IR 05000387/1999005
| ML17165A029 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/29/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17165A028 | List: |
| References | |
| 50-387-99-05, 50-387-99-5, 50-388-99-05, 50-388-99-5, NUDOCS 9907090244 | |
| Download: ML17165A029 (59) | |
Text
June 7, 1999
SUBJECT:
'RC INTEGRATED INSPECTION REPORT 05000387/2000001 and 05000388/2000001
Dear Mr. Byram:
On February 12, 2000, the NRC completed an inspection at the Susquehanna Steam, Electric Station (SSES) Unit 18 2 reactor facilities. The enclosed'report covered routine activities by th'
resident inspectors and announced inspections of your licensed operator requaiification training program by Region I specialists.
The inspectors discussed the findings of these inspections with Mr. B. Shriver, Vice President Nuclear Operations, and other members of your staff, at an exit meeting at the completion of the inspections.
Overall, your staff safely operated the facilityduring this period. During this period we found additional examples in which your staff did not effectively use your corrective action system.
These examples were similar to the findings in our recent corrective action program inspection.
We understand that you have an ongoing. effort to strengthen the effectiveness of the program.
We willcontinue to closely monitor your progress.
In addition, based on the results of this. inspection, the NRC has determined that one violatioh of NRC requirements occurred.
The Severity Level IVviolation is being treated as a Non-Cited Violation (NCV), consistent with Section VII.B.1.a of the Enforcement Policy (November 9, 1999; (64'R 61142)). The NCV is described in the enclosed inspection report and involved fire watch duties for inoperable fire suppression systems.
Ifyou contest the violation or severity level of
. the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001 and the NRC Resident Inspector at the Susquehanna Steam Electric Station.
In accordance with 10CFR 2.790 ofthe NRC's "Rules of Practice," a copy of this letter, its enclosure(s),
and your response willbe placed in the NRC Public Document Room (PDR).
Mr. Robert A reply to this letter is not required, but should you have any'questions regarding this please contact me at 610-337-5322.
Sincerely,
/RA/
Curtis J. Cowgill, Chief Projects Branch 4 Division of Reactor Projects Docket Nos: 05000387, 05000388 License Nos: NPF-14, NPF-22
Enclosure:
Inspection Report 05000387/2000001, 05000388/2000001
REGION I==
Docket Nos:
License Nos:
05000387, 05000388 NPF-14, NPF-22 Report No.
05000387/2000001, 05000388/2000001 Licensee:
PPL, Inc.
2 North Ninth Street Allentown, PA 19101 Facility:
Susquehanna Steam Electric Station Location:
P.O. Box 35 Berwick, PA 18603-0035 Dates January 2, 2000 through February 12, 2000 Inspectors:
S. Hansell, Senior Resident Inspector J. Richmond, Resident Inspector A. Blarney, Resident Inspector P. Bonnett, Resident Inspector. - Limerick G. Smith, Senior Physical Security Insp'ector J. D'Antonio, Operations Engineer S. Dennis, Operations Engineer Approved by:
Curtis J. Cowgill, Chief Projects Branch 4 Division of Reactor Projects
EXECUTIVESUMMARY Susquehanna Steam Electric Station (SSES), Units 1 8 2 NRC Inspection Report 05000387/2000001, 05000388/2000001 This inspection included aspects of PPL's operations, maintenance, engineering and plant support at SSES.
The report covers a six-week period of routine resident inspection activities and announced inspections by regional specialists.
~Oeratione During this inspection period, the inspectors observed additional examples where a'roblem reoccurred because adequate corrective actions had not been implemented.
These missed opportunities challenged your staff and were similar to those identified in the recent corrective action inspection, report number 05000387, 05000388/1 999013.
Most notable examples were the unplanned hydrogen water chemistry isolations and the unplanned reactor protection system half-scrams.
(section 02.1).
The inspectors observed six simulator scenarios and PPL's evaluations.
During this testing cycle, the observed evaluations were thorough and identified performance weaknesses, which included two operating shift and two individual failures. The personnel involved with the failures were removed from licensed duties, as required by the training program, and will be remediated and retested satisfactorily prior to resuming licensed duties.
(section 05.1)
Maintenance We identified that a corrective maintenance activity was performed in conjunction with a surveillance activity without performing the required technical specifications action for an inoperable instrument.
This occurred because the Unit Supervisor did not fully understand the activity work scope.
This missed technical specification action is considered a violation of minor significance and was documented in PPL's corrective action program.
(section M1.2)
On January 3, 2000, PPL experienced a spurious reactor protection system half scram.
The corrective actions for two similar half scrams in November 1999 did not prevent the third half scram. Afterthe third half scram, a barrier was installed at the reactor protection system instrument racks in the Reactor Building. (section M4.1)
Executive Summary
>>8 The NRC identified that, over a 3 month period, PPL had not implemented a continuous fire watch when a fire.suppression system was removed from service to support modification activities. Once identified, PPL took immediate and effective corrective actions.
This Severity Level IVviolation is being treated as a Non-Cited Violation, consistent with section VII.B.1.a of the NRC Enforcement Policy. This violation was documented in PPL's corrective action program as condition report 230084.
(section F1.1)
In December 1999, PPL identified that a flashing light barricade had been used, within a locked high radiation area, to control local access to areas with dose rates greater than 1 rem/hour, without the approval of the Radiological Operations Supervisor.
The inspectors observed that PPL entered this item into the corrective actions program 3 weeks after the condition was identified.
In addition,.PPL's initial corrective actions were narrowly focused and did not identify that the same condition existed in Unit 2.
(section R1.1)
TABLEOF CONTENTS I.'Operations..
Conduct of Operations
.
01.1 Unit Operations and Operator Activities
.
Operational Status of Facilities and Equipment..
....
02.1 Overall Operational Status of Facilities and.Equipment Observations..
02.2 Operational Safety System Alignment
02.3 Unit 1 and Unit 2 Primary Containment Determined to be Inoperable Due
08 to Inadequate Hydrogen and Oxygen (H202) MonitorTesting..
02.4 Unplanned Hydrogen Water Chemistry (HWC) System Isolations Operator Training and Qualifications..
05.1 Licensed Operator Requalification Training Program Miscellaneous Operations Issues..
08.1 Licensee Event Report (LER) Review
2
3
5 II. Maintenance..........'...
..5 M1 Conduct ofMaintenance............................'....
~..
~
'. 5 M1.1 Surveillance and Pre-Planned Maintenance ActivityReview.........
M1.2 Control of Surveillance Test Activities....'.............
M4 Maintenance Staff Knowledge and Performance
.
.......
M4.1 Control ofWork in the Reactor Protection System Instrument Rack Area III. Engineering
.
E3 Engineering Procedures and Documentation
.
E3.'1 Review of 10 CFR 50.59 Safety Evaluations
..8
~
~
'
~
~
.....
~.. 8 IV. Plant Support
.
F1 Control of Fire Protection Activities..
F1.1 Fire Watch Duties for Inoperable Fire Suppression Systems
. '.
R1 Radiological Protection and Chemistry (RPLC) Controls..
R1.1 Radiological Controls for Locked High Radiation Areas......
S3 Security Program Plans
.
....9
9
.
11
.. 12-V. Management Meetings
.
X1 Exit Meeting Summary INSPECTION PROCEDURES USED
.
..13
~
.. 14 ITEMS OPENED, CLOSED, AND'DISCUSSED.
.. 14 LIST OF ACRONYMS USED
..15 IV
Re ort Details Summa of Plant Status Susquehanna Steam Electric Station (SSES) Unit 1 operated at 100% power throughout the inspection period with the following exceptions.
January 7 Power was reduced to 90% to perform a control rod pattern adjustment and then returned to 100% power on January 7, 2000.
January 14 Power was reduced to 75% to repair an oil leak on the "A" reactor feedwater pump. Power was restored to 100% on January 16, 2000.
January 29 Power was reduced to 75% to perform a control rod sequence exchange and control rod testing.
Power was restored to 100% on Januarjj 30, 2000.
February 11 Power was reduced to 80% to perform a control rod pattern adjustment and then returned to 100% power on January 12, 2000.
SSES Unit 2 operated at 100% power throughout the inspection period with one exception.
On
'ebruary 12, power was reduced to 80% for a control rod pattern adjustment and then returned to 100% power on February 13, 2000.
Conduct of Operations
'1.1 Unit 0 erations and 0 erator Activities (71707)
The inspectors determined routine operator activities were satisfactorily established, communicated and conservatively performed in accordance with SSES procedures with one noted exception.
During the removal of the Unit 2 "D" residual heat removal (RHR)
pump from service, the Unit 2 non licensed operator entered the Unit 1 Reactor Building and inadvertently removed the Unit 1 "D" RHR pump from service.
The operator immediately noted that he had removed the. wrong RHR pump from service and restored the Unit 1 "D" RHR pump.
PPL determined that verbal communications did not specify the unit and appropriate self checking was not performed.
PPL reviewed the appropriate method of self check with the individual involved in this event.
Other control room.
activities were well performed and control room logs accurately reflected plant activities.
Topicai headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topics.
Operational Status of Facilities and Equipment
'2.1 Overall 0 erational Status of Facilities and E ui ment Observations (71707, 40500)
During this inspection period, the inspectors observed additional examples where a.
problem reoccurred because corrective actions had not been implemented.
These examples were similar to th'ose iden/ified in the recent corrective action inspection, report number 05000387, 05000388/1 999013.
Most notable examples were the unplanned hydrogen water chemistry isolations (section 02.4) and unplanned reactor protection
'ystem half-scrams (section M4.1).
02.2 0 erational Safet S stem Ali nment (71707)
During routine plant tours, the proper alignment and operability of various safety systems, engineered safety features, and on-site power sources were verified. Partial walkdowns were performed for the containment hydrogen and oxygen monitors, standby liquid control system, Unit 2 safety related batteries, the "D" emergency diesel generator (EDG), Unit 1 and 2 reactor water cleanup systems, and the Unit 2 reactor instrumentation racks.
02.3 Unit 1 and Unit 2 Prima Containment Determined to be Ino erable Due to Inade uate H dro en and Ox en H202 MonitorTestin (71707, 93702)
On February 2, 2000, during an engineering review of a 1997 condition report, PPL determined that the H202 piping is considered an extension of containment and was not tested after maintenance was performed on the system.
PPL isolated the containment isolation valves for the H202 monitors to maintain primary coritainment integrity on both units and then entered TS 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation."
This TS required restoration of the H202 monitors within 7 days.
The monitors were tested and the TS exited within 7 days.
Un IannedH dro enWaterChemist HWC S stemlsolations(71707,40500)
PPL has experienced a number of HWC system automatic isolations that resulted in, reactor water chemistry transients.
In the two most recent cases, on December 2, 1999, and January 24, 2000, improper pressurization of oxygen storage tanks resulted in an automatic HWC system isolation. These isolations resulted in an increase in the reactor water conductivity. During both events, the Unit 1 operators entered the Technical Requirement Manual (TRM) requirement 3.4.1, "Reactor Coolant System Cliemistry,"
due to reactor water conductivity exceeding the action limitof 1.0 Ijmho/cm. PPL restored reactor water chemistry as r'equired by the TRM.
During review of the December 1999 condition report (CR 217997), PPL's management review team (MRT) assigned this CR to operations to evaluate ifinterim actions were required before completion of the condition report.
PPL determined that no interim actions were required and this condition report was transferred to PPL procurement to correct the condition.. On January 24, 2000, improper pressurization of oxygen storage
tanks resulted in an automatic HWC system isolation. The inspectors noted that PPL had not implemented corrective actions from a'HWC system automatic shutdown in early December 1999. This issue was documented in PPL condition reporting program in condition reports 217997 and 228858.
No violation of NRC requirements was noted.
051 Operator Training and Qualifications I
Licensed 0 eratorRe uglification Trainin Pro ram Ins ection Sco e 71001 The inspectors reviewed PPL's licensed operator requalification training program (LORT)
during the week of February 7-11, 2000. The following areas were evaluated with respect to 10CFR55.59 (and 55.53): LORT program content including facility operating history; written and operating test content; operating test administration; training program
'feedback effectiveness; and conformance with license conditions.
b.
Observations and Findin s LORT Pro ram Content PPL's training program material and plant operating history were reviewed to assess the facility's evaluation of plant and industry events for presentation in training. Additionally, the program mate'rial was reviewed to ensure it met PPL's procedural requirements.
The inspectors found. that PPL's procedural requirements r'egarding program content were met and that "just-in-time" training was given as appropriate for infrequent eVolutions or in response to plant and industry events.
Written and 0 eratin Test Content and Administration The written, job performance measures (JPM), and simulator examinations were'cceptable.
Overlap from week to week of the written examinations administered the prior year was reviewed, and was found to be acceptable.
The inspectors observed the administration of six simulator scenarios to three different operating shifts. Scenario critiques were detailed with individual and operating shift performance in each competency discussed.
During this testing cycle, PPL determined that two crews and two individual had failed to perform a critical task. The individuals were removed from licensed duties and will be remediated and satisfactorily retested prior to resuming licensed duties. The inspectors agreed with PPL management's
.'ssessments and corrective actions.
The inspectors observed 14 of the JPM examinations administered in the plant and simulator. The administration and overall results of all the JPM examinations identified no deficiencies.
I II
Use of Risk Insi hts'PL indicated that by training on all emergency operating procedures (EOP) actions during a two year requalification cycle, all significant operator actions identified in the probabilistic risk assessment (PRA) / individual plant evaluation (IPE) willbe addressed.
PPL's PRA identified significant operator actions.
The inspectors reviewed a sampling of these significant operator actions against the facilityJPM and simulator scenario banks and found no omissions.
'Remediation Practices The inspectors reviewed PPL's remediation practices and examples of evaluation and remediation for crews and individuals who had failed or achieved low grades in some aspect of requalification in the preceding two years.
In all cases, these individuals had been evaluated and remediated appropriately in accordance with PPL's program.
Use of Trainin Feedback The inspectors interviewed shift operations personnel and reviewed training material to assess PPL's response to trainee identified problems.
In interviews, operators cited specific examples of comments to which the training department had responded and believed the training department was responsive to their needs and comments.
Com Iiance with License Conditions A review of records and discussions with PPL personnel found that PPL was meeting the requirements of 10 CFR 55.53 for conditions of operator licenses.
10 CFR 55.21 for medical examinations of operators.
10 CFR 55.4S for licensed operator examination security.
Conclusions The inspectors determined that PPL evaluations of operator performance in the licensed operator requalification examination were thorough and identified performance weaknesses, which included two crew and two individual failures. The personnel involved with the failures were removed from licensed duties, as required by the training program, and willbe remediated and retested satisfactorily prior to resuming licensed duties.
PPL's training program included trainee feedback, analyzed plant and industry events, and provided "just-in-time" training for infrequent evolutions and met their procedural requirements.
Written and operating exam content and exam security practices were acceptable and in accordance with the PPL program requirements.
Remediation and re-examination practices were acceptable.
PPL monitored training program attendance and ensured missed training was made up in accordance with program requirements.
Risk insights in the training program, based on significant operator actions identified in the PRA, were included in the facilityJPM and simulator scenario banks.
PPL requirements including'medical exams, license activations, and license renewals were met and the licensee was found, on a sampling basis, to be meeting the regulatory requirements associated with the licensed operator training program.
Miscellaneous Operations Issues 08.1
'Licensee Event Re ort LER Review (37551, 40500, 61726, 71707, 92700)
The inspectors reviewed LERs LER 05000387/92-015-01,
Fire Barriers Not Surveilled and Not Installed per Specification LER 05000388/97-002-01 Loss of Both Loops of Containment Radiation Monitors LERs 05000388/93-008-00,
Condition Prohibited by Plant Technical Specification (TS) Sections 3.0.3 and 4.3.3,for the 93% Degraded Grid AuxiliaryLoad Shed SignaI These are old LERs that had not previously been reviewed.
No violations were identified and these LERs are not reflective of current PPL performance.
These LERs are closed.
Closed LER 05000387/99-006-00
"C" and "D" ESW Pumps Inoperable Greater Than 7 Days Due To Interaction With the
"A"and "B" Pumps..
This event was reviewed in NRC Inspection Report 050000387/1999010 and 050000388/1999010.
No additional violations or issues were identified. This LER is closed.
M1 Conduct of Maintenance M1.1 Surveillance and Pre-Planned Maintenance Activit Review a.
Ins ection Sco e (61726,62707,40500)
The inspectors observed and reviewed selected portions of pre-planned maintenance and surveillance activities, to determine whether the activities were conducted in accordance with NRC requirements and SSES procedures.
Observations and Findin s The inspectors observed portions of the following work activities and surveillances:
RTPM 102216 PCWO 105342 PCWO 200555 PCWO 211336 PCWO 105774 RTPM 10 I285 RTPM 202754 SP-00-0309 OP-ORF-004 PCWO 107633 PCWO 208910 PCWO 208912 PCWO 230306 SI-280-303 PCWO 103084'TPM 103130 -
'A'TPM 103274 -
'C'O-151-A02 Unit 1 "A"SLC Pump 3-year Overhaul Unit 1 "A"SLC Packing Leak Rework Riley Temperature Module Bench Testing Unit 2 "A"RHRSW Pump Discharge Check Valve Rework Dry Fuel Storage Canister No. 5 Processing HV-152-F015A MOVOverhaul Unit 1 "A"Core Spray Pump Protective Relay Calibrations Site Accountability Exercise Unit 2 Refuel Platform Pre-service Checkout LIS-B21-2N031A Test Connection Fitting Replacement TP-202-010, 2D630 Battery Replacement Temporary Installation of 15 Battery Cells for 2D630 Unit 2 HPCI Out-of-Service/Loss-of-Power Alarm Inv'estigation
.
. Unit 2 Wide Range Reactor Water Level Switch Calibrations RHR Pump Room Unit Cooler Heat Exchanger Cleaning and Inspection Core Spray Unit Cooler Cleaning and Inspection.
Core Spray Unit Cooler Cleaning and Inspection.
Quarterly Core Spray Flow Verification Division I In addition, selected portions of procedures and drawings associated with the maintenance and surveilla'nce activities were also reviewed and determined to be acceptable.
In general, maintenance personnel were knowledgeable of their assigned activities.
M1.2 Control of Surveillance Test Activities Ins ection Sco e (61726)
The inspectors observed selected portions of Instrument and Controls (I&C)surveillance tests to determine whether the activities were conducted in accordance with NRC requirements and SSES procedures.
Observations and Findin s On January 27, the inspectors observed that I&Ctechnicians performed a corrective maintenance activity on LIS-B21-2N031A while performing Sl-280-303 (quarterly calibration checks of LIS-B21-2N031A-D). The work instructions for the corrective maintenance work order (WO), WO 107633, required the instrument to be taken out of service "under the surveillance" for the replacement of test tap fittings. The Unit Supervisor (US) who authorized the WO was unaware that the'corrective maintenance activity required the instrument to be taken out of service.
The Unit Supervisor'ad been briefed on the scope of the work by the technicians, and mistakenly believed that the work would be performed with the instrument in-service, prior to the start of the surveillance.
The WO did not identify that the maintenance
.
activity required the instrument out of service (that information was contained in the work instructions). The inspectors noted that the work control center, and the station work schedule also did not identify this activity as requiring the instrument out of service.
Technical Specifications (TS) stated that when an instrument is placed in an inoperable status "solely for the performance of surveillances," entry into the TS required actions
'may be delayed for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The TS action, for an inoperable instrument, had not been, taken as required.
The corrective maintenance activity was short, relative to the duration of the surveillance activity, and was not safety significant. Therefore, this instance of a missed TS action is considered a violation of minor significance that is not subject to formal enforcement action. This violation was documented in PPL's corrective action program as Condition Report 231669.
Conclusions The inspectors identified that a corrective maintenance activity was performed in conjunction with a surveillance activity without performing the required Technical Specifications (TS) actions for an inoperable instrument.
This occurred because the Unit'upervisor did not fullyunderstand the activity work scope.
This missed TS action is considered a violation of minor significance and was documented in PPL's corrective action program.
Maintenance Staff Knowledge and Performance Control of Work in the Reactor Protection S stem Instrument Rack Area ( 27 7 717D7).
On January 3, 2000, Unit 2 received a reactor protection system (RPS) actuation (half-scram).
The half scram was similar to previous half scrams that occurred on November 5, and on November 17. The inspectors reviewed PPL's response to determine whether the work activities were conducted in accordance with NRC requirements and SSES procedures.
Observations and Findin s PPL determined that the two half scrams in November were caused by contract maintenance workers installing thermo-lag insulation on cables and erecting scaffolding for thermo-lag work in the Reactor Building. In both cases the workers inadvertently bumped sensitive equipment connected to the RPS scram instrument rack 1C004.
NRC Inspection Report.No. 05000387,388/1999011, documented the NRC's assessment of the two half scrams and concluded that PPL's corrective actions for the November 5 event were narrowly focused and did not prevent a 'similar event on November 17.
Plant management stated that operators were assigned to monitor the work in the area of the RPS instrument racks.
Nevertheless, a third spurious half scram occurred and was most probably caused by an instrument and control technician bumping the instrument rack. The inspectors determined that the limited response to the previous two half scrams contributed to the third challenge to the RPS system and the plant operators.
'fter the third RPS half scram PPL issued a condition report, No. 223671, to document the problem.
PPL added a sign and yellow rope in front of the instrument racks on both units to state the sensitivity of the equipment and provide a continuous reminder to all personnel.
In addition, on February 9, 2000, PPL issued a written description of the issue to all station personnel.
The letter noted that actions are in progress to provide a permanent modification around the RPS instrument racks.
The inspectors determined that PPL's response to the third half scram was appropriate.
No violation of NRC requirements was identified.
'onclusion On January 3, 2000, PPL experienced a spurious RPS half scram.
The corrective actions for two similar half scrams in November 1999 did not prevent the third half scram. Afterthe third half scram, a barrier was installed at the RPS instrument racks in the Reactor Building.
III. En ineerin
'E3 E3.1 Engineering Procedures and Documentation
. Review of 10 CFR 50.59 Safet Evaluations.
t3T 01)
The inspectors reviewed the PPL safety evaluation procedure and application related to a main steam line radiation moriitor (MSLRM)trip setpoint change package (SCP) No J97-2013, for the hydrogen water chemistry modification. The design change was evaluated and performed using Nuclear Department Administrative Procedure NDAP-QA-0726,."10CFR50.59 Evaluations."
Observations and Findin s PPL staff evaluated the MSLRM high radiation reactor protection system (RPS) trip setpoint change against screening criteria contained in NDAP-QA-0726. PPL staff determined that this change did not involve a change to the facilityas described in the safety analysis report (SAR) and did not require a written safety evaluation.
The MSLRM RPS trip setpoint was documented in the Technical Requirements Manual (TRM). The Susquehanna Safety Analysis Report section 16.3, represented the Unit 1 and 2 TRMs. Therefore, the inspectors determined that the change should have been
documented in a written 50.59 safety evaluation as required by procedure.
This error is similar to findings of your Nuclear Assessment Services.
The failure to document the MSLRM RPS setpoint change in a safety evaluation, as required by PPL procedures, constitutes a violation of minor significance that is not subject to formal enforcement action. The consequences of not using a safety evaluation to document the change were minimal because the MSLRM high radiation trip setpoint change was submitted to and approved by the NRC.
Conclusions The MSLRM RPS trip setpoint change was not documented in a safety evaluation as required by procedure.
The failure to document the setpoint change in a safety evaluation constitutes a violation of minor significance that is not subject to formal enforcement action. The consequences of not using a safety evaluation to document the change were minimal because the MSLRM high radiation trip setpoint change was submitted to and approved by the'NRC.
IV. Plant Su ort Control of Fire Protection Activities Fire Watch Duties for lno erable Fire Su ression S stems The inspectors reviewed fire watch duties for plant areas with inoperable fire suppression systems, to determine whether the activities were conducted in accordance with NRC requirements and SSES procedures.
Observations and Findin s On January 27, 2000, the inspectors observed a fire watch patrol and reviewed the fire watch log sheets for fire zones 2-5A and 2-5B (Unit 2 elevation 749). The fire watch log sheet identified the fire watch patrol as "continuous" to compensate for pre-action system PA-251 being disabled.
The fire watch explained his duties to the inspector, and stated that the "continuous" check on the log sheets meant that he was required to be in the area, but only had to perform a patrol once an hour. The inspector observed that the fire watch routinely sat out of visual sight of the affected fire zones.
During a routine patrol, the inspector obsenied that the fire watch did not perform an adequate inspection, in that he did not enter a high radiation area or vehfy the door temperature to that area, and did not utilize an available camera in the high radiation area to verify room conditions.
In addition, he did not enter an area where modification work was in-progress, located above the 4-KVswitchgear rooms.
Once identified, PPL took immediate and effective corrective actions."
The inspectors determined that fire suppression system PA-251 had been removed from service, on a daily basis, to support thermo-lag modification work, from October 1999 thru January 2000.
PCWO 204799 authorized disabling fire suppression for PA-251 and required a continuous fire watch, as a compensatory action. The inspectors reviewed the fire watch log sheets for the PCWO from October 11, 1999 to January 27, 2000, and determined that, although the log sheets were checked "continuous," hourly fire watch patrols were documented on the log sheets.
'
The inspectors noted that station procedure NDAP,-QA-0443, "Firewatch Procedure,"
required the fire watch log sheets to be reviewed by operations once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The procedure contained a note that for continuous fire watches the review can be made by phone, and in this case the reviews were made using that option.
In discussions with the inspector, the Unit Supervisors and an AuxiliaryUnit Supervisor (AUS) stated that there was no PPL management expectation for the AUS to review the logs. The inspector determined that by not having a visual observation, a problem associated with the
.
continuous firewatch was not detected for an extended period of time.
Technical Specification (TS) 5.4.1(d) required written procedures be established and implemented for the Fire Protection Program.
Technical Requirements Manual 3.7.3.2 required a continuous fire watch be provided during the periods when PA-251 was inoperable.
NDAP-QA-0441, "Fire Protection System Status Control," required a continuous fire watch when PA-251 could not perform its intended function. NDAP-QA-0443, "Fire Watch Procedure," stated that the duties of a continuous fire watch were to
.
perform an area tour every 15 minutes and document each 15 minute tour on the log sheet.
NDAP-QA-0443 also required the use of a camera to verify room conditions.
(e.g., no smoke or fire) for high radiation areas.
Contrary to this, on October 11, 1999 through January 27, 2000, fire watch tours were conducted hourly when pre-action system PA-251 was inoperable.
This Severity Level IVviolation is being treated as a Non-Cited Violation, consistent with section VII.B.1.a of the NRC Enforcement Policy.
This violation was documented in PPL's corrective action program as Condition Report 230084.
(NCV 50-388/00-01-01)
Conclusions The NRC identified that, over a 3 month period, PPL had not implemented a continuous fire watch when a fire suppression system was removed from service to support modification activities. Once identified, PPL took immediate and effective corrective actions.
This Severity Level IVviolation is being treated as a Non-Cited Violation, consistent with section VII.B.1.a of the NRC Enforcement Policy. This violation was documented in PPL's corrective action program as Condition Report 230084.
Radiological Protection and Chemistry (RP&C) Controls R1.1 Radiolo ical Controls for Locked Hi h Radiation Areas The inspectors performed field inspections of selected locked high radiation areas and reviewed PPL's administrative controls for personnel access control to areas with radiation dose rates greater than 1 rem/hour, where such areas are within a larger area
~ that is controlled as a high radiation area, to determine whether the activities were conducted in accordance with NRC requirements and SSES procedures.
"b Observations and Findin s In December 1999, PPL identified that a "flashing light and rope barricade" had been used to control personnel access to areas with dose rates greater than 1 rem/hour without the approval of the Radiological Operations Supervisor (ROS). The flashing light barricade had been installed in the Unit 1 reactor water cleanup (RWCU) room complex between the pump room and the heat exchanger and valve rooms.
The flashing light barricade had been approved, in writing by the ROS, to be used for a 7 day period in August 1999, but had not been removed at the end of the approved usage period. The flashing light barricade continued to be used until December, when a health physics (HP)
technician questioned the continued usage without written ROS approval, as required by SSES procedure.
On December 17, the flashing light barricade was removed.
This issue was documented and entered into the corrective action program on-January 7, 2000 (Condition Report 224987).
On January 11, 2000, the inspector performed a walkdown in the Unit 1 and Unit 2 RWCU room complexes, and observed that a flashing'light barricade was in-place in the Unit 2 RWCU room complex. The inspectors determined that the use of a flashing light barricade had been approved for use in Unit 2 for a 30 day period in July 1999, and had been used during maintenance activities from July 27 to August 17. By review of radiation area surveys and radiation work permits, the inspectors concluded that the flashing light barricade had not been used as a high radiation area barrier between August and January, but had been abandoned in-place in the room. PPL entered the failure to remove the flashing light barricade in their corrective action program on Condition Report 225712.
E
The inspectors observed several examples of poor radiological housekeeping conditions in the locked high radiation areas.
The NRC documented similar observations of poor housekeeping practices in locked high radiation areas during the last inspection period.
I The inspectors veriTied that flashing light barricades were documented on radiation area
~ surveys.
Based on technician interviews, the inspectors concluded that HP technicians provided adequate constant control point coverage and.maintained control of the locked high radiation area room complex door keys. The inspectors determined that HP technicians provided appropriate pre-job briefings of radiological conditions within the
RWCU room complex, including instructions to workers on the flashing light barricades.
Therefore, the inspectors concluded that the flashing light barricades, used in the RWCU room complexes, were adequate to prevent inadvertent personnel access to radiation areas greater than 1 rem/hour. Although the flashing light barricades were not promptly removed, as required by procedure, and in one case remained in use over a four month period without any additional review or approval, no reduction in worker radiological
~
safety occurred.
Technical Specification (TS) 5.7.2 allows the use of a flashing light barricade, in lieu of a physical barrier, locked door, or locked gate.
TS 5.4.1 requires written procedures be established and implemented for activities listed in Regulatory Guide 1.33 Appendix A.
SSES procedure NDAP-00-0626, "Radiologically Controlled Area Access and Radiation Permit System," requires the ROS approval on written evaluation checklist, with an expiration date, before'a flashing light barricade can be installed., On one occasion, PPL failed to remove the barricade and continued to use it during a 4 month period, without any further review or approval.
On a second occasion, PPL failed to remove the barricade at the end of its approved period. The failure to followwritten procedures for the removal of temporary barricades to high radiation areas constitutes a violation of minor significance that is not subject to formal enforcement action.
C.
Conclusion In December 1999, PPL identified that a flashing light barricade had been used, within a locked high radiation area, to control local access to areas with dose rates greater than 1 rem/hour, without the approval of the Radiological Operations Supervisor.
The inspectors observed that PPL entered this item into the corrective actions program 3 weeks after the condition was identified.
In addition, PPL's initial corrective actions were narrowly focused and did not identify that the same condition existed in Unit 2.
S3 Security Program Plans Ins ection Sco e 81700 The inspectors performed an in-office review of changes to the PPL Security Program Plans.
C Observations and Findin s An in-office review was conducted of changes to the Susquehanna Physical Security Plan, identified as Revisions NN and OO, submitted to the NRC on June 4, 1999 and August 24, 1999, respectively, in accordance with the provisions of 10 CFR 50.54(p).
I Conclusion Based on a limited review ofthe changes, as'described in'he plan revisions, no NRC approval of these changes is required, in accordance with 50.54(p). These changes will
~ y
be subject to future inspection to confirm that the changes, as implemented, have not decreased the overall effectiveness of the security plan.
V. Ilana ement Meetin s X1 Exit Meeting Summary Region I specialist presented the results of the licensed operator requalification training program inspection to members of PPL management at the conclusion of the inspection on February 11, 2000.
PPL acknowledged the findings presented.
The inspectors presented the inspection results to members of PPL management at the conclusion of the inspection period, on February 22, 2000.
PPL acknowledged the findings presented.
The inspectors asked PPL whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified.
IP 37551 IP 40500 IP 61726 IP 62700 IP 62707 IP 71707 IP 71750 IP 81700 IP 83750 IP 92700 IP 93702
INSPECTION PROCEDURES USED Onsite. Engineering Observations Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing
.
Problems Surveillance Observations
\\
Maintenance Program Implementation Maintenance Observations Plant Operations Plant Support Activities Physical Security Program for Power Reactors Occupational Radiation Exposure On Site Followup of Reports Prompt Onsite Response to Events at Operating Power Reactors
~Oened ITEMS OPENED, CLOSED, AND DISCUSSED NONE 50-388/00-01-01
~Udeted Closed NCV Fire Watch Duties for Inoperable Fire Suppression Systems
.NONE 50-387/92-015-01 / 02 50-388/93-008-00 / 01
. 50-388/97-002-01 50-.387/99-006-00 LER Fire Barriers Not Surveilled and Not Installed per Specification LER Condition Prohibited by Plant Technical Specification (TS)
Sections 3.0.3 and 4.3.3 for the 93% Degraded Grid AuxiliaryLoad Shed Signal LER Loss of Both Loops of Containment Radiation Monitors
.
LER
"C" and "D" ESW Pumps Inoperable Greater Than 7 Days Due To Interaction With the "A"and "B" Pumps.
A
LIST OF ACRONYNIS USED CFR CR CS DCP EAL EDG 0 F FSAR H202 HWC I&C IPE IR JPM LCO LER LLRT
'LPCI LORT MRT MSIV MSLRM NCV NDAP NOV, NRC NUMARC OD OSHA PAM PCO PCPR PPL PRA RCIC RHR ROS RPS RP&C RWCU scfh SCP SSCs SSES TS US Code of Federal Regulations Condition Report Core Spray Design Change Package Emergency Plan Action Level Emergency Diesel Generator Fahrenheit Final Safety Analysis Report Hydrogen pnd Oxygen (monitor)
Hydrogen Water Chemistry
'nstrument and Controls Individual Plant Evaluation
[NRC] Inspection Report Job Performance Measure Limiting Condition for Operation Licensee Event Report Local Leak Rate Test Low Pressure Coolant Injection Licensed Operator Requalification Program Management Review Team (PPL)
Main Steam Isolation Valve Main Steam Line Radiation Monitor Non-Cited Violation Nuclear Department Administrative Procedure fNRC] Notice of Violation Nuclear Regulatory Commission Nuclear Management and Resources Council Operability Determination Occupational Safety and Health Administration Post Accident Monitoring Plant Control Operator Plant Component Problem Report Pennsylvania Power and Light Company Probabilistic Risk Assessment Reactor Core Isolation Cooling Residual Heat Removal Radiological Operations Supervisor Reactor Piotection System Radiological. Protection and Chemistry Reactor Water Cleanup Standard Cubic Feet per Hour Setpoint Chan'ge Package Structures,-Systems, and Components Susquehanna Steam Electric Station Technical Specification Unit Supervisor