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Category:Letter type:PLA
MONTHYEARPLA-8096, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2024-01-0404 January 2024 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8077, Emergency Plan Revision 67 (PLA-8077)2023-12-27027 December 2023 Emergency Plan Revision 67 (PLA-8077) PLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8084, Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.22023-11-29029 November 2023 Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2 PLA-8091, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091)2023-11-0808 November 2023 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091) PLA-8082, Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2023-11-0202 November 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program PLA-8080, Proposed Relief for Valve 251130 (PLA-8080)2023-08-14014 August 2023 Proposed Relief for Valve 251130 (PLA-8080) PLA-8074, Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2023-08-0303 August 2023 Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8076, Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076)2023-07-20020 July 2023 Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076) PLA-8078, Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-80782023-07-0505 July 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-8078 PLA-8054, Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence2023-06-0808 June 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence PLA-8073, Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval2023-06-0101 June 2023 Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval PLA-8064, Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064)2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064) PLA-8067, Notification of Completion of Emergence from Bankruptcy (PLA-8067)2023-05-17017 May 2023 Notification of Completion of Emergence from Bankruptcy (PLA-8067) PLA-8066, Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-80662023-05-0808 May 2023 Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-8066 PLA-8053, Radiation Exposure Information and Reporting System2023-04-27027 April 2023 Radiation Exposure Information and Reporting System PLA-8058, Annual Radiological Environmental Operating Report (PLA-8058)2023-04-26026 April 2023 Annual Radiological Environmental Operating Report (PLA-8058) PLA-8041, Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041)2023-04-25025 April 2023 Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041) PLA-8047, 2022 Annual Environmental Operating Report (Nonradiological), PLA-80472023-04-19019 April 2023 2022 Annual Environmental Operating Report (Nonradiological), PLA-8047 PLA-8062, Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-80622023-04-11011 April 2023 Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-8062 PLA-8061, Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-80612023-04-10010 April 2023 Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-8061 PLA-8060, Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060)2023-03-30030 March 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060) PLA-8057, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-80572023-03-15015 March 2023 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-8057 PLA-8052, (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums2023-02-13013 February 2023 (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums PLA-8048, Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence2023-01-14014 January 2023 Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence PLA-8042, Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence2023-01-10010 January 2023 Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence PLA-8039, Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information2022-12-22022 December 2022 Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information PLA-8038, Notification of Petition for Bankruptcy (PLA-8038)2022-12-14014 December 2022 Notification of Petition for Bankruptcy (PLA-8038) PLA-8036, Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-80362022-11-30030 November 2022 Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-8036 PLA-8035, Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-80352022-11-0808 November 2022 Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-8035 PLA-8031, Emergency Plan Revision 66 (PLA-8031)2022-11-0707 November 2022 Emergency Plan Revision 66 (PLA-8031) PLA-8032, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032)2022-10-28028 October 2022 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032) PLA-8026, Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026)2022-10-19019 October 2022 Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026) PLA-8015, Application for Order Approving Indirect Transfer of Control of Licenses2022-09-29029 September 2022 Application for Order Approving Indirect Transfer of Control of Licenses PLA-8030, Evacuation Time Estimate Report PLA-80302022-09-15015 September 2022 Evacuation Time Estimate Report PLA-8030 PLA-8025, Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value2022-08-10010 August 2022 Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value PLA-8019, Nd Refueling Outage Owner'S Activity Report, PLA-80192022-07-13013 July 2022 Nd Refueling Outage Owner'S Activity Report, PLA-8019 PLA-8013, Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-80132022-06-27027 June 2022 Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-8013 PLA-8012, 10 CFR 50.46 Annual Report2022-06-10010 June 2022 10 CFR 50.46 Annual Report PLA-8005, Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005)2022-05-23023 May 2022 Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005) PLA-8001, Radiation Exposure Information and Reporting System - PLA-80012022-04-28028 April 2022 Radiation Exposure Information and Reporting System - PLA-8001 PLA-7986, 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-79862022-04-26026 April 2022 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-7986 PLA-7987, Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987)2022-04-26026 April 2022 Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987) PLA-7985, Annual Radiological Environmental Operating Report2022-04-22022 April 2022 Annual Radiological Environmental Operating Report PLA-7883, Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883)2022-03-31031 March 2022 Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883) PLA-7995, Property Insurance Program (PLA-7995)2022-03-30030 March 2022 Property Insurance Program (PLA-7995) PLA-7998, Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report2022-03-29029 March 2022 Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report PLA-7991, Proof of Financial Protection and Guarantee of Payment of Deferred Premium2022-03-24024 March 2022 Proof of Financial Protection and Guarantee of Payment of Deferred Premium PLA-7984, Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 22022-03-0808 March 2022 Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-7962, Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-79622022-01-0505 January 2022 Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-7962 2024-01-04
[Table view] Category:Notice of Violation
MONTHYEARIA-20-025, NRC Office of Investigation Report 1-2019-013 and Notice of Violation2020-03-12012 March 2020 IA-20-025 NRC Office of Investigation Report 1-2019-013 and Notice of Violation ML15173A2972015-06-22022 June 2015 EA-15-022 Susquehanna Final Significance Determination for a White Finding with Assessment Follow-up and Notice of Violation (Inspection Report No. 05000387/2015504 and 05000388/2015504) IR 05000387/20140092014-08-0101 August 2014 IR 05000387-14-009 and 05000388-14-009, and Notice of Violation, June 2-6, 2014 and June 16-20, 2014, Susquehanna Steam Electric Station, NRC Problem Identification and Resolution IR 05000387/20130132013-09-25025 September 2013 NRC Investigation Reports 1-2012-012, 1-2012-043, 1-2011-030, and NRC Inspection Report 05000387-13-013 & 05000388-13-013; and Notice of Violation IR 05000387/20130122013-08-28028 August 2013 NRC Inspection Report 05000387/2013012 and 05000388/2013012; and Notice of Violation ML1200603002012-01-0606 January 2012 IA-11-055 G. Rinehart, Notice of Violation (NRC Office of Investigation Report No. 1-2010-055) PLA-6791, Reply to Notice of Violation, EA-11-244, PLA-67912011-12-0808 December 2011 Reply to Notice of Violation, EA-11-244, PLA-6791 IR 05000387/20110042011-11-0808 November 2011 IR 05000387-11-004, 05000388-11-004; on 07-01-11 - 9-30-11; Susquehanna Steam Electric Station - NRC Integrated Inspection Report and Notice of Violation IR 05000387/20090042010-01-28028 January 2010 EA-09-248, Susquehanna, Notice of Violation (NRC Inspection Report Nos. 05000387/2009004 and 05000388/2009004) 2020-03-12
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Faber A. Kearney PPL Susquehanna, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 DEC 0 8 2011 Tel. 570.542.2904 Fax 570.542.1504 fakearney@pplweb.com U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REPLY TO A NOTICE OF VIOLATION; EA-11-244 Docket Nos. 50-387 PLA-6791 and 50-388
Reference:
I) Letter from NRC (P. G. Krohn) to PPL (T. S. Rausch), "Susquehanna Steam Electric Station -NRC Integrated Inspection Report 0500038712011004 and 05000388/2011004 and Notice of Violation," dated November 8, 2011.
In accordance with 10 CFR 2.201, PPL Susquehanna, LLC (PPL) hereby submits the Reply to a Notice of Violation EA-11-244 for the Susquehanna Steam Electric Station, Unit 1 and Unit 2.
By letter dated November 8, 2011 (Reference 1), the Nuclear Regulatory Commission (NRC) cited PPL for being in violation of 10 CFR 55.25 "Incapacitation Because of Disability or Illness," for failing to notify the NRC of a known permanent change in medical status of a licensed operator, and 10 CFR 55.3, "License Requirements," for failing to ensure that an individual license holder, in the capacity of a reactor operator, met the medical prerequisites prior to performing licensed operator duties.
PPL accepts the violation. As discussed in the attached Enclosure, PPL has taken prompt action to return to compliance with 10 CFR 55.25 and 10 CFR 55.3.
No regulatory commitments are contained in this letter.
Should you have any questions regarding this submittal, please contact Mr. John Petrilla III, Acting Manager- Nuclear Regulatory Affairs at (570) 542-3796.
Sincerely,
Document Control Desk PLA-6791 Copy: NRC Region I Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. R. R. Janati, DEP/BRP Mr. B. K. Vaidya, NRC Project Manager
Enclosure to PLA-6791 Page 1 of4 Enclosure PPL Susquehanna, LLC Reply to Notice of Violation EA-11-244 Restatement of the Violation During an NRC inspection conducted during the third quarter of 2011, a violation of NRC requirements was identified. Below is a description of the violation.
10 CFR 55.3, states that a person must be authorized by a license issued by the Commission to perform the functions of an operator or senior operator as defined in this part.
10 CFR 55.21 requires, in part, that a licensee shall have a medical examination by a physician every two years. The physician shall determine that the applicant or licensee meets the requirements of 10 CFR 55.33(a)(1). 10 CFR 55.33(a)(1) states, in part, that the applicant's medical condition and general health will not adversely affect the performance of assigned job duties or cause operational errors endangering public health and safety. 10 CFR 55.33(b) states, in part, if an applicant's general medical condition does not meet the minimum standards under 10 CFR 55.33(a)(l) the Commission may approve the application and include conditions in the license to accommodate the medical defect.
10 CFR 55.23 requires, in part, that to certify the medical fitness of the applicant, an authorized representative of the facility licensee shall complete and sign NRC Form 396. On the Form 396, PPL certified that it used the guidance in ANSI!ANS 3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants."
10 CFR 55.23(b) states that when the certification requests a conditional license based on medical evidence, the medical evidence must be submitted on NRC Form 396 to the Commission and the Commission then makes a determination in accordance with 10 CFR 55.33.
ANSIIANS 3.4-1983, section 3 states, in part, that the primary responsibility for assuring that qualified personnel are on duty rests with the facility operator. The health requirements set forth herein are considered the minimum necessary to determine that the physical condition and general health of the individual are not such as might cause operational errors endangering public health and safety. The specific health requirements and disqualifying conditions are described in
Enclosure to PLA-6791 Page 2 of4 Section 5.3, "Disqualifying Conditions," and Section 5.4, "Specific Minimum Capacities Required for Medical Qualification," of the ANSI standard.
10 CPR 55.25 states, in part, that if during the term of the license, the licensee develops a permanent physical or mental condition that causes the licensee to fail to meet the requirements of 10 CFR 55.21, the facility licensee shall notify the Commission, within 30 days of learning of the diagnosis. For conditions for which a conditional license (as described in 10 CPR 55 .33(b) of this part) is requested, the facility licensee shall provide medical certification on Form NRC 396 to the Commission.
Contrary to the above, PPL failed to notify the NRC within 30 days of a known permanent change in medical condition of a licensed operator and ensure that an individual license holder, in the capacity of an RO, met the conditions of his license prior to performing licensed operator duties. Specifically, biennial medical examinations conducted on April16, 2009 and April19, 2011 identified that an RO did not meet the health requirements stated in ANSI!ANS 3.4-1983, Section 5.4.5, "Eyes." Despite medical reviews on May 12, 2009 and May 9, 2011, PPL did not report this change in permanent medical condition to the NRC within 30 days nor did PPL request an amended license with a condition requiring corrective lenses until identified by the NRC during a review of the RO's license renewal application package submitted to the NRC on August 9, 2011. This resulted in the RO performing licensed operator duties from April2009 through August 2011 without a properly restricted license. It was noted that the RO had worn his corrective lenses since his medical examination in April2009.
This is an example of a Severity Level IV violation (Enforcement Policy Section 6.4).
Reason for Violation The failure to notify the NRC within 30 days of a known permanent change in medical condition of a licensed operator was documented in Condition Report (CR) 1450138.
The apparent cause evaluation for CR 1450138 identified the cause of the violation as inadequate process/procedures for implementation of the licensed operator medical examination program. Specifically, the process is fragmented and lacks suf~icient levels of review. This conclusion is based on the following:
- Training procedure NTP-QA-31.12, "Preparation and Submission of NRC Form 396 - Certification of Medical Examination by Facility Licensee and NRC Form 398 - Personal Qualifications Statement - Licensee," does not prescribe the
Enclosure to PLA-6791 Page 3 of 4 necessary actions to ensure that all operator license conditions/restrictions are properly identified and submitted to the NRC on NRC Form 396.
- Procedure NTP-QA-31.12 does not require a review of the operator's medical examination results against the current license to identify if a change to the operators license is required to be submitted on NRC.
- The Operations or Training departments are not required to review the Medical Review Officer's letter from the SSES Senior Staff Specialist- Health Services to determine if an NRC form 396 is required to be submitted.
- The preparation of an NRC Form 396 does not require a sufficient level of review to ensure accuracy.
Corrective Steps Taken and Results Achieved PPL completed a review (under Corrective Action 1462949) of medical records for all licensed operators to verify that all applicable medical conditions/restrictions identified since early 2008 were reported to the NRC on NRC Form 396. No discrepancies were found.
Date When Full Compliance Will Be Achieved PPL is in full compliance with the requirements of 10 CFR 55.25 and 10 CFR 55.3. On August 19, 2011, a revised NRC Form 396 was submitted to the NRC identifying the operator's visual acuity requiring "Corrective lenses must be worn when performing licensed duties" as a change in the operator's license conditions/restrictions.
Corrective Steps That Will Be Taken to A void Future Violations The following action from CR 1450138 was developed as part of the apparent cause evaluation:
- Develop a site level administrative procedure for implementation of the licensed operator medical examination process. The procedure shall include all of the medical requirements for licensed operators, including the applicable requirements from 10 CFR 55, NUREG-1021 Rev. 9, Supplement 1, "Operator Licensing Examination Standards for Power Reactors," ANSIIANS 3.4, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants," and Regulatory Guide 1.134, "Medical Evaluation of Licensed Personnel at Nuclear Power Plants." This procedure will replace the medical examination sections ofNTP-QA-31.12 and incorporate all of procedure OP-AD-010.
Enclosure to PLA-6791 Page4 of4 The new procedure will include the following:
- The operator medical examination process and responsibilities for implementation, tracking and reporting required information to the NRC in accordance with NRC Form 396.
- Require each licensed operator to acknowledge all license conditions/restrictions based on the current physical examination results.
- Require that the Operations Training Coordinator maintain a file of all the required forms needed to keep the process efficient.
- Include record retention requirements for SSES operator's licenses in the procedure.
- Include a requirement that when errors are identified that are related to processing operator medical examinations and/or NRC Form 396 reviews, the condition will be entered into SSES's corrective action program.
Why Corrective Steps for EA-09-248 Were Not Effective in Identifying This Issue Earlier The extent of condition performed under CR 1199349 for EA-09-248 was inadequate because it was limited to a CAP database search. An appropriate extent of condition should have included a review (since 2008) of medical records for all licensed operators to verify that all applicable conditions/restrictions were correctly reported to the NRC on NRC Form 396. This review would have possibly identified the performance deficiency documented in Notice of Violation EA-11-244.