accordance with the Technicol Specificat ans (TSs). The 01 investigations were initiated after

you had conducted intemalinvestigations f these matters that were identified by your staff. /

The inspection reports and the synopsis oi the first Olinvestigation were forwarded to you /

previously. The synopsis of the second Olinvestigation is enclosed.

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Based a numberon the investigations of nuclear conducted plant operators (NPOs), as well by the NRC as licensed and your operators, did notstaff, the perform NRC h certain activities, yet documented that the activities had been performed. As a result of thes findings, a predecisional enforcement conference (conference) was conducted with you en

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March 21,1997, to discuss the violations, their causes, and your corrective actions.

Based on the inforrnation developed during the inspections and investigations, the information provided during the March 21,1997, conference, and the information provided in your supplemental letter, dated April 9,1997, a number of violations of NRC requirements were identified. The violations are described in detail in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties (Notice).

hb h,$hhh 9706270197 970620 PDR ADOCK 05000387 G PDR

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Pennsylvania Power and Light Company 2 Most of the violations are described in Section I of the enclosed Notice. Of those violations in Section I, the majority relate to an event in which one of the required four independent diesel generators was inoperable for approximately 20 days because of a circuit breaker alignment error. This inoperability was caused by the failure of a nuclear plant operator (NPO)

to align the diesel generator in accordance with procedures. The supply breaker for the diesel's auxiliary equipment was removed inadvertently as a result of the operator's failure to identify the correct component before taking action while performing the alignment.

Furthermore, multiple barriers that should have prevented or detected the misalignment failed.

t The procedure approved for use in aligning the 'E' diesel generator was inadequate in that it

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did not specifically require tMt the alignment of the supply breaker for the diesel's auxiliary equipment be independently verified. In addition, although shift supervision wasinformed that there was a potential brer.kcr alignment problem, no action was taken to investigate or verify l

the reported condition. Finally, even though the TS surveillance (designed to verify that the

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safety-related electrical systems were properly aligned) was performed on three separate occasions by three different NPOs, the NPOs failed to properly complete the check of the j auxiliary equipment supply breaker and the misalignment went undetected for 20 days.

l The NRC is particularly concerned that even though the surveillanew . s ;edure requirement ,

to verify the alignment of the 'E' diesel generator auxiliary equipment supply breaker was tw l performed, records were completed to indicate that the verification was performed. The completion of records without actually having conducted the activity documented in the record takes on greater significance after considering that on approximately 157 occasions between January 1996 and June 1996, more than half of your NPOs f ailed to perform a required panel alarm test, yet completed a record to indicate that the test was completed. In addition, on multiple occasions between January 1994 and June 1996, Shift Supervisors (SSs), signed a record indicating that they performed the required general station inspection which included an in-plant tour, when in fact, the in-plant tours in some cases were not conducted,-in that the SSs did not leave the control room during those periods. In addition to the SSs, two Assistant Unit Supervisors (AUSs) performing Preventive Maintenance Worklist activities, signed off work as completed between January 1996 and June 1996 indicating that they had accompanied NPOs during theh rounds, when, in fact, the individuals had not entered the plant areas during those periods necessary to accompany the NPOs.

These numerous examples of both licensed and non-licensed pnsonnel not performing required activities, yet documenting on records that the activities were performed, raise serious questions regarding the adequacy of management and supervisory oversight at the station to ensure that management expectations were clearly communicated, understood and followed.

In your April 9,1997,letterto the NRC subsequent to the conference, you acknowledged that these conditions, that were identified and investigated by your staff, were serious regulatory and management issues. Even though no actual safety consequences resulted, management's failure to effectively communicate the expectation that activities be performed in accordance with procedures and with attention to detail, had the potential for significant safety consequences. Given the number of individuals involved in these activities, including licensed operators, the actual and potential impact on equipment operability, the duration of the problem, and the lack of management and supervisory oversight that resulted in the failure to detect this widespread condition; the violations in Section I are categorized in the aggregate as a Severity Level 11 problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.

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Pennsylvania Power and Light Company 3 l

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i I With respect to the violations in Section I,in accordance with the Enforcement Policy in effect at the time these violations occurred, a base civil penalty in the amount of $80,000 is considered for a Severity Level 11 problem. Since this issue constitutes a Severity Level ll

. problem, the NRC would normally consider whether credit was warranted for /denti// cation and Corrective Action in accordance with the civil pensity assessment process in Section VI.B.2

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of the Enforcement Policy. Credit would norme!!y be warranted for both factors because you

identified most of these issues during your investigations, and your corrective actions were ,

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considered prompt and comprehensive. Those corrective actions included: (1) improvements  !

in supervisory oversight; (2) training on the event, on the 'E' diesel generator design, and on ,

l management expectations; and (3) expanded self-assessment in the Operations Department.  !

However, this case represents particularly poor licensee performance, as evidenced by (1) the l nature of the violations associated with the Severity Leveill problem including the inoperability j of the diesel generator for almost three weeks and the number of employees involved, (2) the extensiveness of the problem with inaccurate records; and (3) the management and supervisory failures demonstrated by these violations. Additionally, the NRC previously issued Information Notice 92-30 on April 23,1992, and Generic Letter 93-03 on October 20,1993, that described similar occurrences at other facilities. Your actions in response to these i communications did not assure that plant personnel were properly performing their assigned !

duties at Susquehanna. Therefore, notwithstanding the normal civil penalty assessment outcome, I have decided, in light of this performance, to exercise discretion in accordance with Section Vll.A.1 of the Enforcement Policy and propose a civil penalty at two times the base amount.

Accordingly, to emphasize the importance of performing activities as required, maintaining accurate records of such activities, and providing appropriate control and oversight of such activities, I have been authorized, after consultation with the Director, Office of Enforcement and the Deputy Executive Director for Regulatory Effectiveness, to exercise enforcement discretion and issue the enclosed Notice of Violation and Proposed imposition of Civil Penalties (Notice) in the total amount of $160,000 for the violations in Section 1.

With respect to the violation in Section ll of the Notice, a containment isolation valve in a core spray system test line was opened and deactivated for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, contrary to the TSs, and operators did not initiate action in accordance with the TSs to place the unit in an operational condition in which the TS did not apply. Since the valve in the test line was the only isolation valve in the affected penetration, none of the actions specified by TSs could be taken to isolate the penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required. Instead of taking the action required when a limiting condition for operation cannot be met, you considered the closed system boundary to mest the requirement of the operable isolation va!ve in the system. Even though actions were taken to ensure that this boundary remained intact, none of the additional actions required by TSs to isolate the penetration were taken. This violation of your TSs is of concern because the single isolation valve in tho system was open and inoperable and, based on your interpretation, could have remained in this condition with no time constraint. Therefore, this violation is classified individually at Severity Level lli in accordance with the Enforcement Policy.

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Pennsylvania Power end Light Company 4 With respect to the violation in Section ll,in accordance with the Enforcement Policy in effect at the time this violation occurred, the base civil penalty in the amount of $50,000 is considered for a Severity Level 111 violation. Since PP&L has been the subject of escalated enforcement action within the last 2 years', the NRC considered whether credit was warranted for /dentification and Corrective Action in accordance with the civil penalty i assessment process in Section VI.B.2 of the Enforcement Policy. Credit for identification is not warranted because the violation was identified by the NRC. Credit for corrective actions is warranted because your corrective actions were considered prompt and comprehensive once the violation was identified. These actions included, but were not limito to: (1) formalizing the processes for interpretation of TSs and altering boundaries of closed systems; (2)

providing training on the requirements forTSinterpretations and documentation of engineering guidance; and (3) reviews to ensure that no other informal guidance was being utilized to 1 support plant operations. l I

Therefore, to emphasize the importance of operating the facility in accordance with TSs, I l have been authorized, after consultation with the Director, Office of Enforcement, to issue a l civil penalty in the amount of $50,000. l l

Another violation of NRC requirements is described in Section 111 of the enclosed Notice and is classified individually at Severity LevelIV. That violation involves a nuclear plant operator j repositioning a breaker switch in a cabinet that was being controlled by a status control tag, without obtaining the permission of the individual or work group who required the tag and either Operations Shift Supervision or Operations Outage Group Supervision. This action .

resuited in the de-energization of heat tracing for an operable standby liquid control pump, for a petiod of 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />. At the conference, your staff indicated that the work permit indicated that there were discrepancies between the wiring diagrams and the actual wiring in the field.

During a subsequent telephone conversation on April 15,1997, Mr. J. Kenny of your staff informed Ms. T. Walker of my staff that the note indicating that there were wiring discrepancies was not added to the permit until after the event occurred. This information was considered in our assessment of this problem.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

' e.g., A Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $100,000 was issued to PP&L on February 9,1996, for a Severity Level III violation involving the discrimination of an employee who engaged in protected activities. (EA 95-250).

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Pennsylvania Power and Light Company 5 In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,its enclosures, and your response will be placed in the NRC Public Document Room (PDR). In addition, a summary of the conference that was conducted on March 21,1997, including the slides that were used during the conference and a tape recording of the conference, will be placed in the PDR.

Sincerely,

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Hu rt J. Miller Regional Administrator

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Docket Nos. 50-387: 50-388 License Nos. NPF-14; NPF-22 Enclosures:

1. Notice of Violation and Proposed imposition of Civil Penalties 2. Synopsis of 01 Investigation Report No. 1-96-046 l

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Pennsylvania Power and Light Company 6 cc w/encis:

G. Jones, Vice President - Nuclear Operations G. Kuczynski, Plant Manager J. Kenny, Supervisor, Nuclear Licensing G. Miller, Manager - Nuclear Engineering R. Wehry, Nuclear Licensing M. Urioste, Nuclear Services Manager, General Electric C. Lopes, Manager - Nuclear Security W. Burchill, Manager, Nuclear Safety Assessment H. Woodeshick, Special Office of the President J. Tilton, Ill, Allegheny Electric Cooperative, Inc.

Commonwealth of Pennsylvania i

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OE:Chron OE:EA DCS NUDOCS l DScrenci, PAO R1 NSheehan, PAO-Ri LTremper, OC Nuclear Safety Information Center (NSIC) ,

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