IR 05000387/2012004

IR 05000387-12-004 and 05000388-12-004; 07-01-12 - 09-30-12; Susquehanna Steam Electric Station - NRC Integrated Inspection Report and NRC Office of Investigations Report 1-2012-017

ML12319A022
Person / Time
Site:	Susquehanna
Issue date:	11/13/2012
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
krohn, pg
References
1-2012-017 IR-12-004
Download: ML12319A022 (43)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 13, 2012

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED INSPECTION REPORT 05000387/2012004 AND 05000388/2012004 AND NRC OFFICE OF INVESTIGATIONS REPORT 1-2012-017

Dear Mr. Rausch:

On September 30, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES) Units 1 and 2. The enclosed inspection report (IR) presents the inspection results, which were discussed on October 16, 2012, with you and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

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

This report documents two NRC-identified findings and one self-revealing finding of very low safety significance (Green). Two of these findings were determined to involve violations of NRC requirements. Additionally, one licensee-identified violation, which was determined to be of very low safety significance, is 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 NRCs Enforcement Policy. If you contest any NCVs 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 Regional Administrator Region I; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at SSES. 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 Regional Administrator, Region I, and the NRC Resident Inspectors at SSES.

This inspection also reviewed actions regarding the failure of the C emergency diesel generator (EDG) identified by NRC inspectors in December 2011. In response, the Region I Field Office, NRC Office of Investigations (OI), initiated an investigation on January 2, 2012, to determine whether maintenance technicians and a Quality Control (QC) inspector, employed by PPL, deliberately failed to properly assemble delivery valves on 15 fuel pumps. Based on testimonial and documentary evidence gathered during the investigation, the investigators concluded that while a violation of Technical Specification (TS) requirements had occurred, improper planning and implementation of work instructions was identified as the cause and that the technicians and QC inspector did not deliberately fail to perform the maintenance. The safety significance of this violation was previously evaluated by the NRC and documented in NRC Inspection Report 05000387;388/2011005 as a Green finding. The enforcement aspects of the Green finding were held open pending the completion of the NRC OI Investigation. The NRC is dispositioning this violation of NRC requirements as an NCV in accordance with the Enforcement Policy since it was of very low safety significance, PPL has entered this issue into their CAP, it was not repetitive or willful, and compliance was restored in a reasonable period of time. The finding and associated violation will be counted as one input into the plant assessment process.

Please note that final NRC documents, such as the OI report described above, may be made available to the public under the Freedom of Information Act (FOIA) subject to redaction of information appropriate under FOIA. Requests under FOIA should be made in accordance with 10 CFR 9.23, Request for Records.

In accordance with 10 CFR 2.390 of the NRCs "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 NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387, 50-388 License Nos. NPF-14, NPF-22 cc w/encl: Distribution via ListServ

ML12319A022 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE mmt RI/DRP RI/DRP RI/ORA RI/DRP NAME PFinney/AAR for ARosebrook/ AAR MMcLaughlin/ MMM PKrohn/ PGK DATE 11/ 06 /12 11/06 /12 11/06 /12 11/07 /12 Distribution w/encl: (via e-mail)

W. Dean, RA D. Lew, DRA D. Roberts, DRP J. Clifford, DRP C. Miller, DRS P. Wilson, DRS P. Krohn, DRP A. Rosebrook, DRP S. Ibarrola, DRP P. Finney, DRP, SRI J. Greives, DRP, RI S. Farrell, DRP, AA C. Santos, RI OEDO RidsNrrPMSusquehanna Resource RidsNrrDorlLpl1-2 Resource ROPreports Resource

U.S NUCLEAR REGULATORY COMMISSION

REGION I

Docket No: 50-387, 50-388 License No: NPF-14, NPF-22 Report No: 05000387/2012004 and 05000388/2012004 Licensee: PPL Susquehanna, LLC (PPL)

Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: July 1, 2012 through September 30, 2012 Inspectors: P. Finney, Senior Resident Inspector J. Greives, Resident Inspector R. Edwards, Acting Resident Inspector F. Arner, Senior Reactor Inspector S. Ibarrola, Acting Resident Inspector P. Kaufman, Senior Reactor Inspector J. Caruso, Senior Operations Engineer R. Rolph, Health Physicist S. Hammann, Senior Health Physicist Approved By: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000387/2012004, 05000388/2012004; 07/01/2012 - 09/30/2012; Susquehanna Steam

Electric Station, Units 1 and 2; Adverse Weather Protection, Maintenance Effectiveness,

Maintenance Risk Assessments and Emergent Work Control The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified two non-cited violations (NCVs) and one self-revealing finding of very low safety significance (Green). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, (ROP) Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

The inspectors identified a Green NCV of TS 5.4.1, Procedures, when PPL did not maintain adequate procedures to respond proactively to acts of nature. Specifically, PPLs adverse weather procedure did not ensure timely risk management activities for imminent adverse weather were completed despite a National Weather Service (NWS) declaration of a high wind watch, high wind advisory, and a tornado watch. PPL entered this item in their Corrective Action Program (CAP) as condition report (CR) 1628452.

The issue was evaluated in accordance with IMC 0612 and determined to be more than minor since it affected the procedure quality attribute of the Initiating Events cornerstone and its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure prevented PPL from taking proactive steps to limit the likelihood of high wind or tornado-related missile hazards upsetting plant electrical power systems.

The finding screened to Green in accordance with IMC 0609, Attachment 4, and Appendix A, Exhibit 1, since it did not cause a reactor trip, involve the complete or partial loss of mitigation or support equipment, or impact the frequency of a fire or internal flooding event.

The finding was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution - CAP because PPL did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance.

Specifically, PPL did not identify that the Off Normal procedure was inadequate both during the 2011 periodic procedural review and during documentation of inspector observations in May 2012 as part of CR 1579977. P.1(a) (Section 1R01)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50.65(a)(4) when PPL did not implement risk management actions (RMAs) during maintenance as required by station procedures. The inspectors identified multiple examples of PPL non-compliance with 10 CFR 50.65(a)(4); PPLs implementing procedures NDAP-QA-0340, Protected Equipment Program; and NDAP-QA-1902, Integrated Risk Management. PPL entered the issue in their CAP as CRs 1611044, 1604007, 1601929, 1602495, and 1611876.

The finding was more than minor because it was similar to IMC 0612, Appendix E, examples 7.e and 7.f. Specifically, elevated plant risk required RMAs or additional RMAs that were not implemented as required by plant procedures. The finding also affected the equipment performance attribute of the Mitigating Systems Cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Attachment 4, the issues were determined to involve PPLs assessment and management of risk associated with performing maintenance activities and was further assessed under IMC 0609, Appendix K,

Maintenance Risk Assessment and Risk Management SDP. The issue was evaluated by a Senior Reactor Analyst utilizing flowchart 2, and the finding was determined to be of very low safety significance (Green) since it did not result in an increase to either the incremental core damage probability (ICDP) or to the incremental large early release probability (ILERP).

The finding was determined to have a cross-cutting aspect in the area of Human Performance, Work Control, in that PPL did not plan work activities, consistent with nuclear safety, by incorporating risk insights. Specifically, PPL did not incorporate RMAs into its work activities despite recognition of increased risk. H.3(a) (Section 1R13)

Cornerstone: Barrier Integrity

Green.

A self-revealing Green finding against PPL procedure NDAP-QA-0510,

Troubleshooting Plant Equipment, was identified when inadequate troubleshooting caused repeated inoperability of secondary containment, an associated unplanned Unit 2 entry into a 4-hour limiting condition for operation (LCO) action statement, and a loss of the 1C fuel pool cooling (FPC) pump during equipment restoration. The FPC pump had been designated as protected equipment as a risk management action. The failure to perform adequate troubleshooting activities to identify and correct equipment problems prior to restoration was a performance deficiency that was within PPLs ability to foresee and prevent. PPL entered this issue into their CAP as CR 1628250.

The inspectors determined that the finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity cornerstone and adversely affected its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the event resulted in the inoperability of secondary containment and loss of a FPC pump. The finding was evaluated in accordance with IMC 0609, Attachment 4, and Appendix A - Exhibit 3, and was determined to be of very low safety significance (Green) because the finding did not only represent a degradation of the radiological barrier function provided for the standby gas treatment system and it did not: a) cause the spent fuel pool to exceed a maximum temperature limit; b) cause mechanical fuel damage and detectable release of radio-nuclides; c) result in the loss of spent fuel pool water inventory; or d) affect spent fuel shutdown margin. This finding is related to the cross-cutting area of Human Performance -

Decision-Making because PPL did not make safety-significant or risk-significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. Specifically, PPL failed to restore equipment in a systematic manner, given the intermittent nature of heater faults, to preclude a repeated loss of protected equipment and secondary containment. H.1(a) (Section 1R12)

Other Findings

A violation of very low safety significance that was identified by PPL was reviewed by the inspectors. Corrective actions taken or planned by PPL have been entered into PPLs CAP. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period in Mode 2 starting up from a forced outage. The unit reached 100 percent rated thermal power (RTP) on July 6. On July 7, the unit was reduced to 68 percent over 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> for a control rod pattern adjustment. On July 17, the unit was reduced to 83 percent power over 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> for indications of a main generator oil exciter leak. On August 18, the unit was reduced to 65 percent power over 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> for a control rod sequence exchange. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at or near 100 percent power. On July 28, the unit was reduced to 83 percent power over 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> for a condenser waterbox planned isolation activity.

On August 3, the unit was reduced to 59 percent power over 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> for condenser waterbox cleaning. On August 24, Unit 2 was reduced to 66 percent power over 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> for a control rod sequence exchange. The unit remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Imminent Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed PPLs preparations in advance of and during warnings and advisories issued by the National Weather Service. The inspectors performed walkdowns of areas that could be potentially impacted by the weather conditions, such as the emergency and station black out diesel generators, station transformers, and switchyards, and verified that station personnel secured loose materials staged for outside work prior to the forecasted weather. The inspectors verified that PPL monitored the approach of adverse weather according to applicable procedures and took appropriate actions as required. Documents reviewed for each section of this inspection report are listed in the Attachment.

Common, hot weather alert for July 5 - 7, 2012 Common, high wind watch for afternoon of September 18, 2012

b. Findings

Introduction.

The inspectors identified a Green NCV of TS 5.4.1, Procedures, when PPL did not maintain adequate procedures to respond proactively to acts of nature.

Specifically, PPLs adverse weather procedure did not ensure timely risk management activities for imminent adverse weather were completed despite a National Weather Service (NWS) declaration of a high wind watch, high wind advisory, and a tornado watch.

Description.

On May 25, 2012, inspectors informed Operations staff of a concern regarding debris in the vicinity of the supplemental decay heat removal piping that could become a missile hazard based on the amount of debris in the area if high winds were encountered. The items noted included hoses, buckets, stanchions, and loose piping.

The inspectors based this concern, in part, on forecasted inclement weather. PPL entered this observation in their CAP as CR 1579977, closed the CR without action, and documented that should inclement weather occur prior to clean up, the appropriate off normal procedure would be entered and the area secured. Regulatory Guide (RG) 1.33 identifies Acts of Nature as one type of procedure for combating emergencies and other significant events that is part of the list of safety-related activities that should be covered by written procedures.

On September 17, 2012, the NWS issued a High Wind Watch for Luzerne County in effect from the morning through the evening of September 18. The NWS issues a High Wind Watch when there is a potential for high wind speeds developing that may pose a hazard or is life threatening. At 4:04 a.m. on September 19, the NWS issued a High Wind Advisory to be in effect from 11:00 a.m. to 6:00 p.m. expecting sustained winds of 20 to 30 miles per hour (mph) with gusts of 40 to 50 mph and localized gusts of 50 mph or greater possible. Downed trees and power lines were anticipated. Based on the High Wind Watch and Advisory, the resident inspectors selected an Imminent Weather inspection sample and completed walkdowns of the 500KV and 230KV offsite power switchyards, the primary and backup meteorological towers, offsite power transformers T10 and T20, Unit 1 and 2 main transformers, the station blackout EDG, and the Engineered Safeguards System transformers. The inspectors noted a number of items that could be potential missile hazards that included loose pieces of wood, loose wood blocks, wooden pallets, a wooden cable spool, stanchions, piping, piping flanges, a metal-frame door, and pieces of sheet metal. Some of the loose wood, pallets, and cable spool were located inside the 500KV switchyard. The remaining items were located in the vicinity of the ESS transformers and station blackout (SBO) EDG.

The inspectors reviewed the station procedures concerning adverse weather. At approximately 12:00 p.m., one of the inspectors went to the control room and asked the Shift Manager what procedure(s) had been entered for the High Wind Advisory. During the conversation, the control room received a phone call informing the site that the NWS had declared a Tornado Watch for Luzerne County. The NWS issues a Tornado Watch when conditions are favorable for the development of tornadoes in and close to the watch area. The Shift Manager updated station leadership on the new information and a log entry was made that: a) onsite work groups were notified of weather conditions; b)outside work was prepared for high winds; and c) a walkdown of site areas for missile hazards was commenced. The subsequent PPL walkdown identified items in the vicinity of the main transformers and ESS transformers to include a gas cylinder, tools, ladders, tarps, and pipe flanges. The inspectors observed that not all of the items the inspectors had observed were noted by PPL nor were they all removed during the PPL walkdown.

An Independent Spent Fuel Storage Installation (ISFSI) campaign was also in progress that day and the inspectors noted that a loaded dry fuel cask had been moved from the spent fuel pool to the reactor vessel head washdown area at 11:15 am, despite the High Wind Advisory in effect at that time.

The inspectors reviewed ON-000-002, Natural Phenomena, Revision 28, to determine whether the site met entry conditions for that off-normal procedure. Procedural entry condition 1.1 is a receipt of warning of impending hurricane or tornado with probable impact on station confirmed from Transmission Control Center or Generation Power Dispatcher. The NWS issues a Tornado Warning when a tornado is indicated by radar or sighted by spotters. Step 3.3.3 states, If hurricane/tornado approaching, perform section 3.4. Section 3.4 states, If impending hurricane or tornado impact probable and wind velocity < 50 mph 10 meters above ground, perform following: Call in appropriate personnel to support imminent emergency efforts as required; initiate a walk down of outside areas for loose material/debris such as wood planks, plywood, sheet metal, scaffold planks or material in dumpsters that can be potential missiles; contact PPL Electric Utilities and request a walk down of the 500KV and 230KV switchyards for potential missiles; and notify maintenance to install locking pins on the Unit 1 and Unit 2 Reactor Building Cranes. PPL did not enter this ON procedure during the forecast period of inclement weather when the NWS warnings and advisories were in effect.

The inspectors concluded that, procedurally, PPL would not take anticipatory actions until there is a confirmed tornado and that tornado has probable impact on the station.

This approach was determined to be inadequate given that the touchdown of a tornado with probable impact on the station did not allot sufficient time to take preventive measures or mitigating actions and that a proactive approach to acts of nature was warranted. Additionally, proactive entry into this procedure would have enabled PPL to consider the increased risk of relocating a dry fuel cask from the spent fuel pool to the refueling floor under these conditions since ON-000-002 directs the installation and engagement of locking pins on the reactor building cranes. Finally, the inspectors determined that the procedure had received its periodic review in 2011 and that PPL had missed an opportunity to identify the inadequacy at that time. Specifically, PPL did not identify that the Off Normal procedure was inadequate either during the 2011 periodic procedural review or during documentation of inspector observations in May 2012 as part of 1579977. PPL entered this item in their CAP as CR 1628452.

Analysis.

An inadequate procedure for addressing acts of nature was a performance deficiency within PPLs ability to foresee and correct. The issue was evaluated in accordance with IMC 0612 and determined to be more than minor since it affected the procedure quality attribute of the Initiating Events cornerstone and its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure prevented PPL from taking proactive steps to limit the likelihood of high wind or tornado-related missile hazards upsetting plant electrical power systems. The finding screened to Green in accordance with IMC 0609, Attachment 4 and Appendix A, Exhibit 1, since it did not cause a reactor trip, involve the complete or partial loss of mitigation or support equipment, or impact the frequency of a fire or internal flooding event.

The finding was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution - CAP because PPL did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance.

Specifically, PPL did not identify that the Off Normal procedure was inadequate either during the 2011 periodic procedural review or during documentation of inspector observations in May 2012. P.1(a)

Enforcement.

TS 5.4.1.a, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33, Revision 2, Appendix A. RG 1.33, Appendix A lists safety-related activities that should be covered by written procedures. Section 6 identifies procedures for combating emergencies and other significant events among which is 6.w Acts of Nature (e.g. tornado, flood, dam failure, earthquakes). Contrary to the above, prior to September 2012, PPL did not maintain an adequate procedure to respond proactively to acts of nature, specifically high winds and tornadoes. Since this issue was entered into PPLs CAP as CR 1628452, it is being treated as an NCV in accordance with Section 2.3.2 of the NRCs Enforcement Policy. (NCV 05000387;388/2012004-01, Inadequate Procedure for Acts of Nature)

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Unit 1, 125 VDC batteries during B emergency service water (ESW) pump unavailability Common, E EDG aligned for B EDG during overhaul Common, A control structure (CS) chiller during B CS chiller maintenance 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, TSs, work orders (WOs), CRs, 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 PPL staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On July 18 and 19, 2012, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 reactor core isolation cooling (RCIC) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication, equipment cooling, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure PPL appropriately evaluated and resolved any deficiencies.

b. Findings

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 (OOS),degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Unit 1, remote shutdown panel room (I-109), Fire Zone 1-2D Unit 2, residual heat removal (RHR) pump room A (II-14), Fire Zone 2-1F Unit 2, high pressure coolant injection (HPCI) Fire Zone 2-1C Common, emergency safeguards service water (ESSW) pump house loops A and B, Fire Zones 0-51 and 0-52 Common, heating and ventilation equipment rooms (Fire Zones 0-29A through 0-29D),

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.2 Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection 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, including electrical vaults VA011 and VA006, and manhole MH032 containing power cables, 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.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

Heat Sink Annual Review (71111.07A - 1 sample)

a. Inspection Scope

The inspectors reviewed documents associated with maintenance for the Unit 1, A HPCI room cooler to determine its readiness and availability to perform its safety functions. This review was performed to ensure the performance capability for the HPCI room cooler was consistent with design assumptions. The inspectors verified that PPL initiated appropriate corrective actions for identified deficiencies. Additionally, the inspectors reviewed the WOs associated with the latest as-found maintenance inspection for the HPCI room cooler to evaluate whether maintenance procedures were adequate to ensure the minimum assumed design heat removal capability.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on August 14 and 21, 2012, which included a loss of startup bus 20, loss of the 1D Engineering Safeguard System (ESS) bus, and an auxiliary bus undervoltage load shed. 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 (EOPs). 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 TS 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.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed control room operators during a substitution of the B EDG for the E EDG that placed both units in Orange risk on September 15, 2012, a period of heightened activity and risk. The inspectors observed the crew during the evolution to verify that procedure use, crew communications, and coordination of activities in the control room met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, 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 (a)(2) performance criteria established by PPL staff was reasonable. As applicable, for SSCs classified as (a)(1), 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.

Common, breaker failure during E EDG swap for B EDG Common, ground fault causes loss of reactor Load Centers 1B270/280

b. Findings

Introduction.

A self-revealing Green finding against PPL procedure NDAP-QA-0510, Troubleshooting Plant Equipment, was identified when inadequate troubleshooting caused repeated inoperability of secondary containment, an associated unplanned Unit 2 entry into a 4-hour limiting condition for operation (LCO) action statement, and a loss of the 1C FPC pump during equipment restoration. The FPC pump had been designated as protected equipment by station procedures as a risk management action.

Description.

On April 13, 2012, Load Center (LC) feeder breaker 1B27012 tripped twice on a ground fault while LCs 1B270 and 1B280 were cross-tied. The 480VAC LCs were cross-tied to support plant modifications during Unit 1s refueling outage. The first trip occurred approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the LCs were cross-tied and the second trip occurred approximately 20 minutes after attempts to re-energize the LCs.

The loss of both LCs impacted secondary containment in that both reactor building (RB)heating, ventilation, and air conditioning (HVAC) Zone I equipment compartment exhaust fans tripped due to the loss of power. This in turn caused the supply and exhaust fans for Zone I to trip and Zone I secondary containment differential pressure to drop below the required negative differential pressure of 0.25" water. This rendered Unit 2 secondary containment inoperable and necessitated entry into Unit 2 TS 3.6.4.1 since Zone I was not isolated from the recirculation plenum. Additionally, the power loss impacted Unit 1 Zone III supply fans and unfiltered exhaust fans which caused Zone III differential pressure to drop below its own 0.25" water requirement. Unit 1 was in Mode 5, not performing core alterations, nor any operations with a potential for draining the reactor vessel (OPDRV). Therefore, TS 3.6.4.1 was not applicable for Unit 1. Finally, the loss of the LCs also caused the 1C FPC to trip.

Operators responded by aligning Unit 2 Zone III ventilation to carry the zone for both units, shutting down Unit 1 Zone III filtered exhaust fans, and isolating Zone I from the recirculation plenum since Unit 1 secondary containment was not required for the given plant conditions.

Engineering developed a troubleshooting plan in accordance with procedure NDAP-QA-0510, Troubleshooting Plant Equipment, Revision 6. Electrical maintenance inspected the LC feeder breaker, the Zone III 1A supply fan breaker, and the 1C277 A through D heaters. Electrical maintenance completed their troubleshooting activities on April 15, 2012. Faulty Unit 1 Zone III ventilation heaters were identified and electrically isolated by pulling their respective fuses.

On April 23, 2012, operators attempted to restore non-faulted Zone III ventilation heaters due to concerns that Zone III air temperatures were approaching the lower limits.

Restoration of the load center was conducted outside of the troubleshooting plan with the load centers cross-tied. During the restoration, breaker 1B27012 tripped again on ground fault and the loss of the LC caused Unit 1 and Unit 2 Zone III differential pressure to drop below the required 0.25 water requirement. Unit 2 secondary containment was again declared inoperable and TS 3.6.4.1 was entered, placing Unit 2 in a 4-hour shutdown LCO due to loss of LC-fed HVAC loads. The loss of the LCs also caused a repeat trip of the 1C FPC pump except that the pump had now been designated as protected equipment as a risk management action since the spent fuel pool (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 />. Given the previous two trips on April 13th and the troubleshooting conclusion that this was an intermittent fault, it was reasonable to expect that PPL staff take actions to place ventilation and spent fuel pool cooling in an alternate line up to protect that equipment in case the bus was lost again.

However, the operators did not consider this and it resulted in an additional loss of secondary containment ventilation, 1C FPC pump, and another unplanned LCO entry.

The inspectors reviewed two apparent cause evaluations (ACEs) that were completed for the April 15 and April 23 trips. The second ACE determined that the troubleshooting plan was limited in scope due to the desire to limit interruption to refueling floor work and pose minimal risk to the operating units Zone III HVAC. The troubleshooting plan did not identify the individual LC supply breakers as a possible cause and only their downstream loads were suspected. NDAP-QA-0510, Troubleshooting Plant Equipment, Revision 6, Section 2 states, in part, that troubleshooting is a structured process to systematically identify equipment and system problems, their causes, and the necessary actions to resolve the problem. NDAP-QA-0510, Attachment A states, in part, that recurring faults may be either complete, partial, or intermittent. While the troubleshooting plan classified the heater fault as intermittent in nature, the troubleshooting did not identify all of the faulted heaters and PPL did not account for this by ensuring that system configuration at the time of the equipments restoration would not result in the subsequent loss of secondary containment or protected equipment.

Additionally, the inspectors identified that the second ACE did not identify and consider the impact of the FPC pumps protected status during the assessment of the events actual consequences. PPL entered this issue into their CAP as condition report CR 1628250.

Analysis.

The failure to perform adequate troubleshooting activities per NDAP-QA-0510 to identify and correct equipment problems prior to restoration was a performance deficiency that was within PPLs ability to foresee and prevent. The inspectors determined that the finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity cornerstone and adversely affected its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the events resulted in the inoperability of secondary containment and the loss of a FPC pump. The finding was evaluated in accordance with IMC 0609, Attachment 4 and Appendix A - Exhibit 3, and was determined to be of very low safety significance (Green)because the finding did not only represent a degradation of the radiological barrier function provided for the standby gas treatment system and it did not: a) cause the spent fuel pool to exceed a maximum temperature limit; b) cause mechanical fuel damage and detectable release of radionuclides; c) result in the loss of spent fuel pool water inventory; or d) affect spent fuel shutdown margin.

This finding is related to the cross-cutting area of Human Performance - Decision-Making because PPL did not make safety-significant or risk-significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. Specifically, PPL failed to restore equipment in a systematic manner, given the intermittent nature of heater faults, to preclude a repeated loss of protected equipment and secondary containment. H.1(a)

Enforcement.

This finding does not involve enforcement action because no violation of regulatory requirements was identified. Because this finding does not involve a violation and is of very low safety significance, it is identified as a FIN. (FIN 05000387;388/2011004-02, Inadequate Troubleshooting Results in Loss of Secondary Containment and Protected Equipment)

1R13 Maintenance Risk Assessments and Emergent Work Control

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 stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Common, swap E EDG for D EDG and failure of breaker to close Common, yellow risk during Division I ESW pump testing Common, orange risk during swap of E EDG for B EDG Common, Division II ESW OOS with E EDG unavailable for substitution

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50.65(a)(4) when PPL did not implement risk management actions (RMAs) during maintenance as required by station procedures. The inspectors identified multiple examples of PPL non-compliance with 10 CFR 50.65(a)(4) and PPLs implementing procedures NDAP-QA-0340, Protected Equipment Program, Revision 17, and NDAP-QA-1902, Integrated Risk Management, Revision 9.

Description.

First, on July 24, 2012, PPL performed TP-054-065, Pump Curve for Division I ESW Pumps, Revision 12. PPLs equipment out-of-service (EOOS) risk assessment of the procedure yielded Yellow risk on both Units. However, because the duration was less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, no equipment was required to be protected per NDAP-QA-0340, step 6.2.1 as a RMA. When inspectors requested to review the NDAP-QA-1902, Integrated Risk Assessment for this work activity, PPL could not provide it since it had not been performed. When PPL subsequently performed that assessment, the risk was determined to be Medium Operational risk. Where assessed risk is Medium or High, NDAP-QA-1902, step 6.4.1 requires the staff to consider those RMAs listed in Appendix D, Section 1; determine the RMAs to be used; and document the RMAs selected on Attachment E. The inspectors additionally identified that NDAP-QA-0340, G, step 5, requires protection of the available ESW loop when the other ESW loop is unavailable. This requirement is active when the calculated heatup rate associated with the SFP reaching 200 degrees F is less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The inspectors inquired as to whether the other ESW loop had been protected during completion of TP-054-065 and PPL confirmed that it had not. PPL entered these issues in their CAP as CRs 1601929, 1602495, and 1611876. PPLs short term corrective actions included protecting an ESW loop during the same test on the opposite division of ESW during procedure TP-054-066, on August 25.

Second, on August 13, 2012, the Unit 2 Division I RHR loop was taken OOS for maintenance. That maintenance included work on the breaker associated with the loops minimum flow valve. The inspectors noted that NDAP-QA-0340, Attachment G, step 4, requires that when the SFPs are cross-tied, their time to reach 200 degrees F is less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the A loop of RHR on either unit is unavailable, then the other units A loop of RHR must be protected. Under that condition, the procedure also requires that the supporting residual heat removal service water (RHRSW) and ESW loops be protected. The inspectors inquired as to whether those systems had been protected in accordance with the procedure and PPL confirmed that they had not. PPL entered this issue into their CAP as CR 1611044.

Finally, on July 30, 2012, five vent monitoring system particulate, iodine, and noble gas (SPING) sample pumps were being taken OOS sequentially for maintenance. The vent monitoring systems are used to identify unplanned or uncontrolled releases to the environment. At the time of the schedule review, the standby gas treatment system (SGTS) SPING had already been taken OOS. On the schedule, only the Unit 1 RB SPING was annotated as an Emergency Preparedness (EP) risk item. The inspectors inquired as to why only one SPING met this criterion. A subsequent review by PPL determined that the other four SPING WOs had been improperly reviewed for risk in accordance with NDAP-QA-1902, Attachment C. PPL re-performed the risk screenings for all five SPINGS, determined them all to be Medium EP risk and implemented RMAs from NDAP-QA-1902, Attachment D that included consulting the EP manager to determine additional actions to manage risk, evaluating redundant components required to support the activity, providing field supervisory monitoring of the activity, and verifying pre-planned alternate measures are available. PPL entered this issue into their CAP as CR 1604007.

Analysis.

Not performing RMAs for maintenance activities in accordance with station procedures was a performance deficiency within PPLs ability to foresee and correct.

The finding was more than minor since it was similar to IMC 0612, Appendix E examples 7.e and 7.f. Specifically, elevated plant risk required RMAs or additional RMAs that were not implemented as required by plant procedures. The finding also affected the equipment performance attribute of the Mitigating Systems Cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Attachment 4, the issue was determined to involve PPLs assessment and management of risk associated with performing maintenance activities and was further assessed under IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management SDP. The issue was evaluated by a Senior Reactor Analyst utilizing flowchart 2, and the finding was determined to be of very low safety significance (Green) because it did not result in an increase to either the ICDP or to the ILERP.

The finding was determined to have a cross-cutting aspect in the area of Human Performance, Work Control, in that PPL did not plan work activities, consistent with nuclear safety, by incorporating risk insights. Specifically, PPL did not incorporate RMAs into its work activities despite recognition of increased risk. H.3(a)

Enforcement.

10 CFR 50.65(a)(4) states, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. PPL procedures NDAP-QA-1902, Maintenance Rule Risk Assessment and Management Program, Revision 2, and NDAP-QA-0340, Protected Equipment Program, Revision 8, implement the requirements of 10 CFR 50.65(a)(4) at the station. Contrary to the above, during the months of July and August 2012, there were multiple instances of inadequate implementation of RMAs while maintenance was conducted. Because of the very low safety significance of this finding and because the finding was entered into PPLs CAP as CRs 1611044, 1604007, 1601929, 1602495, and 1611876, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000387;388/2012004-03, Failure to Implement Risk Management Actions)

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

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

Unit 1, anomalies of A steam pressure regulator and 1, 2, and 3 bypass valves Unit 2, reactor recirculation loop decontamination connections Unit 2, HPCI water hammer during comprehensive flow verification Common, passive fire barrier qualification Common, settlement monitoring of the ESSW pump house 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 TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PPLs 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. Findings

No findings were identified.

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

The inspectors evaluated a modification to the Zone III exhaust system on Units 1 and 2 implemented by engineering change 1495468, Close and Block Dampers HD17534C and HD27534C. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification.

In addition, the inspectors reviewed modification documents associated with the upgrade and design change. The inspectors also reviewed revisions to station documents and interviewed engineering personnel.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests (PMTs) 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 and/or 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.

Unit 1, B control rod drive (CRD) pump motor after modification to breaker controls Unit 2, RHR B loop Division II after pressure safety valve (PSV) replacement and electrical maintenance Unit 2, RHR D loop after socket weld leak on suction piping Common, motor-driven fire pump after discharge check valve maintenance Common, E EDG intercooler PSV01126E replacement Common, B EDG 5 year inspection and overhaul Common, B CS chiller following piping and valve work Common, A control room emergency outside air supply system (CREOAS) following hydramotor replacement (HDM07811A)

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, 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:

Unit 1, SO-151-A02, quarterly core spray Division II flow verification Unit 1, SO-100-010, monthly Zone I integrity verification Unit 2, SO-249-B02, RHR Division II quarterly flow verification Common, SO-024-014, monthly EDG E operability test Common, SO-070-001, monthly standby gas treatment

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

This area was inspected to:

(1) review and assess PPLs performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring (RM) and exposure control measures for both individual and collective exposures,

(2) verify PPL is properly identifying and reporting Occupational Radiation Safety cornerstone performance indicators (PIs), and

(3) identify those performance deficiencies that were reportable as a PI and which may have represented a substantial potential for overexposure of the worker.

During August 20 to 24, 2012, the inspectors interviewed the radiation protection manager (RPM), performed walkdowns of various portions of the plant, and reviewed PPL documents. The inspectors used the requirements in 10 CFR Part 20 and guidance in RG 8.38 Control of Access to High and Very High Radiation Areas (VHRAs) for Nuclear Plants, the TSs, and PPLs procedures required by TSs as criteria for determining compliance.

a. Inspection Scope

Instructions to Workers The inspectors selected five containers containing non-exempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers. The inspectors assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements.

Contamination and Radioactive Material Control The inspectors reviewed PPLs procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters.

Risk-Significant High Radiation Area (HRA) and Very High Radiation Area Controls The inspectors evaluated PPL controls for VHRAs and areas with the potential to become a VHRA to ensure that an individual was not able to gain unauthorized access to these areas.

Problem Identification and Resolution The inspectors reviewed CRs associated with RM and exposure control and verified SSESs problems were identified at an appropriate threshold and were properly addressed for resolution. The inspectors specifically evaluated the investigation and resolution for the contaminated transfer trailer issue and the associated CR 1606682.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

This area was inspected August 20 to 24, 2012, to ensure occupational dose is appropriately monitored and assessed. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.13 - Instructions Concerning Prenatal Radiation Exposures, RG 8.36 - Radiation Dose to Embryo Fetus, RG 8.40 - Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and PPLs procedures required by TSs as criteria for determining compliance.

a. Inspection Scope

Inspection Planning

The inspectors reviewed the results of SSES radiation protection program audits related to internal and external dosimetry. The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report on PPL and PPLs vendors most recent results to determine the status of the accreditation.

A review was conducted of PPLs procedures associated with dosimetry operations, including issuance/use of external dosimetry, assessment of internal dose, and evaluation of dose assessments for radiological incidents.

The inspectors evaluated whether PPL had established procedural requirements for determining when external dosimetry and internal dose assessments are required.

External Dosimetry The inspectors evaluated whether PPL and PPLs dosimetry vendor is NVLAP accredited and if the approved irradiation test categories for each type of personnel dosimeter used are consistent with the types and energies of the radiation present and the way the dosimeter is being used.

The inspectors evaluated the onsite storage of dosimeters before issuance, during use, and before processing/reading. The inspectors also reviewed the guidance provided to radiation workers with respect to care and storage of dosimeters.

PPL does not use non-NVLAP accredited passive dosimeters.

The inspectors assessed the use of electronic personal dosimeters to determine if PPL uses a correction factor to address the response of the electronic personal dosimeter as compared to the dosimeter of legal record for situations when the electronic personal dosimeter is used to assign dose and whether the correction factor is based on sound technical principles.

The inspectors reviewed four dosimetry occurrence reports or CAP documents for adverse trends related to electronic personal dosimeters. The inspectors assessed whether PPL had identified any adverse trends and implemented appropriate corrective actions.

Internal Dosimetry

Routine Bioassay (In Vivo)

The inspectors reviewed procedures used to assess the dose from internally deposited radionuclides using whole body counting equipment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, determining the route of intake and the assignment of dose.

The inspectors reviewed the whole body count (WBC) process to determine if the frequency of measurements was consistent with the biological half-life of the radionuclides available for intake.

The inspectors reviewed PPL's evaluation for use of its portal radiation monitors as a passive monitoring system. The inspectors assessed if instrument minimum detectable activities were adequate to determine the potential for internally deposited radionuclides sufficient to prompt an investigation.

The inspectors selected three WBCs and evaluated whether the counting system used had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspectors reviewed the radionuclide library used for the count system to determine if it included the gamma-emitting radionuclides that exist at the site. The inspectors evaluated how PPL accounts for hard-to-detect radionuclides in their internal dose assessments, if applicable.

Special Bioassay (In Vitro)

The inspectors selected two internal dose assessments obtained using whole body counting. The inspectors reviewed and assessed the adequacy of PPLs program for urinalysis of radionuclides including collection and storage of samples.

The inspectors reviewed the vendor laboratory quality assurance program and assessed whether the laboratory participated in an industry recognized cross-check program including whether out-of-tolerance results were reviewed, evaluated, and resolved appropriately.

Internal Dose Assessment - Airborne Monitoring

PPL had not performed any internal dose assessments using airborne/derived air concentration monitoring during the period reviewed.

Internal Dose Assessment - Whole Body Count Analyses The inspectors reviewed several dose assessments performed by PPL using the results of WBC analyses. The inspectors determined whether affected personnel were properly monitored with calibrated equipment and that internal exposures were assessed consistent with PPL's procedures.

Special Dosimetric Situations Declared Pregnant Workers The inspectors assessed whether PPL informs radiation workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.

The inspectors reviewed the records for two individuals who had declared pregnancy during the current assessment period and evaluated whether PPLs radiological monitoring program (internal and external) for declared pregnant workers is technically adequate to assess the dose to the embryo/fetus. The inspectors reviewed exposure results and monitoring controls that were implemented.

Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures The inspectors reviewed PPLs methodology for monitoring external dose in non-uniform radiation fields or where large dose gradients exist. The inspectors evaluated PPL's criteria for determining when alternate monitoring, such as use of multi-badging, is to be implemented.

The inspectors reviewed selected dose assessments performed using multi-badging to evaluate whether the assessment was performed consistent with PPL procedures and dosimetric standards.

Shallow Dose Equivalent

The inspectors reviewed two dose assessments of shallow dose equivalent for adequacy. The inspectors evaluated PPLs method (e.g., VARSKIN or similar code) for calculating shallow dose equivalent from distributed skin contamination or discrete radioactive particles.

Assigning Dose of Record

For the special dosimetric situations reviewed in this section, the inspectors assessed how PPL assigns dose of record for total effective dose equivalent (TEDE), shallow dose equivalent, and lens dose equivalent (LDE). This included an assessment of external and internal monitoring results, supplementary information on individual exposures, and radiation surveys when dose assignment was based on these techniques.

Problem Identification and Resolution The inspectors assessed whether problems associated with occupational dose assessment are being identified by PPL at an appropriate threshold and are properly addressed for resolution in PPLs CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by PPL involving occupational dose assessment.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Safety System Functional Failure (2 samples)

a. Inspection Scope

The inspectors sampled PPLs submittals for the Safety System Functional Failures performance indicator for both Unit 1 and Unit 2 for the period of January 2011 through June 2012. To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed PPLs operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, condition reports, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index (MSPI) (2 samples)

a. Inspection Scope

The inspectors reviewed PPLs submittal of the MSPI for the following systems for the period of October 2011 through May 2012:

Units 1 and 2, Heat Removal System To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment PI Guideline, Revision 6. The inspectors also reviewed PPLs operator narrative logs, CRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.3 Reactor Coolant System (RCS) Specific Activity (2 samples)

a. Inspection Scope

The inspectors reviewed PPLs submittal for the RCS specific activity performance indicator for both Unit 1 and Unit 2 for the period of April 2011 through March 2012. 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.

b. Findings

No findings were identified.

.4 Occupational Exposure Control Effectiveness (1 sample)

a. Inspection Scope

The inspectors reviewed implementation of PPLs Occupational Exposure Control Effectiveness PI Program. Specifically, the inspectors reviewed recent condition reports, and associated documents, for occurrences involving locked HRAs, VHRAs, and unplanned exposures against the criteria specified in NEI 99-02, Regulatory Assessment PI Guideline, to verify that all occurrences that met the NEI criteria were identified and reported as PIs. This inspection activity represents the completion of one

(1) sample relative to this inspection area; completing the annual inspection requirement.

b Findings No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of PI&R Activities

a. Inspection Scope

As required by Inspection Procedure 71152, PI&R, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PPL entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In 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 CR screening meetings.

b. Findings

No findings were identified.

.2 Annual Sample: Review of the Operator Workaround Program

a. Inspection Scope

The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in PPL procedure OI-AD-096, Operator Burdens, Revision 8.

The inspectors reviewed PPLs process to identify, prioritize, and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent PPL self assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

b. Findings and Observations

No findings were identified.

The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.

The inspectors also verified that PPL entered operator workarounds and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report (LER) 05000387/2011-004-00: C Emergency Diesel

Generator Inoperable

a. Inspection Scope

On December 6, 2011, PPL declared the C EDG inoperable due to loss of firing from cylinder 8R during surveillance testing. TS 3.8.1 was entered until the E EDG was substituted for the C EDG. A review of past maintenance on the C EDG determined that it was inoperable from the time maintenance was performed on September 21, 2011 until it was shutdown on December 6, 2011, because it could not have fulfilled its mission time. The cause of the loss of firing was incorrect installation of the delivery valve spring that resulted in interruption of the spray pattern in the fuel injection nozzle and partial blockage. As a consequence of the inoperability, a condition prohibited by TS 3.8.1 occurred. PPL identified the root causes of this event to be that: 1) the work package to install delivery valve springs was insufficient, 2) the work crew proceeded using an inadequate work package, and 3) QC activities were insufficient to prevent the incorrect reassembly of the fuel injector pump components. The inspectors reviewed this LER, and the root cause analysis (RCA) and corrective actions associated with this event. This LER is closed.

b. Findings

An NRC-identified Green FIN (FIN 05000387;388/2011005-01; Failure to Properly Implement Work Instructions Results in C EDG Inoperability) associated with this LER was documented in IR 05000387;388/2011-005. Section 4OA5 of this report provides additional information on the status of that finding and subsequent enforcement.

4OA5 Other Activities

.1 NRC Office of Investigations Report 1-2012-017

In December 2011, NRC inspectors identified a failure to meet TS requirements for properly planning and implementing work instructions on the C EDG and the potential existed that this may have been a deliberate act. In response, the Region I Field Office, NRC Office of Investigations (OI), initiated an investigation on January 6, 2012, to determine whether maintenance technicians and a Quality Control (QC) inspector, employed by PPL at Susquehanna, deliberately failed to implement those work instructions during the assembly of delivery valves on 15 fuel pumps. Based on testimonial and documentary evidence gathered during the investigation the investigators concluded that while violations of TS requirements had occurred, improper planning and implementation of work instructions was identified as the cause and that the technicians and QC inspector did not deliberately fail to perform the maintenance.

The safety significance of the violation was previously evaluated by the NRC and documented in NRC Inspection Report 05000387;388/2011005 as a Green finding (FIN 05000387;388/2011005-01; Failure to Properly Implement Work Instructions Results in C EDG Inoperability). The enforcement aspects of that finding were held open pending the completion of the NRC OI Investigation. While this finding involved a violation of NRC requirements, the NRC has determined that this issue is an NCV in accordance with the Enforcement Policy since it was of very low safety significance, PPL has entered this issue into their CAP, it was not repetitive or willful, and compliance was restored in a reasonable period of time. The finding and associated violation, although dispositioned separately, only count as one input into the plant assessment process.

The enforcement section of the original finding is amended as follows.

Enforcement.

Susquehanna Units 1 and 2 TS Section 5.4.1, requires, in part, that procedures be established, implemented, and maintained for those recommended in Regulatory Guide 1.33. RG 1.33, Appendix A, section 9, states, in part, Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, on September 21, 2011, PPL did not properly plan and implement work instructions and QC hold point inspections on the C EDG. This also resulted in violations of 10 CFR 50, Appendix B, Criterion X, Inspection and TS 3.8.1, AC Sources - Operating, since the C EDG exceeded the TS allowed outage time. Because of the very low safety significance of this finding and because the finding was entered into PPLs CAP (ARs:

1226969, 1226202, 1299543, 1299476, 1302720, and 1303308), it is being treated as an NCV in accordance with Section 2.3.2 of the NRCs Enforcement Policy. (NCV 05000387;388/2011005-01;05000278/2011005-02; Failure to Properly Implement Work Instructions Results in C EDG Inoperability)

.2 Temporary Instruction 2515/187 - Inspection of Near-Term Task Force

Recommendation 2.3 - Flooding Walkdowns On August 6, 2012, inspectors commenced activities to independently verify that PPL conducted external flood protection walkdown activities using an NRC-endorsed walkdown methodology. These flooding walkdowns are being performed at all sites in response to Enclosure 4 of a letter from the NRC to licensees entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ADAMS Accession No.

ML12053A340). The results of this temporary instruction will be documented in a future inspection report.

.3 Temporary Instruction 2515/188 - Inspection of Near-Term Task Force

Recommendation 2.3 - Seismic Walkdowns On July 19, 2012, inspectors commenced activities to independently verify that PPL conducted seismic walkdown activities using an NRC-endorsed seismic walkdown methodology. These seismic walkdowns are being performed at all sites in response to 3 of a letter from the NRC to licensees entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ADAMS Accession No.

ML12053A340). When complete, the results of this temporary instruction will be documented in a future inspection report.

.4 Operation of an ISFSI at Operating Plants (IP 60855 and 60855.1)

a. Inspection Scope

The inspectors observed and evaluated the licensees loading of the third canister associated with PPLs current ISFSI dry cask campaign. The inspectors verified compliance with the Certificate of Compliance (CoC), TS, regulations, and licensee procedures. The inspectors also reviewed PPLs activities related to long-term operation and monitoring of the ISFSI.

The inspectors observed the heavy load movement of the transfer cask and loaded dry shielded canister (DSC) from the spent fuel pool to the cask washdown area next to the spent fuel pool. The inspectors also observed DSC processing operations including:

decontamination and surveying, welding, non-destructive weld examinations, DSC draining, and vacuum drying. During performance of the activities, the inspectors evaluated PPLs familiarity with procedures, supervisory oversight, and communication and coordination between the personnel involved. The inspectors also reviewed loading and monitoring procedures and evaluated PPLs adherence to these procedures.

The inspectors performed a walk-down of the heavy haul path and toured the ISFSI pad to assess the material condition of the pad and the loaded horizontal storage modules.

The inspectors also reviewed the as low as is reasonably achievable (ALARA) goal for the loading of the cask to determine the adequacy of PPLs radiological controls and to ensure that radiation worker doses were ALARA and that project dose goals could be achieved.

The inspectors attended PPL briefings to assess their ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors.

The inspectors reviewed PPLs program associated with fuel characterization and selection for storage. The inspectors reviewed cask fuel selection packages and the video recording of the canister to verify that PPL was loading fuel in accordance with the CoC and TS. PPL did not plan to load any damaged fuel assemblies during this campaign.

The inspectors reviewed corrective action reports and the associated follow-up actions that were generated since the last ISFSI inspection to ensure that issues were entered into the corrective action program, prioritized, and evaluated commensurate with their safety significance. The inspectors also reviewed PPLs 10 CFR 72.48 screenings.

b Findings No findings were identified.

4OA6 Meetings, Including Exit

On August 24, 2012, the inspectors presented the inspection results to Mr. J. Helsel, Plant Manager and Acting Site Vice President, and other members of the staff.

On September 21, 2012, the inspectors presented the inspection results to Mr. J. Helsel, Plant Manager and Acting Site Vice President, and other members of the staff.

On October 16, 2012, the inspectors presented the inspection results to Mr. T. Rausch, Chief Nuclear Officer (CNO) and other members of the PPL staff. PPL acknowledged the findings. No proprietary information is contained in this report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by PPL and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

On September 27, 2011, PPL declared the 10-meter wind direction instrument on the primary meteorological tower inoperable when indications showed, as confirmed by the vendor; the wind direction data was inconsistent with known weather responses.

EP-TP-007, Equipment Important for Emergency Plan Implementation, states compensatory measures for an out of service Meteorological Tower include notifying the control room of potential Emergency Notification System (ENS) notifications, ensuring the availability of the backup and/or Nescopeck towers, using onsite observations by personnel and obtaining external meteorological information. The control room verified and notified the Nuclear Emergency Response Organization (NERO) Duty Planner that the compensatory measures identified in EP-TP-007 were available. However, the NERO was not notified of the meteorological tower 10-meter wind direction indication being inoperable. In addition, the wind direction indication on the plant computer system continued to display a yellow status color indicating valid data was available for use. Because the NERO was unaware the 10-meter wind direction indication on the primary meteorological tower was erroneous, the inaccurate meteorological information on the plant computer system could have been used by the NERO to make emergency classifications, perform dose projections, and make protective action recommendations (PAR). Although the data from the backup meteorological tower would have been available there were no stimuli that would have caused the NERO to use that data instead. PPLs RCA determined the cause of not notifying the NERO was due to the lack of specific procedural guidance defining the conditions for which the duty NERO personnel should be notified when equipment important to EP was out of service or inoperable.

This issue was determined to be a violation of 10 CFR 50.54(q)(2), which requires licensees follow and maintain the effectiveness of an emergency plan that meets the planning standards in 50.47(b). 10 CFR 50.47(b)(9) requires the use of adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition. Contrary to the above, from September 27 through September 30, 2011, PPL did not maintain an adequate method for accurately calculating dose projections and issuing PARS to offsite agencies. In accordance with IMC 0609, Appendix B, Attachment 2, and the examples contained in Table 5.9-1, the inspectors determined the finding was Green since the meteorological tower was not functional for longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time of discovery without adequate compensatory measures. The finding was not greater than Green since the capability for immediate dose projection existed via alternate meteorological towers. The issue was entered in PPLs CAP as CR 1541932.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Boika, Nuclear Operations

M. Christopher, Nuclear Operations Support

S. DiPalma, Nuclear Field Services

L. Fuller, Design Engineer

C. Goff, Nuclear Training Director

J. Goodbred Jr., Nuclear Operations Manager

K. Griffith- Nuclear Training

M. Hanover, Senior Engineer

J. Helsel, Plant General Manager and Acting Site Vice President

J. Hirt, Supervisor, Reactor Engineering

T. Hess, Journeyman Electrician

F. Hickey, Chemistry Support Senior Health Physicist

D. Karchner, Refuel Floor Manager

A. Klopp, Senior Engineer

J. Knorr, Maintenance Foreman

J. Lada, System Engineer

J. Lear, Nuclear Field Services

D. Lock, Manager, Nuclear Maintenance

T. Magrone, Chemistry

C. Manchester, Electrical Maintenance Supervisor

D. Marinos, Nuclear Operations

G. Merenich, Radiation Protection Instrument Foreman

J. Mirilovich, Reactor Engineering

S. Muntzenberger, Supervising Engineer

B. ORourke, Senior Engineer, Licensing

E. Ortuba, Health Physicist

S. Peterkin, Radiation Protection Manager

R. Rodriguez-Gillroy, Radiation Operations Supervisor

D. Smethers, Nuclear Field Services

W. Snyder, Electrician Leader

R. Takacs, Chemistry

D. Wright, Dry Fuel Storage Project Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Opened/Closed

05000387;388/2012004-01 NCV Inadequate Procedure for Acts of Nature (Section 1R01)

05000387;388/2012004-02 FIN Inadequate Troubleshooting Results in Loss of Secondary Containment and Protected Equipment (Section 1R12)

05000387;388/2012004-03 NCV Failure to Implement Risk Management Actions (Section 1R13)

Closed

05000387;388/2011005-01 NCV Failure to Properly Implement Work Instructions Results in C EDG Inoperability (Section 4OA5)

05000387/2011-004-00 LER C Emergency Diesel Generator Inoperable (Section 4OA3.1)