IR 05000387/2019002
| ML19224A288 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/09/2019 |
| From: | Jon Greives Reactor Projects Region 1 Branch 4 |
| To: | Berryman B Susquehanna |
| Greives J | |
| References | |
| IR 2019002 | |
| Download: ML19224A288 (22) | |
Text
August 9, 2019
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -
INTEGRATED INSPECTION REPORT 05000387/2019002 AND 05000388/2019002
Dear Mr. Berryman:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station, Units 1 and 2. On July 11, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any finding or violation of more than minor significance.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects
Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF-22
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000387 and 05000388
License Numbers:
Report Numbers:
05000387/2019002 and 05000388/2019002
Enterprise Identifier: I-2019-002-0035
Licensee:
Susquehanna Nuclear, LLC
Facility:
Susquehanna Steam Electric Station, Units 1 and 2
Location:
Berwick, PA
Inspection Dates:
April 1, 2019 to June 30, 2019
Inspectors:
L. Micewski, Senior Resident Inspector
M. Rossi, Resident Inspector
D. Beacon, Resident Inspector
T. Daun, Resident Inspector
E. Dipaolo, Senior Reactor Inspector
J. Furia, Senior Health Physicist
J. Kulp, Senior Reactor Inspector
A. Turilin, Reactor Inspector
Approved By:
Jonathan E. Greives, Chief
Reactor Projects Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Susquehanna Steam Electric Station,
Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at 100 percent power. On May 1, 2019, operators reduced power to approximately 80 percent for a control rod pattern adjustment, condenser waterbox cleaning, and scram time testing. Operators returned the unit to 100 percent on May 4, 2019.
On May 22, 2019, operators reduced power to approximately 78 percent after a loss of power to a breaker for a 480-volt motor control center (MCC) caused the unit to enter Technical Specification Limiting Condition for Operation (LCO) 3.0.3, which required a shutdown to Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Operators commenced the shutdown, however exited LCO 3.0.3 after restoring power to the affected MCC, when the unit was at about 78 percent. Operators returned the unit to 100 percent power later that same day. On May 31, 2019, operators reduced power to approximately 66 percent to perform a control rod sequence exchange.
Operators returned the unit to 100 percent on June 2, 2019, and remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period shutdown in Mode 5 for a planned refueling outage. Following the completion of refueling and maintenance activities, operators commenced a reactor startup on April 20, 2019, and achieved full power on April 30, 2019. On May 6, 2019, a recirculation pump rundown was automatically initiated following an electrical fault that tripped reactor building cooling water and chillers. The rundown reduced power to 78 percent. Operators subsequently reduced power to approximately 70 percent to stay within rod line operating limits. Following repairs and restoration from the electrical fault, operators returned the unit to 100 percent on May 7, 2019. On May 22, 2019, operators reduced power to approximately 79 percent after a loss of power to a breaker for a 480-volt MCC caused the unit to enter Technical Specification LCO 3.0.3, which required a shutdown to Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Operators commenced the shutdown, however exited LCO 3.0.3 after restoring power to the affected MCC, when the unit was at about 79 percent. Operators returned the unit to 100 percent power later that same day. On June 28, 2019, operators reduced power to approximately 57 percent to perform a control rod sequence exchange. Operators returned the unit to 100 percent on June 30, 2019, and remained at or near 100 percent power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated summer readiness of offsite and alternate alternating current power systems on May 30, 2019.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2, core spray prior to division swap on April 4, 2019
- (2) Unit 2, snubbers inside containment on April 16, 2019
- (3) Unit 1 and Unit 2, spent fuel pool cooling during Unit 2 residual heat removal (RHR)common system outage window on April 22, 2019
- (4) Unit 1, standby liquid control quarterly flow surveillance on April 23, 2019
71111.04S - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 high pressure injection system on April 9, 2019.
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated fire brigade performance on May 23, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 1, division 2, 250V and 125V battery rooms (fire zones 0-28M, 0-28N, 0-28J) on April 3, 2019
- (2) Unit 2, equipment access area elevation 683' (fire zone 2-3C) on April 16, 2019
- (3) Unit Common, 'E' emergency diesel generator (EDG) while swapped in during air compressor upgrades (fire zone 0-41E) on June 5, 2019
- (4) Unit 2, load center and switchgear rooms (fire zones 2-4C/D and 2-5F/G) on June 17, 2019
- (5) Unit 1, low pressure coolant injection equipment elevation 645' (fire zones 1-1B/D/E/F) on June 19, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 2, division 1 RHR room while aligned for shutdown cooling while flood doors obstructed on April 8, 2019
71111.07A - Heat Sink Performance
Annual Review (IP Section 02.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2, division 2 RHR heat exchanger on April 22, 2019
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
- (1) The inspectors verified that the reactor coolant system (RCS) boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined, and accepted by reviewing the following activities during the Susquehanna Unit 2 2R19 refueling outage from April 1, 2019, to April 5, 2019:
03.01.a - Nondestructive Examination and Welding Activities
1. Manual encoded phased array ultrasonic examination of standby liquid control
system weld (SPDCA239-1 W3) for license renewal commitment to examination small bore piping welds
2. Ultrasonic examination of reactor vessel bottom head meridional weld DC
3. Magnetic particle examination of high pressure coolant Injection piping support
weld (HBB2081-HW-1)
4. Visual examination (VT-1) of N2B jet pump riser support weld A
5. Visual examination (EVT-1) of core shroud horizontal weld H4
6. ASME IWE visual examination of drywell liner and penetrations elevation 738-
752
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during reactor startup operations on April 20, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a simulation of a seismic event resulting in multiple system failures on May 23, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Unit 2, reactor pressure vessel/pressure boundary flow accelerated corrosion program on April 15, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 2, spent fuel pool cooling system during common shutdown cooling work window on April 10, 2019
- (2) Unit Common, yellow risk during 'B' emergency service water outage on May 21, 2019
- (3) Unit Common, elevated risk while 'C' and 'E' EDG inoperable on June 7, 2019
- (4) Unit 1, breaker 1B22023 swap at power on June 11, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (4 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 2, 250 VDC molded case circuit breaker failure on April 10, 2019
- (2) Unit 2, high pressure injection snubber inoperable due to missing parts on May 13, 2019
- (3) Units 1 and 2, ACT-01-CR-2019-07154, MCC 0B136 prompt operability determination, dated May 24, 2019
- (4) Unit 2, local power range monitor connection swapped 48-33 B/D on June 11, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 2, EC 2203222, replace obsolete Mallory M200 PK potentiometer with Bourns 3400S-1-201L on April 10, 2019
- (2) Unit Common, 'D' EDG starting air compressor modification on May 13, 2019
71111.19 - Post Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (10 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Unit 2, division 2 RHR following maintenance during refueling outage on April 4, 2019
- (2) Unit 2, 125V battery charger 2D633 following maintenance and installation of engineering change on April 9, 2019
- (3) Unit 2, 125VDC molded case circuit breaker 2D614 on April 11, 2019
- (4) Unit 2, snubber replacement inside containment on April 16, 2019
- (5) Unit 2, reactor vessel leak check on April 18, 2019
- (6) Unit 2, safety relief valve replacement on April 18, 2019
- (7) Unit Common, HS-0041B synchroscope selector switch replacement on April 20, 2019
- (8) Unit 2, reactor core isolation cooling 150# test on April 20, 2019
- (9) Unit 2, high pressure coolant injection exhaust vacuum breaker checked on May 3, 2019
- (10) Unit Common, 'B' emergency system water discharge isolation and check valve repair on May 22, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 2 refueling outage 2R19 activities from April 1, 2019, to April 20, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2, main steam isolation valve 28 D test after maintenance on May 3, 2019
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1, standby liquid control quarterly flow surveillance on April 23, 2019
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) Unit 2, division 2 automatic depressurization system logic system functional test on April 16, 2019
- (2) Unit 2, RCS pressure test on April 18, 2019
- (3) Unit Common, 'A' EDG analyzer run on April 29,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Instructions to Workers (IP Section 02.02) (1 Sample)
The inspectors evaluated instructions to workers, including radiation work permits, used to access high radiation areas.
- (1) The inspectors reviewed high radiation area work permit controls and use; and observed containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with requirements.
Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) The inspectors evaluated in-plant radiological conditions and performed independent radiation measurements during facility walkdowns and observation of radiological work activities. The inspectors examined the physical controls for selected high radiation areas, locked high radiation areas, and very high radiation areas to verify conformance with the occupational performance indicator.
High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)
- (1) The inspectors reviewed the procedures and controls for high radiation areas, very high radiation areas, and radiological transient areas in the plant.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)
- (1) The inspectors evaluated radiation worker performance with respect to radiation protection work requirements. The inspectors evaluated radiation protection technicians in performance of radiation surveys and in providing radiological job coverage.
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 02.03) (1 Sample)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) The inspectors reviewed radiological work controls and as low as reasonably achievable (ALARA) practices during the observation of in-plant work activities. The inspectors reviewed the results achieved against the intended ALARA estimates to confirm adequate implementation and oversight of radiological work controls.
71124.07 - Radiological Environmental Monitoring Program
Groundwater Protection Initiative Implementation (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed: groundwater monitoring results; changes to the Groundwater Protection Initiative program since the last inspection; anomalous results or missed groundwater samples; leakage or spill events including entries made into the decommissioning files (10 CFR 50.75(g)); evaluations of surface water discharges; and evaluation of any positive groundwater sample results including appropriate stakeholder notifications and effluent reporting requirements.
Site Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the radiological environmental monitoring program implementation.
- (1) The inspectors walked down various thermoluminescent dosimeter and air and water sampling locations and reviewed associated calibration and maintenance records. The inspectors observed the sampling of various environmental media as specified in the Offsite Dose Calculation Manual. The inspectors reviewed the groundwater monitoring program as it applies to selected potential leaking structures, systems, and components; and 10 CFR 50.75(g) records of leaks, spills, and remediation since the previous inspection.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicator submittals listed below:
BI01: RCS Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (January 1, 2018 - December 31, 2018)
- (2) Unit 2 (January 1, 2018 - December 31, 2018)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (January 1, 2018 - December 31, 2018)
- (2) Unit 2 (January 1, 2018 - December 31, 2018)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program (CAP) related to the following issues:
- (1) Essential service water (ESW) piping erosion
- (2) Non-Cited Violation (NCV) 05000387;05000388/2018001-01, Failure to Proper Testing of 125VDC Molded Case Circuit Breakers to Confirm their Design Adequacy Long-Term
- (3) Compensatory measures associated with fire barrier impairments
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed Susquehannas CAP for trends that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Observation: Annual Follow-Up of Selected Issues-Essential service water (ESW) piping erosion CR-2017-13423 71152 The inspectors reviewed Susquehannas evaluation and corrective actions to address corrosion of safety-related ESW piping located in vault VA021 as documented in CR 2017-13423. Susquehanna staff performed a causal evaluation and determined the corrosion was a result of original construction pipe wrap failure and standing water in the vault.
Susquehanna staff performed an extent of condition evaluation which included all other vaulted ESW piping. The extent of condition identified similar but less extensive pipe wrap degradation and piping corrosion in vaults VA022 to VA026. Susquehanna staff implemented or scheduled corrective actions to drain the vaults and repair the degraded areas of the pipe wrap. Additionally, the inspectors determined that Susquehanna staff conducted an extent of cause evaluation and determined that the water intrusion resulted from rain water permeating the original deteriorated vault lid gasket. Susquehanna staff developed and implemented corrective actions to prevent rain water intrusion into the vaults. The corrective actions included assessing the vault lid gasket condition after each opening as well as caulking around the vault lid after the vault is closed. Furthermore the inspectors determined that corrective actions are scheduled to evaluate the inner and outer surface condition of the portion of the pipe that is embedded in the ground with non-destructive inspection methods to determine whether the water is intruding into the vaults from the ground. Corrective actions to eliminate standing water in safety-related vaults, which include installation of automatic sump pumps, have also been implemented or scheduled. Additionally, as part of their In-service Inspection program, Susquehanna staff initiated periodic inspections of the vaults to monitor the piping condition and effectiveness of the implemented corrective actions.
Inspectors reviewed Susquehannas evaluation and implemented and scheduled corrective actions and did not identify any issues of concern. The inspectors determined that Susquehannas corrective actions involving extent of condition review, extent of cause, subsequent cleaning and repair of the pipe coating, installation of the automatic sump pumps in the vaults, and periodic vault inspections by the in-service inspection program were commensurate with the safety significance of the issue.
Observation: Annual Follow-Up of Selected Issues-Failure to Conduct Proper Testing of 125VDC Molded Case Circuit Breakers (MCCBs) to Confirm their Design Adequacy Long Term 71152 The inspectors performed an in-depth review of Susquehannas evaluations and corrective actions associated with NCV 05000387;05000388/2018001-01 (ADAMS Accession No.
ML18241A044) for failing to adequately exercise and test safety-related 125 VDC MCCBs. Issues related to verifying the adequacy of the design for 125VDC MCCBs were previous identified in NCV 05000387;05000388/2013010-01 (ADAMS Accession No.
ML13275A074), and in a licensee-identified violation documented in NRC Inspection Report 05000387; 05000388/2016007 (ADAMS Accession No. ML16328A097) for failure to implement corrective actions to establish a preventive maintenance program for MCCBs associated with containment penetration conductors.
The inspectors performed a review of Susquehannas corrective action to address the adequacy of testing 125VDC MCCBs as documented in condition report (CR)-2018-09952, CR-2018-11415, and other related CRs. The inspectors verified that Susquehanna properly evaluated the issue and performed or planned appropriate corrective actions. The inspectors verified that Susquehanna conducted adequate testing of the Unit 2 125VDC MCCBs associated with containment penetration conductors during the Spring 2019 refueling outage and planned to complete similar testing during the next Unit 1 refueling outage.
The inspectors observed incomplete documentation of actions performed and/or planned to correct the issue within individual CAP documents. For example, the population of 125VDC MCCBs associated with containment penetration conductors had to be re-verified by engineering and actual work orders performed during the Unit 2 refueling outage had to be reviewed by the inspectors to conclude that Susquehannas actions were adequate. These issues were determined to be minor because the appropriate population of 125VDC MCCBs associated with containment penetration conductors was subsequently verified, all the associated MCCBs on Unit 2 were tested during the Spring 2019 refueling outage, and all the associate MCCBs on Unit 1 were planned to be tested during the next scheduled refueling outage.
Observation: Annual Follow-Up of Selected Issues-Alternate Compensatory Measures for Firewatches Associated with High Radiation Areas 71152 The inspectors performed a review of Susquehannas corrective action to address the adequacy of compensatory measures documented in CR-2019-00739, CR-2019-03992, and other related CRs. The inspectors verified that Susquehanna properly evaluated the issue and performed or planned appropriate corrective actions. The inspectors verified that Susquehanna implemented appropriate corrective actions to perform a fire hazards analysis prior to authorizing alternate compensatory actions to ensure an adequate level of fire protection is maintained when fire impairments are identified in high radiation areas.
The inspectors identified that Susquehannas fire protection procedure, NDAP-QA-0443, allowed for an hourly firewatch to check around the fire door for smoke and to touch the door to verify no heat was present. After the inspectors questioned whether this practice was evaluated as an alternate compensatory action, Susquehanna initiated CR-2019-03992 and determined that this practice required an area-specific engineering evaluation to ensure an adequate level of fire protection is maintained.
While the ability of procedurally allowing an alternate compensatory action existed for greater than ten years, the inspectors were only able to identify the one instance described in CR-2019-00739 where the practice was used. Additionally, the station performed an engineering analysis for the affected fire zone as part of their past operability process and determined that the alternate compensatory action provided an adequate level of fire protection. Though this evaluation was done after the alternate compensatory action was established, the inspectors determined this conclusion was reasonable.
The immediate and planned corrective actions are appropriate to ensure that an engineering evaluation in the form of a zone-specific fire hazard analysis is performed prior to implementing alternate compensatory actions. While other methods such as installing portable camera(s) could enable the required firewatch actions to be accomplished, the inspectors acknowledged that other factors such as radiation dose concerns must be considered and that establishing an alternate compensatory action following an engineering evaluation can provide for an adequate level of fire protection.
Observation: Semi-Annual Trend Review - Issues not appropriately entered into station processes 71152 The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety concerns. As part of this review, the inspectors included repetitive or closely-related issues documented by Susquehanna in the CAP database, trend reports, site performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed how Susquehannas CAP evaluated and responded to individual issues identified by the NRC inspectors during routine plant walkdowns and daily CR reviews.
The inspectors noted an example where a condition adverse to quality (CAQ) was not entered promptly into the CAP, as required by station procedure LS-120, Issue Identification and Screening Process. LS-120 defines a CAQ as any condition identified with a quality related function which is determined to be in conflict with design documents, regulatory commitments, Final Safety Analysis Report (FSAR) commitments, or applicable state or federal codes. When Susquehanna discovered that a small water leak was wetting a fire barrier beneath it, hourly firewatches were instituted. However, since the location was a locked high radiation area, Susquehanna allowed the firewatch to look at the door for smoke or discolored paint, and feel the outside of the door for heat. When the inspectors questioned whether a more intrusive check was required, such as using a remote camera or opening the door and looking in, Susquehanna documented the question as DI-2019-01497, which is a non-CAP process, and stated that the current practice as described in procedure NDAP-QA-0443, Fire Watch, needed to be evaluated against the Fire Protection Review Report (FPRR). After further assessment of the question, Susquehanna staff concluded that NDAP-QA-0443 did not meet standards as defined in the FPRR, which is a CAQ. The inspectors observed that upon recognition that a CAQ existed, and that actions needed to be taken to correct the condition, Susquehanna staff did not enter the issue into the CAP. After the inspectors shared this observation, Susquehanna staff initiated CR-2019-03992 to document the CAQ. The inspectors determined that the failure to properly document this issue in station programs, as required by procedures LS-120, was a performance deficiency. The inspectors evaluated the deficiency using IMC 0612, Appendix B, "Issue Screening," and IMC 0612, Appendix E, "Examples of Minor Issues," and determined it was of minor significance because the failure to enter the issue into the formal station process did not have any adverse impact on the cornerstone objectives. The underlying technical issue was reviewed and documented separately.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 11, 2019, the inspectors presented the integrated inspection results to Mr. Brad Berryman and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-2019-07504
Indicating lights if shorted in the SSES KV switchyard could
possibly trip Unit 2 off-line
05/30/2019
Miscellaneous
Certification Letter for 2019 Summer Readiness
05/15/2019
Corrective Action
Documents
CR-2019-03868
Two nuts found in U2 drywell
03/27/2019
CR-2019-03942
Snubber failed on high drag
03/26/2019
CR-2019-03971
MSRV cable number did not match procedure
03/26/2019
CR-2019-04249
L MSRV contacted airlock while in transport
03/30/2019
CR-2019-05197
Paint not reapplied to snubber
04/13/2019
Drawings
E105952
Unit 2 Division 2 Core Spray P&ID
Revision 31
E106253
Unit 1 Standby Liquid Control System P&ID
Revision 40
Procedures
CL-251-0012
Unit 2 Core Spray System Division 1 Mechanical
Revision 12
CL-251-0013
Unit 2 Core Spray System Division 2 Mechanical-
Containment
Revision 5
CL-251-0015
Unit 2 Core Spray System Division 2 Mechanical
Revision 13
Drawings
E105956
Revision 31
Procedures
CL-252-0011
Unit 2 HPCI System Electrical
Revision 11
CL-252-0012
Unit 2 HPCI System Mechanical
Revision 17
CL-252-0013
Unit 2 HPCI System Mechanical-Containment
Revision 5
Fire Plans
HPCI Pump Room (II-11) Fire Zone 2-1C Elevation 645'-0"
Revision 5
Miscellaneous
TQ-171-0105
Unit 2 HPCI
Revision 0
71111.05Q Corrective Action
Documents
CR-2019-07537
PA-015 FP in E EDG bay has packing leak
06/03/2019
Fire Plans
'E' Diesel Generator Building Fire Zone 0-41E Elevation
656'-6", 675-6", 708'-0"
Revision 7
RCIC Pump Room (I-12) Fire Zone 1-1D Elevation 645'-0"
Revision 5
RHR Pump Room "B" (I-13) Fire Zone 1-1E Elevation 645'-
0"
Revision 3
RHR Pump Room "A" (I-14) Fire Zone 1-1F Elevation 645'-0" Revision 5
Core Spray Pump Room "B" (1-10) Fire Zone 1-1B Elevation
645'-0"
Revision 4
Equipment Access Area (II-202,204,205) Fire Zones 2-3C-N,
Revision 5
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2-3C-W, 2-3C-S, Elevation 683'-0"
Switchgear Rooms (II-406, II-407) Fire Zones 2-4C, 2-4D,
Elevation 719'-1"
Revision 7
Load Center Room (II-510) Load Center Room (II-507) Fire
Zone 2-5F, 2-5 G, Elevation 749'1"
Revision 5
Corrective Action
Documents
CR-2018-05387
RHR heat exchanger pressure relief valve failed lift test
04/07/2018
CR-2018-06358
Documentation of plugging in RHR heat exchanger
04/19/2018
Procedures
MT-116-002
RHR Heat Exchanger Cleaning, Inspection, and Repair
Revision 15
MT-GM-025
Heat Exchanger Cleaning and Inspection
Revision 22
MT-GM-031
Immersed Component/Heat Exchanger Internals Epoxy
Lining/Cladding
Revision 22
MT-GM-078
SSES Heat Exchanger Tube Plugging
Revision 8
71111.11Q Corrective Action
Documents
CR-2019-05411
Simulator response not as expected during start up Just-In-
Time Training
04/16/2019
Procedures
GO-200-002
Plant Startup, Heatup and Power Operation
Revision 96
Corrective Action
Documents
CR-2019-05079
Wall thinning trend identified in bottom head drain piping
04/11/2019
Calculations
EC-049-0655
RHR fuel pool cooling mode heat capacity
Revision 0
EC-THDY-1069
Excel program for calculating fuel pool heat-up during
refueling operations
Revision 8
Corrective Action
Documents
AR-2015-07176
Confirm time after shutdown when fuel pool cooling assist
can be credited for decay heat removal
03/12/2015
AR-2015-09056
Update shutdown EOOS model to reflect availability of fuel
pool cooling and FPC assist
04/01/2015
Miscellaneous
TM-OP-054-ST
Emergency Service Water
Revision 8
Calculations
EC-PIPE-2569
Piping analysis of Unit 2 HPCI inside containment
Revision 0
EC-SOPC-0554
Relay Setting Calculation for Motor Control Center 0B136
Circuit Breaker at Load Center 1B230
Revision 2
Corrective Action
Documents
AR-2019-04083
Missing rings, washers, and retaining pins on snubber
03/28/2019
CR-2019-04020
Missing pin, washers, and retaining rings on snubber
03/27/2019
CR-2019-04879
AK breaker fails as-found testing
04/07/2019
CR-2019-04935
Removed AK breaker failed to meet acceptance criteria
04/08/2019
CR-2019-07089
Loss of 0B136
05/22/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2019-07122
Troubleshooting revealed an issue with 0EP01
05/22/2019
Corrective Action
Documents
Resulting from
Inspection
CR-2019-07153
NRC question regarding breaker coordination
05/22/2019
Miscellaneous
EPRM 1447078
Perform Preparation of 480 Volt Overhauled Spare Load
Center Breaker Returned from Vendor for use in 1B23023
07/25/2013
EPRM 1802920
Perform Preventive Maintenance of 480 Volt Motor Control
Center Breaker 0B136033
2/14/2016
Snubber visual inspection
Revision 2
UFSAR Table
8.1-2
Affiliated and Non-Class 1E Circuits that Connect to Class
1E Power Supplies
Revision 69
Calculations
2033998
Replace the Compressors and Air Dryers in Diesel
Generator Air Start System
Revision 2
Miscellaneous
203222
Mallory M200PK is obsolete is being replaced by Bourns
3400S-1-201L
Revision 0
Work Orders
2150074
Remove existing EDG air compressor equipment
2/12/2018
Corrective Action
Documents
CR-2015-27535
B ESW pump discharge valve has leakby ~10 gpm
10/12/2015
CR-2019-04153
Electrical questioning the effectiveness of not using lock ring
on new sync switches
03/29/2019
CR-2019-04683
CR to document resolution of 125 VDC electrical testing
04/04/2019
CR-2019-04732
EC-1 failed to trip breaker during testing
04/05/2019
CR-2019-04758
Breaker failed to reset during testing
04/06/2019
CR-2019-04822
Could not build pressure while testing accumulator
04/07/2019
CR-2019-04935
Removed AK breaker failed to meet acceptance criteria
04/08/2019
CR-2019-04957
O-ring leak found
04/08/2019
CR-2019-05260
Casting of new disc arm will not fit in valve body
04/14/2019
CR-2019-05491
40dpm leak found during vessel leak check
04/18/2019
CR-2019-05502
CRDM leaking during RPV hydro test
04/18/2019
CR-2019-05507
CRDM leaking during RPV hydro test
04/18/2019
CR-2019-05529
Packing leak identified
04/18/2019
Drawings
E105955
Revision 46
Procedures
MT-GM-003A
Swing check valve disassembly, inspection, and reassembly
Revision 2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RHR system leakage test
Revision 11
RHR system leakage quantification test
Revision 15
SM-202-C04
Month Channel C 2D630 125VDC Battery Discharge
Modified Performance Test and Battery Charger Capability
Test
Revision 25
SO-054-B03
Quarterly ESW Flow Verification LOOP B
Revision 20
SO-249-014B
RHR cold shutdown valve exercising, Division II
Revision 0
SO-249-018
RHR Division II, 2 year RPI checks
Revision 0
SO-249-B02
day RHR flow verification B loop
Revision 27
SO-250-005
Month RCIC Flow Verification
Revision 23
Work Orders
1938604
B ESW pump discharge valve has ~10 gpm leakby
10/13/2015
2177800
HPCI exhaust vacuum breaker check valve repair
04/13/2019
211054
25 VDC electrical testing
10/11/2018
242551
day RHR flow verification Loop B
03/05/2019
Corrective Action
Documents
AR-2019-04097
Revise TP-259-030 for relief valve set pressure
03/28/2019
CR-2019-04137
Outboard D MSIV exceeded TS leakage limit
03/28/2019
CR-2019-05012
Unexpected results for SO-283-005, test aborted
04/10/2019
CR-2019-05398
Simulator does not respond correctly during RPV hydrostatic
pressurization/depressurization
04/14/2019
Procedures
MT-024-024
Diesel Engine Analysis and Load Bearing
Revision 21
OP-024-001
Diesel Generators
Revision 87
LLRT of main steam isolation valves penetration number X-
7D
Revision 21
SO-024-001A
Monthly Diesel Generator 'A' Operability Test
Revision 28
SO-153-004
Unit 1 Quarterly SBLC Flow Verification
Revision 45
SO-200-023
ASME Class I Boundary System Leakage Test
Revision 4
Calculations
EC-013-1081
Generic Letter 86-10 to Determine Raceway Fire
Revision 1
EC-013-1910
Calculation to Determine CO2 Room Concentrations for the
Rooms Protected with an Automatic CO2 System
Revision 1
Corrective Action
Documents
AR-2019-00903
Evaluate impacts to degraded fire wraps
01/15/2019
AR-2019-01849
Engineering evaluation of wetted versa-wrap on conduit
C1P107 in fire zone 1-6I in support of Operab
2/06/2019
CR-2014-04167
A re-review of IN-2007-06 revealed the original evaluation
2/06/2014
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
did not address ESW/RHRSW manhole pipes
CR-2014-07344
External corrosion discovered on safety related piping and
supports in vaults
03/06/2014
CR-2016-04833
Gaps in corrective actions from CDBI inspection
2/26/2016
CR-2016-23373
Issues identified during CDBI with 125VDC MCCBs
10/14/2016
CR-2017-13423
ISI inspection of A ESW piping VA021
07/18/2017
CR-2017-14366
The scope of the safety related vault inspections needs to be
expanded to five additional vaults
08/04/2017
CR-2017-18437
ISI inspection of ESW/RHRSW piping in VA022
10/27/2017
CR-2018-09952
Understand why actions were not taken to address 2013
06/29/2018
CR-2018-11415
Electrical testing of 125VDC molded case circuit breakers
may be necessary
08/01/2018
CR-2018-12271
Minor surface corrosion found on flange bolting
08/23/2018
CR-2018-12276
Minor surface corrosion found on flange bolting
08/23/2018
CR-2018-12564
Minor surface corrosion found on flange bolting
08/29/2018
CR-2018-12566
Minor surface corrosion found on flange bolting and minor
coating loss on flange surface
08/29/2018
CR-2018-12598
09/28/2018
CR-2018-16967
U1 Entry into ON-FLOOD-101 due to flooding in the reactor
building
2/17/2018
CR-2018-16972
Floor drain slow to accept influent on RW 646'
2/17/2018
CR-2018-17000
U1 RB 749' floor drain blockage requires resolution
2/18/2018
CR-2019-00452
RTSV 2142569 (SI-213-241) fuel pool heat exchanger room
fire protection not able to be performed
01/08/2019
CR-2019-00524
Unable to repressurize PA-223 from air supply
01/09/2019
CR-2019-00739
New Leak identified in U1 Fuel Pool Cooling Hold Pump
Room, Elev 779'. Leak is 15 dpm.
01/15/2019
CR-2019-01495
Fire damper FPD-3-21-3-1 did not pass the inspection
01/30/2019
CR-2019-04113
The fire seal in penetration X-12-5-185 is less than the
minimum required depth
03/28/2019
CR-2019-04683
CR to document resolution of 125VDC MCCB electrical
testing
04/04/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2019-04758
Had breaker fail to reset during testing
04/06/2019
Corrective Action
Documents
Resulting from
Inspection
CR-2019-01497
Question on Firewatch methodology for inaccessible areas
meeting the intent of our FPRR
01/30/2019
CR-2019-07066
NRC walk down observation
05/21/2019
CR-2019-07153
NRC Question regarding beaker coordination of 1B23023
05/22/2019
CR-2019-07380
Penetrations X-27-4-18 and X-27-4-19 (Unit 1 RB Elev 719')
leaking gel
05/29/2019
CR-2019-07537
PA-015 FP in E DG Bay has packing leak dripping roughly 1
drop every 2 minutes
05/31/2019
CR-2019-07541
Housekeeping issue in Unit 1 Reactor Building Elevation
719' Identified by the NRC Resident
05/31/2019
Drawings
C-1725
Reactor Building Fire Zone Plan of Protected Tray Raceway
Elevation 779' 1"
Revision 2
C-1725
Reactor Building Fire Protection Plan Elevation 779' 1'
Revision 5
C-1725
Unit 1 Reactor Building Fire Doors and Fire Dampers
Elevation 779' 1"
Revision 6
C-1725
Unit 1 Reactor Building Fire Zone Plan Elevation 779' 1"
Revision 9
C-1725
Unit 1 Reactor Building Fire Detector Location Plan Elevation
779' 1" to 799' 1"
Revision 6
C-1725
Reactor Building Fire Zone Plan of Protected Conduit
Raceway Elevation 779' 0"
Revision 2
C-1726
Reactor Building Fire Detector Location Plan Elevation 799'
1" to 818' 1"
Revision 4
FF62009
Fire Barrier Upgrade A1P075, A1P105, C1P107 & E1P005
Wrapped Raceways and JB2068
Revision 0
HRC-10-1
Isometric - Yard Emergency Service Water - Unit 1 & 2
Revision 4
HRC-2-53
Isometric - Yard RHR Service Water - Units 1 & 2
Revision 7
Fire Plans
Access Area (I-604) Adjoining Rooms (I-621, 620, 619, 606,
601) Fire Zones 1-6A, 1-61, 0-6G Elevation 779'-1"
Revision 5
Access Area (I-604) Adjoining Rooms (I-621, 620, 619, 606,
601) Fire Zones 1-6A, 1-61, 0-6G Elevation 779'-1'
Revision 5
Miscellaneous
Fire Endurance Test Acceptance Criteria for Fire barrier
Systems Used to Separate Redundant Safe Shutdown
Trains Within the Same Fire Area
03/25/1994
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2149189
Design Change Package, Install Sump Pumps in Vaults
VA011 and VA012
Revision 2
8856-M-208
Technical Specification for External Surface Treatment of
Underground Steel Pipe for the Susquehanna Steam Electric
Station Units 1 and 2
Revision 2
EG263
Transient Combustibles in Crimp
Revision 1
EPRM 2211054
Unit 2 Division I 125VDC Siemens/ITE Molded Case Circuit
Breaker Electrical Testing
04/06/2019
EPRM 2231580
Unit 2 Division II Siemens/ITE Molded Case Circuit Breaker
Electrical Testing
03/27/2019
NRC Regulatory Issue Summary 2005-07 Compensatory
Measures to Satisfy the Fire Protection Program
Requirements
04/19/2005
Periodic Testing and Preventive Maintenance of Molded
Case Circuit Breakers
08/22/1993
Compensatory and Alternative Regulatory Measures for
Nuclear Power Plant Fire Protection
August 2015
Procedures
NDAP-QA-0443
Firewatch Procedure
Revision 14
NDAP-QA-0446
Fire Barrier Program
Revision 8
NSEI-AD-418
Miscellaneous Buildings Structural Monitoring
Revision 4
SI-113-245
Annual Functional Test of Fire Protection Smoke Detectors
for Fire Zones 1-6I and 1-6A
Revision 9