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US NRC SUSO RES OFFICE P.02 i -;
MEMO TO: Allegation File RI-97-A-145 CC: Cliff Anderson, P wet land, Ken Jenison, Dave Vito FROM: Brian McD DATE: November 5,199 : 12:58PM
SUBJECT:
FOLLOW-UP CALL FROM ALLEGER The alleger had two questions:
- 1. The alleger questioned whether PP&L had gotten back to the NRC on the results of their investigation into the alarms and the potential false statements to the NRC contained in PP&L's April 9,1997, letter.
I told the alleger that Cliff Anderson was dealing with PP&L on this issue and that i understood PP&L completed only a part of their investigation. The alleger stated that he was going to call Cliff Anderson.
- 2. The alleger questioned whether the NRC was reinvnstigating the E diesel generator misalignment to determine if tampering was involved.
I told the alleger that as part of NRC on-site follow-up of the event, the potential for '
tampering was considered. (This potential was raised by some of the NPCs during PP&L interviews. These NPCs were interviewed because of questions regarding the accuracy of TS surveillances they signed.) I told the alleger my recollection of the issue; The postulated movement of the "E" diesel generator output breaker, several times between TS surveillances. I did not believe this was a reasonable scenario because of a control room alarm essociated with the breaker and because Wade Whitfield admitted moving the breaker to the incorrect position in the first place. ( l also believe there was hard evidence dealing with the breaker serial numbers) The alleger recalled the alarm feature that I referenced and was satisfied with my response.
I received no new allegations during this call.
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Kenneth Jenison, SRI l V , Brian McDermott, RI
- John Richtiiond, RI
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i October 30,1997 Mr. Robert G. Byram Senior Vice President - Nuclear Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
SUBJECT:
NRC INSPECTION REPORT 50-387/97-07,50-388/97-07 AND NOTICE OF VIOLATION
Dear Mr. Byram:
On October 20,1997, the NRC completed an inspection at your Susquehanna Steam Electric Station facility. The enclosed report presents the results of that inspection.
During the 9-week period covered by this inspection, the conduct of activities at the
- l facility was characterized by safe operation and conservative decision making. In several .)
instances operator response to alarmed conditions was aggressive and well supported by i on shift operations department supervision. We noted that operations department management involvement in severalissues was effective and safety oriented.
Based on the results of this inspection, the NRC has determined that three violations of l NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding the violations are described in detail in the enclosed report. Please note that for two of these violations you are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The violations concern: (1) failure to establish an adequate maintenance procedure prior to removing a design feature of the standby liquid control system from service, and (2) failure to perform a safety evaluation prior to a placing a floating maintenance platform in the safety related spray pond (ultimate heat sink).
We note that violation (2)is the third recent instance in which PP&L has been cited for violation of NRC requirements because PP&L was not able to reasonably determine that the design basis review process described in your 10 CFR 50.54(f) response of February 13, 1997, would have identified the problem. An additional example is discussed in the enclosed inspection report regarding the control of plant equipment hatches. The NRC has reached the same conclusion regarding PP&L's ability to identify this problem given the previously existing design basis review process. Other instances were discussed in NRC inspection report 50-387,388/97-06. In your response to this letter, please include the additional actions you deem appropriate to assure that your 50.54(f) design basis review process will, at its completion, identify design issues of the type discussed. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
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The third violation involves the failure to implement all the required equipment inspections
! specified in your operator rounds procedure. Although, no known equipment problems l were missed by the deferral of the specified activities, the direction of operators to perform j alternate tasks rather than the specified rounds, without changing the procedure to address the deviation, undermined the expectation for operators to perform their activities in ,
accordance with written procedures. The cause and your corrective actions for this violation were documented in this inspection report, and were acceptable. Therefore, you ,
are not required to respond to this violation.
l In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter ]
- and its enclosures will be placed in the NRC Public Docums nt Room. The responses - 1 l directed by this letter and the enclosed Notice are not subject to the clearance procedures i
of the Office of Management and Budget as required by the Paperwork Reduction Act of
- 1980, Public Law No. 96.511. i Sincerely,
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- ORIGINAL SIGNED BY l
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' Clifford J. Anderson, Branch Chief
- l. Projects Branch 4 Division of Reactor Projects
' Docket Nos: 50-387:50-388 License Nos: NPF-14, NPF-22
Enclosures:
- 1. Notice of Violation
- 2. Inspection Report 50-387/97-07,50-388/97-07 l'
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4 01.3 Nuclear Plant Ooerator (NPO) Performance
- a. Insoection Scooe (71707)
On October 9,1997, the inspectors determined that certain portions of NPO rounds as described in Operatiens department procedure Ol-AD-016 were not being i performed in a consistent and complete manner. A review of the licensee's corrective actions for this issue was performed.
- b. Observations and Findinas Based on interviews with five NPOs and ten licensed operators, the inspectors determined that the licensee was not fully implementing Operations department procedure Ol-AD-016, Operator Rounds. The inspectors determined that the required check sheet data, including TS surveillances, were being adequately taken during operator rounds. However, additional Ol-AD-016 general and routine required actions were not always performed when other plant activities were -
deemed more appropriate by the Unit Supervisor and/or the Assistant Unit Supervisor. The flexibility to omit certain general visual inspections (GVis) was not addressed in Ol-AD-016. Through interviews, the inspectors found that the GVis of Ol-AD-016 were interrupted on a regular basis by interfering activities and were routinely not completed to the level that the operators interviewed felt that they were meeting the requirements of the procedure.
The interview process was chosen by the inspectors for this determination because:
(1) there is no available objective evidence on which to judge whether these general l and routine requirernents were being completed, (2) the inspectors verified that field audits by PP&L similarly concluded that there were weaknesses in the NPO round activities and, (3) it was anticipated that any NRC accompaniments of NPO rounds would not be interrupted by the type of activities described by the NPOs.
The inspectors verified through their interviews with NPOs, PCOs, Unit Supervisors (USs), and Shift Supervisors (SS) that portions of the GVis required by OI-AD-016 sections 4.2 through 4.5 were delayed, amended or missed during periods of high activity. The inspectors verified that neither Operations management nor the NPOs had documented the f ailure to implement OP-AD-016 as written in a condition report (CR). This issue was discussed with SSES site management on October 10, 1997 and with Operations department management on October 16,1997.
TS 6.8.1, Procedures, requires procedures including OI-AD-016 to be established, implemented and maintained. The failure to ensure that Operations department procedure OI-AD-016 was implemented as established is considered a violation (VIO 387,388/97-07-02). On October 17,1997, the inspectors met with SSES site management and were presented with an action plan that included procedure l changes and training topic additions that were intended to eliminate the procedural compliance issue and clarify NPO performance expectations. SSES management
! stated that they considered certain parts of OI-AD-016 to be general guidelines which should be considered in relationship to the NPO's experience and training,
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even though the procedure was written in a form that would require complete I implementation. For example, step 1 of the General Rounds Expectations I
attachment to OI-AD-016 states that ... All rotating equipment such as pumps, motors shall be inspected each shift ... Inspections of protective covers on MCC's l and load centers shall be performed ... it is required to inspect all operator i accessible areas of the plant ... The licensee changed the Rounds Expectations attachment to read, for example, "When checking rotating equipment such as pumps, motors, etc., consider the following...", through procedure change PCAF 1-97-0590 series. This change clarifies that the requirements are considered guidelines, and provides the flexibility for more or less effort in given areas based on other more significant shift activities. The inspector concluded that the immediate corrective actions were acceptable. l
- c. Conclusions Interviews were conducted with non-licensed and licensed operators to assess the implementation of SSES Operations department procedure OI-AD-016, Operator -
Rounds. Based on these interviews, the inspectors determined that portions of procedure sections 4.2 through 4.5 were routinely delayed, amended or missed during periods of high activity. This issue was discussed with licensee management on three occasions. The licensee made changes to the procedure to ensure that the procedure was clear and allowed shift supervision the flexibility to delay or amend the requirements for general equipment inspections in the subject procedure steps.
The licensee's immediate corrective actions were adequate and were completed prior to the end of the inspection period. The failure to follow procedure OI-AD-016 as written during previous operator rounds was a violation of TS 6.8.1.