ML17159A021
| ML17159A021 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/27/1997 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML17159A022 | List: |
| References | |
| 50-387-97-06, 50-387-97-6, 50-388-97-06, 50-388-97-6, EA-97-472, NUDOCS 9711030004 | |
| Download: ML17159A021 (8) | |
See also: IR 05000387/1997006
Text
SUBJECT:
Forwards
insp repts
50-387/97-06
E 50-388/97-06
on 970701-
C
0816
6
NOV re concern of failure to adequately
correct
design basis configuration discrepancy.
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TITLE: Environ
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(50 DKT)-Insp Rept/Notice of Violation Respons
05000387
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..>'I-'ATEGORY 2
.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9711030004
DOC.DATE: 97/10/27
NOTARIZED:
NO
DOCKET
FACIL:50-387 Susquehanna
Steam Electric Station,
Unit 1, Pennsylva
05000387
50-388
Susquehanna
Steam Electric Station,
Unit 2, Pennsylva
05000388
AUTH.NAME
AUTHOR AFFILIATION
HEHL,C.W.
Region
1 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
BYRAM,R.G.
Power
a Light Co.
P Op,1$ 'EQ F+~0-
g~EC
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NOTE TO ALL "RZDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL
DESK
(DCD)
ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
17
ENCL
17
October 27, 1997
Mr. Robert.G. Byram
Senior Vice President
- Nuclear
Power 5 Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
SUBJECT:
NRC INSPECTION REPORT 50-387/97-06, 50-388/97-06 AND
Dear Mr. Byram:
On August 16, 1997," the NRC completed
an inspection at the Susquehanna
Steam Electric
Station (SSES) facility. The enclosed report presents the results of that inspection.
During the 6-week period covered by this inspection, the conduct of activities at the SSES
facility was characterized
by safe operation and generally conservative
decision making.
The inspection of the radiological environmental monitoring program (REMP) incorporated
selective examinations of procedures
and representative
records, interviews with
personnel,
and observations
by the inspector.
The REMP at the SSES was considered
overall to be well performed and effective.
The Offsite Dose Calculation Manual and
environmental technical specifications were properly implemented.
We note that a number of the violations and apparent violations listed below involve
inadequacies
in configuration control and corrective actions.
Your attention is needed to
determine whether these instances
are representative
of a broader programmatic weakness
in these areas.
Based on the results of this inspection, the NRC has determined that four violations of NRC
requirements
occurred.
These violations are cited in the enclosed
(Notice), and the circumstances
surrounding the violations are described
in detail in the
enclosed report.
Please note that you are required to respond to this letter and should
follow the instructions specified in the enclosed
Notice when preparing your response.
The
violations concern:
(1) failure to adequately correct a design basis configuration
discrepancy;
(2) failure to establish
a program which ensures that nonconforming
components
are identified and segregated;
(3) failure to test emergency diesel generators
at ambient conditions; and (4) failure to perform a 10 CFR 50.59 reviews prior to
performing a communication equipment test, and prior to minor modifications to several
service water pumps.
97i i030004 97i027
ADOCK 05000387
6
NllltlllttIIllltttllilIlll
Mr. Robert G. Byram
The violations concerning equipment design basis configuration discrepancies
are cited
because
the discrepancies
were identified by the NRC, and the current PPSL design basis
verification activities were not expected to have identified the issues.
NRC determined that
weaknesses
exist in your design basis verification activities.
Therefore, in addition to your
response
to the cited violation, please describe your plans to address
these weaknesses
in
order to preclude future violations, or discuss your basis for determining that no changes
are necessary.
At the inspection exit, you committed to review previously canceled
modification requests,
to determine whether corrective action for any similar known
discrepancies
have been'canceled
in the past.
Please affirm this commitment in your
response
to this violation.
In addition, the violation concerning the performance of a communication equipment test is
the fourth recent example in which PPSL reasoned that meeting the intent of a required
action was equivalent to following that action as written in procedures
or requirements.
In
, this particular case,
PPSL management
determined that the use of certain communication
equipment was not addressed
by PPKL procedures,
despite the appearance
that SSES staff
was violating its communications
equipmenc control procedures.
No procedural test
controls were established
for the communication test and no 10 CFR 50.59 safety
evaluation was performed.
The three previous examples include inadequate
charcoal filter
testing,
a blocked open containment isolation valve and the staffing of the Nuclear Safety
Assessment
Group, each of which were addressed
in previous inspection reports.
The misalignment of the control room emergency outside air supply system (CREOASS)
was promptly corrected.
However, several aspects of this CREOASS configuration
problem were not resolved during this inspection.
These issues involve:
(1) the cause of
the "A"CREOASS door being open was not determined;
(2) the consequences
of a
partially opened
CREOASS door were not analyzed in the operability determination;
and (3)
system initiation is not blocked and/or an entry into a Limiting Condition for Operation
Action Statement
is not required under current SSES practices when a ventilation system is
breached
during normal operator rounds.
You are requested
to address these issues along
with your response
to this letter, including your assessment
of the root cause and the
necessity for corrective actions.
Based on our review of. the "A" emergency
diesel generator misalignment, which was
discovered
by NRC on July 11, 1997, and discussed
in this report; apparent violations
were also identified and are being considered for escalated
enforcement action in
accordance
with the "General Statement of Policy and Procedure for NRC Enforcement
Action" (Enforcement'Policy), NUREG-1600.
The misalignment caused this important
safety-related
equipment to be inoperable for an indeterminate period, thus degrading the
plant's capability to respond to design basis events.
Accordingly, no Notice of Violation is
presently being issued for these concerns.
Please
be advised that the number and
characterization
of apparent violations as described
in the enclosed inspection report may
change
as a result of further NRC review.
Mr. Robert G. Byram
A predecisional'enforcement
conference to discuss these apparent violations will be
scheduled
at a mutually agreeable
date.
The conference will be open to public observation
regarding the EDG operability issue and your corrective actions in response
to prior events.
Discussions regarding your investigation of the potential tampering aspects of this event
may require a closed session of the conference, to the extent that personal privacy or
safeguards
information will be discussed.
In order to maximize the scope of the open
discussion,
you should plan your presentation
to cover all aspects of the event, your
response
and corrective actions that do not involve personal privacy or safeguards
information from the outset of the conference.
Please notify Mr. J. Fewell or Mr. C.
Anderson at the NRC Region
I office if you conclude that any part of your presentation
must be closed to public observation.
Your notification should include sufficient detail to
determine that any proposed
closed session will be limited to information reasonably
associated
with specific privacy or safeguards
information.
The decision to hold a predecisional enforcement conference
does not mean that the NRC
has determined that a violation has occurred or that enforcement action will be taken.
This
conference
is being held to obtain information, to enable the NRC to make an enforcement
decision, such as a common understanding
of the facts, root causes,
missed opportunities
to identify the apparent violation sooner, corrective actions, significance of the issues and
the need for lasting and effective corrective actions.
In particular, we expect you to
address the root'cause of the mispositioned diesel generator governor knob, and your
response
to this and other precursor events.
In addition, this is an opportunity for you to
point out any errors in our inspection report and for you to provide any information
concerning your perspectives
on:
1) the severity of the violation; 2) the application of the
factors that the NRC considers when-it determines the amount of a civil penalty that may
be assessed
in accordance
with Section VI.B.2 of the Enforcement Policy; and 3) any other
application of the Enforcement Policy to this case, including the exercise of discretion in
accordance
with Section Vll of the policy.
You will be advised by separate
correspondence
of the results of our deliberations
on this
matter.
No response
regarding this apparent violation is required at this time.
Sincerely,
ORIGINALSIGNED BY:
Charles W. Hehl, Director
Division of Reactor Projects
Docket Nos.:
50-387;50-388
License Nos:
Mr. Robert G. Byram
4
Enclosures:
2.
NRC inspection Report 50-387/97-06, 50-388/97-06
cc w/encl:
G. T. Jones,
Vice President
- Nuclear Operations
G. Kuczynski, General Manager
J. M. Kenny, Supervisor,
Nuclear Licensing
G. D. Miller, General Manager - Nuclear Engineering
R. R. Wehry, Nuclear Licensing
M. M. Urioste, Nuclear Services Manager, General Electric
C. D. Lopes, Manager - Nuclear Security
H. D. Woodeshick,
Special Office of the President
J. C, Tilton, III, Allegheny. Electric Cooperative,
Inc.
Commonwealth of Pennsylvania
Distribution w/encl:
Region
I Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
H. Miller, RA
W. Axelson, DRA (IRs)
P. Swetland,
A. Keatley, DRP
NRC Resident Inspector
PUBLIC
Distribution w/encl: (Via E-Mail)
W, Dean, OEDO
C. Poslusny, Project Manager,
J ~ Stolz, PDI-2, NRR
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR
F. Talbot, NRR
DOCDESK
DOCUMENT NAME:
- GABRANCH4iSUS9706.INS
To receive a copy of this document, indicate in the box: "C" = Copy without
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OFFICE
RI/DRP
RI/DRP
RI/DRP
NAME
PSw
g
CAnderson
c, ~p
C
DATE
10/
97
10/r"/97
10&)/97
OFFICIAL R
ORD COPY
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