ML17158A135
| ML17158A135 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna |
| Issue date: | 02/09/1994 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| EA-94-022, EA-94-22, NUDOCS 9402220187 | |
| Download: ML17158A135 (12) | |
See also: IR 05000387/1993080
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9402220187
DOC.DATE: 94/02/09
NOTARIZED: NO
DOCKET ¹
ACIL:50-387 Susquehanna
Steam Electric Station, Unit 1, Pennsylva
05000387
50-388
Susquehanna
Steam Electric Station, Unit 2, Pennsylva
05000388
j
AUTH.NAME
AUTHOR AFFILIATION
COOPER,R.W.
Region
1 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
BYRAM,R.G.
Power
& Light Co.
R
SUBJECT: Discusses
insp rept 50-387/93-80,augmented
insp team
finding relative to review of fuel handling events of
931029-1109.
DISTRIBUTION CODE:
IE10D
COPIES
RECEIVED:LTR
ENCL
SIZE:
TITLE: 50 Dkt Augmented Inspection
Team (AIT) R ports/ orrespondence
NOTES:
RECIPIENT
ID CODE/NAME
PD1-2
INTERNAL: AEOD/DEIIB
AEOD/DSP/ROAB
DEDRO
NRR/DORS/DIR
NRR/DORS/OTSB
NRR/DRIL/RPEB
NRR/DRSS/PEPB
NRR/PMAS/ILPB
F
02
RGN1
FILE
01
EXTERNAL: INPO RECORD
CTR
COPIES
LTTR ENCL
1
1
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
RECIPIENT
ID CODE/NAME
AEOD/DO
AEOD/DSP/TPAB
NRR/ADAR
NRR/DORS/OEAB
NRR/DRCH/HHFB
NRR/DRPW
NRR/DSSA/DIR
NUDOCS-ABSTRACT
OGC/HDS2
RES/DSR/HFB
NRC PDR
COPIES
LTTR ENCL
1
1
1
1
1
1
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NOTE TO ALL RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM P 1-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
27
ENCL
27
)I
FEB
9 tgg~
License Nos.
NPF-22
Docket Nos.
50-387
50-388
Mr. Robert G. Byram
Senior Vice President-Nuclear
Pennsylvania Power and Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
Dear Mr. Byram:
SUBJECT:
NRC INSPECTION REPORT 50-387/93-80,
AUGMENTED INSPECTION
TEAM (AIT) FINDINGS RELATIVE TO
THE REVIEW
OF
FUEL
HANDLINGEVENTS (OCTOBER 29 TO NOVEMBER 9, 1993)
The subject inspection report was previously provided to you in our letter dated December 21,
1993. The inspection assessed
the circumstances,
causes, corrective actions, safety significance,
and generic implications of four fuel handling incidents which occurred on October 6, 26, 27,
and 28, 1993, at Susquehanna
Steam Electric Station, Unit 1.
An open management
meeting
was held with you and your staff on November
18,
1993 to discuss your perspective
and
corrective actions relative to this matter; and a public exit meeting was conducted on November
22, 1993, to discuss the preliminary findings of the NRC's Augmented Inspection Team,
As
we indicated at that time, the NRC would consider
enforcement
action upon review and
assessment
of the AIT's findings as documented in the inspection report.
Subsequently,
we have completed our review of the AIT inspection report, and noted that the
inspection identified several
specific deficiencies
and conditions that were allowed to exist
without effective resolution.
We believe these matters contributed to the recurrent performance
problems that were exhibited during Unit 1 fuel handling.
Such deficiencies included a long-
standing history of ineffective corrective measures
to address
previous similar hardware and
personnel'performance
problems involving fuel handling; and insufficient safety perspective,
coupled with weak management oversight and control, relative to the general performance offuel
handling activities.
We determined that several of the identified deficiencies and weaknesses
constitute apparent violations of NRC regulatory requirements
that should be considered for
escalated
enforcement in accordance with the "The General Statement of Policy and Procedure
for NRC Enforcement Actions" (Enforcement Policy), 10 CFR Part 2, Appendix C,
Proposed
enforcement action is pending completion ofour review of this matter.
Accordingly, no Notice
JSAO-3
9402220187
940209
ADOCK 05000387
8
.PFFICIAL PECQRP COPY
FEB
g fggg
of Violation is presently
being issued for these
inspection
findings since the number
and
characterization ofthese matters, as described in the inspection report and the summary enclosed
with this letter, may change as a result of further NRC review.
These matters were discussed
between Mr. James Kenny of your staff and Mr. John White of
this office on January 27,
1993.
Accordingly, an enforcement
conference
to discuss
these
apparent'violations
has been scheduled in NRC Region I on March 3, 1994 at 10:00 a.m.
The
purposes of the conference are to discuss the apparent violations, including the cause and safety
significance; to provide you an opportunity to identify errors that might exist in the inspection
report; to identify corrective actions, taken or planned; and to discuss any other information that
may help us determine the appropriate enforcement action in accordance with the Enforcement
Policy. In addition, this is an opportunity for you to provide any information concerning your
perspective
on
1) the severity of the issue,
2) the factors that the NRC considers
when it
determines the amount of a civilpenalty that may be assessed
in accordance with Section VI.B.2
of the Enforcement Policy, and 3) the possible basis for exercising discretion in accordance with
Section VIIof the Enforcement Policy.
You willbe advised by separate correspondence of the
results of our deliberations on this matter.
No response regarding this matter is required at this
time.
This enforcement
conference will be open
to public observation
in accordance
with the
Commission's trial program as discussed in the enclosed Federal Register notice. Although not
required,
we encourage
you to provide your comments
on how you believe holding this
conference open to public observation affected your presentation and your communications with
the NRC.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice", a copy of this letter and
the enclosure will be placed in the NRC Public Document Room.
We appreciate
your
cooperation in this matter.
Sincerely,
ORIGINALSIGNED BY
WAYNED. LANNING
~
~
Richard W. Cooper, Director
Division of Reactor Projects
Enclosures:
As Stated
OFFICIALRECORD COPY
'
FEB
g tggg
cc w/encl:
H. G. Stanley, Vice President - Nuclear Operations
J. M. Kenny, Nuclear Licensing
G. T. Jones, Vice President - Nuclear Engineering
M. M. Urioste, Nuclear Services Manager
D. F. McGann, Supervisor, Nuclear Compliance
H. D. Woodeshick, Special Office of the President
J. C. Tilton, III, Allegheny Electric Cooperative, Inc.
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO
NRC Resident Inspector
Commonwealth of Pennsylvania
OFFCIAL RECORD CopY
FEB
g
~ggg
bcc w/encl:
Region I Docket Room (with concurrences)
V. McCree, OEDO
R. Clark, Project Manager, NRR
C. Miller,
PDI-2, NRR
J. White, DRP
R. Summers, DRP
E. Wenzingex, DRP
D. Holody, Enforcement Officer, RI
- D
ite
/94
RI;PRP
gz;Po
RI:D
EWenzinger age.Q
Cooper
u,e4
)~ [e
if'FFICIALRECORD COPY
a:enfconf.sus
ENL
E
ARY
F I
THATMAY ON
APPARENT VI LATI N
e Rlated
F IBn
1 Mvmn Error
Technical Specification 6.8.1 requires that written procedures
be established,
implemented and maintained covering the activities referenced Regulatory Guide 1.33.
Regulatory Guide 1.33 requires that refueling procedures
be implemented.
On October 6, 1993, procedures
were not adhered to during refueling operations,
as
evidenced by the following examples:
1.
On October 6, 1993, fuel bundle 31-56 was incorrectly removed from the core
and subsequently
replaced in its core location.
This was contrary to RE-081-
032 which required any improperly withdrawn fuel bundle to be placed in the
spent fuel pool.
2.
On October 6, 1993, RE-081-032, Refueling Operations, required the shift
supervisor to be responsible for directing fuel handling activities.
However, in
this case, bundle 31-56 was improperly placed in the core without his
knowledge or consent.
The outage supervisor,
an off-shift licensed SRO,
directed the activity contrary to procedure.
ssues Related to Ineffective
orrective Action f r Im act Events
10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," requires, in part,
that in cases of significant conditions adverse to quality, measures
shall assure that the
cause of the condition is determined and corrective action taken to preclude repetition.
Prior to the October 6, 26, 27, and 28, 1993 events, similar occurrences
were
experienced but were not sufficiently evaluated to establish effective corrective
measures
to preclue recurrence
as evidenced by the following examples:
On September 20, 1986; September 27, 1987; April 15, 1988; April 13, 1989;,.
September
19, 1989; April 17, 1991; and March 20, 1991 fuel bundles were
either improperly removed or found in an incorrect core location.
Actions
taken ranged from counseling operators and additional training to tacit
acceptance of fuel handling errors.
The combinations of corrective actions for
these events was ineffective at preventing the fuel movement error that
occurred on October 6, 1993.
OFFICIALRECORD COPY
2.
On October 26 a refueling bridge fault lockout was experienced but was not
sufficiently evaluated to recognize the cause as an actual impact of the mast
assembly on the reactor vessel flange.
Since the operator was unaware of the
impact, fuel handling was resumed without understanding
the cause of the
lockout or recognizing that markings on the reactor vessel flange protectors
were the result of the impact.
Followup investigation revealed a previous
similar occurrence in 1992, in which the licensee determined that such impacts
may occur without the operator being aware of the situation.
However, no
corrective action was initiated to preclude recurrence of this type of event.
3.
On October 27, 1993, a double blade guide assembly impacted the reactor
vessel wall when an operator failed to provide adequate
clearance prior to
moving the refueling bridge in the X-Y direction.
The procedure change that
required that the refueling mast be in the "normal up" position prior to moving
the bridge was subsequently only included in one of two procedures
governing
refueling operations.
OP-181-001, Refueling Operations,
the procedure used
by the operators on the bridge, did not receive the procedure change.
Thus,
the corrective action for this event was ineffective.
4.
An operator interview sheet recorded observations for an April 13, 1989
impact of a double blade guide into the refueling transfer canal.
In this
interview, he annotated that this contact was not as hard as other bumps that
he saw.
As a result, he was interviewed by the AITand confirmed a
interference between double guides attached to the mast and those in the spent
fuel pool.
This interference was never addressed
in licensee corrective actions
for this event and remained an unknown problem by licensee management until
the AIT.
III.
Issues Related to Maintenance Activities
Technical Specification 6.8.1 requires that written procedures
be established,
implemented, and maintained covering activities referenced in Regulatory Guide 1.33.
Regulatory Guide 1.33 requires that procedures for maintenance
and surveillance
procedures
be adequately implemented.
During core offload on October 4, 1993, the Unit 1 grapple began to leak air.
On
October 5, mechanical maintenance
removed the grapple from the Unit 1 mast and
replaced it with a spare grapple that was available on the spare mast present on the
refueling floor. This grapple was procured as "non-Q" and it had not been dedicated
prior to use.
NCR 93-112 had been previously written to document this condition.
However, this grapple was placed into use without disposition of NCR 93-112 which
was contrary to Section 6.13 of NDAP-QA-0754.
OFFlClAl RECORD COPY
v
~