ML17159A354
| ML17159A354 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/28/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NUDOCS 9806040253 | |
| Download: ML17159A354 (41) | |
Text
CATEGORY' REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
] ACCESSION NBR:9806040253 DOC.DATE: 98/05/28 NOTARIZED: NO FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva AUTH.NAME AUTHOR AFFILIATION ANDERSON,C.J.
Region 1 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION
'YRAM,R.G.
Pennsylvania Power
& Light Co.
SUBJECT:
Advises of planned insp effort resulting from Susquehanna Plant Performance Review (PPR).Details of insp plan for next 6 months encl.
DOCKET 05000387 05000388 DISTRIBUTION CODE:
XE40D COPIES RECEIVED:LTR ENCL SIZE:
TXTLE: Systematic Assessment of Licensee Performance (SALP) Report NOTES:
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N NOTE TO ALL "RZDS" RECIPIENTS:
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ON EXTENSION 415-2083 II TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24
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May 28, 1998 Mr. Robert G. Byram Senior Vice President - Nuclear Pennsylvania Power 5 I ight Company 2 North Ninth Street Allentown, Pennsylvania 18101
SUBJECT:
PLANT PERFORMANCE REVIEW (PPR) - SUSQUEHANNA STEAM ELECTRIC STATION
Dear Mr. Byram:
On April 30, 1998, the NRC staff completed the semiannual Plant Performance Review (PPR) of the Susquehanna Steam Electric Station.
The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance.
The results are used by NRC management to facilitate planning and allocation of inspection resources.
The PPR for Susquehanna involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period (October 1997 through March 1998.
PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC Systematic Asse'ssment of Licensee Performance (SALP) and senior management meeting (SMM) reviews.
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of licensee performance trends.
The PIM includes only items from inspection reports or other docketed correspondence between the NRC and Pennsylvania Power and Light Company.
The PPR may also have considered some predecisional
'and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
This material willbe placed in the PDR as part of the normal issuance of NRC inspection reports and other correspondence.
This letter advises you of our planned inspection effort resulting from the Susquehanna PPR review. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite.
E'nclosure 2 details our inspection plan for the next 6 months.
Residerit inspections are not listed due to their ongoing and continuous nature.
9806040253 980528 PDR ADOCK 05000387 6
poa OFFICIAL RECORD COPY IE:40
Robert G. Byram We willinform you of any changes to the inspection plan. If you have any questions, please contact me at (610) 337-5227.
Sincerely, Original Signed by:
Clifford J.
Anderson, Chief Projects Branch 4 Division of Reactor Projects Docket Nos,; 50-387;50-388
Enclosures:
1.
Plant Issues Matrix
- 2. Inspection Plan cc w/encls:
G. T. Jones, Vice President - Site Operations G. Kuczynski, General Manager J. M, Kenny, Supervisor, Nuclear Licensing G. D. Miller, General Manager - Nuclear Engineering R. R. Wehry, Nuclear Licensing P.
Ray, Nuclear Services Manager, General-Electric C. D. Lopes, Manager - Nuclear Security A. Male, Manager, Nuclear Assessment Services H. D. Woodeshick, Special Assistant to the President J. C. Tilton, III, Allegheny Electric Cooperative, Inc.
Commonwealth of Pennsylvania
0
Robert G. Byram Distribution w/encls:
4 Region I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
H. Miller, RA/W. Axelson, DRA (IRs)
C. Hehl, DRP J. Wiggins, DRS R. Crlenjak, DRP L. Nicholson, DRS C. Anderson, DRP DRS Branch Chiefs P. Bonnett, DRP R. Junod, DRP R. Ragland, DRS E. King, DRS J. Lusher, DRS R. Fuhrmeister, DRS NRC Resident Inspector PUBLIC Distribution w/encls: (Via E-M'ail)
B. McCabe, OEDO R. Capra, PD 1-2, NRR V. Nerses, Project Manager, NRR D. Brinkman, NRR Inspection Program Branch, NRR (IPAS)
R. Correia, NRR F. Talbot, NRR M. Campion, ORA DOCDESK opy with attach n
nclosure "N" = No copy DOCUMENT NAME: 6:iBRANCH4'iSUSiSPPR-LTR.598 To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" =
C OFFICE NAME DATE RI/DR DFIor 054.
8 RI/DRP CAnderson g
05h'p/98 OFFICIAL RECORD COPY
ENCLOSURE 1 SUSQUEHANNA STEAM ELECTRIC STATION PLANT ISSUES MATRIX(PIM)
Date Type Source ID SFA Code Item Description 3/16/98 NCV IR 98-01 L
Negative NCV 98 11 NCV 98 12 OPS 3A AuxiliarySystem Operators were not consistently performing radwaste control room 5C panel alarm tests and Plant Control Operator performance issues were identified regarding performance of main control room annunciator alarm tests irithe same time period when VIO 50-387, 388/96-270-01022 was issued. These licensee identified issues are considered non-cited violations.
3/16/98 Negative lR 98-01 L
OPS 3A PP&L's corrective actions forthree procedure violations, associated with the June 1996 5C "E"emergency diesel generator circuit breaker misalignment, were acceptable.
Corrective actions focused on improving operator performance, management oversight, and independent assessment.
Subsequent licensee audits of operator performance were acceptable and appropriate actions were taken to validate and verify the quality of computer data used to assess operator performance.
FROM: 10/1/97 TO: 3/1'8/98 1 of 23 27 May 1998
SUSQUEHANNA i.a.2 PLan ISSUES Z>rmX Dafe Type Source
/D SFA Code
/fern Descripfion 3/16/98 NCV IR 98-01 LER NCV 98 Negative
~
03 LER 97 00 L
OPS 2A On March 25, 1997, while the unit was shut down, chemistry technicians were performing a transfer process from the reactor building ventilation stack monitor to the system particulate iodine noble gas (SPING) system.
During the transfer, a spurious reactor building criticalitymonitor alarmed, requiring the evacuation of the area in which the technicians were working. Upon returning to the area the technicians realized that there had been an approximately 20 minute period that continuous sampling ofthe reactor building vent was not maintained in accordance with Technical Specification (TS) 3.3.7.11. The licensee determined that the reactor building criticality monitor had drifted lowwhich caused the unanticipated alarm. The inspectors reviewed the Licensee Event Report (LER), inspected the licensee's corrective actions and root cause evaluation, conducted an onsite field inspection and determined that there were no safety consequences associated with the failure to continuously monitor the stack release.
There were no safety consequences because the unit was shut down and there was a clear pattern of data established both before and after the missed time period. With respect to the criticalityalarm drift, the driftwas in the conservative direction, and there was no significant pattern of spurious alarms. This TS violation resulted from circumstances not within reasonable licensee control, in that the criticalityalarm failure could not have been avoided within the parameters ofthe licensee's surveillance program. Therefore, this non-repetitive licensee identified violation is being treated as a non-cited violation, consistent with Section VI.Aofthe NRC Enforcement Policy. This LER is closed.
FROM: 10/1/97 TO: 3/18/98 2 of 23 27 May 1998
0
SUSQUE>Mi'a.2 pLvn'ssues ~wrmx Date Type Source ID SFA Code Item Description 3/16/98 NCV IR 98-01 L
LER NCV 98 Negative 02 LER 97 00 OPS 3/16/98 Positive IR 98-01 N
OPS 3/16/98 Positive IR 98-01 N
OPS 3A 5A 1C 1C 3B On March 20, 1997, a service water radiation monitor was removed from service.
Subsequently a service water sample required by TS was not collected and analyzed within the time specified by TS LimitingCondition for Operation (LCO) Action 3.3.7.10.
The TS LCO Action states that with less than the minimum required number of radiation monitors operable, the eNuent release pathway may continue for up to 30 days provided that, at least once per eight hours grab samples are collected and analyzed for gross radioactivity at a specific limitof detection.
The subject sample was taken and analyzed within fifteen minutes of the required eight hour period. The licensee determined that the root cause of the event was personnel error and entered the involved individual in the PP8 L performance improvement process.
The inspectors performed a summaiy review ofthe Licensee Event Report (LER), the associated condition report and its corrective actions.
In addition, onsite field inspections were performed.
Itwas determined there was no safety impact from the delay in taking the effluent sample, because the results of the sample were normal and as expected.
Therefore, this non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation, consistent with Section VII.B.1 ofthe NRC Enforcement Policy. This LER is closed.
A selection of Plant Operations Review Committee (PORC) and Susquehanna Review Committee (SRC) activities, covering a 3 month period, were reviewed. NRC determined PORC and SRC, in general, conducted in-depth reviews and demonstrated a conservative and safe approach.
The inspector concluded that Susquehanna's licensed operator re-qualification training program was satisfactory overall. The written examinations were adequate, but a section forfive of six written examinations were weak. Examination administration was good, and operator performance was generally good with some individual operator deficiencies identified forfollowup.
FROM: 10/1/97 TO: 3/18/98 3of 23 27 May 1998
Date ape Source ID SFA Code Item Description 3/16/98 Positive IR 98-01 N
OPS 3/16/98 Positive IR 98-01 N
OPS 3/16/98 Positive IR 98-01 N
OPS 1/19/98 Negative IR 97-10 N
OPS 12/8/97 Positive IR 97-09 N
OPS 4A The licensee's approach to the establishment of alarm setpoints for safety relief valves (SRVs), compensatory measures for a Notice of Enforcement Discretion on the "S" SRV and the control of SRV operability, were acceptable.
1B Operators were observed to respond well to control room alarmed conditions.
Appropriate SSES procedures were adhered to, operability and impact on plant equipment were controlled, and actions were adequately announced and documented.
Operators identified a slow speed driftof one reactor recirculation pump, on two separate occasions, and responded well to these anomalies.
1A Operator communications were observed to be clear, concise, formal, and in compliance with SSES operations department procedures.
Shift turnovers were detailed and complete.
In general, communications between plant control operators and nuclear plant operators were observed to be of good quality.
3C Operator performance was reviewed by direct observations, interviews, and 1C evaluations of PPBL self assessments.
The inspectors verified the weaknesses, identified by the PPBL self assessments, that were described as environmental factors.
Despite the weaknesses, the inspectors verified current operator performance was very good. PPLL management is establishing general approaches to resolve these weaknesses.
The identified weaknesses currently have no apparent impact on the safe operation of SSES.
1B Operators responded well on September 1, 1997, when a feedwater pump minimum flowcontrol valve failed open. The licensee initiated a condition report to review the root cause and work authorizations to perform corrective actions. The inspector reviewed the licensee's corrective actions and found them to be adequate.
FROM: 10/1/97 TO: 3/18/98 4of 23 27 May 1998
SUSQUEE6&INA 1 &.2 PLANTISSUES MATRIX Date 'ype Source ID SFA Code Item Description 12/8/97 Negative IR 97-09 N
OPS 12/8/97 Positive IR 97-09 N
OPS 10/20/97 Negative IR 97-07 N
OPS 5A Several weak initial operability determinations were identified by the inspectors.
After 5B discussions with Operations and Nuclear System Engineering personnel, additional 3B information was provided that justified why the equipment was capable of performing its intended safety function. The inspectors noted that PP8L has not provided operability determination training for on shift personnel responsible for initial operability determinations.
Operations management is aware of this issue and is planning to enhance training in this area.
3A Licensed operators responded well to specific annunciated plant conditions. Licensed 1A operators were able to clearly describe the reasons for their actions, discuss the impact oftheir actions upon the safe operation of the units, and fullyimplement established plant procedures.
4B The initial operability determination forthe Unit 2 High Pressure Coolant Injection 5B (HPCI) overspeed trip assembly problem was weak. Nuclear System Engineering personnel overlooked the potential impact on the HPCI injection valve and how this impact could affect the response time to rated flow. PP8L management made a conservative decision to declare HPCI inoperable, pending further evaluation. A subsequent revision ofthe operability determination provided a good basis for operability. Significant licensee attention was focused on resolution ofthe problem and, the overspeed trip assembly has performed acceptably since the corrective maintenance.
FROM: 10/1/97 TO: 3/18/98 5 of 23 27 May 1998
SUSQUEEGQ4NA IR. 2 PLl&TISSUES MATRIX Date Type Source ID SFA Code Ifem Descripfion 10/20/97 NCV IR 97-07 LER NCV 97 Negative 05 LER 97 00 L
OPS 5A During a review of procedures as a follow-up to a previous plant event, PP8 I determined that the requirement of Technical Specification Table 3.3.7.10-1, ACTION 101 was not being met. ACTION 101, requires a gross radioactivity analysis on liquid effluent grab samples when the associated effluent monitoring instrumentation is not operable to be performed. Performance of gamma isotopic analysis does not meet the verbatim TS requirement since itdoes not measure gross radioactivity to a sensitivity of 1E-7 microcurie/ml.
The cause of the event was determined to be human performance.
Itwas not recognized that a change to the TSs was required since itwas viewed that the isotopic analysis was an improved method of analysis.
The isotopic analysis is a better analysis in determining radioactivity in eNuents.
Corrective actions include: procedure changes to require a gross radioactivity analysis along with the isotopic analysis and a revision to the Technical Specifications.
This was considered a licensee identified non-cited violation.
10/20/97 Positive IR 97-07 N
OPS 5C The resolution of several issues by the PP8L Corrective Action Team (CAT) was direct, safety oriented, and conservative.
The issues included loose pole pieces on 4 kv electrical breakers and level indication maintenance on the standby liquid control system.
10/20/9?
Positive IR 97-07 10/20/97 Positive IR 97-07 N
OPS 1A 3A S
OPS 18 5C 3A The plant control operators (PCOs) responded well to those alarmed conditions requiring actions.
PCOs were able to describe the reasons for their actions and discuss the impact of their actions upon the units. PCO actions were determined to be conservative and in accordance with established plant procedures.
Areactor feedwater pump (RFP) minimum flowcontrol valve failed open resulting in a reactor water level induced transient. The Plant Control Operator (PCO) reduced power to approximately 68%, reactor water level was recovered, and the unit was returned to a steady state condition. PCO actions were conservative and in accordance with unit procedures.
FROM: 10/1/97 TO: 3/18/98 6 of 23 27 May 1998
7
Dafe
~
Type Source
/D SFA Code
/fern Descrlpfion 10/20/97 VIO IR 97-07 VIO 97 02 10/20/97 Positive IR 97-07 N
OPS 1A PPB L management conservatively opted to shut down Unit 2 in response to an 5C increasing trend of unidentified reactor coolant system leakage before reaching Technical Specification (TS) limits. Good management involvement was observed during preparation forthe shutdown and an orderly shutdown was conducted with no significant challenges to the operators.
N OPS 1C On various occasions prior to October 17, 1997, the General Visual Inspections were 3A 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 ofthe plant were not performed on every shift.
FROM: 10/1 /97 TO: 3/18/98 7 of 23 27 May 1998
4
SUSQUEEG&INA 18 2 PMWT ISSUES 1VIATRIX Dafe Type Source ID SFA Code ifem Descripfion 3/16I98 EEI URI LER IR 98-01 IR 97-10 URI 97 04 LER 97 00 EEI 98-01-06 EEI 98-01-07 EEI 98-01-08 N
MAINT 2B 5A Corrective actions, for a previous NRC violation, identified the Unit 1 standby liquid control (SLC) system was potentially inoperable and may not have been capable of fulfillinga safety function needed to shut down the reactor in the event of an accident.
A maintenance work practice and a non-specific procedure appear to have resulted in both Unit 1 SLC pump accumulators being inoperable at the same time. This condition existed for an indeterminate period oftime between September 9, 1997, and November 25, 1997. PP8L is continuing to reanalyze the SLC system design, to determine ifdepressurized accumulators would have prevented the SLC system from performing its safety function. Pending additional licensee information, this issue is being followed as an unresolved item.
Update from IR 98-01: NRC review of additional information, regarding the Unit 1 SLC system operability, between September 10, 1997, and November 25, 1997, identified three apparent violations. The apparent violations contributed to the SLC system being degraded and potentially inoperable.
These apparent violations are being considered as escalated enforcement items (EEIs), in accordance with the NRC Enforcement Policy. Unresolved item 50-387/97-10-04 is closed and the followingthree EEls are opened:
EEI 98-01-06: In 1995 and 1996, standby liquid control accumulators were found below the acceptable pressure range specified by procedure and no Condition Report was initiated as required forthe conditions adverse to quality.
EEI 98-01-07: Procedures controlling the standby liquid control system maintenance were not adequate to ensure the accumulator charging valve cap was installed in accordance with the vendor's instructions.
EEI 98-01-08: The standby liquid control pumps being tested in a condition that was FROM: 10/1/97 TO: 3/18/98 8of 23 27 May 1998
t
'N
SUSQUEI'IANNAIR. 2 PLANTISSUES MiATIUX Dafe Type Source ID SEA Code Ifem Descripfion 3/16/98 Negative IR 98-01 3/16/98 Negative IR 98-01 3/16/98 Positive IR 98-01 3/16/98 Positive IR 98-01 3/16/98 Negative IR 98-01 1/19/98 Positive IR 97-10 N
MAINT 3C 5C S
MAINT 2A 3A N
MAINT 3A 3B N
MAINT 3A 3B S
MAINT 2A 1B N
MAINT 3A 3B The licensee implemented several actions, in response to NRC and SSES self assessment identified issues, in the maintenance and work control programs.
The performance issues include, in part, work control effectiveness, outstanding work backlog, and maintenance activity control. These actions have not been in place for a sufficient period of time to show improvement in the maintenance area.
The "B"Emergency Diesel Generator (EDG) test run was discontinued following receipt of an unexpected turbocharger lube oil low pressure alarm. The cause was adequately identified, and the EDG was repaired and returned to service. within the time period allowed by Technical Specification. Overall, maintenance activities were adequate.
The surveillance activities observed were adequately performed and appropriately controlled. The activities were accomplished by qualified and trained personnel.
No violations of NRC requirements were identified.
Four planned maintenance activities, reviewed during this period, were found to be appropriately conducted and controlled. Interviews with maintenance personnel showed the individuals involved in these activities were knowledgeable, appropriately qualified, and capable of explaining their activities.
A PPBL management decision, to reduce power in response to a main generator isophase bus duct cooler leak, was well communicated within the operations department and was conservative.
The licensee initiated appropriate corrective actions, no violations of NRC requirements occurred, and the failure was documented for maintenance rule tracking purposes.
The surveillance activities observed were adequately performed and appropriately controlled. The surveillance activities were determined to have been accomplished by qualified and trained personnel.
No violations of NRC requirements were identified.
FROM: 10/1/97 TO: 3/18/98 9 of 23 27 May 1998
SUSQUEEBWNA IR. 2 PLQCT ISSUES MATRIX Date rVpe Source
/D SFA Code Item Description 1/19/98 Positive IR 97-10 N
MAINT 3A 3B The planned maintenance activities, reviewed during this period, were found to be appropriately conducted and controlled. Interviews with maintenance personn'el showed the individuals involved in the maintenance activities to be knowledgeable and capable of explaining their activities. No violations of NRC requirements were identified.
12/8/97 VIO LER IR 97-09 VIO 97 02 LER 97 00 N
MAINT 2B 3A In March 1997, maintenance procedures for the replacement of the bonnet vent line for reactor recirculation valve HV-2F031B failed to ensure the vent line support configuration was not altered from its original design. As a result, excessive vibration during power operation caused a weld on the bonnet vent line to crack, resulting in a loss of reactor coolant. The failure to provide adequate procedures for control of safety related maintenance is identified as a violation. This item closed IFI 50-387/97-07-01.
12/8/97 Positive IR 97-09 12/8/97 Positive IR 97-09 N
MAINT 2B 3A N
MAINT 2B 3A The surveillance activities observed were adequately performed and appropriately controlled. No violations of NRC requirements were identified.
Seven of the eight planned maintenance activities reviewed during this period were found to be appropriately conducted and controlled.
In one instance, informal drawings were used during corrective maintenance on non-safety related equipment.
This activity had no impact on safety related equipment and no violation of NRC requirements occurred.
12/8/97 Negative IR 97-09 S
MAINT 2A A problem occurred with the level control valve for the "4C" feedwater heater. A power reduction to 80% was directed by procedures after preparations for corrective maintenance on the control valve caused an automatic an automatic isolation of the steam supply to the feedwater heater.
~
'R 10/1/97 TO: 3/18/98 10of 23 27 May 1998
SUSQUEHANNA IR. 2 PLt'QVT ISSUES MATRIX Dafe ape Source ID SFA Code
/fern Descripfion 10/20/97 NO ED LER Negative IR'97-07 IR 97-09 LER 97 00 10/20/97 Positive IR 97-07 10/20/97 Positive IR 97-07 10/20/97 Positive IR 97-07 10/20/97'CV IR 97-07 Negative NCV 97 07 N
MAINT 5C Corrective actions for a safety related check valve deficiency, identified in 1994, did not address generic implications. In 1996, the same condition was identified on a different valve and, in this case, the planned actions to prevent recurrence were appropriate.
However, the administrative process to implement and track these actions was not initiated. These two corrective action problems are considered a violation of minor signiTicance because this had no impact on safety.
S MAINT 28 PP&L requested enforcement discretion for TS requirements concerning a failed.
1C acoustic position indicator forthe "S" Safety Relief Valve. PP8L requested the enforcement discretion to avoid an undesirable transient as the result offorcing compliance with a license condition. The NRC approved PP8L's request after determining the action involved minimal or no safety impact and had no adverse radiological impact on public health and safety.
N MAINT 58 The licensee's corrective actions in response to an interrupted cool down of the "C" 5C Emergency Diesel Generator (EDG) were adequate.
The interrupted cool down did not affect the operability ofthe EDG.=
N MAINT 38 The maintenance task certification matrix and its implementation were adequate to control the assignment of qualiTied workers to safety related maintenance activities.
No violation of NRC requirements was identified.
N MAINT 3A Susquehanna surveillance activities, observed during this inspection period, were well 1C performed, described and controlled by detailed Susquehanna procedures, and 38 performed by well trained, experienced and capable technicians/operators.
FROM: 10/1/97 TO: 3/18/98 11 of 23 27 May 1998
SUSQUEES'ANNA 18m 2 PLANTISSUES MATRIX Qafe Type Source ID SFA Code Ifem Descripfion 10/20/97 VIO IR 97-07 N
MAINT VIO 97 06 10/20/97 Positive IR 97-07 N
MAINT 3A The work authorization (WA) activities observed during this inspection period were, in 3B general, well performed. The WAs described and controlled maintenance activities with adequate, but in some cases general, procedures.
The maintenance activities were implemented by well trained and experienced maintenance technicians, and resulted in equipment being returned to service in good condition.
2B Susquehanna procedures for control of SBLC maintenance were inadequate in that the 3A 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 ofthis safety related system.
PP&L allowed maintenance work to proceed on the "A"Standby Liquid Control (SBLC) pump nitrogen accumulator without evaluating whether the activitywould affect operability. Afterthe question of operability impact was raised by the NRC, an initial operability determination by the Shift Technical Advisor was weak because it did not address known technical issues with the potential to affect operability. The failure to provide adequate procedures for control of maintenance on safety related equipment is a violation of TSs.
FROM: 10/1/97 TO: 3/18/98 12-of 23 27 May 1998
SUSQUEIRQINA IR. 2 PVQlT ISSUES 1VIATRIX Date Type Source ID SFA Code Item Description 3/16/98 3/16/98 NOED VIO LER NOED URI LER IR 98-01 IR 97-06 VIO 97 01 LER 97 00 IR 98-01 URI 98 09 LER 98 00 S
ENG L
ENG 4C On June 19, 1997, while both units were operating at 100% power, the licensee determined that the testing methodology used for activated carbon samples was different than that required by Technical Specification (TS). The licensee received a Notice of Enforcement Discretion to operate until it accomplished the required testing.
VIO 50-387,388/97-04-01 and a notice of enforcement discretion were issued to the licensee.
The licensee responded to the violation in PP8L letter PLA-4666, dated September 4, 1997, and affected adequate corrective actions which included a TS change, procedure changes, and technician training. VIO 50-387,388/97-04-01 was closed in inspection report 50-387,388/97-06, through onsite field inspection activities.
This LER is closed.
4C On February 2, 1998, SSES requested and received a Notice of Enforcement 5A Discretion (NOED) for containment penetration leak rate tests that were not performed when required. The licensee's request and immediate corrective actions for the issues were adequate.
The licensee's initial NOED commitments were verified to be complete and an unresolved item was opened, pending information on the circumstances which led to this event.
FROM: 10/1/97 TOi 3/18/98 13of 23 27 May 1998
sUsQUEHN rNA ia.2 PLuvr issues MArIUx Date Type Source ID SFA Code
/tern Description 3/16/98 NCV IR 98-01 URI IR 97-07 Negative NCV 98 10 URI 97 09 N
ENG 4C PALfailed to perform a 10 CFR 50.59 safety evaluation prior to opening a plant equipment hatch assumed to be closed by the tornado design basis analysis. This condition existed for an extended period before identification by the NRC.
Subsequently, plant equipment hatches have been verified to be in the condition assumed by the tornado analysis (shut) and are now being administratively controlled.
PP8L's evaluation to determine whether an unreviewed safety question existed with the hatch open is expected in January 1998 and willbe reviewed to determine the safety significance of this violation. In the interim, this item is being tracked as an unresolved item.
3/16/98 Negative IR 98-01 N
ENG Update from IR 98-01: The inspectors identified a fioor hatch in the reactor building which was maintained open for many years.
In response to the inspectors questions, PP8L determined the site tornado analysis assumed the hatch was closed.
No safety evaluabon was performed prior to placing the hatch in other than the analyzed position.
Asubsequent PP8L calculation determined the result ofthe tornado analysis was not adversely affected by hatch position. The failure to perform a safety evaluation prior to changing the hatch position was a violation of minor significance and is being treated as a non-cited violation.
4A NRC identified three control room annunciators which alarm after TS LimitingCondition for Operation (LCO) action levels are exceeded.
The issue was discussed with operations management and itwas determined the general issue of annunciator conservatism, including LCO action statement start time, was being addressed in the PP8 L corrective action system.
Several examples of unalarmed TS entries were identified by the NRC, but no violations of the TS allowed outage time were identified.
FROM: 10/1/97 TO: 3/18/98 14of 23 27 May 1998
SUSQUEHANNA 18m 2 PLPLNT ISSUES MATRIX Dafe Type Source
/D SFA Code Item Description 1/19/98 NCV IR 97-10 N
ENG Negative NCV 97 05 12/8/97 Positive IR 97-09 L
ENG 4B The "E" Emergency Diesel Generator (EDG) tripped on high jacket water temperature, 1A as designed, during a surveillance test. Prior to the surveillance, the Emergency Service Water (ESW) supply valve failed to stroke open under dynamic conditions and was not noticed by the operators.
Post maintenance testing for a previous maintenance activity failed to verifythe valve would function under the expected operational conditions. Although the inadequate post maintenance test of the valve had the potential to impact safety related equipment, the "E" EDG was not aligned to a safety-related bus at the time ofthe event, there was no effect on the operating units, and no damage to the EDG occurred. The licensee identified failure to provide adequate post maintenance testing for safety related equipment is considered a non-cited violation.
5A PP8L identified a potential non-conservatism in the vendor supplied methodology used 4B to establish minimum critical power ratio (MCPR) limits for single loop operation. The identification of.this issue by PP8L was viewed as a positive indication of the level of scrutiny being given to fuel related calculations. The inspector verified that conservative interim corrective actions have been implemented for Susquehanna pending the resolution ofthe potential issue, by the NRC Office of Nuclear Reactor Regulation.
FROM: 10/1/97 TO: 3/18/98 15 of 23 27 May 1998
SUSQUEEDWNA I&.2 PLEAT ISSUES MATRIX Dafe Type Source ID SFA Code
/fern Descripfion 12/8/97 URI IR 97-09 N
ENG Negative URI 97 06 12/8/97 URI IR 97-09 N
ENG Negative URI 97 03 URI 97 04 URI 97 05 58 Susquehanna emergency diesel generator (EDG) frequency TS surveillance 5C requirements were compared to emergency core cooling system (ECCS) design basis assumptions.
EDG frequency is proportional to ECCS pump speed which determines post accident ECCS injection flowrates. When the lowest EDG frequency allowed by TS is overlaid onto Susquehanna design basis ECCS pump performance assumptions, the results are non conservative, because there are situations in which calculations show ECCS pumps can not provide the required post accident injection flow.
However, actual EDG frequency variation, as shown by test data, is significantly better than that allowed by TSs, and when actual frequency test data is overlaid with design ECCS pump performance assumptions, the ECCS flowrates are shown,to be adequate and safe.
Resolution ofthe non-conservative TS surveillance criteria willbe tracked as an unresolved item.
5B PP8L identified three conflicts between the feedwater penetration isolation valve 5C configuration and the licensing basis. Although these issues were placed in PP8L's corrective action process, the NRC questioned the need for licensing actions and more timely corrective action. The three issues involve 1) the failure to test certain feedwater containment isolation valves in accordance with 10 CFR 50 Appendix J, 2) the acceptability of the reactor water clean up isolation valve configuration as an alternative to 10 CFR 50 Appendix A design requirements, and 3) the consequential failure of a feedwater isolation valve during a feedwater line break event and compliance with 10 CFR 50 Appendix A design requirements.
These issues remain unresolved pending additional information from PP&L.
FROM: 10/1/97 TO: 3/18/98 16 of 23 27 May 1998
SUSQUEW&JNA 18'. 2 PL/&ITISSUES MATRIX Dafe Type Source
/D SFA Code
/fern DescripfIon 10/20/97 NCV IR 97-07 LER NCV 97 Positive 03 LER 97 00 L
ENG 10/20/97 Negative IR 97-07 N
ENG 10/20/97 VIO IR 97-07 Vlo 97 10 N
ENG 10/20/97 Positive IR 97-07 N
ENG 4C 5A 5B 5C 2A 4C 4A During a 1997 procedure review, the licensee discovered reactor water level instruments were in-operable, during a 1996 Unit 1 hydrostatic pressure test, without performing the required Technical Specification actions. The cause was determined to be a personnel error, made during a previous procedure revision.
The inspectors reviewed the corrective actions and found them to be adequate. This licensee identified and corrected violation is being treated as a non-cited violation consistent with Section VII.B.1 ofthe NRC Enforcement Policy.
The engineering corrective actions for problems with the Unit 1 RCIC drain pot level switch were not timely. This allowed continuous degradation ofthe drain line and a continuous alarmed condition for over ten months after it caused a forced shutdown. A modification to replace the drain pot level switch was completed and has been effective in restoring the normal operation ofthe RCIC system.
PPBL failed to perform a 10 CFR 50.59 safety evaluation prior to placing a floating service platform on the spray pond that serves as the ultimate heat sink for both Susquehanna units. This condition existed for an extended period before identification by the NRC. PP8 I has yet to perform an evaluation to determine whether an unreviewed safety question existed with the platform on the spray pond.
Subsequently, the spray pond was verified to be in the condition assumed by the Final Safety Analysis (the platform was removed). Analysis of the spray pond design basis and evaluation ofthe potential USQ willbe reviewed with the response to this violation.
A review of the Susquehanna responses to 10 CFR 50.63, Station Blackout (SBO) rule was conducted.
The licensee installed an auxiliary diesel power source to increase the SBO coping duration of its 125 Vdc batteries from approximately 5-hours to greater than 8-hours. The NRC safety evaluation report concluded that Susquehanna must meet a 4-hour coping duration. Therefore, the inspectors concluded that there was no current regulatory requirement forthe licensee to maintain the auxiliary power source.
FROM: 10/1/97 TO: 3/18/98 17 of 23 27 May 1998
SUSQUEWQJNA IR. 2 PLANTISSUES MATRIX Date Type
~ Source
/D SFA Cocfe Item Description 10/20/97 NCV IR 97-07 Negative NCV 97 08 10/20/97 Positive IR 97-07 N
ENG 5B InFebruary1997,PP8Lidentifiedthatthe "A"ControlStructure(CS)chillerwouldnot 2A automatically start as designed and took immediate actions to correct the problem.
However, PP8L initiallyfailed to recognize this condition as outside the plant's design basis, as described in the Final Safety Analysis Report. After identification by the NRC, PP8L initiated a Condition Report, determined the condition was reportable, and submitted a Licensee Event Report as required. Corrective actions for both the technical problem and the failure to recognize the condition outside the design basis were implemented by PP8L.
In this case, the failure to report a condition outside the design basis within 30 days of discovery is characterized as a non-cited violation.
N ENG 4C The erosion control program portion of engineering corrective actions for an indicated high level in a reactor core isolation cooling (RCIC) drain pot was determined to be outstanding..
FROM: 10/1/97 TO: 3/18/98 18 of 23 27 May 1998
SUSQUEEGGVNA lR. 2 PL/iNTISSUES MATRIX Date Type Source lD SFA Cocle Ifem Description 3/16/98 Positive IR 98-01 N
PS 5A The condition reporting system was effectively used to identify, evaluate, and resolve 5B radiological control program deficiencies.
5C 3/16/98 Positive IR 98-01 N
PS 2A Housekeeping and material conditions of plant structures and equipment were good.
3/16/98 Positive IR 98-01 N
PS 2A Health physics equipment and facilities were well maintained.
3/16/98 Positive IR 98-01 N
3/16/98 Positive IR 98-01 N
1/1 9/98 NCV IR 97-10 N
Negative NCV 97 06 PS 2B Astrong commitment to reducing plant contamination was evidenced by the reduction 3C of recoverable-contaminated areas in 1997 from 9A to 6.2 percent and performance of 5A a self-assessment in contamination controls.
PS
- 1C The AIBAorganization was effectively evaluating and implementing radiation dose reduction measures and the health physics staff effectively used the employee ALARA concern program. Although ALARAinitiatives to minimize the radiological impact of hydrogen water chemistry (HWC) appeared comprehensive including the implementation of condensate filtration, shielding up-grades, contingencies for chemical decontamination, and improvements in work practices and scheduling, continued vigilance to assess and mitigate the radiological impact of HWC is warranted.
PS 1C Implementation ofthe licensee's site access authorization (AA)and Fitness-for-Duty (FFD) programs were reviewed. Afailure to allow an individual to review the psychological information contained in his file is considered a violation of NRC regulations of minor significance and is being treated as a non-cited violation.
FROM: 10/1/97 TO: 3/18/98 19 of 23 27 May 1998
Dafe ape Source
/D SFA Code
/fern Descripfion 12/8/97 Positive IR 97-09 N
PS 1A 2A 10/30/97 Positive IR 97-08 N
PS 1C 10/30/97 Positive IR 97-08 N
PS 3A
.The licensee maintained an effective security program. Management support was evident. Quality assurance audits were thorough and in-depth. Alarm station operators were knowledgeable and alert. Security equipment was tested and maintained in accordance with the security plan and security training was performed in accordance with the training and qualification plan. The provisions for land vehicle control measures satisfy regulatory requirements and licensee commitments.
Good communications throughout the emergency response facilities and with the Commonwealth of Pennsylvania.
Good command and control in all emergency response facilities.
10/30/97 Positive IR 97-08 N
PS 3B 3A The overall performance ofthe emergency response organization was good.
Simulated events were accurately diagnosed, proper mitigation actions were performed, emergency declarations were timely and accurate, and off-site agencies were notified promptly. No exercise weaknesses, safety concerns, or violations of NRC requirements were observed.
10/20/97 Positive IR 97-07 N
PS 5C An evaluation of condition reports (CRs), from the Unit 2 eighth refueling outage, concluded that there was no continuing trends regarding inadequate frisking practices with hand held monitors. The licensee's initial corrective actions for the identified weaknesses in the three CRs inspected were adequate.
FROM: 10/1/97 TO: 3/18/98 20 of 23 27 May 1998
SUSQUEIM&NA1R. 2 PEQPT ISSUES 1VIATRIX Date Type Source ID SFA Code Item Description 10/20/97 NCV IR 97-07 LER NCV97 Positive 04 LER 97 00 L
PS 10/20/97 Positive IR 97-07 N
PS 1C The licensee's programmatic response to a potential fire in the control room was reviewed and determined to rely on offnormal procedures which require the manual initiation of a CO2 fire protection system and the immediate evacuation ofthe control room. The controls established by the licensee to ensure that control room operators do not require the use of self contained breathing apparatus (SCBA), during a fire and/or habitability problem in the control room. These controls were determined to be adequate.
5A PPBL determined that the monthly surveillance to inspect fire hose stations had not-been completed within the frequency as required per TS Surveillance Requirement 4.7.6.5.a.
TSs require inspection ofthe fire hose stations listed in Table 3.7.6.5-1 at least once per 31 days. The frequency for performing this surveillance including the grace period was exceeded seven (7) times since January 1995.
In addition, while reviewing other surveillances that used a fixed schedule, itwas determined that the 6-month'surveillance of.fire hydrants had exceeded its frequency, including the grace period on one occasion since January 1995.
The cause of the event was determined to be that the scheduling tool used to track these surveillances used a fixed date each month forthe determination ofthe start of the surveillance instead of calculating the start date from when the surveillance was last performed.
Corrective actions include:
revising the method of tracking these suiveillances and discussion of this event with appropriate plant personnel.
This was,considered a licensee identified non-cited violation.
FROM: 10/1/97 TO: 3/18/98 21 of 23 27 May 1998
ABBREVIATIONSUSED IN PIN TABLE CO2 CR CS ECCS EDG HWC LER NRC PCQ RCIC SBLC TS VIO As-Low-As-Reasonably-Achievable Carbon Dioxide Condition Reports Control Structure Emergency Core Cooling System Emergency Diesel Generator Hydrogen Water Chemistry Licensee Event Report Nuclear Regulatory Commission Plant Control Operator Reactor Core Isolation Cooling Standby Liquid Control Technical Specification Violation FROM: 10/1/97 TO: 3/18/98 22of 23 27 May 1998
GENERAL DESCRIPTION OF PIM TABLECOLUMNS Date Type Source
/D SFA Code llcm Description The adual date ofan event or signifcant issue forthose items that have a char date ofoccurrence (mainly LERs), the date the source ofthe information was issued (such as for EALs), or the last date ofthe inspection period (for IRs).
The categorization ofthe item or finding - see the Type/Findings Type Code table, below.
The document that describes the findings: LER for Licensee Event Reports, EALfor Enforcement Action Letters, or IR for NRC Inspection Reports.
Identification ofwho discovered issue: N for NRC; Lfor Ucensee; or S forSelf Identifying (events).
SALP Functional Area Codes: OPS for Operations; MAINTfor Maintenance; ENG for Engineertng; and PS for Plant Support.
Template Code - see table below.
Details of NRC findings on LERs that have safety signmcance (as stated in IRs), findings described in IR Executive Summaries, and amplifying information contained in EALs.
TYPE/FINDINGS CODES ED Strength Weakness EEI
'lo NCV DEV Positive Negative LER URI" Licensing MISC Enforcement Discretion-No Cbnl Penalty Overall Strong Ucensee Performance Overall Weak Ucensee Performance Escalated Enforcement Item - Waiting Final NRC Action Violation Level I, 11 ~ ill,or IV NoaCited Yiotation Deviation from Ucensee Commitment to NRC Individual Good Inspection Finding Individual Poor Inspection Finding Ucensee Evenl Report to the NRC Unresolved Item from inspection Report Ucensing Issue from NRR Miscellaneous - Emergency Preparedness Finding (EP), Dechred Emergency, Nonconformance Issue, etc. The type of ail MISC findings are to be put in the item Description column.
TEMPLATECODES Operational Performance: A-Normal Operations; B -Operations During Transients; and C-Programs and Processes 2
Material Condition: A-Equipment Condition or B - Programs and Processes Human Performance: A-Work Performance; B - Knowledge, Skills, and Abilities/Training;C-Work Environment 4
Engineering/Design: A-Design; B - Engineering Support; C - Programs and Processes 5
Problem IdentiTication and Resolution: A-Identification; B -Analysis; and C - Resolution NOTES:
EEIs are apparent violations ofNRC requirements that are being considered for escalated enforoement action in accordance with the General Statement of Policy and Procedure for NRC Enforcement Action (Enforcement Policy), NUREG-1600. However, the NRC has not reached its final enforcement decision on the issues identified by the EEls and the PIM entries may be modified when the final decisions are made.
Before the NRC makes its enforcement decision, the
.!icensee willbe provided with an opportunity to either (1) respond to the apparent violation or (2) request a predecishnal enforcement conference.
URls are unresolved items about which more information is required to determine whether the issue in question Is an acceptable item, a deviation, a nonconformance, or a violation. However, FROM: 10/1/97 TO: 3/18/98 23 of 23 27 May 1998
the NRC has not reached its final conctusions on the issues, and the PlM entries may be modified when the final conctusions are made.
ENCLOSURE 2 SUSQUEHANNA INSPECTION PLAN FOR JUNE 1998 THROUGH OCTOBER 1998 Inspection'P 62706 IP-92904 IP 82701 IP 86750 IP 37001 IP 40500 IP 93809 IP 83750 IP 84750 IP 62707 IP 84750 Program Area/Title Maintenance Rule Team Followup to Fire Protection Operational Readiness of the Emergency Preparedness Program Solid Radwaste Management and Transportation of Radioactive Materials Engineering Team Operational Radiation Exposure-Non Outage Environmental Maintenance Observation Effluents Planned Dates 6/8/98 6/29/98 7/13/98 8/17/98 9/14/98 9/28/98 9/21/98 10/5/98 11/16/98 11/30/98 Type Inspection/Comments Mandatory Team Regional Initiative Core Core Core Core Core Regional Initiative Core Legend IP Tl Core Inspection Regional Initiative Inspection Procedure Temporary Instruction Minimum NRC Inspection Program (mandatory at all plants)
Additional Inspection Effort Planned by Region I
I