IR 05000387/2004006

IR 05000387-04-006, 05000388-04-006, on 01/26 - 02/13, 2004,Susquehanna Units 1 and 2. Biennial Baseline Inspection of the Identification and Resolution of Problems. One Finding Was Identified in the Area of Corrective Actions

ML040890030
Person / Time
Site:	Susquehanna
Issue date:	03/26/2004
From:	Ray Lorson NRC/RGN-I/DRS/PEB
To:	Shriver B Susquehanna
Welling B
References
IR-04-006
Download: ML040890030 (18)

Text

rch 26, 2004

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000387/2004006 AND 05000388/2004006

Dear Mr. Shriver:

On February 13, 2004, the US Nuclear Regulatory Commission (NRC) completed a team inspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed inspection report presents the results of that inspection, which was discussed with you and other members of your staff on February 13, 2004.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, the team concluded that in general, problems were properly identified, evaluated, and corrected. However, the teams findings supported the conclusion in the Annual Assessment Letter (NRC Inspection Report 50-387/2004-01) of the existence of a substantive cross cutting issue in the problem identification and resolution area.

There was one Green finding identified during this inspection associated with a weak evaluation and ineffective corrective actions for a lubricating oil foaming condition on the D core spray pump motors for both units. This condition led to the inoperability of these safety related pumps, thereby affecting the mitigating systems reactor safety cornerstone. This finding was determined to be a violation of NRC requirements. However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this finding as a non-cited violation, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny this non-cited violation, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Susquehanna Steam Electric Station.

In addition, some examples of minor problems were identified by the team that your staff entered into the corrective action program. Some of these items involved corrective actions

that were ineffectively tracked or had not been implemented. None of these minor deficiencies resulted in a challenge to system operability or reliability.

In accordance with 10CFR2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If you have any questions please contact me at 610-337-5282.

Sincerely,

/RA/

Raymond K. Lorson, Chief Performance Evaluation Branch Division of Reactor Safety Docket Nos. 50-387, 50-388 License Nos. NPF-14, NPF-22 Enclosure: Inspection Report 05000387/2004006, 05000388/2004006 w/Attachment: Supplemental Information

cc w/encl:

J. H. Miller, President - PPL Generation, LLC R. L. Anderson, Vice President - Nuclear Operations for PPL Susquehanna LLC R. A. Saccone, General Manager - Nuclear Engineering A. J. Wrape, III, General Manager, Nuclear Assurance T. L. Harpster, General Manager - Plant Support K. Roush, Manager, Nuclear Training G. F. Ruppert, Manager, Nuclear Operations R. D. Pagodin, Acting Manager, Station Engineering S. B. Kuhn, Acting Manager, Nuclear Maintenance D. Glassic, Manager, Work Management Director, Bureau of Radiation Protection R. E. Smith, Jr., Manager, Radiation Protection W. F. Smith, Jr., Manager, Corrective Action & Assessments D. F. Roth, Manager, Quality Assurance R. R. Sgarro, Manager, Nuclear Regulatory Affairs R. Ferentz, Manager - Nuclear Security W. E. Morrissey, Supervisor - Nuclear Regulatory Affairs M. H. Crowthers, Supervising Engineer H. D. Woodeshick, Special Office of the President B. A. Snapp, Esquire, Associate General Counsel, PPL Services Corporation R. W. Osborne, Allegheny Electric Cooperative, Inc.

Board of Supervisors, Salem Township J. Johnsrud, National Energy Committee Supervisor - Document Control Services Commonwealth of Pennsylvania (c/o R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Bureau of Radiation Protection)

Mr. Bryce

SUMMARY OF FINDINGS

IR 05000387/2004-006, 05000388/2004-006; 01/26/04 - 02/13/04; Susquehanna Steam

Electric Station, Units 1 and 2; biennial baseline inspection of the identification and resolution of problems. One finding was identified in the area of corrective actions.

This inspection was conducted by three regional inspectors and two resident inspectors. One finding of very low safety significance (Green) was identified during this inspection and was classified as a non-cited violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process (SDP).

Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 3, dated July 2000.

Identification and Resolution of Problems The team determined that, in general, Susquehanna Steam Electric Station properly identified, evaluated and corrected problems. However, the teams findings supported the conclusion in the Annual Assessment Letter (NRC Inspection Report 50-387/2004-01) of the existence of a substantive cross cutting issue in the problem identification and resolution area. The team identified one finding that indicated deficiencies with the evaluation of issues and the effectiveness of corrective actions. Susquehanna was generally effective at identifying problems and placing them in the corrective action program. These items were screened and prioritized using established criteria, but some potentially risk-significant issues were not fully evaluated. Corrective actions were implemented in a timely manner, but some actions were not completed in a comprehensive manner or were not tracked appropriately. The team determined that workers utilized the corrective action program to address problems.

Cornerstone: Mitigating Systems

C

Green.

A non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified because PPL did not adequately evaluate and promptly correct a condition adverse to quality associated with foaming of lubricating oil on the D core spray pump motors for both Units 1 and 2.

This issue is greater than minor because the D core spray pump was allowed to remain in service with a degraded condition that rendered it inoperable. Thus, the finding affected the Mitigating Systems cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. This finding is of very low safety significance, based on a Phase 2 significance determination process evaluation, because only one core spray train of the low pressure injection function on each unit was affected by this condition.

(Section 4OA2b)ii

REPORT DETAILS

4OA2 Problem Identification and Resolution

a.

Effectiveness of Problem Identification

(1) Inspection Scope The inspectors reviewed the procedures describing the corrective action program at PPLs Susquehanna Steam Electric Station. Susquehanna identifies problems by initiating action requests, which become condition reports (CRs) if they involve conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, or other significant issues. Condition reports are subsequently screened for operability, categorized by significance level (1 through 3) and evaluation type (e.g., root cause, apparent cause), and assigned to personnel for evaluation and resolution. The inspectors observed daily meetings in which licensee personnel screened incoming action requests and condition reports.

The inspectors reviewed items selected across the seven cornerstones of safety in the NRC Reactor Oversight Program to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The inspectors selected a sample of CRs that had been issued following the last NRC Problem Identification and Resolution inspection that was completed in February 2002. The inspectors also reviewed a sample of risk significant CRs that dated from January 1999 to January 2002. The inspectors reviewed licensee audits and self-assessments, including a recently issued audit of the corrective action program.

The effectiveness of the audits and assessments was evaluated by comparing the audit and assessment results against self-revealing and NRC-identified findings.

For selected risk significant systems, the inspectors reviewed applicable system health reports, work requests, engineering documents, plant log entries, and results from surveillance tests and maintenance tasks. For these selected systems, the inspectors also interviewed the cognizant station personnel and walked down portions of these systems.

The inspectors also reviewed operator logs, control room deficiencies, operator work-arounds, and procedures. In addition, plant staff and management were interviewed to determine their understanding of and involvement with the corrective action program.

The specific documents reviewed and referenced during the inspection are listed in the attachment to this report.

(2) Observations and Findings No findings of significance were identified.

The inspectors concluded that the station was generally effective at problem identification. The station staff identified problems and entered them into the corrective action program at the appropriate threshold. There were relatively few deficiencies identified by the team that had not been previously identified by PPL. Station staff promptly identified CRs, as appropriate, in response to inspection team identified deficiencies or issues. The CRs that were generated in response to the inspectors activities are listed in the attachment to this report.

Examples of minor deficiencies identified by the team included:

• The inspectors identified that when the Unit 1 high pressure coolant injection (HPCI) system was inoperable for 12 days (September 5-17, 2003) due to a problem with the full flow test valve, PPL did not write a condition report to evaluate missed opportunities to identify the problem earlier in the troubleshooting effort.

• The inspectors identified a difference between the timeliness of expected operator actions for an anticipated transient without scram (ATWS) event as described in the stations probabilistic risk assessment and that documented in emergency operating procedures.

The team found that self-assessments and audits were self-critical and generally consistent with the teams observations.

b. Prioritization and Evaluation of Issues

(1) Inspection Scope The inspectors reviewed the CRs listed in the attachment to this report to assess whether PPL adequately prioritized and evaluated problems. The team selected the CRs in areas to cover the seven cornerstones of safety in the NRC Reactor Oversight Program. The team also considered risk insights from the Susquehanna probabilistic risk assessment to focus the inspection sample. The reviews included the appropriateness of the assigned significance level, the timeliness of resolutions, and the scope and depth of the causal analysis. For significant conditions adverse to quality, the inspectors reviewed the licensees assessment of the extent of condition and the determination of corrective actions to preclude recurrence.

In addition, the inspectors selected a sample of CRs associated with previous NRC non-cited violations (NCVs) to determine whether the licensee evaluated and resolved problems associated with compliance to applicable regulatory requirements. The inspectors reviewed PPLs evaluation of industry operating experience information for applicability to Susquehanna. The inspectors also reviewed PPLs assessment of equipment operability, reportability requirements, and extent of condition.

(2) Observations and Findings The inspectors concluded that, in general, PPL screened and evaluated problems contained within the CR process at the correct significance level. The staff was generally effective at classifying and performing operability evaluations and reportability determinations for discrepant conditions. However, there were some instances in the screening and initial evaluation phases for CRs involving potentially risk-significant conditions, in which the station did not fully evaluate such factors as potential risk, uncertainty, and common cause implications. As a result, the priority and timeliness assigned to corrective actions were not always commensurate with the significance of the issues.

The inspectors noted the following examples of less-than-thorough evaluations. These were of minor significance with the exception of the first item below:

• Engineers did not fully evaluate the potential impact of oil foaming conditions on the D core spray pump motors. This oversight led to incomplete follow-up actions and deferral of corrective actions (discussed in the finding below).

• The evaluation of a configuration control problem affecting two risk significant, safety-related battery chargers was narrowly focused. The evaluation addressed the replacement of the components, but did not fully evaluate the impact of this degraded condition. The evaluation also did not attempt to determine why the wrong components were installed and whether the wrong components could be installed on other battery chargers in the future. (CR 458959)

• The evaluation of simulator fidelity issues after the April 2002 recirculation pump trip at low power did not fully evaluate the reasons why the simulator recirculation flow did not replicate the plant flow for low power/low flow conditions. Condition report 548260 was written to further evaluate the extent of condition with regard to simulator fidelity.

• Susquehannas evaluation of risk for technical issues related to control room habitability (CR 481499) was incomplete. Station personnel stated that the control room envelope integrity was not risk significant but did not address the operator protection function provided by the control room envelope.

The inspectors observed that the classification of action requests (ARs) was sometimes inconsistent. For example, two ARs that documented the venting of air from residual heat removal system piping were classified differently. Also, the levels of classification for these ARs did not assure that a required engineering analysis would be performed.

The inspectors reviewed several root cause evaluations and found that those written after a new procedure was issued in October 2002 were typically thorough. For example, the team noted that a root cause evaluation for smoking insulation on a feed pump in 2001 was narrowly focused and did not fully explore the extent of condition. In contrast, the root cause determination (CR 508017) for a fire in the vicinity of a feed pump in 2003 was detailed and self-critical. This evaluation appropriately identified missed opportunities from the first feed pump event that could have prevented the second event.

Oil Foaming on Core Spray Pump Motors

Introduction.

A Green, non-cited violation (NCV) was identified because PPL did not adequately evaluate and promptly correct a condition adverse to quality associated with foaming of lubricating oil on the D core spray pump motors for both Units 1& 2.

Description.

The inspectors identified that PPL did not fully evaluate and correct a condition that caused lubricating oil foaming on the Unit 1& 2 D core spray pump motors (1P206D/2P206D) during quarterly surveillance test runs in July 2003. During the surveillance tests, PPL identified oil foaming in the sightglasses of the two core spray pump motors. Station personnel noted that oil foaming of this severity, in the upper bearing reservoirs of these pump motors, had not been previously seen.

Operators initiated condition reports to document these deficient conditions.

Susquehannas corrective actions included the initiation of work orders to inspect the upper oil reservoirs and to change the oil before the next quarterly surveillance test runs. At that time, PPLs evaluation attributed the cause of the foaming to minor air entrainment. No further evaluation to understand the extent or severity of the oil foaming or potential common cause aspects was performed during the July 2003 time period.

Susquehanna then deferred the corrective actions to inspect the oil reservoirs and change the oil until January 2004 due to other station activities. On October 21 & 23, 2003, during quarterly surveillance testing, the D core spray pump motors for both units experienced more severe foaming that caused the sightglass oil levels to visibly drop below the minimum allowable level, rendering both pumps (i.e one pump at each unit)inoperable.

Following the October 2003 test events, PPL determined that the foaming condition was caused by contamination due to the mixing of oil with different characteristics. Prior to July 2003, PPL had replaced the type of oil used in the pump motors, but at that time did not fully understand the incompatibility between the existing and replacement oil. The inspectors reviewed selected corrective actions following the October 2003 test events and identified no concerns with those actions, including extent-of-condition assessments for other pump motors. The inspectors also requested engineering to provide an assessment of the time frame that the core spray pumps were unavailable. Engineering personnel stated that the pumps were likely unavailable from July to October 2003. No maintenance had been performed on these core spray pumps between the July and October surveillance runs. There had only been an addition of oil to the pumps after the July surveillance to replace oil lost due to sampling evolutions.

Analysis.

The inspectors determined that the performance deficiency was PPLs failure to correct a condition adverse to quality associated with oil foaming in the D core spray pump motor of each unit, following surveillance test runs in July 2003. Consequently, when the pumps were run in October 2003, the oil foaming condition caused PPL to declare the pumps inoperable. Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRCs regulatory function and was not the result of any willful violation of NRC requirements or PPL procedures. This issue is greater than minor because each units D core spray pump was allowed to remain in service with a degraded condition that rendered it inoperable. Thus, the finding affected the Mitigating Systems cornerstone objective.

This finding was assessed in accordance with NRC Manual Chapter 0609, Appendix A, 1, "Significance Determination Process (SDP) for Reactor Inspection Findings for At-Power Situations," and was determined to be of very low safety significance (Green) based on a Phase 2 analysis. The inspectors determined that this condition represented an actual loss of the low pressure injection (LPI) safety function of the B Train of the two train core spray system for greater than its Technical Specification Allowed Outage Time (7 days) because the D core spray pump, for each unit, was unavailable for three months. Thus, the inspectors entered Phase 2 of the SDP using the applicable worksheets in the "Risk-Informed Inspection Notebook for Susquehanna," Rev. 1. Given the inoperability of the B Train of core spray to perform its safety function, due to the oil foaming condition on the D core spray pump, the chance of a core spray system failure was assumed to increase from 1 in 1000 (a multi-train system) to 1 in 100 of (a single train system). The duration of the condition was assumed to be from July 2003 until October 2003 or greater than 30 days.

The dominant core damage sequences included the frequency of a transient with loss of power conversion system (TPCS) or a stuck open safety relief valve (SORV), each followed by the probability of: failure of the high pressure injection function (HPI),successful reactor depressurization, and failure of the low pressure injection function (LPI). The remaining mitigation capability for both sequences included the unaffected sources of low pressure injection (residual heat removal system and the A Train of the core spray system). The Phase 2 SDP analysis resulted in a finding that was of very low safety significance (Green) and below the risk at which external events or Large Early Release Frequency needed to be addressed.

Enforcement.

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, PPL failed to promptly correct a condition that caused lubricating oil foaming in the D core spray pump motor of each unit in July 2003. Consequently, during surveillance test runs in October 2003, the oil foaming condition rendered the pumps inoperable and unavailable. Because the violation is of very low safety significance and has been entered into the corrective action program (CR 546574), it is being treated as a non-cited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000387, 388/2004006-01)c. Effectiveness of Corrective Actions

(1) Inspection Scope The team reviewed the corrective actions associated with selected condition reports to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for repetitive problems to determine whether previous corrective actions were effective. The team also reviewed the licensees timeliness in implementing corrective actions and their effectiveness in precluding recurrence of significant conditions adverse to quality. Furthermore, the team assessed the backlog of corrective actions to determine if any, individually or collectively, represented an increased risk due to delays in implementation. The team also reviewed non-cited violations issued since the last inspection of the licensees corrective action program to determine if issues placed in the program had been properly evaluated and corrected.

(2) Observations and FIndings No findings of significance were identified.

Overall, the team concluded the licensee developed and implemented corrective actions that appeared reasonable to address the identified problems. Based on the sample reviewed, the team determined that, in general, corrective actions were completed in a timely manner. However, the team observed some instances in which corrective actions were not completed in a comprehensive manner or were not tracked appropriately.

Examples of minor issues in this area included:

• The inspectors identified that despite a detailed root cause evaluation for the September 2003 Unit 1'B reactor feed pump fire, one of the corrective actions was inadvertently omitted and not assigned a condition report action (CRA)number. (CR 544811)

• The station identified that some corrective actions for the NRCs Substantive Crosscutting Issue - Human Performance, documented in the 2002 Annual Assessment Letter, were not being tracked appropriately to assure completion.

(CR 543290)

• Corrective actions for an interruptible power supply problem had been delayed for several months, resulting in overdue preventive maintenance and potentially increasing the risk of an initiating event. (CR 425608)

The team also noted that the station had self-identified several examples of condition reports in which some corrective actions had not been completed. In response, the station had recently revised the corrective action program procedure to improve accountability for the effectiveness of corrective actions. However, because this was a recent change, the team could not yet assess the impact of this action.

The team noted some instances in which corrective actions for previous events did not prevent recurrence because the actions were ineffective, or the actions were delayed or postponed. Examples included:

• Delays in correcting hardware problems on high radiation doors (CR 347918),due to a low priority assigned to the repairs, was a causal factor for an unlocked high radiation area door found on September 3, 2003. (Minor issue - CR 506164)

• The deferral of corrective actions for the core spray pump motor oil foaming condition documented above led to the recurrence of foaming and unavailability of 2 core spray pumps. (Refer to finding in Section 4OA2b)

• Corrective actions for problems involved with lifting certain wiring configurations (termed daisy chain neutrals), during maintenance or modifications, did not prevent recurrence. As documented in CR 383654, the removal of a daisy chain neutral damaged a control room chiller. (Minor issue)

4OA6 Meetings, including Exit

The team presented the inspection results to Mr. Bryce Shriver, Senior Vice President and Chief Nuclear Officer, and other members of the Susquehanna staff on February 13, 2004. No proprietary information was retained by the team.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Anderson Vice President, Nuclear Operations

D. Coffin Senior Assessor, Quality Assurance

D. Glassic Manager, Work Control Systems

T. Harpster General Manager, Plant Support

T. Kirwin General Manager, Maintenance

J. Meter Regulatory Affairs Engineer

B. ORourke Regulatory Affairs Engineer

R. Pagodin Manager, Design Engineering

G. Ruppert Manager, Nuclear Operations

M. Rochester Employee Concerns Program Site Representative

D. Roth Manager, Quality Assurance

R. Saccone General Manager, Nuclear Engineering

B. Shriver Senior Vice President and Chief Nuclear Officer

W. Smith Manager, Corrective Actions and Assessment

A. Wrape General Manager, Nuclear Assurance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000387, 388/2004006-01 NCV Susquehanna did not promptly correct a condition adverse to quality associated with foaming of lubricating oil on the D core spray pump motors for both Units 1 and 2.

Closed

None