ML080840281
| ML080840281 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/20/2008 |
| From: | David Lew Division Reactor Projects I |
| To: | Mckinney B Susquehanna |
| KROHN, PG | |
| References | |
| 1-2007-026, 1-2007-029, RI-2007-A-0038, RI-2007-A-0062 | |
| Download: ML080840281 (2) | |
Text
CERTIFIED MAIL RETURN RECEIPT REQUESTED March 20, 2008 Mr. Britt T. McKinney RI-2007-A-0038 Senior Vice-President & Chief Nuclear Officer RI-2007-A-0062 PPL Susquehanna, LLC 769 Salem Blvd. - NUCSB3 Berwick, PA 18603-0467
Subject:
NRC Office of Investigation (OI) Case Nos. 1-2007-026 and 1-2007-029
Dear Mr. McKinney:
The Region I Field Office, NRC Office of Investigations (OI), initiated an investigation (Case No.
1-2007-026) on April 19, 2007, to determine if Pennsylvania Power & Light (PPL) line management willfully directed contract staff from TriTool to complete cutting through a pipe wall on the feedwater heater system while knowing that the pipe contained standing radioactive water and without the necessary notification of the Health Physics (HP) and effluent groups.
This work activity, associated with the LV20403A valve, was conducted on March 17, 2007, at Susquehanna Unit 2. Based on the evidence developed during the investigation, OI did not substantiate that PPL management directed workers to cut through the pipe without having contacted HP.
Testimonial and documentary evidence revealed that both the HP and Radwaste groups were properly informed of the pipe cutting activity and were involved with this job prior to the contractors being directed to cut the pipe. OI noted that the work order and area survey showed that HP and the Radwaste group were involved before the work began, the area was properly surveyed, and HP did not object to cutting the pipe. OI noted that testimony, provided by a PPL foreman who provided oversight of the activity, revealed that the foreman had visually inspected the valve and did not see any standing water prior to TriTool making the pipe cut. OI also noted that individuals who had knowledge of this activity, gained that knowledge based on second-hand information.
The Region I Field Office, NRC Office of Investigations (OI) initiated an investigation (Case No.
1-2007-029) on April 26, 2007, to determine if contractors from McCarl's and/or the licensee willfully failed to initiate an action request (AR) before the end of the day shift on March 25, 2007, to document a condition adverse to quality at Susquehanna Unit 2 regarding the potential introduction of foreign material into the reactor coolant system (RCS) during a maintenance activity. Specifically, foreign material may have entered the RCS piping during maintenance on the "B" reactor recirculation pump suction valve (HV243FO23B). Based on the evidence developed during the investigation, OI did not substantiate that contractors from McCarl's or the licensee willfully failed to initiate an AR nor were they intimidated by PMOD management to not write one.
While OI concluded that an AR should have been written by day shift personnel, OI found no testimonial or documentary evidence to support that there was any willfulness on the part of day shift personnel to not generate the AR. Once the issue was turned over to night shift personnel,
Mr. Britt T. McKinney RI-2007-A-0038 RI-2007-A-0062 2
the condition adverse to quality was documented in a condition report shortly after the information was received during the shift turnover. Further, OI found no evidence to support that any PMOD managers attempted to intimidate the day shift personnel into not writing the AR.
A violation was identified in that an AR wasnt written by the end of the day shift, in violation of plant procedure NDAP-QA-0702, Step 8.1.1. However, because an AR was written promptly after shift turnover by night shift personnel and equipment operability was not impacted, this violation was of minor significance. Minor violations are not subject to enforcement action in accordance with The Enforcement Policy nor are they required to be documented in inspection reports.
Please note that final NRC investigation documents, such as the OI reports described above, may be made available to the public under the Freedom of Information Act (FOIA) subject to redaction of information appropriate under the FOIA. Requests under the FOIA should be made in accordance with 10 CFR 9.23, Requests for Records, a copy of which is enclosed for your information.
Also, in accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions regarding this letter, please contact Mr. Paul Krohn of my staff at (610) 337-5120.
Sincerely,
/RA David C. Lew, Director Division of Reactor Projects
Enclosure:
As Stated
Mr. Britt T. McKinney RI-2007-A-0038 RI-2007-A-0062 3
Distribution:
C. Carpenter, OE R. Urban, SAC ADAMS (Docket No. 050-00388)
D. Screnci, PAO Region I Docket Room (w/concurrences)
SUNSI Review Complete: PGK (Reviewer=s Initials)
After declaring this document AAn Official Agency Record@ it WILL be released to the Public.
DOCUMENT NAME: G:\\ORA\\ALLEG\\LICENSEE\\20070038&20070062lic.doc To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE DRP:RPB4 RI:RC RI:OI ORA:SAC DRP:DD NAME P Krohn K Farrar E Wilson/Mullen R Urban/jrm D Lew DATE 03/16/2008 03/17/2008 03/18/2008 03/19/2008 03/19/2008 OFFICIAL RECORD COPY