ML17139B704

SALP Rept for Feb 1982 - Jan 1983

ML17139B704
Person / Time
Site:	Susquehanna
Issue date:	08/18/1983
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17139B703	List: ML17139B702 ML17139B704 ML17139B706
References
NUDOCS 8308240614
Download: ML17139B704 (68)

Text

U.S.

NUCLEAR REGULATORY COMMISSION REGION I

'YSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PENNSYLVANIA POWER AND LIGHT COMPANY SUSQUEHANNA STEAM ELECTRIC STATION UNIT I 83082406i4 8308i8 PDR ADOCN 05000387 8

PDR

TABLE OF CONTENTS I.

INTRODUCTION.

1. 1 Purpose and Overview 1.2 SALP Board and Attendees

1.3 Background

II.

SUMMARY

OF RESULTS III. CRITERIA.

IV.

PERFORMANCE ANALYSIS

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1 1

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4 5

4. 1 Plant Operations 4.2 Radiological Controls 4.3 Construction Activities/Maintenance 4.4 Preoperational Testing/Startup Testing/Surveillance 4.5 Fire Protection/Housekeeping 4.6 Emergency Preparedness 4.7 Security and Safeguards 4.8 Licensing Activities V.

SUPPORTING DATA AND SUMMARIES 6

9 11 13 16 17 18 19

5. 1 Licensee Event Reports 5.2 Investigation Activities 5.3 Escalated Enforcement Actions 5.4 Management Conferences 0

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2 1 22 22 22 TABLES TABLE 1 - TABULAR LISTING OF LERS BY FUNCTIONAL AREA TABLE 2 - INSPECTION HOURS

SUMMARY

TABLE 3 VIOLATIONS TABLE 4 - INSPECTION ACTIVITIES TABLE 5 UNPLANNED ACTUATION OF REACTOR PROTECTION AND ENGINEERING SAFEGUARDS FEATURES

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23 24 26 27 30 ATTACHMENT ATTACHMENT 1 ENFORCEMENT DATA

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I.

INTRODUCTION 1.1 Pur ose and Overview The Systematic Assessment of Licensee Performance (SALP) is an inte-grated NRC staff effort to collect the available observations on an annual basis and evaluate licensee performance based on those obser-vations with the objectives of improving the NRC Regulatory Program and 1 icen see per formance.

The assessment period is February 1,

1982 through January 31,

1983, with additional observations through March 1983.

The prior assess-ment period was March 1, 1981 through February 28, 1982;

however, the assessment thoroughly covered all pre-operational activities occurring up to the end of May, 1982.

This assessment covers all other significant findings during this assessment period in the applicable functional areas (Section IV).

Evaluation criteria used during this assessment are discussed in Section III below.

Each criterion was applied using the "Attributes for Assessment of Licensee Performance,"

contained in NRC Manual Chapter 0516.

1.2 SALP Review Board R.

M. Starostecki, Director, Division of Project and Resident Programs (DPRP)

S. Ebneter, Chief, Engineering Programs Branch, Division of Engineering and Technical Programs (DETP)

R.

R. Keimig, Chief, Reactor Projects Branch No. 2, DPRP E. McCabe, Chief, Reactor Projects Section 2B, DPRP L. H. Bettenhausen, Chief, Test Programs

Section, DETP R. Perch, Licensing Project Manager, Licensing Branch No. 2, NRR G.

Rhoads, Senior Resident Inspector, Susquehanna Unit 1

Additional Attendee J.

McCann, Senior Resident Inspector, Susquehanna Unit 2 1.3

~Back round (1)

Licensee Activities From February to July of 1982, the licensee completed construc-tion activities and preoperational testing of Unit 1.

The licensee received an operating license on July 17, 1982 with a requirement not to exceed five percent power without.Commission approval.

Fuel loading commenced on July 27 and was completed

on August 8.

Initial criticality occurred on September 10.

The licensee performed initial reactor core physics testing and com-pleted heatup to rated temperature and pressure on September 20.

After shutdown for a two day period, the low power test program resumed including more core physics tests and initial hot func-tional tests on systems such as Reactor Core Isolation Cooling and High Pressure Coolant Injection.

The licensee performed a maintenance outage from October 4 to November 1, with the major work being final inspections and clearance checks on the main turbine.

Low power testing fol-lowing subsequent star tup continued until November 12, at which time the NRC Commissioners voted to rescind the five percent hold requirement for the license.

During this time period, four non-test related scrams occurred as delineated in Table 5.

From November 11 until November 20, testing as required under Test Condition 1 (520%) including core physics and nuclear instru-mentation testing, Main Steam Isolation Valve Testing, shutdown from outside the control

room, and system vibration and expan-sion testing was completed.

Initial generator synchronization occurred on November 16, 1982.

From November 21 until December 24, the licensee completed testing required by Test Condition 2 (550%).

This included testing of Reactor Core Isolation Cooling, High Pressure Coolant Injection, core performance, generator load reject testing, and loss of offsite power testing.

Four non-test related scrams occur red during thi s period as described in Table 5.

From December 24 to January 16, testing was completed as re-quired by Test Condition 3 (570%).

This included testing of the following:

reactor water cleanup, core performance, emer-gency core cooling, feedwater

response, recirculation system and turbine trip.

The turbine trip test was performed on January 6,

1983 to facilitate shutting down to repair the reactor water cleanup inboard isolation valve.

This valve had developed a packing leak which, on January 6,

1983, created unidentified leakage in excess of 5 gallons per minute, the Technical Specification limit.

The licensee also had reoccur-ring problems during this period with the "A" recirculation pump motor generator tripping due to rectifiers breaking down in the speed regulation circuitry.

From January 16 to January 22, 1983, the licensee completed required testing, including feedwater control testing, for Test Condition 5 (575% power).

One non-test related reactor trip occurred during this phase and is listed in Table 5.

On January 22,

1983, the licensee commenced increasing power to perform necessary testing at Test Condition 6 ( 100% power).

The licensee first reached 100% thermal power on February 4,

1983.

As of March 1,

1983, the licensee had approximately three weeks of testing remaining prior to commercial operations.

(2)

Ins ection Activities Two resident inspectors were assigned throughout the entire period, performing nine inspections.

These inspections covered completion of Unit 1 construction activities, preoperational

testing, fuel loading, startup testing, plant operations and special inspections in pipe supports and plant design.

Three of the resident inspector reports included inputs from regional specialists.

Regional specialists conducted thirty-six inspections.

These inspec-tions covered the following construction inspections in small bore piping, hangers and NOE/PSI testing preoperational inspections in health physics, chemistry, plant procedures, guality Assurance Pro-

gram, environmental, preoperational testing, plant operations, and training; and, post licensing inspections in health physics, chemis-try, technical specification verification, plant operations, and startup testing.

A team evaluation of the licensee's annual emergency drill was per-formed in March 1982 and an Emergency Preparedness Implementation Appraisal in April 1982

'he total inspection hours involved in these inspections is 5,549 hours0.00635 days <br />0.153 hours <br />9.077381e-4 weeks <br />2.088945e-4 months <br /> (1,724 hours0.00838 days <br />0.201 hours <br />0.0012 weeks <br />2.75482e-4 months <br /> for residents and 3,825 hours0.00955 days <br />0.229 hours <br />0.00136 weeks <br />3.139125e-4 months <br /> for region-based inspectors).

This large number of inspection hours was due to the plant being in the final preoperational and initial startup test periods with the additional oversight required by the NRC inspec-tion program.

A tabulation of inspection activities is shown in Table 4, and a

tabulation of enforcement data is shown in Attachment l.

II.

SUMMARY

OF RESULTS SUS UEHANNA STEAM ELECTRIC STATION FUNCTIONAL AREA Cate or I

Cate or 2

Cate or 3

1.

Plant 0 erations 2.

Radiolo ical Controls 3.

Maintenance/Construction Activities 4.

Surveillance/Preoperational Testin /Startu Testin 5.

Fire, Protection and Housekee in 6.

Emer enc Pre aredness 7.

Securit

& Safe uards 8.

Licensin Activities Overall, this licensee has effectively completed construction and preoperational

testing, and made the transition to the operations mode during this SALP period.

Performance has been generally characterized by sound engineering, careful management, thorough corrective actions, prompt response to safety concerns, and a conservative engineering and operational philosophy.

A principal observation is that PP&L management is involved in assuring safe plant operations, and is sufficiently aware of activities at the plant.

III. CRITERIA The following criteria were applied to each area.

1.

Management involvement in assuring quality.

2.

Approach to resolution of technical issues from a safety standpoint.

3.

'Responsiveness to NRC initiatives.

4.

Enforcement history.

5.

Reporting and analysis of reportable events.

6.

Staffing (including management).

7.

Training effectiveness and qualification.

To provide consistent evaluation of licensee performance, attributes describing the characteristics applicable to Category 1, 2, and 3 perfor-mance were applied as discussed in NRC Manual Chapter

0516, Part II and Table 1.

~Cate or 1:

Reduced NRC attention may be appropriate.

Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.

~Cate or 2:

NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effec-tive such that satisfactory performance with respect to operational safety or construction is being achieved.

~Cate or 3:

Both NRC and licensee attention should be increased.

Licensee management attention or involvement is acceptable and considers nuclear

safety, but weaknesses are evident; licensee resources appeared strained or not effectively used such that minimally sati sfactory performance with respect to operational safety or construction is being achieved.

IV.

PERFORMANCE ANALYSIS

4. 1 Plant 0 erations 32%

Analysis of this area includes direct observation of plant operational as well as operational support activities.

The operations area was under continual review by resident inspector s as supplemented by four region-based inspectors including a team inspection covering the Oper-ations Quality Assurance Program and plant procedure reviews.

Other areas covered during this assessment period include the following:

compliance with license and procedural requirements, training, house-keeping and cleanliness, corrective action

systems, onsite and offsite committees, and reporting systems.

This is the first SALP of actual facility operation.

Some of the findings of the preoperational inspections occurring in the early part of this assessment period were discussed in the previous assess-ment.

These included two violations in the Quality Assurance

area, one dealing with the number of audits performed in the preoperational testing area, and one involving performance of work without any documentation.

There was also a concern about QA staffing, and commencement of the Operations QA Program.

Since the previous assessment

period, the licensee has hired additional personnel to bring the organization up to a strength of nine auditors.

They have committed three people to performing audits of the preoperational test areas, and the others to performing audits and surveillances in the operations areas.

To date, the audits reviewed have been com-prehensive and detailed.

The QA Supervisor left in March 1983 and is expected to be replaced in May.

The licensee and the resident inspection plan to specifically monitor the transition period.

The preoperational team inspection concluded that the Operations Quality Control Organization was well manned,

trained, and performing an effective function.

Improper inspection of small pipe hangers was identified during the assessment period.

That is considered an isolated case.

Both the QC and QA organizations report to the corporate Quality Assurance Organization and do not come under the control of the Plant Operations Organization in any way.

This organization structure appears to be functioning well.

Licensed operators generally displayed a detailed working knowledge of the plant, and an ability to explain transient responses, reflect-ing a good initial state of training.

One concern identified during the assessment period is the lack of attention to detail in following approved procedures.

Three examples involved verifying EDG and SBGT lineup, invalidation of APRM setpoints, and installing a temporary RCIC turbine trip switch without procedural control.

Subsequent to

the SALP period, escalated enforcement action was taken for placing both SBGT trains out of service.

These instances indicate that preoperational phase problems with operator control of activities continued into the operations phase.

Also, the licensee identified numerous examples

( LERs 82-01, 82-29, 82-44, and 82-62) where items were declared

operable, or modes were entered prior to accomplishment of all requirements.

This is due in part to the number and complex-ity of evolutions performed during the startup phase of testing.

Additionally, there is a high number of Temporary Change Notices (TCN's) accompanying many procedures.

Although this is a realistic process as procedures are used for the first time, the use of multiple TCN's with a procedure makes it difficult for operators to use the procedure.

Additional management control is warranted in this area.

Design changes and modifications performed show that the licensee is capable of handling both minor and major-design changes.

Modi-fications on the Emergency Service Water System due to water hammer-----'nd single failure problems were complex from both an analytical and hardware aspect.

The licensee performed the detailed analysis

required, performed the modifications required, and effectively pre-sented the modifications to the Commission.

Lack of sufficient detail in some safety evaluations has been a minor problem but in no instance did more detailed evaluation lead to a change in the outcome of the evaluation.

But the licensee should improve the content of safety evaluations, and has taken steps toward doing so.

The licensee has a very effective corrective action system.

The system is computerized and lists the open item, responsible

group, and expected closeout date.

Management is involved in the closeout of open items as demonstrated by frequent meetings with the Resident Inspectors.

The licensee was able to resolve a large number of issues prior to issuance of an operating license via the use of this system.

The licensee also devoted two employees full time for the last month prior to issuance of an operating license to gather necessary information and present it to the NRC.

Responses to violations and bulletins are detailed and accurate.

This aspect is a significant licensee strength.

In general, event reports provide clear and concise descriptions as well as the complete explanation of the effects on system function.

However, several reports-did not fully identify or describe the purpose of the failed component in the effected system.

Management has become involved in this area, and has developed

plans, including putting additional people in the compliance section to improve the content of event reports.

Although the number of event reports is high, this is due in part to the startup period which puts equipment and operators through major transients and the fact that licensee is generally very conservative about making event reports.

The licensee approach here is a strong one, but LER clarity (quality) should be improved.

LER's have been getting better,

however, and the licensee's actions are therefore producing results.

The Plant Operations Review Committee (PORC) has been effective.

The evaluation and reviews which PORC performed indicate a generally conservative and safety oriented outlook on reactor operations.

In summary, during this assessment

period, the licensee has received an operating license, and commenced a rigorous schedule of startup tests.

In general, the plant staff and operators have functioned well.

However, more management attent,ion is warranted in equipment

control, TCN control, and quality of Safety Evaluations.

Conclusion Category 2

Board Recommendation Continue routine inspection with increased emphasis on LER/SER content and evaluation plus procedure implementation.

4.2 Radiolo ical Controls 6%

Evaluation in this area included monthly review of selected program areas by the resident inspectors and six inspections by region-based inspectors of the radiation protection program, radioactive waste management, shipping, radioactive effluent monitoring, and radio-chemistry program.

Review of the licensee's Radiation Protection Program found that an effective program to support fuel load and normal operation was established.

The licensee has established and implemented adequate procedures with adequately staffed, trained, and qualified personnel in the Radiation Protection Department.

Management involvement and control in assuring establishment of an acceptable program was evident.

The licensee utilized corporate personnel in an onsite capacity to provide technical support to the plant staff.

In addi-tion, the licensee provided for contractor audits and assistance in establishing and implementing the program.

Licensee response to identified problems has been technically adequate and timely.

Radiation Protection performance has been good.

Review of the licensee's Radioactive Waste Management

Program, including radioactive waste transportation, found that the licensee has established and implemented an effective program for these areas.

Personnel involved in radioactive waste processing,

handling, and transportation were trained and qualified in their respective duties.

Radioactive Waste Management performance has been good.

In the area of effluent control and monitoring, the licensee's approach to calibration of process and effluent radiation monitors appears sound.

However, the inspections conducted identified a number of deficiencies.

It was found that Technical Specification requirements for determination of a lower limit of detection for certain airborne effluent samples had not been performed due to the requirements being deleted from a procedure.

In addition, chemistry analysis procedures for analyses performed by an offsite contractor were not approved in accordance with Technical Specification require-ments.

Also, a review of the implementation of IE Bulletin 80-10 requirements for sampling of noncontaminated systems which interface with contaminated systems (to detect cross-contamination,)

indicated that instrumentation for analyzing samples could not detect the action levels presented in the procedure.

The licensee identified that grab samples of effluent streams had not been taken as required by Technical Specifications, due in part to the lack of adequate communication between the chemistry and operations groups.

Corrective actions to coordinate collection of the grab samples include developing a

new log to control required samples and a turnover meeting between operations and chemistry to discuss required samples'he licensee has added an additional supervisor in the Chemistry Organization to strengthen control.

The changes have not yet been evaluated but indicate licensee responsiveness.

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Conclusion Category 2

Board Recommendation Based on the deficiencies identified in the area of effluent controls and monitoring, including chemistry, the inspection frequency in these areas should be increased.

The inspection frequency for other program areas should remain as presently specified by MC 2515.

4.3 Maintenance/Construction Activities 7%

Maintenance/Construction Activities were observed during regular resident inspections and ten region-based inspections including four special inspections to determine the validity of allegations in the construction area concerning welder qualification plus small bore piping and hanger installation.

These inspections found inadequacies in the control of small bore pipe support desi'gn and the inspection of installed pipe supports.

Upon identification of these inadequacies, licensee management became actively involved to determine the cause and extent of the problems and required corrective actions'he corrective actions taken by the licensee were prompt and comprehensive, and demonstrated a fundamen-tally sound, safety conscientious organization.

NRC concern about ability to show reci rc risen weld acceptability was followed by licensee offset radiography (RT) of the sweepolet

'to riser weld.

Two respectable defects were then found and repaired, and earlier RT was found to have shown but accepted these indica-tions.

NRC concerns were also identified about non-destructive examination (NDE) examiner qualifications and the NDE examiner qualification program.

Further licensee management attention to NDE is needed.

The problems discussed

above, although concerns, are not indicative of the licensee's overall performance and ability.

The manner in which the licensee's management organization handles such diverse and complicated problems as the Emergency Service Water System single failure problem, the expansion of the system verification program initiated by Teledyne as the result of discrepancies noted in review of hanger design calculations for anchor points, and the reporting and reanalyzing of the vertical and horizontal loading on safety re-lated structures, indicates a strong, coordinated organization.

In all the above

cases, the problem or potential problems were rapidly reported to the NRC, and comprehensively analyzed for safety signifi-cance.

Prompt reporting and review in this case prevented this matter from developing into an operating license issue.

Also, in the review of the Teledyne findings, the licensee requested a delay in the commission briefing for granting a

100% Operating License until they could determine the extent of the problem and its safety sig-nificance.

The plant maintenance organization is adequately staffed and trained to perform the necessary maintenance for the facility.

The plant staff is supplemented during periods of heavy maintenance with members of the Electrical and Structural (E&S) Construction

Group, a

PP@L Outage Maintenance Group.

Observed maintenance work was indicative of generally well trained personnel with accurate, com-plete work instructions.

Work performed during the short maintenance outages during the startup program has been well scheduled and controlled.

During outage periods, the Assistant Superintendent of Plant - Outages is responsible to the Superintendent of Plant for the outage work.

Under this arrangement,.

the Assistant Superintendent of Plant - Operations will always be responsible for the operations of the two units (once Unit 2 is operating) while the Assistant Superintendent of Plant Outages maintains control over the main-tenance work in an outage.

This concept appears to be functioning well.

The management appears to be heavily involved in maintenance activities and has been fully aware of the status of major main-tenance activities.

Conclusion Category 2

Board Recommendation Perform additional inspection in areas of RT examiner qualification, radiograph

reviews, and hanger installation for Unit 2.

Maintain routine program for Unit 1 in the maintenance functional area.

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4.4 Prep erational Testin /Startu Testin /Sur veil lance 35%

4.4. 1 Preo erational Testin Preoperational testing was observed during regular resident inspections and two region-based inspections (four other region-based reviews were incorporated into resident inspection reports).

Most of the preoperational testing program was discussed during the last assessment period.

In June, a report was issued by a licensee consultant (Gilbert Associates) on their review of the Susquehanna test program.

The report concluded that the test program for Unit 1 was adequate.

The consultant review was per-formed in part to resolve previous NRC concerns into the adequacy of the preoperational test program.

The NRC review of this report concluded that the review was in-depth and sufficient to adequately resolve the concerns.

The licensee developed a tracking system for preoperational test exceptions which had not been resolved prior to fuel load.

Review of this system indicates that resolution of issues was conducted in a timely manner.

4.4.

~T Startup testing was observed during regular resident inspections and five region-based inspections (three other region-based reviews were incorporated into resident inspection reports).

The startup test procedures reviewed by NRC inspectors have identified no major discrepancies.

The licensee has been receptive to NRC comments and has quickly explained apparent discrepancies or corrected the procedures.

To

date, there have been eleven reactor trips from power, none of which can be attributed to'inadequacies in the Startup Test Procedures.

The inspectors observed numerous startup tests during this assessment period.

The plant operators and the startup organization was always fully aware of plant conditions, expected plant responses, and expected operator actions.

When plant responses were not as expected, the operators have responded quickly and knowledgeably.

Problems identi-fied during the testing have been well documented.

Plant operation is further discussed in Section l.

The licensee has established a multi-tiered review cycle culminating with approval of tests by the Superintendent of Plant.

These reviews have been generally in-depth and timely.

Concerns raised by inspectors have been resolved

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quickly and accurately.

Management has been directly involved in reviews of test results and has required additional testing when results were not as expected.

4.4.3 Surveillance Testin Surveillance testing was observed during regular resident inspections and six region-based inspections (including three incorporated into resident inspection reports).

A team inspection with followup inspections was performed prior to issuance of the Operating License to determine the adequacy of the surveillance test procedures.

Concerns were raised over the adequacy of Instrument and Control Procedures and their setpoints.

Some discrepancies were found between the procedures and the proof and review copy of Technical Specifications.

The licensee committed to performing a review of setpoints when the official Techni-cal Specifications were issued.

The NRC has not identified any discrepancies in the surveillance procedures in set-points since issuance of the Operating License.

Some weaknesses have been identified both by the licensee and NRC in adequacy of some surveillance procedures.

One violation identified was that suppression pool temperatures required to be recorded by Technical Specifications were not being recorded due to procedural inadequacies.

Although the problems identified are in a small number of the total number of surveillance procedures, more manage-ment attention to surveillance procedure adequacy is indicated.

The surveillance tests witnessed have been accurately performed using knowledgeable, trained per-sonnel.

Five of the eleven reactor trips from power have been caused directly or indirectly from performance of Instrument and Control Survei llances,

however, review of the individual incidents and the training of the personnel involved does not indicate serious problems in this area.

In general, strong management control is evident.

In the surveillance

program, the concept of using periodic testing to demonstrate operability is well understood by management and operators.

No instances were identified in which a failed surveillance test, or a missed test, resulted in anything but a declaration of inoperability and appli-cation of the appropriate action statement.

The licensee's resolution and reporting of technical issues in this area is always conservative.

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4. 4. 4

~Summa r In general, Preoperational Testing, Startup Testing and Surveillance Testing have all been well managed, well operated programs.

There is evidence of strong management controls and a sound safety perspective in all the pro-grams.

Weaknesses were observed in the adequacy of a few surveillance procedures and should be addressed by the licensee.

Conclusion Category 1

Board Recommendation Continued 2514/2594 Program to completion of the Startup

Program, then initiate the prescribed 2515 inspection program.

4.5 Fire Protection/Housekee in 1%

This assessment is based on one (1) region-based inspection and routine observations by the resident inspectors.

Although a rela-tively small amount of inspection was charged to this area, it was also examined during plant tours and inspection activities charged to other areas.

Prior planning and assignment of priorities'y licensee management is evident in program procedures with specific assignments made to implement the requirements of these documents.

Decision making was consistently at a level that ensures adequate management review, e.g.,

review of fire protection engineer activities by the Superintendent of Plant.

The full time fire protection engineer at the site, with support from the corporation fire and safety personnel, provides proper attention to the fire protection area thus removing operating personnel from program concerns.

This organization structure should permit the operating personnel to focus on the continuity of site fire detection/suppression capability during the operation of the plant.

The licensee filled key staff positions in a reasonable time.

The licensee training and qualification program has been adequate to provide the requisite number of qualified fire brigade members on shift.

Planned development and implementation of the new training program is expected to improve understanding of personnel duties and adherence to procedures.

NRC review of the training program indi-cated that more direct involvement in the fire training program by the fire protection engineer may be warranted.

One violation dealing with required fire detection equipment was iden-tified. It involved discrepancies between as-built location of fire detectors and the Technical Specification tabular location of detec-tors.

A Technical Specification change has been submitted correcting some discrepancies, but the licensee should either request that the total number of detectors be deleted from Technical Specification, or update Technical Specifications so that Technical Specifications are in agreement with as-built configuration.

This is an administrative discrepancy, not a safety issue.

An electrical fire occurred in the Emergency Service Pumphouse on September 22, 1982.

The licensee' response to the fire was appro-priate and conservative.

Further, the licensee used this event to exercise his emergency response organization.

Conclusion Category l.

Board Recommendation None

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4.6 Emer enc Pre aredness 15%

~Anal si s Analysis in this area is based on observation by an NRC Team of the prelicensing emergency preparedness exercise which was designed to demonstrate all facets of the emergency

plan, an Emergency'repared-ness Implementation Appraisal (EPIA), followup on findings of the EPIA prior to issuance of an operating license, and periodic obser-vation by the resident inspectors of plant training exercises.

Ouring the annual exercise on March 17,

1982, the licensee demon-strated an adequate capability to deal with a plant emergency.

A number of deficiencies, most of which were also identified by the

licensee, were noted in the areas of communications, and procedural inadequacies.

These deficiencies had been resolved by the time of the EPIA in April 1982.

The EPIA identified nine items which the licensee corrected before loading fuel.

The corrective action demonstrated a clear understanding of the issues and provided 'timely resolution.

Followup inspection verified correction of all significant items.

The licensee management has been involved in emergency preparedness activities and developed a large staff to carry out corporate poli-cies and NRC initiatives.

In addition, the site emergency prepared-ness coordinator interfaces with the lead Shift Technical Advisor (STA) to coordinate activities between the corporate staff, plant staff and operations.

One alert was declared on September 22 due to an electrical fire in the Emergency Service Water Pumphouse.

The licensee response was ade-quate and conservative.

Offsite organizations were properly notified and updated on plant conditions.

After the event was downgraded, plant management critiqued the emergency response of the utility and corrected noted deficiencies.

The licensee has maintained a viable active duty roster of qualified emergency response personnel.

The licensee has also maintained ade-quate shift coverage to ensure that all emergency plan requirements were met.

Evidence and,findings indicate a good performance by the licensee in this functional area.

After the SALP period, in March 1983, a full emergency exercise was observed.

All deficiencies from the previous drill were found to be corrected.

Conclusion Category 1

Board Recommendation None

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4. 7 Securi t and Safe uards 4%

~Anal si s During the assessment period, there were five physical security inspections, one material control and accounting inspection, and continuing coverage by the resident inspectors.

The licensee has been effective in maintaining a high degree of over-all security performance.

Upon initial security system operation, the licensee experienced a large number of security alarms which they reported as degrading the response capability.

Management quickly analyzed the problems, established a task force to correct noted de-ficiencies and make modification to the system to reduce the alarms, and increased the guard force to respond to the alarms.

The licensee held periodic meetings with the NRC to describe the changes being made and the status of the security system.

By January 1983 the alarms had been reduced to well within the capability of the system.

The licensee has emphasized the security training program, as evi-denced by the excellent facilities, including a firearms training range.

A full time security training supervisor and a clerk admini-ster a well defined and professional training program.

Meaningful and well conceived lesson plans and tests were developed.

The Training and qualification Plan implementation is on schedule.

The security department is well staffed and security personnel appeared well trained, knowledgeable of their duties, and professional.

Four security event reports were received during this assessment.

Three of these reports concerned malfunctions of the security system

computer, including the excessive alarm condition discussed above.

The impact oF these events was minimized because of timely and effective compensatory measures.

Measures to reduce demands on the security system have been effective in preventing recurrence.

The licensee was responsive to su'ggestions for effectively imple-menting the physical protection program and corrected any weaknesses noted.

One minor concern was noted (vehicle key control).

Correc-tive action and followup by site management have proven adequate.

Conclusion Category 1

Board Recommendation None 4.8 Licensin Activities A~nal sis During this assessment

period, the staff was involved, along with the applicant, in resolving the remaining open items related to the issuance of a full power license for operation of Susquehanna Unit 1, and in subsequent reviews of proposed amendments to the Unit 1 operat-ing license.

During this period, two supplements to the Susquehanna Safety Evaluation Report were issued in support of a full power license with a 5% power restriction issued on July 17,

1982, and in support of a license amendment for full power operation issued on November 12, 1982.

Pennsylvania Power 5 Light Company (PP5L) has consistently demonstra-ted a high degree of management control and involvement in achieving resolution of licensing activity issues.

Corporate management was frequently involved in these activities which enhanced the planning and assignment of priorities to achieve timely and thorough reviews.

Management involvement was particularly evident in the following areas; independent design review, dynamic model corrections, the natural gas pipeline near the site, and condition of site preparation and readiness for licensing.

During the NRC Senior management site visit prior to licensing, general cleanliness and the state of completion of the facility were considered excellent.

The approaches of the licensee to resolution of technical issues from a safety standpoint are technically sound.

Thorough approaches were evident in almost all cases.

In the area of safeguard

issues, the licensee exhibits a good capability to modify approaches to changing demands without impacting the effectiveness of the program.

The licensee also demonstrated a clear understanding of the issues involved in the technical specifications for which changes from Standard Technical Specifications were sought.

In response to NRC initiatives, the licensee generally provided timely responses, with acceptable resolutions proposed in the first response in most cases.

Personnel in key positions involved in licensing activities are knowledgeable and professional.

In meet-ings with the NRC staff, the licensee has provided the appropriate technical and management level personnel to make the meetings pro-ductive and provide decision making at a level ensuring adequate management review.

During this assessment period, written and oral operator license examinations were given to 49 candidates.

Of these, 39 passed the examinations.

Reactor Operator (RO) licenses were issued to 12 persons and Senior Reactor Operator (SRO) licenses were issued to 27.

These results show that the training and qualification program makes positive contributions to the understanding of the operators.

The training program is well-defined and implemented with dedicated resources.

V.

SUPPORTING DATA AND SUMMARIES

5. 1 Licensee Event Re orts LERs Tabular Listin Type of Events:

A.

Personnel Error 21 B.

Design/Man./Constr. /Install 13 C.

External Cause 0

D.

Defective Procedure

~

6 E.

Component Failure 15 X.

Other 29 Total 84 Six chains were identified:

(a)

LERs 82-36 and 82-77 describe setpoint drift on High Pressure Coolant Injection steam line sensors.

The licensee revised setpoints and instrument tolerances to assure that the instru-ments stay within allowable values.

(b)

LER's 82-65 and 82-76 describe recirculation pump motor gener-ator "A" trips.

The licensee determined that rectifiers were breaking down in the speed regulation circuitry and replaced the entire regulator.

(c)

LER's 82-38, 82-41, 82-42 and 82-67 describe missing required chemistry samples with various automatic sampling equipment in-operable.

The licensee has changed the Incident Report Procedure to require a sample log be initiated by Operations and maintained by Chemistry when sampling equipment becomes inoperable.

(d)

LER's 82-32 and 82-62 describe inoperability of the Standby Gas Treatment System during loss of offsite power testing.

The licensee modified the circuitry such that a high radiation signal in the exhaust of the standby gas treatment system would not trip the running standby gas treatment fan.

This signal was giving a false trip signal on loss of electrical power to the instrument.

(e)

LER' 82-15, 82-68, and 82-71 describe missing required survei 1-lances due to inadequately written procedures.

'I I~

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(f)

LER's 82-06, 82-14, 82-44, and 82-69 describe events in which systems were declared operable prior to proper closeout of maintenance

records, or entering modes of operations without all surveillances being completed, all indicating lack of proper management attention to procedural adherence details.

5.2 Investi ation Activities One investigation was performed by NRC investigators into allegations concerning numerous problems with small bore pipes and hangers.

Region I and resident inspectors also performed special inspections involving the technical issues presented in the allegations.

Portions of the allega-tions were substantiated.

PP&L presented corrective actions in a series of letters and meetings with Region I personnel and a followup inspection by a Region I inspector confirmed corrective action had been taken.

5.3 Escalated Enforcement Actions none (a)

Civil Penalties none (b)

Orders none (c)

Confirmator Action Letters Confirmatory action letter dated May 24, 1982 regarding planned corrective actions on significant findings identified in the Emergency Preparedness Team (NRC) inspection on April 12 through Apri 1 22, 1982.

5.4 Mana ement Conferences:

(a)

On April 21,

1982, PP&L management met with NRC Region I man-agement to discuss open issues requiring disposition prior to construction completion.

(b)

On June 17,

1982, PP&L management met with NRC Region I manage-ment to discuss the Systematic Assessment of Licensee Performance for the period of March 1981 to February 1982.

(c)

On July 30,

1982, PP&L management met with NRC Region I manage-ment to discugs discrepancies found during an NRC special inspection and documented in NRC inspection report 50-387/82-31.

(d)

In addition to the above meetings, the following meetings occurred between PP&L management and NRC management personnel as indicated:

1.

On May 18 and July 12, members of the NRC:NRR Management conducted site visits.

2.

On September 13, Commissioner Gi linsky and members of his staff conducted a site visit.

TABLE 1 TABULAR LISTING OF LERs BY FUNCTIONAL AREA SUS UEHANNA STEAM ELECTRIC STATION UNIT 1 AREA Number/Cause Codes Total 1.

Plant Operations 2.

Radiological Controls 10/A 7/B 0/C 4/D 6/E 15/X 42 6/A 1/B 0/C 0/D 2/E 0/X 9

3.

Maintenance/Construction Activities 2/A 3/B 0/C 1/D 3/E 5/X 14 4.

Surveillance/Preop/Startup Testing 1/A 1/B 0/C 1/D 3/E 8/X 14 5.

Fire Protection

'6.

Emergency Preparedness 7.

Security

& Safeguards 8.

Licensing Activities 2/A 1/B 0/C 0/D 0/E 0/X 3

0/A 0/B 0/C 0/D 0/E 0/X 0

0/A 0/B 0/C 0/D 1/E 1/X 2

0/A 0/B 0/C 0/D 0/E 0/X 0

Totals 21 13 0

6 15 29 84 Cause Codes:

A.

Personnel Error B.

Design/Manufacturing/Construction/Installation C.

External Cause D.

Defective Procedure E.

Component Failure X.

Other

TABLE 2 VIOLATIONS 2/1/82 - 1/31/83 SUS UEHANNA STEAM ELECTRIC STATION - UNIT 1 A.

Number and Severit of Violations*

Severity Level I Severity Level II Severity Level III Severity Level IV Severity Level V

Total 18 23

" One Severity IV and four Severity V Violations classified under the interim NRC Enforcement Policy were reclassified as Severity IV Violations.

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B.

Violations vs.

Functional Areas" FUNCTIONAL AREAS 1.

Plant 0 erations 2.

Radiolo ical Controls I

II III IV V

4 2

3.

Maintenance/Construction Activities 4.

Surveillance/Preo

/Startu Testin 5.

Fire Protection/Housekee in 6.

Emer enc Pre aredness 6

2 1

1 7.

Securit and Safe uards 8.

Licensin Activities Total s 0

0 0

18 5

• One Severity IV and four Severity V Violations classified under the interim NRC Enforcement Policy were reclassified as Severity IV Violations.

TABLE 3 INSPECTION HOURS

SUMMARY

2/1/82 1/31/83 SUS UEHANNA STEAM ELECTRIC STATION - UNIT 1

1.

Plant Operations 2.

Radiological Controls 3.

Maintenance/Construction Activities 4.

Surveillance/Preop/Startup Testing 5.

Fire Protection/Housekeeping 6.

Emergency Preparedness 7.

Security and Safeguards HOURS 1,780 306 407 1,986 38 831 201 OF TIME 32%

6%

7%

35%

1%

15%

40/

8.

Licensing Activities Total Not Available 5,549 100%

1

TABLE 4 INSPECTION ACTIVITIES SUS UEHANNA STEAM ELECTRIC STATION - UNIT 1 REPORT NOS.

82-02 82-03 82-04 82-05 82-06 82-07 82-08 82-09 82-10 82-11 82-12 82-13 82-14 82-15 82-16 INSPECTOR Specialist project Resident/

project Specialist Specialist project Resident Specialist Specialist Resident Specialist Special i st Specialist Specialist Specialist AREAS INSPECTED Radiation protection and radioactive waste management programs.

Routine inspection.

Routine inspection.

Physical protection inspection; physical security plan and implementing procedures.

Emergency preparedness inspection and observation.

Routine inspection.

Routine inspection.

Preoperations quality assurance program implementation; readiness of quality assurance program.

Preoperational test program implementation.

Routine inspection.

Emergency preparedness implementation team.

Preoperational inspection of licensee's chemical and radiochemical measurements program.

Startup test procedure review and tours of the facility.

Routine inspection.

Review of Local Leak Rate Test (LLRT);

Integrated Leak Rate Test (ILRT) proce-dures; LLRT and ILRT witnessing; LLRT and ILRT results evaluation and tours of facility.

TABLE 4 (Continued)

REPORT NOS.

82-17 82-18 INSPECTOR Resident Specialist AREAS INSPECTED Routine inspection.

Routine inspection and observation of NDE in progress; Review of NDE data.

82-19 82-20 82-21 Resident Specialist Specialist Routine inspection.

Routine safety inspection.

Facility organization and operation; shipping and receiving, storage and internal control, physical inventory, records and reports, and management of material control systems.

82-22 82-23 Speci al i st Specialist Preoperational physical protection inspection.

Preoperational physical protection inspection.

82-24 Speci al ist Safety inspection; followup of significant findings from appraisal of the applicant's emergency preparedness program.

82-25 Specialist Preoperational inspection of inplant chemical and radiochemical measurements program for Unit 1 and environmental monitoring program for Units 1 and 2.

82-26 82-27 Specialist Specialist Routine inspection of overall startup program review, procedure review, hot functional test procedure review and foll'owup on previous inspection.

Preoperational inspection of the licensee's radiation protection and radioactive waste management programs.

82-28 82-29 82-30 Specialist Specialist Specialist Previous identified items.

Allegation concerning Bechtel welder.

Preoperational physical pr otection inspection.

82-31 Specialist/

Resident Special inspection of pipe support, structural steel and design activities.

TABLE 4 (Continued)

REPORT NOS.

INSPECTOR AREAS INSPECTED 82-32 82-33 Resident/

Special ist Resident/

Specialist Preoperational test results review; startup test results review, startup test witnessing; licensee event followup; weld-ing activities; Technical Specification compliance; open items and plant status.

Initial fuel load, readiness for initial cri-ticality, ASME Class 1 and 2 piping, storage and insta 1 1 at i on of sa fety components.

82-34 82-36 Specialist/

Resident Specialist Special inspection of engineering and QA/QC programs for pipe supports and piping.

Routine inspection of nondestructive examina-tion results associated with recirculation system modification.

82-37 Specialist Administrative controls of startup testing; initial core verification; pre-critical tests; and review of local leak rate test records.

82-38 82-39 Specialist Specialist Preoperational physical protection.

Control of procedures and calibration of safety-related instrumentation; survei 1-lance testing; radiological controls; and licensee's response to an alert.

82-40 82-41 82-42 Resident/

Specialist Specialist Specialist Routine inspection.

Pipe hangers and restraints.

Previous inspection findings; administrative controls of startup testing; plateau review of heatup phase testing; power escalation testing test condition 2; calibration tests; 50.59 safety evaluation; training and plant tour.

82-43 Specialist Radiation protection program implementa-tion; radioactive waste management programs.

82-45 83-01 83-02 Resident Specialist Specialist Routine inspection.

Plant fire protection/prevention program.

Routine inspection.

30-

TABLE 5 UNPLANNED ACTUATIONS OF REACTOR PROTECTIVE SYSTEMS AND ENGINEERING SAFEGUARDS FEATURES SUS UEHANNA STEAM ELECTRIC STATION UNIT 1 Date 9/10/82 9/16/82 9/20/82 RPS RPS RPS Nature Operator downranged an IRM channel incorrectly causing high flow scram.

Operator manually tripped reactor after CRD pump tripped on low suction pressure.

Reactor tripped on vessel low level caused by loss of feedwater.

11/1/82 11/10/82 RPS RPS Reactor tripped on vessel low level caused by main steam bypass valves opening at low power levels.

Reactor tripped on vessel low level when an Instrument and Control Technician incorrectly placed level instru-ment back in service.

11/23/82 ll/24/82 11/28/82 RPS RPS RPS Reactor tripped on vessel low level when an Instrument and Control Technician was performing surveillance on vessel pressure instrumentation.

Reactor tripped on vessel low level after placing feed-water pump in automatic control causing level fluctua-tions and feedwater pump trip ~

Reactor tripped due to fast closure of control valves caused by pressure 'fluctuations in electrical hydraulic system.

12/8/82 RPS Reactor tripped on turbine trip caused by vessel high level.

Vessel high level was caused by improperly tak-ing Inservice Reactor feedwater level controller out of service.

1/19/82 1/25/82 RPS RPS Reactor tripped when MSIV's shut apparently caused by IKC technicians performing surveillance on main steam low pressure instrumentation.

Reactor tripped on erroneous indication of two main stop valves not fully opened during startup testing of the main stop valves.

"31-

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ATTACHMENT 1 ENFORCEMENT DATA SUS UEHANNA STEAM ELECTRIC STATION UNIT 1 Februar 1

1982 - Januar 31 1983 Insp.

Insp.

No.

Date Subject 82-04 1/27-3/1/82 Preoperational tests for the Atmosphere Control System, Pri-mary Containment Instrument Gas

System, and Reactor Bldg. Chill Water System did not include closure time testing for contain-ment isolation valves.

10CFR50 IV 4

Procedures for activities per-formed on the access pits to the Emergency Service Water and Resi-dual Heat Removal System Flow Instrumentation were not appro-priate to the circumstances, in that conditions were not esta-blished to prevent flooding of safety-related instrumentation in the access pits.

Acceptance Criteria 2(ll) of P55. 1, Revision 2, stated maximum and minimum values for total CRD cooling water flow, but the test did not verify the acceptance cri-teria because the specified toler-ances extended beyond the stated maximum acceptable value.

10CFR50 IV 10CFR50 IV Temporary switch,was found con-nected to terminal box TB0144 with no orange temporary modification identification tag and no entry in the Temporary Modification Log.

10CFR50 IV No work items had been entered on the Startup Work List and no new SFR had been processed for SFR 1531 whose response had been dis-tributed on November 10, 1980.

10CFR50 IV I

\\

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e ATTACHMENT 1 (Continued Insp.

Insp.

No.

Oate 82-08 3/8-4/7/82

~Sub ect False indication of the trip set-point and invalidating the APRM calibration.

Sev.

Area 10CFR50 IV 4

82-09 3/22-27/82 3/29-31/82 4/1-2/82 Standpoint Gas Treatment System Operating Procedure, OP-70-001, Rev.

0, was approved by the Super-intendent of Plant without PORC review and submission for approval.

8 gA audits of the preoperational test program had been conducted of only some aspects of the preopera-tional test program.

Installation of core spray pump suction line strainers, an acti-vity affecting quality of preopera-tional testing, was accomplished without an SWA and the core spray pump preoperational test had been conducted.

10CFR50 IV 10CFR50 IV 10CFR50 IV 82-10 3/23-26/82 Approved preoperational test pro-cedure for the upcoming Cold Functional Test did not include all required loads for this series of tests.

10CFR50 IV Surveillance testing had not been performed on five battery systems due to be tested by January, 1983.

Oil, dirt and debris was observed underneath the diesel engines and generators with oil leaking from "C" diesel

engine, while welding was being conducted in the "B" Oiesel Generator rooms with no fire watch present nor a fire extinguisher in the vicinity of the welder.

10CFR50 V

10CFR50 V

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I ATTACHMENT 1 (Continued)

Insp.

Insp.

No.

Date 82-31 7/21-23/82 7/28/82 82-32 9/8-10/19/82 82-33 7/28-9/7/82 Subject Design and installation of safety-related anchors down on "Detail 600; SPA 600; and SPA 1312" were inadequate for the intended use in that clamps as installed, did not provide positive interferences to the pipe to resist axial and torsonial slippage.

Design change for safety-related pipe supports issued in December

1981, "SPA 600" superced-ing "Detail 600" was not distributed to the field, thus installation and inspection of this type of support continued to be done in accordance with the superceded drawing.

Licensee's followup inspection to determine the acceptability of safety-related pipe supports did not identify all the unacceptable supports.

No ionization fire detectors were located in fire zone 1-7B and the licensee could not provide survei 1-lance data to demonstrate that heat detectors in fire zone 0-27E were operable.

Keys left in unattended Security vehi cl e.

Check-off lists for the Diesel Generators and Standby Gas Treat-ment System did not include a

second verification of system component positions.

Sev.

Area 10CFR50 IV 3

10CFR50 IV 10CFR50 IV 10CFR2 IV 10CFR2 IV 10CFR50 V

ATTACHMENT 1 Coptinued Insp.

Insp.

No.

Date Subject 82-34 8/2-4/82 82-36 8/23-26/82 9/2-3/82 Pipe flanges were trimmed (safety-related pipe supports) reducing the designed minimum load stud center to edge distance below that specified without a Field Change Request being issued.

Pipe support drawings were ob-served to provide no dimensional clearance requirements between pipe clamp flanges and the snubber body.

Safety-related shock sup-pressors were installed such that they had less than 5 degrees of angular rotation.

Unacceptable linear indications in welds; linear indications in radiographs that were not recorded or dispositioned; penetrameters/

markers within the weld.

10CFR50 IV 10CFR50 IV 10CFR50 IV 82-39 9/20-24/82 Listing for computer software which performs a safety-related or quality related function had not been established and software for the Control Room.

Computer data which were used to verify Tech.

Specs.

survei llances were not controlled.

10CFR50 V

82-40 10/20-12/1/82 No record made of average suppres-sion chamber wate'r temperature during Reactor Core Isolation Cool-ing System testing which added heat to the suppression chamber.

TS U. S.

NUCLEAR REGULATORY COMMISSION REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PENNSYLVANIA POWER AND LIGHT COMPANY SUS(UEHANNA STEAM ELECTRIC STATION UNIT 2

I.

INTRODUCTION II.

SUMMARY

OF RESULTS III. CRITERIA.

IV.

PERFORMANCE ANALYSIS TABLE OF CONTENTS

~Pa e

3 5

l.

2.

3.

4.

5.

6.

7.

8.

9.

Soils and Foundation.

Containment and Other Safety Related Structu Piping Systems and Supports Safety Related Components Support Systems Electrical Power Supply and Distribution.

Instrumentation and Control Systems Licensing Activities.

Preoperational Testing.

res 5

6 8

10 12 13 15 16 17 V.

SUPPORTING DATA AND SUMMARIES.

19 l.

2.

3.

4.

TABLES Construction Deficiency Reports (CDRs).

Investigation Activities.

Escalated Enforcement Actions Management Conferences.

19 19 19 19 TABLE 1 CONSTRUCTION DEFICIENCY REPORTS TABLE 2 ENFORCEMENT DATA.

TABLE 3 INSPECTION HOURS

SUMMARY

TABLE 4 INSPECTION ACTIVITIES.

20 22 23 24

I.

INTRODUCTION a.

Pur ose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations on an annual basis and evaluate licensee performance based on those observations with the objectives of improving the NRC Regulatory Program and licensee performance.

The assessment period is February 1,

1982, through January 31, 1983.

The prior assessment period was March 1, 1981, through February 28, 1982.

The one month overlap between assessment periods does not impair the current evaluation as the previous assessment was heavily weighted toward Unit 1 activities.

This is the first independent Performance Analysis for Unit 2.

Evaluation criteria used during this assessment are discussed in Section III below.

Each criterion was applied using the "Attributes for Assessment of Licensee Performance,"

contained in NRC Manual Chapter 0516.

b.

SALP Attendees Review Board Members R. Starostecki, Director, Division of Project and Resident Programs (DPRP)

S. Ebneter, Chief, Engineering Program Branch, Division of Engineer-ing and Technical Programs (DETP)

R. Keimig, Chief, Reactor Projects Branch No. 2, DPRP R. Perch, Project Manager, Licensing Branch No. 2, NRR E.

McCabe, Chief, Reactor Projects Section 2B, Projects Branch No. 2, DPRP J.

McCann, Senior Resident Inspector, Susquehanna Unit 2 Additional Attendee c ~

G.

Rhoads, Senior Resident Inspector, Susquehanna Unit 1

~Back round Susquehanna Unit 2 (DN 50-388) is a 1050 MWE General Electric Mark 4 Boiling Water Reactor, housed in a Mark 2 concrete containment.

It is arranged side-by-side with a sister unit and shares certain systems and structures.

The Architect Engineer for the project is Bechtel Corp.

Unit 1 was licensed for operation on July 17, 1982.

d.

Licensee Activities Activity in Unit 2 increased significantly since the completion of Unit 1.

Construction completion increased from 66% to 76% during the assessment period.

Approximately 45% of the plant systems have been turned over to the Integrated Startup Group ( ISG) for testing.

The Unit 2 manual work force was increased from about 1,300 to 3,800 as personnel were released from Unit 1 work.

The licensee's published fuel load date remains as January

1984, with commercial operation forecast by November 15, 1984.

Construc-tion and testing progress is currently about three months behind

schedule, but the licensee is evaluating the startup test program sequence to regain the lost time.

As of March 2,

1983, two months had been regained on the startup schedule.

Major construction activities included pipe hanger and support installations, cable termination, small pipe installations, suppress-ion pool surface preparation and coating, system flushes, component tests and turnover.

In October

1982, the licensee conducted a self-initiated evaluation of the project using the INPO Performance Objectives and Criteria.

e.

Ins ection Activities A total of 14 inspections were conducted at Unit 2.

Six of these were conducted by the resident inspector alone:

one was initiated by the resident with regional inspector

input, and seven inspections were conducted by regional inspectors.

One of the resident inspec-tions included a trip to the Pennsylvania Power and Light Company corporate offices.

A breakdown of inspection hours by area is provided in Table 3.

Total inspection time was 574 hours0.00664 days <br />0.159 hours <br />9.490741e-4 weeks <br />2.18407e-4 months <br />.

The resident inspector was assigned project responsibility for Unit 2 and Unit 1 construction activities in March 1982.

Resident inspec-tion efforts were primarily directed toward Unit 1 until the licens-ing, fuel load, and initial startup activities were completed in September 1982.

Principal Unit 2 inspection activities prior to Unit 1 licensing consisted of review of licensee action on previous NRC findings which were common to both units.

This was generally consistent with licensee activity.

f.

Licensin Activities The majority of licensing activities during this period were directed toward Unit 1, although most of the reviews will be applicable to both units.

A separate revision to the Safety Evaluation Report Supplement 5 (March 1983) addresses the remaining issues for Unit 2.

II.

SUMMARY

OF RESULTS SUS UEHANNA STEAM ELECTRIC STATION UNIT 2 Functional Areas 1.

Soils and Foundation Category Category Category 1

2 3

No Basis 2.

Containment and Other Safety-Related Structures No Basis 3.

Piping Systems and Supports 4.

Safety Related Components 5.

Support Systems 6.

Electrical Power Supply and Distribution 7.

Instrumentation and Control Systems 8.

Licensing Activities 9.

Preoperational Testing No Basis No Basis No Basis Overview In general, the same staff that was involved in the construction, preopera-tional testing, and startup of Unit 1 is involved in the same activity for Unit 2.

This level of expertise has been found to be well-found and effective such that the following has been observed:

sound engineering practice, careful management, thorough corrective actions, prompt response to safety concerns, and a conservative safety philosophy.

~

I

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(

III. CRITERIA The following criteria were used as applicable in evaluation of each functional area:

1.

Management involvement in assuring quality.

2.

Approach to resolution of technical issues from a safety stand-point.

3.

Responsiveness to NRC initiatives.

4.

Enforcement history.

5.

Reporting and analysis of reportable events.

6.

Staffing (including management).

7.

Training effectiveness and qualifications.

To provide consistent evaluation of licensee performance, attributes associated with each criterion and describing the characteristics applic-able to Category 1, 2, and 3 performance were applied as discussed in NRC Manual Chapter 0516, Part II and Table I.

The SALP Board conclusions were categorized, as follows:

~Cate or 3

Reduced NRC attention may be appropriate.

Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to opera-tional safety or construction is being achieved.

~Cate or 2

NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.

~Cate or 3

Both NRC and licensee attention should be increased.

Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appeared strained or not effectively used such that mini-mally satisfactory performance with respect to operational safety or construction is being achieved.

~

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4

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IV.

PERFORMANCE ANALYSIS 1.

Soils and Foundation

~Anal sis Soils and foundation work was completed and all required inspections were performed prior to the assessment period.

There has been no indication that further inspection is required.

Conclusion No Basis.

Board Recommendation None.

2.

Containment and Other-Safet Related Structures 8%

~Anal sis The containment and safety-related structures were all erected prior to this assessment period.

The principal work consisted of wetwell surface preparation and coating.

This analysis is based on periodic review by the resident inspector.

Work in process observed included installation of an electrical penetration assembly which was being replaced and wetwell surface preparation and coating activities.

A final inspection of the wetwell was also made prior to filling.

The work was well organized, controlled, and properly accomplished.

Some penetration quality record problems were identified.

Three penetration in-process inspection records (of about 100) could not be located; and welding quality records for the work performed by Chicago Bridge and Iron Co.

(CB&I), although complete, were extremely difficult to correlate with the penetrations.

These problems were relatively minor and do not indicate programmatic weaknesses in the maintenance of quality records.

The licensee's response to these findings was thorough and included reinspection of the two penetrations, a review for other in-process inspections, and development of an instruction for locat-ing CB&I records.

The licensee's response to a potential construction deficiency involving an error in the vertical dynamic response to seismic events for the Control Structure, Reactor Buildings, and Diesel Generator Structure demonstrated a thorough and technically sound approach to a complex problem.

The licensee's forthright treatment of this issue with NRC was also noteworthy since their findings were in a very preliminary stage at the time the issue was reported.

Timely involve-ment and decision making by licensee management prevented a potential serious impact on Unit 1 licensing.

One Construction Deficiency Report (CDR) was reported which involved a programmatic weakness in Bechtel Quality Control inspections of AWS welding in that they did not identify various welding deficien-cies.

Bechtel QA identified the problem through routine audits.

Although a programmatic weakness was identified, licensee and Bechtel corrective actions were timely, thorough and indicative of strong management attention to identified problems.

There was also one concern identified by an alleger to both NRC and the licensee about the adequacy of welds in the wetwell liner.

This concern received immediate attention by senior licensee management, and it was concluded that the problem was similar to weld corrosion problems identified by the licensee in 1978 for Unit 1.

Corrective action included reinspection and upgrading of the weld surfaces and application of a protective zinc coating.

.This work was already planned prior to the concerns being raised.

~

5 Conclusion No basis.

(This area demonstrates many characteristics of Category 1

performance.

However, there is insufficient inspection to justify a conclusion.)

Board Recommendation None.

3.

Pi in S stems and Su orts 16%

~Anal si s The majority of work in this area consisted of hanger installation.

Large bore and pressure boundary piping installation is essentially completed.

This analysis is based on two regional inspections and routine resident inspections.

No violations were identified in Unit 2.

Several of the violations identified during Unit 1 inspections were concluded by the licensee to be applicable to Unit 2 and were reported by the licensee as Construction Deficiencies.

These problems involved inadequate design and quality control inspections of small pipe friction clamps, unauthorized tri'mming of shock suppressor pipe clamps, and inadequate design drawing control.

The licensee's response to these items included a two-week investigation of small bore pipe design activi-ties and a review for more generic implications, in addition to correcting the specific problems identified.

The root cause of the small bore pipe problems appears to be the fact that this design work was done on site and was loosely controlled by comparison to large-bore piping design, which is handled through the Bechtel San Fran-cisco home office.

Another contributing factor was a weakness in quality control procedures and inspection practices which failed to detect pipe clamp inadequacies.

Follow-up inspection of the Unit 1

violations and resident observations during plant tours indicates that the licensee's efforts to improve small bore pipe design activi-ties and hanger program controls are effective.

Inspection of pipe welding under the ASME Code identified no signifi-cant weaknesses in the licensee's program.

Piping welders are generally well trained and qualified, and weld quality is good.

One problem was identified in welder proficiency practices.

That was considered an isolated case.

The problem was corrected by requiring inspection of all welds used to establish welder proficiency.

NRC concern about ability to show reci rc riser weld acceptability on Unit 1 was followed by licensee offset radiography (RT) of the sweepolet to ri ser weld.

Two rejectable defects were then found and

repaired, and earlier RT was found to have shown but accepted these indications.

NRC concerns were also identified about nondestructive examination (NDE) examiner qualifications and the NDE examiner qualification program.

As a result of these NRC findings, 10% of the welds examined by the two specific reviewers whose qualifications were of concern were reexamined; and 20 of the weld packages reviewed by each of the other reviewers were reexamined by a NDE Level III reviewer from the Bechtel San Francisco home office.

This sample consisted of 673 welds.

Seven of these welds required additional evaluation, and four of these required rework.

Further licensee management attention to the NDE area is needed in order to assure that problems at Unit 1 do not recur on Unit 2.

One example of prompt and conservative action by the licensee in the piping area occurred when they became aware of possible falsified radiographs for piping supplied by ITT Grinnell.

A 100% review of all shop welds on this piping was conducted even before an NRC Bulletin on the topic was issued.

This was a major effort involving over 4,000 radiographs.

Conclusion Category 2

Board Recommendation Additional inspections should be performed on the pipe hanger area to verify that the licensee's corrective actions are effective.

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10 4.

Safet -Related Com onents (18%)

~Anal sis This analysis is based on two regional inspections and routine resident inspections.

One problem identified was a failure to properly store piping material outside the pipe combination shop.

The violation is not considered to be indicative of a program weak-ness because material and component storage was routinely inspected during plant tours and only the one improper storage problem was identified.

This represents an improvement since the last assessment period when problems were frequently identified in protecting compo-nents stored in place from ongoing construction activities.

The licensee reported and acted on several vendor related Construc-tion Deficiencies, including defective welds on the recirculation pump lugs, check valves which failed to close because of disc travel beyond the center position, and leaking diaphrams on timer relays.

Licensee action was consistently thorough and technically sound in correcting these problems.

One Construction Deficiency Report concerning improper blowdown setpoints for the Main Steam Safety/Relief valves resulted from a failure to use the actual diameter of the Susquehanna relief down-comers instead of the standard design.

This may indicate difficul-ties at the design interface between Bechtel and G.E.;

however, the error was discovered because Bechtel was required to independently calculate the back pressure

values, and the G.E.

and Bechtel values did not agree.

This independent calculation at a design interface indicates sound engineering management in anticipating possible data communication problems at such a design interface.

The licensee's responses to NRC Bulletins and Circulars identifying problems in safety-related components are also thorough.

These items are individually tracked to resolution by the licensing and gA organizations, indicating a strong management commitment to address safety concerns raised by NRC.

Other specific areas inspected included reactor vessel installation

records, pump motor installations and alignment, preturnover compo-nent functional tests, and component procurement records.

There were no significant weaknesses in these areas;

however, one item which is still unresolved with NRC concerned the omission of washers under the nuts on the Reactor Core Isolation Cooling (RCIC) turbine base plate.

The licensee demonstrated through additional analysis that the omitted washers were not required on RCIC and agreed to perform a

100% inspection of other safety-related rotating equipment to ensure washers and jam nuts are not omitted.

Results of this inspection have not been

examined, but such a response is typical of

the licensee's thorough, potential safety concerns raised by NRC inspectors.

However, this raises a concern about licensee perform-ance in identifying such problems.

Conclusion Category 1

Board Recommendation Although this area shows Category I attributes, the importance shown by the potential significance of problem areas like those identified'ictates that inspection coverage not be reduced.

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~ a 12 5.

Su ort S stems 3%

A~nal si s This analysis is based on inspection effort which concentrated in closeout of previously identified items and routine observations made during plant tours.

Many support systems are shared with Unit 1 and were completed prior to the assessment period.

The action taken on previously identified problems was generally thorough and technically sound.

During plant tours, work on the reactor building ventilation intake plenum was routinely observed and found to be properly controlled and accomplished.

A noteworthy strength is the management control over the interface between Unit 1

and 2 portions of shared systems.

Since Unit 2 portions of these systems have not been preoperationally tested and their failure could adversely impact Unit 1 operation, many isolations and bypasses of Unit 2 functions were required.

The careful tracking and control of these temporary modifications will facilitate Unit 2 testing and final integration with the remainder of the system when Unit 2 testing is complete.

To date, Unit 2 testing has not adversely affected safe operation of Unit 1.

This program is also discussed in the Electrical Power Supply and Distribution section of this report.

One Construction Deficiency Report concerning Emergency Service Water water hammer problems involved a significant licensee effort to correct.

The problem analysis, quantification, solution, and verification testing were generally indicative of strong engineering support and management control from the corporate office.

Conclusion Insufficient bases for assignment of category.

Board Recommendation None.

13 6.

Electrical Power Su 1

and Distribution 18%

~Anal sis This assessment is based on one region-based inspection and routine observations by the resident inspector.

Resolution of design capacity problems for the electrical distribu-tion system, which were identified as a Construction Deficiency in the previous assessment, has required substantial licensee engineer-ing effort.

The as-installed electrical distribution system cannot handle a simultaneous LOCA and loss of offsite power for two units within allowable voltage limits.

Several solutions were evaluated, and the final solution is to install two more Emergency Safeguards Systems transformers'horough engineering evaluation and planning were evident in the approach to this problem, which is particularly complex because of the interface with Unit 1.

Two Construction Deficiency Reports concerned a potential for over-loading of the emergency diesels.

One of these resulted from changes to the loading sequence between 1975 and 1982 which were submitted to the manufacturer for review in 1983.

The manufacturer determined that the diesel capacity was exceeded.

Corrective action was to delay starting of the Residual Heat Removal Pumps for three seconds.

The second problem was the possibility of starting Emergency Service Water and Core Spray Pumps at the same time during a medium sized LOCA and, thus, overloading the diesels.

The problem was introduced by the addition of a low vessel pressure interlock to accommodate a

simultaneous LOCA with loss of offsite power at two unit stations.

The interim corrective action was to delete the interlock for one unit operation.

Final correction will require an ESW pump logic change.

These emergency diesel generator loading problems indicate a

weakness in the engineering organization's initial evaluation of the more subtle effects of plant modifications since the problems were a

result of the modifications.

The fact that these problems were discovered by engineering review before preoperational test failure does indicate that the engineering organization follows up on sus-pected weaknesses resulting from design changes.

The most significant licensee findings in the self evaluation to INPO criteria concerned the failure to properly incorporate as-installed cable lengths into design evaluations.

Followup inspection in this area by NRC found additional problems with the validity of as-installed cable length data.

This problem appears similar to a NRC violation during the Unit 1 construction

program, and is the only identified example of failure to properly follow through on previously identified problems.

Licensee action on other previously identified problems in-the electrical area was generally thorough and technically sound.

Of particular note is the increased emphasis on

the protection and cleanliness of installed electrical components.

This is an improvement over the previous year's performance when problems were identified with electrical equipment protection.

Initial energization and preoperational testing of electrical switch gear have thus far identified no significant problems.

Another noteworthy strength in the management control of the electri-cal discipline is interface control between Unit I and 2.

Since many of the Unit 2 electrical systems are shared and could have an adverse impact on Unit 1 operation, isolation or bypassing of many Unit 2 functions was required until the systems could be tested and demonstrated to be reliable.

These isolated and bypassed functions are well controlled and identified.

This should greatly facilitate testing and integration with the portions of the electrical distri-bution system required for Unit 1 operation.

This interface control program is also discussed in the Support Systems section of this report.

Conclusion Category 2

Board Recommendation None.

15 7.

Instrumentation and Control 3%

~Anal sis Analysis in this area is based on resident closeout of previously identified items.

The licensee's action on previous items was generally thorough and technically sound.

There were four Construction Deficiencies reported in this area.

The first concerned inadequate mounting of timer relays for seismic events.

The second concerned a problem identified by G.E. with the HMA relays manufactured in 1974, and the third concerned inability to dynamically qualify the temperature detectors for the suppression pool temperature monitoring system.

Actions taken or planned for these deficiencies were appropriate.

The fourth Construction Defi-ciency concerned the potential for mechanical failure of a contain-ment electrical penetration due to a single failure in the Recircula-tion Pump Trip breaker control circuit.

The cause of this deficiency was inadequate Bechtel evaluation of existing conditions to meet new requirements.

This deficiency was identified as a result of a licensee engineering review, which is indicative of strong licensee involvement and oversight of the project.

Planned corrective action for this problem is appropriate.

Conclusion Insufficient bases for assignment of category.

Board Recommendation None.

16 8.

Licensin Activities A~nal si s The majority of licensing activities during this period have been directed toward Unit 1, although most of the reviews will be applic-able to both Units.

NRR review identified licensing issues for Unit 2, and Safety Evaluation Report Supplement 5 (March 1983) addresses these open items.

Conclusion Insufficient bases for assignment of category.

Board Recommendation None.

17 9.

Prep erational Testin 34%

A~nal si s The greatest amount of inspection effort was devoted to this area which was all performed by the resident inspector.

The preoperational test performance clearly shows that experience gained during the Unit 1 startup was incorporated into the Unit 2 test program.

System readiness at turnover has improved signifi-cantly and is in keeping with the aggressive startup schedule.

Preturnover walk down conferences are now held, and these have reduced the number of invalid walkdowns.

Most of the preoperational tests reviewed meet the FSAR test descrip-tion and are technically adequate.

Exceptions have been minor and generally accompanied by an FSAR change request.

An innovation which may have contributed to the improvement in preoperational test procedures was an outside audit of the Unit 1 preoperational test program to identify where FSAR commitments may not have been met.

Corrections were made for Units 1 and 2 and resulted in similar problems not recurring in Unit 2 during this SALP period.

An addi-tional benefit is having approved Technical Specifications for Unit 1, which alleviates some of the uncertainty regarding final setpoints and requirements.

Tests witnessed during this period were conducted by seasoned startup engineers from the Unit 1 program;

however, many specific responsibilities were shifted.

This provides a fresh perspective on the test procedure and is considered a good idea.

Records of the turnover process and machinery history were found to be complete and accurate.

Formal walkdowns are conducted, and turnover exceptions are tracked for correction.

A program is in, place to specifically identify those tests which could affect Unit 1

operations and ensure that they are scheduled for Unit 1 outage periods.

This indicates strong management control of the turnover process.

Plant operation is a concern.

Contractor personnel made up a large part of the onshift staff, and license candidates did not obtain hands-on experience because they were undergoing other training.

This condition still exists, and the use of nonlicensee personnel for prelicense issue operations is of concern, as well as the train-ing/development loss to licensee personnel.

To date, there have been no problems with operational control of testing, but the test program intensity is increasing substantially, and the test program is very aggressive.

Assignment of Unit 2 licensed operators and candidates to shift operations upon completion of their training is planned.

The licensee has been has been temporarily assigning Unit 1 operators to the Unit 2 control room.

Continuation of that practice should prevent significant problems from developing, but such assignment is

18 on an "as available" basis.

Since power operation has more direct safety significance than preoperational testing, giving priority to Unit 1 at this time is appropriate.

A Unit 2 Operations Supervisor (licensed on Unit 1) has been assigned.

However, careful licensee management and NRC resident inspector attention to this aspect is warranted.

The Tag and Permit system is working well and also reflects the experience gained during the Unit 1 preoperational testing program.

The licensee makes extensive use of automatic data processing for maintenance records and scheduling maintenance.

As a result, a

preventive maintenance program for Unit 2 was essentially in place when the Unit 1 program development was completed.

This is con-sidered a strong feature of the maintenance program for the pre-operational phase.

Another indication of management interest in equipment preventive maintenance is the expressed intention to begin operations phase preventive maintenance on many systems as soon as functional testing is completed.

This intention is also based on previous Unit 1 experience with equipment problems which occurred when only storage type maintenance was performed.

This decision is particulary appropriate since many preopertional tests are equivalent to normal plant operations, and the transition from construction turnover to actual test status is anticipated to be short.

Conclusion Category 1

Board Recommendation None.

19 V.

SUPPORTING DATA AND SUMMARIES 1.

Construction Deficienc Re orts CDRs Nineteen CDRs were submitted by the licensee during the period.

After evaluation, three of these were determined to be not report-able.

One is still under evaluation.

All of the deficiencies listed in Table 1 were analyzed for causual links and evaluated as part of the functional area that they represented.

Three of the deficiencies appear to be linked to poor gC inspection.

These are numbers 82-00-13, 82-00-14, and 82-00-19.

Two of the deficiencies appear to be linked to a failure to adequ-ately evaluate the effect of load sequence and load changes on the electrical distribution system.

They were number 82-00-07 and 82-00-16.

2.

Investi ation Activities No formal investigations were performed.

There was one inquiry into an allegation of defective welding in the wetwell.

No new safety concerns were identified.

The licensee was aware of the potential for rusting of wetwell liner welds since 1978 when similar problems were identified in Unit 1, and it was determined that the weld surfaces needed to be prepared for painting and the liner coated.

3.

Escalated Enforcement Actions None 4.

Mana ement Conferences June 17, 1982 A special, announced management meeting at NRC request to discuss the results of the Region I SALP for both Units 1

and 2 from March 1, 1981, to February 28, 1982.

Susquehanna SALP - Unit 2 CDR No.

82-00-01 82-00-02

<<82-00-03 82-00-OIl 82-00-05 82-00-06

<<82-00-08

<<82-00-09 82-00-10 82-00-11 82-00-13 82-00-1Il 82-00-15 82-00-16 TABLE 1

CONSTRUCTION DEFICIENCY REPORTS (2/1/82 - 1/31/83)

SUS UEHANNA UNIT 2

~Oescri tion Leaky diaphrams on Agastat E-7000 series Timer Relays.

Defective Recirculation Pump Iug welds.

Dynamic response of reactor and control building floor slabs.

Excess line voltage drop during LOCA with loss of off-site power.

Anchor-Darling check valves in core spray vertical line fail to close due to disc travel beyond center position.

ESW System Water Hammer.

Diesel fuel oil piping cracks.

Excessive drywell zinc coating.

Improper field mounting of Agastat 7000/E7000 series relays.

Main Steam Safety/Relief Valve (SRV) settings.

Friction clamp anchors did not perform intended function.

Inadequate cone of motion on PSA shock suppressors with ITT Grinnell pipe clamps.

Incorrect wipe settings on HFA relays Potential for overload of ECCS power distribution systems.

Cause Code F,D D,F 20

Susquehanna SALP - Unit 2 TABLE 1

CDR Ho.

82-00-17 82-00"18 (Continued)

~llescri tice Potential failure of the SPOTHOS temperature elements.

Recirculation pump electrical penetration protection does not meet single failure criterion.

Cause Code 82-00-19 Various welding deficiencies in Unit 2 not detected by Bechtel QC A

++82-00-20 Safety related cable length not verified for as-built conditions.

A "Reported as potential deficiencies and subsequently cancelled.

++Reportabil ity stil I under evaluation.

Cause Codes A

Personnel Error B

Design Error C

Externa I Cause D

Defective Procedures E

Component Failure/Defect F

Fabrication Error 21

Susquehanna SALP Unit 2

,22 TABLE 2 ENFORCEMENT OATA (2/1/82 1/31/83)

A.

Number and Severity Level of Violation Severity Level I Severity Level II Severity Level III Severity Level IV Severity Level V

Total B.

Violations vs. Functional Area The one violation was in the area of Safety Related Components.

C.

Listin of Violations

~Re ort Subject

~ei L

1F 388/82-05 Inadequate protection of material stored outdoors.

E I

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Susquehanna SALP Unit 2 23 TABLE 3 INSPECTION HOURS

SUMMARY

2/1/82 1/31/83 Functional Area 1.

Soils and Foundation 2.

Containment and Other'Safety-Related Structures 3.

Piping Systems and Supports 4.

Safety Related Components 5.

Support Systems 6.

Electrical Power Supply and Distribution 7.

Instrumentation and Control Systems 8.

Licensing Activities 9.

Preoperational Testing Total Hours 95 103 15 104 20 190 574

% of Time 0%

8%

16%

18%

3%

18%

3%

34%

100%

'usquehanna SALP - Unit 2 TABLE 4 INSPECTION ACTIVITIES SUS UEHANNA STEAM ELECTRIC STATION UNIT 2 Re ort Number 388/82-01 388/82-02 388/83-03 388/82-04 388/82"05 388/82-06 388/82-07 388/82-08 388/82-09 388/82"10 388/82-12 388/82-13 388/82-14 388/83"01 388/83-02

~Ios ecto'roject'roject project Resident Resident project Resident Resident Specialist Resident/

Specialists Resident Specialist Resident Resident Sp'ecialist Areas Ins ected Outstanding items Outstanding items Outstanding

items, pipe hangers and supports Outstanding items Outstanding

items, sa fety-rel ated components, welding, nondestruc-tive examination Outstanding items Outstanding items, welder qualifi-cations Outstanding items Reactor vessel

storage, installa-tion records and post installation cleanliness ASME piping, safety-related components, quality assurance, outstanding items Containment penetrations,

welding, preoperations test review, out-standing items

Cable, cable tray conduit, elec-trical equipment Preoperational test review, program review, test witnessing, outstanding items Pipe hangers and supports, wetwell zinc coating, p'reoperational test review, outstanding items, test witnessi,ng Sa fety-re 1 ated components