ML17164A731
| ML17164A731 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/06/1998 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML17164A732 | List: |
| References | |
| 50-387-98-08, 50-387-98-8, 50-388-98-08, 50-388-98-8, EA-98-300, NUDOCS 9808130273 | |
| Download: ML17164A731 (9) | |
See also: IR 05000387/1998008
Text
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CATEGORY 2
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9808130273
DOC.DATE: 98/08/06
NOTARIZED: NO
ACXL:50-387
Susquehanna
Steam Electric Station, Unit 1, Pennsylva
50-388
Susquehanna
Steam Electric Station, Unit 2, Pennsylva
AUTH.NAME
AUTHOR AFFILIATION
HEHL,C.W.
Region
1 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
BYRAM;R.G~
Power
&. Light Co.
DOCKET ¹
05000387
0'5000388
SUBJECT:
Forwards insp repts
50-387/98-08
&. 50-388/98-08
on
980601-30
& NOV.Purpose of insp was to review issues
re mod
of EDG .fuel oil sys in 1990
& subsequent
controls <imposed
upon diesel
day tank volume.
DISTRIBUTION CODE: IEOIP
COPIES
RECEIVED:LTR J
ENCL j
SIZE: 3 T 2
TITLE: General
(50 Dkt) -Insp Rept/Notice of Violation Response
NOTES:
05000387
RECIPIENT
ID CODE/NAME
PD3:-2
INTERNAL: ACRS
A
NRR/DRPM/PECB
NUDOCS-ABSTRACT
OGC/HDS2
COPIES
LTTR ENCL
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EXTERNAL: LITCO BRYCE,J H
NRC PDR
1
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NOAC
NUDOCS FULLTEXT
NOTES:
Lo>>>awol
, NBC FL,OPPy
NOTE TO ALL "RZDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL
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(DCD)
ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
20
ENCL
20
August 6,
1998
EA 98-300
Mr. Robert G. Byram
Senior Vice President - Nuclear
Pennsylvania Power & Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
SUBJECT:
NRC SPECIAL INSPECTION REPORT 50-387/98-08, 50-388/98-08;
NOTICE OF VIOLATION;AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Byram:
On June 30, 1998, the NRC completed
a special inspection at your Susquehanna
Steam
Electric Station (SSES)
1 5, 2 reactor facilities. The purpose of this inspection was to
review the issues related to the modification of the emergency diesel generator fuel oil
system in 1990, and the subsequent
administrative controls imposed'upon the diesel day
tank volume. We also reviewed the planned and completed corrective actions for these
issues.
The enclosed report presents the results of this inspection.
The inspectors
discussed
the findings of this inspection with Mr. R. Saunders,
Vice President Nuclear
Operations,
and others of your staff at the exit meeting on July 2, 1998.
Based on the results of this inspection, the NRC has determined that two violations of NRC
requirements occurred.
The first violation was for failure to effect timely resolution of a
nonconformance
in the emergency diesel generator fuel oil system and is cited in the
enclosed Notice of Violation (Notice).. The circumstances
surrounding this violation are
described in detail in the subject inspection report.
This violation is of concern because
the
nonconformance was originally identified by your staff in 1990, but remained uncorrected
and was re-identified in, 1998, by the NRC.
The second violation was for a failure to meet the requirements of 10 CFR 50.59, in that
you did not obtain NRC approval prior to implementing a plant modification which involved
an unreviewed safety question.
After consideration of this issue, the NRC has concluded
that this issue would be normally classified as a Severity Level IV violation. However, after
consultation"with the Director, Office of Enforcement,
I have been authorized to not issue
a
Notice of Violation in accordance with the provisions provided in Section VII.B.6 of the
NRC's Enforcement Policy. This decision for the 50.59 issue was made after consideration
that:
(1) this 8-year old issue did not represent
a significant unreviewed safety question,
because it involved an insignificant reduction of a margin of safety defined in a TS basis,
and (2) PPRL, although incorrect in its determination that prior NRC approval was not
required, did inform the NRC by letter of its determination to perform the modification prior
to submitting a TS change.
'7808130273
980806
ADGCK 05000387
6
OFFICIAL RECORO
COPY
IE: 01
Robert G. Byram
2
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response.
The NRC will use your response,
in part,
to determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
In the PPS.L July 1, 1998 document provided to the resident inspector, "Evaluation of NRC
Questions on Emergency Diesel Generator Fuel Oil Day Tanks," which is attached to the
inspection report, your staff indicated that PPS.L would "not implement the same
modification today without requesting
a Tech Spec change from the NRC." In your
response to this letter, we request that you confirm that the PPKL 50.59 safety evaluation
process
has the necessary
provisions to assure that in future modifications that create
a
condition that would cause technical specifications to be non-conservative,
PPSL would
obtain NRC approval prior to implementation of the modification.
In addition, you are
requested to identify and evaluate any similar occurrences,
where a license amendment
submittal has not already been made, where administrative controls are being used to
supplement technical specification requirements because the technical specification
requirement is either non-conservative
or insufficient to verify compliance with the
associated
design basis.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter,
its enclosure(s),
and your response will be placed in the NRC Public Document Room
(PDR).
Sincerely,
Original Signed
by:
Charles W. Hehl, Director
Division of Reactor Projects
Docket Nos.: 50-387;50-388
License Nos:
Enclosures:
2. Inspection Report 50-387/98-.08, 50-388/98-08
Robert G. Byram
cc w/encls:
3
R. F. Saunders,
Vice President - Site Operations
G. T. Jones, Vice President - Engineering and Support
G. Kuczynski, General Manager - SSES
J. M. Kenny, Supervisor, Nuclear Licensing
G. D. Miller, General Manager - Nuclear Engineering
R. R. Wehry, Nuclear Licensing
F. P. Arcury, 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
Robert G. Byram
w
Distnbution
/encls:
Region
I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
B. Boger, ADPR, NRR
J. Goldberg, OGC
.J. Lieberman, OE (OEMAIL)
D. Holody, ORA
T. Walker, SES
H. Miller, RA/W. Axelson, DRA
C. Anderson, DRP
D. Florek, DRP
R. Junod, DRP
NRC Resident Inspector
PUBLIC
Distribution w/encls: (Via E-Mail)
B. McCabe, OEDO
V. Nerses, Project Manager, NRR
D. Brinkman, NRR
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR
, F. Talbot, NRR
M. Campion, ORA
DOCDESK
DOCUMENT NAME: G:iBRANCH4~tSUS9808. INS
To receive a copy of this document, Indicate In the box:
C
~ Copy without attachment/enclosure
E" ~ Copy with attachment/enclosure
N
~ No copy
OFFICE
Rl/
NAME
K "ni
n
DATE
07/') /98
Rl/DRP
Q
CAnde s
n
07/ 0/98
RI/OR
DHolo +r
07/gq /98
J'b
an
0 /
/98
RI/DRP
0 /
/98
OFFICIAL RECORD COPY
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ru(L
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Robert G. Byram
Distribution w/encls:
Region
I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
B. Boger, ADPR, NRR
J. Goldberg, OGC
J. Lieberman, OE (OEMAIL)
D. Holody, ORA
T. Walker, SES
H. Miller, RA/W. Axelson, DRA (1)
C. Anderson, DRP
D. Florek, DRP
R. Junod, DRP
NRC Resident Inspector
PUBLIC,
Distribution w/encls: (Via E-Mail)
B. McCabe, OEDO
V. Nerses, Project Manager, NRR
D. Brinkman, NRR
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR
F. Talbot, NRR
M. Campion, ORA
DOCDESK
DOCUMENT NAME: G IBRANCH4IISUS~ISUS9808.INS
"See previous concurrences
To receive a copy of this document, Indicate In the box: "C" ~ Copy without attachment/enclosure
"E
~ Copy with attachment/enclosure
N
No copy
OFFICE
"RI/DRP
"RI/DRP
NAME
KJenison/DF for
CAnderson/CA
"RI/ORA
DHolody/TW
for
"OE
JLieberman
/OE
concurrenc
e
w/comment
s via e-mail
8/3/98
comments
incorporate
d
% RI/DRP
CHehl/CH
DATE
07/29/98
07/29/98
07/29/98
08/03/98
08/06/98
OFFICIAL RECORD COPY
0