ML17164B007
| ML17164B007 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/09/1999 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NUDOCS 9904160194 | |
| Download: ML17164B007 (64) | |
Text
April 9, 1999 Mr. Robert G. Byram Senior Vice President - Nuclear Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
SUBJECT:
PLANT PERFORMANCE REVIEW-SUSQUEHANNA STEAM ELECTRIC STATION On February 24, 1999, the NRC staff completed a Plant Performance Review (PPR) of the Susquehanna Steam Electric Station. The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance.
The results are used by NRC management to facilitate planning and allocation of inspection resources.
PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews.
PPRs examine information since the last assessment of licensee performance to evaluate long term trends, but emphasize the last six months to ensure that the assessments reflect current performance.
The PPR for Susquehanna Steam Electric Station involved the participation of all technical divisions in a detailed evaluation of inspection results and safety performance information for the period April 1998 to January 15, 1999 and a review of long-term performance trends since your last Systematic Assessment of Licensee Performance (SALP). The NRC's most recent summary of licensee performance was provided in a letter of September 26, 1997 and was discussed in a public meeting with you on October 9, 1997.
As discussed in the NRC's Administrative Letter 98-07 of October 2, 1998, the PPR provides an assessment of licensee performance during an interim period that the NRC has suspended its SALP program. The NRC suspended its SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the NRC'ill decide whether to resume the SALP program or terminate it in favor of an improved process.
During this assessment period, Susquehanna Units 1 and 2 experienced a variety of challenges, including three automatic reactor shutdowns, four unplanned manual reactor shutdowns and several unplanned power reductions, primarily related to equipment failures.
Overall performance at the Susquehanna Steam Electric Station was acceptable.
Senior managemerit involvement in station activities increased.
Some improvements were noted in the operations and maintenance areas.
However, early in the period there were a number of plant shutdowns and unplanned power reductions (transients) that challenged the station.
In the maintenance area, some improvement has been made in the work control planning and scheduling processes in response to previously identified problems.
Station management took steps to address problems in coordination and communication among work groups; however, this area remains a challenge.
While the engineering organization has contributed to improved plant operations, it has been slow to resolve some longstanding material condition issues.
The
~eoeaeo~~n 9e0409 PDR ADOCK 05000387 6
Mr. Robert G. Bryam Susquehanna Steam Electric Station W
.radiation protection, security, and emergency preparedness programs continued to be effective.
The fire protection program performance was satisfactory.
The PP8L program for identifying and correcting problems was deficient in a number of instances, in that PP8L's response to some important problems was slow or narrowly focused.
Operators typically demonstrated competent performance during normal operations, plant transients and planned evolutions. This performance was attributed, in part, to station management's continued attention to daily operation and an effective operator training program.
In contrast, some instances of poor reactivity control management and oversight by operators were noted during two reactor startups in the summer of 1998.
During the second startup, these deficiencies in reactivity control management resulted in an automatic shutdown of the reactor.
Station management made several changes, which were observed to be effective in improving performance during subsequent reactor startups.
These changes strengthened the reactivity management program and resulted in increased oversight of reactor startup activities by senior operations and training managers.
We plan to perform the normal core inspection program in the operations area, with some increased emphasis placed on reactivity management.
Overall performance in the maintenance area has improved since station management made changes in the maintenance program, although equipment failures continue to burden the operators.
Recently, work coordination issues delayed the restoration of the 'B'nd
'E'mergency diesel generators and extended the diesels unavailability time.
In the last six
'onths, some improvement was observed in the work control planning and scheduling processes due to implementation of a new work schedule process.
Emergency core cooling systems were maintained in a highly reliable state.
However, other equipment covered within the scope of the Maintenance Rule experienced some failures that were preventable.
Notable examples included problems with the emergency diesel generator (EDG) air system and the
. reactor water cleanup system.
We plan to perform the normal core inspection program in the maintenance area.
In addition, initiative inspections are planned.to review the new work control process, the predictive maintenance program and the Maintenance Rule program implementation.
The engineering organization has contributed to improved plant operation through the implementation of improved technical specifications and efforts to reduce the number of temporary plant modifications.
However, the engineering organization was slow to resolve longstanding equipment problems regarding main steam relief valve acoustic monitors and feedwater isolation valves.
In addition, the engineering organization significantly delayed taking.
corrective actions for two degraded conditions involving EDG fuel oil tanks. We plan to perform the normal core inspection program in the engineering area.
In addition, initiative inspections are planned to review the engineering organization involvement in the work control and corrective action programs.
I Performance in the plant support functional area continued to be very effective. The
, occupational radiation protection program, radioactive liquid and gaseous effluent control programs and the radioactive environmental and meteorological monitoring programs were effective. The implementation of the security and emergency preparedness programs was also effective. The fire protection program continued to be acceptable, with PP&L having established
Mr. Robert G. Bryam Susquehanna Steam Electric Station acceptable corrective actions for identified fire protection issues.
We plan to perform the normal core inspection 'program in the plant support area.
In addition, an initiative inspection to review the major upgrades being made to security system equipment and an operational safeguards response evaluation are planned.
4 PP8L performance in identifying and correcting problems at the station was deficient on a number of important issues.
While the threshold for identifying problems was appropriately low, on some occasions (e.g. July 1998 automatic reactor shutdown during startup, core spray system design errors and EDG fuel oil tank issues), the root cause analyses and corrective actions were narrowly focused and not timely, in part because of some weaknesses in communication and coordination among work groups.
In addition, recurrence of some problems, such as the emergency diesel generator cooldown cycle trips and reactor water cleanup seal purge pump failures was attributed, in part, to limited trending of corrective action program data.
The effectiveness of your corrective action program willbe assessed as part of the planned core and initiative inspections in the four functional areas.
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of licensee performance trends.
The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and Pennsylvania Power and Light. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately.
Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance.
In addition, the PPR may also have considered some predecisional and draft material that does not appear in
'he 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 will be 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 Steam Electric Station PPR 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 through January 2000. Also included in the plan are NRC non-inspection activities. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas.
Resident inspections are not listed due to their ongoing and continuous nature.
Mr. Robert G. Bryam 4
Susquehanna Steam Electric Station Because of the anticipated changes to the inspection program and other initiatives, this inspection schedule is subject to revision. Any changes to the schedule listed willbe promptly discussed with your staff. Ifyou have any questions, please contact Curtis Cowgill of my staff at (610) 337-5233.
Sincerely, Original Signed By:
A. Randolph Blough, Director Division of Reactor Projects Docket Nos. 50-387, 50-388 License Nos. NPF-14, NPF-22
Enclosures:
- 1. Plant Issues Matrix
'. Inspection Plan cc w/encl:
R. F. Saunders, Vice President - Site Operations G. T. Jones, Vice President - Engineering and Support G. Kuczynski, General Manager-SSES T. Harpster, Supervisor, Nuclear Licensing G. D. Miller, General Manager - Nuclear Engineering R. R. Wehry, Nuclear Licensing F. P. Arcury, Nuclear Services Manager, General Electric W. Lowthert, Manager -Nuclear Plant Services A. Male, Manager, Nuclear Assessment Services H. D. Woodeshick, Special Assistant to the President R. W. Osbume, Vice President, Supply & Engineering Commonwealth of Pennsylvania Institute for Nuclear Power Operations (INPO)
Mr. Robert G. Bryam Susquehanna Steam Electric Station Distribution w/encl:
Region I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector PUBLIC H. Miller, RA/J. Wiggins, DRA Blough, Director, DRP R. Crlenjak, Deputy Director, DRP W. Lanning, Director, DRS W. Ruiand, Deputy Director, DRS C. Cowgill, DRP D. Florek, DRP C. O'Daniell, DRP J. McFadden, DRS R. Fuhrmeister, DRS M. Oprendek, DRP Distribution w/encl:
ia E-Mail W. Travers, EDO S. Collins, NRR J. Zwolinski, NRR B. Boger, NRR M. Tschiltz, OEDO T. Boyce,, NRR E. Adensam, PD 1, NRR V. Nerses, Project Manager, NRR Inspection Program Branch, NRR (IPAS)
R. Correia, NRR DOCDESK DOCUMENT NAME: G:>BRANCH4(PPRIISUS>SSLTR-DF.WPD To receive'a copy ofthIs document, Indicate In the box: "C = Cop without attachment/enciosure "E"= Cop with attachment/enciosure "N = No cop OFFICE NAME DATE RIDRP/
DFlorek 04/09/99 Rl/DRP CCowgill 04/
/99 RI/DRP RBlough 04/
/99 OFFICIALRECORD COPY 04/
/99 04/
/99
Mr. Robert G. Bryam Susquehanna Steam Electric Station Distribution w/encl:
Region I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector PUBLIC H. Miller, RA/J. Wiggins, DRA A. Blough, Director, DRP R. Crlenjak, Deputy Director, DRP W. Lanning, Director, DRS W. Ruland, Deputy Director, DRS C. Cowgill, DRP D. Florek, DRP C. O'Daniell, DRP J. McFadden, DRS R. Fuhrmeister, DRS M. Oprendek, DRP Distdibution w/encl: Via E-Mail W. Travers, EDO S. Collins, NRR J. Zwolinski, NRR B. Boger, NRR M. Tschiltz, OEDO T. Boyce, NRR E. Adensam, PD 1, NRR V. Nerses, Project Manager, NRR Inspection Program Branch, NRR (IPAS)
R. Correia, NRR DOCDESK DOCUMENT NAME: G:>BRANCH4)PPR>SUS(SSLTR-DF.WPD
.To receive a cop of this document, indicate in the box: "C"= Cop without attachment/enclosure "E" = Copy with attachment/enclosure "N"-"No copy OFFICE NAME DATE RIDRP DFlore 04/09/
Rl/DRP CCowgill 04/
/99 Rl/DRP RBlough 04/
/99 04/
/99 04/
/99 OFFICIALRECORD COPY
Mr. Robert G. Bryam Susquehanna Steam Electric Station Distribution w/encl:
Region I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector PUBLIC H. Miller, RA/J. Wiggins, DRA A. Blough, Director, DRP R. Crlenjak, Deputy Director, DRP W. Lanning, Director, DRS W. Ruland, Deputy Director, DRS C. Cowgill, DRP D. Florek, DRP C. O'Daniell, DRP J. McFadden, DRS R. Fuhrmeister, DRS M. Oprendek, DRP Distribution w/encl: Via E-Mail W. Travers, EDO S. Collins, NRR Zwolinski, NRR B. Boger, NRR M. Tschiltz, OEDO T. Boyce, NRR E. Adensam, PD 1, NRR V. Nerses, Project Manager, NRR Inspection Program Branch, NRR (IPAS),
R. Correia, NRR DOCDESK DOCUMENT NAME: G:iBRANCH4iPPR tSUSiSSLTR-DF.WPD Torecehreaco ofthlsdocument,tndlcatelnthebox:
"C"=Cop withoutattachment/enclosure "E"=Copywithattachment/enclosure "N"=Nocopy OFFICE RIDRP NAME DFlore DATE 04/09/
Rl/DRP CCowgill 04/
/99 RI/DRP RB!ough 04/
/99 OFFICIALRECORD COPY 04/
/99 04/
/99
Page:
1 of 10 Region I
SUSQUEHANNA United States Nuclear Regulato'ry Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time 1621 51 Date Source Functional Area Template ID Type Codes Item Description 01/04/1999 1998012 Pri: OPS NRC NEG Prl: 1A Sec:
Sec: 1C Ter:
During a planned plant process computer outage, PP&L removed one of the two methods being utilized to monitor suppression pool average water temperature and disabled the initial suppression pool water high temperature control room overhead annunciator.
PP&L did not recognize that Unit 2 had entered two limiting conditions for operations.
This resulted in a violation of minor significance because suppression pool bulk temperature did not exceed 90 degrees Fahrenheit.
(Section 04.1) 01/04/1999 1S98012 Prl: OPS Sec:
NRC NEG Prl: 1C Sec:
Ter.
in December 1998, PP&L incorrectly iinpiemented a complex residual heat removal service water system Technical Specification Interpretation (TSI). Previous to this event m October, 1998, PP8 L did not implement this TSI due to a lack of a reference to the TSI. In both instances PP&L returned the equipment to an operable status within the required time limitspecified in the TSI. PP& L corrective actions inciude planned revisions to the TSI and ultimately removal of all TSis. (Section 03.1)
. 01/04/1999 1998012 Prl: OPS Sec:
NRC POS Prl: 1B Sec: 2A Ter.
The operator response to a Unit 1 loss of main condenser offgas system was excellent. Timely restoration of the offg equipment by nuclear plant operators enabled plant control operators to stabilize the plant in a safe condition. (Section 01.1) 01/04/1999, 1S98012 Pri: OPS Sec: MAINT NRC POS Pri: SA Sec: 5C
. Ter:2A Management's decision to stroke the Unit 1 outboard main steam isolation valve (MSIV), prior to the required surveillance test, was proactive and resolved a potential safety problem that could have resulted in a higher than expected pressure increase during a postulated MSIVdosure event. (Section M1.1) 11/23/1998 1S98011 Prl: OPS Sec:
11/23/1998 1998011 Pri: OPS Sec:
NRC NEG NRC NEG Prl: 1A Sec: 1C Ter:
Prl: 1C Sec:
Ter:
Plant operator building rounds were thorough and properly maintained.
Communications between control room and field operators were good, operations personnel were knowledgeable of their responsibilities and control board awareness was good. However, the inspectors observed inconsistencies in the number of identified leaking safety relief valves on multiple Plant Control Operator and Unit Sypervisor turnover sheets during the week of October 19, 1998, and operations personnel were unsuccessful in starting the "A"Turbine Building Filter Exhaust Fan because they were unaware that a blocking permit was still in effect on the fan dampers'ir supply.
PP&L identified several problems associated with the implementation ofTechnical Specifications (TS)i including a missed surveillance test (drywell floor drain sump level instrumentation), a PP&L determination that prior surveiiiances for the source range monitors were not adequately performed, and an instance where a more conservative TS Interpretation was not recognized.
In each case, the inspectors concluded PP&L took prompt and effective initial corrective actions.
11/23/1998 1998011 Prl: OPS Sec:
NRC POS Prl:1A Sec: 2A Ter:
The obsenred operator performance during the October 9 ~ 1998, startup was good. Changes made to plant procedure in response to a previous event were effective in minimizing operator distractions and resulted in improved control of core reactivity. However, operators were challenged by minor equipment problems and discrepancies between training and actual operation of nuclear instrumentation.
11/23/1998 1998011%1 Pri: OPS Licensee NCV Prl: 1C Sec:
Sec:
Ter:
PP&L identified that four eighteen month logic system functional feedwater/main turbine trip system actuation instrumentation tests, required by TS, were missed.
PP&L's corrective actions, including procedure and programmatic actions, were good. This did not represent a repetitive condition because it resulted from a single failure to establish an adequate sunreiilance procedure.
Therefore, this non-repetitive, licensee identified violation is being treated as a non-cited violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
11/23/1998 1998011 02 Prl: OPS LIcensee NCV Prl: 1C Sec:
Sec:
Ter:
The failure to perform a monthly channel functional test on four SPOTMOS alarm relays was a violation of TS 4.6.2.1.c.2, functions 3a, b, c, and d sunreillance requirements.
This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
Item Type (Compliance,Followup,Other)
~ From 08/01/1998 To 01/15/1999
0
Page:
2 of 10 Region I
SUSQUEHANNA United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time 1621 51 Date'ource Functional Area Template ID Type Codes Item Description 11/23/1998 1998011 03 Prl: OPS Licensee NCV Prl: 1C Sec:
Sec:
Ter.
The failure to establish a continuous fire watch within one hour of halon system inoperability was a violationofTS 3.7.6.4 action "a" requirements.
This non-repetitive licensee-identiflied and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
11/23/1998 1998011-04 Pri: OPS Sec:
Licensee NCV Prl: 1C Sec:
Ter:
PP&L identified, in a Licensee Event Report, that a one hour fire watch was established, instead of a continuous fire watch, as required by TS. PP&L's corrective actions, including procedure and programmatic actions, were good. This non-repetitive, licensee identified and corrected violation is being treated as a nonwted violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
10/12/1998 1998010 Prl: OPS Sec:
NRC POS Prl: 1A Sec: 2A Ter:
The licensee conducted plant operations in accordance with SSES procedures, and established effective equipment alignment and operability. The alignment of the Essential Service Water, Residual Meat Removal Service Water, Spe Fuel Pool Cooling Water, and Reactor Water Cleanup systems was determined to be adequate.
The material condition ofthese systems was adequate.-
10/12/1998 199801045 Prl: OPS Sec:
Self NCV Prl: 4B Sec: 4C Ter:
PP8 L identified in LER 50-387/984)08 that a test procedure error resulted in inadvertently dewnergizing a portion of Secondary Containment Isolation Logic for about fourteen hours, a time in excess ofthat allowed by technical specifications.
The licensee's corrective actions were adequate.
This non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation.
10/12/1998 1998010-06 Prl: OPS Licensee NCV Prl: 5A Sec:
Sec:
Ter:
PP8L identified in LERs 50-388/98-001, 50-388/98403, and 50-388/98404 an inadequate surveillance that resulted from a word processing soffware conversion error. The licensee's corrective actions were adequate.
This non-repetitive, licensee identified and corrected violation is being treated as a nonwted violation.
10/12/1998 1998010 Prl: OPS Sec: MAINT NRC NEG Prl:1B Sec: 2A Ter.
Operators responded adequately to an unplanned Unit 1 scram on October 3, 1998. A corroded connection on a potential transformer resulted in a main generator protective relay actuation which, in turn, caused a generator trip and subsequent reactor scram.
PP&L's corrective actions were adequate.
10/12/1998 1998010 Prl: OPS Sec: MAINT NRC NEG Prl: 1B Sec: 2A Ter:
Operators were challenged and responded appropriately to several equipment malfunctions and minor plant transient including oil injection into Unit 1 reactor coolant due to a reactor water cieanup system fault, a Unit 2 main generator transient during main turbine control valve testing, and a Unit 2 unexpected half-scram, due to a recirculatIon flowunit failure. Appropriate SSES procedures were adhered to and actions were adequately performed, communicated and documented.
08/31/1998 1998007 Prl: OPS Sec:
NRC NEG Pri: 1B Sec:
'er:
On July 2, 1998, a Unit 2 scram during plant startup occurred due to poor reactivity control management.
Procedures did not contain sufficient restrictions for reactivity manipulations of Group 2 control rods, operating crew team dynamics and shift management and supervisory oversight were not effective in preventing the scram.
After criticalitybut before the point of adding heat was achieved, control rod withdrawals were stopped for about 60 minutes.
During this time, core decay heat caused reactor coolant temperature to increase, returning the core to a subcritical condition. With the core now subcritical, and lacking specific procedural restrictions, a Plant Control Operator (PCO), with approval of the senior reactor operator responsible for reactivity management, continuously withdrew a Group 2 control rod. The continuous rod withdrawal caused relatively high reactivity addition and power increase rates.
Two PCOs attempted to up-range intermediate range monitors (IRMs) to keep the IRMs on scale.
Each PCO down-ranged an IRM, in error, resulting in a reactor scram.
Item Type (Compliance,Followup,Other)
~ From 08/01/1998 To 01/15/1999
I'
Page:
3 of 10 Region I
SUSQUEHANNA United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time: 16:21:51 Date Source Functional Area Template ID Type Codes Item Description 08/31/1998 1998007 Prl: OPS Sec:
NRC NEG Pri: 3A Sec: 5A Ter.
The staitup training portion of the SSES licensed operator re-qualification program was adequate.
However, on July 2, 1998, operators departed from the staitup training by using two Plant Control Operators to operate the intermediate range monitor range switches.
PP&L training and condition report action items on training in support of the July 3, 1998, staitup were adequate.
08/31/1998 1998007 Prl: OPS Sec:
NRC POS Pri:1B Sec: 1C Ter.
PP &L's initial corrective actions following the Unit-2 scram on July 2, 1998, were adequate, including the activities of the Event Review Team, Plant Operations Review Committee, and Independent Safety Engineering Group.
08/31/1998 1998007 Prl: OPS Sec:
NRC POS Pri: 1C Sec: 2A Ter:
The licensee conducted plant operations in accordance with SSES procedures, and established effective equipment alignment and operability. The alignment of the Ultimate Heat Sink, Reactor Water Cleanup and Transverse Incore Probe systems was determined to be adequate.
The material condition of both units was adequate.
08/31/1998 1998007 Pri: OPS Sec:
NRC POS Pri: 1C Sec: 3A Ter.
Based on inspector review of a sample of 38 Operability Determinations (ODs) and Condition Report (CR) action items, PP&L adequately identified degraded conditions on safety related equipment, adequately initiallyresolved the degraded condition, and ifappropriate, developed adequate long term corrective actions.
08/31/1998 199800741 Prl: OPS Sec:
NRC VIO IV Prl: 4B Sec: 5A Ter. 5C PP&L failed to promptly identify and take corrective actions for a significant condition adverse to quality that could have prevented the July 2, 1998 reactivity control scram event.
PP&L failed to initiate a condition report following a June 26, 1998, reactivity control event in which continuous Group 2 rod withdrawal caused a relatively high reactivity addition rate and a corresponding high rate of power increase which required operator action to mitigate. On July 2, 1998, a similar Group 2 control rod withdrawal led to a reactor scram.
The failure to initiate a condition report was a violation of 10CFR 50 Appendix B Criterion XVI.
08/31/1998 1998007%3 Prl: OPS Licensee NCV Pri: 1C Sec:
Sec: 5A Tel".
PP&L kfentified in LER 5M87/984)08 that the position indication for some primary containment isolation valves had not been tested as required by Technical Specifications.
The licensee's corrective actions were adequate.
This non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation.
01/04/1999 1998012 Prl: MAINT NRC POS Prl: 3A Sec:
Sec:
Ter:
The Unit 2 high pressure coolant injection (HPCI) system outage was well planned and executed.
The pump and turbine equipment areas were maintained as dean areas which resulted in an excellent work environment.
Excellent coordination of the HPCI post maintenance test minimized the heat addition to the suppression pool. (Section M1.1) 01/04/1999 199801241 Pri: MAINT Licensee NCV Sec:
Prl: 2B Sec:
Ter.
PP&L identified that channel functional surveillance tests of the source range monitors did not include the indication portion ofthe channels as acceptance criteria, as required by Technical Specifications.
PP&L's proposed and
, completed corrective actions, induding procedure and programmatic actions, were good. This non-repetitive, licensee identified and corrected violation is being treated as a nonmted violation, consistent with Section VII.B.1 of the NRC Enforcement Policy. LER 50-387/388/98-01 7 is dosed.
(Section 08.1) 01/04/1999 1998012 Pri: MAINT Sec: OPS NRC POS Pri: 3A Sec: 5A Ter: 1C Instrumentation and control technicians promptly reported an activity that led to the foreign material addition to the Unit 2 standby liquid control (SLC) tank. The technicians, actions were representative of a good safety culture to report work activity problems.
The shift supervisor's continuous operability assessment led to the appropriate SLC pump operability determination and the timely removal of all foreign material from the SLC tank. (Section M1.1)
Item Type (Compliance,Followup,Other), From 08/01/1 998 To 01/15/1 999
Page:
4 of 10 Region I
SUSQUEHANNA United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time: 16:21:51 Date Source Functional Area Template ID Type Codes Item Description 11/23/1998 1998011 Pri: MAINT NRC NEG Prl: 2A Sec:
Sec:
Ter.
Operators and maintenance technicians responded properly to numerous equipment problems.
Previous analysis and completed corrective actions have not been fullyeffective at preventing recurrence of some equipment problems.
Examples included repetitive instances of Unit 2 containment instrument gas header pressure loss due to a stuck open check valve, "C" emergency diesel failure to start, and a repetitive steam leak on reactor feedwater pump turbine steam supply valve HV-12710C requiring a second on-line leak seal repair.
11/23/1998 1998011 Prl: MAINT.
NRC POS Prl: 2B Sec:
Sec:
Tel".
The inspectors concluded that the PP8 L method to assess plant risk for on-line/emergent work, by reviewing the work in accordance with the current revision of the Susquehanna Team Manual and quality assurance procedures, meets the intent of the maintenance rule.
11/23/1998 1998011 Prl: MAINT NRC POS Prl: 5A Sec:
Sec:
Ter:
PP&L Management's proactive response to the residual heat removal service water pump shalt failure aggressively resolved this potential common cause failure.
10/12/1998 1998010 Prl: MAINT NRC NFG Prl: 1B Sec:
Sec: 2A Ter.
Operators and maintenance technicians were challenged and responded well to several degraded material conditions, including a minor steam leak on the Unit 1 feedwater check valve, a Unit 2 electro-hydraulic control system power supply failure, and a minor steam leak on a Unit 2 pressure sensing line to a pressure switch for the Main Steam Low Pressure Isolation logic. Appropriate SSES procedures were adhered to and actions were adequately performed and documented.
10/12/1998 199801042 Prl: MAINT Licensee NCV Sec:
Prl: 2A Sec: 5A Ter. 5C PP8 L identified in LERs 50-387/98401, 50-387/98406, 50-388/98402, and 50-388/98406 that continuous vent sampling, as required by Technical Specifications, was not performed on four separate occasions, over a four month period, due to sample tubing separation from its connectors.
PP&L determined the cause to be age related loss of resilience of the tubing. The licensee's corrective actions were adequate.
These non-repetitive, licensee identified and corrected violations are being treated as a non-cited violation.
10/12/1998 199801044 Prl: MAINT Licensee Sec:
NCV Prl: 4C Sec: 5A Ter.
PP&L identified in LER 50-387/98-005 that the test frequency for nine check valves exceeded the inservice testing program test frequency. The appropriate tests were performed with adequate results. The licensee's corrective actions, including procedure and programmatic corrective actions, were adequate.
This non-repetitive, licensee identified and corrected violation is being treated as a nonmted violation.
10/12/1998 199801047 Prl: MAINT Licensee NCV Prl: 2A Sec:
Sec: 5A Ter: 5C 10/12/1998 199801043 Prl: MAINT Licensee NCV Prl: 4C Sec: ENG Sec: 5A Ter:
PP&L identified continuous vent sampling, as required by Technical Specification (TS), was not performed on three separate occasions, over a four day period; during this same period, sample flow rate estimates were not completed within the TS time limiton one occasion.
These events involved the mechanical failure of a sample pump, inadequate temporary installation and operation of a backup sampling system, and inadequate attention to detail by non-licensed technicians.
The licensee's corrective actions were adequate.
These non-repetitive, licensee identified and corrected violations are being treated as a non-cited violation.
PP&L identified in LER 50-387/98402 pressure instruments that were not leak rate tested as required by Technical Specifications. A Notice of Enforcement Discretion, requested by the licensee, was approved by the NRC on February 3, 1998. The licensee completed testing with adequate results. The licensee's corrective actions were adequate.
This non-repetitive, licensee identified and corrected violation is being treated as a nonmted violation.
Item Type (Compliance,Followup,Other), From 08/01/1998 To 01/15/1999
Page:
5 of 10 Region I
SUSQUEHANNA United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time: 16:21:51
.Date Source Functional Area Template ID Type Codes Item Description 09/18/1998 01014-EA1998140 Prl: MAINT Sec:
NRC VIO IV Pri: 5B Sec:
Ter:
Contrary 10 CFR 50 Appendix B Criterion XVI~ Corrective Action, PP &Lfailed to promptly identify and correct a condition adverse to quality involving the depressurization of the SLCS accumulators.
Specifically, prior to September 1997, PP&L did not initiate Condition Reports, nor perform an evaluation to justify that the ability of the SLCS to perform its safety function was not adversely impacted when the accumulators were found below the pressure required by procedure.
Additionally, following maintenance on both Unit 1 SLCS accumulators in September 1997. PP&L did not recognize that the caps on the accumulator gas valves were apparently improperly tightened causing the valves to leak.
Although your staff recognized in September 1997 that depressurization of the accumulators could adversely impact the operability of the SLCS, the degraded condition of the Unit 1 accumulators was not identified until November 25, 1997.
08/31/1998 199800742 Prl: MAINT Licensee NCV Sec:
Prl: 2A PP&L identified in LER 50-387/97-022 that the primary coolant degasifier exhaust treatment system may have been degraded, due to water intrusion and wetting of the charcoal filter, and had not been surveillance tested, as required by Sec:5A
. TechnicalSpecification.
Thelicensee'scorrectiveactionswereadequate.
Thisnon-repetitive,licenseeidentifiedand corrected violation is being treated as a non-cited violation.
Ter: 5B 01/04/1999 1998012 Prl: ENG NRC POS Prl: 3A Sec:
Sec:
Ter.
System and maintenance engineers provided good outage support at the high pressure coolant injection (HPCI) jobsite.
Also, the HPCI system engineer monitored the post maintenance surveillance test and provided timely feedback to the operator performing the test.
(Section M1.1) 01/04/1999 1998012-02 Prl: ENG Sec: MAINT 11/23/1998 1998011 Prl: ENG Sec:
NRC VIO IV Pri: 4C Sec: 5C Ter. 2A NRC NEG Prl: 4A Sec:
Ter:
PP&L failed to adequately translate the system design, from a modification, into appropriate specifications, drawings, and procedures, and on two separate occasions substituted gasket material without a review for suitability of materials.
The inspectors determined this was an apparent violation of 10 CFR 50 Appendix B, Criterion III~ Design Control.
PP&L's initialcorrective actions were good. However, the proposed final corrective actions, which appeared reasonable.
to correct the original condition, were not performed ln a timely manner.
In addition, PP&L failed to recognize that SSES design control requirements had not been followed, when a different type gasket was installed in the plant. URI 50487,388/98-06-03 is closed. (Section E8.2)
The inspectors concluded that the lack of an adequate feedwater loop seal existed since initial plant startup.
Once the lack of an adequate loop seal and other related issues were documented in condition reports, PP&L performed thorough operability determinations.
PP&L's completed and planned corrective actions were well planned and thorough.
11/23/1998 199801145 Prl: ENG Licensee NCV Sec:
10/12/1998 199801041 Prl: ENG Licensee NCV Sec:
Prl: 4A Sec:4C Ter.
Prl: 5A Sec: 5B Ter. 5C PP&L identified inconsistencies within the FSAR and TS for the feedwater containment boundary penetrations.
These inconsistencies resulted in PP&L not requesting an exemption from 10 CFR 50 Appendix J testing. PP&L's complete corrective actions and scheduled corrective actions were thorough and complete.
This non-repetitive, PP&L identifie and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
PP &Lidentified in Licensee Event Report 50-387/97424 a single failure mechanism that could enable drywell and suppression chamber atmospheres to communicate through a bypass line, following a postulated loss of coolant accident.
The licensee's interiin corrective actions and planned modifications were adequate to resolve this issue.
In accordance with the NRC Enforcement Policy,Section VII.B.3,Violations Involving Old Design Issues, the NRC is exercising enforcement discretion and not citing this violation.
10/02/1998 1998005 Prl: ENG Sec:
NRC NEG Prl: 4B Sec:4C Ter. 5A PP&L Nuclear Department Administrative Procedures provide adequate guidance to determine ifa 10 CFR 50.59 unreviewed safety question exists. These docuinents dearly delineate the responsibilities for various processes within the 10 CFR 50.59 program and provide adequate controls for record retention and reporting the results of the evaluations.
The team noted several instances in which the required 10 CFR 50.59 documentation was not completed for condition reports dispositioned "use-as-is," as required by program procedures.
However, technical evaluations provided bases for no unreviewed safety question.
The failure to implement the administrative procedure for 10 CFR 50.59 evaluations is considered a minor violation of procedural adherence, and is not being cited for formal enforcement action.
Item Type (Compliance,Followup,Other), From 08/01/1998 To 01/15/1 999
Page:
6 of 10 Region I
SUSQUEHANNA United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time: 16:21:51 Date Source Functional Area Template ID Type Codes Item Description 10/02/1998 1998005 Pri: FNG NRC POS 'rl:4B Sec:
Sec: 4C Ter.
10/02/1998 1998005 Prl: ENG NRC POS Pri: 4B Sec:
Sec: 4C Ter:
The core spray system was found to be installed and operated in a manner consistent with the design requirements for electrical power supplies as described in the update final safety analysis report and design basis documents.
Calculations reviewed were adequate to assure that the components and control circuits associated with the operation of the core spray system had sufficient direct current voltage to perform the intended design function. Refueling testing and emergency diesel load calculations demonstrated the adequacy of the electrical power supply to the core spray system components.
The inservice testing program for the core spray system was sound.
Program documents were found to be well organized, with appropriate records of relief requests, test deferral justifications and supporting technical information.
Test failures identified during relief valve testing were appropriately dispositioned.
The industry experience review program appropriately considered industry information.
10/02/1998 199800541 Pri: ENG Sec:
NRC VIO IV Prl: 4B Sec: 5A Ter. 5C Discrepancies identified in surveillance test procedures indicated weak engineering support in assuring acceptance criteria bases were sound. The acceptance criteria for Unit 1 core spray test pressure did not take into account system configuration differences between Units 1 and 2, even though these differences were identified in design calculations.
The Unit 2 core spray quarterly fiowsurveillance test inappropriately included a non-conservative correction factor for which no basis could be identified. Although the consequence of these discrepancies did not result in system inoperability, the above failures to incorporate the requirements and acceptance limits contained in apphcable design documents are two examples of a violation of 10 CFR Part 50, Appendix B, Criterion III.
The resolution of core spray flowconcerns reflected a lack of questioning attitude. PP&L missed opportunities to identify that the loss of coolant accident (LOCA) analysis did not reflect the correct core spray flowin the faciTity's design. The failure to ensure that the design basis is correctly translated into the LOCA analysis is a third example of a violation of the design control requirements of 10 CFR Part 50, Appendix B, Section III.
10/02/1998 1998005 Prl: ENG Sec: OPS NRC NEG Prl: 1C Sec:4B Ter: 5A PP&L's program and process controls for the identification of conditions adverse to quality were adequate.
The team's review of sixty condition reports indicated that the initiation threshold was sufficiently low. However, two conditions, which were not documented, reflected inconsistency in the initiation of condition reports. A pressurization of a portion of Unit 1 core spray discharge piping was not documented in a condition report, although a similar problem with the residual heat removal system was documented.
An unexpected power increase was not document in a condition report; this event was also documented in NRC inspection report 50-387,388/98-07.
08/31/1998 1998007-05 Pri: ENG Licensee NCV Prl: 4C Sec:
Sec: 5A Ter.
PP&L identified In LER 50-387/98404 that a portion of Residual Heat Removal system logic had not been surveillance tested, as required by Technical Specification. The licensee's corrective actions were adequate.
This non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation.
08/31/1998 199800746 Prl: ENG Sec:
NRC URI Prl: 4A Sec: 4B Ter: 5A PP&L took adequate initial corrective actions for a non-conseivative ultimate heat sink (UHS) Technical Specification (TS) surveillance requirement that resulted from a PP&L evaluation.
However, since the PP&L TS surveillance requirement acceptance criteria for key UHS parameters do not consider instrument measurement uncertainty in establishing the acceptance criteria, an unresolved item was identified to review a PP&L assessment of margins available in the UHS analysis and a PP8L assessment of measurement uncertainty as applied to the surveillance procedures.
01/04/1999 1998012 Prl: PLTSUP NRC POS Pri: 3A Sec:
Sec:
Ter.
The security computer replacement, in the Security Control Center, was well controlled and completed with minimal interruptions to the normal plant access areas.
A significant improvement was noted for the plant accountability capabilities.
(Section S2) 11/23/1998 1998011 Prl: PLTSUP NRC POS Prl: 3A Sec:
Sec: 3B Ter:
PP&L implemented overall effective surveys, monitoring, and control of radioactive materials and contamination.
The surveys, monitoring, and controls were performed with calibrated and properly used devices.
Personnel and area contamination rates were properly tracked and trended.
Item Type (Compliance,Followup,Other), From 08/01/1998 To 01/15/1999
4
Page:
7 of 10 Region I
SUSQUEHANNA United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time: 16:21:51 Date Source Functional Area Template ID Type Codes Item Description 11/23/1998 1998011 Prl: PLTSUP NRC POS Prl: 3A Sec:
Sec: 3B Ter:
PP&L's self-identification and corrective action processes in the area of radiation protection were effective. Quality Assurance surveillances, corporate assessments, and self-assessments continued to be effective in identifying, at a low threshokl, deficiencies and improvement opportunities.
Corrective actions were implemented for findings.
11/23/1998 1998011 Pri: PLTSUP NRC STR Prl: 3A Sec:
Sec:3B Ter.
PP8L implemented effective radiological controls at SSES.
Access controls to radiologically controlled areas were effective, appropriate occupational exposure monitoring devices were provided and used, personnel occupational exposure was maintained within applicable regulatory hmits and As-Low-As-Reasonably-Achievable (ALARA),and the radiation work permit program was implemented properly for control of radiological work.
10/19/1998 02014 Prl: PLTSUP NRC Sec:
VIO IV Pri: 4A PP&L failed to properly implement the requirements of National Fire Protection Association Standards 13, 15, 72D, an 72E in the design and installation ofthe SSES fire detection and suppression systems, as required by SSES Fire Sec:
Protection Review Report (FPRR), Sections 4.1.2, 4.3, and Table 5.0-1, sections E.1, and E.3.c. This was a violation of
- Operating License Conditions to implement and maintain provisions of the approved fire protection program, as
'escribedin the SSES FPRR.
10/19/1998 03014 Prl: PLTSUP NRC VIO IV Prl: 4A Sec:
Sec: 1C Ter.
PP&P failed to provide 8-hour battery powered emergency lighting in all areas of the plant requiring manual actions for safe shutdown; as required by SSES Fire Protection Review Report (FPRR), Section 3.3.2 and Table 5.0-1 ~ section D.5.a. This was a violation of Operating License Conditions to implement and maintain provisions ofthe approved fire protection program, as descnbed in the SSES FPRR.
10/19/1998 05014 Prl: PLTSUP NRC Sec:
VIO IV Pri: 4A Sec: 4C Ter:
PP&L failed to provide tools and equipment necessary to make connection from the fire water system to the condensate transfer system to assure availability of the keepfill system, which is necessary to prevent water hammer in the High Pressure Coolant Injection, Reactor Core Isolation Cooling, Core Spray, and Residual Heat Removal system discharge iping, as required by SSES Fire Protection Review Report (FPRR), Section 3.3.1.1. This was a violation of Operating icense Conditions to implement and maintain provisions of the approved fire protection program, as described in the SSES FPRR.
10/19/1998 01014 Prl: PLTSUP NRC VIO IV Prl'A Sec: ENG Sec:4C Ter.
PP&L failed to provide a shutdown methodology that would have maintained the indicated reactor vessel water level above the top of the active fuel dunng a postulated fire, as required by SSES Fire Protection Review Report (FPRR) ~
Section 3.0. This was a violation of Operating License Conditions to implement and maintain provisions of the approved fire protection program, as described in the SSES FPRR.
10/12/1998 1998010 Prl: PLTSUP NRC POS Prl: 2A Sec:
Sec: 2B Ter: 3A SSES security facilities and equipment in the areas of protected area assessment aids, protected area detection aids, and personnel search equipment were determined to be well maintained and reliable and met PP&L's commitments and NRC requirements.
10/12/1998 1998010 Prl: PLTSUP NRC POS Prl: 2B Sec:
Sec: 3A Ter:
The licensee effectively maintained and implemented a radiological environmental monitoring program in accordance with regulatory requirements.
10/12/1998 1998010 Prl: PLTSUP NRC POS Prl: 2B Sec:
Sec: 3A Ter:
Generally, the licensee effectively maintained system operability and performed channel calibrations and channel functional tests for the meteorological instrumentation. A NRC identified concern with the adequacy of the channel calibration methodology involving the wind speed channel was entered into PP&L's corrective action system for resolution.
Item Type (Compliance,Followup,Other), From 08/01/1998 To 01/1 5/1999
Page:
8 of 10 Region I
SUSQUEHANNA Date'ource Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX
. By Primary Functional Area Template ID Type Codes Item Description Date: 04/06/1999 Time: 16:21:51 10/12/1998 1998010 prl: pLTSUp NRC pOS Prl: 28 The licensee maintained effective radioactive liquid and gaseous effluent control programs.
The Offsite Dose Calculation Manual contained suflicient specification and instruction to acceptably implement and maintain the Sec:
Sec: 3A radioactive liquid and gaseous effluent control programs.
Ter:
10/12/1998 1998010 Pri: PLTSUP NRC POS Pri: 28 Sec:
Sec: 3A Ter.
The licensee established, implemented, and maintained an effective radiation monitoring system program with respect to electronic and radiological calibrations. As a result of self-assessment initiatives, the licensee implemented efforts to improve radiation monitoring system reliability. Licensee tracking and trending efforts provided sufficient information to assess radiation monitoring system performance.
10/12/1998 1998010 Prl:pLTSUp NRC pOS Pri:28 TheIicenseeestablished, implemented,andmaintainedaneffectiveventilationsystemsuivefllanceprogramwith respect to charcoal adsorption surveillance tests, high efficiency particulate mechanical efficiency tests, and air flowra Sec:
Sec: 3A tests.
Ter:
10/12/1998 1998010 Prl: PLTSUP NRC POS'ri:28 Sec:
Sec: 3A Ter:
The licensee established, implemented, and maintained an effective quality assurance program for the radioactive effluent control program with respect to audit scope and depth, audit team experience, and response to audit findings.
The licensee also implemented an effective quality control program to validate measurement results for radioactive effluent samples.
10/12/1998 1998010 Pri: pLTSUp NRC pOS Pri: 28 PP8L conducted security and safeguards activities in a manner that protected public health and safety in the areas of alarm stations, commumcations, and protected area access control of personnel, packages, and vehicles. This portion Sec:
Sec: 3A of the program, as implemented, met PP&L's commitments and NRC requirements.
Ter:
10/12/1998 1998010 Pri: pLTSUp NRC pOS Prl: 28 Security and safeguards procedures and documentation were properly imp'iemented.
Event logs were properly maintained and effectively used to analyze, track, and resolve safeguards events.
Sec:
Sec: 3A Ter:
10/12/1998 1998010 Prl: pLTSUp NRC pOS Prl: 28 Security training was conducted in accordance with the training and qualification plan and, based upon interviews an inspector observations, was considered effective.
Sec:
Sec: 3A Ter:
10/12/1998 1998010 Prl: pLTSUp NRC pOS Pri: 28 The level of management support was adequate to ensure effective implementation ofthe security program, as evidenced by adequate staffing levels and allocations of resources to support programmatic needs.
Sec:
Sec: 3A Ter:
10/12/1998 1998010 Pri: PLTSUP Sec:
pOS Prl: 2EI The review of PP&L's audit of the security program indicated that the audit was comprehensive in scope and depth, the audit findings were reported to the appropnate level of management, and the program was being properly administered.
Sec: 3A In addition, a review of the documentation applicable to the self-assessment program, indicated that the program as being effectively implemented to identify and resolve potential weaknesses.
Ter:
Item Type (Compliance,Foflowup,Other), From 08/01/1998 To 01/15/1999
Page:
9 of 10 Region I
SUSQUEHANNA Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSuE MATRIX By Primary Functional Area Template ID Type Codes Item Description P
Date: 04/06/1 999 Time: 16:21:51 10/12/1998 1998010 Prl: PLTSUP NRC POS Prl: 2B The audits and self-assessments were of sufficient depth to assess the implementation of the Radiological Environmental Monitoring Program and the Meteorological Monitoring Program.
Sec:
Sec: 3A Ter. 5A 10/12/1998 1998010 Pri: PLTSUP NRC POS Prl: 2B The environmental laboratory continued to implement effective Quality Assurance and Quality Control programs for the Radiological Environmental Monitoring Program samples, and continued to provide effective validation of analytical Sec:
Sec: SA results.
Tef:
10/12/1998 1998010 Prl: PLTSUP NRC POS Prl: 3A Security force members adequately demonstrated they had the requisite knowledge necessary to effectively irnpleme the duties and responsibilities associated with their position.
Sec:
Sec:
Ter.
08/31/1998 1998007 Prl: PLTSUP
'NRC POS Prl: 2B Sec:
Sec: 3A Ter.
The solid radioactive waste management program was effective based on proper implementation ofthe program by knowledgeable personnel, the existence of appropriate procedures and controls, and the acceptable condition of facilities and equipment.
The Process Control Program was complete, detailed, and provided an accurate description of the waste types generated, waste stream sampling and analyses performed, and waste processing methods used.
08/31/1998 1998007 Prl: PI.TSUP NRC POS Pri: 2B The program to transport low level radioactive waste and other radioactive materials was generally effective. The shipping manifests and supporting documentation were properly prepared, radiation and contamination limits were met, Sec:
Sec: 3A waste was properly c/assified, and shipments were properly typed as to their Department ofTransportation dass.
Ter.
08/31/1998 1998007 Prl: PLTSUP NRC POS Pri: 2B The NRC and Department ofTransportation training and retraining requirements for radioactive waste group personnel were met. While overall performance was effective, compensatory measures were initiated to assure that personnel Sec:
Sec: 3A training and qualification in the use and application of programs and procedures used to document waste shipments, and ctassify waste type, was sufficient.
Ter:
08/31/1998 1998007 Prl: PLTSUP NRC POS Prl: 2B The self-assessment and corrective action programs, in the area of radioactive waste and radioactive material transportation, were effective. The Technical Specification required audit was extensive in scope and depth, and Sec:
Sec: 3A surveillance and quality control inspections identified items for enhancement and corrective action. The threshold for generation of condition reports was low.
Tel".
'8/31/1998 1998007 Pri: pLTSUp NRC POS Pri: 3A The licensee's presentation of training to the offsite emergency response agencies was good and included all the topics required by NRC regulations.
Sec:
Sec:
Ter.
08/31/1998 1998007-04 Prl: PLTSUP Licensee NCy Pri: 2B PP&L identified in LER 50-387/98403 that a fire barrier wall in the emergency diesel generator building was not included in fire protection surveillance procedures.
The licensee's corrective actions were adequate.
This Sec:
Sec: 5A non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation.
Ter.
Item Type (Compliance,Foliowup,Other), From 08/01/1998 To 01/15/1999
Page:
10 of 10 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 04/06/1999 Time: 16:21:51 Legend Type Codes:
8 Bulletin CDR Construction 0EV Deviation EEI Escalated Enforcement Item IFI Inspector follow-up item LER Licensee Event Report LIC Licensing Issue MISC Miscellaneous MV MinorViolation NCV NonCited Violation NEG Negative NOED Notice of Enforcement Discretion NON Notice of Non<onformarice P21 Pait21 POS Positive SGI Safeguard Event Report STR Strength URI Unresolved item VIO Violation WK Weakness Template Codes 1A Normal Operations 1B Operations During Transients 1C Programs and Processes 2A Equipment Condition 2B Programs and Processes 3A Work Perfonnance 3B KSA 3C Work Environment 4A Design 4B Engineering Support 4C Programs and Processes 5A Identification 5B Analysis 5C Resolution ID Codes:
NRC NRC Self Self-Revealed Licensee Licensee Functional Areas:
OPS Operations MAINT Maintenance ENG Engineering PLTSUP Plant Support OTHER Other EEls are apparent violations of NRC Requirements that are being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action" (Enforcement Policy), NUREG-1600. However, the NRC has not reached its final enforcement decision on the issues identified by the EEls and the PIM entries may be modified when the final decisions are made.
URls are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. A URI may also be a potential violation that is not likelyto be considered for escalated enforcement action. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.
Item Type (Compliance,Followup,Other), From 08/01/1998 To 01/15/1999
SUSQUEH/&lNA 18z 2 PLP84T ISSUES MATRIX Date Type Source
/D SFA Code Item Description 7/20/98 Positive IR 98-06 N
OPS 1A 1C 3B Each of the CRs contained an operability determination (OD). With the exception of the operability determination related to the acoustic monitor and water intrusion into the "A" emergency diesel generator fuel oil storage tank, the ODs were found to have been adequately performed.
(Section 04.1) 7/20/98 Negative IR 98-06 7/20/98 Positive IR 98-06 N
OPS 1A 1C 3A N
OPS 1A 3A The NRC identified a work control evolution that had removed redundant Emergency Switch Gear Coolers (ESGC) from service.
When brought to the licensee's attention, the licensee 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)
The licensee conducted plant operations in accordance with SSES procedures, and established 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) 6/8/98 Positive IR 98-03 N
OPS 1A 3A 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) 6/8/98 Positive IR 98-03 N
OPS 1A 3A 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) 6/8/98 Positive 6/8/98 Positive IR 98-03 IR 98-03 L
OPS 1B 3B N
OPS 1A 3A Operator response to the discovery of a misaligned resin effiuent 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 02.3)
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)
FROM: 10/1/97 TO: 9/17/98 Page 1 of 25 6 April 1999
SUSQUEH/NINA IR. 2 PV'iNT ISSUES MATRIX Date Type Source ID SFA Code Item Description 6/8/98.
Negative IR 98-03 N
OPS 1A 1C 3B Twenty seven safety related initial Operability Determinations (ODs) and Condition Reports (CRs) were reviewed in detail and were'found to be adequately performed.
Two PP&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.
(Section 04.1) 6/8/98 Positive IR 98-03 N
OPS 1B-3B 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) 5/14/98 Positive 5/14/98 Positive IR 98-02 S
LER 97-04 NCV 98-02-01 IR'98-02 N
OPS 1B 2A OPS 1C 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 in<epth and conservative reviews and demonstrated a conservative and safe approach.
5/14/98 Positive IR 98-02 N
OPS 1A 3A A sample 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.
5/14/98 Positive 5/14/98
.Positive IR 98-02 L
IR 98-02 N
OPS 3A 5A OPS 1C Operator response to the discovery of a misaligned 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 system.
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.
FROM: 10/1/97 TO: 9/17/98 Page2 of 25 6 April 1999
SUSQUEH/NINA IS. 2 PLANT ISSUES IVIATRIX Date ape Source
/D SFA Code
/tern Description 5/14/98 Positive IR 98-02 N
OPS 1A Operators were observed to respond well to control room alarmed conditions 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 announced and documented.
5/14/98 Positive IR 98-02 3/16/98 NCV IR 98-01 Negative NCV 98-01-11 NCV 98-01-12 N
OPS 1A
'3B L
OPS 3A 5C 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.
Licensed and non-licensed operator activities were well performed and communicated.
Shift tumovers were observed to be detailed and complete.
AuxiliarySystem Operators were not consistently performing radwaste control room panel alarm tests and Plant Control Operator performance issues were identified regarding performance of main control room annunciator alarm tests in the same time period when VIO 50-387, 388/96-270-01022 was issued.
3/16/98 Negative IR 98-01 L
OPS 3A PP8L's corrective actions for three procedure violations, associated with the June 1996 "E" 5C emergency diesel generator circuit breaker misalignment, were acceptable.
Corrective actions focused on improving operator performance, management oversight, and independent assessment.
Subsequent licensee audits of operator performance were acceptable and appropriate actions were taken to validate and verify the quality of computer data used to assess operator performance.
FROM: 10/1/97 TO: 9/17/98 Page3of 25 6 April 1999
h II
SUSQUEWWNA IR. 2 PIAIVTISSUES MATRIX Date Type Source ID SFA Code 3/16/98 NCV IR 98-01 L
'egative LER 97-05-00 Item Description On March 25, 1997, while the unit was shut down, chemistry technicians were performing a transfer process from the reactor building ventilation stack monitor to the system particulate iodine noble gas (SPING) system.
During the transfer, a spurious reactor building criticality monitor alarmed, requiring the evacuation of the area in which the technicians were working.
Upon returning to the area the technicians realized that there had been an approximately 20 minute period that continuous sampling of the reactor building vent was not maintained in accordance with Technical Specification (TS) 3.3.7.11. The licensee determined that the reactor building criticality monitor had drifted low which caused the unanticipated alarm. The inspectors reviewed the Licensee Event Report, inspected the licensee's corrective actions and root cause evaluation, conducted an onsite field inspection and determined that there were no safety consequences associated with the failure to continuously monitor the stack release.
There were no safety consequences because the unit was shut down and there was a clear pattern of data established both before and after the missed time period. With respect to the criticality alarm drift, the driftwas in the conservative direction, and there was no significant pattern of spurious alarms. This TS violation resulted from circumstances not within reasonable licensee control, in that the criticality alarm failure could not have been avoided within the parameters of the licensee's surveillance program.
3/16/98 NCV IR 98-01 L
OPS LER NCV 98-01-02 Negative LER 97-03-00 3A On March 20, 1997, a service water radiation monitor was removed from service.
Subsequently a service water sample required by TS was not collected and analyzed within-the time specified by TS Limiting Condition for Operation (LCO) Action 3.3.7.10.
The TS LCO Action states that with less than the minimum required number of radiation monitors operable, the eNuent release pathway may continue for up to 30 days provided that, at least once per eight hours grab samples are collected and analyzed for gross radioactivity at a specific limitof detection.
The subject sample was taken and analyzed within fifteen minutes of the required eight hour period. The licensee determined that the root cause of the event was personnel error and entered the involved individual in the PP&L performance improvement process.
The inspectors performed a summary review of the Licensee Event Report, the associated condition report and its corrective actions.
In addition, onsite field inspections were performed.
Itwas determined )here was no safety impact from the delay in taking the eNuent sample, because the results of the sample were normal and as expected.
Therefore, this non-repetitiye, licensee identified and corrected violation is being treated as a non-cited violation, consistent with Section VII.B.1 of the NRC Enforcement Policy. This LER is closed.
FROM: 10/1/97 TO: 9/17/98 Page 4 of 25 6 April 1999
Date Type 3/16/98 Positive Source IR 98-01 N
OPS 5A 1C ID SFA Code Item Description A selection of Plant Operations Review Committee (PORC) and Susquehanna Review Committee (SRC) activities, covering a 3 month period, were reviewed.
NRC determined PORC and SRC, in general, conducted in-depth reviews and demonstrated a conservative and safe approach.
3/16/98 Positive IR 98-01 N
OPS 1C 3B The inspector concluded that Susquehanna's licensed operator re-qualification training program was satisfactory overall. The written examinations were adequate, but a section for five of six written examinations were weak. Examination administration was good, and operator performance was generally good with some individual operator deficiencies identified for followup.
3/16/98 Positive IR 98-01 N
OPS 3/16/98 Positive IR 98-01 N
OPS 4A 1B The licensee's approach to the establishment of alarm setpoints for safety relief valves (SRVs),
compensatory measures for a Notice of Enforcement Discretion on the "S" SRV and the control of SRV operability, were acceptable.
Operators were observed to respond well to control room alarmed conditions. Appropriate SSES procedures were adhered to, operability and impact on plant equipment were controlled, and actions were adequately announced and documented.
Operators identified a slow speed driftof one reactor recirculation pump, on two separate occasions, and responded well to these anomalies.
3/16/98 Positive IR 98-01 N
OPS 1A Operator communications were observed to be clear, concise, formal, and in compliance with SSES operations department procedures.
Shift tumovers were detailed and complete.
In general, communications between plant control operators and nuclear plant operators were observed to be of good quality.
1/19/98 Negative IR 97-10 N
OPS 3C 1C Operator performance was reviewed by direct observations, interviews, and evaluations of PP&L self assessments.
The inspectors verified the weaknesses, identified by the PP &Lself assessments, that were described as environmental factors.
Despite the weaknesses, the inspectors verified current operator performance was very good.
PP&L management is establishing general approaches to resolve these weaknesses.
The identified weaknesses currently have no apparent impact on the safe operation of SSES.
12/8/97 Positive IR 97-09 N
OPS 1B Operators responded well on September 1 ~ 1997, when a feedwater pump minimum flow control valve failed open. The licensee initiated a condition report to review the root cause and work authorizations to perform corrective actions. The inspector reviewed the licensee's corrective actions and found them to be adequate.
FROM: 10/1/97 TO: 9/17/98 Page5of 25 6 April 1999
SUSQUEILt&1NAIR. 2 PLANT ISSUES MATRIX Date Type Source
/D SFA Code Item Description 12/8/97 Negative IR 97-09 N
OPS SA 5B 3B Several weak initial operability determinations were identified by the inspectors.
After discussions with Operations and Nuclear System Engineering personnel, additional information was provided that justified why the equipment was capable of performing its intended safety function. The inspectors noted that PP8L.has not provided operability determination training for on shift personnel responsible for initial operability determinations.
Operations management is aware of this issue and is planning to enhance training in this area.
12/8/97 Positive IR 97-09
. N OPS 3A 1A Licensed operators responded well to specific annunciated plant conditions.
Licensed operators were able to clearly describe the reasons for their actions, discuss the impact of their actions upon the safe operation of the units, and fullyimplement established plant procedures.
10/20/97 Negative IR 97-07 N
OPS 4B 5B The initial operability determination for the Unit 2 High Pressure Coolant Injection (HPCI) overspeed trip assembly problem was weak. Nuclear System Engineering personnel overlooked the potential impact on the HPCI injection valve and how this impact could affect the response time to rated flow. PP8L management made a conservative decision to declare HPCI inoperable, pending further evaluation. Asubsequent revision of the operability determination provided a good basis for operability. Significant licensee attention was focused on resolution of the problem and the overspeed trip assembly has performed acceptably since the corrective maintenance.
10/20/97 NCV IR 97-07 L
LER NCV 97-07-05 Negative LER 97 00 OPS 5A During a review of procedures as a follow-up to a previous plant event, PP&L determined that the requirement ofTechnical Specification Table 3.3.7.10-1, ACTION 101 was not being met.
ACTION 101, requires a gross radioactivity analysis on liquid effluent grab samples when the associated effluent monitoring instrumentation is not operable to be performed.
Performance of gamma isotopic analysis does not meet the verbatim TS requirement since it does not measure gross radioactivity to a sensitivity of1E-7 microcurie/ml.
The cause of the event was determined to be human performance.
Itwas not recognized that a change to the TSs was required since itwas viewed that the isotopic analysis was an improved method of analysis.
The isotopic analysis is a better analysis in determining radioactivity in effluents.
Corrective actions include: procedure changes to require a gross radioactivity analysis along with the isotopic analysis and a revision to the Technical SpeciTications.
10/20/97 Positive IR 97-07 N
OPS 5C The resolution of several issues by the PP8L Corrective Action Team (CAT)was direct, safety oriented, and conservative.
The issues included loose pole pieces on 4 kv electrical breakers and level indication maintenance on the standby liquid control system.
FROM: 10/1/97 TO: 9/17/98 Page 6 of 25 6 April 1999
SUSQUEH/NINA IR. 2 PL/&TISSUES MATRIX Date Type Source ID SFA Code Item Descripf/on 10/20/97 Positive IR 97-07 S
OPS 10/20/97 Positive IR 97-07 N
OPS VIO 97-07-02 10/20/97 Positive IR 97-07 N
OPS 1A The plant control operators (PCOs) responded well to those alarmed conditions requiring 3A actions.
PCOs were able to describe the reasons for their actions and discuss the impact of their actions upon the units. PCO actions were determined to be conservative and in accordance with established plant procedures.
1B A reactor feedwater pump (RFP) minimum flowcontrol valve failed open resulting in a reactor 5C water level induced transient. The Plant Control Operator (PCO) reduced power to 3A approximately 68%, reactor water level was recovered, and the unit was returned to a steady state condition. PCO actions were conservative and in accordance with unit procedures.
1A PPBL management conservatively opted to shut down Unit 2 in response to an increasing 5C trend of unidentifled reactor coolant system leakage before reaching Technical Specification (TS) limits. Good management involvement was observed during preparation for the shutdown and an orderly shutdown was conducted with no significant challenges to the operators.
1C On various occasions prior to October 17, 1997, the General Visual Inspections were not 3A performed during operator rounds as specified in Attachment A to procedure Ol-AD-016; in that, inspections of all rotating equipment, protective covers on load centers, and all accessible areas of the plant were not performed on every shift.
FROM: 10/1/97 TO: 9/17/98 Page 7 of 25 6 April 1999
SUSQUEH/WNA IR. 2 PLiI84T ISSUES MATRIX Date Type Source
/D SFA Code Item Description 7/20/98 URI Negative IR 98-06 S
MAINT 2A 5C 5B On July 3, 1998, the Unit 1 "S" safety relief valve (SRV) acoustic monitor had indication of a malfunction. Maintenance was performed on this monitor and the monitor was returned to 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 adequacy of acoustic monitor maintenance instructions and. procedures, the adequacy of the operability determination for the "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) 7/20/98'OED
IR 98-06 S
MAINT Negative 6/12/98 NCV IR 98-04 N
MAINT Negative NCV 98-04-04 EA 98-350 2A 5C 5B 4C PP8L requested enforcement discretion forTechnical Specification requirements concerning a failed acoustic position indicator for the Unit 2 "J" Safety Relief Valve, to avoid an undesirable transient as a result of forcing compliance with a license condition. The NRC approved PP8 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)
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, however addressing of the issues was delayed.
Atthe time of the 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 the Enforcement Policy.
6/12/98 Negative IR.98-04 N
MAINT 4C The licensee's program for assessing 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 assessment was adequately detailed, developed, and implemented.
FROM: 10/1/97 TO: 9/17/98 Page 8 of 25 6 April 1999
SUSQUEEGQPNA IR. 2 PIANTISSUES MATRIX Date 6/12/98 Type Source NCV IR 98-04 Negative NCV 98-04-03 EA 98-350 ID SFA Code N
MAINT 4C Item Description The licensee's new periodic maintenance effectiveness assessment procedure was adequate for implementing the requirements of the periodic assessments under 50.65(a)(3).
The first periodic 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 6/12/98 Positive IR 98-04 N
MANT 4C 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.
6/12/98 NCV IR 98-04 Negative NCV 98-04-02 EA 98-350 N
MAINT 4C Several structures, systems and components had exceeded their performance criteria in 1996 or 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.
6/12/98 Positive IR 98-04 N
MAINT 4C 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 reliability criteria were linked to the PRA assumptions and were acceptable.
6/12/98 Positive IR 98-04 N
MAINT 4C 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 for containment systems.
Truncation levels and human recovery actions were considered appropriately when evaluating the PRA results.
FROM: 10/1/97 TO: 9/17/98 Page 9 of 25 6 April 1999
SUSQUEHANNA IS. 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code Item Description 6/12/98 VIO SL-IV IR 98-04 VIO 98-04-01 EA 98-350 N
MAINT 4C PPBL 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 qualiTied personnel and approved procedures.
In general, proper implementation, appropriate examination documentation, and adequate PPBL 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 ofwork 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) 6/8/98 VIO IR 98-03 VIO 98-03-04 N
MAINT 3A 3B 2B 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 M1.4) 6/8/98 Negative IR 98-03 6/8/98 Negative IR 98-03 N
MAINT N
MAINT 3A 3B 3B 3A 2B Seventeen of nineteen pre-planned maintenance activities observed/reviewed were found to be appropriately conducte'd 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)
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)
FROM: 10/1/97 TO: 9/17/98 Page10of 25 6 April 1999
'I
SUSQUEHANNA 16m 2 PVQIT ISSUES MATRIX Date TJPe 5/14/98 Positive Source IR 98-02
/D SFA Code N
MAINT 2A Item Description 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.
5/14/98 Positive IR 98-02 N
MAINT 3A 3B The surveillance activities observed/reviewed were adequately performed and appropriately controlled. The surveillance activities were accomplished by qualified and trained personnel 5/14/98 Positive IR 98-02 N
MAINT 3A 3B The planned maintenance activities observed/reviewed were found to be appropriately 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.
3/16/98 Negative IR 98-01 N
MAINT
. 3C 5C The licensee implemented several actions, in response to NRC and SSES self assessment identified issues, in the maintenance and work control programs.
The performance issues include, in part, work control effectiveness, outstanding work backlog, and maintenance activity control. These actions have not been in place for a sufficient period of time to show improvement in the maintenance area.
3/16/98 Negative IR 98-01 S
MAINT 2A 3A The "B" Emergency Diesel Generator (EDG) test run was discontinued following receipt of an unexpected turbocharger lube oil low pressure alarm. The cause was adequately identified, and the EDG was repaired and returned to service within the time period allowed by Technical Specification.
Overall, maintenance activities were adequate.
3/16/98 Positive
'/16/98 Positive IR 98-01 IR 98-01 N
MAINT 3A 3B N
MAINT 3A 3B The surveillance activities observed were adequately performed and appropriately controlled.
The activities were accomplished by qualiTied and trained personnel.
No violations of NRC requirements were identified.
Four planned maintenance activities, reviewed during this period, were found to be appropriately conducted and controlled. Interviews with maintenance personnel showed the individuals involved in these activities were knowledgeable, appropriately qualified, and capable of explaining their activities.
3/16/98 Negative IR 98-01 S
MAINT 2A 1B A PPBL management decision, to reduce power in response to a main generator isophase bus duct cooler leak, was well communicated within the operations department and was conservative.
The licensee initiated appropriate corrective actions, no violations of NRC requirements occurred, and the failure was documented for maintenance rule tracking purposes.
FROM: 10/1/97 TO: 9/17/98 Page 11 of 25 6 April 1999
SUSQUEH/NINA IR. 2 PLIGHT ISSUES MATRIX Date rape 1/19/98 Positive Source ID IR 97-10 N
SFA Code MAINT 3A 3B Item Description The surveillance activities observed were adequately performed and appropriately controlled.
The surveillance activities were determined to have been accomplished by qualified and trained personnel.
No violations of NRC requirements were identiTied.
12/8/97 VIO LER IR 97-09 N
VIO 97-09-02 LER 97-06-00 MAINT
~ 1/19/98 Positive IR 97-10 N
MAINT 3A 3B 2B 3A The planned maintenance activities, reviewed during this period, were found to be appropriately conducted and controlled. Interviews with maintenance personnel showed the individuals involved in the maintenance activities to be knowledgeable and capable of explaining their activities. No violations of NRC requirements were identified.
In March 1997, maintenance procedures for the replacement of the bonnet vent line for reactor recirculation valve HV-2F031B failed to ensure the vent line support configuration was not altered from its original design. As a result, excessive vibration during power operation caused a weld on the bonnet vent line to crack, resulting in a loss of reactor coolant. The failure to provide adequate procedures for control of safety related maintenance is identified as a violation.
12/8/97 Positive IR 97-09 N
MAINT 2B 3A The surveillance activities observed were adequately performed and appropriately controlled.
No violations of NRC requirements were identified.
12/8/97 Positive IR 97-09 N
MAINT 2B 3A 12/8/97 Negative IR 97-09 S
MAINT 2A Seven of the eight planned maintenance activities reviewed during this period were found to be appropriately conducted and controlled.
In one instance, informal drawings were used during corrective maintenance on non-safety related equipment.
This activity had no impact on safety related equipment and no violation of NRC requirements occurred.
A problem occurred with the level control valve for the "4C" feedwater heater. A power reduction to 80% was directed by procedures after preparations for corrective maintenance on the control valve caused an automatic an automatic isolation of the steam supply to the feedwater heater.
10/20/97 NCV IR 97-07 N
Negative NCV 97-07-07 MAINT 5C Corrective actions for a safety related check valve deficiency, identified in 1994, did not address generic implications.
In 1996, the same condition was identified on a different valve and, in this case, the planned actions to prevent recurrence were appropriate.
However, the administrative process to implement and track these actions was not initiated. These two corrective action problems are considered a violation of minor significance because this had no impact on safety.
FROM: 10/1/97 TO: 9/17/98 Page12of 25 6 April 1999
SUSQUEEGQVNA IR. 2 PLliNTISSUES MATRIX Date TIrpe Source ID SFA Code Item Description 10/20/97 NOED IR 97-07 LER IR 97-09 Negative LER 97-20-00 S
MAINT 2B 1C PP8L requested enforcement discretion for TS requirements concerning a failed acoustic position indicator for the "S" Safety Relief Valve. PP8L requested the enforcement discretion to avoid an undesirable transient as the result of forcing compliance with a license condition.
The NRC approved PP8L's request after determining the action involved minimal or no safety impact and had no adverse radiological impact on public health and safety.
10/20/97 Positive IR 97-07 N
MAINT 5B 5C The licensee's corrective actions in response to an interrupted cool down of the "C" Emergency Diesel Generator (EDG) were adequate.
The interrupted cool down did not affect the operability of the EDG.
10/20/97 Positive IR 97-07 N
MAINT 3B The maintenance task certification matrix and its implementation were adequate to control the assignment of qualified workers to safety related maintenance activities. No violation of NRC requirements was identified.
10/20/97 Positive IR 97-07 N
MAINT 3A 1C 3B Susquehanna surveillance activities, observed during this inspection period, were well performed, described and controlled by detailed Susquehanna procedures, and performed by well trained, experienced and capable technicians/operators.
10/20/97 Positive IR 97-07 N
MAINT 3A 3B The work authorization (WA)activities observed during this inspection period were, in general, well performed. The WAs described and controlled maintenance activities with adequate, but in some cases general, procedures.
The maintenance activities were implemented by well trained and experienced maintenance technicians, and resulted in equipment being returned to service in good condition.
10/20/97 VIO IR 97-07 VIO 9747-06 N
MAINT 2B 3A Susquehanna procedures for control of Standby Liquid Control (SLC) maintenance were inadequate in that the procedures did not control the activities such that the system remained in an analyzed configuration. The unanalyzed configuration had the potential to negatively affect the performance of this safety related system.
PP8L allowed maintenance work to proceed on the "A"SLC pump nitrogen accumulator without evaluating whether the activity would affect operability. Afterthe question of operability impact was raised by the NRC, an initial operability determination by the Shift Technical Advisor was weak because it did not address known technical issues with the potential to affect operability. The failure to provide adequate procedures for control of maintenance on safety related equipment is a violation of TSs.
FROM: 10/1/97 TO: 9/1 7/98 Page13 of 25 6 April 1999
0
SUSQUEE6&fNA 18 2 PLANT ISSUES MATRIX Date Type 7/20/98 URI Negative Source IR 98-06
/D SFA Code S
ENG 2A 4A 4C Item Description The heavy rains on June 23, 1998 resulted in significant quantities ofwater entering the "A" emergency diesel generator (EDG) storage tank through an unsealed penetration in the "A" EDG 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 activity which 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) 7/20/98 Negative IR 98-06 7/20/98 Negative IR 98-06 S
ENG 2A 2B
.4B S
ENG 4A 4C 2A During heavy rains, the Emergency Diesel Generator (EDG) Building sump room flooded, and as a result of foreign material lodged in a backflow preventer valve, the "A"EDG room basement also flooded. The licensee's initial actions for this 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 flood all of the EDG rooms from a single event, no violations of NRC requirements were identified. (Section E2.2)
The weld crack occurred because of a lack of fusion on the end cap weld base pass and unexpected high amplitude vibration. The vibration was the result of an error in the engineering analysis that resulted in a less than optimum installation of the flowsensing element.
PP8L took action to correct the Unit 2 failure and determined that Unit 1 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: 10/1/97 TO: 9/17/98 Page 14of 25 6 April 1999
sUsqvzH/DNA ia.2 pr.ANr rssvas Mere Date Type Source
/D SFA Code
/tern Description 11/5/96 NCV IR 98-03 L
ENG LER NCV 98-03-03 Positive LER 96-15-00 10/7/97 NCV IR 98-03 L
ENG LER NCV 98-03-02 Positive LER 97-23-00 8/8/97 NCV IR 98-03 L
ENG LER NCV 9843-01 Positive LER 97-18-00 5A 5B 5C 4C 4A 4C 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). PP8L 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 switchgear and established administrative controls for the position of breakers in switchgear.
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, "Circuit Breakers Left Racked Out in Non-Seismically Qualified Positions." The issue also was not likely to be identified by routine PPBL 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 of TS.
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.
PP8L 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 for the 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: 10/1/97 TO: 9/17/98 Page 15 of 25 6 April 1999
SUSQUEII/iZINAIR. 2 PL/&TISSUES MATRIX Date Type 6/30/98 VIO Source IR 98-08 VIO 98-08-02 6/30/98 NCV IR 98-08 Negative NCV 98-08-01 N
ENG N
ENG 4C 5A 5C 4C 5A 5C ID SFA Code Item Descr/pt/on In 1990 and 1991, PPEL 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. PP8L 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 PP&L safety evaluation for a facility modification concluded a Technical Specification (TS) revision was involved for a 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.
5/14/98 Positive IR 98-02 N
ENG 5/14/98 Positive IR 98-02 5/14/98 NCV IR 98-02 LER NCV 98-02-02 Positive LER 97-04 N
ENG L
ENG 5/14/98 Negative
- IR 98-02 N
ENG 4B 4A 4C 5A 4B 4C 5A The PP&L methodology, which used a test pressure less than the integrated teak 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..
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: 10/1/97 TO: 9I17/98 Page 16 of 25 6 April 1999
SUSQUEEBWNA I&.2 PLANT ISSUES MATRIX Date 3/16/98 ape NOED VIO LER Source IR 98-01 IR 97-06 VIO 97-04-01 LER 97-1 3-00
/D SFA Code S
ENG 4C
/tern Description On June 19, 1997, while both units were operating at 100% power, the licensee determined that the testing methodology used for activated carbon samples was different than that required by Technical Specification (TS). The licensee received a Notice of Enforcement Discretion to operate until it accomplished the required testing. VIO 50-387,388/97-04-01 and a notice of enforcement discretion were issued to the licensee.
The licensee responded to the violation in PP8L letter PLA4666, dated September 4, 1997, and affected adequate corrective actions which included a TS change, procedure changes, and technician training. VIO 50-387,388/97-04-01 was closed in inspection report 50-387,388/97-06, through onsite field inspection activities.
3/16/98 NCV IR 98-01 Negative IR 97-07 NCV 98-01-10 URI 97-07-09 N
ENG 4C PP8L failed to perform a 10 CFR 50.59 safety evaluation prior to opening a plant equipment hatch assumed to be closed by the tornado design basis analysis.
This condition existed for an extended period before identification by the NRC. Subsequently, plant equipment hatches have been verified to be in the condition assumed by the tornado analysis (shut) and are now being administratively controlled. PP&L's evaluation to determine whether an unreviewed safety question existed with the hatch open is expected in January 1998 and willbe reviewed to determine the safety significance of this violation. In the interim, this item is being tracked as an unresolved item.
3/16/98 Negative IR 98-01 N
ENG 4A Update from IR 98-01: The inspectors identified a floor hatch in the reactor building which was maintained open for many years.
In response to the inspectors questions, PP8L determined the site tornado analysis assumed the hatch was closed.
No safety evaluation was performed prior to placing the hatch in other than the analyzed position. A subsequent PP&L calculation determined the result of the tornado analysis was not adversely affected by hatch position.
The failure to perform a safety evaluation prior to changing the hatch position was a violation of minor significance and is being treated as a non-cited violation.
NRC identified three control room annunciators which alarm after TS Limiting Condition for Operation (LCO) action levels are exceeded.
The issue was discussed with operations
. management and itwas determined the general issue of annunciator conservatism, including LCO action statement start time, was being addressed in the PP8L corrective action system.
Several examples of unalarmed TS entries were identified by the NRC, but no violations of the TS allowed outage time were identified.
FROM: 10/1/97 TO: 9/17/98 Page 17 of 25 6 April 1999
'I SUSQUEH/&ANNAIR. 2 PL/&TISSUES MATRIX Date Type Source ID SFA Code Item Description 1/19/98 NCV IR 97-10 N
Negative NCV 97-10-05 ENG 4B 1A The "E" Emergency Diesel Generator (EDG) tripped on high jacket water temperature, as designed, during a surveillance test.
Prior to the surveillance, the Emergency Service Water (ESW) supply valve failed to stroke open under dynamic conditions and was not noticed by the operators.
Post maintenance testing for a previous maintenance activity failed to verify the valve would function under the expected operational conditions. Although the inadequate post maintenance test of the valve had the potential to impact safety related equipment, the "E" EDG was not aligned to a safety-related bus at the time of the event, there was no effect on the operating units, and no damage to the EDG occurred.
The licensee identified failure to provide adequate post maintenance testing for safety related equipment is considered a non-cited violation.
12/8/97 Positive IR 97-09 L
ENG 5A 4B PP8L identified a potential non-conservatism in the vendor supplied methodology used to establish minimum critical power ratio (MCPR) limits for single loop operation. The identification of this issue by PP8L was viewed as a positive indication of the level of scrutiny being given to fuel related calculations.
The inspector verified that conservative interim corrective actions have been implemented for Susquehanna pending the resolution of the potential issue, by the NRC Office of Nuclear Reactor Regulation.
10/20/97 NCV LER Positive IR 97-07 L
NCV 97-07-03 LER 97-1 0-00 ENG 4C 5A During a 1997 procedure review, the licensee discovered reactor water level instruments were inwperable, during a 1996 Unit 1 hydrostatic pressure test, without performing the required Technical Specification actions. The cause was determined to be a personnel error, made during a previous procedure revision.
The inspectors reviewed the corrective actions and found them to be adequate.
10/20/97 Negative IR 97-07 N
ENG 5B 5C 2A-The engineering corrective actions for problems with the Unit 1 RCIC drain pot level switch were not timely. This allowed continuous degradation of the drain line and a continuous alarmed condition for over ten months after it caused a forced shutdown. A modification to replace the drain pot level switch was completed and has been effective in restoring the normal operation of the RCIC system.
10/20/97 VIO IR 97-07 N
VIO 97-07-10 ENG 4C PP8L failed to perform a 10 CFR 50.59 safety evaluation prior to placing a floating service platform on the spray pond that serves as the ultimate heat sink for both Susquehanna units.
This condition existed for an extended period before identification by the NRC. PP8L has yet to perform an evaluation to determine whether an unreviewed safety question existed with the platform on the spray pond. Subsequently, the spray pond was verified to be in the condition assumed by the Final Safety Analysis (the platform was removed). Analysis of the spray pond design basis and evaluation of the potential USQ willbe reviewed with the response to this violation.
FROM: 10/1/97 TO: 9/17/98 Page 18 of 25 6 April 1999
SUSQUEHANNA IR. 2 PIANT ISSUES MATRIX Date Type 10/20/97 Positive Source IR 97-07 ID SFA Code Item Description N
ENG 4A A review of the Susquehanna responses to 10 CFR 50.63, Station Blackout (SBO) rule was conducted.
The licensee installed an auxiliary diesel power source to increase the SBO coping duration of its 125 Vdc batteries from approximately 5-hours to greater than 8-hours.
The NRC safety evaluation report concluded that Susquehanna must meet a 4-hour coping duration.
Therefore, the inspectors concluded that there was no current regulatory requirement for the licensee to maintain the auxiliary power source.
10/20/97 NCV IR 97-07 Negative NCV 97-07-08 N
ENG 5B 2A In February 1997, PP&L identified that the "A"Control Structure (CS) chiller would not automatically start as designed and took immediate actions to correct the problem.
- However, PP&L initiallyfailed to recognize this condition as outside the plant's design basis, as described in the Final Safety Analysis Report. Afte'r identification by the NRC, PPBL initiated a Condition Report, determined the condition was reportable, and submitted a Licensee Event Report as required.
Corrective actions for both the technical problem and the failure to recognize the condition outside the design basis were implemented by PP&L. In this case, the failure to report a condition outside the design basis within 30 days of discovery is a non-cited violation.
10/20/97 Positive.
IR 97-07 N
ENG 4C The erosion control program portion of engineering corrective actions for an indicated high level in a reactor core isolation cooling (RCIC) drain pot was determined to be outstanding.
FROM: 10/1/97 TO: 9/17/98 Page19of 25 6 April 1999
SUSQUEH/NINA IR. 2 PL4dlT ISSUES MATRIX Date Tj(pe 7/20/98 Positive Source IR 98-06
/D SFA Code N
PS, 1C 5A Item Description 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 with the offsite organization was not complete since it failed to evaluate interface with representatives of one of the risk counties.
(Section P7) 7/20/98 Positive IR 98-06 N
PS 1C 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) 7/20/98 Negative IR 98-06 N
PS 1C The licensee maintained a good Emergency Plan training program and ensured completion of all 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 of the same evaluation scenario for radiological assessment personnel for the last six years.
The licensee was effectively using mini-drillsto train on severe accident management concepts.
(Section P5) 7/20/98 Negative IR 98-06 N
PS 1C 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 of the 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 noncompliance is one of minor significance. This violation, therefore, willnot be subject to formal enforcement action. (Section P3) 7/20/98 Positive IR 98-06 N
PS 3A The emergency response facilities were very well maintained.
The licensee has enhanced the ability to 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)
FROM: 10/1/97 TO: 9/17/98 Page 20 of 25 6 April 1999
0
SUSQUEH/WNA 18z 2 PLIANTISSUES MATRIX s
Date ape Source
/D SFA Code Item Description 11/7/98 11/7/97 NCV IR 98-09 N
Negative IR 97-201 URI 97-201-5 NCV98-09-07 Negative IR 97-201 N
PS 4A PS 4B 4C Failure to properly implement the requirements of NFPA 14 in the design and installation of standpipe system.
Failure of the SSES Individual Plant Examination for External Events Review to consider the operational plant conditions or fire conditions which propagate into a large fire.
11P/97 Negative IR 97-201 N
PS 5A.
Failure of fire protection audits to evaluate the plant's compliance with 10CFR50 Appendix R.
5B 11/7/97 Negative IR 97-201 N
11/7/97 Negative IR 97-201 N
PS 1B 2A PS 1C 4C Fire brigade's effectiveness to control and suppress a fire during a drillexercise impaired by equipment logistics and deployment problems.
Fire brigade effectiveness to control and extinguish a fiammable or combustible liquids fire impacted by the policy to restrict the use of fire fighting foams on site.
5/14/98 Positive IR 98-02 N
PS 2B 1C Radiological controls for the As-Low-As-Reasonably-Achievable (ALARA)program were 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.
5/14/98 NCV Positive IR 98-02 L
NCV 98-02-04 PS 3A 5A Overall, effective performance in the area of radiological controls for radioactive materials,
=-
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.
5/14/98 Positive IR 98-02 N
'I PS 3A 1C Performance in radiological controls for individual external and internal exposures for 1997 and for 1998 up to April28 was fullyeffective.
3/16/98 Positive IR 98-01 N
PS 5A 5B 5C 3/16/98 Positive IR 98-01 N
PS 2A The condition reporting system was effectively used to identify, evaluate, and resolve radiological control program deficiencies.
Housekeeping and material conditions of plant structures and equipment were good.
FROM: 10/1/97 TO: 9/17/98 Page21of 25 6 April 1999
SUSqUEH/WNA i.a.2 PuaVT rSSUaS MhTrux Date rape Source ID SFA Code Item Description'/16/98 Positive
~ IR 98-01 N
PS 2A Health physics equipment and facilities were well maintained.
3/16/98 Positive IR 98-01 N
PS 28 3C 5A Astrong commitment to reducing plant contamination was evidenced by the reduction of recoverable-contaminated areas in 1997 from 9.4 to 6.2 percent and performance of a self-assessment in contamination controls..
3/16/98 Positive IR 98-01 N
PS 1C The ALARAorganization was effectively evaluating and implementing radiation dose reduction measures and the health physics staff effectively used the employee ALARAconcern program.
Although ALARAinitiatives to minimize the radiological impact of hydrogen water chemistry (HWC) appeared comprehensive including the implementation of condensate filtration, shielding up-grades, contingencies for chemical decontamination, and improvements in work practices and scheduling, continued vigilance to assess and mitigate the radiological impact of HWC is warranted.
1/19/98 12/8/97 Positive IR 97-09 N
NCV IR 97-10 N
Negative NCV 97-10-06 PS PS-1C 1A 2A Implementation of the licensee's site access authorization (AA)and Fitness-for-Duty (FFD) programs were reviewed. A failure to allow an individual to review the psychological information contained in his file is considered a violation of NRC regulations of minor significance and is being treated as a non-cited violation.
The licensee maintained an effective security program.
Management support was evident.
Quality assurance audits were thorough and in-depth. Alarm station operators were knowledgeable and alert. Security equipment was tested and maintained in accordance with the security plan and security training was performed in accordance with the training and qualification plan. The provisions for land vehicle control measures satisfy regulatory requirements and licensee commitments.
10/30/97 Positive IR 97-08 N
10/30/97 Positive IR 97-08 N
PS 1C PS 3A Good communications throughout the emergency response facilities and with the Commonwealth of Pennsylvania.
Good command and control in all emergency response facilities.
10/30/97 Positive IR 9748 N
PS 38 3A The overall performance of the emergency response organization was good. Simulated events were accurately diagnosed, proper mitigation actions were performed, emergency declarations were timely and accurate, and off-site agencies were notified promptly. No exercise weaknesses, safety concerns, or violations of NRC requirements were observed.
FROM: 10/1/97 TO: 9/17/98.
Page 22 of 25 6 April 1999
I
SUSQUEH/'ANNA IS. 2 PLANT ISSUES MATRIX Date Type Source
/D SFA Code
/tern Description 10/20/97 Positive IR 97-07 N
PS 10/20/97 Positive IR 97-07 N
PS 10/20/97 NCV IR 97-07 L
PS LER NCV 97-07-04 Positive LER 97-16-00 5C An evaluation of condition reports (CRs), from the Unit 2 eighth refueling outage, concluded that there was no continuing trends regarding inadequate frisking practices with hand held monitors. The licensee's initial corrective actions for the identified weaknesses in the three CRs inspected were adequate.
1C The licensee's programmatic response to a potential fire in the control room was reviewed and determined to rely on offnormal procedures which require the manual initiation of a CO2 fire protection system and the immediate evacuation of the control room. The controls established by the licensee to ensure that control room operators do not require the use of self contained breathing apparatus (SCBA), during a fire and/or habitability problem in the control room.
These controls were determined to be adequate.
5A PP&L determined that the monthly surveillance to inspect fire hose stations had not been completed within the frequency as required per TS Surveillance Requirement 4.7.6.5.a.
TSs require inspection of the fire hose stations listed in Table 3.7.6.5-1 at least once per 31 days.
The frequency for performing this surveillance including the grace period was exceeded seven (7) times since January 1995.
In addition, while reviewing other surveillances that used a fixed schedule, itwas determined that the 6-month surveillance of fire hydrants had exceeded its frequency, including the grace period on one occasion since January 1995.
The cause of the event was determined to be that the scheduling tool used to track these surveillances used a fixed date each month for the determination of the start of the surveillance instead of calculating the start date from when the surveillance was last performed.
Corrective actions include: revising the method of tracking these surveillances and discussion of this event with appropriate plant personnel.
FROM: 10/1/97 TO: 9/17/98 Page 23 of 25 6 April 1999
I
ABBREVIATIONSUSED IN PIM TABLE CO2 CR CS ECCS EDG HWC LER NRC PCO RCIC SLC TS VIO As-Low-As-Reasonably-Achievable Carbon Dioxide Condition Reports Control Structure Emergency Core Cooling System Emergency Diesel Generator Hydrogen Water Chemistry Licensee Event Report Nuclear Regulatory Commission Plant Control Operator Reactor Core Isolation Cooling Standby Liquid Control Technical Specification Violation FROM: 10/1/97 TO: 9/17/98 Page24of 25 6 April 1999
GENERAL DESCRIPTION OF PIN TABLECOLUMNS Date T) PB Source ID SFA Code Item Description The actual date of an event or significa'nt issue for those items that have a dear date of occurrence (mainly LERs), the date the source of the information was issued (such as for EALs), or the last date ofthe inspection period (for IRs).
The categorization ofthe item or finding - see the Type / Findings Type Code table, below.
The document that describes the findings: LER for Licensee Event Reports, EALfor Enforcement Action Letters, or IR for NRC Inspection Reports.
Identification ofwho discovered issue: N for NRC; Lfor Licensee; 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 table below.
Details of NRC 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 TEMPLATE CODES ED Strength Enforcement Discretion - No CivilPenalty Overall Strong Licensee Performance Operational Performance: A-Normal Operations; B - Operations During Transients; and C - Programs and Processes Weakness Overall Weak Licensee Performance 2
Material Condition: A - Equipment Condition or B - Programs and Processes EEI
'CV Escalated Enforcement Item - Waiting Final NRC Action Violation Level I, II, III,or IV Non-Cited Violation 3
Human Performance: A-Work Performance; B - Knowledge, Skills, and Abilities/
Training; C - Work Environment 4
Engineering/Design: A-Design; B - Engineering Support; C - Programs and Processes DEV Positive Negative LER URI
- 'eviation from Licensee Commitment to NRC Individual Good Inspection Finding Individual Poor Inspection Finding Licensee Event Report to the NRC Unresolved Item from Inspection Report Licensing Ucensing Issue from NRR MISC Miscellaneous - Emergency Preparedness Finding (EP),
Declared Emergency, Nonconformance Issue, etc. The type of all MISC findings are to be put in the Item Description column.
Problem Identification and Resolution: A - Identification; 8 - Analysis; and C-Resolution NOTES:
EEls are apparent violations of NRC requirements that are being considered for escalated enforcement action in accordance with the General Statement of Policy and Procedure for NRC Enforcement Action (Enforcement Policy), NUREG-1600.
However, the NRC has not reached its final enforcement decision on the issues identified by the EEls and the PIM entries may be modified when the final decisions are made.
Before the NRC makes its enforcement decision, the licensee willbe provided with an opportunity to either (1) respond to the apparent violation or (2) request a predecisional enforcement conference.
URls are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final condusions are made.
FROM: 10/1/97 TO: 9/17/98 Page25 of 25 6 April 1999
ENCLOSURE 2 Susquehanna Inspection Plan forApril 1999 through Januaxy 2000 Inspection IP-37551 IP-60853 IP-60854 IP-60854 IP-81080 IP-37750 IP-60855 IP-81110 IP-62706 IP-62700
'rogram Area/Title Root Cause Evaluations and Review LPCI Valve Stem Breakage Issue On-site Fabrication of Independent Spent Fuel Storage Installation Independent Spent Fuel Storage Installation-Preoperational Test Program-Procedure Review Licensed Operator Examination Y2K Review Independent Spent Fuel Storage Installation-Dry Runs Detection Aids and Organization Engineering Support to Operations Independent Spent Fuel Storage Loading Operations Safeguards
Response
Evaluation
'redictive Maintenance Program and Maintenance Rule Work Controls Planned Dates April 12, 1999 May 3, 1999 May 3, 1999 May 10, 1999 May 10, 1999 June 7, 1999 June 7, 1999 July 12, 1999 August 2, 1999 August 2. 1999 August 16, 1999 August 16, 1999 Type Inspection/Comments Regional Initiative Regional Initiative-Date may change based on PP8L fabrication status Regional Initiative-Date may change based on PP8L fabrication status NRC Operator License Examination'RC review of Y2Kreadiness Regional Initiative-Date may change based on PP8L fabrication status Regional Initiative Regional Initiative Regional Initiative-Date may change based on PP&L fabrication status Regional Initiative Regional Initiative Regional Initiative
~
C 1$
l 4'r
ENCLOSURE 2 Susquehanna Inspection Plan for April 1999 through January 2000 IP-37550 IP-84750 IP-81700 IP-86750 IP-40500 IP-83750 Engineering Radioactive Waste Treatment and Effluent and Environmental Monitoring Security Solid Rad Waste Management and Transportation of Radioactive Materials Problem Identification and Corrective Action Occupational Radiation Exposure Non-Outage Sept 13, 1999 Core
. Sept 20, 1999 Core November 1, 1999 Core November 15, 1999 Core November 29, 1999 Core December 6, 1999 Core Legend:
IP Core Inspection Regional Initiative Inspection Procedure Minimum NRC Inspection Program (mandatory at all plants)
Additional Inspection Effort Planned by Region I