ML20024A723
| ML20024A723 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/22/1983 |
| From: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kenyon B PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML20024A724 | List: |
| References | |
| EA-83-026, EA-83-26, NUDOCS 8306220155 | |
| Download: ML20024A723 (4) | |
Text
JERLE Copy APR sg 1993 Docket No. 50-387 EA 83-26 Pennsylvania Power & Light Company ATTN: Mr. Bruce D. Kenyon Vice President, Nuclear Operations 2 North Ninth Street Allentown, Pennsylvania 18101 Gentlemen:
Reference:
NRC Inspection Report No. 50-387/83-03 This refers to the NRC inspection conducted between January 12, 1983 and March 8, 1983 at the Susquehanna Steam Electric Station, Unit 1, Berwick, Pennsylvania, of activities authorized by NRC License No. NPF-14. The report of the inspection was forwarded to you on March 14, 1983.
During the inspec-tion, violations of NRC requirements were identified.
One violation involved the authorization of maintenance on the standby gas treatment system (SGTS) without adequate review and approval of the activity. As a result, both sub-systems of SGTS were rendered inoperable for a period of approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
These subsystems are required to be operable in accordance with a technical specification limiting condition for operation (LCO). Another violation involved the failure to make a required report of this violation to the NRC after it was identified. These violations were discussed during an enforcement conference held with you and other members of your staff on March 17, 1983.
The violation of the LCO is described in Section I of the attached Notice.
The cause of this violation appears to be inadequacy in your process for review-ing maintenance activities to assure that these activities do not affect safe plant operation.
In tnis instance, certain electrical circuit breakers were opened prior to maintenance on one of the SGTS subsystems, but the maintenance and operations supervisors, during their preparation, review, and approval of the appropriate work authorization form and equipment release form, apparently did not recognize that the opening of those breakers would cause both SGTS subsystems to be inoperable. Your review process did not require any further review by an appropriate technical group.
Moreover, there were indications in the control room that both subsystems were inoperable. Specifically, several abnormal instrument and damper indications were apparent after the breakers were opened. Also, an instrument power failure alarm occurred for both SGTS subsystems. Although these alarms and abnormal indications existed for a period during which the control room was manned by three different shifts, control room operators did not adequately CERTIFIED MAIL RETURN RECEIPT REQUESTED
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investigate the alarms, did not enter the alarms into the control room log during the shift and at shift turnovers as required, and did not recognize that both SGTS subsystems were inoperable until after SGTS subsystem "A" was tested, in preparation for return to service, and would not function. When this condition was finally recognized, it was not reported to the NRC Operations Center within one hour as required by our regulations. We do note, however, that our resident inspector was informed of the matter approximately 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> after you recognized the problem.
These events demonstrate the need for improvements in your operation at Susquehanna, particularly with regard to:
(1) the process for reviewing and approving maintenance activities to assure these activities do not affect safe plant operation; (2) alarm response procedures and training of operating personnel in responding to and investigating alarms and indications; and (3) prompt compliance with reporting requirements.
Proper planning and review of the maintenance activity performed on SGTS subsystem "A" could have prevented the LCO violation. Also, had the alarm response procedure been more thorough and had the operators been properly trained and attentive to the procedure, the fact that both SGTS subsystems were inoperable could have been recognized sooner.
At the enforcement conference on March 17, 1983, we discussed our concerns with you regarding these events and the need for improvements at the Susquehanna station. Your corrective actions as described at the enforcement conference, if properly implemented, should prevent recurrence of violations of this type.
Those actions included: (1) additional reviews by the appropriate technical group of any proposed maintenance activity prior to implementation of the activ-ity; (2) revisions to alarm response procedures; and (3) additional training of control room operators.
In order to emphasize the need for the improvements in the operation of the Susquehanna station, as previously stated, to assure safe plant operation is not affected by maintenance activities, and the facility is operated in accord-ance with technical specifications, I have been authorized, after consultation with the Director of the Office of Inspection and Enforcement, to issue the attached Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Sixty Thousand Dollars ($60,000) for the violation described in'Section I of the attached Notice. This violation has been classified at Severity Level III in accordance with Section C.1 of Supplement I of the NRC Enforcement Policy (10 CFR Part 2, Appendix C), dated March 9, 1982.
The base civil penalty amount of $40,000 has been increased to $60,000 because sufficient information existed in the control room immediately after the breakers were opened to alert operators to the violation, yet the condition was not recog-nized and corrected, and this condition went undetected by three different operating shifts.
You are required to respond to the attached Notice and should follow the in-structions specified therein when preparing your response.
In your response, you should describe the specific actions that you have taken, or will take, to improve the process of revi. ewing maintenance activities, improve alarm response OFFICIAL RECORD COPY
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procedures, and improve operator training. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is appropriate.
In accordance with 10 CFR 2.790, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the attached Notice are not subject to the clearance procedures of the Office of Management and Budget, otherwise required by the Paperwork Reduction Act of 1980, P1 96-511.
Sincerely, ORIGINAL SIGNED BY:
JAMES M. ALUtN James M. Allan Acting Regional Administrator
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty
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Norman W. Curtis, Vice President, Engineering and Construction - Nuclear A. R. Sabol, Manager, Nuclear Quality Assurance W. E. Barberich, Licensing Engineer H. W. Keiser, Plant Superintendent Public Document Room (POR)
Local Public Document Room (LPDR)
NRC Resident Inspector Commonwealth of Pennsylvania l
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Region I Docket Room (with concurrences)
Senior Operations Officer (w/o encls)
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