ML20202G829

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Informs That Alleger Called in Reference to Topics Contained in RI-97-A-145
ML20202G829
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 08/21/1997
From: Brian Mcdermott
NRC
To: Swetland P, Vito D
NRC
Shared Package
ML20202F480 List:
References
FOIA-99-36 NUDOCS 9902050300
Download: ML20202G829 (1)
v • d • e


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AUG-21-1997 15:13 US NRC SUSQ RES OFR cE 717 542 4573 P.02 MEMO T0: Allegation File RI-97-A-145 CC: Paul Swetland, David Vito <

FROM: Brian McDermott, Resident Inspector - Susquehan DATE: August 21, 1997, 11:30 a.m.

SUBJECT:

FOLLOWUP CALL FROM ALLEGER The alleger called in reference to the topics contained in RI-97-A-145.

- The alleger requested a copy of the PP&L response to the NRC letter, H.J. ,

Miller to R.G. Byram, " Notice of Violation and Proposed Imposition of Civil Penalties - $210,00," dated June 20, 1997. As a courtesy, I faxed a copy of the PP&L response dated July 30, 1997, to the alleger's home, rather than send him to the FOIA process.

- The alleger stated that he had a telephone call from Mr. Martin Urban, Manager of PP&L Corporate Auditing. Mr. Urban told the alleger that he was currently ,

investigation the "who knew what and when" of the April 9,1997 letter from PP&L )

to the NRC. Based on this statement the alleger concluded that Corporate  ;

Audittng knows that the April 9,1997 letter was not accurate. The alleger wanted to know if the NRC had received a recent letter from PP&L stating the April 9,1997, letter was inaccurate. I told the alleger that no such letter had -- -

been received by the Resident Office and that PP&L correspondence are typically  :

CC'd to our office.

- I asked the alleger if there was anything else he needed from me at this time  !

and he said "no." The alleger stated that he would keep in touch.

- To followup on the alleger's conclusion, and in accordance the Allegation Panel Decision, I telephoned Mr. Urban for an update on the progress of his i investigation. I asked Mr. Urban if he had information showing that alarm tests

- other than the 'E' DG local panel OC577 - were not tested when required. He said "no." He told me that he was still investigating if other alarms panels had  ;

not been tested and in parallel, he is investigating who provided the data for the April 9,1997, PP&L letter, where the information came from, and what was j done to validate it. He stated that the computer records and circumstances 4 surrounding the alarms being. investigated are not as clear cut as the OC577 alarm panel test. He closed by saying that he would notify me as soon as he had evidence to show that other alarms weret not being tested.

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l August 5,1997

Mr. Robert G. Byram

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Senior Vice President Nuclear -

Pennsylvania Power & Light Company

. 2 North Ninth Street Allentown, Pennsylvania 18101

SUBJECT:

.NRC INTEGRATED li4SPECTION REPORT 50-387/97-04, 50-388/97-04; NOTICE OF VIOLATION

Dear Mr. Byram:

. On June 30,1997, the NRC completed an inspection at your Susquehanna Steam Electric Station Units.1 & 2 reactor facilities. The enclosed report presents the results of that inspection. I l

During the 6-week period covered by this inspection, the conduct of activities at the -i facility was characterized generally by safe operation and conservative decision making. In

. . one instance, a Shift Supervisor made good decisions involving the potential for a dual unit shutdown and was deliberate in the communication of this situation to each unit operator.

In a second case, a Unit Supervisor responded, coached 'and coordinated an excellent

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response to a minor test failure. We noted that operations department management involvement in both issues was aggressive and safety oriented. Of special note was the

direction and control supplied by the Operations Supervisor in response to charcoal testing operability questions, and the ensuing Notice of Enforcement Discretion.

Based on the results of this inspection the NRC has determined that violations of 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 you are required to respond to this letter and should follow the instructions specified in the_ enclosed Notice when preparing your response. The

' violations concerni (1) the failure to adequately test the standby gas treatment system charcoal beds; (2) two examples of a failure to initiate adequate corrective action

. concerning an operability determination for a degraded emergency diesel generator ventilation damper, and the post accident sampling system; (3) failure to get prior NRC approval for an organization change that affected the Quality Assurance Program; and,

-(4) failure to revise the Final Safety Analysis Report after emergency service water (ESW) pump start times were changed by a modification.

The NRClalso determined that violations occurred concerning the staffing of the

'Susquehanna Nuclear Safety Assessment Group (NSAG). These concerns involve the reduction of the dedicated staff size and the qualification of one of the safety engineers.

The latter example is included in the Notice even though it was licensee-identified because 7

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Mr. Robert G. Byram 2 your corrective action did not include measures to prevent recurrence of the problem. ,

Further, several instances of weak management control and oversight of NSAG were j identified including organization changes that could compromise the independence of the l NSAG function, and inadequate planning for implementation of required NSAG functions.

Consequently, in your response to these violations, please address your planned corrective l actions to review and reconcile the activities performed by NSAG and the current licensing i

basis requirements.

In addition, we note that this is the third recent example in which PP&L has been found to ,

l be in violation of NRC requirements because you reasoned that meeting the intent of a l

! technical specification was equivalent to following the requirement as written. The other examples include a blocked open containment isolation valve, previously cited, and the inadequate charcoal filter testing discussed in this report. Therefore, in your response to this letter, please include those additional actions you deem appropriate to assure that all l requirements are strictly adhered to and that appropriate changes wi!I be requested prior to implementing new methods of conformance. The NRC will use your response, in part, to

' determine whether further enforcement action is necessary to ensure compliance with. -

regulatory requirements.

Also of concern during this period was an instance that could have resulted in serious i personnel injury. An activity was identified by the Resident inspector in which your safety i requirements for rigging of heavy loads were not met. Even though there were no ,

violations of NRC requirements, this activities could have resulted in damaged equipment or serious personnel injury. It was noted that Susquehanna plant management and plant safety representatives responded well from a corrective action and investigation standpoint.

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 Document Room. The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Public Law No. 96.511.

Sincerely, Original Signed By:

Charles W. Hehl, Director Division of Reactor Projects Docket Nos.: 50-387;50-388 License Nos: NPF-14, NPF-22 l

Enclosures:

l 1. Notice of Violation l 2. Inspection Report 50-387/97-04,50-388/97-04 1

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c. Conclusigna  !

Personnel performance errors, procedural problems and equipment deficiencies were identified during a functional test of the post accident sampling system. During a

  • subsequent test, licensee actions were effective in correcting the personnel l performance and procedure issues. However, the licensee's failure to initiate a I

condition report and to repair a non-functional sample holder since August'1994 is cited as a violation of 10 CFR 50 Appendix B, Criterion XVI.

V. Manaaement Meetings X1 - Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 30,1996. The licensee acknowledged the findings presented.

l X3 Management Meeting Summary i On June 12, the inspector attended a management meeting in the NRC Region I  !

l offices between NRC Region i management and representatives of PP&L. The meeting was held to discuss weaknesses noted by NRC in PP&L's approach to the investiga+ ion of technical issues referred to them, and to the lack of comprehensive assessment and corrective measures in response to those investigations. PP&L's presentation materials are attached. During this meeting, PP&L related that a task l

group had been formed to review PP&L's investigation and NRC response practices.

Also, a safety culture assessment had been initiated to measure the climate for

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safety concerns processing at Susquehanna. The licensee committed to: (1) amend l a prior written response on these issues to more specifically address the scope of l the intended actions, and (2) update the NRC staff with the results of the task i group and safety culture assessments.  ;

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