IR 05000387/2011004

IR 05000387-11-004, 05000388-11-004; on 07-01-11 - 9-30-11; Susquehanna Steam Electric Station - NRC Integrated Inspection Report and Notice of Violation

ML113120409
Person / Time
Site:	Susquehanna
Issue date:	11/08/2011
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
Krohn P
References
EA-11-244 IR-11-004
Download: ML113120409 (57)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION _ NRC INTEGRATED I N SpECTt ON REPORT 05000387/201 1 004 AN D 050003881201 1 004 AND NOTICE OF VIOLATION

Dear Mr. Rausch:

On September 30, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed integrated inspection report presents the inspection results, which were discussed on October 13,2011, with you and other members of your staff.

This inspection examined activities completed under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the NRC has determined that a Severity Level (SL) lV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy included on the NRC's Web site at www.nrc.qov. Select About NRC, How We Regulate, Enforcement, then Enforcement Policy.

The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The inspectors identified a SL lV Violation of 10 CFR 55.25, "lncapacitation Because of Disability or lllness," for PPL failing to notify the NRC of a known permanent change in medical status of a licensed operator, and 10 CFR 55.3, "License Requirements," for failing to ensure that an individual license holder, in the capacity of a reactor operator (RO), met the medical prerequisites prior to performing licensed operator duties. Specifically, biennial medical examinations conducted on April 16, 2009 and April 19,2011 identified that an RO did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." However, PPL did not inform the NRC or request an amended license for the RO until August 2011. Therefore, the RO performed licensed duties without an NRC-approved, amended license from April 2009 through August 2011, until the NRC identified this issue. Upon notification PPL submitted, and the NRC approved, a conditional license to address the disqualifying medical condition. See Section 1R1 1 of the attached report for additional details. Violations of operator licensing requirements are of particular concern to the NRC, and may be considered for escalated enforcement under certain circumstances. However, in this case, the NRC has classified this violation at SL lV, after considering that the operator was wearing corrective lenses since the first failed test in April 2009 and that an amended license for a condition of "Corrected Lenses Required" likely would have been approved. Thus, the basis for the RO's license was not impacted since his actual corrected vision while performing his duties was within the standards.

This violation is being cited in the enclosed Notice in accordance with NRC Enforcement Manual Section 3.1.2, because the violation was determined to be repetitive of NRC Enforcement Action (EA)09-248 dated January 28,2010, an SL lll Notice of Violation related to a Senior Reactor Operator (SRO) standing watch without meeting a medical qualification requirement. The medical conditions in both the former and current cases were similar; therefore, it was reasonable that an adequate extent of condition review for EA-09-248 should have identified the additional discrepancy.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. Please discuss the corrective actions taken to restore compliance, corrective actions to preclude recurrence of similar issues in the future, and a discussion why actions for EA-09-248 were not effective in identifying this issue. Also, if you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

This report also documents two NRC-identified findings and one self-revealing finding, all of very low safety significance (Green), and one NRC-identified SL lV NCV. Two of these findings were determined to involve violations of NRC requirements. Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report.

However, because of the very low safety significance and because they are entered into your correction action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC's Enforcement Policy. lf you contest any NCV in this report, 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, D.C. 20555-0001;with copies to the RegionalAdministrator Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Susquehanna Steam Electric Station.

In addition, if you disagree with the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the RegionalAdministrator, Region l, and the NRC Resident lnspector at the Susquehanna Steam Electric Station.

ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.qov/readino-rm/adams.html (the Public Electronic Reading Room). To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction. lf personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that deletes such information. lf you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.9., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). lf safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

tuL-4u Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects DocketNos. 50-387;50-388 License Nos. NPF-14, NPF-22

Enclosures:

1. Notice of Violation 2. lnspection Report 05000387/2011004 and 05000388/201 1004 wl Attachment: Supplemental Information Mencl: Distribution via ListServ copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. lf you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.9., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). lf safeguards information is necessary to provide an a

REGION I Docket Nos: 50-387, 50-388 License Nos: NPF-14, NPF-22 Report No: 05000387/201 1 004 and 050003881 201 1 004 Licensee: PPL Susquehanna, LLC Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Benruick, Pennsylvania Dates: July 1 ,2011through September 30,2011 Inspectors: P. Finney, Senior Resident lnspector J. Greives, Resident Inspector A. Rosebrook, Senior Project Engineer S. Pindale, Senior Reactor Inspector E. Burket, Reactor Inspector M. Orr, Reactor Inspector Approved By: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure 2

TABLE OF CONTENTS 1R01 Adverse Weather Protection ...............7 1R04 Equipment Alignment. ........8 1 R05 Fire Protection........... ....,...8 1R06 Flood Protection Measures .................9 1R07 Heat Sink Performance............... ........9 1R11 Licensed Operator Requalification Program ............. ..........10 1R12 Maintenance Effectiveness ........ ......13 1R13 Maintenance Risk Assessments and Emergent Work Control ............13 1R15 Operability Evaluations and Functionality Assessments .....................17 1R18 Plant Modifications.... .......19 1R19 Post-Maintenance Testing (PMT) ...............,.....20 1 R20 Refueling and Other Outage Activities ........,.....21 1R22 Surveillance Testing .,....-21 1EP6 Drill Evaluation .......... ......24 4041 Performance lndicator (Pl) Verification ........ .....25 4C.42 fdentification and Resolution of Problems .............. ............27 4043 Event Followup ...............30 4045 Other Activities ..............,.31 4046 Meetings, lncluding Exit........... .........34 4QA7 Licensee-ldentified Violations ...........34 ATTACHMENT: SUPPLEMENTAL INFORMATION .............35 SUPPLEMENTARY INFORMATION.......,.. .,...,..A-1 KEY POTNTS OF CONTACT ............. A-1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED .... A-1 LIST OF DOCUMENTS REVIEWED ,.......... ..,....A-2 LtsT oF ACRONYMS............... ....... A-13 Enclosure 2

SUMMARY OF FINDINGS

lR 05000387 1201 1004, 05000388i20 1 1 A04; 07 101 1201 1 - 091301201 1 ; Susquehanna Steam

Electric Station, Units 1 and 2; Licensed Operator Requalification Program, Maintenance Risk Assessments and Emergent Work Control, Operability Evaluations and Functionality Assessments, surveillance Testing, Performance lndicator Verification.

This report covered a three-month period of inspection by resident inspectors and announced inspections by regional inspectors. One Severity Level (SL) lV Notice of Violation (NOV), two Green non-cited violations (NCV), one SL lV NCV, and one Green finding were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

. Severitv Level lV. The inspectors identified a SL lV NOV of 10 CFR 55.25, "lncapacitation Because of Disability or lllness," for PPL failing to notify the NRC of a known permanent change in medical status of a licensed operator, and 10 CFR 55.3, "License Requirements," for failing to ensure that an individual license holder, in the capacity of a reactor operator (RO), met the medical prerequisites prior to performing licensed operator duties.

Specifically, an RO failed a medical examination in both 2009 and 2011 which identified a disqualifying condition and performed licensed duties without an NRC-approved, amended license. He performed the function of an RO while on watch from April 2009 through August 2011, when the NRC identified this issue. However, the operator did wear corrective lenses while standing watch since April 2009. Upon notification PPL submitted, and the NRC approved, a conditional license to address the disqualifying medical condition. PPL entered this issue into their corrective action program (CAP) as condition report (CR)1 4501 38.

The inspectors determined that PPL's failure to notify the NRC of a known permanent change in a licensed operator's medical status and request an amended license in order to assume licensed duties was a performance deficiency. This finding was evaluated using the traditional enforcement process because the issue had the potential to impact or impede the regulatory process. Specifically, there was a potentialfor license termination or the issuance of a conditional license to accommodate for a medical condition. The RO performed licensed duties from April 2009 through August 2011 with a disqualifying condition that required his license to be amended. Using the NRC Enforcement Policy, this violation was characterized at SL lV, in accordance with Section 6.4.

This violation is being cited in the enclosed Notice in accordance with NRC Enforcement Manual Section 3.1.2, because the violation was determined to be repetitive of NRC Enforcement Action (EA)09-248 dated January 28,2Q1Q, an SLlll Notice of Violation related to a Senior Reactor Operator (SRO) standing watch without meeting a medical qualification requirement. The medical conditions in both the former and current cases were similar:

therefore, it was reasonable that an adequate extent of condition review for EA-09-24g should have identified the additional discrepancy.

This significance of the associated performance deficiency was screened against the Reactor oversight Process (Rop) per the guidance of tMC 0612, Appendix B. No associated ROP finding was identified and no cross-cutting aspect was assigned. (Section 1R1 1)o Green' An NRC-identified Green NCV of 10 CFR 50, Appendix B, Criterion V, "lnstructions,

Procedures, and Drawings," was identified when PPL did not perform an adequate operability assessment in accordance with procedure NDAP-QA-0703, "Operability Assessments and Requests for Enforcement Discretion," Revision 15, to ensure the continued operability of the 'M' safety relief valve (SRV). Upon identification, operators initiated an Operability Follow-up Request which ultimately resulted in the'M' SRV being declared inoperable.

The finding was more than minor because it was similar to example 3.j in IMC 0612 Appendix E, "Examples of Minor lssues" in that an error in a calculation is not minor if the error results in reasonable doubt on the operability of the system or component. In this case, the error made in evaluating the operability of the SRV resulted in reasonable doubt of operability. The finding was evaluated for significance using IMC 0609, Attachment 4,

"Phase 1 - lnitial Screening and Characterization of Findingl." Since the finding was not a design or qualification deficiency, did not result in a loss of system safety function, did not result in loss of a single train for greater than its allowed outage time, and was not potentially risk significant due to external events, the finding was determined to be of very low safety significance (Green). This finding was related to the cross-cutting area of Problem ldentification and Resolution (Pl&R) - CAP because PPL did not thbroughly evaluate problems such that the resolutions address the causes and extent of co-nditions, to include properly classifying, prioritizing and evaluating for operability. Specifically, ppl failed to consider the effect that seat leakage had on the lift point oftne ;M' SRV bnd failed to correctly assess the sRV for operabitity. [p.1 .(c)] (section 1R15)

Cornerstone: Barrier Integrity

o

Green.

A self-revealing Green finding of NDAP-QA-0340, "Protected Equipment program," Revision 10, was identified when the 2A fuel pool cooling (FPC) pump tripped during maintenance on the 2AFPC heat exchanger (HX). The pump and HX had been deiignated as protected equipment. The unavailability and loss of pump functionality resulted in in off-normal procedure entry. PPL entered this issue into their CAP as CR 1438904 and completed an apparent cause evaluation (ACE).

The finding was more than minor due to its adverse effect on the Barrier lntegrity cornerstone attribute of system, structure, and component performance to maintain spent fuel pool cooling (SFPC) system functionality and its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding was screened in accordance with IMC 0609 Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and was determined to be of very low safety significance, Green, due to its not being associated with the loss of cooling to the spent fuel pool (SFP) that would have precluded restoration prior to boiling, a fuel handling error, or loss of SFP inventory. The finding had a cross-cutting aspect in the area of Human Performance, Work Practices, in that PPL did not use human error prevention techniques commensurate with the risk of the assigned task nor did personnel stop work in the face of uncertainty. [H.4.(a)] (Section 1R13)

Green.

An NRC-identified Green NCV of Susquehanna Unit 1 and 2 TS 5,4.1,

"Procedures," was identified for an inadequate surveillance procedure for implementing Technical Specifications (TS) Surveillance Requirement (SR) 3.6.4.1.4 and 3.6.4.1.5.

Specifically, the implementing procedure was revised allowing the SR to be missed and subsequently required entry into SR 3.0.3. PPL entered this issue in their CAP as CR 1460362.

The finding is more than minor because it was similar to example 3.d in IMC 0612 Appendix E, "Examples of Minor lssues" in that the failure to implement the TS SR as required is not minor if the surveillance had not been conducted. In this case, the SR had not been completed for all configurations of secondary containment and required both Unit 1 and Unit to enter SR 3.0.3 for a missed surveillance. Additionally, it is associated with the procedure quality attribute to maintain functionality of containment and the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the inadequate surveillance procedure resulted in missed surveillances, SRs 3.6.4.1.4 and 3.6.4.1 .5 and entry into SR 3.0.3 for missed surveillances, The finding was evaluated for significance using IMC 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings." Since the finding only represented a degradation of the radiological barrier function provided for the reactor building (RB) (i.e. secondary containment), the finding was determined to be of very low safety significance (Green). This finding is related to the cross-cutting arca of Human Performance - Resources because PPL did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety. Specifically, the procedures did not ensure surveillance requirements (SRs) required by TS 3.6.4.1 were implemented. H.2(c)

(Section 1R22\

Severitv Level lV. An NRC-identified SL-IV NCV of 10 CFR 50.9(a), "Completeness and Accuracy of Information," occurred when PPL inaccurately reported reactor coolant system (RCS) leakage values under the RCS leakage performance indicator (Pl)for both units since inception of the Pl in April 2000. PPL entered the issue in their CAP as CR 1441824, completed an apparent cause evaluation, and plans to revise Pl data previously submitted.

No performance indicator crossed the GreenMhite threshold once the values were updated.

Because violations of 10 CFR 50.9 are considered to potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process. The inspectors concluded that PPL had reasonable opportunity to foresee and correct the inaccurate information prior to the information being submitted to the NRC. PPL's failure to identify and correct the recurring errors over this period of time indicated the existence of a programmatic issue. Additionally, verification of the corrected Pl data in a subsequent inspection will have more than an insignificant regulatory impact on the NRC. Accordingly, although none of the affected Pls in this case would have crossed the threshold, the NRC has determined that the violation is of more than minor significance. The finding was not considered to be more significant since had this information been accurately reported, it would not have likely caused the NRC to reconsider a regulatory position or undertake a substantial further inquiry. The significance of the associated performance deficiency was screened against the ROP per the guidance of Manual Chapter 0612, Appendix B. No associated ROP finding was identified and no cross-cutting aspect was assigned. (Section 4OA1)

Other Findings

Violations of very low safety significance or severity level lV, identified by PPL, were reviewed by the inspectors. Corrective actions taken or planned by PPL have been entered into PPL's CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summarv of Plant Status Susquehanna Steam Electric Station (SSES) Unit 1 began the inspection period at 92 percent rated thermal power (RTP) in a control rod pattern adjustment and power ascension from a reactor startup. The unit reached 100 percent RTP on July 1. On July 6, the unit was reduced to 72 percent RTP in response to a condensate conductivity excursion. On July 22, the unit was reduced to 85 percent RTP due to condenser backpressure associated with a hot weather limit.

On August 23, a seismic event registered in the area and as a result, Unit 1 entered a Notice of Unusual Event at2:05 p.m. and exited it at 9:10 p.m. On September 9, the unit was reduced to 69 percent RTP for a control rod sequence exchange. Unit 1 operated at full RTP for the remainder of the inspection period.

Unit 2 began the inspection period at 16 percent RTP in a power ascension. Unit 2 reached its former licensed power level of 94.4 percent RTP on July 15. The unit reached 97

.5 percent and

its extended power uprate (EPU) licensed power limit of 100 percent RTP on July 17 and26, respectively. The unit reduced power to 63 percent RTP on August 13 for a control rod pattern adjustment and sequence exchange. On August 19, the Unit 2 reactor tripped from a main turbine trip that was actuated during integrated control system (lCS) leveltesting. A reactor startup was commenced on August 21. On August 23, a seismic event registered in the area and as a result, Unit 2 entered a Notice of Unusual Event at 2:05 p.m. and exited it at 9:10 p.m.

100 percent RTP was attained on August 26. Unit 2 operated at full RTP for the remainder of the inspection period.

Note: The licensed RTP for both units is 3952 megawatts thermal. The authorized power level for both units is 100 percent of the EPU licensed power limit. For the purposes of this report and the remainder of current operating cycle, the authorized power level for Unit 2 is 100 percent of the EPU licensed power limit.

1. REACTORSAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrity

1R01 Adverse Weather Protection

Readiness for lmminent Adverse Weather Conditions (71111.01 - 1 sample)

a. Inspection Scope

During the weeks of August 29 and September 5,2011, the inspectors evaluated implementation of imminent weather preparation to include procedures and compensatory measures as they relate to high winds and heavy rain. The inspectors toured susceptible plant areas and reviewed associated issues in the CAP for appropriate evaluation and resolution. Documents reviewed for each section of this inspection report are listed in the Attachment

.

Common. station readiness for severe weather associated with Hurricane lrene and Tropical Storm Lee

b. Findinqs No findings were identified.

1R04 EquipmentAlionment

.1 Partial Walkdown (71111.04Q

- 3 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

r Unit 1, Division ll residual heat removal (RHR) during Division I RHR work window o Unit 1,'1A' Standby Liquid Control (SBLC) train during 1B SBLC train outage

.

Common, 'A' CS chiller while 'B' CS chiller out of service (OOS)

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether (Licensee) staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findinqs No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that PPL controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

.

Unit 1, RB 749'(Fire Zones l-sA-N, 1-5A-S, 1-sAW, 1-58, 1-5E, 1-5G, 1-5H)

.

Unit 2, access and remote shutdown panel areas (Fire Zones 2-2A,2-2C)

.

Common, A-D DG bays (Fire Zones 0-41A,0-418, 0-41C, 0-41D)

.

Common, main control room (Fire Zones 0-26H, 0-26N, 0-26P)

.

Common, circulating water pump house basement (Fire Zones 0-71A and 0-71B)b. Findinqs No findings were identified.

1R06 Flood Protection Measures

.1 Annual Review of Cables Located in Underqround Bunkers/Manholes (71111.06 -

1 sample)a. lnsoection Scope The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could disable risk-significant equipment. The inspectors performed walkdowns of risk-significant areas to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged.

The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed. The following area was reviewed:

.

Common, underground manhole inspection (MH22, MH23, MH27, and MH28)b. Findinos No findings were identified.

1R07 Heat Sink Performance

Heat Sink Annual Review (71111.07A - 1 sample)

a. Inspection Scope

The inspectors reviewed the Unit 2, 'A' FPC HX to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified (Licensee's) commitments to NRC Generic Letter 89-13.

The inspectors reviewed documents associated with maintenance for the HX to ensure the performance capability for the HX was consistent with design assumptions. The inspectors reviewed the results of previous inspections of the Unit 2, 'A' FPC HX and similar heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that PPL initiated appropriate corrective actions for

identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.

b.

Findinqs No findings of significance were identified.

1R1 1 Licensed Operator Requalification Proqram

.1 1Q - 1 sample)

a.

lnspection Scope The inspectors observed licensed operator simulator training on September 13, 2011, which included a stuck radiation source, anticipated transient without scram (ATWS),and an unisolable reactor core isolation cooling (RCIC) steam leak. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by the shift technical advisor.

Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

Additionally, the inspectors reviewed an instance in August 2011 where an NRC operator licensing assistant identified an issue with the medical qualification records for an RO during a review of the RO's License Renewal Application form. The inspectors reviewed the medical certification forms, reviewed PPL's formal correspondence with the NRC upon discovery of the issue, PPL's conditional license request submittals, and reviewed PPL's corrective actions for a similar NOV issued by the NRC on January 28, 2010 (EA-09-248). Documents reviewed are listed in the Attachment.

b.

Findinqs lntroduction. The inspectors identified a SL lV NOV of 10 CFR 55.25, "lncapacitation Because of Disability or lllness," for PPL failing to notify the NRC of a known permanent change in medical status of a licensed operator, and 10 CFR 55'3, "License Requirements," for failing to ensure that an individual license holder, in the capacity of a reactor operator (RO), met the medical prerequisites prior to performing licensed operator duties. Specifically, an RO failed a medical examination in both 2009 and 2011 which identified a disqualifying condition and performed licensed duties without an NRC-approved, amended license.

Discussion. On August 9, 2011, during a Licensed Operator License Renewal Application review, an NRC Operator Licensing Assistant identified that an RO's current license had a condition of "shall take medication." The application included a Form 396, Certification of Medical Examination by Facility Licensee, dated May 9, 2011. The form recommended the conditions of "shall take medication" and "corrective lenses must be worn" based on a documented biennial medical examination on April 19,2011. This was

a change from the previous Form 396 submittal, so the box for "restriction change from previous submittal" should have been checked. The Operator Licensing Assistant also identified that since this was a change that PPL was aware of on May 9,2011, they had missed the requirement to notify the NRC by June 8,2011, 30 days from PPL becoming aware of this permanent change in medical condition.

The Operator Licensing Assistant informed PPL of the issue and requested the supporting medical documentation for processing the requested license condition changes. PPL discovered that a medical examination conducted on April 16, 2009, first identified that the RO's vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." Specifically, the RO did not meet the standard for uncorrected near vision. The medical review for this examination was completed on May 12,2009. On April 19,2011, the RO's biennial medical examination confirmed the same results. The medical review for this examination had been completed on May 9, 2011. PPL had been aware of this condition since 2009, but did not report this change to the NRC or request a change to the RO's license.

The RO wore corrective lenses upon his return to licensed duties in April 2009, which brought his corrected near vision into compliance with the requirements of ANSI/ANS 3.4-1983. He stood watch on both units and participated in refuelfloor operations with no evidence of impacted performance. Had PPL submitted a request for a conditional license, a condition would likely have been added to require corrective lenses. Following the identification of this issue in August 2011, a conditional license was requested on August 16,2011, and the NRC issued an amended license adding the condition "corrective lenses required" on September 9, 2011. PPL entered this issue into their CAP as CR 1451039 and is conducting an evaluation. Interim corrective actions included a review of allforms submitted from November 2009 to August 2011 in order to verify that all medical changes documented and/or submitted to the NRC were correct.

No discrepancies were found from this interim action.

10 CFR 55.3 requires a person to be authorized by a Commission-issued license to perform the function of an operator. 10 CFR 55.25 requires the facility licensee to notify the Commission within 30 days if a licensee develops a permanent physical or mental condition which causes the licensee to failto meet the requirements of 10 CFR 55.21 and to submit an NRC Form 396 for a conditional license. With respect to these regulations, PPL had previous opportunities to identify that a report and conditional license were required during their extent of condition review for EA-09-248, dated January 28,2010. This Enforcement Action was a SL lll NOV related to a senior reactor operator (SRO) standing watch without meeting the same medical qualification requirements for vision in August 2009. The inspectors concluded that an adequate extent of condition review would have identified the additional discrepancy that existed in 2009 and that corrective actions for the previous violation were ineffective given they failed to identify this issue when it recurred in 2Q11.

Analvsis. The inspectors determined that PPL's failure to notify the NRC of a known permanent change in a licensed operator's medical status and request an amended license in order to assume licensed duties was a performance deficiency. This finding was evaluated using the traditional enforcement process because the issue had the potential to impact or impede the regulatory process. Specifically, there was a potential for license termination or the issuance of a conditional license to accommodate the medical condition. The RO performed licensed duties from April 2009 through August

2011 with a disqualifying condition that required his license to be amended. lt is noted that the RO's job performance was satisfactory during this period' Using the NRC Enforcement Policy, this violation was assessed using Section 6.4.

The NRC also considered that the underlying medical basis for the RO's license was not affected since appropriate corrective lens had been worn since April 2009 while he was performing licensed operator duties. As a result, the violation was characterized as SL tv.

This significance of the associated performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B. No associated ROP finding was identified and no cross-cutting aspect was assigned.

Enforcement.

10 CFR 55.3 states that a person must be authorized by a license issued by the Commission to perform the function of an operator or senior operator as defined in this part.

10 CFR 55.21 requires, in part, that a licensee shall have a medical examination by a physician every two years. The physician shall determine that the applicant or licensee meets the requirements of 10 CFR 55.33(aX1). 10 CFR 55.33(a)(1) states, in part, that the applicant's medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety. 10 CFR 55.33(b) states, in part, that if an applicant's general medical condition does not meet the minimum standards under 10 CFR 55.33(aX1) of this part, the Commission may approve the application and include conditions in the license to accommodate the medical defect.

10 CFR 55.23 requires, in part, that to certify the medical fitness of the applicant, an authorized representative of the facility licensee shall complete and sign NRC Form 396.

On the Form 396, PPL certified that it used the guidance in ANSI/ANS 3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants."

10 CFR 55.23(b) states that when the certification requests a conditional license based on medical evidence, the medical evidence must be submitted on NRC Form 396 to the Commission and the Commission then makes a determination in accordance with 10 cFR 55.33.

ANSI/ANS 3.4-1983, section 3 states, in part, that the primary responsibility for assuring that qualified personnel are on duty rests with the facility operator. The health requirements set forth herein are considered the minimum necessary to determine that the physical condition and general health of the individual are not such as might cause operational errors endangering public health and safety. The specific health requirements and disqualifying conditions are described in Section 5.3, "Disqualifying Conditions," and Section 5.4, "specific Minimum Capacities Required for Medical Qualification," of the ANSI standard.

10 CFR 55.25 states, in part, that if during the term of the license, the licensee develops a permanent physical or mental condition that causes the licensee to fail to meet the requirements of 10 CFR 55.21, the facility licensee shall notify the Commission, within 30 days of learning of the diagnosis. For conditions for which a conditional license (as

described in 10 CFR 55.33(b) of this part) is requested, the facility licensee shall provide medical certification on Form NRC 396 to the Commission.

Contrary to these requirements, PPL failed to notify the NRC within 30 days of a known permanent change in medical condition of a licensed operator and ensure that an individual license holder, in the capacity of an RO, met the conditions of his license prior to performing licensed operator duties. Specifically, biennial medical examinations conducted on April 16, 2009 and April 19, 201't identified that an RO did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." Despite medical reviews on May 12, 2009 and May 9, 2011, PPL did not report this change in permanent medical condition to the NRC within 30 days nor did PPL request an amended license with a condition requiring corrective lenses until identified by the NRC during a review of the RO's license renewal application package submitted to the NRC on August 9,2011. This resulted in the RO performing licensed operator duties from April 2009 through August 2011 without a properly restricted license. lt was noted that the RO had worn his corrective lenses since his medical examination in April 2009.

Since this violation is considered to be repetitive, based on EA-09-248 and its occurrence within two years, and it was NRC-identified, the NRC is issuing an NOV in accordance with the guidance in NRC Enforcement Manual Section 3.1.2.3. PPL has entered this issue into their CAP as CR 1450138. (NOV 05000387;38812011004'01, Violation of 10GFR55.25, Failure to Notify NRC of a Change in Medical Status and Request a Conditional License)

1R12 Maintenance Effectiveness

a.

lnspection Scope The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that PPL was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (aX2)performance criteria established by PPL staff was reasonable. As applicable, for SSCs classified as (aX1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that PPL staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

.

Unit 1 , RHR Loop 'A' suppression pool cooling/test control valve, HV151 F0244, failed to close o Unit 1, main steam line (MSL) flow indicating switches

.

Common, review of 50.65(a)(3) Assessment, dated June 2,2011 b.

Findinos No findings were identified.

1 R13 Maintenance Risk Assessments and Emerqent Work Control (71111

.13 -

4 samples)

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that PPL performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that PPL personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When PPL performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.

The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

The inspectors reviewed scheduled and emergent work activities with licensed operators and work-coordination personnel to evaluate whether risk management action threshold levels were correctly identified. ln addition, the inspectors compared the assessed risk configuration to the actual plant conditions and any in-progress evolutions or external events to evaluate whether the assessment was accurate, complete, and appropriate for the emergent work activities. The inspectors performed control room and field walkdowns to evaluate whether the compensatory measures identified by the risk assessments were appropriately performed. Documents reviewed are listed in the

. The selected maintenance activities included:

r Unit 1, red online risk for a 'B' emergency diesel generator (EDG) damper failure and station portable diesel generator OOS o Unit 1, RCIC discharge check valve failure results in high suction pressure r Unit 2, trip of 2A FPC pump during 2A FPC HX cleaning

.

Common, dual-unit yellow risk during Unit 1 Division ll RHR work and 'B' EDG heating, ventilation and air-conditioning (HVAC) work Findinqs lntroduction. A self-revealing Green finding of NDAP-QA-0340, "Protected Equipment Program," Revision 10, was identified when the 2A FPC pump tripped during maintenance on the 2AFPC HX. The pump and HX had been designated as protected equipment.

Descriotion. On July 14,2011, PPL was performing preventive maintenance on the 24 FPC HX. This maintenance included cleaning, inspection, and eddy current testing.

During the tube cleaning via pneumatic hose, air pressure pushed what was noted as excessive mud past a plastic cover installed on the opposite end of the heat exchanger and impacted the operating 2A and 28 FPC pumps. At 10:00 p.m. on the same day, the 2A FPC pump supply breaker tripped. The control room received a fuel pool panel trouble alarm and a fire alarm for the FPC pump room. The diesel-driven fire pump and motor-driven fire pump started. Operators responded by entering ON-235-001, "Loss of FPC/Coolant Inventory," Revision 32, evaluating ON-O13-001, "Response to Fire,"

Revision 30, for entry, and restoring FPC by starting the 2C FPC pump. PPL's investigation confirmed that 0.25" of mud had covered the 2A FPC pump and motor including the motor casing and vents. The thermal overloads were not tripped and motor winding insulation was charred. PPL concluded that the motor shorted to ground and that the adjacent heat exchanger work was the source of the mud and the direct cause of the pump trip.

At the time of this event, all three FPC HXs and all three FPC pumps on each unit were being protected under PPL's Protected Equipment Program since the SFP time to 200 degrees Fahrenheit was less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The program is implemented under NDAP-QA-0340, "Protected Equipment Program," Revision 10. Section 3.1 defines protected equipment as "active or passive systems or components essential to ensuring safety functions or unit generation are maintained for given plant conditions." Step 6.7.3 of the procedure directs that if work is on or near protected equipment, the protected equipment work approvalform will be completed, approvalwill come from the shift manager, and the shift manager will be briefed on critical steps and human performance tools or actions in place to minimize potential impact to protected equipment. lt also directs that continuous or periodic supervisory oversight of the activity will be provided if working on or near the protected equipment respectively, operations supervision will provide periodic oversight once per shift or more frequently if directed by the shift manager, and that the work approval form will be kept with the work package.

lnspectors reviewed contributors to this event and noted the following insights.

.

There was a misunderstanding between maintenance and operations personnel regarding whether HX work was considered on or near protected equipment which changed the expectations for supervisory oversight. During inspector interviews with operations management, it appeared clear that the work was on protected equipment and operations is procedurally responsible for implementation of the program.

.

An initial shift briefing was held between an assistant operations manager (AOM)and the maintenance crew on July 11,2011, when the work began but subsequent shift briefings either did not occur or at a minimum did not repeat the protected equipment discussions required. This was a missed opportunity for clarification of the work category.

.

No protected equipment work approval forms were retained with the work package as required. Since the shift manager and AOM are required signatures for work at least near protected equipment, it was expected that one or more forms would be available considering the work lasted multiple shifts.

.

Lighting and inadequate housekeeping before and after the maintenance were factors. The as-found room lighting and area cleanliness did not meet station standards despite a work package prerequisite step to inspect the area prior to beginning work for housekeeping and foreign material exclusion (FME) issues. The as-left area cleanliness also did not meet station standards. A work package step to clean the work area was annotated as in-progress but not complete despite a signed and initialed subsequent step that the jobsite met station housekeeping expectations.

Workers observed mud on the floor of the room but did not question the extent of the condition nor raise a concern with operations.

.

The room was a high radiation area (HRA). Radiological Protection staff restricted access to the room to maintain dose as low as is reasonable achievable (ALARA)and required the two workers to be on the same side of the HX at all times. The

dose concern also limited the time that supervisory oversight could be present in the room and also mandated the side of the HX viewed. The effects of ALARA concerns were not addressed in briefings and staff did not challenge or raise concerns with management.

.

The historic method of cleaning an FPC HX was to leave the opposite endbell partially installed to capture water and debris as it leaves the HX. Due to the condition of the endbell coating, it was removed and a plastic sheet was taped over the HX open end. This change to the normalwork method was not challenged for adequacy and ultimately proved inadequate in that the plastic sheet was not a robust enough barrier to prevent mud and debris from the HX cleaning from impacting the other FPC pumps in the room.

While this issue had many aspects, the inspectors determined that all of the contributors had a common characteristic of human error prevention techniques in that they are to be used commensurate with the risk of the assigned task to perform it safely and that personnel do not proceed in the face of uncertainty or unexpected circumstances.

Inspectors determined that use of human error prevention techniques would have eliminated issues associated with communications, briefings, housekeeping, oversight, and work activity changes.

Failing to protect equipment under the protected equipment program was a performance deficiency that was within PPL's ability to foresee and prevent. PPL entered this issue into their CAP as CR 1438904.

Analvsis. Failure to protect equipment under the protected equipment program is a performance deficiency within PPL's ability to foresee and correct. The inspectors determined that the finding was more than minor because it was associated with the Barrier Integrity cornerstone attribute of system, structure, and component performance to maintain FPC system functionality and its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the finding resulted in the unavailability and associated loss of functionality of a FPC system pump.

The finding was screened in accordance with IMC 0609 Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and was determined to be of very low safety significance, Green, due to its not being associated with the loss of cooling to the SFP that would have precluded restoration prior to boiling, a fuel handling error, or loss of SFP inventory. Specifically, other FPC pumps and heat exchangers were available on both units and the spent fuel pools were cross-connected.

The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Work Practices, in that PPL did not use human error prevention techniques commensurate with the risk of the assigned task nor did personnel stop work in the face o'f uncertainty or unexpected circumstances. Specifically, PPL did not implement human error prevention techniques commensurate with the potential to affect protected equipment and did not stop work when confronted with the uncertainty associated with communications, briefings, and work activity changes nor the unexpected circumstances associated with housekeeping and oversight. [H.a.(a)]

Enforcement.

This finding does not involve enforcement action because no regulatory requirement violation was identified. Because this finding does not involve a violation

I and has very low safety significance, it is identified as a FlN. (FlN 0500038812011004-02, Inadequate Maintenance Practices Result in Trip of Protected Equipment Spent Fuel PoolCooling Pump)

1R15 Operabilitv Evaluations and FunctionalitvAssessments (71111.15 - 7 samples)

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

.

Unit 1, 1D660 float voltage high out of specification

.

Unit 2, RCIC post-refueloutage

.

Unit 2, suppression pool-drywell vacuum breakers dual open/close indication o Unit 2,'M'SRV seat leakage o Unit 2, HV252 F0318 failed first acceptance criteria

.

Common, startup bus 10 after lightning strikes

.

Common, SRV ASME testing (Second Quarter sample - see 4OA5.4)

The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. ln addition, the inspectors reviewed the selected operability determinations to evaluate whether the determinations were performed in accordance with NDAP-QA-0703, "Operability Assessments." The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to PPL evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by PPL. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findinqs

Introduction.

An unresolved item (URl) was opened concerning Unit 2 RCIC following refuel outage maintenance to allow completion of the licensee's cause evaluation and determine if a performance deficiency exists.

Description.

On June 29, 2011, Unit 2 RCIC was declared inoperable after it tripped on overspeed in automatic flow control when initiated for SR 3.5.3.3 between 920 and 1060 psig reactor pressure. RCIC had previously been operated in manual flow controlfor SR 3.5.3.4 with reactor pressure less than 165 psig reactor pressure. The failure was attributed to the ramp generator signal converter (RGSC) prior to the end of the refueling outage. The completion of SR 3.5.3.4 did not identify the issue with the RGSC. PPL entered this issue into their CAP as CR 1430270. At the end of this inspection period, PPL was conducting an apparent cause evaluation, a root cause analysis (RCA), and post-mortem investigation of the RGSC. This issue will be tracked as an URI pending inspection and review of PPL's completed ACE, RCA, and RGSC investigation.

(URl 0500038812011004-03, RCIC Failure During Surveillance)

2.

Introduction.

An NRC-identified Green NCV of 10 CFR 50, Appendix B, Criterion V, "lnstructions, Procedures, and Drawings," was identified when PPL did not perform an adequate operability assessment in accordance with procedure NDAP-QA-0703, "Operability Assessments and Requests for Enforcement Discretion," to ensure the continued operability of the 'M' Safety Relief Valve (SRV).

Description.

On August24,2011, operations personnel identified a step change in the tail pipe temperature for the 'M' SRV from 166F to 212F. Condition Report (CR)

===1456166 was initiated to document the condition and evaluate operability. The prompt operability determination performed by the on-shift SRO stated that "at the temperatures indicated, the 'M' SRV is leaking." Additionally, it stated that "the SRV remains operable as leakage will not have an adverse effect on lift point."

On August 29, after reviewing the CR and operability determination, inspectors questioned the validity of the statement that leakage will not have an adverse effect on lift point. The basis of the question was CR 1399810 which evaluated three SRVs that failed to meet the TS 3.4.3 setpoint criteria of +/-3 percent in May 2011. In this case, all three valves failed to meet the criteria below -3 percent, indicating they would have lifted prior to their design setting. The apparent cause attributed to one of the failed valves was setpoint variance caused by seat leakage. This was reported to the NRC in Licensee Event Report (LER) 50-388/201 1-001. Upon review of the ACE associated with CR 1399610, the inspectors determined that PPL failed to consider the effect that seat leakage could have on future operability determinations.

In response to inspectors'questions, Operability Follow-up Request (OFR) 1459248 was written to validate the operability determination. The OFR stated that at a tail pipe temperature in excess of 22QF, the valve would be declared inoperable. This was based on the fact that, since 2006, four valves had experienced this magnitude of seat leakage and all four failed to meet the TS setpoint criteria in the low (>-3 percent) direction during the subsequent testing. However, for temperatures below 220F PPL concluded in the OFR that the valve would be considered operable. PPL based this on historical data since 2006 in which, of three leaking SRVs with tail pipe temperatures below 220F,"

only one failed its as-found setpoint test." Upon review of test data, the inspectors determined that, of the three leaking SRVs below 220F, though one had failed its as-found testing, only one had passed its as-found setpoint test, since one of the valves had yet to be tested per the In-service Testing Program. The conclusion of the OFR stated that, since tail pipe temperature for the 'M' SRV was only 212F, the valve was operable. lnspectors evaluated the OFR against the requirements of Part 9900 Technical Guidance "Operability Determinations & Functionality Assessment for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," and determined that the use of such a limited data set to support operability, without technicaljustification, was insufficient and did not provide reasonable assurance that the

'M' SRV was operable.

PPL generated CR 1479436 to address the inspectors' concerns regarding the OFR.

Though the written response to the CR had not been completed at the time of this report, additional follow-up conversations with PPL staff identified that the OFR adopted a philosophy of using test data to prove the SRV was operable, vice one of providing reasonable assurance of operability. In this case, since there was evidence that a valve with low levels of leakage (i.e. tail pipe temperature between 200F and 220F) could fail

its subsequent test and no technicaljustification for why the condition would only occur at higher levels of leakage, there was reasonable doubt on the operability of the 'M' SRV.

On September 4, operators identified another step change in 'M' SRV tail pipe temperature to 226F and initiated CR 1460990 to evaluate the condition for operability.

Upon review and evaluation against the OFR criteria, operators declared the 'M' SRV inoperable. This determination was the direct result of inspectors'questioning and the OFR generated following the first step change in tail pipe temperature.

Analvsis. Failure to adequately assess component operability by incorporating results of previous failure modes analysis is a performance deficiency which was reasonably within PPL's ability to foresee and correct. The finding is more than minor because it was similar to example 3.j in IMC 0612 Appendix E, "Examples of Minor lssues," in that an error in a calculation is not minor if the error results in reasonable doubt on the operability of the system or component. ln this case, the error made in evaluating the operability of the'M' SRV resulted in reasonable doubt of operability. The finding was evaluated for significance using IMC 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings." Since the finding was not a design or qualification deficiency, did not result in a loss of system safety function, did not result in loss of a single train for greater than its allowed outage time, and was not potentially risk significant due to external events, the finding was determined to be of very low safety significance (Green).

This finding was related to the cross-cutting area of Pl&R - CAP because PPL did not thoroughly evaluate problems such that the resolutions address the causes and extent of conditions, to include properly classifying, prioritizing and evaluating for operability.

Specifically, PPL failed to consider the effect that seat leakage had on the lift point of the

'M' SRV and failed to correctly assess the SRV for operability. [P.1.(c)]

Enforcement.

10 CFR Part 50, Appendix B, Criterion V, "lnstructions, Procedures, and Drawings," states, in part, that "activities affecting quality shall be prescribed by instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings." NDAP-QA-0703, "Operability Assessments and Requests for Enforcement Discretion," Revision 15, states, in part, that an initial operability screening should be documented such that it provides a basis for operability.

Contrary to the above, the prompt operability determination performed on August 24, 2011, following identification that the 'M' SRV was experiencing seat leakage was inadequate since it failed to identify that seat leakage had resulted in previous occurrences of setpoint variance outside of acceptable as-found tolerances. Because this finding is of very low safety significance and has been entered into PPL's corrective action program (CR 1459230 and 1465729), this violation is being treated as an NCV consistent with section 2.3.2 of the NRC Enforcement Policy. (NCV 05000388/2011004-04, Inadequate Operability Assessment of Safety Relief Valve Seat Leakage)

1R18 Plant Modifications

.1 Temporarv Plant Modifications (71111.18

- 1 sample)

a. Inspection Scope

The inspectors reviewed the temporary modification listed below to determine whether the modification affected the safety functions of systems that are important to safety.

The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems. The inspectors also assessed configuration control of the changes by reviewing selected drawings and procedures to verify that appropriate updates had been made.

o Unit 2, RCIC steam trap on-line leak sealing b. Findinqs No findings were identified.

1R19 Post-Maintenance Testinq (PMT)

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis andlor design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

The inspectors reviewed PMT activities relating to EPU design changes for the reactor feed pump turbine speed control unit. Specifically, the review included auto-flow control mode testing.

o Unit 1, 1B residual heat removal service water (RHRSW) pump following lift adjustment e Unit 2, two reactor feed pumps (RFPs) in auto-flow control mode testing (EPU)r Unit 2, rod worth minimize inoperable during reactor startup

.

Common, 'B' EDG exhaust damper following repairs

.

Common, 'D'ESW motor replacement o Common, 'C' EDG after 5 year inspection b. Findinqs No findings were identified.

1R20 Refuelinq and Other Outaqe Activities (71111

.1 Unit 2 Refuel Outaqe (RFO)

a. lnspection Scope Unit 2 began the inspection period in a power ascension from 16 percent RTP after an RFO. Through power ascension, inspectors performed the activities below:

o Monitoring of startup and heatup activities r lmplementation of the EPU testing plan r ldentification and Resolution Problems - reviewed CAP entries to verify an adequate threshold for issues and appropriate corrective actions During the inspection activities, the inspectors reviewed the associated documentation to ensure that the tasks were performed safely and in accordance with plant TS requirements and operating procedures b. Findinqs No findings were identified.

1R22 Surveillance Testinq (71111.22 - 5 samples)

a. lnspection Scope The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and PPL procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

o Unit 1, Division I core spray (CS) quarterly flow surveillance and inservice testing (rsr)

.

Unit 2, Division ll RHRSW comprehensive flow surveillance (lST)

.

Unit 2, drywell floor drain in-leakage calculation (RCS Leak Detection)r Unit 2, SE-204-103,24 month 2A auxiliary bus degraded grid testing

.

Common, SE-070-01 1 and SE-170-01 1, 24 month secondary containment drawdown and in-leakage surveillance test b. Findinqs lntroduction. The inspectors identified a Green NCV of Susquehanna Unit 1 and 2 TS 5.4.1, "Procedures" for an inadequate implementing procedure for TS SR 3.6.4.1

.4 and

3.6.4.1.5. Specifically, the implementing procedures were revised to allow missing the SR and subsequently required entry into SR 3.0.3.

Description.

On October 10, 2Q04, PPL identified that TS SRs 3.6.4.1

.4 and 3.6.4.1 .5 as

written were non-conservative and CR 610828 was generated to initiate the necessary corrective actions. Specifically, the SRs test the leak-tightness of secondary containment by assuring in-leakage into secondary containment is within limits (SR 3.6.4.1.5) and that secondary containment drawdown times are within limits (SR 3.6.4.1.4). The SRs are required to be performed on a 24 month staggered test basis for each ventilation subsystem. The TS SRs modified the frequency with a note that required that the three zone configuration of secondary containment be tested every 60 months. This note assumed that the three-zone configuration was the most limiting configuration of secondary containment based on being the largest air volume. Upon review of historicaltest data, PPL determined that, due to differences in the damper positions for the three different configurations of secondary containment (i,e. Zones 113, Zones 213, or Zones 11213), the three-zone configuration was not necessarily the most limiting configuration. Thus, as written, the TS SRs did not ensure the most limiting configuration was tested every 60 months. Despite this, PPL had been testing all configurations every 24 months on a staggered test basis such that all configurations were tested every 48 months. This was controlled by the implementing procedures in-place at the time and controlled via their work scheduling process.

As part of corrective actions for the non-conservative TS, a licensing document change was requested via PLA-5857 on February 7,2005. Additionally, the TS Bases were modified on March 1, 2005, to reflect the testing requirements. Due to the change in the TS Bases, System Engineering updated the surveillance frequency in the work scheduling process such that the required frequency for each of the two-zone configurations was changed from 24 months to 48 months. This change was made without performing an impact review. Additionally, the surveillance implementing procedures, SE-170-011, "Secondary Containment Drawdown and In-leakage Test Zones I and lll" and SE-270-01 1, "Secondary Containment Drawdown and In-leakage Test Zones ll and lll," were modified on May 14, 2007, to describe the tests as 60 month tests and ensure that, for human performance concerns, the two-zone test was performed on the same ventilation train on which the three-zone test was being performed. A note was added to the surveillance procedures to describe the change:

"Note: SE-070-011 will be performed every 2 years with the A/B divisions staggered.

SE-170-01 1 and SE-270-01 1 will be performed on a 2 year staggered basis.

SE-170-01 1 and SE-270-01 1 should be performed with the same division that was tested during surveillance of SE-070-011 in order to minimize human performance errors."

This procedure change was processed as an administrative correction, and as such, did not require a Surveillance Procedure Review per NDAP-QA-0722, "Surveillance Testing" and allowed a lower level approval authority than would be required for a technical change. The testing methodology was changed as follows:

Testing Methodology Testing Methodology Time (Prior to 2005) (After 2005)

(months) Configurations Ventilation Train Configurations Ventilation Train Tested Tested Tested Tested 1t2t3&1t3&213 A 1t2t3 &2t3 A 1t2t3 & 1t3 &2t3 B 1t2t3 & 1t3 B 112t3 & 1t3 &213 A 1t2t3 &2t3 A 112t3 & 1t3 &213 B 1t2t3 & 1t3 B These two changes resulted in the Zone 113 configuration, which is tested via SE-170-01 1, and the Zone 2i3 configuration, which is tested via SE-270-01 1, were only tested with the'B' and'A' ventilation trains, respectively.

On August 19,2011, after observing performance of SE-070-011, Revision 11, "Secondary Containment Drawdown and lnleakage Test Zones l, ll and lll" and SO-170-01 1 , Revision 1 1, "Secondary Containment Drawdown and lnleakage Test Zones I and lll," inspectors questioned how the implementing procedures and testing methodology met the TS SR requirement of 24 month staggered tests basis, as modified by a note that states "test each configuration at least one time every 60 months."

Specifically, after reviewing previous test data, inspectors noted that the SE-170-01 1, which tests the Zone 113 configuration, had not been performed with the'A'train of ventilation since June 15, 2001 and SE-270-011, which tests the Zone 213 configuration, had not been performed with the 'B' train of ventilation since April 18, 2003.

PPL entered the issue into their CAP as CR 1460362. Upon review, PPL determined that the failure to perform the TS SR on all configurations as required by plant TSs constituted a missed surveillance and complied with the requirements of TS SR 3.0.3 for both Unit 1 and Unit 2. As required by SR 3.0.3, a risk assessment determined that the impact of delaying completion of the surveillance would be negligible and an additional 6 month delay was determined to be reasonable to schedule and perform the SR per existing plant processes.

Analvsis. Failure to have an adequate procedure to implement TS SRs is a performance deficiency which was reasonably within PPL's ability to foresee and correct. The finding is more than minor because it was similar to example 3.d in IMC 0612 Appendix E, "Examples of Minor lssues," in that the failure to implement the TS SR as required is not minor if the surveillance had not been conducted. ln this case, the SR had not been completed for all configurations of secondary containment and required both Unit 1 and Unit 2 to enter SR 3.0.3 for a missed surveillance. Additionally, it is associated with the procedure quality attribute to maintain functionality of containment and the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.

Specifically, the inadequate surveillance procedure resulted in missed surveillances, SRs 3.6.4.1

.4 and 3.6.4.1.5, and entry into SR 3.0.3 for missed surveillances. The

finding was evaluated for significance using IMC 0609, Attachment 4, "Phase 1 - Initial

Screening and Characterization of Findings." Since the finding only represented a degradation of the radiological barrier function provided for the reactor building (i.e.,

secondary containment), the finding was determined to be of very low safety significance (Green).

This finding is related to the cross-cutting area of Human Performance - Resources because PPL did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety. Specifically, the surveillance procedures SE-170-011 , Revision 1 1, "Secondary Containment Drawdown and In-leakage Test Zones I and lll," and SO-270-011, Revision 11, "Secondary Containment Drawdown and ln-leakage Test Zones ll and lll," did not ensure SRs required by TS 3.6.4.1were implemented. Since these procedures were last implemented in 2011 and 2009 respectively, the inspectors determined it was reflective of current performance. [H.2.(c)]

Enforcement.

Susquehanna Unit 1 and 2 TS 5.4.1, "Procedures," requires that written procedures be established, implemented and maintained as recommended in Regulatory Guide 1

.33 , Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A

requires implementing procedures for each surveillance listed in TSs. Contrary to the above, from March 1 , 2005 to the present, the implementing procedures for SR 3.6.4.1.4 and 3.6.4.1.5, SE-170-011, Revision 1 1, "Secondary Containment Drawdown and In-leakage Test Zones I and lll," and SO-270-01 1, Revision 1 1, "Secondary Containment Drawdown and In-leakage Test Zones ll and lll," were inadequate such that they resulted in missing the required surveillance frequency and subsequent entry into SR 3.0.3, Because this finding is of very low safety significance and has been entered into PPL's CAP (CR 1460362), this violation is being treated as an NCV consistent with section 2.3.2 of the NRC Enforcement Policy. (NCV 05000387;38812011004-05, Inadequate Surveillance Procedure Results in Missed TS SRs for Secondary Containment)

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors evaluated the conduct of routine PPL emergency drills to identify weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, and technical support center to determine whether the event classifications, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by PPL staff in order to evaluate PPL's critique and to verify whether the PPL staff was properly identifying weaknesses and entering them into the corrective action program.

.

Common, semi-annual HP drill - Blue Team, August 23,2011

.

Common, HP Drill - White Team, September 13,2Q11 b. Findinqs No findings were identified.

=

.1 Mitiqatino Svstems Performance Index (MSPI) (4 samples)

Inspection Scope The inspectors reviewed PPL's submittal of the MSPI for the following systems and timeframes. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance lndicator Guideline," Revision 6. The inspectors also reviewed PPL's operator narrative logs, condition reports, and MSPI derivation reports to validate the accuracy of the submittals. The review also included revisions of the MSPIs for January through September 2010, as corrective actions for NCV 2010005-06 in lR 05000387;38812011005.

Units 1 and2, MS07, High Pressure Injection Systems, April2010 through June 2011 Units 1 and 2, MS10, Cooling Water Systems, August 2010 through June 201 1 Findinos No findings were identified.

.2 Reactor Coolant Svstem (RCS) Specific Activitv and RCS Leak Rate (4 samples)

lnspection Scope The inspectors reviewed PPL's submittal for the RCS specific activity and RCS leak rate Pls for both Unit 1 and Unit 2 for the period of June 2010 through April 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors alsoreviewed RCS sample analysis and control room logs of daily measurements for RCS leakage, and compared that information to the data reported by the Pl.

Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personneltaking and analyzing an RCS sample.

b. Findinos lntroduction. The inspectors identified a severity level lV NCV of 10 CFR 50.9(a),

"Completeness and Accuracy of lnformation," when PPL inaccurately reported RCS leakage values under the RCS leakage Pl, 8102, since inception of the Pl in April 2000 through June 201 1. PPL entered the issue in their CAP as CR 1448124, conducted an ACE, and plans to revise Pl data previously submitted.

Description.

During a review of the RCS Leakage Pls for Units 1 and 2, the inspectors identified that PPL was not reporting leakage data in accordance with NEI 99-02, "Regulatory Assessment Performance lndicator Guideline," Revision 6. Inspection Procedure (lP) 71 151 , 'Pl Verification," dated June 28, 2007 , provides guidance to verify

Pl data submitted by licensees. lP 71 151 , section 3 states, "lnspectors should refer to NEI 99-02 for more in-depth definitions and descriptions of Pl inputs" since it provides the guidelines for collection and submittal of Pl data for review by the NRC. NEI 99-02, section 2.3 describes the RCS leakage Pl, 8102, and defines the indicator as, "The maximum RCS identified leakage in gallons per minute each month per the TSs and expressed as a percentage of the TS limit." Under the data reporting elements subsection, it states "The following data are required to be reported each quarter:

o The maximum RCS identified leakage calculation for each month of the previous quarter (three values)

.

The TS limit" NEI 99-02, section 2.3 defines the monthly Pl value as a calculation using the maximum monthly value of identified leakage divided by the TS limit for identified leakage, multiplied by 100 to obtain a percentage. There is a clarifying note in the section that states, "For those plants that do not have a TS limit on identified leakage, substitute RCS total leakage in the data reporting elements." Total leakage is considered the sum of both identified and unidentified leakage and both items listed above are considered the data reporting elements. This NEI 99-02 guidance remains unchanged in all its revisions. Since Susquehanna Units 1 and 2 do not have a TS for identified leakage, PPL should use their maximum RCS total leakage calculation for each month and their TS limit for total leakage which is 25 gallons per minute. While PPL was correctly using the TS limit for total leakage in the Pl, inspectors determined that PPL was incorrectly using their maximum identified leakage value resulting in a non-conservative Pl value for both units. An inspector review of historical data showed that the largest error on Unit 1 occurred in February 2011 when the reported value was 6.44 percent versus the correct value of 9.20 percent. This was due to the HPCI inboard isolation valve steam leak in the drywell. The largest error on Unit 2 occurred in September 1997 when the reported value was 6.48 percent versus a correct value of 14.88 percent. PPL entered this issue into their CAP as CR 1448124, conducted an Apparent Cause evaluation, and plans to revise the Pl data previously submitted. Upon review of all historical RCS Pl data for Units 1 and 2, PPL noted slight reductions in margin, but no data crossed the GreenMhite threshold.

Analvsis. The performance deficiency involved PPL's failure to submit complete and accurate Pl data for RCS leakage for both Unit 1 and Unit 2 since inception of the Pl program in April 2000. Because violations of 10 CFR 50.9 are considered to potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process.

PPL submitted inaccurate data for the affected Pl for Units 1 and 2 every quarter from April 2000 through its current submittal of June 2011. PPL's failure to identify and correct the recurring errors over this period of time indicated the existence of a programmatic issue. Additionally, verification of the corrected Pl data in a subsequent inspection will have more than an insignificant regulatory impact on the NRC.

Accordingly, although none of the affected Pls in this case would have crossed the threshold, the NRC has determined that the violation is of more than minor significance.

The inspectors concluded that PPL had reasonable opportunity to foresee and correct the inaccurate information prior to the information being submitted to the NRC. The finding was not considered to be more significant since had this information been

accurately reported, it would not have likely caused the NRC to reconsider a regulatory position or undertake a substantial further inquiry.

The significance of the associated performance deficiency was also screened against the ROP per the guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned.

Enforcement.

10 CFR 50.9(a) requires, in part, that information provided to the NRC by a licensee be complete and accurate in all material respects. NEI 99-02, "Regulatory Assessment Pl Guideline," Revisions 0 through 6, provided guidance to the industry for submittal of Pl data to the NRC. Per NEI 99-02, licensees without a TS limit for ldentified Leakage are to report RCS leakage using Total Leakage values. Contrary to this, since inception of the Pls in April 2000 through June 2011, PPL did not report the RCS leakage Pl correctly. Specifically, PPL incorrectly calculated the Pl using maximum identified leakage vice total leakage (sum of identified and unidentified leakage). This resulted in inaccurate Pl values being calculated and submitted for both units since April 2000. This violation is characterized as an SL-IV NCV consistent with sections 2.2.1.c and 6.9 of the NRC Enforcement Policy. Because this violation was of very low safety significance, was not repetitive or willful, and was entered into PPL's CAP as CR 1448124, this violation is being treated as an NCV, consistent with section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000387;388/2011004-06, Inaccurate RCS Pl Data Submittal)4c.A2 ldentification and Resolution of Problems (71152)

.1 Routine Review of Problem ldentification and Resolution Activities

a. Inspection Scope

As specified by lP 71152, "Problems ldentification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PPL entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. ln order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended screening meetings.

b. Findinqs No findings were identified.

.2 Annual Sample: Review of CAP Evaluation Products (1 sample)

a. Inspection Scope

The NRC's 2010 Annual Assessment Letter dated March 4, 2011 (ML110620317) and the NRC's 2011 Mid-Cycle Assessment Letter dated September 1,2011 (ML112430469), documented weaknesses in the area of Problem ldentification and Resolution - Problem Evaluation, IMC 0310, P.1(c). Both letters documented a cross-

cutting theme in this area and the 2011 Mid-Cycle Assessment letter assigned a Substantive Cross-Cutting lssue in this area.

The inspectors reviewed a sample of PPL's root cause, apparent cause, and common cause evaluations completed in 2011 prior to the inspection. The inspectors also reviewed selected effectiveness reviews, quality assurance (QA) reviews and program audits, and attended corrective action review board (CARB) meetings to assess PPL's progress in addressing the cross-cutting theme in Pl&R, Problem Evaluation. The inspectors also reviewed a sample of CAP documents, reviewed self-assessments and CAP training plans, observed station operation committee (SOC) and management review committee (MRC) meetings, and conducted interviews to assess the level of progress PPL had made in addressing the identified weaknesses. The majority of the evaluation products selected were issues identified during the Unit 2 refueling outage.

Findinqs and Observations No findings of significance were identified.

The quality of the PPL's problem evaluation products for the sample reviewed was adequate, with some noted weaknesses. Also, between the 4tn quarter o'f 2010 and the end of June 201 1, there appears to have been limited improvement in the overall quality of PPL's evaluation products related to apparent cause evaluations. PPL had planned a number of corrective actions to improve the quality of evaluations including ACE team leader training and qualifications, increased focus on CAP by senior management, and the implementation of Department-level Corrective Action Review Board (DCARB)reviews. However, some planned corrective actions to address weaknesses in problem evaluation were deferred from the originally intended dates thereby delaying the implementation of effective corrective actions. For example:

.

The procedure for DCARB reviews was issued on May 27,2Q11 with the expectation of implementation within 30 days. The original procedure due date was February 25,2011. Extensions were based on additional time needed to resolve the extensive nature of the comments to the initial draft, resource limitations prior to the Unit 2 refueling outage, and implementation of a change management plan.

.

The lesson plan for ACE training was not completed until late-May 2011. The original due date for the lesson plan was extended three times from February,25 to June 30, 2Q11. The extensions were based on clarification of the assignment, reassigning the work, and training committee reviews.

.

ACE training began in mid-June and was completed in mid-August 2011. The original intent had been to complete ACE training for all personnel by June 17,2011.

Regarding the Unit 1 and 2 outages, much of the workforce was involved in Unit 2 refueling outage activities from early April to early May 2011. Once turbine blade replacement began on both Units (mid-May 2011), however, substantially less of the workforce was involved in supporting the outages, thereby creating another opportunity to move fonrvard in addressing evaluation weaknesses. In summary, several actions could have been completed, substantially or in part, before the Unit 2 Spring 2011 refueling outage or during the period of the dual-unit outage (mid-May to late June 2011); thereby increasing the quality and effectiveness of many of the problem evaluations conducted during this time frame.

For some of the CAP evaluation products reviewed, the inspectors noted weaknesses in the timeliness of evaluations, corrective actions, and in the level of rigor/ documentation for supporting the basis for the conclusions. The inspectors also noted that a PPL QA audit identified similar weakness. Specific examples include:

r AR 1438453 identified that the guidance in NDAP-00-0753, Revision 0, was not consistent with industry practice for conducting common cause/common issue analysis and created a potential for the evaluator to stop short of determining the common cause. Corrective actions were developed under AR1438452 in July 2011; however, at the end of September 2011, PPL QA made a similar observation for the common cause analysis performed for the White Pl which stopped short of identifying a common cause for these operational events.

o The ACE and RCA (CR1430270 and CR1450534 respectively) for a RCIC issue which resulted in a functional failure of the system and an LER (50-388-11-002-00)did not appear to be timely. The event occurred on June 29,2011. As of the close of the quarterly inspection period, the ACE and RCA were not complete for this matter. Further, the post-mortem analysis of the RGSC had not been completed to support the ACE.

.

For CR 1396005 for a configuration control event, the conclusion was not supported with data. Specifically, the evaluation took credit for actions previously taken by management to reinforce the use of human performance tools and thereby determined that no further action was required. However, no basis was provided for this decision.

Finally, the inspectors evaluated selected effectiveness reviews of CAs and attended CARB reviews for RCAs performed in 2009 and 2010. In general, the reviews were objective and thorough, and the conclusions were reasonable and well supported. For effectiveness reviews that were determined to be ineffective. CRs were written and evaluations were assigned as appropriate.

However, in one case, the CR and Level 3 evaluation (CR 1 445763) performed for an unsatisfactory effectiveness review of CR 1194033 related to CAP programmatic weaknesses did not appear to address the underlying problems identified by the effectiveness review. The Level 3 evaluation challenged the effectiveness review's conclusion and suggested alternate acceptance criteria such that the review would have been judged effective. Notwithstanding, the level 3 evaluation did not address why the CARB approved acceptance criteria were not met and the effectiveness review had to determine the review was ineffective.

From observations of DCARBs and CARBs during the quarter, the inspectors concluded that these meetings are providing value to reviewed CAP products. The CARB rejection rate in June and July averaged approximately 39 percent. PPL raised the performance thresholds for CARB grades in July based on the expectation that DCARBS will improve the products that are subsequently reviewed by CARB. However, challenges to the ability to execute these processes exist. Examples include:

.

Increased number of RCAs and ACEs requiring DCARB and CARB review; o Documents frequently not provided to DCARB or CARB members within the program specified guidelines for minimum time for review;

.

One meeting was observed where the presenter (i.e. ACE evaluator) was not present (CR 1a56182);o Numerous DCARB and CARB meetings cancelled due to inability to establish a meeting quorum; r Feedback from CARB members being provided to evaluators with insufficient time to resolve comments prior to the meetings, resulting in several cancelled CARB meeting (1a87536);

.

Numerous CARBS are being scheduled as "Special CARB meetings." Though allowed by process, the frequency of this occurrence seemed inconsistent with the procedure that states these are occasional occurrences; and

.

Several DCARB and CARB meetings were observed to take in excess of several hours, leading to more troubleshooting and evaluation during the meeting, vice assessment of the product.

Each of the specific examples discussed above were screen for risk significance using IMC 0609 Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings,"

IMC 0612, Appendix B, "lssue Screening," and IMC 0612, Appendix E, "Examples of Minor lssues." They were determined to be of minor risk significance.

4043 Event Followup (71153 - 2 samples)

.1 Unit 2 Reactor Trip from Main Turbine Trip Durinq ICS Level Testinq

a. Inspection Scope

On August 19,2011, the Unit 2 reactor scrammed on a Level 8 main turbine trip during a quarterly functional test of the feedwater/main turbine trip system associated with reactor vessel water level channels, The main turbine tripped but reactor feedwater pumps remained in service. No automatic emergency core cooling system (ECCS) initiations occurred and RCIC did not initiate. Six SRVs lifted and both reactor recirculation pumps tripped. A resident inspector responded to the control room and observed the plant's response to the transient and associated operator actions during the response.

Additionally, inspectors reviewed the transient response post-event as well as reviewed immediate corrective actions. The event was entered into PPL's CAP as 1453671.

b. Findinqs No Findings were identified.

.2 Notice of Unusual Event (NOUE) for Seismic Activitv at Units 1 and 2

a. Inspection Scope

On August 23,2011, central Virginia experienced a 5.8 earthquake on the Richter scale with the epicenter in Mineral, Virginia. The seismic event was felt by personnel onsite at Susquehanna at 1:55 p.m. and was recorded by the seismic monitoring system. The seismic monitoring system classified the event as less than an Operating Basis Earthquake (OBE) and less than a Safe Shutdown Earthquake (SSE). At 2:05 p.m.

SSES declared a Notice of Unusual Event, OUS, for both units after confirmation by outside agencies that an actual seismic event had occurred and reports from numerous

personnel that they had detected ground motion. There was no indication of equipment damage or personnel injuries and no automatic initiations of any ECCS, emergency safety feature (ESF) systems, or RPS actuations. A resident inspector, who was onsite at the time, felt the seismic event and responded to the control room. Inspectors observed and assessed plant and control room operator responses to the event to include emergency response staffing, event classification, and event notification. An independent walkdown of ECCS equipment and exterior sections of the drywells for both units was completed. Inspectors also established and maintained communications with NRC Region I and Headquarters to ensure awareness of specific site impacts and PPL's event response.

b. Findinqs No findings were identified.

40A5 Other Activities

.1 EPU and Mitioatinq Svstem Startup Testinq (71004 and71111.19)

a. lnspection Scope The inspectors observed portions and reviewed the following major plant test. The details of this inspection sample are described in section 1 R19 of this report. The test was considered an inspection sample that meets the requirements of lP 71004, 02.03.c:

.

Unit 2, RFPs in auto-flow control mode testing b. Findinqs and Observations No findings were identified.

.2 EPU Power Ascension (lnteqrated Plant Evolutions) (lP 71004 and 71

111

.20 )

Inspection Scope lnspectors witnessed power ascension following the Unit 2 refueling outage. Inspectors witnessed portions of all reactivity changes made to achieve specific EPU test conditions. lnspectors also reviewed operator actions, procedure adherence, and plant response during these integrated plant maneuvers. This was a required inspection sample that meets the requirements of lP 71004, 02.03.d.

b. Findinqs No findings of significance were identified.

.3 (Closed) NRC Temporarv Instruction 2515/177 - Manaqinq Gas Accumulation in

Emeroencv Core Coolinq. Decav Heat Removal and Containment Sprav Svstems

a. Inspection Scope

The inspectors performed the inspection at Units 1 and 2 in accordance with Temporary lnstruction (Tl) 251 51177, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." The NRC staff developed T125151177 to support the NRC's confirmatory review of licensee responses to NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." Based on a review of PPL's GL 2008-01 response letters, the NRC Office of Nuclear Reactor Regulation (NRR) staff provided additional plant specific guidance on inspection scope to the regional inspectors. The inspectors used this inspection guidance along with the Tl to verify that PPL implemented or was in the process of acceptably implementing the commitments, modifications, and programmatically controlled actions described in their GL 2008-01 response. The inspectors verified that the plant-specific information (including licensing basis documents and design information) was consistent with the information that PPL submitted to the NRC in response to GL 2008-01.

The inspectors reviewed a sample of isometric drawings, and piping and instrument diagrams, and conducted selected system piping walkdowns to verify that PPL's drawings reflected the subject system configurations and Updated Final Safety Analysis Report (UFSAR) descriptions. Specifically, the inspectors verified the following related to a sample of isometric drawings for the high pressure coolant injection (HPCI), CS, and residual heat removal (RHR) systems:

o High point vents were identified r High points that did not have vents were recognized and evaluated with respect to their potential for gas buildup

.

Other areas where gas could accumulate and potentially impact subject system operability, such as orifices in horizontal pipes, isolated branch lines, heat exchangers, improperly sloped piping, and under closed valves, were acceptably evaluated in engineering reviews or had ultrasonic test (UT) points which would reasonably detect void formation o For piping segments reviewed, branch lines and fittings were clearly shown The inspectors conducted walkdowns of portions of the above systems to evaluate the acceptability of PPL's drawings utilized during their review of GL 2008-01. The inspectors verified that PPL conducted walkdowns of the applicable systems to confirm that the combination of system orientation, vents, instructions and procedures, tests, and training, would ensure that each system was sufficiently full of water to ensure operability. The inspectors reviewed PPL's methodology used to determine system piping high points, identification of negative sloped piping, and calculations of void sizes based on UT equipment readings, to ensure the methods were reasonable. The inspectors also reviewed engineering analyses associated with the development of acceptance criteria for as-found voids. The review included engineering assumptions for void transport and acceptability of void fractions at the suction and discharge piping of the applicable system pumps. In addition, the inspectors verified that PPL included all emergency core cooling systems, along with supporting systems, within the scope of the GL.

The inspectors reviewed a sample of PPL's procedures used for filling and venting the systems associated with GL 2008-01 to verify that the procedures were effective in venting or reducing voiding to acceptable levels. The inspectors verified that PPL's

venting surveillance frequencies were consistent with TSs and associated bases, and the UFSAR. The inspectors reviewed a sample of system venting surveillance results to ensure proper implementation of the surveillance program.

The inspectors reviewed CAP documents to verify that selected actions described in PPL's nine-month and supplemental submittals were acceptably documented including completed actions, and implementation schedule for incomplete actions. The inspectors also verified that the NRC commitments in PPL's submittals were included in the CAP.

The inspectors specifically verified the installation of hardware vents, located in the HPCI, CS, and RHR discharge piping, as committed to in PPL's GL response.

Additionally, the inspectors reviewed evaluations and corrective actions for various issues PPL identified during their GL 2008-01 review. The inspectors performed this review to ensure PPL appropriately evaluated and adequately addressed any gas voiding concerns including the evaluation of operability for gas voids discovered in the field. Finally, the inspectors reviewed PPL's training associated with gas accumulation to assess if appropriate training had been provided to the operations and engineering support staff to ensure appropriate awareness of the effects of gas voiding. Documents reviewed are listed in the Attachment.

Findinqs No findings were identified. This completes the inspection requirements for Tl 25151177 at Units 1 and 2.

.4 Omission of Operabilitv Evaluation Inspection Sample in lR 05000387:388/2011-003

a. lnspection Scope During a review of samples conducted during previous quarters, the resident inspectors identified that a completed Operability Evaluation sample was not documented in the associated inspection report. lt is listed here as well as section 1R15 so as to provide documented evidence of its completion.

r Common, SRV ASME testing b. Findinoq No findings were identified.

.5 URI 05000387/201 0003-05 Update

a. Inspection Scope

A URI regarding configuration control and operation of ICS was opened in lR 05000387;38812010003 pending the review of a root cause analysis (RCA) associated with a Unit 1 reactor scram to determine if a performance deficiency exists. Subsequent to completion of this RCA, Unit 1 was issued a White FIN for a condenser bay flooding event and its Pl for Unplanned Scrams turned White. This placed Unit 1 in the Degraded Cornerstone column of the NRC's action matrix. In preparation for the associated 95002 inspection for a Degraded Cornerstone, PPL re-performed the RCA for the scram associated with this URl. Since the results of this new RCA may differ

from the original, this URI is intended to be inspected coincident with the review of the RCAs during the 95002, currently scheduled for February 2012.

b. Findinqs No findings were identified.

4OAO Meetinos. Includinq Exit On September 1 , 2011, the inspectors presented the inspection results to Mr. J. Petrilla, Acting Manager, Nuclear Regulatory Affairs, and other members of PPL staff. The inspectors verified that no proprietary information is documented in this report.

On October 13,2011, the inspectors presented inspection results to Mr. T. Rausch, Chief Nuclear Officer (CNO) and other members of his staff. PPL acknowledged the findings. The inspectors verified that no proprietary information is documented in this report.

4CA7 Licensee-ldentified Violations The following violations of very low safety significance (Green) or severity level lV were identified by PPL and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as non-cited violations:

o On July 29, 2011, the Unit 1 RCIC system was declared inoperable when the pump discharge check valve failed to fully shut and consequentially failed the surveillance acceptance criteria. PPL declared the system inoperable and took several days of unplanned unavailability to troubleshoot and repair the check valve. The apparent cause of the check valve failure was sticking or binding as the result of the right hinge pin having excessive axial clearance. The maintenance procedures for disassembly of the check valve, last performed in July 2QQ7, did not specify a tolerance for sideto-side hinge pin clearance. This issue was determined to be a violation of Susquehanna Unit 1 TS 5.4.1, "Procedures," which requires that written procedures be established, implemented and maintained as recommended in Regulatory Guide 1

.33 , Revision 2, Appendix A, February 1978. Regulatory Guide

1.33, Appendix A, requires procedures to perform maintenance on the RCIC system.

The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Equipment Performance, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using IMC 0609, Attachment 4, "lnitial Screening and Characterization of Findings," and determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not iesult in a loss of safety function or the loss of a train for greater than its TS allowed outage time, and was not potentially risk significant due to external event initiators. The issue was entered into PPL's CAP as CR 1444679.

.

On May 23, 2011, PPL identified that effluents decontamination workers entered the Unit 2 equipment pit on RB elevation 818'without a survey performed to assess radiological conditions, or escorted by healthy physics personnel in violation of TS 5.7.1.e. TS 5.7.1.e requires that entry by individuals, other than those qualified in or escorted by those qualified in radiation protection procedures, into a High Radiation Area only be made after dose rates in the area have been evaluated and entry personnel are knowledgeable of them. The issue was more than minor because it was determined to be similar to example 6.h of IMC 0612, Appendix E, in that a survey was not actually performed. Additionally, the finding affected the program and process attribute, as measured by procedures, of the Occupational Radiation Safety cornerstone and its objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The issue was evaluated in accordance with IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," and inspectors determined that the finding was of very low safety significance (Green) because the finding was due to ALARA work control and the 3-year rolling average collective exposure was less than 240 person-rem/unit (99.7 person-remiunit for 2008-2010). PPL entered the issue into their CAP as CR 1412115.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Rausch, Chief Nuclear Officer

C. Coddington, Senior Engineer

J. Eisenhauer, Nuclear Plant Operator

R. Centenaro, Design Engineer

S. Muntzenberger, System Engineer

T. Walters, System Engineer

J. Petrilla, Acting Manager Regulatory Affairs

J. Goodbred Jr, Manager Nuclear Operations

G. Maertz, Manager Engineering

J. Waclawski, Senior Engineer

D. Lock, Manager Nuclear Maintenance

M. Potter, Assistant Operations Manager

D. Wright, Maintenance CAP Coordinator

J. Felock, Supervising Engineer

M. Murphy, Supervising Engineer

J. Siroka, Senior Engineer

M. Rochester, Regulatory Affairs

L. West, CAP Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000388/201 1 004-03 URI RCIC Failure During Surveillance (1R15.1)

05000387;38812011004-01 NOV Violation of 10CFR55.25, Failure to Notify NRC of a Change in Medical Status and Request a Conditional License (1R1 1)

Opened/Closed

05000388/2011004-02 FrN Inadequate Maintenance Practices Result in Trip of Protected Equipment Spent Fuel Pool Cooling Pump (1R13)

05000388/2011004-04 NCV Inadequate Operability Assessment of Safety Relief Valve Seat Leakage (1R15.2)

05000387:38812011004-05 NCV Inadequate Surveillance Procedure Results in Missed Technical Specification Surveillance Req uirements for Secondary Containment (1R22)

05000387;38812011004-06 NCV Inaccurate RCS Pl Data Submittal (4OA1.2)

Discussed

05000387/201 0003-05 URI Configuration Control and Operation of ICS (4OA5.5)