ML18026A449

Forwards Request That NRC Take Actions Re 10CFR2.206 to Protect Public from Undue Risk from Spent Fuel Storage

ML18026A449
Person / Time
Site:	Susquehanna
Issue date:	11/28/1994
From:	Lochbaum D, Prevatte D AFFILIATION NOT ASSIGNED
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
2.206, NUDOCS 9412190197
Download: ML18026A449 (61)

Text

C i p t

g Ce November 28, 1994 David A. Lochbaum Donald C. Prevatte 80 Tuttle Road 7924 Woodsbluff Run Watchung, NJ 07060 Fogelsville, PA 18051 (908) 754-3577 (215) 398-9277 Mr. James Taylor Executive Director for Operations United States Nuclear Regulatory Commission Washington, DC 205554001

SUBJECT:

10 CFR 2.206 Request for NRC Action

Dear Mr. Taylor:

. In a lener dated October 13, 1994, Mr. Gary M, Holohan, Director - Division of Systems Safety and Analysis, transmitted the Task Action Plan for Spent Fuel Storage Pool Safety to Mr. Ashok C. Thadani, Associate Director for Technical Assessment. This action plan outlined the NRC plans to evaluate the generic implications of the nuclear safety concerns we identified in the Susquehanna Steam Electric Station and submitted to the NRC in a 10 CFR 21 report dated November 27, 1992. The draft of this action plan was described in a public meeting on September 6, 1994. The approved action plan was transmitted by a letter dated October 24, 1994, and discussed in a public meeting on October 25, 1994.

The action plan involves team inspections at selected sites, industry experience report reviews, and risk assessments to develop a course of action for potential generic actions. The action plan indicates that this course of action is scheduled to be developed by November 1995 and the course of action implemented by December 1996.

Pursuant to the provisions of Section 2.206 of Title 10 of the Code of Federal Regulations, we respectfully request that the NRC take the actions specified on the enclosure to protect the public from undue risk from spent fuel storage. These actions are only intended to prevent any licensee from increasing the probability of and/or consequences from the spent fuel pool cooling problems while the staff is evaluating the generic implications of the 10 CFR 21 issues. These requested actions only apply to the interim period while the staff defines a course of action and terminate upon implementation of the course of action. In accordance with Part II of NRC Directive 8.11, Review Process for 10 CFR 2.206 Petitions", we have carefully structured these requested actions so as not to "...avoid or circumvent..." the staff's stated action plan. Please note that the requested actions were submitted together for convenience, and the requested actions should be accepted or denied based on their individual merits.

Please feel free to contact us for additional information or clarification regarding this request for action. We are not requesting an informal public hearing for this petition since the staff should have sufficient understanding of the underlying concerns.

Sincerely, Ctuu/ r.

David A. hbaum g,. Donald C. vatte Vih vgagggpg Enclosure Enclosure 3

CC: Mr. Noel Dudley Advisory Committee on Reactor Safeguards United States Nuclear Regulatory Commission Washington, DC 20555 Mr. Sam Holland Office of the Inspector General United States Nuclear Regulatory Commission Washington, DC 20555 Dr. John T. Larkins Executive Director, Advisory Committee on Reactor Safeguards United States Nuclear Regulatoty Commission Washington, DC 20555 Mr. Richard A. Matakas United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. William Russell Director, Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 205554001 Mr. Ivan Selin Chairman United States Nuclear Regulatory Commission Washington, DC 205554001 Mr. Joseph W. Shea, Project Manager Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 205554001 Mr. David C. Williams Inspector General United States Nuclear Regulatory Commission Washington, DC 20555

The Honorable Joseph I. Lieberman Chairman, Senate Environment and Public Works Committee, Subcommittee of Clean Air and Nuclear Regulation SD458 Washington, DC 20510 The Honorable Richard H. Lehman Chairman, House Natural Resources Committee, Subcommittee on Energy and Mineral Resources 818 O'eill Building 300 New Jersey Avenue, S.E.

Washington, DC 20515 The Honorable Philip R. Sharp Chairman, House Energy and Commerce Committee, Subcommittee on Energy and Power 331 Ford Building 2" and D Streets, S.W.

Washington, DC 20515 Ms. Leslie Greer Massachusetts Assistant Attorney General 1 Ashburton Place Boston, MA 02108 Mr. Paul Gunter Nuclear Information and Resource Service 1424 16~ Street NW Washington, DC 20036 Dr. Judith Johnsrud 433 Orlando Avenue State College, PA 16803 Mr. Robert D. Pollard Union of Concerned Scientists 1616 P Street NW Washington, DC 20036 Ms. Joanne Royce Government Accountability Project 810 P Street NE, Suite 630 Washington, DC 20002-3633

'I I as November 28, 1994 Enclosure Page 1 of 3 Actions Requested under Section 2.206 of TMe 10 of the Code of Federal Regulations

1) Requested Action With Respect to Issuance of Operathg Licenses of Federal Regulations to any applicant (e.g. Tennessee Valley Authority for the %'atts Bar Nuclear Plant) until the course of action developed by the Task Action Plan for Spent Fuel Storage Pool Safety dated October 13, 1994 is implemented unless that applicant evaluates the spent fuel pool cooling safety concerns identified in the 10 CFR 21 report dated November 27, 1992 and addressed in the staff s Safety Evaluation (scheduled to be issued in December 1994) and the applicant's evaluation is formally reviewed and accepted by the staff as part of the licensing process. The applicant's evaluation shall explicitly address how the requirements of Section 100 of Title 10 of the Code of Federal Regulations are satisfied for spent fuel handling and storage during normal operation and Qal design basis events.

Justification The staff issued an operating ticenm for the Susquehanna Steam Electric Station whhout requiring,its licensee to be in full compliance with etdsting regulations such as IO CFR SO, Appendix A, General Design Criterion 61 because design basis event scenarios identified h the 10 CFR 21 report dated November 27, 1992 had not been considered at the time of initial licensing. Previous staff evaluations covering the handling and storage of spent fuel, including NUREG4404 and NUREG-1353, determined that compliance with existing regulations provided reasonable assurance that public health and safety would be protected. This requested action is intended to provide reasonable assurance that another operating license is not granted without the applicant demonstrating full compliance with all applicable regulations on spent fuel storage. This requested action is terminated by the staff s implementation of the course of action resulting from its determination of generic implications associated with spent fuel storage since appropriate measures (i.e. ruiemaking or generic bulletins) will be in place to provide reasonable assurance,

2) Requested Action With Respect to Amendments of Operating Licenses 50.92 of Title 10 of the Code of Federal Regulations to any licensee in any of the areas listed below until the course of action developed by the Task Action Plan for Spent Fuel Storage Pool Safety dated October 13, 1994 is implemented unless that licensee evaluates the spent fuel pool cooling safety concerns identifiied in the 10 CFR 21 report dated November 27, 1992 and addressed in the staff s Safety Evaluation (scheduled to be issued in December 1994) and the licensee's evaluation is formally reviewed and accepted by the staff as part of the amendment process. The licensee's evaluation shall explicitly address how the requirements of Section 100 of Title 10 of the Code of Federal Reguhrions are satisfied for spent fuel handling and storage during normal operation and +al design basis events.

Operating license amendments which involve one or more of the following subjects are covered by this requested action:

2.1 increased capacity of spent fuel storage pool 2.2 increased licensed reactor power level

November 28, 1994 Enclosure Page 2 of 3 Actions Requested under Section 2.206 of Title 10 of the Code of Fedeml Regulations Justification The staff issued an operating licease for the Susquehanna Steam Electric Station without requiring its licensee to be in full compliance with existing regulations such as 10 CFR 50, Appendix A, General Design Criterion 61 because design basis event scenarios identified in the 10 CFR 21 report dated November 27, 1992 had not been considered at the time of initial licensing. The staff may have issued operating licenses for other facilities which also failed to comply with all applicable regulations on spent fuel storage. Previous staff evaluations covering the handling and storage of spent fuel, including NUREG4404 and NUREG-1353, determined that compliance with existing regulations provided reasonable assurance that public health and safety would be protected. This requested action is intended to provide reasonable assurance that an operating license amendment for hy wl'th of any acti vlhy thee potential e for increasing spent fuel storage risk is not granted without the licensee demonstratin ns g full compliance with all applicable regulations on spent fuel storage. Increasing the capacity of the spent fuel pool or the reactor thermal power level has the potential for increasing the decay heat generation rate and source term inventory in the spent fuel pool which are primary factors in spent fuel storage risk. This requested action is terminated by the staff's implementation of the course of action resulting from its determination of generic implications associated with spent fuel storage since appropriate measures (i.e. rulemaking or generic bulletins) wBI be in place. to provide reasonable assurance.

3) Requested Action With Respect to Renewals of Operating Licenses Title 10 of the Code of Federal Regulations to any licensee until the course of action developed by the Task Action Plan for Spent Fuel Storage Pool Safety dated October 13, 1994 is implemented unless that licensee evaluates the spent fuel pool cooling safety concerns identified in the 10 CFR 21 report dated November 27, 1992 and addressed in the staff s Safety Evaluation (scheduled to be issued in December 1994) and the licensee's evaluation is formally reviewed and accepted by the staff as part of the license renewal/extension process. The licensee's evaluation shall explicitly address how the requirements of Section 100 of Title 10 of the Code of Federal Regulations are satisfied for spent fuel handling and storage during normal operation and +al design basis events.

Jcstlgcstion The staff issued an operatiog license for the Susquehanna Steam Electric Stadon without requiring its licensee to be in full compliance with existing regulations such as 10 CFR 50, Appendix A, General Design Criterion 61 because design basis event scenarios identified in the 10 CFR 21 d ated November 27, 1992 had not been considered at the time of initial licensing. The staff may have issu operating licenses for other facilities which also failed to comply with all applicable regulations on spent fuel storage. Previous staff evaluations covering the handling and storage of spent fuel, including NUREG4404 and NUREG-1353, determined that compliance with existing regulations provided reasonable assurance that public health and safety would be protected, This requested action is intended to provide reasonable assurance that an operating license renewal/extension is not granted without the licensee demonstrating full compliance with all applicable regulations on spent fuel storage.

icense renewal/extension has the potential for increasing the decay heat generation rate and source term inventoty in the spent fuel pool which are primary factors in spent fuel storage risk. This requested action is terminated by the staff li implementation of the course of action resulting from its determination of generic implications associated with spent fuel storage since appropriate measures (i.e.

rulemaking or generic bulletins) will be in place to provide reasonable assurance.

November 28, 1994 Enclosure Page 3 of 3 Actions Requested under Section 2.206 of Title 10 of the Code of Federal Regulations

4) Requested Action With Respect to Independent Spent Peel Storage Licenses issued under Part 72 of Title 10 of the Code of Federal Regulations to any licensee until the course of action developed by the Task Action Plan for Spent Fuel Storage Pool Safety dated October 13, 1994 is implemented unless that licensee (or applicant) evaluates the spent fuel pool cooling safety concerns identified in the 10 CFR 21 report dated November 27, 1992 and addressed in the staff s Safety Evaluation (scheduled to be issued in December 1994) and the licensee's (or applicant's) evaluation is formally reviewed and accepted by the staff as part of the licensing process. The licensee's (or applicant's) evaluation shall explicitly address how the requirements of Section 100 of Title 10 of the ~

Code of Federal Regulations are satisfied for spent fuel handling and storage during normal operation and all design basis events.

Justification 'ihe staff issued an operating license for the Susquehanna Steam Electric Station without requiring its licensee to be in full compliance with existing regulations such as 10 CFR 50, Appendix A, General Design Criterion 61 because design basis event scenarios identified in the 10 CFR 21 report dated November 27, 1992 had not been considered at the time of initial licensing. The staff may have issued operating licenses for other facilities which also failed to comply with all applicable regulations on spent fuel storage, Previous staff evaluations covering the handling and storage of spent fuel, including NUREG4404 and NUREG-1353, determined that compliance with existing regulations provided reasonable assurance that public health and safety would be protected. This requested action is intended to provide reasonable assurance that a license for independent spent fuel storage is not granted without the licensee demonstrating full compliance with all applicable regulations on spent fuel storage. Independent spent fuel storage activities involve the movement of heavy loads in and around the refueling floor area. One of the elements of the Task Action Plan is to re-assess the risks associated with heavy loads on loss of spent fuel pool cooling events. NUREG4612 allowed licensees to resolve the heavy load issue through reliance on designated pathways which avoided transporting heavy loads over safety related equipment. In many nuclear power plants, the spent fuel pool cooling systems are non-safety related systems and thus may not be protected from the postulated drop of a heavy load. This requested action is terminated by the staff s implementation of the course of action resulting from its determination of generic implications associated with spent fuel storage since appropriate measures (i.e. rulemaking or generic bulletins) willbe in place to provide reasonable assulailce.

5'~-.2~7' +/U/60536'/I /gal Mr. Ulrich Mueller Ms. Ueli Mueller March 15, 2000 + ~f1 NP=O<d Greenpeace Postfach CH-8031 Zurich, Switzerland

Dear Mr. and Ms. Mueller:

I am responding to your electronic mail of January 17, 2000, to the U. S. Nuclear Regulatory Commission's (NRC) Office of Public Affairs requesting information on the December 17, 1999, shutdown of the Susquehanna Steam Electric Station, Unit 2. You referred to a December 23, 1999, Nucleonics Week article that indicated that the NRC would evaluate the shutdown to determine if a generic issue exists. You requested information regarding the shutdown, whether other facilites have experienced similar problems, and whether the NRC has initiated generic action related to these issues. Responses to your questions are provided in the enclosure to this letter.

I trust that you will find the enclosed information responsive to your questions. Should you have any questions or comments regarding these matters, please contact Mr. Robert Schaaf, the NRC Project Manager for the Susquehanna Steam Electric Station, at 1-301-415-1312, or via electronic mail at rgsnrc.gov.

Sincerely,

/RA/

Elinor G. Adensam, Director Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation

Enclosure:

Responses to Questions cc w/encl: Mr. Sabyasachi Chakraborty Head of Safety Research and International Programs Swiss Federal Nuclear Safety Inspectorate Postfach CH-5232 Villigen-HSK, Switzerland DISTRIBUTION File Center (50-388) w/original incoming R. Schaaf (w/incoming)

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~s March 15, 2000 grrrrs Mr. Ulrich Mueller Ms. Ueli Mueller Greenpeace Postfach CH-8031 Zurich, Switzerland

Dear Mr. and Ms. Mueller:

I am responding to your electronic mail of January 17, 2000, to the U. S. Nuclear Regulatory Commission's (NRC) Office of Public Affairs requesting information on the December 17, 1999, shutdown of the Susquehanna Steam Electric Station, Unit 2. You referred to a December 23, 1999, Nucleonics Week article that indicated that the NRC would evaluate the shutdown to determine if a generic issue exists. You requested information regarding the shutdown, whether other facilites have experienced similar problems, and whether the NRC has initiated generic action related to these issues. Responses to your questions are provided in the enclosure to this letter.

I trust that you will find the enclosed information responsive to your questions. Should you have any questions or comments regarding these matters, please contact Mr. Robert Schaaf, the NRC Project Manager for the Susquehanna Steam Electric Station, at 1-301-415-1312, or via electronic mail at rgsnrc.gov.

Sincerely, Elinor G. Adensam, Director Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation

Enclosure:

Responses to Questions cc w/encl: Mr. Sabyasachi Chakraborty Head of Safety Research and International Programs Swiss Federal Nuclear Safety Inspectorate Postfach CH-5232 Villigen-HSK, Switzerland

Res onse to Questions Re aidin the December 17 1999 Shutdown of the Sus uehanna Steam Electric Station Unit 2 Question 1 What kind of material was affected?

~Res onse The Susquehanna Steam Electric Station Final Safety Analysis Report identifies the instrumentation line material as austenitic stainless steel.

Question 2 Has the NRC released a publication addressing this specific event?

~Res onse NRC Inspection Report No. 05000387/1 999012, 05000388/1999012, issued on January 24, 2000, provides a summary of the Unit 2 shutdown and the licensee's actions to identify and correct the source of the leak. A copy of the inspection report is attached to this response. The summary of the shutdown and licensee actions is on page 2 of the report.

Question 3 What findings caused the NRC to examine the event for potential generic implications?

~Res onse It is the policy of the NRC to systematically review operating data from a range of sources to identify potential generic issues. Operational data is screened each business day to evaluate the need for additional review. Sources of operational data include licensee event notifications submitted in accordance with 10 CFR 50.72, daily reports from NRC regional offices, and daily plant operating status reports obtained through the NRC's Headquarters Operations Center.

The initial review includes consideration of the loss of margin associated with regulatory requirements and the potential risk significance of the event. Risk insights and staff engineering judgement are used to select issues that warrant follow-up effort. The Susquehanna shutdown was not selected for further review.

Question 4 Is the detailed cause of the problem known and is it related to power uprating of boiling wagner reactors (BWRs)?

ENCI OSURE

~Res onse As noted in our inspection report, the licensee determined the cause of the leak to be a crack in an instrumentation line weld caused by high-cycle fatigue due to vibration. No link has been identified between the instrumentation line leak and the Susquehanna power uprate.

Question 5 Have other U.S. BWRs experienced similar problems? If so, has NRC taken any action to oblige facilities to address the problem?

~Res ense A review of historical data, including licensee reports filed in accordance w'ith 10 CFR 50.72 and 50.73 and NRC preliminary notifications of unusual events, identified a number of instances where plants experienced minor leaks attributed to mechanical or flow-induced vibration. These failures typically occurred in small piping and usually resulted in minor leaks of less than 1 gallon per minute. Several instances of vibration attributed to high recirculation flow or recirculation system harmonic resonances have occurred at U.S. BWR facilities. The affected licensees typically instituted administrative controls to limit recirculation flow, or to monitor vibration and reduce recirculation flow if excessive vibration is detected. The NRC issued Information Notice 95-16, "Vibration Caused by Increased Recirculation Flow in a Boiling Water Reactor," on March 9, 1995, to notify the industry of these occurrences. Information notices are a form of generic communication used by the NRC to inform the nuclear industry of significant operating experience. Information notices do not convey or imply new requirements and do not request information or actions.

No generic action has been taken to require licensees to address these occurrences because the existing regulatory structure affecting the design and operation of nuclear, power plants .

effectively directs licensee actions. The NRC recognizes that complete reliance cannot be placed on any single element of the design, maintenance, or operation of a nuclear power plant to assure safe operation. Therefore, the defense-in-depth philosophy is applied in licensing nuclear power plants. In the defense-in-depth philosophy, protection is provided by several layers of defense involving accident prevention, accident mitigation, radiation protection, and emergency preparedness. Design features addressing each of these areas for each operating reactor have been reviewed and approved by the staff. Controls to'support accident prevention include design controls to prevent piping degradation due to operational stresses, procedures to detect piping degradation prior to development of leaks, systems and procedures to enable prompt identification of minor leaks, and procedures to ensure that prompt, effective corrective action is implemented to correct and prevent recurrence of identified deficiencies.

Question 6 Have similar problems caused by increased material stress due to power uprating occurred previously in U.S. BWRs?

~Res ense None of the identified examples of vibration induced leaks noted were attributed to power .

up rating.

The NRC will continue to routinely evaluate operating reactor events for generic significance in accordance with our policy. These evaluations include consideration of the defense-in-depth philosophy discussed above.

Attachment:

Inspection Report

January 24, 2000 Mr. Robert G. Byram Senior Vice President, Nuclear PP&L, Inc.

2 North Ninth Street Allentown, PA 18101

SUBJECT:

NRC INTEGRATED INSPECTION REPORT 05000387/1999012 and 05000388/1 99901 2 Dear Mr. Byram On January 1,'000, the NRC completed an inspection at the Susquehanna Steam Electric Station (SSES) Unit 1 & 2 reactor facilities. The enclosed report covered routine activities by the resident inspectors and announced inspections of your Security and Safeguards, and Radiological Controls-External and Internal Exposure programs by R'egion I specialists. The inspectors discussed the findings of these inspections with Mr. R. Saunders, Vice President Nuclear Operations, Mr. B. Shriver, General Manager SSES, and other members of your staff, at an exit meeting at the completion of the inspections.

Overall, your staff safely operated the facility during this period. Plant Management's decisions to perform a controlled shutdown of Unit 2 to address the increase in primary containment unidentified water leakage and to correct additional known equipment problems prior to restart was a positive initiative.

In accordance with 10CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure(s), and your response will be placed in the NRC Public Document Room (PDR).

A reply to this letter is not required, but should you have any questions regarding this please contact me at 610-337-5322.

Sincerely, ORIGINAL SIGNED BY Curtis J. Cowgill, Chief Projects Branch 4 Division of Reactor Projects Docket Nos: 05000387, 05000388 License Nos: NPF-14, NPF-22

Enclosure:

Inspection Report 05000387/1 999012, 05000388/1 99901 2 ATTACHMENT

Mr. Robert G. Byram cc w/encl:

R. F. Saunders, Vice President - Nuclear Site Operations G. T. Jones, Vice President - Nuclear Engineering and Support B. L. Shriver, General Manager - SSES R. M. Peal, Manager, Nuclear Training G. D. Miller, General Manager - Nuclear Assurance R. R. Wehry, Nuclear Licensing - SSES M. M. Golden, Manager - Nuclear Security P. Nederostek, Nuclear Services Manager, General Electric W. H. Lowthert, Manager, Nuclear Plant Services A. M. Male, Manager, Quality Assurance H. D. Woodeshick, Special Assistant to the President G. DallaPalu, PP&L Nuclear Records R. W. Osborne, Vice President, Supply & Engineering Allegheny Electric Cooperative, Inc.

Commonwealth of Pennsylvania

U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos: 05000387, 05000388 License Nos: NPF-14, NPF-22 Report No. 05000387/1999012, 05000388/1999012 Licensee: PP&L, Inc.

2 North Ninth Street Allentown, PA 19101 Facility: Susquehanna Steam Electric Station Location: P.O. Box 35 Berwick, PA 18603-0035 Dates: November 20, 1999 through January 1, 2000 Inspectors: S. Hansell, Senior Resident Inspector J. Richmond, Resident Inspector A. Blarney, Resident Inspector P. Frechette, Security Specialist J. McFadden, Radiation Specialist Approved by: Curtis J. Cowgill, Chief Projects Branch 4 Division of Reactor Projects

EXECUTIVE

SUMMARY

Susquehanna Steam Electric Station (SSES), Units 1 & 2 NRC Inspection Report 05000387/1 999012, 05000388/1 999012 This inspection included aspects of PP&L's operations, maintenance, engineering and plant support at SSES. The report covers a five-week period of routine resident inspection activities and announced inspections by regional specialists.

~Qerattone

~ PP8 L made conservative and effective decisions in response to increasing primary containment leakage on Unit 2. (Section 04.1) 1

~ Two recent equipment failures related to the Unit 2 main transform'er and Unit 1 reactor core isolation cooling temperature switch module were attributed to inadequate follow-up actions related to industry event information that had been previously reviewed by PP&L in the 1986 and 1990 time frames. (Section 08.1)

Maintenance I

After PPBL management established an Event Review Team, PP&L successfully resolved the numerous problems that occurred following the 2 year preventive maintenance on the "A" emergency diesel generator. (Section M1.2)

During the planned replacement of two emergency service water (ESW) pumps, PP&L's maintenance department exhibited excellent work performance and good management oversight. (Section M1.3)

~En ineerin

~ The Independent Safety Engineering Group report results wer'e indicative of thorough

. investigation and analysis of plant issues and personnel performance. The reports were objective and contained meaningful feedback to plant management. (Section E7.1)

Plant Su ort PP8 L implemented effective applied radiological controls. The radiation work permit program was adequately implemented. Personnel occupational exposure was maintained within applicable regulatory limits and as low as reasonably achievable.

Access controls to radiologically controlled areas were effective, and appropriate occupational exposure monitoring devices were provided and used. (Section R1.1)

PP&L implemented overall effective surveys, monitoring, and control of radioactive materials and contamination. Health Physics technicians properly documented survey results. In general, radiological housekeeping conditions were acceptable.

(Section R1.2)

t' Executive Summary o Security and safeguards activities with respect to alarm station controls, communications, and protected area access control of personnel, packages and vehicles were effectively implemented. (Section S1)

Security and safeguards procedures and documentation were properly implemented.

Event logs were properly maintained and effectively used to analyze, track, and resolve safeguards events. (Section S3)

The security force members (SFMs) were provided effective training and adequately demonstrated that they had the requisite knowledge necessary to effectively implement their duties and responsibilities. (Sections S4 and S5)

C Management support was adequate to ensure effective implementation of the security program, as evidenced by adequate staffing levels and the allocations of resources to support programmatic needs. (Section S6)

TABLE OF CONTENTS I. Operations 01 Conduct of Operations ..

01.1 Unit Operations and Operator Activities 02 Operational Status of Facilities and Equipment 02.1 Operational Safety System Alignment .

04 Operator Knowledge and Performance .

04.1 Unit 2 Reactor Shutdown and Plant Restart 08 Miscellaneous Operations Issues 08.1 Licensee Event Report (LER) Review II. Maintenance .. I

..3 M1 Conduct of Maintenance ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ P ~ ~ ~ ~ ~ ~ ~ ~ ~ ..3 M1.1 Surveillance and Pre-Planned Maintenance Activity Review.... ..3 M1.2 "A" Emergency Diesel Generator Restoration following 2-Year r"

Inspection M1.3 "C" and "D" Emergency Service Water Pump Overhauls ... ~... ~.... 5 III. Engineering .. ..6 E7 Quality Assurance in Engineering Activities 6 E7.1 Oversight of Station Activities .. ..6 IV. Plant Support . 6 R1 Radiological Protection and Chemistry (RP&C) Controls 6 R1.1 Radiological Controls-External and Internal Exposure 6 R1.2 Radiological Controls-Radioactive Materials, Contamination, Surveys, and Monitoring . . '.

7 R1.3 Radiological Controls-As Low As Reasonably Achievable (ALARA) .. ~ ~ 8 R7 Quality Assurance in RP&C Activities 9 S1 Conduct of Security and Safeguards Activities 10 S2 Status of Security Facilities and Equipment S3 Security and Safeguards Procedures and Documentation S4 Security and Safeguards Staff Knowledge and Performance.............. 12 S5 Security and Safeguards Staff Training and Qualification . 12 S6 Security Organization and Administration................... 13 S7 Quality Assurance (QA) in Security and Safeguards Activities............. 13 S8 Miscellaneous Security and Safeguards Issues ........... 14 S8.1 (Closed) LER 50-387/99-005-00, Safeguards Event V. Management Meetings .. .... 14 X1 Exit Meeting Summary . ,. 14 INSPECTION PROCEDURES USED . ..15 ITEMS OPENED, CLOSED, AND DISCUSSED ..15 LIST OF ACRONYMS USED ..16 IV

Re ort Details Summa of Plant Status Susquehanna Steam Electric Station (SSES) Unit 1 operated at 100% power throughout the inspection period with two exceptions. On December 4, power was reduced to 75% to change control rod positions and to perform control rod insertion time and main steam isolation valve testing, then returned to 100% power. On December 31, power was reduced to 80% as a year 2000 contingency, then returned to 100% on January 1, 2000.

SSES Unit 2 operated at 100% power throughout the inspection period with three exceptions.

On December 11, power was reduced to 85% to change control rod positions and perform control rod insertion time testing, then returned to 100% power. On December 17, a normal shutdown was performed to repair a leaking instrument line for the "A" reactor recirculation pump. The Unit was restarted on December 23, and reached 100% power on December 25.

On December 31, power was reduced to 80% as a year 2000 contingency, then returned to 100% on January 1, 2000.

l. 0 erations 01 Conduct of Operations Unit 0 erations and 0 erator Activities (71707)

'1.1 The inspectors determined routine operator activities were satisfactorily established, communicated and conservatively performed in accordance with SSES procedures.

Control room logs accurately reflected plant activities. During tours of the main control room, the inspectors observed good turn-over briefings and formal communications.

02 Operational Status of Facilities and Equipment 02.1 0 erational Safe S stemAIi nment (71707)

During routine/lant tours, the proper alignment and operability of various safety systems, engineered safety features, and on-site power sources were verified. Partial walkdowns were performed for the emergency service water, "A" emergency diesel generator, con'trol rod drive, and reactor recirculation systems. No equipment problems were noted.

Topical headings such as 01, MB, etc., are used in accordance viith the NRC standardized reactor inspection report outline. Individual reports are not expected to address ail outline topics.

04 Operator Knowledge and Performance 04.1 Unit 2 Reactor Shutdown and Plant Restart The inspectors reviewed PP8L's response to an increase in primary containment unidentified water leakage; the management evaluation and decision to perform a controlled reactor shutdown; and the assessment of the operator actions during the plant shutdown, equipment repairs, and subsequent reactor startup.

C

b. Observations and Findin s In response to an increasing primary containment unidentified water leakage, operators started reducing reactor power on Unit 2 on December 16, to allo'w for inspection inside the primary containment . Primary containment unidentified water leakage had increased to 0.87 gallons per minute (gpm.) The Technical Specification (TS) limit was 5 gpm.

The PP8 L inspection discovered a small water leak on a 3/4 inch instrument pipe associated with the pressure indication for the "A" reactor recirculation pump seal. The leak was located at a welded 45 degree elbow connection. PP8 L determined that the weld cracked due to high cycle fatigue caused by vibrational stresses. The line was replaced with a modified pipe that eliminated the 45 degree elbow weld. In addition, a pipe hanger was added to provide added support. PP8L ins'pected the "B" pump pipe and other similar reactor recirculation pipes and found no additional problems.

The "A" reactor recirculation pump pipe repairs were completed December 20, 1999.

PP8 L management decided to keep the unit shutdown to repair. several other equipment reliability problems prior to plant restart. The decision to correct additional known equipment problems prior to restart was in line with PP&L's new policy concerning improvement in equipment reliability. Unit 2 was restarted safely on December 23, and reached full power on December 25.

C. Conclusions PP&L made conservative and effective decisions in response to increasing primary containment leakage on Unit 2.

08 Miscellaneous Operations Issues

'8.1 Licensee Event Re ort LER Review (71707,92700)

Closed LER 50-387/99-004-00 Reactor Core Isolation Cooling (RCIC) Manually Isolated due to Failure of Steam Leak Detector Temperature Switch

On August 8, 1999, operators manually isolated RCIC in response to a steam leak detection piping area high temperature alarm. The alarm was caused by a failure of a temperature switch module which had been installed 3 days earlier. The module was replaced and RCIC returned to service within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

PP8 L analysis found that a faulty power supply capacitor caused the module to fail.

These modules were the subject of a 1986 General Electric Service Information Letter which recommended that the 7 year shelf life for the module should not be extended unless the capacitors were replaced with upgraded components. The failed module, although new, had been stored in the warehouse since 1984 and had not been upgraded. PP&L concluded that the vendor notice had been properly processed in accordance with the SSES Industry Event Review Program (IERP);but inadequate action had been taken for the IERP recommendations.

The inspectors noted that this was a second example where Induhtry event information had been previously reviewed by PP8L without adequate follow-up action. NRC IR 50-387,388/99-06 discussed the June 1999 Unit 2 main transformer failure which resulted from a manufacturing defect identified in 1990. The inspectors determined that the PP8 L documentation of this event was appropriate and relet the requirements of 10 CFR 50.73. This event was reviewed in more detail in NRC IR 050000387/1 999012 and 050000388/1 999012. This LER is closed.

II. Maintenance M1 Conduct of Maintenance M1.1 Surveillance and Pre-Planned Maintenance Activi Review The inspectors observed and reviewed selected portions of pre-planned maintenance and surveillance activities, to determine whether the activities were conducted in accordance with NRC requirements and SSES procedures.

b. Observations and Findin s The inspectors observed portions of the following work activities and surveillances:

Work Authorizations

~ PCWO 205801 Unit 2 Control Rod Drive Discharge Valve Inspection and Repair PCWO 214659 "A" Emergency Diesel Generator Troubleshooting PCWO 215235 Excess Flow Check Valve XV-142-F059G Rework PCWO 218447 "2B" Recirc M-G Scope Tube Lockup Investigation PCWO 105153 "C" ESW Pump Overhaul PCWO 106084 "C" ESW Pump Motor Bearing Replacement PCWO 202805 "D" Emergency Service Water Pump Rebuild

Surveillances CH-SY-004 Functional Test of the Post Accident Sampling Station (PASS)

OP-264-001 Unit 2 Recirculation Pump Scoop Tube Unlocking 4 TP-024-145 "A" Emergency Diesel Generator Post Maintenance Test SI-264-305 Recirc M-G Mechanical Stop Verification SO-015-002 Valve Stroke Testing

'SW SE-024-B01 "B" EDG 24-hour Surveillance Run SO-024-A01 "A" EDG Monthly Surveillance Run In addition, selected portions of procedures and drawings associated with the maintenance and surveillance activities were also reviewed and determined to be acceptable. In general, maintenance personnel were knowledgeable of their assigned activities.

M1.2 "A" Emer enc Diesel Generator Restoration followin 2-Year In 'ction The inspectors observed and reviewed selected portions of tHe "A" Emergency Diesel Generator (EDG) restoration and surveillance activities. The activities and work documents were reviewed to determine whether the activities were conducted in accordance with NRC requirements and SSES procedures.

b. Observations and Findin s On October 4, 1999, the "A" EDG was removed from service to perform the 2 year preventative maintenance inspection. The "E" EDG was substituted for the "A" EDG.

Restoration of the "A" EDG initially commenced on November 5, following completion of the planned maintenance.

During the post maintenance testing, numerous problems were encountered including an air start failure, gasket leakage (starting air header to cylinder), governor instability, and an unexpected diesel start when switching from local to remote control. After approximately 2 weeks of troubleshooting and rework failed to restore EDG operability, PP8 L formed an Event Review Team (ERT) to review the "A" EDG issues and post maintenance testing methodology.

On December 3, PP&L determined that a new Agastat relay installed during the restoration troubleshooting had a manufacturing defect in the internal wiring. The internally mis-wired relay accounted for several of the problems observed during the initial restoration attempt. The ERT troubleshooting activities were thorough and the corrective action adequately resolved identified deficiencies.

The "A" EDG was successfully tested and returned to service on December 6. PP&L is evaluating the mis-wired Agastat relay in accordance with 10 CFR 50.21, "Reporting of Defects and Noncompliance."

c. Conclusions

After PP8L management established an Event Review Team, PP8L successfully resolved the numerous problems that occurred following the 2 year preventive maintenance on the "A" emergency diesel generator.

M1.3 "C" and "D" Emer enc Service Water Pum Overhauls The inspectors observed and reviewed selected portions of the "C" and "D" Emergency Service Water (ESW) pump overhauls to determine whether the activities were conducted in accordance with NRC requirements and SSES procedures.

I Observations and Findin s During December 13 to 16, an ESW system maintenance outage.,%as performed to replace the "C" and "D" ESW pumps with rebuilt pumps and replace the "C" pump motor bearings. The "D" ESW pump was returned to service on December 14. The "C" ESW pump was returned to service on December 16.

The work activities were well planned, scheduled, and coordinated. The inspectors observed excellent work performance by the maintenance department under extreme weather conditions and good supervisory and management oversight.

The inspectors and a Regional risk assessment specialist reviewed PP8L's risk assessment for the planned ESW work activities. The inspectors found that PP8L's core damage risk assessment was thorough and considered all equipment and administrative controls related to station blackout and loss of off-site power scenarios.

Nevertheless, the inspectors noted that by performing maintenance on two pumps in parallel, versus one pump at a time, the potential for a Technical Specification driven plant shutdown appeared to be greater. The increased potential of a forced shutdown was offset by the shorter period of pump out of service time associated with the parallel work schedule.

C. Conclusions During the planned replacement of two emergency service water (ESW) pumps, PPBL's maintenance department exhibited excellent work performance and good management oversight.

III. En ineerin E7 Quality Assurance in Engineering Activities E7.1 Oversi ht of Station Activities The inspectors reviewed three Independent Safety Engineering Group (ISEG) assessment reports related to the following topics:

4 ISEG report 7-99, Investigation of the Unit 1 Reactor Recirculation Runback Event of September 4, 1999.

ISEG report 8-99, Investigation of the Response to Emergency Service Water (ESW) Flow Anomalies of September 20, 1999.

ISEG report 9-99, Surveillance of Plant Operations, October 1999.

b. Observations and Findin s I

The selected ISEG reports contained extensive reviews of selected plant issues which provided recommended actions to improve performance in administrative and technical areas. The ISEG reports were indicative of thorough investigation and analysis. The 1999 evaluations were thorough and self critical of the evaluated areas. The reports contained candid feedback to station management and were documented in the corrective action program.

c. Conclusions The Independent Safety Engineering Group report. results were indicative of thorough investigation and analysis of plant issues and personnel performance. The reports were objective and contained meaningful feedback to plant management.

IV. Plant Su ort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Radiolo ical Controls-External and Internal Ex osure The inspector evaluated the effectiveness of selected aspects of the applied radiological control program. The evaluation included a selective review of the adequacy and implementation of the following radiological control program elements and activities:

implementation of the radiation work permit (RWP) program RWP No. 1999-0095 and 1999-0109 related to the reactor water clean-up (RWCU) system access controls to radiologically controlled areas (RCAs)

use and adequacy of personnel occupational exposure monitoring devices maintenance of personnel occupational radiation exposures (external and internal) within applicable regulatory limits and as low as reasonably achievable (ALARA) status of the National Voluntary Laboratory Accreditation Program (NVLAP) periodic thermoluminescent dosimeters (TLD) quality control (QC) testing operation and maintenance of a whole-body-counting (WBC) program dose calculations for skin dose and for internal uptakes The inspector evaluated performance in the above-selected areas via observation of work activities, tours of the radiologically controlled area (RCA), discussions with plant personnel, review of documentation, and evaluation of applicable station procedures.

Observations and Findin s PP&L maintained personnel occupational radiation exposures (external and internal) within regulatory limits and as low as reasonably achievable (ALARA).

PP&L implemented effective access controls to the radiologichlly controlled areas of the station including use of RWPs, bar code readers, and computerized log-in stations. No access control deficiencies were identified. Appropriate personnel monitoring devices for access to the RCA were supplied and properly used.

c. Conclusions PP&L implemented effective applied radiological controls. The radiation work permit program was adequately implemented. Personnel occupational exposure was maintained within applicable regulatory limits and as low as reasonably achievable.

Access controls to radiologically controlled areas were effective, and appropriate occupational exposure monitoring devices were provided and used.

R1.2 Radiolo ical Controls-Radioactive Materials Contamination Surve s andMonitorin Ins ection Sco e (83750)

The inspector evaluated the effectiveness of PP&L's surveys, monitoring, and control of radioactive materials and contamination. The evaluation included a selective review of the adequacy and effectiveness of the following radioactive material and contamination control program elements:

surveys and monitoring of radioactive material and contamination the calibration status of survey and monitoring equipment the proper use of personal contamination monitors and friskers the tracking of personnel contamination events and goals The inspector evaluated performance in the above selected areas via observation of work activities, tours of the RCA, discussions with personnel, review of documentation, and evaluation of applicable station procedures.

b. Observations and Findin s In general, radiological housekeeping conditions in the reactor and turbine buildings were acceptable. The inspector noted several examples of poor housekeeping practices in locked areas of the reactor and turbine buildings. Generally, radioactive material and radioactive waste were clearly labeled, segregated, and stored in an orderly manner.

PP&L implemented an effective radioactive material and contamination control program.

Continuous air monitors were used in the RCA. A review of instrument calibration records indicated that the calibration program was implemented in accordance with procedures and only one minor discrepancy was noted.

~

to assist in monitorirfg and tracking personnel and area contamination rates and

'Goals percent recoverable contaminated area continued to be maintained and used to gauge the overall effectiveness of the station's programs in this area.

c. Conclusions I

PP&L implemented effective surveys, monitoring, and control of radioactive materials and contamination. Health Physics technicians properly documented survey results. In general, radiological housekeeping conditions were acceptable.

R1.3 Radiolo ical Controls-As Low As Reasonabl Achievable ALARA The inspector evaluated the effectiveness of PP&L's program to maintain occupational radiation exposure as low as is reasonably achievable. The. evaluation included a selective review of the adequacy and effectiveness of the following ALARAprogram elements/documents:

April 1999 HP Performance Indicator Report 1998 ALARAAssessment Draft Year 2000 Person-Rem Goal Breakdown HP Unit 2 (U2) Ninth Refueling and Inspection Outage (9RIO) Report Site ALARACommittee (SAC) Agenda for November 8, 1999 The inspector evaluated performance in the above selected areas via observation of work activities, tours of the RCA, discussions with personnel, review of documentation and station procedures.

Observations and Findin s The ALARAprogram continued to be well staffed and was being implemented in accordance with procedural controls. Post-job reviews were being used to generate exposure reduction plan (ERP) items for improving the ALARA effort. Annual and outage person-rem goals for the site were established, and person-rem goals for each work group were developed. On a regular periodic basis, actual person-rem accumulated for the site and for each work group was compared to the projections based on the established goals.

Lessons-learned from 1999 were being used in the development of the annual and outage goals for the year 2000. To this end, the Site ALARACommittee (SAC) established actions to improve dose control for the remainder of 1999 and was involved in the development of longer range exposure reduction activities irtcluding improved high radiation area controls and evaluation of remote monitoring methods. Additionally, the SAC initiated corrective actions to address long-standing employee concerns and

,exposure reduction plan items.

Conclusions The ALARAprogram remains acceptable.

Quality Assurance in RP&C Activities The inspector evaluated the effectiveness of PP&L's self-identification and corrective action'processes in the RP&C area. The evaluation included a selective review of the various surveillance, audit, and condition reports. The inspector also discussed the process with several cognizant personnel.

Observations and Findin s The Health Physics Program SRC/NAS Audit No.99-007 was broad in scope and detailed. The seven Quality Surveillance Reports reviewed were detailed. Four assessments were reviewed which covered radiation protection management, external dose assessment, the vendor-provided TLD irradiation service, and a vendor-provided instrumentation service. The breadth varied, but each was detailed and resulted in recommendations for improvement.

Approximately 160 Radiological Protection condition reports were issued in the period from December 31, 1998 to November 22, 1999. A number of condition reports related to HP were reviewed and found to include low threshold items. The inspector found that for those HP condition reports reviewed, the issues were elevated to an adequate management level, evaluated, and adequately corrected. Additional inspection of PP&L's corrective action program is discussed in Inspection Reports 05000387/1999013 and 05000388/1 999013.

10

c. Conclusions PP8 L's self-identification process in the area of radiation protection was generally, effective.

S1 Conduct of Security and Safeguards Activities Determine whether the conduct of security and safeguards activities met PP8 L's commitments in the NRC-approved security plan (the Plan) and NRC regulatory requirements. The security program was inspected during the period of November 29-December 3, 1999. Areas inspected included: alarm stations; communications; protected area (PA) access control of personnel, packages and vehicles.

b. Observations and Findin s Alarm Stations The inspector verified that the alarm stations were equipped with appropriate alarms, surveillance and communications capabilities. The inspector determined in interviews with the alarm station operators, that they were knowledgeable of their duties and responsibilities. The inspector also verified, through observations and interviews, that the alarm stations were continuously manned, independent, and diverse. The alarm stations did not contain any operational activities that could interfere with the execution of the detection, assessment, and response functions.

Communications The inspector determined by document reviews and discussions with alarm station operators, that the alarm stations were capable of maintaining continuous intercommunications and communications with each security force member (SFM) on duty and were exercising communication methods with the local law enforcement =

agencies as committed to in the Plan.

PA Access Control of Personnel Vehicles and Hand-Carried Packa es and Material On November 30, and December 1, 1999, the inspector observed personnel and package search activities at the personnel access portal. The inspector determined that positive controls were in place to ensure only authorized individuals were granted access to the PA, that all personnel and hand-carried items entering the PA were properly searched and that vehicles entering the PA were properly controlled, and searched.

C. Conclusions Security and safeguards activities with respect to alarm station controls, communications, and protected area access control of personnel, packages and vehicles were effectively implemented and met PP&L commitments and NRC requirements.

11 S2 Status of Security Facilities and Equipment (81'M)

Areas inspected were: PA assessment aids, PA detection aids, personnel search equipment and testing, maintenance and compensatory measures.

b. Observations and Findin s PA Assessment Aids On December 2, 1999, the inspector assessed the effectiveness of the assessment aids'by observing, on closed circuit television, two SFMs conducting a walkdown of the perimeter of the PA. The assessment aids had generally good picture quality and zone overlap. Additionally, to ensure Plan commitments are satisfied, PP&L had procedures in place requiring the implementation of compensatory m'easures in the event the alarm station operators are unable to properly assess the cause of an alarm.

Personnel and Packa e Search E ui ment On December 1, 1999, the inspector observed both routine use and performance testing of PP&L Personnel and package search equipment. The inspector determined that the search equipment performed in accordance with PP&L procedures and Plan commitments.

PA Detection Aids The inspector observed an SFM conducting performance testing of the perimeter intrusion detection system (PIDS). The testing consisted of intrusion attempts in numerous randomly selected zones during the camera walkdown. The appropriate alarms were generated in each attempt. The equipment was functional and effective and met the requirements of the Plan.

Conclusions PP&L's security facilities and equipment were determined to meet their commitments and NRC requirements.

S3 Security and Safeguards Procedures and Documentation

a. Ins ection Sco e(81700)

Areas inspected were: implementing procedures and security event logs.

b. Observations and Findin s Securi Pro ram Procedures The inspector determined that the procedures were consistent with the Plan commitments, and were properly implemented and accomplished based on review of selected implementing procedures associated with PA access control of personnel, packages and materials, testing and maintenance of personnel search equipment, and performance testing of PA detection aids.

12 Securit Event Lo s The inspector reviewed the Security Event Logs for the previous twelve months. Based on this review, and discussion with security management, the inspector determined that PP&L appropriately analyzed, tracked, resolved and documented safeguards events that PP8L determined did not require a report to the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Conclusions Security and safeguards procedures and documentation were properly implemented.

Event Logs were properly maintained and effectively used to analyze, track, and resolve safeguards events.

1 S4 Security and Safeguards Staff Knowledge and Performance

~.(B'M)

Area inspected was: security staff requisite knowledge.

b. Obs'ervations and Findin s Securit Force Re uisite Knowled e The inspector observed a number of SFMs in the performance of their routine duties. These observations included alarm station operations, personnel, vehicle and package searches, and performance testing of the PIDS. Additionally, interviews of SFMs were conducted. Based on the responses, the inspector determined that the SFMs were knowledgeable of their responsibilities and duties and could effectively carry out their assignments.

Conclusions The SFMs adequately demonstrated that they had the requisite knowledge necessary to effectively implement the duties and responsibilities associated with their position.

S5 Security and Safeguards Staff Training and Qualification Areas inspected were security training and qualifications, and training records.

b. Observations and Findin s Securi Trainin and Qualifications On December 3, 1999, the inspectors observed 7 randomly selected training and qualification (T8Q) records of SFMs. Physical and requalification records were inspected for armed and supervisory personnel. The results of the review indicated that the security force was being trained in accordance with the approved T8Q plan.

Trainin Records The inspector determined that the records were properly maintained, accurate, and reflected the current qualifications of the SFMs.

C. Conclusions

t Security force personnel were being trained in accordance with the requirements of the T&Q Plan. Training documentation was properly maintained and accurate and the training provided by the training staff was effective.

S6 Security Organization and Administration Areas inspected were: management support, effectiveness and staffing levels.

Observations and Findin s Mana ement Su ort The inspector determined based on review of program implementation since the last program inspection, that adequate support and resources continued to be available to ensure program implementation.

Ti i i i d i i y

minimum requirements specified in the Plan and implementing procedures. No performance issues were noted in the areas inspected.

Conclusions Management support was adequate to ensure effective implementation of the security program, as evidenced by adequate staffing levels and the allocations of resources to support programmatic needs.

S7 Quality Assurance (QA) in Security and Safeguards Activities Ins ection Sco e(81700)

Areas inspected were: audits, problem analyses, corrective actions and effectiveness of management controls.

b. Observations and Findin s Audits The inspector reviewed the annual physical security audit. The audit was thorough and in-depth. The audit identified 4 deficiencies. The deficiencies were related to administrative controls, and were minor documentation errors. None of the audit findings were indicative of programmatic issues.

Problem Anal ses The inspector reviewed data derived from the security department's self-assessment program. Potential weaknesses were being properly identified, tracked, and trended.

'orrective Actions The inspector reviewed the corrective actions implemented by PP&L in response to the 1999 QA audit and self-assessment program. The corrective actions were technically sound and were performed in a timely manner.

Effectiveness of Mana ement Controls PP&L had programs in place for identifying, analyzing and resolving problems. They included the performance of annual QA audits, a departmental self-assessment program and the use of industry data such as violations

of regulatory requirements identified by the NRC at other facilities, as a criterion for self-assessment.

c. Conclusions PP8 L's audit program was being properly administered. In addition', the self-assessment program was being effectively implemented to identify and resolve potential weakness.

SS Miscellaneous Security and Safeguards Issues S8.1 Closed LER 50-387/99-005-00 Safe uards Event (71750, 92700)

On August 6, 1999, PP8L identified that an observation which inadvertently contained safeguards information had been distributed via an uncontrolled electronic mail (e-mail) system.

A review was conducted of PP8 L's corrective actions associated with this event, addressing the dissemination of safeguards via company e-rrfail. It was determined that PP8L implemented appropriate compensatory measures, and corrective actions to preclude recurrence were acceptable. No violation of NRC requirements was identified.

This LER is closed.

V. Mana ement Meetin s X1 Exit Meeting Summary A Region I security specialist presented the results of the Security and Safeguards program inspection to members of PP8 L management at the conclusion of the inspection on December 3, 1999. PP8L acknowledged the findings presented.

A Region I health physics specialist presented the results of the Radiological Controls-External and Internal Exposure programs inspection to members of PP8L management at the conclusion of the inspection on December 10, 1999. PPBL acknowledged the findings presented.

The inspectors presented the inspection results to members of PP&L management at the conclusion of the inspection period, on January 7, 2000. PP8L acknowledged the findings presented.

The inspectors asked PP&L whether any materials examined during the inspection ~

should be considered proprietary. No proprietary information was identified.

15 INSPECTION PROCEDURES USED IP 37551 Onsite Engineering Observations IP 40500 Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726 Surveillance Observations IP 62700 Maintenance Program Implementation IP 62707 Maintenance Observations IP 71707 Plant Operations IP 71750 Plant Support Activities IP 81700 Physical Security Program for Power Reactors I IP 83750. Occupational Radiation Exposure IP 92700 On Site Followup of Reports ITEMS OPENED, CLOSED, AND DISCUSSED

~Oened None.

0 ened/Closed None

~Udated None.

Closed 50-387/99-004-00 LER Reactor Core Isolation Cooling (RCIC) Manually Isolated due to Failure of Steam Leak Detector Temperature Switch (Section 08.1) 50-387/99-005-00 LER Safeguards Event (Section S8.1)

16 LIST OF ACRONYMS USED CFR Code of Federal Regulations CR Condition Report CS Core Spray DCP Design Change Package EAL Emergency Plan Action Level EDG Emergency Diesel Generator 0

F Fahrenheit FSAR Final Safety Analysis Report IR [NRC] Inspection Report LCO Limiting Condition for Operation LER Licensee Event Report LLRT Local Leak Rate Test LPCI Low Pressure Coolant Injection MSIV Main, Steam Isolation Valve NCV Non-Cited Violation NDAP Nuclear Department Administrative Procedure NOV [NRC] Notice of Violation NRC Nuclear Regulatory Commission NUMARC Nuclear Management and Resources Council OD Operability Determination OSHA Occupational Safety and Health Administration PCO Plant Control Operator PCPR Plant Component Problem Report PP8L Pennsylvania Power and Light Company RCIC Reactor Core Isolation Cooling RHR Residual Heat Removal RPS Reactor Protection System RP&C Radiological Protection and Chemistry scfh Standard Cubic Feet per Hour SSCs Structures, Systems, and Components SSES Susquehanna Steam Electric Station TS Technical Specification

ORIGINAL DUE DT: 02/25/00 TICKET NO: 020000010 FROM: l&gD @~4 "'g/(y/~gNRR DOC DT'1 18 00 VICTOR DRICKS RCVD DATE: 01/24/00 TO:

VICTOR NERSES FOR SIGNATURE OF ** +EL **

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SUSQUEHANNA-2 SHUTDOWN, DEC 99 COLLINS/ZIMMERMN g'JOHNSON SHERON NRR MAILROOM ASSIGNED TO: CONTACT:

DLPM J. ZWOLINSKI SPECIAL INSTRUCTIONS OR REMARKS:

~ wats .A4~rrerassewt PRober: Sohaaf- Fwd: Susquehanna-2 Shufdown, Deo.99 a

~

S ~

From: Victor Dricks To: Victor Nerses Date: Tue, Jan18,2000 8:50AM

Subject:

Fwd: Susquehanna-2 Shutdown, Dec.99 Vic: Could you please respond to this inquiry directly? Please cc me as it involves Greenpeace.

's

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Fwd: Susquehanna-2 Shutdown, Dec.99 Creation Date: Tue, Jan 18, 2000 8:50 AM From: Victor Dricks Created By: OWFN DO.OWF1 PO:VLD Recipients Post Office OWFN DO.owf4~o VXN (Victor Nerses)

Domain. Post Office Route OWFN DO.owf4~o OWFN DO.owf4~o Files Size Date & Time Mail MESSAGE 592 Tuesday, January 18, 2000, 8:50 AM I

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Robe( Schaat - Susquehanna-2 Shutdown, Dec.99 Page 1 .

From: Ueli Mueller <ueli.muellerch.greenpeace.org>

To: OWFN DO.owf1~o(OPA)

Date: Mon, Jan 17, 2000 8:36 AM

Subject:

Susquehanna-2 Shutdown, Dec.99 Dear Sirs in a Nucleonics Week article (23/12/99, p.3) was mentioned a shutdown of Susquehanna-2 NPP due to a stresswaused weld leak in a reactor circulation pump. On the NRC website I couldn't find any mention of the event. So if you could provide me with information to following points:

- what kind of material was affected (INCONEL type)?

- has the NRC released a publication addressing this specific event'

- NRC-spokesman Sam Hansell is quoted in the article, stating that NRC will examine if there is a BWR generic issue. What findings generated the examination of the Susquehanna-leakV

- Is the detailed cause of the problem known and is it related with power uprating of BWR'?

- Are other BWR-owners in the US confronted with similar problems'? If so, has NRC taken any action yet to oblige the owners to address the problem'

- Have similar problems eventually caused by increased material stress due to power uprating occurred before in BWR in the US'?

I thank you in advance for your answer.

Sincerely yours Ulrich Mueller Ueli Mueller Koordinator Atomkampagne Greenpeace Postfach CH-8031 Zuerich

++411 447 4123 Phone

++411 447 4199 Fax

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Date: Mon, 17 Jan 2000 14:36:27+0100 To: opanrc.gov From: Ueli Mueller <ueli.mueller@ch.greenpeace.org>

Subject:

Susquehanna-2 Shutdown, Dec.99 Content-Type: text/plain; charset="us-ascii"; format="flowed" Dear Sirs in a Nucleonics Week article (23/12/99, p'.3) was mentioned a shutdown of Susquehanna-2 NPP due to a stress-caused weld leak in a reactor circulation pump. On the NRC website I couldn't find any mention of the event. So if you could provide me with information to following points:

- what kind of material was affected (INCONEL type)'

- has the NRC released a publication addressing this specific event'

- NRC-spokesman Sam Hansell is quoted in the article, stating that NRC will examine if there is a BWR generic issue. What findings generated the examination of the Susquehanna-leak7

- Is the detailed cause of the problem known and is it related with power uprating of BWR'?

- Are other, BWR-owners in the US confronted with similar problems'? If so, has NRC taken any action yet to oblige the owners to address the problem7

- Have similar problems eventually caused by increased material stress due to power uprating occurred before in BWR in the US'?

I thank you in advance for your answer.

Sincerely yours Ulrich Mueller Ueli Mueller Koordinator Atomkampagne

Icooert 5cnaar.- Message.tut Page 2-Greenpeace Postfach CH-8031 Zuerich

++411 447 4123 Phone

++411 447 4199 Fax

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Created By: GATED.nrcsmtp:"ueli.mueller@ch.greenpeace.org" Recipients Post Office OWFN DO.owfl~o OPA I

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]~~n ORIGINAL DUE DT: 02/25/00 TICKET NO: 020000010 FROM: ~p/iq/~'g DOC DT: 01/18/00 VICTOR DRICKS NRR RCVD DATE: 01/24/00 TO:

VICTOR NERSES FOR SIGNATURE OF ** +EL **

DESC: ROUTING:

SUSQUEHANNA-2 SHUTDOWN, DEC 99 COLLINS/ZIMMERMN JOHNSON SHERON NRR MAILROOM ASSIGNED TO: CONTACT:

DLPM J. ZWOLINSKI SPECIAL INSTRUCTIONS OR REMARKS:

Rufbe.'; Schaaf- wd: Susquehanna-2 S tdown, Dec.99 Page 1 From: Victor Dricks To: Victor Nerses Date: Tue, Jan18,2000 8:50AM

Subject:

Fwd: Susquehanna-2 Shutdown, Dec.99 1

Vic: Could you please respond to this inquiry directly'? Please cc me as it involves Greenpeace.

H

C:PPIII'OOWS(TEMP<G~00021. MP Page 1, Mail Envelope Properties (38846F89.F00: 4: 61446)

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Fwd: Susquehanna-2 Shutdown, Dec.99 Creation Date: Tue, Jan 18, 2000 8:50 AM From: Victor Dricks Created By: OWFN DO.OWF1 PO:VLD Recipients Post Office OWFN DO.owf4~o VXN (Victor Nerses)

Domain. Post Office Route OWFN DO.owf4~o OWFN DO.owf4~o Files Size Date Ch Time Mail MESSAGE 592 Tuesday, January 18, 2000 8:50 AM Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

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No.

Security: Standard

4' fa

R jb'e~ Sc aaf - Susque anna-2 Shutdo, Dec.99 Page 1.

From: Ueli Mueller <ueli.muelleroch.greenpeace.org>

To: OWFN DO.owf1~o(OPA)

Date: Mon, Jan 17, 2000 8:36 AM

Subject:

Susquehanna-2 Shutdown, Dec.99 Dear Sirs in a Nucleonics Week article (23/12/99, p.3) was mentioned a shutdown of Susquehanna-2 NPP due to a stress-caused weld leak in a reactor circulation pump. On the NRC website I couldn't find any mention of the event. So if you could provide me with information to following points:

- what kind of material was affected (INCONEL type)'

- has the NRC released a publication addressing this specific event'

-.NRC-spokesman Sam Hansell is quoted in the article, stating that NRC will examine if there is a BWR generic issue. What findings generated the examination of the Susquehanna-leak'

- ls the detailed cause of the problem known and is it related with power uprating of BWR'?

- Are other BWR-owners, in the US confronted with similar problems'? If so, has NRC taken any action yet to oblige the owners to address the problem'? .

- Have similar problems eventually caused by increased material stress due to power uprating occurred before in BWR in the US'?

I thank you in advance for your answer.

Sincerely yours Ulrich Mueller Ueli Mueller Koordinator Atomkampagne Greenpeace Posffach CH-8031 Zuerich

++411 447 4123 Phone

++411 447 4199 Fax

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Date: Mon, 17 Jan 2000 14:36:27+0100 To: opa@nrc.gov From: Ueli Mueller <<ueli.mueller@ch.greenpeace.org>

Subject:

Susquehanna-2 Shutdown, Dec.99 Content-Type: text/plain; charset="us-ascii"; format="flowed" Dear Sirs in a Nucleonics Week article (23/12/99, p.3) was mentioned a shutdown of Susquehanna-2 NPP due to a stress-caused weld teak in a reactor circulation pump. On the NRC website I couldn't find any mention of the event. So if you could provide me with information to following points:

- what kind of material was affected (INCONEL type)'?

- has the NRC released a publication addressing this specific event'

- NRC-spokesman 5am Hansell is quoted in the article, stating that NRC will examine if there is a BWR generic issue. What findings generated the examination of the Susquehanna-leak'

- Is the detailed cause of the problem known and is it related with power uprating of BWR?

- Are other, BWR-owners in the US confronted with similar problems'? If so, has NRC taken any action yet to oblige the owners to address the problem7

- Have similar problems eventually caused by increased material stress due to power uprating occurred before in BWR in the US'?

I thank you in advance for your answer.

Sincerely yours Ulrich Mueller Ueli Mueller Koordinator Atomkampagne

Rc,be~ Schaaf.- Message. ul Page lol 2'reenpeace Postfach CH-8031 Zuerich

++411 447 4123 Phone

++411 447 4199 Fax

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