ML17159A023

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Notice of Violation from Insp on 970701-0816.Violation Noted:Condition Adverse to Quality Involving Inadequate Loop Seals for Standby Gas Treatment Sys Filter Drains Was Not Promptly Corrected
ML17159A023
Person / Time
Site: Susquehanna  
Issue date: 10/27/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17159A022 List:
References
50-387-97-06, 50-387-97-6, 50-388-97-06, 50-388-97-6, NUDOCS 9711030006
Download: ML17159A023 (5)


Text

Ilg ENCLOSURE 1 NOTICE OF VIOLATION Pennsylvania Power and Light Company (PPRL)

Susquehanna Steam Electric Station (SSES)

Unit 1 and Unit 2 Docket Nos. 50-387, 50-388 License Nos. NPF-14, NPF-22 During an NRC inspection conducted from.July 1, 1997, through August 16, 1997, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

'3 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, requires, in part, that licensees establish measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, defective materials and equipment are promptly identified and corrected.

PP5L Nuclear Department Administrative Procedure NDAP-QA-702, Condition Report, implements the Criterion XVI requirements to promptly identify and correct conditions adverse to quality or safety and prevent their recurrence when the condition is safety significant.

Contrary to the above, a condition adverse to quality involving inadequate loop seals for the standby gas treatment system filter drains was not promptly corrected, This deficiency was originally identified in a 1987 engineering study (SEA-ME-093),

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and as of August 16, 1997, PPRL had not corrected the deficiency, a period of greater than 10 years.

This is a Severity Level IV violation (Supplement 1).

l 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, requires, in part, that

'icensees establish measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, defective materials and equipment are promptly identified and corrected.

For significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, when on September 14, 1996, PPRL identified a condition adverse to quality involving nonconforming materials that were not being controlled in accordance with 10 CFR 50 Appendix B, Criterion XV, Nonconforming Materials, Parts, or Components; the corrective ac;ions to preclude repetition were inadequate.

As a result, on June 16, 1997, a nonconforming damper actuator was not controlled by tag and/or segregation as required.

This is a Severity Level IV violation (Supplement 1).

9711030006 971027 PDR ADOCK 05000387 6

PDR

Enclosure 3.

Technical Specification (TS) surveillance TS 4.8.1.1.2 requires that the emergency diesel generators (EDGs) be tested from ambient conditions.

Contrary to the above, on April 18, 1997, the TS 4.8.1.1.2 surveillance conducted to confirm EDG "B" operability, was not performed from an ambient condition.

A maintenance run of the EDG was performed prior to the TS surveillance test that warmed the EDG above ambient conditions.

This is a Severity Level IV violation (Supplement 1).

4.

10 CFR 50.59,'Changes, Tests and Experiments, states that the holder of a license authorizing operation may make changes to the facility or conduct tests not described in the safety analysis report without prior Commission approval, unless the proposed change or test involves a TS change or an unreviewed safety question (USQ) ~ It further states that the licensee must maintain records of changes/tests, and that the records must include a written safety evaluation which provides the bases for the determination that the change/test does not involve a USQ.

a0 Contrary to the above, communication system transmission demonstration tests were conducted between September and November 1996, and a safety evaluation was not written to support a determination that the demonstration tests did not involve a USQ.

b.

Contrary to the above, changes had been made to the residual heat removal and emergency service water pump motors by adding protective screens not described in the safety analysis report, and as of July 16, 1997, a safety evaluation had not been written to support a determination that the changes did not involve a USQ.

These are Severity Level IV violations (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power and Light Company 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 violations, and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

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.

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Enclosure 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 identifies the information that should be protected and a redacted 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 withhold-ing (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 level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 27th day of October 1997

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