ML17164A901

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Notice of Violation from Insp on 980914-1002.Violation Noted:On 981002 PP&L Had Not Ensured That Facility Design Basis Was Correctly Translated Into Accident Analyses
ML17164A901
Person / Time
Site: Susquehanna  
Issue date: 11/13/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17164A900 List:
References
50-387-98-05, 50-387-98-5, 50-388-98-05, 50-388-98-5, NUDOCS 9811240050
Download: ML17164A901 (5)


Text

NOTICE OF VIOLATION Docket Nos.

50-387, 50-388 License Nos.

NPF-14, NPF-22 Pennsylvania Power and Light Company, Inc.

Susquehanna Steam Electric Station During an NRC inspection conducted during the period September 7 through October 2, 1998, a violation of NRC requirements was identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

A.

Section III, "Design Control," of Appendix B to Title 10 of the Code of Federal Regulations, Part 50, requires that measures be established to ensure that the applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instructions.

It further requires that design control measures be applied to items such as accident analyses and delineation of acceptance criteria for tests and inspections.

Contrary to the above, three examples were identified, in which measure did not ensure that regulatory requirements and the design basis were correctly translated into accident analyses or test acceptance criteria.

Contrary to the above, on July 27, 1998, Pennsylvania Power and Light Company (PPSL) did not ensure that the design basis of the facility was correctly translated into test acceptance criteria in that, when PPS,L revised the Unit 1 quarterly core spray flow verification test, SO-151-A02, the acceptance criteria for system flow and pressure did not assure the level of core spray pump performance required by Improved Technical Specification SR 3.5.1.7 would be met. Specifically, SR 3.5.1.7 requires that the core spray system loops be capable of injecting 6350 gpm into the reactor vessel at a steam dome pressure of 105 psig.

However, based upon calculation EC-051-004, the SO-151-A02 acceptance criterion of 282 psig discharge pressure at 6350 gpm correlated to 99 psig reactor vessel steam dome pressure.

2.

Contrary to the above, on and before October 1, 1998, PPSL did not ensure that the design basis of the facility was correctly translated into test acceptance criteria in that the acceptance criteria for the Unit 2 quarterly core spray flow verification test did not assure the level of core spray pump performance required by Technical Specification 4.5,1 b. would be met.

Specifically, the Unit 2 core spray quarterly flow test methodology specified adding a 7 psig correction factor to the indicated discharge pressure before comparing the discharge pressure to the acceptance criterion pressure.

No basis existed for adding the 7 psig correction factor.

'PBii240050 98iii3 PDR ADOCK 05000387 6

PDR

3.

Contrary to the above, on and before October 2, 1998, PPRL had not ensured that the facility design basis was correctly translated into the accident analyses in that the Loss of Coolant Accident analysis assumed core spray system flows up to and including 8143 gallons per minute per loop. These flows are in excess of the system design flow limitof 7900 gallons per minute per loop.

This is a Severity Level IV violation (Supplement I) ~

For examples 1 and 2 of the cited violation, the NRC inspection team determined that appropriate corrective actions have been taken to ensure compliance is achieved, and no response to this Notice of Violation is required for those examples.

For example 3 of the cited violation, pursuant to the provisions of 10 CFR 2,201, Pennsylvania Power and Light Company, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facilitythat is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance willbe achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate, reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the.

license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to'the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response

that you seek to'have.withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information willcreate an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable

response, please provide the level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 13th day of November, 1998