ML17164A928
| ML17164A928 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/08/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NUDOCS 9812180094 | |
| Download: ML17164A928 (27) | |
Text
December 8, 1998 Mr. Robert G. Byram Senior Vice President - Nuclear Pennsylvania Power 5 Light Company 2 North Ninth Street.
Allentown, Pennsylvania 18101
SUBJECT:
Mid-Year Inspection Resource Planning Meeting - Susquehanna Steam Electric Station
Dear Mr. Byram:
On November 10, 1998, the NRC staff held an inspection resource planning meeting (IRPM). The IRPM provided a coordinated mechanism for Region I to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in May 1999.
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this IRPM 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 PP5L.
The IRPM 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 IRPM 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. details our inspection plan for the next 6 months.
Resident inspections are not listed due to their ongoing and continuous nature.
We willinform you of any changes to the inspection plan.
If you have any questions, please contact Clifford Anderson at 610-337-5227.
Sincerely, Original Signed by:
98i2i80094 98i208 PDR ADOCK 05000387 8
PDR CliffordJ. Anderson, Chief
~ Projects Branch 4 Division of Reactor Projects OFFICIAL RECORD COPY
C P
Robert G. Byram Docket Nos.
50-387, 50-388
Enclosures:
- 1) Plant Issues Matrix
- 2) Inspection Plan cc w/encls:
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 R. W. Osburne, Vice President, Supply 5 Engineering Commonwealth of Pennsylvania
Robert G. Byram Distribution w/encls:
Region I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
H. Miller, RA/W. Axelson, DRA (1)
C. Hehl, DRP J. Wiggins, DRS R. Crlenjak, DRP L. Nicholson, DRS C. Anderson, DRP DRS Branch Chiefs J. Lanning, DRP D. Florek, DRP R. Ragland, DRS G. Smith, DRS J. Lusher, DRS R. Fuhrmeister, DRS R. Junod, DRP NRC Resident Inspector PUBLIC Distribution w/encls: (Via E-Mail)
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 M. Campion, ORA DOCDESK DOCUMENT NAME: G:>BRANCH4)PPR>SUS-IRPM.11 To receive a co f this document, indicate in the box: "C" = Copy without attachment/en o
re "E" = Copy with attachment/enclosure "N" = No copy DFI NAME DATE 1
OFFICE RI/
98 RI/DRP CAnderson 4~
12/
/98 OFFICIAL RECORD COPY
ENCLOSURE 1
SUSQUEHANNA PLANT ISSUES MATRIX
SUSQUEHANNA PLANT ISSUES MATRIX Date Type Source
/D SFA Code
/tern Description 7/20/98 Positive IR 98-06 N
OPS 7/20/98 Negative IR 98-06 N
OPS 1A Each of the CRs contained an operability determination (OD). With the exception of the 1C operability determination related to the acoustic monitor and water intrusion into the "A"
. 3B emergency diesel generator fuel oil storage tank, the ODs were found to have been adequately performed.
(Section 04.1) 1A The NRC identified a work control evolution that had removed redundant Emergency Switch 1C Gear Coolers (ESGC) from service. When brought to the licensee's attention, the licensee 3A entered the appropriate Technical Specification Interpretation, secured the work evolution and returned one of the ESGC divisions within the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. (Section 01.4) 7/20/98 URI Negative IR 98-06 N
OPS 1B In the Unit2 moisture separator drain tank high-high level turbine trip/reactor scram on June 29, 1998, and in the Unit2 intermediate range monitor scram on July 2, 1998, the reactor achieved a stable shutdown condition. PP&L implemented initial corrective actions that prevented similar condition on the subsequent plant startup. Since the intermediate range monitor scram involved a reactor period significantly shorter than normal, and involved two separate operators performing incorrect operator actions, an unresolved item willbe opened to obtain further-information to determine ifthe actions were acceptable, a deviation, a non-conformance or a violation. (Section 01.3) 7/20/98 Positive IR 98-06 N
OPS 6/8/98 Positive IR 98-03 N
OPS 6/8/98 Positive IR 98-03 N
OPS 1A The licensee conducted plant operations in accordance with SSES procedures, and established 3A effective equipment alignment and operability. The alignment of the residual heat removal and core spray systems was found to be adequate.
The material condition of both units was adequate with the exception of the Unit 1 acoustic monitor and the Unit.2 condensate filtration flowelement.
(Section 01.2) 1A Asample of operator log entries was observed to be complete and accurate.
Aspecific series o~,
3A operator log entries accurately reported equipment status tag data, Technical Specification requirements, and condition report data.
(Section 02.2) 1A The alignment of eight safety related systems were found to be adequate.
The licensee 3A conducted plant operations in accordance with SSES procedures, and established effective equipment alignment and operability. (Section 01.2)
FROM: 3/98 TO: 9/98 Page 1 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date rape 6/8/98 Positive Source IR 98-03 6/8/98 Positive IR 98-03 6/8/98 Negative IR 98-03 6/8/98 Positive IR 98-03 5/14/98 Positive IR 98-02 LER 97-04 NCV 98-02-01 5/14/98 Positive IR 98-02 5/14/98 Positive IR 98-02
/D SFA Code L
OPS 1B 3B N
OPS 1A 3A N
OPS 1A 1C 3B N
OPS 1B 3B S
OPS 1B 2A N
OPS 1C N
OPS 1A 3A
/tern Description Operator response to the discovery of a misaligned resin effluent valve was in accordance with the PP8L Equipment Status Control Event procedure. Operators responded well and conservatively.
There was no safety impact associated with the misaligned component.
(Section 02.1)
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)
Twenty seven safety related initial Operability Determinations (ODs) and Condition Reports (CRs) were reviewed in detail and were found to be adequately performed.
Two PP8L OD procedural requirements were not being consistently implemented by the licensee (consideratior 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)
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)
A Unit 1 recirculation pump increased speed to its high speed stop, resulting in a reactor power increase to approximately 103.5%. The operators responded appropriately to the alarmed transient condition and limited the time that the licensed full power limitor 102% was exceeded, to approximately one minute. The licensee determined that the cause of the transient was a failed fuse in a Bailey controller and replaced the fuse and additional suspect components.
The two Plant Operations Review Committee (PORC) meetings observed demonstrated that PORC conducted in4epth and conservative reviews and demonstrated a conservative and safe approach.
Asample of operator log entries was determined to be complete and accurate.
A specific series of operator log entries was compared to condition report data and determined to be consistent with the data in condition reports.
FROM: 3/98 TO: 9/98 Page 2 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date rVPe 5/14/98 Positive 5/14/98 Positive 5/14/98 Positive Source IR 98-02 ID SFA Code Item Description L
OPS N
OPS IR 98-02 IR 98-02 N
OPS 3A Operator response to the discovery of a misaligned valve was in accordance with the PP&L 5A Equipment Status Control Event procedure. Operators responded well and conservatively.
There was no safety impact associated with the misaligned system.
1C Safety permits (tagouts) authorized by the control room were properly prepared.
However, due to a weak Work Control review process, the control room operators identified and corrected several errors in the permits, prior to the permit application in the field.
1A Operators were observed to respond well to control room alarmed conditions and an infrequentl>> ~
occurring condition (power coast down). Appropriate SSES procedures were adhered to, operability and impact on plant equipment were controlled, and actions were adequately announced and documented.
5/14/98 Positive IR 98-02 OPS 5/14/98 Positive IR 98-02 N
OPS 1A The licensee conducted plant operations in accordance with SSES procedures, and established effective equipment alignment and operability.
1A Licensed and non-licensed operator activities were well performed and communicated.
Shift 3B tumovers were observed to be detailed and complete.
FROM: 3/98 TO: 9/98 Page 3 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date Type Source ID SFA Code Item Description 7/20/98 7/20/98 6/12/98 URI Negative IR 98-06 S
MAINT NOED Negative IR 98-06 S
MAINT NCV IR 98-04 N
MAINT Negative NCV 98-04-04 EA 98-350 2A On July 3, 1998, the Unit 1 "S" safety relief v'alve (SRV) acoustic monitor had indication of a 5C malfunction. Maintenance was performed on this monitor and the monitor was returned to 5B service.
On July 6, 1998, the Unit 1 "S" SRV acoustic monitor again malfunctioned, with the same indications that occurred on July 3, 1998. Unit 1 was shutdown to repair the monitor. All Unit 1 acoustic monitors were modified during the shutdown to improve equipment reliability.
The adequa'cy of acoustic monitor maintenance instructions and procedures, the adequacy of the operability determination forthe S" acoustic monitor, the adequacy of the diagnostic field techniques used to verify acoustic monitor operability and the adequacy of the corrective actions for previous acoustic monitor failures willbe tracked as an URI to obtain further information to determine ifthe actions were acceptable or represent a violation of NRC requirements. (Section M2.2) 2A PP8L requested enforcement discretion forTechnical Specification requirements concerning a 5C failed acoustic position indicator forthe Unit2 "J" Safety Relief Valve, to avoid an undesirable 5B transient as a result of forcing compliance with a license condition. The NRC approved PP&L's request, on June 15, 1998, after determining the action involved minimal or no safety impact and had no adverse radiological impact on public health and safety. (Section M2.1) 4C Starting in December 1995, PP8L conducted a thorough set of evaluations of the maintenance rule program implementation. These evaluations identified a number of problem areas, howevei addressing ofthe issues was delayed.
Atthe time ofthe team's inspection in June 1998, the corrective actions were in place and the maintenance rule program was appropriately established.
Failure to have an adequate maintenance rule program that met the requirements of the rule on July 10, 1996 constituted apparent violations of 10 CFR 50.65. However, this violation is not cited, based on the exercise of discretion in accordance with Section VII.B.6of t the Enforcement Policy.
FROM: 3/98 TO: 9/98 Page 4 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date TYpe Source ID SFA Code Item Description 6/12/98 NCV IR 98-04 Negative NCV98-04-03 EA 98-350 6/12/98 Negative IR 98-04 N
MAINT 4C 4C The licensee's program forassessing the risk of taking equipment out of service when on-line was weak in that undesirable risk configurations could occur for scheduled work as well as for emergent work. While currently not a mandatory requirement, the team concluded that the licensee's process for assessment of plant risk during on-line maintenance does not appear to meet the intent of the maintenance rule. The plant procedure for risk assessment did not cover all risk significant systems and was not utilized for emergent work. However, when a formal risk assessment was required by the plant procedure, the assess'ment was adequately detailed, developed; and implemented.
The licensee's new periodic nlaintenance effectiveness assessment procedure was adequate fo implementing the requirements of the periodic assessments under 50.65(a)(3). The first periodii assessment did not meet the requirements of the rule by failing to adequately balance reliability and availability and assess the continued adequacy of goals for (a)(1) structures, systems and components.
This failure is an apparent violation. However, this violation is not cited, based on the exercise of discretion in accordance with Section VII.B.6of the Enforcement Policy.
6/12/98 Positive IR 98-04 N
MANT 4C 6/12/98 NCV IR 98-04 Negative NCV 98-04-02 EA 98-350 N
MAINT 4C 6/12/98 Positive IR 98-04 N
MAINT 3B Appropriate goal setting was in place for the (a)(1) systems which were reviewed.
However, the team observed the corrective actions for (a)(1) systems did not include review of preventive maintenance activities. Correction and preventive maintenance were considered appropriate and effective for the (a)(2) systems reviewed.
The system engineers had excellent knowledge of their systems, and good knowledge of the maintenance rule requirements.
The system engineer's involvement and role was found to be a significant positive attribute of the maintenance rule program.
In general, system engineers, work coordination managers, and licensed operators appeared able to fulfilltheir responsibilities under the maintenance rule. Their understanding of rule was acceptable.
Several structures, systems and components had exceeded their performance criteria in 1996 oi~
1997, but were not evaluated and placed in (a)(1) status until as late as June 1998. This was an~
apparent violation. However, this violation is not cited, based on the exercise of discretion in accordance with Section VII.B.6of the Enforcement Policy.
FROM: 3/98 TO: 9/98 Page 5 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date Type 6/12/98 Positive 6/12/98 VIO SL-IV 6/12/98 Positive Source IR 98-04 IR 98-04 IR 98-04 VIO 98-04-01 EA 98-350 N
MAINT 4C MAINT 4C ID SFA Code N
MAINT 4C Item Description The unavailability performance criteria resulted in an acceptable increase in core damage frequency when factored into the probabilistic risk assessment (PRA), and were based on the PRA unavailability data. The reliabilitycriteria were linked to the PRA assumptions and were acceptable.
The risk ranking process was based on probabilistic risk assessment information and was acceptable.
Appropriate actions had been taken by the expert panel to compensate for any weaknesses in the probabilistic risk assessment (PRA). The risk ranking process appropriately used the risk achievement worth, risk reduction worth and 90% of cutsets and included considerations forcontainment systems.
Truncation levels and human recovery actions were considered appropriately when evaluating the PRA results.
PP&L adequately placed structures, systems and components within the scope of the maintenance rule, with the exception of the Bypass Indication System.
Failure to include the Bypass Indication System in the maintenance rule program was an apparent violation of 10 CFR 50.65(b) 6/8/98 Negative IR 98-03 N
MAINT 3A 3B 2B Inservice inspections (ISI) were performed acceptably, with qualified personnel and approved procedures.
In general, proper implementation, appropriate examination documentation, and adequate PP8L oversight were observed.
The ISI were thorough and of sufficient extent to determine the integrity of the components. Non-conforming conditions were adequately identiTiec and reported for disposition. However, two instances ofwork package problems were identified by the NRC, including an outdated procedure and an inacctirate qualification record, which constituted a violation of NRC document control requirements of minor safety significance.
(Section M2.1) 6/8/98 VIO IR 98-03 VIO98-03-04 N
MAINT 3A Two emergency diesel generator (EDG) maintenance activities were inadequate, resulting in a 3B violation of NRC requirements.
Under Work Authorization (WA) H50056, dated February 6, 2B 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 WAH70311, 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 M1.4)
FROM: 3/98 TO: 9/98 Page 6 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date Type Source
/D SFA Code Item Description 6/8/98 Negative IR 98-03 N
MAINT 6/8/98 Negative IR 98-03 N
MAINT 5/14/98 Positive IR 98-02 N
MAINT 5/14/98 Positive IR 98-02 N
MAINT 5/14/98 Positive IR 98-02 N
MAINT 3A Seventeen of nineteen pre-planned maintenance activities observed/reviewed were found to be 3B appropriately conducted and controlled; the remaining two maintenance activities are discussed in detail in other sections of this report Overall, maintenance procedural controls were determined to be general in nature and did not prescribe some activities performed by maintenance personnel.
Specifically, performed activities forwhich 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) 3B Also, symptomatic of problems in work planning, on at least three occasions, scheduled NDE 3A workwas delayed from hours to a day due to various work planning problems. While these 2B 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) 2A The present material condition and general housekeeping at SSES were determined to be good.
Several minor housekeeping and material condition items that did not affect the system operability were communicated to the licensee for its review.
3A The surveillance activities observed/reviewed were adequately performed and appropriately 3B controlled. The surveillance activities were accomplished by qualified and trained personneL 3A The planned maintenance activities observed/reviewed were found to be appropriately 3B conducted and controlled. Procedural control was general in nature.
Interviews with maintenance personnel showed the individuals were knowledgeable, appropriately qualified, and capable of explaining their activities.
FROM: 3/98 TO: 9/98 Page 7 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date Type Source
/D SFA Code Item Description 7/20/98 URI IR 98-06 S
ENG Negative 7/20/98 Negative IR 98-06 S
ENG 7/20/98 Negative IR 98-06 S
ENG 2A The heavy rains on June 23, 1998 resulted in significant quantities ofwater entering the "A" 4A emergency diesel generator (EDG) storage tank through an unsealed penetration in the "A EDC 4C storage tank vault, due to in-progress modification work, and a loose flange on the "A"storage tank. The "A"EDG was declared inoperable for a short period of time and remained in a degraded condition for several days, following rain water leakage into the "A"fuel oil storage tank. This appears to have been the result of inadequate design control during the installation a diesel fuel oil storage tank sampling system, in conjunction with an inadequate maintenance activitywhich left'a loose flange on the storage tank. The design control and maintenance issues willbe tracked as an unresolved item, to obtain further information to determine ifthe actions were acceptable or represented a violation of NRC requirements.
(Section E2.3) 2A During heavy rains, the Emergency Diesel Generator (EDG) Building sump room flooded, and 2B as a result of foreign material lodged in a backflow preventer valve, the "A"EDG room basement 4B also flooded. The licensee's initialactions forthis event appeared reasonable.
Room flooding alarms and sump high-high level alarms failed to alert operations personnel of the flooding, condition. Although this presented a single means to fiood all of the EDG rooms from a single event, no violations of NRC requirements were identified. (Section E2.2) 4A The weld crack occurred because of a lack of fusion on the end cap weld base pass and 4C unexpected high amplitude vibration. The vibration was the result of an error in the engineering 2A analysis that resulted in a less than optimum installation of the flowsensing element.
PPBL took action to correct the Unit2 failure and determined that Unit1 does not have similar conditions that would lead to this type of failure. Because of PP&L corrective actions and the low safety significance of this issue, no further actions are planned by the NRC. No violation of NRC requirements were identified. (Section E2.1)
FROM: 3/98 TO: 9/98 Page 8 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date TYpe Source
/D SFA Code
/tern Description 11/5/96 10/7/97 8/8/97 NCV LER Positive IR 98-03 NCV98-03-02 LER 97-23-00 NCV LER Positive IR 98-03 NCV 98-03-01 LER 97-1 8-00 NCV IR 98-03 LER NCV98-03-03 Positive LER 96-15-00 L
ENG L
ENG 4C 4A 4C L
ENG 5A 5B 5C PP&L identified safety-related 4KVswitchgear were dynamically qualified with breakers in the racked-in position only (i.e., the switchgear had not been dynamically qualified for service with the breakers in the "test" position or installed but racked out). PP&L determined, based on the breaker alignment, that seven breakers were, at various times, in positions other than the dynamically qualified position, which represents a violation of Technical Specification (TS) 3.8.3.1.
PPBL modified the sviitchgear and established administrative controls for the position ol breakers in sviitchgear. The inspectors noted that excellent questioning attitude by PP8L led to identification of the design deficiency, and ultimately resulted in issuance of NRC Information Notice 97-53, "CircuitBreakers Left Racked Out in Non-Seismically Qualified Positions." The issue also was not likelyto 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.3of the Enforcement Policy, the NRC has exercised enforcement discretion and not cited the violation ofTS.
The license identified Technical Specification (TS) 4.7.6.3 surveillance requirements were not included in the SSES surveillance program. The licensee determined the root cause to be inadequate control of fire protection modification and licensing processes.
The errors occurred between 1988 and 1991. The failure to test fire system equipment 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.
PP&L 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 and determined that the identification of the untested relays was the result of corrective actions for a violation identified in NRC Inspection Report 50-387,388/97-03, ~
which addressed a failure to perform required Technical Specification testing. The root cause for this event was different than the root cause forthe previous violation identified. 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. (section 08.1)
FROM: 3/98 TO'/98 Page 9 of 15
SUSQUEHANNA PLANT ISSUES MATRIX ID SFA Code Date Type 6/30/98 VIO Source IR 98-08 VIO 98-08-02 N
ENG 6/30/98 NCV IR 98-08 Negative NCV9848-01 N
ENG 5/14/98 Positive IR 98-02 N
ENG 5/14/98 Negative IR 98-02 N
ENG 5/14/98 Positive IR 98-02 N
ENG 4C SA 5C 4C 5A 5C 4B 4A 4C 5A 4B
/fern Descripfion In 1990 and 1991, PP&L identified the fuel oil transfer pump automatic start level-switch setpoints in the emergency diesel generator day tanks did not meet the American National Standards Institute (ANSI) requirement to ensure a day tank minimum fuel oil volume sufficient for 60 minutes of operation at the level where fuel oil is automatically added to the day tank, at rated load, plus a 10% margin. PP&L documented this nonconforming condition in Nonconformance Report 90-0173 and engineering study SEA-ME-332, and implemented administrative controls, as compensatory measures, but failed to effect timely resolution. The failure to effect timely resolution of this nonconformance is considered a violation of 10 CFR 50 Appendix B, Criterion XVI,Corrective Action.
In 1990, a PP8L safety evaluation for a facilitymodification concluded a Technical Specification (TS) revision was involved fora proposed change to the diesel day tank minimum volume. The safety evaluation failed to identify the proposed change as an unreviewed safety question.
PP&L did not obtain NRC approval prior to implementing the change and did not submit a TS change until 1996. This is considered a violation of 10 CFR 50.59 requirements.
However, this violation is not cited, based on the exercise of discretion in accordance with Section VII.B.6of the Enforcement Policy.
The PP&L methodology, which used a test pressure less than the integrated leak rate test pressure, to accomplish closed loop system integrity verification for the suction lines on the high pressure coolant injection and the reactor core isolation cooling systems was consistent with the NRC expectations for leakage testing of these lines.
The licensee's Final Safety Analysis Report, for the refuel platform and refueling interlocks, had not been revised following a 1996 modification. In response to NRC questions, the licensee has issued a Condition Report to review the current design control process which allows partial modification closeouts.
The licensee implemented a detailed analysis, qualification, and testing program to address the issue of electrical isolation.
5/14/98 NCV IR 98-02 LER NCV 98-02-02 Positive LER 9744 L
ENG 4C 5A The licensee identified that portions of the Residual Heat Removal System, designated as closed loop systems which function as redundant containment isolation barriers, had never been leak rate tested as required by the technical specifications.
FROM: 3/98 TO: 9/98 Page 10 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date Type
'ource
/D SFA Code Item Description 7/20/98 Positive IR 98-06 N
PS 7/20/98 Positive IR 98-06 N
PS 7/20/98 Negative IR 98-06 N
PS 7/20/98 Negative IR 98-06 N
PS
. 1C 5A 1C 1C 1C The licensee's review of the emergency preparedness program was well structured and addressed all NRC requirements for conducting an independent review of the emergency preparedness program. Auditors evaluated the program against all of the attributes specified in 10 CFR 50.54(t) of NRC regulations. The assessment of the adequacy of licensee interface witl the offsite organization was not complete since it failed to evaluate interface with representatives of one of the risk counties.
(Section P7)
The licensee maintained the Nuclear Emergency Planning staff at consistent levels with only brief periods of under staffing. The recently appointed Senior Nuclear Emergency Planning Coordinator was well qualified to perform his assigned duties. Nuclear Emergency Planning kept well informed of station issues and conducted appropriate interface with station management.
(Section P6)
The licensee maintained a good Emergency Plan training program and ensured completion of al required training. Evaluation techniques for some elements of this program were unreliable, including the lack of annual re-examination of the entire spectrum of emergency action levels for decision makers and the use ofthe same evaluation scenario for radiological assessment personnel forthe last six years. The licensee was effectively using minidrillsto train on severe accident management concepts.
(Section P5)
Discrepancies in the recent revision of the emergency plan indicate that the licensee did not perform a sufficient level of review of emergency plan changes and had not given an adequate amount of attention to the annual reviews of the plan. The reduction of the radiological assessment staff in the Emergency Operations Facility from three to two, after that staffing level had been increased to three during a recent revision ofthe plan was a reduction of the effectiveness of that plan. Although this change was not in compliance with the requirements of 10 CFR 50.54(q), the actual level of preparedness was not reduced and the non-compliance is one of minor significance. This violation, therefore, willnot be subject to formal enforcement action. (Section P3)
FROM: 3/98 TO: 9/98 Page 11 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date Tgpe 7/20/98 Positive Source IR 98-06 11/7/98 NCV IR 98-09 Negative IR 97-201 URI 97-201-5 NCV98-09-07
/D SFA Code Item Descr/pt/on N
PS 3A The emergency response facilities were very well maintained. The licensee has enhanced the abilityto assess plant and environmental conditions by installing a recent computer data display modification and a remote radiation monitoring system.
Surveillances were accomplished, but a management expectation regarding communication surveillances created the possibility for a missed surveillance. The surveillance was performed correctly despite the management expectation.
(Section P2)
N PS 4A Failure to properly implement the requirements of NFPA 14 in the design and installation of standpipe system.
11/7/98 EEI IR 98-09 Negative IR 97-201 URI 97-201-5 EEI 98-09-06 N
PS 4A Failure to properly implement the requirements of NFPA 13 in the design and installation of the fire suppression sprinkler systems.
11/7/97 11/7/97 11/7/97 EEI Negative EEI Negative EEI Negative IR 98-09 IR 97-201 URI 97-201-5 EEI 98-09-05 IR 98-09 IR 97-201 URI 97-201-7 EEI 9849-08 IR 98-09 IR 97-201 URI 97-201-3 EEI 98-09-04 N
PS 4A Failure to properly implement the requirements of NFPA 72E in the design and installation of the fire detectors.
N PS 4A Failure to provide 8-hour battery powered emergency lighting in all areas of the plant requiring 1C manual actions for safe shutdown..
N PS 4A Failure of the automatic depressurization system/core spray post-fire safe shutdown 4C methodology to meet the 10CFR50 Appendix R reactor performance goals by maintaining the reactor water level above the top of active fuel.
FROM: 3/98 TO: 9/98 Page 12 of 15
SUSQUEHANNA PLANT ISSUES MATRIX Date Tgpe Source
/D SFA Code Item Descript/on 11/7/97 11/7/97 11/7/97 EEI Negative EEI Negative EEI Negative IR 98-09.
iR 97-201 URI 97-201-2 EEI 98-09-03 IR 9849 IR 97-201 EEI 98-09-02 IR 98-09 IR 97-201 URI 97-201-1 EEI 98-09-01 N
PS N
PS N
PS 5/14/98 NCV Positive IR 98-02 NCV98C2C4 L
PS 5/14/98 Positive IR 98-02 N
PS 5/14/98 Positive IR 98-02 N
PS 4A Failure to provide tools and equipment necessary to make connection from the fire water system 4C to the condensate transfer system to assure availability of keepfiil system to prevent water hammer in the High Pressure Coolant Injection, Reactor Core Isolation Cooling, Core Spray, anc Residual Heat Removal system discharge piping.
1C Failure to meet PP&L procedural requirements for annual physical forfire brigade members.
2A Failure to followPP&L administrative control procedures in the Emergency Service Water pump 2B house: flammable material in excess of PP&L approved limitswithout combustible material permit, and portable staiNvay chained to spare conduit contrary to PP&L requirements.
Corrected prior to end of Fire Protection Functional Inspection.
2B Radiological controls for the As-Low-As-Reasonably-Achievable (ALARA)program were 1C performed in an effective manner. The selection and qualification of contracted radiological control technicians was proceduralized, conducted, administered, and documented in a detailed and thorough manner. The combination of audits, surveillances, corporate assessments, self-assessments, and the problem identification process resulted in a high volume of deficiencies and improvement opportunities being identified and in a low threshold for such identification.
3A Overall, effective performance in the area of radiological controls for radioactive materials, 5A contamination, surveys, and monitoring was evident. The licensee identified that they had failed to post high radiation areas during work that involved changing exposure conditions.
3A Performance in radiological controls for individual external and internal exposures for 1997 and 1C for 1998 up to April28 was fullyeffective.
FROM: 3/98 TO: 9/98 Page 13 of 15
SUSQUEHANNA PLANT ISSUES MATRIX ABBREVIATIONSUSED IN PIM TABLE CR ECCS EDG LER NFPA NRC OD PP8L RCIC SSES TS VIO WA As-Low-As-Reasonably-Achievable
-Condition Reports Emergency Core Cooling System Emergency Diesel Generator Licensee Event Report National Fire Protection Association Nuclear Regulatory Commission Operability Determination Pennsylvania Power and Light Probabilistic Risk Assessment Reactor Core Isolation Cooling Susquehanna Steam Electric Station Technical Specification Violation Work Authorization FROM: 3/98 TO: 9/98 Page 14 of 15
SUSQUEHANNA PLANT ISSUES MATRIX GENERAL DESCRIPTION OF PIM TABLECOLUMNS Date Type Source
/D SFA Code
/tem Descr/ption.
The actual date ofan event or significant issue forthose items that have a dear date of occurrence (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 of the item or finding - see the Type/Findings Type Code tabb, below.
The document that describes the findings: LER for Licensee Event Reports, EALfor Enforcement Action Letters, or IR for NRC inspection Reports.
Identification of who discovered issue: N for NRC; Lfor Ucensee; or S for Self Identifying (events).
SALP Functional Area Codes: OPS for Operations; MAINTfor Maintenance; ENG for Engineering; and PS for Plant Support.
Template Code - see tabb below.
Details ofNRC findings on LERs that have safety significance (as stated in IRs), findings described In IR Executive Summaries, and amplifying information contained in EALs.
TYPE/ FINDINGS CODES TEMPLATECODES ED Strength Weakness VIO NCV Positive Negative LER URI" Licensing MISC Enforcement Discretion - No CivilPenalty Overall Strong Licensee Performance Overall Weak Ucensee Performance Escalated Enforcement Item - Waiting Final NRC Acfion Violation Level I~ II, III~ or IV Non<ited Violation Deviation from Ucensee Commitment to NRC Individual Good Inspection Finding Individual Poor Inspection Finding Licensee Event Report to the NRC Unresolved Item from Inspection Report Ucensing Issue from NRR Miscellaneous - Emergency Preparedness Finding (EP), Dedared Emergency, Nonconformance Issue, etc. The type of all MISC findings are lo be put in the Item Description column.
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 Abigities/Training; C-Work Environment 4
Engineering/Design: A-Design; B-Engineering Support; C-Programs and Processes 5
Problem Identification and Resolution: A-Identification; B - Analysis; and C - Resolution NOTES:
EEls are apparent vtotations of NRC requkements that are being considered tor escalated enforcement action ki accordance with the 'General Statement of Poficy and Procedure for NRC Enforcement Action (Enforcement Percy), NUREG-1600. However, the NRC has not reached its final enforcement decision on the issues ldentified~
by the EEts and the PIM entries may be moditied when the finat deciskws are made.
Before the NRC makes its enforcement dedsbn, the ficensee wlbe provkled with an opportunity to either (I)respond to the apparent violation or (2) request a predectskwat enforcement conference.
URts are unresolved items about which more htonnation is required to determine whether the issue h quesbon is an acceptable item, a deviation, a nonconformance, or a viotafion. However, the NRC has not reached its final conctuskes on the issues. and the PIM entries may be modified when the final condusbns are made.
FROM: 3/98 TO: 9/98 Page 15 of 15
SUSQUEHANNA INSPECTION PLAN FOR DECEMBER 1998 THROUGH MAY1999 Inspection 251 5/139 40500 60851 83750 60853 60854 Program Area/Title Generic Letter 96-01 Implementation Corrective Action Independent Spent Fuel Storage 50.59 and 72.212 Review Radcon-Outage Independent Spent Fuel Storage Receipt Inspection/Installation of HSM /DCS Independent Spent Fuel Storage Review Loading Procedures Initial Operating Examination Planned Dates 1-1 1-1 999 1-18-1999 3-1-1999 3-29-1999 TBD TBD 5-10-1 999 Type Inspection/Comments Safety Initiative Core Regional Initiative Core Regional Initiative Regional Initiative Legend:
IP Tl Core OA RI Sl Inspection Procedure Number Temporary Instruction Program / Sequence Number Minimum NRC Inspection Program (mandatory at all plants)
Other Inspection Activity Additional Inspection Effort Planned by Region I
Safety Initiative Inspection