IR 05000387/2023001

Integrated Inspection Report 05000387/2023001 and 05000388/2023001

ML23132A143
Person / Time
Site:	Susquehanna
Issue date:	05/12/2023
From:	Sarah Elkhiamy Division of Operating Reactors
To:	Berryman B Susquehanna
References
IR 2023001
Download: ML23132A143 (1)

Text

May 12, 2023

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000387/2023001 AND 05000388/2023001

Dear Brad Berryman:

On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station, Units 1 and 2. On May 1, 2023, the NRC inspectors discussed the results of this inspection with Edward Casulli, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2. 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 Title 10 of the Code of Federal Regulations (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Sarah H. Elkhiamy, Chief Projects Branch 4 Division of Operating Reactor Safety

Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF-22

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000387 and 05000388

License Numbers:

NPF-14 and NPF-22

Report Numbers:

05000387/2023001 and 05000388/2023001

Licensee:

Susquehanna Nuclear, LLC

Facility:

Susquehanna Steam Electric Station

Location:

Berwick, PA

Inspection Dates:

January 1, 2023, to March 31, 2023

Inspectors:

C. Highley, Senior Resident Inspector

E. Brady, Resident Inspector

J. Bresson, Acting Resident Inspector

H. Anagnostopoulos, Senior Health Physicist

C. Dukehart, Resident Inspector

V. Fisher, General Engineer, NRAN

N. Floyd, Senior Reactor Inspector

K. Mangan, Senior Reactor Inspector

J. Schoppy, Senior Reactor Inspector

Approved By:

Sarah H. Elkhiamy, Chief

Projects Branch 4

Division of Operating Reactor Safety

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

Emergency Service Water 'A' Pump Discharge Check Valve Failure to Close Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000387,05000388/2023001-01 Open/Closed

[H.7] -

Documentation 71111.15 The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(f)(4) because the licensee did not perform adequate inservice testing on the emergency service water (ESW) 'A' pump discharge check valves within the scope of the American Society of Mechanical Engineers (ASME) OM Code. Specifically, the ESW 'A' pump discharge check valves testing did not adequately ensure check valve closure in accordance with the inservice testing program requirements, because an error in a calculation allowed manual closure of the check valve which exceeded the back flow pressure required by ASME OM Code. As a result, the licensee did not adequately detect and correct degraded conditions with the 'A' ESW pump check valve sticking open.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000387/2022-001-00 LER 2022-001-00 for Susquehanna Steam Electric Station, Unit 1, Main Steam Isolation Valve Leakage 71153 Closed LER 05000387/2022-001-01 LER 2022-001-01 for Susquehanna Steam Electric Station, Unit 1, Main Steam Line Isolation Valve Leakage Due to Seating Surfaces Wear and Material Deposits 71153 Closed LER 05000387/2022-002-00 LER 2022-002-00 for Susquehanna Steam Electric Station, Unit 1, Automatic Reactor Scram Due to High Reactor Vessel Pressure Following Inadvertent Closure of Inboard Main Steam Isolation Valve 71153 Closed

LER 05000387/2022-002-01 LER 2022-002-01 for Susquehanna Steam Electric Station, Unit 1, Automatic Reactor Scram Due to Reactor Protection System Actuation on High Reactor Vessel Pressure Signal Following Inadvertent Closure of Inboard Main Steam Isolation Valve 71153 Closed

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On January 6, 2023, the unit was down powered to 63.7 percent for a rod pattern adjustment. The unit was returned to rated thermal power on January 8, 2023. On March 17, 2023, the unit was down powered to 61.9 percent for scram time testing and a rod pattern adjustment. The unit was returned to rated thermal power on March 20, 2023, and remained at or near rated thermal power for the remainder of the inspection period.

Unit 2 began the inspection period at rated thermal power. On January 5, 2023, the unit was down powered to 79.5 percent for a rod pattern adjustment. The unit was returned to rated thermal power on January 6, 2023. On January 13, 2023, the unit was shut down for a planned maintenance outage. The unit was returned to rated thermal power on January 23, 2023. On January 24, 2023, the unit was down powered to 68.3 percent for a rod pattern adjustment. The unit was returned to rated thermal power on January 25, 2023. On February 5, 2023, the unit was down powered to 71.5 percent for a rod pattern adjustment. The unit was returned to rated thermal power on February 6, 2023. On February 10, 2023, the unit was down powered to 71.7 percent for a rod pattern adjustment. The unit was returned to rated thermal power on February 10, 2023. On February 17, 2023, the unit was down powered to 69 percent for a rod pattern adjustment. The unit was returned to rated thermal power on February 19, 2023. On February 23, 2023, the unit was down powered to 76 percent for a rod pattern adjustment. The unit was returned to rated thermal power on February 24, 2023. On February 24, 2023, the unit commenced coast down and shut down for the refueling outage on March 20, 2023, and remained shut down 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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk-significant activities, and completed on-site portions of IPs. 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.

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2, loop 'A' residual heat removal on January 18, 2023

(2) Unit 2, division II residual heat removal on March 13, 2023

(3) Unit 1, reactor core isolation cooling pump partial walkdown on March 17, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 2, divisions I and II 4.16 kV switchgear rooms, FZ 2-5F and 2-5G, on February 14, 2023

(2) Unit Common, refueling floor, FZ 0-8A, on March 10, 2023

(3) Unit 2, divisions I and II 125V and 250V battery rooms, FZ 0-28C, D, E, F, and G, on March 21, 2023

(4) Unit 1, divisions I and II 125V and 250V battery rooms, FZ 0-28I, J, K, L, M, and N on March 21, 2023

(5) Unit Common, 'E' diesel generator bay, FZ 0-41E, on March 21, 2023

Fire Brigade Drill Performance (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on February 21, 2023.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit Common, 'D' emergency diesel generator lube oil and jacket water heat exchangers on February 7, 2023

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 the Unit 1 sequence exchange on January 6, 2023, and the inspectors observed and evaluated licensed operator performance in the control room during the Unit 2 cooldown from Mode 3 to 4 on March 20, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator cycle evaluation (LOR-23-02-SA9) which included spurious start emergency diesel generator, a runback, loss of a reactor recirculating pump, failure of scram discharge volume to isolate, fuel failure, emergency core cooling system flow controller failure, steam leak, loss of electrical busses, and failure of low-pressure emergency core cooling system on February 16, 2023.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (10 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit Common, elevated risk during automatic depressurization system, standby liquid control, and uninterruptible power supply work on January 4, 2023

(2) Units 1 and 2, increased risk window due to equipment out of service when performing reactor core isolation cooling surveillance requirement because the 'A' emergency diesel generator was out of service due to a failed post-maintenance test on January 24, 2023

(3) Units 1 and 2, increased risk during performance of the Unit 2 control rod drive pump work and diesel generator and motor-driven fire pump runs on February 7, 2023

(4) Unit 1, high-pressure coolant pump out of service for maintenance on February 27, 2023

(5) Unit 2, increased risk due to OTS536 emergency diesel generator and reactor core isolation cooling functional test at remote shutdown panel 2C201A on March 2, 2023

(6) Unit 2, high-pressure coolant injection increased risk window on March 9, 2023

(7) Unit 1, increased risk window on March 9, 2023

(8) Unit 2, yellow risk window on March 13, 2023

(9) Unit 2, refueling outage shutdown risk on March 15, 2023

(10) Unit 2, yellow risk division II loss of offsite power/loss-of-coolant accident test on March 22, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)

The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 2, control rod operability following license amendment on January 17, 2023

(2) Unit Common, 'A' emergency diesel generator failed post maintenance testing, CR-2023-01436, on January 25, 2023

(3) Unit 1, control rod drive pump, valves, and piping operability/functionality based on CR-2022-13790, CR-2022-13684, and CR-2021-15378 on February 1, 2023

(4) Unit Common, 'E' emergency diesel generator breaker to emergency core cooling system bus 4kV motor disconnect switch failure on February 1, 2023

(5) Unit Common, ESW pump 'A' discharge check valve not closing after securing pump, CR-2023-02503, on February 2, 2023

(6) Unit 1, high-pressure coolant injection ramp generator delayed resetting (up to 7 minutes) after the stop valve closure, CR-2023-02899 and CR-2023-02849, on February 21, 2023

(7) Unit 2, 2C core spray pump discharge check valve failure to close following reactor pressure vessel fill to the flange on March 22, 2023

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, temporary modification of 2A-C reactor feed pump vibration trip and temporary design change 2474035 on January 17, 2023

(2) Unit 1, permanent modification engineering change (EC) 2380975, commercial load center Unit 1 230 kV tie-in; EC-2392937, Unit 1 230 kV relay and protection upgrades; and associated 10 CFR 50.59 safety evaluation (SE 00033) on March 13, 2023

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage (IP Section 03.01) (2 Partials)

(1)

(Partial)

Unit 2, The inspectors evaluated planned maintenance outage for unidentified leakage activities from January 13 to 17, 2023. The inspectors completed inspection procedure sections a, b1, b2, c.1, c.2, c.6, d.1, and d.2.

(2)

(Partial)

Unit 2, The inspectors evaluated refueling outage U221RIO activities from March 20 to 31, 2023. The inspectors completed inspection procedure sections a, b, and c.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (IP Section 03.01) (2 Samples)

(1) Unit 2, 101/103 reactor water cleanup bottom head drain isolation valve repair during the forced outage on November 15, 2022

(2) Unit Common, 'A' emergency diesel generator failed post-maintenance testing, CR-2023-01436, on January 25, 2023

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Unit Common, out of calibration measuring and test equipment used during inservice testing of residual heat removal loops crossover pressure relief valve on March 1, 2023

(2) Unit 2, high-pressure coolant injection logic system functional test, SO-252-102, on March 9, 2023

(3) Unit 2, residual heat removal service water and ESW functional test from the remote shutdown panel, SO-200-022, on March 13, 2023

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 1 reactor core isolation coolant flow surveillance on January 26, 2023

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Unit 2 reactor coolant system leakage detection testing on January 12, 2023

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) Unit Common, turbine marine generator quarterly functional run on February 13, 2023

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Licensed operator cycle evaluation (LOR-23-02-SA9) which included spurious start emergency diesel generator, a runback, loss of a reactor recirculating pump, failure of scram discharge volume to isolate, fuel failure, emergency core cooling system flow controller failure, steam leak, loss of electrical busses, failure of low-pressure emergency core cooling system, and the emergency declaration of a site area emergency FS 1.1 on February 16,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Release of material from the Unit 2, 686-foot elevation, reactor building truck lock

(2) Routing personnel and material release from the north health physics access area

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensees control of radiological hazards for the following radiological work:

(1) RWP 20232382

(2) RWP 20232115

(3) RWP 20232351

(4) RWP 20232320

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) Unit 2 reactor building, 719-foot elevation, penetration room

(2) Unit 2 drywell bottom head area inner annulus door

(3) Unit 2 reactor building, 719-foot elevation, control rod drive mechanism removal chute

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (8 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Small Article Monitor 3CPO-0002

(2) Frisker L177-0086

(3) Personnel Contamination Monitor ARGO-0030

(4) Continuous Air Monitor AMS4-0039

(5) Portal Monitor GEM5-0013

(6) Whole Body Counter FSCN-0002

(7) Frisker L236-0008

(8) Frisker L177-0093

Calibration and Testing Program (IP Section 03.02) (13 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Continuous Air Monitor AMS4-0018 (observed calibration)

(2) Ion Chamber Fluke Model 451B FMFM-0043 (observed calibration)

(3) Bench Counter Ludluum (observed calibration)

(4) Small Article Monitor 3CPO-0002

(5) Frisker L177-0086

(6) Personnel Contamination Monitor ARGO-0030

(7) Continuous Air Monitor AMS4-0039

(8) Portal Monitor GEM5-0013

(9) Whole Body Counter FSCN-0002

(10) Frisker L236-0008

(11) Frisker L177-0093

(12) Portal Monitor GEM5-0010

(13) Portal Monitor GEM5-0011

Effluent Monitoring Calibration and Testing Program (IP Sample 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) General Atomics Liquid Radwaste Effluent Discharge Radiation Monitor

(2) Unit 1A Residual Heat Removal Service Water Radiation Monitor

OTHER ACTIVITIES - BASELINE

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

(1) Online risk management

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000387/2022-002-00, Automatic Reactor Scram Due to High Reactor Vessel Pressure Following Inadvertent Closure of Inboard Main Steam Isolation Valve (Agencywide Documents Access and Management System (ADAMS) Accession No.

ML22202A279): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements. This LER is closed.

(2) LER 05000387/2022-002-01, Automatic Reactor Scram Due to Reactor Protection System Actuation on High Reactor Vessel Pressure Signal Following Inadvertent Closure of Inboard Main Steam Isolation Valve (ML22339A095): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements. This LER is closed.

(3) LER 05000387/2022-001-00, Main Steam Isolation Valve Leakage (ML22152A249):

The inspection conclusions associated with this LER are documented in this report under the Inspection Results Section. This LER is closed.

(4) LER 05000387/2022-001-01, Main Steam Isolation Valve Leakage Due to Seating Surfaces Wear and Material Deposits (ML22222A010): The inspection conclusions associated with this LER are documented in this report under the Inspection Results Section. This LER is closed.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===71003 - Post-Approval Site Inspection for License Renewal

From February 13 to 16, 2023, the NRC conducted a Post-Approval Site Inspection for License Renewal - Phase 3 at Unit 1 in accordance with the license renewal inspection program. This inspection took place after the period of extended operation (PEO) for Unit 1, which began on July 18, 2022. Per IMC 2516, the license renewal inspection program is the process used by NRC staff to verify the adequacy of aging management programs, time limited aging analyses, and other activities associated with an applicants request to renew an operating license of a commercial nuclear power plant beyond the initial licensing period under 10 CFR Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants.

Post-Approval Site Inspection for License Renewal===

(1) Review of commitment items that remained open during the Phase 2 inspection:

As documented in the NRC Post-Approval Site Inspection for License Renewal - Phase 2 Inspection Report 05000387/2022011 (ML22066B013), commitment numbers 25, 34, and 35 remained open and subject to further inspection to verify the commitment would be completed as described in the NRC safety evaluation report.

The inspectors reviewed closure documents, updated programs and procedures, corrective action documents, completed surveillance records, work orders, and conducted interviews to verify the licensee completed the necessary actions for the closure of these commitments. The following commitments and associated aging management programs were evaluated by the team:

• Selective Leaching Inspection, Commitment 25

The Selective Leaching Inspection Program is a new one-time inspection program to detect and characterize age-related degradation on internal and external surfaces of susceptible components including piping, valve bodies, pump casings, heat exchanger components, hydrants, level gauges, and orifices. The inspectors verified that remaining one-time inspections were completed prior to the plant entering the PEO in 2022.

During the Phase 2 inspection, the inspectors determined the licensee did not address the active degradation mechanism identified at the plant. During the Phase 3 inspection, the inspectors verified that the licensee developed a new aging management program to periodical inspect and evaluate selective leaching for the duration of the renewed operating license. This commitment is complete.

• Structures Monitoring Program, Commitment 34

The Structures Monitoring Program is an existing program, with enhancements, to ensure that age-related degradation of plant structures and structural components is managed so that each structure or structural component retains the ability to perform its intended safety function. The inspectors verified that remaining inspections were completed prior to the plant entering the PEO in 2022.

During the Phase 2 inspection, the inspectors determined that the licensee did not adequately implement the enhancement to the program to provide direction for quantifying, monitoring, trending, applying acceptance criteria, and documenting evaluation results. During the Phase 3 inspection, the inspectors verified the structures monitoring program and associated procedures were updated to address the enhancement. The inspectors also reviewed a sample of monitoring reports completed over the past year to determine whether the results included quantitative data and evaluations, when applicable. This commitment is complete.

• RG 1.127 Water-Control Structures Inspection, Commitment 35

The RG 1.127 Water-Control Structures Inspection is an existing program, with enhancements, to detect age-related degradation of the spray pond, engineered safeguards service water pumphouse, and the earthen embankments along the spray pond.

During the Phase 2 inspection, the inspectors determined that the licensee did not complete two of the enhancements under the license renewal commitment. During the Phase 3 inspection, the inspectors verified the structures monitoring program and associated procedure were updated to include specific acceptance and evaluation criteria, and the inspectors verified that the updated procedure included instruction that wetted surfaces of submerged areas are considered accessible. In addition, the inspectors verified that submerged areas of the structures were added to the scope of the program and that the licensee had planned actions to complete the inspections of the submerged areas. This commitment is complete.

Impact of Financial Conditions on Continued Safe Performance

In that the licensee, Susquehanna Nuclear, LLC, and the licensees parent company, Talen Energy Supply, was under bankruptcy protection/reorganization during the inspection period, NRC Region I conducted reviews of processes at Susquehanna. Using the flexibilities in the baseline inspection program, the inspectors evaluated several aspects of the licensees operations to assess whether any identified plant performance issues could be related to the stations financial condition. The factors reviewed included:

(1) impact on regulatory required plant staffing,

(2) corrective maintenance backlog,

(3) changes to the planned maintenance schedule,

(4) corrective action program implementation, and (5)reduction in outage scope, including risk-significant modifications. In particular, the inspectors verified that licensee personnel continued to identify problems at an appropriate threshold and enter these problems into the corrective action program for resolution. The inspectors also verified that the licensee continued to develop and implement corrective actions commensurate with the safety significance of the problems identified.

The review of processes at Susquehanna included continuous reviews by the resident inspectors, as well as the specialist-led baseline inspections completed during the inspection period:

71124.05 - Radiation Monitoring Instrumentation, 71003 - Post-Approval Site Inspection for

License Renewal, and 71152A - Performance Indicator and Resolution for Online Maintenance Risk Management.

INSPECTION RESULTS

Emergency Service Water 'A' Pump Discharge Check Valve Failure to Close Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000387,05000388/2023001-01 Open/Closed

[H.7] -

Documentation 71111.15 The inspectors identified a Green NCV of 10 CFR 50.55a(f)(4) because the licensee did not perform adequate inservice testing on the 'A' ESW pump discharge check valves within the scope of the ASME OM Code. Specifically, the 'A' ESW pump discharge check valves testing did not adequately ensure check valve closure in accordance with the inservice testing program requirements, because an error in a calculation allowed manual closure of the check valve which exceeded the back flow pressure required by ASME OM Code. As a result, the licensee did not adequately detect and correct degraded conditions with the 'A' ESW pump check valve sticking open.

Description:

The ESW system is a safety-related system designed to provide a reliable source of cooling water to support operation of the emergency core cooling system and reactor core isolation coolant room coolers, diesel generators, the Unit 2 direct expansion units, and control structure chillers as needed during normal plant operation, transient plant operation, and under plant accident conditions. The ESW system consists of four pumps that are divided into two loops, each of which is designed to supply 100 percent of the ESW cooling requirements to both units and the common emergency diesel generators simultaneously. The four pumps are located in the ESW pumphouse located at the edge of the spray pond. The ESW system is designed to take water from the spray pond, discharge flow through the various heat exchangers and cooling loads in both units, and return the flow to a common residual heat remover service water/ESW return header to the spray pond for dissipation of heat to the atmosphere. Each ESW pump has a discharge check valve, which opens to permit required pump flow and closes when the pump is off to prevent reverse flow if the second pump in the loop is operating.

On January 6, 2023, the 'A' ESW pump discharge check valve failed to close after securing the pump during a station procedure, and CR-2023-00658 was written to document the condition. The station started the 'C' ESW pump to provide reverse flow to shut the 'A' ESW pump discharge check valve, but it did not close. The station then used both the 'C' ESW pump reverse flow and an operator manually closing on the valve arm to get the valve closed.

The station declared the 'A' ESW pump inoperable and entered the Technical Specification (TS) 3.7.2 Limiting Condition of Operation (LCO). On January 7, 2023, the station performed a repack of the valve, but the valve still would not close on its own and required an operator on the arm to close the valve. The station determined that the 'A' ESW pump discharge check valve was operable and exited the TS 3.7.2 LCO. Additionally, the station identified that the 'A' ESW pump discharge check valve had failed to close on securing the pump on three instances during 2022 (CR-2022-00994, CR-2022-03954, and CR-2022-04293).

On February 3, 2023, the inspectors observed the securing of the 'A' ESW pump and observed that the discharge check valve did not close. The operator in the field pushed the valve closed with their foot using the external valve arm. The operator commented that the valve was getting harder to close. On February 10, 2023, the 'A' and 'C' ESW pumps were in operation to support emergency diesel generator testing. When the 'A' ESW pump was secured, the back flow from the 'C' ESW pump was insufficient to close the 'A' ESW pump discharge check valve as required, and CR-2023-02503 was written to document the condition. The station entered the TS 3.7.2 LCO for the 'A' ESW loop inoperable at 1650 and exited at 1703. A prompt operability determination was requested for CR-2023-02503.

ASME OM Code 2004 ISTC-5220 check valves ISTC-2521 valve obturator movement (a)(1),states, in part, that check valves that have safety function in both directions shall be exercised by initiating flow... to a full open position or position required to perform its intended function, verify that on cessation or reversal of flow, and the obturator has traveled to the seat. Additionally, ISTC-5224 corrective action, states, in part, if check valve fails to exhibit the required change of obturator position, it shall be declared inoperable. A retest showing the acceptable performance shall be run following any required corrective action before the valve is returned to service.

The inspectors reviewed the ESW operating procedure and the calculation EWR-2017-16108. The operating procedure allowed the operator to manually close the ESW pump check valves with reasonable force without declaring the loop inoperable. However, the calculation that supported this approach was determined by the licensee to have an error, such that the force applied by the reverse flow was a factor of four lower than the calculated value. This was captured in CR-2023-02620. The inspectors had further discussions with the station concerning the calculation and the forces applied by the manual operation which led to the licensee determining that the manual closing of the ESW pump discharge check valves did not meet inservice testing criterion. This was documented in CR-2023-02620 and CR-2023-04179.

Corrective Actions: The licensee replaced the 'A' ESW pump discharge check valve with a rebuilt one on February 21, 2023, and updated the ESW system operating procedure to remove the allowance for manual closure of the check valve, requiring use of reverse flow from the other pump to close the valve.

Corrective Action References: ACT-01-CR-2023-04179

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to perform adequate closure testing of the ESW pump discharge check valve in accordance with the ASME OM Code was reasonably within the licensees ability to foresee and correct and should have been prevented. Specifically, a calculation that was developed in 2017 contained an error that resulted in the station allowing manual closure of the check valves, contrary to the ASME OM Code for ISTC-5220 check valves and ISTC-5224 corrective action. This resulted in the licensee not performing timely corrective maintenance to address the sticking open 'A' ESW pump discharge check valve.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the ESW pumps discharge check valves safety function includes closing, and the 'A' ESW pump discharge check valve was observed to remain open with sustained reverse flow, resulting in inoperability of the 'A' ESW loop.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined that the finding was of very low safety significance (i.e., Green). Specifically, the ESW system has two independent trains that provide cooling to the emergency core cooling system, so the loss of the 'A' train of ESW does not constitute a loss of the probabilistic risk assessment (PRA) safety function of the ESW system since the 'B' train of ESW remains operable. Therefore, the finding screened to Green based on the determination that the performance deficiency did not cause a loss of PRA safety function for a train or system.

Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate, and up-to-date documentation. Specifically, the licensee failed to perform an adequate and accurate calculation as part of an engineering justification to close the ESW check valves manually vice using the reverse flow from the opposite pump. The calculation did not adequately account for all the forces occurring on the check valve internals and had an error that caused the force calculated to be higher by a factor of four in a non-conservative direction.

Enforcement:

Violation: 10 CFR 50.55a(f)(4) requires, in part, that valves that are within the scope of the ASME OM Code must meet the inservice test requirements. 2012 ASME OM Code Edition, the code edition of record for the interval, ISTC-3522, Category C Check Valves, requires each category C check valve to be exercised or examined in a manner that verifies obturator travel by using the methods in ISTC-5221. ISTC-5221, Valve Obturator Movement, requires necessary valve obturator movement during exercise testing to be demonstrated by performing both an open and a close test and the exercise test to verify that on cessation or reversal of flow the obturator has traveled to the seat. ISTC-5224, Corrective Action, requires that if a check valve fails to exhibit the required change of obturator position, it shall be declared inoperable. SUS-ISTPLN-100.0, Susquehanna Steam Electric Station Unit 1 Inservice Testing Program, Revision 9, requires the category C, ESW pump discharge check valves to be tested in both the full open and full closed positions per ISTC-5221.

Contrary to this, from April 1, 2020, to April 4, 2023, the station did not adequately test the ESW pump discharge check valves in accordance with the ASME OM Code. Specifically, the ESW operating procedure relied on an inadequate calculation that allowed for the manual closing of the discharge check valves rather than requiring reverse flow to close the valves.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Online Risk Management 71152A On August 22, 2022, the licensee initiated a corrective action condition report to evaluate an adverse online risk management trend associated with PRA codes that were inadvertently removed from the work week schedule while the component was still unavailable.

Specifically, the licensee initiated CR-2022-12807 to evaluate, determine the cause of the performance gaps, and provide corrective actions addressing CR-2022-01004, CR-2022-08279, and CR-2022-12764. In CR-2022-12807, the licensee noted that there were no actual consequences for the previous issues (captured in the above CRs), but the adverse performance trend had the potential for a more consequential outcome such as an unknown or unexpected online risk color change. The licensees associated level of effort causal evaluation determined that the direct cause was inadequate work week manager (WWM)guidance for managing PRA scheduled component work statuses during performance of the daily routine to ensure fidelity when conditions change. Corrective actions included creating a PRA desktop guide for WWM use to provide detailed guidance to drive consistency in how PRA components are managed in the schedule and when emergent conditions occur or when work scope changes. Following implementation of their corrective actions, the licensee also completed an effectiveness review to verify that the actions taken, including the new PRA desktop guide, were effective in addressing the adverse trend.

The inspectors reviewed the work week schedule and risk assessments for both units for the week of February 20, 2023, performed several walkdowns of Units 1 and 2 protected equipment as conditions changed throughout the work week, reviewed the daily leadership alignment package PRA report, observed several work control morning meetings and the WWM turnover process, and performed an independent review of initiated CRs to assess the licensees corrective action effectiveness with respect to the online risk management performance deficiencies previously identified. The inspectors considered the standards that applied in the licensees online risk management and protected equipment procedures, the licensees corrective action program (CAP), 10 CFR Part 50, Appendix B, and 10 CFR 50.65(a)(4). Based on the documents reviewed, protected equipment walkdowns, and discussions with operations and work control management personnel, the inspectors did not identify any findings of significance during this inspection.

Minor Violation: 'B' Steam Line Inboard Main Steam Isolation Valve Exceeded Technical Specification Leakage Limit 71153 The inspectors identified a self-revealing violation of TS 3.6.1.3 for main steam isolation valve (MSIV) HV141F022B exceeding the TS limit for seat leakage. Specifically, on April 2, 2020, during the Unit 1 refueling outage, CR-2020-04785 was written to document that the inboard

'B' steam line MSIV HV141F022B leakage trend projected that the valve would challenge the TS limit over the next operating cycle, based on linear trend projection. The condition report recommended that internal valve maintenance be performed to reduce seat leakage.

Susquehanna's management review committee reviewed the condition report and decided not to work in the body of the valve, stating that there was variability in the MSIV leakage values from cycle to cycle making it difficult to predict future seat leakage. During the subsequent Unit 1 refueling outage on April 2, 2022, during local leak rate testing, as-found leakage through the inboard MSIV HV141F022B exceeded the TS limit. The inspectors reviewed CR-2020-04785 and the leakage trend data from 2018, 2020, and 2022. The inspectors determined that the 2022 failure of the MSIV was reasonably within the licensees ability to foresee and correct and should have been prevented.

Screening: The inspectors determined the performance deficiency was minor. The licensees failure to ensure the MSIV HV141F022B was operable during the next operating cycle in accordance with TS 3.6.1.3 was a minor performance deficiency, because although it is associated with the design control attribute it did not adversely affect the Barrier Integrity cornerstone objective since the redundant MSIV (HV141F028B) in the 'B' steam line had an as-found leakage of 32.8 scfh, below the TS Surveillance Requirement (SR) 3.6.1.3.12 limit of 100 scfh, and the combined inboard and outboard leakage was less than 300 scfh. The redundant valve, bounded by engineering evaluation, provided assurance that dose consequences would have remained within the regulatory limit of 5 rem total effective dose equivalent for the control room and 25 rem total effective dose equivalent for the low population zone and exclusion area boundary.

Enforcement:

TS 3.6.1.3, Primary containment isolation valves (PCIVs), LCO requires each PCIV shall be operable in Modes 1, 2, and 3.

Contrary to the above, on April 2, 2022, during local leak rate testing conducted during the Unit 1 refueling outage, as-found leakage through the inboard MSIV HV141F022B exceeded the TS allowable leak rate. This condition existed during the previous operating cycle for longer than allowed by TS 3.6.1.3.

This condition was corrected during the Unit 1 refueling outage and restored compliance to TS 3.6.1.3.

The disposition of this violation closes LER 05000387/2022-001-00 and 05000387/

2022-001-01, Main Steam Isolation Valve Leakage.

This failure to comply with TS 3.6.1.3 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On February 9, 2023, the inspectors presented the radiological instrumentation inspection results to Derek Jones, Acting Site Vice President, and other members of the licensee staff.

• On February 16, 2023, the inspectors presented the Unit 1 license renewal phase 3 inspection results to Doug LaMarca, Acting Plant Manager, and other members of the licensee staff.

• On February 23, 2023, the inspectors presented the online risk management inspection results to Dave Hoppe, Nuclear Operations Manager, and other members of the licensee staff.

• On April 6, 2023, the inspectors presented the radiological hazards assessment during Unit 2 refueling outage inspection results to Edward Casulli, Site Vice President, and other members of the licensee staff.

• On May 1, 2023, the inspectors presented the integrated inspection results to Edward Casulli, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Corrective Action

Documents

CR-2022-01935, CR-2022-01936, CR-2022-01937

71003

Corrective Action

Documents

Resulting from

Inspection

CR-2023-02613, CR-2023-02710

71003

Miscellaneous

EC-STRU-2019

Structural Monitoring Program Inspections of Reactor

Building

Revision 7

71003

Miscellaneous

EC-STRU-2031

Structural Monitoring Program Inspections of ESSW

Pumphouse

Revision 4

71003

Miscellaneous

EC-STRU-2055

Structural Monitoring Program Inspections of Control

Structure

Revision 3

71003

Miscellaneous

EC-STRU-2076

Structural Monitoring Program Inspections of Spray Pond

Revision 3

71003

Procedures

NDAP-QA-1163

Structures Monitoring Program

Revision 10

71003

Procedures

NEPM-QA-1205

ESSW Pumphouse / Spraypond - Structures Monitoring

Program

Revision 3

71003

Procedures

NSEP-QA-0405

Selective Leaching Inspection Program - PEO

Revision 1

71003

Procedures

NSEP-QA-0411A

License Renewal Program Implementation Guidelines

Revision 2

71111.04

Corrective Action

Documents

Resulting from

Inspection

CR-2023-01168

71111.04

Procedures

OP-249-002

RHR Shutdown Cooling

Revision 86

71111.18

Engineering

Changes

EC-2380975

Commercial Load Center Unit 1 Phase I 230 kV Tie-In

Revision 2

71111.18

Engineering

Changes

EC-2392937

Commercial Load Center Unit 1 Phase II 230 kV Relay and

Protection Upgrades

Revision 3

71111.18

Engineering

Evaluations

50.59 SE 00033

Safety Evaluation for Commercial Load Center Unit 1

Phase I 230 kV Tie-in

Revision 0

71111.20

Corrective Action

Documents

Resulting from

CR-2023-04444

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Inspection

71152A

Corrective Action

Documents

CR-2021-00583, CR-2021-12876, CR-2021-17469,

CR-2022-01004, CR-2022-08279, CR-2022-12764,

CR-2022-12807, CR-2022-16767, CR-2022-16863,

CR-2022-18477, CR-2023-00569, CR-2023-00632,

CR-2023-00697, CR-2023-01388, CR-2023-02229,

CR-2023-02229, CR-2023-02281, CR-2023-02557

71152A

Corrective Action

Documents

Resulting from

Inspection

CR-2023-02956, CR-2023-02957, CR-2023-02994,

CR-2023-03046, CR-2023-03047

71152A

Miscellaneous

Level of Effort Evaluation (CR-2022-12807)

10/07/2022

71152A

Procedures

LS-120

Issue Identification and Screening Process

Revision 14

71152A

Procedures

LS-125

Corrective Action Program

Revision 14

71152A

Procedures

NDAP-QA-0340

Protected Equipment Program

Revision 41

71152A

Procedures

NDAP-QA-1902

Integrated Risk Management

Revision 40

71152A

Procedures

PSP-26

Online and Shutdown Nuclear Risk Assessment Program

Revision 27