ML15173A297
| ML15173A297 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/22/2015 |
| From: | Dan Dorman Region 1 Administrator |
| To: | Rausch T Susquehanna |
| Crisden C | |
| References | |
| EA-15-022 05000387/2015504, 05000388/2015504 | |
| Download: ML15173A297 (8) | |
See also: IR 05000387/2015504
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100
KING OF PRUSSIA, PA 19406-2713
June 22, 2015
Mr. Timothy S. Rausch
President and Chief Nuclear Officer
Susquehanna Nuclear, LLC
769 Salem Blvd - NUCSB3
Berwick, PA 18603-0467
SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING WITH
ASSESSMENT FOLLOW-UP AND NOTICE OF VIOLATION [INSPECTION
REPORT NO. 05000387/2015504 and 05000388/2015504] - SUSQUEHANNA
STEAM ELECTRIC STATION UNITS 1 AND 2
Dear Mr. Rausch:
This letter provides you the final significance determination of the preliminary White finding
discussed in the U.S. Nuclear Regulatory Commission (NRC) letter dated April 16, 2015, which
also enclosed Inspection Report No. 05000387/2015503 and 05000388/2015503
(ML15105A471)1. This letter also transmits the follow-up NRC assessment of Susquehanna
Nuclears 2 (Susquehannas) performance at the Susquehanna Steam Electric Station (SSES),
which supplements the NRC annual assessment letter issued on March 4, 2015
(ML15062A232).
The finding was identified through an NRC Problem Identification and Resolution Sample
Inspection at SSES to review Susquehannas evaluation of a concern related to emergency
action level (EAL) declaration timeliness associated with the fission product barrier degradation
EALs. The finding, which is described in detail in Inspection Report No. 05000387/2015503 and
05000388/2015503, involved Susquehannas incorrect implementation of the 15-minute
assessment, classification, and declaration period for a potential loss of Reactor Coolant
System (RCS) barrier EAL. Specifically, Susquehanna interpreted the 15-minute assessment,
classification, and declaration clock to start when operator actions were, or were expected to be,
unsuccessful in isolating an RCS leak rather than upon exceeding the EAL thresholds.
Susquehannas interpretation of the 15-minute assessment, classification, and declaration
period potentially degraded their ability to make a timely Site Area Emergency declaration for
one postulated scenario involving an unisolable primary coolant system leak outside of primary
containment. Susquehanna entered the issue into its corrective action program and
implemented compensatory measures to address the issue and ensure timeliness in making
event declarations.
1 Designation in parentheses refers to an Agency-wide Documents Access and Management System
(ADAMS) accession number. Documents referenced in this letter are publicly-available using the
accession number in ADAMS.
2 Effective June 1, 2015, PPL Corporation, LLC is no longer an NRC licensee. The new licensee is
Susquehanna Nuclear, LLC.
T. Rausch 2
In the April 16, 2015, letter transmitting the NRC preliminary determination and the inspection
report, the NRC offered Susquehanna the option to attend a regulatory conference, to reply in
writing to provide its position on the facts and assumptions the NRC used to arrive at the finding
and its safety significance, or to accept the finding as characterized in the inspection report.
In a letter dated May 15, 2015, (ML15135A493), Susquehanna provided a written response to
NRCs preliminary determination. In the response, Susquehanna acknowledged the finding, but
stated that the training and programs that were already in place prior to the finding would have
ensured that the impact of the deficiency would have remained relatively minor. In addition,
Susquehanna noted that the finding is associated with only one accident scenario: a primary
coolant system leak outside primary containment, and inside the secondary containment. In the
response, Susquehanna also noted a corrective action taken in response to the finding.
Specifically, Susquehanna revised the EAL basis to clearly state that for a potential loss of RCS,
the assessment of EAL entry conditions commences immediately when the emergency
thresholds are exceeded. A summary of Susquehannas position as provided in its May 15,
2015, letter, the NRCs response to the points raised in Susquehannas letter, and the details of
the NRCs conclusion on the safety significance of this issue, are provided in Enclosure 1.
After careful consideration of the information developed during the inspection and the additional
information provided in your letter dated May 15, 2015, the NRC has concluded that the finding
is appropriately characterized as White, a finding of low to moderate safety significance. You
have 30 calendar days from the date of this letter to appeal the staffs determination of
significance for the identified White finding. Such appeals will be considered to have merit only
if they meet the criteria given in the NRC Inspection Manual Chapter 0609, Attachment 2. An
appeal must be sent in writing to the Regional Administrator, Region I, 2100 Renaissance
Boulevard, King of Prussia, PA 19406.
The NRC has also determined that the finding is a violation of Title 10 of the Code of Federal
Regulations (10 CFR) 50.54(q), Condition of Licenses, as cited in the Notice of Violation
(Notice) in Enclosure 2. The circumstances surrounding the violation were described in detail in
Inspection Report No. 05000387/2015503 and 05000388/2015503. In accordance with the
NRC Enforcement Policy, the Notice is considered escalated enforcement action because it is
associated with a White finding. You are required to respond to this letter and should follow the
instructions specified in the enclosed Notice when preparing your response. If you have
additional information that you believe the NRC should consider, you may provide it in your
response to the Notice. The NRC review of your response to the Notice will also determine
whether further enforcement action is necessary to ensure compliance with regulatory
requirements.
With respect to the supplemental NRC assessment of Susquehannas performance at SSES
Units 1 and Unit 2, as a result of this White finding in the Emergency Preparedness
Cornerstone, the NRC has assessed SSES Units 1 and 2 to be in the Regulatory Response
column of the NRC Action Matrix, retroactive to the second calendar quarter of 2015.
Therefore, we plan to conduct a supplemental inspection using Inspection Procedure 95001,
Supplemental for One or Two White Inputs in a Strategic Performance Area, when your staff
notifies us of their readiness for this inspection. This inspection is conducted to provide
assurance that the root cause and contributing causes of any performance issues are
understood, the extent of condition is identified, and the corrective actions are sufficient to
prevent recurrence.
T. Rausch 3
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response will be made available electronically for public inspection in the
NRC Public Document Room located at NRC Headquarters in Rockville, MD, and from the
NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html . To the extent possible, your
response should not include any personal privacy, proprietary, or safeguards information so that
it can be made available to the Public without redaction.
Should you have any questions regarding this matter, please contact Mr. Anthony Dimitriadis,
Chief, Division of Reactor Safety, Plant Support Branch 1, in Region I, at (610) 337-6953.
Sincerely,
/RA/ Original Signed by:
Daniel H. Dorman
Regional Administrator
Docket Nos. 50-387 and 50-388
License Nos. NPF-14 and NPF-22
Enclosures: As stated
cc w/encl: Distribution via ListServ
T. Rausch 3
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response will be made available electronically for public inspection in the
NRC Public Document Room located at NRC Headquarters in Rockville, MD, and from the
NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html . To the extent possible, your
response should not include any personal privacy, proprietary, or safeguards information so that
it can be made available to the Public without redaction.
Should you have any questions regarding this matter, please contact Mr. Anthony Dimitriadis,
Chief, Division of Reactor Safety, Plant Support Branch 1, in Region I, at (610) 337-6953.
Sincerely,
/RA/ Original Signed by:
Daniel H. Dorman
Regional Administrator
Docket Nos. 50-387 and 50-388
License Nos. NPF-14 and NPF-22
Enclosures: As stated
cc w/encl: Distribution via ListServ
S:\Enf-allg\Enforcement\Proposed-Actions\Region1\Susquehanna EA-15-022 EP FINAL WHITE.docx ADAMS No.: ML15173A297
X Non-Sensitive X Publicly Available
X SUNSI Review/ CJC
Sensitive Non-Publicly Available
OFFICE RI/ORA RI/DRP RI/DRS RI/DRP RI/DRS
NAME C Crisden/CJC* F Bower/FLB* A Dimitriadis/STB for* H Nieh/HKN* R Lorson/RKL*
DATE 05/28/15 5/29/15 5/29/15 6/1/15 5/29/15
OFFICE RI/ORA RI/ORA OE RI/RA
NAME B Klukan/BMK* B Bickett/MMM for* G Figueroa via email* D Dorman
DATE 06/2/15 6/3/15 6/10/15 6/22/15
- See previous concurrence page OFFICIAL RECORD COPY
Letter to T. Rausch from D. Dorman dated June 22, 2015
SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING WITH
ASSESSMENT FOLLOW-UP AND NOTICE OF VIOLATION [INSPECTION
REPORT NO. 05000387/2015504 and 05000388/2015504] - SUSQUEHANNA
STEAM ELECTRIC STATION UNITS 1 AND 2
DISTRIBUTION w/encl: (via email)
SECY RidsSecyMailCenter
OEMAIL OEMAIL Resource
OEWEB OEWEB Resource
MSatorius, EDO RidsEdoMailCenter
MJohnson, DEDR
KMorgan Butler, OEDO
YChen, OEDO
PHolahan, OE RidsOeMailCenter
NSosa, OE
NHasan, OE
NHilton, OE
GFigueroa, OE
DWillis, NRR
LCasey, NRR
BKahler, NSIR
SLavie, NSIR
SCoker, NSIR
Enforcement Coordinators RII, RIII, RIV (D Gamberoni, R Stokowski, M Hay)
CScott, OGC RidsOgcMailCenter
HHarrington, OPA RidsOpaMail Resource
HBell, OIG RidsOigMailCenter
CMcCrary, OI RidsOiMailCenter
LBates, OCFO RIDSOcfoMailCenter
MWilliams, OCFO
DDorman, RI/RA R1ORAMail Resource
DLew, DRA/RI R1ORAMail Resource
DScrenci, PAO-RI / N Sheehan, PAO-RI
HNieh, DRP R1DRPMail Resource
MScott, DRP R1DRPMail Resource
RLorson, DRS R1DRSMail Resource
JTrapp, DRS R1DRSMail Resource
ADimitriadis, DRS
EBurket, DRS
FBower, DRP
SBarber, DRP
TDaun, DRP, RI
BKlukan, RI
BBickett, RI
CCrisden, RI
MMcLaughlin, RI
DBearde, RI
Region I OE Files (with concurrences)
ROPasssessment Resource
ROPreports Resource
ENCLOSURE 1
NRC RESPONSE TO INFORMATION PROVIDED IN THE
SUSQUEHANNA NUCLEAR, LLC (SUSQUEHANNA) LETTER DATED May 15, 2015
SUMMARY OF SUSQUEHANNAS POSITION
In a May 15, 2015, letter, Susquehanna submitted Susquehanna Steam Electric Station
Response to the Preliminary White Finding in Inspection Report No. 05000387/2015503 and
05000388/2015503, (ML15135A493) for the NRCs review and consideration prior to reaching
a final significance determination. Susquehanna acknowledged the finding, but stated that the
training and programs that were already in place prior to the finding would have ensured that the
impact of the deficiency would have remained relatively minor.
In support of this view, Susquehanna raised two points for NRC consideration. These points,
and the NRC responses to each, are summarized below:
Susquehanna Point #1:
The preliminary finding relates to one specific accident type - a primary coolant system leak
outside primary containment, and inside the secondary containment. The performance
deficiency was not noted in any other accident scenarios.
NRC Response
The NRC agrees the preliminary White finding relates to one specific accident type, however,
the Emergency Preparedness (EP) Significance Determination Process (SDP) does not
determine significance based on the number of accident scenarios impacted. The EP SDP
determines significance with regard to the impact on the accuracy and timeliness of an
emergency classification level. Therefore, because the accident scenario affects a timely Site
Area Emergency (SAE) declaration, as discussed in Inspection Report No. 05000387/2015503
and 05000388/2015503, the preliminary finding has a significance of low to moderate safety
significance (White).
Susquehanna Point #2:
Susquehanna reviewed two years of historical operator performance at SSES for simulator
scenarios involving a primary coolant system leak outside primary containment. Although
Susquehanna procedures allowed completion of isolation actions prior to emergency
declaration, in the majority of the scenarios involving this type of event, the operators took the
proper mitigating action, correctly declared an emergency within 15 minutes of indication of the
steam leak, and communicated with offsite agencies in less than 30 minutes.
NRC Response
Attachment 3, Significance Determination Process Basis Document, to Appendix B, Technical
Basis for Emergency Preparedness Significance Determination Process, to Inspection Manual
Chapter 0308, Reactor Oversight Process (ROP) Basis Document, provides the technical
basis for the EP SDP. The Technical Basis for the EP SDP states that the performance
expectation is to demonstrate that reasonable assurance exists such that the licensee can
effectively implement its emergency plan to protect public health and safety adequately in the
event of a radiological emergency. The Technical Basis also discusses the development of
the EP SDP and the contribution of the risk-significant planning standard (RSPS) functions
Enclosure 1 2
provided in assessing risk. The preliminary finding is associated with RSPS 50.47(b)(4),
Emergency Classification System.
The EP SDP defines the EAL classification process as: facility procedures; training; ERO
staffing; system, instrumentation, or equipment; or other resources or capabilities necessary to
complete a classification or declaration. For the preliminary finding described in Inspection
Report No. 05000387/2015503 and 05000388/2015503, the EAL classification process was
impacted because Susquehannas procedures allowed operators to attempt to complete
mitigating actions before starting the 15 minute clock to complete the classification or
declaration. Although past performance indicates that the declarations have been made on
time, the procedural guidance could have resulted in longer declaration times under different
circumstances.
Therefore, the NRC determined that the potential for an untimely emergency declaration
associated with an unisolable primary system leak outside of primary containment existed, and
thus, the public could have been placed at a greater risk.
SUMMARY
The NRC staff reviewed Susquehannas written response to the preliminary White Finding dated
May 15, 2015. The NRC acknowledges and considered Susquehannas viewpoint; however,
the NRC staffs position is unchanged. The NRC regulations require, in part, that licensees
establish and maintain the capability to assess, classify, and declare an emergency condition
within 15-minutes after the availability of indications to plant operators that an emergency action
level has been exceeded and shall promptly declare the emergency condition as soon as
possible following identification of the appropriate emergency classification level. Licensees
shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid
declaring an emergency action due to an EAL that has been exceeded. The EP SDP provides
staff guidance on how delays in declarations that affect Site Area Emergencies and General
Emergencies should be evaluated for risk significance. The NRC confirmed that the guidance
was properly applied in this case.
Based upon the information provided, the NRC staff concluded that the issue should remain low
to moderate safety significance (White).
ENCLOSURE 2
NOTICE OF VIOLATION
Susquehanna Nuclear, LLC. Docket Nos. 50-387, 50-388
Susquehanna Steam Electric Station License Nos. NPF-14, NPF-22
During an NRC inspection conducted from January 12 - March 17, 2015, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
10 CFR 50.54(q)(2), requires that a holder of a nuclear power reactor
operating license under this part, shall follow and maintain the effectiveness of an
emergency plan that meets the requirements in Appendix E of this part and the
standards in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.
10 CFR 50.47(b)(4), requires a standard emergency classification and action level
scheme, the bases of which include facility system and effluent parameters, is in use by
the nuclear facility licensee, and state and local response plans call for reliance on
information provided by facility licensees for determinations of minimum initial offsite
response measures.
Appendix E,Section IV.C.2, requires that by June 20, 2012, nuclear power reactor
licensees shall establish and maintain the capability to assess, classify, and declare an
emergency condition within 15-minutes after the availability of indications to plant
operators that an emergency action level has been exceeded and shall promptly declare
the emergency condition as soon as possible following identification of the appropriate
emergency classification level. Licensees shall not construe these criteria as a grace
period to attempt to restore plant conditions to avoid declaring an emergency action due
to an EAL that has been exceeded.
Contrary to the above, as of June 20, 2012, Susquehanna Nuclear, LLC (Susquehanna)
failed to maintain in effect an emergency plan that met the standards in 10 CFR
50.47(b)(4) and the requirements in 10 CFR 50, Appendix E, Section IV.C.2.
Specifically, Susquehannas interpretation of the 15-minute assessment and declaration
period degraded their ability to make a timely Site Area Emergency (SAE) declaration for
a potential loss of Reactor Coolant System (RCS) barrier emergency action level.
Susquehanna interpreted the 15-minute assessment and declaration clock to start when
operator actions were, or expected to be, unsuccessful in isolating an RCS leak.
Susquehannas incorrect interpretation of the 15-minute assessment and declaration
period degraded its ability to make timely a SAE declaration.
This violation is associated with a White Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Susquehanna Nuclear, LLC is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional
Administrator, Region I, and a copy to the NRC Resident Inspector at the Susquehanna Steam
Electric Station, within 30 days of the date of the letter transmitting this Notice of Violation
(Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; EA-15-022"
Notice of Violation 2
and should include the following: (1) the reason for the violation, or, if contested, the basis for
disputing the violation, (2) the corrective steps that have been taken and the results achieved,
(3) the corrective steps that will be taken, and (4) the date when full compliance will be
achieved. Your response may reference or include previous docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, Susquehanna may be required to post this Notice within two
working days of receipt.
Dated this 22nd day of June, 2015.