ML17159A031

NOV from Insp on 970817-1020.Violation Noted:On 970910,SSES Procedures for Control of Sblc Maint Were Inadequate in That Procedures Did Not Control Activities Such That Sys Remained in Analyzed Configuration

ML17159A031
Person / Time
Site:	Susquehanna
Issue date:	10/30/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17159A030	List: ML17159A029 ML17159A031 ML17159A032
References
50-387-97-07, 50-387-97-7, 50-388-97-07, 50-388-97-7, NUDOCS 9711070078
Download: ML17159A031 (3)

Text

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 August 17, 1997 to October 20,.1997, two 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:

Unit 1 Technical Specification (TS) 6.8.1 requires written procedures be established, implemented, and maintained covering the procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978.

Item 9.a. of Appendix A to RG 1.33, requires procedures for maintenance that can affect.the performance of safety related equipment.

On September 10, 1997, SSES procedures to control maintenance on the "A" Standby Liquid Control (SBLC) nitrogen accumulator included work authorization H70595, maintenance procedure MT-053-003, SBLC Accumulator Maintenance, and operations procedure SO-153-004, Quarterly SBLC Flow Verification.

Contrary to the above, on September 10, 1997, the SSES procedures for control of SBLC maintenance were inadequate in that the procedures did not control the activities such that the system remained in an analyzed configuration.

The unanalyzed configuration had the potential to negatively affect the performance of.

this safety related system.

This is a Severity Level IV violation (Supplement 1) 2.

10 CFR 50.59 states, in part, that licensees may make changes in the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves an unreviewed safety question (USQ), The licensee shall maintain'records of changes in the facility made pursuant to this section.

These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, as of September 24, 1997, a change was made to the ultimate heat sink, the spray pond, which is described in the SSES safety evaluation report, by adding a floating maintenance platform without a safety evaluation to support a determination that the change did not involve a USQ.

The platform had been manufactured by PP&L and placed on the ESW/RHRSW spray pond on several occasions without a supporting safety evaluation.

This violation applies to both SSES Unit 1 and 2.

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

97fi070078 97i030 PDR ADQCK 05000387 8

PDR

Enclosure 1

hnical Specification (TS) 6.8.1 for Units 1 and 2 requires written procedures be established, implemented, and maintained covering the procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978.

Item 1 of Appendix A to RG 1.33, recommends administrative procedures for equipment control, log entries and responsibilities for safe operation.

Pursuant to the above, Nuclear Department Administrative Procedure NDAP-AD-0300, "Conduct of Operations," Sections 4.13 and 6.3.1 c.(1) require nuclear plant operators (NPOs) to perform rounds in accordance with OI-AD-016, "Operator Rounds."

Steps 4.2 through 4.5 of OI-AD-016, Revision 18, require visual inspections of plant areas and equipment.

Attachment A to OI-AD-016, "General Rounds Expectations,"

provides the minimum requirements for General Visual Inspections (GVls) including, for example, all rotating equipment shall be inspected each shift, inspections of protective covers on the load centers shall be performed, and it is required to inspect all operator accessible areas of the plant.

P Contrary to the above, on various occasions prior to October 17, 1997, the GVls were not performed during operator rounds as specified in Attachment A to procedure Ol-AD-016; in that, inspections of all rotating equipment, protective covers on load centers, and all accessible areas of the plant were not performed on every shift.

This is a Severity Level IV violation (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 Inspectors 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 violations 1 and 2:

(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.

The NRC has concluded that the information regarding the reason for violation 3, the corrective actions taken or planned to correct that violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in this inspection report.

However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position.

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.

Enclosure 1

3 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 ihformation). 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 30th day of October 1997