ML17158B860
| ML17158B860 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/12/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158B859 | List: |
| References | |
| 50-387-96-10, 50-388-96-10, NUDOCS 9611190022 | |
| Download: ML17158B860 (7) | |
Text
NOTICE OF VIOLATION Pennsylvania Power and Light Company Susquehanna Units 1 and 2 Docket Nos. 50-387, 50-388 License Nos. NPF-14, NPF-22 During an NRC inspection conducted from September 10 - October 21, 1996, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions (NUREG-1600)," the violations are listed below:
A.
Unit 1 Technical Specification (TS) 6.8.1, "Procedures,"
states that the licensee shall establish and implement procedures recommended in Regulatory Guide 1.33, including item 9.c(2) procedures for repair and replacement of control rod drives (CRDs).
Susquehanna Steam Electric Station (SSES) Nuclear Department Administrative Procedure (NDAP)-QA-0500 establishes approved practices for maintenance procedures and work plans.
NDAP-QA-0500 refers to Maintenance Procedure MT-AD-501, Maintenance Procedure Program, which establishes the procedural adherence requirements for different types of SSES maintenance procedures.
Section 6.2 of MT-AD-501, states that a step-by-step conditional procedure provides specific detailed direction.
It further states that strict adherence to the procedure, exactly as written and in its entirety, is required.
Finally, it states that the procedure must be in the field and on the job.
Maintenance Procedure MT-055-001, CRD Removal, is a step-by-step conditional procedure that controls the removal and replacement of the CRD mechanisms, including the identification of the correct mechanism, and controls to second party verify the correct mechanism.
Contrary to the above, on September 26, 1996, MT-055-001 was not used in a step-by-step fashion in the field by the foreman directing the CRD removal activities on Unit 1. The correct CRD was not identified nor second party verified. This failure resulted in the wrong CRD being partially disassembled, with the potential to negatively affect the cooling of fuel assemblies in the core and spent fuel pool; and/or affect local reactivity conditions.
This is a Severity Level IV violation (Supplement 1).
B.
Units 1 5 2 TS 6.12, "High Radiation Area," requires each high radiation area to be barricaded and conspicuously posted as a high radiation area.
Contrary to the above, the following high radiation areas were not barricaded and conspicuously posted as high radiation areas.
96iii90022 9hiii2 PDR ADQCK 05000387 8
On May 5, 1996, the entrance to the Unit 1 Turbine Building 676'levation "D" Demin Room from the "E" Demin Room was not posted as a high radiation area, and had dose rates of 200 mrem/h.
On May 11, 1996, the entrance to the Unit 1 Turbine Building 676'levation, Steam Jet Air Ejector (SJAE) Room from the spare SJAE room was not barricaded and posted as a high radiation area, and had dose rates of 1200 mrem/h.
On July 31, 1996, an un-posted high radiation area of 400 mrem/h was found originating from the Unit 2 Reactor Building 779'elevation at resin inlet valve HV-24511 B.
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On September 6, 1996, the west entrance to the Unit 2 Turbine Building 729'levation moisture separator room was not barricaded or posted as a high radiation area, and had dose rates as high as 800 mrem/h.
This is a Severity Level IV violation (Supplement IV).
Pursuant to the provision of 10 CFR 2.201, Pennsylvania Power and Light is hereby required to submit a written statement or explanation to the U.S. Nuclear regulatory Commission, ATTN. Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violation, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
level of protection described in 10 Dated at King of Prussia, PA this 12th day of November, 1996 Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable
- response, then please provide a bracketed copy of your response that deletes such information.
If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information).
If safeguards information is necessary to provide an acceptable
- response, please provide the CFR 73.21.
U.S. NUCLEAR REGULATORY COMMISSION REGION I
License Nos.
NPF-14 NPF-22 Report Nos.
96-10 96-1 0 Docket Nos.
50-387 50-388 Licensee:
PENNSYLVANIAPOWER AND LIGHT COMPANY 2 NORTH NINTH STREET ALLENTOWN, PENNSYLVANIA 18101 SUSQUEHANNA STEAM ELECTRIC STATION Inspection Period:
September 10, 1996 through October 21, 1996 Inspectors:
K. Jenison, Senior Resident Inspector B. McDermott, Resident Inspector R. Ragland, Radiation Specialist Approved by:
W. Pasciak, Chief Projects Branch 4
EXECUTIVE
SUMMARY
Susquehanna Steam Electric Station, Units 1 5 2 NRC Inspection Report 50-387/96-10, 50-388/96-10 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support.
The report covers a six week period of resident inspection; in addition, it includes the results of announced inspections by a regional health physics inspection.
~Oerations In its normal 100% injection mode lineup, the Residual Heat Removal system is operated in a configuration that is consistent with the design basis and the design basis is supported by design basis calculations.
Operators adequately responded to an unexpected upset condition involving the Unit 2 Turbine Combined Intermediate Valves.
Pennsylvania Power 5 Light (PPSL) management's response to the potential risk of storing material for which there was no supporting analysis, in transient equipment areas near safety related equipment was good.
PPSL identified no present impacts on the safe operation of plant equipment from the storage of transient equipment.
The failure to fully control transient equipment near safety related equipment constitutes a violation of minor significance and is being treated as a Non-Cited Violation consistent with Section IV of the NRC Enforcement Policy.
The licensee did not document an operability determination for a Control Room Emergency Outside Air Supply System (CREOASS) damper that had failed in an open position, despite the fact this position was contrary to its fail-closed design.
Maintenance activities with the potential for draining the reactor cavity were allowed to commence based on the presumed operability of both CREOASS subsystems.
The operability determination provided after, questions from the inspector provided a reasonable basis for operability.
In this case, the failure to implement required administrative procedures for a condition adverse to quality constitutes a violation of minor significance and is being treated as a Non-Cited Violation consistent with Section IV of the NRC Enforcement Policy.
Working hours of Susquehanna Steam Electric Station (SSES) staff who perform safety related functions were sampled in the Operations and Maintenance areas.
No examples of excessive use of overtime were identified.
Three examples were found in the Maintenance organization where administrative forms were not processed in a timely manner however, this delay was inconsequential.
From a programmatic standpoint, the licensee has established and implemented an effective program of controls for the resolution of identified problems.
These controls include the activities of the Independent Safety Evaluation Services, the
Plant Operations Review Committee, and the visible support of corporate officer level management.
Based on the selected sample, most Condition Reports (CRs) were resolved effectively and were associated with adequate evaluations of safety significance and operability impact.
Maintenance
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In general, the majority of the observed maintenance and surveillance activities were well performed.
An exceptionally well performed activity involved the 18 month Unit 1, Division 1, Loss of Coolant Accident/Loss of Offsite Power surveillance test.
This comprehensive test included an excellent pre-job briefing, effective coordination by the Nuclear System Engineering (NSE) test directors, and good communication with control room operators.
During the replacement of Unit 1 control rod drive (CRD) mechanisms, the licensee failed to adequately control activities affecting quality, in accordance with established SSES procedures.
As a result the reactor coolant system was placed in an adverse condition with a potential to affect the water level in the core and the spent fuel and/or local reactivity conditions in the core.
The resulting adverse plant condition (a partial removal on an incorrect CRD mechanism) was identified by an SSES worker and no leak actually occurred.
There was sufficient pump capacity and onsite emergency power available to supply water and cooling to the core and spent fuel pool if the leak had occurred.
Secondary containment was operable and would have allowed a filtered vent path through the standby gas treatment system (SBGTS) to the environment.
A notice of violation was issued for this event.
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The activities involved in the weld repair and milling of the Unit 1 'A'eactor feed pump and other maintenance on the 'C'eactor feed pump, were well controlled by first line management, and were performed in an excellent manner.
The activities involved in the core shroud inspection and evaluation were well controlled by first line management, and were performed in an excellent manner.
PP5L management's response to the potential risk of having scaffolds remaining erected for long periods of time near safety related equipment was comprehensive and identified no present impacts on the safe operation of plant equipment from existing scaffolds.
Because of the length of time the scaffolds were erected, they were considered defacto modifications by the inspector.
Therefore, an NRC identified failure to consider the effects of plant modifications in accordance with 10 CFR 50.59, constitutes a violation of minor significance and is being treated as a Non-Cited Violation consistent with Section IV of the NRC Enforcement Policy.
The licensee's followup in response to a broken lockwire and seal discovered on set screws for the 'S'afety relief valve was good.
plant support, we found that the licensee continued to maintain an effective radiological controls program.
This was evidenced by extensive planning and effective implementation of radiological controls for outage work.
Use of temporary shielding and ALARAflushes to reduce radiation levels were excellent; controls for radioactive materials and contamination showed improvement; use of warning lights and radiation work permit controls for access to high radiation areas were reasonable; the organization and administration of the health physics program for outage work allowed for excellent oversight of work and performance monitoring of contract health physics technicians; training provided to the health physics contractor staff and training records were excellent; and quality assurance and self assessment oversight were excellent.
Although no unplanned exposures occurred, and licensee responses to self-identified deficiencies were very good, weaknesses were identified. in the radiological posting and access control program.
Accordingly, a Notice of Violation has been issued for the failure to properly post and barricade high radiation areas in accordance with Technical Specification 6.12, "High Radiation Areas."
(See Notice of Violation and Section R8.5 of this report)
TABLE OF CONTENTS EXECUTIVE
SUMMARY
TABLE OF CONTENTS............
v I. Operations 02 04 06 07 08
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Operational Status of Facilities and Equipment..
02.1 Residual Heat Removal (RHR) System Alignment 02.2 Unit 2 Turbine Combined Intermediate Valves (CIV) 02.3 Transient Material Storage in the Unit 1 and 2 Reactor Buildings.......
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02.4 Unit 1, Restart between October 17 and 22, 1996..
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Operator Knowledge and Performance....... ~....... ~,
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04.1 Control Room Emergency Outside Air supply System (CREOASS) Fan 'B'utlet Damper Failure 04.2 Nuclear Plant Operator Log Review......
Operations Organization and Administration.....
06.1 Overtime Approval Review.............
Quality Assurance in Operations...... ~...............
07.1 Effectiveness of Licensee Controls - Problem Resolution Miscellaneous Operations Issues................
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08.1 (Closed) LER 50-387/96-007
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2 3
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II, Maintenance M1 Conduct of Maintenance M1.1 General Comments M1.2 Control Rod Drive (CRD) Mechanism Replacement M1.3 Reactor Feedwater Pump Repair..................
M1.4 Core Shroud Examination and Repair.......... ~....
M1.5 Scaffolding M1.6 Overall Conclusions on Conduct of Maintenance M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Safety Relief Valve Set Screw Lockwire M8 Miscellaneous Maintenance Issues M8.1 (Closed) Unresolved Item (URI) 50-388/95-12-01; High Pressure Coolant Injection (HPCI) On-line Maintenance M8.2 (Closed) URI 50-387/95-05-01:
Observation Of Activities The Refuel Floor 0
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10 13 13 14 15 15 15 16 16 17 III. Engineering E1 Conduct of Engineering E1.1 (Update - URI 387, 388/96-06-01) Containment Secondary Bypass Leakage (73051) 17 17 17 v