IR 05000387/2017001

Integrated Inspection Report 05000387/2017001 and 05000388/2017001

ML17130A896
Person / Time
Site:	Susquehanna
Issue date:	05/09/2017
From:	Daniel Schroeder Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
Schroeder D
References
IR 2017001
Download: ML17130A896 (30)

Text

[Type here]

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713 May 9, 2017 Mr. Timothy President and Chief Nuclear Officer Susquehanna Nuclear, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603 SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION - INTEGRATED INSPECTION REPORT 05000387/2017001 AND 05000388/2017001

Dear Mr. Rausch:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station (SSES), Units 1 and 2. On April 7, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff.

The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, 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, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Susquehanna. In addition, if you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Susquehanna. This letter, its enclosure, and your response, (if any), will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387 and 50-388 License Nos. NPF-14 and NPF-22

Enclosure:

Inspection Report 05000387/2017001 and 05000388/2017001 w/Attachment:

Supplementary Information

REGION I==

Docket Nos.: 50-387 and 50-388 License Nos.: NPF-14 and NPF-22 Report No.: 05000387/2017001 and 05000388/2017001 Licensee: Susquehanna Nuclear, LLC (Susquehanna)

Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: January 1, 2017 through March 31, 2017 Inspectors: L. Micewski, Senior Resident Inspector J. Greives, Senior Resident Inspector T. Daun, Resident Inspector T. OHara, Reactor Inspector J. Furia, Senior Health Physicist Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

IR 05000387/2017001 and 05000388/2017001; January 1, 2017 through March 31, 2017;

Susquehanna Steam Electric Station Units 1 and 2; Follow-Up of Events and Notices of Enforcement Discretion.

This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. The inspectors identified one non-cited violation (NCV), which was of very low safety significance (Green). The significance of most findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

Cornerstone: Barrier Integrity

Green.

A self-revealing finding of very low safety significance (Green) and associated NCV of TS 5.4.1, Procedures, was identified for failure to implement procedures that resulted in a secondary containment fan trip and associated loss of safety function. Susquehannas immediate corrective actions included restoring the secondary containment system to an operable configuration, and entering the issue into their corrective action program (CAP).

Inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute (Routine OPS/Maintenance Performance) of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (Secondary Containment) protect the public from radionuclide releases caused by accidents or events. The failure to adequately implement procedures for operation and maintenance of the secondary containment resulted in the inoperability of Zone 3 secondary containment and an associated loss of safety function. In accordance with IMC 0609.04, Initial Characterization of Findings, dated October 7, 2016, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency only impacted the radiological barrier function of secondary containment. This finding had a cross-cutting aspect in the area of Human Performance, Teamwork because individuals and work groups did not communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained. Specifically, personnel did not conduct a re-brief of the team after the plan deviated from what was originally briefed, and the team did not adequately respond to challenges from workers in the field about whether it was appropriate to commence load center restoration with work still in progress.

[H.4] (Section 4OA3)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On February 24, 2017, operators reduced power to approximately 72 percent for a planned control rod sequence exchange.

Following the exchange, operators returned the unit to 100 percent on February 25, 2017.

The unit remained at 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power. On January 20, 2017, operators reduced power to approximately 82 percent, performed rod pattern adjustments and returned the unit to 100 percent on January 21, 2017. On January 28, 2017, power was reduced to 85 percent for rod pattern adjustments and returned to 100 percent the same day. On January 31, 2017, operators lowered power and commenced end-of-cycle coast down for the remainder of the cycle. On March 3, 2017, operators commenced reducing power from 87 percent for a planned refueling outage. Unit 2 reached Mode 4 on March 4, 2017 and remained shut down for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Susquehannas preparations for a winter weather advisory for an impending winter storm on February 8, 2017. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the emergency diesel generator (EDG) system and emergency service water to ensure system availability. The inspectors verified that operator actions defined in Susquehannas adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

• Unit Common, B control structure chiller during A control structure chiller system outage window (SOW) on January 6, 2017;

• Unit Common, E EDG while substituted for A EDG during A EDG SOW on January 18, 2017;

• Unit 2, high pressure coolant injection (HPCI) during reactor core isolation cooling (RCIC) SOW on January 24, 2017;

• Unit 2, spent fuel pool cooling while shutdown cooling was secured for residual heat removal (RHR) common work window on March 23, 2017 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), work orders, condition reports (CRs),and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Susquehanna staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Susquehanna controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out-of-service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

• Unit 2, HPCI pump room (fire zone 2-1C) on January 25, 2017;

• Unit 1, RCIC pump room (fire zone 1-1D) on February 1, 2017;

• Unit Common, C EDG (fire zone 0-41C) on February 8, 2017;

• Unit Common, engineered safeguards service water pump house (fire zones 0-51 and 0-52) on March 20, 2017;

• Unit Common, spent fuel pool cooling rooms (fire zones 1-5 A-S and 2-5 A-S) on March 24, 2017

b. Findings

No findings were identified.

1R07 Heat Sink Performance (711111.07A - 1 sample)

a. Inspection Scope

The inspectors reviewed the 2A residual heat removal service water (RHRSW) heat exchanger readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified Susquehannas commitments to NRC Generic Letter 89-13, Service Water System Requirements Affecting Safety-Related Equipment. The inspectors reviewed the results of previous inspections of the 2A RHRSW heat exchanger. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that Susquehanna initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.

• Unit 2, A RHRSW heat exchanger on March 21, 2017

b. Findings

No findings were identified.

1R08 In-service Inspection

a. Inspection Scope

From March 13 to March 17, 2017, the inspectors conducted an inspection and review of in-service inspection program activities in order to assess the effectiveness of Susquehannas program for monitoring degradation of the reactor coolant system boundary, risk-significant piping and components, and containment systems during the Susquehanna Unit 2 18th refueling outage. The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in systems where degradation would result in a significant increase in risk.

Non-destructive Examination (NDE) and Welding Activities (Section 02.01)

For each evaluation, the inspectors verified NDE activities were performed in accordance with the 2007 Edition, 2008 Addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements. The inspectors also verified the NDE activities met the requirements in ASME Section XI, Mandatory Appendix VIII, Article VIII-2000 and the examination personnel were qualified in accordance with ASME Section XI, Mandatory Appendix VII. The inspectors verified that indications and defects, if present, were dispositioned in accordance with the ASME Code.

ASME Code Required Examinations:

The inspectors observed or reviewed the following NDE activities and completed data review of the inspection records:

• Manual ultrasonic testing (UT), volumetric inspection record, ASME Class 1 Reactor Head seam weld to intersecting welds AG and AH.

• Manual (Inner Radius) UT Exam Plan, Susquehanna N4C RV feedwater nozzle UT inspection examination record, ASME Class 1.

• Manual UT Exam of Susquehanna component N1A nozzle safe end.

• Reviewed Radiographic testing, volumetric inspection records, during the installation of EC#1672802, installation of a reliable hardened vent on Unit 2; ASME Class 2,Section XI and Section III new welds. The inspectors reviewed welds FW-3, FW-4, and FW-6.

Other Augmented, License Renewal or Industry Initiative Examinations:

The inspectors performed a record review of the containment general visual examination implemented in conformance with the 2007 Edition, 2008 Addenda of Article IWE of Section XI. The inspectors ensured that difficult to access areas or areas made visible by maintenance activities, were included within the scope of the visual examination.

Additionally, the inspectors verified the basis for declaring some containment areas as inaccessible for visual examination by comparing the basis against previous containment visual examination records. The inspectors reviewed the data records from Susquehannas 2015 visual inspection of the accessible areas to verify that Susquehanna was visually inspecting the containment and documenting deficiencies noted and entering the conditions into the corrective action process.

Review of Previous Indications There were no samples available for review during this inspection which involved examinations with recordable indications that had been accepted for continued service after evaluation or analysis, following the previous Unit 2 outage.

Welding on Pressure Boundary Systems The inspectors reviewed NDE results for the installation of ASME Class 2 valves and piping to complete the addition of a hardened containment vent system for the Unit 2 primary containment. The inspectors reviewed the radiographic records associated with the radiographic testing completed for joining sections between ASME Section XI and to ASME Section III requirements. The inspectors reviewed the results of the air pressure test completed on the hardened containment vent system.

The inspectors further verified that the welding and acceptance testing were performed in accordance with the 2007 Edition, 2008 Addenda of the ASME Boiler and Pressure Vessel Code requirements and the applicable Susquehanna modification record.

Specifically, the inspectors verified the welding procedure specification contained the essential variables and supplemental essential variables, in conformance with ASME Section IX, QW-200, and that the weld variables were within the range qualified by the supporting procedure qualification record as required by ASME Code Section IX, QW-250.

Identification and Resolution of Problems (IMC 02.05)

The inspectors reviewed a sample of condition reports which identified NDE indications, deficiencies and other nonconforming conditions since the previous refueling outage.

The inspectors verified that nonconforming conditions were properly identified, characterized, evaluated, corrective actions identified and dispositioned, and appropriately entered into the CAP.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on February 13, 2017, which included a loss of instrument air, a loss of coolant accident, and the failure of select components to automatically start as required. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.

The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

On March 4, 2017 the inspectors observed the control room operators perform a planned reactor shutdown for the Unit 2 refueling outage. The inspectors observed the reactivity control briefing to verify that it met the criteria specified in OP-AD-002, Standards for Shift Operations, Revision 63, OP-AD-300, Administration of Operations, Revision 20, and OP-AD-338, Reactivity Manipulations Standards and Communication Requirements, Revision 31. The inspectors observed the crew during the evolution to verify that procedure use, crew communications, control board component manipulations, and coordination of activities in the control room met established standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component performance and reliability.

The inspectors reviewed system health reports, CAP documents, and maintenance rule basis documents to ensure that Susquehanna was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the structure, system, or component was properly scoped into the maintenance rule in accordance with 10 CFR (Code of Federal Regulations) 50.65 and verified that the (a)(2) performance criteria established by Susquehanna staff was reasonable. As applicable, for structures, systems, and components classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these structures, systems, and components to (a)(2).

Additionally, the inspectors ensured that Susquehanna staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

• Review of 10 CFR 50.65(a)(3) assessment dated December 21, 2016 on March 7, 2017

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Susquehanna performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Susquehanna personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When Susquehanna performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

• Unit 2, elevated risk during B EDG maintenance on February 27, 2017;

• Unit 2, shutdown risk assessment for operations with the potential to drain the reactor vessel on March 10, 2017;

• Unit 2, protected equipment for shutdown cooling on March 17, 2017;

• Unit 2, shutdown risk during RHR common work window on March 24, 2017;

• Unit 1, elevated risk during C EDG work on March 27, 2017

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and systems:

• Unit Common, A control structure chilled water temperature control valve failure on January 13, 2017;

• Unit 2, 3A recirculation pump trip breaker coil status light extinguished on February 17, 2017;

• Unit Common, A emergency service water pump differential pressure in alert range on March 2, 2017;

• Unit 2, control rod drive mechanism cap screws exceeding maximum allowable torque on March 17, 2017;

• Unit Common, main steam isolation valve solenoid splicing not environmentally qualified on March 29, 2017;

• Unit 2, missing hardware on suppression pool RHR division 1 return line strut on March 31, 2017 The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Susquehannas evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, such as in the case of operator workarounds (OWAs), the inspectors determined whether the measures in place would function as intended and were properly controlled by Susquehanna.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold points were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.

• Unit Common, A EDG following overhaul on January 23, 2017;

• Unit 2, testing of primary containment boundary following hardened containment vent tie-in on March 24, 2017;

• Unit Common, C EDG Automatic Transfer Switch following 0ATS536 maintenance on March 28, 2017

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant structures, systems, and components to assess whether test results satisfied TSs, the UFSAR, and Susquehanna procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied.

Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

• Unit 2, RCIC logic system functional test on January 24, 2017;

• Unit Common, EDG A integrated surveillance test on February 21, 2017;

• Unit 2, RHR logic system functional test on February 21, 2017;

• Unit 1, secondary containment drawdown and in-leakage testing zones 1 and 3 on March 8, 2017;

• Unit 2, division 1 EDG loss of coolant accident/loss of offsite power testing on March 15, 2017;

• Unit 2, main steam isolation valve 28D local leak-rate test on March 30, 2017

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on February 13, 2017 which required emergency plan implementation by an operations crew. Susquehanna planned for this evolution to be evaluated and included in performance indicator (PI) data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew.

The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Susquehanna evaluators noted the same issues and entered them into the CAP.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

(2 samples)

a. Inspection Scope

The inspectors reviewed Susquehannas performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR 20, TSs, regulatory guide (RG) 8.38, and the procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the PIs for the occupational exposure cornerstone, radiation protection (RP) program audits, and reports of operational occurrences in occupational radiation safety since the last inspection.

Radiological Hazards Control and Work Coverage (1 sample)

The inspectors evaluated in-plant radiological conditions and performed independent radiation measurements during facility walkdowns and observation of radiological work activities. The inspectors assessed whether posted surveys; radiation work permits; worker radiological briefings and RP job coverage; the use of continuous air monitoring, air sampling and engineering controls; and dosimetry monitoring were consistent with the present conditions. The inspectors examined the control of highly activated or contaminated materials stored within the spent fuel pools and the posting and physical controls for selected high radiation areas, locked high radiation areas and very high radiation areas to verify conformance with the occupational PI.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample)

The inspectors evaluated radiation worker performance with respect to RP work requirements. The inspectors evaluated RP technicians in performance of radiation surveys and in providing radiological job coverage.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

(2 samples)

a. Inspection Scope

The inspectors assessed Susquehannas performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements contained in 10 CFR 20, RGs 8.8 and 8.10, TSs, and procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors conducted a review of Susquehannas collective dose history and trends; ongoing and planned radiological work activities; previous post-outage ALARA reviews; radiological source term history and trends; and ALARA dose estimating and tracking procedures.

Verification of Dose Estimates and Exposure Tracking Systems (1 sample)

The inspectors reviewed the current annual collective dose estimate; basis methodology; and measures to track, trend, and reduce occupational doses for ongoing work activities.

The inspectors evaluated the adjustment of exposure estimates, or re-planning of work.

The inspectors reviewed post-job ALARA evaluations of excessive exposure.

Radiation Worker Performance (1 sample)

The inspectors observed radiation worker and RP technician performance during radiological work to evaluate worker ALARA performance according to specified work controls and procedures. Workers were interviewed to assess their knowledge and awareness of planned and/or implemented radiological and ALARA work controls.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

(1 sample)

a. Inspection Scope

The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25, NUREG/CR-0041, TS, and procedures required by TS as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring systems associated with airborne radioactivity controls and respiratory protection equipment staged for emergency use. The inspectors also reviewed respiratory protection program procedures and current PIs for unintended internal exposure incidents.

Engineering Controls (1 sample)

The inspectors reviewed operability and use of both permanent and temporary ventilation systems, and the adequacy of airborne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm set-points.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

Complications (6 samples)

a. Inspection Scope

The inspectors reviewed Susquehanna submittals for the following Initiating Events Cornerstone PIs for the period of January 1, 2016, through December 31, 2016.

• Units 1 and 2, Unplanned Scrams;

• Units 1 and 2, Unplanned Power Changes;

• Units 1 and 2, Unplanned Scrams with Complications To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment PI Guideline, Revision 7. The inspectors reviewed Susquehannas operator narrative logs, maintenance planning schedules, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify Susquehanna entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings. The inspectors also confirmed, on a sampling basis, that for identified defects and non-conformances, Susquehanna performed an evaluation in accordance with 10 CFR Part 21.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Susquehanna made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Susquehannas follow-up actions related to the events to assure that Susquehanna implemented appropriate corrective actions commensurate with their safety significance.

• Unit Common, loss of zone 3 secondary containment function due to human performance error

b. Findings

Introduction.

A self-revealing finding of very low safety significance (Green) and associated NCV of TS 5.4.1, Procedures, was identified for failure to implement procedures that resulted in a secondary containment fan trip and associated loss of safety function.

Description.

On March 9, 2017, Susquehanna reported a loss of secondary containment safety function that was the result of human performance error in implementing procedures. The secondary containment completely surrounds each respective primary containment and encloses the refueling area common to both units, to reduce, under all conditions, the ground-level release of contaminated air. The secondary containment includes the exterior structure of the reactor building and the interior walls and floors that comprise three separate isolable ventilation zones. The common refueling area for both units is designated as Zone 3. The reactor building heating, ventilation, and air conditioning (HVAC) system maintains the secondary containment at a minimum negative pressure of 0.25 inches of vacuum, water gauge. Each of the ventilation zones is provided with independent HVAC systems designed to operate under normal and shutdown conditions. Zone 3 systems will function during normal fuel handling and storage operation.

During electrical work on multiple breakers associated with Unit 2 load center 2B240, the required differential pressure for Zone 3 secondary containment (common refuel floor)was lost when operators prematurely commenced restoration from the maintenance.

OT-205-005, Load Center 2B240 Outage Coordination Procedure, Revision 1, had steps that required confirmation of work completion and readiness for re-energization, including a review of the status of associated equipment, temporary installations and completed maintenance activities.

As operators proceeded to return equipment impacted by the maintenance to their normal power sources, they attempted to return Zone 3 HVAC damper control power to a source that was not energized. This caused the Unit 2 Division 2 Zone 3 isolation dampers to automatically fail closed, which is their safety position. Consequently, all Unit 2 Zone 3 fans tripped on low flow, rendering Zone 3 of secondary containment inoperable and unable to perform the required safety function as required by TS 3.6.4.1, Secondary Containment. TS 3.6.4.1 requires Zone 3 secondary containment be greater than or equal to 0.25 inches of vacuum water gauge (surveillance requirement 3.6.4.1.1) while either unit is in mode 1, 2, or 3; during movement of irradiated fuel; during core alterations; and during operations with the potential to drain the reactor vessels. Unit 1 was in Mode 1 at the time of the event.

Susquehanna subsequently restarted the Zone 3 secondary containment fans, restoring secondary containment operability. Zone 3 secondary containment was inoperable for a total of sixteen minutes. This event was reported to the NRC as required by 10 CFR 50.72(b)(3)(v)(C) in Event Notification#52599.

Susquehannas investigation determined the suspected causes of the event were failure to stop and evaluate the plan to begin load center restoration while a portion of the work was still incomplete, despite the fact that this was inconsistent both with the plan that the team had briefed before starting the work and the pre-staged work plan, and that the team did not adequately respond to challenges from workers in the field about proceeding with restoration of the load center while work was still in progress.

Analysis.

Inspectors reviewed the circumstances surrounding this failure to implement procedures as required and determined that this constituted a performance deficiency that was within Susquehannas ability to foresee and correct and should have been prevented. Operators failed to review and confirm the load center was ready for re-energization, as required by OT-205-005, Load Center 2B240 Outage Coordination Procedure. Specifically, on March 8, 2017, operators prematurely commenced re-energization of load center 2B240, although work on a downstream electrical component, the supply breaker to an instrument AC control panel, was incomplete.

Inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute (Routine OPS/Maintenance Performance) of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (Secondary Containment) protect the public from radionuclide releases caused by accidents or events. The failure to adequately implement procedures for operation and maintenance of the secondary containment resulted in the inoperability of Zone 3 secondary containment and an associated loss of safety function. In accordance with IMC 0609.04, Initial Characterization of Findings, dated October 7, 2016, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency only impacted the radiological barrier function of secondary containment.

This finding had a cross-cutting aspect in the area of Human Performance, Teamwork because individuals and work groups did not communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained.

Specifically, personnel did not conduct a re-brief of the maintenance and control room team after the plan deviated from what was originally briefed, and the control room operators did not adequately respond to challenges from workers in the field about whether it was appropriate to commence load center restoration with work still in progress. [H.4]

Enforcement.

TS 5.4.1, Procedures, requires that written procedures be implemented for activities recommended in RG 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Revision 2. RG 1.33 requires, in part, implementing procedures for general procedures for energization and operation of secondary containment. On March 9, 2017, Susquehanna reported a loss of secondary containment safety function as a result of human performance error in implementing procedures. OT-205-005, Load Center 2B240 Outage Coordination Procedure, is the implementing procedure to coordinate the safe de-energization of engineered safeguards system Channel D Load Center 2B240, and requires verification that work is complete and the load center is ready to be re-energized. Contrary to the above, Susquehanna did not implement procedures as required. Specifically, on March 8, 2017, operators commenced restoration of Load Center 2B240 with work still in progress. Susquehanna took immediate action to restore the secondary containment system to an operable configuration. Because this violation was of very low safety significance (Green), and Susquehanna has entered this performance deficiency into the CAP as CR-2017-04957, the NRC is treating this as an NCV in accordance with Section 2.3.2 of the NRCs Enforcement Policy. (NCV 05000387/2017001-01; Human Performance Error Results in Loss of Secondary Containment Safety Function)

4OA5 Other Activities

Temporary Instruction (TI) 2515/192, Inspection of Susquehannas Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems

a. Inspection Scope

The objective of this performance-based TI is to verify implementation of interim compensatory measures associated with an open phase condition (OPC) design vulnerability in electric power system for operating reactors. The inspectors conducted an inspection to determine if Susquehanna had implemented the following interim compensatory measures. These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for OPC design vulnerability. The inspectors verified the following:

• Susquehanna identified in December 2016 that they had no records indicating they had identified and discussed with plant staff the lessons-learned from the OPC events at the US operating plants including the Byron station OPC event and its consequences. No records could be found documenting that operator training was conducted for promptly diagnosing, recognizing consequences, and responding to an OPC event. Susquehanna documented this in CR-2016-27905 and has scheduled training which is anticipated to be completed by June 2017;

• Susquehanna had updated plant operating procedures to help operators promptly diagnose and respond to OPC events on off-site power sources credited for safe shutdown of the plant;

• Susquehanna had established periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission lines and transformer connections associated with the offsite power circuits to detect a visible OPC. Susquehannas response to NRC Bulletin 2012-01 (ML14031A086) indicated that they would perform weekly walkdown activities to inspect the switchyard. This weekly requirement was changed to a monthly requirement in September 2015 when ownership of Susquehanna was transferred from PPL to Talen. PPL maintains ownership of the switchyard and responsibility of monthly walkdowns while Susquehanna tracks the activity completion. Through discussions with the system engineer and regulatory affairs, no justification for the acceptability of monthly vice weekly walkdowns could be identified;

• Susquehanna had ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, Susquehanna assessed and managed plant risk in accordance with 10 CFR 50.65(a)(4) requirements.

b. Findings and Observations

No findings of significance were identified. The inspectors determined that while Susquehanna had not completed all interim compensatory measures, no violations of regulatory requirements were identified.

4OA6 Meetings, Including Exit

On April 7, 2017, the inspectors presented the inspection results to Mr. Timothy Rausch, President and Chief Nuclear Officer, and other members of the Susquehanna staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Rausch, President and Chief Nuclear Officer

B. Berryman. Site Vice President

B. Franssen, Plant Manager

K. Cimorelli, Operations General Manager

W. Reppa, Engineering General Manager

D. Jones, Maintenance General Manager

TJ Kupetz, Unit 1 and Unit 2 ISI Program Manager

D. Lamarca, Operations Manager

P. Scanlan, Maintenance Manager

M. Murphy, Station Engineering Manager

D. Ambrose, Design Engineering Manager

B. Bridge, Radiation Protection Manager

J. Jennings, Regulatory Affairs Manager

M. Krick, Regulatory Affairs Senior Engineer

C. Manges, Regulatory Affairs Senior Engineer

B. Sprung, Regulatory Affairs Engineer

M. Zidzik, Level 3 Radiographer

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000387/2017001-01 NCV Human Performance Error Results in Loss of Safety Secondary Containment Function (Section 4OA3)