IR 05000387/2014003

NRC Integrated Inspection Report 05000387-14-003 and 05000388-14-003 and Exercise of Enforcement Discretion (April 1, 2014 - June 30, 2014)

ML14225A018
Person / Time
Site:	Susquehanna
Issue date:	08/13/2014
From:	Ho Nieh Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
BOWER, FL
References
EA-14-125, IR-14-003
Download: ML14225A018 (49)

Text

UNITED STATES ust 13, 2014

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED INSPECTION REPORT 05000387/2014003 AND 05000388/2014003 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Rausch:

On June 30, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES) Units 1 and 2. The enclosed integrated inspection report documents the inspection results, which were discussed on July 9, 2014, 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.

The report documents one NRC-identified violation of NRC requirements, which was of very low safety significance (Green). Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in the report. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2.a of the NRC Enforcement Policy. If 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 Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at SSES. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement 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 Senior Resident Inspector at SSES. Separately, a violation involving a failure to set secondary containment during operations with the potential to drain the reactor vessel (OPDRVs) was identified during the Unit 1 refueling outage. Specifically, from April 16, 2014, to May 23, 2014, while all other Technical Specifications (TSs) were met, PPL conducted several OPDRVs without establishing secondary containment operability, which is a violation of TS 3.6.4.1, Secondary Containment. NRC issued Enforcement Guidance Memorandum (EGM) 11- 003, Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor (BWR) Licensee Noncompliance with TS Containment Requirements during Operations with a Potential for Draining the Reactor Vessel, on October 4, 2011, allowing for the exercise of enforcement discretion for such OPDRV-related TS violations, when certain criteria are met. The EGM, which was most recently revised on December 13, 2013, also requires that, to be eligible for discretion, a licensee must submit a license amendment request (LAR) to accept the NRCs generic change to the standard TS that will allow a graded approach to OPDRV requirements. The LAR must be submitted within twelve months of NRC publication of the generic change in the Federal Register. Because the violation was identified during the discretion period described in EGM 11-003, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation, subject to a timely license amendment request being submitted.

In accordance with Title 10 of the Code of Federal Regulations (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 NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and 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/

Ho K. Nieh Director Division of Reactor Projects Docket Nos. 50-387 and 50-388 License Nos. NPF-14 and NPF-22

Enclosures:

Inspection Report 05000387/2014003 and 05000388/2014003 w/Attachment: Supplemental Information

REGION I==

Docket Nos. 50-387 and 50-388 License Nos. NPF-14 and NPF-22 Report Nos. 05000387/2014003 and 05000388/2014003 Licensee: PPL Susquehanna, LLC (PPL)

Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: April 1, 2014 through June 31, 2014 Inspectors: J. Greives, Senior Resident Inspector T. Daun, Resident Inspector N. Floyd, Reactor Inspector C. Graves, Health Physicist F. Arner, Senior Reactor Inspector T. Burns, Reactor Inspector B. Lin, Project Engineer Approved By: Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

IR 05000387/2014003, 05000388/2014003; 04/01/2014 - 06/30/2014; Susquehanna Steam

Electric Station (SSES), Units 1 and 2; Operability Determinations and Functionality Assessments.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green), which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, revised July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Barrier Integrity

Green.

An NRC-identified Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified for PPL's failure to identify conditions adverse to quality by not implementing timely actions to address the extent of a previously identified inoperable condition. Specifically, when a reactor core isolation cooling (RCIC) turbine exhaust line vacuum breaker failed its inservice test, PPL did not take timely actions in accordance with NDAP-QA-0702, Action Request and Condition Report Process, to test other valves that could be susceptible to the failure mechanism and, therefore, did not identify conditions adverse to quality in similar valves in a timely manner. PPL entered the issue into the corrective action program (CAP) as condition report (CR) 2014-17151 and tested all other susceptible valves. Additionally, degraded conditions that were identified were corrected prior to restoring the systems to service.

The finding was determined to be more than minor because it was associated with the structures, systems, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone and affected its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Inspectors determined the risk significance was bounded by the failure of the high pressure coolant injection (HPCI) turbine exhaust line vacuum breaker, which was stuck in a partially opened state. With the valve stuck in this state, failure of the redundant valve would have resulted in HPCI exhaust steam relieving directly to the suppression chamber air space affecting containment performance. The inspectors assessed the finding in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP)for Findings At-Power, dated June 19, 2012, and determined the finding to be of very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room, did not represent an actual open pathway in the physical integrity of reactor containment, and did not involve the actual reduction in function of hydrogen igniters in containment. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Resolution, because PPL did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance.

Specifically, despite properly identifying appropriate corrective actions while evaluating the extent of a condition adverse to quality, PPL failed to implement those actions in a timely manner resulting in the failure to identify and correct conditions adverse to quality in three similar valves. [P.3] (Section 1R15)

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 number are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at or near 100 percent rated thermal power. On April 4, 2014, operators lowered power on Unit 1 to 80 percent for planned rod pattern adjustment and power was returned to 100 percent the following day. On April 11, 2014, operators commenced a reactor shutdown on Unit 1 for a planned refueling outage. Following the completion of the maintenance activities, operators commenced a reactor startup on June 4, 2014. Power was restored to 100 percent on June 11, 2014. On June 13, 2014, operators reduced power to 70 percent for a planned rod pattern adjustment. Power was returned to 100 percent on June 15, 2014 and Unit 1 ended the inspection period at or near 100 percent power.

Unit 2 began the inspection period at or near 100 percent rated thermal power. On June 6, 2014, power was reduced to 64 percent on Unit 2 for a planned rod sequence exchange. Unit 2 was restored to 100 percent on June 9, 2014. On June 24, 2014, operators commenced a reactor shutdown on Unit 2 to perform repairs to the low pressure turbines. Unit 2 ended the inspection period in Mode

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed PPLs procedures affecting these areas and the communications protocols between the transmission system operator and PPL. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether PPL established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing CRs and open work orders (WOs), and walking down portions of the offsite and AC power systems including the 500 kilovolt (KV) and 230 KV switchyards. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Unit 1, Division II residual heat removal (RHR) with Division I aligned for shutdown cooling on April 25, 2014 Unit 1, System alignments during operations with the potential to drain the reactor vessel (OPDRVs) on April 21, 2014 Unit 1, A reactor recirculation pump (RRP) and support systems following motor replacement on May 17, 2014 Unit 2, Division I RHR and residual heat removal service water (RHRSW) during Division II RHRSW maintenance on June 19, 2014 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 Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), 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.

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, Reactor building steam tunnel (Fire Zone 1-4G) on May 25, 2014 Unit 1, Drywell (Fire Zone 1-4F) on April 24, 2014 Unit 1, A and B RHR pump rooms (Fire Zones 1-1E and 1-1F) on May, 28, 2014 Unit 1, Turbine building (TB) elevation 729 (Fire Zone 0-35A) on June 24, 2014 Common, Engineered safeguards service water (ESSW) pump house (Fire Zones 0-51 and 0-52) on May 5, 2014

b. Findings

No findings were identified.

1R07 Heat Sink Performance

Heat Sink Annual Review

a. Inspection Scope

The inspectors reviewed the Unit 1 B RHR heat exchanger on April 29, 2014, to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified PPLs commitments to NRC Generic Letter 89-13. 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. Findings

No findings were identified.

1R08 Inservice Inspection

a. Inspection Scope

From April 21, 2014, to April 25, 2014, the inspectors conducted an inspection and review of PPL staff implementation of inservice inspection (ISI) program activities for monitoring degradation of the reactor coolant system (RCS) boundary, risk significant piping and components, and containment systems during the SSES Unit 1 18th refueling outage (1R18). The sample selection for this inspection was based on the inspection procedure objectives and risk priority of those pressure retaining components in systems where degradation would result in a significant increase in risk. The inspectors observed in-process nondestructive examinations (NDE), reviewed documentation, and interviewed PPL personnel to verify that the NDE activities performed as part of the third interval, third period, of the SSES ISI program were conducted in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1998 Edition through 2000 Addenda.

NDE and Welding Activities The inspectors performed direct observation of NDE activities in process and reviewed documentation of NDEs listed below. Activities included review of ultrasonic testing (UT)and visual examination (VT).

The inspectors reviewed certifications of the NDE technicians performing the examinations and verified that the inspections were performed in accordance with approved NDE procedures and industry guidance. The inspectors verified that the test results were reviewed and evaluated by certified Level III NDE personnel and that the parameters used in the test were in accordance with the limitations, precautions and prerequisites specified in the test procedure.

ASME Code Required Examinations The inspectors performed direct observation of an automated UT of the N2K recirculation discharge nozzle-to-shell weld. The inspectors reviewed the test procedure, weld volume coverage, examination report, and test results, and noted that 100 percent code coverage was achieved. The test analysis and results were discussed with the respective Level III examiner.

The inspectors performed a documentation review of a manual UT of the RRP closure studs (1P401B-STUD-01 through -16). The inspectors also observed the site-specific performance demonstration for the NDE technician prior to the examination.

The inspectors performed direct observation of a VT of the RRP flange surface (1P401B-FLSUR) and verified that 100 percent coverage was obtained. SSES performed a partial examination on a similar component during the Unit 2 refueling outage in 2013 and requested relief from the ASME Code for not meeting the coverage requirements.

The inspectors performed direct observation of a VT of the underside of the reactor pressure vessel (RPV) head, including the flange surface which houses the O-rings for head-to-vessel closure.

The inspectors visually examined the condition of the primary containment liner surfaces on the 719, 738, and 752 elevations. Limited portions of the containment surfaces above and below the listed elevations were accessible for examination.

The inspectors also performed a document review of the containment VT records and compared those to the inspector walkdowns.

Other Augmented or Industry Initiative Examinations The inspectors sampled the remote enhanced VT records of reactor vessel internals as done under water inside the reactor vessel during in-vessel visual inspection (IVVI)activities. The inspection scope included portions of the jet pump wedges, slip joints, and steam dryers. The inspectors reviewed the applicable parts of the IVVI procedure, observation of a sample of digital video records, the analysis process for the observations, and documentation of indications. The inspectors verified that the activities were performed in accordance with applicable examination procedures and industry guidance.

Repair/Replacement Activities Including Welding Activities The inspectors performed a record review of the replacement activities associated with the Class 3, 4-inch diameter emergency service water piping, to verify that welding and applicable NDE activities were performed in accordance with ASME code requirements.

This section of emergency service water piping provides cooling to the emergency diesel generators (EDGs) and was being replaced due to a through-wall leak. The inspectors reviewed the weld procedures and welder qualifications and verified that welding was conducted according to the repair/replacement plan. The replacement activities were conducted with the unit on-line prior to 1R18 under job number 1655484.

The inspectors also performed a record review of the replacement activities associated with the Class 2 reactor water cleanup (RWCU) piping and valves that were being replaced with materials resistant to flow accelerated corrosion. Specifically, the inspectors looked at the welding activities for the sections of 3-inch and 4-inch diameter pipe, and valves that were being prefabricated prior to installation in the plant. The inspectors reviewed the weld procedures and welder qualifications, and required NDE to verify that the welding activities were performed in accordance with the ASME code requirements. The inspectors also reviewed the reconciliation documentation associated with the change in piping and valve body material. The replacement work was performed under job number 1704425.

Identification and Resolution of Problems The inspectors reviewed a sample of PPL corrective action reports, which identified NDE indications, deficiencies, and other nonconforming conditions since 1R17 and during the current refueling outage. The inspectors verified that nonconforming conditions were properly identified, characterized, and evaluated, and that corrective actions were identified and entered into the CAP for resolution.

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 June 16, 2014. 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 TS action statements entered by the senior reactor operator.

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 reactor shutdown and planned manual reactor scram for the

1R18 on April 12, 2014. The inspectors observed pre-shift briefings and reactivity

control briefings to verify that the briefings met the criteria specified in OP-AD-002, Standards for Shift Operations, Revision 51, OP-AD-004, Operations Standards for Error and Event Prevention, Revision 33, and OP-AD-338, Reactivity Manipulations Standards and Communications Requirements, Revision 24. Additionally, the inspectors observed crew performance to verify that procedure use, crew communications, and coordination of activities between work groups 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 SSC 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 the first sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR Part 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. For the second sample, inspectors reviewed PPLs assessment to ensure it met regulatory requirements.

Unit 1, Source range monitor failures Common, Post-maintenance testing using test travelers

b. Findings

No findings were identified.

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 Part 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.

Unit 1, D main steam isolation valve (MSIV) seat replacement on May 2, 2014 Unit 1, Yellow risk due to HV112F075B quick look in conjunction with E EDG OOS on June 6, 2014 Unit 2, Yellow risk due to loss of coolant accident/loss of offsite power (LOCA/LOOP)testing on Unit 1 on April 3, 2014 Unit 2, 1D643 battery charger inoperable due to high voltage output on April 30, 2014 Common, A EDG inoperable due to slow start on May 27, 2014

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

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

Unit 1, failure of A core spray pump to start and 1A TB chiller to trip during LOCA/LOOP TS surveillance testing on April 17, 2014 Unit 1, HPCI exhaust vacuum breaker failed to close on April 17, 2014 Unit 1, Shutdown cooling hardening during refuel outage on April 27, 2014 Unit 2, Bypass valve fast opening on April 10, 2014 Common, B standby gas treatment (SBGT) due to pressure differential instrument controller 07554B failure on April 1, 2014 Common, A EDG recirculation dampers failed closed on April 26, 2014 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

Introduction.

An NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified for PPL's failure to identify a condition adverse to quality by not implementing timely actions to address the extent of a previously identified inoperable condition. Specifically, when a RCIC turbine exhaust line vacuum breaker failed its inservice test (IST), PPL did not take timely actions in accordance with NDAP-QA-0702, Action Request and Condition Report Process, to test other valves that could be susceptible to the failure mechanism and, therefore, did not identify conditions adverse to quality in similar valves in a timely manner.

Description.

On April 27, 2011, PPL identified that the shaft counterweight for one of the Unit 2 RCIC turbine exhaust vacuum breakers, 249F064, had rotated out of position resulting in the valve failing to open within the 0.5 psid IST lift criteria. The condition represented a failure under the IST program, was entered into the CAP as CR 1396536, and an apparent cause evaluation (ACE) was performed. The apparent cause for the counterweight rotating out of position was degradation of its set screw due to normal wear. The set screw had been installed since 1999 and was not routinely inspected or replaced.

ISTC-5224, Corrective Action, states, in part, that check valves in a sample disassembly program that have failed shall have the cause of the failure analyzed.

ISTC-5224 continues that other check valves in the sample group that may also be affected by this failure mechanism shall be examined or tested during the same refueling outage to determine the condition of internal components and their ability to function.

This section has an amplifying note which states that valves outside of the sample group that are determined to be directly affected by the failure mechanism should be examined or tested.

To meet this requirement, PPL disassembled and examined the other three check valves in the same sample group during the 2011 Unit 2 refueling outage; all passed their IST criteria to lift within 0.5 psid. Additionally, the ACE generated a correct condition action (AR WM 1412299) to generate WOs to inspect the Unit 1 valves during the subsequent Unit 1 refueling outage in 2012. The correct condition action was closed on June 8, 2011, when WOs 1413019, 1413032, 1413032, and 1413027 were scheduled for the following refueling outage in 2012 to inspect 149F063, 149F064, 155F076 and 155F077, respectively. Step 7.16.2.c of NDAP-QA-0702, Action Request and Condition Report Process, Revision 32, states that if an action is closed to an open work document, the new work document shall be related to the CR with the same relationship as the closed document. Step 7.17 of NDAP-QA-0702 requires the supervisor or functional unit manager to verify the proper relationship between the work document and the CR. The Inspectors reviewed the work orders and determined that the new WOs were not related to the CR as required. All the WOs were the routine IST inspections of the valves and had simply had their scheduled dates for the activities adjusted without being related to the CR as correct condition actions necessary to correct a condition adverse to quality.

Subsequent to this, all but the WO for 155F076 were rescheduled from 2012 to 2014 or 2016 refueling outages to align the dates with the due dates of routine scheduling per the IST program. NDAP-QA-0702, Action Request and Condition Report Process, Revision 32, provides a process to extend correct condition actions and requires expanded justification and functional unit manager concurrence for the first extension.

By not identifying the WOs as correct condition actions for a condition adverse to quality, there was no mechanism in place to ensure that the work orders were completed as specified in the evaluation. Therefore, no mechanism existed to ensure the correct approvals and justifications when extensions were requested.

On April 17, 2014, while executing WO 1413027, check valve 155F077 (HPCI TURB EXHAUST VAC BKR LINE CKV) was found to be approximately 20 degrees stuck open.

Pressure applied to the valves disc was unsuccessful in opening or closing the valve.

Safety functions for 155F077 are to: open to provide a HPCI turbine exhaust line vacuum relief path; and, close during HPCI operations to prevent steam flow into the suppression chamber. Though this was not the same failure mechanism as was identified on Unit 2 in 2011, inspectors determined that had this inspection been performed in 2012 as specified by the ACE for CR 1396536, the condition adverse to quality would have been discovered earlier and two additional years of inoperability would have been avoided. PPLs causal evaluation for the failure of 155F077 performed under CR 2014-12407 determined that inadequate maintenance performed in 2007 was the cause of the valve binding such that the valve had been inoperable and stuck open for the entire seven year period.

Additionally, inspectors identified that the WOs for 149F063 and 149F064 were not scheduled until 2016. Upon identification, PPL took action to disassemble and inspect each of the valves. When completed, both valves were found with degraded set screws which caused the counterweight to rotate out of position, a similar condition adverse to quality to the one described in CR 1396536. In these two cases, the counterweight had not shifted sufficiently to render the valve inoperable.

Analysis.

The failure to identify and correct a condition adverse to quality in a timely manner associated with the Unit 1 HPCI and RCIC turbine exhaust line vacuum breakers was a performance deficiency. The finding was determined to be more than minor because it was associated with the SSC and barrier performance attribute of the Barrier Integrity cornerstone and affected its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The risk significance was bounded by the failure of 155F077 which was stuck in a partially opened state. With the valve stuck in this state, failure of the redundant valve would have resulted in HPCI exhaust steam relieving directly to the suppression chamber air space affecting containment performance. The inspectors assessed the finding in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, and determined the finding to be of very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room, did not represent an actual open pathway in the physical integrity of reactor containment, and did not involve the actual reduction in function of hydrogen igniters in containment.

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Resolution, because PPL did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, despite properly identifying appropriate corrective actions while evaluating the extent of a condition adverse to quality, PPL failed to implement those actions in a timely manner resulting in the failure to identify and correct conditions adverse to quality in three similar valves. [P.3]

Enforcement.

10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to this requirement, prior to April 17, 2014, PPL failed to identify conditions adverse to quality associated with HPCI and RCIC turbine exhaust line vacuum breakers in a timely manner when work orders specified as correct condition actions were not completed or extended in accordance with the stations CAP. Specifically, the failure to inspect failure of valve 155F077 in 2012 as originally scheduled as a correct condition action resulted in two additional years of inoperability. PPLs immediate corrective actions included entering the issue into their CAP as CR 2014-17151, performing testing of all valves included in the extent of condition, and correcting any degraded conditions that were identified prior to restoring the systems to service. Because the violation is of very low safety significance and has been entered into PPL's CAP, this violation is being treated as an NCV, consistent with section 2.3.2.a of the Enforcement Policy. (NCV 05000387/2014003-01, Failure to Identify Conditions Adverse to Quality due to Untimely Actions to Address Extent of Condition)

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

The inspectors evaluated a modification to core spray piping lead shielding implemented by engineering changes 1791212, Permanent Shielding for GBB-101 (Loop A & C)

Core Spray Discharge Piping, and 1791213, Permanent Shielding for GBB-101 (Loop A & C) and GBB-201 (Loop B & D) Core Spray Discharge Piping. 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, including the related TS bases changes for the secondary containment in-leakage requirements.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance testing 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, D inboard MSIV seat replacement on May 21, 2014 Unit 1, HPCI maintenance on June 5, 2014 Unit 1, HV155F003 overhaul and seat repair on May 11, 2014 Unit 1, B RRP motor and impeller replacement on June 6, 2014 Common, Engineering Safeguard System (ESS) bus 1A202 following multiple spurious operation modifications on May 4, 2014

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the stations work schedule and outage risk plan for the Unit 1 refueling outage (1R18), which was conducted April 12 through May 22, 2014. The inspectors reviewed PPLs development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:

Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment OOS Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that TSs were met Monitoring of decay heat removal operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by TSs Refueling activities, including fuel handling and fuel receipt inspections Fatigue management Tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation.

Identification and resolution of problems related to outage activities

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 TSs, 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, LOCA/LOOP testing on April 16, 2014 Unit 1, SM-102-C03 1D630 discharge test and 1D633 capability test on April 21, 2014 Unit 1, SI-169-302, 24 month calibration of drywell floor drain sumps on June 26, 2014 (RCS)

Unit 1, A and D MSIV as-found local leak rate testing (LLRT) on April 21, 2014 (PCIV)

Unit 1, HV144F004 as-left LLRT on May 27, 2014 (PCIV)

Unit 2, RCIC flow verification in May 1, 2014 (IST)

Common, B EDG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance run on April 2, 2014

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During May 13-16, 2014, the inspectors reviewed PPLs performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR Part 20 and guidance in [NRC] Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas for Nuclear Plants, TSs, and procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the 2013 performance indicators (PIs) for the occupational exposure cornerstone, radiation protection program audits, and any reports of operational occurrences related to occupational radiation safety since the last inspection.

Radiological Hazard Assessment The inspectors determined there have been no changes to plant operations since the last inspection that may result in significant new radiological hazards for onsite workers or members of the public.

The inspectors conducted walk-downs and independent radiation measurements in the facility, including radioactive waste processing, storage, and handling areas to evaluate material and radiological conditions.

The inspectors selected various work activities that involved exposure to radiation and evaluated the pre-work surveys and the adequacy of established protective measures.

The inspectors observed work in potential airborne radioactivity areas and evaluated whether the air samples were representative of the breathing air zone and were properly evaluated. The inspectors evaluated whether continuous air monitors were representative of actual work areas. The inspectors evaluated PPLs program for monitoring levels of loose surface contamination in areas of the plant.

Instructions to Workers The inspectors selected three containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements.

The inspectors reviewed various radiation work permits (RWPs) used to access high radiation areas (HRA) and evaluated if the work controls and control barriers were consistent with TS requirements. The inspectors assessed whether permissible dose for work under each RWP was clearly identified. The inspectors evaluated whether electronic personal dosimeter (EPD) alarm set-points were in conformance with survey indications and plant procedural requirements.

The inspectors reviewed two occurrences where a workers EPD alarmed and evaluated whether workers responded appropriately. The inspectors assessed whether the issue was included in the CAP and whether compensatory dose evaluations were conducted as appropriate. For work activities that could suddenly increase radiological hazards, the inspectors assessed PPLs means to inform the workers.

Contamination and Radioactive Material Control The inspectors observed the Unit 2 access control point where PPL monitors material leaving the radiological control area and inspected the methods used for control, survey, and release of these materials from the control point. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with 10 CFR Part 20 requirements.

Radiological Hazards Control and Work Coverage The inspectors evaluated radiological conditions and performed independent radiation measurements during walkdowns of the facility and assessed whether the conditions were consistent with postings, surveys, RWPs, and worker briefings. The inspectors evaluated the adequacy of radiological controls, surveys, and radiation protection job coverage, and evaluated PPLs use of EPDs in high noise areas.

The inspectors reviewed the application of dosimetry to monitor exposure to personnel in high radiation work areas with significant dose rate gradients. The inspectors reviewed two RWPs for work within airborne radioactivity areas and, evaluated airborne radioactive controls, monitoring containment barrier integrity and the operation of temporary high efficiency particulate air ventilation systems. The inspectors examined the posting and physical controls for selected very high radiation areas (VHRA) to verify conformance with the occupational PI.

Risk-Significant HRA and VHRA Controls The inspectors discussed with the radiation protection manager the controls and procedures for HRAs and VHRAs and assessed whether any changes to PPLs procedures reduce the effectiveness of worker protection.

The inspectors discussed with first line health physics supervisors the controls in place for special areas that have the potential to become VHRAs during certain plant operations and ensure that an individual was not able to gain unauthorized access to these VHRAs.

Radiation Worker Performance The inspectors observed the performance of radiation workers with respect to radiation protection requirements and assessed whether workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place.

The inspectors reviewed radiological problem reports since the last inspection that attributed the cause of the event to human performance errors and evaluated whether there was an observable pattern traceable to a similar cause and whether this perspective matched the corrective action approach taken by PPL to resolve the reported problems.

Radiation Protection Technician Proficiency The inspectors observed the performance of radiation protection technicians with respect to controlling radiation work. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the RWP controls/limits, and whether their performances were consistent with their training and qualifications.

The inspectors reviewed radiological problem reports since the last inspection that attributed the cause of the event to radiation protection technician error and evaluated whether there was an observable pattern traceable to a similar cause and assessed whether this perspective matched the corrective action approach taken by PPL to resolve the reported problems.

Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by PPL at an appropriate threshold and were properly addressed for resolution in PPLs CAP. The inspectors assessed PPLs process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

During May 13-16, 2014, the inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants Will Be ALARA, RG 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure ALARA, TSs, and PPLs procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed pertinent information regarding PPLs collective dose history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors compared the site specific trends in collective exposures against the industry average values and those values from similar vintage reactors. The inspectors reviewed site specific procedures associated with maintaining occupational exposures ALARA, which included a review of processes used to estimate and track exposures from specific work activities.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for the current annual collective dose estimate for accuracy and reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and for department and station collective dose goals.

The inspectors evaluated whether PPL had established measures to track, trend, and reduce occupational doses for ongoing work activities and assessed whether dose threshold criteria were established for work in-progress reviews. The inspectors evaluated the method used for adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered.

Source Term Reduction and Control The inspectors reviewed PPLs records to determine the historical trends and current status of plant source term and assessed whether PPL had developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.

Radiation Worker Performance The inspectors observed radiation worker and radiation protection technician performance during work activities being performed in radiation areas, airborne radioactivity areas, and HRAs and evaluated whether workers demonstrated the ALARA philosophy in practice and whether there were any procedural compliance issues.

Problem Identification and Resolution The inspectors evaluated whether problems associated with ALARA planning and controls are being identified by PPL at an appropriate threshold and were properly addressed for resolution in PPLs CAP. The inspectors assessed PPLs process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

During May 13-16, 2014, the inspectors verified in-plant airborne concentrations are being controlled consistent with ALARA principles and the use of respiratory protection devices on-site does not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, RG 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, TSs, and procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the UFSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. The review included a review of the respiratory protection program and a description of the types of protective devices used. The inspectors reviewed the location and quantity of respiratory protection devices stored for emergency use. The inspectors reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus, as well as, procedures for air quality maintenance.

The inspectors reviewed reported PIs to identify any related to unintended dose resulting from intakes of radioactive material.

Engineering Controls The inspectors reviewed PPLs use of permanent and temporary ventilation to determine whether PPL uses these systems as part of its engineering controls to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems to reduce dose and assessed whether the systems are used during high risk activities.

The inspectors selected two temporary ventilation system setups used to support work in contaminated areas. The inspectors assessed whether the use of these systems was consistent with procedural guidance and the principles of ALARA.

Use of Respiratory Protection Devices The inspectors selected two work activities where respiratory protection devices were used to limit the intake of radioactive materials, and assessed whether PPL performed an evaluation concluding that further engineering controls were not practical and that the use of respirators is ALARA. The inspectors assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration or have been approved by the NRC.

Problem Identification and Resolution The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by PPL at an appropriate threshold and were properly addressed for resolution in PPLs CAP. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by PPL.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

The inspectors verified that occupational dose is appropriately monitored, assessed, and reported by PPL. 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.

Inspection Planning

The inspectors reviewed the results of radiation protection program audits related to internal and external dosimetry. The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program report on the principal dosimetry used to establish dose of legal record. A review was conducted of procedures associated with dosimetry operations, including issuance/use of external dosimetry, and assessments of external and internal dose 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 PPLs dosimetry vendor is National Voluntary Laboratory Accreditation Program accredited and if the approved irradiation test categories for each type of personnel dosimeter used are consistent with the radiation present and the use of the dosimetry. The inspectors evaluated the onsite storage of dosimeters before issuance, during use, and before processing/reading, and reviewed the guidance provided to radiation workers with respect to care and storage of dosimeters.

The inspectors assessed the use of EPD to determine if PPL uses a correction factor to address the response of the EPD as compared to the dosimeter of legal record for situations when the EPD is used to assign dose.

The inspectors reviewed three dosimetry occurrence reports or CAP documents for adverse trends related to EPDs and 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 count equipment and 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 process to determine if the frequency of measurements was consistent with the biological half-life of the radionuclides available for intake.

The inspectors selected three whole body counts and evaluated whether the counting system used had sufficient counting sensitivity for the potential radionuclides of interest.

The inspectors evaluated how PPL accounts for hard-to-detect radionuclides in their internal dose assessments.

Special Bioassay (In Vitro)

There was no internal dose assessments obtained using In Vitro results for the inspector to review.

Internal Dose Assessment - Airborne Monitoring PPL had not performed any internal dose assessments using airborne/derived air concentration monitoring during the period reviewed.

Special Dosimetric Situations Declared Pregnant Workers The inspectors assessed whether PPL informs 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. No individuals had declared pregnancy during the current assessment period for the inspectors to review.

Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures The inspectors reviewed the methodology for monitoring external dose where large dose gradients exist and evaluated the criteria for determining when the use of multi-badging is implemented. The inspectors reviewed selected dose assessments performed using multi-badging to evaluate whether the assessment was performed consistent with procedures and industry standards.

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.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

During June 16-20, 2014, the inspectors verified that gaseous and liquid effluent processing systems are maintained so radiological discharges are properly reduced, monitored, and released. The inspectors also verified the accuracy of the calculations for effluent releases and public doses.

The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50.35(a) TSs; 10 CFR Part 50, Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases; 10 CFR Part 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water- Cooled Nuclear Power Reactor Effluents; 10 CFR Part 50.75(g), Reporting and Recordkeeping for Decommissioning Planning; 40 CFR Part 141, Maximum Contaminant Levels for Radionuclides; 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations; RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents; RG 1.21, Measuring, Evaluating, Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste; RG 4.1, Radiological Environmental Monitoring for Nuclear Power Plants; RG 4.15, Quality Assurance for Radiological Monitoring Programs; NUREG-1302, (BWRs) Offsite Dose Calculation Manual (ODCM) Guidance: Standard Radiological Effluent Controls; applicable Industry standards; and PPL procedures required by TSs/ODCM as criteria for determining compliance.

Event Report and Effluent Report Reviews The inspectors determined if reports were submitted as required by the ODCM/TSs.

The inspectors reviewed anomalous results, unexpected trends, abnormal releases, and radioactive effluent monitor operability issues that were identified and determined if these effluent results were evaluated, were entered in the CAP and were adequately resolved.

ODCM and UFSAR Review The inspectors reviewed UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths to identify system design features and required functions. The inspectors reviewed changes to the ODCM made since the last inspection. When differences were identified, the inspectors reviewed the technical basis or evaluations of any changes. The inspectors reviewed documentation to determine if any non-radioactive systems that have become contaminated were disclosed either through an event report or the ODCM.

Groundwater Protection Initiative (GPI) Program The inspectors reviewed reported groundwater monitoring results and changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

Procedures, Special Reports, and Other Documents The inspectors reviewed Licensee Event Reports, event reports, and special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.

The inspectors reviewed effluent program implementing procedures, including those associated with effluent sampling, effluent monitor set-point determinations, and dose calculations.

The inspectors reviewed copies of self-assessments and third party (independent)evaluation reports of the effluent monitoring program since the last inspection.

Walkdowns and Observations The inspectors walked down selected components of the gaseous and liquid discharge systems to verify that equipment configuration and flow paths align with the descriptions in the UFSAR and to assess equipment material condition. This review included potential unmonitored release points, building alterations which could impact airborne, or liquid, effluent controls, and ventilation system leakage that communicate directly with the environment.

The inspectors reviewed effluent system material condition surveillance records for equipment and areas associated with the systems that were not readily accessible due to radiological conditions. The inspectors walked down filtered ventilation systems to verify there are no degraded conditions associated with high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system.

The inspectors observed portions of the routine processing and discharge of radioactive gaseous effluent systems to verify that appropriate treatment equipment was used and the processing activities align with discharge permits.

The inspectors determined that PPL had not made any changes to their effluent release paths since the last inspection. The inspectors observed portions of the routine processing and discharge of liquid waste. The inspectors verified that appropriate effluent treatment equipment is being used and that radioactive liquid waste is being processed and discharged in accordance with procedures.

Sampling and Analyses The inspectors selected three effluent sampling activities and assessed whether adequate controls have been implemented to ensure representative samples were obtained. The inspectors selected two effluent discharges made with inoperable effluent radiation monitors to verify that controls are in place to ensure compensatory sampling was performed consistent with the TSs/ODCM and that those controls were adequate to prevent the release of unmonitored liquid and gaseous effluents. The inspectors determined whether the facility is routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the inter-laboratory and intra-laboratory comparison program to verify the quality of the radioactive effluent sample analyses.

The inspectors also assessed whether the intra- and inter-laboratory comparison program includes hard-to-detect isotopes.

Effluent Flow Measuring Instruments The inspectors reviewed the methodology used to determine the effluent stack and vent flow rates to verify that the flow rates are consistent with TSs/ODCM and FSAR values and reviewed any differences between assumed and actual stack and vent flow rates to ensure that they do not affect the calculated results of public dose.

Air Cleaning Systems The inspectors assessed whether surveillance test results for TS-required ventilation effluent discharge systems meet TS acceptance criteria.

Dose Calculations The inspectors reviewed all significant changes in reported dose values compared to the previous radioactive effluent release report to evaluate the factors which may have resulted in the change.

The inspectors reviewed three radioactive liquid and gaseous waste discharge permits to verify that the projected doses to members of the public were accurate and based on representative samples of the discharge path.

Inspectors evaluated the methods used to ensure that all radionuclides in the effluent stream source term are included, within detectability limitations. The review included the current waste stream analyses to ensure hard-to-detect radionuclides are included in the effluent releases.

The inspectors reviewed changes in methodology for offsite dose calculations since the last inspection to verify the changes are consistent with the ODCM and RG 1.109. The inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to ensure appropriate dispersion/deposition factors are being used for public dose calculations.

The inspectors reviewed the latest Land Use Census to verify changes that affect public dose pathways have been factored into the dose calculations and environmental sampling/analysis program.

The inspectors evaluated whether the calculated doses are within the 10 CFR Part 50, Appendix I and TS dose criteria.

The inspectors reviewed records of any abnormal gaseous or liquid tank discharges to ensure the abnormal discharge was monitored by the discharge point effluent monitor.

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages were reviewed to ensure that an evaluation was made of the discharge to account for the effluent release and were included in the calculated doses to the public.

GPI Implementation The inspectors reviewed monitoring results of the voluntary Nuclear Energy Institute (NEI) GPI to determine if PPL has implemented the GPI as intended.

The inspectors reviewed identified leakage or spill events and entries made into PPLs decommissioning files. The inspectors reviewed evaluations of leaks or spills, and reviewed the effectiveness any remediation actions. The inspectors reviewed onsite contamination events involving contamination of ground water and assessed whether the source of the leak or spill was identified and isolated/terminated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by: assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and assessing whether a survey/evaluation has been performed; and determining whether the licensee completed offsite notifications, as provided in its GPI implementing procedures.

Problem Identification and Resolution Inspectors assessed whether problems associated with the effluent monitoring and control program are being identified by PPL at an appropriate threshold and are properly addressed for resolution in PPLs CAP. In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Radiological Effluent TS/ODCM Radiological Effluent Occurrences

a. Inspection Scope

During June 16 - 20, 2014, the inspectors sampled PPLs submittals for the radiological effluent TS/ODCM radiological effluent occurrences PI for the period from the first quarter 2013 through the first quarter 2014. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, to determine if the PI data was reported properly during this period.

The inspectors reviewed PPLs corrective action report database and selected individual reports generated since this PI was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated offsite dose calculations for selected dates between the first quarter 2013 through first quarter 2014, to determine if PI results were accurately reported. The inspectors also reviewed PPLs methods for quantifying gaseous and liquid effluents and determining effluent dose.

b. Findings

No findings were identified.

.2 Occupational Exposure Control Effectiveness

a. Inspection Scope

During May 13 - 16, 2014, the inspectors sampled PPL submittals for the occupational exposure control effectiveness PI for the period from the first quarter 2013 through the first quarter 2014. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment PI Guideline, Revision 7, dated August 31, 2013, to determine the accuracy of the PI data reported.

To assess the adequacy of PPLs PI data collection and analyses, the inspectors discussed with radiation protection staff the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed EPD accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences. The inspectors also conducted walkdowns of numerous locked HRA and VHRA entrances to determine the adequacy of the controls in place for these areas.

b. Findings

No findings were identified.

.3 RCS Specific Activity and RCS Leak Rate

Inspection Scope The inspectors reviewed PPLs submittal for the RCS specific activity and RCS leak rate PIs for both Unit 1 and Unit 2 for the period of April 1, 2013, through March 31, 2014. 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 7, dated August 31, 2013. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the PI.

Findings No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, 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 followup, 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 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by PPL outside of the CAP, such as trend reports, PIs, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed PPLs CAP database for the first and second quarters of 2014 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed the PPL quarterly trend report for the first quarter of 2013 through the first quarter of 2014, conducted under LS-125-1009, Station Trending Manual, Revision 0, to verify that PPL personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified.

Human Performance Related Events. The inspectors identified a continuing trend in human performance related events for the period of January 2014 through June 2014.

This trend was originally identified and documented in NRC Inspection Report 05000387, 05000388/2013005 (ML14045A295) when fifteen prompt human performance investigations were completed in the fourth quarter 2013, which represented more than double the highest value of any of the previous eight quarters.

Notwithstanding this, a total of 51 prompt human performance investigations were performed in the first six months of 2014 in accordance with NDAP-00-0032, Human Performance - Standards for Error and Event Prevention. This represents over two times the average number per quarter over the last three years. The increase in the number investigations may have been partly due to additional management emphasis on the prompt human performance investigation process. Previously, human performance events were not assessed or trended to the current standards. However, the inspectors also identified that the relative significance of human performance events has increased.

Specifically, inspectors identified that:

three of these human performance errors challenged the operating crews by requiring entries into either off-normal or emergency operating procedures; two resulted in the station entering a four hour shutdown action statement in accordance with the stations TSs limiting condition for operation 3.0.3; two were classified as level one energy control process events, indicating that there were no remaining barriers for worker or equipment protection, which was the first event of such magnitude since 2011; and seven were classified as level two Employee Concerns Program events, indicating the only remaining barrier was the willingness of the holder to sign on to the clearance.

Since this adverse trend was identified, PPL has initiated three common cause evaluations: CR-2013-04796, which reviewed status control events; CR-2014-04795, which reviewed Energy Control Process events in the first quarter of 2014; and, CR 2014-19462, which is currently reviewing all operations department human performance events.

Secondary Containment Operability. The inspectors identified a continuing adverse trend in the performance of the secondary containment. Since the trend was last discussed in NRC Inspection Report 05000387, 05000388/2013005, the station has had four additional events that resulted in secondary containment being declared inoperable as defined by TSs limiting condition for operation 3.6.4.1, Secondary Containment. In particular, the material condition of door and hatch seals has challenged the station during required TS surveillance testing of the secondary containment. To compensate for some of these degraded conditions, as documented in NCV 05000387; 388/2013005-03: Missed TS Surveillance for Secondary Containment Drawdown Testing, PPL implemented a temporary engineering change to eliminate certain secondary containment configurations that had not been tested in accordance with the plant TSs. To date, PPL has been unable to satisfactorily test the Zone I/III configuration of secondary containment and continues to operate with the compensatory measure in place to maintain system operability.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000387/2014-006-00: Implementation of

Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 From April 16 through May 23, PPL performed OPDRVs without establishing secondary containment integrity. An OPDRV is an activity that could result in the draining or siphoning of the RPV water level below the top of fuel, without crediting the use of mitigating measures to terminate the uncovering of fuel. TS 3.6.4.1, Secondary Containment, requires that secondary containment be operable and is applicable during OPDRVs. The required action for this specification if secondary containment is inoperable in this condition of applicability is to initiate actions to suspend OPDRVs immediately. Therefore, failing to maintain secondary containment operability during OPDRVs without initiating actions to suspend the operation was considered a condition prohibited by TSs as defined by 10 CFR Part 50.73(a)(2)(i)(B).

As reported in LER 05000387/2014-006, PPL conducted the following OPDRVs during the period of secondary containment inoperability:

Recirculation system maintenance; RWCU system maintenance; RHR system LLRT and maintenance; Hydraulic control unit maintenance; Local power range monitor replacement; Standby liquid control testing; Control rod drive mechanism replacements; Full Scram testing.

NRC EGM 11-03, Enforcement Guidance Memorandum On Dispositioning BWR Licensee Noncompliance With TS Containment Requirements During Operations With A Potential For Draining The Reactor Vessel, Revision 2, provides, in part, for the exercise of enforcement discretion only if the licensee demonstrates that it has met four specific criteria during an OPDRV activity. The inspectors assessments of PPLs implementation of these four criteria during each of the eight above described maintenance activities are described below:

1) The inspectors observed that, as required by the EGM, the OPDRV activities were logged in the control room narrative logs and that the log entries appropriately documented actions being taken to ensure water inventory was maintained and defense-in-depth criteria were in place.

2) The inspectors noted that the reactor vessel water level was maintained above the RHR high water level setpoint of 22 feet. The inspectors also noted that at least one safety-related pump was the standby source of makeup designated in the control room narrative logs for the evolutions. PPL logged that the worst case estimated time to drain the reactor cavity to the RPV flange was greater than the EGM criteria of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3) The inspectors verified that the OPDRVs were not conducted in Mode 4 and that PPL maintained secondary containment operability for the refueling floor while moving irradiated fuel during OPDRVs. The inspectors noted that PPL had contingency plans in place for isolating the potential leakage paths, should difficulty arise during various maintenance activities. Additionally, the inspectors verified that two independent means of measuring RPV water level (one alarming) were available for identifying the onset of loss of inventory events.

4) Inspectors verified that all other TSs were met during OPDRVs with secondary containment inoperable.

TS 3.6.4.1 is applicable during OPDRVs and requires that secondary containment be operable. TS 3.6.4.1, action C.3, requires operators to initiate actions to suspend OPDRVs immediately upon discovery that secondary containment is inoperable.

Contrary to the above, from April 16, 2014 through May 23, 2014, PPL did not maintain secondary containment operable while performing OPDRVs. Because the violation was identified during the discretion period described in EGM 11-003, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation. In accordance with EGM 11-003, each licensee that receives discretion must submit a license amendment request within 12 months of the NRC staffs publication in the Federal Register of the notice of availability for a generic change to the Standard TSs to provide more clarity to the term OPDRV. The inspectors observed that PPL is tracking the need to submit a license amendment request in its CAP as CR 1707662. This LER is closed.

4OA5 Other Activities

.1 Buried Piping, Temporary Instruction (TI) 2515/182, Phase 2 (1 sample)

a. Inspection Scope

PPLs buried piping and underground piping and tanks program was inspected in accordance with paragraphs 03.02.a of TI 2515/182, and it was confirmed that activities which correspond to the completion dates, specified in the program, which have passed since the Phase 1 inspection was conducted, have been completed.

PPLs buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of TI 2515/182 and responses to specific questions found in http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to NRC headquarters staff.

b. Findings

No findings were identified.

.2 TI 2515/189, Inspection to Determine Compliance of Dynamic Restraint (Snubber)

Program with 10 CFR Part 50.55a Regulatory Requirements for Inservice Examination and Testing of Snubbers

a. Inspection Scope

The inspectors conducted an inspection and review of SSESs snubber program in accordance with TI 2515/189 to verify that the program was in compliance with the requirements of 10 CFR Part 50.55a, as discussed in Regulatory Information Summary 2010-06, Inservice Inspection and Testing of Dynamic Restraints (Snubbers). The inspectors provided specific information relative to Attachment 1 of this TI to the NRC headquarters point of contact listed in TI 2515/189.

The inspectors selected a sample of sixteen

(16) snubbers based on risk-informed insights, performance history, plant conditions, and accessibility. For the selected snubbers, the inspectors reviewed the inservice visual examination records and functional test records during the current 10-year ISI interval, and verified that the personnel performing the tasks were qualified. The inspectors also observed in-process bench testing of one of the selected snubbers and verified that the test parameters met the acceptance criteria specified in the SSES test procedure. The inspectors reviewed the process for snubber service life monitoring at SSES and determined that the selected snubbers were being monitored and maintained. The inspectors also reviewed a sample of SSES corrective action reports identified during the inspection and testing of snubbers and verified that issues were properly evaluated and entered into the CAP for resolution.

b. Findings

No findings were identified.

.3 Contingency Plans for Licensee Strikes or Lockouts

PPL developed a Business Continuity Plan to ensure a sufficient number of qualified personnel were available to continue operations in the event that Local International Brotherhood of Electrical Workers, Local 1600 personnel engaged in a job action upon the expiration of their contract on May 11, 2014. Using the guidance contained in NRC Inspection Procedure 92709, Contingency Plans for Licensee Strikes or Lockouts, the inspectors reviewed PPLs plans to address a potential job action at the site. The inspection included an evaluation of the Business Continuity Plan content and the actions needed to implement the plan; a review to determine whether the number of qualified personnel needed for the proper operation of the facility would be available; a review to determine if security operations would be maintained, as required; and a review to determine if the plan complied with NRC requirements. On May 9, PPL and International Brotherhood of Electrical Workers, Local 1600, tentatively agreed to a new contract and union members approved the contract on May 21, 2014. No job action was taken.

.4 World Association of Nuclear Operators (WANO)/Institute of Nuclear Power Operations

(INPO) Report Review

a. Inspection Scope

The inspectors reviewed the final report for the WANO/INPO plant assessment of SSES conducted in November 2013. The inspectors evaluated this report to ensure that NRC perspectives of PPL performance were consistent with any issues identified during the assessments. The inspectors also reviewed these reports to determine whether WANO/INPO identified any significant safety issues that required further NRC follow-up.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On July 9, 2014, the inspectors presented the inspection results to Mr. T. Rausch, Chief Nuclear Officer, and other members of the PPL staff. The inspectors verified that no proprietary information was retained by the inspectors or documented 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.

10 CFR Part 20.1701 requires, in part, that the licensee use, to the extent practicable, process or engineering controls to control the concentration of radioactive materials in air. Contrary to this requirement, PPL did not use, to the extent practicable, process or engineering controls during pipe weld preparation on the RWCU piping on April 27, 2014, due to miscommunication between the workers and radiation protection. A radiation protection technician monitoring a continuous air monitor noticed increasing airborne radioactivity and subsequently stopped the work. This failure to use, to the extent practicable, process or engineering controls led to a worker receiving an unplanned, unintended uptake of approximately 11 millilrem. This violation has been entered into PPLs CAP as CR-2014-16603. The inspectors determined the finding was of very low safety significance (Green)because it did not involve:

(1) ALARA occupational collective exposure planning and controls,

(2) an overexposure,

(3) a substantial potential for overexposure, or

(4) an impaired ability to assess dose.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Broski, R/R Program Owner

E. Camacho, IVVI Program Owner

R. Day, ISI Program Owner

M. Dziedzic, Site Level III and IWE/IWL Program Owner

F. Hickey, Senior Health Physicist

B. Hyduk, Design Engineer

S. Jurek, Nuclear Regulatory Affairs

J. Kanute, Snubber Program Owner

R. McIntosh, Licensing

C. Minor, GE Level III

B. O Rouke, Licensing Engineer

E. Ortuba, Dosimetry Supervisor

S. Peterkin, Radiation Protection Manager

S. Sienkiewicz, Supervisor Programs and Testing

R. Whiteknight, FAC Program Owner

P. Scanlan, Manager- Station Engineering

D. Deretz, Manager- Programs Engineering

B. Payne, Engineer- IST Program

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Opened/Closed

05000387/2014003-01 NCV Failure to Identify Conditions Adverse to Quality due to Untimely Actions to Address Extent of Condition (1R15)

Closed

05000387/2014-006-00 LER Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 (4OA3)