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REG!oN i 475 ALLENDALE ROAD KING oF PRusstA. PENNSYLVANIA 19406-1415 l
April 16, 1998 i
RI-97-A-0145 C
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SUBJECT:
CONCERNS YOU RAISED TO THE NRC REGARDING PENNSYLVANIA POWER & IJGHT'S (PP&L) SUSQUEHANNA FACILITY Dea The NRC Region I office has completed its follow up in response to the concerns you brought to our attention in your telephone conversation with Mr. Brad Fewell, Regional Counsel, on June 20,1997. Specifically, you indicated that (1) there were additional alarm tests that were not performed (other than those recently reviewed with regard to the 'E' emergency diesel generator and General Station inspections (GSis)); and (2) PP&L management knew these tests (i.e., the ESS transfer alarm tect, the OC 322 panel alarm test for radwaste, and the control room panel alarm test) were not being performed, except by the afternoon shift.
This also refers to your telephone conversations with Mr. Brian McDermott, an NRC resident inspector at Susquehanna, on June 24,1997, July 17,1997, August 21,1997, November 5,1997, and December 5,1997; your telephone conversations with Ms. K.
Modes, of this office, on December 5,1997, January 5 and 15,1998, February 18,1998, March 19 and 25,1998, and April 16,1998; and your telephone conversation with Mr. C.
Anderson, Branch Chief, on January 5,1998, during which you requested the status of our review of your concerns.
In response to concern #1, our inspections have found that you were correct in saying that additional alarm tests (other than those associated with the E emergency ciesel generator) were not performed in 1996. Our review of computer records for the alarm tests you specified found that the radwaste panel alarm test was not consistently performed between January and July 1996. Whereas there was no computer data which would indicate whether specific main control room annunciators alarm tests were, or were not, performed, performance problems were identified regarding the main control room annunciator alarm test. The NRC viewed the inconsistent radwaste alarm testing and performance problems regarding the main control room annunciator test to be further evidence of the personnel performance and management oversight problems identified in the escalated enforcement action issued on June 20,1997. Because these past problems provided no new information regarding the licensee's performance, and because the identified performance problems were being adequately addressed, a non-cited violation was determined to be the appropriate regulatory action.
CfATIFIED MAIL RETURN RECElPT REQUESTED 9902080018 990129 i
SORENSEN99-36 PDR T? ECON #$
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During review of computer records associated with these alarms, some deficiencies were i
identified. However, the NRC found that PP&L accounted for the computer data
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deficiencies and reached reasonable conclusions regarding the validity of the data.
Computer records for the ESS transformer tests indicated the required tests were routinely performed.
l The NRC reviewed four PP&L corporate audits, an assessment by the Independent Safety Engineering Group, and a Nuclear Assessment Services audit associated with operator performance. PP&L's overall conclusions and corrective actions to improve operator performance, management oversight, and independent assessment were found to be acceptable. We have documented our inspection findings and conclusions in NRC inspection Reports 50-387&388/97-09,50-387&388/97-10, and 50-387&388/98-01. A copy of the relevant sections from each report is enclosed.
in response to concern #2, our review indicated that there was no data to indicate that i
personnel performance issues concerning panel testing, other than at the E diesel alarm panel, were known to PP&L management at the time of the March 21,1997 meeting. Our review indicated that PP&L management became aware of performance problems regarding alarm panel testing in the main control room and the radwaste control room subsequent to April 9,1997.
Should you have any additional questions, or if I can be of further assistance in this matter, please call me via the NRC Safety Hotline at 1-800-695-7403.
Sincerely, J
David J. Vito Senior Allegation Coordinator
Enclosures:
As stated l
TELEPHONE CONVERSATION Dsta: 1/15/98 Time:
RECORD File No.: RI-97-A-0145 Licensee: Susquehanna q
Person Calling: the vocal alleger Telephone No.-
Person Called: Kathleen Modes (610) 337-5251
Subject:
Telecon Summary: Alleger asked where his letter was. I informed alleger that we are' busy and that we are drafting a letter.
Alleger said that his arbitration started this week and that at first there were going to be no deals, but later said that PP&L are dealing with 3 of the 7 individuals. Alleger explained that the arbitration is "not talking, its's a battle."
Alleger said that they were supposedly fired under the responsible behavior program and that this deals with the union contract. The alleger said that PP&L is contending Responsible Behavior problems and not looking at the overall year (s).
The alleger contends that PP&L used the NRC to break the union.
Alleger said he was the person who told PP&L how to obtain and analyze the computer data for the missed alarms. He said it wa's getting data by exception.
Alleger said that he heard that interviewers are questioning employees with the following question: "Now that we have computer data, do you want to change your previous story't" Action Required /Taken: Place in fi(e Signature: [ M.MgM-Date: 1/15/98 b
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}ll TELEPHONE CONVERSATION Date: 3/25/98 Time: 4:15 PM RECORD File No.: RI-97-A-0145 Licensee: Susquehanna Person Calling: the vocal alleger Telephone No.-
Person Called: Kathleen Modes (610) 337-5251
Subject:
Telecon Summary: 1 informed the individual that decommissioning (financial assurance) can be found in 10 CFR 50.75. I tried to explain to the individual how this came to be (i.e., the NRC was concerned with NRC-licensees going bankrupt and the cost of decommissioning being forced upon the public)....so this regulation came into effect. The individual said it should go to DOE. I told the individual that the earnest Iles with the licensee...if they want to be licensed they need this assurance mechanism. The individual tried to go into plant life expectancy and types of financial assurance. Then he said that I answered his question.
Then the individual asked where his letter was. I informed alleger that we ara
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working on getting the inspection Report issued, there has been a glitch, we are trying to resolve it, and will get him a letter.
I informed the individual that I was very busy and asked if he had any other questions...he said no. The call ended.
Action RequirsidWp4syg.Jg. file Signaturehg/gg h
Date: 3/25/98
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KING of PRUSSIA. PENNSYLVANIA 19406 1415 April 16, 1998 RI-97-A-0145
SUBJECT:
CONCERNS YOU RAISED TO THE NRC REGARDING PENNSYLVANIA POWER
& LIGHT'S (PP&L) SUSQUEHANNA FACILITY Dea The NRC Region i offica has completed its follow-up in response to the concerns you brought to our attention in your telephone conversation with Mr. Brad Fewell, Regional Counsel, on June 20,1997. Specifically, you indicated that (1) there were alarm tests (i.e., the ESS transfer alarm test, the OC 322 panel alarm test for radwaste, and the control room panel
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alarm test) that were not performed; and (2) if PP&L management asserted, during the NRC enforcement conference on March 21, 1997, that the failures on the "E" diesel alarm test were isolated, they made a misrepresentation to the NRC because PP&L management (i.e.,
Kevin Chambliss, Jon Edwards, Tom Markowski, Mike Peal, and G. Kuczynski) knew these other alarm tests were not being performed and did not do anything to ensure they would be performed.
This also refers to your telephone conversation with Mr. Brian McDermott, an NRC resident inspector at Susquehanna, on June 23,1997, in which you provided information related to the other missed tests to the NRC; and your telephone conversation with Mr. D. Nelson, NRC Office of Enforcement, on October 3,1997, in which you indicated that in PP&L's letter dated April 9,1997, to the NRC, PP&L did not divulge other missed alarm tests (i.e., four ESS transformers, off-gas system for the radwaste control panel, and the Main Control Room annunciator alarm test).
In response to concern #1, our inspections have found that you were correct in saying that additional alarm tests (other than these associated with the E emergency diesel generator) were not performed in 1996. Our review of computer records for the alarm tests you specified found that the radwaste panel alarm test was not consistently performed between January and July 1996. Whereas there was no computer data which would indicate whether specific main control room annunciators alarm tests were, or were not, performed, performance problems were identified regarding the main control room annunciator alarm test. The NRC viewed the inconsistent radwaste alarm testing and performance problems regarding the main control room annunciator test to be further evidence of the personnel performance and management oversight problems identified in the escalated enforcement action issued on June 20,1997.
Because these past problems provided no new information regarding the licensee's performance, and because the identified performance problems were being adequately addressed, a non-cited violation was determined to be the appropriate regulatory action.
CERTIFIED Mall RETURN RECEIPT REQUESTED xA
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'During review of computer records associated with these alarms, some deficiencies were identified. However, the NRC found that PP&L accounted for the computer data deficiencies i
and reached reasonable conclusions regarding the validity of the data. Computer. records for the ESS transformer tests indicated the required tests were routinely performed.
The NRC reviewed four PP&L corporate audits, an assessment by the Independent Safety Engineering Group, and a Nuclear Assessment Services audit associated with operator performance.
PP&L's overall conclusions and corrective actions to improve operator performance, management oversight, and independent assessment were found to be acceptable. We have documented our inspection findings and conclusions in NRC Inspection Reports 50-387&388/97-09, 50-387&388/97-10, and 50-387&388/98-01. A copy of the relevant sections from each report is enclosed.
In response to concern #2, our review indicated that there was no data to indicate that personnel poibTdsrice issues concoming panel testing, other than at the E diesel alarm panel, were known to PP&L management at the time of the March 21,1997, meeting. Our review indicated that PP&L management became aware of performance problems regarding alarm panel testing in the main control room and the radwaste control room subsequent to April 9, 1997.
Should you have any additional questions, or if I can be of further assistance in this matter, please call me via the NRC Safety Hotline at 1-800-695-7403.
Sincerely,'
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David J. Vito Senior Allegation Coordinator
Enclosures:
As stated i
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