ML17164A765
| ML17164A765 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/24/1998 |
| From: | Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML17164A766 | List: |
| References | |
| 50-387-98-04, 50-387-98-4, 50-388-98-04, 50-388-98-4, EA-98-350, NUDOCS 9809010201 | |
| Download: ML17164A765 (5) | |
See also: IR 05000387/1998004
Text
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CATEGORY
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I
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSXON NBR:9809010201
DOC.DATE: 98/08/24
NOTARIZED: NO
FACXL:50-387 Susquehanna
Steam Electric Station, Unit 1, Pennsylva
50-388
Susquehanna
Steam Electric Station, Unit 2, Pennsylva
AUTH.NAME
AUTHOR AFFILIATION
WIGGINS,J.T.
Region
1 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
BYRAM,R.G.
Power
& Light Co.
SUBJECT: Discusses
insp repts
50-387/98-04
&. 50-388/98-04
on 980808-
12
& forwards notice
of violation.
DISTRIBUTION CODE:
IEOID
COPIES
RECEIVED:LTR J
ENCL $
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
DOCKET ¹
05000387
05000388
05000387
RECIPIENT
ID CODE/NAME
PD1-2
INTERNAL: ACRS
AEOD/~T.
NT-
NRR/DRPM/PECB
NUDOCS-ABSTRACT
OGC/HDS2
TERNAL: LITCO BRYCE,J H
NRC
COPIES
LTTR ENCL
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2
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RECIPIENT
ID CODE/NAME
NERSES,V
AEOD/SPD/RAB
DEDRO
NRR/DRCH/HOHB
NRR/DRPM/PERB
OE DIR
RGN1
FILE
01
NOAC
NUDOCS FULLTEXT
COPIES
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NOTES:
E
NOTE TO ALL "RZDS" RECZPZENTS:
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
DESK
(DCD)
ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
20
ENCL
20
August 24,
1998
EA 98-350
Mr. Robert G.
Byram
Senior Vice President - Nuclear
Pennsylvania Power & Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
SUBJECT:
NOTICE OF VIOLATIONAND EXERCISE OF ENFORCEMENT DISCRETION
(NRC INSPECTION REPORT NOS. 50-387/98-04 &50-388/98-04)
Dear Mr. Byram:
This letter refers to the NRC inspection conducted at the Susquehanna
Steam Electric Plant during the week of June 8, 1998. The purpose of the inspection was
to review your maintenance
rule implementation in accordance with 10 CFR 50.65.
During
the inspection, apparent violations were identified related to the failure to properly
implement the maintenance
rule. The findings of the inspection were discussed with
members of your staff at the conclusion of the inspection on June 12, 1998, and the
inspection report addressing these issues was sent to you on July 16, 1998. Our letter
indicated that we were still making a decision on enforcement matters and the purpose of
this letter is to provide you with the results of our deliberations.
Based on the results of this inspection, the NRC has determined that a violation of NRC
requirements occurred.
This violation is cited in the enclosed Notice of Violation (Notice)
and the circumstances
surrounding it is described in detail in the subject inspection report.
The violation involved failure to include in the scope of the Maintenance Rule program, as
required by 10 CFR 50.65(b), the Bypass Indication system which is a safety related
display instrumentation system.
The violation was identified by the NRC and has been
categorized
as Severity Level IV in accordance with the "General Statement of Policy and
Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, Revision 1,
May 1998.
Further, during your self-assessment
of your maintenance
rule program, you identified
significant performance weaknesses
and inadequacies
in implementing the maintenance
rule. The identified deficiencies included examples of failure to demonstrate effective
preventive maintenance
and failure to include structures, systems and components
(SSCs)
in the scope of the maintenance
rule program, failure to place systems into an (a)(1) status
in a timely manner when it was evident that preventive maintenance was not effective,
failure to consider all modes of operation when determining risk significance of SSCs,
>
j
failure to establish adequate
performance criteria for demonstrating the effectiveness of
maintenance
and failure to perform an adequate
periodic assessment.
For example, you
identified that the instrument air system, the standby liquid control system, the control
room emergency outside air supply system, the "A"standby emergency diesel generator
'P8090i020i
980824
ADQCK 05000387
8
Mr. Robert G.
Byram
and the reactor manual control system were not placed into an (a)(1) status until
May 1998, but should have been placed in (a)(1) in July 1996. It was apparent that your
organization was not in compliance with the maintenance
rule as of July 10, 1996 when
the rule became effective.
The NRC recognizes that considerable progress was made in
the months prior to the subject inspection.
Nonetheless,
these violations collectively
represented
an initial programmatic breakdown in the development and implementation of
the Rule.
These violations were considered for escalated enforcement action in accordance with the
Enforcement Policy and due to the programmatic nature of the deficiencies would normally
have resulted in a Severity Level III violation. However', after consultation with the
Director, Office of Enforcement, and the Regional Administrator, I have been authorized to
not issue a Notice-of Violation and not propose
a civil penalty (for the violations identified
by your organization) in accordance with the provisions provided in Section VII.B.6of the
Enforcement Policy. The decision to exercise discretion was made in consideration of the
facts that: (I) your self-assessment
identified the deficiencies in your maintenance
rule
program;
(2) your corrective actions to address the weaknesses
were reasonably prompt
and comprehensive after identification; (3) there was little actual adverse impact on system
performance as a result of the deficiencies in your program; and (4) at the time of the
inspection, your maintenance
rule program and implementation were in compliance with
10 CFR 50.65 with the exception noted above.
Although the NRC identified a violation
during the inspection, this deficiency was not indicative of a continuing programmatic
breakdown.
Rather, it appeared that you had not had a chance to review your corrective
actions for effectiveness.
You are required to respond to this letter and should followthe instructions in the enclosed
Notice. The NRC will use your response,
in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter
and its enclosures will be placed in the NRC Public Document Room (PDR).
Your cooperation with us is appreciated.
Sincerely,
James T. Wiggins, Director
Division of Reactor Safety
Docket Nos.: 50-387 & 50-388
License Nos.: NPF-14 &, NPF-22
Enclosure:
Mr. Robert G.
Byram'c
w/encl:
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
Mr. Robert G.
Byram
Distribution w/encl:
Region
I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
H. Miller, RA/W. Axelson, DRA (1)
J. Wiggins, DRS
L. Nicholson, DRS
R. Conte, DRS
H. Williams, DRS
C. Anderson, DRP
D. Florek, DRP
R. Junod, DRP
D. Holody, DRS
NRC Resident Inspector
PUBLIC
DRS File
Distribution w/encl (VIAE-NAIL):
B. McCabe, OEDO
V. Nerses, Project Manager, NRR
D. Brinkman, NRR
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR
F. Talbot, NRR
F. Davis, OGC
A; Nicosia, OGC
J. Lieberman, OE (OEMAIL)
R. Zimmerman, ADPR, NRR
M. Campion, ORA
DOCDESK
DOCUMENT NAME: G:iOLHPiWILLIAMSiSUSQ9804,NOV
To receive a copy of this document,
indicate in the box:
"C" ~ Copy without attachment/enctosure
"E" = Copy with attachment/enctosure
N" ~ No
copy
OFFICE
RI/ORA
Rl/DR
OE i/i~ $ .//">
NRR b.t)A
NAME
TWalker
HWilliams/RCo te
Nelson/Borchardt
DAshley/R orreia
He
DATE
08/1 8/9
OFFICE
RI/DRS
E
JWiggins
E
08/20/98
08//
98
08/
/98
08
/98
08/
/98
OFFICIAL RECORD COPY
08/I /98
08/
/98
8/
/98
08/
/98