ML093170375

IR 05000387-09-004, 05000388-09-004, 07/01/2009 - 09/30/2009; Susquehanna Steam Electric Station, Units 1 and 2; Fire Protection, Licensed Operator Requalification Program, Maintenance Effectiveness, ALARA Planning and Controls

ML093170375
Person / Time
Site:	Susquehanna
Issue date:	11/13/2009
From:	David Lew Division Reactor Projects I
To:	Rausch T Susquehanna
KROHN P, RI/DRP/PB4/610-337-5120
References
EA-09-248 IR-09-004
Download: ML093170375 (47)

See also: IR 05000387/2009004

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA, PA 19406-1415

November 13, 2009

EA-09-248

Mr. Timothy S. Rausch

Senior Vice President and Chief Nuclear Officer

PPL Susquehanna, LLC

769 Salem Boulevard, NUCSB3

Berwick, PA 18603

SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED

INSPECTION REPORT 05000387/2009004 AND 05000388/2009004

Dear Mr. Rausch:

On SeptElmber 30, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed integrated

inspection report presents the inspection results, which were discussed with you and other

members of your staff during a preliminary exit meeting on October 9, 2009.

This inspection examined activities completed under your license as they relate to safety and

compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, two examples of an apparent violation (AV) were

identified, involving PPL Susquehanna, LLC (PPL) failing to ensure that individual license

holders, on shift in the capacity of senior reactor operators (SROs), met the medical

prereqUisites required for holding a license prior to performing the duties of a licensed operator

as required by 10 CFR 55.3. In one occasion in August 2009, an SRO failed a medical

examination which identified a disqualifying condition, in that, the examination identified that the

SRO's vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5,

"Eyes." However, he performed the function of an SRO during three watches with a license

that was not appropriately conditioned to require that corrective lenses be worn. In the second

occasion, a different SRO performed licensed operator duties 52 times between April 1, 2009,

and July 22, 2009, after the deadline for his biennial medical examination had passed. The

medical examination may have identified an issue with the SRO's medical condition and general

health that would have disqualified him from being authorized by a license.

This app,arent violation is being considered for escalated enforcement action in accordance with

the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web

site at (http://www.nre.gov/about-nrciregulatorv/enforcementienforce-pol.html).

T. Rausch 2

Upon discovery, PPL removed both individuals from watchstanding duties pending follow-up

medical evaluations and, in the August 2009 example involving the SRO who failed his vision

examination resulting in a disqualifying condition, PPL requested a conditional NRC license to

address the disqualifying medical condition. For the July 2009 example, the SRO passed his

biennial medical examination when administered. Both issues have been entered into PPL's

corrective action program. See Section 1R11 of the attached report for additional details. In

addition, since you identified the violation, and based on our understanding of your corrective

actions, a civil penalty may not be warranted in accordance with Section VI.C.2 of the

Enforcement Policy.

The NRC believes we have enough information to make a final decision on the matter. Before

the NRC makes its enforcement decision, we provided you an opportunity to either: (1) respond

to the apparent violation addressed in this inspection report within 30 days of the date of this

letter or, (2) request a predecisional enforcement conference. On November 9, 2009, I

contacted Mr. Jeff Helsel, Susquehanna Plant Manager, and members of your staff and

informed them of this opportunity.

On November 10, 2009, Michael Crowthers, Susquehanna Regulatory Assurance Manager,

informed my staff that you elected to provide a written response. Your written response should

be clearly marked as a "Response to an Apparent Violation in Inspection Report

0500038"712009004 AND 05000388/2009004; EA-09-248" and should include for each example

of the AV: (1) the reason for the AV, or, if contested, the basis for disputing the AV; (2) the

corrective steps that have been taken and the results achieved; (3) the corrective steps that will

be taken to avoid further violations; and (4) the date when full compliance will be achieved.

Your response may reference or include previously docketed correspondence, if the

correspondence adequately addresses the required response. If an adequate response is not

received within the time specified or an extension of time has not been granted by the NRC, the

NRC will proceed with its enforcement decision.

In addition, please be advised that the number of violations and characterization of the AV

described in the enclosed inspection report may change as a result of further NRC review. You

will be advised by separate correspondence of the results of our deliberations on this matter.

In addition, this report documents two NRC-identified findings and one self-revealing finding of

very low safety significance (Green). Two of these findings were determined to involve a

violation of NRC requirements. Additionally, one licensee-identified violation, which was

determined to be of very low safety significance, is listed in this report. However, because of

the very low safety significance and because they are entered into your corrective action

program (CAP), the NRC is treating these findings as non-cited violations (NCVs), consistent

with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you

should provide a response within 30 days of the date of this inspection report, with the basis for

your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk,

Washington, D.C. 20555-0001; with copies to the Regional Administrator Region I; the Director,

Office of Enforcement, United States NRC, Washington, D.C. 20555-0001; and the NRC

Resident Inspector at the Susquehanna Steam Electric Station. In addition, if you disagree with

the characterization of the cross cutting aspect of any finding in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at the

T. Rausch 3

Susquehanna Steam Electric Station. The information you provide will be considered in

accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any), will be available electronically for public inspection in the

!\IRC Public Document Room or from the Publicly Available Records (PARS) component of the

NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.qov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely,

IRA!

David C. Lew, Director

Division of Reactor Projects

Docket Nos. 50-387; 50-388

License Nos. NPF-14, NPF-22

Enclosures: Inspection Report 05000387/2009004 and 05000388/2009004

Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

T. Rausch 4

Susquehanna Steam Electric Station. The information you provide will be considered in

accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any), will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of the

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).

Sincerely,

IRA!

David C. Lew, Director

Division of Reactor Projects

Docket Nos. 50-387; 50-388

License Nos. NPF-14, NPF-22

Enclosures: Inspection Report 05000387/2009004 and 05000388/2009004

Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

Distribution w/encl: (via E-mail)

S. Collins, RA (R10RAMAIL Resource)

M. Dapas, DRA (R10RAMAIL Resource)

D. Lew, DRP (R1 DRPMAIL Resource)

J. Clifford, DRP (R1 DRPAMAIL Resource)

P. Krohn, DRP

D. Holody I~I OE (R10RAMAIL Resource)

R Fuhrmeister, DRP

A. Rosebrook, DRP

E. Torres, DRP

J. Bream, DRP

F. Jaxheimer, DRP, SRI

P. Finney, DRP, RI

S. Farrell, DRP, OA

L. Trocine, RI OEDO

RidsNrrPMPeachBottom Resource

RidsNrrDorlLpl1-2 Resource

ML093170375

SUNSI Review Complete: AAR (Reviewer's Initials)

DOCUMENT NAME: G:\DRP\BRANCH4\lnspection Reports\Susquehanna\SQ 3rd Qtr

2009\SUS2009_004_g.doc

After declaring this document "An Official Agency Record" it will be released to the Public.

To receive a copy of this document. indicate in the box: "C":: Copy without attachment/enclosure "E";; Copy with attachmenUenciosure liN" No copy

OFFICE RIIDRP I RI/DRP I R1/0E I R1/DRP I

NAME ARosebrookl PKrohnl DHoiody/AED for DLew

lOATE 11/12/09 11/12/09 11112109 11/12/09

OFFICIAL RECORD COPY

U.S NUCLEAR REGULATORY COMMISSION

REGION I

Docket No: 50-387, 50-388

License No: NPF-14, NPF-22

Report No: 05000387/2009004 and 05000388/2009004

Licensee: PPL Susquehanna, LLC

Facility: Susquehanna Steam Electric Station, Units 1 and 2

Location: Berwick, Pennsylvania

Dates: July 1, 2009 through September 30, 2009

Inspectors: F. Jaxheimer, Senior Resident Inspector

P. Finney, Resident Inspector

G. Meyer, Senior Reactor Inspector

S. Chaudhary, Reactor Inspector

J. Furia, Senior Health Physicist

A. Rosebrook, Senior Project Engineer

O. Masnyk-Bailey, Health Physicist

S. Hammann, Health Physicist

J. Nicholson, Health Physicist

Reviewed By: Paul G. Krohn, Chief

Projects Branch 4

Approved By: David C. Lew, Director

Division of Reactor Projects

Enclosure

2

TABLE OF CONTENTS

SUMMARY OF FINDINGS ......................................................................................................... 3

REPORT DETAILS .....................................................................................................................6

1. REA,CTOR SAFETy ...........................................................................................................6

1R04 Equipment Alignment ..............................................................................................6

1R05 Fire Protection .........................................................................................................7

1R06 Flood Protection Measures ...................................................................................... 9

1R07 Heat Sink Performance ........................................................................................... 9

1R11 Licensed Operator Requalification Program .......................................................... 11

1R12 Maintenance Effectiveness .................................................................................... 15

1R13 Maintenance Risk Assessments and Emergent Work Control ............................... 17

1R15 Operability Evaluations .......................................................................................... 18

1R18 Plant Modifications ................................................................................................ 19

1R19 Post-Maintenance Testing .....................................................................................20

1R22 Surveillance Testing .............................................................................................. 20

1EP6 Drill Evaluation ......................................................................................................21

2. RADIATION SAFETY .......................................................................................................21

20S1 Access Control to Radiologically Significant Areas ................................................ 21

20S2 ALARA Planning and Controls ...............................................................................22

20S3 Radiation Monitoring Instrumentation .................................................................... 24

4. OTHER ACTiViTIES ......................................................................................................... 25

40A1 Performance Indicator Verification ......................................................................... 25

40A2 Identification and Resolution of Problems .............................................................. 25

40A5 Other Activities ......................................................................................................28

40A6 Meetings, Including Exit. ........................................................................................ 29

40A7 Licensee-Identified Violations ................................................................................ 29

ATTACHMENT: SUPPLEMENTAL INFORMATION ................................................................ 30

SUPPLE.MENTAL INFORMATION ......................................................................................... A-1

KEY POINTS OF CONTACT .................................................................................................. A-1

LIST OF ITEMS OPENED, CLOSED, AND DiSCUSSED ....................................................... A-1

LIST OF DOCUMENTS REVIEWED ...................................................................................... A-2

LIST OF ACRONYMS .......................................................................................................... A-12

Enclosure

3

SUMMARY OF FINDINGS

IR 05000387/2009004,05000388/2009004,07/01/2009 - 09/30/2009; Susquehanna Steam

Electric Station, Units 1 and 2; Fire Protection, Licensed Operator Requalification Program,

Maintenance Effectiveness, ALARA Planning and Controls.

The report covered a 3-month period of inspection by resident inspectors and announced

inspections by regional reactor inspectors. Two Green non-cited violations (NCVs), and one

Green finding were identified. In addition, one apparent violation (AV) item being considered for

escalated enforcement action in accordance with the NRC Enforcement Policy. The current

Enforcement Policy is included on the NRC's Web site at

(http://wvvw.nrc.gov/about-nrc!regulatory/enforcementlenforce-pol.html). The significance of

most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual

Chapter (IMC) 0609, "Significance Determination Process" (SOP). Cross-cutting aspects

associated with findings are determined using IMC 0305, "Operating Reactor Assessment

Program," dated August 2009. Findings for which the SOP does not apply may be Green or be

assigned a severity level after NRC management review. The NRC's program for overseeing

the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor

Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

• Green. The inspectors identified a Green NCV of the Susquehanna, Unit 2 Operating

License Condition 2.C.(3), Fire Protection for failure to administratively control

combustible loading in an area on the 686' elevation of the control structure. As a result,

a normally locked storage area was discovered to contain numerous combustibles

without deSignated detection, suppression, or a pre-fire plan. This issue was placed in

PPL's corrective action program (CAP) and immediate corrective actions included the

removal of some of the combustible materials and the assignment of hourly fire watches.

The finding was more than minor because it was associated with the external factors

attribute (fire) of the Mitigating Systems cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Specifically, PPL did not ensure that plant procedures

controlled the use and storage of combustible materials and that a combustible loading

analysis was maintained for a locked storage area fire zone in the control structure. The

inspectors assessed this finding in accordance with IMC 0609, Appendix F, "Fire

Protection Significance Determination Process", and determined the finding to be of very

low safety significance (Green) because the fire barrier between the safety-related

equipment in the lower relay room and this storage area was being properly maintained

and found in good physical condition. The finding was determined to have a cross

cutting aspect in the area of Problem Identification and Resolution, Corrective Action

Program, because PPL did not implement a CAP with a low threshold for identifying

issues P.1(a). Specifically, PPL had reasonable opportunities to identify the

combustible loading issue on multiple occasions during access of the storage room.

(Section 'I R05)

Enclosure

4

AV... PPL identified two examples of an apparent violation (AV), involving PPL

Susquehanna, LLC (PPL) failing to ensure that individual license holders, on shift in the

capacity of senior reactor operators (SROs), met the medical prerequisites required for

holding a license prior to performing the duties of a licensed operator as required by 10

CFR 55.3. In one occasion in August 2009, an SRO failed a medical examination which

identified a disqualifying condition, in that, the examination identified that the SRO's

vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5,

"Eyes." However, he performed the function of an SRO during three watches with a

license that was not appropriately conditioned to require that corrective lenses be worn.

In the second occasion, a different SRO performed licensed operator duties 52 times

between April 1, 2009, and July 22, 2009, after the deadline for his biennial medical

examination had passed. The medical examination may have identified an issue with

the SRO's medical condition and general health that would have disqualified him from

being authorized by a license. Upon discovery, PPL removed both individuals from

watchstanding duties pending follow-up medical evaluations and, in the case involving

the SRO whose failed medical examination resulted in a disqualifying condition, PPL

requested a conditional NRC license to address the disqualifying medical condition.

Both issues have been entered into PPL's corrective action program.

Each example was evaluated independently using the traditional enforcement process

bf:lcause the failure to determine an operator's medical condition and general health has

the potential to impact or impede the regulatory process. Specifically, medical

certification and conditional licensing are used by the NRC to ensure health conditions

wi" not adversely affect operator duties or performance. The finding was determined to

have a cross-cutting aspect in the area of Problem Identification and Resolution,

Operating Experience, because PPL did not systematically collect, evaluate, and

communicate relevant external operating experience P.2(a). Specifically, PPL failed to

evaluate NRC Information Notice 2004-20 for medical examination issue applicability in

accordance with their operating experience review program as evidenced by the 2008

SL-IV NCV (NRC IR 50-387 & 50-388 2008302-01), for an initial licensed operator

application submitted to the NRC with a disqualifying medical condition, as well as these

two events in July and August of 2009. (Section 1R11.2)

• Green. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion

XVI, "Corrective Action," in that PPL did not implement timely corrective actions to

preclude repetition of a significant condition adverse to quality. Specifically, actions

taken to address causes of the Unit 1 high pressure coolant injection (HPCI) stop valve

failure to close in 2006 did not prevent the same HPCI stop valve from failing to close on

August 18, 2009. In both cases, the stop valve failure to close rendered this single train

HPCI system inoperable as it was unable to meet the 30 second injection response time

as described in the design basis. Corrective maintenance was performed on the valve

and the issue was entered into PPL's CAP.

The finding is more than minor because it adversely affected the performance attribute

of the Mitigating Systems cornerstone objective, to ensure the availability, reliability, and

capability of equipment that respond to initiating events to prevent undesirable

consequences. Specifically, a full closed stop valve indication resets the HPCI ramp

generator via a lower limit switch. Without this reset, the governor is unprepared to

restart the turbine from an idle state during a designed basis event. The inspectors

assessed this finding in accordance with IMC 0609, Attachment 4, "Phase 1 Initial

Screening and Characterization of Findings" and determined the finding to be of very low

Enclosure

5

safety significance because it did not result in an actual loss of safety function for greater

than the Technical Specification allowed outage time. The finding was determined to

have a cross-cutting aspect in the area of Problem Identification and Resolution,

Corrective Action Program, because PPL did not take appropriate corrective actions to

address safety issues in a timely manner, commensurate with their safety significance

and complexity [P .1 (d)]. Specifically, PPL did not appropriately implement corrective

actions following the 2006 failure of the HPCI stop valve. (Section 1R12)

Cornerstone: Occupational Radiation Safety

• Green. A self-revealing, Green finding was identified that involved inadequate work

planning relative to the in-vessel visual inspection! inservice inspection (lWIIISI) of the

reactor vessel that resulted in additional unplanned collective exposure contrary to as

low-as-is-reasonably-achievable (ALARA) controls. Specifically, the utilization of

inexperienced workers to perform the various tasks involved in the IWIlISI activity

resulted in the additional collective exposure to perform this routine task. This finding

was entered into PPL's Correction Action Program for resolution.

This finding is more than minor because it resulted in unplanned, unintended collective

exposure that was greater than 50 percent above the intended collective exposure and

greater than 5 person-rem. Additionally, the performance deficiency adversely affected

the radiation protection cornerstone objective. The inspectors assessed the finding in

accordance with IMC 0609, Appendix C, "Occupational Radiation Safety Significance

Determination Process," and determined that the finding was of very low safety

significance (Green) because the finding was due to ALARA work control planning and

the 3-year rolling average collective exposure at Susquehanna was less than 240

person-rem (107 person-rem for 2005-2007). This finding was determined to have a

cross-cutting aspect in the area of Human Performance, Resources, because PPL did

not utilize sufficiently qualified personnel to assure occupational radiation safety

requirements were met H.2{b). Specifically, PPL's use of inexperienced contract

workers resulted in additional collective exposure that could have been avoided.

(Section 20S2)

B. Licensee Identified Violations

A violation of very low safety significance. which was identified by PPL. has been

reviewed by the inspectors. Corrective actions taken or planned by PPL have been

entered into PPL's CAP. This violation and corrective action tracking numbers are listed

in Section 40A7 of this report.

Enclosure

6

REPORT DETAILS

Summary of Plant Status

Susquehanna Steam Electric Station (SSES) Unit 1 began the inspection period at the

authorized licensed power level of 94.4 percent rated thermal power (RTP). On September 4,

2009, Unit 1 was reduced to 70 percent over 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in support of a control rod sequence

exchangEl and pattern adjustment. Unit 1 remained at 94.4 percent RTP for the remainder of

the inspection period.

SSES Unit 2 began the inspection period at the authorized licensed power level of 94.4 percent

RTP. On September 12,2009, Unit 2 was reduced to 58 percent over 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in support of a

control rod sequence exchange and pattern adjustment. Unit 2 remained at 94.4 percent RTP

for the remainder of the inspection period.

Note: The licensed RTP for both units is 3952 megawatts thermal. The Extended Power

Uprate (EPU) License Amendment for SSES was approved in January 30,2008, and was

implemented for both units in accordance with the issued license conditions. For the current

inspection period, the authorized power level for both units is 94.4 percent of the EPU licensed

power limit.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and 8arrier Integrity

1R04 Equipment Alignment

.1 Partial Walkdown (71111.04 - 3 Samples)

a. Inspection Scope

The inspectors performed partial walkdowns to verify system and component alignment

and to identify any discrepancies that would impact system operability. The inspectors

verified that selected portions of redundant or backup systems or trains were available

while certain system components were out-of-service. The inspectors reviewed

selected valve positions, electrical power availability, and the general condition of major

system components. Documents reviewed are listed in the Attachment. The

walkdowns included the following systems:

• Unit 1, 18 residual heat removal (RHR) components and instrumentation with

focus on behavior during pressurization and venting;

• Plant discharge line (blow down) and river water make-up system parameters

and lineup during investigation of groundwater issue described by CR 1167146;

and

• "An and "En emergency diesel generators (EDGs) when "En EDG substituted for

"8" EDG.

b. Findings

No findings of significance were identified.

Enclosure

7

.2 Complete Walkdown (71111.04S - 1 Sample)

a. Inspection Scope

The inspectors performed a detailed review of the alignment and condition of the station

nitrogen system and the Unit 2 containment instrument gas system. The inspectors

reviewed operating procedures, checkoff lists, and system piping and instrumentation

drawings. Walkdowns of accessible portions of the systems were performed to verify

components were in their correct positions and to assess the material condition of

systems and components. The inspectors evaluated ongoing maintenance and

outstanding Condition Reports (CR) associated with both systems to determine the

effect on system health and reliability. The inspectors verified proper system alignment

and looked at system operating parameters. Documents reviewed are listed in the

Attachment. The walkdown included the following system and its interconnection:

• Unit 2, Nitrogen and Primary Containment Instrument Gas.

b Findings

No findings of significance were identified.

1R05 Fire Protection (71111.050 - 5 Samples)

Fire Protection - Tours

a. Inspection Scope

The inspectors reviewed PPL's fire protection program to evaluate the specified fire

protection deSign features, fire area boundaries, and combustible loading requirements

for selected areas. The inspectors walked down those areas to assess PPL's control of

transient combustible material and ignition sources, fire detection and suppression

capabilities, fire barriers, and any related compensatory measures to assess PPL's fire

protection program in those areas. Documents reviewed are listed in the Attachment.

The inspected areas included:

• Unit 1, battery rooms, fire zones 0-28 B-1 (11) and 0-28 I thru N;

• Unit 1, containment access area (1-401);

• Security control center, fire zone 0-83, FP-013-360;

• Control structure charcoal filter area and operations storage area on elevation

687', FP-013-135; and

• Central access control area and chemistry laboratory, elevation 676', FP-013

134.

b. Findings

Introduction: The inspectors identified that PPL was not administratively controlling

combustible loading in an area on the 686' elevation of the control structure as

specifically required by the Susquehanna Fire Protection Program and specifically

described as a provision of the Fire Protection Program Report (FPPR). This finding

Enclosure

8

was determined to be of very low safety significance (Green) and an NCV of the SSES

Unit 2 Operating License Condition 2.C(3), Fire Protection.

Description: During a fire walkdown inspection in the control structure, the resident

inspectors identified that an operations department space, a normally locked storage

area on 686' elevation, contained numerous combustibles. Most items stored in the

area were found on open shelves or stacked on the floor. The accumulation of

combustibles included (but was not limited to) wood, plastic, cardboard boxes, old paper

records, rubber drain hoses, radio equipment, refueling support furniture, and labeling

supplies. Inspectors immediately asked operations staff if this room was part of any fire

pre-plan (fire fighting guideline/procedure). The room was not incorporated in any of the

site fire pre-plans and inspectors did not locate any combustible storage permits. When

inspectors could not verify the area was being controlled by the design control process

as a combustible storage area and could not verify that PPL was procedurally controlling

the use and storage of combustible materials in this area, the issue was brought to PPL

management's attention. PPL took immediate action to dispatch the fire protection

engineer (FPE) and field unit supervisor to the area. An hourly fire watch was started for

the area and some of the combustibles were promptly removed from the room. The

operations shift manager determined that the area was overcrowded with materials that

were no longer needed. Longer term correction actions are planned and the issue is

bl~ing tracked by CR 1179995.

As part of the evaluation of this performance issue, inspectors also completed additional

walkdowns and drawing reviews which revealed that the operations department storage

area was actually located directly below the following rooms on the 698' elevation of the

control structure: the computer maintenance room, the uninterrupted power supply

computer room, Corridor C-200, and the Unit-2 lower relay room. Inspectors reviewed

d~9sign drawings, the FPPR and held a discussion with the site FPE, to verify that there

was no automatic detection, no automatic suppression, and no fire pre-plan for this

storage area.

Analysis: The inspectors determined that this finding was more than minor because it

was associated with the external factors attribute (fire) of the mitigating systems

cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences (Le., core damage).

Specifically, PPL did not ensure that fire combustible storage was procedurally

controlled in the control structure. Fire combustibles accumulated in an area directly

b,elow the Unit 2 relay room and three other separated rooms. This storage area did not

have any fire suppression or detection capability.

The inspectors assessed this finding in accordance with IMC 0609, Appendix F, "Fire

Protection Significance Determination Process." This finding was determined to be of

very low safety significance (Green) in Phase 1 of the SDP because it was assigned a

low degradation rating. A low degradation rating was assigned because the fire barrier

between the safety-related equipment in the lower relay room and this storage area was

being properly maintained and found in good physical condition.

The finding was determined have a cross-cutting aspect in the area of Problem

Identification and Resolution, Corrective Action Program, because PPL did not

implement a CAP with a low threshold for identifying issues [P.1 (a)]. Specifically, PPL

Enclosure

9

had reasonable opportunities to identify the combustible loading issue on multiple

occasions during access of the storage room.

Enforcement: The Susquehanna Unit 2 Operating License Condition 2.C.(3), requires

that PPL implement and maintain in effect all provisions of the Fire Protection Program

as described in the FPPR. FPPR section 1.4 requires that plant procedures control the

use and storage of combustible materials and section 6.0 also requires that the

combustible loading analysis was maintained through the design control process.

Contrary to these requirements, prior to September 2009 PPL did not procedurally

control the use and storage of combustible materials on the 686' elevation of the control

structure and did not evaluate changes to combustible storage in this area through the

dE~sign control process. Because the finding is of very low safety significance and has

been entered into PPL's CAP (CR 1179995), this violation is being treated as a Non

Cited Violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 05000388/2009004-01, Failure to Implement and Maintain the Fire Protection

Program with Respect to the Use and Storage of Combustibles in the Control

Structure)

1R06 Fiood Protection Measures (71111.06 - 1 Sample)

Underground Cables

a. Inspection Scope

The inspectors reviewed documents, interviewed plant personnel, and entered four

underground vaults to evaluate the conditions of risk-significant cables. The inspection

focus included a visual inspection of cable integrity. Additionally, the material condition

o'f support structures and credited components such as watertight plugs, floor drains,

flood detection equipment, and alarms were also assessed to determine whether the

components were capable of performing their intended function. Some dewatering

devices were observed in operation. Documents reviewed are listed in the Attachment.

The following risk significant area was reviewed:

• Engineered Safeguards Service Water pump house and spray pond vault

inspections VA006, VA007, VA011, and VA012.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance (71111.07T - 3 Samples)

Triennial Heat Sink

a. Inspection Scope

Based on safety significance and prior inspection history, the inspectors selected the

following heat exchangers to evaluate PPL's means (inspection, cleaning, maintenance,

and performance monitoring) of ensuring adequate heat sink performance.

• Unit 1 A RHR heat exchanger;

Enclosure

10

• 'A' Emergency diesel generator heat exchangers:

1) Intercooler heat exchanger;

2) Jacket water cooler; and

3) Lubricating oil cooler.

• 'E' Emergency diesel generator heat exchangers:

1) Intercooler heat exchanger;

2) Jacket water cooler; and

3) Lubricating oil cooler.

The inspectors assessed the external condition of the above heat exchangers in the

field, reviewed the eddy current, surveillance test and inspection results, and reviewed

the applicable system health reports since the last inspection to confirm that results were

acceptable and that design basis assumptions for flow rate, plugged tube percentage,

and heat transfer capability had been met. The inspectors discussed piping corrosion,

and heat exchanger practices, including the specifications and procedures for heat

exchanger maintenance, and consistency with the Generic Letter 89-13 requirements

with cognizant, system engineers, and chemistry personnel. The inspectors reviewed

applicable corrective action program documents to confirm that identified problems and

d,egraded conditions had been resolved properly.

In addition to the inspections of heat exchangers in the RHR and EDG systems, the

inspectors visually examined equipment, slope protection and water level in the spray

pond, and the apparent condition of primary and support equipment in the intake

structure.

The inspectors assessed the condition of the spray pond (ultimate heat sink) and the

pump house, and reviewed the August 2009 inspection/evaluation of spray pond

sediment depth. The review included discussions with the RHR service water system

engineer, a walk-down of the spray pond and pump house, and discussions with

cl1emistry personnel and the emergency service water (ESW) system engineer.

The chemical treatment programs for the spray pond (ESW ultimate heat sink) and the

cooling tower basin (service water heat sink) were reviewed to verify that potential

bio-fouling mechanisms were being addressed, including on-going treatment and

monitoring as specified in the chemistry manual. The inspectors noted that the SSES

results were aided by the ability to chemically control their ultimate heat sink, the

extensive use of stainless steel AL-6XN in tubing, and the experience of involved

engineering, testing, and chemistry personnel.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

Enclosure

11

1R11 Licensed Operator Requalification Program (71111.11 Q - 2 Sample)

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On August 10, 2009, the inspectors observed as-found licensed operator simulator

performance. The inspectors compared their observations to Technical Specifications

(TSs), emergency plan implementation, and the use of system operating procedures.

Tlhe inspectors also evaluated PPL's critique of the operators' performance to identify

discrepancies and deficiencies in operator training. Documents reviewed are listed in

the Attachment. The following training was observed:

• Anticipated transient without scram, reactor pressure vessel power and level

control, and event declaration.

b. Findings

No findings of significance were identified .

.2 Licensed Operator Medical Review (1 sample)

a.. Inspection Scope

The inspectors reviewed two instances in July 2009 and August 2009 where PPL had

identified issues with the medical qualification records for two separate Senior Reactor

Operators. The inspectors reviewed the medical certification forms, reviewed the PPL's

formal correspondence with the NRC upon discovery of the issue to ensure timeliness

requirements were met, PPL conditional license request submittal and reviewed PPL's

corrective actions.

b. Findings

Introduction: The licensee identified two examples of an AVof 10 CFR 55.3, Licensed

Requirements, for two cases in which PPL licensed operators failed to have valid

medical examinations consistent with their position. Specifically, one licensed operator

performed duties with an expired biennial medical examination while another licensed

operator performed duties with a failed visual examination. In both cases, operators

performed the function of a senior reactor operator without meeting the medical

rE~quirements for requalification specified in 10 CFR 55.21, 10 CFR 55.23 and

10 CFR 55.33. As such both operators were not qualified while being assigned to and

performing licensed duties as required by 10 CFR 55.3.

Discussion: During July and August 2009, two instances were identified where SSES

licensed operators failed to meet the medical requirements to maintain their license, and

these operators subsequently performed licensed operator duties.

,!;,vent 1: On October 13, 2008, a senior reactor operator (SRO) self-identified a medical

issue that resulted in his disqualification, a medical restriction entered into a corporate

database and an automatic update of TMX, (the site's training and qualification

database) was completed from the corporate source. The operator subsequently

Enclosure

12

completed a medical follow-up and was reinstated on December 12, 2008. While the

corporate database entry could have been deleted upon reinstatement, manual

corrections to TMX were made. When the restriction was manually updated with a

December 12, 2008 date, TMX automatically and incorrectly changed the medical

examination due date to October 31, 2010, to reflect a biennial requirement from the

date of the SRO's self-identified medical issue.

In 2004, the NRC issued NUREG-1021, Revision 9, which clarified the periodicity of

medical examinations. Appendix F of the NUREG defines biennial as 730 days and

allows for an extension to include the remaining days in the anniversary month. For

example, the subject SRO had a biennial medical examination due on March 9, 2009,

exactly two years from the previous examination but the permitted extension carried the

due date to March 31,2009.

During a medical record review on July 22, 2009, PPL discovered that the SRO had not

received a biennial licensed medical examination by March 31, 2009. The SRO

qualifications for the individual were immediately revoked and a physical was scheduled

for July 24, 2009. The operator passed the physical examination and was subsequently

reinstated on July 30,2009. Upon review, it was determined that the SRO stood a total

of 52 watches in a TS licensed position without a certifying medical examination as

outlined in ANSI/ANS-3.4-1983, "Medical Certification and Monitoring of Personnel

Requiring Operator Licenses for Nuclear Power Plants." Upon discovery, PPL placed

this issue in their corrective action program under CR 1166686.

Event 2: On August 18, 2009, a PPL health services specialist determined that an on

shift SRO did not pass the corrected or uncorrected visual examination which had been

performed during the previous week. Upon discovery, the SRO was disqualified for the

licensed position and the operator was removed from standing watch. PPL operations

staff promptly initiated Condition Report 1173182, which described the non-compliance

and established corrective actions to implement measures to mitigate the recurrence of

similar conditions. PPL also implemented actions to request a conditional license for this

SRO adding a condition to the operator's license requiring corrective lenses be worn.

It was determined that the licensed operator performed licensed duties during three

scheduled work shifts which included assuming the role of the refueling SRO during fuel

moves for a dry fuel storage campaign. This SRO performed licensed duties even

though he had not met the medical condition and general health prescribed for licensed

operators at the facility as outlined on NRC Form 396 and required by 10 CFR 55.21.

Information Notice (IN) 2004-20, "Recent Issues Associated with NRC Medical

Requirements for Licensed Operators," states, "Given the importance of the operators'

role in maintaining reactor safety, the NRC staff becomes concerned whenever

inspection results, facility audits, and other indicators suggest that facility medical

programs may not be receiving sufficient management oversight to ensure that the

fitness of licensed operators is being maintained at the required level." Despite the fact

that PPL entered IN 2004-20 into their corrective action program for operating

experience evaluation (CRs 625137 and 622658), that evaluation did not occur.

Enclosure

13

Analysis:

Event 1: The inspectors determined that PPL's failure to ensure that the licensed

operator received a biennial medical examination was a performance deficiency. This

finding was evaluated using the traditional enforcement process because the failure to

determine an operator's medical condition and general health has the potential to impact

or impede the regulatory process. Specifically, there was potential for license

termination or the issuance of a conditional license to accommodate the medical

problems.

This operator performed licensed duties during 52 scheduled work shifts as an SRO.

Tile NRC notes that the operator was actually qualified the entire time (his follow-up

medical examination results were satisfactory), he had not developed any condition that

required a license condition and there was no actual impact to his requalification; the fact

that the SRO was never the only SRO being credited to met minimum TS manning

requirement; and the fact that the SRO's job performance was satisfactory during the

period of the expired physical examination, and these factors will be considered prior to

a final severity level determination.

Event 2: The inspectors determined that PPL's failure to ensure that the licensed

operator received the required vision examination and passed the required visual before

assuming licensed reactor operator duties was a performance deficiency. This finding

was evaluated using the traditional enforcement process because the failure to

determine an operator's medical condition and general health has the potential to impact

or impede the regulatory process. Specifically, there was a potential for license

termination or the issuance of a conditional license to accommodate for medical

problems.

This operator perform licensed duties during three scheduled work shifts, which included

assuming the role of the refueling SRO during fuel moves for the ongoing dry fuel

storage campaign, but he did so with a disqualifying condition that would have required

his license to be amended. The NRC notes that the Fuel Handling SRO position is a

procedurally required position which was performed by a qualified individual; the SRO

had an actual disqualifying medical condition which required an amended license; and

the SRO's job performance was satisfactory during three watches he stood with this

identified condition, and these factors will be considered prior to a final severity level

determination.

Each of the two events would be considered violations of the same regulatory standard

(10 CFR 55.3) and share a common root cause of programmatic issues within PPL's

licensed operator medical reviews.

The finding was determined to have a cross-cutting aspect in the area of Problem

Identification and Resolution, Operating Experience, because PPL did not systematically

collect, evaluate, and communicate relevant external operating experience P.2(a).

Specifically, PPL failed to properly evaluate IN 2004-20 for medical examination issue

applicability in accordance with their operating experience review program as evidenced

by the 2008 SL-IV NCV (NRC IR 50-387 & 50-388 2008302-01), for an initial licensed

operator application submitted to the NRC with a disqualifying medical condition, as well

as these two events in July and August of 2009.

Enclosure

14

Enforcement:

Event 1: 10 CFR 55.21 requires, in part, that "a licensee shall have a medical

examination by a physician every two years. The physician shall determine that the

applicant or licensee meets the requirements of 10 CFR 55.33(a)(1).

10 CFR 55.33(a)(1) states, in part, that the applicants medical condition and general

health will not adversely affect the performance of assigned job duties or cause

operational errors endangering public health and safety. 10 CFR 55.3 states that, "A

person must be authorized by a license issued by the Commission to perform the

function of an operator or a senior operator as defined in this part".

Contrary to the above, between April 1, 2009, and July 22, 2009, PPL failed to ensure

that the individual licensee, an SRO, while on shift, was authorized by a license to

perform the function of an SRO, after he failed to have the required two-year medical

examination. Specifically, the SRO performed licensed operator duties 52 times

between April 1, 2009, and July 22, 2009, after the deadline for his medical examination

had passed. The medical examination may have identified an issue with the SRO's

medical condition and general health that would have disqualified him from being

authorized by a license.

Event 2: 10 CFR 55.21 requires, in part, that a licensee shall have a medical

examination by a physician every two years. The physician shall determine that the

applicant or licensee meets the requirements of 10 CFR 55.33{a)(1).

10 CFR 55.33(a){1) states, in part, that the applicant's medical condition and general

health will not adversely affect the performance of assigned job duties or cause

operational errors endangering public health and safety. 10 CFR 55.33(b) states, in

part, if an applicant's general medical condition does not meet the minimum standards

under 10 CFR 55.33(a)(1) the Commission may approve the application and include

conditions in the license to accommodate the medical defect.

10 CFR 55.23(b) states in part, when the certification requests a conditional license

based on medical evidence, the medical evidence must be submitted to the Commission

and the Commission then makes a determination in accordance with 10 CFR 55.33.

10 CFR 55.3 states that a person must be authorized by a license issued by the

Commission to perform the function of an operator or a senior operator as defined in this

part.

Contrary to the above, between August 10,2009, and August 18, 2009, PPL failed to

ensure that the individual licensee, an SRO, while on-shift, was authorized by a license

to perform the function of an SRO, after he failed a medical examination which identified

a disqualifying condition. Specifically, a medical examination conducted on August 10,

2009, identified that the SRO's vision did not meet the health requirements stated in

ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." However, he performed the function of an

SRO during three watches with a license that was not appropriately conditioned to

rE~quire that corrective lenses be worn.

Each example was evaluated independently using the traditional enforcement process

because the failure to determine an operator's medical condition and general health has

the potential to impact or impede the regulatory process. Specifically, medical

certification and conditional licensing are used by the NRC to ensure health conditions

Enclosure

15

will not adversely affect operator duties or performance. (AV 05000387; 388/2009004

02, Violation of 10CFR55.3, Senior Reactor Operators Performing Licensed Duties

While Not Qualified Due to Medical Examination Issues)

1R12 Maintenance Effectiveness (71111.120 - 3 Samples)

a. Inspection Scope

Tile inspectors evaluated PPL's work practices and follow-up corrective actions for

selected structures, systems and components (SSC) issues to assess the effectiveness

of PPL's maintenance activities. The inspectors reviewed the performance history of

those SSCs and assessed PPL's extent of condition determinations for these issues with

potential common cause or generic implications to evaluate the adequacy of PPL's

corrective actions. The inspectors reviewed PPL's problem identification and resolution

actions for these issues to evaluate whether PPL had appropriately monitored.

evaluated. and dispositioned the issues in accordance with PPL procedures and the

requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of

Maintenance." In addition, the inspectors reviewed selected SSC classification,

performance criteria and goals, and PPL's corrective actions that were taken or planned.

to verify whether the actions were reasonable and appropriate. Documents reviewed

are listed in the Attachment. The following issues were reviewed:

• Unit 1, HPCI turbine stop valve failure and previous corrective actions for

inadequate preventative maintenance;

• Multiple failures of EDG air start system relief valves which caused "A" EDG

unavailability; and

• Station blackout (SBO) diesel generator (DG) unavailability due to radiator

coolant leakage.

b. Findings

Introduction: The inspectors identified a Green NCVof 10 CFR Part 50, Appendix B.

Criterion XVI. "Corrective Action," in that, PPL did not implement timely corrective

actions to preclude repetition of a significant condition adverse to quality. Specifically,

the actions taken to address the causes of the Unit 1 HPCI stop valve failure to close in

2006 did not prevent the same Unit 1 HPCI stop valve from failing to close on August 18,

2009. In both cases, the failure of the stop valve to close rendered this single train high

pressure injection system inoperable as it was unable to meet the 30 second injection

response time as described in the design basis.

Discussion: On August 18, 2009, the Unit 1 HPCI stop valve (FV-15612) indicated dual

position after performance of the weekly lubricating oil functional check. FV-15612 did

not go full closed as expected and was verified to be approximately one inch from full

closed. Operations cycled the valve with maintenance personnel present in the field and

found that the valve did not operate smoothly when closing. Based on previous history

with FV-15612, engineering recommended that the HPCI system be declared

inoperable. Unit 1 HPCr was declared inoperable and the FV15612 valve was

disassembled and repaired.

The failure of FV-15612 Significantly impacts HCpr operation because the HPCI ramp

generator resets to idle when the lower limit switch opens (at the full closed indication on

Enclosure

16

FV-15612). Thus, FV-15612's closure is necessary to prepare the governor to restart

the turbine and if FV-15612 does not fully close, the generator can not reset, and the

governor would demand full open when the turbine restarts. This condition greatly

increases the probability of an overspeed trip upon turbine start. Historical data from the

original HPCI speed control design reveals that it would be expected to have at least 1

or 2 overspeed trips before the HPCI governor would be able to control turbine speed.

In this condition the HPCI 30 second design basis response time would not be met.

(Ref: TS 3.5.1.13). Therefore, HPCI was not able to perform its safety function with

design limits and was inoperable. In addition, this degraded component also challenges

the system protective features {overspeed trip function} which reduces the reliability of

the system to function.

The safety system remained unavailable for several days as extensive effort was

required to repair the component for this type of degradation. Inspectors witnessed

some of the maintenance work and observed that there were many physical similarities

to the conditions found when this valve was disassembled and repaired following the

failure to close in August of 2006.

One documented cause for the 2006 FV-15612 failure was an observed seal area that is

periodically wetted by HPCI operation and a material which is susceptible to general

corrosion and requires periodic replacement to maintain proper operation. In 2006, PPL

took the action to replace the rod bushing. However, there were no actions to address

the cause and reduce moisture exposure, change or evaluate materials to reduce the

susceptibility to corrosion, and no actions to increase component monitoring for moisture

or corrosion. The second documented apparent cause for the 2006 FV-15612 failure

was inadequate preventive maintenance (PM). An administrative error had caused this

component to go past the PM expiration date. PPL performed the inspections as part of

the 2006 repair and recalculated a new due date for the PM task. PPL did not change

the 10 year interval for maintenance and inspection and did not increase the PM

frequency for this component to more appropriately address this identified apparent

cause (inadequate PM). The inspectors determined that the limited corrective actions

taken following the apparent cause evaluation in 2006 contained in CR 806988 were a

primary contributor to the repeat failure of the FV-15612 in 2009. In both cases, valve

FV15612 failed in the same manner and would not travel to the full closed position. In

both cases, the actuator stem to bushing interface was very tight and required the use of

pullers and/or hammers during actuator disassembly. For both failures the most likely

cause was due to increased friction between the actuator shaft and the rod bushing as a

result of corrosion. The inspectors also identified that the corrective action report CR

806988 did not have an effectiveness review plan. The CR stated that given the long

duration of the PM interval, it would be unreasonable to hold an effectiveness review

open for several years.

The inspectors reviewed PPL's cause evaluation for the August 2009 valve failure, as

documented in CR 1172997. This evaluation described how the leakage through the

seat of the Unit 1 HPCI Steam Admission Valve (HV-155F001) was a contributing cause

to the 2009 component failure. The HV-155F001 had chronic through seat leakage for

the last decade. Inspectors concluded that this leakage and moisture source was also a

contributing factor from 2006, and that more aggressive action to fix the seat leakage

which contributed to the corrosive environment would have reduced the probability

and/or frequency of the experienced component failure.

Enclosure

17

Analysis: The finding is more than minor because it adversely affected the equipment

pE:lrformance attribute of the Mitigating Systems cornerstone objective, to ensure the

availability, reliability and capability of equipment that respond to initiating events to

prevent undesirable consequences. Specifically, with FV-15612 unable to fully close,

the HPCI 30 second design basis response time would not be met. Not only did this

dE3graded component make the HPCI system inoperable; it also challenged the system

protective features (overspeed trip function) which reduced the reliability of the system to

function. In addition, the repairs necessary to restore the system required extensive

effort and resulted in several days of unplanned unavailability for a single train safety

system.

The inspectors assessed this finding in accordance with IMC 0609 Attachment 4, "Phase

1 - Initial Screening and Characterization of Findings" and determined the finding to be

of very low safety significance (Green) because it did not result in an actual loss of

safety function for greater than the TS allowed outage time. The finding was not

potentially risk Significant due to seismic, flood, or severe weather initiating events.

This finding was determined to have a cross-cutting aspect in the area of Problem

Identification and Resolution, Corrective Action Program, because PPL did not take

appropriate corrective actions to address safety issues in a timely manner,

commensurate with their safety Significance and complexity [P.1 (d)]. Specifically, PPL

did not take appropriate corrective actions for a significant condition adverse to quality

from the 2006 failure of the HPCI stop valve to prevent the 2009 failure of the same

valve.

Enforcement: 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires,

in-part, for significant conditions adverse to quality, measures shall assure that the

cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, PPL did appropriately identify several causes but corrective

actions following the 2006 valve failure did not prevent repetition of the same HPCI stop

valve failure on August 18, 2009. In both cases, the failure of the stop valve to close

rendered this single train high pressure injection system inoperable as it was unable to

meet the 30 second injection response time as described in the design basis. In 2009

this particular failure also caused several days of unplanned unavailability due to the

extensive effort to repair the component. Because the finding is of very low safety

significance and has been entered into PPL's CAP (CR 710737), this violation is being

treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the NRC

Enforcement Policy. (NCV 05000387/2009004-03, Inadequate Corrective Actions

Result in a Repeat Failure of Unit 1 HPCI Turbine Stop Valve).

1R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13 7 Samples)

a. Inspection Scope

The inspectors reviewed the assessment and management of selected maintenance

activities to evaluate the effectiveness of PPL's risk management for planned and

emergent work. The inspectors compared the risk assessments and risk management

actions to the requirements of 10 CFR Part 50.65(a)(4) and the recommendations of

NUMARC 93-01, Section 11, "Assessment of Risk Resulting from Performance of

Maintenance Activities." The inspectors evaluated the selected activities to determine

Enclosure

18

whether risk assessments were performed when specified and appropriate risk

management actions were identified.

The inspectors reviewed scheduled and emergent work activities with licensed operators

and work-coordination personnel to evaluate whether risk management action threshold

levels were correctly identified. In addition, the inspectors compared the assessed risk

configuration to the actual plant conditions and any in-progress evolutions or external

events to evaluate whether the assessment was accurate, complete, and appropriate for

the emergent work activities. The inspectors performed control room and field

walkdowns to evaluate whether the compensatory measures identified by the risk

assessments were appropriately performed. Documents reviewed are listed in the

Attachment. The selected maintenance activities included:

• Unit 1, 2-4 GPM leak on RWCU filter demineralizer outlet isolation valve

emergent work control;

• Unit 1, Yellow Risk during corrective maintenance on SBO DG concurrent with

Unit 1 HPCI stop valve and "B" EDG jacket water heater failures on August 21;

• Units 1 and 2, 2A residual heat removal service water (RHRSW) pump

inoperable due to loose electrical junction box supports concurrent with Unit 1

RHRSW subsystem inoperable for scheduled maintenance; dual unit 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

shutdown limiting condition for operation (LCO);

• Orange equipment out-of-service risk for both Unit 1 and Unit 2 during "A" EDG

outage and emergent "E" EDG inoperability, CR 1165553;

• Replace recirculation/standby gas treatment system (SGTS) damper actuator;

dual unit 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> shutdown LCO;

• Emergent wiring repairs on ESS transformer OX203 in 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO; and

• T20 startup transformer (T20) high voltage bushing replacement and Bus 20

clean and inspect.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - 7 Samples)

a. Inspection Scope

The inspectors reviewed operability determinations that were selected based on risk

insights, to assess the adequacy of the evaluations, the use and control of

compensatory measures, and compliance with TSs. In addition, the inspectors reviewed

the selected operability determinations to evaluate whether the determinations were

performed in accordance with NDAP-QA-0703, "Operability Assessments." The

inspectors used the TSs, Technical Requirements Manual, Final Safety Analysis Report

(FSAR), and associated DeSign Basis Documents as references during these reviews.

Documents reviewed are listed in the Attachment. The issues reviewed included:

• Unit 1, RHR Oivision I, gas entrainment issue;

• Unit 1, repeat failure of 1B RHRSW pump 1ST;

• Unit 2, '0' main steam line radiation monitor on multiple alarms and work orders;

Enclosure

19

• Unit 2, HPCI operators disabled auxiliary oil pump during surveillance restoration

steps on May 16, 2009;

• Common cause analysis after "C" EDG trip on overspeed;

• <IE" EDG with failed turbocharger overspeed speed trip circuit, OFR 1166085;

and

• "0" EDG, ESW piping clamp support on floor, CR 1181216.

b. Findings

No findings of significance were identified

1R18 Plant Modifications (71111.18 - 2 Samples)

.1 T,emporary Plant Modifications (1 Sample)

a. Inspection Scope

The inspectors reviewed a temporary plant modification to determine whether the

change adversely affected system or support system availability, or adversely affected a

function important to plant safety. The inspectors reviewed the associated system

design bases, including the FSAR, TSs, and assessed the adequacy of the safety

determination screening and evaluation. The inspectors also assessed configuration

control of the change by reviewing selected drawings and procedures to verify whether

appropriate updates had been made. The inspectors compared the actual installation to

the temporary modification documents to determine whether the implemented change

was consistent with the approved documents. The inspectors reviewed selected

post-installation test results to determine whether the actual impact of the change had

been adequately demonstrated by the test. Documents reviewed are listed in the

Attachment. The following modification and document was included in the review:

• Unit 1, Temporary Engineering Change 1136133, bypass gas discharge

temperature trip on 1K206B.

b. Fr:ndings

No findings of significance were identified .

.2 Permanent Plant Modifications (1 Sample)

a. Inspection Scope

The inspectors reviewed a permanent plant modification to determine whether the

change adversely affected system or support system availability, or adversely affected a

function important to plant safety. The inspectors reviewed the associated system

design bases, including the FSAR, TSs, and assessed the adequacy of the safety

determination screening and evaluation. The inspectors also assessed configuration

control of the change by reviewing selected drawings and procedures to verify whether

appropriate updates had been made. The inspectors compared the actual installation to

the permanent modification documents to determine whether the implemented change

was consistent with the approved documents. The inspectors reviewed selected

Enclosure

20

post-installation test results to verify whether the actual impact of the change had been

adequately demonstrated by the test. Documents reviewed are listed in the Attachment.

The following modification and document was included in the review:

• Engineering Work Request 1086364, T20 H1 bushing replacement.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19- 6 Samples)

a. Inspection Scope

The inspectors observed portions of post-maintenance test (PMT) activities in the field to

determine whether the tests were performed in accordance with the approved

procedures. The inspectors assessed the test adequacy by comparing the test

methodology to the scope of maintenance work performed. In addition, the inspectors

evaluated acceptance criteria to determine whether the test demonstrated that

components satisfied the applicable design and licensing bases and TS requirements.

The inspectors reviewed the recorded test data to determine whether the acceptance

criteria were satisfied. Documents reviewed are listed in the Attachment. The PMT

activities reviewed included:

• Unit 1, HPCI PMT after stop valve repair;

• Unit 1, single control rod scram during scram switch functional check;

• Unit 1, core spray valve exercising, HV152F0005A and F015A after breaker

swaps;

• Unit 2, reactor core isolation cooling (RCIC) pump and flow testing and

overspeed trip test following resolution of turbine trip tappet nut alignment,

CR 1146099;

• Unit 2, PMT of PSV 251 F087 after maintenance to eliminate emergency core

cooling system keepfill leakage past valve; and

• T20 high bushing replacement, tap charger inspection and bus 20 cleaning and

inspection.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - 4 Routine Surveillance and 1 1ST Samples)

a. Inspection Scope

The inspectors observed portions of selected surveillance test activities in the control

room and in the field and reviewed test data results. The inspectors compared the test

results to the established acceptance criteria and the applicable TS or Technical

Requirements Manual operability and surveillance requirements to evaluate whether the

systems were capable of performing their intended safety functions. Documents

Enclosure

21

reviewed are listed in the Attachment. The observed or reviewed surveillance tests

included:

• Unit 1, quarterly functional test of reactor vessel water level channels

LlS-B21-IN031A, 3B, C, D, SI-180-203;

• Unit 2, 1ST testing of RCIC pump flow indication from remote shutdown panel;

• "A" SGTS filter and absorber leak tests;

• "D" EDG full load rejection test, SE-024-D01; and

• Monthly operation of SGTS train "A", SO-070-001.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation (71114.06 - 1 Sample)

a. Inspection Scope

Tlhe inspectors reviewed the combined functional drill scenario (2009 Gold Team

Emergency Drill) that was conducted on August 25, 2009, and observed selected

portions of the drill in the simulator control room and technical support center. The

inspection focused on PPL's ability to properly conduct emergency action level

classification, notification, and protective action recommendation activities and on the

evaluators' ability to identify observed weaknesses and/or deficiencies within these

areas. Ten performance indicator (PI) opportunities were included in the scenario.

The inspectors attended the evaluators' post-drill critique and compared identified

weaknesses and deficiencies including missed PI opportunities against those identified

by PPL to determine whether PPL was properly identifying weaknesses and failures in

tbese areas. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

2. RADIATION SAFETY

Cornerstone: Occupational Radiation Safety (OS)

20S1 Access Control to Radiologically Significant Areas (71121.01 6 Samples)

a. Inspection Scope

The inspectors reviewed and assessed the adequacy of PPL's internal dose assessment

for any actual internal exposure greater than 50 mrem committed effective dose

equivalent.

The inspectors examined PPL's physical and programmatic controls for highly activated

or contaminated materials (non-fuel) stored within spent fuel and other storage pools.

Enclosure

22

For high radiation work areas with significant dose rate gradients (factor of 5 or more),

the inspectors reviewed the application of dosimetry to effectively monitor exposure to

pE!rSOnnel.

The inspectors discussed with the radiation protection manager high dose rate-high

radiation area, and very high radiation area controls and procedures. The inspectors

focused on any procedural changes since the last inspection. The inspectors verified

that any changes to PPL's procedures did not substantially reduce the effectiveness and

level of worker protection.

The inspectors discussed with health physics supervisors the controls in place for

special areas that have the potential to become very high radiation areas during certain

plant operations. The inspectors determined that these plant operations required

communication beforehand with the health physics group, so as to allow corresponding

timely actions to properly post and control the radiation hazards.

The inspectors verified adequate posting and locking of entrances to high dose rate-high

radiation areas, and very high radiation areas.

The inspectors evaluated PPL's performance against the requirements contained in

10 CFR 20 and Plant Technical Specification 5.7.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

20S2 ALARA Planning and Controls (71121.02 - 3 Samples)

a. Inspection Scope

The inspectors obtained from PPL a list of work activities ranked by actual/estimated

exposure that are in progress or that have been completed during the last outage and

select the 2 work activities of highest exposure significance (in-vesseIISIIIVVI and EPU

alternate decay heat removal modification).

The inspectors reviewed PPL's method for adjusting exposure estimates, or re-planning

work, when unexpected changes in scope or emergent work are encountered. The

inspectors evaluated whether adjustments to estimated exposure (intended dose) were

based on sound radiation protection and ALARA principles or just adjusted to account

for failures to control the work.

The inspectors evaluated PPL's performance against the requirements contained in

10 CFR 20.1101.

Documents reviewed are listed in the Attachment.

Enclosure

23

b. Findings

Introduction: A self-revealing Green finding was identified due to a deficiency in the area

of maintaining occupational radiation exposures ALARA. Work performance involving

the IWI/ISI during the Unit 2 14th Refuel and Inspection Outage was less than adequate

resulting in collective exposure for the work to expand from 5.00 person-rem to 11.04

person-rem.

Description: The IWI/ISI dose overrun was primarily due to the utilization of

inexperienced contract workers to perform the task. The contractor selected by PPL

utilized workers for major IWIIISI tasks, including: inspection; camera placement and

repair; and, pressure washing/surface preparation, were inexperienced in performing

these tasks. The work hours to perform these tasks then expanded to include an

additional 294 hours0.0034 days <br />0.0817 hours <br />4.861111e-4 weeks <br />1.11867e-4 months <br /> for inspection; 207 hours0.0024 days <br />0.0575 hours <br />3.422619e-4 weeks <br />7.87635e-5 months <br /> for camera placement and repair; and,

1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> for pressure washing/surface preparation. These examples of additional in

fiE~ld high radiation work resulted in additional collective exposure that could have been

avoided had sufficient pre-job training been provided. Pre-task training for workers, as

described in the pre-outage work plan, was inadequate for the tasks to be performed,

based on the use of inexperienced workers. Outage planning for this work was based

upon past performance in earlier outages with experienced work crews, and estimated to

require less than 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br />. Actual hours to perform these tasks with the

inexperienced workers were over 5000 hours0.0579 days <br />1.389 hours <br />0.00827 weeks <br />0.0019 months <br />. The original exposure estimate was 5.00

person-rem. When compared to the actual work activity exposure of 11.04 person-rem,

the results were 120 percent greater than the exposure estimate.

Analysis: Inadequate work planning that resulted in significant unplanned collective

exposure was a performance deficiency which was reasonably within PPL's ability to

foresee and correct and which should have been prevented. Specifically, the original

exposure estimate was 5.00 person-rem. When compared to the actual work activity

exposure of 11.04 person-rem, the results were 120 percent greater than the exposure

estimate.

The finding is more than minor because the issue involved actual collective exposure

greater than 5 person-rem that was greater than 50 percent above the estimated or

intended exposure and the dose overrun was due to activities within PPL's control. This

issue is similar to the greater than minor examples provided in Appendix E of Manual

Chapter 0612. Further, the performance deficiency is associated with the radiation

safety cornerstone attribute of the program (ALARA planning) and adversely affected the

cornerstone objective to ensure adequate protection of worker health and safety from

exposure to radiation. The finding was evaluated in accordance with IMC 0609,

Appendix C, "Occupational Radiation Safety Significance Determination Process." The

inspectors determined that the finding was of very low safety significance (Green)

because: (1) it involved an ALARA planning issue, and (2) the 3-year rolling average

collective dose history was less than 240 person-rem (107 person-rem annual exposure

for 2005-2007). This finding was entered into PPL's CAP (CR 1140623 and 1137835).

This finding was determined to have a cross-cutting aspect in the area of Human

Performance, Resources, because PPL did not utilize sufficiently qualified personnel to

assure occupational radiation safety requirements were met H.2(b). Specifically, PPL's

use of inexperienced contract workers resulted in additional collective exposure that

could have been avoided.

Enclosure

24

Enforcement: Enforcement action does not apply because the performance deficiency

did not involve a violation of regulatory requirement. The ALARA rule contained in

1(I CFR 20.1101 (b) Statements of Consideration indicates that compliance with the

ALARA requirement will be judged on whether the licensee has incorporated measures

to track and, if necessary, to reduce exposures and not whether exposures and doses

represent an absolute minimum or whether the licensee has used all possible methods

to reduce exposures. The overall exposure performance of the nuclear power plant is

used to determine compliance with the ALARA rule. Since SSES is below the three

year-rolling-average of 240 person-rem and PPL has an established ALARA program to

reduce exposure consistent with the statements of consideration for 10 CFR 20.1101, no

violation of regulatory requirements [10 CFR 20.11 01 (b)] is considered. Because this

finding does not involve a violation of regulatory requirements and has very low safety

significance, it is identified as (FIN 05000388/2009004-04, Failure to Maintain

Occupational Radiation Exposure as Low as Reasonably Achievable during the

Unit 2 Refueling Outage)

20S3 Radiation Monitoring Instrumentation (71121.03 -1 Sample)

a. Inspection Scope

The inspectors verified the calibration, operability, and alarm setpoints of several types

of instruments and equipment. Verification methods included: review of calibration

documentation and observation of PPL's source check or calibrator exposed readings.

The inspectors reviewed the detector measurement geometry, calibration method and

appropriate selection of calibration sources to closely represent the actual measurement

conditions in the plant. The inspectors observed electronic and radiation calibration of

these. The inspectors reviewed the alarm set point determinations and observed in-field

source checks. The inspectors determined what actions were taken when, during

calibration or source checks, an instrument was found significantly out of calibration (>50

percent). The inspectors determined the possible consequences of instrument use since

last successful calibration or source check. The inspectors determined if the out of

calibration result was entered into the CAP.

During an on-site visit, the inspectors reviewed calibration data, quality assurance (QA)

data and National Voluntary Laboratory Accreditation Program audits and

intercomparison test data for PPL's personnel dosimetry laboratory located in Allentown.

The inspectors evaluated PPL's performance against the requirements contained in

10 CFR 20.1501,10 CFR 20.1703 and 10 CFR 20.1704.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

Enclosure

25

4. OTHER ACTIVITIES

40A1 Performance Indicator Verification (71151 - 8 Samples)

Injtiating Events

a. Inspection Scope

The inspectors reviewed PPL's PI data for the period of August 2008 through August

2009 to verify whether the PI data was accurate and complete. The inspectors

examined selected samples of PI data, PI data summary reports, and plant records. The

inspectors compared the PI data against the guidance contained in Nuclear Energy

Institute 99-02, "Regulatory Assessment Performance Indicator Guideline." Documents

reviewed are listed in the Attachment. The following PIs were included in this review:

• Units 1 and 2 unplanned scrams per 7000 critical hours (IE01);

• Units 1 and 2 unplanned power changes per 7000 critical hours (IE03);

• Units 1 and 2 unplanned scrams with complications (IE04);

• Common Occupational Exposure Control Effectiveness (OR01); and

• Common RETS/ODCM Radiological Effluents (PR01)

b. Findings

No findings of significance were identified.

40A2 Identification and Resolution of Problems (71152 - 1 Sample)

.1 Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As specified by Inspection Procedure 71152, Problem Identification and Resolution, and

in order to help identify repetitive equipment failures or specific human performance

issues for follow-up, the inspectors performed screening of all items entered into PPL's

CAP. This was accomplished by reviewing the description of each new action

requesUcondition report and attending daily management meetings.

b. Findings

No findings of significance were identified .

.2 Annual Sample: Review of PPL's Progress in Implementing Corrective Actions to

Address General Work Environment and Potential Chilling Effect Concerns

a. Inspection Scope

The inspectors performed a detailed review of PPL's corrective actions associated with

the Root Cause Analysis (RCA) conducted in response to the NRC's Potential Chilling

Effect (PCE) letter of January 28, 2009 and the associated action plan. The inspectors

reviewed the RCA, the general work environment action plan, Employees Concern

Enclosure

26

Program (ECP), QA documents, and selected reference RCA documents. The

inspectors also reviewed the corrective action schedules and reviewed completed

corrective actions such as revised procedures, training material, and records. The

inspectors also conducted interviews with site ECP and QA personnel, and several focus

groups consisting of workers and supervisors from the Security, Work Management,

Health Physics, and Operations Departments. These interviews were performed in

order to assess how the staff viewed the effectiveness of the corrective actions to date in

addressing the general work environment. The inspectors also assessed PPL's longer

term action plan items by verifying action item entries in the CAP as well as through

interviews of responsible personnel.

b. Findings and Observations

No findings of significance were identified.

Background: On January 28, 2009, the NRC issued a PCE letter advising PPL of

concerns related to the safety conscious work environment (SCWE) at SSES and

requested PPL provide: (1) a description of PPL's current action plans to address

existing SCWE concerns to preclude a chilled work environment at SSES; (2) PPL plans

for further evaluating the health of the SCWE at SSES; and (3) the metrics PPL intended

to monitor to determine the effectiveness of their actions and ensure a SCWE at SSES

(ML090280115). Also, on January 28, 2009, the NRC issued SSES - NRC Integrated

Inspection Report 05000387/2008005 and 05000388/2008005 (ML090230434) which

described the SCWE concerns at PPL and provided additional background. PPL

completed their formal RCA of the work environment issues in May 2009. The NRC's

review of that RCA is documented in NRC Integrated Inspection Report

05000387/2009003 and 05000388/2009003 (ML092230158).

Root Cause Analysis Corrective Actions

The inspectors determined that the corrective actions developed by the RCA team to

address the root cause and causal factors were being appropriately scheduled and that

the actions were being completed in accordance with that schedule. The time frame for

completion of these scheduled actions was also determined to be appropriate. Any

changes to the schedule required a review by the Management Review Committee and

approval by senior management.

Corrective actions completed to date included the roll out of the RCA through formal site

presentations and small group discussions, the establishment of two methods for

workers to raise an anonymous concern (Safety Hotline and anonymous computer

generated CRs), developing training materials and case studies related to work

environment issues and conducting this training with all first line supervisors and

positions above, and revising several procedures. The training was well received by

plant personnel and the new anonymous concern processes was being utilized by plant

personnel.

In addition, several organizational changes were made including the arrival of the new

eNO in July 2009, the establishment of a plant manager position, restructuring to have

QA, ECP, and Regulatory Affairs directly reporting to the CNO, and the selection of

several new personnel for key management positions. The inspectors observed that

these changes were well communicated to the site and generally have been well

Enclosure

27

received. Most personnel interviewed felt the organizational changes were appropriate

and the personnel selected were a good fit for their new positions. These changes have

allowed progress to be made in re-establishing trust between the workers and upper

management and improving the general work environment.

Employee Concerns Program

Another corrective action from the RCA was to evaluate and make changes to the ECP.

A strong ECP is a pillar of a successful safety culture. However, in the past at SSES,

the ECP was not seen by many plant employees as a viable and effective program.

During the third quarter 2009, PPL restructured the ECP program by eliminating the

Ombudsman position and hiring an additional ECP representative who was full time

on-site at SSES. The inspectors interviewed ECP representatives and discussed the

ECP program re-organizations with each of the focus groups. The inspectors concluded

that PPL did a good job communicating the changes in the ECP program to the site. All

groups interviewed knew who the new ECP representative was and were aware that the

Ombudsman position had been eliminated. Most had a positive impression and an

inherent level of trust for the new on-site ECP representative selected. In addition,

corrective actions were completed changing the organizational reporting requirements,

taking the ECP program out to the line organization and making it a direct report to the

CNO.

However, additional organizational changes in the ECP Oversight Team remain to

ensure that the ECP process is viewed by the workforce as a viable alternative for

issues. See NRC Integrated Inspection Report 05000387/2009003 and

05000388/2009003 (ML092230158) for further details on this concern.

Challenges: The inspectors identified two upcoming challenges which have the potential

to impact the general work environment. The first challenge will be the implementation

of the NRC Fatigue Rule (10 CFR 26 Subpart I) which went into effect October 1,2009.

The inspectors observed that the plant had done a good job communicating the new

rule, and had done a good job working with the departments most heavily impacted

(Operations and Security); however, several workers and supervisors interviewed

expressed uncertainty as to how the rule will be implemented and what will be the true

impact. PPL acknowledged it was slow in engaging the bargaining unit regarding

potential shift rotation adjustments in the Health Physics Department, which was a

concern to the mc:ijority of the Health Physics personnel interviewed. In a similar note,

the upcoming collective bargaining unit negotiations have the potential to impact the

general work environment.

Assessment

During the 3rd quarter of 2009, PPL made reasonable process in implementing their

action plan and RCA corrective actions to address the general work environment at

SSES. Based on interviews with a sample population of site employees, the actions to

date have been well received and are making a positive impact on the general work

environment at SSES. Overall, the workers stated they were cautiously optimistic that

changes were being implemented; however, they acknowledged that significant work

remained to be done and several Significant challenges still need to be addressed. The

NRC plans to continue monitoring PPL's progress in this area.

Enclosure

28

40A5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force

personnel and activities to ensure that the activities were consistent with licensee

security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

b. Findings

No findings of Significance were identified .

.2 Independent Spent Fuel Storage Installation (60855 and 60855.1)

a. Inspection Scope

The inspectors observed selected activities associated with loading of a dry cask

canister to ensure that TSs were met and equipment operated properly. The inspectors

reviewed documents and records associated with the operation of the SSES

independent spent fuel storage installation (ISFSI), including training records for

personnel involved with loading of a dry cask canister. A list of the documents reviewed

is provided in the Supplemental Information section. The inspectors met with reactor

engineering personnel to review the fuel selection process and associated

documentation. The inspectors discussed how the cask loading computer program is

created for each cask loading. The video recording of the fuel bundles placed into the

canister was reviewed to ensure that each bundle was placed into the proper location.

The inspectors observed work activities on the refuel floor associated with the fuel

selection, loading of fuel into the cask, vacuum drying, welding, and moving of the

loaded canister to the truck bay.

b. Findings

No findings of significance were identified. However, the inspectors did identify an issue

regarding compliance with procedure MT-GM-014, "Rigging and Lifting Equipment

Inspection." This procedure references ASME code 830.9-2003, "Slings." Both

documents require that slings are to be inspected annually. While the licensee also

performs an inspection of each sling prior to use in accordance with the same

procedure, the pre-job inspection does not meet the annual inspection requirement.

Inspectors noted that when synthetic slings used in dry cask storage are inspected by

PPL they receive an August 5th due date sticker for the following year, regardless of

when they are inspected in the current year. This presented a potential for a sling to

exceed its annual inspection based on the annotated date. PPL entered this issue into

their corrective action program under CR 1173698, "SSES Rigging Committee review of

procedural guidance." The licensee's extent of condition review did not identify any

slings used in safety related activities which had actually exceeded the annual inspection

criteria. As a result, this issue was determined to be of minor significance and a violation

of minor significance that is not subject to enforcement action in accordance with the

NRC's Enforcement Policy. However, for assessment purposes, this issue does

Enclosure

29

illustrate a weakness in PPL's Corrective Action Program because it did not identify a

non compliance with a regulatory requirement.

.3 Operation of an ISFSI at Operating Plants (60855)

a. Inspection Scope

The inspectors verified by direct observation and independent evaluation that PPL had

performed loading activities at the ISFSI in a safe manner and in compliance with

applicable procedures. This included observing the loading of one canister of spent fuel

into the ISFSI on August 10, 2009. The inspectors verified by direct observation that

radiation dose and contamination levels were within prescribed limits after a dry cask

storage system container had been installed at the ISFSI.

b. Findings

No findings of significance were identified.

40A6 Meetings, Including Exit

On August 14, 2009, the health physics inspector presented inspection results to Mr. C.

Gannon and other members of his staff, who acknowledged the findings. The inspector

confirmed that proprietary information was not provided or examined during the

inspection.

On August 21,2009, the health physics inspectors presented inspection results to Mr. C.

Gannon and other members of his staff, who acknowledged the findings. The inspectors

confirmed that proprietary information was not provided or examined during the

inspection.

On October 9,2009, the resident inspectors presented their findings to Mr. T. Rausch,

and other members of his staff, who acknowledged the findings. The inspectors

confirmed that proprietary information was not provided or examined during the

inspection.

40A7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by PPL and

is a violation of NRC requirements which meets the criteria of Section VI of the NRC

Enforcement Policy, NUREG-1600, for being dispositioned as an NCV:

• On 25 August 2009, while performing pre-start checks to place Unit 2 RHR in

suppression pool cooling, a field operator identified the ESW cooling water

valves 211193 and 211194 to be unlocked and closed. These valves are

required to be locked open to assure supply of cooling to a Unit 2 RHR room

cooler and 2C RHR pump motor oil cooler. This was an identified violation of

TS 5.4.1, and a violation of those procedures that must be implemented for

operation of the unit and for the performance of maintenance as delineated in

Regulatory Guide 1.33. Contrary to NDAP-QA-0302, "System Status and

Enclosure

30

Equipment Control," PPL did not use a proceduralized method to maintain

status control of these valves and contrary to NDAP-QA-502, "Work Control

Process," these valves were not returned to the original design configuration

following maintenance. PPL determined that the status control of these

valves was most likely lost during the post-modification testing performed in

late April 2009. Upon discovery, the valves were promptly aligned to provide

cooling flow and the performance issue was captured in CR 1174837. Using

a Phase III risk evaluation model, the region staff determined this finding to

be of very low safety significance (Green).

AITACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

N. D'Angelo, Manager, Station Engineering

R. Doty, Radiation Protection Manager

T Iliadis, GM - Nuclear Operations

S. Ingram, Dosimetry Supervisor

R. Kessler, Health Physicist - ALARA

A. Klopp, Heat Exchanger Program Engineer

D. Leimbach, Eddy Current Level III, In-service Inspection

R. Pagodin, GM - Nuclear Engineering

G. Ruppert, GM - Work Management

S. Davis, Fire Protection Program Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000387; 388/200900402 AV Violation of 10CFR55.3, Senior Reactor

Operators Performing Licensed Duties

While Not Qualified Due to Medical

Examination Issues (1 R11.2)

Opened/Closed

05000388/200900401 NCV Failure to Implement and Maintain the Fire

Protection Program with Respect to the Use

and Storage of Combustibles in the Control

Structure (1 R05)

05000387/200900403 NCV Inadequate Corrective Actions Result in a

Repeat Failure of Unit 1 HPCI Turbine Stop

Valve (1R12)

05000388/200900404 FIN Failure to Maintain Occupational Radiation

Exposure As Low As Reasonably

Achievable during the Unit 2 Refueling

Outage (20S2)

Attachment

A-2

BASELINE INSPECTION PROCEDURE PERFORMED

LIST OF DOCUMENTS REVIEWED

(Not Referenced in the Report)

Section 1R04: Equipment Alignment

Condition Reports:

1168300, 1175048, 1176331, 1174964

Procedures:

OP-225-001, Containment Instrument Gas System. Revision 30

CL-225-0012, Unit 2 Containment Instrument Gas Mechanical, Revision 13

Drawings:

M-2126, Unit 2 Containment Instrument Gas Sheets 1 and 2, Revision 33 and 13

M-157, Unit 1 Containment Atmosphere Control, Revision 47

M-134, A-D Diesel Auxiliaries Fuel Oil, Lube Oil. Air Intake and Exhaust and Jacket Water

Cooling System. Revision 45

Engineering Work Request:

EWR 1168578

Other:

Chemistry Analysis and Sample Results Attached to CR 1167146

Drainage Contour Map, Potentiometric Surface Contours Overburden Monitoring Wells

August/September 2008

Section 1 R05: Fire Protection

Condition Reports:

1172702

Procedures:

FP-113-113, Containment Access Area (1-401, 1-404, 1-405) Fire Zones 1-4A-N, S, W,

Elevation 719'-0", Revision 6

FP-013-168, Equipment and Battery Rooms Unit 1 West Side (C-605, 606, 600,601,607) Fire

Zones 0-28B-11, 0-28K, 0-28L, 0-281, Elevation 771'-0", Revision 5

FP-013-169, Equipment and Battery Rooms Unit 1 East Side (C-604, 602, 603, 608) Fire Zones

0-28B1, 0-28M, 0-28N, 0-28J, Elevation 771'-0", Revision 4

Attachment

A-3

Section 1R06: Flood Protection Measures

Condition Reports:

1121942,1171337,1172365,and606589

Work Order:

606837

Section 1R07: Heat Exchanger Performance

Condition Reports and Action Requests:

1003096,915409,984635,1136415,1153052, 1178867, 1095358, 1109759, 1172704,892305,

1095358,1109759,1162322,1084289, 1162414, 1108376, and 1044430

Procedures:

H-1001, Heat exchanger tube cleaning, Revision 5

H-1004, Heat exchanger inspection and condition assessment, Revision 6

H-1005, Eddy Current Examination Services, Revision 6

NDAP-QA-0504, Heat Exchanger Program, Revision 4

TP-149-079, RHR Heat Exchanger Performance Test, Revision1

ER-AA-340, GL 89-13 Program Implementing Procedure, Revision 4

ER-AA-340-1001, GL 89-13 Program Implementation Instructional Guide, Revision 6

ER-AA-5400, Buried Pipe and Raw Water Corrosion Program Guide, Revision 1

ER-AA-5400-1001, Raw Water Corrosion Program Guide, Revision 0

ER-AA-5400-1002, Buried Piping Examination Guide, Revision 1

Limerick GL 89-13 Program Basis Document, Revision 0

CY-LG-120-828, Clam Control Activities, Revision 5

CY-LG-120-1102, Outside Chemistry/NPDES related Sampling and analysis schedule,

R:evision 18

CY-LG-120-1117, Spray Pond Chemistry Guide, Revision 2

ST-2-011-390-0, ESW/Diesel Generator Heat Transfer Test, Revision 4

M-011-001, LGS Preventive Maintenance Procedure for Diesel Generator Heat Exchanger

Cleaning and Examination, Revision12

Standing work order R0920468-01, EDG heat exchangers

Drawings

Drawing # M-109/E106214, Service Water System, Revision 50,

Drawing # M-111/E106216, Emergency Service Water System, Revision 48

Drawing # M-112/E106217, RHR Service Water System, Revision 47

Drawing # M-120/E106225, Diesel Oil Transfer System, Revision 32

SIM-M-12, Emergency Service Water! RHR Service Water Overview, Revision 9

8031-M-11, Sh. 1-5, Emergency Service Water, Revision 68, 81,53,50,48, respectively

8031-M-12, Sh. 1-2, Residual Heat Removal Service Water, Revision 62,6, respectively

8031-E-1045, Cathodic Protection Plan Spray Pond & Cooling Towers Area, Revision 14

8031-E-'1046, Cathodic Protection Plan - PCMU, RHR & ESW Piping, Units 1 & 2, Revision 14

Unit 2 RHR Heat Exchanger Assembly & Cross Section Drawings, April 1972

Attachment

A-4

Work Orders:

796290, 796291,2E205A,889724,888029,OE505A1&2, 1078542,808322,OE505E1&2,

889732,889516,OE506A, 1111425, 1067871,OE506E,916733,889717,OE507A, 1111426,

1067872,OE507E,941280,889240

Miscellaneous Documents

Regulatory Guide 1.27, Ultimate Heat Sink for Nuclear Power Plants, dated January 1976

Generic Letter 89-13 and Supplement 1, Service Water System Problems Affecting

Safety-Related Equipment, Dated July 1989

PPL responses to GL 89-13, dated Feb. 23,1990, through Feb. 12, 1997, et al

Spray Pond Inspection Report, November 13, 2007

Zebra Mussel & Asiatic Clam Survey, November 6, 2007

ECT Test Report for Heat Exchanger 2A-E205, March 2005

WO R0966553, Clean and eddy current test 2A-E205, performed May 19, 2005

IC-C-11-02021, Testing of Cathodic Protection System, performed September 4, 2007

RT-1-012-390-0, RHR Heat Exchanger Heat Transfer Performance Computation Test,

performed Feb. 15, 2005

RT-2-011-251-0, ESW Loop A Flow Balance, Rev. 15, performed April 26, 2008

RT-6-012-390-2, 2A-E205 Heat Exchanger Heat Transfer Test, performed Feb. 9, 2005

RT-6-109-001-0, Cathodic Protection Monthly Inspection, performed September 4, 2007

ST-1-012-901-0, Spray Pond Structural Inspection, performed September 5,2002,

August 10, 2003, August 10, 2005, and July 27,2007

ST-6-011-231-0, A Loop ESW Pump, Valve, and Flow Test, performed May 9,2008, and

August 8, 2008

ST-6-012-232-0, A Loop RHRSW Pump, Valve, and Flow Test, performed May 16, 2008,

elnd August 7,2008

Structural Integrity Associates, Inc., Limerick ESW/RHRSW Pre-Outage Support, May 7,2008

Nuclear Event Report NC-07-044, Essential Service Water Piping Degradation, Rev. 0 & 1

Operational Event Review - Degradation of Essential Service Water Piping, January 15, 2008

Technical Evaluation - Cumulative Leakage from the ESW System (CR 714581-02)

Technical Evaluation EDG Permissible Fouling Factors as a Function of ESW Flow and

Plugged Tubes (IR 691841)

Apparent Cause Evaluation -Internal Corrosion of RHRSW System Piping (CR 731389)

Apparent Cause Evaluation -Increased Frequency of ESW Throttle Valve Silting (11/14/05)

Apparent Cause Evaluation - Diesel Heat Exchanger GL 89-13 Heat Transfer Test Performed

Too Soon After Cleaning (CR 174574)

RHRSW Pipe Minimum Wall Thickness Action Plan (IR 693495-32)

1D-G501, EDG Heat Exchanger Inspection Report, June 23, 2008

2D-G501, EDG Heat Exchanger Inspection Report, December 10,2007

LG 96-02349-000, Undersized Lube Oil Cooler

LG 01-0'1096-000, LGS Unit 1 & 2 GL 98-13 Program Recommendation - Heat Exchanger

Cleaning

LG 01-00968-000, Final Report on DG Heat Exchanger Performance Tests GL 89-13

Calculation LM-0225, Performance Curve for EDG Heat Exchanger for GL 89-13

Engineering Analysis LEAM-0007, Emergency Diesel Heat Exchanger Performance Tests

GL 89-13, September 10, 2001.

Evaluation of 0-22 EDG Heat Exchanger Performance Test of August 26, 2003

Evaluation of 0-22 EDG Heat Exchanger Performance Test of July 24,2004

Attachment

A-5

Evaluation of lube oil cooler fouling factor increases in winter, October 1, 2008

Commitment Change Evaluation 2006-002

ECR LG 96-02349, Undersized Lube Oil Cooler

ECR LG 01-01096, GL 98-13 Program Recommendation Heat Exchanger Cleaning

ECR LG 01-00968, Final Report on DG Heat Exchanger Performance Tests GL 89-13

ECR LG 04-00433, Licensing Basis of RHRSW Flow

Summary of RHRSW/ESW Valve Pit Inspections

Other:

Station Health Reports for RHR and EDG Systems:

2009, 1st period - Jan 1 - May 31

2008, 151 period - Jan 1 - Apr. 30

2 nd period - May 1- Aug. 31

3 rd period - Sept 1 - Dec. 31

2007, 1sl period - Jan 1 - Apr 30

2 nd period - May 1 Aug 31

3rd period Sept 1- Dec 31

Eddy Current Testing Final Reports

1E205B** 1B RHR Hx, 2E205A -1A RHR Hx, OE505 - Ai, A2, E1, E2, OE505, OE506 A, E,

OE526 E, OE507 A, E

ESSW Spray Pond Dive Inspection Report

Ecology III, Inc. report dated 3 August 2009

SO-054-A03, Quarterly ESW flow verification - Loop A, February 23, 2005 and

November 24, 2004

SO-054-803, Quarterly ESW flow verification - Loop B, February 16, 2005 and

November 17, 2004

TP-054-076, ESW flow balance, September 24, 2004

Chemistry Matrix Ch-054-001 (ESW), Revision 23, March 05, 2008

Design Calculations

CALC EC-CHEM-1018, Justification for the Assurance of Adequate Heat Removal Capabilities,

Revision 5

CALC EC-054-0537, ESW System Heat Load and Flow Rate Requirements for Updated Power

Conditions, Revision 5

CALC-049-1001, RHR Heat Exchanger Performance at 8000 gpm RHR Flow, Revision 5

Section 1R11: Operator Re-qualification Program

Condition Report:

1159194,1173155,1173182,622658,625137,389555,1166686

Procedures:

ON-164-002, Loss of Reactor Recirculation Flow, Revision 28

ON-178-002, Core Flux Oscillations, Revision 14

Attachment

A-6

ON-100-101, SCRAM, SCRAM Imminent, Revision 22

EO-000-113, Level/Power Control, Revision 6

EO-000-102, RPV Control, Revision 7

NDAP-QA-0725, Operating Experience Review Program, Revision 7

Other:

OP002-09-06-01, Simulator Scenario, Revision 0

Section 11R12: Maintenance Effectiveness

Condition Report:

1172458,1173175,1173454,1173859,1174337

Procedure:

ES-002-001, Supplying 125 VDC Loads with Portable Diesel Generator, Revision 12

Work Orders:

1172466,1172530

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Condition Report:

1162039,1172088,1171760,1171814, 1171764,and 1137572

Procedure:

MT-GE-030, ITT Damper Hydramotor Model NH91 NH93 Overhaul, Revision 17

OI-AD-029, Emergency Load Control, Revision 13

MT-GE-030, ITT Damper Hydramotor Model NH91 and NH93 Overhaul, Revision 17

DrawingS'~:

E-102, Sheet 17, ESS Transformer 101R201 Isolating Relay Control, Revision 13

E-102, Sheet 17 Circuit Breaker DA10406 Control, Revision 11

M-144, Sheet 2, Reactor Water Clean-Up, Revision 11

M-144, Sheet 1, Reactor Water Clean-Up, Revision 41

E6-8, sheet 1, ESS Trans EX201 and OX203, Revision 8

VC-175, Heating, Ventilation and Air-Conditioning Control Diagram SBGT System, Revision 31

M-145, Sheet 1, Clean-up Filter Demineralizer, Revision 21

Work Order:

1162052 and 828214

Other:

Attachment

A-7

2009 RFM Daily Status Report August 3-4,2009 - Cask 53

Section 1R15: Operability Evaluations

Condition Reports:

1159448,1159214,1159461,478425,794697,478350, 1160418, 1160653, 1112465, 1119661,

1147886,1145418,1152053,1152076,1161825, 1162050, 1172110, and 1172113

Procedures:

FSAR 7.:3.1

TRO 3.3.6

Drawings:

J-412, Sheet 6, RHR SW Pump Discharge Pressure, Revision 6

M-134, Sheet 3, A - D Diesel Auxiliaries Starting Air System, Revision 15

Work Order:

1159273

Engineering Work Request:

EWR 110707

Other:

10M 183-2, KSV Diesel Generator Instruction Manual, Revision 89

Section 1R18: Permanent Plant Modifications

Condition Reports:

1179204,1179788,1179777,1178870,1136097, 1136107, 1136188, 1141687,1136189,

1135663

Procedures:

FSAR 9.4.2.2,9.2.12.3, Table 9.4-4,5

TRO 3.8.6 and bases

LA-1K206B-001, 1K206B Reactor Building Chiller B Safety Indicator Panel, Revision 2

Drawingq:

M310-245, Sheet 2, Chiller 1K206B, Revision 2

Work Order:

1180017,1104170.1082776,1136153,1136156,1136013

Attachment

A-8

Engineering Work Request:

EWR 1086364

TEC 1136133, Bypass Gas Discharge Temperature Trip on -IK206B

Other:

10M 694, Type SL Core Form Substation Transformer Type UTT-B Load Tap Changer Spare

Startup Transformer, Revision 2

Section '1 R19: Post-Maintenance Testing

Condition Reports:

1079703" 1161553, 1174414, 1174403, 1177692, 1177906, 1183410

Procedures:

SO-151-014, Core Spray System Cold Shutdown Valve Exercising, September 28,2009,

Revision 16

SO-151-A04, Quarterly Core Spray Valve Exercising Division I, September 28,2009, Revision 9

SO-152-006, High Pressure Coolant Injection Comprehensive Flow Verification, Revision 8

SO-158-001, "Weekly Manual Scram Control Switch Functional Check," Revision 12

OP-003-003, Startup Bus 20 (OA104)fr20 Outage and restoration, Revision 1

Drawing

9220248, Connection Diagram Hydraulic Control Unit, Revision 3

10505411, Box and Cables Hydraulic Control Unit, Revision 3

105D5634, Connection Diagram Hydraulic Control Unit, Revision 2

922D234, Assembly Electrical box, Revision 3

E-157, Sheet 3, Trip Signals to hydraulic control unit Unit 1, Revision 7

MI-C72-~~2, Sheet 12, Elementary Diagram Reactor Protection System, Revision 13

Work Orders:

1046829., 1177693, 1012176

Engineering Work Reguest:

EC 1100766, Generic ECO 480V MCC Bucket Replacement

Section'1R22: Surveillance Testing

Condition Reports:

10419999,1159516, 1159518,1159520,1176579,917309,1041999, 1176718,1176719

Procedures:

Attachment

A-9

SE-070-A09, "A" SGTS HEPA Filter and Charcoal Adsorber in-Place Leak Test, Revision 5

MT-GM-076, Operations of the Aerosol Detector and Aerosol Generator for Testing HEPA

Filters, Revision 3

MT-GM-077, Operation of the Halide Detector and Halide Generator for Testing Charcoal

Filters, Revision 4

SI-250-312, 24 Month calibration of RCIC System Pump Flow Channel FT-E51-2N003 Remote

Shutdown Monitor

SE-150-004, RCIC Functional Test at 1C2014, January 21,2008, Revision 0

SE-100-008, RCIC Functional test at Remote Shutdown Panel, Revision 4

SE-200-008, RCIC Functional test at Remote Shutdown Panel, January 21, 2009, Revision 2

SE-100-011, HV143F023B, Functional Test at 1C2014, March 5, 2008, Revision 0

Work Orders:

875249,1130776

Drawing:

VC-175, Sheet 3, HVAC Control Diagram RB SGTS, Revision 31

E-201, Sheet 9, SGTS Dampers HD-0755A & B, Revision 17

E-154, Sheet 3, RCIC Outboard Steam Line Isolation Valve Unit 1, Revision 18

E-154, Sheet 22, RCIC Outboard Steam Line Isolation Valve Unit 2, Revision 5

E-149, Sheet 6, Remote Shutdown Panel 2C201, transfer Switches Unit 2, Revision 9

Section 1EP6 Drill Evaluation

Condition Reports:

1174697,1174731

Procedures:

EP-TP-001, EAL Classification Levels, Revision 2

Other:

August 25,2009 Drill Results Summary

Section 20S1: Access Control to Radiologically Significant Areas

Condition Reports:

1168353; 1167515; 1167427; 1162310; and 1165207

Section 20S2: ALARA Planning and Controls

Condition Reports:

1155780; 1153396; and 1140623

Section 20S3: Radiation Monitoring Instrumentation

Attachment

A-10

Quality Assurance Internal Audit Reports:

665555; 819260; and 1093653

NIST NVLAP On-Site Assessment Report, March 13,2009

Personnel Dosimetry Performance Testing Quarterly Report, 4th Quarter 2007

Section 40A1: Performance Indicator Verification

Procedures:

NDAP-QA-0737, Reactor Oversight Process Performance Indicators, Revision 5

Operator Logs, Unit 1 and Unit 2

Section 40A2: Identification and Resolution of Problems

Condition Reports:

1159518, 1159523, 1160653, 1161370, 1161398, 1162307, 1168487, 1168500, 1172365,

1173445,1173454,1174011,1174052,1174964,1175030, 1175048, 1175140, 1175332,

1175332, 1176331,1176959,1177165,1177499,1177965,1178870, 1179656, 1179995,

1027040,1044490,1073866,1114121,1128499, 1147908, 1148761,1148762,1148765,

1148790,1148824,1148828,1148834,1148851, 1148852, 1148853, 1148854, 1148859,

1148862,1148879,1148884,1148887,1148891, 1148895, 1148900,1157872,1158039,

1162998,.1173604,1173611,1173614, 1173619,1173697, 1181243

Engineering Work Request:

1161370

Procedures:

NDAP-00-0109, "Employee Concerns Program", Revision 13

NDAP-QA-0702, "Action Request and Condition Report Process", Revision 23

NRC Letter-EA-09-003, Work environment Issues at SSES-PCE, dated January 28, 2009

PPL Lettt:3r PLA-6486, SSES NRC Request to Address Work Environment Issues at SSES,

dated February 27, 2009

PPL Letter PLA-6489 SSES NRC Request to Address Work Environment Issues at SSES,

dated March 13, 2009

PPL Letter PLA-6528 SSES PPL Susquehanna LLC Work Environment Improvement Plan,

dated June 23, 2009

SSES Organization chart dated 9/10/2009

SSES Concerns Hotline flyer

Attachment

A-11

Safety Conscious Work Environment Trending Survey November 2008, Revision 0

General Work Environment-PCE Power Point Presentation, dated June 15, 2009

Communication Plan for Work Environment Root Cause Analysis report, dated June 3, 2009

USNRC Allegation Website allegation data from January 2005 - August 2009

SSES Organizational Effectiveness Oversight Panel, Employee Focus Group Meeting May 5-7,

2009 summary report

SSES Focus (Internal Communications newsletter) dated July 16, 2009; July 21,2009; July 29,

2009; July 31, 2009:;August 7, 2009 (2); August 14, 2009, August 17,2009, August 20,

2009, August 24,2009, August 26,2009, August 31,2009; September 1,2009,

September 4, 2009; September 11, 2009; September 14, 2009 (2); September 15, 2009;

September 22, 2009; and September 23, 2009

SSES Grapevine dated August 28, 2009; September 2, 2009; and September 8, 2009

SSES Work Environment Performance Indicators for July 2009 and August 2009

Proposed Draft General Work Environment Performance Indicator data dated

September 23, 2009

PPL Performance Planning and Review Process- Personnel Goals and Observation planning

sheet dated April 21, 2009

Nuclear culture review survey provided to Operations Department on 8/19/09 and preliminary

evaluation of the data

Memorandum of Agreement between PPL and IBEW Local 1600 dated may 9,2002

SSES RCA rollout Presentation and feedback forms

Section 40A5: Other

Condition Reports:

1173698

ISFSI related Condition Reports since July 12, 2006

Procedures:

ME-ORF-023, Dry Fuel Storage 61 BT Dry Shielded Canister, Revision 14

MT -EO-045, Guidance and Use of NUHOMS Automated Welding System for Welding

Operation, Revision 1

ME-ORF*,179, Dry Fuel Storage EqUipment List and Reference Information, Revision 8

NDAP-QA-0658, Dry Fuel Storage Program, Revision 6

IVIE-ORF-152, Dry Fuel Storage Response to Crane/RigginglTransfer Equipment, Malfunction

and Certificate of Compliance Technical Specification Requirements, Revision 2

MT-EO-058, E1000 Series Vacuum Drying System Operation, Revision 8

ME-ORF*,150, Dry Fuel Storage Dry Shielded Canister Unloading, Revision 1

RE-081-43, Selection and Monitoring of Fuel for Dry Storage, Revision 5

ON-089-001, Dry Fuel Storage Temperature Anomaly, Revision 6

MT-199-001, Reactor Building Crane Operating Procedure, Revision 18

MT-199-002, Reactor Building Crane Main & Auxiliary Hoist Limit Switch Testing, Revision 6

MT-GM-014, Rigging and Lifting Equipment Inspection, Revision 16

Work Orders:

ERPM 937419, Inspect 1H213 Crane for Proper Operation

ERPM 1065158, 1H213 Perform 4 year Weld Inspections, completed May 30,2009

Attachment

A-12

Other:

2008 PPL SSES LLC Dry Fuel Storage Project Completion Review Self Assessment

2009 Dry Fuel Storage Readiness Review

Annual Synthetic Round Sling Inspection Checklist

72.48 Screens, SO 00041, SO 00035, SO 00038, SO 00033, SO 00035, SO 00028, SO 00027,

SO 00024, SO 00000022, SO 00016, SO 00015, SO 00006

Final safety Analysis Report (FSAR), November 9, 2007

Decay Heat Calculation, EC-Fuel-1185, Revision 26

FACCTAS for DSC #53, July 31,2009, Revision 0

ISFSI Temperature Monitoring System Software Requirement Specification, July 2, 1999,

Revision 1.1

Annual Preventative Maintenance Plan for Unit 1 Reactor Building Crane, WO 19018,

completed December 5, 2008

SSES Area Survey Map, ISFSI Facility, dated: January 28, 2008; April 22, 2008; July

25, 2008; October 24, 2008; January 22, 2009; April 25, 2009; May 1, 2009

LIST OF ACRONYMS

ADAMS Agencywide Document and Access Management System

ALARA As Low As Is Reasonably Achievable

AV Apparent Violation

CAP Corrective Action Program

CFR Code of Federal Regulations

CR Condition Report

DG Diesel Generator

ECP Employee Concerns Program

EDG Emergency Diesel Generator

EPU Extended Power Uprate

ESW Emergency Service Water

FIN Finding

FPE Fire Protection Engineer

FPPR Fire Protection Program Report

FSAR [SSES] Final Safety Analysis Report

HPCI High Pressure Coolant Injection

HV High Voltage

IN Information Notice

IMC Inspection Manual Chapter

ISFSI Independent Spent Fuel Storage Installation

lSI Inservice Inspection

IWIIISI In Vessel Visual Inspectionll nservice Inspection

LCO Limiting Condition for Operation

NCV Non-Cited Violation

NDAP Nuclear Department Administrative Procedure

NRC Nuclear Regulatory Commission

PARS Publicly Available Records

PCE Potential Chilling Effect

PI [NRC] Performance Indicator

PM Preventive Maintenance

Attachment

A-13

PMT Post-Maintenance Test

PPL PPL Susquehanna, LLC

QA Quality Assurance

RCA Root Cause Analysis

RCIC Reactor Core Isolation Cooling

RHR Residual Heat Removal

RHRSW Residual Heat Removal Service Water

RTP Rated Thermal Power

SBO Station Blackout

SCWE Safety Conscious Work Environment

SOP Significance Determination Process

SGTS Standby Gas Treatment System

SRO Senior Reactor Operator

SSC Structures, Systems and Components

SSES Susquehanna Steam Electric Station

TS Technical Specifications

T20 T20 Startup Transformer

Attachment