IR 05000387/2024002: Difference between revisions

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One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.


A licensee- identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a an NCV consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a an NCV consistent with Section 2.3.2 of the Enforcement Policy.


If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555- 0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2.
Document Control Desk, Washington, DC 20555- 0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2.


If you disagree with a cross -cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 -0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
If you disagree with a cross -cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 -0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely, Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety
Sincerely, Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety


Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF- 22
Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF-22


===Enclosure:===
===Enclosure:===
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Docket Numbers: 05000387 and 05000388
Docket Numbers: 05000387 and 05000388


License Numbers: NPF-14 and NPF- 22
License Numbers: NPF-14 and NPF-22


Report Numbers: 05000387/2024002 and 05000388/2024002
Report Numbers: 05000387/2024002 and 05000388/2024002
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=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Susquehanna Steam Electric Station,
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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. A licensee- identified non- cited violation (NCV) is documented in report section: 71111.2
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. A licensee-identified non-cited violation (NCV) is documented in report section: 71111.2


===List of Findings and Violations===
===List of Findings and Violations===
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=PLANT STATUS=
=PLANT STATUS=


Unit 1 began the inspection period shut down for the U123RIO refueling outage. On April 23, 2024, the unit was started up and achieved rated thermal power on April 29, 2024. On May 9, 2024, the unit was down powered to 59 percent due to 'B' reactor building closed- cooling water chiller shutdown and returned to rated thermal power May 11, 2024. On May 18, 2024, the unit was down powered to 75 percent for control rod exercising and returned to rated thermal power May 19, 2024. On June 29, 2024, the unit was down powered to 68 percent for a rod sequence exchange and returned to rated thermal power June 30, 2024.
Unit 1 began the inspection period shut down for the U123RIO refueling outage. On April 23, 2024, the unit was started up and achieved rated thermal power on April 29, 2024. On May 9, 2024, the unit was down powered to 59 percent due to 'B' reactor building closed-cooling water chiller shutdown and returned to rated thermal power May 11, 2024. On May 18, 2024, the unit was down powered to 75 percent for control rod exercising and returned to rated thermal power May 19, 2024. On June 29, 2024, the unit was down powered to 68 percent for a rod sequence exchange and returned to rated thermal power June 30, 2024.


Unit 2 began the inspection period at rated thermal power.
Unit 2 began the inspection period at rated thermal power.
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==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.
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.
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.
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: (3) Unit Common emergency service water pumphouse, FZs 0-51 and 0-52, on April 22, 2024
: (3) Unit Common emergency service water pumphouse, FZs 0-51 and 0-52, on April 22, 2024
: (4) Unit 2 reactor building, FZs 2-2A, 2-2B, 2-1C, and 2-1D, on May 1, 2024
: (4) Unit 2 reactor building, FZs 2-2A, 2-2B, 2-1C, and 2-1D, on May 1, 2024
: (5) Unit 1 turbine building common generator area, reactor coolant recirculation pump motor generator area and heating and ventilation equipment room, FZs 0-35A, 1- 35C, and 1-36A, on May 23, 2024
: (5) Unit 1 turbine building common generator area, reactor coolant recirculation pump motor generator area and heating and ventilation equipment room, FZs 0-35A, 1-35C, and 1-36A, on May 23, 2024
: (6) Unit Common lower cable spreading room and lower relay room, FZs 0-25A and 0-25E, on June 17, 2024
: (6) Unit Common lower cable spreading room and lower relay room, FZs 0-25A and 0-25E, on June 17, 2024


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{{IP sample|IP=IP 71111.08G|count=1}}
{{IP sample|IP=IP 71111.08G|count=1}}


The inspectors evaluated boiling- water reactor nondestructive testing by reviewing the following examinations from April 1 to 4, 2024:
The inspectors evaluated boiling-water reactor nondestructive testing by reviewing the following examinations from April 1 to 4, 2024:
: (1) Nondestructive Examinations
: (1) Nondestructive Examinations
* Automatic Encoded Phased Array Ultrasonic Examination of the BM Reactor Pressure Vessel Weld (VE-24- 008)
* Automatic Encoded Phased Array Ultrasonic Examination of the BM Reactor Pressure Vessel Weld (VE-24- 008)
* Manual Ultrasonic Examination of Residual Heat Removal Pipe to Elbow Weld DCA1101- FW-5 (UT-24-006)
* Manual Ultrasonic Examination of Residual Heat Removal Pipe to Elbow Weld DCA1101-FW-5 (UT-24-006)
* Ultrasonic Thickness Measurements of Reactor Water Bottom Head Drain -
* Ultrasonic Thickness Measurements of Reactor Water Bottom Head Drain -
90 Degree Elbow (FAC-U1-24- 050)
90 Degree Elbow (FAC-U1-24- 050)
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Expander Inlet (FAC-U1-24- 052)
Expander Inlet (FAC-U1-24- 052)
* Ultrasonic Thickness Measurements of FAC-U1-24-053, Reactor Water Bottom Head Drain - Expander Outlet (FAC-U1-24- 053)
* Ultrasonic Thickness Measurements of FAC-U1-24-053, Reactor Water Bottom Head Drain - Expander Outlet (FAC-U1-24- 053)
* Enhanced Visual Examination (EVT- 1) Top Guide Beam Location 02- 19 (1-B13.40.0409)
* Enhanced Visual Examination (EVT-1) Top Guide Beam Location 02-19 (1-B13.40.0409)
* Dye Penetrant Examination of Feedwater Vent Pipe to Coupling Weld SPDLA103-1 FW-1B (BOP-PT-24-083)
* Dye Penetrant Examination of Feedwater Vent Pipe to Coupling Weld SPDLA103-1 FW-1B (BOP-PT-24-083)
* Manual Ultrasonic Examination of N5A Nozzle to Safe End Dissimilar Metal Weld (UT-24-009)
* Manual Ultrasonic Examination of N5A Nozzle to Safe End Dissimilar Metal Weld (UT-24-009)
* Manual Ultrasonic Examination of High- Pressure Core Injection Steam Line Pipe to Elbow Weld DBA-1021-2- G (UT-24-008)
* Manual Ultrasonic Examination of High-Pressure Core Injection Steam Line Pipe to Elbow Weld DBA-1021-2-G (UT-24-008)
Pressure Boundary Weld
Pressure Boundary Weld
* Cutout and replace feedwater valves 141023B, 141022B (work order (WO) 2686329-2)
* Cutout and replace feedwater valves 141023B, 141022B (work order (WO) 2686329-2)
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The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
: (1) Review of corrective actions associated with the following condition reports (CRs):
: (1) Review of corrective actions associated with the following condition reports (CRs):
: (1) CR-2023- 12632, entered ON-PWR-201 on July 31, 2023;
: (1) CR-2023-12632, entered ON-PWR-201 on July 31, 2023;
: (2) CR-2023- 06833, reactor vessel/cavity level lowering prior to initiating letdown while performing OP-2RF-001 6.16;
: (2) CR-2023- 06833, reactor vessel/cavity level lowering prior to initiating letdown while performing OP-2RF-001 6.16;
: (3) CR-2023-05314, control room received AR-016-001 'D' EDG trip (A03), 'D' EDG tripped on start;
: (3) CR-2023-05314, control room received AR-016-001 'D' EDG trip (A03), 'D' EDG tripped on start;
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==INSPECTION RESULTS==
==INSPECTION RESULTS==
Testing, Inspection, and Maintenance Were Not Performed on the Hardened Containment Ventilation System Power Supply Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.15 Systems NCV 05000387,05000388/2024002- 01 Management Open/Closed A self- revealed Green finding and associated NCV of NRC Order EA- 13- 109 was identified when the licensee did not perform battery performance testing, inspection, or maintenance of the HCVS battery. Specifically, there were no activities to monitor battery health after installation, which would have identified degradation prior to the battery being identified as failed during containment isolation testing.
Testing, Inspection, and Maintenance Were Not Performed on the Hardened Containment Ventilation System Power Supply Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.15 Systems NCV 05000387,05000388/2024002- 01 Management Open/Closed A self-revealed Green finding and associated NCV of NRC Order EA-13-109 was identified when the licensee did not perform battery performance testing, inspection, or maintenance of the HCVS battery. Specifically, there were no activities to monitor battery health after installation, which would have identified degradation prior to the battery being identified as failed during containment isolation testing.


=====Description:=====
=====Description:=====
The licensee was required by NRC Order EA -13- 109 to have a reliable, severe accident capable HCVS. The HCVS was implemented using an existing drywell penetration and contains two primary containment isolation valves. These valves are air operated valves that require nitrogen to open and use a spring to close. Nitrogen is directed to the valve for opening using an AC powered solenoid valve, which directs nitrogen from bottles to the HCVS valves. In addition to the solenoid valve operation, power is needed for the control room switches, instrumentation for vent status, and instrumentation for effluent discharge.
The licensee was required by NRC Order EA -13-109 to have a reliable, severe accident capable HCVS. The HCVS was implemented using an existing drywell penetration and contains two primary containment isolation valves. These valves are air operated valves that require nitrogen to open and use a spring to close. Nitrogen is directed to the valve for opening using an AC powered solenoid valve, which directs nitrogen from bottles to the HCVS valves. In addition to the solenoid valve operation, power is needed for the control room switches, instrumentation for vent status, and instrumentation for effluent discharge.


The control room switches allow remote system operation from the control room. Vent status is determined with valve positions indication, pressure instrum ents, and temperature instruments. Radiation sensors are used to monitor effluent discharge. The system is required to provide adequate power and motive gas to support 24 hours of operation without normal AC power. A 125 DC voltage battery is designed to provide the power during the first 24 hours in the event of an extended loss of power, with a portable EDG used to power the system after the first 24 hours.
The control room switches allow remote system operation from the control room. Vent status is determined with valve positions indication, pressure instrum ents, and temperature instruments. Radiation sensors are used to monitor effluent discharge. The system is required to provide adequate power and motive gas to support 24 hours of operation without normal AC power. A 125 DC voltage battery is designed to provide the power during the first 24 hours in the event of an extended loss of power, with a portable EDG used to power the system after the first 24 hours.


On June 6, 2013, the NRC issued order EA - 13- 109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, following the Fukushima Dai - ichi nuclear plant earthquake and tsunami.
On June 6, 2013, the NRC issued order EA - 13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, following the Fukushima Dai - ichi nuclear plant earthquake and tsunami.


EA- 13- 109, Section 1.2.13, state s the HCVS shall include features and provisions for operation, testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained. Sections 1.2.8 and 1.2.9 describe two of the system functions.
EA-13-109, Section 1.2.13, state s the HCVS shall include features and provisions for operation, testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained. Sections 1.2.8 and 1.2.9 describe two of the system functions.


Section 1.2.8 states the HCVS shall include means to monitor the status of the vent system (e.g., valve position indication) from the control panel. Section 1.2.8 further states the monitoring system shall be designed for sustained operation during an extended loss of AC power. Section 1.2.9 states the HCVS shall include a means to monitor effluent discharge for radioactivity that may be released from operation of the HCVS. The monitoring system shall provide indication from the control panel. The section further states the system shall be designed for sustained operation during an extended loss of AC power. Sections 1.2.8 and 1.2.9 functions cannot be maintained without functioning batteries. Section 1.2.13, states, in part, the HCVS shall include features and provisions for testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained.
Section 1.2.8 states the HCVS shall include means to monitor the status of the vent system (e.g., valve position indication) from the control panel. Section 1.2.8 further states the monitoring system shall be designed for sustained operation during an extended loss of AC power. Section 1.2.9 states the HCVS shall include a means to monitor effluent discharge for radioactivity that may be released from operation of the HCVS. The monitoring system shall provide indication from the control panel. The section further states the system shall be designed for sustained operation during an extended loss of AC power. Sections 1.2.8 and 1.2.9 functions cannot be maintained without functioning batteries. Section 1.2.13, states, in part, the HCVS shall include features and provisions for testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained.
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Following battery installation, the licensee created an action on May 1, 2015, AR-2015-12620, to evaluate and implement a maintenance strategy for the 125 DC voltage batteries. The action was extended multiple times without inspection, testing, or maintenance activities being implemented.
Following battery installation, the licensee created an action on May 1, 2015, AR-2015-12620, to evaluate and implement a maintenance strategy for the 125 DC voltage batteries. The action was extended multiple times without inspection, testing, or maintenance activities being implemented.


On April 4, 2024, the station performed local leak rate testing of the primary containment isolation valves in the HCVS. The procedure required a breaker to be closed which provides battery power to the solenoid valves and valve position indication. The breaker tripped when closed, and the system did not receive power. CR- 2024- 05592 was generated to investigate the issue. On April 29, 2024, during troubleshooting the licensee determined that the HCVS batteries for both units were degraded. In both batteries, multiple cell-to-cell connections were found corroded and disconnected. The batteries were determined to be non- functional. Based on the inspectors' questions, the batteries were added to the equipment important to emergency response (EITER) non- functional list. Once the batteries were added to the EITER list, the battery replacements were prioritized and completed within 90 days of identification of the non-functionality.
On April 4, 2024, the station performed local leak rate testing of the primary containment isolation valves in the HCVS. The procedure required a breaker to be closed which provides battery power to the solenoid valves and valve position indication. The breaker tripped when closed, and the system did not receive power. CR-2024- 05592 was generated to investigate the issue. On April 29, 2024, during troubleshooting the licensee determined that the HCVS batteries for both units were degraded. In both batteries, multiple cell-to-cell connections were found corroded and disconnected. The batteries were determined to be non-functional. Based on the inspectors' questions, the batteries were added to the equipment important to emergency response (EITER) non-functional list. Once the batteries were added to the EITER list, the battery replacements were prioritized and completed within 90 days of identification of the non-functionality.


Corrective Actions: Units 1 and 2 HCVS batteries were replaced on June 25 and 26, 2024, respectively. The station created a corrective action to determine and implement the required testing, inspection, and maintenance of the HCVS battery.
Corrective Actions: Units 1 and 2 HCVS batteries were replaced on June 25 and 26, 2024, respectively. The station created a corrective action to determine and implement the required testing, inspection, and maintenance of the HCVS battery.
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=====Performance Assessment:=====
=====Performance Assessment:=====
Performance Deficiency: A self-revealed Green finding and associated NCV was identified because the licensee did not perform battery testing, inspection, or maintenance as required by EA- 13- 109.
Performance Deficiency: A self-revealed Green finding and associated NCV was identified because the licensee did not perform battery testing, inspection, or maintenance as required by EA-13-109.


Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, since the licensee had not conducted battery testing, inspection, or maintenance of the HCVS battery from installation in 2015 and 2016, there was reasonable doubt that the equipment maintained the capability to meet the requirements of the associated FLEX strategies (i.e., that no portable equipment should be required to operate the HCVS within the first 24 hours).
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, since the licensee had not conducted battery testing, inspection, or maintenance of the HCVS battery from installation in 2015 and 2016, there was reasonable doubt that the equipment maintained the capability to meet the requirements of the associated FLEX strategies (i.e., that no portable equipment should be required to operate the HCVS within the first 24 hours).
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=====Enforcement:=====
=====Enforcement:=====
Violation: NRC Order EA-13- 109 was issued to Susquehanna Steam Electric Station, Units 1 and 2, effective June 6, 2013. NRC Order EA -13-109, Attachment 2, Section 1.2.13, states, in part, the HCVS shall include features and provisions for testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained.
Violation: NRC Order EA-13-109 was issued to Susquehanna Steam Electric Station, Units 1 and 2, effective June 6, 2013. NRC Order EA -13-109, Attachment 2, Section 1.2.13, states, in part, the HCVS shall include features and provisions for testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained.


Contrary to this, since installation, the licensee did not provide provisions for testing, inspection, and maintenance adequate to ensure that the reliable function and capability of the HCVS batteries were maintained. As a result, the HCVS batteries were found degraded and non- functional on April 4, 2024, for Unit 1 and April 21, 2024, for Unit 2.
Contrary to this, since installation, the licensee did not provide provisions for testing, inspection, and maintenance adequate to ensure that the reliable function and capability of the HCVS batteries were maintained. As a result, the HCVS batteries were found degraded and non-functional on April 4, 2024, for Unit 1 and April 21, 2024, for Unit 2.


Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
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Licensee-Identified Non-Cited Violation 71111.24 This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71111.24 This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.


Violation: Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, states measures shall be established to assure conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non- conformances are promptly identified and corrected.
Violation: Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, states measures shall be established to assure conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.


Contrary to the above, from August 2023 through January 2024, the licensee failed to take appropriate corrective actions associated with the E EDG temperature control valve, which was previously identified as having internal leakage resulting in abnormally low jacket water temperatures when emergency service water was in service. As a result, the E EDG was declared inoperable on January 22, 2024, when the jacket water temperature dropped below the technical specification limit. Engineering later determined that the EDG remained operable with the condition because the impact would have increased EDG start time from 7.6 to 9.3 seconds, which is below the required value of 10 seconds.
Contrary to the above, from August 2023 through January 2024, the licensee failed to take appropriate corrective actions associated with the E EDG temperature control valve, which was previously identified as having internal leakage resulting in abnormally low jacket water temperatures when emergency service water was in service. As a result, the E EDG was declared inoperable on January 22, 2024, when the jacket water temperature dropped below the technical specification limit. Engineering later determined that the EDG remained operable with the condition because the impact would have increased EDG start time from 7.6 to 9.3 seconds, which is below the required value of 10 seconds.
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Significance/Severity: Green.
Significance/Severity: Green.


The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At- Power, and determined it screened as very low safety significance (Green) because it did not represent a loss of the probabilistic risk assessment function for greater than its technical specification allowed outage time.
The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined it screened as very low safety significance (Green) because it did not represent a loss of the probabilistic risk assessment function for greater than its technical specification allowed outage time.


Corrective Action References : CR- 2024 - 01353
Corrective Action References : CR-2024 - 01353


Observation : Review of Feedwater Penetration Leakage Corrective Actions 71152A The inspectors reviewed the licensee s corrective action program CRs, action requests, and the associated corrective actions including corrective maintenance WO s to repair feedwater system containment isolation valves that experienced test leakage exceeding administrative leakage limits during the Unit 2 spring 2023 refueling outage. The inspectors also reviewed procedure changes made to ensure proper valve reassembly and preventive maintenance scheduling. The inspectors did not identify any violations or performance deficiencies during the review.
Observation : Review of Feedwater Penetration Leakage Corrective Actions 71152A The inspectors reviewed the licensee s corrective action program CRs, action requests, and the associated corrective actions including corrective maintenance WO s to repair feedwater system containment isolation valves that experienced test leakage exceeding administrative leakage limits during the Unit 2 spring 2023 refueling outage. The inspectors also reviewed procedure changes made to ensure proper valve reassembly and preventive maintenance scheduling. The inspectors did not identify any violations or performance deficiencies during the review.
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Plant Corrective Action AR-2024-05542
Plant Corrective Action AR-2024-05542
Status Documents AR-2024- 06210
Status Documents AR-2024- 06210
Resulting from CR- 2024- 06619
Resulting from CR-2024- 06619
Inspection CR- 2024- 07578
Inspection CR-2024- 07578
CR- 2024- 07645
CR-2024- 07645
CR- 2024- 07779
CR-2024- 07779
CR- 2024- 07782
CR-2024- 07782
CR- 2024- 07783
CR-2024- 07783
CR- 2024- 07784
CR-2024- 07784
CR- 2024- 07785
CR-2024- 07785
CR- 2024- 08164
CR-2024- 08164
CR- 2024- 08648
CR-2024- 08648
CR- 2024- 08925
CR-2024- 08925
CR- 2024- 08927
CR-2024- 08927
CR-2024-08928
CR-2024-08928
71111.01 Procedures NDAP-00-1913 Seasonal Readiness Revision 18
71111.01 Procedures NDAP-00-1913 Seasonal Readiness Revision 18
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Documents CR-2024-07138
Documents CR-2024-07138
Corrective Action CR-2024-08791
Corrective Action CR-2024-08791
Documents CR- 2024- 08807
Documents CR-2024- 08807
Resulting from
Resulting from
Inspection
Inspection
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SO-249-A02 Quarterly RHR System Flow Verification Division 1 Revision 30
SO-249-A02 Quarterly RHR System Flow Verification Division 1 Revision 30
71111.12 Corrective Action CR-2022-09837
71111.12 Corrective Action CR-2022-09837
Documents CR- 2022- 11036
Documents CR-2022-11036
CR- 2022- 13732
CR-2022-13732
CR- 2022- 17631
CR-2022-17631
CR- 2022- 17707
CR-2022-17707
CR- 2023- 04998
CR-2023- 04998
CR- 2023- 05211
CR-2023- 05211
CR- 2023- 05298
CR-2023- 05298
CR- 2023- 05433
CR-2023- 05433
CR-2023-07804
CR-2023-07804


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Procedure Date
Procedure Date
CR-2023-09775
CR-2023-09775
CR- 2023- 11656
CR-2023-11656
CR- 2023- 11930
CR-2023-11930
CR- 2023- 12897
CR-2023-12897
CR- 2023- 13577
CR-2023-13577
CR- 2024- 03496
CR-2024- 03496
CR- 2024- 03710
CR-2024- 03710
CR- 2024- 03717
CR-2024- 03717
CR- 2024- 05753
CR-2024- 05753
CR- 2024- 06251
CR-2024- 06251
CR- 2024- 06719
CR-2024- 06719
CR- 2024- 06791
CR-2024- 06791
CR- 2024- 06963
CR-2024- 06963
CR-2024-08019
CR-2024-08019
Corrective Action CR-2024-08383
Corrective Action CR-2024-08383
Line 413: Line 413:
71111.13 Procedures NDAP-QA-0340 Protected Equipment Program Revision 46
71111.13 Procedures NDAP-QA-0340 Protected Equipment Program Revision 46
71111.15 Corrective Action AR-2015-12620
71111.15 Corrective Action AR-2015-12620
Documents CR- 2024- 05592
Documents CR-2024- 05592
CR- 2024- 06852
CR-2024- 06852
CR- 2024- 06998
CR-2024- 06998
CR- 2024- 07001
CR-2024- 07001
CR- 2024- 07335
CR-2024- 07335
CR- 2024- 07371
CR-2024- 07371
CR- 2024- 08057
CR-2024- 08057
CR-2024-09234
CR-2024-09234


Corrective Action AR-2024-08943
Corrective Action AR-2024-08943
Documents CR- 2024- 08721
Documents CR-2024- 08721
Resulting from CR- 2024- 09353
Resulting from CR-2024- 09353
Inspection CR- 2024- 10013
Inspection CR-2024-10013
CR-2024-10014
CR-2024-10014
Drawings E-157 Alternate Rod Injection Schematic Diagram, Sheet 7 Revision 2
Drawings E-157 Alternate Rod Injection Schematic Diagram, Sheet 7 Revision 2
Line 452: Line 452:
EP-PS-102 TSC Technical Support Coordinator Revision 44
EP-PS-102 TSC Technical Support Coordinator Revision 44
71111.20 Corrective Action CR-2024-06683
71111.20 Corrective Action CR-2024-06683
Documents CR- 2024- 06686
Documents CR-2024- 06686
Resulting from CR- 2024- 06691
Resulting from CR-2024- 06691
Inspection CR- 2024- 06773
Inspection CR-2024- 06773
CR-2024-06850
CR-2024-06850
Procedures GO-100-02 Plant Startup, Heatup, and Power Operation Revision 126
Procedures GO-100-02 Plant Startup, Heatup, and Power Operation Revision 126


71111.24 Corrective Action EWR-2024-02815
71111.24 Corrective Action EWR-2024-02815
Documents CR- 2023- 04344
Documents CR-2023- 04344
CR- 2024- 01353
CR-2024- 01353
CR- 2024- 05401
CR-2024- 05401
CR- 2024- 09208
CR-2024- 09208
CR-2024-10499
CR-2024-10499
Corrective Action CR-2024-06686
Corrective Action CR-2024-06686
Documents CR- 2024- 08749
Documents CR-2024- 08749
Resulting from CR- 2024- 09388
Resulting from CR-2024- 09388
Inspection
Inspection
Drawings M-151 Susquehanna SES Unit 1 P&ID Residual Heat Removal. Revision 72
Drawings M-151 Susquehanna SES Unit 1 P&ID Residual Heat Removal. Revision 72
Line 478: Line 478:
MT-GE-040 Agastat Inspection, Calibration, Removal, and Installation Revision 13
MT-GE-040 Agastat Inspection, Calibration, Removal, and Installation Revision 13
OT-054-076 ESW Flow Balance Revision 9
OT-054-076 ESW Flow Balance Revision 9
SI-183-321 Quarterly Calibration of Drywell Pressure Channel PS-E11- Revision 25
SI-183-321 Quarterly Calibration of Drywell Pressure Channel PS-E11-Revision 25
1N010A, B, C, D (ADS Permissive, RCIC Exhaust Vacuum
1N010A, B, C, D (ADS Permissive, RCIC Exhaust Vacuum
Breaker Isolation)
Breaker Isolation)
Line 514: Line 514:
AR-2023- 06921
AR-2023- 06921
AR-2023- 07688
AR-2023- 07688
CR- 2023- 05314
CR-2023- 05314
CR- 2023- 06833
CR-2023- 06833
CR- 2023- 05557
CR-2023- 05557
CR- 2023- 06444
CR-2023- 06444
CR- 2023- 12632
CR-2023-12632
CR-2024-02302
CR-2024-02302
Corrective Action CR-2024-07779
Corrective Action CR-2024-07779
Documents CR- 2024- 07782
Documents CR-2024- 07782
Resulting from CR- 2024- 07783
Resulting from CR-2024- 07783
Inspection CR- 2024- 07784
Inspection CR-2024- 07784
CR- 2024- 07785
CR-2024- 07785
CR-2024-07788
CR-2024-07788


Latest revision as of 07:38, 4 October 2024

Integrated Inspection Report 05000387/2024002 and 05000388/2024002
ML24225A143
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 08/12/2024
From: Jon Greives
NRC/RGN-I/DORS
To: Berryman B
Susquehanna
References
IR 2024002
Download: ML24225A143 (1)
v • d • e


Text

August 12, 2024

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000387/2024002 AND 05000388/2024002

Dear Brad Berryman:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station, Units 1 and 2. On August 1, 2024, the NRC inspectors discussed the results of this inspection with Edward Casulli, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a an NCV consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555- 0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2.

If you disagree with a cross -cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 -0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety

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: 05000387/2024002 and 05000388/2024002

Enterprise Identifier: I-2024-002- 0044

Licensee: Susquehanna Nuclear, LLC

Facility: Susquehanna Steam Electric Station, Units 1 and 2

Location: 769 Salem Blvd., Berwick, PA

Inspection Dates: April 1, 2024 to June 30, 2024

Inspectors: J. England, Senior Resident Inspector E. Brady, Resident Inspector H. Anagnostopoulos, Senior Health Physicist S. Haney, Senior Enforcement Specialist J. Kulp, Senior Reactor Inspector C. Lally, Senior Operations Engineer

Approved By: Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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. A licensee-identified non-cited violation (NCV) is documented in report section: 71111.2

List of Findings and Violations

Testing, Inspection, and Maintenance Were Not Performed on the Hardened Containment Ventilation System Power Supply Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.15 Systems NCV 05000387,05000388/2024002- 01 Management Open/Closed A self-revealed Green finding and associated NCV of NRC Order EA-13-109 was identified when the licensee did not perform battery performance testing, inspection, or maintenance of the hardened containment vent system (HCVS) battery. Specifically, there were no activities to monitor battery health after installation, which would have identified degradation prior to the battery being identified as failed during containment isolation testing.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period shut down for the U123RIO refueling outage. On April 23, 2024, the unit was started up and achieved rated thermal power on April 29, 2024. On May 9, 2024, the unit was down powered to 59 percent due to 'B' reactor building closed-cooling water chiller shutdown and returned to rated thermal power May 11, 2024. On May 18, 2024, the unit was down powered to 75 percent for control rod exercising and returned to rated thermal power May 19, 2024. On June 29, 2024, the unit was down powered to 68 percent for a rod sequence exchange and returned to rated thermal power June 30, 2024.

Unit 2 began the inspection period at rated thermal power.

On June 14, 2024, the unit down powered to 68 percent for rod sequence exchange and returned tora ted thermal power June 15, 2024. The unit was at or near rated thermal power for the rest of the inspection period.

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 performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, P roblem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures on June 7, 2024.

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit Common 'D' emergency diesel generator (EDG) support systems during the week of April 22, 2024
(2) Unit 1 high-pressure coolant injection during the week of May 6, 2024
(3) Unit Common 'C' EDG on May 30, 2024
(4) Unit 1 residual heat removal service water train 'A' on June 20, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 1 drywell, fire zone (FZ) 1-4F, on April 7, 2024
(2) Unit 1 main steam pipeway, FZ I-4G, on April 9, 2024
(3) Unit Common emergency service water pumphouse, FZs 0-51 and 0-52, on April 22, 2024
(4) Unit 2 reactor building, FZs 2-2A, 2-2B, 2-1C, and 2-1D, on May 1, 2024
(5) Unit 1 turbine building common generator area, reactor coolant recirculation pump motor generator area and heating and ventilation equipment room, FZs 0-35A, 1-35C, and 1-36A, on May 23, 2024
(6) Unit Common lower cable spreading room and lower relay room, FZs 0-25A and 0-25E, on June 17, 2024

71111.08G - Inservice Inspection Activities (Boiling-Water Reactor)

Boiling-Water Reactor Inservice Inspection Activities - Nondestructive Examination and Welding

Activities (IP Section 03.01)

Main article: IP 71111.08G

The inspectors evaluated boiling-water reactor nondestructive testing by reviewing the following examinations from April 1 to 4, 2024:

(1) Nondestructive Examinations
  • Ultrasonic Thickness Measurements of Reactor Water Bottom Head Drain -

90 Degree Elbow (FAC-U1-24- 050)

  • Ultrasonic Thickness Measurements of Reactor Water Bottom Head Drain -

Straight Pipe (FAC-U1-24-051)

  • Ultrasonic Thickness Measurements of Reactor Water Bottom Head Drain -

Expander Inlet (FAC-U1-24- 052)

  • Ultrasonic Thickness Measurements of FAC-U1-24-053, Reactor Water Bottom Head Drain - Expander Outlet (FAC-U1-24- 053)
  • Enhanced Visual Examination (EVT-1) Top Guide Beam Location 02-19 (1-B13.40.0409)
  • Manual Ultrasonic Examination of High-Pressure Core Injection Steam Line Pipe to Elbow Weld DBA-1021-2-G (UT-24-008)

Pressure Boundary Weld

  • Cutout and replace feedwater valves 141023B, 141022B (work order (WO) 2686329-2)

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Unit 2 control room during the residual heat removal 'A' loop flow surveillance on May 8, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed a Unit 1 simulator scenario evaluation that included an earthquake and suppression pool flooding on May 9, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Unit Common 250 volts direct current system, batteries, and battery chargers due to multiple recent issues on May 15, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (1 Sample)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit Common failure of fiber optic board on 'E' EDG during the week of June 10, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee s justifications and actions associated with the following operability determinations and functionality assessments:

(1) Units 1 and 2 hardened containment ventilation functionality assessment due to degraded batteries on April 4, 2024
(2) Unit 1 expected voltage not received during performance of anticipated transient without scram recirculation pump trip functional test due to degraded relay 62X-14725D1 on April 19, 2024
(3) Unit Common 'A' EDG trip due to Gen Loss Field Trip on April 29, 2024
(4) Unit 1 main steam isolation valve due to continuity light out with low voltage on May 14, 2024
(5) Unit Common 'B' EDG due to Hi Priority alarm received on June 9, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1 Implementation for GL-89 MOVs a Four Rotor Design Modification -

Engineering Change Package 2107077 (permanent modification)

(2) Unit Common Licensing Document Change Notice, LDCN-5814, Elimination of Secondary Containment Bypass Leakage Testing Requirements for Feedwater Penetration (permanent modification)

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated Unit 1 refueling outage U123RIO activities from March 25 to April 29, 2024.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (IP Section 03.01) (9 Samples)

(1) Unit Common 'E' EDG jacket water heater temperature control valve repairs on August 23, 2023
(2) Unit Common 'C' EDG run following replacement of bus 1C sync selector switch on April 3, 2024
(3) Unit 1 SO-149-201 following regulator and elastomer replacement of an HV151F122A

'A' residual heat removal testable check valve on April 3, 2024

(4) Unit 1 SM-104-002, 4kV 1A202 24-Month Undervoltage Channel Calibration, following relay replacement on April 5, 2024
(5) Unit 1 SO-100-023A, ASME Class 1 Boundary System Leakage Test - 10-Year Test, following control rod drive mechanism replacement on April 16, 2024
(6) Unit 1 SO-152-002, Quarterly HPCI Flow Verification After Repair of the HV155F001, HPCI Steam Admission Valve on April 24, 2024
(7) Unit Common SO-024-014, Monthly Diesel Generator 'E' Operability Test, following emergency service water valve work on week of June 10, 2024
(8) Unit Common MT-024-033E, Diesel Generator 'E' Relay Testing, following Agastat relay preventive maintenance and 'G' fiber optic board replacement on June 12, 2024
(9) Unit Common SO-216-A03, Quarterly Residual Heat Removal Service Water (RHRSW) System Flow Verification Division 1, following spray pond nozzle cleaning and residual heat removal service water pump 2A discharge check valve disassembly and inspection on June 25, 2024

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Unit 1 inspection of blowout panels on April 1, 2024
(2) Unit 1 SO-149-101, Residual Heat Removal Logic System Functional Test Division I Outage Partial on April 11 and 12, 2024
(3) Unit 1 SI-183-321, Quarterly Calibration of Drywell Pressure Channel PS-E11-1N010A, B, C, D (Automatic Depressurization System Permissive, Reactor Core Isolation Cooling Exhaust Vacuum Breaker Isolation) on May 2, 2024

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) DC-B5B-100, Depressurization of Reactor Pressure Vessel Using Automatic Depressurization System Safety Relief Valves with a Portable Power Supply Connected in the Upper and Lower Relay Room on May 29,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Workers exiting the radiologically controlled area at the Unit 1 access control point during a refueling outage
(2) Controls for high dose rate water filters (used for desludging) stored under water in the suppression pool

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee s control of radiological hazards for the following radiological work:

(1) Suppression pool diving activities with desludging and coating inspections (RWP 20241115)
(2) Transfers of high radiation material during the refueling outage (RWP 20241403)
(3) Fuel movements and in-vessel inservice inspection activities (RWP 20241002)
(4) Control rod drive mechanism removal and replacement under vessel (RWP20241351)

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) Unit 1 drywell and associated access control points at the personnel hatch and the equipment hatch
(2) Locked high radiation area associated with desludging water filter storage in the suppression pool
(3) Control rod drive removal hatch, removal track, and path to the control rod drive mechanism rebuild room

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.08 - Radioactive Solid Waste Processing and

Radioactive Material Handling, Storage, and Transportation

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed the preparation of radioactive shipment 24-023 on April 2,

OTHER ACTIVITIES - BASELINE

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Review of corrective actions associated with the following condition reports (CRs):
(1) CR-2023-12632, entered ON-PWR-201 on July 31, 2023;
(2) CR-2023- 06833, reactor vessel/cavity level lowering prior to initiating letdown while performing OP-2RF-001 6.16;
(3) CR-2023-05314, control room received AR-016-001 'D' EDG trip (A03), 'D' EDG tripped on start;
(4) CR-2024-02302, residual heal removal service water heat exchanger 'B' outlet HV-21215B found open during panel walkdowns
(2) Unit 2 review of corrective actions associated with CR-2023-05057, for feedwater penetration local leak rate test failure and secondary containment bypass leakage violation, the week of May 13, 2024

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

Main article: IP 71152
(1) The inspectors reviewed the licensees corrective action program for trends in the first and second quarters of 2024 that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Testing, Inspection, and Maintenance Were Not Performed on the Hardened Containment Ventilation System Power Supply Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.15 Systems NCV 05000387,05000388/2024002- 01 Management Open/Closed A self-revealed Green finding and associated NCV of NRC Order EA-13-109 was identified when the licensee did not perform battery performance testing, inspection, or maintenance of the HCVS battery. Specifically, there were no activities to monitor battery health after installation, which would have identified degradation prior to the battery being identified as failed during containment isolation testing.

Description:

The licensee was required by NRC Order EA -13-109 to have a reliable, severe accident capable HCVS. The HCVS was implemented using an existing drywell penetration and contains two primary containment isolation valves. These valves are air operated valves that require nitrogen to open and use a spring to close. Nitrogen is directed to the valve for opening using an AC powered solenoid valve, which directs nitrogen from bottles to the HCVS valves. In addition to the solenoid valve operation, power is needed for the control room switches, instrumentation for vent status, and instrumentation for effluent discharge.

The control room switches allow remote system operation from the control room. Vent status is determined with valve positions indication, pressure instrum ents, and temperature instruments. Radiation sensors are used to monitor effluent discharge. The system is required to provide adequate power and motive gas to support 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation without normal AC power. A 125 DC voltage battery is designed to provide the power during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the event of an extended loss of power, with a portable EDG used to power the system after the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

On June 6, 2013, the NRC issued order EA - 13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, following the Fukushima Dai - ichi nuclear plant earthquake and tsunami.

EA-13-109, Section 1.2.13, state s the HCVS shall include features and provisions for operation, testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained. Sections 1.2.8 and 1.2.9 describe two of the system functions.

Section 1.2.8 states the HCVS shall include means to monitor the status of the vent system (e.g., valve position indication) from the control panel. Section 1.2.8 further states the monitoring system shall be designed for sustained operation during an extended loss of AC power. Section 1.2.9 states the HCVS shall include a means to monitor effluent discharge for radioactivity that may be released from operation of the HCVS. The monitoring system shall provide indication from the control panel. The section further states the system shall be designed for sustained operation during an extended loss of AC power. Sections 1.2.8 and 1.2.9 functions cannot be maintained without functioning batteries. Section 1.2.13, states, in part, the HCVS shall include features and provisions for testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained.

Following battery installation, the licensee created an action on May 1, 2015, AR-2015-12620, to evaluate and implement a maintenance strategy for the 125 DC voltage batteries. The action was extended multiple times without inspection, testing, or maintenance activities being implemented.

On April 4, 2024, the station performed local leak rate testing of the primary containment isolation valves in the HCVS. The procedure required a breaker to be closed which provides battery power to the solenoid valves and valve position indication. The breaker tripped when closed, and the system did not receive power. CR-2024- 05592 was generated to investigate the issue. On April 29, 2024, during troubleshooting the licensee determined that the HCVS batteries for both units were degraded. In both batteries, multiple cell-to-cell connections were found corroded and disconnected. The batteries were determined to be non-functional. Based on the inspectors' questions, the batteries were added to the equipment important to emergency response (EITER) non-functional list. Once the batteries were added to the EITER list, the battery replacements were prioritized and completed within 90 days of identification of the non-functionality.

Corrective Actions: Units 1 and 2 HCVS batteries were replaced on June 25 and 26, 2024, respectively. The station created a corrective action to determine and implement the required testing, inspection, and maintenance of the HCVS battery.

Corrective Action References: CR-2024-09634, CR-2024-09636

Performance Assessment:

Performance Deficiency: A self-revealed Green finding and associated NCV was identified because the licensee did not perform battery testing, inspection, or maintenance as required by EA-13-109.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, since the licensee had not conducted battery testing, inspection, or maintenance of the HCVS battery from installation in 2015 and 2016, there was reasonable doubt that the equipment maintained the capability to meet the requirements of the associated FLEX strategies (i.e., that no portable equipment should be required to operate the HCVS within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The finding screened as very low safety significance (Green) because it was associated with equipment, training, procedures, and/or other programmatic aspects credited for the sole purpose of satisfying the requirements of Order EA-13-109.

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

The station created an action to determine and implement the testing, inspection, or maintenance of the HCVS battery, but the required changes were not implemented in a timely manner.

Enforcement:

Violation: NRC Order EA-13-109 was issued to Susquehanna Steam Electric Station, Units 1 and 2, effective June 6, 2013. NRC Order EA -13-109, Attachment 2, Section 1.2.13, states, in part, the HCVS shall include features and provisions for testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained.

Contrary to this, since installation, the licensee did not provide provisions for testing, inspection, and maintenance adequate to ensure that the reliable function and capability of the HCVS batteries were maintained. As a result, the HCVS batteries were found degraded and non-functional on April 4, 2024, for Unit 1 and April 21, 2024, for Unit 2.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71111.24 This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, states measures shall be established to assure conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.

Contrary to the above, from August 2023 through January 2024, the licensee failed to take appropriate corrective actions associated with the E EDG temperature control valve, which was previously identified as having internal leakage resulting in abnormally low jacket water temperatures when emergency service water was in service. As a result, the E EDG was declared inoperable on January 22, 2024, when the jacket water temperature dropped below the technical specification limit. Engineering later determined that the EDG remained operable with the condition because the impact would have increased EDG start time from 7.6 to 9.3 seconds, which is below the required value of 10 seconds.

Significance/Severity: Green.

The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined it screened as very low safety significance (Green) because it did not represent a loss of the probabilistic risk assessment function for greater than its technical specification allowed outage time.

Corrective Action References : CR-2024 - 01353

Observation : Review of Feedwater Penetration Leakage Corrective Actions 71152A The inspectors reviewed the licensee s corrective action program CRs, action requests, and the associated corrective actions including corrective maintenance WO s to repair feedwater system containment isolation valves that experienced test leakage exceeding administrative leakage limits during the Unit 2 spring 2023 refueling outage. The inspectors also reviewed procedure changes made to ensure proper valve reassembly and preventive maintenance scheduling. The inspectors did not identify any violations or performance deficiencies during the review.

Observation: Semiannual Trend 71152S The inspectors conducted a semiannual trend review by evaluating a sample of issues that occurred in the first and second quarters of 2024. During the evaluation, the inspectors verified the issues identified were addressed within the scope of the corrective action program. The inspectors reviewed related databases for trends and considered prior issues while performing routine walkdowns and attending the plan of the day meetings. The licensee has identified an adverse trend of deficiencies of the EDGs. The licensee has generated an action to review the last 5 years of EDG issues and use this information to adjust the maintenance strategy, as needed. The inspectors will continue to monitor the corrective action program and maintenance effectiveness during routine inspection activities.

EXIT MEETINGS AND DEBRIEFS

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

  • On April 4, 2024, the inspectors presented the radiological hazards inspection results to Paul Ervin, Manager Nuclear Oversight, and other members of the licensee staff.
  • On April 4, 2024, the inspectors presented the inservice inspection results to Paul Ervin, Manager Nuclear Oversight, and other members of the licensee staff.
  • On May 9, 2024, the inspectors presented the operations department event review problem identification and resolution inspection results to Katie Brown, NRA Supervisor, and other members of the licensee staff.
  • On August 1, 2024, the inspectors presented the integrated inspection results to Edward Casulli, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

Plant Corrective Action AR-2024-05542

Status Documents AR-2024- 06210

Resulting from CR-2024- 06619

Inspection CR-2024- 07578

CR-2024- 07645

CR-2024- 07779

CR-2024- 07782

CR-2024- 07783

CR-2024- 07784

CR-2024- 07785

CR-2024- 08164

CR-2024- 08648

CR-2024- 08925

CR-2024- 08927

CR-2024-08928

71111.01 Procedures NDAP-00-1913 Seasonal Readiness Revision 18

71111.04 Corrective Action CR-2024-07135

Documents CR-2024-07138

Corrective Action CR-2024-08791

Documents CR-2024- 08807

Resulting from

Inspection

Drawings M-112 Unit 1 P&ID RHR Service Water System Revision 56

M-134 P&ID Diesel Auxiliaries Jacket Water and Lube Oil Systems, Revision 8

Sheet 4

M-156 Unit 1 P&ID High-Pressure Coolant Injection Turbine - Pump Revision 40

Procedures CL-024-0016 Diesel Generator 'C' Revision 13

CL-024-0018 Diesel Generator 'D' Revision 14

CL-116-0012 Unit 1 RHRSW System A Revision 11

CL-152-0012 Valves, Unit 1 HPCI System Revision 29

71111.05 Corrective Action CR-2024-09642

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action AR-2024-08712

Documents

Resulting from

Inspection

Fire Plans FP-1-CS-698-A Control Structure-EL. 698 Revision 1

FP-1-CS-714-A Control Structure-EL. 714 Revision 1

FP-1-ESSW-685-A Prefire Plan Unit 1 Pump House-ESSW Elev. 685'6" Revision 0

FP-1-RB-719-2 Main Steam Pipeway Revision 0

FP-1-RB-719-3 Emergency Personnel Decontamination Station Revision 0

FP-1-RB-749-7 Circulation Space 2 Revision 0

FP-1-TB-729-0 U1 Turbine Building El. 729 Revision 0

FP-1-TB-762-1 U1 Heating and Ventilation Equip. Room Revision 0

FP-113-100 Drywell (I 400, I 516, I 607) Fire Zone 1 4F Elevation 704' Revision 4

thru 807'

FP-2-RB-670-0 Susquehanna S.E.S. Prefire Plan U2 Reactor Building Revision 0

El. 670

FP-2-RB-670-2 Susquehanna S.E.S. Prefire Plan U2 Remote Shutdown Revision 0

Panel

FP-2-RB-670-4 Susquehanna S.E.S. Prefire Plan U2 Open Area Revision 0

FP-2-RB-670-5 Susquehanna S.E.S. Prefire Plan U2 RCIC Valve Room Revision 0

FP-2-RB-670-6 Susquehanna S.E.S. Prefire Plan U2 HPCI Valve Room Revision 0

FP-2-RB-670-7 Susquehanna S.E.S. Prefire Plan U2 Open Area Revision 0

71111.11Q Procedures GO-100-02 Plant Startup, Heatup, and Power Operation Revision 126

SO-249-A02 Quarterly RHR System Flow Verification Division 1 Revision 30

71111.12 Corrective Action CR-2022-09837

Documents CR-2022-11036

CR-2022-13732

CR-2022-17631

CR-2022-17707

CR-2023- 04998

CR-2023- 05211

CR-2023- 05298

CR-2023- 05433

CR-2023-07804

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-2023-09775

CR-2023-11656

CR-2023-11930

CR-2023-12897

CR-2023-13577

CR-2024- 03496

CR-2024- 03710

CR-2024- 03717

CR-2024- 05753

CR-2024- 06251

CR-2024- 06719

CR-2024- 06791

CR-2024- 06963

CR-2024-08019

Corrective Action CR-2024-08383

Documents

Resulting from

Inspection

Work Orders RTSV 2250016

RTSV 2420466

RTSV 2496598

RTSV 2542436

71111.13 Procedures NDAP-QA-0340 Protected Equipment Program Revision 46

71111.15 Corrective Action AR-2015-12620

Documents CR-2024- 05592

CR-2024- 06852

CR-2024- 06998

CR-2024- 07001

CR-2024- 07335

CR-2024- 07371

CR-2024- 08057

CR-2024-09234

Corrective Action AR-2024-08943

Documents CR-2024- 08721

Resulting from CR-2024- 09353

Inspection CR-2024-10013

CR-2024-10014

Drawings E-157 Alternate Rod Injection Schematic Diagram, Sheet 7 Revision 2

M1-B21-131 Nuclear Steam Supply Shutoff Sys Susquehanna 1, Revision 15

Sheet 3112

M30-124 Susquehanna S.E.S. Common DG Control Schematic Revision 24

Starting Sequence, Sheet 1

M30-124 Susquehanna S.E.S. Common DG Control Schematic Revision 6

Starting Sequence Control Panel 0C521A, Sheet 4

M30-124 Susquehanna S.E.S. Common DG Control Schematic Revision 16

Shutdown and Alarm System 0C521A, Sheet 11

M30-124 Susquehanna S.E.S. Common DG Control Schematic Revision 12

Starting Sequence Control Panel 0C521B, Sheet 1A

M30-124 Susquehanna S.E.S. Common DG Control Schematic Revision 1

Starting Sequence Control Panel 0C521B, Sheet 4A

Engineering EC-0021081 Hardened Containment Vent System Battery Sizing Revision 0

Changes

EC-2253781 AVCO Coil and Stem for MSIV Solenoids Revision 0

EC-333356 MSIV Pilot Solenoid Valve Current Monitoring Revision 1

Miscellaneous ES-173-007 Venting Suppression Chamber Through the HCVS

71111.18 Calculations EC-059-1024 Design Requirement for and Evaluation of Potential Revision 17

Secondary Containment Bypass Leakage (SCBL) Pathways

Engineering EC-2107077 Implementation for GL 89-10 MOV'S a Four Rotor Design Revision 0

Changes Change

Procedures EP-PS-001 Emergency Planning Forms and Supplementary Instructions Revision 24

EP-PS-102 TSC Technical Support Coordinator Revision 44

71111.20 Corrective Action CR-2024-06683

Documents CR-2024- 06686

Resulting from CR-2024- 06691

Inspection CR-2024- 06773

CR-2024-06850

Procedures GO-100-02 Plant Startup, Heatup, and Power Operation Revision 126

71111.24 Corrective Action EWR-2024-02815

Documents CR-2023- 04344

CR-2024- 01353

CR-2024- 05401

CR-2024- 09208

CR-2024-10499

Corrective Action CR-2024-06686

Documents CR-2024- 08749

Resulting from CR-2024- 09388

Inspection

Drawings M-151 Susquehanna SES Unit 1 P&ID Residual Heat Removal. Revision 72

Sheet 1

Miscellaneous PCWO 2629500-0 Investigate TCV03412E JW Temp Control Vlv (Priority 4)

Procedures DC-B5B-100 Depressurization of Reactor Pressure Vessel using Revision 14

Automatic Depressurization System Safety Relief Valves

with a Portable Power Supply Connected in the Upper and

Lower Relay Room

MT-024-033E Diesel Generator E Relay Testing Revision 2

MT-GE-040 Agastat Inspection, Calibration, Removal, and Installation Revision 13

OT-054-076 ESW Flow Balance Revision 9

SI-183-321 Quarterly Calibration of Drywell Pressure Channel PS-E11-Revision 25

1N010A, B, C, D (ADS Permissive, RCIC Exhaust Vacuum

Breaker Isolation)

SM-104-002 4kV 1A202 24-Month Undervoltage Channel Calibration Revision 18

SO-024-014 Monthly Diesel Generator 'E' Operability Test Revision 54

SO-100-023A ASME Class 1 Boundary System Leakage Test - 10-Year Revision 2

Test (Infrequently Performed Test or Evolution)

SO-104-102 4.16KV Class 1E Bus 1C (1A203) Offsite Supply Check Revision 4

SO-149-101 RHR Logic System Functional Test Division I Outage Partial Revision 11

SO-149-201 1035 PSIG LLRT of LPCI Loop 'A' Injection Pressure Revision 4

Isolation Valves

SO-152-002 Quarterly HPCI Flow Verification After Repair of the Revision 75

HV155F001, HPCI Steam Admission Valve

SO-216-A03 Quarterly Residual Heat Removal Service Water (RHRSW) Revision 23

System Flow Verification Division 1

Work Orders PCWO 2047642

PCWO 2629500-0

PCWO 2735356-0

RTPM 2506956

RTPM 2575640-0

RTPM 2590952

RTPM 2665769

RTSV 2542431

RTSV 2643242

RTSV 2714671

RTSV 2718984

71152A Calculations EC-RADN-1189 CRHE Dose Analysis Input for LER 50-388/2023-001-00 Revision 0

U2-21RIO SCBL Results

Corrective Action AR-2021-03120

Documents AR-2023- 05354

AR-2023- 05752

AR-2023- 06362

AR-2023- 06772

AR-2023- 06921

AR-2023- 07688

CR-2023- 05314

CR-2023- 06833

CR-2023- 05557

CR-2023- 06444

CR-2023-12632

CR-2024-02302

Corrective Action CR-2024-07779

Documents CR-2024- 07782

Resulting from CR-2024- 07783

Inspection CR-2024- 07784

CR-2024- 07785

CR-2024-07788

Procedures AOP-024-001 Diesel Generator Abnormal Operating Procedure Revision 5

MT-AD-504 Scaffold Erection, Review, and Inspection Revision 38

NDAP-QA-0027 Concurrent and Independent Verification Requirements Revision 18

NDAP-QA-0340 Protected Equipment Program Revision 41

NDAP-QA-1902 Integrated Risk Management Revision 43

ON-PWR-201 Reactor Power Revision 8

OP-1RF-001 RX Vessel/Cavity Flood-up and Let Down During Refueling Revision 40

Outages

OP-2RF-001 RX Vessel/Cavity Flood-up and Let Down During Refueling Revision 36

Outages

OP-AD-300 Administration of Operations Revisions

49-51

PSP-26 On Line and Shutdown Nuclear Risk Assessment Program Revision 29

PSP-40 Performance of the Independent Pre-Outage Shutdown Revision 3

Safety Risk Management Plan Assessment

Work Orders PCWO 2631477-0

PCWO 2631477-1

PCWO 2658495-0

RACT 2629364

RLWO 2647852

19

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