ML17164A729

Insp Repts 50-387/98-03 & 50-388/98-03 on 980428-0608. Violations Noted.Major Areas Inspected:Operations & Maintenance Activities

ML17164A729
Person / Time
Site:	Susquehanna
Issue date:	07/31/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17164A727	List: ML17164A726 ML17164A728 ML17164A729
References
50-387-98-03, 50-387-98-3, 50-388-98-03, 50-388-98-3, NUDOCS 9808110121
Download: ML17164A729 (36)

See also: IR 05000387/1998003

Text

US. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos:

License Nos:

50-387, 50-388

NPF-14, NPF-22

Report No.

50-387/98-03, 50-388/98-03

Licensee:

Pennsylvania Power and Light Company

2 North Ninth Street

Allentown, Pennsylvania

19101

Facility:

Susquehanna

Steam Electric Station

Location:

P.O. Box 35

Berwick, PA 18603-0035

Dates:

April 28 through June 8, 1998

Inspectors:

K. Jenison, Senior Resident Inspector

J. Richmond, Resident Inspector

A. Lohmeier, Senior Reactor Engineer

T. Burns, Reactor Engineer

Approved by:

Clifford Anderson, Chief

Projects Branch 4

Division of Reactor Projects

'P808iiOi2i 98073K

PDR

ADQCK 05000387

6

PDR

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EXECUTIVE SUMMARY

Susquehanna

Steam Electric Station (SSES), Units

1 5. 2

NRC Inspection Report 50-387/98-03, 50-388/98-03

This integrated inspection included aspects of Pennsylvania

Power and Light Company's

(PPS.L's) operations and maintenance activities at SSES.

The report covers a 6-week

period of resident inspection as well as a region based inspection.

~Oerations

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Operator activities in support of the Unit 1 shutdown for refueling, the Unit 1 restart

following refueling, and Unit 2 shutdown to repair the 2A recirculation pump were

adequate

and conservative.

(Section 01.1)

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The alignment of eight safety related systems were found to be adequate.

The

licensee conducted plant operations in accordance with SSES procedures,

and

established effective equipment alignment and operability.

(Section 01.2)

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Operators were observed to respond well to a selection of seven alarmed

conditions, including a loss of Residual Heat Removal system cooling and an

infrequently occurring condition (power coast down). Appropriate SSES procedures

were adhered to, operability and impact on plant equipment were controlled, and

actions were adequately performed, communicated and documented.

(Section

01.3)

Operator response to the discovery of a misaligned resin effluent valve was in

accordance with the PPSL

Equipment Status Control Event procedure. Operators

responded well and conservatively.

There was no safety impact associated with

the misaligned component.

(Section 02.1)

A sample of operator log entries was observed to be complete and accurate.

A

specific series of operator log entries accurately reported equipment status tag data,

Technical Specification requirements,

and condition report data.

(Section 02.2)

Twenty seven safety related initial Operability Determinations (ODs) and Condition

Reports (CRs) were reviewed in detail and were found to be'adequately

performed.

Two PPKL OD procedural requirements were not being consistently implemented by

the licensee (consideration of compounded deficiencies and all applicable operating

conditions).

Failure to implement these procedural requirements

has the potential

to affect the quality of ODs, but, no issues of safety significance were identified by

the inspectors in the selected sample.

(Section 04.1)

Maintenance

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Seventeen

of nineteen pre-planned maintenance

activities observed/reviewed

were

found to be appropriately conducted

and controlled; the remaining two maintenance

activities are discussed

in detail in other sections of this report.

Overall,

0

Executive Summary (cont'd)

maintenance

proced ural controls were determined to be general in nature and did

not prescribe some activities performed by maintenance

personnel.

Specifically,

performed activities for which there were no detailed guidance included; emergency

diesel generator

(EDG) valve grinding, valve lapping technique, and valve seat

tightness testing.

Each of these activities were identified by the inspectors

as

potential contributors to a failed EDG performance test.

(Section M1.1)

Two emergency diesel generator

(EDG) maintenance

activities were inadequate,

resulting in a violation of NRC requirements.

Under Work Authorization (WA)

H50056, dated February 6, 1996, maintenance technicians installed repair parts on

the "C" emergency diesel generator

(EDG) that had not received proper quality

receipt inspections and were potentially defective materials.

Under WA H70311,

dated September 26, 1997, maintenance technicians installed a defective EDG head

on the "A" EDG that had not received

a proper quality receipt inspection.

The

defective head caused

a February 3, 1998, EDG performance test abort.

(Section M1 A)

Inservice inspections

(ISI) were performed acceptably, with qualified personnel and

approved procedures.

In general, proper implementation, appropriate examination

documentation,

and adequate

PPRL oversight were observed.

The ISI were

thorough and of sufficient extent to determine the integrity of the components.

Non-

conforming conditions were adequately identified and reported for disposition.

However, two instances of work package problems were identified by the NRC,

including an outdated procedure

and an inaccurate qualification record, which

constituted

a violation of NRC document control requirements of minor safety

significance.

(Section M2.1)

Also, symptomatic of problems in work planning, on at least three occasions,

scheduled

NDE work was delayed from hours to a day due to various work planning

problems.

While these delays of themselves did not represent

a regulatory concern,

the high frequency of delays did appear to be related to weak work planning, which

could potentially affect the quality of NDE work, including As-Low-As-Reasonably-

Achievable (ALARA). (Section M2.1)

TABLE OF CONTENTS

EXECUTIVE SUMMARY

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iv

Summary of Plant Status

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I. Operations

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Conduct of Operations ...

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01.1

Operator Shift Activities

01.2

Operational Safety System Alignment

01.3

Operator's Response to Alarmed, Unexpected and Infrequently

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Performed Situations

01.4

Equipment Status Tags

Operational Status of Facilities and Equipment

02.1

Equipment Status Control Event - Valve Misalignment

02.2

Operator Logs

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Operator Knowledge and Performance .....

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04.1

Operability Determinations and Condition Report Action Items

Miscellaneous Operations, Issues

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Licensee Event Report Review ~.....

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II. Maintenance

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Conduct of Maintenance........ ~....... ~.......

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Pre-Planned

Maintenance ActivityReview.

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M1.2

Surveillance Test ActivitySample Reviews

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M1.3

Radiological Waste Supply Filter Replacement

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Repair of the "A" and "C" Emergency Diesel Generators

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Maintenance and Material Condition'of Facilities and Equipment

M2.1

Inservice Inspection Program..........

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V. Management Meetings....

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Exit Meeting Summary ..

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ATTACHMENT

Attachment

1 - Inspection Procedures

Used

- Items Opened, Closedand Discussed

- List of Acronyms Used

0

Re ort Details

Summer

of Plant Status

Susquehanna

Steam Electric Station (SSES) Unit 1 commenced

a power coast down,

plant shutdown, and a refueling and inspection outage prior to this inspection period.

On

June 5, 1998, Unit 1 began

a normal reactor startup from its 10th refueling and inspection

outage and continued throughout this inspection report period at 100% power.

Unit 2 operated at 100% during the inspection period, except for a forced outage, to

perform repairs on the 2A reactor recirculation pump seal, which began on June 6, 1998.

I. 0 erations

01

Conduct of Operations

'1.1

0 erator Shift Activities

a.

Ins ection Sco

e 71707

r

Routine activities of plant control operators

(PCOs), nuclear plant operators

(NPOs)

and unit supervisors

(USs) were observed throughout the inspection period.

b.

Observations

and Findin s

Routine operator activities were prescribed, concisely communicated,

and performed

in accordance with SSES operations department procedures.

Shift turnovers were

observed to be detailed and complete.

Operator activities in support of the Unit 1 refueling and inspection outage, the

Unit 1 restart following refueling, and Unit 2 shutdown to repair the 2A recirculation

pump were adequate

and conservative.

The inspectors discussed

plant conditions. with oncoming PCOs and USs following

shift turnovers and observed that sufficient information and status were transferred

to the oncoming shift to ensure the safe'operation of the units.

C.

Conclusions

Operator activities in support of the Unit 1 shutdown for refueling, the Unit 1 restart

following refueling, and Unit 2 shutdown to repair the 2A recirculation pump were

adequate

and conservative.

'Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline.

Individual reports are not expected to address

all outline topics.

1

2

01

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0 erational Safet

S stem Ali nment

a.

Ins ection Sco

e 71707

The inspectors observed plant operation to verify that the facility was operated

safely and in accordance with procedures

and regulatory requirements.

Inspectors

observed the control room alignment of selected safety related systems.

b.

Observations

and Findin s

The inspectors observed that the licensee conducted plant operations in accordance

with procedures,

and effective controls were implemented for safe plant operation.

Overall equipment operability, material condition, and housekeeping

conditions were

good.-

The alignment/operability of eight selected safety related systems including,

engineered safety features and on-site power sources were verified. Verification of

the functioning of a refueling heat sink (supplemental decay heat removal system)

was performed in the field and the control room.

The inspectors identified several minor housekeeping

and material condition items,

that did not affect system operability, and communicated the items to the licensee

for its review.

c.

Conclusions

The alignment of eight safety related systems were found to be adequate.

The

licensee conducted plant operations in accordance with SSES procedures,

and

established effective equipment alignment and operability.

01.3

0 erator's Res

onse to Alarmed

Unex ected and lnfre uentl

Performed Situations

a.

Ins ection Sco

e 71707

During control room observations, the inspectors observed/reviewed

PCO and US

response to alarmed, unexpected,

and infrequently performed situations to

determine compliance with Technical Specification (TS) and SSES operating

procedures.

b.

Observations

and Findin s

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Operator responses

to the seven alarmed conditions were observed to be aggressive

and in accordance with TSs and SSES operating procedures.

The control room staff

responded well to a loss of Residual Heat Removal system cooling to Unit 1.

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c.

Conclusions

Operators were observed to respond well to a selection of seven alarmed

conditions, including a loss of Residual Heat Removal system cooling and an

infrequently occurring condition (power coast down). Appropriate SSES procedures

were adhered to, operability and impact on plant equipment were controlled, and

actions were adequately performed, communicated and documented.

01.4

E ui ment Status Ta s 71707

The inspectors reviewed four equipment status tags that were in effect and/or being

applied to plant systems.

It was observed that the status tags were properly

prepared and authorized.

Some of the tags required supplemental

NRC review of

additional materials, to determine if the systems were still capable of performing as

designed; no violations of NRC requirements were identified.

02

Operational Status of Facilities and Equipment

02.1

E ui ment Status Control Event - Valve Misali nment

a.

Ins ection Sco

e 71707

The inspectors observed/reviewed

Shift Supervisor (SS), US, and Auxiliary System

Operator (ASO) response to a licensee identified misalignment of a Unit 1 resin tank

effluent line drain valve, which occurred during a Unit 1 reactor coolant system

hydraulic pressure test.

b.

Observations

and Findin s

Operator response, to the discovery of a valve misalignment, was in accordance

with the Equipment Status Control Event procedure, NDAP-QA-302. The system

was realigned and a condition report (CR) was initiated to determine root cause.

The inspectors observed the licensee responded to the misalignment conservatively

and in accordance with established

SSES procedures.

There was no safety impact

associated with this specific misaligned system.

c.

Conclusions

Operator response to the discovery of a misaligned resin effluent valve was in

accordance with the PP5L

Equipment Status Control Event procedure. Operators

responded well and conservatively.

There was no safety impact associated with

the misaligned component.

a.

Ins ection Sco

e 71707

During routine control room tours, the inspectors made detailed reviews of PCO,

US, Limiting Condition for Operations (LCO), BypassWork Around, and Equipment

Status logs.

b.

Observations

and Findin s

Overall, operator logs were observed to adequately document and discuss plant

conditions and events.

The inspectors questioned the completeness

of some log

entries, the age and necessity of some work arounds, status controlled plant

conditions, and bypasses,

but no safety impacts or violations of NRC requirements

were identified.

c.

Conclusions

A sample of operator log entries was observed to be complete and accurate.

A

specific series of operator log entries accurately reported equipment status tag data,

Technical Specification requirements,

and condition report data.

04

Operator Knowledge and Performance

04.1

0 erabilit

Determinations and Condition Re ort Action Items

a.

Ins ection Sco

e 71707

The inspectors reviewed a sample of Operability Determinations (ODs) and

Condition Report (CR) action items to determine if degraded conditions were

identified, were initiallyresolved with conservatism,

and long term corrective

actions were completed.

b.

Observations

and Findin s

Twenty seven CR corrective actions were reviewed.

Each of the CRs contained an

operability determination (OD).

In general, the ODs were found to have been

adequately performed.

The inspectors questioned the adequacy of one OD and had

two general findings with potential for significance.

The OD and two general

findings are discussed

below:

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OD for CR 98-1328, "C" Emergency Diesel Generator

(EDG) Air Start Valves

This OD was written in response to NRC concerns that repair parts (air start valve

components) were installed on the "C" EDG without a proper receipt inspection,

adequate control over the maintenance

installation activities or a detailed operability

determination.

The repair parts that did not receive proper receipt inspection and

control included components such as air start valves, valve springs, slide valves,

retaining devices, slide valve rings and valve seats.

The initial OD was limited to one component failure mode (failure of one air start

valve to open) and concluded that the "C" EDG was operable,

The OD concluded

in-head air start valves were provided in sufficient redundancy to ensure that the

EDG would start within acceptable

limits, and that the installation of these

components would not impact the ability of the EDG to start or accelerate.

The OD

analysis for the one failure mode was based upon operating experience related to a

stuck shut air start valve, system design features, test, results related to the failure

of air start valves to open on the "C" EDG, engineering judgement and a vendor

letter. The inspectors reviewed this initial OD and determined that for one

component failure mode (failed shut air start valve) the licensee analysis was

adequate.

However, the licensee did not address other failure modes of the potentially

defective components.

One component failure mode (failed open air start valve)

occurred on the "A" EDG just prior to the writing of the OD (see section M1.4 of

this report)

~ The inspectors determined that the initial OD did not address the ability

of the EDG to withstand a failed open air start valve, or other potential failures (ex.

FME from broken slide valve rings).

In addition, neither the vendor letter nor the

initial OD addressed

the ability of the "C" EDG to startup, load and run long term

with multiple potentially defective parts installed.

Subsequent to the

inspectors'uestions,

the licensee revised its initial OD.

The revised OD considered the impact defective parts could have on "C" EDG

operability and determined that the EDG was currently operable.

The revised OD

satisfactorily established that part failure was not expected based on the premise

that the EDG had successfully started and run approximately 50 times since the

application of the parts in question.

During these tests,

EDG performance was

adequate

including several run times of moderate length.

The inspector reviewed the revised OD and concluded that 50 successful starts

were statistically significant, and an indication that the component failure modes in

addition to a failed shut air start valve were not likely to occur in the future.

The

inspector determined that the revised OD was adequate

and that the "C" EDG was

operable.

General Finding 1, Compounding of Deficiency Conditions

NDAP-QA-703, section 5.2, indicated that ODs consider compounded conditions,

where each condition by itself may not result in a system structure or component

(SSC) in-operability but when taken together, may result in SSC in-operability.

In

addition, the procedure states that system interrelationships should be considered.

Section 6.3 of NDAP-QA-703 requires the consideration

be documented.

In the sample of CR ODs reviewed, the inspectors identified no instances where this

required action was performed and documented or was determined to not be

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applicable and documented.

Example:

In the case of the "C" EDG discussed

above, there were several outstanding WAs, performance test findings and CR

action items against "C" EDG when the CR OD was written. There was no

indication whether the review for compounded condition was applicable or was

performed.

With respect to the sample of CR ODs reviewed during this inspection,

no instances of compounded conditions affecting safety related equipment

operability were identified.

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General Finding 2, Operating Conditions

NDAP-QA-703, section 6.2, indicated that ODs evaluate the degraded condition for

impact on the component's function for all operating conditions.

Section 6.3 of

NDAP-QA-703 requires the evaluation be documented.

Based on the sample of CR ODs reviewed, the inspectors identified that some CR

ODs for safety related equipment did not document an evaluation of degraded

conditions for all applicable operating conditions, but focused on some mitigating

alignment or unit operating condition. With respect to the sample of CR ODs

reviewed during this inspection, no instances were identified where the failure to

consider all operating conditions affected the safe operation of the units.

C.

Conclusions

Twenty seven safety related initial Operability Determinations (ODs) and Condition

Reports (CRs) were reviewed in detail and were found to be adequately performed.

Two PPS.L OD procedural requirements were not being consistently implemented by

the licensee (consideration of compounded deficiencies and all applicable operating

conditions).

Failure to implement these procedural requirements

has the

potential

to affect the quality of ODs, but, no issues of safety significance were identified by

the inspectors

in the selected sample.

08

Miscellaneous Operations Issues

08.1

Licensee Event Re ort Review (92700)

Closed

LER 50-387 97-016

Fire Protection Surveillance Not Completed Within Time Required by Technical

Specifications

The licensee determined through an audit of the fire protection program that

monthly TS 4.7.6.5 surveillance requirements were not met.

The root cause of the.

failure to meet TS requirements was determined by the licensee to be the use of a

scheduling tool that incorporated

a fixed date for each surveillance instead of

calculating the start date from when the surveillance was last performed.

The inspectors evaluated (through direct inspection, interviews and observation) the

long term effect of the licensee's corrective actions, which included changes to the

scheduling method used by the licensee.

No instances were identified where

missed surveillance periods resulted in significant degraded equipment conditions.

The inspectors determined that the root cause of the missed surveillance was

inadequate control over work planning and scheduling of TS required activities.

A sample of other surveillance were performed and with the exception of response

time testing (see IR 50-387,388/97-03)no

other examples were identified. The

failure=to test fire system related equipment. in accordance with the schedule set by

TS had little safety impact.

This licensee identified and corrected event was treated

as a non-cited violation, consistent with Section VII.B.1 of the NRC Enforcement

Policy in NRC IR 50-387,388/97-07.

This LER is closed.

Closed

LER 50-387 97-017

Mis-positioned "A" Emergency Diesel Generator Governor Knob

On July 11,'1997, the NRC resident inspector identified a mis-positioned "A"

Emergency Diesel Generator (EDG) governor load control knob.

The mis-positioning

event, escalated

enforcement and the licensee's corrective actions were addressed

in NRC Ins'pection Report 50-387,388/97-06.

Based on direct inspection,

interviews and observation of the issues discussed

in this LER, the inspector

determined that the licensee adequately reported the mis-positioned component.

Other aspects of the issues identified in the LER are addressed

in NRC escalated

enforcement as discussed

in NRC Inspection Report 50-387,388/97-06.

This LER is

closed.

Closed

LER 50-387 97-008-00

Instrument Response

Time Testing

On March 26, 1997, with Unit 1 at 100% power and Unit 2 in refueling, PPSL

determined that the requirements of TS surveillances 4.3.1, 4.3.2, and 4.3.3 for

Response Time Testing were not fulfilled. In NRC IR 50-387,388/97-03,

the NRC

dispositioned

LER 50-387/97-008concerning

the identification that Technical

Specification Response

Time Testing requirements were not being met. A sample of

other surveillances was performed (using direct inspection, interviews and

observation of the issues)

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In reviewing this matter at other sites where it has not been dispositioned, the NRC

concluded that the PPRL LER was insufficient in that it did not address

an

inadequate

10 CFR 50.59 safety evaluation as a cause of not meeting the TS

requirements

and therefore did not specify any corrective actions proposed or taken

for the inadequate safety evaluation.

While the NRC is not reopening any

enforcement action pursuant to Section XIII of the NRC's Enforcement Policy, the

licensee

is requested to either supplement the LER or otherwise address

on the

docket SSES corrective actions taken or proposed for the failure of your 10 CFR 50.59 process to identify that the elimination of Response

Time Testing

requirements from the FSAR required a TS amendment.

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Closed

LER 50-387 97-018

Relay Logic Not Response Time Tested

On August 7, 1997, the licensee identified that specific relays related to two Unit-1

reactor building closed cooling water isolation valves had not been included in its

original response time testing program.

The appropriate tests were subsequently

completed acceptably.

The inspectors reviewed the licensee's corrective actions

(employing direct inspection, interviews and observation of the issues discussed

in

this LER) and determined that the identification of the untested relays was the result

of corrective actions for an violation identified in Inspection Report 50-387,388/97-

03. The subject violation addressed

the failure to perform TS testing.

The root

cause for this event was different that the root cause for the violation identified in

Inspection Report 50-387,388/97-03.

Therefore, this licensee identified and

corrected event was treated as a non-cited violation, consistent with Section VII.B.1

of the NRC Enforcement Policy. This LER is closed.

(NCV 50-387/98-03-01)

Closed

LER 50-387 97.-023

Fire Protection Surveillance Requirements Not Included In the Susquehanna

Surveillance Program

The license determined through an audit of the fire protection program that TS 4.7.6.3 surveillance requirements were not included in the SSES surveillance

program.

The root cause of the failure to meet TS requirements was determined by

the licensee to be the inadequate control of fire protection modification and

licensing processes.

The errors occurred between 1988 and 1991, and the

inspector verified that the present SSES controls, if properly implemented, would

have prevented the errors that occurred in the past.

The inspector reviewed the

licensee's corrective actions that included equipment testing, procedure changes

and training, and determined that the licensee's corrective actions were adequate.

No instances were identified where missed surveillances were followed by

significant degraded equipment conditions.

A sample of other surveillance was performed (using direct inspection, interviews

and observation of the issues) and with the exception of response time testing (see

IR 50-387,388/97-03)no

other examples of missed surveillances were identified.

The failure to test fire system equipment (seventeen

doors, carbon dioxide

suppression

equipment, detection equipment and one damper) in accordance with

the TS had little safety impact because

when tested, the equipment performed

appropriately.

Therefore, this licensee identified and corrected event was treated as

a non-cited violation, consistent with Section VII.B.1 of the NRC Enforcement

Policy. This LER is closed.

(NCV 50-387,388/98-03-02)

Closed

LER 50-387 96-015

4.16 KV Breakers Not in Dynamically Qualified Position

PPSL identified that Class-1E 4.16KV switchgear for both units were dynamically

qualified with breakers

in the racked in position only. With breakers in either the

racked out and installed in the cubicle position or the racked into 'test'osition, the

4.16KV switchgear would not be dynamically qualified due to inadequate

restraint

of the breaker in those positions.

PP&L determined, based on the breaker

alignment, that seven breakers were, at various times, in positions other than the

dynamically qualified position, which affected three out of four 4.16KV switchgear

busses

per unit.

Technical Specification 3.8.3.1 requires four load group channels of 4.16KV

switchgear to be operable with the reactor in Operation Condition 1, 2, and 3.

Since the seven breakers were in positions other than the dynamically qualified

position, three of the four 4.16KV switchgear busses

per unit were inoperable from

the time of each units's original startup until compensatory measures

were

implemented on November 5, 1996.

Failure to have the required operable load

group channels of 4.16KV switchgear is a violation of Technical Specification 3.8.3.1

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PP&L placed the switchgear in an analyzed configuration after the condition was

identified.

PP&L designed and installed modifications to secure open switchgear

cubicle doors and established

administrative controls for the position of breakers in

switchgear cubicles.

The inspectors concluded that the PP&L corrective actions

addressed

the violation.

The inspectors noted that excellent questioning attitude by PP&L led to

identification of the design deficiency, and ultimately resulted in issuance of NRC

Information Notice 97-53, Circuit Breakers Left Racked Out in Non-Seismically

Qualified Positions.

The issue also was not likely to be identified by routine PP&L

activities.

The corrective actions were comprehensive

and performed within a

reasonable time frame,

In accordance with Section VII.B.3 of the Enforcement

Policy, the NRC is exercising enforcement discretion and not citing the Technical specification 3.8.3.1 violation. This LER is closed.

(NCV 50-387/98-03-03)

II. Maintenance

Conduct of Maintenance

Pre-Planned

Maintenance Activit Review

Ins ection Sco

e 62707

The inspectors observed/reviewed

selected portions of pre-planned maintenance

activities, to determine whether the activities were conducted in accordance with

NRC requirements

and SSES procedures.

Observations

and Findin

s

Maintenance activities authorized by nineteen WAs were observed/reviewed

during

this inspection and seventeen

were found to be adequately performed.

In addition,

selected personnel qualifications, equipment permits (e.g., tagouts), procedures,

10

drawings, and/or vendor technical manuals associated with the maintenance

activities were also reviewed and found to be acceptable.

In general, maintenance

personnel were knowledgeable of their assigned activities.

Field supervision was

present for the observed activities.

The procedural guidance was general in nature

with references

identified to obtain detailed information.

Of the nineteen WAs, the inspector determined two WAs entailed inadequate

maintenance activities.

The two WA activities are discussed

in section M1.4

(H50056 and H70311) of this report. Seventeen

of nineteen pre-planned

maintenance activities observed/reviewed

were found to be appropriately conducted

and controlled.

Overall, maintenance

procedural controls were determined to be

general in nature and did not prescribe some activities performed by maintenance

personnel

~ Specifically, performed activities for which there were no detailed

guidance included; emergency diesel generator valve grinding, valve lapping

technique, and valve seat tightness testing.

Each of these activities were identified

by the inspectors as potential contributors to a failed emergency diesel generator

performance test.

Conclusions

Seventeen of nineteen pre-planned maintenance activities observed/reviewed

were

found to be appropriately conducted and controlled; the remaining two maintenance

activities are discussed

in detail in other sections of this report.

Maintenance

procedural controls were determined to be general in nature and did not prescribe

some activities performed by maintenance

personnel.

Specifically, performed

activities for which there were no detailed guidance included; emergency diesel

generator

(EDG) valve grinding, valve lapping technique, and valve seat tightness

testing.

Each of these activities were identified by the inspectors as potential

contributors to a failed EDG performance test.

Surveillance Test Activit Sam

le Reviews (61726)

The inspectors observed/reviewed

selected portions of seven surveillance activities.

The observed/reviewed

surveillance activities were determined to conform to the

requirements of TS and met PP&L administrative requirements (i.e., approvals,

personnel qualifications, scheduling, and permits).

Components were properly

removed from service and, when appropriate, the TS LCOs were documented

and

met.

The surveillance activities were determined to have been accomplished by

qualified and trained personnel.

No violations of NRC requirements were identified.

Radiolo ical Waste Su

I

Filter Re lacement

(62707)

Maintenance activities authorized by WAs P71811, S71372, and S72260 were

reviewed, specifically to evaluate the job task certification of assigned maintenance

personnel.

The maintenance

activities that were reviewed were performed by

mechanical, electrical, and instrument maintenance technicians.

For those activities

requiring specific certification, safety related activities, and activities identified by

11

detailed descriptions

in the WAs, the inspectors concluded that the technicians

were adequately trained and certified.

In one non safety related activity, a temporary differential pressure measurement

device, dwyer manometer, was applied around an installed non-safety related

instrument.

The temporary differential pressure

measurement

device was applied by

. electricians, who did not possess

required specific certification to install the

equipment.

A permit was r'equired by licensee procedures but was not applied.

Because there was no impact on the equipment, subsequent

functional tests of the

installed differential measurement

devices were acceptable,

the equipment was not

safety related and the actions taken were reviewed and approved by qualified first

line supervisors representing

all three crafts, there was no violation of NRC

requirements.

As part of the inspection of WA P71811, the inspector reviewed a sample of the

task certification and training records for mechanical, electrical and instrument

maintenance technicians and maintenance first line supervisors.

The inspector

concluded that for safety related activities, the task certification and training

processes

were accredited, met current industry standards

and were adequately

implemented.

M1.4

Re air of the "A" and "C" Emer enc

Diesel Generators

Ins ection Sco

e 62707

The inspectors observed/reviewed

selected portions of pre-planned emergency

diesel generator

(EDG) maintenance activities, and corrective EDG maintenance to

determine whether the activities were conducted in accordance with NRC

requirements

and SSES procedures.

Following a February 3, 1998, emergency diesel generator (EDG) maintenance test

abort, the inspectors reviewed; the licensee's corrective actions for the test abort,

the corrective maintenance activities following the test abort, and the root cause of

the test abort (note: the root cause of the 1998 test abort was related to a previous

1996 failure to adequately control EDG maintenance

activities).

Observations

and Findin s

EDG maintenance

activities were determined to have resulted in two examples of a

violation regarding receipt control inspections of quality material

~

1998 Maintenance Test Abort - "A" EDG Re airs - WA H70311

On September 26, 1997, Work Authorization (WA) H70311 was established to

perform routine maintenance activities on the "A" EDG. Following completion of

these maintenance activities, the "A" EDG underwent

a maintenance test on

February 3, 1998. After approximately 40 minutes of operation at low load (800

kW) nuclear plant operators

(NPOs) noticed indications of overheating on the air

12

start manifold adjacent to the "8L" cylinder. The test was aborted and the EDG

was manually shutdown from the local panel.

The licensee removed the head near the overheated

air start manifold and

determined that the air start valve had stuck in the open position.

The licensee

initiated an Event Review Team (ERT), a root cause evaluation, and Condition

Report 98-0351

~ The inspectors attended one of the ERT working meetings and

reviewed the licensee's root cause activities,

The licensee's activities were

determined to be detailed and conservative with respect to the physical

determination of the failure and the implementation of corrective maintenance.

The aborted maintenance test was caused by a defective EDG head returned from

the PPRL vendor (Cooper).

The EDG head was defective since foreign material was

contained in the repaired EDG head.

The foreign material was not identified in the

PPS.L receipt inspection process.

10 CFR 50, Appendix B, Criterion Vill, Identification and Control of Materials, Parts

and Components,

in part, required that measures

shall be established for the

identification and control of parts and components.

These measures

shall be

designed to prevent the use of incorrect or defective material, parts, and

components.

PPKL procedure, NDAP-QA-0201, Material Control Activities, established the

requirements for receipt inspection for quality materials, and stated that all quality

materials shall be forwarded to the receipt inspection group for inspection in

accordance with procedure NP-QA-0401, Receiving Inspection.

NP-QA-0401,

section 6.1, required', in part, visual inspections for physical damage and

cleanliness.

On September 26, 1997, Work Authorization (WA) H70311 was established to

perform routine maintenance activities on the "A" EDG. The maintenance

activities

installed a defective EDG head that was not receipt inspected

in accordance with

NP-QA-0401, in that the head was not clean and the receipt inspection was not

adequate to identify the foreign material in the,EDG head.

The foreign material

resulted in the defective EDG head which subsequently

caused

an aborted EDG

performance test.

The failure to perform an adequate receipt inspection is example

(a) of a violation of NRC requirements.

(VIO 50-387,388/98-03-04(a))

As part of the inspectors'eview of the 1998 event, a 1996 EDG maintenance

activity was identified which also involved inadequate receipt inspection of safety

related repair parts.

1996 Maintenance Activit - "C" EDG Re

air Parts Recei t Control - WA H50056

On February 6, 1996, WA H50056 was established to perform maintenance

activities on the "C" EDG.

Maintenance technicians installed repair parts that had

not received proper quality receipt inspections.

These repair parts were potentially

defective material.

13

The inspectors identified that on March 5, 1996, a PPSL vendor (Cooper) returned

to the licensee certain air start valves and associated

components,

under service

order 5-54297-5.

The vendor provided documentation stating that they had not

treated these components

as quality materials.

About half of the components were

determined to be damaged and/or otherwise rejected by maintenance technicians

repairing the "C" EDG. However, the other half of the components were installed

on the "C" EDG without receiving receipt inspection from the receipt inspection

group.

10 CFR 50, Appendix B, Criterion Vill, Identification and Control of Materials, Parts

and components,

requires, in part, that measures

shall be established for the

identification and control of parts and components.

These measures

shall assure

that identification of the item is maintained by an appropriate means, either on the

item or on records traceable to the item. These identification and control measures

shall be designed to prevent the use of incorrect or defective material, parts, and

components.

PP&L procedure, NDAP-QA-0201, Material Control Activities, established the

requirements for receipt inspection for quality materials, and stated that all quality

materials shall be forwarded to the receipt inspection group for inspection in

accordance with procedure NP-QA-0401, Receiving Inspection.

NP-QA-0401,

section 6.1, required, in part, item inspections to assure that; item identification and

markings were in accordance with procurement document requirements; applicable

codes and standards were met and vendor specifications were met.

Although the vendor provided documentation with the repair parts stating that they

had not treated the components

as quality materials, the returned parts were

received by SSES maintenance

personnel and were installed into safety related

equipment ("C" EDG) without the receipt inspection group performing the required

receipt inspection.

The failure to perform the required receipt inspections prior to,

installing the safety related repair parts in,the "C" EDG is example (b) of a violation

of NRC requirements.

(VIO 50-387,388/98-03-04(b))

Conclusions

Two emergency diesel generator

(EDG) maintenance

activities were inadequate,

resulting in a violation of NRC requirements.

Under Work Authorization (WA)

H50056, dated February 6, 1996, maintenance technicians installed repair parts on

the "C" emergency diesel generator

(EDG) that had not received proper quality

receipt inspections and were potentially defective materials.

Under WA H70311,

dated September 26, 1997, maintenance technicians installed a defective EDG head

on the "A" EDG that had not received

a proper quality receipt inspection.

The

defective head caused

a February 3, 1998, EDG performance test abort.

M2

Maintenance and Material Condition of Facilities and Equipment

M2.1

Inservice lns ection Pro ram

a.

Ins ection Sco

e 73753

The inspector reviewed plans and schedules for the current inservice inspection (ISI)

interval (first outage, second interval, second period) to verify compliance with the

requirements of ASME Section XI and 10 CFR 50.55a(g).

Specific areas inspected

included ASME Section XI ISI program coverage, qualifications and certifications of

the non destructive examination (NDE) personnel,

ISI NDE procedures

and

examination results.

In addition, the inspectors observed selected

NDE activities,

including ultrasonic test (UT) of two main steam line welds and one reactor vessel

head spray line weld, liquid penetrant test (LP) of one head spray weld and

magnetic particle test (MT) of two main steam welds.

b.

Observations

and Findin s

NDE contractors performed ISI examinations and PPSL provided oversight which

involved review and approval of qualifications and procedures,

and monitoring of

selected tests.

The inspector found the ISI work activities to be performed

acceptably.

The'ISI ultrasonic, liquid penetrant and magnetic particle test

procedures were approved by both the ISI contractor and PPRL, and were

determined by the inspectors'to

be in accordance with the ASME Code

requirements.

The inspectors found the inspection implementation consistent with the approved

procedures.

The personnel qualification records for six NDE inspectors were

examined and found to be in compliance with the ASME code requirements.

Based

on selected

NRC inspections of two head spray welds, PP&L oversight of contractor

NDE activities was found to be adequate.

During the inspection of qualification records, the quality of work packages

was

also inspected by NRC. The inspector identified two instances

in which the quality

of work packages

was inadequate

and the requirements of 10 CFR 50, Appendix B,

Criterion Vl were not met.

In one case,

an ISI Level II examiner was prepared to perform the magnetic

particle test of welds VNBB211-20-Land VNBB211-20-Pin the main steam

system, using an outdated revision (revision-9) of PPRL procedure NMTWD-

1.

In response to the NRC identifying this issue, licensee personnel obtained

the correct revision of the procedure (revision-10)

~ The out of date

procedure was not used to perform safety related work.

In the second case, the inspector noted errors in the certification

documentation for a Level II ultrasonic examiner.

Performance

Demonstration Initiative (PDI) certificate 332 issued by the Electric Power

15

Research Institute (EPRI), which attested to the qualification of the examiner

in the use of Generic Procedure for the Ultrasonic Examination of Ferritic Pipe

Welds, PDI-UT-1, Revision B, Addenda 0, was found to have errors regarding

the demonstrated

ranges of diameter and thickness.

The documentation had

been issued by EPRI, reviewed and accepted

by the contractor,'and

accepted

by PPSL.

The acceptance

of such errors by PPSL indicated an inadequate

review of contractor qualification records.

These issues constitute

a violation of minor significance and is not subject to formal

enforcement action.

Also, symptomatic of problems in work planning, the inspector noted that on at

least three occasions,

scheduled

NDE work was delayed from hours to a day due to

various work planning problems.

While these delays of themselves

did not

represent

a regulatory concern, the high frequency of delays did appear to be

related to weak work planning, which could potentially affect the quality of NDE

work, including As-Low-As-Reasonably-Achievable

(ALARA)~

Examination data and documentation were reviewed and found to be in accordance

with the ISI procedures

and ASME Code requirements.

NDE personnel performing

inspections had properly identified and recorded indications and, where applicable,

had processed

and re-examined those indications evaluated

as non-relevant.

Non-

conforming conditions were identified, explored for relevance,

and reported on PPS,L

ISI Notification Form 98-010. A Condition Report was initiated as a result of one

non-conforming condition. The tracking of ISI examination results indicated that the

ISI program was in compliance with the ASME Code,Section XI for the specified

penod.

Conclusions

Inservice inspections

(ISI) were performed acceptably, with qualified personnel and

approved procedures.

In general, proper implementation, appropriate examination

documentation,

and adequate

PP&L oversight were observed.

The ISI were

thorough and of sufficient extent to determine the integrity of the components.

Non-

conforming conditions were adequately identified and reported for disposition.

However, two instances of work package problems were identified by the NRC,

including an outdated procedure and an inaccurate qualification record, which

constituted

a violation of NRC document control requirements of minor safety

significance.

Also, symptomatic of problems in work planning, on at least three. occasions,

scheduled

NDE work was delayed from hours to a day due,to various work planning

problems.

While these delays of themselves

did not represent

a regulatory concern,

the high frequency of delays did appear to be related to weak work planning, which

could potentially affect the quality of NDE work, including As-Low-As-Reasonably-

Achievable (ALARA).

0

0

16

V. Mana ement Meetin

s

X1

Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management

at an exit meeting on June 9, 1998.

The licensee acknowledged the findings

presented.

The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary.

No proprietary information was

identified.

ATTACHMENT1

INSPECTION PROCEDURES USED

IP 37551

IP 61726

IP 62707

IP 71707

IP 73753

IP 92700

Onsite Engineering Observations

Surveillance Observations

Maintenance Observations

Plant Operations

Inservice Inspection

On Site Followup of Reports

ITEMS OPENED, CLOSED, and DISCUSSED

~Oened

50-387,388/98-03-04

VIO

"A" 5. "C" Emergency Diesel Generator Repairs

(section M1.4)

Closed

50-387,388/98-03-02

50-387/98-03-03

NCV

Fire Protection Surveillance Requirements Not Included

In the Susquehanna

Surveillance Program (section'08.1)

NCV

4.16 KV Breakers Not in Dynamically Qualified Position

(section 08.1)

, 50-387/98-03-01

50-387/96-01 5

50-387/97-01 6

50-387/97-01 7

50-387/97-01 8

50-387/97-023

NCV

Relay Logic Not Response

Time Tested (section 08.1)

LER

4.16 KV Breakers Not in Dynamically Qualified Position

(section 08.1)

LER

Fire Protection Surveiltances Not Completed Within

Time Required by Technical Specifications (section

08.1)

LER

Mis-positioned "A" Emergency Diesel Generator

Governor Knob (section 08.1)

LER

Relay Logic Not Response

Time Tested (section 08.1)

LER

Fire Protection Surveillance Requirements Not Included

In the Susquehanna

Surveillance Program (section 08.1)

Attachment

1

LIST OF ACRONYMS USED

ALARA

ASME

ASO

CFR

CR

EDG

EEI

EPRI

ERT

FSAR

HPCI

IR

ISI

KV

kw

LCO

LER

LP

MT

NCV

NDAP

NDE

NOV

NPO

NRC

NSAG

NSE

OD

PCO

PDI

PORC

psIg

QA

SDHR

SLC

SR

SRV

SS

SSES

TS

URI

US

UT

VIO

WA

As-Low-As-Reasonably-Achievable

American Society of Mechanical Engineers

AuxiliarySystems Operator

Code of Federal Regulations

Condition Report

Emergency Diesel Generator

Escalated

Enforcement Item

Electric Power Research Institute

Event Review Team

Final Safety Analysis Report

High Pressure

Coolant Injection

[NRC] Inspection Report

Inservice Inspection

Kilovolts

Kilowatts

Limiting Condition for Operation

Licensee Event Report

Liquid Penetrant Test

Magnetic Particle Test

Non-Cited Violation

Nuclear Department Administrative Procedure

Non-destructive Examination

Notice of Violation

Nuclear Plant Operator

Nuclear Regulatory Commission

Nuclear Safety Assessment

Group

Nuclear System Engineering

Operability Determination

Plant Control Operator

Performance Demonstration Initiative

Plant Operations Review Committee

pounds per square inch gauge

Quality Assurance

Supplemental Decay Heat Removal

Standby Liquid Control System

surveillance Requirement

Safety Relief Valve

Shift Supervisor

Susquehanna

Steam Electric Station

Technical Specification

[NRC] Unresolved Item

Unit Supervisor

Ultrasonic Test

Violation

Work Authorization