IR 05000387/1997006

Discusses Insp Repts 50-387/97-06 & 50-388/97-06 Conducted 970701 & 0816 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Re Failure to Establish Adequate Controls for Alignment of EDG Controls

ML20198M155
Person / Time
Site:	Susquehanna
Issue date:	01/09/1998
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Byram R PENNSYLVANIA POWER & LIGHT CO.
Shared Package
ML20198M158	List: IR 05000387/1997006 ML20198M168
References
50-387-97-06, 50-387-97-6, 50-388-97-06, 50-388-97-6, EA-97-472, NUDOCS 9801200005
Download: ML20198M155 (5)

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5m L NUCLEAR REGULATORY COMMISSION -  ;

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475 ALLENDALE ROAD-~

KING oF PRUSSIA, PENNSYLVANIA 19406-1415 : l w -

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January 9,1998  !

q EA 97-472

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Mr. Robert G. Byram' .

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- Senior Vice President Nuclear -

Pennsylvania Power & Light Company ,

2 North Ninth Street

-- Allantown, Pennsylvania 'i J101 --

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SUBJECT:' NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL

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PENALTY - $55,000 (NRC Inspection Report Nos._50-387/97-06 and 50 388/97-06)-

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Deer Mr. Byram: '

This refers to the inspection conducted betwoon July 1,1997, and August 16,1997, at the Susquehanna Steam Electric Station in Berwick, Pennsylvania, the f;ndings of which were j discussed with members of your staff during exit meetings on. August 26,1997i and

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September 11,1997. During the inspection,' apparent violations were identified related to the ~

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. misalignment of the ?A' emergency diesel generator (EDG), which was discovered by the NRC

. on July 11,1997. The inspection report addressing these issues was previously forwarded to you on October 27, 1997. On December 16, 1997, .a predecisional enforcement conference'(conference) was conducted with you and members of your staff, to discuss the

' _ violations, their causes, and yeur corrective actions.

" Based on the information developed during the inspection and the information provid ad during $

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, ,m, the conference, the NRC has determined that a violation of NRC requirements occurred. The

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violation involved your failure to establish adequate controls for ~the alignment of the  :

emergency diesel generator (EDG) woodward governor controls contrary to 10 CFH Part 50, Appendix B, Criterion ll, "Ciuality Assurance." The violation is cited in the enclosed Notice of  !

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Violation and Proposed imposition of Civil Penalty (Notice) and the circumstances surrounding It are described in detail in the subject inspection repor i

- Specificsily, the load limit' setting for the 'A' EDG governor was not adequately controlled in

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that the setting was not maintained in the required 100% load position. The load limit setting 1 t

was misaligned sometime between June 16,1997, when an opera'oility surveillance test was F  : satisfactorily performed and the setting was left in the 100%= load position, and July 11,-

1997, when the NRC found tho setting _at approximately 35%. Due to the misaiignment,

t ~during an acc; dent, the 'A'_ EDG would not have started within the required time and woul ...not have been able to supply the required load as designed. As a result of the misalignment, .

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the ?A' EDG was ihoperable for_ an indeterminate period of time between June 16,1997 and LJuly 11,1997!while' both units were operating. Your; subsequent investigation of the'

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misalignment.did not determine the proximate cause. . However, a work sequence error, 1

inadvertent human interaction, or tampering could not be eliminated as potential proximate i

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Pennsylvania Power & Light Compan ;

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p During the _ time that the 'A' EDG was inoperable, only three EDGs were operable? Technical

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. Specifications require four EDGs to be operable during plant operations.~ With the 'A' EDG -

inoperable,'the units did not have the capability to withstand a single failure of another EDG p following a design basis accident.- Additionally, there was the potential that emergency core

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cooling system (ECCS) motors fed from the 'A' EDG operating in this degraded condition could .

! have been damaged due to operation of the EDG at low frequency. The failure to adequately control the EDG load limit setting caused important safety-related equipment to be inoperable .

for an indeterminate period, thus degrading the plant's capability to respond to design basis events. Therefore, this violation has been categorized in accordance with the " General

- Statement of Policy and Procedure for NRJ Enforcement Actions" (Enforcement Policy),

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NUREG 1600f at Severity LevelIl Further, the NRC is concerned that you f ailed to implement effective controls for the alignment of the Woodward governor controls despite the. fact that multiple wants involving the functioning of Woodward governors have been identified in the industry between 1985 and ,

the present, including three at SSES Also, the NRC is concerned that your investigation of this event could not preclude tampering as a cause and that the investigations evealed at least two other recent instances of unexplained misalignment of out-of-service EL'Gs similar p to the misalignment of the 'A' EDG. It appears that personnel performance issues persist at g

SSES and there is an adverse trend in equipment status control event ;

e . in accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level 111 violation. Because your facility has been the subject of 4 vocalated enforcement actiot.s within the last 2 years,' the NRC cons!dered whether credit was warranted for /dentification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy." Credit was not warranted for identification because the violation was identified by the NRC. Additionally, you had prior opportunities to identify the need for additional controls on Woodward governors. Credit was

• ' -+ - warranted for corrective actions because your corrective actions were considered prompt and

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comprehendvs. Those actions, as described at the conference, included: 1) restoration of the 'A' EDG governor to the correct alignment and verification that the other EDGs and other safat', related equipment were properly aligned; 2) installation of protective covers en the EDG -

Woodward governor controls; 3) review and curtailment of access to vital areas; 4)

assessment of EDG maintenance work practices; 5) enhancements to security and operations procedures for responding to status control events; and 6) communications with employees concerning this event and origoing activities to improve industrial relations, e.g., A Notice of Violation and Proposed Imposition of Civil Penalties in the amount of $210,000 was issued to PP&L on June 20,1997,8a part, for a Severity level 11 problem involving the misalignment of an EDG breaker -

. and the documentation of activities that had not actually beca performed (EA 9G270).

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Pennsylvants Power & Light Company 3

- Therefore, to emphasize the importance of controlling the status of safety related equipment and of promps identification of violations, and in recognition of your previous escalated enforcement actions, I have been_ authorized, t.fter consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalty (Notice) in the base amount of $55,000 for the Severity Level ill violatio You are required to respond to this letter and should fellow the instructions specified in the enclosed Notice when prepa.ing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.790 of the NRC's ' Rules of Practice," a copy of this letter,its

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enclosure, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely, f

Hu Sert J. Miller W

Regional Administrator i Docket Nos. 50 387; 50-388 License Nos. NPF-14; NPF-22 Er closure: Notice of Violation and Proposed imposition of Civil Penalty

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t Pennsylvania Power & Light Company' -4 7 .

.cc w/en$1: s

- G. Jones, Vice President - Nuclear Operations ,

. G. Kuczynski, General Manager - ,

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J.' Kenny, Supervisor, Nuclear Licens!ng

. G. Miller, General Manager - Nuclear Engineering

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i R. Wehry, Nuclear Licensing ..

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M. Urioste, Nuclear Services Manager,- General Electric C. Lopes, Manager, Nuclear Security' .

A Male, Manager, Nuclear Assessment Services-

- li. Woodeshick, Special Off;2e of the President .

'J Tilton Ill Allt,gheny Electric Cooperative Inc

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Commonwealth of Pennsylvania

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I DISTRIBUTION:

PUBLIC

' SEC CA-LCallan, EDO '

AThadani, DEDO

' JLieberman, OE HMiller, Rl FDavis, OGC SCollins, NRR RZimmerman, NRR

Enforcement Coordinators Rl, Rll, Rill, RIV BBeecher,' GPA/PA - '

GCaputo, 01 ,

DBangart, OSP Hbell, OlG -

TManin, AEOD

OE:Chron OE:EA DCS ,

NUDOCS DScrencl, PAO-RI NBheehan, PAO-RI LTromper, OC -

n Nuclear Safety information Center (NS!r.)

NP.C Resident inspector - Snsquehanni

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