ML092440270

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Mid-Cycle Performance Assessment Letter - Susquehanna Steam Electric Station
ML092440270
Person / Time
Site: Susquehanna  
Issue date: 09/01/2009
From: David Lew
Division Reactor Projects I
To: Rausch T
Susquehanna
KROHN P, RI/DRP/PB4/610-337-5120
References
Download: ML092440270 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 September 1, 2009 Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603-0467

SUBJECT:

MID-CYCLE PERFORMANCE ASSESSMENT LETTER -

SUSQUEHANNA STEAM ELECTRIC STATION

Dear Mr. Rausch:

On August 13, 2009, the NRC staff completed its performance review of Susquehanna Steam Electric Station (Susquehanna). Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2008 through June 30, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information.

A separate letter designated and marked as Official Use Only - Security information will include the security cornerstone review and resultant inspection plan.

Overall, Susquehanna Units 1 and 2 operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct reactor oversight process (ROP) baseline inspections at your facility.

On January 28, 2009, we issued you a potential Chilling Effect Letter (CEL) regarding the Safety Conscious Work Environment (SCWE) at Susquehanna (ML090280115)1. In that letter we expressed concern with the progress and effectiveness of your actions to address indications of a declining SCWE and negative employee perceptions during 2008, as it may have impacted employee willingness to raise safety concerns and could lead to a chilling effect on site. In accordance with NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, the issuance of this CEL met the first criteria for consideration of a Substantive Cross 1 Designation in parenthesis refers to an ADAMS accession number. Documents referenced in this letter are publicly available using the accession number in ADAMS.

T. Rausch 2

Cutting Issue (SCCI) in the area of SCWE. As a result, the NRC will evaluate whether a SCCI exists in the area of SCWE over three plant assessment cycles, including this current assessment.

In response to the CEL, you responded on the public docket via letters dated February 27, 2009 (ML090620124); March 13, 2009 (ML090760146); and June 23, 2009 (ML091800460) describing your plan to address the SCWE issues at Susquehanna and to update the NRC on the progress of these actions. We reviewed these letters and determined that they provided an acceptable written response to the NRC and proposed a reasonable plan to address SCWE issues. We also conducted follow-up inspections on site which are documented in NRC Inspection Reports 05000387 & 05000388/2008002 (ML091330762) and 05000387 &

50000388/2008003 (ML092230158). In addition, NRC management conducted several site visits and meetings with PPL management, including a public meeting on July 6, 2009, to discuss your plans for improving the work environment at Susquehanna and your progress to date (ML091940440).

We have determined through correspondence, meeting, and direct inspection that following issuance of the potential CEL, you have made reasonable progress in understanding the underlying causes and developing an action plan for addressing the SCWE issues at Susquehanna. You completed an appropriate root cause evaluation, identified reasonable causes for the SCWE issues, and scheduled corrective actions to address each of these causes. You also developed internal metrics to monitor and evaluate your progress in addressing the SCWE issues at Susquehanna. We also noted that the number of allegations received by the NRC during 2009, although still greater than the industry norm, were significantly lower than the same period in 2008. As a result, the NRC has determined that a SCCI for SCWE does not exist at this time.

The NRC will continue to monitor PPL's activities to address SCWE issues at Susquehanna through the baseline inspection program. We will review, through focused inspection samples, the progress and effectiveness of the corrective actions developed by your work environment root cause assessment team. We will review the results of the upcoming site-wide safety culture survey and your continuing assessment of the effectiveness of the action plan, evaluation of emergent issues, and adjustments to the plan, if appropriate. In the first quarter of 2010, we will also perform a biennial problem identification and resolution team inspection with special attention in the area of SCWE.

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through December 31, 2010. We also plan on conducting inspections related to Extended Power Uprate activities and operation of independent spent fuel storage facilities.

The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle review.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made 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 website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

T. Rausch 3

As you may know, the NRC is currently evaluating the scope and frequency of all the baseline inspection procedures as part of our biennial review of the ROP. If the results of the evaluation, or any other circumstances, cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Paul Krohn at 610-337-5120 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

David C. Lew, Director Division of Reactor Projects Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22

Enclosure:

Susquehanna Inspection/ Activity Plan cc w/encl:

W. Spence, President and Chief Operations Officer C. Gannon, Vice President, Nuclear Operations R. Paley, General Manager, Plant Support R. Pagodin, General Manager, Nuclear Engineering M. Crowthers, Manager, Nuclear Regulatory Affairs R. Smith, General Manager, Site Preparedness and Services J. Helsel, Manager, Training D. McGann, Manager, Quality Assurance J. Scopelliti, Community Relations Manager B. Snapp, Esq., Associate General Counsel, PPL Services Corp E. Kovalski, Supervisor, Document Control Services, PPL Susquehanna, LLC R. Osborne, Allegheny Electric Cooperative, Inc.

D. Allard, Director, PA Dept of Environmental Protection Board of Supervisors, Salem Township J. Johnsrud, National Energy Committee, Sierra Club E. Epstein, TMI-Alert (TMIA)

Inspection / Activity Plan Page 1 of 2 08/31/2009 16:40:11 Report 22 07/01/2009 - 12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Susquehanna 71004

- POWER UPRATE 6

1, 2 IP Power Uprate 71004 03/01/2009 12/31/2009 7111111B

- BIENNIAL REQUAL INSP WITH P/F RESULTS 3

1, 2 IP Licensed Operator Requalification Program 7111111B 09/28/2009 10/02/2009 71121

- OCC RAD SAFETY 1

1, 2 IP Access Control to Radiologically Significant Areas 7112101 08/10/2009 08/14/2009 1, 2 IP ALARA Planning and Controls 7112102 08/10/2009 08/14/2009 1, 2 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 08/10/2009 08/14/2009 ISFSI

- ISFSI LOADING CAMPAING INSPECTION 1

1 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 08/17/2009 08/21/2009 7111107T

- HEAT SINK INSP 2

1, 2 IP Heat Sink Performance 7111107T 09/21/2009 09/25/2009 71121

- OCC RAD SAFETY 1

1, 2 IP Access Control to Radiologically Significant Areas 7112101 11/30/2009 12/04/2009 1, 2 IP ALARA Planning and Controls 7112102 11/30/2009 12/04/2009 1, 2 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 11/30/2009 12/04/2009 1, 2 IP Occupational Exposure Control Effectiveness 71151-OR01 11/30/2009 12/04/2009 1, 2 IP RETS/ODCM Radiological Effluent 71151-PR01 11/30/2009 12/04/2009 71152B

- PI&R 4

1, 2 IP Identification and Resolution of Problems 71152B 01/11/2010 01/15/2010 1, 2 IP Identification and Resolution of Problems 71152B 01/25/2010 01/29/2010 ISFSI

- ANNUAL SAMPLE - ISFSI INSPECTION 1

1 IP Operation Of An ISFSI 60855 01/01/2010 12/31/2010 2515/173

- GROUNDWATER TI 1

1, 2 IP Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 2515/173 02/08/2010 02/12/2010 7111108G

- U1 INSERVICE INSPECTION 1

1 IP Inservice Inspection Activities - BWR 7111108G 03/15/2010 03/19/2010 71121

- OCC RAD SAFETY 1

1 IP Access Control to Radiologically Significant Areas 7112101 03/15/2010 03/19/2010 1

IP ALARA - Required 7112102-7112102R 03/15/2010 03/19/2010 1

IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 03/15/2010 03/19/2010 7112201

- PUB RAD SAFETY - RETS 1

1, 2 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 7112201 05/10/2010 05/14/2010 71121

- OCC RAD SAFETY 1

1, 2 IP Access Control to Radiologically Significant Areas 7112101 06/07/2010 06/11/2010 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Inspection / Activity Plan Page 2 of 2 08/31/2009 16:40:11 Report 22 07/01/2009 - 12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Susquehanna 71121

- OCC RAD SAFETY 1

1, 2 IP ALARA - Required 7112102-7112102R 06/07/2010 06/11/2010 1, 2 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 06/07/2010 06/11/2010 71121

- OCC RAD SAFETY 1

1, 2 IP Access Control to Radiologically Significant Areas 7112101 08/23/2010 08/27/2010 1, 2 IP ALARA - Required 7112102-7112102R 08/23/2010 08/27/2010 1, 2 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 08/23/2010 08/27/2010 1, 2 IP Occupational Exposure Control Effectiveness 71151-OR01 08/23/2010 08/27/2010 CDBI

- COMPONENT DESIGN BASES INSPECTION 9

1, 2 IP Component Design Bases Inspection 7111121 09/13/2010 09/17/2010 1, 2 IP Component Design Bases Inspection 7111121 09/27/2010 10/08/2010 12/13EXM

- INITIAL OPERATOR LICENSING EXAM 5

1 FY11-SUSQUEHANNA U1&2 INITIAL OPERATOR LICENSING EXAM U01793 12/13/2010 12/17/2010 EP EX

- EP EXERCISE EVALUATION 4

1, 2 IP Exercise Evaluation 7111401 10/04/2010 10/08/2010 1, 2 IP Emergency Action Level and Emergency Plan Changes 7111404 10/04/2010 10/08/2010 1, 2 IP Drill/Exercise Performance 71151-EP01 10/04/2010 10/08/2010 1, 2 IP ERO Drill Participation 71151-EP02 10/04/2010 10/08/2010 1, 2 IP Alert & Notification System 71151-EP03 10/04/2010 10/08/2010 7112202

- PUB RAD SAFETY - RADWASTE 1

1, 2 IP Radioactive Material Processing and Transportation 7112202 11/29/2010 12/03/2010 1, 2 IP RETS/ODCM Radiological Effluent 71151-PR01 11/29/2010 12/03/2010 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.