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==SUBJECT:==
==SUBJECT:==
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - TEMPORARY INSTRUCTION 251 5/191 INSPECTION REPORT 05000387/2019010 AND 05000388/2019010
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -
TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000387/2019010 AND 05000388/2019010


==Dear Mr. Berryman:==
==Dear Mr. Berryman:==
On June 28, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station, Units 1 a nd 2. On July 25, 2019, the NRC inspectors discussed the results of this inspection with Mr. Kevin Cimorelli, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
On June 28, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station, Units 1 and 2. On July 25, 2019, the NRC inspectors discussed the results of this inspection with Mr. Kevin Cimorelli, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.


The NRC inspectors did not identify any finding or violation of more than minor significance.
The NRC inspectors did not identify any finding or violation of more than minor significance.


This letter, its enclosure, and your response (if any) will be made available for public inspection  
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
 
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."


Sincerely,
Sincerely,
/RA/ Matthew R. Young, Chief Technical Support and Administrative Team  
/RA/
 
Matthew R. Young, Chief Technical Support and Administrative Team Division of Reactor Projects Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF-22
Division of Reactor Projects  
 
Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF-22  


===Enclosure:===
===Enclosure:===
As stated  
As stated


==Inspection Report==
==Inspection Report==
 
Docket Numbers: 05000387 and 05000388 License Numbers: NPF-14 and NPF-22 Report Numbers: 05000387/2019010 and 05000388/2019010 Enterprise Identifier: I-2019-010-0021 Licensee: Susquehanna Nuclear, LLC Facility: Susquehanna Steam Electric Station Location: Berwick, PA Inspection Dates: June 24, 2019 to June 28, 2019 Inspectors: A. Siwy, Resident Inspector (Team Lead)
Docket Numbers: 05000387 and 05000388  
F. Arner, Senior Reactor Analyst P. Presby, Senior Operations Engineer Approved By: Matthew R. Young, Chief Technical Support and Administrative Team Division of Reactor Projects Enclosure
 
License Numbers: NPF-14 and NPF-22  
 
Report Numbers: 05000387/2019010 and 05000388/2019010  
 
Enterprise Identifier: I-2019-010-0021  
 
Licensee: Susquehanna Nuclear, LLC  
 
Facility: Susquehanna Steam Electric Station  
 
Location: Berwick, PA  
 
Inspection Dates: June 24, 2019 to June 28, 2019  
 
Inspectors: A. Siwy, Resident Inspector (Team Lead)
F. Arner, Senior Reactor Analyst P. Presby, Senior Operations Engineer  
 
Approved By: Matthew R. Young, Chief Technical Support and Administrative Team  
 
Division of Reactor Projects  
 
2


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting a Temporary Instruction (TI) 2515/191 inspection at Susquehanna Steam Electric Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The  
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Temporary Instruction (TI) 2515/191 inspection at Susquehanna Steam Electric Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
 
Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.


List of Findings and Violations No findings or violations of more than minor significance were identified.
List of Findings and Violations No findings or violations of more than minor significance were identified.


Additional Tracking Items None.
Additional Tracking Items None.
3


=INSPECTION SCOPES=
=INSPECTION SCOPES=


===Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light-Water Reactor Inspection Program - Operations Phase.The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL  
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 2515/191 - Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & Emergency
 
2515/191 - Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & Emergency Preparedness Info Request March 12, 2012 (1 Sample)===
: (1) The inspectors verified plans for complying with NRC Orders EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (A DAMS Accession No. ML12056A045) and EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee.


Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS Accession No. ML12053A340) and multi-unit dose assessment information provided per COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013 (ADAMS Accession No. ML12339A262).
===Preparedness Info Request March 12, 2012 (1 Sample)===
: (1) The inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee.


1. Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML18284A455) and determined that the licensee is in compliance with NRC Order EA-12-049, "Order Modifying Licenses with R egard to Requirements for Mitigation Strategies for Beyond-Design-Basis Exte rnal Events."  The inspectors verified the licensee satisfactorily:
Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS Accession No. ML12053A340) and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).


a. Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b. Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c. Protected FLEX equipment from site-specific hazards; d. Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e. Trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and 4 f. Developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.
1. Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML18284A455) and determined that the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The inspectors verified the licensee satisfactorily:
a. Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b. Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c. Protected FLEX equipment from site-specific hazards; d. Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e. Trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f. Developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.


2. Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is in compliance with NRC Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.The inspectors verified the licensee satisfactorily:
2. Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is in compliance with NRC Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation. The inspectors verified the licensee satisfactorily:
a. Installed the spent fuel pool (SFP) instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b. Installed the SFP instrumentation display in the location, environmental conditions, and accessibility as described in the plant specific submittals; c. Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d. Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.
a. Installed the spent fuel pool (SFP) instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b. Installed the SFP instrumentation display in the location, environmental conditions, and accessibility as described in the plant specific submittals; c. Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d. Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.


3. The inspectors reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter, and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all AC power to all site units and impedes access to the site. The inspectors verified the following:  
3. The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter, and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all AC power to all site units and impedes access to the site. The inspectors verified the following:
 
a. The licensee satisfactorily implemented required staffing changes to support a multi-unit extended loss of AC power (ELAP) scenario; b. Emergency preparedness communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and c. The licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensees site-specific dose assessment software and approach.
a. The licensee satisfactorily implemented required staffing changes to support a multi-unit extended loss of AC power (ELAP) scenario; b. Emergency preparedness communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and c. The licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensee's site-specific dose assessment software and approach.


The inspectors verified that non-compliances with requirements, and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.
The inspectors verified that non-compliances with requirements, and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.
Line 113: Line 80:
The inspectors verified no proprietary information was retained or documented in this report.
The inspectors verified no proprietary information was retained or documented in this report.


On July 25, 2019, the inspectors presented the TI 2515/191 results to Mr. Kevin Cimorelli, Site Vice President, and other members of the licensee staff. On June 28, 2019, the inspectors presented the Debrief to Mr. Brad Berryman, Chief Nuclear Officer, and other members of the licensee staff.
On July 25, 2019, the inspectors presented the TI 2515/191 results to Mr. Kevin Cimorelli, Site Vice President, and other members of the licensee staff.


6
On June 28, 2019, the inspectors presented the Debrief to Mr. Brad Berryman, Chief Nuclear Officer, and other members of the licensee staff.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection
Inspection Type             Designation   Description or Title                                         Revision or
Procedure Type Designation Description or Title Revision or
Procedure                                                                                                Date
Date 2515/191 Calculations EC-FLEX-0023 Portable Diesel Generator (0G505 - 0G510) Fuel Oil Temperature Response
2515/191   Calculations     EC-FLEX-0023   Portable Diesel Generator (0G505 - 0G510) Fuel Oil           0
Corrective Action Documents
Temperature Response
Resulting from Inspection AR-2019-08567, AR-2019-08659,
Corrective Action AR-2019-08567,
CR-2019-08073, CR-2019-08457, CR-2019-08463,
Documents        AR-2019-08659,
Resulting from    CR-2019-08073,
Inspection        CR-2019-08457,
CR-2019-08463,
CR-2019-08482,
CR-2019-08482,
CR-2019-08490,
CR-2019-08490,
CR-2019-08516, CR-2019-08518, CR-2019-08575,
CR-2019-08516,
CR-2019-08518,
CR-2019-08575,
CR-2019-08621,
CR-2019-08621,
CR-2019-08631,
CR-2019-08631,
CR-2019-08635, CR-2019-09449
CR-2019-08635,
Miscellaneous MBDBE Program
CR-2019-09449
Document EP-
Miscellaneous     MBDBE Program Diverse and Flexible Coping Strategies (FLEX), Hardened     2
1101 Diverse and Flexible Coping Strategies (FLEX), Hardened Containment Vent System (HCVS), and Spent Fuel Pool Instrumentation (SFPI) Program Document - Susquehanna
Document EP-  Containment Vent System (HCVS), and Spent Fuel Pool
SES 2 ML18284A455 Susquehanna Steam Electric Station, Units 1 and 2 - Safety Evaluation Regarding Implementation of Mitigation Strategies
1101          Instrumentation (SFPI) Program Document - Susquehanna
SES
ML18284A455   Susquehanna Steam Electric Station, Units 1 and 2 - Safety   11/07/2018
Evaluation Regarding Implementation of Mitigation Strategies
and Reliable Spent Fuel Pool Instrumentation Related to
and Reliable Spent Fuel Pool Instrumentation Related to
Orders EA-12-049 and EA-12-051 (CAC NO
Orders EA-12-049 and EA-12-051 (CAC NO
: [[contact::S. MF0888]], MF0889, MF0890, and MF0891; EPID NOS. L-2013-JLD-
: [[contact::S. MF0888]],
MF0889, MF0890, and MF0891; EPID NOS. L-2013-JLD-
21 and L-2013-JLD-0022)
21 and L-2013-JLD-0022)
11/07/2018 PLA-7710 Susquehanna Seam Electric Station Report of Full
PLA-7710       Susquehanna Seam Electric Station Report of Full             06/26/2018
Compliance with March 12, 2012 Commission Order
Compliance with March 12, 2012 Commission Order
Modifying Licenses with Regard to Requirements for
Modifying Licenses with Regard to Requirements for
Mitigation Strategies for Beyond-Design-Basis External
Mitigation Strategies for Beyond-Design-Basis External
Events (NRC Order EA-12-049)
Events (NRC Order EA-12-049)
06/26/2018 Sample No. Laboratory Report 10/19/2018
Sample No. Laboratory Report                                           10/19/2018
Inspection
Inspection Type       Designation Description or Title                                         Revision or
Procedure Type Designation Description or Title Revision or
Procedure                                                                                        Date
Date 2018006423
2018006423
Sample No.
Sample No. Laboratory Report                                             11/27/2018
2018006961 Laboratory Report 11/27/2018
2018006961
Sample No.
Sample No. Laboratory Report                                             12/21/2018
2018007555 Laboratory Report 12/21/2018
2018007555
Sample No.
Sample No. Laboratory Report                                             01/31/2019
2019000496 Laboratory Report 01/31/2019
2019000496
Sample No.
Sample No. Laboratory Report                                             03/12/2019
2019001536 Laboratory Report 03/12/2019
2019001536
Sample No.
Sample No. Laboratory Report                                             04/03/2019
2019001773 Laboratory Report 04/03/2019
2019001773
Sample No.
Sample No. Laboratory Report                                             05/03/2019
2019002264 Laboratory Report 05/03/2019
2019002264
Sample No.
Sample No. Laboratory Report                                             05/17/2019
2019002572 Laboratory Report 05/17/2019
2019002572
Sample No.
Sample No. Laboratory Report                                             06/06/2019
2019003090 Laboratory Report 06/06/2019
2019003090
Sample No.
Sample No. Laboratory Report                                             06/21/2019
2019003279 Laboratory Report 06/21/2019 TI-2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency
2019003279
TI-2515/191 Inspection of the Implementation of Mitigation Strategies and 2
Spent Fuel Pool Instrumentation Orders and Emergency
Preparedness Communication/Staffing/Multi-Unit Dose
Preparedness Communication/Staffing/Multi-Unit Dose
Assessment Plans
Assessment Plans
Work Orders 2209661 Perform Monthly PM checks on 0P911 and 0P912 06/13/2019
Work Orders 2209661     Perform Monthly PM checks on 0P911 and 0P912                 06/13/2019
7
}}
}}

Latest revision as of 02:02, 2 November 2019

Temporary Instruction 2515/191 Inspection Report 05000387/2019010 and 05000388/2019010
ML19219A244
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 08/06/2019
From: Matt Young
NRC/RGN-I/DRP/PB7
To: Berryman B
Susquehanna
Young M
References
IR 2019010
Download: ML19219A244 (9)


Text

ust 6, 2019

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -

TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000387/2019010 AND 05000388/2019010

Dear Mr. Berryman:

On June 28, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station, Units 1 and 2. On July 25, 2019, the NRC inspectors discussed the results of this inspection with Mr. Kevin Cimorelli, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Matthew R. Young, Chief Technical Support and Administrative Team Division of Reactor Projects Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF-22

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000387 and 05000388 License Numbers: NPF-14 and NPF-22 Report Numbers: 05000387/2019010 and 05000388/2019010 Enterprise Identifier: I-2019-010-0021 Licensee: Susquehanna Nuclear, LLC Facility: Susquehanna Steam Electric Station Location: Berwick, PA Inspection Dates: June 24, 2019 to June 28, 2019 Inspectors: A. Siwy, Resident Inspector (Team Lead)

F. Arner, Senior Reactor Analyst P. Presby, Senior Operations Engineer Approved By: Matthew R. Young, Chief Technical Support and Administrative Team Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Temporary Instruction (TI) 2515/191 inspection at Susquehanna Steam Electric Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 2515/191 - Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & Emergency

Preparedness Info Request March 12, 2012 (1 Sample)

(1) The inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee.

Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS Accession No. ML12053A340) and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).

1. Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML18284A455) and determined that the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The inspectors verified the licensee satisfactorily:

a. Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b. Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c. Protected FLEX equipment from site-specific hazards; d. Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e. Trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f. Developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.

2. Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is in compliance with NRC Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation. The inspectors verified the licensee satisfactorily:

a. Installed the spent fuel pool (SFP) instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b. Installed the SFP instrumentation display in the location, environmental conditions, and accessibility as described in the plant specific submittals; c. Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d. Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.

3. The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter, and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all AC power to all site units and impedes access to the site. The inspectors verified the following:

a. The licensee satisfactorily implemented required staffing changes to support a multi-unit extended loss of AC power (ELAP) scenario; b. Emergency preparedness communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and c. The licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensees site-specific dose assessment software and approach.

The inspectors verified that non-compliances with requirements, and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.

This TI is considered closed.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On July 25, 2019, the inspectors presented the TI 2515/191 results to Mr. Kevin Cimorelli, Site Vice President, and other members of the licensee staff.

On June 28, 2019, the inspectors presented the Debrief to Mr. Brad Berryman, Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/191 Calculations EC-FLEX-0023 Portable Diesel Generator (0G505 - 0G510) Fuel Oil 0

Temperature Response

Corrective Action AR-2019-08567,

Documents AR-2019-08659,

Resulting from CR-2019-08073,

Inspection CR-2019-08457,

CR-2019-08463,

CR-2019-08482,

CR-2019-08490,

CR-2019-08516,

CR-2019-08518,

CR-2019-08575,

CR-2019-08621,

CR-2019-08631,

CR-2019-08635,

CR-2019-09449

Miscellaneous MBDBE Program Diverse and Flexible Coping Strategies (FLEX), Hardened 2

Document EP- Containment Vent System (HCVS), and Spent Fuel Pool

1101 Instrumentation (SFPI) Program Document - Susquehanna

SES

ML18284A455 Susquehanna Steam Electric Station, Units 1 and 2 - Safety 11/07/2018

Evaluation Regarding Implementation of Mitigation Strategies

and Reliable Spent Fuel Pool Instrumentation Related to

Orders EA-12-049 and EA-12-051 (CAC NO

S. MF0888,

MF0889, MF0890, and MF0891; EPID NOS. L-2013-JLD-

21 and L-2013-JLD-0022)

PLA-7710 Susquehanna Seam Electric Station Report of Full 06/26/2018

Compliance with March 12, 2012 Commission Order

Modifying Licenses with Regard to Requirements for

Mitigation Strategies for Beyond-Design-Basis External

Events (NRC Order EA-12-049)

Sample No. Laboratory Report 10/19/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

2018006423

Sample No. Laboratory Report 11/27/2018

2018006961

Sample No. Laboratory Report 12/21/2018

2018007555

Sample No. Laboratory Report 01/31/2019

2019000496

Sample No. Laboratory Report 03/12/2019

2019001536

Sample No. Laboratory Report 04/03/2019

2019001773

Sample No. Laboratory Report 05/03/2019

2019002264

Sample No. Laboratory Report 05/17/2019

2019002572

Sample No. Laboratory Report 06/06/2019

2019003090

Sample No. Laboratory Report 06/21/2019

2019003279

TI-2515/191 Inspection of the Implementation of Mitigation Strategies and 2

Spent Fuel Pool Instrumentation Orders and Emergency

Preparedness Communication/Staffing/Multi-Unit Dose

Assessment Plans

Work Orders 2209661 Perform Monthly PM checks on 0P911 and 0P912 06/13/2019

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